In recent years, institutions have started to move away from the practice of stopping students with unpaid balances from accessing their official transcripts. These transcript holds have been criticized as ineffective tools for debt collection and for their role in the creation of stranded credits, credits students have earned but cannot access. In July 2024, regulations from the Department of Education went into effect that limited this practice. By that time, at least 13 states had already adopted similar legislation limiting or banning transcript holds for past due balances. How did institutions interpret and respond to these rules?

To answer this question, Ithaka S+R collaborated with the American Association of Collegiate Registrars and Admissions Officers (AACRAO) in a three-part research project to understand the actual and anticipated impacts of the state and federal regulations on institutions. For the third part of this project, registrars were invited to participate in focus groups to discuss their experiences preparing for the new federal guidelines on transcript withholding and, where applicable, managing change following a state limitation or prohibition on the practice. We are excited to share the findings from these focus groups in a new report. We thank Lumina Foundation for their financial support of this research.

Overall, institutions did not respond to the federal regulations uniformly. Instead, a patchwork system has developed, with some institutions releasing all transcript holds and others maintaining the practice for some students or utilizing partial-transcript holds.

These findings shed light on the ways that institutions have adapted or implemented new practices in addition to changing their policies on transcript holds. Some adaptations may have negative effects on students’ ability to remain enrolled or re-enroll after stopping out. For example, some institutions planned to lower the threshold for registration holds, which are not covered in the federal regulation and impact a student’s ability to re-enroll at their institution. Other changes have brought benefits to students and institutions, including more proactive efforts to have students enroll in payment plans and student-focused financial literacy and wellness programs.

Read the full report to learn more about how institutions implemented state and federal transcript holding regulations, and what the outcomes of these changes were for students and staff.

For more research on this topic, visit AACRAO’s site to read part one, which explored the anticipated impacts of the federal regulation limiting transcript holds on higher education institutions in states that did not have existing laws related to the practice, and part two, which examined the actual impacts of state-level limitations on institutions.