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Protecting Beauty Education: Make Your Voice Heard

May 5, 2026
Paul Mitchell Schools

On April 20, 2026, the US Department of Education published a Notice of Proposed Rulemaking (Docket ID ED-2026-OPE-0100) for new Earnings Accountability regulations (also known as the Gainful Employment / Earnings Premium rule). This rule could completely change the beauty industry as we know it.

Despite the One Big Beautiful Bill Act (OBBB) specifically excluding non-degree/undergraduate certificate programs such as cosmetology and barbering, the Department has applied its “earnings test” to those programs anyway. The Department’s own analysis projects that approximately 92 percent of cosmetology programs would fail the test, putting their Title IV eligibility future at serious risk—along with access to those schools for thousands of students.

Fortunately, the public comment period for this notice is now open and closes May 20, 2026. For those who care about the future of beauty and wellness education, this is our most important opportunity to make our voices heard before the rule is finalized.

WATCH THIS!

For a brief summary of the challenge and overview of the comment process, watch this video. Feel free to share this video with others who may not understand the issue at hand and encourage them to make a comment.

NEED HELP WITH YOUR COMMENT?

If you would like to comment but need some guidance, our friends at the American Association of Career Schools (AACS) have created ready-to-use templates to make submitting effective comments fast and easy.

Beginner Guide — Intended for anyone who cares to comment. This guide explains the proposal and its background, why the 92.5 percent projected failure rate is concerning, and how the general public can submit a comment.

Intermediate Guide — Intended for institutions that want to go further and explain why the Earnings Premium metric is structurally misaligned. It compiles input from the broader AACS Regulatory Response Coordination Group into a menu of 12 positions, drawing from congressional letters, studies, analyses, and ideas already circulating within the group.

Salon, Spa, and Barbershop Guide — Intended for employers. This guide translates the same core issues into workforce language, focusing on hiring, time to earnings, hours worked, tips, flexibility, and the importance of access to accredited training programs for maintaining a worker pipeline. It also encourages employers to submit their own public comments.

Please note that the templates in these guides are not meant to be copied. It’s important to personalize the template with your personal or business-related story, such as why you chose the beauty industry, how it has made an impact in your life, and real-world examples—unique, authentic comments carry the most weight.

Submit Comments Here

RELATED LINKS

https://www.mysecretimpact.com/

https://myaacs.org/submit-your-comment/

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