Continuing Education Attestation and the Board's Discipline Authority
Dr. Karen Grant has been a licensed psychologist in Pennsylvania for 12 years. At her biennial renewal, the online form required her to attest that she completed 30 hours of continuing education, including 2 hours of ethics. Dr. Grant had completed only 18 hours. She checked yes because she had already registered for two weekend workshops that would bring her to 30 hours before the end of the renewal period, although the workshops had not yet occurred. The Board audits her and requests certificates. Dr. Grant also realizes that she has been seeing clients for six weeks after her license expired because the renewal was not processed. She asks whether she should simply complete the courses now and say nothing, or report the discrepancy.
1. Was Dr. Grant's attestation of completed continuing education truthful? Analyze under the Board's regulations and professional-conduct standards.
Read the worked answer
No. The renewal attestation is a representation of fact as of the date she signs it. Registering for future workshops is not completing them. At the moment she checked yes, she had not met the required 30 hours, including the ethics hours. The fact that she intended to complete the courses later does not make the statement true when made. A false attestation to a licensing board is a serious professional-conduct issue, not a clerical slip.
Under Act 52 and 49 Pa. Code Chapter 41, the Board may discipline a licensee for unprofessional conduct, including making a false statement in a licensing matter. The Board may also treat the underlying failure to complete continuing education as a separate violation. Even if she later finishes all 30 hours, the original attestation remains inaccurate. Her best argument is prompt correction and remediation, not that the courses were scheduled. The Board will consider whether she was trying to mislead or simply made a careless assumption, but the objective falsity is the starting point.
2. What disciplinary authority does the Board have, and what sanctions are realistically possible?
Read the worked answer
The Board has authority to investigate, reprimand, fine, suspend, revoke, or place conditions on a license, and to require additional continuing education or remediation. It can also deny renewal until requirements are met. The Board is not limited to the continuing-education deficiency; it can consider the false attestation and any practice after expiration. Practicing on an expired license may also be treated as unlicensed practice or unprofessional conduct, depending on the facts.
Realistically, a first offense with no patient harm, prompt cooperation, and completion of the missing hours may result in a reprimand, civil penalty, and required documentation rather than revocation. But the Board could take a harsher view if it concludes she practiced for six weeks without a license and then tried to conceal the problem. Aggravating factors include prior discipline, dishonesty, and continued practice after notice. Mitigating factors include self-reporting, remorse, remediation, and a long clean record. The Board will weigh the risk to the public against the likelihood of rehabilitation.
3. What should Dr. Grant do now?
Read the worked answer
She should stop seeing clients until she confirms that her license is active and renewal has been processed. She should report the discrepancy to the Board honestly, provide the certificates she actually has, and complete the missing continuing education as soon as possible. She should not backdate certificates, create false documentation, or tell the Board that the future workshops were already completed. She should consult an attorney experienced in licensing matters before submitting a written explanation.
She should also document the timeline: when her license expired, when she stopped practicing, what she told clients, and how she handled ongoing care. If clients were transferred or paused, the record should show a clinically appropriate plan. Her response to the audit should be prompt, accurate, and complete. Concealment or a second false statement would turn a correctable compliance problem into a much more serious discipline case. The Board generally responds better to candor and remediation than to a cover-up.