Public Comments for Events Organized by the FTC's Economic Liberty Task Force #00034

Submission Number:
Shari Miller
Initiative Name:
Public Comments for Events Organized by the FTC's Economic Liberty Task Force
Some licensing is critical from a public safety perspective and some from a consumer protection perspective. Some is pure protectionism. The issue continues to increase in complexity as the lines are getting blurred regarding higher education programs that lead to licensure and requirements of disclosing all the requirements of obtaining such licensure. Each state has unique requirements in many cases and higher ed institutions as of July 1 2018 are being required to disclose all the various state requirements of every program to every student or prospect in a professional licensure program. The main problem is that because these are state laws, there is no single source of information on the state requirements. As a result, each institution must spend many hours (100's at least) to try to determine the current requirements in an every changing landscape. This means that some students may not be able to practice their profession in certain states if their university did not provide the exact requirements.A central database accessible for free of all requirements would be welcomed by higher education institutions and students so that they know in advance of graduation where they may practice their profession. The other related aspect is that states should not be allowed to make the requirements more stringent or if they do, others can be grandfathered in. Today, holding a professional license actually limits professional mobility. I know this, I'm a lawyer and my license is not reciprocal in many states. Thanks for the ability to comment.