On August 19th, the AACS (American Association of Cosmetology School) Government Relations Committee (GRC) consisting of Greg Jones (Chairman), Christine Gordon (AACS Immediate Past-President), Anthony Fragomeni (AACS Past-President), and Tom Netting, Public Policy Advisor at Akerman LLP, met with a Special Assistant to the President on Education Policy and an Office of Policy Development Senior Advisor for a discussion at the White House centered on Gainful Employment. During the one-hour conversation prompted by AACS’ response to the “2014 Notice of Proposed Rulemaking on Program Integrity: Gainful Employment”, GRC representatives advocated on behalf of AACS member schools and individuals who desire to pursue a career in the beauty and wellness industry. AACS’ discussion with White House and Department of Education (DOE) senior advisors reflects the urgency of a pending Final Rule on Gainful Employment scheduled for completion by November 1, 2014, with implementation scheduled for July 1, 2015.

As they met with senior policy and education administrators, AACS’ GRC stressed concerns about the lack of complete and comprehensive data, specifically noting flaws in the integrity of data used to calculate debt-to-earnings (D/E) metrics and program cohort default rates (pCDR). Additionally, they advocated for review and revision of the procedures and methodology used to establish aggregate mean and median rates.They provided analysis showing that under the current calculation and assessment structure, calculations are inherently flawed and incomplete. Finally, the GRC advocated consideration of alternative methodologies for assessing an institution’s meeting of Gainful Employment thresholds, such as a requirement to meet either a D/E or pCDR threshold, but not both metrics.

Looking beyond the impact a Final Rule may have on cosmetology schools and the beauty and wellness industry, AACS’ GRC urged the DOE and White House advisors to undertake a more expansive and accurate analysis of the effect proposed regulations would have on individuals who want to work in the beauty and wellness industry.

Greg Jones characterized the meeting as “highly productive” and noted that by the end, Administration officials acknowledged that information and metrics used in determining eligibility calculations could lead to potentially skewed outcomes, detrimental to institutions and the students they serve. “We believe the meeting was very successful in providing our members’ viewpoints to an audience that may not have heard these viewpoints before,” said Jones in a video message to AACS member schools.

Despite acknowledging the validity of AACS concerns expressed in the meeting, the Administration suggested that not every concern will be incorporated into the Final Rule. However, senior officials did indicate a willingness to consider issues that the Final Rule does not fully address, and work toward a resolution prior to the July 1, 2015 implementation date.

Anthony Fragomeni said AACS’ leadership on Gainful Employment serves not only schools and students, but also the beauty and wellness industry and the consumers it serves. He states, “Our industry is incredibly interconnected; from the schools that prepare students to the employers that hire beauty and wellness professionals to the consumers they serve. AACS is committed to working with lawmakers, regulators and policy makers to preserve and protect choice, equity and access for those in our industry and those wishing to join our industry,”

As the November 1st Final Rule approaches, AACS will continue to publish regulatory news and updates at http://www.aacsaction.org/

About the American Association of Cosmetology Schools: Founded in 1924, the American Association of Cosmetology Schools is committed to advancing educational excellence. The Association represents more than 1100privately owned cosmetology schools in North America. A non-profit association, AACS serves cosmetology, skin, nail, barbering and massage schools.