Managing Student Records for Closed and Merged Institutions: 2025 Update

April 1, 2025
  • FERPA
  • Registration & Records
  • Reporting and Research
  • work group
merging train tracks

By Autumn Walden, Editor, AACRAO Connect, Content Strategy Manager, AACRAO

In 2024, U.S. colleges and universities experienced closures at an alarming rate, averaging one closure per week, according to The Hechinger Report. As financial and enrollment pressures intensify, the ripple effects of institutional closures are becoming more widespread and disruptive, impacting thousands of learners, faculty, and staff. For higher education practitioners, these closures are no longer outliers—they signal a system in transition. 

A Timely Update to Essential Guidance

AACRAO has released Closed or Merged Institutions: Guidance and Best Practices Pertaining to Student Education Records, an updated 2025 report offering clear, practical guidance to ensure that learner education records, rights, and academic continuity remain protected amid institutional shifts. Initially published in 2020, the January 2025 revision reflects the latest best practices, FERPA considerations, and the increasing frequency of institutional transformation. Building on established frameworks from AACRAO's Academic Record and Transcript Guide, Student Records Management: Retention, Disposal, and Archive of Student Records, and the CAS Standards for Registrar Services, this revision offers practical solutions for minimizing disruption to students' academic journeys.

“Institutional transitions, whether closure or merger, are deeply consequential to learners,” said Julia Pomerenk, AACRAO Vice President for Records and Academic Services and 2025 review work group chair. “Our updated guidance ensures institutions can carry out these changes with integrity, transparency, and learner protection at the forefront.”

Whether an institution is closing its doors or merging with another entity, the stakes for learners are high. Disrupted academic plans, concerns about transcript access, and uncertainty around transfer credits can leave learners in limbo. AACRAO’s updated report, also presented at the 110th AACRAO Annual Meeting, equips higher education professionals—particularly registrars, enrollment managers, and academic and technology leaders—with actionable tools to protect learner interests and ensure compliance with federal regulations. The updated guidance aligns with AACRAO’s broader commitment to learning mobility and systemic transformation, and reintroduces several significant practice enhancements designed to address contemporary challenges:

  • Checklists for both closing and receiving institutions provide step-by-step protocols for managing the complex process of records transfer, retention, and student communication. 

  • FERPA-compliant frameworks for data custodianship and access, ensuring student privacy remains protected throughout institutional transitions. This includes detailed protocols for determining appropriate access levels and maintaining compliance with federal regulations.

  • Technological considerations for records migration and offers guidance on SIS integration, digital preservation, and the long-term accessibility of learner data. 

  • Specialized recommendations for handling unique record types, including veterans' benefits documentation, international student records, and financial aid data. These targeted approaches ensure that vulnerable learner populations receive appropriate support throughout institutional transitions.

Supporting Learners Through Institutional Change

The revised guidance emphasizes proactive communication and support. By providing tips for notification letters, FAQ resources, and advising protocols, the guidelines help institutions maintain transparency and build trust during periods of significant change. The guidance also includes teach-out planning recommendations that ensure learners have viable pathways to degree completion, minimizing disruption to their educational goals.

AACRAO's updated guidance is an essential resource for institutional leaders who must navigate closures and mergers while fulfilling their fundamental obligation to preserve learner records and support learner success.

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