Recent changes to federal regulations, as outlined in the Federal Register under "Financial Responsibility, Administrative Capability, Certification Procedures, Ability to Benefit" (Docket ID: ED-2023-OPE-0089), have significant implications for institutions'
use of transcript holds in cases of unpaid balances. These regulations, which are part of an institution's Program Participation Agreement (PPA). The new regulations, specifically C.F.R. 668.14(b) (33 & 34), prohibit institutions from withholding
official transcripts for unpaid balances under specific conditions.
668.14(b)(33) To provide that an institution may not withhold official transcripts or take any other negative action against a student related to a balance owed by the student that resulted from an error in the institution’s administration of the title IV, HEA programs, or any fraud or misconduct by the institution or its personnel;
668.14(b)(34) To require an institution to provide an official transcript that includes all the credit or clock hours for payment periods in which 1) the student received title IV, HEA funds; and (2) all institutional charges were paid, or included in an agreement to pay, at the time the request is made.
These regulatory changes have led some institutions to consider implementing partial-transcript holds as a way to comply with the new requirements while still addressing unpaid balances. To assist institutions in navigating these changes, AACRAO, in collaboration
with higher education experts, has developed guidance and recommendations for implementing partial-transcript holds in a manner that is compliant with the new regulations and maintains the integrity of official transcripts.