Enforcement managers told the California State Board of Optometry that investigations of unlicensed practice are increasing and that the board’s continuing‑education audit program shows persistent noncompliance.
Staff reported an uptick in unlicensed activity cases in 2025, largely targeting nonresident ophthalmic lens dispensers—online sellers located outside California who ship into the state. Enforcement staff said many of those cases involve cosmetic contact lenses sold through social platforms and direct websites; staff said outreach and registration efforts have brought some operators into compliance, while others remain difficult to locate or to compel to register.
The board also heard that continuing‑education (CE) audits rose in the first quarter of the fiscal year. Enforcement staff performed 50 CE audits in that quarter, the largest number in more than a year; but only 66 percent of audited licensees passed, meaning 17 of 50 failed that quarter. Staff said the most frequent reason for failure was not completing the required number of hours (for many, simply not having the required 50 hours), rather than questions about whether courses were valid.
Enforcement staff asked licensees to use available tools—such as CE tracking services—and warned that the board will continue audits, outreach, and citations. Staff said citation revenue from CE violations has been a significant portion of the board’s citation receipts in recent years but emphasized the goal is higher compliance, not revenue.
Board members asked whether the cost of enforcement is covered by fines and whether staff can scale up audits. Enforcement staff said some citation recipients have registered and paid fines after outreach; the program is not always cost neutral, but recent years have produced citation revenue above $100,000, largely from CE enforcement.
The board discussed staffing and options to expand audits. Enforcement staff said they have added analysts to increase audit capacity and will continue outreach to reduce noncompliance.