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More Consistent Consideration of Coursework by Not Basing 
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Report to Congressional Requesters: 

United States Government Accountability Office: 

GAO: 

October 2005: 

Transfer Students: 

Postsecondary Institutions Could Promote More Consistent Consideration 
of Coursework by Not Basing Determinations on Accreditation: 

GAO-06-22: 

GAO Highlights: 

Highlights of GAO-06-22, a report to congressional requesters: 

Why GAO Did This Study: 

Each year thousands of students transfer from one postsecondary 
institution to another. The credit transfer process, to the extent that 
it delays students’ progress, can affect the affordability of 
postsecondary education and the time it takes students to graduate. 
Seeking information on the processes and requirements that 
postsecondary institutions have in place to assess requests to transfer 
academic credits, Congress asked GAO to examine (1) how postsecondary 
education institutions decide which credits to accept for transfer, (2) 
how states and accrediting agencies facilitate the credit transfer 
process, and (3) the implications for students and the federal 
government of students’ inability to transfer credits. 

What GAO Found: 

When deciding which credits to accept from transfer students, receiving 
institutions consider the sending institution's type of accreditation, 
whether academic transfer agreements with the institution exist, and 
the comparability of coursework. However, institutions vary in how they 
evaluate and apply a student’s transferable credits. Many officials 
from postsecondary institutions with regional accreditation told GAO 
that they would not accept credits earned from nationally accredited 
institutions. To streamline the transfer process, most institutions 
have transfer agreements with other institutions that generally provide 
for the acceptance of credits from the other institution without 
further evaluation. In some instances, institutions review student 
credits—not rejected for other reasons, such as accreditation—to 
determine comparability to their academic offerings. 

State legislation, statewide initiatives, and the accreditation 
standards that accrediting agencies set help facilitate the transfer of 
academic credits from one postsecondary institution to another. Among 
other things, states support the establishment of statewide transfer 
agreements, common core curricula, and common course numbering systems. 
Accrediting agencies facilitate the transfer process through the 
standards they set. The accrediting agencies that GAO reviewed 
generally adhere to the principle that institutions should not accept 
or deny transfer credit exclusively on the basis of a sending 
institution’s type of accreditation. 

Potential Outcomes for Students Seeking Transfer of Academic Credits: 

[See PDF for image] 

[End of figure] 

A student’s inability to transfer credit may result in longer 
enrollment, more tuition payments, and additional federal financial 
aid, but current data do not allow GAO to quantify its effects on the 
students or the federal government. Data are not available on the 
number of credits that do not transfer, making it difficult to assess 
the actual costs associated with nontransferable credits. 

What GAO Recommends: 

GAO suggests that Congress consider further amending the Higher 
Education Act of 1965 to require postsecondary institutions eligible 
for Title IV funding to not deny the transfer of credit on the basis of 
a sending institution’s type of accreditation. 

www.gao.gov/cgi-bin/getrpt?GAO-06-22. 

To view the full product, including the scope and methodology, click on 
the link above. For more information, contact Cornelia Ashby, (202) 512-
7215, ashbyc@gao.gov. 

[End of section] 

Contents: 

Letter: 

Results in Brief: 

Background: 

Institutions Consider Accreditation, Transfer Agreements, and 
Coursework Equivalency when Making Credit Transfer Decisions, but 
Policies Vary: 

Some States and Accrediting Agencies Facilitate the Credit Transfer 
Process: 

Students' Inability to Transfer Credits May Have Cost Implications, but 
Financial Effects on Students and the Federal Government Are Unknown: 

Conclusions: 

Appendix I: Scope and Methodology: 

Appendix II: State Legislation Related to Transfer of Academic Credit: 

Appendix III: Comments from the Department of Education: 

Appendix IV: GAO Contacts and Staff Acknowledgments: 

Tables: 

Table 1: Information from Regional Accrediting Agencies on the Role of 
Accreditation in Credit Transfer Decisions: 

Table 2: Source and Response Rate of GAO's Sampling of Education's 
IPEDS Database: 

Figures: 

Figure 1: Types of First-Time Transfers between 1995 and 2001: 

Figure 2: Percentage of Enrolled Postsecondary Students Enrolled in 
Public, Private Nonprofit, and Private For-Profit Institutions 
Participating in Title IV: 

Figure 3: Institutions Receiving Title IV Federal Financial Aid, by 
Type: 

Figure 4: The Evaluation Process for Transfer Credits: 

Abbreviations: 

AACC: American Association of Community Colleges: 

AACRAO: American Association of Collegiate Registrars and Admissions 
Officers: 

BPS: Beginning Postsecondary Students: 

CCA: Career College Association: 

CHEA: Council for Higher Education Accreditation: 

CSU: California State University: 

FACT: Florida Academic Counseling and Tracking for Students: 

HEA: Higher Education Act: 

IPEDS: Integrated Postsecondary Education Data System: 

IHEP: Institute for Higher Education Policy: 

NATN: National Articulation and Transfer Network: 

NCES: National Center for Education Statistics: 

NELS: National Educational Longitudinal Study: 

SUNY: State University of New York: 

UC: University of California: 

[End of section] 

United States Government Accountability Office: 

Washington, DC 20548: 

October 18, 2005: 

The Honorable Michael B. Enzi: 
Chairman: 
Committee on Health, Education, Labor, and Pensions: 
United States Senate: 

The Honorable John A. Boehner: 
Chairman: 
Committee on Education and the Workforce: 
House of Representatives: 

The Honorable Howard P. "Buck" McKeon: 
Chairman: 
Subcommittee on 21st Century Competitiveness: 
Committee on Education and the Workforce: 
House of Representatives: 

Because thousands of students transfer each year from one postsecondary 
institution to another, the credit transfer process, to the extent that 
it delays students' progress, can affect the affordability of 
postsecondary education and the time it takes students to graduate. As 
of 2001, 40 percent of students entering college in the 1995-1996 
academic year attended at least two institutions during the next 6 
school years. Annually, the federal government invests billions of 
dollars--$21 billion in 2004--in student financial aid under the Higher 
Education Act of 1965, as amended (HEA). Because of the federal 
government's large investment in student financial aid, it is in the 
best interest of taxpayers that transfer students do not unnecessarily 
repeat coursework, since such repetition could result in additional 
financial aid awards. 

Postsecondary institutions, state governments, and accrediting agencies 
all play critical roles in the transfer process. As part of the 
transfer process, receiving institutions must decide whether the 
credits of incoming students are equivalent to those of their own 
course offerings. States can influence the transfer process through 
legislation and regulation, and accrediting agencies provide general 
guidelines regarding the transfer of credit. Congress requires 
postsecondary institutions to be accredited by an accrediting agency 
recognized by the Department of Education (Education) before its 
students can become eligible for federal financial aid. 

In recent years, the ability of students to transfer credits has taken 
on added importance because of increasing numbers of transfer students 
and the changing nature of the types of institutions they attend. In 
general, Education recognizes two main types of accrediting agencies-- 
regional and national. Regional accrediting agencies review 
institutions in a region of the United States that includes at least 
three states that are reasonably close to one another. National 
accrediting agencies review programs or specialized institutions, such 
as acupuncture schools or private business schools, on a national 
basis. In recent years, some nationally accredited institutions have 
broadened their curricula to bring their course offerings into line 
with those of traditional 4-year academic institutions. Yet students 
from these types of institutions have complained that they have been 
denied transfer credits on the basis of accreditation. 

As Congress considers the reauthorization of HEA, it has requested 
information on the processes and requirements that postsecondary 
institutions have in place to assess requests to transfer academic 
credits. You asked us to provide information on the credit transfer 
process, including how and when decisions are made to accept or reject 
credits for transfer. Specifically in this report, we examined (1) how 
postsecondary education institutions decide which credits to accept for 
transfer, (2) how states and accrediting agencies facilitate the credit 
transfer process, and (3) the implications for students and the federal 
government of students' inability to transfer credits. 

To answer these questions, we reviewed transfer of credit policies from 
a nationally representative random sample of 2-year public and 4-year 
public and private institutions. In addition, we conducted site visits 
in California, Florida, Missouri, New Jersey, and New York, where we 
interviewed officials from public, private nonprofit, and private for- 
profit postsecondary institutions that were nationally and regionally 
accredited. In order to get a broad perspective on the challenges that 
students face when transferring credit, we selected states with large 
transfer student populations and varying levels of involvement in the 
credit transfer process. We also interviewed officials from state 
education agencies regarding institutional transfer policies and state 
initiatives to facilitate credit transfer. We also interviewed 
officials from accrediting agencies and national experts on credit 
transfer. Further, we reviewed state legislation and accrediting 
agencies' standards concerning transfer of credits. Finally, we 
examined Education's databases on postsecondary institutions. We 
reviewed documentation about the various methodologies used to collect 
the data in the databases and conducted interviews to establish the 
reliability of the data. We conducted our work from January 2005 
through September 2005 in accordance with generally accepted government 
auditing standards. For a more detailed explanation of our methodology, 
see appendix I. 

Results in Brief: 

When deciding which credits to accept from transfer students, receiving 
institutions consider the sending institution's type of accreditation, 
whether academic transfer agreements with the sending institution 
exist, and the comparability of coursework, but policies vary in how 
they evaluate and apply a student's transferable credits. About 84 
percent of institutions consider whether the sending institution is 
accredited, and many consider the type of accreditation--national or 
regional--when determining which transfer credits to accept. Many 
institutions' transfer policies specify that they only accept credits 
from a regionally accredited institution. As a result, students from 
nationally accredited institutions may have their credits denied on the 
basis of their previous institution's type of accreditation. About 69 
percent of the institutions have agreements with other institutions to 
streamline the transfer process. In these agreements, receiving 
institutions, after reviewing the sending institution's coursework and 
faculty credentials, agree to accept credits directly from the sending 
institution without further evaluation. If agreements do not exist, 
many institutions review student coursework to determine its 
equivalency and applicability toward a degree. The processes 
institutions follow when evaluating the transferability of prior 
coursework and accepting credits for transfer vary. Specifically, 
institutions vary in how they evaluate credits, who makes the decisions 
to accept credits, and when credit transfer decisions are made. For 
example, some institutions evaluate transfer credits prior to student 
transfer, while others make final credit transfer decisions after 
student enrollment. 

State legislation, statewide initiatives, and the accreditation 
standards that accrediting agencies set help facilitate the transfer of 
academic credits from one postsecondary institution to another. Some 
states facilitate the transfer of credit among their public 
institutions through a variety of statewide legislation and initiatives 
that, among other things, support the establishment of statewide 
transfer agreements, common core curricula, and common course numbering 
systems, and encourage institutions and others to make transfer 
information available to the public. Accrediting agencies facilitate 
the transfer process through the standards they set. The accrediting 
agencies we reviewed set standards for accreditation that require 
institutions to review the educational quality of the sending 
institution, the comparability of credit to be transferred to the 
receiving institution, and applicability of the credit in relation to 
the programs being offered at the receiving institution. In addition, 
the six regional accrediting agencies that we reviewed generally 
encourage member institutions not to use the sending institution's type 
of accreditation as the sole factor in determining which credits to 
accept for transfer. 

A student's inability to transfer credit may result in longer 
enrollment, more tuition payments, and additional federal financial 
aid, but the full extent to which these occur cannot be determined 
because institutions told us that they do not collect specific data on 
students unable to transfer credit. If the receiving institution 
decides that few or no credits earned at the sending institution are 
equivalent to its course offerings, the student may need to repeat 
coursework that could result in enrolling for one or more additional 
terms. National data indicate that graduates who transferred from a 
community college take on average 10 more credits and 3 more months 
than nontransfer graduates. Transfer graduates may take more credits 
for reasons, such as changing majors, which are not related to their 
decision to transfer. We could not determine the extent to which 
transfer students differ from nontransfer students in these areas. 
However, a student taking additional credits as a result of being 
unable to transfer credits will likely have to pay additional tuition, 
ranging from $150 per credit hour at public institutions to $520 per 
credit hour at private institutions. The extent to which these costs 
are borne by the student or the federal government varies depending on 
the student's eligibility for financial aid. 

In this report, we suggest that Congress consider amending the Higher 
Education Act of 1965 to require postsecondary institutions eligible 
for federal financial aid to issue a statement in their transfer of 
credit policy that they will not deny the transfer of credit on the 
basis of a sending institution's type of accreditation. 

Background: 

Patterns of enrollment in postsecondary education reflect that students 
frequently enroll in more than one postsecondary institution. 
Education's National Center for Educational Statistics (NCES) found 
that 40 percent of students who entered college in the 1995-1996 
academic year attended at least two institutions in the following six 
years. Many students enroll in community colleges with a plan for 
eventually transferring to a 4-year baccalaureate program. As a result, 
4-year institutions face pressure to award transfer credit for 
coursework taken at another institution. 

Data show that students transfer in numerous directions. Traditional 
transfer is typically from a 2-year institution to a 4-year 
institution. However, students also transfer from 4-year institutions 
to 2-year institutions, known as reverse transfer, as well as laterally 
between similar institutions (e.g., 2-year to 2-year or 4-year to 4- 
year). As shown in figure 1, traditional transfer accounts for at least 
one-third of first transfer activity. 

Figure 1: Types of First-Time Transfers between 1995 and 2001: 

[See PDF for image] 

[End of figure] 

When students want to transfer their earned academic credits from one 
institution to another, they must submit a transcript showing their 
coursework and earned grades to the receiving institution. The 
receiving institution may then evaluate the transcript and assess the 
educational quality of the student's learning experience, compare the 
level and content of the learning experience with those of the learning 
experience offered by the receiving institution, and determine the 
applicability of the student's coursework to the degree or programs 
offered at the receiving institution. To help streamline the evaluation 
process, sending and receiving institutions enter into voluntary 
transfer agreements, which contain criteria for credits to transfer. 

Today, many students who begin their studies at private, for-profit 
institutions transfer to public or private nonprofit 4-year 
institutions. To meet this demand, many private, for-profit 
institutions have revamped their curricula, transforming what had 
chiefly been vocational training aimed at job placement to a core 
educational curriculum that prepares students to pursue associate's, 
bachelor's, and even graduate degrees. 

The Department of Education administers federal postsecondary education 
programs, including the Title IV federal financial aid programs under 
the Higher Education Act of 1965, as amended. To be eligible for 
federal financial aid, a postsecondary institution must be accredited 
by an accrediting agency recognized by the Secretary of Education. 
Accrediting agencies are private educational associations of regional 
or national scope that develop evaluation standards and conduct site 
visits to evaluate postsecondary institutions. To become recognized, an 
accrediting agency must submit a written application to Education that 
lays out its standards for accrediting institutions as well as its 
procedures for ensuring that institutions follow those standards. 
Education requires accrediting agencies to set standards that instruct 
institutions to have the resources and policies in place to provide a 
quality education. Education applies the same requirements to both 
regional and national accrediting agencies. Education has recognized 
eight regional accrediting agencies that generally accredit academic 
degree granting institutions in their specific region of the country, 
and about 50 national accrediting agencies that accredit various kinds 
of specialized postsecondary institutions, such as technological or 
religious institutions, and programs such as nursing and engineering. 

The most current national data on students show that in September 2003, 
an estimated 15.2 million students were enrolled in postsecondary 
institutions; 77 percent of these students were enrolled in public 
institutions, 17 percent in private nonprofit institutions, and 6 
percent enrolled in private for-profit institutions.[Footnote 1] 
Additionally, about 6,900 degree-and non-degree-granting postsecondary 
education institutions had students that were receiving federal 
financial aid. Figure 2 shows the percentage of students attending 
public, private nonprofit, and private for-profit institutions, and 
figure 3 shows the type of institutions receiving these funds. 

Figure 2: Percentage of Enrolled Postsecondary Students Enrolled in 
Public, Private Nonprofit, and Private For-Profit Institutions 
Participating in Title IV: 

[See PDF for image] 

[End of figure] 

Figure 3: Institutions Receiving Title IV Federal Financial Aid, by 
Type: 

[See PDF for image] 

[End of figure] 

In order to acquire federal financial aid, students are required, among 
other things, to demonstrate financial need, demonstrate qualifications 
to enroll in postsecondary education, be working toward an eligible 
degree or certificate, be a U.S. citizen or eligible noncitizen, and 
maintain satisfactory academic progress while in school. Education uses 
a formula to determine the amount of a student's financial need and his 
or her expected family contribution toward tuition, taking into account 
a number of factors including the student's or family's resources and 
the costs of attending an institution. In their financial aid packages, 
students may receive federal grants or loans, with the neediest 
students receiving about $4,000 per year in a Pell grant and up to 
$4,000 in loans under the Perkins loan program. Additionally, all 
students qualify to receive Stafford loans for which the government may 
subsidize or defer the loan interest while students remain enrolled in 
school. 

Institutions Consider Accreditation, Transfer Agreements, and 
Coursework Equivalency when Making Credit Transfer Decisions, but 
Policies Vary: 

Prior to granting credit for courses taken at another institution, 
institutions may consider a variety of criteria, such as accreditation, 
transfer agreements, and course equivalency. Many institutions consider 
the accreditation of the sending institution, including the type of 
accreditation--national or regional--when determining which transfer 
credits to accept. Institutions may also assess the equivalency of 
coursework taken at other institutions, either through establishing 
transfer agreements covering a number of courses or on a course-by- 
course basis. Though reviewing courses can be time-consuming and 
maintaining transfer agreements requires an ongoing commitment, 
officials said that transfer agreements do facilitate the transfer 
process. Institutions also vary in who makes the final decision on 
which credits to accept--administrative official or departmental 
faculty--and when they inform a student of their decision. 

Institutions Consider Accreditation when Deciding Which Transfer 
Credits to Accept and Commonly Accept Credits Earned at Regionally 
Accredited Institutions: 

We found that when making decisions about whether or not to accept 
transfer credits, institutions often used the sending institution's 
accreditation as the initial measure of the quality of the institution 
and its coursework. We found that about 84 percent of postsecondary 
institutions had policies to consider the accreditation of the sending 
institution when assessing transfer credits.[Footnote 2] About 63 
percent of these institutions specified that accreditation from any 
regional accrediting agency was acceptable, and about 14 percent 
specified that they accepted national accreditation.[Footnote 3] 
Institutions indicating that they accepted regional accreditation told 
us that they also provide students with other options for getting their 
credits transferred, such as passing a competency examination before 
their credits would be granted. Many also said that they would allow 
any student to appeal a decision, and an appeal would result in a more 
thorough review of the student's transcript. 

Several officials from postsecondary institutions with regional 
accreditation told us that as a rule, they did not accept credits 
earned at institutions with national accreditation. For example, an 
official at one institution told us that the institution did not accept 
credits from nationally accredited institutions because the coursework 
was technical and not academic. Similarly, an official at a regionally 
accredited institution told us that the institution could not accept 
credits from nationally accredited institutions unless the accrediting 
standards of the sending institution paralleled their own standards. 
One reason given by regional accrediting agency official for the 
incomparability of credits earned at nationally accredited institutions 
was that these institutions follow less stringent standards regarding 
such factors as faculty qualifications and library resources. However, 
our review of the standards from the regional accrediting agencies 
found that no regional accrediting agency explicitly stated in its 
written policy that credits from nationally accredited institutions 
should be denied. 

We found that about 11 percent of institutions have policies that 
explicitly state that they will accept both regionally and nationally 
accredited credits. For example, one institution's credit transfer 
policy states that it will accept credits from "universities and 
colleges with accreditations by one of the regional accrediting 
associations,… community and technical colleges with accreditation by 
one of the regional accrediting associations,… and technical colleges, 
business colleges and other schools lacking regional accreditation but 
having accreditation by another agency recognized by the Council for 
Higher Education Accreditation [CHEA]."[Footnote 4] Officials from a 
regionally accredited institution told us that they would accept 
credits regardless of accreditation and would review all credits the 
same way. However, this process was more time-consuming than relying 
solely on accreditation. To save time, some institutions had developed 
databases to track previously approved courses in order to remove the 
need to reevaluate them. 

Officials at a nationally accredited institution told us that their 
students often have difficulty transferring credits and that they are 
taking actions to assist their prospective transfer students. They told 
us that regionally accredited institutions did not always accept 
courses taken at the nationally accredited institution. They advised 
students to assume that credits would not transfer to regionally 
accredited institutions. Two nationally accredited institutions we 
visited have responded to the credit transfer difficulties by 
attaining, or seeking to attain, regional accreditation in order to 
improve their students' ability to transfer credits. One of the three 
nationally accredited institutions we visited--the institution with 
dual national-regional accreditation--reported having no problems with 
transferring its students to 4-year institutions. In lieu of seeking 
dual accreditation, another nationally accredited institution we 
visited is reaching out to regionally accredited institutions to 
develop transfer agreements to facilitate the transfer process. 

Institutions Said That Transfer Agreements, though Time-Consuming, Do 
Facilitate Transfers: 

While many institutions use accreditation as a factor to assess 
transfer credits, about 69 percent of postsecondary institutions have 
entered into voluntary transfer agreements with other 
institutions.[Footnote 5] Typically, institutions we visited establish 
transfer agreements with institutions that send large numbers of 
transfer students. For example, Columbia College in Missouri--a college 
with campuses in 11 states--has transfer agreements with 18 community 
colleges throughout the country. In these agreements, receiving 
institutions review a number of courses from sending institutions and 
agree to accept comparable credits from that institution. For example, 
the State University of New York system has a transfer agreement among 
all of its institutions specifying that all 4 year universities will 
accept associate degrees from community colleges within its system, 
thus guaranteeing a baccalaureate degree with the completion of 60 
additional credits. Agreements can also cover individual courses, such 
as mathematics and science courses that are required prerequisites for 
upper-level courses. 

Institution officials told us that although maintaining transfer 
agreements requires considerable commitment, these agreements are 
useful because they make the transfer process more transparent and 
allow it to operate more smoothly. The agreements require receiving 
institutions to review the course content of each partner institution 
to determine its comparability and applicability to meeting the degree 
program requirements. Maintaining these agreements requires regular 
ongoing communication between participating institutions to keep 
apprised of all new course offerings or any changes to current courses 
or degree requirements. According to officials from several of the 
schools we visited, the process of establishing the agreements and 
keeping them current requires considerable commitment because 
institutions frequently revise their courses and degree requirements. 
For example, it took one private institution in New Jersey a full year 
to review courses for every community college with which it had 
established new transfer agreements. At another institution we visited, 
the official responsible for credit evaluation told us that the time 
required for maintaining transfer agreements had led the institution to 
reduce the number of its transfer agreements by about 25 percent. While 
transfer agreements can be time-consuming, they help make the transfer 
process more transparent. For example, in New Jersey, many 4-year 
institutions have established transfer agreements with community 
colleges in the state. Community college students may also access a Web 
page listing courses at their institution that will transfer to 
participating 4-year institutions in New Jersey, allowing students to 
know which credits will transfer before they apply to a new 
institution. One official told us that the transfer agreements, once 
established, allow the credit transfer process to operate smoothly 
between the partnering institutions, because it becomes a matter of 
checking a list to determine which credits to accept or deny. 

Officials offered a variety of reasons for pursuing transfer 
agreements. In some instances, transfer agreements were mandated in 
state law or facilitated by state agencies, but these types of 
agreements were usually between public institutions only. In other 
instances, institutions sought to establish transfer agreements out of 
convenience because of the significant number of students that moved 
between their institutions. In addition to states and institutions, 
another organization we visited is also involved in facilitating the 
establishment of transfer agreements. To improve access to 
baccalaureate programs for certain populations of minority students, 
the National Articulation and Transfer Network has facilitated transfer 
agreements between community colleges and minority-serving institutions 
across the country. [Footnote 6] 

Institutions Review the Comparability of Coursework but Vary in How 
They Administer This Process: 

Some institutions review students' transcripts to determine the 
comparability of the students' coursework. Specifically, institutions 
consider the characteristics of individual courses, such as the 
similarity of courses on a student's transcript to courses offered at 
the receiving institutions and the applicability of the courses to the 
student's intended major. Institutions may ask for a course description 
or a class syllabus to support their assessment. To expedite this 
review, some institutions maintain a historical list of transfer 
courses that they have accepted in the past. While not always a 
guarantee of transferability, listed courses have a greater likelihood 
of acceptance than unlisted courses. 

At the institutions we visited, two groups of reviewing officials are 
generally responsible for determining which courses to accept for 
transfer: (1) an admissions or other administrative officer, who 
determines which courses meet general requirements, and (2) academic 
department faculty members, who determine which courses meet degree 
requirements within their departments. When reviewing officials 
consider the student's official transcript, they may review transfer 
agreements and historical lists of accepted courses, request the 
syllabus or a list of books used in the course, or discuss the course 
with a representative from the sending institution or use an Internet 
service, such as the one maintained by the American Association of 
Collegiate Registrars and Admissions Officers, to obtain a syllabus and 
description of the course, among other things. This process is shown in 
figure 4. 

Figure 4: The Evaluation Process for Transfer Credits: 

[See PDF for image] 

[End of figure] 

Some 4-year institutions, citing time constraints and a significant 
backlog, have taken steps to limit the number of courses they review. 
Some institutions have established criteria for transferable courses, 
such as determining the minimum grade or course level for which credits 
will be accepted. Several 4-year institutions told us that they did not 
accept for transfer any remedial (developmental) courses, technical 
courses, or upper-level courses taken at a 2-year institution. Because 
of the backlog created by the number of transcripts to review, not all 
institutions succeed in providing students with an official report of 
transfer credits accepted before classes begin. Officials at one 
institution told us that they provide the report within 1 year of the 
student's matriculation and encourage students to take upper-level 
general education courses in the interim until the report is received. 

Some States and Accrediting Agencies Facilitate the Credit Transfer 
Process: 

To facilitate the transfer of academic credits, states enact a variety 
of legislation and implement statewide initiatives covering primarily 
public postsecondary institutions, and accrediting agencies set 
accreditation standards. Many states have passed legislation that 
requires public community colleges and 4-year public institutions to 
establish transfer agreements and authorizes common curricula to ease 
the transfer of credits. Some states have established a common course 
numbering system for public institutions within the state and created 
statewide committees to oversee the transfer of credit process within 
the state. In other states, state law requires university systems to 
initiate and form transfer agreements with institutions within the 
system to enhance the transferability of credits. Some states have also 
launched statewide initiatives to encourage transfer between 2-year and 
4-year public institutions, including offering guarantees that credit 
will transfer. For their part, accrediting agencies facilitate the 
transfer process through the standards they set for affiliated 
institutions. Accrediting agencies that we reviewed have set standards 
for accreditation that require institutions to make their credit 
transfer policy publicly available. The six regional accrediting 
agencies that we reviewed generally encourage their member institutions 
not to accept or deny transfer credit exclusively on the basis of the 
accreditation of the sending institution. Some accrediting agencies 
have incorporated this criterion into their standards; others have 
issued policy or position statements. 

Some State Legislation and Statewide Initiatives Ease Credit Transfer: 

States facilitate the transfer of credits among public institutions 
through various statewide legislation and initiatives that, among other 
things, support the establishment of statewide transfer agreements, 
common core curricula, and common course numbering systems, and 
encourage institutions and others to make transfer information 
available to the public. We identified 39 states that had legislation 
pertaining to the transfer of credit between postsecondary public 
institutions. In general, most of the legislation focuses on 
facilitating the transfer of credit for students transferring from 
community colleges to 4-year public institutions. 

Some states require or encourage the establishment of statewide 
transfer agreements. For example, a Massachusetts statute empowers its 
board of higher education to develop and implement a statewide transfer 
agreement to facilitate the transfer of students without the loss of 
academic credit or standing from one public institution to another. 
Arizona law requires institutions to cooperate in operating a statewide 
transfer network to facilitate the transfer of community college 
students to Arizona public universities without a loss of credit toward 
a baccalaureate degree. An Indiana statute requires the state's 
Commission for Higher Education to develop statewide transfer of credit 
agreements for courses that are most frequently taken by 
undergraduates. Colorado's statewide transfer policy guarantees that as 
many as 37 credits of approved general education courses taken at a 
Colorado public college or university will transfer among all 2-year 
and 4-year institutions in the state. 

Some states require or encourage the establishment of common core 
curricula. A California statute directed the governing boards of the 
University of California, the California State University, and the 
California community colleges to jointly develop and adopt a common 
core curriculum in general education for the purpose of transfer. These 
efforts led to California's general education transfer curriculum, 
which identifies courses that community college students may complete 
to satisfy general education requirements at campuses of both the 
University of California and California State University systems. An 
Arkansas statute requires the Arkansas Higher Education Coordinating 
Board to consult with colleges and universities to establish a minimum 
core of courses that applies toward the general education core 
curriculum requirements and is fully transferable between state 
institutions. 

Some states require or encourage the establishment of a common course 
numbering system. Florida has developed a statewide course numbering 
system that provides a database of equivalent postsecondary courses at 
public vocational technical centers, community colleges, universities, 
and participating nonpublic institutions. More than 100 institutions in 
Texas participate in the state's voluntary course numbering program, 
which provides a shared, uniform set of course designations for 
students and their advisers to use in determining both course 
equivalency and degree applicability of transfer credits on a statewide 
basis. 

Some state statutes identify the types of courses or blocks of courses 
that are transferable. For example, Missouri officials told us that 
they interpret their state law as requiring all institutions to accept 
associate degrees from any source as evidence that general education 
courses have been completed. Additionally, to facilitate student 
transfer among Missouri institutions and to increase institutions' 
accountability for student performance in general education, the 
Coordinating Board for Higher Education designed a 42-semester-hour 
block of general education.[Footnote 7] Similarly, a Texas statute 
states that if a student successfully completes a field-of-study 
curriculum developed by the state's board of higher education, that 
block of courses may be transferred and must be substituted for the 
receiving institution's lower division requirements for the comparable 
degree program, and the student must receive full academic credit. 
Likewise a Kentucky statute mandates that all lower division academic 
courses offered by community colleges be transferable for academic 
credit to any and all 4-year public colleges and universities in the 
state. 

Some state higher education agencies make information on transfer 
agreements and course equivalency guides available to the public. For 
example, some states, such as California, Maryland, and Florida, have 
placed course equivalencies online for easy access and reference. 
California maintains an online student transfer system called ASSIST 
that serves as the official repository of transfer agreements for all 
public postsecondary institutions in California and facilitates 
transfer from a California community college to a University of 
California or California State University campus. Maryland's 
interactive online transfer information source called ARTSYS allows 
students to find course equivalencies between institutions, evaluate 
their transcripts, search for majors, and explore recommended transfer 
programs. In addition, it provides faculty access to update courses and 
provide course evaluations. The Florida Academic Counseling and 
Tracking for Students (FACTS) system offers a comprehensive range of 
transfer services, including a transfer student bill of rights, links 
to statewide transfer agreements, and an interactive transfer 
evaluation tool.[Footnote 8] A Pennsylvania statute supports the 
implementation of a Web-based application that makes all transfer 
agreements among higher education institutions available on the 
Internet. Similarly, Virginia requires its state council of higher 
education to publicize all general education courses offered at public 
2-year institutions, designating the courses accepted for transfer 
credit at 4-year public and private postsecondary institutions in 
Virginia. Ohio implemented a framework that guarantees students a 
statewide transfer and published a transfer assurance guide to advise 
students of the 38 different baccalaureate degree pathways available 
for them to pursue anywhere within the public higher education system 
and in Ohio's participating private institutions, and to identify which 
courses are guaranteed to transfer and apply to requirements within the 
system. 

While state legislation regarding credit transfer is generally intended 
to facilitate the transfer of credits among public institutions, a few 
state statutes require or encourage the involvement of private 
institutions. For example, the Louisiana Board of Supervisors of 
Community and Technical Colleges is required to continue development of 
articulation agreements between institutions under the management of 
the board and institutions managed by other postsecondary management 
boards, both public and private. A Minnesota statute requests the 
governing boards of private institutions that grant associate and 
baccalaureate degrees and have a high frequency of transfer students to 
participate in the development of required course equivalency guides. A 
West Virginia statute requires the state's Council for Community and 
Technical College Education to establish and implement policies and 
procedures that ensure that students may transfer and apply the credits 
earned at any regionally accredited in-state or out-of-state higher 
education institution. 

Accrediting Agencies Set Accreditation Standards, and Some Encourage 
Institutions to Promote the Consistent Evaluation of Transfer Credit: 

Accrediting agencies' standards for evaluating transfer credit 
generally reflect the three criteria specified in a 1978 joint national 
statement on the transfer and award of credit: the educational quality 
of the sending institution, the comparability of credit to be 
transferred to the receiving institution, and applicability of the 
credit in relation to the programs being offered at the receiving 
institution.[Footnote 9] These agencies' accrediting standards 
generally require receiving institutions to consider if courses are 
equivalent with their own curricula and standards. In 2000, CHEA issued 
an updated statement that offered four additional criteria that 
accrediting agencies and institutions should consider when making 
decisions about transfer of credit and academic quality. Specifically, 
these criteria emphasized the need for institutions and accrediting 
agencies to: 

(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 that inform transfer decisions are 
applied consistently in the context of changing student attendance 
patterns and emerging new providers of higher education, 

(3) ensure that students and the public are fully and accurately 
informed about their respective transfer policies and practices, and: 

(4) be flexible and open in considering alternative approaches to 
managing transfer when these approaches will benefit students. 

The accrediting standards and transfer policies of the 6 regional and 
10 national accrediting agencies that we reviewed generally reflect the 
original criteria included in the 1978 joint statement.[Footnote 10] In 
addition, some accrediting agencies incorporated into their standards 
the CHEA criteria added in 2000 that the institutions' process for 
accepting transfer credit be fair, consistently applied, and publicly 
communicated. 

The 6 regional accrediting agencies that we reviewed all support CHEA's 
statement on the role of accreditation in the credit transfer decision- 
making process. As shown in table 1, some accrediting agencies have 
incorporated this criterion into their standards; others have issued 
policy or position statements. 

Table 1: Information from Regional Accrediting Agencies on the Role of 
Accreditation in Credit Transfer Decisions: 

Agency: Middle States Commission on Higher Education; 
Information source: Standards; 
Specific language: "The acceptance or denial of transfer credit will 
not be determined exclusively on the basis of the accreditation of the 
sending institution or the mode of delivery, but rather will consider 
if the course is equivalent, including expected learning outcomes with 
those of the receiving institution's curricula and standards. Such 
criteria will be fair, consistently applied, and publicly 
communicated." 

Agency: New England Association of Schools and Colleges; 
Information source: Standards; 
Specific language: "Accreditation speaks to the probability but does 
not guarantee that students have met acceptable standards of 
educational accomplishment. . . . Since accreditation does not address 
[comparability and applicability], the information must be obtained 
from catalogs and other materials and from direct contact between 
knowledgeable and experienced faculty and staff at both the receiving 
and sending institutions." 

Agency: North Central Association of Colleges and Schools; 
Information source: Position Statement; 
Specific language: "The Commission does not dictate organizational 
policies and procedures for accepting transfer credits, but it holds 
that good practice requires the consideration of more than the source 
of the accreditation of a sending program or institution." 

Agency: Northwest Commission on Colleges and Universities; 
Information source: Standards; 
Specific language: "Accreditation speaks to the probability but does 
not guarantee that students have met acceptable standards of 
educational accomplishment. . . . Since accreditation does not address 
[comparability and applicability], the information must be obtained 
from catalogs and other materials and from direct contact between 
knowledgeable and experienced faculty and staff at both the receiving 
and sending institutions." 

Agency: Southern Association of Colleges and Schools; 
Information source: Position statement; 
Specific language: "The accreditation standards do not mandate that 
institutions accept transfer credit only from regionally accredited 
institutions. When an institution relies on another institution's 
regional accreditation as an indicator for acceptability of credit, it 
should not be the only criterion used for acceptability nor should it 
be represented as a requirement of this accreditation agency, which it 
is not." 

Agency: Western Association of Schools and Colleges; 
Information source: Policy; 
Specific language: "Accreditation speaks to the probability but does 
not guarantee that students have met applicable standards of 
educational accomplishment. . . . Since accreditation does not address 
[comparability and applicability], the information must be obtained 
from catalogs and other materials and from direct contact between 
knowledgeable and experienced faculty and staff at both the receiving 
and sending institutions." 

Source: GAO analysis of regional accrediting agencies' standards. 

[End of table] 

Regional accrediting agencies recognize that the institutions are 
responsible for determining their own policies and practices with 
regard to the transfer and award of credit. Accrediting agencies will 
not know whether an institution is following the standards and general 
guidelines until the institution is reviewed. Officials at one 
accrediting agency told us that because of the nature of the review 
cycle, it could take several years to review all of the institutions 
and thereby ensure that they had implemented the standards. 

Students' Inability to Transfer Credits May Have Cost Implications, but 
Financial Effects on Students and the Federal Government Are Unknown: 

The inability to transfer credits may result in longer enrollment, more 
tuition payments, and additional federal financial aid awards, but the 
full extent to which such results occur cannot be determined because 
institutions told us they do not collect specific data on students that 
are unable to transfer credit. For example, a 1996 study of Arizona's 
public university transfer practices found that community college 
transfer students may be required to take additional courses in order 
to complete their degrees because academic departments do not always 
accept community college courses as prerequisites.[Footnote 11] The 
study found that the accumulation of excess college credit hours could 
lead to additional years in school, added taxpayer expense such as 
financial aid awards, or a failure to complete a degree. Officials at 
selected nationally accredited institutions also told us that denials 
based on accreditation can result in students taking additional 
coursework in order to graduate. For example, one nationally accredited 
institution told us that one of its recent graduates had been required 
to repeat 2 years of coursework at a regionally accredited institution 
before he could be admitted to a graduate program. While credit 
transfer denials likely affect transfer students in a number of ways, 
the effect that these denials have on students' enrollment duration, 
success in completing a baccalaureate program, or the affordability of 
postsecondary education cannot be determined with available data. 
Institution officials told us that they did not maintain data on the 
number of credits they have denied for transfer because it would be too 
cumbersome to maintain these files. 

Our analysis of Education's postsecondary education data found that 
transfer students fare differently from nontransfer students. The 
national data indicate that, on average, transfer graduates take about 
10 more credits[Footnote 12] and 3 more months[Footnote 13] to complete 
their baccalaureate degree than nontransfer graduates. However, 
transfer students could take longer to graduate for a variety of 
reasons that may or may not be related to their decision to transfer. 
For example, a student who changes majors may need to take additional 
courses in order to graduate. We could not determine the extent to 
which transfer students differ from nontransfer students in these 
areas. Nonetheless, students taking additional credits as a result of 
being unable to transfer credits will likely have to pay additional 
tuition. Based on national averages, these tuition payments could range 
from about $150 per credit hour for students attending public 
institutions to about $520 for those attending private schools. The 
extent to which these costs are borne by the student or the federal 
government would vary depending on the student's eligibility for 
financial aid. 

Conclusions: 

Postsecondary institutions differ in how they assess transfer credits, 
and as a result, the current credit transfer process does not ensure 
the consistent consideration of student coursework. To facilitate the 
credit transfer process, many states have enacted legislation and 
implemented statewide initiatives covering primarily public 
postsecondary institutions within their respective states. However, 
state efforts have limited influence over students transferring to and 
from the nation's private institutions or institutions located outside 
state boundaries. Also, all regional accrediting agencies subscribe to 
the principle that credits should not be accepted or denied on the 
basis of the type of accreditation, but not all of them have set 
standards requiring their member institutions to do so. When such 
standards have been set, it takes accrediting agencies years to review 
their member institutions' policies to confirm their compliance. 

To preserve their institutional reputations and maintain quality, 
postsecondary institutions want their graduates to meet certain 
academic standards. The federal government sets the same standards for 
regional and national accrediting agencies to ensure that postsecondary 
institutions provide a quality education. At the same time, it is in 
the federal government's interest to ensure that students receiving 
assistance through federal aid programs, who have earned credits at an 
approved accredited institution, do not have to repeat coursework when 
transferring to another institution meeting the same standards. 
However, some institutions continue to deny credits from institutions 
with national accreditation without reviewing student coursework 
despite the fact that these institutions are accredited by federally 
recognized national accrediting bodies. Consequently, qualified 
students could be denied credit for comparable coursework, leading them 
to incur further educational costs that they may need to offset with 
additional federal financial aid. 

Matter for Congressional Consideration: 

In order to ensure consistent consideration of students' previous 
coursework, Congress should consider further amending the Higher 
Education Act of 1965 to require postsecondary institutions eligible 
for Title IV funding to not deny transfer credits on the basis of the 
type of accreditation. 

Agency Comments: 

We provided a draft of this report to the Department of Education for 
review and comment. In its written response, included as appendix III, 
Education said our report was useful and informative. 

As arranged with your offices, unless you publicly announce its 
contents earlier, we plan no further distribution of this report until 
30 days from the issue date. At that time, we will send copies of this 
report to the Secretary of Education, interested congressional 
committees, and other interested parties. We will also make copies of 
this report available to others on request. In addition, the report 
will be available at no charge on GAO's Web site at http://www.gao.gov. 

If you have any questions about this report, please contact me at (202) 
512-7215 or ashbyc@gao.gov. Staff acknowledgments are listed in 
appendix IV. 

Signed by: 

Cornelia M. Ashby: 
Director, Education, Workforce, and Income Security Issues: 

[End of section] 

Appendix I: Scope and Methodology: 

To describe how the transfer of credit operates among postsecondary 
institutions, we examined transfer of credit policies for a nationally 
representative sample of institutions and interviewed officials 
responsible for credit transfer evaluations from public, private, 
nonprofit, and private for-profit institutions. At each institution, we 
interviewed officials and asked them questions related to their 
policies and practices on transfer of credit, such as their criteria 
for accepting transfer credits, their process for evaluating 
transcripts, and if students had appeal rights once a decision was 
made. We also interviewed officials from the Council for Higher 
Education Accreditation (CHEA), the American Association of Collegiate 
Registrars and Admissions Officers (AACRAO), and the Institute for 
Higher Education Policy (IHEP). We reviewed publications and studies 
conducted by these organizations, the American Association of Community 
Colleges (AACC), and the Career College Association (CCA). 

To learn about how states and accrediting agencies facilitate the 
transfer of credit process, we searched legal databases for state 
statutes in all 50 states to determine if the states had legislation 
related to transfer of credit. We also interviewed officials 
responsible for higher education from five states, officials from 
national and regional accrediting agencies, and the Department of 
Education (Education). We reviewed standards for accreditation from 10 
national accrediting agencies that accredit institutions that grant 
degrees and the 6 regional accrediting agencies that accredit senior or 
4-year institutions. The 5 states we visited were California, Florida, 
Missouri, New Jersey, and New York. In order to get a broad perspective 
on the challenges that students face when transferring credit, we 
selected states based on their varying levels of involvement in the 
credit transfer process and with large transfer student populations. 

To understand the implications for students and the federal government 
of students' inability to transfer credit, we reviewed some of 
Education's national databases to describe the typical transfer 
student. We reviewed the Integrated Postsecondary Education Data System 
(IPEDS) database to analyze the average cost of attendance at various 
types of institutions and the Beginning Postsecondary Students (BPS) 
database to learn about the transfer trends. We also used data from the 
National Educational Longitudinal Study of 1988 (NELS). In addition, we 
spoke with national experts and reviewed national studies related to 
the implications for students and the federal government of student's 
inability to transfer credits. 

Sampling Strategy: 

In order to collect information about the ways in which institutions of 
higher education treated transfer credits, we undertook a data 
collection effort from a random sample of 270 institutions of higher 
education. The sample was obtained from the IPEDS database. The IPEDS 
data were from the 2000-2001 time period. IPEDS is the Department of 
Education's core postsecondary education data collection program. It is 
a single, comprehensive system that encompasses all identified 
institutions with the primary purpose of providing postsecondary 
education. IPEDS is designed to produce national-, state-, and 
institution-level data for most postsecondary institutions. 

We conducted a stratified random sample from the IPEDS database. The 
sample represented 270 institutions, with 90 institutions from each of 
three categories of postsecondary institutions. The three categories we 
sampled included 4-year public, 4-year private nonprofit, and 2-year 
public institutions. These three types of institutions represent 3,096 
institutions and over 95 percent of students attending higher education 
institutions. GAO did not sample 4-year private, for-profit 
institutions and 2-year private institutions. These types of 
institutions represented 1,264 institutions but less than 5 percent of 
students attending higher education institutions. 

Of the 270 institutions that were randomly selected, 6 were found to be 
out of scope because our research indicated that they did not grant 
degrees or granted only graduate degrees. These 6 institutions were not 
included in the eventual results. Table 2 describes our source and 
response rates for our sample of institutions. 

Table 2: Source and Response Rate of GAO's Sampling of Education's 
IPEDS Database: 

Type of institution: 4-year public; 
Total institutions in IPEDS database: 624; 
GAO sample size: 90; 
Response rate for GAO Web or telephone data collection instrument: 
100%. 

Type of institution: 4-year private nonprofit; 
Total institutions in IPEDS database: 1,326; 
GAO sample size: 88; 
Response rate for GAO Web or telephone data collection instrument: 
100%. 

Type of institution: 2-year public; 
Total institutions in IPEDS database: 1,146; 
GAO sample size: 86; 
Response rate for GAO Web or telephone data collection instrument: 
100%. 

Source: GAO analysis of IPEDS database. 

[End of table] 

Survey results based on probability samples are subject to sampling 
error. Our sample of 264 institutions is only one of a large number of 
samples we might have drawn from the total population of postsecondary 
institutions. Since each sample could have provided different 
estimates, we express our confidence in the precision of our three 
results as 95 percent confidence intervals. These are intervals that 
would contain the actual population values for 95 percent of the 
samples we could have drawn. As a result, we are 95 percent confident 
that each of the confidence intervals in this report will include the 
true values of the study population. All percentage estimates from this 
survey of 4-year public institutions, 4-year private nonprofit 
institutions, and 2-year public institutions have sampling errors not 
exceeding plus or minus 7 percentage points. 

Data Collection Methods: 

We collected data from the 264 schools primarily through a data 
collection instrument that we filled out after examining the Web sites 
of the sampled schools. Before deploying the Web site data collection 
instrument, we conducted pretests with Web sites from 5 randomly 
sampled schools. We followed up these Web site examinations with 
telephone calls to ensure that the information we were obtaining from 
the Web sites accurately reflected the transfer credit policies of the 
respective schools. 

The extent of an institution's policies on transferring credit from 
sending institutions varied widely, and the policies were found under 
different categories on the institutions' Web sites. For example, some 
institutions listed their policies under links to transfer student 
information or admissions information, while others listed their 
policies only in the college catalog/bulletin that was available at the 
Web site. Most college catalogs/bulletins listed the transfer credit 
policy. In almost all cases, we printed proof of answers and 
highlighted, underlined, or numbered the answers to match the question 
number. All results obtained from the Web site data collection 
instrument were verified by a second GAO reviewer who independently 
examined documentation from the Web site or the information on the Web 
site itself. 

All but 8 of the 264 institutions had Web sites that we were able to 
examine. For those institutions that did not have Web sites, we spoke 
with officials from the institutions and asked questions from a 
telephone data collection instrument. The results of these telephone 
interviews were recorded by GAO interviewers. 

Data Reliability Assessments: 

For this report we used data from the Integrated Postsecondary 
Education Data System database, the National Educational Longitudinal 
Study of 1988, and the Beginning Postsecondary Students longitudinal 
study database. We reviewed technical and methodological documentation 
for all three databases, and in the case of NELS also spoke with a 
research methodologist who had worked on the study. We found the data 
from the databases to be sufficiently reliable for the purposes of this 
engagement. 

[End of section] 

Appendix II: State Legislation Related to Transfer of Academic Credit: 

Alabama; Ala. Code § 16-5-8. Mandates a statewide articulation 
agreement under which all applicable credits transferred from a 2-year 
institution to a 4-year institution shall fulfill degree requirements 
at the 4-year institution as if they were earned at the 4-year 
institution. 

Alaska; None found. 

Arizona; Ariz. Rev. Stat. § 15-1824. Requires that community college 
districts and universities cooperate in operating a statewide 
articulation and transfer system, including the process of transfer of 
lower division general education credits, general elective credits, and 
curriculum requirements for approved majors, to facilitate the transfer 
of community college students to Arizona public universities without a 
loss of credit. 

Arkansas; Ark. Code Ann. § 6-53-205. Requires that the Arkansas Higher 
Education Coordinating Board develop a plan to maximize transfer 
credits of students from institutions within the system, including the 
development of a core transfer program for students desiring to obtain 
a baccalaureate degree after transferring from an institution within 
the 2-year system to the 4-year system; Ark. Code Ann. § 6-61-218. 
Requires the Arkansas Higher Education Coordinating Board to establish 
in consultation with the colleges and universities a minimum core of 
courses that shall apply toward the general education core curriculum 
requirements and that shall be fully transferable between state 
institutions; A.C. Ark. Code Ann. § 6-61-505. Gives the State Community 
College Board the duty and power to work with senior institutions of 
the state to develop the criteria for transfer of credits of students 
entering senior institutions from community colleges. 

California; Cal. Ed. Code § 66720. Requires the Board of Governors of 
the California Community Colleges, the Regents of the University of 
California, and the Trustees of the California State University to 
jointly develop, maintain, and disseminate a common core curriculum in 
general education courses for the purposes of transfer; Cal. Ed. Code § 
66730 and note. Directs the Regents of the University of California 
(UC), the Trustees of the California State University (CSU), and the 
Board of Governors of the California Community Colleges to have as a 
fundamental policy the maintenance of a healthy and expanded student 
transfer system. Community college students must have access to a 
viable and efficient transfer agreement program to the California State 
University and the University of California for upper division work 
toward a baccalaureate degree; Cal. Ed. Code § 66738. Holds the 
governing board of each public postsecondary education segment 
accountable for the development and implementation of formal systemwide 
articulation agreements and transfer agreement programs; Cal. Ed. Code 
§ 66739.5. States the intent of the legislature as ensuring that 
community colleges students who wish to earn the baccalaureate degree 
at California State University are provided with a clear and effective 
path to this degree; Cal. Ed. Code § 66740. Requires each department, 
school, and major in UC and CSU to develop, in conjunction with 
community college faculty in appropriate and associated departments, 
discipline-specific articulation agreements and transfer agreements for 
those majors that have lower-division prerequisites. 

Colorado; Colo. Rev. Stat. § 23-1-108. Requires the Colorado Commission 
on Higher Education to establish, after consultation with the governing 
boards of institutions, and enforce student transfer agreements between 
2-year and 4-year institutions and among 4-year institutions. Such 
transfer agreements shall include provisions under which institutions 
shall accept all credit hours of acceptable coursework for automatic 
transfer to another state-supported institution of higher education in 
Colorado. The commission shall also establish and enforce student 
transfer agreements between degree programs offered on the same campus 
or within the same institutional system; Colo. Rev. Stat. § 23-1-125. 
Directs the Colorado Commission on Higher Education, in consultation 
with each Colorado public institution of higher education, to outline a 
plan to implement a core course concept that defines the general 
education course guidelines for all public institutions of higher 
education; Colo. Rev. Stat. § 23-5-122. Requires the governing board of 
every state-supported institution of higher education to have in place 
and enforce policies regarding transfers by students between 
undergraduate degree programs that are offered within the same 
institution or within the same system; Colo. Rev. Stat. § 23-13-104. 
Lists statewide expectations and goals for higher education, including 
ensuring that no student's graduation is delayed due to lack of access 
to or availability of required and core courses and ensuring that 
students who change degree programs lose only those credit hours that 
clearly and justifiably cannot apply in the degree programs to which 
the student transfers. 

Connecticut; Conn. Gen. Stat. § 10a-19a. Directs the Commissioner of 
Higher Education, in consultation with the Higher Education 
Coordinating Council, to establish a statewide Advisory Council on 
Student Transfer and Articulation to maximize the transferability of 
course credits. 

Delaware; None found. 

Florida; Fla. Stat. Ann. § 1007.01. Requires the State Board of 
Education, in order to improve and facilitate articulation systemwide, 
to develop policies and guidelines with input from statewide K-20 
advisory groups established by the Commissioner of Education relating 
to a number of issues, including articulation agreements, admissions 
requirements, and the transferability of credits among institutions; 
Fla. Stat. Ann. § 1007.22. Authorizes university boards of trustees and 
community college boards of trustees to establish intrainstitutional 
and interinstitutional programs to maximize articulation. These may 
include transfer agreements that facilitate the transfer of credits 
between public and nonpublic postsecondary institutions and the 
concurrent enrollment of students at a community college and a state 
university; Fla. Stat. Ann. § 1007.23. Requires the State Board of 
Education to establish in rule a statewide articulation agreement, 
which must among other things specifically provide that every associate 
in arts graduate of a community college shall have met all general 
education requirements and must be granted admission to the upper 
division of a state university, except for certain listed programs. The 
articulation agreement must also guarantee the statewide articulation 
of appropriate courses within associate in science degree programs to 
baccalaureate degree programs. 

Georgia; None found. 

Hawaii; None found. 

Idaho; None found. 

Illinois; 110 Ill. Comp. Stat. 805/2-11. Empowers the State Board in 
cooperation with the 4-year colleges to develop articulation procedures 
to the end that maximum freedom of transfer among community colleges 
and between community colleges and degree-granting institutions be 
available. 

Indiana; Ind. Code Ann. § 20-12-0.5-8. Requires the Commission for 
Higher Education to, among other things, develop through the committee 
statewide transfer of credit agreements for courses that are most 
frequently taken by undergraduates; develop through the committee 
statewide agreements under which associate degrees articulate fully 
with related baccalaureate degree programs; and publicize by all 
appropriate means, including an Internet Web site, a master list of 
course transfer of credit agreements and program articulation 
agreements; Ind. Code Ann. § 20-12-17-2. Requires all state-supported 
universities to accept the transfer credit of all appropriate courses 
successfully completed by any student at any other state-supported 
postsecondary educational institution having the same level of 
accreditation. 

Iowa; None found. 

Kansas; Kans. Stat. Ann. § 72-4454. Requires the state board of regents 
to adopt a policy requiring articulation agreements among area 
vocational schools, area vocational-technical schools, community 
colleges, technical colleges, and state educational institutions. 

Kentucky; Ky. Rev. Stat. Ann. § 164.580. Requires the Kentucky 
Community and Technical College System to be responsive to the needs of 
students and employers to support the lifelong learning needs of 
Kentucky citizens in order to, among other things, facilitate transfers 
of credit among certificate, diploma, technical, and associate degree 
programs; Ky. Rev. Stat. Ann. § 164.583. Requires all lower-division 
academic courses offered by the community colleges to be transferable 
for academic credit to any and all 4-year public colleges and 
universities. 

Louisiana; La. Rev. Stat. Ann. § 17:3129.1. Requires postsecondary 
management boards to adopt and implement in the institutions under 
their jurisdiction common core courses that articulate from any 
institution of public higher education to any other such institution, 
taking into consideration the accreditation criteria of the institution 
receiving the credit; La. Rev. Stat. Ann. § 17:1871. Requires the Board 
of Supervisors of Community and Technical Colleges to continue 
development of articulation agreements between institutions under the 
management of the board and institutions managed by other postsecondary 
management boards, both public and private. 

Maine; Me. Rev. Stat. Ann. tit. 20-A, § 10902. States that one of the 
fundamental policies in the state's public higher educational planning 
is to provide for a uniform system of transferring credits for 
equivalent courses among the various units of the University of Maine 
system; Me. Rev. Stat. Ann. tit. 20-A, § 10907. Requires the Chancellor 
of the University of Maine system to form a committee that shall, among 
other things, establish a uniform system to facilitate the transfer of 
credits for equivalent courses among the various units of the 
University of Maine system. 

Maryland; Md. Code Ann., Education § 11-207. Lists among the duties of 
the Maryland Higher Education Commission the establishment of 
procedures for transfer of students between the public segments of 
postsecondary education and the establishment, in conjunction with the 
governing boards, of standards for articulation agreements. 

Massachusetts; Mass. Gen. Laws ch. 15A, § 9. Gives the board of higher 
education the duty and power to, among other things, develop and 
implement a transfer compact for the purpose of facilitating and 
fostering the transfer of students without the loss of academic credit 
or standing from one public institution to another. 

Michigan; None found. 

Minnesota; Minn. Stat. Ann. § 135A.052. Recognizes as one of the 
missions of postsecondary institutions that community colleges shall 
offer lower-division instruction in occupational programs in which all 
credits earned will be accepted for transfer to a baccalaureate degree 
in the same field of study; Minn. Stat. Ann. § 136F.05. Requires the 
Minnesota State Colleges and Universities Board of Trustees to develop 
administrative arrangements that make possible the efficient use of the 
facilities and staff of the technical colleges, community colleges, and 
state universities so that students may have the benefit of improved 
and broader course offerings, ease of transfer among schools and 
programs, integrated course credit, coordinated degree programs, and 
coordinated financial aid; Minn. Stat. Ann. § 135A.08. Requires the 
regents of the University of Minnesota and the trustees of the 
Minnesota State Colleges and Universities shall develop and maintain 
course equivalency guides for use by institutions that have a high 
frequency of transfer. The governing boards of private institutions 
that grant associate and baccalaureate degrees and that have a high 
frequency of transfer students are requested to participate in 
developing these guides. 

Mississippi; None found. 

Missouri; Mo. Rev. Stat. § 173.005. Requires the coordinating board for 
higher education to establish guidelines to promote and facilitate the 
transfer of students between institutions of higher education within 
the state. 

Montana; None found. 

Nebraska; Neb. Rev. Stat. Ann. § 85-1413. Requires the Coordinating 
Commission for Postsecondary Education to incorporate into the 
comprehensive statewide plan for postsecondary education, among other 
things, the facilitation of statewide transfer-of-credit guidelines to 
be considered by institutional governing boards; Neb. Rev. Stat. Ann. § 
85-963. Encourages the community college areas to work in cooperation 
with the University of Nebraska and the state colleges for the 
articulation of general academic transfer programs of the six community 
college areas. 

Nevada; Nev. Rev. Stat. Ann. § 396.568. Requires that all credits 
earned by a student in a course at a community college within the 
system must be accepted and applied toward the coursework required of 
the student in his major or minor for the award of a baccalaureate 
degree upon graduation from any university or state college within the 
system if certain criteria are met. 

New Hampshire; N.H. Rev. Stat. Ann. § 188-F:6. Requires the department 
of regional community-technical colleges and the university system of 
New Hampshire to develop mutually agreed upon transfer articulation 
agreements. 

New Jersey; N.J. Stat. Ann. § 18A:3B-8. Gives responsibility to the New 
Jersey Presidents' Council to encourage the formation of regional or 
other alliances among institutions, including interinstitutional 
transfers, program articulation, cooperative programs and shared 
resources and the development of criteria for full faith and credit 
transfer agreements between county colleges and other institutions of 
higher education. 

New Mexico; N.M. Stat. Ann. § 21-1B-3. Requires the commission on 
higher education to establish and maintain a comprehensive statewide 
plan to provide for the articulation of educational programs and 
facilitate the transfer of students between institutions. The 
commission shall define, publish, and maintain modules of lower- 
division courses accepted for transfer at all institutions; N.M. Stat. 
Ann. § 21-1B-4. Requires each institution to accept for transfer course 
credits earned by a student at any other institution that are included 
in a transfer module; N.M. Stat. Ann. § 21-1B-5. Requires the 
commission on higher education to establish and maintain a process to 
monitor and improve articulation through frequent and systematic 
consultation with institutions. The commission shall establish a 
complaint procedure for transfer students who fail to receive credit 
and investigate all articulation complaints and render decisions as to 
the appropriateness of the actions of the participants. 

New York; N.Y. Educ. Law § 351. Lists as one of the missions of the 
state university system to exercise care to develop and maintain a 
balance of its human and physical resources that promotes appropriate 
program articulation between its state-operated institutions and its 
community colleges as well as encourages regional networks and 
cooperative relationships with other educational and cultural 
institutions. 

North Carolina; 1995 Sess. Laws, c. 287, §§ 1-3. Provides for the 
development, by the Board of Governors of the University of North 
Carolina and the State Board of Community Colleges, of a plan for the 
transfer of credits among the institutions of the North Carolina 
Community College System, and between those institutions and the 
constituent institutions of the University of North Carolina, the 
intention of the General Assembly to adopt a plan for the transfer of 
credits, and the implementation, by the State Board of Community 
Colleges, of a common course numbering system; 1995 Sess. Laws, c. 625. 
Provides that the Board of Governors of the University of North 
Carolina and the State Board of Community Colleges shall develop a plan 
to provide students with information regarding the transfer of credits 
among community colleges and between community colleges and the 
University of North Carolina and shall develop a timetable for 
development of guidelines. 

North Dakota; None found. 

Ohio; Ohio Rev. Code Ann. § 3333.16. Requires the Ohio board of regents 
to establish policies and procedures applicable to all state 
institutions of higher education that ensure that students can begin 
higher education at any state institution of higher education and 
transfer coursework and degrees to any other state institution of 
higher education without unnecessary duplication; the board must also 
develop and implement a universal course equivalency classification 
system for state institutions so that the transfer of students and the 
transfer and articulation of equivalent courses are not inhibited by 
inconsistent judgment about the application of transfer credits. 
Coursework completed within such a system at one state institution of 
higher education and transferred to another institution shall be 
applied to the student's degree objective in the same manner as 
equivalent coursework completed at the receiving institution. The board 
of regents shall develop a system of transfer policies that ensure that 
graduates with associate degrees shall be admitted to a state 
institution of higher education. The board of regents shall study the 
feasibility of credit recognition and transferability to state 
institutions of higher education for graduates who have received 
associate degrees from a career college. 

Oklahoma; Okla. Stat. Ann. tit. 70, § 3207.1. States that the intent of 
the legislature is that credits earned by students in any institution 
of higher education within the Oklahoma State System of Higher 
Education be fully accepted at any other institution of higher 
education within the system. 

Oregon; Or. Rev. Stat. § 348.470. Declares that it is the policy of the 
state to encourage cooperation between the Oregon University System and 
community colleges on issues affecting students who transfer between 
the two segments and that all unnecessary obstacles that restrict 
student transfer opportunities between the two segments shall be 
eliminated; 1997 Or. Laws ch. 653, § 1. Requires the State Board of 
Higher Education to continue to work with the State Board of Education 
to develop policies and procedures to ensure maximum transfer of 
academic credits between community colleges and state institutions of 
higher education. 

Pennsylvania; 24 Pa. Cons. Stat. Ann. § 15-1504-A. Requires the 
Department of Education and the Office of Administration to establish 
management teams to distribute funds appropriated for the researching, 
planning, and development of the Pennsylvania Education Network, which 
can include, when appropriate, implementing a Web-based application 
that makes all articulation agreements among higher education 
institutions available on the Internet. 

Rhode Island; R.I. Gen. Laws § 16-45-1.1. Requires vocational programs 
to be organized for maximum articulation between educational levels. 

South Carolina; S.C. Code Ann. § 59-52-100. Requires the State Board of 
Technical and Comprehensive Education and the Council of College 
Presidents, through the Commission on Higher Education, to clarify and 
strengthen articulation agreements between associate degree programs 
and baccalaureate degree programs. 

South Dakota; S.D. Codified Laws § 13-53-43. Requires that all general 
education credit hours fulfilling graduation requirements in 
institutions accredited by the North Central Association of Colleges 
and Secondary Schools be transferable between the universities under 
the control of the South Dakota Board of Regents and the technical 
institutes governed by the South Dakota Board of Education. General 
education course credit hours are transferable between the technical 
institutes and universities only for credit for general education 
courses. 

Tennessee; Tenn. Code Ann. § 49-7-202. Requires the Tennessee Higher 
Education Commission to establish and ensure that all postsecondary 
institutions in Tennessee cooperatively provide for an integrated 
system of postsecondary education. The commission shall guard against 
inappropriate and unnecessary conflict and duplication by promoting 
transferability of credits and easy access of information among 
institutions. 

Texas; Tex. Educ. Code Ann. § 61.822. States that if a student 
successfully completes the core curriculum at an institution of higher 
education, that block of courses may be transferred to any other 
institution of higher education and must be substituted for the 
receiving institution's core curriculum. A student shall receive 
academic credit for each of the courses transferred and generally may 
not be required to take additional core curriculum courses at the 
receiving institution; Tex. Educ. Code Ann. § 61.823. States that if a 
student successfully completes a field of study curriculum developed by 
the board, that block of courses may be transferred to a general 
academic teaching institution and must be substituted for that 
institution's lower division requirements for the degree program for 
the field of study into which the student transfers, and the student 
shall receive full academic credit toward the degree program for the 
block of courses transferred; Tex. Educ. Code Ann. § 61.831. States 
that it is the purpose of the statutory subchapter on transfer of 
credit to develop a seamless system of higher education with respect to 
student transfers between institutions of higher education, including 
student transfers from public junior colleges to general academic 
teaching institutions. 

Utah; Utah Code Ann. § 53B-6-105.5. Requires the Technology Initiative 
Advisory Board to provide the State Board of Regents with an assessment 
and reporting plan that includes an analysis of program articulation 
among higher education institutions in engineering, computer science, 
and related technology; Utah Code Ann. § 53B-16-105. Requires the Board 
of Regents to facilitate articulation and the seamless transfer of 
courses within the state system of higher education; develop, 
coordinate, and maintain a transfer and articulation system within the 
state system of higher education that allows students to transfer 
courses among institutions of higher education to meet requirements for 
general education and lower-division courses that transfer to 
baccalaureate majors and facilitates student acceleration and the 
transfer of students and credits between institutions; and identify 
common prerequisite courses and course substitutions for degree 
programs across all institutions of higher education. 

Vermont; None found. 

Virginia; Va. Code Ann. § 23-9.6:1. Gives the State Council of Higher 
Education the duty, responsibility, and authority to facilitate the 
development of dual admissions and articulation agreements between 2- 
and 4-year public and private institutions of higher education in 
Virginia. Such agreements shall be subject to the admissions 
requirements of the 4-year institutions; Va. Code Ann. § 23-9.14:2. 
Requires the State Council of Higher Education to develop, in 
cooperation with the governing boards of the public 2-and 4-year 
institutions of higher education, a State Transfer Module that 
designates those general education courses that are offered within 
various associate degree programs at the public 2-year institutions 
that are transferable for credit or admission with standing as a junior 
to the public 4-year institutions. In developing such module, the 
council shall also seek the participation of private institutions of 
higher education. The council shall also facilitate the development of 
dual admissions and articulation agreements between the state's public 
and private 2-and 4-year institutions of higher education, which are 
subject to the admissions requirements of the 4-year institutions. The 
council shall make public all general education courses offered at 
public 2-year institutions and designating those that are accepted for 
purposes of transfer for course credit at 4-year public and private 
institutions of higher education in Virginia. 

Washington; Wash. Rev. Code Ann. § 28B.45.014. Requires higher 
education branch campuses to collaborate with the community and 
technical colleges in their region to develop articulation agreements 
to ensure that branch campuses serve as innovative models of a two plus 
two educational system. Areas of collaboration include joint 
development of curricula and degree programs; Wash. Rev. Code Ann. § 
28B.76.240. Requires the higher education coordinating board to adopt 
statewide transfer and articulation policies that ensure efficient 
transfer of credits and courses across public 2-and 4-year institutions 
of higher education. The intent of the policies is to create a 
statewide system of articulation and alignment between 2-and 4-year 
institutions; Wash. Rev. Code Ann. § 28B.76.2401. States that the 
statewide transfer of credit policy and agreement must not require or 
encourage the standardization of course content or prescribe course 
content or the credit value assigned by any institution to the course. 
Policies adopted by public 4-year institutions concerning the transfer 
of lower-division credit must treat students transferring from public 
community colleges the same as students transferring from public 4-year 
institutions; Wash. Rev. Code Ann. § 28B.76.250. Requires the higher 
education coordinating board to convene work groups to develop transfer 
associate degrees that will satisfy lower-division requirements at 
public 4-year institutions of higher education for specific academic 
majors. Each transfer associate degree developed under this section 
must enable a student to complete the lower-division courses or 
competencies for general education requirements and preparation for the 
major that a direct-entry student would typically complete in the 
freshman and sophomore years for that academic major. Completion of a 
transfer associate degree does not guarantee a student admission into 
an institution of higher education; Wash. Rev. Code Ann. § 28B.720. 
Requires the higher education coordinating board, in consultation with 
the state board for community and technical colleges and the council of 
presidents, to recruit and select institutions of higher education to 
participate in a pilot project to define transfer standards in selected 
academic disciplines on the basis of student competencies. Under the 
pilot project, participants shall develop standards, definitions, and 
procedures for quality assurance for a transfer system based on student 
competencies. 

West Virginia; W. Va. Code Ann. § 18B-2B-6. Lists among the powers and 
duties of the West Virginia Council for Community and Technical College 
Education to establish and implement policies and procedures to ensure 
that students may transfer and apply toward the requirements for a 
degree the maximum number of credits earned at any regionally 
accredited in-state or out-of-state higher education institution; to 
cooperate with the governor's P-20 council of West Virginia to remove 
barriers relating to transfer and articulation between and among 
community and technical colleges, state colleges and universities, and 
public education, and to implement a policy jointly with the commission 
whereby any course credit earned at a community and technical college 
transfers for program credit at any other state institution of higher 
education and is not limited to fulfilling a general education 
requirement. 

Wisconsin; Wis. Stat. Ann. § 36.11. Lists among the powers and duties 
of the board of regents to establish policies for the appropriate 
transfer of credits between institutions within the system, to 
establish policies for the appropriate transfer of credits with other 
educational institutions outside the system, and to establish and 
maintain a computer-based credit transfer system that shall include all 
transfers of credit between institutions within the system and other 
courses for which the transfer of credits is accepted. 

Wyoming; Wyo. Stat. Ann. § 21-16-602. Requires the Wyoming Education 
Planning and Coordination Council to facilitate cooperative 
arrangements among state education institutions in the sharing of 
facilities, personnel, and technology or otherwise assist in 
articulation between the institutions. 

Source: GAO analysis of state legislation. 

[End of table] 

[End of section] 

Appendix III: Comments from the Department of Education: 

UNITED STATES DEPARTMENT OF EDUCATION: 
OFFICE OF POSTSECONDARY EDUCATION: 
THE ASSISTANT SECRETARY: 

OCT 6 2005: 

Ms. Cornelia M. Ashby: 
Director, Education, Workforce, and Income Security Issues: 
United States Government Accountability Office: 
Washington, DC 20548: 

Dear Ms. Ashby: 

Thank you for providing the Department of Education with a copy of the 
U.S. Government Accountability Office's (GAO) draft audit report 
entitled "Transfer Students: Postsecondary Institutions Could Promote 
More Consistent Consideration of Coursework by Not Basing 
Determinations on Accreditation" (GAO-06-22). We have reviewed the 
draft report and have the following comments. 

We appreciate your examining a complex subject area the processes and 
requirements that colleges, universities, and other postsecondary 
education institutions have established to assess requests by students 
to transfer their academic credits-and providing very useful 
information. We found your description of the legislative and 
administrative efforts by states to facilitate the credit transfer 
process especially informative. 

We appreciate your examination of this important issue and look forward 
to receiving a copy of the final report when it is issued. 

Sincerely, 

Signed by: 

Sally L. Stroup: 

[End of section] 

Appendix IV: GAO Contacts and Staff Acknowledgments: 

GAO Contacts: 

Cornelia M. Ashby; (202) 512-7215 or ashbyc@gao.gov. 

Staff Acknowledgements: 

Bryon Gordon, Assistant Director: 

Anjali Tekchandani: Analyst-in-Charge: 

In addition to those mentioned above, Elizabeth Bax, Richard Burkard, 
Sara Edmondson, Jonathan S. McMurray, John Mingus, James Rebbe, Walter 
Vance, and Ann T. Walker made significant contributions to this report. 

FOOTNOTES 

[1] Integrated Postsecondary Education Data System, U.S. Department of 
Education. 

[2] Less than 1 percent of postsecondary institutions specified that 
accreditation is not considered, while about 15 percent did not specify 
whether or not accreditation was considered or the information was not 
available. 

[3] Many institutions' policies toward national accreditation were 
unclear and did not specifically refer to national accreditation as 
unacceptable. For example, one institution's credit transfer policy 
said, "The institution will consider courses from postsecondary 
institutions that are regionally accredited or are candidates for 
regional accreditation." In this case (and in cases that were similar 
to this), we considered the policy on national accreditation to be 
unspecified. 

[4] CHEA is a nonprofit organization that certifies accrediting 
agencies. 

[5] About 29 percent of institutions had not specified whether they had 
transfer agreements, and the rest, about 2 percent, had no transfer 
agreements. 

[6] Participating organizations include the American Association of 
Community Colleges (AACC), American Council on Education (ACE), 
American Indian Higher Education Consortium (AIHEC), Council of the 
Great City Schools (CGCS), Hispanic Association of Colleges and 
Universities (HACU), National Association for Equal Opportunity in 
Higher Education (NAFEO), American Association of State Colleges and 
Universities (AASCU), and the United Negro College Fund (UNCF). 

[7] The 42-hour block of general education is required of public 
institutions and recommended for private institutions in the state. 

[8] Unlike California's and Maryland's systems, which are devoted to 
transfer information, Florida's FACTS system assists users in 
determining career objectives, choosing the major and institutions that 
are best suited for them, applying for admission and financial aid, and 
tracking their progress toward a degree or certificate. In addition, it 
allows students to access their grades and transcripts online. 

[9] The joint statement was developed by the three national 
associations whose member institutions are directly involved in the 
transfer and award of academic credit: the American Association of 
Collegiate Registrars and Admissions Officers, the American Council on 
Education, and the Council for Higher Education Accreditation. 

[10] We reviewed accrediting standards of the 6 regional accrediting 
agencies that accredit senior institutions (i.e., those that grant 
bachelor's degrees) and the 10 national accrediting agencies that 
accredit degree-granting institutions, rather than programs. 

[11] Wright, M. Irene, and others, Articulation and Transfer: 
Definitions, Problems, and Solutions. Tempe, Arizona: Maricopa County 
Community College District (January 1996).The study was published prior 
to the enactment of Arizona's legislation that required state 
institutions to operate a statewide transfer network. 

[12] National Education Longitudinal Study, 1988-1994, U.S. Department 
of Education, National Center for Education Statistics. 

[13] Beginning Postsecondary Students Longitudinal Study: 1996-2001, 
U.S. Department of Education, National Center for Education Statistics 

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