Policy Influences

This guide presents examples that the 12 public institutions in the No Holding Back project identified of the types of federal, state, governing system, and other policy and external influences that frame their usage of holds. These examples can provide useful insights for other institutions considering an assessment of their own holds policies and practices.

Some holds are codified in legislation, regulation, or documented policy at a federal or state level. And holds may be influenced by other overarching initiatives such as statewide or higher education system completion, or transfer campaigns. At an institutional level, policies referring to registration or transcripts are often reflected in the academic and administrative regulations and procedures. These policies are publicized for students and are often replications or duplications of higher-level federal, state, or system source policies.

The examples offered by institutions in the No Holding Back project suggested that holds usage and implementation may be less likely to be codified and often relies instead on institutions’ best interpretations and discretionary decisions for implementation of the source policy.

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There may be regulated holds, but those that are non-regulated provide more discretion for possible alternatives and approaches to get students to do something that is needed.

Flathead Valley Community College

An assessment of administrative holds usage must include both a systematic inventory of, and an understanding about, the policies, regulations, administrative requirements, and institutional guidance governing holds. From this, institutions may also discover where there is discretion in the use of holds, and where there is possibility for improvement.

There is wide variation in what external policies and factors influence an institution’s usage of holds. Users of this guide can consult existing policy research, as it does not identify every possibly relevant policy or provide legal interpretation of policies or regulations. But, the examples articulated by the 12 public institutions in the No Holding Back project may inform a methodical inventory of holds-influencing policies and factors.

See more in the detailed PDF.

Some holds may be codified by or derived from state legislation or regulation. For example, institutions may place holds on registration or transcripts to administer, manage, and comply with requirements such as these:

Requirements for satisfactory academic progress, such as those related to federal financial aid, military tuition assistance, scholarships, and grants (see, for example, considerations about aid timing in the video animation of perspectives from a community college military veteran student).

Requisites for financial aid application, eligibility, and renewal requirements, such as for the Free Application for Federal Student Aid (FAFSA®).

[This university] has hold types to address immigration requirements for international students, and exit interview requirements for federal loans.

University of Nevada, Las Vegas

See more in the detailed PDF.

Policies for the administration of state or institutional aid can also reflect or satisfy similar federal requirements. Other examples where institutions may use holds to reflect state legislation or regulations include:

For example, No Holding Back project participants located in California, Colorado, Oregon, and Washington, were subject to existing and forthcoming state restrictions on transcript holds during this project. Specific restrictions vary, but they typically limit, restrict or define institutions’ use of transcript holds as part of debt collections.

Debt collection regulations are closely associated with the use of transcript holds, and they may be codified by other state or educational system regulations.

Policy makers and institutions may need to attend to more than one policy as related policies are revised, to prevent unintended consequences, and to optimize the potential for improvement.

Immunization and communicable disease policies may also govern the use of holds in certain jurisdictions.

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Institutions may be subject to regulations and policies from state higher education agencies or systems of higher education. These policies may originate from state legislation or from higher education governance bodies.

For public institutions, system-wide conversations are highly recommended, including discussing strategies and solutions with colleagues from other institutions in the state system, who are familiar with the state’s context and policies.

University of Nevada, Las Vegas

See more in the detailed PDF.

Policy makers and planners may wish to evaluate whether holds are associated with other overarching initiatives or alliances, including for example:

Strategic priorities around student success, enrollment, and loan forgiveness initiatives.

Institutions in the No Holding Back project did not specifically find any holds derived from accreditation-related policies, but several institutions referred to accreditation standards, like those set forth by the Northwest Commission on Colleges and University (NWCCU), which address mobility of transfer credit, student success and the closure of equity gaps. Such standards may support the limited use of transcript holds and allowing for temporary removal of transcript holds for students wishing to transfer.

Other overarching factors, initiatives or alliances may be associated with holds, including institutional guidance around distance education, out-of-state enrollments, and cross-state tuition reciprocity and discount options.

By and large, the institutions in this project did not cite institutional policies as examples of codified or documented policies that influence their use of holds. The ‘institutional policies’ described by project participants often appeared to be the institutions’ duplicate representation of higher-level regulations, presented in the form of academic and administrative regulations and procedures. These policies were typically publicized in the college catalog, student handbook, or other materials.

Based on our experience, institutions should prepare themselves for possibly unwelcome or unexpected findings. More often than not, student holds reflect long-standing and unwritten practices adopted by departments and administrative units with very little oversight, rather than existing in written policy.

University of Nevada, Las Vegas


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