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Foreign Program With Enough Total Hours but Too Few Hands-On Hours

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Foreign Program With Enough Total Hours but Too Few Hands-On Hours

Marisol is 19 and applies for a New York massage therapy license. She completed a 1,050-hour massage program in Spain taught entirely in Spanish. Her translated transcript lists 1,050 total hours: 700 hours of classroom theory, 200 hours of clinic administration, 110 hours of supervised practice on a person, and 40 hours of observation. She also has a high school equivalency diploma, a current CPR card, and no criminal record. She has not taken any licensing examination. She sends the translated transcript and asks whether she can schedule the next exam. The application instructions require a 1,000-hour program that includes at least 150 hours of practice on a person, and they may require English proficiency when the applicant's education was not in English. Marisol believes her 1,050 total hours should be enough because they exceed 1,000.

1. Does Marisol's education satisfy New York's 1,000-hour and 150-hour practice requirements? Explain how each category of hours should be treated.

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No, not as documented. The 1,000-hour threshold is a floor, not a substitute for the specific practice requirement. Her total of 1,050 hours exceeds 1,000, but only 110 hours are documented as supervised practice on a person. The 40 observation hours are not practice on a person; clinic administration and classroom theory do not fill that gap. New York requires at least 150 hours of practice on a person within the program. She is short 40 hands-on hours. The remedy is not to relabel hours. She needs a school or supervised setting to verify additional practice on a person, or the Department must evaluate whether any foreign supervised clinic hours qualify. She should obtain a detailed course-by-course credential evaluation and school verification before applying for exam eligibility.

2. What should Marisol do about English proficiency and the examination before applying?

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She should not assume the translated transcript resolves language proficiency. If her massage education was in Spanish, the Department may require evidence of English proficiency under its application instructions. She should check the current requirement and submit an accepted test score or other documentation if required. She also has not taken the licensing exam; education alone does not license her. She should first resolve the 40-hour practice deficiency and credential evaluation, then apply for exam eligibility. Paying for an exam seat before eligibility is confirmed risks a wasted fee. A practical sequence is: credential evaluation, supplemental hands-on hours, English proficiency documentation if required, then exam application.