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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.

SparkHours Team

SparkHours Team
Published · Updated · 8 min read
Reviewed by Evalin Sosa, AMFT

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

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.

When your hours actually start

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.

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.

Two Live Scans, and only one of them counts here

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 this means on your track

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.

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.

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.

There are two 90-day provisions, and they aren't related

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.

About the author

SparkHours Team
SparkHours contributor

SparkHours Team

The SparkHours team writes practical guidance for California pre-licensed therapists tracking hours toward licensure.

Sources

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.

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