Ask the FERPA Professor

December 16, 2014
  • AACRAO Connect
  • FERPA Professor

Greetings, Professor!

I just read AACRAO’s Nov 18 posting entitled FERPA: Noting student misconduct on transcripts.

The practice at my institution is to note “Administrative withdrawal” on a student’s transcript for three possible reasons: (1) academic (GPA too low), (2) financial (outstanding bill), (3) student conduct (disciplinary/honor code, etc.). This is explained in our Academic Catalog.

My questions:

  1. Do you think it is OK to use one notation for three reasons that are so different from each other? Or do you think it is bad practice?
  2. If you think it is bad practice, do you think it is especially bad practice since, if the GPA on the transcript is OK, the receiving institution would automatically know the reason is either “financial” or “student conduct”?
  3. Is my understanding correct that, if an institution receiving a transcript from my institution asked which type of “administrative withdrawal” it is, we would need written consent from the student before disclosing which reason unless the circumstance falls under FERPA §99.31?
  4. If the receiving institution requests additional details for the transcript notation, would we be able to disclose this (either via phone or sending hard copies of supporting documents) without needing to obtain another consent from the student?


Aster Ricks


Dear *,

Your institution can put any of the items/information noted above on the transcript.  The reason you can do this is because either the student has to provide written consent prior to any release or one of the §99.31exceptions to signed consent have to be met.  One of these is the §99.31(a)(2) "seeks or intends to enroll" exceptions which would not only permits your institution to forward the transcript but also any other information to the other institution.  This would include details on any notation which you might have included on the transcript. If the request from the other institution is for a student who is applying to attend that institution, then you do not need a consent, either initially or in order to disclose any additional education records on the student.


I hope you find this helpful.

The FERPA Professor


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