50 State Comparison Report

This report was funded to reduce excessive occupational licensing requirements and explore alternative approaches that maintain public health and safety.

A Comparison of State Occupational Licensure Requirements and Processes 

(As of May 2021)

This report was funded as part of a $422,000, three-year grant received from the U.S. Department of Labor in 2018 to reduce excessive occupational licensing requirements and explore alternative approaches that maintain public health and safety.


Over the past several decades, the share of U.S. workers holding an occupational license has grown sharply. In the 1950s, just five percent of U.S. workers were required to hold an occupational license – meaning they completed additional schooling or training and passed an exam to be licensed to practice their trade or profession in a certain state. Today, the U.S. Bureau of Labor Statistics estimates that nearly a quarter of full-time workers (43 million people) hold an occupational license. This uptick in licensed workers is directly correlated to the growth of occupational licensing laws. In the early 1990s, 800 occupations required licenses in at least one state. According to the National Conference of State Legislatures, that number is currently over 1,100 occupations.

When designed and implemented carefully, licensing can offer important health and safety protections to consumers, as well as benefits to workers. Licensing may also help practitioners to professionalize, encouraging individuals to invest in occupational skills and creating career paths for licensed workers. For example, accountants in States requiring more experience (three or more years) are 26 to 36 percent more likely to have acquired training since starting their current job.

However, in other instances, occupational licensure can serve as a form of "title protection," shielding practitioners with a license from competition from those who are not licensed but wish to practice the trade or profession. It is incumbent on policy makers to continually ensure that an appropriate balance between the costs and benefits of occupational licensure is maintained.

Occupational licensing laws require individuals to meet entry and renewal requirements to work in specified occupations. These requirements may include minimum levels of schooling, training, or experience; initial licensing and renewal fees; passing exams; and/or meeting other requirements as defined in enabling statutes and accompanying regulations. In some instances, the requirements of occupational licensure in terms of training, continuing education, and oversight help raise the quality of service and protects consumers.

In Pennsylvania, the Bureau of Professional and Occupational Affairs  oversees professional licensure. BPOA was established in 1963 as part of the Department of State ( to provide administrative, logistical and legal support services to professional and occupational licensing boards and commissions.

There are twenty-nine licensing boards and commissions, each with their own statute governing their powers and functions. The boards and commissions also promulgate regulations to further govern their respective professions. There are over 900,000 licensed professionals among hundreds of license types offered in the Commonwealth.

The boards and commissions are each comprised of between seven and seventeen members, including professionals in those fields and public members who represent the public at-large. Members are appointed by the Governor and confirmed by the Senate. The licensee classes regulated by each board and commission varies significantly. The largest—Pennsylvania's Board of Nursing—oversees the licensure of over 300,000 nurses and dietitian-nutritionists, while the smallest—the Navigation Commission for the Delaware River and its Navigable Tributaries—licenses just over a few dozen maritime pilots.

The Department provides these boards and commissions with legal, technical and administrative support to conduct written practical licensure examinations; review and verify education and experience of candidates for licensure; certify providers of education; receive and investigate public complaints; conduct periodic facility inspections; prosecute, adjudicate, fine and sanction violators; administer licensure programs, revise standards for licensure to keep pace with changes in the professions and advise the legislature on proposed statutory changes. 

The Bureau of Enforcement and Investigation provides the boards and commissions with facility inspection and law enforcement capabilities. It maintains regional offices in Harrisburg, Philadelphia, Pittsburgh, and Scranton.


Occupational Licensing Research and Reform Grant

In July 2018, the Department of State was awarded a three-year grant from the U.S. Department of Labor – Employment & Training Administration, devoted to the identification and evaluation of reform priorities related to occupational licensure that improve workforce development.

One of the projects that came as a result of grant funding is the following report of occupational licensure requirements for all fifty states. The report compares licensure requirements for nearly ninety occupations licensed under the Pennsylvania Department of State to requirements in the forty-nine sister states. The report contains comprehensive data on licensure accessibility, educational and examination requirements, training and experience requirements, criminal history policies, continuing education requirements, renewal terms, fees, and reciprocity requirements.

The goal of this report is to compare Pennsylvania licensure requirements to other states in order to identify burdensome licensing standards that are inconsistent with the national trend. In any case where Pennsylvania exceeds the national average, the report recommends state officials to evaluate the health and safety protections associated with licensure against the impact of employment restrictions on Pennsylvania workers and businesses.

The analysis seeks to provide lawmakers and officials with insight into existing or potential conditions within the current licensure framework that may prevent individuals from seeking or maintaining entry into professional occupations. A reduction of overbearing requirements, to be consistent with other states, will keep Pennsylvania competitive in attracting licensed professionals and keep pace with sister states in relation to workforce development and job growth.

The twenty-nine individual board reports featuring the 50-state comparison for licensed occupations can be found in Appendix B.


National Trends in Occupational Licensing

The National Conference of State Legislatures (NCSL) produced a report in December 2020 titled, "Occupational Licensing Final Report: Assessing State Policies and Practices", which tracked state policy options at the executive, legislative, and board levels. These policies range from broad, structural changes in overall licensing regulation in the states to smaller and targeted approaches aimed at reducing barriers for a certain occupation or population group.

The report highlights the following national trends in occupational licensure:

  • Legislative priorities between 2017 and 2019 included reducing licensing fees and requirements, clarifying licensing requirements, creating a new license for a previously unlicensed occupation, and studying or instituting reciprocity agreements between states.
  • There was an increased interest in universal licensure bills in 2019, with enactments in Arizona (HB 2569), Montana (HB 105), New Jersey (A1531) and Pennsylvania (HB 1172), and then in 2020 with Missouri (HB 2046) and Colorado (HB 1326) enacting bills.

Further, the report identifies key populations that states are focusing on in terms of reforming occupational licensure policy. These populations include individuals with a criminal record, veterans and military spouses, and immigrants with work-authorizations.

Individuals with a criminal record

In recent years, individuals with a criminal record have been the highest priority for lawmakers as nearly 170 bills proposing to remove barriers for this population have been introduced by states across the country from 2017 – 2019. Examples of targeted approaches by states to reform occupational licensure policy to smooth the licensure process for individuals with a criminal record include:

Relevancy Limitations: States that favor reform to licensing policies that exclude people with convictions have aimed to "refrain from categorically excluding individuals with criminal records, and instead exclude those individuals whose convictions are recent, relevant, and pose a threat to public safety". At least nineteen states and Washington, D.C. ban boards from considering arrests that did not result in a conviction:

  • Arkansas, California, Colorado, Connecticut, Illinois, Indiana, Iowa, Kansas, Michigan, Minnesota, New Hampshire, New Mexico, New York, Ohio, Pennsylvania, Rhode Island, Texas, Utah, Wisconsin (Source: Institute for Justice)

Modification of Morality Clauses: States have chosen to remove vague and broad standards that limit individuals from obtaining a license. Examples include "good moral character" and restrictions against "moral turpitude" offenses to provide more clarity on exclusionary convictions. Sixteen states generally prevent licensing boards from using vague standards like "good moral character" or "moral turpitude" to deny licenses for ex-offenders:

  • Arkansas, California, Idaho, Illinois, Indiana, Iowa, Kansas, Kentucky, Minnesota, Mississippi, New York, North Carolina, Ohio, Pennsylvania, Washington, West Virginia (Source: Institute for Justice)

Preliminary Determinations: Several  states allow an applicant to request a determination on eligibility before going through the licensing application process. The following eighteen states, plus Washington, D.C., allow ex-offenders to petition a licensing board at any time, including before enrolling in any required training, to determine if their record would be disqualifying:

  • Arizona, Arkansas, Idaho, Indiana, Iowa, Mississippi, Missouri, Nebraska, New Hampshire, North Carolina, Ohio, Oklahoma, Pennsylvania, Tennessee, Texas, Utah, West Virginia, Wisconsin (Source: Institute for Justice)

Veterans and Military Spouses

Another focus of lawmakers are veterans and military spouses, as states have introduced over 120 bills during the same timeframe targeted towards this population. The difficulty in translating military credentials and work experience to satisfy state occupational license requirements pose a significant barrier to veterans. States interested in improving their licensing processes and policies to benefit veterans often must figure out how to translate military education and experience to state-specific licensure requirements.

The following legislative approaches should be considered in order to address this barrier to Veterans' licensure:

  • Washington's House Bill 1418, signed into law by Governor Christine Gregoire in 2011, instructed the Washington Department of Licensing to consider military training and experience in satisfying professional licensure requirements unless the Department determines that the training and experience is not "substantially equivalent" to state standards. This legislation created a streamlined path for qualified veterans while shifting the burden of determining substantial equivalency for licensure to the licensing authority.
  • Maryland's Veterans' Full Employment Act of 2013 – Under this Act, Maryland licensing boards are required to consider a veteran's relevant military experience when calculating their years of practice in an occupation. Maryland licensing boards must also credit any substantially equivalent military training and education. In addition, the Act requires certain health occupation boards to assign advisors to military applicants.

The United Service Organization (USO) estimates military families move to a new state on average every three years. For military spouses, frequent moves and the resulting need to search for a new job can be a significant problem, especially when finding employment in a new state requires obtaining an occupational license. Military spouses in professionally licensed fields are burdened from the expenses involved in transferring a license or certification to a new state and in some cases, holding multiple state licenses due to the uncertainty of re-location in the future. In order to smooth the transition of re-locating to a new state and securing employment, many states have implemented waivers for initial licensing fees.

  • Over one-third of states waive or reduce initial licensure fees for military spouses in certain professions: Alabama, Colorado, Florida, Iowa, Louisiana, Massachusetts, Missouri, Nebraska, New Mexico, New York, North Carolina, North Dakota, Ohio, Oklahoma, South Dakota, Texas, West Virginia. (Source: Department of Labor)

Immigrants with work authorization

According to the U.S. Bureau of Labor Statistics, immigrants make up 17.4% of the U.S. labor force. Foreign-trained workers and U.S.-trained immigrants are filling key niches in the U.S. labor force, alleviating shortages in certain sectors such as health care, where one in six health care professionals overall is foreign-born. Certain occupations are estimated to be growth areas for the U.S. economy, partly as people retire from the workforce and require more health care and other services. Despite the need for qualified professionals, immigrants often struggle in obtaining recognition for foreign education and credentials when applying for an occupational license. The difficulty immigrant professionals encounter in navigating licensure requirements often leave them underemployed or unemployed.

In order to address these challenges and increase research efforts and transparency related to immigrant licensure policy, states have created programs such as welcoming centers for employment, which include training, education and career re-entry services for foreign-trained professionals to expand and improve their local workforce and economy.

  • Currently ten states have established an Office on New Americans: California, Michigan, Maryland, Massachusetts, Nevada, New Jersey, New York, Ohio, Virginia, and Washington.

These state offices help New Americans fully participate in civic and economic life by creating "opportunity" centers for information sharing and skill-building, increasing access to English-for-Speakers-of-other-Languages (ESOL) training, develop and leverage the professional skills of workers, and connect workers to business resources to harness their knowledge and abilities.


Prevalence of Licensure

Occupational licensure is a form of government regulation requiring a license to pursue a particular profession or vocation for compensation. The share of American workers who hold an occupational license has grown five-fold over the past half century, and nearly a quarter of the U.S. working population currently holds some form of state license. According to the U.S. Bureau of Labor Statistics (BLS), nationally a quarter of full-time workers have a state license to work in their designated occupation. With 24.71 percent of the workforce professionally licensed and certified, Pennsylvania is ranked 30th in the country for the percentage of its total workforce licensed or certified. Looking solely at percentage of workforce professionally licensed, Pennsylvania is comparable to the national average at 19.13 percent.

It is important to note that while licensure is the strictest form of occupational regulation, there are a variety of other options which can be utilized to help protect the public and ensure high quality delivery of services, without creating an unnecessary barrier to entry for a profession. For example:

  • Mandatory Bonding and Insurance requirements: With bonding, employers or workers are required to maintain funds against which consumer claims can be made. This both communicates confidence in the expected quality of work and ensures that consumers will be compensated in the event they suffer harm. Alternatively, a worker or firm may purchase insurance. This serves a similar purpose, with the insurance company's willingness to sell a policy itself signaling confidence in the expected quality of work. 
  • Registration: Registration is the least restrictive form of occupational regulation. It generally  involves individuals paying a fee and filing their names, addresses, and qualifications with a  government agency. This ensures that practitioners can be reached in the event of a complaint, thereby supporting civil remedies for consumer harm.
  • Private certification: Certification often provided by a private organization for the purpose of providing the public protection on those individuals who have successfully met all requirements for the credential and demonstrated their ability to perform their profession competently.
  • State Certification: State certification, or "right-to-title," restricts the use of a profession's title to those who have been certified but allows anyone to perform the duties of the profession, regardless of whether they have been certified or not. By restricting use of a title to workers who have achieved certain minimum requirements, certification may represent a less restrictive means of providing consumers with information regarding provider quality. Regulation through certification provides information to consumers while allowing them to choose the quality they can afford and does so without limiting workers' access to the occupation. Thus, for occupations where the consequences of low-quality service are not severe, voluntary certification from a private or public accreditor may in some cases be more appropriate than licensing. Certification is less appropriate, however, when the public is likely to make improper or dangerous decisions, and when these decisions might have spillover consequences for others.

Table 1 displays the percentage of each state's workforce that is licensed or certified to perform in an occupation.

Table 1: State Workforce Licensure & Certification (as of 11/2018)

State% of workforce licensed% of workforce certifiedTotal % of workforce licensed or certifiedRank of workforce licensed or certified
(from highest to lowest)
West Virginia21.95%8.42%30.38%4
Rhode Island17.35%11.17%28.52%11
North Dakota22.60%4.18%26.78%14
New York20.72%5.32%26.04%20
South Dakota20.94%5.07%26.01%21
New Jersey19.62%5.70%25.32%27
New Mexico18.37%6.42%24.79%29
District of Columbia18.89%4.52%23.41%-
New Hampshire16.02%7.24%23.26%40
North Carolina18.90%4.17%23.07%42
South Carolina17.83%4.93%22.76%45

Comparison of Licensure Types

Licensing an occupation which is not licensed in many other surrounding states or having licensing requirements that are significantly dissimilar can have negative effects on mobility. Individuals practicing in states without equivalent licenses may have difficulty entering Pennsylvania, despite having experience in the profession, because they will now need to be licensed. According to the National Conference of State Legislatures , there are more than 1,100 occupations licensed throughout the country. The number of unique license types depends in part on how states distinguish certain occupations from one another.

After a comprehensive review of occupations licensed in Pennsylvania and across the country, ten license types found in less than 10 states were identified, including three which are exclusive to Pennsylvania.

Please see Table 2 below for those occupations and the states that license them.

Table 2: License Types found in less than 10 states:

License TypeName of Licensing BoardOther States that license this occupation
Cemetery Associate BrokerState Real Estate CommissionNone (Pennsylvania only)
Cemetery BrokerState Real Estate CommissionArizona, California, Florida, Georgia, North Carolina, Texas
Funeral SupervisorState Board of Funeral DirectorsNone (Pennsylvania only)
Manager of RecordState Real Estate CommissionConnecticut
Natural Hair Braider TeacherState Board of CosmetologyAlabama, Illinois, Michigan, North Carolina, Ohio, Tennessee, Washington D.C.
Orthotic FitterState Board of MedicineAlabama, Florida, Kentucky, Minnesota
Osteopathic Physician AssistantState Board of Osteopathic MedicineNevada, New Mexico, Washington, West Virginia
Practitioner of Oriental MedicineState Board of MedicineDelaware, Nevada, New Mexico, Ohio, Washington
Rental Listing Referral AgentState Real Estate CommissionCalifornia, New Jersey
Trading AssistantsState Board of Auctioneer ExaminersNone (Pennsylvania only)

Pennsylvania's Licensing Framework

The Bureau of Professional and Occupational Affairs  was established in 1963 as part of the Department of State to provide administrative, logistical and legal support services to professional and occupational licensing boards and commissions. Professional licensing is intended to protect the health and safety of the public from fraudulent and unethical practitioners.

The following is a list of the 29 boards and commissions housed under BPOA:

  • State Board of Accountancy
  • State Architects Licensure Board
  • State Board of Auctioneer Examiners
  • State Board of Barber Examiners
  • State Board of Certified Real Estate Appraisers
  • State Board of Chiropractic
  • State Board of Cosmetology
  • State Board of Crane Operators
  • State Board of Dentistry
  • State Board for Professional Engineers, Land Surveyors, & Geologists
  • State Board of Funeral Directors
  • State Board of Landscape Architects
  • State Board of Massage Therapy
  • State Board of Medicine
  • Navigation Commission for the Delaware River and Its Navigable Tributaries
  • State Board of Nursing
  • State Board of Nursing Home Administrators
  • State Board of Occupational Therapy Education and Licensure
  • State Board of Optometry
  • State Board of Osteopathic Medicine
  • State Board of Pharmacy
  • State Board of Physical Therapy
  • State Board of Podiatry
  • State Board of Psychology
  • Real Estate Commission
  • State Board of Social Workers, Marriage and Family Therapists, and Professional Counselors
  • State Board of Examiners in Speech-Language Pathology and Audiology
  • State Board of Vehicle Manufacturers, Dealers, and Salespersons
  • State Board of Veterinary Medicine

The commissioner of the Bureau is a voting member on all boards and commissions under the department's jurisdiction, except the State Board of Certified Real Estate Appraisers and the Navigation Commission for the Delaware River and its Navigable Tributaries. The Secretary of the Commonwealth or a designee serves on these boards.

Pennsylvania's regulatory environment is unique in that all proposed agency rules are statutorily subject to independent and transparent review. In 1982, the General Assembly created the Independent Regulatory Review Commission (IRRC), an independent body charged with oversight of the regulatory process, to ensure that all regulations comply with Pennsylvania law, are subject to public scrutiny, and expressly measured in terms of their costs versus benefits to the public and the regulated community.

For any board to promulgate a policy statement or regulation, pursuant to Executive Order 1996-1, it must first be reviewed and approved by the Governor's Offices of General Counsel; Policy and Planning; and Budget to assure that it conforms to the laws and policies of the state. This independent review process ensures public scrutiny through mandatory legal publication and 30-day public comment periods.

While the decision whether to regulate a profession is ultimately left to the General Assembly and the Governor, groups seeking licensure or certification (either with a new or an existing board) are invited to submit a Sunrise Application to DOS' Office of Policy (DOS-OP). DOS-OP then reviews the survey, conducts independent research, and completes an analysis with recommendation for the Sunrise Evaluation Committee. DOS-OP does not conduct a Sunrise Evaluation if a group seeking licensure has not requested such an evaluation. Since 2016, DOS-OP has conducted five Sunrise Evaluations.

The Department's Sunrise Evaluation Committee consists of either the Director or Deputy Director of Policy; the Commissioner of the Bureau of Professional and Occupations Affairs, the Division Chief where the proposed board would presumably be located; the Director or Deputy Director of Legislative Affairs; the Chief Counsel or Deputy Counsel for Regulatory Affairs; and the Deputy Secretary for Regulatory Affairs. This committee reviews the materials and provides a recommendation regarding whether to support licensure or certification.

An evaluative report, recommending for or against licensure, is then forwarded to the Secretary of the Commonwealth and the Secretary of Policy and Planning for final review. Proponents are subsequently notified of the administration's position.


Licensee Population in Pennsylvania

As previously noted, in Pennsylvania, twenty-nine professional boards and commissions regulate over 900,000 professionals. The licensee population in Pennsylvania can be split into two categories: health care professionals and business professionals. The bulk of professional licensees are in health care professions, as they make up over 67 percent of the licensee population in Pennsylvania. Table 3 shows a breakdown of Pennsylvania licensees by licensing board. For licensee totals categorized by license type, please see Appendix A of this report. The data below is current as of March 2021. 

Table 3: Licensee Population in Pennsylvania (As of March 2021)

Name of Licensing Board | Count

Navigation Commission for the Delaware River: 39

State Architects Licensure Board: 9,086

State Board of Accountancy: 27,623

State Board of Auctioneer Examiners: 1,767

State Board of Barber Examiners: 6,060

State Board of Certified Real Estate Appraisers: 4,403

State Board of Chiropractic: 3,880

State Board of Cosmetology: 105,610

State Board of Crane Operators: 3,202

State Board of Dentistry: 23,683

State Board of Examiners in Speech-Language Pathology and Audiology: 9,413

State Board of Examiners of Nursing Home Administrators: 1,811

State Board of Funeral Directors: 4,855

State Board of Landscape Architects: 1,017

State Board of Massage Therapy: 8,045

State Board of Medicine: 131,181

State Board of Nursing: 304,070

State Board of Occupational Therapy: 13,671

State Board of Optometry: 2,708

State Board of Osteopathic Medicine: 15,193

State Board of Pharmacy: 39,206

State Board Physical Therapy: 21,235

State Board of Podiatry: 1,431

State Board of Psychology: 6,339

State Board of Social Workers, Marriage & Family Therapists & Professional Counselors: 26,541

State Board of Vehicle Manufacturers, Dealers and Salespersons: 35,858

State Board of Veterinary Medicine: 8,230

State Real Estate Commission: 52,503

State Registration Board for Professional Engineers, Land Surveyors & Geologists: 52,386

TOTAL: 921,046

Disciplinary Process

The Professional Compliance Office, within the Prosecution Division of the BPOA's Legal Office, reviews thousands of complaints per year to establish whether the complaint alleges conduct, which is a violation of a practice act, whether a Board has jurisdiction, and whether there is enough evidence to merit further investigation. Complaints can be initiated by consumers, licensees, board or commission members, board or commission staff, competitor complaints, other state licensing boards, media information, and law enforcement.

When a complaint requires investigation, the Department's Bureau of Enforcement and
Investigation (BEI) interview witnesses, obtains documents, and collects evidence related to the allegation made in the complaint. Subsequently, a prosecuting attorney determines whether to close the complaint or to initiate a disciplinary action before the administrative licensing board. Prosecution for violations of standards of practice are initiated through the filing of an Order to Show Cause or via an administrative citation imposing a civil penalty under Act 48 of 1993 (hereinafter Act 48) [20 - Act of July 2, 1993 (P.L. 345, No. 48) (Act 48 of 1993). In accordance with section 5(a) of the Act, the Commissioner of Professional and Occupational Affairs promulgates regulations at 49 Pa. Code Chapter 43b. To date, 24 of the 29 boards and commissions have approved schedules of civil penalties.].

Act 48 citations can be issued by BEI staff in the field, or by legal office staff for technical or administrative violations. Through either avenue, the prosecutor who proceeds with the disciplinary action then bears the burden of proving misconduct before the board. Licensees are provided due process and the board adjudicates the case to either dismiss or sanction. Depending on the severity of the conduct proven, sanctions can range from probation and discretionary suspension to revocation or automatic suspension as required by statute. Licensees have the right to appeal any sanctions to the Commonwealth Court for review.

Six of the practice acts also establish an inspection program administered by the boards through BEI. The State Boards of Cosmetology, Barber Examiners, Funeral Directors, Pharmacy, Vehicle Manufacturers, Dealers, and Salespersons, as well as the State Real Estate Commission, all license facilities where business take place, as well as the individuals directing that business. Each practice act provides for regular inspection of those licensed facilities to ensure that sanitation, equipment, security of chemicals and drugs, recordkeeping, and financial requirements and obligations are being followed.
The inspection standards are delineated in the practice acts and regulations as to equipment maintenance, record-keeping, item integrity, and money-handling.

Inspections that discover technical infractions of these requirements generally lead to the resolution of those issues through the Act 48 citation disciplinary process. Act 48 citations streamline the disciplinary process by eliminating the need for formal orders to show cause, answers, adjudications and orders, and consent agreements.

Act 48 is used primarily to address those minor violations for which the boards and commissions have determined that a monetary civil penalty of no more than $1,000 is an appropriate sanction. An individual who receives an Act 48 citation retains their due process right to a hearing prior to the imposition of the civil penalty. Much like a citation that might be issued by law enforcement, the individual may choose to admit the violation and pay the civil penalty or may deny the violation and request a hearing.

The Barber and Cosmetology boards issue the most Act 48 citations, as violations are found for types of equipment, cleanliness of equipment, and the employment of licensees to perform professional functions. Examples of common Act 48 citations include failure to have the proper equipment to sanitize tools used to perform manicures and pedicures, or the of use of prohibited or harmful chemicals.

Overall Trend

Table 4 below displays the number of annual disciplinary actions per licensing board over the past few years. Disciplinary actions include revocations, suspensions, stayed suspensions, voluntary surrenders, probations, reprimands, civil penalties, and Act 48 violations. The total amount of disciplinary actions has decreased year-over-year as 2,410 actions were recorded in 2018, 2,015 recorded in 2019, and finally 1,505 recorded in 2020. Due to the COVID-19 pandemic, less investigations were being conducted by BEI and as a result, some licensing boards saw a significant decrease in the total number of sanctions issued in 2020 compared to prior years.  

Table 4 and Table 5 displays trends in total disciplinary actions annually by licensing board.

Table 4: Annual Disciplinary Actions per Licensing Board (2018 – 2020)

Name of Licensing Board201820192020Total
Navigation Commission for the Delaware River0000
State Architects Licensure Board810220
State Board of Accountancy31153379
State Board of Auctioneer Examiners103114
State Board of Barber Examiners16814490402
State Board of Certified Real Estate Appraisers13131844
State Board of Chiropractic8131839
State Board of Cosmetology428255222905
State Board of Crane Operators418426
State Board of Dentistry485165164
State Board of Examiners in Speech-Language Pathology and Audiology63514
State Board of Examiners of Nursing Home Administrators2204
State Board of Funeral Directors554035130
State Board of Landscape Architects0000
State Board of Massage Therapy414148130
State Board of Medicine211215143569
State Board of Nursing8856463861,917
State Board of Occupational Therapy18312
State Board of Optometry2024
State Board of Osteopathic Medicine444221107
State Board of Pharmacy687093231
State Board of Physical Therapy127322
State Board of Podiatry5229
State Board of Psychology821635
State Board of Social Workers, Marriage & Family Therapists and Professional Counselors324633111
State Board of Vehicle Manufacturers, Dealers and Salespersons197207114518
State Board of Veterinary Medicine21363289
State Real Estate Commission8989109287
State Registration Board for Professional Engineers, Land Surveyors and Geologists13181748

Since 2018, the five boards listed in Table 5 account for 4,311 of the 5,930 total disciplinary actions taken by all licensing boards, nearly 73%. In the case of the State Board of Nursing, the number of disciplinary actions taken as a percentage of the total overall (32.3%) closely mirrors the number of licensed nurses and dietitian-nutritionists as a percentage of total licensees (33.1%). For the remainder of the boards listed, the number of disciplinary actions taken did not correlate—was either higher or lower— with the number which would be expected based solely on the number of licensees regulated by the board. This discrepancy was most pronounced for the State Board of Barber Examiners, which regulates less than 1% of the licensees regulated by BPOA but was responsible for over 6% of total disciplinary actions.

Table 5: Number of Disciplinary Actions by Board (Top 5) (2018 – 2020)

RankName of Licensing BoardNumber of Disciplinary Actions TakenPercentage of Total Disciplinary ActionsPercentage of Total Licensees
1State Board of Nursing1,91732.3%33.1%
2State Board of Cosmetology90515.3%11.5%
3State Board of Medicine5699.5%14.2%
4State Board of Vehicle Manufacturers, Dealers and Salespersons5188.7%3.9%
5State Board of Barber Examiners4026.7%>1%

Legislation in Pennsylvania

Over the past few years, Pennsylvania has taken major legislative steps to reduce barriers to licensure for professionals re-locating from other states as well as reforming restrictions that previously held back re-entrants from obtaining licensure.

Act 41

Act 41, signed by Governor Wolf on July 2, 2019, allows for increased portability of out-of-state professional licensees coming to work in Pennsylvania. Many of the boards and commissions of BPOA already have existing procedures that allow for consideration of applicants licensed in another state, territory or country to obtain a Pennsylvania license by way of reciprocity or endorsement.

Licensure by reciprocity is when a license is granted to an applicant based on an agreement between or among licensing jurisdictions in which each agrees to issue licenses to applicants who hold the same type of license in the other jurisdiction, usually based on an assessment that their licensing requirements are similar.

Licensure by endorsement is when a license is granted to an applicant who holds the same type of license in another licensing jurisdiction with substantially equivalent licensing requirements, without regard as to whether the other jurisdiction would do the same.

Act 41 provides yet another option for the boards to consider applicants licensed in other jurisdictions and will help reduce unnecessary barriers for new residents, veterans, military spouses and other individuals who wish to move to and work in Pennsylvania.

If a board's existing endorsement/reciprocity options do not provide a means of licensure, applicants who hold a license in another state or country will be given Act 41 consideration on a case-by-case basis.

Most boards have an application review subcommittee to review applications. Under Act 41, the subcommittee will consider whether an applicant:

  • hold the same or similar license in another jurisdiction and the jurisdiction's licensing requirements are substantially equivalent to those required in Pennsylvania.
  • are in good standing with the other jurisdiction.
  • demonstrate competency in the occupation or profession; and
  • meet other administrative and background requirements [21 - Act 41 requires that the applicant hold a current license from another state, territory or country whose licensing requirements are substantially equivalent to Pennsylvania's requirements.  An applicant will also have to demonstrate competency and satisfy several additional requirements as set forth in Act 41.]

For applications that do not initially satisfy all of Act 41's requirements, the boards may (but are not required to) issue a "provisional license" in appropriate situations which will allow an applicant to practice while fulfilling additional requirements for licensure.

A provisional license enables an applicant to begin operating in Pennsylvania for a limited period while satisfying any outstanding requirements or issues that remain, and for the Board to then make its determination whether to issue or deny the license.

As of February 2021, there have been over one hundred full Act 41 licenses issued to applicants. Table 6 displays the amount of Act 41 licenses issued by their respective licensing board. The State Board of Social Workers, Marriage and Family Therapists, and Professional Counselors have utilized Act 41 the most of any licensing board, with forty-six Act 41 Licenses issued.

Table 6: Act 41 Licenses Issued – As of February 2021

Name of BoardNumber of Act 41
Licenses Issued
State Board of Barber Examiners2
State Board of Certified Real Estate Appraisers2
State Board of Cosmetology11
State Board of Dentistry11
State Registration Board for Professional Engineers,
Land Surveyors, and Geologists
State Board of Massage Therapy12
State Board of Medicine6
State Board of Nursing8
State Board of Optometry2
State Board of Osteopathic Medicine8
State Board of Physical Therapy2
State Board of Psychology2
State Board of Social Workers, Marriage and
Family Therapists,and Professional Counselors

Act 53

On July 1, 2020, Governor Tom Wolf signed into law Act 53 of 2020, which made sweeping changes to the occupational licensing rules that govern the use of criminal history information in determining whether to grant, deny, suspend, or revoke a professional license.

With regard to the consideration of criminal convictions, Act 53:

  • Prohibits BPOA's licensing boards and commissions from denying licensure based on considerations of "good moral character," "crimes of moral turpitude," or "ethical or honest practice."
  • Requires each board and commission to develop and publish a schedule of criminal offenses that may constitute grounds to deny, suspend or revoke a license. The list must also identify which crimes are likely to pose a barrier to licensure because they are offenses "directly related" to the occupation/profession.
  • Provides for an "individualized assessment" of each license applicant using objective, detailed criteria that includes rehabilitation and public safety.
  • Provides a process for individuals who have criminal convictions to request a "preliminary determination" as to whether a particular conviction will be a bar to licensure. This new tool will enable people with criminal convictions to find out if their convictions would prevent them from getting a license − before enrolling in a training or educational program, before investing significant time and resources, and before formally applying for licensure.


50 State Occupational Licensure Requirement Comparison – Criteria Measured

This comparison of occupational licensure requirements required a critical and complete review of the processes and regulations set in all fifty states. The Department of State has prepared this comparative report for each of the twenty-nine professional and occupational licensing boards in the Commonwealth, which compares licensure requirements for all occupations licensed under the Department of State to all forty-nine sister states.

The comparison includes education and examination requirements, training and experience requirements, continuing education requirements, initial licensing fees, renewal fees, and a description of any applicable reciprocity, endorsement, or comity provisions.

A description of each criteria measured in the analysis are as follows:

Education (Degree) Requirement

States set a certain level of educational attainment in order to fulfill licensure requirements. This can range from a state-approved training program to a high school diploma/graduate equivalency degree (GED) or academic degree. An academic degree is a qualification awarded to students upon successful completion of a course of study in higher education, usually at a college or university. These institutions commonly offer degrees at various levels, usually including bachelor's, master's and doctorates, often alongside other academic certificates and professional degrees.

Examination Requirement

States will often require a professional association accredited examination or certification to serve as their minimum requirements for initial licensure, which can provide a level of uniformity. Exams are a formal test of a person's knowledge or proficiency in a subject or skill.

Training & Experience Requirement

State licensing boards require applicants have a minimum number of hours or years of training and/or experience in the field, under supervision of a licensed professional or through completion of an approved training program, in order to become fully licensed.

Training requirements are meant to ensure that services provided within a licensed occupation meet a minimum standard of quality; however, training requirements can limit portability and cause problems for workers who may otherwise be qualified to enter a profession.

Continuing Education Requirement

In order to help safeguard life, health and property and to promote public safety, state licensing boards require continuing professional competency in the form of continuing education (CE) courses. Licensees are required to complete a specific number of CEs, set by the board and statute, in order to renew their license. Continuing education requirements help keep professionals informed of innovations and updates in their fields as well as current trends or issues that may arise. For instance, the heroin and opioid epidemic has led to continuing education requirements that prescribers must complete.

Application & Renewal Fees

Pursuant to statute, each Board is required to support its operations from the revenue it generates from fees, fines and civil penalties. The Boards are also statutorily required to increase fees if the revenue raised by those fees, fines and civil penalties is determined to be insufficient to meet expenditures over a two-year period.

For those applying for licensure, initial application fees are reflective of the actual costs associated with processing each application. For the day-to-day operating expenses of each board – which includes administrative, legal and investigatory oversight – revenue is derived primarily from the biennial renewal fees paid by licensees to renew their license every two years. This creates less of a burden for individuals initially entering a profession than for individuals who are already licensed and have been practicing.

Fees are established through regulation. When considering changes to its fees, each Board generally projects costs and expenses over a six-year (three biennium) period.  If increases are necessary, the Boards may seek graduated increases (as opposed to a flat fee increase) to ensure that the fees charged will coincide more closely with the proposed expenses for each biennium.

Ultimately, this fee structure benefits every citizen in that it ensures the fiscal integrity and continuing operation of each Board moving forward, thereby enabling each Board to carry out its duty to license and regulate the various professions.


Analysis & Recommendations

For comparative analysis, the national average was calculated for each of the criteria measured. Where Pennsylvania licensure requirements exceed the national average, it is recommended that the state board review the requirement to justify that it is necessary to protect the public from harm and is not creating a barrier to entry for professionals.

Education (Degree) Requirement

The analysis found that Pennsylvania education requirements for licensure are equivalent, or less stringent, than the national average for each occupation analyzed. There are no recommendations for this licensure requirement.

Examination Requirement

The analysis found that Pennsylvania examination requirements for licensure are equivalent, or less stringent, than the national average for each occupational analyzed. There are no recommendations for this licensure requirement.

Training & Experience Requirement

Pennsylvania had less stringent training and experience requirements than the national average for 90% of the occupations analyzed. There were only seven occurrences, as outlined on the next page in Table 7, where Pennsylvania had a higher amount of training hours or years requirement than the national average.

It is recommended that the licensing board governing each profession examine the existing training/experience requirement to determine if the excess hours/years are necessary to specifically fulfill a public health, safety or welfare concern. If not, the requirement should be reduced to stay consistent with the national trend.

Table 7: Training/Experience Requirements higher than the U.S. Average

License TypeName of Licensing BoardPennsylvania
National Average Training/Experience
Apprentice AuctioneerState Board of Auctioneer Examiners2 years1.45 years
AuctioneerState Board of Auctioneer Examiners2 years1.35 years
Barber InstructorState Board of Barber Examiners5 years1.88 years
Massage TherapistState Board of Massage Therapy600 hours572 hours
PhysicianState Board of Medicine2 years1.40 years
ProsthetistState Board of Medicine2 years1.06 years
Public Health Dental Hygiene PractitionerState Board of Dentistry3,600 hours3,225 hours
Real Estate BrokerState Real Estate Commission3 years2.33 years

Continuing Education Requirement

Overall, Pennsylvania's Continuing Education (CE) requirements are largely in line with the national trend. CE hour requirements for licensure renewal are below the national average for 88 percent of the occupations analyzed. Table 8 shows the cases where Pennsylvania exceeds the national average for continuing education requirements.

It is recommended that the licensing board governing each profession examine the existing continuing education requirement to determine if the excess hours are necessary to specifically fulfill a public health, safety or welfare concern. If not, the continuing education hour requirement should be reduced to stay consistent with the national trend.

Another recommendation would be to repurpose continuing education hour requirements to concentrate on current issues in the profession. For example, the State Board of Nursing Home Administrators repurposed 12 of the 48 CE hours required for licensure renewal - with 6 clock hours dedicated to infection control and another 6 clock hours dedicated to emergency preparedness.

Table 8: Continuing Education Requirements higher than the U.S. Average

License Type 
Name of Licensing Board
Continuing Education
National Average
Continuing Education
Doctor of Podiatric MedicineState Board of Podiatry50 hours44 hours
GeologistState Board of Engineers, Geologists,
and Land Surveyors
24 hours9 hours
Massage TherapistState Board of Massage Therapy24 hours18 hours
Nursing Home AdministratorState Board of Nursing Home Administrators48 hours37 hours
Osteopathic PhysicianState Board of Osteopathic Medicine100 hours54 hours
Osteopathic Physician AssistantState Board of Osteopathic Medicine100 hours78 hours
Physical Therapy AssistantState Board of Physical Therapy30 hours24 hours
Physician/SurgeonState Board of Medicine100 hours50 hours
Registered NurseState Board of Nursing30 hours23 hours
Respiratory TherapistState Board of Medicine30 hours20 hours

Initial Licensing & Renewal Fees

Pennsylvania's fee change structure skews its fees in relation to comparison states. For this study, the initial licensing fee comparison excludes, examination fees, background check fees, and finger printing fees.

Pennsylvania’s initial licensing fees are lower than the national average for 91% of the occupations analyzed. 

Pennsylvania's renewal fees are lower than the national trend for 76% of the occupations analyzed. Please see Table 10 for the occurrences where Pennsylvania exceeds the national average. It is recommended that the licensing board governing each profession examine the excess licensing fees to determine if the fees are justified in order to process initial and renewal licensing applications.

Table 10: Licensure Renewal Fees higher than the U.S. Average

License Type
Name of Licensing Board
Renewal Fee
National Average
Renewal Fee
AuctioneerState Board of Auctioneer Examiners$260$221
BarberState Board of Barber Examiners$109$86
Barber InstructorState Board of Barber Examiners$174$112
Certified Registered Nurse PractitionerState Board of Nursing$122$111
CosmetologistState Board of Cosmetology$67$64
Cosmetology TeacherState Board of Cosmetology$105$71
Crane OperatorState Board of Crane Operators$130$114
Esthetician InstructorState Board of Cosmetology$105$82
Funeral DirectorState Board of Funeral Directors$400$228
Nail TechnicianState Board of Cosmetology$67$60
Nail Technician InstructorState Board of Cosmetology$105$79
Natural Hair BraiderState Board of Cosmetology$67$65
Natural Hair Braider TeacherState Board of Cosmetology$105$68
Registered NurseState Board of Nursing$122$112
Vehicle SalespersonState Board of Vehicle Manufacturers,
Dealers, and Salespersons
VeterinarianState Board of Veterinary Medicine$360$279
Veterinary TechnicianState Board of Veterinary Medicine$100$88


To summarize, the report found that Pennsylvania is on pace with the national trend for education and examination requirements for occupational licensure. Additionally, Pennsylvania's training and continuing education requirements were equivalent or less stringent than the national average. Furthermore, initial licensing and renewal fees for Pennsylvania licenses were found to be typically less than the national average.

The intent of this analysis is to identify opportunities for state officials to remove unnecessary barriers that prevent Pennsylvanians from gaining employment without compromising the health and safety of residents. The report should be used as a resource when officials evaluate the health and safety protections associated with licensure against the impact of restrictions on Pennsylvania works and businesses.

The twenty-nine individual board reports featuring the 50-state comparison for licensed occupations can be found in Appendix B.



Below is a list of terms that are featured in the 50-state comparison report that may be unfamiliar:

Licensure by Credentials - Issuing a license using a performance record in place of examinations

Mutual Recognition - An agreement between states that allows an individual to be licensed in another state in most cases by taking the reciprocal state's exam

Licensure by Waiver – State boards may waive certain requirements for expedited licensure for professionals from other states (usually in times of emergency)

Licensure without Examination – When a state board waives the examination requirement for licensure



For more information on occupational licensing in Pennsylvania, please visit the Department of State's website.


Licensure Guides & Timelines

The Department of State, in carrying out its mission to protect, preserve and improve the health and safety of Pennsylvania's citizens through the licensing and regulation of occupational and health professionals, developed a series of professional licensing guides to provide transparency, inform applicants of expected timeframes in receiving their license, and outline steps one can take to reduce mistakes and mitigate delays. Licensure guides have been developed for the following occupations:

  • Barber
  • Cosmetologist
  • Engineer
  • Physician & Surgeon
  • Graduate Medical Trainee
  • Physician Assistant
  • Osteopathic Physician & Surgeon
  • Osteopathic Graduate Medical Trainee
  • Osteopathic Physician Assistant
  • Registered Nurse
  • Pharmacist
  • Real Estate Salesperson
  • Real Estate Broker
  • Social Worker

To provide the greatest clarity on the licensing process from start to finish, the guides are broken down into three phases, providing estimated times for each stage of the process, and recommendations for how to reduce processing times.

  • Phase One measures the time between a submitted application or graduation from an educational program and the initial determination of the status of the application by Department staff. Determinations issued in this phase may include authorization to take a required exam, a notice of missing information or an incomplete application, or that a payment is needed.
  • Phase Two measures the time that it takes for an applicant or third-party entity to respond to the Department with all application requirements. This phase may include the applicant preparing for and taking an exam, third-party institutions providing education or training documents, background checks, or completion of training hours by the applicant.
  • Phase Three measures the time between the Department's receipt of a complete application, including examination results, confirmation of training hours, and results of background checks, and when a license is issued or denied to an applicant.

Appendix A: Licensee Population in Pennsylvania (As of March 2021)

Name of Licensing BoardLicense TypeCount
AccountancyCertified Public Accountant27,517
AccountancyPublic Accountant106
ArchitectsRegistered Architect9,086
Auctioneer ExaminersApprentice Auctioneer179
Auctioneer ExaminersAuctioneer1,552
Auctioneer ExaminersTrading Assistant36
Barber ExaminersBarber3,278
Barber ExaminersBarber Manager2,506
Barber ExaminersBarber Teacher276
Certified Real Est. AppraisersCertified Broker Appraiser299
Certified Real Est. AppraisersCertified General Appraiser1,436
Certified Real Est. AppraisersCertified Pennsylvania Evaluator593
Certified Real Est. AppraisersCertified Residential Appraiser1,739
Certified Real Est. AppraisersLicensed Appraiser Trainee336
CosmetologyCosmetology Apprentice48
CosmetologyCosmetology Teacher7,242
CosmetologyEsthetician Teacher35
CosmetologyNail Technician14,400
CosmetologyNail Technician Teacher14
CosmetologyNatural Hair Braider49
CosmetologyNatural Hair Braider Teacher2
Crane OperatorsCrane Operator3,202
DentistryDental Hygienist9,559
DentistryExpanded Function Dental Asst2,945
DentistryPublic Health Practitioner937
EngineersEngineer in Training17,334
EngineersGeologist in Training329
EngineersProfessional Engineer30,417
EngineersProfessional Geologist2182
EngineersProfessional Land Surveyor1796
EngineersSurveyor in Training328
Funeral DirectorsFuneral Director3099
Funeral DirectorsFuneral Intern83
Funeral DirectorsFuneral Supervisor1276
Funeral DirectorsFuneral Trainee397
Landscape ArchitectsLandscape Architect1,017
Massage TherapyMassage Therapist8,045
MedicineAcupuncture Supervisor147
MedicineAthletic Trainer3,390
MedicineBehavior Specialist4,074
MedicineGenetic Counselor552
MedicineGraduate Medical Trainee7,656
MedicineGraduate Orthotist11
MedicineGraduate Prosthetist11
MedicineMedical Physician and Surgeon54,562
MedicineMedical Physician Asst10,589
MedicineOrthotic Fitter213
MedicinePhysician Acupuncturist141
MedicinePractitioner of Oriental Medicine245
MedicineRadiology Technician40,083
MedicineRespiratory Therapist7,408
Navigation CommissionPilot- Fifth Class3
Navigation CommissionPilot- First Class35
Navigation CommissionPilot- Sixth Class1
NursingCertified Registered Nurse Practitioner16,191
NursingClinical Nurse Specialist265
NursingDietitian-Nutritionist (LDN)4,459
NursingGraduate Practical Nurse Permit374
NursingGraduate Registered Nurse Permit722
NursingPractical Nurse50,434
NursingRegistered Nurse231,625
Nursing Home AdministrationAdministrator in Training56
Nursing Home AdministrationNursing Home Administrator1,755
Occupational TherapyOccupational Therapist9,768
Occupational TherapyOccupational Therapy Assistant3,903
OptometryOptometrist-Therapeutics and Glaucoma2,396
Osteopathic MedicineAthletic Trainer301
Osteopathic MedicineGraduate Osteopathic Trainee2,281
Osteopathic MedicineOsteopathic Acupuncturist98
Osteopathic MedicineOsteopathic Acupuncturist Supervisor26
Osteopathic MedicineOsteopathic Genetic Counselor25
Osteopathic MedicineOsteopathic Perfusionist35
Osteopathic MedicineOsteopathic Physician Acupuncturist51
Osteopathic MedicineOsteopathic Physician and Surgeon9,225
Osteopathic MedicineOsteopathic Physician Assistant2,644
Osteopathic MedicineOsteopathic Respiratory Therapist507
PharmacyAuthorization to Administer Injectables for Pharmacist11,356
PharmacyAuthorization to Administer Injectables for Pharmacy Intern239
PharmacyPharmacy Intern4,424
Physical TherapyPhysical Therapist15,240
Physical TherapyPhysical Therapist Assistant5,995
PodiatryDoctor of Podiatric Medicine1,431
Real Estate CommissionAssociate Broker3,834
Real Estate CommissionBroker Multi-Licensee3,566
Real Estate CommissionCemetery Associate Broker4
Real Estate CommissionCemetery Broker of Record48
Real Estate CommissionCemetery Salesperson419
Real Estate CommissionManager of Record1
Real Estate CommissionReal Estate Salesperson44,631
Social WorkClinical Social Worker7,422
Social WorkMarriage and Family Therapist894
Social WorkProfessional Counselor9,676
Social WorkSocial Worker8,549
SpeechSpeech Language Pathologist8,391
Vehicle BoardVehicle Representative1,245
Vehicle BoardVehicle Salesperson34,613
Veterinary MedicineVeterinarian5,257
Veterinary MedicineVeterinary Technician2,973
TOTAL 921,04