I do not support this reduction in education for several reasons.

1. There are other avenues to licensure in Virginia through the apprenticeship program and the high school program. No one is forced into the school avenue, so why is the school avenue to licensure the one being targeted for reduction? Most students choose a school because they want a higher quality of education. Limiting that education is not fair to the student. 
2. It will reduce license portability drastically (especially important for military or transient areas and schools close to a bordering state since Maryland, Tennessee, Kentucky, and North Carolina all require 1500 hours and West Virginia requires 1800 hours.). There are only 6 states as low as 1000. Over 40 states are at 1500 or higher. When training hours are not equivalent, most states require proof of work experience or additional school hours to make up the difference. Right now it is fairly easy to transfer to other states since the hours requirement is on par. Dropping to 1000 hours would put Virginia licensees at a disadvantage when attempting to transfer their license.
3. It limits career options like opening a salon or working in a high-end salon because the likelihood of needing to assist or work for lower wages increases with less training. There is value in education. Removing education will lead to devalued pay and an increase in industry attrition at a time when there is already a workforce shortage. 500 hours can make a huge difference between a graduate working for minimum wage at a chain salon versus starting their career making 35-50% commission. Which one do you think will remain in the industry long-term?
4. It increases the burden on salon owners to provide education to make up for the missing hands-on training as well as increased cost to fix mistakes from lack of practical experience. Small business owners need graduates who are prepared to work behind the chair immediately. The RAP was not asked what graduates need to be successful, only what is necessary for safety of the general public. However, if a licensed stylist cannot perform a quality cut and color, the industry will see a dramatic increase in attrition, at a time when the industry is in desperate need of more workers due to attrition.
5. A reduction in hours will not fix the workforce shortage problem or reduce barriers to entry. This profession requires passion, creativity, people skills and long hours on your feet. People don’t enter this profession on a whim. Reducing the program from 11 months to 7 months will not increase the number of people desiring a career in Cosmetology. Less than 1 year is considered short to graduate with a career when most colleges require 4 years.
6. It will reduce the amount of Pell grant eligibility for students by thousands of dollars, increasing out-of-pocket costs for students by the same amount. Without a change in scope, schools will be unable to lower tuition because they are required to teach the same program in a shorter amount of time, which will increase costs to achieve similar outcomes, especially during a period of soaring inflation.

If, despite the reasons above, the Board continues to move forward with this hour reduction, I urge the Board to consider the following when writing the regulations:

• In order to lower Cosmetology hours to 1000, will there be a reduction in scope of practice? Waxing, nails, skin, and a broad scope of hair services must be taught all in 1000 hours when the barbering program is 1100 with a much lower scope and esthetics is 600 on its own? If no, then will this change the scope of practice for esthetics and barbering? Barbering does not include waxing, nail care, wig care, perming, relaxing, bleaching, or thermal styling. If barbering requires 1100 hours to ensure safety, then the additional of so many chemical services to the cosmetology program, should increase its required training hours, not lower them.
• Accredited schools should be consulted regarding the time frame for implementation. Updating curriculum and submitting the required documents for such a significant program change to SCHEV, DPOR, the accreditor, and USED all take substantial manpower and time waiting for agencies to approve the new program before moving on to the next step. This can take months to a year. Rushing the timeline for implementation will halt enrollment, which will create barriers to entry rather than eliminate them.
• Students must be left with the option to choose a program at higher hours to meet their needs. Students should be allowed to decide whether they want more education and hands-on practice in a 1500 hour program, or are content with the bare minimum of training to ensure safety at 1000 hours. Schools must continue to be allowed to offer programs above the minimum state requirement, as is the case now. This is very important and must be written into the language of the new regulations so there is no confusion as to it being allowed.
• And finally, I urge you to consider adding a Hairstylist license at 1000 hours, rather than lowering Cosmetology hours. This would be in line with many states and would provide options for students without compromising the industry.