AACRAO Executive Director Statement on Transcript Withholding and Partial Transcript Holds

June 6, 2024

Over the past year, AACRAO has been actively engaged in discussions around the use of institutional holds, particularly transcript holds used as leverage against learner debt. We have seen increased scrutiny of this practice at both the state and federal levels, with some states calling for an outright ban on withholding transcripts for any amount of outstanding debt.

In response to these developments and the recently announced federal regulations scheduled to go into effect on July 1, 2024, AACRAO has developed guidance to help institutions navigate the changing landscape around transcript holds. Our guidance document, "AACRAO Guidance in Response to Federal Regulation Changes on Financial Responsibility and Administrative Capability," builds upon our previous work on this issue and the joint statement we issued with NACUBO in April 2022.

AACRAO’s new guidance provides clarity on how institutions who intend to withhold transcripts for debt collection purposes can comply with the upcoming regulations and covers key topics such as:

  • Specific details of the new federal regulations and their implications for institutions

  • Limitations and allowable uses of entire-transcript holds under the new rules

  • The distinction between partial transcripts and partial-transcript holds

  • AACRAO's position on the use of partial-transcript holds

  • Recommendations for implementing partial-transcript holds in a standardized, equitable manner.

  • Guidance on withholding earned credentials and transcript annotation.

Note: AACRAO has also created a new resource page that provides additional information for individuals on this issue.

There are divergent opinions regarding the use of partial-transcript holds in the membership. Data extrapolated from our April 2024 member survey on the topic indicate that nearly 24% of institutions intend to explore or implement the practice, which is allowable under the regulation. With nearly a quarter of institutions considering the practice for a July 1 implementation, we realized we needed to act quickly to develop clear guidance that strikes an appropriate balance between institutional and learner interests. We remain concerned about the potentially burdensome and counterproductive impacts transcript holds can have on learners and believe there is room for improvement in how they are used at many institutions. The emergent use of partial-transcript holds and earned-credential holds raises numerous questions about their impact on learner academic progression. Incomplete transcripts have the potential to create new issues in admissions, transfer, financial aid, and advising that have yet to be fully explored. If the use becomes a widespread practice in higher education, the downstream impact on other institutional and learner success processes is not yet fully known or understood and must be monitored carefully. 

Our guidance emphasizes the importance of treating all learners equally, regardless of their funding source, and provides recommendations that promote transparency, maintain the integrity of education records, and minimize barriers to learner success. We recognize that every institution’s situation is unique and that transcript holds can serve as a vital tool supporting learner success and progression. We are confident that our member institutions are well-equipped to create policies that work for their campuses.

As you work to align your institution's practices with the new regulations, we encourage you to carefully review the guidance and collaborate with relevant departments, including Financial Aid, Veterans Services, International Student Services, and the Bursar or Business Office. Consistency in the implementation of policies across the institution is crucial.

This is an ongoing dialogue. We anticipate all institutions will be required to reevaluate some internal practices. As an association AACRAO remains committed to supporting our members as they navigate this complex environment, finding solutions that promote both institutional and learner success.

Thank you for your ongoing dedication to your institutions and to advancing learner access, equity, and success in higher education.

Melanie Gottlieb,
AACRAO Executive Director