Reconciliation of TDLR Statements and Actions
An IntroductionI. TDLR StatementsII. Conclusions - OperationalIII. Conclusions - StrategicIV. TDLR ActionsV. Facts and Assumptions Table

An Introduction


TDLR implementation of Tex. Occ. Code 455.161 and 455.2035 has caused a great deal of confusion and vulnerability within the massage school community. The buggy rollout of the PALMS system and TDLR’s conflicting statements have only made this situation worse. The numerous attempts from schools to work with TDLR to clear up this confusion have not led to any significant improvement, and in many cases, have made the situation worse. New statements made by TDLR conflict with their previously released statements.

This situation is dangerous to the public, detrimental to a student’s education, and exposes massage schools to unnecessary litigation and regulatory action.

This document is designed to provide a set of conclusions that massage schools can use. It is done by reconciling TDLR’s statements and actions against the laws and truths of reality. Every attempt was done to be mindful that the highest priorities are placed on public safety and the educational quality delivered to students. To keep it simple, the influence of federal regulations such as FERPA were excluded, as not everyone is subject to them. However, this reconciliation should cover those cases effectively as well.

I must stress that much of this would have been avoided if TDLR (and lawmakers) had closer cooperation with massage schools, which, due to these new bills, are easily the single largest users of Texas’ massage regulatory services.