Parchment and California Legislation on Transcripts and Financial Holds

We’ve heard many questions from our members on the recently passed California legislation, Assembly Bill No. 1313 Educational Debt Collection Practices Act, which has a direct impact on those that are responsible for transcripts at their institution. If you haven’t taken the time to do so, push pause on reading this blog post and take a minute to review AB 1313 for yourself here.

Here is an extracted excerpt of the bill: …a school shall not do any of the following:

(a) Refuse to provide a transcript for a current or former student on the grounds that the student owes a debt.
(b) Condition the provision of a transcript on the payment of a debt, other than a fee charged to provide the transcript.
(c) Charge a higher fee for obtaining a transcript, or provide less favorable treatment of a transcript request because a student owes a debt.
(d) Use transcript issuance as a tool for debt collection.

Given the number of Parchment members in California, the number of questions that we’ve received, and our commitment to the community, we took some time to sit down with an industry expert on how their institution is handling AB 1313.

We’ve approached this as a Q&A, at the end of the post you’ll have the opportunity to submit additional questions; we’ll either get back to you individually, or post the answer by updating this post.

• Give us some background and context on your institution. Loma Linda University is a faith-based health sciences institution located in southern California.  We are mainly a graduate/professional institution and 100% of our students are transfer (no first-time freshmen).  Our more than 4,400 students in eight schools share the campus with six hospitals where they receive hands-on training, along with opportunities in local and international clinics.
• Erin, did you know about AB 1313 before it was passed by the California legislature? Yes.  It was on the radar of our Director of Student Finance and between him and our Director of Financial Aid we were kept apprised of where it was in the legislative process.
• Once Assembly Bill 1313 passed, who did you start talking within your organization? Within two weeks of the signing of the bill on October 18 we held a general meeting and invited Student Finance (Bursar and Campus-based loans), IT, University Records, and our CFO to talk through the implications of losing the ability to collect debts via transcript holds.
• Is there any particular processes at your institution that AB 1313 impacts? Yes.  We have multiple holds added to student accounts to help students and alumni follow up on financial obligations.  These holds currently prevent the fulfillment of requests for academic transcripts, degree verifications, and diplomas.

As of January 1, 2020, AB 1313 states these holds can no longer prevent a transcript request from being fulfilled.  As other institutions may have also recognized, this legislation mostly impacts our campus-based loans, as that is an institutional liability that can no longer be mitigated by withholding transcripts.  In the past, we have been able to encourage payment plans and other options to get alumni back on track with loan repayment, but now there needs to be other ways of recouping debt. We are still in conversation about what we will do in that vein.

The first step was to identify all of the holds in the system that (1) are used for financial reasons and (2) prevent the release of transcripts.  This was a larger list than we anticipated as some holds are administered by the schools, some by the university, and some by financial officers. We then reviewed the list and set up a process with IT to mark those holds as “null” for all academic transcript requests starting January 1, 2020.

A key understanding we came to was that we are still going to add the holds to the student accounts in our usual practice to ensure other processes work as needed, we just need to turn off the hard stop for transcript requests.  Because this process affects how holds work, it was highly important for IT to be at the table and part of the conversation.

• This legislation is specific to transcripts, are you changing anything for diplomas and verifications? No, we are only changing the way financial holds affect requests for academic transcripts.  We’re going to change the information we send to Parchment to ensure transcripts are not held for financial reasons.  Again, an important role for our incredible IT team to fill.
• Is this institution specific or student specific? We are taking a read of AB 1313 that because we are in California, it is applicable to all students.  That makes it pretty cut and dry for us.
• Will you be creating a new hold type for “California Residents”? No, since we are located in California we are treating all transcript requests the same regardless of state residence.

So let’s turn the table, what questions do you have for Parchment.

• What have you heard from other member institutions and how they are approaching a solution to AB 1313? We have heard from several institutions who are taking different approaches. Some are taking no action at all. Others are removing financial holds for students and alumni who have an address in California. Our recommendation stands that institutional leaders should review the policy with campus general counsel.
• What principles come to mind for Parchment in the context of AB 1313? The number one goal is ease of use, installation, configuration, and maintenance for our members. Our member institutions maintain full control and continuity of their transcript processes. In the same way, the member institution SIS remains the ultimate authority and custodian of their learner records.
• How do the Parchment Connectors work? At the highest level they function as a broker between the Parchment platform and your SIS. Hold checks can occur pre or post ordering, but regardless, Parchment works to configure the system to fit the business workflows in place. This includes respecting any transcript impacting holds. In the event the connector locates a hold, the learner is notified and the order is not processed. It’s common to maintain a number of different hold types with specific messaging regarding remediation steps for learners.
• As it relates to AB 1313, is Parchment changing anything in its process to circumvent any financial holds on the student record in the SIS? No, we are not changing processes as it relates to AB 1313. If a transcript impacting hold is removed in your SIS, the connector simply won’t locate the hold and insert the request for standard processing.
• Where do I go if I have more questions for Parchment about AB 1313? Please submit those questions to info@parchment.com

In summary, review the legislation here, talk to key stakeholders on campus, determine your institutional policy in response to the aforementioned legislation, and as applicable make updates your student information system. There are no configuration requirements required to the Parchment Connectors.

There’s always more to learn.