A Step Forward for Transfer of Credit: What the AIM Rule Gets Right and What Comes Next

By Dr. Monty Sullivan, President of Rebuilding America’s Middle Class (RAMC) and Acting President of the North Carolina Community College System

This past spring, I was selected to represent public institutions of higher education on the U.S. Department of Education’s (ED) Accreditation, Innovation and Modernization (AIM) Negotiated Rulemaking Committee. As the representative for all public institutions of higher education, I supported the AIM Committee in coming to consensus on the proposed regulations, including provisions to improve the transfer of credit process. The consensus agreement would change the presumption that transfer credits be accepted unless the institution to which the student is transferring provides a written basis for a denial. Institutions would also be required to provide a student with an opportunity to appeal a decision to deny transfer credits. This new policy, once promulgated in final form, is an important first step that needs to be built upon by institutional implementation and practice.

This issue is personal for me and the institutions I represent because, for far too long, the process of transferring credits has been overly burdensome, especially for community college students, making it difficult for them to receive the full benefits of the credits they have completed. The language related to transfer of credit puts students first by preventing colleges from rejecting credits from another college based on the type of institution or the accreditor that oversees it and by creating a simple pathway for students to appeal if credits are denied. This marks a strong first step towards ensuring that students are recognized for the coursework that they are completing. This will be especially impactful for the low-income and working students that we serve since these regulations will reduce the economic and time burdens that often accompanies the process of transferring credits.

While these efforts demonstrate meaningful progress on this issue, further action is necessary to ensure this proposed rule achieves its intended impact. Without institutional dedication to implementing the transfer standards adopted by their accreditors, the intent behind ED’s regulatory language will fall short, and students will continue to face unnecessary costs and delays in completing their education. Institutions must take the requirement to implement these policies seriously and with fidelity so the confusing and burdensome transfer process we have now can be changed to help students complete and enter the workforce faster, providing them with a path to the middle class.

That is why it is critical that the responsibility for improving the transfer of credit process be shared across all institutions of higher education, regardless of whether they are two-year or four-year, public, private, or nonprofit. We must all work together to implement the regulations put forth by ED while continuing to build on this language and identify additional ways to improve the transfer process for students across the country.