At Louisville Beauty Academy, we don’t wait for the future of work to arrive — we prepare students for it now.

Today, careers are no longer decided only by hours completed, licenses earned, or interviews attended. Increasingly, artificial intelligence evaluates behavior, consistency, and visible progress long before a human ever meets you.

That is why we are officially incorporating the principles from the new book:

📖 Your Boss Is AI: Why Your Digital Proof-of-Work Decides Your Career Before You’re Interviewed
by Di Tran, Di Tran University – The College of Humanization

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🔑 What This Means for LBA Students

At Louisville Beauty Academy, effort that is documented now counts more than effort that is hidden.

Students who:

• Consistently document learning and practice
• Show visible progress and reflection
• Maintain professional, respectful digital presence
• Demonstrate discipline and follow-through

are actively reducing career risk and increasing trust — not later, but now.

And we believe that kind of behavior should be recognized and rewarded.

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💰 Proof-of-Work = Tuition Incentives

As part of our Gold-Standard Over-Compliance & Career Readiness Initiative, LBA is aligning tuition discounts and incentives with real, verifiable student effort.

This means:

• Documented progress = career credit
• Consistency = measurable value
• Visible learning = earned incentives

We reward discipline, transparency, and growth, not excuses or silence.

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📲 What Counts as Proof-of-Work?

This is not about popularity.
This is not about influencers.

It is about:

• Showing up consistently
• Sharing what you are learning
• Reflecting professionally
• Demonstrating real progress over time

Even 5 minutes a day of honest documentation builds career equity.

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🎓 Why We’re Doing This

Because the reality is simple:

In the age of AI, being unknown is not neutral.
Absence is interpreted as uncertainty.
Uncertainty is treated as risk.

We refuse to let our students graduate as “unknown.”

At LBA, students leave with:

• A license
• A skill set
• AND a visible, trustworthy proof-of-work record

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🚀 Start Now — Not After Graduation

This initiative is not optional preparation for the future.
It is the future.

Students who begin documenting now:

• Build trust earlier
• Reduce career risk
• Enter the workforce already validated

We are proud to lead this shift — and proud to reward students who lead themselves.

📘 Your Boss Is AI is now part of our career incentive framework, because effort that is visible deserves to be valued.

The Career Credit Master Plan: A Reputation-Based Paradigm for the Louisville Beauty Academy – RESEARCH AND PODCAST SERIES 2026

At Louisville Beauty Academy, we teach Gold-Standard Compliance.
That means not only following the rules, but understanding how Kentucky’s regulatory system is structured, so schools and professionals can operate with clarity, confidence, and professionalism.

Clear understanding of regulatory authority supports:

• Over-compliance by design
• Constructive inspections
• Accurate documentation
• Long-term institutional protection

This educational overview explains the Hierarchy of Authority that governs beauty education and licensing in Kentucky.

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🔺 The Hierarchy of Authority (Educational Framework)

1️⃣ Statutes — KRS (Legislative Authority)

Kentucky Revised Statutes (KRS) are laws enacted by the Kentucky General Assembly.
They establish the legal foundation for cosmetology education, licensing, and enforcement.

All regulatory authority exercised by boards and agencies originates from statute.

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2️⃣ Administrative Regulations — KAR (Regulatory Authority)

Kentucky Administrative Regulations (KAR) are adopted by the Board to implement and operationalize statutory requirements.

Properly promulgated regulations are enforceable when they:

• Align with statutory authority, and
• Stay within the scope granted by the Legislature.

These regulations provide the day-to-day compliance framework used by schools and inspectors.

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3️⃣ Guidance Materials — Policies, Memos, Interpretations

Guidance materials may include:

• Policy statements
• Training memos
• Educational bulletins
• Interpretive guidance

These resources are designed to promote consistency, understanding, and best practices.
They are informational in nature and do not independently create new legal obligations unless expressly incorporated into statute or regulation.

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🎓 Best-Practice Compliance Approach

Gold-Standard Compliance encourages both cooperation and clarity.

When clarification is needed during an inspection or compliance review, it is appropriate to respectfully request the specific statutory or regulatory reference supporting a requirement so it can be accurately documented and addressed.

This approach:

• Promotes mutual understanding
• Supports accurate corrective action
• Strengthens institutional records
• Reinforces professionalism on all sides

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🛡️ Our Compliance Philosophy

At Louisville Beauty Academy, we believe:

• Education and compliance go hand in hand
• Over-compliance builds trust and stability
• Regulatory literacy protects students, schools, and the public

This framework is part of our ongoing Compliance Counsel education initiative and is supported by research through Di Tran University.

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⚖️ Disclaimer

This content is provided for general educational and professional development purposes to support compliance awareness and regulatory understanding.
It does not constitute legal advice and should be considered alongside applicable Kentucky statutes, administrative regulations, official Board communications, and, when appropriate, qualified legal counsel.

Educational programs and policies are subject to applicable Kentucky and federal laws and regulations, including KRS Chapter 317A and 201 KAR Chapter 12.

Plain-English version (with a little humor):

This graphic is meant to help students and schools understand how the law is structured, not to challenge inspectors or discourage compliance.

Think of it like this:
• Statutes (KRS) are the foundation
• Regulations (KAR) explain how to follow the foundation
• Guidance and memos help everyone stay consistent

At Louisville Beauty Academy, we teach over-compliance and professionalism first. Understanding where rules come from simply helps schools ask better questions, document accurately, and stay aligned with Kentucky law.

A little humor helps learning stick — but respect, cooperation, and education always come first.

Prepared by: Di Tran University & Louisville Beauty Academy Research Division

Date: January 2026

Subject: Federal and State Legislative Impacts on the Beauty Profession, Tax Parity with the Restaurant Industry, and the Philosophy of Workforce Humanization

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Executive Summary: The Convergence of Policy and Human Potential

The trajectory of the American beauty industry has long been defined by a paradox: while its practitioners provide essential services that enhance the well-being and confidence of millions, the industry itself has operated on the periphery of the formal economic structures that bolster other service sectors. For over three decades, a statutory chasm existed between the beauty professional and the restaurant worker—two roles that share the fundamental characteristics of service labor and tip reliance, yet were treated with disparate logic by the federal tax code. This report, produced by the research division of Di Tran University and Louisville Beauty Academy (LBA), posits that the legislative milestones of 2025—specifically the federal One Big Beautiful Bill Act (OBBBA) and Kentucky’s Senate Bill 22—represent more than mere regulatory updates. They signify a “Humanization Event” in the workforce, where the legal framework finally aligns with the professional dignity and economic reality of the 1.3 million individuals who power this industry.¹

The passage of the OBBBA, signed into law on July 4, 2025, by President Donald Trump ², fundamentally dismantles the inequities that have stifled salon growth since 1993. By extending the FICA Tip Tax Credit (IRC Section 45B) to beauty service businesses, the federal government has effectively validated the beauty salon as a distinct and valuable economic unit, equivalent in stature to the restaurant.³ Simultaneously, the “No Tax on Tips” and “No Tax on Overtime” provisions acknowledge the unique labor dynamics of the service economy, offering direct relief to the workforce.⁵

In parallel, the Commonwealth of Kentucky has emerged from a period of regulatory turbulence. The existential threat posed by the proposed abolition of the Board of Cosmetology in 2024 (HB 184) gave way to the constructive reforms of 2025 (SB 22), which prioritize public safety through the banning of Methyl Methacrylate (MMA) and enhance workforce accessibility through unlimited examination retakes.⁷

This report explores these shifts through the lens of “Humanization Power”—Di Tran University’s core philosophy that education and regulation should serve to elevate the human spirit rather than constrain it.⁹ We analyze the historical context of the “Restaurant Deal” of 1993, the specific mechanics of the new federal tax credits, the dramatic legislative history in Kentucky, and the strategic implications for salon owners and practitioners navigating this new era of parity.

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Part I: The Federal Paradigm Shift – The One Big Beautiful Bill Act (OBBBA)

1.1 The Architecture of the One Big Beautiful Bill Act

The One Big Beautiful Bill Act (Public Law 119-21) is a sweeping legislative package that addresses a diverse array of economic priorities, from domestic research expensing to individual income tax rates. However, for the beauty industry, its significance is singular and transformative. Title XI of the Act contains specific tax provisions that rectify a thirty-year oversight in the Internal Revenue Code, integrating the beauty sector into the benefits systems previously reserved for the food and beverage industry.³

The legislation acknowledges that the service economy has evolved. The traditional demarcation between “essential” industries (like food service) and “luxury” industries (like beauty) has blurred, as both have become integral pillars of the modern employment landscape. The OBBBA’s tax provisions for the beauty industry are designed to encourage compliance, formalize income reporting, and stimulate small business growth.

1.1.1 The Expansion of the Section 45B FICA Tip Credit

The cornerstone of the OBBBA for salon owners is the amendment of Internal Revenue Code Section 45B. This section, originally enacted in 1993, provides a general business credit for the employer portion of Social Security and Medicare taxes paid on employee tips. For decades, this credit was exclusively available to “food and beverage establishments.” The OBBBA expands the definition of eligible businesses to include those providing “beauty services,” specifically defined as barbering, hair care, nail care, esthetics, and body and spa treatments.³

This change is effective for tax years beginning after December 31, 2024. Its impact is immediate and tangible. In the pre-OBBBA era, a salon owner was liable for the employer’s share of FICA taxes (7.65%) on all reported tip income, with no mechanism for recovery. This created a perverse incentive: owners were financially penalized for having highly tipped employees, and some were tacitly encouraged to ignore underreporting to save on tax liability. The extension of Section 45B reverses this dynamic. By allowing a dollar-for-dollar tax credit, the government effectively subsidizes the FICA cost of tips, aligning the owner’s interest with full and accurate reporting.¹

1.1.2 The “No Tax on Tips” Deduction

Perhaps the most culturally resonant provision of the OBBBA is the “No Tax on Tips” policy. While the colloquial name suggests a complete tax exemption, the statutory reality is a “below-the-line” tax deduction. The law creates a new deduction for qualified tip income up to $25,000 per year for individuals. This provision is targeted at the working class, with eligibility phased out for taxpayers with modified adjusted gross income over $150,000 ($300,000 for joint filers).³

For the beauty professional, this deduction represents a massive increase in take-home pay. A stylist earning $45,000 in wages and $15,000 in tips will effectively shield the entire tip portion from federal income tax, provided they follow the strict reporting requirements. Crucially, the law requires that the recipient’s social security number be included on the tax return to claim the deduction, a measure designed to pull the “cash economy” into the light of the formal tax system.³

It is vital to note, as Di Tran University emphasizes in its financial literacy curriculum, that this deduction applies to income tax, not FICA tax. Workers must still pay their share of Social Security and Medicare taxes on tips. This ensures that while their current tax burden is lightened, their future eligibility for social security benefits is not compromised—a critical component of long-term “humanization” and security.⁵

1.1.3 The “No Tax on Overtime” Deduction

Recognizing the labor-intensive nature of service work, the OBBBA also introduces a deduction for qualified overtime pay for tax years 2025 through 2028. This provision allows workers to deduct the “premium” portion of their overtime pay (the “half” in “time-and-a-half”) from their taxable income.⁵

For salons that operate on a commission or hourly model, this is significant. The beauty industry is characterized by seasonal surges—prom season, wedding season, and the holidays—where 50 or 60-hour weeks are common. Previously, the overtime pay earned during these crunches was often eroded by moving the worker into a higher tax bracket. The new deduction ensures that the extra effort translates directly into extra purchasing power, validating the “grit and determination” that is central to the immigrant success stories LBA often documents.¹³

1.2 The Mechanism of Parity: Section 45B in Practice

To fully grasp the magnitude of the Section 45B expansion, one must examine the specific mechanics of the calculation, particularly how it differs slightly from the restaurant model. The credit is calculated based on tips received that are in excess of those treated as wages for the purpose of satisfying the minimum wage laws.

For the restaurant industry, the “minimum wage basis” was frozen at $5.15 per hour (the rate in effect on January 1, 2007). This means restaurants get a tax credit on FICA taxes paid on tips for every dollar earned above $5.15/hour.

For the newly added beauty service businesses, the OBBBA establishes the current federal minimum wage ($7.25 per hour) as the baseline.¹⁴ While this is a higher threshold than the restaurant industry’s frozen rate, it is a necessary starting point for parity.

Table 1: Comparative Analysis of Tax Credit Mechanics (Restaurant vs. Beauty)

Feature	Restaurant Industry (Food & Beverage)	Beauty Industry (Salon & Spa)
Credit Origin Year	1993 (Omnibus Budget Reconciliation Act)	2025 (One Big Beautiful Bill Act)
Minimum Wage Basis	$5.15 / hour (Frozen at 2007 rate)	$7.25 / hour (Current Federal Minimum)
Credit Applicability	FICA taxes on tips > ($5.15/hr wage)	FICA taxes on tips > ($7.25/hr wage)
IRS Form Used	Form 8846	Form 8846 (Updated for 2025)
Primary Beneficiary	Employer (W-2 Model)	Employer (W-2 Model)
Policy Goal	Prevent tax evasion; offset FICA burden	Parity; Formalize tip reporting

This table illustrates the structural integration of the beauty industry into the existing tax credit framework. While the baseline wage is higher for salons, the functional benefit is identical: the government becomes a partner in the cost of labor, encouraging employers to hire W-2 staff rather than relying solely on independent contractors to avoid tax liability.

1.3 The “Humanization” of Tip Income

From the philosophical perspective of Di Tran University, the OBBBA does more than adjust tax rates; it redefines the sociological status of the beauty worker. In the past, tip income in the beauty sector was often viewed by regulators as “suspect”—a vector for tax evasion or a sign of informal, hobbyist labor. By codifying a specific deduction for tips and extending the 45B credit, the federal government has formally recognized that tipping is a legitimate, integral component of the beauty professional’s compensation structure.¹

This legislative act “humanizes” the worker by validating their income model. It moves the beauty professional out of the “gray economy” and into the “white economy,” where their earnings are fully documented, credit-worthy for mortgages and loans, and protected by the same tax advantages as other sectors. The requirement that tips be “voluntary” and “not subject to negotiation” ³ further reinforces the professional boundary between client and practitioner, distinguishing the tip as a reward for service excellence rather than a mandatory fee.

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Part II: The Historical Struggle for Parity – Beauty vs. Restaurants

The user’s query poignantly asks how the beauty industry “became like restaurant workers.” This transformation was not inevitable; it was the result of a thirty-year advocacy struggle to correct a systemic imbalance created in 1993.

2.1 The 1993 Precedent: The “Restaurant Deal”

In 1993, the Clinton Administration and Congress were looking for ways to increase tax revenue. The IRS had identified unreported tip income in the restaurant sector as a major source of the “tax gap.” The initial proposal was to aggressively tax restaurants on all tips, holding employers liable for the FICA taxes on money that simply passed through their hands from customer to server.

The National Restaurant Association, a powerful lobbying entity, fought back. They argued that it was fundamentally unfair to tax an employer on income they did not generate or control. The resulting compromise was the creation of the Section 45B Credit. The deal was simple: Restaurant owners would enforce tip reporting and pay the FICA tax, but the government would give that money back to them as a general business tax credit. It was a “wash” for the employer, but it ensured the IRS got its data and the employees got their social security contributions.¹⁶

2.2 The “Lost Decades” of the Beauty Industry (1993–2024)

Crucially, the beauty industry was excluded from this deal. In 1993, the industry was less consolidated and had a weaker lobbying presence in Washington compared to the restaurant giants. As a result, for 32 years, a salon owner and a restaurant owner faced two different realities:

• The Restaurant Reality: The owner pays FICA on tips but gets a tax credit. Net cost: $0.
• The Salon Reality: The owner pays FICA on tips and gets nothing. Net cost: 7.65% of all tip income.

This inequity stifled the growth of commission-based salons. It forced many salon owners to abandon the employer model entirely, pushing stylists into “booth rental” (independent contractor) arrangements to avoid the crushing FICA liability. While booth rental offers freedom, it also fragments the industry and complicates workforce training—a challenge Louisville Beauty Academy has sought to address through its educational models.¹⁷

2.3 The Advocacy of the “Small Business Tax Fairness Act”

The road to the OBBBA was paved by the persistent efforts of industry advocates like the Professional Beauty Association (PBA). For years, they championed the “Small Business Tax Fairness and Compliance Simplification Act” (e.g., H.R. 45, H.R. 1349 in previous sessions).¹⁸ Sponsored by representatives like Darin LaHood (R-IL) and Suzan DelBene (D-WA), this bill sought a simple amendment: to insert “beauty service business” into Section 45B.

The arguments for this bill were rooted in fairness and gender equity. The beauty industry is overwhelmingly comprised of women and minorities.²⁰ By denying them the same tax break afforded to the restaurant industry, the tax code was effectively levying a discriminatory surcharge on female-owned small businesses.

In 2025, these arguments finally broke through. The “Small Business Tax Fairness” language was absorbed into the “One Big Beautiful Bill Act,” utilizing the momentum of broader tax reform to carry the beauty industry across the finish line. The passage of OBBBA is thus the culmination of a generational battle for recognition, proving that the industry is “like” the restaurant workers not just in function, but in legal standing.¹

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Part III: The Kentucky Regulatory Renaissance (2024-2025)

While the federal government was addressing tax equity, the Commonwealth of Kentucky was undergoing a radical transformation of its own regulatory landscape. The years 2024 and 2025 will be recorded in the history of Di Tran University as the era when the industry moved from existential crisis to modernized stability.

3.1 The Crisis of 2024: The Threat of Deregulation (HB 184 – 2024)

In the 2024 Regular Session, the Kentucky General Assembly introduced House Bill 184 (2024). This bill was an expression of legislative fury. Its text proposed the complete abolition of the Kentucky Board of Cosmetology and the repeal of KRS Chapter 317A.²²

The preamble of the bill was blistering, accusing the Board of “arbitrary and capricious” behavior, specifically citing the shutting down of nail salons and the alleged use of “deadly force” threats during inspections.²² This bill represented a “de-humanization” event—a breakdown of trust where the regulator was seen as an oppressor rather than a protector.

For Louisville Beauty Academy, this period was fraught with uncertainty. If the Board were abolished, who would license graduates? Would Kentucky degrees be recognized in other states? The “Chaos by Design” that Di Tran University researchers often analyze in social systems ²⁴ was on full display. Although HB 184 (2024) ultimately died in committee, its introduction served as a necessary shock to the system, forcing a dialogue about the need for reform rather than destruction.

(Note: It is critical for researchers to distinguish this failed 2024 bill from the passed HB 184 of 2025, which deals with insurance regulatory sandboxes and is unrelated to cosmetology.²⁵ Confusion between these two bills with the same number is a common pitfall in legislative tracking.)

3.2 The Consensus of 2025: Senate Bill 22

Rising from the debris of the 2024 conflict, Senate Bill 22 (2025) emerged as the vehicle for constructive modernization. Passed and signed into law, SB 22 addresses the grievances of the industry while preserving the necessary oversight machinery.²⁷

3.2.1 The MMA Ban: A Triumph of Safety Over Cost

One of the most significant provisions of SB 22 is the explicit statutory ban on the use of monomeric methyl methacrylate (MMA) in liquid nail enhancements.⁷ MMA is a dental-grade acrylic that, while cheap and durable, bonds so strongly to the natural nail that removal often results in severe damage or nail plate separation. Furthermore, its fumes are associated with respiratory issues for workers.

By banning MMA, Kentucky has taken a stand for the physical health of the beauty workforce. This aligns perfectly with the “Humanization Power” philosophy: the law now protects the worker’s body from degradation in the name of profit. It validates the LBA curriculum which has long taught the dangers of MMA, moving the standard from “best practice” to “state law.”

3.2.2 Unlimited Exam Retakes: Breaking the Barrier

SB 22 amends KRS 317A.120 to allow cosmetology and esthetician applicants to retake failed examinations an unlimited number of times.⁸ Previously, caps on retakes could permanently end a student’s career before it began.

For the diverse student body at Louisville Beauty Academy—many of whom are English as a Second Language (ESL) learners—this change is monumental. A failure on a standardized test, often due to linguistic nuance rather than lack of skill, is no longer a career death sentence. It allows for perseverance, a core tenet of Di Tran’s “Yes I Can” mentality. It humanizes the testing process by acknowledging that learning curves vary and that persistence should be rewarded, not punished.²⁹

3.2.3 Administrative Reform

Addressing the administrative complaints of 2024, SB 22 removes the requirement that the Executive Director of the Board be a licensed cosmetologist.⁸ This seemingly minor change allows for professional public administrators to run the agency, potentially reducing the “insider” dynamics and conflicts of interest that can arise when a regulator is drawn from the pool of the regulated. It suggests a move toward professional, objective governance.

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Part IV: The Di Tran University Philosophy – “Humanization Power” in Legislation

At Di Tran University and Louisville Beauty Academy, we view these legal changes not merely as bureaucratic shifts, but as manifestations of a deeper philosophical movement we call “Humanization Power.” This concept, explored in Di Tran’s writings, asserts that systems—whether educational, economic, or legal—must be designed to validate the inherent worth and agency of the individual.⁹

4.1 From “Chaos” to “Certainty”

In the philosophy of “Humanization Power,” chaos is a dehumanizing force. When laws are unclear, or enforcement is arbitrary (as alleged in the 2024 HB 184 preamble), the individual loses agency. They live in fear of the inspector or the tax auditor.

The legislation of 2025 acts as a “Certainty Engine”.³¹

• The OBBBA creates financial certainty: “If I report my tips, I get a deduction. If I employ staff, I get a credit.”
• SB 22 creates regulatory certainty: “If I fail my test, I can try again. If I avoid MMA, I am safe.”

This certainty is the bedrock of dignity. It allows the beauty professional to plan, to invest, and to grow. It transforms the salon from a place of precarious labor into an institution of stable enterprise.

4.2 The Validation of “Women’s Work”

The historical exclusion of the beauty industry from the 45B credit was a subtle form of dehumanization, implying that the labor performed in salons (predominantly by women) was less “economic” or less “serious” than the labor performed in steakhouses. The OBBBA corrects this. By extending the credit, the federal government is effectively saying, “This work matters. This industry generates value. These professionals deserve the same safety net as everyone else.”

For the students of LBA, many of whom are entering the workforce after overcoming significant personal hurdles, this validation is empowering. It reinforces the message that they are entering a profession, not just a “gig.”

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Part V: Strategic Analysis & Future Outlook

As we look toward the implementation of these laws in late 2025 and 2026, the industry faces a strategic crossroads. The interplay between the federal tax incentives and the state regulatory environment will reshape the business models of Kentucky salons.

5.1 The Strategic Pivot: W-2 vs. Booth Rental

The most profound impact of the OBBBA will be on the choice between the “Commission” (W-2) model and the “Booth Rental” (1099) model.

• The Federal Nudge: The Section 45B credit is a massive subsidy for W-2 employment. A salon owner with $500,000 in tip volume could see a tax credit of nearly $38,000—money that goes straight to the bottom line or can be reinvested in benefits. This makes the W-2 model significantly more financially viable than it was in 2024.
• The State Reality: Kentucky’s new regulations (201 KAR 12:260) have tightened the documentation requirements for booth renters, ensuring they are truly independent businesses with their own licenses and insurance.¹⁷

Prediction: We anticipate a resurgence of the W-2 Commission Salon. Owners, now able to offset the FICA burden, will be able to offer more competitive commission splits and benefits (like health insurance or retirement plans), drawing talent away from the booth rental model. The “No Tax on Overtime” deduction further sweetens the pot for W-2 employees, making the employment model attractive during busy seasons.

5.2 Implementation Guide for Salon Owners

Based on this research, Di Tran University recommends the following implementation steps for Kentucky salon owners:

Table 2: 2026 Compliance and Strategy Checklist

Area	Action Item	Motivation
Tax Strategy	Update Payroll Software to track tips against the $7.25/hr minimum wage basis.	To calculate and claim the new Section 45B Tax Credit.
Financials	Review 2025 P&L to estimate potential 45B credits.	To plan for reinvestment or debt reduction.
Safety	Audit Inventory for Liquid MMA. Dispose of any found.	Compliance with SB 22; avoidance of fines/license revocation.
Workforce	Educate Staff on “No Tax on Tips” deduction requirements.	To encourage full tip reporting, which maximizes the owner’s 45B credit.
Recruiting	Reach out to unlicensed talent.	The “Unlimited Retake” rule in SB 22 may allow former students to finally license.
Structure	Re-evaluate Business Model (W-2 vs. Rental).	The tax advantages may now favor a W-2 structure for growth-oriented salons.

5.3 Conclusion

The “One Big Beautiful Bill Act” and Kentucky Senate Bill 22 represent a synchronized leap forward for the beauty industry. They close the chapter on the “Lost Decades” of inequity and open a new era of professional parity.

For the researcher, the salon owner, and the student, the message is clear: The industry has arrived. It has been recognized by the tax code, modernized by the state, and validated by the economy. It is now up to the practitioners—the “Humanization Power” on the ground—to seize these tools and build a future defined not by survival, but by thriving. As we say at Louisville Beauty Academy: “Yes, You Can.”

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Appendix: Detailed Legislative Tracking

A.1 Federal Legislation: The One Big Beautiful Bill Act

• Public Law: 119-21
• Effective Date: July 4, 2025 (Signed); Tax provisions effective Jan 1, 2025.
• Key Sections:
  • Sec. 45B Amendment: Adds “beauty service business” to tip credit.
  • Sec. 112208: “No Tax on Tips” deduction.
  • Sec. 70202: “No Tax on Overtime” deduction.

A.2 Kentucky Legislation: The 2025 Reformation

• Senate Bill 22 (Passed): The “Safety and Access” bill. Bans MMA, allows unlimited exam retakes.
• House Bill 6 (Passed): Administrative fee restructuring.
• 201 KAR 12:260: New regulations on booth rental documentation and fees.
• House Bill 184 (2025 Passed): Note: Unrelated to Cosmetology (Insurance Sandbox). Do not confuse with 2024 HB 184.

A.3 The “Humanization” Index

Di Tran University measures the impact of legislation on a “Humanization Index,” assessing three factors:

1. Agency: Does it give the individual control? (SB 22 Retakes = High Agency)
2. Equity: Does it level the playing field? (OBBBA 45B Credit = High Equity)
3. Dignity: Does it validate the work? (No Tax on Tips = High Dignity)

End of Report

References

Acts of Congress & Legislation

• One Big Beautiful Bill Act (2025). Public Law 119-21. Congress.gov. https://www.congress.gov/bill/119th-congress/house-bill/1/all-info
• Small Business Tax Fairness and Compliance Simplification Act. (2023). H.R. 45. Congress.gov. https://www.congress.gov/bill/118th-congress/house-bill/45

Kentucky State Legislation

• Senate Bill 22 (2025). An Act relating to licensed professionals. Kentucky General Assembly. https://legiscan.com/KY/bill/SB22/2025
• House Bill 184 (2024). An Act abolishing the Kentucky Board of Cosmetology. BillTrack50. https://www.billtrack50.com/billdetail/1662385
• House Bill 184 (2025). An Act relating to insurance. Kentucky General Assembly. https://apps.legislature.ky.gov/record/25rs/hb184.html
• 201 KAR 12:260 (2025). Fees and Regulations. Kentucky Legislative Research Commission. https://apps.legislature.ky.gov/services/karmaservice/documents/16149/ToPDF?markup=true

Government Publications & Guidance

• Internal Revenue Service. (2025). FICA Tip Credit for Employers. https://www.irs.gov/businesses/small-businesses-self-employed/fica-tip-credit-for-employers
• Internal Revenue Service. (2025). Instructions for Form 8846: Credit for Employer Social Security and Medicare Taxes Paid on Certain Employee Tips. https://www.irs.gov/pub/irs-pdf/f8846.pdf
• Internal Revenue Service. (2025, July). One Big Beautiful Bill Act Tax Deductions for Working Americans and Seniors. https://www.irs.gov/newsroom/one-big-beautiful-bill-act-tax-deductions-for-working-americans-and-seniors
• Kentucky Board of Cosmetology. (2025). Salon Requirements and Booth Rental Regulations. https://kbc.ky.gov/Licensure/Pages/Salon-Requirements.aspx

Di Tran University & Louisville Beauty Academy Research

• Di Tran University. (2026). Di Tran University: A Certainty Engine for Workforce Stability. NABA Research. https://naba4u.org/2025/12/louisville-beauty-academy-di-tran-and-di-tran-university-as-a-certainty-engine-for-workforce-stability-in-an-era-of-volatility/
• Louisville Beauty Academy. (2025). Ensuring Full Compliance with Kentucky’s SB22. https://louisvillebeautyacademy.net/louisville-beauty-academy-ensuring-full-compliance-with-kentuckys-sb22-key-updates-for-students-licensees-and-the-public/
• Louisville Beauty Academy. (2025). Independent Contractor Rules in Beauty: A Journey from Past to Present. https://louisvillebeautyacademy.net/independent-contractor-rules-in-beauty-a-journey-from-past-to-present-research-may-2025/
• Viet Bao Louisville. (2025, June). Research 2025: Louisville Beauty Academy and Di Tran University – A Pioneering Model for the Future of Education. https://vietbaolouisville.com/2025/06/research-2025-louisville-beauty-academy-and-di-tran-university-a-pioneering-model-for-the-future-of-education/
• Di Tran. (2026). Di Tran: Prolific Author, Lifelong Learner, and Visionary Leader. https://ditran.net/di-tran-prolific-author-lifelong-learner-dynamic-speaker-innovator-and-inspiring-leader-for-louisville-ky/

Industry & Legal Analysis

• CCH AnswerConnect. (2025). Explanation: 45B Employer Tax Credit for FICA Paid on Tip Income. https://answerconnect.cch.com/topic/8de28bbc7d47100081010050568873fd02/credit-for-employer-social-security-and-medicare-taxes-paid-on-employee-tips
• Nelson Mullins. (2025). Significant Tax Provisions of the One Big Beautiful Bill Act. https://www.nelsonmullins.com/insights/blogs/tax-reports/all/significant-tax-provisions-of-the-one-big-beautiful-bill-act
• Professional Beauty Association. (2025). FICA Tax Tip Fairness: A Generational Victory. https://www.probeauty.org/fica-tax-tip-fairness/
• Wikipedia. (2025). One Big Beautiful Bill Act. https://en.wikipedia.org/wiki/One_Big_Beautiful_Bill_Act

How Louisville Beauty Academy Applies Humanized Financial Principles in Real-World Training

Louisville, KY — Financial success in the beauty industry is rarely taught in a structured, ethical, and practical way. While technical skill is essential, long-term stability requires something more: financial literacy, disciplined decision-making, and ownership thinking.

This philosophy is explored in the recently launched podcast, Financial Mastery for Beauty Professionals: From $0 to Salon Empire, and in the latest book published through Di Tran University, Financial Mastery for Beauty Professionals: From $0 to Salon Empire. Together, they represent a growing body of research and applied learning centered on humanization, self-leadership, and economic empowerment.

The Role of Di Tran University: Research & Humanization

Di Tran University (DTU), known as The College of Humanization, functions as a research and development institution focused on studying how individuals—especially working adults, immigrants, and skilled professionals—can achieve upward mobility through action-based learning and disciplined systems.

The book and podcast draw from DTU’s R&D work examining:

• Financial behavior patterns among beauty professionals
• The impact of emotional spending on long-term stability
• Ownership pathways in non-Title-IV vocational education
• Practical transitions from worker to business owner

DTU’s research is philosophical and educational in nature, not prescriptive financial advice, and is designed to inform institutions, educators, and adult learners.

Louisville Beauty Academy: Applied Human Services Education

Louisville Beauty Academy (LBA) is a state-licensed, non-Title-IV, adult postsecondary beauty college and one of the Colleges of Human Services that carries out these principles in practice—within lawful educational boundaries.

At LBA, students receive:

• State-required technical instruction for licensure
• Career readiness education aligned with adult responsibility
• Exposure to general financial literacy concepts such as budgeting awareness, cost tracking, and long-term planning

These principles support students as independent adults preparing to enter the workforce, while remaining fully compliant with Kentucky law and regulatory requirements.

What LBA Does — and Does Not — Do

To ensure clarity and compliance, Louisville Beauty Academy makes the following distinctions clear:

LBA DOES:

• Provide state-approved cosmetology and beauty education
• Educate adult students on general financial awareness as part of career readiness
• Encourage personal responsibility, discipline, and lawful business conduct
• Refer students to external professionals (CPAs, attorneys, real estate agents) when appropriate

LBA DOES NOT:

• Provide financial, tax, legal, or investment advice
• Guarantee income, business success, or wealth outcomes
• Require or promote real estate ownership, entrepreneurship, or specific financial strategies
• Act as a financial advisor, broker, or fiduciary

About the Podcast and Book

The podcast and book are authored by Di Tran, drawing from over two decades of experience in beauty, education, entrepreneurship, and real estate. They are independent educational works produced through Di Tran University and are not part of LBA’s required curriculum.

They are offered as optional educational resources for adults seeking to expand their understanding of money, ownership, and long-term planning.

Adult Education, Adult Responsibility

Louisville Beauty Academy serves adult learners who are legally responsible for their own decisions. Students are encouraged to:

• Ask questions
• Seek licensed professionals for specialized advice
• Make independent financial and career choices

LBA does not act on behalf of parents, sponsors, employers, or third parties, and maintains a zero-disruption learning environment consistent with postsecondary education norms.

A Shared Mission, Separate Roles

Together:

• Di Tran University researches and publishes ideas on humanized education and financial behavior
• Louisville Beauty Academy lawfully delivers licensed beauty education and career readiness
• The podcast and book serve as optional learning tools for motivated adults

Each entity operates independently, with clear boundaries, unified by a shared mission:
to empower individuals through education, discipline, and ethical self-leadership.

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Legal & Educational Disclaimer

Louisville Beauty Academy is a Kentucky-licensed postsecondary beauty institution serving adult students.
Nothing in this article, podcast, or related publications constitutes financial, tax, legal, or investment advice.
Outcomes vary based on individual effort, market conditions, and personal circumstances.
Students are encouraged to consult licensed professionals for specialized guidance.

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Purpose of Publication

Louisville Beauty Academy (LBA) publishes this framework to support regulators, workforce agencies, policymakers, and education partners by providing a clear, lawful, and operational example of how licensed beauty education can be delivered at a gold standard level in an industry that continues to face national challenges with:

• Low graduation rates
• Low licensing exam pass rates
• Low workforce placement and career persistence

This framework is published for public benefit and workforce clarity, not to criticize other institutions. It exists to demonstrate what is achievable when compliance, education quality, accountability, and documentation integrity are intentionally designed and continuously monitored.

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I. What the Law Requires (Baseline Compliance)

Kentucky law requires licensed beauty schools to correctly and accurately track student hours, evaluate eligibility, and report credited hours to the Kentucky State Board of Cosmetology in accordance with applicable statutes and administrative regulations.

In summary, the law requires that:

• Student hours be accurately recorded
• Hours be lawfully evaluated
• Only hours a student “shall receive” be reported
• Reporting be truthful, timely, and verifiable

The law does not require:

• Monthly transcript-style SAP reports
• Multi-system redundancy
• AI-assisted monitoring
• Public disclosure of internal compliance systems
• Overlapping academic, behavioral, and professional grading layers

Those elements are voluntary institutional choices, not legal mandates.

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II. LBA’s Over-Compliance Standard (Voluntary & Internal)

Louisville Beauty Academy voluntarily operates beyond statutory minimums through an internal over-compliance and quality assurance framework, adopted solely to:

• Protect student licensing eligibility
• Improve graduation and pass rates
• Strengthen workforce readiness
• Reduce regulatory risk
• Enable responsible scale and replication

These standards are private institutional policies and do not represent additional legal requirements imposed by the State.

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III. Hours Tracking — Biometric, Accurate, and Unedited

All student attendance hours are captured as-is using a fingerprint biometric timekeeping system:

• Clock-in occurs upon physical arrival
• Clock-out occurs upon physical departure
• All records are timestamped automatically
• Records are locked and non-editable

No manual changes, estimates, or retroactive adjustments are permitted.

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IV. Monthly Evaluation & Pass / Fail Credit Determination

Although the law requires only accurate tracking and reporting, LBA adds a monthly evaluation and grading layer.

Each student receives a Monthly SAP Report, functioning as a monthly transcript, which evaluates whether logged hours are eligible to be credited.

To receive a PASS for the month, the student must demonstrate:

• Theory participation and progress
• Practical training participation
• Professional conduct
• Compliance with student policies
• Adherence to safety, sanitation, and licensing law

Only PASS-graded hours are considered credit hours.

Any hours associated with academic failure, policy violations, behavioral issues, or compliance concerns are:

• Documented internally
• Retained for transparency
• Not reported to the State

This aligns with statutory language that a student “shall receive” hours — affirming lawful school grading authority.

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V. State Reporting — Lawful, Conservative, and Timely

Louisville Beauty Academy reports to the State:

• Only PASS-graded credit hours
• Only within legal limits
• Monthly, within the first 10 days
• Without alteration or inflation

Even where Kentucky law allows broader thresholds (e.g., up to 9 hours per day or a 25:1 student-instructor ratio as of December 2025), LBA often applies more conservative internal limits as a quality control measure.

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VI. Automation, AI-Assisted Monitoring & Self-Correction

LBA’s over-compliance framework is supported by automation and AI-assisted monitoring, designed to enable:

• Real-time data capture
• Rule-based compliance checks
• Threshold alerts
• Instructor-ratio monitoring
• Documentation completeness validation
• Early self-correction before State reporting

AI and automation support compliance but do not replace human oversight, academic judgment, or regulatory authority.

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VII. Multi-System Documentation Ecosystem (Gold Standard)

To prevent gaps, disputes, or reconstruction during audits, student progress is documented across 10+ interconnected systems, including:

• Biometric timekeeping
• School student management system
• Monthly SAP reports emailed to students
• Email communication records
• Text message compliance notices
• Theory platforms (e.g., Milady CIMA)
• LBA learning platforms
• Clinic training documentation
• Public service feedback indicators
• Student self-documentation and professional presence

This redundancy ensures accuracy, transparency, and audit-readiness.

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VIII. Why This Matters for Workforce & Policy

Licensed beauty education is workforce infrastructure.

When schools fail to graduate, license, and place students successfully, the consequences are borne by:

• Workforce agencies
• Employers
• Licensing boards
• Communities
• Students and families

LBA’s model demonstrates that outcomes improve when systems are designed correctly — not when standards are lowered.

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IX. Scalability & Public Interest

This framework is published to support:

• Workforce partnerships
• Policy understanding
• Responsible expansion
• Replication by partner schools
• Future-ready education models

It is offered as a reference standard, not a mandate.

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Legal Clarification

Louisville Beauty Academy’s over-compliance practices:

• Exceed legal minimums
• Are voluntary and internal
• Do not alter statutory requirements
• Do not impose obligations on other schools

State reporting remains limited to accurate, PASS-graded credit hours, reported monthly in accordance with law.

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Closing Statement

This framework reflects Louisville Beauty Academy’s commitment to:

• Student protection
• Licensing integrity
• Workforce readiness
• Regulatory trust
• Scalable excellence

It represents a gold standard by choice, designed to be replicable, future-proof, and aligned with the public good — for the benefit of all students.

Legal & Regulatory Disclaimer

This document is provided for informational and educational purposes only and reflects the internal policies, operating philosophy, standard practices, and voluntary over-compliance measures of Louisville Beauty Academy.

Nothing herein:

• alters or expands statutory or regulatory requirements
• creates legal obligations beyond those required by applicable law
• constitutes legal advice
• guarantees licensure, examination outcomes, employment, or income
• imposes standards on other licensed schools or institutions

Louisville Beauty Academy reports to the Kentucky State Board of Cosmetology only those student credit hours permitted by law, as determined through the school’s academic and compliance evaluation processes.

All student data is maintained in accordance with applicable privacy, record-retention, and regulatory requirements.

AI-assisted and automated tools are used to support compliance monitoring and documentation integrity; they do not replace human oversight, academic judgment, or regulatory authority.

References in this publication to “gold-standard,” “over-compliance,” multi-system documentation, automation, validation, and quality-assurance processes describe institutional goals and standard practices, not guarantees of uninterrupted performance or perfection in all circumstances. Temporary system downtime, administrative review, or human error may occur as part of normal operations and continuous improvement.

This framework is published in the spirit of transparency and collaboration and is not intended as criticism or comparison to other licensed beauty schools or regulatory bodies.

Laws, regulations, and interpretations may change. This framework may be updated accordingly.

Louisville Beauty Academy (LBA) represents a new and necessary evolution in beauty education—one that goes beyond technical instruction and licensing compliance to develop confident, resilient, action-oriented human beings prepared for the realities of modern professional life.

This blueprint defines LBA as a gold-standard human and beauty professional training model, where success is not measured by fear avoidance or perfection, but by consistent action, continuous learning, and the courage to engage with people. In an industry built on human interaction, trust, and service, LBA trains students first to master themselves—before mastering tools, techniques, or trends.

At the core of this model is the YES I CAN → I HAVE DONE IT philosophy, founded by Di Tran. Students are taught that confidence is not something one waits for—it is something that is earned through action, even while fear is present. Fear of customers, fear of communication, fear of exams, fear of rejection, and fear of failure are not treated as weaknesses to eliminate, but as natural signals that learning is occurring.

Louisville Beauty Academy institutionalizes the principle of “fail fast, fix fast” as a disciplined learning system. Students are encouraged to attempt, fail safely, learn immediately, and repeat—again and again—until mastery emerges. Licensing exams are not feared; they are approached with calm repetition. Client interaction is not postponed; it is practiced early and often. Job-seeking is not theoretical; it is lived through walk-ins, conversations, and real engagement.

This model rejects result-obsession in favor of action accumulation. Students are trained to win daily through effort—showing up, practicing, communicating, studying, serving—knowing that results are a guaranteed byproduct of disciplined action over time. Every small completion becomes a self-earned “I Have Done It” certificate, strengthening identity, self-trust, and professional presence.

As a community-based institution, LBA functions as a living learning ecosystem. Students learn alongside peers, instructors, graduates, and the public. Growth happens collectively, transparently, and continuously. The Academy evolves with its students, technology, regulation, and workforce demands—ensuring relevance not just today, but for the future.

Louisville Beauty Academy therefore stands as more than a school. It is a human-development system, a confidence-building engine, and a replicable gold-standard blueprint for preparing beauty professionals who are adaptable, resilient, communicative, ethical, and ready to serve in a rapidly changing world.

The beauty professional of the future is not fearless.
They are action-driven.
They are people-centered.
They are learning-obsessed.
They are confident through doing.

This is the Louisville Beauty Academy standard.

Louisville Beauty Academy (LBA), founded by Di Tran, is a Kentucky state-licensed and accredited beauty college dedicated to empowering students – especially immigrants and underserved communities – to achieve success in the beauty industry. The academy’s mission is built on care, accessibility, and cutting-edge training. LBA offers flexible scheduling, scholarships, and even AI‑aided multilingual support so that no student is left behind. Under Di Tran’s leadership, the school emphasizes a “Yes I Can” culture: students are taught to believe in themselves, start small, and steadily accumulate achievements. This report outlines LBA’s gold-standard approach: rigorous compliance and outcomes, a “fail fast, fix fast” learning mindset, and concrete steps to overcome common fears (servicing clients, taking exams, communicating). Together, these form a blueprint that helps every student build real confidence and say “I have done it.”

Gold-Standard Education and Outcomes

Louisville Beauty Academy sets the gold standard for quality, accountability, and integrity in cosmetology education. As a fully licensed and state-accredited institution, every process is law-driven and aligned with applicable Kentucky regulations. Curriculum delivery, attendance, practice hours, assessments, and student progress are tracked through secure and systematic documentation. This transparency allows both students and regulators to verify learning activities and compliance at every stage of education.

This structured and accountable approach builds trust. Students understand that their education is legitimate, traceable, and aligned with licensure requirements. Regulators and partners can clearly see that Louisville Beauty Academy operates with intentional oversight, ethical responsibility, and compliance-first design.

Louisville Beauty Academy’s educational model emphasizes efficiency, clarity, and relevance. Programs are designed to focus on required competencies rather than unnecessary filler, allowing students to progress with purpose and confidence. Flexible scheduling and continuous enrollment support diverse learners and real-life responsibilities, helping students remain consistent and engaged.

Graduates of Louisville Beauty Academy are prepared to enter the beauty workforce with confidence and professionalism. Many transition smoothly into salon environments and related professional settings because they have been trained not only in technical fundamentals, but in communication, responsibility, and action-oriented learning. The Academy’s reputation within the community supports this transition by signaling reliability, readiness, and ethical preparation.

Key Principles of the Gold Standard

• Accountability: Clear documentation and transparent processes support compliance and trust.
• Competency-Focused Training: Education centers on required skills and practical readiness.
• Flexible Access: Scheduling and enrollment models accommodate working adults and diverse learners.
• Workforce Alignment: Training reflects real salon environments and professional expectations.

Embracing Failure: The LBA Learning Mindset

A core philosophy at LBA is that failure is an essential part of learning – indeed, students are encouraged to “fail fast” and learn from every mistake. Di Tran insists that students must push boundaries and accept errors as feedback, not reasons to quit. As one LBA program description explains: “At LBA, failure is not seen as something to avoid but rather as an essential part of the learning process.” Students are explicitly told to experiment, make mistakes, and grow from those experiences. In other words, short‑sighted focus on perfection is replaced by a long‑view of mastery. Each action is a victory: the school reinforces that simply taking action and correcting it is the real win, because consistent effort inevitably leads to improvement.

This “fail fast” approach is widely recognized in education and innovation. As one educational expert noted, the idea of “fail fast, fail often” is to value trying and learning from failure rather than demanding perfection. By promptly correcting errors and moving on, learners quickly internalize what works. LBA embodies this: students retake exams and redo practical tasks until they achieve mastery, turning each failure into a stepping stone. In practice, instructors celebrate each failed attempt as new knowledge gained. Over time, this builds resilience; learners fear mistakes less because they know errors only guide them to do better next time. As a result, LBA graduates emerge not just technically skilled but confident in tackling real-world challenges.

Building the “Yes I Can” Attitude

At Louisville Beauty Academy, having a “Yes I Can” mindset is taught and reinforced constantly. Students learn to believe in their own potential from day one. This positive attitude is explicitly tied to effort and learning. LBA stresses that success is not about innate talent but about persistent action: “Believe in yourself, believe that you can succeed, and you will.”. Every student is encouraged to view each completed task as a personal milestone – an “I Have Done It” achievement – rather than fixating on final results or comparisons. Instructors praise incremental progress; for example, finishing a chapter in the theory software or mastering a basic technique earns an “I have done it” affirmation. This accumulation of small wins boosts morale and reduces fear of failure.

Similarly, LBA’s curriculum blends technical training with essential soft skills like communication and customer service. Instructors explicitly train students to engage clients and colleagues confidently. By combining “Yes I Can” self-talk with these practical skills, students internalize a cycle of setting modest goals, achieving them, and celebrating the action taken. Each day at LBA reinforces the idea that the act of doing is itself a success. Over time, students naturally shift focus from fearing outcomes (“Will I pass the test or satisfy a client?”) to trusting the process (“I can take the next step”). As Di Tran emphasizes, mastering this mindset ensures that students accumulate confidence and “worry less about the result,” knowing the result will follow diligent work.

Overcoming Common Fears in Beauty Training

LBA recognizes that many students arrive with specific anxieties: fear of working on real clients, fear of the licensing exam, fear of communication barriers, etc. The academy confronts each fear with targeted strategies:

• Fear of Client Service: Students gain hands-on practice from the very beginning. LBA operates a student salon and volunteer clinics (such as at Louisville’s Harbor House) where trainees provide free beauty services to real clients. These “real-world labs” demystify salon work and build social confidence. In one program description, it’s noted that Harbour House volunteer events made clients feel like “celebrities” and gave LBA students “empathy, experience, and a deeper understanding of the power of their craft.”. By treating practice clients with kindness and humility, students learn to handle diverse customers, alleviating initial shyness. In short, actual service experience creates competence and confidence: encountering new scenarios on live clients teaches adaptability far faster than simulations.
• Fear of Licensing Exams: LBA systematically builds exam confidence. Recognizing that the theory portion causes most failures nationwide, the school dedicates extensive time to theory mastery. Students work on the Milady CIMA digital platform all day, every day if needed: taking chapter quizzes repeatedly until they reach 100%. One LBA article explains, “we encourage students to take exams over and over again… giving students the confidence to excel on the licensing exam.”. This drill-to-mastery approach means that by the time students graduate, they have effectively failed any given theory topic dozens of times in practice, eliminating surprise on test day. Moreover, LBA abolishes stigma around retakes: failing part of the exam is just another chance to learn more before trying again. This reframing turns a high-stakes hurdle into a low-pressure process, so students approach the licensing exam with calm preparation instead of fear.
• Fear of Communication (Language/Email): Many LBA students are non-native English speakers or feel shy about reaching out. The academy addresses this head-on. All staff speak multiple languages and AI translators are available in classrooms. LBA even offers a communication consulting service: students can get help drafting emails or letters to state boards, employers, and clients. For example, one program launched provides templates and coaching for professional correspondence “crafted to empower individuals to communicate confidently and effectively”. Lessons in English essentials for beauty professionals are part of the curriculum. By normalizing this help (even making it affordable and multilingual), students learn that asking questions and seeking guidance is a strength, not a weakness. Over time, even the most reserved student becomes comfortable scheduling appointments or introducing themselves, because they have practiced and received support doing exactly that.
• Supportive Environment: Above all, LBA cultivates a culture where “you cannot fail unless you want to”. Faculty treat students like family and proactively help anyone who shows effort. If someone falls behind – for any reason (language barriers, personal issues, learning differences) – the school offers tutoring, flexible hours, weekend classes, or bilingual assistance. This unwavering support reassures students that they won’t be abandoned by challenges. Knowing that guidance is always available reduces anxiety; students fear less when they know LBA’s mentors are on their side. This ethos is reflected in the outcomes: well over 95% of students persist to graduation because the school refuses to let them fall by the wayside.

A “Yes I Can” Blueprint: Steps to Confidence

LBA’s methods can be distilled into actionable principles that any student (or educator) can follow:

• Affirm Positive Intent: Begin each day with “Yes, I can”. Commit mentally to taking on challenges, even small ones. This sets the tone to act rather than hesitate.
• Take Concrete Actions: Focus on doing the next task – a haircut section, a set of flashcards, a salon shift. Each completed step is progress (an “I have done it” certificate in spirit). Action builds skill and erodes fear.
• Embrace Mistakes Quickly: When a setback occurs, stop to fix it immediately. Learning quickly from errors (fail fast, fix fast) keeps momentum. As LBA teaches, “failure is an essential part of the learning process”– so a mistake is just information, not a final verdict.
• Repeat and Review: Use repetition to master fundamentals. Re-take quizzes, redo practice boards, or practice a style until it’s right. Trust that repeated effort deepens understanding.
• Celebrate Every Win: No result is too small to acknowledge. Finishing a chapter, doing a service on a client, even sending that first email are victories. Each “I did it” moment boosts confidence and reminds you that progress is happening, reducing pressure for perfection.
• Seek Support Without Hesitation: If something is unclear or scary, ask for help. LBA’s resources – tutors, bilingual staff, communication guides, or even email-drafting services – are there to aid you. Use them freely. Understanding that help is always available lets you experiment and learn without fear of being on your own.
• Build Gradually, Consistently: Growth often comes one small step at a time. Trust that consistent effort compounds. Even if progress seems slow, each day of learning adds up. LBA’s rolling graduations and continuous enrollment reflect this mentality: move forward at your own pace and keep adding skills.

By following these steps, students embody the “Yes I Can” blueprint. They learn to act in spite of fear, knowing that action generates confidence. Over time, the myriad small actions become a portfolio of experience. Eventually, each student can proudly say “I have done it,” with the backing of solid skills and personal resilience.

Conclusion

Louisville Beauty Academy’s approach proves that excellence in beauty isn’t about being born fearless – it’s about taking action, learning continuously, and trusting a growth mindset. LBA’s gold-standard compliance and support structure create a safety net: students know they are guided and held to high standards. Its unique learning culture turns failure into fuel and fear into confidence. By focusing on doing rather than dreading outcomes, and by celebrating each “I did it” along the way, graduates finish not only with licenses but with the inner knowledge that they can succeed. This “Yes I Can” blueprint – grounded in action, community, and continuous improvement – equips every LBA student to overcome fear and thrive in their career.

Working in a Salon Without a Beauty License: A Clear, Lawful, and Fear-Free Explanation

Louisville Beauty Academy states this clearly, directly, and without ambiguity:

You do NOT need a beauty license to work in a salon.
You only need a beauty license to perform regulated beauty services.

A common and harmful fear among students and graduates is the belief that “without a license, I cannot work in a salon at all.”
This belief is incorrect.

A salon is a business environment, not a license itself. Like any business, it operates through many roles and responsibilities—most of which do not require a beauty license.

What Requires a Beauty License

A state-issued beauty license is required only when an individual performs regulated beauty services, such as cosmetology, esthetics, nail technology, barbering, or any hands-on service defined by state law as licensable activity.

Until licensed, an individual must not perform those regulated services.

What Does NOT Require a Beauty License

Many roles inside a salon do not require a beauty license and may be performed lawfully by individuals who are:

• Current students
• Graduates awaiting licensure
• Apprentices (where permitted by law)
• Career changers
• Entry-level or support staff

These individuals may work in salons legally and ethically, provided they do not perform regulated services.

Lawful Salon Positions That Do Not Require a Beauty License

Without holding a beauty license, an individual may work in a salon in roles including, but not limited to:

• Front desk or receptionist
• Customer service associate
• Cashier or checkout support
• Appointment scheduler
• Client check-in, intake, and reception
• Retail product sales and education
• Salon cleaning and sanitation support
• Laundry and supply management
• Salon assistant (non-service tasks only)
• Apprentice-style observation (as permitted by law)
• Inventory and ordering support
• Social media or marketing assistant
• Administrative or office support
• Client relations or concierge
• Training or education assistant (non-hands-on)
• Salon operations support

These roles allow individuals to earn income, build professional relationships, learn salon culture, and develop communication confidence—all while remaining fully compliant with licensing laws.

Why This Matters for Graduates and Licensing Exam Candidates

Graduating from school does not mean waiting in fear or inactivity while studying for the licensing exam.

Graduates may immediately and lawfully:

• Work inside salon environments
• Continue learning through observation
• Build customer-facing communication skills
• Reduce fear of people and client interaction
• Stay connected to the profession daily
• Prepare mentally and emotionally for licensure

This time should be understood as professional development, not delay.

Early Hiring: Why LBA Students Are Often Employed Before Graduation

Louisville Beauty Academy observes that many students are hired by salons before graduation or licensure.

This happens not because students already know everything, but because they are trained in a mindset salons actively seek:

• YES I CAN mentality
• Willingness to take action without fear
• Comfort engaging with people
• Reliability and consistency
• Coachability and openness to training
• The habit of completing tasks and saying “I have done it”

Salon owners understand that:

• Skills can be taught
• Systems are salon-specific
• Mindset determines long-term success

Students trained with the YES I CAN → I HAVE DONE IT mentality are seen as low-risk, high-potential team members. Salons are often willing—and eager—to train technical skills in their own way when the mindset is already strong.

Louisville Beauty Academy’s Compliance Position

Louisville Beauty Academy explicitly teaches:

• Clear boundaries between licensed and non-licensed work
• Respect for state laws and board regulations
• Ethical conduct and transparency
• No unauthorized practice of beauty services

Students and graduates are trained to understand what is permitted, what requires licensure, and how to act lawfully and professionally at all times.

Core Message to Students and Graduates

Do not be fearful of working in a salon.

You are allowed to be present.
You are allowed to learn.
You are allowed to contribute.
You are allowed to earn.

Licensure authorizes services—not presence, learning, or employment in non-licensed roles.

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Educational Purpose & Liability Disclaimer

This section is provided for educational and informational purposes only as part of Louisville Beauty Academy’s instructional philosophy and workforce readiness education.

Louisville Beauty Academy:

• Does not provide legal advice
• Does not guarantee employment or job placement
• Does not authorize or encourage unlicensed practice
• Does not control hiring decisions made by salons
• Requires all students and graduates to comply with applicable state laws and board regulations

Individual responsibilities, permissions, and job duties may vary by jurisdiction and employer. Students and graduates are responsible for understanding and complying with all applicable laws.

References (APA 7th Edition)

Bandura, A. (1997). Self-efficacy: The exercise of control. W. H. Freeman.
→ Foundational theory explaining why belief in one’s ability grows through action and mastery, not results alone.

Bjork, R. A., & Bjork, E. L. (2011). Making things hard on yourself, but in a good way: Creating desirable difficulties to enhance learning. Psychology and the Real World: Essays Illustrating Fundamental Contributions to Society, 56–64.
→ Supports learning through struggle, repetition, and corrective failure.

Brown, P. C., Roediger, H. L., & McDaniel, M. A. (2014). Make it stick: The science of successful learning. Harvard University Press.
→ Demonstrates that retrieval practice, repeated failure, and correction lead to durable learning.

Clark, D. A., & Beck, A. T. (2010). Cognitive therapy of anxiety disorders. Guilford Press.
→ Explains how action and exposure reduce fear, not avoidance.

Dweck, C. S. (2006). Mindset: The new psychology of success. Random House.
→ Core framework for growth mindset, persistence, and reframing failure as learning.

Ericsson, K. A., Pool, R., & Coyle, D. (2016). Peak: Secrets from the new science of expertise. Houghton Mifflin Harcourt.
→ Validates deliberate practice, repetition, and fine-tuning craft over talent.

Kolb, D. A. (1984). Experiential learning: Experience as the source of learning and development. Prentice Hall.
→ Academic basis for learning by doing, reflection, and iterative improvement.

LeDoux, J. (2015). Anxious: Using the brain to understand and treat fear and anxiety. Viking.
→ Neuroscience evidence that fear diminishes through repeated safe action, not reassurance alone.

Resnick, M. (2017). Lifelong kindergarten: Cultivating creativity through projects, passion, peers, and play. MIT Press.
→ Supports community learning, experimentation, and iterative failure.

Skinner, B. F. (1953). Science and human behavior. Macmillan.
→ Behavioral foundation for action-reinforcement cycles and habit formation.

Vygotsky, L. S. (1978). Mind in society: The development of higher psychological processes. Harvard University Press.
→ Establishes the importance of social learning, mentorship, and scaffolding.

Weick, K. E. (1984). Small wins: Redefining the scale of social problems. American Psychologist, 39(1), 40–49.
→ Strong academic support for accumulating small wins to build confidence and momentum.

Yerkes, R. M., & Dodson, J. D. (1908). The relation of strength of stimulus to rapidity of habit-formation. Journal of Comparative Neurology and Psychology, 18(5), 459–482.
→ Classic law explaining why moderate stress + action improves performance.

Kentucky Board of Cosmetology Oversight Reports (Published AS-IS for Educational Use)

Downloaded December 4, 2025 — 100% Literal Text Reproduced From State Records

Louisville Beauty Academy (LBA) is a National Gold Standard Center of Excellence in Beauty Education, recognized for its unwavering commitment to compliance, transparency, public accountability, and regulatory literacy.

A core part of our mission is ensuring that every student, educator, professional, and member of the public has open access to public records relating to Kentucky’s beauty industry governance.

All materials below are:

• Public documents issued by the Kentucky Legislative Research Commission (LRC)
• Reproduced exactly as downloaded, without modification, interpretation, or opinion
• Presented for education-only purposes
• Linked directly to the original LRC sources for verification

LBA provides these materials strictly to support regulatory literacy, public understanding, and compliance education.

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⚠️ Compliance & Ethical Use Reminder

“At Louisville Beauty Academy (LBA), we believe that a professional beauty license is not just about skill — it’s about integrity, respect for law, and ethical responsibility. We encourage every student and visitor to:

• Respect the authority and regulations of the Kentucky Board of Cosmetology and other regulatory bodies.
• Use this Public Record Library as an educational tool — but always cross-check with official sources when in doubt.
• Ask questions and seek clarification directly from the state board or relevant legal authority if a law or regulation seems unclear or ambiguous.
• Approach every aspect of beauty practice with transparency, safety, and professionalism.

This site does not provide legal advice. The information is public-record only, for education. For official guidance or regulatory compliance, please consult the Kentucky Board of Cosmetology or a licensed legal professional.”

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📎 OFFICIAL LRC DOCUMENT LINKS (Unmodified)

1. LOIC Cosmetology Fact Sheet (Nov 14, 2024)

Click to access 2024-11-14%20LOIC%20Cosmetology%20Fact%20Sheet.pdf

2. LOIC Cosmetology Slides (Nov 14, 2024)

Click to access 2024-11-14%20LOIC%20Cosmetology%20Slides.pdf

3. LOIC Research Report No. 492 (Adopted Nov 14, 2024)

Click to access RR492.pdf

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📄 FULL TEXT EXTRACTION (AS-IS)

Below is all extracted content exactly as provided in state publications, including every word, punctuation mark, table text, and formatting note.

No edits, summaries, interpretations, or alterations have been made.
This satisfies the requirement of zero opinion, zero agenda, and maintains pure educational value.

✅ DOCUMENT 1 — LOIC COSMETOLOGY FACT SHEET

(Downloaded as of 12-04-2025) – https://apps.legislature.ky.gov/CommitteeDocuments/344/30790/2024-11-14%20LOIC%20Cosmetology%20Fact%20Sheet.pdf
Exact text extracted AS IS from the full-page image:

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Report Highlights

Inspections

• The board faces a shortage of inspectors and is not meeting a regulatory requirement to inspect all licensed establishments twice a year.
• The board lacks sufficient policy and procedures for training inspectors, conducting inspections, and reviewing complaints against inspectors.
• The inspection checklist lacks sufficient detail to ensure that violations are uniformly documented.

Recommendations

• The board should amend inspection requirements to reflect standards that can be reasonably met while ensuring all practitioners are reviewed regularly.
• The board should adopt more detailed written policies and procedures for conducting inspections to ensure statutory and regulatory compliance.
• The board should ensure that its inspector checklists are sufficiently detailed and that inspectors consistently file them.
• The board should develop written policies and procedures for initial inspector training and ongoing inspector education.

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Fines

• The board has received and kept $374,200 in fine revenue even though it is statutorily required to deposit all fine revenue with the State Treasury.
• The board has no electronic system for tracking fines, and some paper files lack documented justification for issuing a fine.
• The board does not offer guidance on how a licensee can remedy violations, and it does not follow up to ensure a violation is fixed. The fine process lacks transparency.

Recommendations

• Board staff should work with the state Office of the Controller to return the $374,200 in fine revenue to the general fund.
• Board staff should develop a policy for processing fine revenue and implement an electronic system for tracking fines.
• The board should provide guidance or require corrective measures in either the agreed orders or the formal letter to licensees to correct violations.
• All agreed order files should include proper documentation.
• The board should develop smaller fine ranges tied to specific violations and include set progressions for repeat offenders and more severe offenses.
• Fine amounts for each offense should be cited in the agreed orders.

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Other Conclusions

• The board lacks policies for when licensees give unsolicited money or gifts to inspectors.
• The board and its staff face uncertainty over the statutory term “emergency order” and over the board’s authority related to hair braiding.
• Regulatory language contradicts statutory language for retesting requirements.

Recommendations

• The board should amend regulations to align with state law and create a policy to clarify the meaning of “emergency order.”
• The General Assembly may wish to consider amending state statute to delineate the practices of natural hair braiding and cosmetology.
• The board should develop policies for appeal hearings, for transferring of signature authority in the event of staff changes, for mass communication system use, and for managing unsolicited gifts.

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Key Notes (Sidebar Text EXACTLY AS IS)

• The board faces a shortage of inspectors.
• $374,200 — What the board has received in fine revenues.
• The inspection checklist lacks sufficient detail.
• The board has no electronic system for tracking fines.
• Board offers no guidance on how to fix violations.

✅ LOIC COSMETOLOGY SLIDES — FULL EXTRACTION START

(Downloaded as of 12-04-2025) – https://apps.legislature.ky.gov/CommitteeDocuments/344/30790/2024-11-14%20LOIC%20Cosmetology%20Slides.pdf

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PAGE 1 — EXACT TEXT

Legislative Oversight and Investigations
Board of Cosmetology Oversight Functions
November 14, 2024

Kentucky Board of Cosmetology
Oversight Functions
Legislative Oversight and Investigations Committee
November 14, 2024

Board of Cosmetology
• Created in 1974
• Protects the health and safety of the public
• Protects the public against misrepresentation, deceit, and fraud in the practice or teaching of beauty culture
• Sets standards for schools and salons
• Protects students under the provision of KRS 317A

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Legislative Oversight and Investigations
Board of Cosmetology Oversight Functions
November 14, 2024

Board Membership
KRS 317A.030
• Two salon owners
• One cosmetology teacher
• One owner or financial stakeholder in a school
• One citizen at large
• One nail technician
• One esthetician

Board Membership
KRS 317A.030
• All board members are appointed by the Governor
• Appointments are for 2-year terms ending on February 1
• No members shall be removed except for cause

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Legislative Oversight and Investigations
Board of Cosmetology Oversight Functions
November 14, 2024

What the Board Regulates
• Regulates
• Cosmetology, esthetics, and nail technology
• 33,921 licenses as of July 16, 2024
• Businesses and practitioners
• Schools and instructors

Three General Finding Areas
• Structural Issues
• Issues that impact the functioning of the board including the setup of the board and its staff and lack of clarity from leadership
• Inspectors and Inspections
• Issues with inspector hiring, training, and reporting
• Fines
• Issues with fine issuance, amounts, and records

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Legislative Oversight and Investigations
Board of Cosmetology Oversight Functions
November 14, 2024

Senate Bill 14 2024 Regular Session
• Amended KRS 317A.120
• Created new retesting requirements for nail technicians
• Amended KRS 317A.020
• Changed requirements for an emergency order

Structural Issues  Inspections/Inspectors  Fines

Retesting Requirements
201 KAR 12:030
• 201 KAR 12:030 covers retesting requirements
• Allows for immediate retesting until three failures
• After three failures they must wait 6 months before retesting and take a supplemental course
• After five failures they must wait 3 years before retaking

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Legislative Oversight and Investigations
Board of Cosmetology Oversight Functions
November 14, 2024

Retesting Requirements
KRS 317A.120
• SB 14 amended KRS 317A.120 and now requires nail technicians to wait 1 month before retesting
• no failure limit

Structural Issues  Inspections/Inspectors  Fines

Retesting Requirements
• Prior to SB 14, 201 KAR 12:030 regulated retesting requirements for nail technicians, cosmetologists, and estheticians
• SB 14 created new retesting requirements for nail technicians
• 201 KAR 12:030 is still in place and contradicts statute for nail technicians

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Legislative Oversight and Investigations
Board of Cosmetology Oversight Functions
November 14, 2024

Recommendation 2.1
The Kentucky Board of Cosmetology should amend 201 KAR 12:030 to align with KRS 317A.120, as amended by Senate Bill 14 from the 2024 Regular Session.

Structural Issues  Inspections/Inspectors  Fines

Emergency Order
• SB 14 changed the definition and requirements of emergency order
• Prior to SB 14: based upon probable cause
• After SB 14: based upon verified probable cause or substantial evidence
• Board staff report confusion over the term

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Legislative Oversight and Investigations
Board of Cosmetology Oversight Functions
November 14, 2024

Recommendation 2.2
By July 1, 2025, the Kentucky Board of Cosmetology should create a policy to clarify the meaning of emergency order and when it should be used.

Structural Issues  Inspections/Inspectors  Fines

Minimal Oversight
• KRS 317A.030 establishes the board as an independent agency
• Very little oversight
• Fine decisions are made by board
• No higher or impartial authority to appeal to for complaints
• Can appeal a final decision to Franklin Circuit Court

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Legislative Oversight and Investigations
Board of Cosmetology Oversight Functions
November 14, 2024

Recommendation 2.3
By July 1, 2025, the Kentucky Board of Cosmetology should develop policies to allow administrative hearings for appeals and post the process on its website.

Structural Issues  Inspections/Inspectors  Fines

Signature Authority
• Signature authority allows a person to make legally binding decisions and sign documents
• Personnel Cabinet has process for appointing signature authority but no requirement for time frame
• Board was left without an individual with signature authority from March 25, 2024 to May 6, 2024

PAGE 9 — EXACT TEXT

Legislative Oversight and Investigations
Board of Cosmetology Oversight Functions
November 14, 2024

Recommendation 2.4
The Kentucky Board of Cosmetology should create a policy for a timely transfer of signature authority in the event of staff changes or vacancies.

Structural Issues  Inspections/Inspectors  Fines

Unsolicited Compensation
• Board inspectors offered unsolicited compensation or gifts
• Sometimes unclear who left the items or the environment is unsafe to return the unsolicited compensation or gifts
• Currently, no policy on how to handle this issue

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Legislative Oversight and Investigations
Board of Cosmetology Oversight Functions
November 14, 2024

Recommendation 2.5
The Kentucky Board of Cosmetology should establish a written policy outlining processes for holding and disposing of unsolicited compensation given to inspectors and other staff.

Structural Issues  Inspections/Inspectors  Fines

Mass Email Use
• The board does have a system to send out mass emails to all licensees
• There is currently no policy in place for when this system should be used
• Can result in pertinent or important information not being communicated to licensees

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Legislative Oversight and Investigations
Board of Cosmetology Oversight Functions
November 14, 2024

Recommendation 2.6
The Kentucky Board of Cosmetology should develop a policy for how and when information should be communicated through its mass communications system.

Structural Issues  Inspections/Inspectors  Fines

Continuing Education
• Prior to 2012, KRS 317A.050 required continuing education
• 8 hours for cosmetology instructors
• 6 hours for cosmetologists and nail technicians
• No current requirement for continuing education
• Four bordering states require continuing education

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Legislative Oversight and Investigations
Board of Cosmetology Oversight Functions
November 14, 2024

Recommendation 2.7
By July 1, 2025, the Kentucky Board of Cosmetology should review examples of continuing education in other states, consider the benefits and costs of the requirements, and promulgate regulations on continuing education if necessary.

Structural Issues  Inspections/Inspectors  Fines

Regulatory Inspection Requirements
• 201 KAR 12:060 requires establishments licensed by the board be inspected twice a year
• Inspection frequency is not in compliance with this regulation
• Some locations have not been inspected since 2014

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Legislative Oversight and Investigations
Board of Cosmetology Oversight Functions
November 14, 2024

Recommendation 3.1
The Kentucky Board of Cosmetology should revisit the inspection requirements set forth in 201 KAR 12:060 and amend them to standards that can be reasonably met while ensuring all practitioners are reviewed regularly.

Structural Issues  Inspections/Inspectors  Fines

Natural Hair Braiding
• SB 269 RS 2016 created exemption for hair braiders
• No longer regulated by the board of cosmetology
• The statutory definition for natural hair braiding overlaps with listed practices governed by the board of cosmetology

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Legislative Oversight and Investigations
Board of Cosmetology Oversight Functions
November 14, 2024

Overlapping Definitions

Hair Styling
• Twisting, wrapping, weaving, and braiding
• Minor trimming incidental to style
• Use of conditioners, oils, moisturizers, and shampoos

Natural Hair Braiding
• Arranging and manipulating
• Trimming
• Cleansing
• Use of lotions, creams, and antiseptics

Matter For Legislative Consideration 3.A
The General Assembly may wish to consider amending KRS 317A.010 or KRS 317A.020 to clearly delineate the practices of natural hair braiding and cosmetology.

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Legislative Oversight and Investigations
Board of Cosmetology Oversight Functions
November 14, 2024

Policies and Procedures for Inspections
• Board policies are broad and unspecific
• Few instructions on how an investigator should conduct an investigation
• Few requirements ensuring uniform documentation

Structural Issues  Inspections/Inspectors  Fines

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Legislative Oversight and Investigations
Board of Cosmetology Oversight Functions
November 14, 2024

Recommendation 3.2
The Kentucky Board of Cosmetology should adopt more detailed written policies and procedures for conducting inspections to ensure statutory and regulatory compliance and the consistent application of oversight authority. Board staff should consult with inspectors before drafting policies and procedures to understand where inspectors would best benefit from more guidance.

Structural Issues  Inspections/Inspectors  Fines

Inspection Checklists
• Inspection forms provides only a basic checklist
• Structured checklist ensures uniform inspections
• Only 54 percent of files included completed inspection forms

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Legislative Oversight and Investigations
Board of Cosmetology Oversight Functions
November 14, 2024

Recommendation 3.3
The Kentucky Board of Cosmetology should ensure that inspector checklists are sufficiently detailed and that inspectors consistently file them.

Structural Issues  Inspections/Inspectors  Fines

Inspector Training
• No internal written policies for inspector training
• No education experience requirement outside of holding an active cosmetology license
• Risk of error and misconduct

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Legislative Oversight and Investigations
Board of Cosmetology Oversight Functions
November 14, 2024

Recommendation 3.4
The Kentucky Board of Cosmetology should develop written policies and procedures for initial inspector training and ongoing inspector education.

Structural Issues  Inspections/Inspectors  Fines

Inspector Complaints
• No formal policies or procedures in place for how to evaluate complaints against inspectors
• No policy on following up with a complainant

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Legislative Oversight and Investigations
Board of Cosmetology Oversight Functions
November 14, 2024

Recommendation 3.5
The Kentucky Board of Cosmetology should develop written policies and procedures for review of complaints against inspectors and follow up with those who submit complaints.

Structural Issues  Inspections/Inspectors  Fines

Fines and Fees
• KRS 317A.080 establishes the trust and agency fund allowing the board to retain all licensing and other fees
• KRS 317A.140 requires all payments collected in lieu of suspension (fines) to be deposited in the State Treasury and credited to the general fund

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Legislative Oversight and Investigations
Board of Cosmetology Oversight Functions
November 14, 2024

Board of Cosmetology Fine Revenue
FY 2022 to FY 2024

Fiscal Year — Fine Revenue
2022 — $26,525
2023 — $297,325
2024 — $50,350
Total — $374,200

Note: From FY 2007 to FY 2021, there is no records of fines in eMARS.

Source: Staff analysis of eMARS Revenue Analysis Report-FAS Power BI.

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Legislative Oversight and Investigations
Board of Cosmetology Oversight Functions
November 14, 2024

Recommendation 4.1
Kentucky Board of Cosmetology staff should work with the Office of the Controller in the Finance and Administration Cabinet to determine how the $374,200 in fine revenue can be returned to the general fund, as established in KRS 317A.140(2).

Structural Issues  Inspections/Inspectors  Fines

Recommendation 4.2
Kentucky Board of Cosmetology staff should develop a policy for processing fine revenue that is inadvertently received. The policy should be provided to board members for adoption.

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Legislative Oversight and Investigations
Board of Cosmetology Oversight Functions
November 14, 2024

Formal Letters and Agreed Orders
• The board sends both formal letters and agreed orders when issuing fines
• Formal letters are not specific
• Agreed orders lack detail about the violations
• No guidance for corrective actions
• No follow-up actions are required

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Legislative Oversight and Investigations
Board of Cosmetology Oversight Functions
November 14, 2024

Fine Tracking
• No method for tracking issued fines
• Board database is meant to track license renewal and is not searchable
• All files are physical
• Lack of digitized system makes it difficult to track ownership and past offenses

Recommendation 4.3
The Kentucky Board of Cosmetology should implement an electronic tracking system to organize and search fines given.

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Legislative Oversight and Investigations
Board of Cosmetology Oversight Functions
November 14, 2024

Inspection Documentation
• Inspection sheets often missing
• 46 percent of agreed orders from 2019–2023 had no inspection sheet
• Lack of documentation increases risk of improper actions

Recommendation 4.4
The Kentucky Board of Cosmetology should provide guidance or require corrective measures in either the agreed orders or the formal letter to licensees to correct the violation that prompted the fine.

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Legislative Oversight and Investigations
Board of Cosmetology Oversight Functions
November 14, 2024

Broad Fine Ranges
• Fine amounts not tied to specific violations
• Broad discretionary ranges
• Lack of transparency can appear arbitrary

Recommendation 4.5
Kentucky Board of Cosmetology staff should ensure the proper documentation of salon inspection sheets in all agreed order files.

Recommendation 4.6
The Kentucky Board of Cosmetology should develop smaller fine ranges tied to specific violations and include set progressions for repeat offenders and more severe offenses.

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Legislative Oversight and Investigations
Board of Cosmetology Oversight Functions
November 14, 2024

Recommendation 4.7
The Kentucky Board of Cosmetology should include the fine amount for each offense cited in the agreed orders and formal letter instead of a total amount.

Structural Issues  Inspections/Inspectors  Fines

Payment of Fines
• Only money order and cashier’s check accepted
• Not easily trackable
• Online payment option not available
• Licensees have complained

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Legislative Oversight and Investigations
Board of Cosmetology Oversight Functions
November 14, 2024

Recommendation 4.8
The Kentucky Board of Cosmetology should update its method of fine payment by adding an option to pay the fine through an online portal.

Structural Issues  Inspections/Inspectors  Fines

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[This page contains only the closing slide elements; the text extracted from the file ends at recommendation 4.8. There is no additional text content displayed on the final page.]

✅ LOIC RESEARCH REPORT NO. 492 — EXACT FULL EXTRACTION

(Downloaded as of 12-04-2025) – https://apps.legislature.ky.gov/lrc/publications/ResearchReports/RR492.pdf

PAGE 1 — EXACT TEXT

Board Of Cosmetology
Oversight Functions
Research Report No. 492
Legislative Oversight And Investigations Committee
Legislative Oversight And Investigations Committee
Legislative Research Commission
702 Capital Avenue, Capitol Annex, Frankfort, KY 40601
legislature.ky.gov

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Kentucky Legislative Research Commission

SENATE
Robert Stivers
President, LRC Co-Chair
David P. Givens
President Pro Tempore
Damon Thayer
Majority Floor Leader
Gerald A. Neal
Minority Floor Leader
Julie Raque Adams
Majority Caucus Chair
Reginald Thomas
Minority Caucus Chair
Mike Wilson
Majority Whip
David Yates
Minority Whip

HOUSE
David W. Osborne
Speaker, LRC Co-Chair
David Meade
Speaker Pro Tempore
Steven Rudy
Majority Floor Leader
Derrick Graham
Minority Floor Leader
Suzanne Miles
Majority Caucus Chair
Cherlynn Stevenson
Minority Caucus Chair
Jason Nemes
Majority Whip
Rachel Roberts
Minority Whip

Jay D. Hartz, Director

The Kentucky Legislative Research Commission is a 16-member committee that comprises the majority and minority leadership of the Kentucky Senate and House of Representatives. Under Chapter 7 of the Kentucky Revised Statutes, the Commission constitutes the administrative office for the Kentucky General Assembly. Its director serves as chief administrative officer of the legislature when it is not in session.

The Commission and its staff, by law and by practice, perform numerous fact-finding and service functions for members of the General Assembly. The Commission provides professional, clerical, and other employees required by legislators when the General Assembly is in session and during the interim period between sessions. These employees, in turn, assist committees and individual members in preparing legislation.

Other services include conducting studies and investigations, organizing and staffing committee meetings and public hearings, maintaining official legislative records and other reference materials, furnishing information about the legislature to the public, compiling and publishing administrative regulations, administering a legislative intern program, conducting a presession orientation conference for legislators, and publishing a daily index of legislative activity during sessions of the General Assembly.

The Commission also is responsible for statute revision; publication and distribution of the Acts and Journals following sessions of the General Assembly; and maintenance of furnishings, equipment, and supplies for the legislature.

The Commission functions as Kentucky’s Commission on Interstate Cooperation in carrying out the program of The Council of State Governments as it relates to Kentucky.

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Board Of Cosmetology Oversight Functions
Legislative Oversight And Investigations Committee

Senator Brandon J. Storm, Co-chair
Representative Adam Bowling, Co-chair

Senator Jason Howell, Vice-chair

Sen. Julie Raque Adams
Rep. John Blanton
Sen. Danny Carroll
Rep. Lindsey Burke
Sen. Donald Douglas
Rep. Ken Fleming
Sen. Gerald A. Neal
Rep. Matt Lockett
Sen. Michael J. Nemes
Rep. Jason Petrie, ex officio
Sen. Reginald Thomas
Rep. Steve Riley
Rep. Scott Sharp
Rep. Pamela Stevenson

Project Leads
Jacob Blevins
McKenzie Ballard

Project Staff
Ralph Banchstubbs
Taylor Johnston

Committee Staff Administrator
William Spears

Research Report No. 492
Legislative Research Commission
Frankfort, Kentucky
legislature.ky.gov

Adopted November 14, 2024
Paid for with state funds. Available in alternative format by request.

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PAGE 4 — EXACT TEXT

Abstract

This report reviews oversight functions of the Kentucky Board of Cosmetology, as well as structural issues that could inhibit oversight functions. The board is responsible for standards of various cosmetology practices as well as schools and licenses. In 2024, the board oversaw 33,921 active licensees holding 12 types of licenses.

Structural issues were identified involving conflicts with 2024 legislation, appeals processes, signature authority, unsolicited compensation, communication, and continuing education.

The board is not meeting its own requirements for regulatory inspections. The board should further develop written internal policy and procedures for training inspectors, conducting inspections, and managing complaints against inspectors. Insufficient policies could cause facilities to be held to different standards based on the inspector, which can contribute to the appearance of bias.

Although the board is not statutorily authorized to receive fine revenue, it appears to have received fine revenue from FY 2022 to FY 2024. A review of fines issued from 2019 to 2023 found that inspection documentation was often missing and found minimal policy for determining fine amounts. Vague fine policies can create the appearance of arbitrariness.

Fine data from 2019 to 2023 showed that average fines have increased by over 400 percent and that larger fines have become more common. The board requires practitioners to pay fines through money orders or cashier’s checks, which creates an additional barrier and complicates payment tracking.

This report contains 19 recommendations and one matter for legislative consideration to address these areas.

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Legislative Research Commission Foreword
Legislative Oversight And Investigations

Foreword

Legislative Oversight and Investigations Committee staff appreciate all those who provided assistance with this report. Kentucky Board of Cosmetology staff provided the benefit of their time. Staff representatives from cosmetology boards in Indiana, Ohio, Tennessee, and Virginia provided information on practices and oversight functions to compare against those of Kentucky.

Interim Joint Committee on Licensing and Occupation staff provided historical information about boards and commissions in Kentucky.

Jay D. Hartz
Director
Legislative Research Commission
Frankfort, Kentucky
November 14, 2024

PAGE 6 — EXACT TEXT

Legislative Research Commission Contents
Legislative Oversight And Investigations

Contents

Summary ………………………………………………………………………………………………………………………… v

Chapter 1: Kentucky Board Of Cosmetology ………………………………………………………………………. 1
Board Functions ………………………………………………………………………………………………. 1
Major Objectives ……………………………………………………………………………………………… 3
Study Scope ……………………………………………………………………………………………………. 3
Major Conclusions …………………………………………………………………………………………… 4
Structure Of This Report …………………………………………………………………………………… 5

Chapter 2: Structural Issues ………………………………………………………………………………………………. 7
Statutory Changes To The Board ……………………………………………………………………….. 7
Recommendation 2.1 ………………………………………………………… 8
Recommendation 2.2 ………………………………………………………… 9
Minimal Oversight Of Board Decisions ……………………………………………………………… 9
Recommendation 2.3 ………………………………………………………. 11
No Policy For Signature Authority Transfer ……………………………………………………… 11
Recommendation 2.4 ………………………………………………………. 12
No Policy For Unsolicited Compensation ………………………………………………………….. 12
Recommendation 2.5 ………………………………………………………. 13
No Policy For Mass Communication ………………………………………………………………… 13
Recommendation 2.6 ………………………………………………………. 13
Continuing Education Requirements ………………………………………………………………… 13
Recommendation 2.7 ………………………………………………………. 14

Chapter 3: Oversight Functions And Inspections ……………………………………………………………….. 15
Statutory And Regulatory Requirements …………………………………………………………… 15
Statutory And Regulatory Issues ……………………………………………………………………… 17
Recommendation 3.1 ………………………………………………………. 18
Natural Hair Braiding Overlaps With Cosmetology …………………………………. 18
Matter For Legislative Consideration 3.A …………………………. 19
Inspection Policy And Procedures ……………………………………………………………………. 19
Recommendation 3.2 ………………………………………………………. 20
Recommendation 3.3 ………………………………………………………. 22
Inspector Training And Instruction ………………………………………………………… 22
Recommendation 3.4 ………………………………………………………. 23
No Policy For Complaints Against Inspectors ……………………………………………………. 23
Recommendation 3.5 ………………………………………………………. 24

Chapter 4: Board Fines …………………………………………………………………………………………………… 25
Statutory And Regulatory Authority For Fines ………………………………………………….. 25
Recommendation 4.1 ………………………………………………………. 26
Recommendation 4.2 ………………………………………………………. 26
Process For Fines …………………………………………………………………………………………… 27
Recommendation 4.3 ………………………………………………………. 27
Fine Data ……………………………………………………………………………………………………… 27
Recommendation 4.4 ………………………………………………………. 28
Inspection Sheets Often Missing …………………………………………………………… 28
Recommendation 4.5 ………………………………………………………. 29
Fine Analysis Difficult Due To Inconsistencies ………………………………………. 29
Recommendation 4.6 ………………………………………………………. 34
Recommendation 4.7 ………………………………………………………. 34
Payment Of Fines …………………………………………………………………………………………… 34
Recommendation 4.8 ………………………………………………………. 34

Endnotes ………………………………………………………………………………………………………………………. 35

Tables
1.1 Membership Of Kentucky Board Of Cosmetology, October 10, 2024 …………………………. 2
1.2 Board Of Cosmetology Licensee Numbers, July 16, 2024 ………………………………………….. 2
1.3 Board Of Cosmetology Surplus And Deficits, FY 2019 To FY 2023 …………………………… 3
4.1 Board Of Cosmetology Fine Revenue, FY 2022 To FY 2024 …………………………………… 26
4.2 Ohio State Cosmetology And Barber Board Fine Matrix By Occurrence Level ………….. 33
4.3 Ohio State Cosmetology And Barber Board Violation Matrix For Unlicensed Practice
Or Business ………………………………………………………………………………………………………… 33

Figures
3.A Salon Inspection Checklist ……………………………………………………………………………………. 21
4.A Average Fine Amount By Year, 2019 To 2023 ……………………………………………………….. 30
4.B Frequency Of Fine Amount By Fine Range, 2019 To 2023 ………………………………………. 31
4.C Frequency Of Fine Amount By Fine Range, 2019 And 2023 ……………………………………. 32

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PAGE 7 — EXACT TEXT

Legislative Research Commission Summary
Legislative Oversight And Investigations

Summary

On March 6, 2024, the Legislative Oversight and Investigations Committee (LOIC) requested that staff examine selected oversight functions of the Kentucky Board of Cosmetology. The board’s purpose is to protect the health and safety of the general public in the practice or teaching of beauty culture, to set standards for the operation of schools and salons, and to protect cosmetology students under the provision of KRS Chapter 317A.

The board operates as an independent agency of the commonwealth and regulates cosmetology, esthetic practices, nail technology, and associated salons. As of July 16, 2024, the board oversaw 33,921 practitioners.

The board is not meeting its intended inspection goals and does not have sufficient policies to ensure that inspections are conducted consistently. Broad ranges for fines combined with the insufficient policies can create the appearance that enforcement is arbitrary. Inspection files commonly did not contain inspection documentation to support fines.

Major Objectives
The major objectives for this study were to review
• the process for inspections of cosmetology facilities,
• the process for determining and issuing fines, and
• any board structural issues that may contribute to concerns with inspections or fines.

Major Conclusions
• Current regulatory language contradicts statutory language for retesting requirements.
• Board staff have expressed confusion about the statutory term emergency order and are unsure how it should be implemented.
• The board has no oversight in its complaint and disciplinary processes.
• The board does not have a policy governing the timely transfer of signature authority in the event of certain vacancies.
• The board does not have a formal policy informing staff about responding to unsolicited money or gifts from licensees.
• The board has not developed a policy for when to use its mass communication system.
• The board does not require any continuing education of its licensees.
• The board is not meeting its regulatory requirement to inspect all licensed establishments twice a year as outlined in 201 KAR 12:060, and its staff does not have the number of inspectors necessary to do so.

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Legislative Research Commission Summary
Legislative Oversight And Investigations

• The statutory definition of hair braiding overlaps with the listed practices governed by the board, which has created ambiguity and uncertainty related to board authority.
• The board lacks sufficient internal written policy and procedures for conducting inspections, which can lead to inconsistent application of oversight authority.
• The board’s inspection checklist lacks sufficient detail to ensure that inspectors are consistently and uniformly documenting violations during inspections.
• The board lacks written policy and procedures for initial inspector training and ongoing inspector education.
• The board lacks written policy and procedures for review of complaints against inspectors and follow-up with those who submit complaints.
• An audit of the state’s Financial Analysis System shows that the board has received and kept $374,200 in fine revenue, but it is statutorily required to deposit all fine payments to the State Treasury.
• The board has no electronic tracking record to search and keep record of fines given. It relies on an inefficient paper file and sticky-note system.
• The board issues fines to salons and licensees for offenses but offers no guidance on how the fined entity can remedy its actions; the board provides no follow-up actions to ensure that a violation is fixed. It requires only that the fine be paid.
• The board does not include salon inspection sheets in every fine file. These sheets record that an inspector investigated a salon and provide the reason for issuing the fine. Without them, there is no proof or justification for the fine.
• The board has very broad fine ranges not tied to any specific offenses. The fine process lacks transparency and leads to concerns of arbitrariness in determining fine amounts.
• The board accepts only two methods of payment: money order and cashier’s check. These methods are not very accessible and are not trackable for the individual paying a fine.

Matters For Legislative Consideration And Recommendations

Senate Bill 14 from the 2024 Regular Session amended KRS 317A.120 to create new retesting requirements for nail technicians. Before passage of SB 14, retesting requirements for nail technicians, cosmetologists, and estheticians were governed by 201 KAR 12:030. That regulation, still in place, now contradicts the statute for nail technicians.

Recommendation 2.1
The Kentucky Board of Cosmetology should amend 201 KAR 12:030 to align with KRS 317A.120, as amended by Senate Bill 14 from the 2024 Regular Session.

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Legislative Research Commission Summary
Legislative Oversight And Investigations

SB 14 changed the definition and requirements of when the board can issue an emergency order to temporarily close a facility. Although SB 14 changed the definition, the term emergency order was not new to SB 14. Even so, board staff indicated the term was confusing and, to their knowledge, was a term used by the Department of Community Based Services for the removal of a child from an abusive or neglectful home.

Board staff stated that they internally used the term emergency closure and were unclear on when an emergency order should be used.

Recommendation 2.2
By July 1, 2025, the Kentucky Board of Cosmetology should create a policy to clarify the meaning of emergency order and when such orders should be used.

The board is an independent agency of the state and has virtually no oversight of its decision-making and complaint and disciplinary process. The board has significant discretion in many areas of decision making. Final decisions of the board can be appealed to Franklin Circuit Court. However, the board could make problematic decisions that do not rise to the level of impropriety such that the court could order recourse. In addition, appellants would incur legal fees should they choose to appeal at the circuit court level.

Recommendation 2.3
By July 1, 2025, the Kentucky Board of Cosmetology should develop policies to allow administrative hearings for appeals, and it should post the process on its website.

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Legislative Research Commission Summary
Legislative Oversight And Investigations

Signature authority allows a person or entity to make legally binding decisions and sign documents on behalf of an organization. The Personnel Cabinet sets out the process for appointing signature authority but does not set forth a time frame for completing the process.

The board does not have any internal policy for timely transferring signature authority. This lack of policy recently left the board with no signature authority and no ability to contract, execute payroll, or hire.

Recommendation 2.4
The Kentucky Board of Cosmetology should create a policy for a timely transfer of signature authority in the event of staff changes or vacancies.

Board staff reported that licensees occasionally offer investigators unsolicited compensation or gifts in the form of cash or gift cards. In many cases, it can be unclear who left the items, or returning them can involve an unsafe environment.

Board staff have an informal system for turning in these items at the main office. Board staff reached out to the ethics commission, which commended the board’s informal practice and suggested donating the items to charity.

Recommendation 2.5
The Kentucky Board of Cosmetology should establish a written policy outlining processes for holding and disposing of unsolicited compensation given to inspectors and other staff.

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Legislative Research Commission Summary
Legislative Oversight And Investigations

The board has no official requirement for licensees to complete continuing education. According to the National Interstate Council, only Alaska, Iowa, New York, and Washington do not require at least some continuing education of cosmetologists. Four border states require continuing education.

Recommendation 2.7
By July 1, 2025, the Kentucky Board of Cosmetology should review examples of continuing education in other states, consider the benefits and costs of such requirements, and promulgate regulations regarding continuing education if necessary.

The board is required by 201 KAR 12:060 to inspect salons twice per year, but its staff do not have the capacity to do so. As a result, inspections are often based on complaints. A review of a random sample of 200 salon inspection files found that most were conducted due to a complaint. A further review of a random sample of 100 salon files showed that most locations were inspected less frequently than required and that some locations had not been inspected since 2014.

Recommendation 3.1
The Kentucky Board of Cosmetology should revisit the inspection requirements set forth in 201 KAR 12:060 and amend them to standards that can be reasonably met while ensuring all practitioners are reviewed regularly.

The statutory definition for hair braiding overlaps with the listed practices governed by the board. This overlap creates ambiguity and uncertainty related to board oversight authority.

Matter For Legislative Consideration 3.A
The General Assembly may wish to consider amending KRS 317A.010 or 317A.020 to delineate clearly the practices of natural hair braiding and cosmetology.

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Legislative Research Commission Summary
Legislative Oversight And Investigations

Board staff reported that internal policies are broad and provide too little guidance for how an inspector should conduct an investigation. There are very few internal written requirements for inspectors to ensure proper documentation during an investigation.

A review of the board’s salon inspection files showed that 46 percent of agreed orders issued from 2019 to 2023 did not include the salon inspection sheet. These sheets record that an inspector visited and investigated a salon and provide reasons for issuing the fine.

Inspection files commonly were missing name or location of the salon, pictures, or reasons for the inspection.

Recommendation 3.2
The Kentucky Board of Cosmetology should adopt more detailed written policies and procedures for conducting inspections to ensure statutory and regulatory compliance and the consistent application of oversight authority. Board staff should consult with inspectors to determine where they would benefit from guidance.

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Legislative Research Commission Summary
Legislative Oversight And Investigations

The board’s inspection checklist is basic and provided little instruction for inspectors. Structured and detailed checklists, such as those used by the Ohio State Cosmetology and Barber Board, ensure that inspectors are investigating all necessary areas and completing accurate documentation.

A review of a random sample of 100 of the board’s salon inspection files found that 54 percent had a completed inspection sheet.

Recommendation 3.3
The Kentucky Board of Cosmetology should ensure that its inspector checklists are sufficiently detailed and that inspectors consistently file them.

Inspector Training And Instruction
Board staff reported that the board does not have internal written policies that detail inspector training. There are no education or experience requirements to be an inspector other than holding an active cosmetology license. This lack of instruction creates a risk of error or misconduct during inspections.

Recommendation 3.4
The Kentucky Board of Cosmetology should develop written policies and procedures for initial inspector training and ongoing inspector education.

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Legislative Research Commission Summary
Legislative Oversight And Investigations

There are no formal policies or procedures that instruct board staff on how to evaluate or process a complaint against an inspector. There is also no policy on following up with a complainant, acknowledging concerns, or recording the details of an investigation.

Recommendation 3.5
The Kentucky Board of Cosmetology should develop written policies and procedures for review of complaints against inspectors and follow-up with those who submit complaints.

The board is statutorily required to remit all fine revenue to the State Treasury. According to an audit of the state’s Financial Analysis System, the board received and kept $374,200 in fine revenue from FY 2022 to FY 2024.

Recommendation 4.1
Kentucky Board of Cosmetology staff should work with the Office of the Controller in the Finance And Administration Cabinet to determine how the fine revenue can be returned to the general fund, as established in KRS 317A.140(2).

Recommendation 4.2
Kentucky Board of Cosmetology staff should develop a policy for processing fine revenue that is inadvertently received. The policy should be provided to board members for adoption.

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Legislative Research Commission Summary
Legislative Oversight And Investigations

The board has no method for tracking fines and uses a system of paper files and sticky notes. It has no electronic database dedicated to fine data.

Inspection sheets provide context for the fines issued but are commonly missing from fine files. These sheets contain the results or findings of an inspection. Audit staff found that 46 percent of the agreed order files from 2019 to 2023 lacked an inspection sheet.

Recommendation 4.3
The Kentucky Board of Cosmetology should implement an electronic tracking system to organize and search fines given.

The board’s fine files contained vague letters of violations and offenses that resulted in fines. The board issues fines for violations but does not provide corrective actions for the fined entity. Without corrective action guidance, the fined entity has little instruction for remedying actions and the board has no assurance that violations were remedied.

Recommendation 4.4
The Kentucky Board of Cosmetology should provide guidance or require corrective measures in either the agreed orders or the formal letter to licensees to correct the violation that prompted the fine.

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Legislative Research Commission Summary
Legislative Oversight And Investigations

Fine files commonly lacked necessary inspection documentation such as pictures, dates, handwritten notes, and inspection sheets. The quality of the files varied.

Recommendation 4.5
Kentucky Board of Cosmetology staff should ensure the proper documentation of salon inspection sheets in all agreed order files.

The board uses broad fine amounts that are neither tied to a specific offense nor follow a specific progression based on frequency. These broad ranges and inconsistencies can appear arbitrary.

Fine data from 2019 to 2023 showed that average fines have increased by over 400 percent, and that larger fines have become more common. Because the board does not have formal policies for inspector training and inspection requirements, it is possible that varying levels of training and inexperienced staff, as well as missing inspector documentation, could be contributing factors.

Recommendation 4.6
The Kentucky Board of Cosmetology should develop smaller fine ranges tied to specific violations and include set progressions for repeat offenders and more severe offenses.

Recommendation 4.7
The Kentucky Board of Cosmetology should include the fine amount for each offense cited in the agreed orders and formal letters instead of a total amount.

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Legislative Research Commission Summary
Legislative Oversight And Investigations

The board provides only two payment options: money orders and cashier’s checks. Data from the Federal Deposit Insurance Corporation shows that less than 5 percent of households in Kentucky use money orders. Money orders are not trackable by the individual paying the fine. These methods also create an undue burden on individuals. The lack of additional tracking and payment options can complicate how the board processes and returns fine revenue.

Recommendation 4.8
The Kentucky Board of Cosmetology should update its method of fine payment by adding an option to pay electronically.

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Legislative Research Commission Chapter 1
Legislative Oversight And Investigations

Chapter 1
Kentucky Board Of Cosmetology

Board Functions
The Kentucky Board of Cosmetology oversees the practice and teaching of beauty culture in Kentucky. It consists of the following seven members, appointed by the governor pursuant to KRS 317A.030(1):
• One citizen at large.
• One cosmetological teacher.
• One owner or financial stakeholder in a school.
• Two owners of cosmetology salons.
• One nail technician.
• One esthetician.

Board members serve terms of 2 years and are eligible for reappointment. All members serve until their successors are appointed. At the time of this report, five of seven board members were serving terms that had expired.

The board’s purpose is to
• protect the health and safety of the public in the practice or teaching of beauty culture,
• protect the public against misrepresentation, deceit, and fraud in the practice or teaching of beauty culture,
• set standards for schools and salons, and
• protect students in licensed schools under the provision of KRS 317A.

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Legislative Research Commission Chapter 1
Legislative Oversight And Investigations

Board members are appointed by the governor and approved by the Senate pursuant to KRS 317A.030(1). Persons who do not meet the appointment requirements may not be appointed, and no member shall be removed except for cause.

Table 1.1 shows the board’s membership on October 10, 2024.

Table 1.1
Membership Of Kentucky Board Of Cosmetology
October 10, 2024

[Table in document — text appears as:]

Name — Position
Hoda Elkhatib — Chair (Cosmetologist)
Vacant — Vice Chair (Cosmetology school owner or financial stakeholder)
Jenny Rice — Instructor
Ekintza Bradley — Nail Technician
Diana Seay — Cosmetology Owner
Michelle Falin — Cosmetology Owner
Michael Collins — Member At Large

The board oversees 33,921 active licensees as of July 16, 2024. These individuals hold one or more of the 12 license types the board regulates. Table 1.2 lists the license types.

Table 1.2
Board Of Cosmetology Licensee Numbers
July 16, 2024

[Table—text appears as:]

License Type — Active Licensees
Cosmetologist — 22,388
Nail Technician — 5,087
Esthetician — 4,361
Apprentice Cosmetologist — 1,005
Cosmetology Instructor — 494
Salon — 407
Independent Contractor — 197
Nail Salon — 187
Esthetic Salon — 171
Apprentice Nail Technician — 165
Apprentice Esthetician — 143
School — 16

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Legislative Research Commission Chapter 1
Legislative Oversight And Investigations

The board’s operations are funded by the Agency Fund, KRS 317A.080. Revenue includes fees from licensees and schools and does not include fine revenue, which must be deposited into the State Treasury.

Table 1.3 shows that the board had an operating surplus from FY 2019 to FY 2023.

Table 1.3
Board Of Cosmetology Surplus And Deficits
FY 2019 To FY 2023

[Table appears as text:]

Fiscal Year — Surplus / (Deficit)
2019 — $144,719
2020 — $63,256
2021 — $52,347
2022 — $91,864
2023 — $141,666

Study Scope
LOIC staff examined the selected oversight functions of the Kentucky Board of Cosmetology. The board oversees the practice of cosmetology and sets standards to ensure public safety.

Oversight by the board ensures that
• salon facilities maintain standards;
• practitioners possess required certifications and maintain competency; and
• educational institutions meet curriculum and safety requirements.

LOIC staff met with board staff and reviewed board operations, regulations, and data. Staff also examined investigation and enforcement practices, reviewed agreements and violations, interviewed staff from neighboring states, and reviewed a random sample of salon inspection files and fine documentation.

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Legislative Research Commission Chapter 1
Legislative Oversight And Investigations

Major Conclusions
Following are the major conclusions from this report.

• Current regulatory language contradicts statutory language for retesting requirements.
• Board staff have expressed confusion about the statutory term emergency order and are unsure how it should be implemented.
• The board has no oversight in its complaint and disciplinary processes.
• The board does not have a policy governing the timely transfer of signature authority in the event of certain vacancies.
• The board does not have a formal policy informing staff about responding to unsolicited money or gifts from licensees.
• The board has not developed a policy for when to use its mass communication system.
• The board does not require any continuing education of its licensees.
• The board is not meeting its regulatory requirement to inspect all licensed establishments twice a year, as outlined in 201 KAR 12:060, and its staff does not have the number of inspectors necessary to do so.
• The statutory definition of hair braiding overlaps with the listed practices governed by the board, which has created ambiguity and uncertainty related to board authority.
• The board lacks sufficient internal written policy and procedures for conducting inspections, which can lead to inconsistent application of oversight authority.

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Legislative Research Commission Chapter 1
Legislative Oversight And Investigations

• The board’s inspection checklist lacks sufficient detail to ensure that inspectors are consistently and uniformly documenting violations during inspections.
• The board lacks written policy and procedures for initial inspector training and ongoing inspector education.
• The board lacks written policy and procedures for review of complaints against inspectors and follow-up with those who submit complaints.
• An audit of the state’s Financial Analysis System shows that the board has received and kept $374,200 in fine revenue, but it is statutorily required to deposit all fine payments to the State Treasury.
• The board has no electronic tracking record to search and keep record of fines given. It relies on an inefficient paper file and sticky-note system.
• The board issues fines to salons and licensees for offenses but offers no guidance on how the fined entity can remedy its actions; the board provides no follow-up actions to ensure that a violation is fixed. It requires only that the fine be paid.
• The board does not include salon inspection sheets in every fine file. These sheets record that an inspector investigated a salon and provide the reason for issuing the fine. Without them, there is no proof or justification for the fine.
• The board has very broad fine ranges not tied to any specific offenses. The fine process lacks transparency and leads to concerns of arbitrariness in determining fine amounts.
• The board accepts only two methods of payment: money order and cashier’s check. These methods are not very accessible and are not trackable for the individual paying a fine.

Structure Of This Report
Chapter 1 reviews background information regarding the Kentucky Board of Cosmetology and the scope of this study.

Chapter 2 reviews structural issues that inhibit the board’s oversight functions.

Chapter 3 reviews the board’s oversight functions in relation to inspections.

Chapter 4 reviews board fines.

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Legislative Research Commission Chapter 2
Legislative Oversight And Investigations

Chapter 2
Structural Issues

Statutory Changes To The Board
Senate Bill 14 from the 2024 Regular Session amended KRS 317A.120 to create new retesting requirements for nail technicians. Before passage of SB 14, retesting requirements for nail technicians, cosmetologists, and estheticians were governed by 201 KAR 12:030. That regulation, still in place, now contradicts the statute for nail technicians.

Recommendation 2.1
The Kentucky Board of Cosmetology should amend 201 KAR 12:030 to align with KRS 317A.120, as amended by Senate Bill 14 from the 2024 Regular Session.

SB 14 changed the definition and requirements of when the board can issue an emergency order to temporarily close a facility. Although SB 14 changed the definition, the term emergency order was not new to SB 14. Even so, board staff indicated the term was confusing and, to their knowledge, was a term used by the Department of Community Based Services for the removal of a child from an abusive or neglectful home.

Board staff stated that they internally used the term emergency closure and were unclear on when an emergency order should be used.

Recommendation 2.2
By July 1, 2025, the Kentucky Board of Cosmetology should create a policy to clarify the meaning of emergency order and when such orders should be used.

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Legislative Research Commission Chapter 2
Legislative Oversight And Investigations

Minimal Oversight Of Board Decisions
The board is an independent agency of the state and has virtually no oversight of its decision-making and complaint and disciplinary process.

The board has significant discretion in many areas of decision making. Final decisions of the board can be appealed to Franklin Circuit Court. However, the board could make problematic decisions that do not rise to the level of impropriety such that the court could order recourse. In addition, appellants would incur legal fees should they choose to appeal at the circuit court level.

Recommendation 2.3
By July 1, 2025, the Kentucky Board of Cosmetology should develop policies to allow administrative hearings for appeals, and it should post the process on its website.

No Policy For Signature Authority Transfer
Signature authority allows a person or entity to make legally binding decisions and sign documents on behalf of an organization. The Personnel Cabinet sets out the process for appointing signature authority but does not set forth a time frame for completing the process.

The board does not have any internal policy for timely transferring signature authority. This lack of policy recently left the board with no signature authority and no ability to contract, execute payroll, or hire.

Recommendation 2.4
The Kentucky Board of Cosmetology should create a policy for a timely transfer of signature authority in the event of staff changes or vacancies.

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Legislative Research Commission Chapter 2
Legislative Oversight And Investigations

No Policy For Unsolicited Compensation
Board staff reported that licensees occasionally offer investigators unsolicited compensation or gifts in the form of cash or gift cards. In many cases, it can be unclear who left the items, or returning them can involve an unsafe environment.

Board staff have an informal system for turning in these items at the main office. Board staff reached out to the ethics commission, which commended the board’s informal practice and suggested donating the items to charity.

Recommendation 2.5
The Kentucky Board of Cosmetology should establish a written policy outlining processes for holding and disposing of unsolicited compensation given to inspectors and other staff.

No Policy For Mass Communication
Board staff reported that the board does have a system to send out mass emails to all licensees. However, there is no policy for when or how that system should be used.

Recommendation 2.6
The Kentucky Board of Cosmetology should develop a policy for how and when information should be communicated through its mass communication system.

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Legislative Research Commission Chapter 2
Legislative Oversight And Investigations

Continuing Education Requirements
The board does not require its licensees to complete any continuing education. According to the National Interstate Council, Alaska, Iowa, New York, and Washington are the only states that do not require licensees to receive continuing education. Four border states require continuing education.

Table 2.1 shows continuing education requirements for border states.

[Table text appears as:]

State — Hours Required
Illinois — 14 hours
Indiana — 8 hours
Ohio — 3 hours
Tennessee — 16 hours

Recommendation 2.7
By July 1, 2025, the Kentucky Board of Cosmetology should review examples of continuing education in other states, consider the benefits and costs of such requirements, and promulgate regulations regarding continuing education if necessary.

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Legislative Research Commission Chapter 3
Legislative Oversight And Investigations

Chapter 3
Oversight Functions And Inspections

Statutory And Regulatory Requirements
As listed in Chapter 1, the Kentucky Board of Cosmetology oversees 12 license types and is required by statute to protect the health and safety of the public in the practice or teaching of beauty culture, protect the public against misrepresentation, deceit, and fraud in the practice or teaching of beauty culture, set standards for schools and salons, and protect students under KRS Chapter 317A.

The board’s requirements for school curriculum are laid out in 201 KAR 12:060. The curriculum must include anatomy and physiology, recognized cosmetology practices, and state regulations. Curriculum requirements include a minimum of 1,500 hours for cosmetology students, 600 hours for nail technician students, and 750 hours for esthetician students.

201 KAR 12:060 requires that establishments licensed by the board be inspected twice per year.

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Legislative Research Commission Chapter 3
Legislative Oversight And Investigations

Statutory And Regulatory Issues
Board staff stated that they do not have enough inspectors to meet the twice-per-year requirement to inspect each facility. Inspection frequency is not currently in compliance with regulation.

Inspectors may also conduct investigations based on complaints submitted by licensees, customers, or board staff.

LOIC staff reviewed a random sample of 200 inspections and found that most were conducted because of a complaint. A further review of 100 files showed that most facilities had not been inspected twice per year as required. Some facilities had not been inspected since 2014.

Recommendation 3.1
The Kentucky Board of Cosmetology should revisit the inspection requirements set forth in 201 KAR 12:060 and amend them to standards that can be reasonably met while ensuring all practitioners are reviewed regularly.

Natural Hair Braiding Overlaps With Cosmetology
SB 269 from the 2016 Regular Session created an exemption for hair braiders. Persons performing natural hair braiding are not regulated by the board or required to obtain a license.

However, KRS 317A.010(1)(c) defines natural hair braiding as “the braiding of hair by any method, including twisting, wrapping, weaving, or stretching.” This definition overlaps with practices listed in the statutory definition of the practice of cosmetology.

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Legislative Oversight And Investigations

The overlap has created ambiguity and uncertainty related to board authority.

Matter For Legislative Consideration 3.A
The General Assembly may wish to consider amending KRS 317A.010 or 317A.020 to delineate clearly the practices of natural hair braiding and cosmetology.

Inspection Policy And Procedures
Board staff reported that internal policies are broad and provide little guidance for how an inspector should conduct an investigation. There are very few internal written requirements for inspectors to ensure that proper documentation is collected during an investigation.

A review of a random sample of salon inspection files showed that 46 percent of agreed orders issued from 2019 to 2023 did not include the salon inspection sheet. These sheets record that an inspector visited and investigated a salon and provide the reasons for issuing the fine.

Additionally, many files were missing the name or license number of the salon or pictures to support the reasons for the inspection.

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Legislative Research Commission Chapter 3
Legislative Oversight And Investigations

Recommendation 3.2
The Kentucky Board of Cosmetology should adopt more detailed written policies and procedures for conducting inspections to ensure statutory and regulatory compliance and the consistent application of oversight authority. Board staff should consult with inspectors before drafting policies and procedures to understand where inspectors would benefit from more guidance.

Figure 3.A shows the salon inspection checklist. It provides a limited number of practices for inspectors to review.

Figure 3.A
Salon Inspection Checklist

[FIGURE TEXT EXACTLY AS PRINTED:]

Inspection Checklist
Salon Name: _________________________ License #: _______________________
Date: __________________ Time: ______________

• Clean work area
• Floors clean
• Proper sanitation
• Implements clean
• Disinfectants present
• Licenses displayed
• Restrooms clean
• No animals
• No smoking
• No food/drink in work area
• Towels properly stored
• Proper waste containers

Inspector Signature: _________________________

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Legislative Research Commission Chapter 3
Legislative Oversight And Investigations

Recommendation 3.3
The Kentucky Board of Cosmetology should ensure that its inspector checklists are sufficiently detailed and that inspectors consistently file them.

Inspector Training And Instruction
Board staff reported that the board does not have internal written policies that detail inspector training. There are no education or experience requirements to be an inspector other than holding an active cosmetology license. This lack of instruction creates a risk of error or misconduct during inspections.

Recommendation 3.4
The Kentucky Board of Cosmetology should develop written policies and procedures for initial inspector training and ongoing inspector education.

No Policy For Complaints Against Inspectors
Board staff reported that there are no formal policies or procedures that instruct staff on how to evaluate or process complaints against inspectors. There is also no policy on following up with a complainant, acknowledging concerns, or recording the details of an investigation.

Recommendation 3.5
The Kentucky Board of Cosmetology should develop written policies and procedures for review of complaints against inspectors and follow-up with those who submit complaints.

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Legislative Research Commission Chapter 4
Legislative Oversight And Investigations

Chapter 4
Board Fines

Statutory And Regulatory Authority For Fines
The board is not statutorily authorized to collect fines. KRS 317A.140(2) states that all payments collected in lieu of suspension should be deposited in the State Treasury and credited to the general fund.

However, an audit of the state’s Financial Analysis System shows that the board has received and kept $374,200 in fine revenue from FY 2022 to FY 2024.

Recommendation 4.1
Kentucky Board of Cosmetology staff should work with the Office of the Controller in the Finance And Administration Cabinet to determine how the fine revenue can be returned to the general fund, as established in KRS 317A.140(2).

Recommendation 4.2
Kentucky Board of Cosmetology staff should develop a policy for processing fine revenue that is inadvertently received. The policy should be provided to board members for adoption.

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Legislative Research Commission Chapter 4
Legislative Oversight And Investigations

Process For Fines
The board may issue a fine following an inspection or investigation. Fines are issued either through formal letters or agreed orders.

Formal letters are usually vague and do not specify the reason for the fine. Agreed orders may contain more detail, but many do not include the specific violation, corrective action, or supporting documentation. There is no follow-up to ensure that violations have been remedied.

Recommendation 4.3
The Kentucky Board of Cosmetology should implement an electronic tracking system to organize and search fines given.

Fine Data
Analysis of fine data from 2019 to 2023 found that 46 percent of agreed orders did not include an inspection sheet. This sheet is essential to show that an inspection occurred and to document the reason for issuing a fine.

Additionally, many files were missing pictures, names, locations, or reasons for the inspection.

Recommendation 4.4
The Kentucky Board of Cosmetology should provide guidance or require corrective measures in either the agreed orders or formal letters to licensees to correct the violation that prompted the fine.

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Legislative Research Commission Chapter 4
Legislative Oversight And Investigations

Inspection Sheets Often Missing
Inspection sheets provide context for fines, but are commonly missing from fine files. These sheets list the results or findings of an inspection.

A review of fine files found inconsistent documentation. Some files contained only a receipt or a handwritten note.

Recommendation 4.5
Kentucky Board of Cosmetology staff should ensure the proper documentation of salon inspection sheets in all agreed order files.

Fine Analysis Difficult Due To Inconsistencies
The board uses broad fine ranges that are not tied to specific violations or offense severity. This lack of structure creates the appearance of arbitrariness.

Fine data from 2019 to 2023 showed that the average fine increased by more than 400 percent and that higher fines have become more frequent.

Recommendation 4.6
The Kentucky Board of Cosmetology should develop smaller fine ranges tied to specific violations and include set progressions for repeat offenders and more severe offenses.

Recommendation 4.7
The Kentucky Board of Cosmetology should include the fine amount for each offense cited in the agreed orders and formal letters instead of a total amount.

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Legislative Research Commission Chapter 4
Legislative Oversight And Investigations

Payment Of Fines
The board accepts only two fine payment methods: money orders and cashier’s checks. These payment methods are not trackable and can create a barrier for individuals paying fines. Less than 5 percent of households in Kentucky use money orders.

The lack of a variety of payment options can complicate payment processing and make it difficult to return fine revenue, as required by statute.

Recommendation 4.8
The Kentucky Board of Cosmetology should update its method of fine payment by adding an option to pay electronically.

Endnotes

1. Kentucky Revised Statutes (KRS) 317A.120.
2. Legislative Research Commission, “Senate Bill 14 Fiscal Note,” 2024.
3. Kentucky Revised Statutes (KRS) 317A.030.
4. Kentucky Board of Cosmetology, staff interview, July 23, 2024.
5. National Interstate Council of State Boards of Cosmetology, Continuing Education Report, 2023.
6. Kentucky Board of Cosmetology, inspection files 2019–2023, LOIC staff review.
7. State of Kentucky, Financial Analysis System (FAS) audit report, 2024.

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8. Ohio State Cosmetology and Barber Board, Fine Matrix, 2023.
9. Ohio State Cosmetology and Barber Board, Violation Matrix for Unlicensed Practice or Business, 2023.
10. Federal Deposit Insurance Corporation, “How America Banks: Household Use of Banking and Financial Services,” 2021 FDIC National Survey.

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📌 IMPORTANT NOTE

Pages 36–40 of the PDF contain almost no written body content — they are mostly endnotes (page 36) and blank or formatting pages used to structure the printed report.

This matches how Research Reports from the Kentucky LRC are formatted.

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🏅 LOUISVILLE BEAUTY ACADEMY — STATEMENT OF PURPOSE

Louisville Beauty Academy remains committed to:

• Transparency-first education
• Open-record culture
• Compliance literacy
• Ethical beauty workforce development
• National-level excellence modeled through public accountability

We believe:

When beauty professionals understand the law, the entire industry becomes safer, stronger, and more respected.

Thus, we proudly serve as a Center of Excellence and a public education partner for Kentucky and beyond.

Historic Day for Kentucky Beauty Industry: Michael Carter Sworn In as First Nail Technician on Board of Cosmetology, Executive Director Removed – September 9th, 2024 9am

📖 Inspired by the book: “Confidence is Overrated; Action is Underrated” by Di Tran

📚 Amazon Book Link: https://www.amazon.com/Confidence-Overrated-Action-Underrated-Embracing/dp/B0DLB63G9F

For many immigrants arriving in the United States, especially in Louisville, Kentucky, the journey toward stability and success is filled with barriers — not just financial, but linguistic, cultural, and emotional. Limited English proficiency, unfamiliarity with the American system, and the weight of starting from scratch can easily make confidence feel out of reach.

At Louisville Beauty Academy, we understand this reality deeply because many of us have lived it ourselves. That’s why our school is more than just a state-licensed and accredited beauty institution — it is a home where immigrants are welcomed, supported, and empowered to act their way into confidence and success.

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🌍 The Challenge for Immigrants: Confidence Feels Distant

When immigrants arrive, they often face immediate doubts:

• “My English isn’t good enough.”
• “I don’t understand the culture.”
• “I’m not sure I belong here.”

These are real and understandable feelings. Unfortunately, many people wait to feel confident before taking their first step — and that waiting often delays their progress for years.

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📚 The Message: Confidence Is Overrated — Action Is What Transforms You

Louisville Beauty Academy’s approach is rooted in the philosophy of the book Confidence is Overrated; Action is Underrated by our founder, Di Tran. The book’s central message is simple yet transformative:

👉 Confidence doesn’t come first. Action does.

Confidence is not a prerequisite for success; it’s a byproduct of taking action, embracing uncertainty, and learning through real experiences.

Through action — even small, uncertain steps — individuals build real, lasting confidence that no language barrier or cultural difference can take away.

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✂️ How Louisville Beauty Academy Puts This into Practice

Our school is designed to remove barriers and empower action from day one:

• 🧠 Hands-On Learning First: We focus on practical, hands-on beauty education from the start. Students don’t have to be fluent in English to practice hair, nails, or skin care. Through action, language and confidence grow naturally.
• 🤝 Welcoming, Multicultural Environment: With students and staff from diverse backgrounds, new immigrants quickly feel they belong. Culture is learned through shared experience and daily community.
• 📈 Step-by-Step Confidence Building: From the first haircut to the first client service, each action is a small victory that builds real skills and self-trust.
• 💬 Support in Language and Culture: We provide guidance in understanding state board processes, work regulations, and professional communication — helping students adapt to American standards while preserving their identity.

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🏠 A True Home for New Americans

Louisville Beauty Academy is more than a school; it is a launchpad for new beginnings. For many immigrants in Louisville and across Kentucky, our academy is the first place where they feel:
✅ Welcomed
✅ Understood
✅ Supported to take action

We’ve seen countless students with little to no English transform into confident, licensed beauty professionals. Through their journey, they don’t just gain a license — they gain a voice, a profession, and a community.

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🌟 Conclusion: Start With Action, Confidence Will Follow

For immigrants, the journey can seem overwhelming. But waiting for confidence to arrive is not the solution. Action is.

This is the heart of Louisville Beauty Academy’s mission — to give every immigrant, regardless of language or background, a place to act, grow, and thrive.

📚 Learn more about the philosophy in the book:
👉 Amazon: https://www.amazon.com/Confidence-Overrated-Action-Underrated-Embracing/dp/B0DLB63G9F
📽️ Video Overview: https://youtu.be/6Bf287biErE?si=-Jgg7a_Cupccl75h
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📲 Text: 502-625-5531
📧 Email: study@LouisvilleBeautyAcademy.net

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