News Briefs

What Does the Kentucky Optometric Licensing Proposed Amendment Actually Say?

The future of the NBEO exam in Kentucky

June 19, 2025

Photo credit: Getty Images

Recent chatter (and April testimony before Kentucky’s Administrative Regulation Review Subcommittee) related to proposed legislation to allow substitution of  the National Board of Examiners in Optometry (NBEO) Part I exam with the Canadian (OEBC) written exam for optometric licensure focuses on just a few specific words.

Dr. Joseph Ellis

Dr. Joseph Ellis

As Joe Ellis, OD, president of the Kentucky Board of Optometric Examiners (KBOE), said in testimony, the KBOE is trying “to make our regulatory match up with what’s in the statute.”

The proposal that licensure in Kentucky will require the NBEO results but adds that the Optometry Examining Board of Canada (OEBC) results may be submitted as an alternative for the NBOE Part 1 test.

What’s unusual about this scenario is that this difference of opinion is between optometrists. More commonly, optometry and ophthalmology present different views. Nearly all the testimony during the April hearing came from optometrists.

The Kentucky amendment addresses only Part I test results. It has moved out of the subcommittee and is expected to be heard by the Interim Joint Committee on Health Services sometime this summer.

The NBOE is a three-part exam. Part II is the Patient Assessment and Management Section and assesses the candidate’s clinical thinking and decision-making, with an emphasis on diagnoses and treatment. NBEO’s Part III involves the Patient Encounters and Performance Skills. This test addresses case analysis, critical thinking and essential skills evaluation in a simulated-live patient encounter.

A Look at Part I

Part I of both NBOE and OEBC test the basic science, but here’s where proponents and opponents disagree. Opponents say that the scope of practice in the U.S. is broader than in Canada, so the Canadian test doesn’t address all the relevant material. Using the three NBEO scores is the standard procedure so they argue that consistency is important. Plus, they say that the in-person requirement of NBOE is more reliable than the proctored OEBC testing.

Proponents say the differences in Part I will come out in the wash in Parts II and III.

Some students take both. Students at accredited optometry schools or colleges in Canada can take the NBOE so that they can obtain licensure in the U.S. And U.S. students who foresee practicing in Canada one day may take both.

Incidentally, in March, the Canadian province of British Columbia announced it would stop accepting NBEO scores in lieu of OEBC scores.

Students do not stand to save much with this proposal. Each of the NBEO exams costs $1,445. The written component of the OEBC is $2,000 Canadian or a little less than $1,500 in mid-June. However, OEBC test-takers do not incur travel expenses. If a student fails, they have to pay for each retake.

Down the Road

Lisa Fennell, executive director at the Association of Regulatory Boards of Optometry (ARBO) wonders what this could mean for students down the road. If this proposal were to become law, “Kentucky would be the only state to allow any part of the Canadian exam. That could cause confusion” particularly for optometrists who move to any other state that uses the same standardized exam. Reciprocity or endorsement for licensing might be at stake. At this time, Canadian ODs who took only OEBC tests would need to pass their NBEO tests to get a U.S. license.

Dr. Hannah Huffman

Dr. Hannah Huffman

Wait and See

For now, many are watching to see what happens at the June 20 meeting of the Kentucky Board of Optometric Examiners and perhaps at a summer regulatory hearing.

Kentucky Optometric Association President Hannah Huffman, OD, says that the KOA Board of Trustees “recognizes and strongly supports the sole authority of the KBOE to oversee the practice of optometry in Kentucky, which includes the legal authority to approve an alternate examination for licensure. Per KRS 320.250(2), the KBOE ‘may accept an examination prepared, administered and graded by the National Board of Examiners in Optometry or any other organization approved by the board as qualified to administer the examination.’”

Dr. Fraser Horn

Dr. Fraser Horn

The Association of Schools and Colleges of Optometry President Fraser Horn, OD, says the discussion falls outside of the control or purview of ASCO. “Our view is that we educate our students to take care of their future patients to the fullest scope of the states and provinces. In doing so, we believe that we prepare them for licensure exams in the U.S., Canada or any other country. This type of proposed regulatory change is something we are aware of, but really do not have an opinion or stance on as it is up to the states to determine how best they should license practitioners.”

He continues, “What we care about is that the testing is fair, accurate and transparent. ASCO nominates representatives to the NBEO board and they are beholden to the NBEO organizational by-laws. We know both NBEO and OEBC work diligently to make sure that their exams are valid and fair.”

The ECP Shortage

Rural populations are often underserved by a variety of primary care and specialty doctors. According to the Kentucky Association of Counties, 93 of Kentucky’s 120 counties are predominantly rural, and 54 are entirely rural.

Dr. Ellis says that the amendment could make it easier for Canadian-trained ODs to obtain licensure as well as give Kentucky ODs another avenue to licensure, without lowering the standards. He said that students he’s spoken with support the amendment.

Legislative committee co-chair, Rep. Derek Lewis, said he has been in contact with Kentucky ODs who are in favor of this revision. Factors he cited were the rising cost of the NBEO exams, which were $725 in 2016 and about double that now, as well as frustration with what some perceive as NBEO’s monopoly on testing.

What’s Next?

On Friday, June 20, the KBOE is expected to meet. The NBEO has submitted its testimony, encouraging the KBEO to see that the amendment is withdrawn. “As independent eye care providers, optometrists are held to the medical standard of care. Protecting the public from practitioners who have not demonstrated competency must take precedence over easing requirements for entry into the profession,” the testimony says.

Attend the meeting? The Kentucky Board of Optometric Examiners meets on Friday, June 20, at 11 am EST, Hyatt Regency Hotel, 401 W. High Street in Lexington; Mary Todd Lincoln Board Room

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