Hour Reduction but Expanded Curriculum?

Because this hour reduction removes 500 hours from the current program, the assumption would be that the curriculum is reduced. However, the curriculum has been expanded to include straight razor shaving, extensive skin care services such as electrical facials and extractions, camouflage and special occasion makeup, lash perming and extensions, body treatments, aromatherapy, lightening of body hair, chemical hair removal, and threading – all of which are not part of the 1500-hour curriculum. This is nonsensical. When other states have reduced hours, they have removed requirements instead of adding new ones. New York has offered a 1000-hour Cosmetology program for years but only require 60 hours of skin and 40 hours of nails, for a total of 100 hours. VA’s proposed curriculum requires 345 hours of skin and nails, more than triple the amount.

No Avenue for Hairstylists

Virginia does not have a Hairstylist license. We have advocated for the addition of this license during the legislative process for years, but it has not been implemented. Students seeking to learn how to be a hairstylist have historically enrolled in a Cosmetology program because there is no alternative option in a school environment. Therefore, the large majority of the 1500-hour program has been spent on hair-related subjects to satisfy this demand and prepare students for a successful career in the hair salon industry. Because of the expansion of the curriculum to include emphasis on skin, nails, waxing and shaving, the number of hours spent on hair under the proposed regulations is reduced to 505. This is a nearly two-thirds reduction in training on the subjects most needed for a successful career as a hairstylist. Students interested in esthetics will pursue an Esthetics or Master Esthetics program. Students interested in nail will pursue a Nail Tech program. Students interested in hair will be forced to be a “jack of all trades, a master of none.”

Effective Date Too Soon

These changes to the Cosmetology curriculum and required hours are set to be effective 9/1/2024. This is not reasonable for schools to implement. The process of getting a new program approved can take several months to a year. We first have to completely overhaul our curriculum and reformat it, especially with the expanded curriculum and new practical requirements. This will take significant time and resources to get accomplished once the regulatory process is completed. Then we have to get that new program/curriculum approved through the Board before we can submit an application for a new program to SCHEV. Then we must wait for SCHEV approval before submitting our application for accreditor approval. After our accreditor approves the new program, we have to submit it to the Department of Education to get approved before we can add the program to our catalog and begin offering it to our prospective students. Schools also need time to inform prospective students of the upcoming changes. We’ve been communicating with prospective students for our fall classes for over a year. In some cases, students have already signed contracts for a 1500-hour program this fall. In states that have reduced the hours in recent years, such as Texas, they have allotted a full year for schools to implement the new program, which is a reasonable timeframe. If you implement these changes on 9/1/2024, you will have a complete halt of enrollment in Cosmetology programs at the busiest time of the year for enrollment while schools wait months on these approvals to go through. This will put Cosmetology schools out of business.

Effective Date puts Students at Risk of Losing Federal Student Aid due to 150% Rule Elimination

As of July 2024, the Department of Education has eliminated the 150% rule, which allowed schools to offer programs exceeding the state minimum hours requirement up to 150% of the state hours. This means that previously schools in states requiring 1000 hours of Cosmetology would be allowed to continue to offer a 1500-hour program. However, with the elimination of that rule, schools are limited to the exact number of hours that the state requires, meaning that as soon as the state reduces the hours, our 1500-hour program will not be approved by the Department of Education. This puts even our current students at risk in terms of the funding of their education. There are huge implications to lowering state hours at this critical juncture. Schools must be able to inform students accurately of what portion of the tuition their federal student aid can be reasonably expected to cover. Without significant lead time on the hour reduction, schools are unable to inform students prior to signing a contract of what their costs may be.

State & Federal Governments At Odds; Puts Schools and Students in No-Win Situation

DPOR has admitted that their goal is to set minimum safety standards in order to protect the public, not to train students to be successful in the profession. In an email dated April 6, 2022 to the Regulatory Advisory Panel, the panel members were tasked with a list of “20-25 training topics for you to identify whether there are safety risks involved, whether training is the least restrictive way to address that risk, and the least number of hours needed to train a student to perform that service safely. This last item we call ‘minimum competence,’ and should be thought of as a minimum training for safety, not skill level or professional performance.”

However, the Department of Education believes that when a state arrives at a minimum number of required education hours, the state has made a reasonable judgment about how many hours it takes to be trained and ready to work in a profession.[1]

The phrase above, pulled from an article on the elimination of the 150% Rule, is the perfect example of the dilemma our industry faces when we are caught between state and federal government agencies. The state thinks they are setting a minimum for safety, but because of the federal Department of Education, the state is actually setting a maximum. This process was started before the Department of Education made changes and DPOR needs to take that into consideration before revising current programs. The Department of Education expects schools to train students to be successful in the industry and to find gainful employment in the profession, to the extent that the Gainful Employment regulation holds schools responsible for the income a student makes post-graduation. How are schools expected to improve employment outcomes while being forced to spend less time on marketable skills? The ability for a graduate to avoid burning or cutting a client when performing a service has little bearing on their success in the industry if they’re unable to give a client the desired cut and color. That graduate will not be successful or remain in the industry. This dilemma will result in the closure of Cosmetology schools in Virginia as a direct result of these changes.

Makeup is Not a Regulated Profession

Why are there required makeup hours in the Cosmetology curriculum when Makeup Artist is not a regulated profession in Virginia? Forcing schools to spend 35 hours on Makeup doesn’t align with the fact that someone can work as a Makeup Artist without a license. If it’s unsafe to perform makeup without 35 hours of instruction for a Cosmetologist, then it should be unsafe for an unlicensed Makeup Artist to do so. This section of the curriculum should be removed due to inconsistency.

Not Solving Any Problems

This regulation was started because of a need for more stylists in the industry, but removing a third of a student’s education will make a huge impact on their career trajectory. This 33% reduction of total hours (realistically closer to 60% reduction for hairstylists) could mean the difference between a student working for minimum wage as an assistant, not being able to make a living or advance their career, and quickly burning out of the industry versus a student having the training and skills to work behind the chair right out of school and open up their own salon. There is value in education. By taking away education from our students/graduates, we are reducing their value in the workforce. We want our students to not only graduate, get licensed, and work in the field, but most importantly to make a living to support their families. We fear that by devaluing our students by reducing their education, this will lead to devalued pay, high turnover, and high industry attrition rates.

Increased Burden on Salon Owners

Salon owners will bear the burden of providing education to make up for the missing hands-on training as well as increased costs to fix mistakes from lack of practical experience. Small businesses need and want graduates who are prepared to work behind the chair immediately.

Reduced License Portability

Because a majority of the states have Cosmetology at 1500 hours or higher, including ALL of our bordering states (Maryland, North Carolina, Tennessee, Kentucky, and West Virginia), having a 1500-hour program makes it much easier to transfer educational hours and licenses to nearby states. Reducing the hours to 1000 will create increased difficulty for transient students.