For school owners & compliance directors
Texas Distance Education Compliance
If you already run a compliant school, you already track hours, attendance and transcripts. Distance education does not add a setting to that — it adds eight obligations across two authorities, each evidenced per student, and the systems built for in-person schools do not carry them.
The 50% cap is really two caps, and that is where schools fail
Every published account of the Texas limit — including the rule itself at 16 TAC §83.202(e)(1) — states it as 50% of total course hours. TDLR's April 2026 SHEARS manual is stricter:
“A school may not not report more than 350 hours of Distance Education or 70 hours of Field Trip within the first 700 hours of education, which are assigned to the CORE permit.”
“The specialty permit may not have more than 150 hours of Distance Education or 30 hours of Field Trip reported.”
350 + 150 = 500, so the totals agree. But they are two ceilings against two separate pools. A school running 500 distance hours entirely inside the core 700 sits at exactly 50% overall — and is in violation. Nothing that tracks a single percentage will catch it.
Your ceiling, by course
From the manual's own table. The two 1,000-hour courses carry the core/specialty split; the specialty courses have a single pool.
| Course | Total hrs | Max distance | Split |
|---|---|---|---|
| Class A Barber | 1,000 | 500 | 350 in core 700 · 150 in specialty 300 |
| Cosmetology Operator | 1,000 | 500 | 350 in core 700 · 150 in specialty 300 |
| Esthetician | 750 | 375 | single pool |
| Esthetician/Manicurist | 800 | 400 | single pool |
| Hair Weaving/Esthetician | 800 | 400 | single pool |
| Manicurist | 600 | 300 | single pool |
| Eyelash Extension | 320 | 160 | single pool |
| Hair Weaving | 300 | 150 | single pool |
And your own limit may be lower. The manual: “Approved distance education hours can be found on your certificate of approval.” Compliance is measured against the certificate, not the statute.
What SHEARS requires, quoted
SHEARS is the Student Hour and Enrollment Automated Reporting System — the system every licensed Texas school files hours through. These are from the April 2026 operations manual.
Distance hours are a separate field — not classroom hours
“DO NOT ENTER DISTANCE EDUCATION HOURS UNDER CLASSROOM HOURS.”
Capitalised in the manual, which tells you schools do it. The moment distance hours are filed as classroom hours the split is unrecoverable, and the transcript NACCAS requires — distance component identified separately — cannot be produced from the filing.
350 distance hours maximum inside the first 700 (core)
“A school may not not report more than 350 hours of Distance Education or 70 hours of Field Trip within the first 700 hours of education, which are assigned to the CORE permit.”
This is the rule almost nobody tracks. It is not 50% of the programme — it is a ceiling against the core pool specifically, and a school can be at 50% overall while breaching it.
150 distance hours maximum in the 300 specialty hours
“The specialty permit may not have more than 150 hours of Distance Education or 30 hours of Field Trip reported.”
The second ceiling. Together with the core limit it totals 500 — the same number §83.202(e)(1) implies — but as two buckets that must each hold.
Monthly filing, opening the first week for the prior month
“For clock-hour schools, you must report hours each month. The first week of each month, the system will update to allow school access to SHEARS for hours to be reported for the previous month.”
A monthly cadence means a monthly reconciliation. Whatever the school's own records say has to match what was filed, every month, per student.
184 hours per student per month, hard ceiling
“Students are only allowed up to 184 hours each month.”
A cap that catches back-filled or batched hours. A school reconstructing a term's hours at the end will hit it and have nowhere to put the overflow.
Distance education must be approved per course, before any hours
“You will not be able to enter distance education hours until you have been approved to offer distance education. To be approved to offer distance education, submit a new curriculum course application for each course, noting the distance education requested.”
Per course, not per school. And the approved number lives on the certificate of approval — so the school's own ceiling may be lower than the statutory one.
Your approved ceiling is on the certificate, not in the rule
“Approved distance education hours can be found on your certificate of approval.”
A school approved for 200 distance hours is capped at 200, whatever §83.202 permits. Compliance is against the certificate.
The eight obligations, and why in-person systems miss them
A school does not experience TDLR and NACCAS as two problems, so these are ordered by how badly each fails when missing rather than by which body requires it.
| Requirement | Who | Evidence needed | Why it's missing today |
|---|---|---|---|
| Distance hours separated from classroom hours at the point of entry | both | Per student, per month, in a field of their own | In-person systems have one hours field because in-person schools have one kind of hour. Reconstructing the split later cannot be evidenced. |
| Core and specialty distance hours capped separately — 350 and 150 | TDLR | Running totals against two ceilings, not one | Tracking a single 50% figure passes a school that has put every distance hour in the core pool. Nothing on the market watches two buckets. |
| Distance hours tracked by the same verification method as attendance | TDLR | One method, demonstrable, across both kinds of hour | A time clock for the floor and a video-completion log for theory is two methods. Both can be diligently kept and still fail. |
| Student physically on campus at least once every 10 business days | NACCAS | A presence timeline per student with gap analysis | Nothing computes this. It requires joining attendance to the calendar and to the enrolment contract, then finding the longest gap. |
| All GPA-bearing assessment taken physically on campus | NACCAS | Assessment log with location, per student | An LMS that grades online quizzes creates the violation by working as designed. |
| Distance component identified on every transcript | NACCAS | Transcript with the split shown, official or unofficial | Only possible if the split was recorded from the first hour. This is downstream of the first obligation and fails with it. |
| Signed, dated reciprocity disclaimer in every student file | NACCAS | One signed artefact per student, retrievable | A filing cabinet satisfies the letter and fails the audit, because producing 100 of them on request is the actual test. |
| Monthly SHEARS filing that reconciles to the school's own records | TDLR | Filed vs recorded, per student, per month | Two systems that never compare. The discrepancy is only discovered when someone asks. |
Four questions that tell you where you stand
- Can you show, right now, that no student has gone more than 10 business days without a full day on campus? That is NACCAS VI.02 element 3, and it is the one nothing computes.
- Are your distance hours inside the core 700 under 350 — separately from the specialty 300? Not the overall percentage. The two buckets.
- Is the method you verify distance hours with the same method you verify floor attendance with? A time clock plus a video-completion log is two methods.
- Can you produce a signed reciprocity disclaimer for every enrolled student? Having them filed is not the test; producing 100 on request is.
Common Questions
How many distance education hours can a Texas school report?
Not simply half the course. TDLR's SHEARS manual sets two separate ceilings for the 1,000-hour Class A Barber and Cosmetology Operator courses: no more than 350 distance hours inside the first 700 hours, which are assigned to the core permit, and no more than 150 inside the 300 specialty hours. They total 500 — the same as the 50% in 16 TAC §83.202(e)(1) — but they must each hold independently. A school running 500 distance hours entirely within the core 700 is at 50% overall and in violation.
Can distance education hours be entered as classroom hours in SHEARS?
No, and the manual capitalises the instruction: "DO NOT ENTER DISTANCE EDUCATION HOURS UNDER CLASSROOM HOURS." Once filed as classroom hours the distinction is unrecoverable from the filing, which also makes the transcript NACCAS requires — distance component identified separately — impossible to produce accurately.
How often must Texas schools report student hours?
Monthly, for clock-hour schools. The manual states the system opens in the first week of each month for the previous month's hours. There is also a hard ceiling of 184 hours per student per month, which is what catches a school trying to back-fill a term's hours in one filing.
Does my school's distance education limit come from the rule or from TDLR?
From your certificate of approval. The manual says approved distance education hours can be found there, and that you cannot enter distance hours at all until approved. Approval is granted per course via a new curriculum course application. A school approved for 200 distance hours is capped at 200 regardless of what the statute permits — compliance is measured against the certificate, not the rule.
What does NACCAS require beyond the Texas hour rules?
Policy VI.02 adds five obligations that stack on top: instructor interaction validated by measurable participation, all GPA-bearing assessments taken physically on campus, the student on campus at least once every 10 business days for a full scheduled class day, distance hours identified on every transcript, and a signed dated disclaimer in each student file warning that distance hours may not transfer to another state. You meet the stricter of the two authorities on every dimension.
Why doesn't our existing school management software handle this?
Because it was built for schools where every hour is the same kind of hour. In-person systems have one hours field, one attendance method and one transcript format. Distance education splits the hour into two kinds with separate ceilings, adds a residency clock nobody computes, and requires an assessment location per graded item. Those aren't settings — they're a different data model.