The U.S. Department of Education recently advised Colorado schools teaching Massage Therapy that programs over 750 hours in length are no longer eligible for participation in Title IV FSA Programs. Although such programs were historically eligible, the State of Colorado recently mandated a minimum number of hours for licensure. Massage Therapists now must complete a minimum of 500 hours of training before taking their State license exams in Colorado. Colorado isn’t the only state to establish minimum hours or minimum credits needed for licensure. A number of States require a minimum number of hours before students can obtain professional licenses in fields like Barbering, Cosmetology, Certified Nurses Aid (CNA) and Nursing. If your state has such requirements, better check your programs fast.
Although this rule has been around for a while, ED has recently provided clarification that any Gainful Employment program where the State has a minimum number of hours required for training, the school’s GE programs cannot exceed the State’s minimum requirements by more than 50 percent. This is true whether the program is a clock hour or credit hour program. So, if the State has a clock hour minimum requirement for a certain program of study, but the school offers the program in credit hours, the school will have to demonstrate how the number of in–class clock hours under our credit hour definition in 34 CFR 600.2 or in our clock-to-credit hour conversion, if the program is subject to the conversion, does not exceed the State minimum by more than 50 percent.
In addition, if the State provides a minimum training requirement in credit hours, an institution’s credit hour GE program may not exceed the State minimum by more than 50% of the credit hours required by the State.
This is a very important concept to understand and implement since it can impact the eligibility of an entire program for Title IV purposes.