Fourteen Weeks on an Expired License
Andre is a Pennsylvania dental hygienist whose license expired on March 31. His office manager told him there was a grace period, so he continued working 14 weeks at two practices and treated about 220 patients. He completed 30 hours of continuing education during the prior biennium, but only 1 hour was in child abuse recognition and reporting; he believed the requirement was 1 hour. He also lacks certificates for 4 of the 30 hours. The Board sends a letter requesting an explanation and renewal materials. Andre has already paid a late fee but not any civil penalty. He asks whether he can keep working while the renewal is pending, whether the 30 hours will be accepted, and what will happen to the 14 weeks of treatment he provided.
1. Was Andre’s practice after March 31 lawful? Explain the effect of the grace-period advice and the Board’s authority over an expired license.
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No lawful practice after expiration. Pennsylvania does not give a grace period for an expired license. Practicing while expired is unlicensed practice and can be charged as unprofessional conduct. The office manager’s advice is not a defense. Andre must stop seeing patients immediately and must not resume until the Board renews or reactivates his license. The Board has authority to investigate the lapse, require an explanation, impose a civil penalty and costs, issue a reprimand, or suspend or revoke the license. The fact that he paid a late fee does not authorize practice in the meantime.
2. What must Andre do about the CE deficit and missing documentation before his renewal can be granted?
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The standard biennial requirement is 30 hours, including the required child abuse recognition and reporting hours, which are 2 hours. One hour is insufficient, and four hours lack documentation. The Board generally will not accept undocumented hours. Andre should complete the missing child abuse hour and obtain certificates or other acceptable documentation for the four missing hours, or complete replacement CE, before submitting a complete renewal. He should keep proof of all hours and submit a clear explanation of the deficiency. Renewal should not be granted until the CE requirement is satisfied.
3. What disciplinary outcomes are reasonably possible, and what should Andre tell his employers?
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Possible outcomes include refusal of renewal until compliance, a civil penalty and costs, a reprimand, or suspension or revocation. The Board will consider the length of the lapse, the number of patients treated, whether he self-reported, whether he cooperated, and whether he has prior discipline. He should notify both employers in writing that he cannot practice, ask them not to schedule him, and keep copies. The treatment he already provided is not erased, but the records must remain accurate and he remains responsible for the care he gave. He should not perform any further clinical services until the Board acts.