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Prepared Testimony before the
United States Senate Committee on the Judiciary
Subcommittee on Antitrust, Competition Policy and Consumer Rights
Hearing on “License to Compete: Occupational Licensing and the State Action Doctrine”
Jason Furman, Chairman, Council of Economic Advisers
February 2, 2016
Chairman Lee, Ranking Member Klobuchar, and Members of the Subcommittee: thank you for
the opportunity to appear here today to testify about occupational licensing. This is an important
economic issue, and one which only in recent years has begun to receive commensurate attention
from policymakers and analysts. When carefully designed, licensing can offer important health
and safety protections to the public and other benefits to workers. But there is a fine line to tread:
the ways that licensing policies are designed and implemented can also affect workers’ wages,
employment opportunities, and ability to move across State lines, as well as consumers’ access to
essential goods and services. In fact, occupational licensing sometimes functions as an unfair
barrier to competition, preventing the benefits of our economic growth from reaching the widest
range of households and workers.
My testimony today will draw on a recent report prepared by the Council of Economic Advisers
(CEA), the Department of the Treasury’s Office of Economic Policy, and the Department of
Labor, which reviews the evidence of the costs and benefits of licensing and recommends several
best practices for improving our system of occupational regulation. I will also describe our
Administration-wide efforts to reduce overly burdensome and unnecessary licensing.

The Prevalence of Licensing: National Increase, State Differences
Occupational licensing has grown substantially over the past several decades. As documented by
economists Morris Kleiner and Alan Krueger, the share of the U.S. workforce covered by State
licensing laws grew from less than 5 percent in the early 1950s to 25 percent by 2008 (Figure 1).
Although State licenses account for the bulk of licensing, the addition of local and Federal
licensed occupations further increases the share of the workforce that is licensed to 29 percent. 1

1

Morris M. Kleiner and Alan B. Krueger. 2013. “Analyzing the Extent and Influence of Occupational Licensing on
the Labor Market.” Journal of Labor Economics vol. 31, no. 2: S173-S202.

Figure 1
Share of Workers with a State Occupational License

Percent of the Workforce
28
24
20
16
12
8
4
0

1950s

1960s

1970s

1980s

1990s

2000

2008

CEA analysis shows that about two-thirds of this change stems from an increase in the number of
professions that require a license, with the remaining growth coming from changing composition
of the workforce (Figure 2).
Figure 2
Percent Licensed Over Time: Estimated and Counterfactual
Percent of the Workforce
35
Estimate Licensed
at the State Level

30
25

Holding Constant Fraction
Licensed by Occupation

20
15
10
5
0

1965

1970

1975

1980

1985

1990

1995

2000

2005

Licensing laws have expanded considerably to cover not only traditionally highly-licensed fields,
such as health care and law, but also ones such as sales, management, and construction (Figure
3).

2

Figure 3
Share of All Licensed Workers in the 12 Occupations
with the Most Licensed Workers
Health Care Practitioners
Education
Transportation
Sales
Management
Construction
Personal care
Protective Service
Health Care Support
Installation and Maintenance
Business and Financial
Production
0
3
6
9
12
15
18
Occupation's Share of All Licensed Workers (Percent)

Licensing practices also differ among States. States vary in the licensed share of their workforce,
ranging from a low of 12 percent in South Carolina to 33 percent in Iowa (Figure 4).

3

This pattern appears to largely reflect differences across States in which occupations require a
license. 2 According to estimates from the Council of State Governments, over 1,100 occupations
were licensed, certified, or registered in at least one State but fewer than 60 were regulated in all
50 States. 3 States also vary dramatically in their requirements for obtaining a license (Figure 5).
For example, Michigan requires three years of education and training to become a licensed
security guard, while most other States require only 11 days or less. South Dakota, Iowa, and
Nebraska require 16 months of education to become a licensed cosmetologist, while New York
and Massachusetts require less than 8 months. 4

2

Morris M. Kleiner and Evgeny Vorotnikov. 2015. “The Economic Effects of Occupational Licensing Among the
States.” Working Paper. Harris data. To see this, we used data from the Survey of Income and Program Participation
(SIPP) to test how State licensing rates would change if every State had the same occupation mix but kept their own
licensing rates within occupations. This resulting picture was very similar to the actual distribution of shares
licensed across States, indicating that differences in occupational mix are not the primary determinant of State
licensing differences.
3
Pamela L. Brinegar, and Kara L. Schmitt. 1992. “State Occupational and Professional Licensure.” The Book of the
States 567–80. Lexington, KY: Council of State Governments.
4
Dick Carpenter, Angela C. Erickson, Lisa Knepper, and John K. Ross. 2012. “License to Work: A National Study
of Burdens from Occupational Licensing.” Institute for Justice. https://www.ij.org/licensetowork.

4

The Benefits and Costs of Licensing
Like many economic policies, occupational licensing has benefits and costs. Licensing is usually
justified on the grounds that it improves quality and protects the public against incompetent or
dangerous practitioners. This argument is strongest when low-quality practitioners can
potentially inflict serious harm, or when it is difficult for consumers to evaluate provider quality
beforehand. Few people, for example, would feel comfortable traveling in a commercial plane
flown by an unlicensed pilot or having a medical procedure performed by an unlicensed
physician. In such cases, the costs to consumers and the public of choosing an incompetent
practitioner are large enough to justify an intervention in the labor market.
But when consumers choose a florist, a barber, or a decorator, there is considerably less potential
harm to the public on the line and it may be easier for consumers to evaluate provider quality on
their own. It is important to balance the potential quality-improving and safety-promoting
benefits of licensing against its potential costs in the labor market. Moreover, while the academic
literature has studied only a handful of specific licensing requirements, most empirical evidence
does not find that stricter licensing requirements improve quality, public safety or health. 5
Licensing can also have clear costs. Licensing requirements can create benefits for licensed
practitioners at the expense of excluded workers and consumers—increasing inefficiency and
inequality. While licensing requirements can lead to higher wages for those able to obtain a
license, they can also reduce employment opportunities and depress wages for excluded
workers. 6 This is especially problematic when obtaining a license requires paying large upfront
costs, including tuition and lost wages from educational requirements, which many low-income
workers cannot afford. Licensing laws also lead to higher prices for goods and services, in many
cases for lower-income households, which are not always justified by improved quality or public
safety.
The wide variation in licensing requirements at the State level also creates barriers that reduce
mobility across State lines. Moving to a new State can entail—among other things— fulfilling
new education, training, or testing requirements, as well as paying fees. CEA finds that workers
in highly licensed occupations are much less likely than other workers to move across State lines,
while these two groups differ only modestly in their likelihood of moving within a State (Figure
6). These barriers to mobility can prevent workers from matching with the jobs best suited to
their skills, which in turn makes our labor market less efficient, reducing productivity and wages.

5

For a review of the literature on the effects of occupational licensing on the labor market and quality, health, and
safety, see: The Department of the Treasury Office of Economic Policy, the Council of Economic Advisers, and the
Department of Labor. 2015. “Occupational Licensing: A Framework for Policymakers”
(https://www.whitehouse.gov/sites/default/files/docs/licensing_report_final_nonembargo.pdf).
6
For example, see Maya N. Federman, David E. Harrington, and Kathy J. Krynski. 2006. “The Impact of State
Licensing Regulations on Low-Skilled Immigrants: The Case of Vietnamese Manicurists.” American Economic
Review vol. 96, no. 2: 237-241.

5

Figure 6
Difference in Migration Rates of Workers
in Most vs. Least Licensed Occupations

Percent Difference
0.0
-5.0
-10.0

Between State
-15.0

Within State

-20.0
-25.0

All

Under Age 35

Age 35 or Older

Our licensing system places special burdens on certain populations. For example, it creates high
costs for military spouses, who frequently have to relocate across State lines. 7 Our licensure
system can also prevent immigrants from applying their training and work experience from
abroad to jobs in the United States. 8 In addition, licensing laws often contain blanket exclusions
for those with criminal records, regardless of whether their records are relevant to the job for
which they are applying. 9 As many as one in three Americans has some form of criminal record,
so these exclusions render a great number of individuals ineligible for a large share of jobs,
which in turn can perpetuate unstable economic situations. 10

Best Practices for Occupational Regulation
The relative magnitude of these costs and benefits depends on the specific circumstances for
each profession, so it is important for policymakers to weigh the costs and benefits of licensing
proposals in each instance. To that end, drawing on promising State policies, the Administration
has developed three sets of best practices that States can apply to ensure that their licensing

7

U.S. Department of the Treasury and U.S. Department of Defense. 2012. Supporting our Military Families: Best
Practices for Streamlining Occupational Licensing across State Lines
(http://www.defense.gov/home/pdf/Occupational_Licensing_and_Military_Spouses_Report_vFINAL.PDF).
8
Matthew Hall, Audrey Singer, Gordon F. De Jong, and Deborah Roempke Graefe. 2011. “The Geography of
Immigrant Skills: Educational Profiles of Metropolitan Areas.” State of Metropolitan America no. 33. The
Brookings Institution (http://www.brookings.edu/~/media/research/files/papers/2011/6/immigrantssinger/06_immigrants_singer.pdf).
9
The Legal Action Center. “After Prison: Roadblocks to Reentry: A Report on State Legal Barriers Facing People
with Criminal Records” (http://www.lac.org/roadblocks-to-reentry/main.php?view=law&subaction=4).
10
Rebecca Vallas and Sharon Dietrich. 2014. “One Strike and You’re Out: How We Can Eliminate Barriers to
Economic Security and Mobility for People with Criminal Records.” Center for American Progress
(https://www.americanprogress.org/issues/poverty/report/2014/12/02/102308/one-strike-and-youre-out/).

6

policies safeguard the well-being of consumers, while maintaining flexibility in the labor market
and opportunities for workers. 11
First, licensing restrictions should be closely targeted to protecting public health and safety,
and should not be overly broad or burdensome. For example, policymakers should refrain
from categorically excluding individuals with criminal records, and instead should only exclude
those individuals whose convictions are recent, relevant, and pose a threat to public safety.
Drawing on work done by the National Association of Criminal Defense Lawyers and the Legal
Action Center, we find that twenty-one States do not have standards in place governing the
relevance of conviction records of people applying for occupational licenses for most or all
occupations (Figure 7).

Second, States should create or strengthen “sunrise” review processes to facilitate a careful
cost-benefit analysis each time a new licensing law is proposed. Data collected by the Council
on Licensure, Enforcement, and Regulation indicate that 13 States have some sort of sunrise law,
while 32 States maintain a sunset process for existing licensing laws, and only 10 States have

11

See CEA et al. (2015) for a more detailed list of best practices.

7

both (Figure 8). 12 For example, since 1995, Maine’s Department of Professional and Financial
Regulation has conducted a sunrise review of any proposed legislation that would establish an
occupational licensing board or expand a current practitioner’s scope of practice. According to
Maine’s Department of Professional and Financial Regulation, only one occupation has acquired
licensed status in Maine in the past 15 years. 13

Finally, States should expand reciprocity agreements and harmonize licensing
requirements to increase workers’ mobility across state lines. For example, various

12

The Council on Licensure, Enforcement, and Regulation defines sunset and sunrise reviews as follows: “Sunset is
the automatic termination of regulatory boards and agencies unless legislative action is taken to reinstate them...
Sunrise is a process under which an occupation or profession wishing to receive State certification or licensure must
propose the components of the legislation, along with cost and benefit estimates of the proposed regulation. The
profession must then convince the legislators that consumers will be unduly harmed if the proposed legislation is not
adopted.” Council on Licensure Enforcement and Regulation. Sunrise, Sunset and State Agency Audits
(http://www.clearhq.org/page-486181).
13
Maine Revised Statutes Title 32 § 60-J (http://legislature.maine.gov/statutes/32/title32sec60-J.html); Maine
Department of Professional and Financial Regulation. 2015. Private Correspondence.

8

professions, including nurses, 14 physicians, 15 and physical therapists, 16 either have constructed
or are in the process of constructing their own interstate compacts. Ideally, however, States
would establish a compact that applied to a range of different professions.

Federal Reform Efforts
While licensing reform takes place primarily at the State level, the Administration is committed
to working with Congress and collaborating with States to make progress on this issue.
Following the release of the White House report in July, we have presented the report’s findings
and policy recommendations to a wide range of State policymakers, officials from State licensing
boards, members of professional organizations, and members of the think tank community.
The Administration has also worked with Congress, to reduce licensing burdens for veterans,
service members, and military spouses. Under the President’s direction, the Department of
Defense established the Military Credentialing and Licensing Task Force in 2012, and with its
help, thousands of service members have earned or are in the process of earning civilian
occupational credentials and licenses through partnerships with national certifying bodies. 17
Thanks in part to the leadership of Senators Blumenthal and Klobuchar, the President signed into
law the Veterans Skills to Jobs Act in 2012, which requires federal agencies to recognize
relevant military training when certifying veterans for occupational licenses. In addition,
building on First Lady Michelle Obama and Dr. Jill Biden’s call to governors in 2012, the
Administration has partnered with States to streamline State occupational licensing for service
members, veterans, and their spouses. 18 As a result of this call for action, and through the
Department of Defense’s efforts working side by side with the Department of Labor, the
Department of Veterans Affairs, and the States, over 54 laws have been enacted in nearly all 50
States that reduce licensing and credentialing barriers for military members and their families. 19
Over the coming year, we will continue to conduct outreach to help spur action at the State level.
The FY2016 Budget signed by the President included $7.5 million to support efforts by a
consortium of States to expand reciprocity for a range of occupational licenses.
14

National Council of State Boards of Nursing. “Nurse Licensure Compact” (https://www.ncsbn.org/94.htm).
Humayun J. Chaudhry, Lisa A. Robin, Eric M. Fish, Donald H. Polk, and J. Daniel Gifford. 2015. “Improving
Access and Mobility – The Interstate Medical Licensure Compact.” The New England Journal of Medicine vol. 372,
no. 17: 1581:1583.
16
American Physical Therapy Association. 2014. “Interstate Licensure Compact for Physical Therapy”
(http://www.apta.org/StateIssues/InterstateLicensureCompact/).
17
The White House. 2013. “Fact Sheet: Administration Partners with Industry to Get Service Members Credentialed
for High-Demand Jobs” (https://www.whitehouse.gov/the-press-office/2013/04/29/fact-sheet-administrationpartners-industry-get-service-members-credenti).
18
National Economic Council and Council of Economic Advisers. 2013. The Fast Track to Civilian Employment:
Streamlining Credentialing and Licensing for Service Members, Veterans, and their Spouses; Department of
Defense and States, Partnering to Support Military Families. “Removing Licensure Impediments for Transitioning
Military Spouses”
(http://www.usa4militaryfamilies.dod.mil/MOS/f?p=USA4:ISSUE:0::::P2_ISSUE:2).
19
Department of Defense Briefing. 4 December 2015. “DoD Credentialing Update to Office of Senator Barbara
Boxer.”
15

9

Conclusion
The rise of occupational licensing fits into a broader context of what appears to be the growing
importance of “economic rents.” 20 Economists define rents as the return to a factor of production
like capital, labor, or land that exceeds what is needed to keep that factor of production in the
market. Rents often result from unproductive “rent-seeking” behavior that limits competition in
the market. Sometimes the benefits of rents are worth that limited competition—such as in welldesigned occupational licensing systems and well-designed intellectual property regimes. But in
many cases, rents protect entrenched interests without providing broader societal benefit.
Removing overly burdensome licensing requirements is one example of a policy that can reduce
harmful rents, but there are others, such as limiting zoning and other land-use restrictions and
appropriately balancing intellectual property regimes. These types of policies can foster more
competitive markets, increasing efficiency while also reducing inequality.
Licensing reform is only a small part of the effort to raise incomes, improve access to
employment, and reduce inequality. But when the problem we are facing is so large, we cannot
afford to leave any stone unturned in addressing it. And we certainly cannot afford not to take
measures that would provide greater opportunities for Americans while making the economy
more efficient.

20

Jason Furman and Peter Orszag. 2015. “A Firm-Level Perspective on the Role of Rents in the Rise in Inequality”
(https://www.whitehouse.gov/sites/default/files/page/files/20151016_firm_level_perspective_on_role_of_rents_in_i
nequality.pdf); Jason Furman. 2015. “Occupational Licensing and Economic Rents”
(https://www.whitehouse.gov/sites/default/files/page/files/20151102_occupational_licensing_and_economic_rents.p
df).

10

References
Figure 1
Source: The Council of State Governments (1952); Greene (1969); Kleiner (1990); Kleiner
(2006); and Kleiner and Krueger (2013), Westat data; CEA Calculations.
Figure 2
Source: Kleiner and Krueger (2013), Westat data; Bureau of Labor Statistics; Current Population
Survey.
Note: To make the adjustment, we use Kleiner and Krueger’s estimates of the shares of Statelicensed workers in each occupation in 2008, and adjust for changes in occupational mix back to
1968, taking advantage of a historically consistent occupational classification system contained
in the Integrated Public Use Microdata Series version of the Current Population Survey. Meyer,
Peter B. and Anastasiya M. Osborne. 2005. “Proposed category system for 1960-2000 Census
Occupations.” U.S. Bureau of Labor Statistics. Working Paper 383; Alexander, J. Trent, Sarah
Flood, Katie Genadek, Miriam King, Steven Ruggles, Matthew B. Schroeder, and Brandon
Trample. 2010. Integrated Public Use Microdata Series, Current Population Survey: Version 3.0.
[Machine-readable database].
Figure 3
Source: Source: Kleiner and Krueger (2013) Westat data; Current Population Survey Outgoing
Rotation Group; CEA calculations.
Figure 4
Source: 2013 Harris Poll Interactive survey, reported in Kleiner and Vorotnikov (2013) and
Kleiner (2015).
Figure 5
Source: Source: Institute for Justice analysis, reported in Carpenter (2012).
Note: Sample of 102 lower- and middle-skill occupations. Hours averaged over all licensed
occupations from the sample of 102, by state.
Figure 6
Source: Census Bureau, American Community Survey 2010-2013; CEA Calculations.
Note: Number is calculated from an OLS regression controlling for race, citizenship, sex,
citizenship, number of children, marital status, education, income, year, and state. Ages 25 to 65
were included.
Figure 7
Source: National Association of Criminal Defense Lawyers; Legal Action Center; UST and CEA
tabulations.
Figure 8
Source: Council on Licensure, Enforcement, and Regulation (2015).

11