By Michael Bilfinger, AACRAO Assistant Director of Public Policy
AACRAO’s Senior Director of Research, Dr. Wendy Kilgore, played a very active role in developing AACRAO’s new guidance on Transcript Withholding and Partial Transcript Holds. As a former registrar with over 25 years of experience in higher education, she is very familiar with how these practices can potentially impact students and the function they can also serve for institutions. Here are some of her thoughts on the new guidance:
Why did AACRAO develop this guidance?
AACRAO developed this guidance in response to a new federal regulation that will take effect on July 1, 2024, regarding the withholding of transcripts for learners who have used Title IV/HEA funds. AACRAO members were concerned and needed clarification about how to comply with the new regulations. AACRAO aimed to clarify how, when, and under what circumstances transcripts may be held, and to provide recommendations for implementing partial-transcript hold practices equitably and consistently across all learner populations.
What is the impact of transcript withholding policies on learners?
Transcript-withholding practices can create significant barriers for learners. Having an entire transcript withheld due to an unpaid balance for a single payment period can hinder their ability to transfer to another institution, obtain employment, or earn professional licensure.
How does AACRAO's guidance impact learners?
AACRAO's guidance prioritizes treating all learners equitably, regardless of how their education is funded. The guidance includes recommendations for implementing standardized practices for using partial-transcript holds if the institution determines that the use of such holds is a practice they want to employ. By advocating for consistent and transparent partial-transcript hold practices, AACRAO aims to minimize the negative impact of this practice on learners while helping institutions comply with federal regulations and be able to recognize when a partial-transcript hold has been applied to a learner's record.
What does transcript withholding/partial transcript holds look like ten years from now?
In 10 years, I anticipate that transcript withholding for unpaid balances will be more strictly regulated and less commonly used. With increasing awareness of the barriers these practices create for learners, there will likely be a push for alternative approaches to managing unpaid balances, such as measures preventing an unpaid balance from being incurred, more flexible payment plans, and debt forgiveness programs. Ultimately, I believe the goal will be to prioritize learner success and mobility while ensuring institutions can maintain financial stability.
Going Forward
We recognize that every learner’s and institution’s situations are unique and that transcript holds can serve as a vital tool. For institutions that intend to withhold transcripts for debt collection purposes, AACRAO’s new guidance provides clarity on how they can comply with the upcoming regulations. We are confident that our member institutions are well-equipped to create policies that work for their campuses. We invite you to reach out and share any questions you have on this topic in the AACRAO Exchange, as well as email GR@AACRAO.org.