Cosmetology and Barber Licensure Through Career and Technical Education (CTE) PILOT PROGRAM
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Through a combination of academic classes and hands-on learning experiences, high school students enrolled in Career and Technical Education (CTE) programs gain academic, employability, technical and real-world skills that prepare them for many postsecondary options including direct entry into a skilled career, apprenticeships and college.
In the Commonwealth, more than 1,700 approved CTE programs are offered in over 200 schools. Those schools include 80-plus regional Career and Technology Centers (CTCs) and more than 140 high schools.
The majority of CTCs in Pennsylvania operate as a "shared time" option; students spend about half of the day at the CTC engaged in a CTE program and the other half of the day at their home or "sending" high school where they take required academic courses and earn a high school diploma.
For students interested in becoming a cosmetologist or barber, Pennsylvania has 72 cosmetology programs and three barber programs within its CTCs. The Cosmetology Law requires 1,250 hours of instruction for licensure as a cosmetologist, which CTC students typically complete over a period of three years (grades 10, 11 and 12). Likewise, the Barbers' License Law requires 1,250 hours of instruction for licensure as a barber. In each case, the required education is provided through a sequential set of steps that address specific subjects and tasks necessary for state board preparation, graduation and entry-level job skills.
IMPACT OF COVID-19 ON COSMETOLOGY AND BARBER CTE STUDENTS
As a result of the Governor's declaration of a state of emergency related to COVID-19 in March 2020, schools across the Commonwealth (including CTCs) were closed. While many high school students were able to continue educational activities remotely from home and complete the remainder of the 2019-20 academic year, CTC students enrolled in cosmetology and barber programs had a more difficult time. First, the cosmetology and barber laws and regulations do not provide for the delivery of instruction remotely (i.e., distance education). Second, due to the hands-on nature of the cosmetology and barbering professions, many of the necessary skills cannot be adequately taught by teachers − let alone learned, practiced and perfected by students − virtually.
The Governor approved requests from the State Board of Cosmetology and the State Board of Barber Examiners to allow cosmetology and barber students, respectively, to obtain up to 50% (625 hours) of the required 1,250 instruction hours through distance learning. The increases apply all cosmetology and barber programs (CTC and non-CTC) throughout the Commonwealth, enabling students in both public and privately-run schools to more easily continue their education during the pandemic.
While those increases in allowable distance learning did provide
some relief, the educational landscape for CTC students is not the same as that of their counterparts in private schools. For example, attending school during the months of June, July and August when public schools are typically closed for summer vacation is not an available option for CTC students.
Private schools can also offer classes in the evening to their students, another option that is not available to CTC students. Additionally, CTC students are subject to the in-person educational limits that happen to be imposed by the particular school district in which they reside, another variable that is not as much of a factor for students attending private schools. For these reasons, this pilot program for cosmetology and barber CTC students has been developed.
COMPONENTS OF THE PILOT PROGRAM
This pilot program provides additional opportunities for cosmetology and barber CTC students to earn educational hours and practical experience. It is also designed to allow CTC educators the flexibility necessary to assist these students in obtaining all of the required education hours prior to their planned graduation date. These opportunities and flexibilities will help achieve the collective goal of students, educators and parents/guardians, which is to graduate prepared and competent future cosmetologists and barbers . . .
The pilot consists of three major components by which cosmetology and barber CTC students may earn educational credit toward their respective 1,250-hour instruction requirements:
Distance Education, including Practical Skills Review;
Internships and Job Shadowing; and
1. DISTANCE EDUCATION - UP TO 650 HOURS
In recognition of the unique challenges faced specifically by students in cosmetology and barber CTC programs, the amount of allowable instruction through distance education which these students may obtain is increased by 25 hours above the existing waiver allowing for 625 hours, for a total of
650 hours. Such distance education can be a combination of theory-based subjects and skills and, as explained in more detail below, for review of certain previously-taught practical skills.
See Appendix A.
The Cosmetology Board's regulations recommend that a cosmetology student's education include 50 hours of instruction in "Professional Practices" (Pennsylvania Department of Education Tasks 101-401).
For cosmetology CTC students participating in this pilot, all 50 hours may be obtained through distance education.
The Cosmetology Board's regulations recommend that a cosmetology student's education further include 200 hours of instruction in "Sciences" (PDE Tasks 501-1004). For cosmetology CTC students participating in this pilot, all 200 hours may be obtained through distance education.
The Cosmetology Board's regulations recommend that the remainder of a cosmetology student's education include 1,000 hours of instruction in "Cosmetology Skills−Cognitive and Manipulative" (PDE Tasks 1101-2304). Due to the techniques that must be learned in order to practice cosmetology and barbering and the nature of some of the tools and equipment involved, many of the cognitive and manipulative skills need to be taught and evaluated at least partially (if not entirely) in person; they cannot be taught solely via distance learning or on a virtual platform. For example, shampooing is a process that would be difficult to teach/learn entirely online if a student did not, at some point, have access to a standard shampoo bowl with which to work.
There are, however, some tasks within "Cosmetology Skills" that
could be taught virtually from start to finish. As such, cosmetology CTC students may earn credit for hours of instruction in the following areas, even if taught entirely via distance education: PDE Tasks 1102, 1303, 1401, 1403, 1502, 1609, 1802, 1804, 1902, 1906, 1908, 2001, 2102, 2201 and 2204 (referred to hereinafter as the "Theory-Based Tasks").
Even the tasks that are not one of the Theory-Based Tasks involve certain practical concepts where distance learning could be employed to allow students to earn hours for "practical skills review." Delivery of instructional content from teachers to students, as well as teachers' assessment of student performance, would be achieved electronically (video, photographs, online platforms, etc.). "Practical skills review" hours may be earned for any of the Cosmetology Skills (PDE tasks 1101-2304).
To demonstrate practical skills to their CTC educator for credit, students may utilize any form of video-based media or platform. Videos shall demonstrate practical skills as assigned by the educator and may occur in real time or through recorded video. For recorded video, the educator shall provide the student with the amount of time the student must practice a particular skill prior to the video demonstration. The video itself and the preparation/practice for the skill demonstrated in the video can be viewed and used for evaluation, and then counted towards the student's hourly requirements, with the number of hours or fractions thereof earned through each of these tasks determined by the educator. Practical skills review could take a number of forms. For example:
For skills and tasks that have already been taught, student-created videos or photos can be particularly useful. For example, a student can submit a video of a hairstyle done through roller-setting of a before, after the roller set, and then the comb-out. The final product could be graded. Teachers would have discretion to identify which skills they could evaluate using videos or pictures.
Students could also earn hours for a product-type skill by taking pictures at each step of the process, and then sending the pictures to the teacher through Instagram, email or the like. Students could be given a rubric to use as a self-evaluation, which they would then return to the teacher.
Teachers could demonstrate a lesson using Zoom or some other platform, give students an assignment, and then the students can send in pictures or videos of their work (or students could bring their project into school on their in-school days) for the teacher to evaluate and give feedback.
Teachers could demonstrate a procedure using Zoom or another platform while students follow along with the teacher and practice at home. Teachers could observe students in real time. Students can produce a final product during in-school days. Students can ask questions and the teacher can evaluate the final product.
For cosmetology CTC students participating in this pilot, the number of hours that may be obtained through distance education will vary, depending upon how many distance education hours a student earns for "Professional Practices" and "Sciences." For example, if a student obtains 50 hours of instruction in "Professional Practices" and 200 hours of instruction in "Sciences" (both maximums), the most a student could earn for "Cosmetology Skills" would be 400 hours of instruction. Those 400 hours could be spread across a combination of (a) virtual instruction in the Theory-Based Tasks, and (b) hours earned for "practical skills review" (any of PDE Tasks 1101−2304).
The Barber Board's guidance currently allows for 625 hours of instruction through distance education. This allowance will increase to 650 hours for barber CTC students participating in the pilot program, with the breakdown of specific subjects set forth at Appendix B. The additional 25 hours may be spread out over any of the subjects and in varying increments as determined by the teacher. For subjects that cannot be taught entirely via distance education, barber CTC students may also earn hours through "practical skills review" in a manner similar to cosmetology CTC students.
Certain adjustments and accommodations can be made at the teacher's/school's discretion, and flexibility is encouraged with student's having unique circumstances or needs. Students who are unable to access video-capable devices by reason of IEP or other issues outside of the control of the CTC or student are permitted to use alternative methods identified by the CTC educator to earn hours.
For example, if a student lacks certain equipment to perform practical tasks, CTCs may allow students to borrow school equipment for home use. CTCs could also provide students with artificial products that simulate cosmetology products to allow students to practice chemical application procedures at home without using the actual chemicals.
2. INTERNSHIPS AND JOB SHADOWING − UP TO 350 HOURS
The second component of the pilot program allows students to earn up to 350 hours in a licensed cosmetology salon or barber shop.
Existing Vocational Program Participants: Students participating in a vocational program through the Office of Vocational Rehabilitation, Goodwill Industries International, Inc. or PA Careerlink
may earn up to 350 hours of credit towards the required 1,250 instruction hours for work done through one of those programs. The hours must consist of practical experience rather than job shadowing.
New Vocational Program Participants: All other CTC students shall be permitted to obtain 350 educational hours through practical experience at a licensed salon (in the case of cosmetology students) or at a licensed shop (in the case of barber students). The hours must consist of practical experience rather than job shadowing.
Job Shadowing: For students not participating in a vocational program, another means of earning hours is job shadowing. Cosmetology CTC students will be permitted to shadow a licensed cosmetologist or cosmetology teacher in a salon, and barber CTC students will be permitted to shadow a licensed barber or barber manager in a shop. Students then earn hours preparing and presenting reports on their job shadow experiences. Teachers may use their discretion to determine the format of such presentations, the number of hours that may be earned, and so forth.
Except as otherwise noted herein, each cosmetology CTC student shall at all times be supervised by a licensed cosmetologist or cosmetology teacher who has at least five years of experience. Similarly, each barber CTC student shall at all times be supervised by a licensed barber or barber manager who has at least five years of experience. Existing vocational program students shall be permitted to remain with their pre-existing supervisor/salon or supervisor/shop, regardless of the supervisor's years of experience.
The CTC educator shall provide the supervisor and student with a list of practical skill assignments. Each supervisor shall complete a "Verification of Practical Experience" along with a
"Practical Experience Hourly Report" in substantially the form provided herewith at Appendix C for submission to the CTC educator on a monthly basis.
The salon or shop shall notify each client upon whom the student performs services that the service is being performed by a student. The salon or shop supervisor may, at his or her option, allow the student to perform practical skills previously taught by the CTC educator upon a mannequin for observation and evaluation of practical skills. For example, the student could practice and demonstrate a cut, foil wrap or some other skill that the educator has already taught. The supervisor will use a rubric provided by the CTC educator to gauge the student's skill level, with the rubric then returned to the CTC educator for grading.
For each student earning hours at a shop or salon, CTC schools shall provide a letter to the salon or shop identifying the students and indicating the student's participation in the pilot program. The salon or shop shall keep this letter on hand in the event of an inspection. Students shall carry some form of identification with them (driver's license, school ID or the like) while in the salon or shop.
3. IN-PERSON INSTRUCTION − NO LESS THAN 250 HOURS
The third component of the pilot program is traditional, in-person instruction at the student's CTC.
The number of hours will vary, depending upon how many hours the student obtains from the first and second components of the pilot. For example, if a student obtains the maximum 650 hours of instruction through distance education (component 1) and 350 hours in a salon or shop (component 2), the student will need to obtain 250 hours of in-person instruction in order to reach the required total of 1,250 hours. Certainly students could obtain more than 250 hours of in-person instruction, and therefore not need the full 650 hours of distance education or the full 350 hours in a salon or shop.
Cosmetology CTC students may work on other students in school when face-to-face instruction is permitted if the program is following the State Board of Cosmetology COVID-19 Guidance for operating a school and salon during COVID-19. Similarly, barber CTC students may work on other students in school when face-to-face instruction is permitted, so long as the program is following the State Board of Barber Examiners COVID-19 Guidance for operating a school and shop.
Some schools are opening their student clinics to the public following the guidelines and all applicable requirements of the Pennsylvania Department of Health, which will allow students additional opportunities to perfect their skills in an "in-person" setting.
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To facilitate this pilot program, a number of statutory and regulatory waivers related to cosmetology and barbering have been approved. All such waivers apply solely to CTC students participating in this pilot.
 For purposes of this pilot program, "distance education" is learning that is accomplished while the student is at a location separate and apart from their cosmetology or barber school.
 The prohibition against practicing cosmetology without a license is waived (63 P.S. § 508). The "requirements to practice" − including submitting an application for licensure, providing a health certificate, paying a license fee and passing an examination prior to practicing cosmetology − are waived (63 P.S. § 509). The prohibition against schools permitting students to practice cosmetology upon the public waived (63 P.S. § 513). The requirement that cosmetology students wear uniforms during school hours is waived when students are engaged in on-the-job training or job shadowing (49 Pa. Code § 7.118a). In making any "maximum occupancy" computation established by Order of the Governor or the Secretary of Health, salons do not need to include cosmetology students operating pursuant under this pilot into the count.
 The prohibition against practicing without a barber license is waived (63 P.S. § 563). The prohibition against an unlicensed individual being employed in a licensed barber shop or school is waived (49 Pa. Code § 3.14(a)). The limitation on the manner in which a student may earn hours − giving credit only for the actual time spent performing barbering services or being instructed in theory − is waived (49 Pa. Code § 3.22). Finally, in making any "maximum occupancy" computation established by Order of the Governor or the Secretary of Health, shops do not need to include barbering students operating pursuant under this pilot into the count.