Kentucky's Waived Licenses and Moving to Another State

For most optometrists, the Kentucky story is background news. For a Kentucky licensee who never passed one of the NBEO parts, or who used the Canadian exam in place of Part I, it decides how a move to another state will go. Boards in other states license on an NBEO record, and a Kentucky license by itself no longer tells them that record is complete.

What happened in Kentucky?

According to NBEO, the Kentucky Board of Optometric Examiners (KBOE) granted at least 21 optometry licenses to graduates who had not passed all required parts of the NBEO exam, voting on waivers on at least six dates during and after the COVID-19 emergency (2020 to 2023).

On Oct. 1, 2025 the Kentucky Attorney General issued opinion OAG 25-13. As NBEO quotes it, the opinion found that the board "acted beyond its authority in waiving licensure requirements," that the waivers were "null, void, and unenforceable," and directed the board to review the licensure of optometrists licensed under the waivers and alternative testing measures to make sure they met 201 KAR 5:010.

Two rounds of emergency regulations followed. The board filed one on Dec. 31, 2025, which NBEO opposed. At a special meeting on Feb. 5, 2026, the board withdrew it and filed a replacement. NBEO's Feb. 9, 2026 statement describes the replacement as letting the waiver recipients keep practicing for another year with a restriction on four laser procedures, with a renewal deadline in March 2027, and as allowing them, and only them, to substitute a computer-based exam from the American Board of Optometry for NBEO Part III. NBEO objects strongly to both points. Those descriptions are NBEO's, and the regulation's details may still change.

Which rules govern Kentucky licensure now?

The emergency regulation 201 KAR 5:010E sets the current requirements, as read in October 2026:

• The standard application requires NBEO Parts I, II and III and TMOD, all passed within five years of applying.
• The Canadian OEBC exam could replace NBEO Part I only for tests taken or submitted between July 30, 2025 and April 15, 2026.
• The NBEO Injections Skill Examination is required from Jan. 1, 2027.
• Endorsement requires active practice for the past five years, a therapeutic license and good-standing certificates from every state ever licensed. Fees are $700 by endorsement or $500 standard, plus a $25 data bank query.

So Kentucky now has three kinds of licensees with different exam records: those who passed every NBEO part, those licensed through a waiver, and those who used the OEBC exam for Part I during the 2025 to 2026 window.

Why does this matter when you apply in another state?

Because most boards ask for the NBEO record itself, sent by NBEO, and many ask for all three parts. A few examples from current requirements:

• Texas requires Parts I, II and III (Part III on or after June 1994) and TMOD for the Acceptance Application.
• North Carolina requires Parts I, II, every Part III PEPS section, TMOD and the ISE, and has no endorsement route at all.
• Tennessee requires graduates since 1992 to pass all parts of NBEO, including clinical skills.
• Nevada's endorsement route requires all NBEO parts released by NBEO, plus five continuous years of practice.
• Michigan asks endorsement applicants licensed elsewhere for less than three years to send NBEO scores and transcripts.

Boards also ask for verification from every state you have held. A Kentucky verification will show the license; it will not show which NBEO parts you passed, and the new board will look to NBEO for that. Kentucky's own notes now say a Kentucky license is not proof of a full NBEO record. A board that sees a missing part will ask about it, and an application that does not explain it will stall.

Never treat a Kentucky license as a substitute for a missing NBEO part. Some endorsement routes weigh years of licensure heavily, but boards still look at how you were examined, and the answer on a sworn application has to be complete.

How should a Kentucky licensee prepare?

1. Pull your NBEO score history. NBEO score reports show your entire examination history. Confirm Parts I, II and III, TMOD, and the ISE or LSPE if your target state asks for them.
2. Read the target state's NBEO list. Some states list Parts I and II with Part III or an equivalent state exam (Montana's endorsement route), and Oklahoma does not list Part III for its State Board Exams, but most list all three. See NBEO parts each state asks to see.
3. Plan the exam before the application. If a part is missing, the clean path is to pass it. NBEO allows six attempts per exam. Part III and the ISE are given only at NBEO's center in Charlotte, and clinical scores are released about two months later.
4. Answer every question accurately. Questions about how you were licensed, any board action and any limitation on your license have to match what the Kentucky board and NBEO will report.
5. Keep the Kentucky license current. It renews every year by March 1 ($300 as of October 2026), and Kentucky requires KASPER registration for optometrists with a DEA number or the license will not be renewed.

Does this affect Kentucky licensees who passed everything?

Only a little. Expect the new board to rely on NBEO's report rather than Kentucky's license, which is what most boards do anyway. Order NBEO score reports early; see sending NBEO score reports to a new board. If you hold Kentucky's Expanded Therapeutic Procedures credential, remember that it is a Kentucky credential; another state's laser or procedure authority comes from its own statute (how states decide on laser procedures).

Where do we fit?

Our Optometry Licensing Readiness Review ($149, credited in full toward a first application) includes a Kentucky-waiver screen: we read your NBEO history against the target state's requirements before you pay a board fee, and tell you whether the file will hold up or which exam comes first. You register for and sit any NBEO exam yourself. When the record is complete, the Optometry License, One State service is $699. See pricing and the Kentucky license page.