The Expired-Registration Hygienist
Dr. Alvarez runs a two-chair general practice in Lubbock. On a busy Tuesday she learns that her hygienist, Priya, completed her required continuing education in December but never submitted her registration renewal, which lapsed 40 days ago. The office manager says Priya has been seeing recall patients all week and "everyone does this." Dr. Alvarez also discovers her own dental license is current, but her office's radiography equipment registration with the state radiation program expired last month and the staff took bitewings yesterday. Priya asks whether she can keep working while she sorts out paperwork, and the office manager proposes backdating the renewal forms so the gap looks continuous. Two patients are scheduled for prophies this afternoon.
1. Can Priya continue performing hygiene services today, and what should Dr. Alvarez do about the schedule?
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No. Practicing dental hygiene without a current registration is unlicensed practice, regardless of completed CE. Dr. Alvarez should pull Priya from patient care immediately and reschedule or reassign the two prophies (another registered hygienist or the dentist for limited services within her own scope). The dentist's supervisory duty includes ensuring auxiliaries are currently registered before they treat patients; "everyone does this" is not a defense. Priya may complete administrative duties that do not require a license. Dr. Alvarez should document the lapse, have Priya submit the renewal with any late fees, and confirm active status before returning her to clinical duties.
2. Evaluate the office manager's proposal to backdate the renewal paperwork.
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Backdating is falsification of a government record and exposes both Priya and Dr. Alvarez to disciplinary action, including possible license suspension or revocation and civil penalties. The correct path is an honest late renewal disclosing the actual lapse dates. If the board asks about the gap, truthful disclosure with corrective action is far better than a fabricated record. Dr. Alvarez should also consider whether any services billed during the lapse must be addressed, since billing for services rendered by an unregistered provider raises separate compliance issues.
3. What is the significance of the expired radiography equipment registration, and what should happen next?
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Taking radiographs with equipment whose state registration has lapsed is a separate regulatory violation from the hygienist's lapse. Dr. Alvarez should stop using that equipment for patient imaging until registration is reinstated, arrange for any required equipment inspection, and notify the radiation program. She should document that no patient harm occurred and review the images taken yesterday for diagnostic adequacy; if they are adequate and the only defect is the registration lapse, retakes may not be clinically necessary, but the compliance failure still must be corrected and disclosed. The cumulative pattern (hygienist lapse plus equipment lapse) suggests the office needs a compliance calendar with renewal deadlines.