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Kansas Board of Pharmacy proposes replacing numeric 75% exam cutoff with pass/fail set by national test vendor
Summary
The Kansas Board of Pharmacy wants to remove a 75% numeric passing score from regulation and accept the National Association of Boards of Pharmacy's new pass/fail reporting for licensing exams. Legislators raised constitutional and transparency concerns and asked the board to disclose the vendor's passing threshold and record of board review.
Bradford D. Young, an attorney for the Kansas Board of Pharmacy, told the legislative committee that the board wants to update regulation K681-2 to reflect a change in how national exams are reported: “the organization that administers both of these examinations, the NABP, has switched to a pass fail system.”
Why it matters: the existing regulation names a 75% numeric passing score. If the board simply accepts the vendor’s pass/fail result, applicants, schools and the public would not see the numerical threshold that previously defined competence — a change several legislators said raises legal and notice concerns.
What the committee pressed the board to explain
Representative Carmichael pressed the board on the legal basis for deferring the licensing standard to a private organization, saying, “It sounds to me like what may be an unconstitutional delegation of authority to a private organization” and asking whether the board can cite authority that it may rely on vendor scoring without publishing the standard. Other lawmakers echoed worries about notice to applicants and consumers if the numerical score is no longer published.
Board response and next steps
Young said the board is adopting the vendor’s pass/fail reporting because the vendor no longer provides numerical scores; he told the committee the board reviewed prior years’ score distributions and sees the pass/fail outcomes as “substantially the same” in practice. He also noted the change went through standard administrative review and attorney-general review, and he agreed to bring the committee’s concerns back to the board for further explanation.
What the committee asked for
Members requested documentation showing when the board discussed the change, any materials the board relied on comparing historical numeric scores to pass/fail outcomes, and a public explanation of how the board believes the transition complies with the board’s statutory duty to set licensing standards. The committee also asked whether alternative vendors exist and whether applicants will be given notice of the numeric threshold (if any) underlying the pass/fail determination.
Procedural note
Young said the administrative rulemaking process includes a public hearing; the board will hold a public comment hearing on the regulation after the administrative-review steps are complete. The committee asked for the materials above ahead of that hearing so members can evaluate whether the proposed regulatory language preserves due-process notice and statutory authority.
