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.