By Anthony Dynar

I have been researching for several months about the portability of my cosmetology license across state lines. I wanted to make sure I can start working as a cosmetologist in another state immediately without having to comply with any additional state-specific licensing requirement.

     I realized during my research how much my profession is regulated at the state level. Even after being a licensed cosmetologist since 2006, some states would still require me to go back to beauty school for several months before I could even be eligible to take that state’s licensing exam. Now, all states tout the reason for such extensive testing is health and sanitation. You would think after years of being a practicing cosmetologist, I’d know a thing or two about how to sanitize my equipment, how to deal with cuts and burns, and so on. But these respective state boards of cosmetology seem to have a convoluted logic of their own.

     Curious as I am, I decided to dig a bit deeper into what these different licensing exams really entail. After many hours of being creative with the Google search engine, here are my findings:

     1) What you and I and every licensed cosmetologist know is that all 50 states regulate our profession, some states more stringently than others. What we didn't know was that ours is one of the top-5 most regulated professions in the United States, ranking above professions like EMT services. One would think Emergency Medical Technicians would have to undergo more extensive training than cosmetologists or interior designers. After all, EMT’s literally hold our lives in their hands, compared to interior designers whose biggest professional mistake would probably be designing a room where the window blinds don’t match the sofa covers. An excellent study published last year by the Institute for Justice (https://www.ij.org/license-to-work-release-5-8-12) had this to say: “States consider an average of 33 days of training and two exams enough preparation for EMTs, but demand 10 times the training—372 days, on average—for cosmetologists. . . . Unnecessary and needlessly high licensing hurdles don’t protect public health and safety—they protect those who already have licenses from competition, keeping newcomers out and prices high.”

     The rabbit hole goes deeper. Even assuming for a second that states do have a legitimate health and safety concern in regulating my profession, and even assuming that cosmetologists trained in states that require 2,000 hours of schooling instead of 1,600 would be better-informed about sanitary practices, what I found casts serious doubt on having 50 separate licensing requirements—requirements that severely reduce portability of a cosmetology license from one state to another.

     2) All 50 state boards of cosmetology have come together and formed what’s called the National-Interstate Council of State Boards of Cosmetology, Inc. (http://www.nictesting.org/about.asp), more commonly known as the NIC. They offer a “standardized, valid and legally defensible National Examination Program.” It is not the individual state boards that test you, it is the NIC. Have no illusions about this: one organization does all the testing nation-wide.

     3) But the NIC itself does not create examination questions and standards. That is outsourced to a private company: Schroeder Measurement Technologies, Inc. (http://home.smttest.com/default.aspx). Sure enough, NIC is listed as a client on SMT’s client list (http://home.smttest.com/clients/about-our-clients.aspx).

     4) Moreover, neither the NIC nor the respective state boards actually conduct the licensing exam. That is outsourced to another private company: Professional Credential Services, Inc. (https://www.pcshq.com/?page=home).

     So, one private company—SMT—sets the exam questions and the examination evaluation standards. Another private company—PCS—actually conducts the exam and grades the written and practical portion of a cosmetologist licensing exam. You know what I’d do if I were running those two companies? Instead of framing 50 different question papers and instead of having 50 different examination standards, I’d frame just one question set and have just one standard, call it a trade secret, and laugh my way to the bank.

     Having onerous state-specific requirements that aren't portable does not make sense. Why don’t we call a nationwide standardized test a nationwide standardized test? One solution would be for states to give blanket reciprocity, i.e. all states should recognize cosmetology licenses issued in any other state. That’s no different than the regime we already have in place regarding driver’s licenses.

     Of course, I am not saying that because this is a matter of nationwide concern, it is now somehow the federal government’s responsibility to regulate the cosmetology profession instead of the individual states’. I am not going to quibble about the locus of regulation—whether states or the federal government are better-suited to regulate cosmetologists. But my findings surely cast doubt on the need for onerous regulation that is the root cause of non-portable licenses.

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