We would like to express significant concerns regarding the implementation timeline for the Barber hour reduction and the challenges it presents for accredited schools and their currently enrolled part-time students. We respectfully request that the Board reconsider the current deadline or, alternatively, provide a defined exception for accredited institutions.
Our understanding is that the Board’s standard guidance for students unable to complete their program by the deadline is to transition them into the new curriculum. Unfortunately, this is not feasible for accredited schools. These students have already been awarded and packaged for Title IV financial aid based on the published program length and curriculum in place at the time of their enrollment. Reducing the required hours changes the official program length and jeopardizes Title IV eligibility for these students.
The alternate suggestion—disenrolling affected students—is not permissible under federal financial aid regulations, accrediting requirements, or practical instructional standards. Altering a program mid-progress introduces substantial compliance risks and places institutions in an impossible position.
Beyond financial aid implications, shifting students into a new curriculum after instruction has begun presents significant academic and operational challenges. It also raises potential misrepresentation concerns, as accredited institutions are required to ensure that all enrollment disclosures—program length, structure, and expectations—remain accurate and consistent. A mandated change that contradicts information provided at enrollment places schools in direct conflict with federal consumer-information standards.
These concerns mirror those we raised in 2024 when the Board reduced Cosmetology hours from 1500 to 1000. At that time, the Board established an August 31, 2026 transition deadline to protect students, particularly part-time students, who were already enrolled under the previous program. We were grateful for that thoughtful and student-centered accommodation. Given that precedent, it is unclear why a similar approach has not been applied to the Barber hour reduction.
For these reasons, we respectfully request that the Board either:
Extend the transition deadline for the Barber program, or
Provide an exemption for accredited institutions that allows currently enrolled students—especially part-time students—to complete the program in which they originally enrolled, with full retention of Title IV financial aid eligibility.
We would sincerely appreciate the Board’s reconsideration. As written, the current timeline creates compliance conflicts that accredited institutions cannot resolve without placing students at risk.