Parts I and II Plus NERCOATS After a Failed Part III
Marcus has passed NBEO Part I in 2020, Part II in 2022, and NERCOATS in 2021. He took NBEO Part III in 2023 and 2024 and failed both times. He applies for NY licensure and submits passing reports for Part I, Part II, and NERCOATS. He does not submit a Part III pass. The examiner notes that NERCOATS was taken before Part II and asks whether the combination is valid. Marcus's employer says he must start in two weeks. Marcus asks whether he can be licensed on the basis of the three passes or whether he must pass Part III. He has all education and additional requirement certificates. The file contains official Part I and Part II reports, but the NERCOATS report was sent only to another state and Marcus has a candidate copy.
1. Analyze whether Marcus meets NY's examination requirement.
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NY accepts either (a) NBEO Parts I, II, and III or (b) Parts I and II plus NERCOATS. Marcus has Part I, Part II, and NERCOATS. The failed Part III attempts do not erase the alternative pathway. The regulation does not, on its face, require NERCOATS to be taken after Part II; sequence is not the test.
The examiner should verify that the NERCOATS report is the specific examination accepted by NY, that it is an official score report sent to NYSED, and that all three passes are valid. If those are confirmed, Marcus meets the examination requirement despite no Part III pass. If NERCOATS is a different exam or the score was never officially reported, the combination fails.
2. What if the Department's records show Marcus's NERCOATS score was reported to another state and never to NY?
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A candidate's copy is not the same as an official report. Marcus must request that the NERCOATS score be transmitted directly to NYSED. He should also confirm the name and ID match. Until the official report is in the file, the Department cannot credit it. He can submit a copy to show good faith, but the examiner should not approve on an unofficial copy.
3. Can Marcus practice before the license is issued?
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No. Passing exams does not authorize practice. He needs a license, or if he qualifies, a limited permit. A limited permit is generally for a candidate who has met education and other requirements but is awaiting exam results; Marcus has already satisfied the exam pathway, so his issue is administrative issuance. He should not see patients until the license or a valid permit is in hand. He can perform non-clinical duties that do not constitute optometry.