Policy No. : 11-011
Purpose: To provide guidance regarding the advertisement by licensed optometrists of post-licensure certification issued to the optometrist by an entity other than the Board of Registration in Optometry.
Policy: An optometrist who holds a current license to practice optometry in the Commonwealth of Massachusetts may publicize post-licensure certifications issued to that optometrist by entities other than this Board, provided the optometrist does so in compliance with all applicable laws and Board regulations and does not engage in any form of misrepresentation or deceit.
Discussion: The Massachusetts Board of Registration in Optometry ("the Board" or "this Board") has the statutory authority to enforce initial licensure, scope of practice, and renewal requirements for the practice of optometry in the Commonwealth. Numerous private organizations now offer "certification" or "fellowship" status to licensed optometrists who meet specific experience, testing and/or educational requirements. Such post-licensure certifications have no relation to an optometrist's licensure status with this Board and this Board does not endorse, require or support any post-licensure certification process. Each Massachusetts licensed optometrist must continue to comply with all standards of practice and renewal requirements enforced by the Board to retain his or her authority to practice optometry in Massachusetts. See G.L. c. 112, s. 69; 246 CMR 2.00.
Although the Board does not endorse any certification process above the statutory requirements for licensure in Massachusetts, it recognizes that some licensed optometrists have obtained or will be obtaining such certifications. The purpose of this guideline is to clarify that a Massachusetts optometrist may publicize post-licensure certifications issued to that optometrist by entities other than this Board, provided the optometrist does so in compliance with all applicable laws and Board regulations including but not limited to, 246 CMR 3.07, 246 CMR 3.10, 246 CMR 3.11, and does not engage in any form of misrepresentation or deceit.
Board regulations at 246 CMR 3.07 require that an optometrist clearly identify him or herself as an "optometrist" or use the "OD" designation when engaging in the practice of optometry. Designations of post-licensure certifications issued by non-state entities may be listed after the "optometrist" or "OD" designation if the optometrist has completed all necessary steps to receive such certification and currently holds such certification.
Any designation used to describe the attainment of a post-licensure certification must clearly identify the entity issuing the certification. General designations, such as "Board Certified," without further identifying detail regarding the certifying entity, are not permissible because they fail to distinguish between certification of registration issued by this Board, which is the statutory pre-requisite to practicing optometry in the Commonwealth, and certifications issued by a private entity, which documents the successful completion of a voluntary process.
Any optometrist who lists a certification from an entity other than this Board must be able to verify that he or she has received such certification. The optometrist must be able to show continued studies to maintain certification and competency for continued use of the designation, when this is applicable and appropriate. Because it cannot be factually substantiated, at no time should an optometrist advertise that by having such designation that they are "better, superior, or more advanced," or any other superlative, compared to other licensed optometrists in the Commonwealth.
Should the Board or any member of the public have questions or want clarification concerning the listed certification, the optometrist should have available a complete description of the course of study and the agency from which it was obtained, and the optometrist should be able to provide this to the consumer. This may be done in writing or by directing the customer to the appropriate website. All optometrists are reminded that Board regulations prohibit false, misleading or deceptive advertising and the use of any designation that confuses the nature of the optometrist's practice. See 246 CMR 3.10; 246 CMR 3.11.