The barber and cosmetology world is evolving at a rapid pace. With changes to legislation in different States, developments in exam delivery and development, and changes to health and safety regulations since the pandemic.
In this environment, an increasing number of Cosmetology State Boards are signing up to join the Interstate Cosmetology Compact. This includes the California Board of Cosmetology, one of the largest programs in the United States. As a result of this move towards seamless bi-directional reciprocity, it is becoming easier for licensed professionals to work in multiple States without having to relicense every time. And there are multiple benefits to State Boards from joining the Compact.
We met with Leslie Roste, State Government Relations at The Future of the Beauty Industry Coalition (FBIC), to find out more.
Let’s start with the fundamentals. Why do we license barbering and cosmetology?
There’s a misconception that licensure testing is like a final exam, for example an SAT or an ACT test at the end of High School. They are not the same. A cosmetology license is exclusively intended to protect consumers from harm.
Licensure by a state is only intended to ensure the safety of consumers, and we work in an industry where a practitioner has the potential to cause injury, and we are working to prevent that. People often forget why we have licensing, so it’s important to always remember this purpose – while we are deciding what someone needs to learn, the hours they need to learn and what we assess in a State Board exam.
How can we protect against deregulation?
Regulation (licensure) is needed to protect public safety, but to be effective and worthwhile licensure must deliver across four areas:
- Standardization – what can we agree on across the States? What are the risks? What do test takers need to know to avoid them? What learning do they need and what exams will demonstrate the necessary skills and knowledge? I am a nurse and I see how well this works in nursing. We can learn a lot from that sector about the benefits of standardization.
- Defensibility – we need clear and consistent rules, exams and licensing requirements. We also need good arguments as to why these rules exist, why these exams are important, and how these licensing requirements count. Always remembering that we’re not making a judgement about whether an individual does a good haircut or offers great customer service. We are assessing whether they are safe.
- Focus on the real risks – licensure is important, but we need to be careful not to exaggerate the risks or focus on the wrong thing. For example, we spend 80% of time teaching hair and 20% on skin and nails. But the risks and injuries reported to State Boards are the opposite – 80% related to skin and nails and 20% to hair. I would maintain there’s less risk of harm in hair than there is in skin and nails, and that needs to be better reflected in licensure requirements.
- Assess safety – the key thing to remember is that States assess safety and schools assess competence. And there is a way to develop more competent and safe licensees in less hours than many people working for State Boards might think.
Many States are reducing hours. How do we make room within licensure programs?
There are things that can be removed from cosmetology State licensure programs and still turn out safe licensees. Memorizing all the names of the bones in the body or the muscles in the face, for instance, isn’t necessary. Having that knowledge doesn’t make someone safer to work and students will likely forget the information the day after their exam.
Multiple States have already reduced to a 1,000-hour program. When hours are reduced, we still have to ensure someone is safe and that they have mobility with that license. That’s where the Compact comes in.
What is a Compact and how does it work?
Compact laws are very common outside of occupational licensing and are legislated agreements between states on how things like land rights, water rights and licenses will be handled. The oldest Compact is between New York and New Jersey and created the Port Authority to ensure terms around water use and rights between the two States. The biggest Compact, other than occupational licensing compacts and the driver’s license, is between the seven Colorado River Basin States that use water from the Colorado river, known as the Colorado River Compact. The largest and oldest occupational licensing compact is the nursing compact, which is 20 years old and has 42 states participating.
Consider how the driver’s license works. When you live in Texas, and you have proven that you are safe to drive in Texas, it is agreed that you are safe enough to drive in all the other States. So why, if you are safe to do hair, skin or nails in Texas, aren’t you considered safe enough to do it in any other State?
Why is the Department of Defense sponsoring the development this Compact?
People are often surprised about this, but the Department of Defense, has sponsored the development of multiple licensing compacts to benefit their military spouses/families. Being a spouse or family member of someone in active duty military service, ensures you will move frequently and if you are working in a licensed profession, it may make continuing to work extremely difficult. In fact, the unemployment rate for military spouses is 21-27% and often means that people just give up on their career or practice without a license, putting them at risk. Relicensing is time consuming and expensive, even with the expedited laws in some States, particularly if you are moving from a State with lower hours or different testing requirements. This creates barriers to employment for military spouses and the rest of the family. While the Compact is a true necessity for military families, it applies to all licensees in member states, not just those with military ties.
Who else does the Compact benefit?
Multiple groups benefit from the Compact:
- Licensees who use one home state license that allows them to work in all member states.
- Employers with multiple locations that can be flexible about where their staff work.
- State Boards with access to a shared database where licensees can be red flagged.
- The cosmetology industry as a whole, which benefits from a platform for states to work together on common issues.
How do State Boards benefit?
The Compact creates a national platform for States via a Commission that is made up of one member from each State. The Commission meets monthly to discuss relevant issues.
As well as the ability to red flag licensees who might be creating problems, the Compact database allows States to collaborate on investigations about a particular licensee or a cosmetology school. All that information will be reflected on the database.
The final benefit for State Boards is that funding for the Commission and the database comes from licensing fees. Like nursing, there is a higher fee for a multi-State license than a single State license. The cost of a license is set by each State and they can fund Compact costs from licensing fees.
What are the timescales involved?
There’s a lot of movement and excitement about this opportunity even though it’s only been available as of 3rd January this year. The first three States have already been enacted – Kentucky, Alabama and Arizona. When seven States are enacted the Compact becomes activated and people can apply for a multi-state license and begin moving freely between those States. The Compact expects to have 20+ member states by 2025.
Where does exam development come into this?
One of the areas where we can ensure standardization, defensibility and a focus on what’s important is exam development. Right through from the job analysis that breaks down the knowledge and skills required for the job, Subject Matter Expert (SME) involvement in creating the exam content outline and items, to item review and standard setting is critical.
Diverse SME involvement is important to ensure the exam is relevant to all States, so the goal is to include representatives from multiple States are involved in the exam development process.
What’s new in barbering and cosmetology exams?
We’re seeing changes in a couple of areas. For example, written practical exams which replicate a work situation in writing or using an image. These are multiple choice items where the test taker is asked to choose the correct answer from a list of options.
We’re also seeing changes in exam delivery to more remote exams, with online proctoring. As well as multi-modal programs where test takers can choose to take their exam remotely or use the facilities at a test center. This gives them more flexibility and choice of exam times, for example.
There’s so much work going on in the field. As well as growing the Compact, I work with PSI on their Barber and Cosmetology Advisory Board with a team of experienced individuals from across the profession. We’ve pulled together a list of universal infection control and safety precautions to support the move to standardization and increased defensibility.
All of this is overcoming barriers for test takers, whether that’s military spouses or others experiencing the challenges of State-to-State licensure. As well as those struggling with education costs and getting a return on the funds they have invested. It’s satisfying work and an exciting time to be working in barbering and cosmetology.