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:
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