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