The AACRAO Public Policy Agenda outlines major issues impacting AACRAO members and presents a framework for AACRAO's involvement in the public policy arena in the following areas:

Federal Funding of Higher Education

In an increasingly competitive global marketplace, a strong higher education infrastructure and a well-educated population are important to ensure economic innovation and competitiveness.

Student Financial Aid

  • AACRAO strongly supports federal funding for financial aid to ensure that all qualified students have access to higher education.
  • AACRAO strongly urges maintenance of the current maximum Pell Grant Award, as well as the restoration of year-round Pell Grants. The association supports the improvement of gatekeeping for the Pell Grant program so that every dollar of federal support reaches students most in need.

Student Loans

  • AACRAO endorses the Education Department's role as the sole originator of federal student loans. The association strongly opposes any expansion of the role of private actors in providing federal student loans.
    • Private lenders expose students to predatory practices, while doing little to reduce college costs or student loan amounts.
  • The association supports flexible and reasonable repayment options, tailored to individual circumstances that will help students manage their educational debt more responsibly.
  • AACRAO also believes that Congress should restore a pre-2005 provision in the bankruptcy code to allow for discharge of privately-issued student loans in bankruptcy.


  • AACRAO endorses federal support of critical research initiatives at colleges and universities and strongly believes that this support has contributed significantly to the nation's global leadership in research and innovation.

Privacy and Data

In 1974, the passage of the Family Educational Rights and Privacy Act (FERPA) ushered in a new era for educational privacy rights through its application of fair information practices to educational records. The culture of privacy is so deep-rooted within the education community that there have been few violations of FERPA over the past four decades. AACRAO is deeply committed to the promotion of privacy policies that maintain the confidentiality of the highly sensitive data that students willingly entrust to educational institutions.

Correcting Certain Provisions Created by 2012 Regulations
In 2012, the Obama Administration, through the Department of Education, implemented regulatory amendments that dramatically expanded FERPA. The amendments greatly broadened the definition of who is given access to personally identifiable information (PII) from student records on a nonconsensual basis. AACRAO strongly believes that some of the 2012 regulatory actions require statutory action to ensure students’ private information will not be inappropriately disclosed to third parties. 

The Term "Authorized Representative"

  • The 2012 regulations inappropriately expanded the definition of "Authorized Representative" to anyone chosen by the designated official.
  • AACRAO believes that the definition "Authorized Representative" should be restored to its previous definition of "individuals and entities under direct control of officials" as designated in the original statute.

The Term "Implied Authority"

  • The 2012 regulations also overreached on the definition of "Implied Authority" to audit programs and have created much confusion, and lacks legal precedent.
  • AACRAO believes that Congress should close this loophole for non-consensual disclosure of education records.

The Term "Education Program"

  • The 2012 regulations vastly widened this definition to include programs not administered by educational authorities.
  • AACRAO believes that the definition of "Education Programs" should revert back to the original definition of "programs administered by an educational agency or institution."

The Term "Non-Consensual Disclosure for Studies"

  • The 2012 regulations expanded the meaning of non-consensual disclosure of personal information from education records to organization conducting "for, or on behalf of" educational agencies or institutions.
  • AACRAO believes that Congress should restore the limitation on the purposes that the research exception may be invoked.

Data Systems
AACRAO is concerned about individual privacy protections under State Longitudinal Data Systems (SLDS). As a result of regulatory modifications to FERPA in 2009 and 2012, many SLDS fail to incorporate basic fair information practices in their policies and operating procedures.

  • Recognizing the need for collecting better data on students and colleges, AACRAO supports the exploration of alternative methods for collecting and reporting student information.
  • Any new approach must include meaningful privacy protection for students—such as notice and choice, right of review, correction and amendment, and the right to control re-disclosure of unit-level data records.
  • AACRAO believes that reasonable regulatory or legislative modifications can be made to accommodate legitimate policy goals without surrendering the educational privacy rights of families and students.

FERPA and Electronic Records
FERPA provides students with the right to inspect and review their educational records, exercise significant control over the disclosure of information from those records, and correct or amend erroneous information in the records. It serves as the cornerstone to ensuring student privacy.

Electronic Records

  • While AACRAO believes that the current law is media-neutral and focuses solely on the information contained in educational records, recent court decisions have created confusion on this issue.
  • That is why AACRAO strongly supports the inclusion of language that will identify "Electronic Records" in the definition of "Educational Records."

Third Party Record Collection

  • The creation of third party services that directly capture and maintain information that otherwise was maintained by institutions means that the inclusion of "Third Party Record Collection Agencies," through cloud storage for example, needs to be included in the list of entities that capture and maintain student data. 

Reverse Transfer

  • Reverse transfer is the transfer of credits from a four-year institution to any two-year institution from which a student transferred for the purpose of facilitating the awarding of a degree or certificate.
  • Currently, there are clear processes and guidelines on how two-year institutions may share student information with four-year institutions. However, there are no processes or guidelines for sharing student information from four-year to two-year year institutions.
  • AACRAO supports the creation of a new exemption that will allow the sharing of student information between institutions that will facilitate increased college completion rates. 

Transcript Disciplinary Notations

  • There has been considerable discussion on whether serious disciplinary notations (sexual assault, robbery, burglary, arson, etc.) should be placed on academic transcripts.
  • AACRAO has been studying this issue for several years and in 2015 created the "Transcript Disciplinary Notations Work Group," which is comprised of Registrar and Admission Officers from ten higher education institutions.
  • AACRAO will release a "White Paper" with recommendations from this working group in May 2017.

Accountability and Program Integrity

AACRAO feels strongly about the need to maintain the integrity and accountability of the Higher Education Act's gatekeeping system of federal recognition, accreditation and state licensure policies.

Federal Recognition

  • AACRAO recognizes the responsibility of higher education to strengthen its own oversight and accountability and supports reasonable changes to the accreditation process and state licensure.


  • Academic freedom, institutional autonomy, and federal non-intervention in the academic affairs of colleges and universities are paramount to their ability to fulfill their missions of teaching and learning, research, and service.
  • AACRAO is committed to an institutions' ability to regulate their academic affairs without governmental interference.
  • AACRAO believes that the accreditation process, based on institutional peer review, remains the best mechanism for quality assurance.

State Licensure

  • AACRAO supports substantive state licensure programs with oversight and consumer protection activities appropriate to the level of risk.
  • Such alternative state regulatory frameworks, if designed carefully, can lead to the rooting out of fraudulent or predatory practices while, at the same time, providing compliance relief to legitimate institutions.

State Authorization

  • Although state authorization is designed to be a key protector of the integrity of Title IV Federal Student Aid programs, states vary greatly in their practices in this regard. The rapid growth of distance education has further contributed to confusion regarding state authorization.
  • Some institutions, seeking to evade the more robust licensure requirements of some states, have set up operations in states with the weakest licensure requirements and have been conducting business nationwide from these locations.
  • AACRAO supports efforts to extend minimum standards of state authorization for participation in Title IV programs to distance education programs and correspondence courses, but is wary of any federal requirement that may overly burden well-intentioned institutions with relatively few students enrolled outside of the state.
  • The association endorses recognition of state authorization through participation in reciprocity agreements under which institutions receiving significant funding from any state would be allowed to provide distance education in all states without multistate approvals, provided that they do not exceed certain ratios in revenues or enrollments outside their own state.

Credit Transfer

  • In an era where increasing numbers of students transfer at least once in their college careers, AACRAO supports college and university faculty-led initiatives to examine and improve the transfer process.
  • At the same time, academic judgment about equivalency of coursework from one institution to another must rightly be kept within academic institutions and governmental non-interference in such decisions should be preserved.

Diploma Mills and Credential Fraud

  • The number of diploma mills – from fake "high schools" to "doctoral" institutions – has risen dramatically in the past decade, resulting in a proliferation of claims of educational attainment based upon fraudulent and questionable credentials.
  • AACRAO supports international efforts to combat diploma mills and credential fraud, actively partnering with federal agencies, international counterparts, foreign ministries of education, and law enforcement to identify and expose these institutions.

Access and Equal Opportunity

AACRAO firmly supports the principle that the doors of higher education must be open to all qualified students regardless of their financial resources and that access and equal opportunity for all are the cornerstones to a thriving democracy.

  • AACRAO is committed to growing the number of qualified students who attend college, increasing completion and graduation rates for all students, and supporting at-risk students so that they may have the tools and skills to succeed.
  • AACRAO believes that improving access to higher education is one of the most important investments our nation can make. The nation's continued economic strength and security, as well as the quality of life of its citizens, depends upon increasing both access to and completion of college.

Veterans' Issues

AACRAO recognizes and honors the sacrifices these men and women have made and its members are proud to assist and help them meet their educational goals.

  • AACRAO strongly supports improved efforts to safeguard veterans, especially from unscrupulous providers who deliver sub-par programs and waste hard-earned benefits.
  • AACRAO believes that agency oversight and enforcement should place primary emphasis on areas where military students and tax dollars are now disproportionately concentrated.

Immigration Policy

AACRAO firmly believes that the nation is best served by providing access to higher education to ambitious young men and women who can make vital contributions the nation's economic strength and global competitiveness.

Deferred Action for Childhood Arrivals (DACA)

  • AACRAO strongly supports the DACA program, which allows qualified individuals to receive a renewable two-year work permit and exemption from deportation.
  • The association strongly urges the maintenance of DACA and supports the proposed expansion to include individuals who entered the country before 2010.

Comprehensive Immigration Reform (CIR)

  • AACRAO is concerned that there are thousands of individuals currently enrolled in colleges and universities that are still living in the shadows due to their legal status with little hope of finding success in this country upon completion of their college degrees.
  • For this reason, AACRAO strongly believes that now, more than ever, we need to pass Comprehensive Immigration Reform (CIR) that will allow these, as well as DACA individuals, a pathway to citizenship.

Transgender Student Rights

AACRAO has been at the forefront of issues supporting gender identity recognition, and in many cases leading the charge to push for more inclusive institutional policies.

  • AACRAO members have been working diligently to update their practices to treat students consistent with their gender identity, using preferred names and pronouns to ensure transgender students’ privacy in a supportive and nondiscriminatory school environment.
  • In order to develop guidance for institutions on serving transgender students and students who wish to update their gender marker, AACRAO recently created the "Student Identity Working Group," which is comprised of Registrar and Admission Officers from fourteen higher education institutions.
  • AACRAO expects to release a "White Paper" with recommendations from this working group in early 2018.

International Policy

AACRAO is the leading source for international education research for international credential evaluation for the purposes of higher education and immigration. The association engages in initiatives that contribute to the development of policy and practice that supports international student access and mobility. 

  • The AACRAO EDGE database is used by more than 600 higher education institutions to determine admissions, placement, and transfer credit for foreign-educated persons, and also is the primary source of information for the US Citizenship and Immigration Services (USCIS) to determine eligibility for employment visas.
  • Given the lack of a Ministry of Education, AACRAO is leading a number of initiatives that provide professional standards for the field of international credential evaluation in the US.