COMMENT FOR REGULATORY REVIEW

Consumer who are seeking esthetic and master esthetic procedures are expecting that because this is a state regulated profession, where individuals must achieve licensure status prior to operating within the industry, that the state has made all good faith efforts to ensure the health, safety, and welfare of the citizens of the Commonwealth of Virginia, as required by Virginia code.

Through research, we can confirm, there are not any identifiable deficiencies that are leading to threats to the health, welfare, and safety of the citizens of the Commonwealth of Virginia.  The investigations division does not have an onslaught of open cases where estheticians and master estheticians are injuring clients. Employers are hiring graduates who can begin work right away without any employer training programs.  Current school programs are providing sufficient education to ensure safety and the ability serve the demands of consumers as a direct result of the required hours and curriculum topics in the regulations.  

In short, the regulations and curriculum requirements that lead to the ability to sit for the licensure examination are meeting its intended goal.

Additionally, through our extensive research, we have confirmation from employers that they do not want to incur the additional expense associated with additional training or have the desire or ability to develop and enact new hire training programs to rectify any deficiencies that new hires that would incur as a direct result of curriculum reductions or hour reductions. Employers specifically want to continue to receive the ability to hire candidates at the current level of educational attainment provided by the current regulations.  Employers want to be able to continue to provide safe and effective treatments to their patrons.

Since there is factual proof that the regulations are meeting the intended goal, the regulations do not need to be changed. 

We ask that the board consider this reliable and valid factual data and research and not make any changes to the regulations.

ESTHETIC PROGRAM DISCUSSIONS IN CONSIDERATION

There has been discussion of restricting online theory topics, reducing the hours in esthetics and master esthetics in the last board meeting and even there has been discussion of merging master esthetics into esthetics in the last board meeting. I will now make comment as to why this could be problematic for the health, welfare, and safety of the citizens of the Commonwealth of Virginia, why this would present obstacles and barriers to entry into to the profession and harm student in or applying to schools.

Additionally, all would require a change to the code of Virginia and the associated regulations.    

ONLINE THEORY TOPICS

The Board approved non-traditional or “online” instruction guidance document revision on September 17, 2020, states that it is “allowing schools to teach online instruction for theory topics in a school- approved curriculum”.

This is a concerning statement because there is nothing in Virginia code that prohibits online theory.

• There is no movement to restrict the amount or certain topics for community colleges or universities in the state of Virginia (or nationwide) why are career college and vocational students being discriminated against in the state of Virginia?
• As a textbook author for the industry, I am and privy to the fact that beauty school textbooks are written on the 8^th grade level. This is further supporting that no restrictions or limitations should be imposed on theory online education as it is lesser academic level than community college and university level academic topics and beauty school students should not be discriminated against. 
• Students should be able to receive as much theory education online as possible.  It helps them with schedule flexibility and ability to work a job and handle family responsibilities and reduces childcare expenses.   It reduces out of pocket expenses for students traveling to school and makes education easier to obtain.  Some students would not be able to attend school without it.

HOUR REDUCTION SAFETY ISSUES

• Reducing the hours results in reduction in the amount of education delivered.  This in turn reduces the preparedness of graduates entering the field and their ability to be prepared to protect the health welfare and safety of the citizens of the Commonwealth of Virginia while delivering services.
• Since the implementation of the curriculum the industry has grown not retracted and therefore schools have been responsible for adding in components not reducing components.
•  It would be unreasonable to expect school administrators to reduce the number of hours when the amount of topics schools are required to teach have only increased. 
• Employers want to provide services to customers they do not want to provide additional education to new hires.  

COMBINING BASIC AND MASTER PROGRAMS

Our concerns are that we want to ensure any decisions that are made are done so with information that is valid and reliable by individuals who are fully capable of doing so without bias or the perception of bias. Our first-hand observations have been contrary to that effect on many occasions during both board and committee meetings.

For example, at the last meeting “Board Member X” (name redacted) stated to the effect that “master esthetics should be dissolved because people can’t afford to go to the next level”.  “Most people can’t afford to do both.”

This is very concerning to the Esthetician Community.

This is akin to stating because not everyone can afford to be an RN, and they can only afford to be a CNA that we should no longer have RNs programs. Are we now reducing RN programs, hours and curriculum requirements due to concerns that people can’t afford an RN education?

In the last meeting, “Board Member X” (name redacted) also made comments that there were “no employment opportunities for basic estheticians”, another reason to dissolve master esthetics programs. This is a concerning statement as well. 

There are many job opportunities for graduates of schools who work with basic esthetician employers. Many schools and schools such as the Aveda Institute, focus on basic esthetics and have great job placement assistance success rates.  Many are accredited and those rates are published.

Clinical/medical spas employers only choose to hire master level graduates because that fits their business model. Just as they must hire an RN to perform certain procedures, not a CNA.

There has been a surge in basic body/facial care businesses, waxing bars, and lash bars in the recent years, and taking away the ability for individuals to “choose” to not push themselves to the “RN level” (master) would be detrimental to people’s ability to choose what level of education they wish to pursue and what investment they wish to incur.

Our school has been in operation for 19 years, we have students who begin wanting to work at the clinical medical level, but change their minds or realize through struggles of barely passing basic esthetician coursework that they are not academically prepared to continue to the master level and are very satisfied with staying at the basic level and happy with their employment options.

What is most concerning about this discussion is removing the ability to have a choice.

The master esthetics textbook and academic content rigorous and is not something to be taken lightly. As a school administrator I can attest to the fact that not everyone would be able to pass the master class topics no matter where they were positioned program wise, and not everybody is interested in those topics. Just as we find with CNA vs RN educational content.  Forcing individuals to pursue academic levels that they would not be successful in would result in them failing the entirety of the program.

As the individual who helped initiate laws for esthetician licensure and the regulations, this was a very clear concept that was discussed during the legislative process.  At the request of legislators, this led to the development of the basic versus master level licenses. It also was very clearly stated by the legislators that academically these were two separate educational attainments and the risk level of the master level treatments required separate and extensive dedication to those topics to allow for choices for people who did not want to go to the master level. 

Removing choices would be akin to forcing everyone to go to Harvard or become an RN.

Removing this choice also reduces the quality of the Harvard education for those who are ready and willing to take on that level academic rigor.

Neither of these scenarios seems to be the best interest of people or their ability of people to make a choice.

CLOSING STATEMENTS

• The esthetician regulations are meeting their intended goal.
• Reducing the standards of excellence currently established and which have been working, will only bring risk to the health, safety, and welfare of the citizens of the Commonwealth of Virginia.  
• Reductions in hours or combining programs will only increase barriers into entry into the industry.
• Board decisions should be made with factual data.