Continuing Education Audits and Citations
How an Audit Works
Most Pennsylvania licensees must complete continuing education for each renewal period, and the boards audit a sample of renewals to confirm it. A shortfall found in an audit is often handled through a citation, but it should not be ignored.
An audit usually follows three stages.
Selection
After renewal, a licensee may be selected for audit and asked to produce certificates or other proof of the courses reported.
Response
The licensee must produce the requested documentation by the stated date. Missing or incomplete proof may be treated as a deficiency. Failing to respond to an audit request on time is itself a violation, with its own civil penalty.
Outcome
A deficiency may lead to a citation with a civil penalty, an order to make up the hours or, in more serious cases, formal action.
Citations
For certain violations, such as practice on a lapsed license or specified continuing education deficiencies, the Department may issue a citation with a civil penalty set by schedule. A licensee must, within 10 days of the date the citation is issued, either admit the violation and pay or deny it and request a hearing. Payment is treated as an admission, and a failure to respond within 10 days will result in a default judgment for the full amount and may lead to additional disciplinary action.
Keeping a Clean Record
A single disciplinary record for a continuing education violation, or for practicing six months or less on a lapsed license, may be expunged on application after five years.
Because payment is treated as an admission and the citation becomes a disciplinary record, the choice between paying and requesting a hearing deserves careful thought.
Questions Licensees Ask
Can I make up missing hours?
Boards commonly require the missing hours to be made up, often within six months, in addition to any civil penalty, and under some boards’ regulations hours used to cure a deficiency may not also count toward the current renewal period.
Should I simply pay the citation?
Payment is treated as an admission, and a failure to respond within 10 days will result in a default judgment for the full amount and may lead to additional disciplinary action. Paying may be sensible for a small, clear deficiency, but the decision should be made knowing that it creates a disciplinary record, although a single continuing education record may later be expunged on application after five years.
What if I answered the renewal question about continuing education incorrectly?
A false answer on a renewal application can be a separate ground for discipline, apart from the shortfall itself.
What happens if I practiced on a lapsed license?
Practice on a lapsed or expired license is unlicensed practice. Short lapses are commonly addressed through the citation program with a civil penalty; longer lapses may lead to formal action. The licensee should stop practicing, renew or reactivate the license and address the period of unlicensed practice directly.
Meet Your Attorney
Steven A. Mimm, Esq.
Founder, Mimm Law, LLC. Admitted in Pennsylvania (2008) and New Jersey (2022).
From 2014 to 2022, Attorney Steven A. Mimm served as a prosecuting attorney bringing disciplinary actions on behalf of the Bureau of Professional and Occupational Affairs before Pennsylvania's licensing boards. That experience informs how the firm evaluates evidence, negotiates with the Commonwealth and prepares cases for hearing. Where a licensee also faces criminal charges, the firm handles the licensing matter and coordinates with the licensee's criminal defense counsel.
Related: Licensing and FAQs · All Licensing Boards
Last reviewed September 2026. The information on this page is general in nature and is not legal advice. Contacting the firm does not create an attorney-client relationship.