Kansas optometry board will not hold patient-based clinical exam for July 2025; will use written tests and interviews

The Board of Examiners in Optometry voted during its April meeting to forgo a patient-contact clinical practical for the July 2025 licensure exam and instead administer the state written exam, a written clinical (paper-based/case) test and continue applicant interviews.

Board Chair (name not provided) moved the measure, saying, “I am going to make a motion that during the 02/2025 application process for a Kansas State optometric license, that we administer a written state test, a written clinical test, and we are not administering a clinical didactic test,” and the motion was seconded and approved by voice vote.

Why it matters: Board members said recent changes and security incidents involving the National Board of Examiners in Optometry’s (NBEO) new Part 3 patient‑encounter format — plus a higher failure rate in some cohorts — prompted discussion about whether the state should add another live clinical exam on top of the NBEO test. Several board members and staff argued the NBEO’s new Part 3 now emphasizes clinical decision‑making and is administered and scored by psychometric professionals; others cited equity concerns for candidates caught between older and newer NBEO formats.

What the board discussed: Several members said Kansas historically administered an in‑person clinical practical; others noted the NBEO’s new Part 3 (patient encounter performance stations, “PEPs”) was specifically redesigned to test clinical decision making. Board counsel and members discussed statutory limits and reciprocity implications, including recent legislative changes cited in the meeting as House Bill 2066 (referenced in the discussion as codified at KSA 40-8-34-6), and whether those changes affect the board’s discretion to accept out‑of‑state credentials in place of local testing.

Board counsel Tim Resner advised that the statute governing the board’s exam obligation is general and that, absent a different statutory requirement, the board retains discretion to set exam format. Counsel also noted the board can revert to administering an in‑person clinical practical in future years if it decides that is necessary.

Aspirational next steps and public comment: The board voted to prepare a brief public notice summarizing the change and to solicit comment before pursuing longer‑term regulatory changes. Members discussed whether additional public notice or a formal public comment period was required for a substantive change; counsel and staff said a formal rulemaking process was not required to implement the testing approach for the 2025 cycle but recommended publishing the rationale and opening a comment window.

What the decision does and does not do: The motion specifically removes the patient‑in‑clinic (live patient) practical for the 2025 July licensure session only; the board said it will still administer the state written exam and a written clinical case test and will interview applicants. The board emphasized this year’s change is not a permanent rule change and that it may reinstate a hands‑on clinical practical in later years.

Quote summarizing the board’s view: Board member (Dr.) Nagarajah, who reviewed NBEO material, told the board the new NBEO clinical exam “is very thorough… it covers a breadth and depth of knowledge” and that the updated national exam “covers clinical decision making… very, very well.”

What this means for applicants: The board did not adopt a new, blanket policy on whether it will offer additional exam dates beyond the usual annual schedule; members agreed to revisit scheduling and administrative details separately. Staff advised applicants with incomplete school documentation to follow the board’s normal application and (if needed) appeal procedures rather than assume eligibility for the July session.

Votes at the meeting: The motion to omit the live patient clinical practical for the July 2025 session passed by voice vote; a written summary of the decision and an invitation for public comment will be posted by staff.

Next dates and follow up: The board directed staff to prepare a short explanatory notice to be released publicly and to ask members of the profession for comment; the board also asked the staff and the vice president to review the state law exam questions and proposed edits for future administrations.