We live in a world of deadlines. When I was growing up, I learned the maxim, “Failure to properly plan on your part does not constitute an emergency on my part.”
Sound familiar?
The excuse “the dog ate my homework” did not work in my childhood home.
If you practice medicine (or any licensed profession in healthcare), you need a license. You also need a license to prescribe controlled substances. There are deadlines for renewing such licenses. And for renewing your hospital credentials, clinical privileges, in-network status with healthcare insurance carriers, and more.
Each of these applications ask a gazillion questions. If you answer “yes” to any of the important ones, the reviewing body will want to know more. For example, “Over the past year, has the medical board opened an investigation?” “Has any hospital restricted your clinical privileges?” “Have you ever been suspended?”
If you just answer “Yes” and leave it at that, expect your renewal application to get gummed up. Even if you submitted your application in time, it may not be processed in time.
The medical board may not timely renew your license. The DEA may also fail to renew your license. Without a license, can you still practice?
If you do not have an “in force” medical license, you cannot practice medicine.
If you believe you’ll have to answer yes to any of the concerning questions, have a narrative ready to go. Renewal applications have a place to explain your “yes” answer. While it likely won’t sidestep the institution’s need to know more, it’ll probably speed up the process.
Most healthcare institutions have access to the National Practitioner Data Bank (NPDB). They may already be aware of your “yes” answer. And renewal applications generally ask even more detailed questions than that which might be noted in the NPDB. For example, a hospital might restrict your privileges for 2 wks. To be a line item in the NPDB, that restriction would have to last over 30 days. Still, a medical board might ask if your privileges were ever restricted. Ever.
You have to answer honestly and accurately.
Honestly means subjectively (based on what you actually know).
Accurately means objectively (based on what you should know).
One physician in the Midwest turned in his medical license renewal application just before his license expired. It included a narrative explaining his “yes answer.” The clock struck midnight, and his license was not automatically extended. The Board’s website listed his license as “expired.” Technically, he was foreclosed from practicing medicine until fixed.
The medical board was reviewing his renewal application. Fortunately, he was able to contact a helpful person at the board. They updated his profile’s status on the website to read “Valid to practice while reviewed.” This bought him time and did not shut down his practice.
In any event, had his narrative been submitted weeks earlier, his blood pressure might never have spiked. And the application likely would have timely processed and renewed once the existing term expired.
What about the DEA?
Most physicians don’t need a DEA license to practice medicine. But for many physicians, it’s not a luxury. Imagine being a surgeon without access to prescribe any controlled substances. Depending upon your specialty, I suppose it’s possible. But for most, it would be a hardship, if not a showstopper.
Interestingly, if the DEA has not processed your application and you submitted your renewal over 45 days before expiration, the calendar is extended for you.
It’s called the 45 days rule.
In the event that an applicant for reregistration (who is doing business under a registration previously granted and not revoked or suspended) has applied for reregistration at least 45 days before the date on which the existing registration is due to expire, and the Administrator has issued no order on the application on the date on which the existing registration is due to expire, the existing registration of the applicant shall automatically be extended and continue in effect until the date on which the Administrator so issues his/her order. The Administrator may extend any other existing registration under the circumstances contemplated in this section even though the registrant failed to apply for reregistration at least 45 days before expiration of the existing registration, with or without request by the registrant, if the Administrator finds that such extension is not inconsistent with the public health and safety.
As summarized on legal blog, federal-lawyer.com:
In other words, as long as a physician files for renewal at least 45 days prior to the expiration date of the physician’s current registration, the physician’s registration will remain active. The DEA grants an “automatic extension” that allows for continued prescribing during the pendency of the physician’s renewal application (provided that the DEA has not expressly revoked the physician’s privilege to prescribe).
However, if a physician files for renewal fewer than 45 days before the physician’s current registration expires, then the physician does not receive an automatic extension. Instead, whether the physician may continue prescribing is subject to the DEA’s discretion.
The take home message is this. Get started on renewal applications sooner rather than later. While there are some potential workarounds, it’s best to expect that a “yes answer” will stall your renewal applications. You don’t want to defend by arguing the dog ate your homework.
What do you think?
Is it a generational issue that physicians do not file for renewals in time?
Something of this importance should take precedence over anything else.
A friend of mine who was dying had one request of me. To return his cable modem from his office.
We thought it interesting that even though he was dying he was thinking of such a small obligation.
But that was the type of gentleman he was.
Now taking that in context, what possible excuse (short of a major illness/surgery) could physicians have for not renewing their license on time?
Good questions. These things (state license renewal every 2, DEA renewal every 3) were at or near the forefront of my brain when I was in practice; same with my similarly-aged colleagues. This article should be mandatory reading for every resident.
(That was a reply to Retired).