I am writing to express concern about the mandated completion deadlines for students enrolled in the Board-approved 1,000-hour cosmetology program effective September 1, 2024, as well as the 1,100-hour barber, 400-hour master barber, and 1,500-hour dual barber/master barber programs. The guidance allows schools to continue enrolling students through November 30, 2025, yet requires those same students to complete their programs by July 31, 2026. These deadlines conflict with already established, legally binding enrollment agreements between students and the schools, which include program completion dates and contract end dates that coincide with DPOR approved program lengths. For example, a student beginning a DPOR-approved 50-week, 1,000-hour cosmetology program in November 2025 is scheduled to complete in November 2026, with a contract end date in January 2027. Forcing completion by July 31, 2026, would require the school to offer an unapproved, shortened program length, placing it out of compliance with DPOR and other regulatory agencies.

Schools cannot accelerate or compress the programs without violating approved program structures, altering contracted schedules, or exceeding permissible instructional limits established by SCHEV, accrediting bodies, and the U.S. Department of Education. Enrollment agreements are formal contracts, and schools are required to honor the full duration and completion expectations outlined within them. Students enrolling close to the November 30, 2025 deadline into programs explicitly authorized and approved by DPOR, must be permitted to complete their training according to those agreements (with DPOR approved program lengths) and within the institution’s teach-out obligations. Imposing a completion deadline of July 31, 2026 for cosmetology and barbering, or similar 2026 dates, creates a situation in which schools cannot remain compliant with multiple regulatory agencies simultaneously, including DPOR.

Extending the completion deadline for all affected programs to January 31, 2027 or a date based on the longest DPOR-approved program length would resolve this conflict. It would allow students to progress through their training at the approved pace, protect part-time students from being forced into accelerated instruction placing schools out of compliance, and ensure schools can meet both their contractual commitments and their teach-out requirements. This revised timeline supports fairness, consistency, and regulatory alignment while avoiding unintended harm to students who enroll during the period the Board has designated as permissible.

For these critical reasons, I respectfully request that the Board extend all applicable program teach-out deadlines to January 31, 2027, or a date consistent with the longest approved DPOR program.  This adjustment will ensure a smooth and compliant transition that protects students, maintains program integrity, and aligns DPOR's expected completion dates to already approved program lengths, while remaining compliant with SCHEV, accrediting agencies, and federal regulations.

Thank you for your consideration.

I'm asking for the Board to extend the deadlines given for completing programs that were still Board-approved as of November 30, 2025 to enroll new students. The admissions departments work with prospective students months ahead of their start dates, providing them with crucial information about the program, including the program length and scheduled completion dates. Students then sign contractually-binding enrollment agreements committing to that program that was presented to them by our admissions team. We pride ourselves on making sure the information we provide is accurate and not misrepresenting the programs we offer. Both parties entered agreements within the past several months with the full expectation that the school would be able to meet those contractual obligations to the student by providing the program that was approved and available at the time of signing. The completion deadline dates in this guidance document were not made public until more recently, after several classes of students had already committed to a program that according to these dates they will be unable to finish. This is harmful to students and to schools.

The Board is putting schools in a precarious position by creating a compliance conflict. Not only does accelerating the program in order for students to finish prior to the deadline violate our accrediting agency standards as well as the Department of Education requirements, but it violates DPOR's own standards since our program approvals contain the published program length. Schools are left with no options to maintain compliance while still meeting our contractual obligations.

Students must be allowed to continue in the program in which they enrolled, through it's scheduled completion date. Our school's longest program length is 50 weeks, for a 1000-hour part-time program at 20 hours a week, but if other schools have longer programs then the guidance document should be set accordingly. If the longest approved program is 50 weeks, then the earliest possible completion date for a part-time student with zero absences who enrolled by November 30, 2025 would be around November 30, 2026 when accounting for holidays and school closures. These students should be given until at least January 2027 to complete their program. 1500-hour Dual Barber/Master Barber students will need until November 30, 2027.

We appreciated the consideration of this concern last year when the 1500-hour Cosmetology program was being reduced to 1000 hours. Allowing those students who enrolled by 8/31/2024 to complete by 8/31/2026 was a reasonable deadline. Even with that deadline, there are a small number of students who may not be able to complete due to circumstances requiring a leave of absence from the program, such as pregnancy, but all students at least had the opportunity to complete based on their original signed enrollment agreement. I am asking for the same consideration for the current Cosmetology & Barber students. The small change of extending these deadlines will benefit the students by resolving these compliance conflicts. 

Thank you for your consideration of these extensions for the best interests of our students. 

This is in reference to the mandated completion dates and deadlines for Cosmetology Schools. The proposed deadlines for students to complete the courses they have already been enrolled in and approved for by the board are in direct conflict with a student's ability to complete their training according to approved enrollment agreements. 

Consideration must be made when adjusting the dates for student absences, and medical leaves. Part-time students previously enrolled will not be able to meet the deadline proposed by the board.

What is the alternative for the students who do not finish with the proposed dates? Are the students to be withdrawn and re-enroll for the remaining hours? This could cause schools to be out of compliance with their accreditors as schools are required to maintain completion, rates annually. Also, there is the concern of how this will affect the students funding if their education is interrupted. Schools reporting student status for NSLDS could be a problem as well.

We would request that the Board extend the proposed deadlines so all students will have the opportunity to complete the programs based on the enrollment agreement contract end date that is currently approved.

Thank you for considering these recommendations.

Linda Ingram

Staunton School of Cosmetology

We would like to raise significant concerns regarding the implementation timeline for the Barber hour reduction and its impact on accredited schools and their currently enrolled part-time students. We respectfully request that the Board reconsider the current deadline or, alternatively, provide a specific exception for accredited institutions.

At present, our understanding is that the Board’s standard recommendation for students unable to complete their program by the deadline is to transition into the new curriculum. Unfortunately, this is not a viable option for accredited schools. These students have already been packaged for Title IV financial aid based on the published program length and curriculum in place at the time of enrollment. Reducing the required hours changes the total program length and jeopardizes Title IV eligibility for those students. The only alternative suggested—“disenrolling” affected students—is not compatible with federal financial aid regulations, accrediting standards, or practical instructional operations. Revising a program mid-stream creates compliance vulnerabilities across multiple areas and places institutions in an untenable position.

In addition to the funding implications, transitioning students into a new curriculum after instruction has already begun presents substantial academic complexities. It also exposes schools to potential misrepresentation concerns, as we take great pride in ensuring that our Enrollment Team provides accurate and compliant information regarding program structure and length. A State-mandated shift that invalidates previously disclosed program expectations places institutions in direct conflict with federal requirements for consistency and accuracy in consumer information.

These concerns are not new. We raised similar issues in 2024 when the Board reduced Cosmetology hours from 1500 to 1000. At that time, the Board established an August 31, 2026 transition deadline specifically to protect students—particularly part-time students—who were already enrolled under the previous program structure. We greatly appreciated that thoughtful accommodation. Given that precedent, it is unclear why the same approach was not applied to the Barber hour reduction.

For these reasons, we respectfully request that the Board either:

1. Extend the transition deadline for the Barber program, or

2. Create an exemption for accredited institutions allowing currently enrolled students, especially part-time students, to complete the program in which they originally enrolled, with full retention of their financial aid eligibility.

We would sincerely appreciate the Board’s reconsideration, as the current timeline creates compliance conflicts that accredited institutions cannot resolve without placing students at risk.

The purpose of this letter is to highlight a serious issue created by the rollout schedule for the Barber hour reduction, particularly for accredited institutions and the part-time students who are already progressing through their programs. We are urging the Board to revisit its current plan—either by adjusting the transition deadline or by carving out an exemption for accredited schools.

Accredited institutions operate under federal rules that make mid-program changes extremely difficult. Students presently enrolled were awarded Title IV financial aid based on the published program length and curriculum that existed when they signed their enrollment agreements. When required hours are reduced after the fact, the official length of the program is altered, and those same students risk losing Title IV eligibility. Although the Board’s standard response has been that such students should just adopt the new curriculum, that is not an option for institutions bound by federal financial aid regulations and accrediting standards. The only alternative suggested—disenrolling students—is equally unworkable and would place schools out of compliance on several fronts.

The academic ripple effects are equally concerning. Reassigning students to a curriculum different from the one they began undermines instructional sequencing and raises potential misrepresentation issues. Our schools are required to provide accurate, consistent disclosures about program length and structure. A State-mandated change that effectively nullifies the information provided at enrollment creates a direct conflict with federal consumer information rules.

This is not the first time concerns like these have surfaced. When Cosmetology hours were reduced from 1500 to 1000 in 2024, the Board ultimately established an August 31, 2026 transition deadline in order to protect part-time students who were already advancing through the prior program. That decision was appreciated by institutions across the state. Given that history, it is difficult to understand why a parallel approach was not adopted for the Barber hour change.

In light of these issues, we respectfully ask the Board to consider one of the following actions:

1. Extend the transition timeframe for the Barber program; or

2. Allow accredited institutions to let currently enrolled students—especially those attending part-time—complete the program in which they originally enrolled, without jeopardizing their financial aid.

At present, the mandated timeline places accredited schools in an unavoidable compliance conflict and exposes students to academic and financial risk. We hope the Board will reconsider and provide a path that keeps all institutions aligned with state, federal, and accrediting requirements.

I am writing to express significant concerns regarding the implementation timeline for the Barber hour reduction and its impact on accredited schools and their currently enrolled students.  We strongly request that the Board reconsider the deadline or provide a specific exemption for accredited institutions.

At this time, we understand that any students that can't complete the program by the deadline should transition to the new curriculum.  However, this isn't practical or feasible for accredited school because these students have already been packaged for specific Title IV financial aid based upon the published program length and curriculum in place at the time they enrolled.  By reducing the required hours, it reduces the amount of Title IV eligibility for those students that have already begun the education with us.  We also understand that the Board's only recommendation is that we "disenroll" these studentsm which does not line up with Title IV regulations, accrediting standards or practical instruction considerations.  Our goal is to educate them to the point of obtaining a license in Barbering, and to disrupt their education plan jeopardizes that goal, as well as compliance we must adhere to in multiple areas, putting us in an untenable position.

Shifting the education program in the middle of a planned curriculum after a student has faithfully begun their education, expecting to achieve the same goals we have - to prepare them to get licensed - creates substantial academic complications.  Furthermore, this could place the school at risk of misrepresentation claims.  We go to great lengths to ensure that our enrollment team provides fully accurate and compliant information about program length and structure to anyone interested in enrolling.  A state-mandated change that invalidates previously disclosed program expectations puts institutions in direct conflict with federal rules requiring consistency and accuracy in consumer information.  Changes like this need to come with rules that allow sufficient time to properly be implemented.  

We raised similar concerns in 2024 when the Board reduced Cosmetology hours from 1500 to 1000.  At that time, the Board ultimately established a transition deadline of 8.31.26 to protect part-time students already enrolled under the previous program structure.  We greatly appreciate this consideration.  We are asking the same transition opportunity be given to the Barber program moving from 1000 to 750 hours.  

We respectfully request that the Board either:

1. Extend the transition deadline for the Barber Program, or
2. Create an exemption for accredited institutions allowing currently enrolled students, especially part-time students, to complete the program in which they originally enrolled, with full retention of their financial aid eligibility.

Thank you for your consideration in this matter and would appreciate your willingness to ensure that all students, including those in accredited programs, are protected during this transition.  Thank you

As a licensed individual in the industry with 17 years of experience, an educator for 7 years, and someone who has worked in school operations, financial aid, and compliance for 8 years, I want to express concerns regarding the implementation timeline outlined in the proposed guidance. I recognize that the hour reductions themselves have already been finalized and are not subject to change at this stage. However, the current timelines and completion deadlines surrounding these changes create challenges that were not fully anticipated and are already placing schools and students in a difficult position.

Students who enrolled through November 30, 2025 did so under Board-approved program lengths and signed enrollment agreements that extend well beyond the July 2026 completion requirement. For part-time students in particular, there is no feasible way to meet these shortened windows without altering instructional pacing in a way that conflicts with accrediting standards, federal financial aid regulations, and the program structures DPOR previously approved. The guidance makes it clear that schools may continue to enroll under the former program structures until November 30, yet the completion dates do not reflect the actual duration of those approved programs.

These students were awarded financial aid based on the curriculum in place at the time they enrolled. Changing required completion timelines mid-program compromises their eligibility and creates compliance complications with Title IV, accrediting bodies, SCHEV, and Board regulations. This is not simply an academic concern. It places institutions in a financial and operational bind. Schools must honor contracted program lengths, staffing plans, instructor allocations, and operational budgets that were built around the originally approved hours. Being required to compress or reconfigure instruction on short notice results in unplanned financial strain and added costs that were not accounted for when programs were approved and students were enrolled. It is difficult to justify this burden as fair or reasonable when both schools and students acted in good faith based on the approvals in place at the time of enrollment.

We encountered a similar scenario during the 2024 cosmetology hour reduction, and at that time the Board established an extended transition timeline that protected part-time students and allowed institutions to remain compliant. The same approach is needed here. While the hour change itself is final, the implementation plan can still be adjusted to prevent unnecessary compliance conflicts and financial impact.

For these reasons, I respectfully request that the Board reconsider the completion deadlines identified in the guidance and allow for a more reasonable transition period or provide an allowance for accredited schools to let currently enrolled students complete the program they committed to. This would support students, protect institutional compliance, and prevent the financial and operational strain that the current timeline creates.

Thank you for your time and consideration.

John McCown

I am writing on behalf of Paul Mitchell The School Roanoke in Roanoke, Virginia. My name is Natasha Greene and I serve as the Campus/Education Leader as well as a licensed Cosmetology Instructor and Master Barber Instructor. I have been actively involved in shaping our students’ educational experience and preparing them for successful careers in the beauty and barbering industries.

When cosmetology hour requirements were reduced in 2024, we inquired about any expected changes to barbering hours and were informed that no reductions were planned. Unfortunately, we now find ourselves facing yet another unexpected and challenging situation. This recent change to barbering hour requirements was made without sufficient notice, leaving no time for proper announcements, planning, or preparation.

As a result, several of our part-time students will be unable to complete their required hours by the July deadline. These students are frustrated and discouraged, as the reduction in hours does not appear to take into account the needs of those currently enrolled, who must still learn and demonstrate all required practical skills and competencies—now within a significantly shortened timeframe. The abruptness of this change has created unnecessary stress and has the potential to compromise the quality of their training.

On behalf of our students and our institution, I respectfully request that an extension be granted for current barbering students. Allowing additional time would ensure they can complete their assignments, practical requirements, and state competencies thoroughly and confidently, without the pressure of unrealistic time constraints.

Please consider the impact this situation has on our future barbers and provide them the opportunity to complete their education properly and without undue hardship.

Thank you for your attention to this matter.

Natasha Greene