# 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.

## 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.

## 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.

| | Your employer's Live Scan | The Board's Live Scan |
|---|---|---|
| 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.

| | 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](/amft).

### 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](/apcc) and [ASW hour requirements](/asw).

### 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](/practicum).

## 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.

See [the weekly log the Board would ask for](/guides/bbs-weekly-log-of-experience-hours).

## 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.

| | 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.

## 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](https://www.bbs.ca.gov/pdf/90day_rule.pdf), the Board's flyer, revised September 2025.
- [LMFT handbook](https://www.bbs.ca.gov/pdf/publications/lmft_handbook.pdf), page 13.
- [LPCC handbook](https://www.bbs.ca.gov/pdf/publications/lpcc_handbook.pdf), page 9.
- [LCSW handbook](https://www.bbs.ca.gov/pdf/publications/lcsw_handbook.pdf), page 9.

## Common Questions

### What is the BBS 90-Day Rule?

It's a California Board of Behavioral Sciences rule that lets you count supervised experience gained between your degree date and the date your associate registration is issued. The rule has four conditions. The Board has to receive your associate application within 90 days of your degree date. The agency where you're gaining hours has to have required completed Live Scan fingerprinting before you gained them. That agency can't be a private practice or professional corporation. And you have to keep a copy of that Live Scan form and submit it when you apply for licensure.

### Does the 90-Day Rule mean my hours start at graduation?

Not on its own. Your hours start on your degree date, or the day after the Live Scan your employer required, whichever is later. The Board says post-degree hours may only be counted after the date recorded on the form, so the form's own date isn't countable.

### Is my employer's Live Scan the same as the Live Scan I do for the BBS?

No, and one can't stand in for the other. The Live Scan you complete as part of your associate registration application cannot be accepted as meeting the 90-Day Rule. The rule needs a separate Live Scan required by your employer, completed before you earn hours there.

### What if my employer didn't require Live Scan fingerprinting?

Then you cannot count the hours in that gap. The Board's words: 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.

### Does "apply within 90 days" mean postmarked within 90 days?

No. The Board has to receive your associate registration application within 90 days of your degree date. The Board reads that date off the date posted on your transcript, so if your ceremony landed on a different day, the transcript date is the one your 90 days runs from.

### What if I have more than one employer?

You need a Live Scan at each one. The Board asks you to be fingerprinted separately for each employer to count hours at each employer, and to keep a copy of the completed form from each. Fingerprints don't transfer between employers or agencies.

### Can I count private practice hours under the 90-Day Rule?

No. One of the four conditions is that you aren't employed or volunteering in a private practice or professional corporation before your registration is issued. After it's issued you may work in those settings, but only for the first six years of your registration.

### Does the 90-Day Rule work the same way for AMFTs, APCCs and ASWs?

The rule is the same on all three tracks. What differs is what's riding on it. AMFTs can count up to 1,300 pre-degree hours toward the 3,000, so the rule covers one stretch of a longer path. APCCs and ASWs count no pre-degree hours at all, so for those two tracks the rule governs where the whole 3,000 starts.

### Is this the same as the 90-day practicum rule in the LMFT handbook?

No. Those are two separate provisions. The 90-Day Rule is about post-degree hours counting before your associate registration is issued. The other one is a pre-degree MFT Trainee provision: you can keep counseling through a lapse in practicum enrollment of less than 90 calendar days, as long as practicum enrollment comes right before the lapse, and practicum enrollment or your completed degree comes right after it. Only the first one is called the 90-Day Rule.

## How SparkHours Helps

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. It builds the weekly log for you as you go, and your supervisor signs each week from a link, so if the Board ever asks for that period, it's already there.

SparkHours also 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. Read more about the [AI assistant](/assistant).

Start with a 14-day free trial. No credit card required.

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