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Transfer Access for All? Depends on Where You Start

Written by Rose Rojas, Director of Workforce Strategies

Maricopa Community Colleges


Institutional recognition of learning outside of regionally accredited bodies is critical to the development of an equitable higher education system. As employees of higher education institutions within this system, we should work to fulfill these long-held and recently restated responsibilities in transfer decision-making.



Even before COVID-19, higher education was facing many issues that accelerated the trend of colleges closing. Among the contributing factors are financial difficulties, dropping enrollments, lack of significant state or federal support and intervention, and increased competition from academic and non-academic providers. According to an article in the Chronicle of Higher Education, How America’s College-Closure Crisis Leaves Families Devastated (2019), an analysis of federal data shows that about half a million students were displaced by more than 1,200 college campus closures in the last five years. That was an average of twenty closed campuses per month before the COVID-19 pandemic reached the US.

While it is yet to be seen if schools will continue to close at this rate, the pandemic will undoubtedly affect the bottom lines of thousands of schools. Many institutions won’t survive. They will either merge with other institutions, downsize, or close their doors altogether. These closures, compounded with the disruption of COVID, plunge students into an unexpected crisis that can derail their higher education pursuits and often leave them in debt. The ability to transfer credits is more important than ever due to the high number of students in flux, and the nature of the institutions they attend will vary more widely. To attract transfer students and help them attain their goals, institutions must develop ways to support their mobility and thoughtfully manage the broader implications of their experiences, particularly since many students have already completed nationally and programmatically accredited coursework. Major higher education groups have come together to urge colleges to be flexible and transparent when accepting credits in light of the public health pandemic, as cited in the Inside Higher Education article College Credit in the Time of Coronavirus (2020).

Sometimes referred to as the “forgotten students” in the educational pipeline, transfer students suffer unintentional neglect because institutions tend to prioritize services for incoming freshmen (for example, with new student orientation, campus and housing tours, and scholarships). Additionally, non-traditional transfer students who previously attended non-regionally accredited institutions are not merely “forgotten” but often excluded through traditional transfer policies and practices. Students from these types of institutions have complained of denial of transfer credits based only on their sending institution’s accreditation—without their coursework ever being evaluated. Certainly, the receiving institution may consider the sending institution’s accreditation type when deciding which credits to accept from transfer students; however, in most cases, receiving institutions choose whether or not to even evaluate a student’s credits on this criterion alone. By automatically ruling out coursework from non-regionally accredited institutions, colleges and universities are mistakenly disregarding a student’s academic record and potential.


Institutional policies that support the blanket denial of credit transfers create artificial barriers to inter-institutional mobility. Even on a case-by-case basis, the failure to consider potentially equivalent courses ignores individual student achievement and impedes academic progression. Programs of study should allow students to build on their previously established foundation of coursework rather than force them to redo it. Current policies delay time to degree completion and help drive up the cost of post-secondary education. Consequently, some students may just give up on their dreams.



The Costs of Non-transferable Credits

Students’ inability to transfer credits certainly bears cost implications, though the cumulative financial effects on students and the federal government are unknown. The full impact of these policies on students’ lives, taxpayers’ wallets, and even college/university enrollment may never be determined, since few (if any) institutions collect or track data specific to non-transferable credits.

In addition to the impact on individual students, the implications of transfer credit decision-making policies ripple far and wide. While it is in the federal government’s interest to see that students who have earned credits with the assistance of financial aid at a Department of Education Title IV approved institution do not have to repeat coursework or prolong their time to completion, it is also ultimately in taxpayers’ best interests as well. Repeating credits and delaying completion comes at additional costs borne not just by transfer students but by American society as a whole.

Transferability of Credit

When differentiating institutional practices by regional and national accreditation, transferability of credit is a key issue. Schools routinely—and naturally—prioritize learning from other similarly accredited institutions because of familiar, consonant curricular standards. The inter-institutional comparability of the coursework is ensured by quality assurance processes based on peer review. In contrast, colleges and universities with regional accreditation often dismiss credits from unfamiliar, non-regionally accredited schools or those with programmatic accreditation. For receiving institutions capable of evaluating prior learning, including whether to transfer credit from other institutions, the type of accreditation and source of college-level learning should not automatically rule out a student’s opportunity to be evaluated for transfer credit.

Actions Taken Regarding Transferability of Credit

Almost twenty years ago, the Council for Higher Education Accreditation (CHEA) recognized the severity of the issue of transferability and published A Statement to the Community: Transfer and the Public Interest (2000). CHEA stated that the type of accreditation (program or institutional) should not hinder students in the transfer process. In this update to its 1978 statement on transfer and awarding of academic credit, CHEA recommended the use of four criteria for accrediting agencies and institutions to consider when making decisions about the transfer of credit and academic quality:

  1. Ensure that transfer decisions are not solely based on the source of accreditation of a sending program or institution.

  2. Reaffirm that the considerations informing transfer decisions are applied consistently in the context of changing student attendance patterns and emerging new providers of higher education.

  3. Inform students and the public fully and accurately about their respective transfer policies and practices.

  4. Commit to flexibility and remain open to considering alternative approaches to managing transfer when such approaches can benefit students.

The following points expand on CHEA’s recommendations for facilitating fair transfer decisions:

  • While the 2008 Higher Education Opportunity Act (HEOA) stopped short of requiring higher education institutions to recognize transfer credit from non-regionally accredited entities, the HEOA affirmed CHEA’s position: acceptance of transfer credit should not be based solely on the accreditation status, which is simply one of several factors to consider in the evaluation of transfer credit.

  • The United States Department of Education (USDE) publishes an annual database of accredited postsecondary institutions and programs, which includes nationally accredited associations. All accrediting agencies recognized by the USDE are deemed to be reliable authorities on institutional quality and integrity. In recent news, on November 1, 2019, the USDE published final regulations on accreditation. A significant change is the department’s decision to eliminate reference to “regional” accreditation. Regional accrediting organizations are now described as “national” and are required to make public all the states or countries in which they are engaged in accrediting activity.

  • According to two reports from the United States Government Accountability Office (2005, 2017), regionally accredited schools usually prefer to accept credits only from other regionally accredited schools. Yet, all seven regional accrediting agencies subscribe to the principle that credits should not be accepted or denied based on the type of accreditation. The Accrediting Commission for Community and Junior Colleges Western Association of Schools and Colleges, the Middle States Commission on Higher Education, the New England Association of Schools and Colleges, and the Northwest Commission on Colleges and Universities have all incorporated this criterion overtly into their standards. Others, such as the Higher Learning Commission, the Southern Association of Colleges and Schools Commission on Colleges, and the Accrediting Commission for Schools Western Association of Schools and Colleges, have issued position statements.

  • Because accreditation does not address questions about the comparability of the nature, content, and level of potential transfer credit, two national higher education professional associations, the American Association of Collegiate Registrars and Admissions Officers (AACRAO) and the American Council on Education (ACE), joined CHEA to issue the Joint Statement on the Transfer and Award of Credit (2017). The statement advocates equal examination of course quality, comparability, and applicability by encouraging institutions to assure that those transfer decisions are not based only on the source of accreditation. Also, the document indicates that students should receive reasonable explanations about (1) how their work is or is not of sufficient quality comparable to the receiving institution’s standards and (2) how their work is or is not comparable for meeting the degree requirements of the receiving institution.

In spite of these criteria, credits from nationally accredited institutions continue to be denied—often without a review.

The Need for Further Action

Institutional recognition of learning outside of regionally accredited bodies is critical to the development of an equitable higher education system. As employees of higher education institutions within this system, we should work to fulfill these long-held and recently restated responsibilities in transfer decision-making.

Our institutions hold autonomy in determining standards for the transfer of academic credit. Acceptance of credit or graduates is always the prerogative of the receiving institution. Is our prerogative based on the principles of equity, access, and inclusivity? Are we positioning our institutions toward more open and accountable transfer processes that may help redress unfair practices or the exclusion of students’ past educational opportunities?

As student advocates and colleagues, we should openly discuss matters affecting transfer with an emphasis on collaboration for facilitating academic, credit, and learner mobility. This collaborative advocacy toward equity and inclusion can contribute significantly to larger collective efforts supporting certificate and degree attainment. Transfer access should be for all, regardless of where or how a student begins their path toward completion.


About the Author


Rose Rojas, director, workforce strategies at the Maricopa community colleges (Arizona), has established Maricopa as a national leader in student transfer by creating a university partnership model adapted by community college systems across the country. Rose has demonstrated strengths in the coordination, planning and management of academic and student affairs, curriculum strategy, and transfer operations. In her current role, Rose provides academic solutions for workforce initiatives, which includes prior learning assessment, competency-based education, and micro credentialing while keeping transfer on the forefront. Rose has 25 years in higher education and was a recipient of the National Institute for the Study of Transfer Students Transfer Champion Award.

The views and opinions expressed on the NISTS Blog are those of the authors and do not necessarily reflect the official policy or position of NISTS. Any content provided by our bloggers or authors are of their opinion and are not intended to malign any religion, ethnic group, club, organization, company, individual or anyone or anything.

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