An IntroductionI. TDLR StatementsII. Conclusions - OperationalIII. Conclusions - StrategicIV. TDLR ActionsV. Facts and Assumptions Table
IV. Actions and a Determination of their Legality
ACT1: TDLR issued massage therapist licenses using PALMS data as a source of record for transcript information prior to 4/1/2021.
2020 - 4/1/2021
Determination: LAWFUL
Rationale: Item 1 being TRUE means TDLR has received a transcript so TDLR was issuing licenses only after meeting the requirements of 117.20.
ACT2: TDLR will not issue a massage therapy license to students enrolled in PALMS until marked as graduated despite receiving a transcript in another manner.
2020 - Present
Determination: LAWFUL
Rationale: 117.20 does not explicitly require any data be entered into PALMS to issue a transcript, and there are no specific stipulations allowing TDLR to deny licensure to otherwise eligible applicants. However, 127.20(b) requires the use of department approved forms, it can be reasoned that the only approved form for transcripts for students is PALMS. Which makes this a lawful action.