The following is the opinion and analysis of the writer:
Cathy Koluch
The federal government’s proposed “Do No Harm” rule may sound like common-sense consumer protection — but for Arizona’s beauty and wellness professionals, it threatens to dismantle an entire workforce pipeline.
Hairstylists, estheticians, nail technicians, barbers and massage therapists are the backbone of a thriving, service-driven economy. Yet under this proposed rule, the very schools that train them could lose access to federal student aid — not because they fail students, but because the federal government is using the wrong yardstick to measure success.
Well-intentioned rule with flawed consequences
The “Do No Harm” rule would require career training programs to prove that their graduates earn more than the average high school graduate within a few years of completing their education. Programs that fail the test risk losing access to federal loans and, in some cases, Pell Grants.
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On paper, that may seem reasonable. In reality, it fundamentally misunderstands how the beauty and wellness industry works.
These are careers built on entrepreneurship, flexible schedules, and gradual income growth. Many professionals start part-time, build a loyal client base, and eventually open their own businesses. Income often includes tips or self-employment revenue — earnings that federal data systems frequently fail to capture accurately.
A disproportionate hit to beauty and wellness careers
The data are alarming. According to industry analysis, more than 92% of cosmetology programs and 89% of massage therapy programs would fail the proposed earnings test.
If that happens, the consequences will be immediate:
Schools will lose access to federal funding.
Programs will close.
Students will lose affordable career pathways.
Employers will struggle to find licensed professionals.
The ripple effects would extend far beyond the classroom — impacting salons, spas, small businesses, and local economies across Arizona.
An industry built on opportunity is at risk
Beauty and wellness careers are one of the most accessible pathways to entrepreneurship, especially for women. These professions allow individuals to build independent businesses, control their schedules, and create upward mobility without a traditional four-year degree.
But the “Do No Harm” rule ignores those realities. It compares part-time, tip-based, or self-employed workers to full-time salaried employees in entirely different industries — without accounting for regional differences, work flexibility, or long-term earnings growth.
As a result, programs that successfully launch careers could be labeled as failures.
Arizona cannot afford this policy
Arizona already depends heavily on licensed beauty and wellness professionals to meet demand in both urban and rural communities. Eliminating the training pipeline would not reduce demand — it would simply create shortages, drive up costs, and limit access to essential services. Seventy-five percent of Arizona beauty industry professionals come from accredited schools.
This is not just an education issue. It’s a workforce issue.
A voice from the industry
Cathy Koluch, founder and former owner of a multi-campus cosmetology and esthetics school in Arizona, warns that the rule could have devastating real-world consequences:
“This rule doesn’t measure success—it misrepresents it. Our graduates build careers over time, many becoming small business owners who contribute to their communities. If this policy moves forward, Arizona won’t just lose schools—we will lose an entire generation of skilled professionals.”
A better way forward
Accountability in education is important. Students deserve transparency and value. But accountability must be rooted in reality.
The “Do No Harm” rule, as written, applies a rigid, one-size-fits-all metric to professions that are anything but uniform. It risks eliminating viable career pathways, disproportionately impacting women and entrepreneurs, and destabilizing a critical workforce.
If policymakers truly want to “do no harm,” they must fix this rule before it does exactly that.
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Cathy Koluch is founder of The Studio Academy of Beauty, former President of the American Association of Cosmetology Schools, former Commissioner Post Secondary Education Commission, current Commisioner, City of Chandler Housing & Human Services Commission.
