The BBS 90-Day Rule for AMFTs, APCCs, and ASWs: A Complete California Guide

What Is the BBS 90-Day Rule?

The BBS 90-day rule is a rule in the Business and Professions Code (BPC 4980.43(b), 4996.23(b), 4999.46(b)) that lets recent graduates count post-degree supervised experience hours earned between their degree award date and the date their associate registration number is issued. Without it, hours gained during that gap before your AMFT, APCC, or ASW registration is issued would not be credited.

The rule is codified in California Business and Professions Code (BPC) sections 4980.43 (for MFTs), 4996.23 (for LCSWs), and 4999.46 (for LPCCs). In practical terms, it works like this: if the BBS receives your associate registration application within 90 days of your degree award date and the Board then grants the registration, qualifying post-degree hours you gained before your registration issue date are credited toward licensure. If you completed graduate study on or after January 1, 2020, those hours must also have been gained at a workplace that required completed Live Scan fingerprinting before you started (BPC 4980.43(b)(1)(B)).

This is not automatic. If the BBS does not receive your application within 90 days, or a 2020+ graduate's workplace did not require Live Scan first, hours gained before your registration is issued are not credited. Before your registration is issued you also may not be employed by or volunteer in a private practice or professional corporation.

Who Does the 90-Day Rule Apply To?

The 90-day rule applies to all three associate registration types issued by the California BBS. It is not limited to AMFTs. If you are pursuing any of the three license types below and have recently completed your qualifying degree, the 90-day rule is relevant to you.

It is important to note that while APCCs and ASWs cannot count pre-degree practicum hours toward licensure (unlike AMFTs, who can count limited pre-degree hours under specific conditions), all three registration types benefit equally from the 90-day rule when it comes to protecting post-degree hours earned during the application processing gap. For a detailed breakdown of all hour requirements, see our guide on complete LMFT hour requirements. If you are still deciding between paths, our guide on comparing the LMFT and LCSW paths in California covers how hours, supervision and exams differ between the LMFT and LCSW paths.

How the 90-Day Window Is Calculated

The clock begins on your degree award date, the term the BBS uses (the statute says "the granting of the qualifying master's degree or doctoral degree"). Ask your registrar which date that is for your degree before you count the 90 days.

We recommend treating day 60 as your personal deadline. That leaves a 30-day buffer for any corrections or missing documents before day 90.

HourJourney sorts every week by your degree date

Enter your degree date once. Each week you log is labeled pre-degree or post-degree, so your post-degree weeks are clear from the start.

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The Live Scan Fingerprinting Requirement

For people who completed graduate study on or after January 1, 2020, the 90-day rule has an added condition: the workplace must have required completed Live Scan fingerprinting before you gained hours there (BPC 4980.43(b)(1)(B)). That is separate from the fingerprints you submit with your registration application.

Two different fingerprint items can apply:

What Happens If You Miss the 90-Day Window?

The Board must receive the application within 90 days of the degree award date. If it does not, hours you gained between your degree award date and the date your registration is issued are not credited.

However, it is important to understand what is not lost. Once your registration number is issued, all hours you gain from that date forward count normally toward licensure. The damage from missing the 90-day window is limited to the gap period. The sooner your registration is issued, the sooner your hours count again.

Private Practice Under the 90-Day Rule

You may not be employed by or volunteer in a private practice or professional corporation until your associate registration is issued (BPC 4980.43(b)(2)). The 90-day rule does not change this, even if the BBS received your application on day one after graduation.

During the gap you may work in an exempt setting (a governmental entity, a school, a college, a university, or a nonprofit charitable 501(c)(3) institution; MFT FAQ Q15) or in another nonexempt setting that is not a private practice or professional corporation (BPC 4980.06(b)(2)). If your supervisor invites you to see clients at their private practice after graduation, wait until your registration is issued.

Once your registration number is issued, you can begin working in private practice. Plan accordingly. If you want to transition to a private practice setting, have the arrangement ready so you can begin immediately upon receiving your number rather than losing additional time.

Step-by-Step: How to Protect Your 90-Day Hours

These steps cover the conditions in the statute plus practical advice for the gap period.

How HourJourney Helps During the Gap Period

HourJourney logs your hours by week and supervisor and shows your progress toward the totals. For more on setting up your tracking, see our guide on how to track your LMFT supervised hours.

HourJourney fills in your weekly log from the first week you log

Log your hours each week from your degree award date. HourJourney fills in the Weekly Log of Experience Hours for each supervisor and setting, with every page totaled, ready for your supervisor's signature. Whether pre-registration hours count still depends on the 90-day rule conditions above.

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FAQ: 90-Day Rule

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