TDLR staff outline block-based ‘stackable’ curriculum option that could accelerate licensure; educators flag financial-aid, reciprocity and quality concerns

TDLR staff introduced a block-based "stackable hours" proposal at the Nov. 5 advisory summit that would let students carry coursework from specialty licenses into combination or full operator/class A barber curricula. The concept was presented as a policy option for discussion, not a finalized rule.

Derek Burkhalter, assistant general counsel, described a visual chart mapping statutory service items to license types and then grouping those services into modular "blocks." Under the illustrative model he presented, the blocks and sample hour allocations were: hair care (250 hours), skin care (200), nails (200), hair weaving (100), eyelash extensions (100), unguarded shaving (100) and a 150-hour "fundamentals" block covering law, health and safety and professional practice. Using those numbers, a full class A barber or cosmetology operator would still total roughly 1,000 hours, but many specialty or combination pathways could be shorter — for example, a manicurist could total ~350 hours in the example instead of the current 600 hours.

"If I have an eyelash extension specialist license, I have the one block. And if I want to get an aesthetician license, I should be able to carry over that one block and only add the skin care services block to obtain my aesthetician license," Burkhalter said, describing the stacking principle.

Lorraine Stroh, school services education manager, said staff researched other states and did not find an identical model in active use; she emphasized the approach raises many operational questions. "There’s a lot to think about," Stroh said, noting issues including how reduced hours would interact with financial aid eligibility, credit transfer, and whether other states would accept such stacked credentials for reciprocity.

Yvonne Lopez, licensing manager, said licensing staff already evaluate course-by-course transcripts today and can grant credit when a clear transcript is submitted. "This would provide my team with a really good guide," Lopez said, but she cautioned that the model’s success would depend on consistent course documentation from schools and clear rules for evaluation.

Educators and school owners raised several concerns. Multiple speakers warned that substantial hour reductions would jeopardize hands-on clinic experience and that the proposed hour breakdowns in the illustrative chart would require careful revision. Participants also flagged financial-aid rules: many postsecondary programs require a minimum number of clock hours (commonly 600) to qualify for federal financial aid; reducing program hours could remove students’ access to those funds, increasing out-of-pocket costs. In addition, schools reported that even when TDLR grants transcript credit, receiving schools sometimes decline to acknowledge transferred hours, creating barriers for students.

Staffers recommended additional work: they suggested a rulemaking work group, careful modeling of hour distributions tied to exam content, and outreach to the financial-aid community and other states to understand reciprocity implications. Lorraine Stroh said TDLR plans an educator academy in 2026 to support instructors and mentioned that licensing-system upgrades are in progress to better manage transcripts and credentialing steps.

No policy was adopted at the summit. Staff and advisory board members framed the block-hour idea as an option for further study and encouraged stakeholders to submit detailed comments, sample course-by-course transcripts and operational concerns for staff to consider in potential rulemaking or strategic-planning work.

Provenance (selected): Derek Burkhalter presentation with chart and hour examples; follow-on discussion by Lorraine Stroh and Yvonne Lopez; public commentary on hours, financial aid and transferability.