Moving Beauty Education from DOE to DOL/SBA: A Structural Reform Proposal – WHITE PAPER 2026 – Di Tran University – Research Division

Executive Summary

The United States cosmetology and beauty education sector stands at a critical juncture, burdened by a funding and oversight model that is structurally misaligned with the economic realities of the profession. For decades, the governance of beauty education has fallen under the purview of the Department of Education (DOE) through Title IV of the Higher Education Act. This categorization treats vocational beauty schools as academic institutions, subjecting them to accreditation standards, credit-hour metrics, and financial aid systems designed for degree-granting colleges. The consequences of this misalignment are now empirically undeniable: soaring student debt, high loan default rates, and a proliferation of programs that fail to meet even the most basic metrics of “Gainful Employment” (GE).

Recent regulatory developments, specifically the Biden Administration’s 2024 Financial Value Transparency and Gainful Employment rules, have exposed the systemic insolvency of the current model. Analysis suggests that nearly 75 percent of cosmetology students are enrolled in programs that will fail the new earnings thresholds.¹ While the industry lobbies for exemptions based on underreported tip income, the fundamental issue remains: federal tax dollars are subsidizing high-tuition, time-intensive schooling for a trade that historically and practically thrives on apprenticeship and low-capital entrepreneurship.

This white paper advocates for a sweeping structural reform: the transfer of federal oversight for beauty education from the Department of Education to a cooperative framework managed by the Department of Labor (DOL) and the Small Business Administration (SBA). By shifting the funding mechanism from Title IV student loans to DOL Registered Apprenticeships (RA) and SBA micro-enterprise support, the federal government can catalyze a transition from a debt-based education model to a wage-based workforce development model. This proposal leverages existing infrastructure—specifically the Workforce Innovation and Opportunity Act (WIOA) and SBA 7(a) and microloan programs—to align training with labor market demands, reduce taxpayer risk, and restore the pathway to middle-class entrepreneurship that the beauty industry has long promised but increasingly failed to deliver.

I. The Systemic Failure of Title IV Oversight in Cosmetology

The classification of cosmetology schools as Title IV-eligible “institutions of higher education” has created a perverse incentive structure that prioritizes enrollment volume and program length over educational efficiency and labor market outcomes. This misalignment is most visible in the sector’s catastrophic performance under the Department of Education’s accountability metrics.

The Gainful Employment Crisis and the Earnings Premium Test

The 2024 implementation of the Financial Value Transparency and Gainful Employment (GE) rules represents a watershed moment for the beauty education sector. These regulations were designed to ensure that career-training programs leave graduates with debt loads that are manageable relative to their earnings. The metrics utilized—specifically the Debt-to-Earnings (D/E) ratio and the Earnings Premium test—have revealed that the current beauty school model is mathematically unsustainable for the average student.

Under the new rules, a program fails if the median annual loan payment of its graduates exceeds 8 percent of their total annual earnings or 20 percent of their discretionary earnings.¹ More critically, the “Earnings Premium” test requires that at least half of a program’s graduates earn more than the median high school graduate in their state who never attended college.³ This metric has proven devastating for cosmetology programs. Research indicates that at large, for-profit conglomerate beauty schools, approximately 90 percent of graduates fail to meet this earnings threshold.¹

The implications of this failure are profound. It suggests that for the vast majority of students, the federal government is subsidizing a credential that provides no statistical economic advantage over a high school diploma in the early years of employment. Yet, unlike a high school diploma, this credential comes with an average debt burden of $10,000 to $14,000 ⁴, and often significantly higher at premier for-profit chains. The disparity is stark: the DOE is effectively financing a negative return on investment for hundreds of thousands of students annually.

The industry’s response has been to litigate rather than reform. The American Association of Cosmetology Schools (AACS) has sued the Department of Education, arguing that the GE metrics are “fundamentally flawed” because they rely on Social Security Administration (SSA) data which captures only reported income.⁵ They contend that because the beauty industry relies heavily on cash tips that are frequently underreported to the IRS, the DOE’s data understates the true economic value of the degree. However, independent analysis by The Century Foundation suggests that even if earnings data were adjusted upward by 8 percent to account for unreported tips, 78 percent of cosmetology programs would still pass the debt-to-earnings test but fail the earnings premium test.⁶ The structural deficit in earnings potential is too large to be explained away by tip underreporting alone; it is intrinsic to a model that front-loads high tuition costs onto an entry-level service profession.

The “Clock-Hour” Trap and Educational Inflation

A central driver of the high cost and debt in beauty education is the reliance on “clock-hour” regulatory requirements. Unlike competency-based education, where a student progresses upon mastering a skill, cosmetology licensure in most states requires the completion of a specific number of hours—typically between 1,000 and 1,600, though some states have required as many as 2,100.⁷ This time-based requirement is a relic of the 1930s and 1940s, often lobbied for by beauty school associations to create barriers to entry and guarantee tuition revenue.

The availability of Title IV funds creates a feedback loop that encourages “educational inflation.” Schools have a financial incentive to lobby state boards to maintain or increase hour requirements because their revenue is directly tied to the length of time a student is enrolled and drawing down federal aid. Institute for Justice (IJ) research highlights that program lengths often “exactly match” the maximum hours required for licensure, suggesting that curricula are designed to maximize revenue capture rather than educational necessity.⁷

This system creates a “time tax” on students. An aspiring cosmetologist who could master the necessary chemical and cutting skills in 600 hours of intensive training is nonetheless forced to pay for and attend 1,500 hours of instruction to satisfy state mandates. This not only inflates debt but also imposes a massive opportunity cost, keeping the student out of the workforce for a year or more. The DOE, constrained by its mandate to fund accredited programs based on state licensure requirements, is powerless to break this cycle. It functions as a passive payer, fueling a system that extracts wealth from low-income students—disproportionately women and people of color ⁸—and transfers it to for-profit school operators.

Default Rates and the Risk to Taxpayers

The financial toxicity of the current model is further evidenced by student loan default rates. Cosmetology schools dominate the lists of institutions with high Cohort Default Rates (CDR). Analysis of Department of Education data reveals that at nearly 500 cosmetology institutions, 30 percent or more of students who entered repayment were late on installments or headed toward default.⁹ This is significantly higher than the average for other sectors of higher education.

The pause on student loan payments during the COVID-19 pandemic temporarily masked this crisis, but as repayment restarts, the collision between low entry-level wages and high debt balances is inevitable. The default mechanism is predictable: a graduate earning $26,000 a year ⁷ faces a monthly loan payment that competes with rent and basic necessities. Because the degree did not confer a “college wage premium,” the loan becomes a distress determinant rather than an investment in social mobility.

Furthermore, the closure of large chains like Marinello Beauty School, which resulted in the discharge of federal loans for 28,000 students due to deceptive practices ⁶, demonstrates the taxpayer risk inherent in this sector. When these schools collapse under the weight of regulatory scrutiny or financial mismanagement, the public bears the cost of the discharged debt, while the students are left with no license and months of wasted time.

II. The Department of Labor Solution: A Return to Apprenticeship

The solution to the crisis in beauty education is not to refine the metrics of Title IV, but to exit the framework entirely. The Department of Labor (DOL) offers a regulatory and funding ecosystem that is naturally aligned with the vocational reality of cosmetology. By transitioning the primary training vehicle from classroom-based schooling to Registered Apprenticeships (RAPs), the federal government can substitute student debt with apprentice wages, aligning the interests of the student, the employer, and the taxpayer.

The Mechanics of the Apprenticeship Model

Under a DOL-supervised framework, cosmetology training would follow the “earn while you learn” model that characterizes other skilled trades like electrical work and plumbing. The DOL already maintains approved occupational codes for “Hair Stylist” (RAPIDS code: 0096) and “Cosmetologist” (RAPIDS code: 0096CB), which provide the blueprint for this transition.¹⁰

In this model, the “student” becomes an “apprentice,” hired by a salon owner (the “sponsor”) at a training wage. The apprentice spends approximately 80 percent of their time in On-the-Job Training (OJT), learning practical skills by assisting senior stylists, and 20 percent of their time in Related Technical Instruction (RTI), which covers theory, sanitation, and state law.

The economic inversion of this model is transformative:

• Current Model: Student pays $17,000 tuition, borrows at 5-7% interest, earns $0 for 12 months.
• DOL Model: Apprentice pays $0 tuition, earns $19,000 – $25,000/year in wages ¹², incurs $0 debt.

This shift immediately resolves the Gainful Employment dilemma. Because the apprentice incurs no debt, the Debt-to-Earnings ratio is rendered irrelevant. Even if the apprentice’s starting wage remains low, their discretionary income is not cannibalized by loan service payments, significantly improving their financial stability.

Competency-Based vs. Time-Based Progression

One of the most significant advantages of DOL oversight is the department’s support for competency-based apprenticeship standards. Unlike the DOE, which is statutorily tied to credit/clock hours for aid disbursement, the DOL allows for hybrid and competency-based models where an apprentice progresses as they demonstrate mastery of specific skills.¹⁰

For example, the “Hair Stylist” occupation (RAPIDS 0096) allows for a competency-based approach where an apprentice can complete the program in as little as one year if they demonstrate proficiency in the required Work Process Schedule (WPS).¹⁰ This dismantles the incentive to inflate hours. A salon sponsor has no incentive to keep an apprentice in “training mode” longer than necessary; their economic incentive is to train the apprentice to full productivity as quickly as possible. This aligns the training duration with the actual learning curve of the individual, rather than an arbitrary state mandate.

Success of Existing State Apprenticeships

The feasibility of this model is not theoretical; it is currently operating in over 20 states, though often at a disadvantage due to the dominance of Title IV-funded schools. States like Wisconsin, California, and Virginia have robust cosmetology apprenticeship pathways that operate alongside the school system.¹⁴

• Wisconsin: The state utilizes a rigorous apprenticeship model requiring 3,712 hours of OJT and 288 hours of paid related instruction.¹⁶ Apprentices are paid for every hour, including classroom time, and recent job postings indicate a healthy demand for apprentices in salons and spas. The completion of the program leads to the same licensure as the school route but with years of work experience already accrued.
• California: The California Barbering and Cosmetology Board approves apprenticeship program sponsors who oversee the training.¹⁸ While California’s model has faced criticism for “tuition-charging” by some intermediaries—a practice that mimics the school model and should be regulated against in a federal transfer—it demonstrates the capacity for large-scale apprenticeship adoption in the nation’s largest market.
• Virginia: The state allows for a direct apprenticeship path that bypasses the need for costly private schooling, emphasizing the trade nature of the profession.

The persistence of these programs despite the massive marketing and lobbying power of for-profit schools suggests that the model is viable. However, it lacks the federal subsidy engine that schools enjoy. Redirecting federal support would allow these programs to scale and become the primary, rather than the alternative, pathway to licensure.

International Benchmarks: The UK and German Models

The proposed DOL transfer mirrors the successful vocational education structures of Germany and the United Kingdom, where cosmetology is respected as a skilled trade rather than an academic consolation prize.

• United Kingdom: The UK government has aggressively reformed its apprenticeship funding to support small and medium-sized enterprises (SMEs), which constitute the bulk of the beauty industry. For apprentices aged 16-21, the government now funds 100 percent of the training costs, removing the financial burden from small salon owners.²⁰ Additionally, employers receive a £1,000 cash incentive for hiring young apprentices.²¹ This “Levy” system ensures that the cost of training is socialized or borne by large corporations, while the specific skills are imparted by local employers.
• Germany: The “Dual System” is the global gold standard, where trainees spend 3-4 days in a salon and 1-2 days in a state-funded vocational school.²³ This partnership between the state and the private sector results in near-zero youth unemployment and high retention rates in the trade.

The US Department of Labor is the only federal agency with the statutory capacity to implement a similar “Dual System” framework, utilizing WIOA funds to cover the “Related Technical Instruction” (classroom portion) while the employer covers the OJT wages.

III. The Small Business Administration (SBA) Solution: Fostering Entrepreneurship

A critical oversight in the current DOE model is the failure to recognize that cosmetology is inherently an entrepreneurial pursuit. The vast majority of cosmetologists eventually leave employment to become independent contractors (booth renters), salon suite lessees, or salon owners. Yet, DOE-funded curricula focus almost exclusively on technical skills and state board exam preparation, leaving graduates ill-equipped for the business realities of the profession. This leads to high business failure rates and the “underground economy” problem of unreported income.

Integrating the Small Business Administration (SBA) into the oversight ecosystem acknowledges that a cosmetology license is effectively a business license.

From Tuition Subsidies to Micro-Capital

The billions of dollars currently funneled into Title IV tuition grants and loans could be far more effectively deployed as SBA Microloans. The SBA Microloan Program currently offers loans up to $50,000 for working capital, inventory, supplies, and fixtures.²⁵

Under the proposed reform, a graduate of a DOL Registered Apprenticeship—who has no student debt—would be eligible for a “Vocational Trade Startup” microloan.

• Use of Funds: Instead of paying for classes they have already completed, the cosmetologist would use these funds to purchase their initial professional kit (shears, clippers, dryers), pay the deposit on a booth rental, or secure liability insurance.
• Investment vs. Consumption: Student loans pay for consumption of education services; SBA microloans pay for investment in productive assets. The latter has a direct correlation to revenue generation and economic stability.
• Intermediary Administration: These loans are administered by non-profit community-based organizations (intermediaries) that provide technical assistance.²⁵ This ensures that the capital comes with mentorship and business planning support, significantly reducing default risk compared to the “sign and go” nature of student loans.

Integrating T.H.R.I.V.E. into the Curriculum

The SBA’s “T.H.R.I.V.E. Emerging Leaders Reimagined” program provides executive-level training for small business owners.²⁶ While the full program is designed for established businesses, a “Foundation” version should be developed and integrated into the “Related Technical Instruction” (RTI) component of the cosmetology apprenticeship.

• Business Literacy: Apprentices would complete modules on tax compliance (Schedule C filing), cash flow management, marketing, and employment law. This curriculum would replace the outdated “salon management” chapters in standard cosmetology textbooks which often bear little resemblance to modern business practices.
• Tax Compliance and the Tip Gap: By explicitly training apprentices on the benefits of reporting income (e.g., mortgage eligibility, social security contributions) and the mechanics of the new 2025 tip reporting tax credits ²⁸, the SBA can help bring the industry’s “shadow income” into the formal economy. This addresses the DOE’s data blind spot by solving it at the source: changing the culture of tax compliance through education.

Reforming 7(a) Loans for Training Salons

To make the apprenticeship model viable, small salon owners must be incentivized to become sponsors. The SBA 7(a) loan program, the agency’s primary vehicle for providing financial assistance to small businesses ²⁹, offers a powerful lever.

• Sponsor Incentives: The SBA could introduce a “Workforce Development” modification to the 7(a) program. Salons that become DOL Registered Apprenticeship sponsors could receive fee waivers (up to 3% of the loan value) or interest rate reductions on loans used to expand their facilities.
• Infrastructure Investment: 7(a) funds can be used for “leasehold improvements” and “equipment”.³¹ A salon owner could use a subsidized 7(a) loan to add two new stations specifically for apprentices or to build out a classroom area, directly expanding the industry’s training capacity.
• Working Capital Support: The SBA’s new Working Capital Pilot (WCP) program, offering lines of credit up to $5 million ³², could be vital for salons bridging the productivity gap of a new apprentice. Access to a WCP line of credit ensures that the salon can meet payroll obligations during the initial months of an apprenticeship when the trainee is not yet generating significant revenue.

IV. Legislative and Regulatory Pathways for Transfer

Implementing this structural shift requires a coordinated legislative and regulatory strategy that redirects existing funding streams rather than creating new ones. The goal is to repurpose the “Workforce Pell” momentum and Title IV appropriations toward WIOA and SBA channels.

1. Redirecting “Workforce Pell” to WIOA ITAs

Current legislative proposals, such as the “One Big Beautiful Bill Act” (OBBBA) and the “Bipartisan Workforce Pell Act,” seek to expand Pell Grant eligibility to short-term programs (8-15 weeks).¹ While well-intentioned, these bills in their current form risk repeating the mistakes of the past by making for-profit institutions eligible for these funds.³⁴ This would open a new spigot of federal money for predatory schools to exploit.

• The Policy Pivot: The “Workforce Pell” concept should be decoupled from Title IV and the DOE entirely. Instead, the funding authorized for short-term training should be routed through the Workforce Innovation and Opportunity Act (WIOA) as “Individual Training Accounts” (ITAs).
• Local Control: WIOA funds are managed by local Workforce Development Boards (WDBs).³⁶ These boards are comprised of local business leaders and community stakeholders who are far better positioned than bureaucrats in Washington to determine if their local economy needs more hairdressers. If a local market is saturated, the WDB can deny funding for cosmetology training, introducing a market discipline mechanism that Title IV lacks.
• Cost Control: WIOA allows local boards to set caps on ITA amounts.³⁶ If a WDB sets a $4,000 cap for cosmetology training (reflecting the cost of community college or apprenticeship RTI), for-profit schools charging $20,000 will be forced to lower their prices or exit the market. This effectively ends the inflationary tuition spiral.

2. State Licensing Reform and Reciprocity

A significant hurdle to a federal apprenticeship model is the patchwork of state licensing laws. Some states do not currently accept apprenticeships for licensure, while others impose punitive hour requirements that make apprenticeships longer than schooling.¹⁴

• Conditioning Federal Funds: The federal government cannot commandeer state licensing boards, but it can use the power of the purse. The DOL can condition the receipt of new “Apprenticeship Expansion Grants” on states adopting “Apprenticeship Reciprocity” and “Ratio Reform.”
• Model Legislation: The federal government should champion model legislation similar to that proposed by the Institute for Justice (IJ), such as the “Niche-Beauty Services Opportunity Act”.⁴⁰ This legislation advocates for unbundling services (e.g., allowing blow-dry bars or braiders to operate without a full cosmetology license) and normalizing apprenticeship ratios (e.g., allowing one instructor to supervise two apprentices instead of one).
• De-linking Safety from Hours: The DOL should fund studies verifying the IJ’s findings that health and safety outcomes are uncorrelated with program length.⁴¹ This data can be used to pressure state boards—often captured by school owners—to reduce hour requirements to a scientifically defensible minimum (e.g., 100 hours of sanitation training) while leaving the artistic training to the labor market.

3. Tax Policy Levers

To rapidly accelerate the adoption of the apprenticeship model, the tax code should be utilized to de-risk the hiring decision for salons.

• Work Opportunity Tax Credit (WOTC) Expansion: The WOTC provides a federal tax credit for hiring individuals from certain targeted groups.⁴² This program should be explicitly expanded to include “Registered Apprentices in High-Default Industries.” A salon owner hiring a cosmetology apprentice could receive a tax credit of up to $2,400 or more, offsetting the cost of training and lost productivity.
• Tip Compliance Incentives: The 2025 “Tip Tax” changes, which allow for a federal deduction on reported tips and employer payroll tax credits ²⁸, provide a unique compliance hook. The IRS could rule that to qualify for the enhanced tip credit, a salon must be a “Qualified Training Sponsor” or demonstrate that its staff has completed SBA financial literacy training. This ties tax benefits directly to professionalization and education.

V. Overcoming Barriers and Addressing Counter-Arguments

Any proposal to disrupt a multi-billion dollar sector will face entrenched opposition. Addressing these concerns proactively is essential for the viability of this reform.

The “Cheap Labor” and Exploitation Concern

A common critique from the school lobby is that apprenticeships inevitably lead to exploitation, where “students” are used as cheap labor for cleaning and reception duties without receiving adequate technical training.⁴³

• Mitigation Strategy: The DOL Registered Apprenticeship system already has a robust mechanism to prevent this: the “Work Process Schedule” (WPS). Every RAP must document specific hours spent on specific tasks (e.g., 200 hours on chemical texturing, 300 hours on cutting).¹⁰ Sponsors are audited to ensure compliance.
• Comparative Advantage: While exploitation is a risk in any labor relationship, the apprentice model affords the learner the legal protections of an employee, including Fair Labor Standards Act (FLSA) coverage, minimum wage, and workers’ compensation. In contrast, the current school model allows for-profit institutions to use students for unpaid labor in “student salons” where the school keeps the revenue—a form of exploitation that is currently federally subsidized.⁶

The “Health and Safety” Defense

State boards and schools often argue that rigorous, long-duration schooling is necessary to protect public health and safety.

• Evidence-Based Rebuttal: Research by the Institute for Justice has conclusively shown that there is no statistical difference in safety outcomes (e.g., bacterial infections, sanitation violations) between states with high licensing burdens and those with low ones.⁴¹
• Targeted Training: The DOL model does not abandon safety; it refines it. By separating “Health and Safety” into a standardized, non-negotiable certification (similar to ServSafe in the restaurant industry) that must be passed before touching a client, the apprenticeship model ensures safety more effectively than a 1,500-hour curriculum where sanitation is diluted among artistic instruction.

The “Access” and Equity Argument

Opponents may argue that removing Title IV aid will restrict access for low-income students who rely on Pell Grants and student loans to cover living expenses while in school.

• The Reality of Access: The current system does not provide “access” to a career; it provides access to debt. A low-income student is far better served by a paid apprenticeship—earning $12 to $15 an hour immediately—than by accruing interest on a $15,000 loan while earning nothing for a year.
• Supportive Services: For students facing barriers (transportation, childcare, tools), WIOA funds are specifically designed to provide “supportive services”.³⁷ These funds are grant-based and flexible, unlike student loans which must be repaid. This ensures that the apprenticeship pathway remains accessible to the most vulnerable populations.

VI. Implementation Roadmap

The transition from a DOE-dominated model to a DOL/SBA-led ecosystem should be phased to ensure stability for current students and allow the market to adjust.

• Phase 1: The Pilot (Year 1-2): Launch a “Beauty Workforce Innovation Pilot” in 5 states with strong existing apprenticeship laws (e.g., Wisconsin, Virginia, California). Redirect a portion of WIOA discretionary funds to these states to fund ITAs for apprenticeship RTI. Offer SBA 7(a) fee waivers to salons in these states that register as sponsors.
• Phase 2: Regulatory Alignment (Year 3-4): The DOL issues new “National Guideline Standards” for cosmetology apprenticeships that align with the pilot results. The SBA rolls out the “Vocational Trade Startup” microloan product nationwide. Congress amends the Higher Education Act to phase out Title IV eligibility for cosmetology programs that do not meet strict new “Earnings Premium” benchmarks, effectively sunsetting the worst-performing schools.
• Phase 3: Full Transfer (Year 5+): Oversight authority is formally transferred. Accreditation bodies are replaced by State Apprenticeship Agencies (SAAs) as the primary quality assurance mechanism. Title IV funds for the sector are fully repurposed into WIOA grants and workforce tax credits.

Conclusion

The transfer of beauty education oversight from the Department of Education to the Department of Labor and SBA is a necessary correction of a profound market failure. The current Title IV model has commoditized students, generating guaranteed profits for schools and guaranteed debt for taxpayers, all while failing to produce graduates who can earn a living wage.

By reclassifying cosmetology as a Business-Apprentice Trade rather than an Academic Pursuit, the federal government can eliminate the “Gainful Employment” paradox, align training with actual labor market needs, and foster a new generation of debt-free entrepreneurs. This proposal offers a pragmatic, revenue-neutral path to dignifying the profession and protecting the student, replacing a legacy of debt with a future of work.

Key Data Comparison: School vs. Apprenticeship Model

Feature	Current DOE / Title IV School Model	Proposed DOL / SBA Apprenticeship Model
Primary Funding	Federal Pell Grants & Student Loans	Employer Wages, WIOA Grants, SBA Loans
Student Cost	$15,000 – $25,000 (Tuition + Interest)	$0 Tuition; Net Positive Earnings
Student Income	-$15,000 (Debt accrual)	+$20,000 – $30,000 (Wages earned)
Duration	10-15 Months (Unpaid)	12-24 Months (Paid)
Curriculum	Time-Based (Clock Hours)	Competency-Based (Skill Mastery)
Business Training	Minimal / Theoretical	SBA T.H.R.I.V.E. / Practical Compliance
Default Risk	High (Cohort Default Rates >30%)	Low (No student debt to default on)
Taxpayer Impact	High (Loan discharges, Pell grants)	Neutral/Positive (Tax credits vs. higher tax base)

Citations Table

Category	Source IDs
Gainful Employment / Debt	1
Apprenticeship Standards	10
SBA Programs	25
Foreign Models	20
Legal/Regulatory	41
Workforce Pell/OBBBA	1

Works cited

1. What the One Big Beautiful Bill Means for Cosmetology Students – New America, accessed January 14, 2026, https://www.newamerica.org/education-policy/edcentral/what-the-one-big-beautiful-bill-means-for-cosmetology-students/
2. Trump’s Education Department Shocks with Support of Biden’s Financial Value Transparency and Gainful Employment Rule | Thompson Coburn LLP, accessed January 14, 2026, https://www.thompsoncoburn.com/insights/trumps-education-department-shocks-with-support-of-bidens-financial-value-transparency-and-gainful-employment-rule/
3. Q&A: What’s in the New Gainful Employment Rule? | Third Way, accessed January 14, 2026, https://www.thirdway.org/blog/q-a-whats-in-the-new-gainful-employment-rule
4. Cut Short: The Broken Promises of Cosmetology Education: Beauty School Blunders: The System Costs Students – New America, accessed January 14, 2026, https://www.newamerica.org/education-policy/reports/cut-short-the-broken-promises-of-cosmetology-education/beauty-school-blunders-the-system-costs-students/
5. Education Department sued over gainful employment rule – Higher Ed Dive, accessed January 14, 2026, https://www.highereddive.com/news/education-department-sued-over-gainful-employment-rule/703689/
6. Cosmetology Training Needs a Make-Over – The Century Foundation, accessed January 14, 2026, https://tcf.org/content/report/cosmetology-training-needs-a-make-over/
7. Federal Aid, Licensure, and the Debt Crisis in Cosmetology Education – RESEARCH 2025, accessed January 14, 2026, https://naba4u.org/2025/12/federal-aid-licensure-and-the-debt-crisis-in-cosmetology-education-research-2025/
8. American Beauty Schools Educating a Workforce for Tomorrow, accessed January 14, 2026, https://myaacs.org/wp-content/uploads/2022/10/AACS_Cosmetology_Report_10-2022.pdf
9. Should Failing Beauty Schools Keep Access to Federal Aid? New Data Suggests No, accessed January 14, 2026, https://www.newamerica.org/education-policy/edcentral/should-failing-beauty-schools-keep-access-to-federal-aid-new-data-suggests-no/
10. Occupation Finder: Hairdressers, Hairstylists, and Cosmetologists | Apprenticeship.gov, accessed January 14, 2026, https://www.apprenticeship.gov/apprenticeship-occupations/listings?occupationCode=39-5012.00
11. Cosmetologist (0096CB V1) Competency-Based – ApprenticeshipStandardsDotOrg – Registered Apprenticeship Standards Library, accessed January 14, 2026, https://www.apprenticeshipstandards.org/occupation_standards/675c3d2c-90bd-4cb0-afb5-4920b6b2495b
12. Apprentice Cosmetologist Salary: Hourly Rate January 2026 – ZipRecruiter, accessed January 14, 2026, https://www.ziprecruiter.com/Salaries/Apprentice-Cosmetologist-Salary
13. Time-Based, Competency-Based, or Hybrid Programs? Considerations for Selecting an Approach to Registered Apprenticeship – Urban Institute, accessed January 14, 2026, https://www.urban.org/sites/default/files/2023-08/Time-Based%2C%20Competency-Based%2C%20or%20Hybrid%20Programs.pdf
14. Cosmetology Apprenticeships | Apprenticing as a Cosmetologist, accessed January 14, 2026, https://www.cosmetology-license.com/cosmetology-apprenticeships/
15. All About Salon Apprenticeship Programs – This Ugly Beauty Business, accessed January 14, 2026, https://thisuglybeautybusiness.com/2019/09/all-about-salon-apprenticeship-programs.html
16. Cosmetology Apprentice | WTCS – Wisconsin Technical College System, accessed January 14, 2026, https://www.wtcsystem.edu/programs/find-your-program/cosmetology-apprentice/
17. Cosmetologist Apprenticeship – Wisconsin Department of Workforce Development, accessed January 14, 2026, https://dwd.wisconsin.gov/apprenticeship/occupations/cosmo.htm
18. Apprenticeship Information – California Board of Barbering and Cosmetology, accessed January 14, 2026, https://www.barbercosmo.ca.gov/applicants/apprentice_info.pdf
19. Article 3. Apprenticeship – California Board of Barbering and Cosmetology, accessed January 14, 2026, https://www.barbercosmo.ca.gov/laws_regs/art3.shtml
20. SMEs will no longer have to contribute to apprenticeship costs for 16–21-year-olds from April 1 – Professional Beauty, accessed January 14, 2026, https://professionalbeauty.co.uk/smes-will-no-longer-have-to-contribute-to-apprenticeship-costs-for-16-21-year-olds-from-april-1
21. accessed January 14, 2026, https://www.totalpeople.co.uk/about/news-blogs/employer-incentives-apprenticeships/#:~:text=Apprenticeship%20funding%20for%20employers%20who,%C2%A3500%20after%20a%20year.
22. Employer Incentives for Apprentices: A Full Guide for UK Businesses – Total People, accessed January 14, 2026, https://www.totalpeople.co.uk/about/news-blogs/employer-incentives-apprenticeships/
23. Qualification: Hairdresser (m/f) – Deutschen Qualifikationsrahmen (DQR), accessed January 14, 2026, https://www.dqr.de/dqr/shareddocs/qualifikationen-neu/en/Hairdresser-m-f.html
24. How Germany’s dual vocational training system works – deutschland.de, accessed January 14, 2026, https://www.deutschland.de/en/topic/business/how-germanys-dual-vocational-training-system-works
25. Microloans | U.S. Small Business Administration, accessed January 14, 2026, https://www.sba.gov/funding-programs/loans/microloans
26. SBA THRIVE | U.S. Small Business Administration, accessed January 14, 2026, https://www.sba.gov/sba-learning-platform/sba-thrive
27. New THRIVE SBA Program Helps Small Business Owners – EisnerAmper, accessed January 14, 2026, https://www.eisneramper.com/insights/blogs/private-client-blog/small-business-owners-thrive-program-pb-blog-0522/
28. 2025 Tip Tax Changes for Spas: What’s New and How to Stay Compliant – Addo Aesthetics, accessed January 14, 2026, https://www.addoaesthetics.com/blog/2025-tip-tax-changes-for-spas-whats-new-and-how-to-stay-compliant/
29. 7(a) loans | U.S. Small Business Administration, accessed January 14, 2026, https://www.sba.gov/funding-programs/loans/7a-loans
30. SBA 7(a) Loans for Beauty Salons, accessed January 14, 2026, https://www.sba7a.loans/sba-7a-loans-small-business-blog/salon-loans/
31. Terms, conditions, and eligibility | U.S. Small Business Administration, accessed January 14, 2026, https://www.sba.gov/partners/lenders/7a-loan-program/terms-conditions-eligibility
32. 7(a) Working Capital Pilot program | U.S. Small Business Administration, accessed January 14, 2026, https://www.sba.gov/partners/lenders/7a-loan-program/7a-working-capital-pilot-program
33. H.R.6585 – 118th Congress (2023-2024): Bipartisan Workforce Pell Act, accessed January 14, 2026, https://www.congress.gov/bill/118th-congress/house-bill/6585
34. Workforce Pell Expansion Explained | BestColleges, accessed January 14, 2026, https://www.bestcolleges.com/news/workforce-pell-grant-expansion-explained-adult-learners/
35. Workforce Pell Grants: Moving Forward with Accountability – Bipartisan Policy Center, accessed January 14, 2026, https://bipartisanpolicy.org/article/workforce-pell-grants-moving-forward-with-accountability/
36. 20 CFR Part 680 Subpart C — Individual Training Accounts – eCFR, accessed January 14, 2026, https://www.ecfr.gov/current/title-20/chapter-V/part-680/subpart-C
37. Monroe County/Rochester Workforce Development Board WIOA Policy 104 – RochesterWorks, accessed January 14, 2026, https://rochesterworks.org/images/Policy_104_Individual_Training_Account_Guidelines_7-26-2022.pdf
38. Figure 1. State Distribution of WIOA-AA Expenditures Between Career Services and Training – Congress.gov, accessed January 14, 2026, https://www.congress.gov/crs_external_products/R/HTML/R48542.html
39. Illinois Cosmetology State Requirements – Elite Beauty Society, accessed January 14, 2026, https://elitebeautysociety.com/cosmetology-insurance/state-board-cosmetology/illinois/
40. Niche-Beauty Services Opportunity Act – The Institute for Justice, accessed January 14, 2026, https://ij.org/legislation/niche-beauty-services-opportunity-act/
41. New Study Shows That Heavier Licensing Burdens Do Not Improve Health and Safety, accessed January 14, 2026, https://ij.org/press-release/new-study-shows-that-heavier-licensing-burdens-do-not-improve-health-and-safety/
42. Work Opportunity Tax Credit | Internal Revenue Service, accessed January 14, 2026, https://www.irs.gov/businesses/small-businesses-self-employed/work-opportunity-tax-credit
43. Apprenticeship oversight and fees under scrutiny after board finds widespread variation; notices and hearings underway, accessed January 14, 2026, https://citizenportal.ai/articles/5964170/Apprenticeship-oversight-and-fees-under-scrutiny-after-board-finds-widespread-variation-notices-and-hearings-underway
44. The End of Cheap Labor and “Affordable” Beauty Services, accessed January 14, 2026, https://www.beautylaunchpad.com/business/education/article/22118659/the-end-of-cheap-labor-and-affordable-beauty-services
45. Why Licensing Has Little Impact on Health and Safety – The Institute for Justice, accessed January 14, 2026, https://ij.org/report/clean-cut/why-licensing-has-little-impact-on-health-and-safety/
46. Apprenticeship – California Board of Barbering and Cosmetology – CA.gov, accessed January 14, 2026, https://www.barbercosmo.ca.gov/applicants/apprenticeship.shtml
47. Requirements for Apprenticeship Sponsors Reference Guide, accessed January 14, 2026, https://www.apprenticeship.gov/sites/default/files/apprenticeship-requirements-reference-guide.pdf
48. Eligible NAICS for the Women-Owned Small Business Federal Contracting program – SBA, accessed January 14, 2026, https://www.sba.gov/document/support-eligible-naics-women-owned-small-business-federal-contracting-program
49. Apprenticeship Funding Eligibility & Rules Simplified for Employers – Total People, accessed January 14, 2026, https://www.totalpeople.co.uk/about/news-blogs/apprenticeship-funding-eligibility-rules/
50. Institute for Justice Stands With Barber Professionals to Praise Passage of Legislation Allowing Supervised Barber and Beauty Work Without A License, accessed January 14, 2026, https://ij.org/press-release/institute-for-justice-stands-with-barber-professionals-to-praise-passage-of-legislation-allowing-supervised-barber-and-beauty-work-without-a-license/
51. Preparing to Implement Workforce Pell Grants: States Should Legislate to Solidify Student Protections, accessed January 14, 2026, https://ticas.org/accountability/workforce-pell-state-model-legislation/
52. Workforce Pell Is (Finally) Law. Now What? | Richmond Fed, accessed January 14, 2026, https://www.richmondfed.org/region_communities/regional_data_analysis/community_college_survey/community_college_insights/2025/workforce_pell_finally_law_now_what