V. Facts/Assumptions Table

“daily attendance” per 455.2035 bears a standard educational definition measuring the number of hours of class attended against the number of hours that were scheduled to be attended--tracking both presence and absence from a class without regard to pass or fail.

“credit hours” per 455.2035 bears a standard education definition, which is a calculation of the number of contact hours per week.

“daily attendance” hours marked present are not considered “satisfactory” for the purposes of successful completion (supporting A16, A17).

“daily attendance” per 455.2035 refers to the same attendance tracked by 117.68.

PALMS has no mechanisms for reporting progress other than reporting hours, graduation, or termination.

PALMS only has one place for entering hours.

PALMS only allows the owner of a school to log in and report hours.

PALMS retains all hours credited to a student if they are terminated (and not marked graduated), and makes them visible to schools that a student transfers to.

The only way to transfer a student in PALMS is by marking a student as terminated.

A student must have satisfactorily completed a 500-hour approved course to be eligible for licensure.

PALMS has no mechanism for entering any hours that are not directly correlated to meeting the requirements of licensure (455.156).

A student should receive all training on the required curriculum as prescribed by 117.59(a).

PALMS was created in response to the legislative addition of Tex. Occ. Code 455.161 and 455.2035 for the purposes of combating human trafficking.

TDLR relies on massage schools to establish and vet student identity. They also rely on schools associating this data with a photograph.

The enactment of Tex. Occ. Code 455.161 and 455.2035 has not assisted in the identification of human traffickers.

The public is not served by issuing licenses to people who have failed their courses or who have completed the first half of the same course twice.

Current testing does not cover any hands-on skills, so a school’s evaluation of student skills is the only protection the public has.

TDLR does not grant educational credit for Business requirements to massage students who have a Bachelors in Business