TDLR summit divided over value of practical state exam as educators, licensees debate safety and access

TDLR convened a summit of the Barbering and Cosmetology Advisory Board and industry stakeholders on Nov. 5, 2025, to discuss the role and format of the state practical exam and related testing policies.

The meeting included a legal overview from Athena Ponce, assistant general counsel for the Texas Department of Licensing and Regulation, who said written exams are required for licensure and must be professionally validated under Texas Occupations Code §1603.252–.255, and that the practical exam is discretionary under §1603.256. "The department, a person with whom the department contracts, a licensed school approved by the department, or a Wyndam school district may administer a practical examination," Ponce said, summarizing the statute.

Tom Foster, manager in the education and examination division, presented a May 2025 survey of 439 respondent schools. Foster said the survey found 77.1% of respondents believed the practical exam provides value and 79.1% said it should remain a requirement for licensure. He also summarized results showing the written exam and practical exam were among the top items schools viewed as critical for maintaining industry standards.

Those numbers framed a wide public comment period in which instructors, school owners and licensees voiced sharply divergent views. Amanda Smith of Lamar State College, who said she has 40-plus years in the industry, called for eliminating the practical and placing more emphasis on scenario-based written items: "My opinion was to, yes. I think it will be beneficial to eliminate it… add a portion of it to the written exam, scenarios, color scenarios, chemical scenarios," she said.

By contrast, Kevin Howell, who identified himself as a licensed barber with more than 20 years of experience, urged keeping the practical to protect public safety and professional standards. "Hands-on professionals need hands-on testing," Howell said. "Skill without safe execution endangers clients and shop reputation." Other speakers echoed concerns that removing the practical would lower standards for technique, infection control and client safety.

Multiple educators said the current practical’s administration and scoring create the tension. Laura Hayes, a community college instructor in Waco, said the testing environment — "portable tables with power strips" at some sites — undermines test integrity and that, "if we're going to maintain it, we have a lot of work to do to bring it back to the integrity that once was." Several commenters proposed an alternative: keep a hands-on assessment but permit approved schools to proctor or administer practicals under revised rules so testing could occur in more realistic training environments.

Athena Ponce said the statute already authorizes licensed schools to administer practicals if the department approves them and the department prescribes method and content. "No statutes prohibit schools from proctoring written or practical examinations, and no statutory changes are needed to create rules allowing schools to proctor practical exams," Ponce said, while noting rules would need amendment to implement such a change.

Participants also raised access and equity issues. Speakers from regions with large Spanish-speaking populations asked whether English-only testing disadvantages some candidates; practitioners reported long wait times for PSI test dates and noted PSI handles financial transactions and accommodation requests separately from TDLR. Licensing staff said accommodations are requested directly from the contractor and that transcript-evaluation processes exist to grant credit when applicants present course-by-course documentation.

TDLR staff acknowledged technical and operational problems and said improvements are underway: Yvonne Lopez, licensing manager for barbering and cosmetology, said licensing staff already evaluate course-by-course transcripts when students seek partial credit. Lorraine Stroh, school services education manager, said the agency is developing training and system improvements and that an "educator academy" is planned for 2026 to support instructors and schools.

No formal rule or statute was adopted at the summit. The discussion clarified that while the Legislature has previously altered statutory requirements (for example, reducing hours and eliminating the separate instructor license), the advisory board and TDLR can pursue rule changes within the current statutory framework; statutory changes would require action by the Texas Legislature. The session closed with an invitation for continued input, including during TDLR’s strategic planning process and through future advisory meetings.

Provenance (selected): Athena Ponce presentation and Q&A; Tom Foster survey review; multiple public commenters including Amanda Smith and Kevin Howell.