California Board of Behavioral Sciences
The BBS 90-Day Rule, explained.
There's a gap between the day your degree posts and the day your associate registration arrives. The 90-Day Rule decides whether the hours you work in that gap count.
Start here
What the 90-Day Rule does
The 90-Day Rule lets you count supervised experience gained between your degree date and the date your associate registration is issued. Without it, your hours start on the day your registration number is issued.
The rule reads the same on all three tracks. It has four conditions, and you have to meet all four, not most of them.
The four conditions
| # | Condition | What it actually means |
|---|---|---|
| 1 | The Board receives your associate registration application within 90 days of your degree date | Received, not postmarked. The Board reads your degree date off the date posted on your transcript, so that's the date your 90 days runs from. |
| 2 | Your workplace required completed Live Scan fingerprinting before you gained the hours | This applies if you completed your graduate study on or after January 1, 2020. It's your employer's Live Scan, not the Board's. |
| 3 | You are not employed or volunteering in a private practice or professional corporation | That bar runs until your registration is issued. After that you may work in these settings, but only for the first six years of your registration. |
| 4 | You keep a copy of that Live Scan form and submit it when you apply for licensure | The one document the rule asks you to produce. It goes with your licensure application, not your associate one. |
The credit stays provisional until the Board grants your registration. If it isn't granted, these hours don't count under this rule.
The usual requirements still apply
Hours in this window aren't credited on easier terms. The Board's FAQs say hours gained under the 90-day rule must comply with all experience and supervision requirements in order to count toward licensure.
- At least one hour of direct supervisor contact in each week experience is credited, in each work setting.
- A supervisor who meets the Board's supervisor qualifications.
- A weekly log of your hours, signed by your supervisor each week.
When your hours actually start
Your degree date, or the day after your employer's Live Scan, whichever is later.
It is not "at graduation." That shorthand is common and it is wrong in the expensive direction. The Board's flyer is flat about it: post-degree hours may only be counted after the date recorded on the "Request for Live Scan Service" form completed for your employer. After, not on.
| Your situation | Degree posted | Employer Live Scan | Registration issued | Hours start |
|---|---|---|---|---|
| Fingerprinted before you graduated | May 20 | May 12 | Sept 15 | May 20 |
| Fingerprinted after you graduated | May 20 | June 3 | Sept 15 | June 4 |
| Employer never required a Live Scan | May 20 | none | Sept 15 | Sept 15 The rule gives you nothing here. No hours in the gap count. |
One Live Scan per employer
If you work at two places, you need a Live Scan at each one, and each one has its own start date. The Board asks you to be fingerprinted separately for each employer, and to keep a copy of the form from each. Fingerprints don't transfer between employers or agencies.
SparkHours applies the right rules on each side of the line
SparkHours knows your degree date and your registration date, and applies the right rules on each side of the line. Hours you log after your degree and before your number arrives are treated as post-degree hours, not practicum hours.
Two Live Scans, and only one of them counts here
You will do two different Live Scans, and they are not interchangeable.
The Live Scan you complete for the Board as part of your associate registration application does not satisfy the 90-Day Rule. The Board says it cannot be accepted for that purpose.
| What is being compared | Your employer's Live Scan This one counts here | The Board's Live Scan Not for this rule |
|---|---|---|
| Who requires it | Your employer | The Board |
| What it is for | Meeting the 90-Day Rule | Your associate registration application |
| When | Before you earn post-degree hours at that employer | With your associate application |
| One per employer? | Yes | No |
| Where the form goes | You keep it, then send a copy with your Application for Licensure | Handled inside the registration application |
What the Board will accept as proof
One document: a copy of your completed, employer-required "Request for Live Scan Service" form. The Board says the law doesn't allow it to accept DOJ results or a letter from your employer instead.
So keep the form. You'll send a copy with your licensure application, which could be two or three years later. Don't send it with your associate application.
There is no separate 90-Day Rule application, checkbox or attestation. You qualify by meeting the conditions.
Staying on at your practicum site
The Live Scan requirement doesn't apply to your pre-degree trainee hours. It does apply the moment those hours become post-degree hours.
So if you graduate and keep working at the same agency, the Board's position is that the agency must have fingerprinted you before you earn post-degree hours there. Being a known face at the site for a year doesn't carry over.
What this means on your track
The rule is identical on all three tracks. What's riding on it is not.
| What is being compared | AMFT (LMFT track) | APCC (LPCC track) | ASW (LCSW track) |
|---|---|---|---|
| Hours before your degree that count toward the 3,000 | Up to 1,300 | None | None |
| What the 90-Day Rule covers | The gap between your degree date and your AMFT number | The same gap | The same gap |
| If you don't meet it | Your pre-degree hours still stand. The gap doesn't count. | Your 3,000 starts at your APCC number | Your 3,000 starts at your ASW number |
AMFTs
You may already have hours banked. As an MFT Trainee you can earn up to 1,300 hours toward the 3,000 before your degree is awarded, and at most 750 of those can be counseling and direct supervisor contact combined. Those hours are pre-degree, and the 90-Day Rule doesn't touch them. It governs one stretch: the post-degree weeks before your AMFT number arrives. See the full AMFT hour requirements.
APCCs and ASWs
No hours earned before your degree count toward your 3,000. Not practicum, not field placement, not a single one.
That makes the 90-Day Rule the start line for your entire count. Every hour you will ever claim is post-degree, so a missed window doesn't cost you a slice of the total. It moves where the total begins. See the full APCC hour requirements and ASW hour requirements.
Careful with a common phrase
"Pre-degree" and "pre-registration" are not the same thing. APCC and ASW hours earned before your degree never count. Hours earned before your registration can, under this rule. For the pre-degree side of the line, see how practicum and pre-degree hours work.
If you don't meet the rule
Where your employer never required fingerprinting, the Board's answer is short. You cannot count any hours gained between the date your degree was awarded and the issuance date of your associate registration, and the law does not provide for any exceptions.
If your supervisor has already signed off on those hours, the Board publishes a procedure. It asks you to submit your weekly logs covering the period from the start of your supervision through the date your registration was issued. Your evaluator uses those logs to identify and deduct hours gained before the issuance date. Logs covering time after your registration was issued aren't required unless your evaluator asks for them.
Our guide to the weekly log the Board would ask for goes through every column.
SparkHours builds that log as you go
SparkHours builds the weekly log for you as you go, and your supervisor signs each week from a link. If the Board ever asks for that period, it's already there.
Commonly confused
There are two 90-day provisions, and they aren't related
If you're on the LMFT track, you'll run into a second 90-day provision in the same handbook. It is about practicum enrollment, it applies before your degree, and it has nothing to do with the rule above.
| What is being compared | The 90-Day Rule | The practicum enrollment gap |
|---|---|---|
| Who | AMFT, APCC and ASW applicants | MFT Trainees, LMFT track only |
| Phase | Post-degree | Pre-degree |
| What the 90 days measures | How long you have to get your application to the Board after your degree date | How long a lapse in practicum enrollment can run while you keep counseling |
| Where it lives | Its own Board flyer, plus a section named for it in all three handbooks | One paragraph in the LMFT handbook's trainee section |
| At stake | Whether the hours between your degree and your registration count | Whether you can keep seeing clients through the gap |
| Called "the 90-Day Rule"? | Yes, by the Board | No |
How the practicum enrollment gap works
All counseling you provide as an MFT Trainee has to be part of your supervised course of study while you're enrolled in practicum. The handbook makes one exception, and it needs both of these to be true:
- The lapse in your enrollment is less than 90 calendar days.
- That lapse comes straight after a period of practicum enrollment, and is straight followed by practicum enrollment again, or by completing your degree program.
So a summer between two practicum terms can qualify, and so does a gap that ends with your degree being conferred. A gap with nothing enrolled on the far side does not. The Board states the consequence directly: if a Trainee's practicum break is 90 days or greater, the Trainee cannot count any hours gained during that time period toward licensure.
You don't have to keep the same supervisor or the same site through the gap. Hours you gain during the gap are ordinary Trainee hours, so they count against your 1,300, not on top of it.
This provision says nothing about whether hours count once you graduate. So when someone says "the 90-day rule" on the LMFT track, ask which one they mean. Only the post-degree one carries the name.
Ask which one applies to you
SparkHours includes a built-in AI assistant trained on the official BBS handbooks. Ask it which 90-day provision applies to you, or anything else about supervision requirements and hour categories.
Learn more about the AI Assistant →Where this comes from
The Board's flyer is "Don't Lose Your Hours: Know the 90-Day Rule," revised September 2025. The rule also appears in each handbook: the LMFT handbook at page 13, the LPCC handbook at page 9, and the LCSW handbook at page 9.
Don't Lose Your Hours: Know the 90-Day Rule
The Board's flyer on the rule, revised September 2025.
Opens bbs.ca.gov in a new tabLMFT handbook
The 90-Day Rule section sits at page 13.
Opens bbs.ca.gov in a new tabLPCC handbook
The 90-Day Rule section sits at page 9.
Opens bbs.ca.gov in a new tabLCSW handbook
The 90-Day Rule section sits at page 9.
Opens bbs.ca.gov in a new tabCommon questions
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