AACRAO and NACUBO Issue Joint Statement on Institutional Holds | 4/7/2022

Melanie Gottlieb |
April 7, 2022
  • Advocacy
  • Financial Aid and FAFSA
  • Records and Academic Services
  • Transcripts
  • Access and Equity
  • Bars/Holds
  • college completion
  • Debt
  • education department
  • Federal Regulations
  • Federal relations
  • Negotiated Rulemaking
  • Student Success

AACRAO and the National Association of College and University Business Officers (NACUBO) issued a joint statement this week on the use of administrative process and student success-related holds. 

The practice of institutional holds has recently garnered national attention, with specific focus given to an institution's use of the transcript hold as a leverage against student debt. Several states have enacted or are considering legislation to tackle the issue. U.S. Education Secretary Miguel Cardona specifically called on institutions to end the practice during his remarks to a federal financial aid training conference in December, noting that withholding transcripts from students who owe their colleges money drives inequitable outcomes. And, most recently, negotiators on the department's institutional and programmatic eligibility rulemaking committee proposed and discussed a universal ban on the ability of institutions of higher education to withhold a transcript for any amount of outstanding debt. 

Amid those earlier discussions, AACRAO issued a statement on transcript withholding, asserting that the association does not support the use of transcript holds for the purposes of collecting trivial or minor debt. And that we encourage our member institutions to seek alternative means to clearing student debt. 

However, we understand that the ability to use holds to prompt a student to take an action is one of the few resources in an institution's toolkit that supports student success and addresses the administrative needs of an institution. There are few options for institutions to deploy to collect on debt beyond withholding a transcript or referring it to a private debt collection agency, which could further damage learners' future prospects by increasing the debt owed and damaging their credit report.

Therefore, holds can serve as a vital part of a student success program, but there is room for improvement. AACRAO and NACUBO worked collaboratively to develop specific guidance and best practices on the use of student success and administrative process holds, as well as on the use of holds tied to an unpaid balance. The joint statement builds on AACRAO’s previous work on this issue, providing practical policy recommendations and guidance to ensure that institutional holds do not serve as a barrier to student success.


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