For school owners & compliance directors
Distance Education Audit Binder
When an inspector asks whether a student has broken the 10-business-day rule, the honest answer at most schools is “give me a week” — because the attendance lives in a time clock, the theory hours in an LMS, and nothing joins them. This is what the answer looks like when the evidence is a report rather than a project.
These five students are invented. Each one exercises a different failure so the checks are visible — a screen of green ticks would demonstrate nothing. No real student records are shown here, and none are stored. The rules are real: every check cites the TDLR or NACCAS provision it comes from.
What is being checked
350 / 150
Distance ceilings
Core 700 and specialty 300, separately. Not one 50% figure.
10
Business days
Maximum between full days on campus. NACCAS VI.02 element 3.
184
Hours per month
Per student ceiling. Catches back-filled reporting.
0
Ungraded exceptions
Every GPA-bearing assessment on campus. No allowance.
| Student | Course | Distance / total | Core distance | Status |
|---|---|---|---|---|
| Alicia MorenoS-1042 | Cosmetology Operator | 360 / 720(50%) | 360 / 350 | Exposed |
| Devon WrightS-1108 | Class A Barber | 270 / 630(43%) | 270 / 350 | Exposed |
| Priya RamanS-1163 | Esthetician | 168 / 372(45%) | 168 / 350 | Exposed |
| Marcus BellS-1201 | Class A Barber | 240 / 650(37%) | 240 / 350 | Exposed |
| Sofia DelgadoS-1247 | Cosmetology Operator | 398 / 958(42%) | 308 / 350 | Clear |
Look at the first row. 50% distance hours overall — and over the core ceiling. A tracker watching a single percentage reports that student as compliant.
Alicia Moreno
S-1042 · Cosmetology Operator · enrolled 2025-09-02 · as of 2026-08-05
In-person hours
360
clinic floor
Distance hours
360
50% of hours earned
Core distance
360 / 350
16 TAC §83.202(e)
Specialty distance
0 / 150
second ceiling
Distance hours inside the core 700 — 360 of 350
TDLRSHEARS manual; 16 TAC §83.202(e)Over the core ceiling by 10 hours. Overall distance is 50%, which is why a percentage check would pass this student.
Maps to: “Failed to comply with distance education parameters”Distance hours inside the 300 specialty — 0 of 150
TDLRSHEARS manual; 16 TAC §83.202(e)150 hours of headroom in the specialty segment.
On campus at least every 10 business days
NACCASPolicy VI.02, element 3No gap exceeded the limit, counting weekends and federal holidays out.
No month over 184 hours
TDLR16 TAC §83.72(w)Every month within the ceiling — no sign of back-filled reporting.
All GPA-bearing assessments on campus
NACCASPolicy VI.02, element 22 graded assessments, all on campus.
Reciprocity disclaimer on file
NACCASPolicy VI.02, element 5Signed 2025-09-02, before the first distance hour.
What changes with a real school's data
- The business-day calendar comes from the enrolment contract, not from federal holidays. NACCAS measures presence against "a scheduled class day as outlined in the enrollment contract", so term dates and closures are the school's own.
- The distance ceiling comes from the certificate of approval, which can be lower than the statutory 350/150. TDLR's manual: "Approved distance education hours can be found on your certificate of approval."
- Hours reconcile against what was filed in SHEARS each month, so the school's records and the state's agree before anyone asks.
- Transcripts carry the distance component separately, which only works if the split was recorded from the first hour rather than reconstructed later.
This is running on sample data. Yours will look different.
Send us an hours export and we'll run your actual roster through the same checks against the same sources, and hand back a dated binder you can put in the file.
Run this on our school