HIGHER EDUCATION

Students Need More 

Information to Help 

Reduce Challenges in 

Transferring College 

Credits

Report to Congressional Requesters

August 2017

GAO-17-574

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-17-574, a report to 

congressional requesters

August 2017

HIGHER EDUCATION

Students Need More Information to Help Reduce 

Challenges in Transferring College Credits 

What GAO Found 

Based on GAO’s analysis of the Department of Education’s (Education) most 

recently available data, an estimated 35 percent of college students transferred 

to a new school at least once from 2004 to 2009, and GAO found that students 

may face challenges getting information or advice about transferring course 

credits. An estimated 62 percent of these transfers were between public schools. 

According to stakeholders GAO spoke with, students can face challenges 

transferring credits between schools that do not have statewide polices or 

articulation agreements, which are transfer agreements or partnerships between 

schools designating how credits earned at one school will transfer to another. 

Stakeholders also said that advising and information may not be adequate to

help students navigate the transfer process. 

The possible financial implications of transferring depend in part on the extent of 

credits lost in the transfer. Using Education’s transfer data, GAO estimated that

students who transferred from 2004 to 2009 lost, on average, an estimated 43 

percent of their credits, and credit loss varied depending on the transfer path. For 

example, students who transferred between public schools—the majority of 

transfer students—lost an estimated 37 percent of their credits. In comparison, 

students who took some of the less frequent transfer paths lost a relatively 

higher percentage of their credits. For example, students who transferred from 

private for-profit schools to public schools accounted for 4 percent of all transfer

students but lost an estimated 94 percent of their credits. Transferring can have 

different effects on college affordability. Students seeking to obtain a bachelor’s 

degree at a more expensive school may save on tuition costs by transferring

from a less expensive school. On the other hand, transfer students may incur 

additional costs to repeat credits that do not transfer or count toward their 

degree. Transfer students can receive federal financial aid. GAO’s analysis 

showed that almost half of the students who transferred from 2004 to 2009

received Pell Grants and close to two-thirds received Federal Direct Loans. 

Students who lose credits may use more financial aid to pay for repeated 

courses at additional cost to the federal government, or they may exhaust their 

financial aid eligibility, which can result in additional out-of-pocket costs. 

While GAO estimated that the websites for almost all schools nationwide 

provided credit transfer policies, as required by Education, about 29 percent did 

not include a list of other schools with which the school had articulation 

agreements. Among those schools, GAO found that some did not have any 

articulation agreements, while others did but did not list partner schools on their 

websites. Schools must provide such listings, but they are not required to do so 

specifically on their website. As a result, students may not have ready access to 

this information to fully understand their transfer options. Moreover, Education

provides limited transfer information to students and their families, contrary to 

federal internal control standards that call for agencies to provide adequate 

information to external parties. General information on key transfer 

considerations that are applicable across schools and more complete information 

on schools’ articulation agreements can help students avoid making uninformed 

transfer decisions that could add to the time and expense of earning a degree.

View GAO-17-574. For more information, 

contact Melissa Emrey-Arras at (617) 788-

0534 or emreyarrasm@gao.gov.

Why GAO Did This Study

College students sometimes opt to 

transfer schools in response to 

changing interests or for financial 

reasons. The extent to which students

can transfer previously earned course 

credits can affect the time and cost for 

completing a degree. Given the federal

government’s sizeable investment in 

student aid—$125 billion in fiscal year 

2016—and potential difficulties 

students may face in transferring 

credits, GAO was asked to examine 

the college transfer process. 

GAO examined (1) transfer rates and 

challenges students face in transferring 

credits, (2) the possible financial 

implications of transfer, and (3) the 

extent to which students are provided

with transfer information to help them 

plan their college path. GAO analyzed 

Education’s data, including its most 

recent available transfer data from the 

2004-2009 student cohort, interviewed 

a non-generalizable sample of 

stakeholders from 25 schools and 

higher education organizations, and 

reviewed a nationally-representative 

sample of 214 school websites.

What GAO Recommends

GAO recommends that Education (1) 

require schools to disclose on their 

websites (a) the list of other schools 

with which they have articulation 

agreements and (b) when no such 

agreements are in place; and (2) 

provide general transfer information to 

students and families. Education 

disagreed with the first and agreed with 

the second recommendation. GAO 

maintains that students can more 

easily understand transfer options if 

information is accessible on a school’s 

website, as discussed in the report.
Page i GAO-17-574 College Credit Transfer

Letter 1

Background 3

About a Third of College Students Transferred Schools from 2004 

to 2009; Students May Face Challenges in Transferring Credits 7

Credits Lost in a School Transfer Could Result in Additional 

Tuition Costs and Limited Financial Aid Eligibility for Students 15

Almost All Schools Provided Credit Transfer Policies on Websites, 

but Comprehensiveness of Information Varied 29

Conclusions 37

Recommendations for Executive Action 37

Agency Comments and Our Evaluation 38

Appendix I Objectives, Scope, and Methodology 40

Appendix II Example of Implementing an Articulation Agreement 

through a Transfer Guide 48

Appendix III Additional Information on Credit Loss and Tuition Averages, 

and Additional Examples of Transfer Scenarios 49

Appendix IV Comments from the Department of Education 55

Appendix V GAO Contact and Staff Acknowledgments 57

Tables

Table 1: Select Federal Student Aid Program Characteristics in 

Fiscal Year 2016 6

Table 2: Estimated Percentage of First-Time College Students 

Who Transferred by Type of First School, Academic 

Years 2003-04 to 2008-09 8

Table 3: Estimated Percentage of Credits Lost in Transfer, on 

Average, by School Type, Academic Years 2003-04 to 

2008-09 49

Contents
Page ii GAO-17-574 College Credit Transfer

Table 4: Estimated Percentage of Credits Lost in Transfer, on 

Average, by Transfer Direction, Academic Years 2003-04 

to 2008-09 50

Table 5: Estimated Percentage of Credits Lost in Transfer, on 

Average, by Transfer Path, Academic Years 2003-04 to 

2008-09 51

Table 6: Estimated Average Net Tuition by School Type, 

Academic Year 2013-14 52

Table 7: Estimated Percentage of Transfer Students Who Did Not 

Obtain a Degree by Transfer Direction, Academic Years 

2003-04 to 2008-09 53

Figures

Figure 1: Estimated Percentage of Transfer Students by Transfer 

Path, Academic Years 2003-04 to 2008-09 9

Figure 2: Estimated Percentage of Credits Lost in Transfer, on 

Average, by School Type, Academic Years 2003-04 to 

2008-09 16

Figure 3: Estimated Percentage of Credits Lost in Transfer, on 

Average, by Transfer Path, Academic Years 2003-04 to 

2008-09 18

Figure 4: Examples of Potential Outcomes for Students 

Transferring from a Less Expensive to a More Expensive 

School 20

Figure 5: Transfer Scenarios and Potential Financial Implications 

for Students 23

Figure 6: Transfer Scenario and Potential Costs to the 

Government in Student Financial Aid 27

Figure 7: Estimated Percentage of School Websites Listing 

Partner Schools for Transfer Articulation Agreements, by 

School Type 31

Figure 8: Estimated Percentage of School Websites with 

Additional Transfer-Related Information 34

Figure 9: Example of a Transfer Guide Based on an Articulation 

Agreement 48

Figure 10: Additional Transfer Scenarios and Potential Financial 

Implications for Students 54
Page iii GAO-17-574 College Credit Transfer

Abbreviations 

BPS Beginning Postsecondary Students Longitudinal Study 

Education Department of Education 

IPEDS Integrated Postsecondary Education Data System 

This is a work of the U.S. government and is not subject to copyright protection in the 

United States. The published product may be reproduced and distributed in its entirety 

without further permission from GAO. However, because this work may contain 

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Page 1 GAO-17-574 College Credit Transfer

441 G St. N.W.

Washington, DC 20548

August 14, 2017

The Honorable Rosa DeLauro

Ranking Member

Subcommittee on Labor, Health and Human Services, Education, and 

Related Agencies

Committee on Appropriations

House of Representatives

The Honorable Richard Durbin

United States Senate

The Honorable Brian Schatz

United States Senate

Students may opt to transfer schools in response to changing interests or 

for financial reasons, though the path to obtain a college degree can be 

complicated if a student decides to transfer.1 As part of the transfer 

process, destination schools determine whether to accept the course 

credits earned at a student’s previous school, and any loss of credits 

affects a student’s progress and costs in earning a degree. In addition, 

school closures in recent years have affected thousands of students, 

leaving many of them with credits but no degree. The extent to which 

students can transfer their credits from one school to another can thus 

affect their ability to complete a degree at an affordable cost. To help 

students pay for college, the federal government provided approximately 

$125 billion in financial aid to college students in fiscal year 2016.

In light of the federal government’s investment in student financial aid and 

the potential difficulty some students may face in transferring credits, you 

asked us to examine the college transfer process. This report answers 

the following questions:

1. How many college students transfer and what challenges, if any, do 

they face in transferring credits?

2. What are possible financial implications associated with transferring 

credits?

 1 In this report we use the term “college” or “school” to refer to all types of postsecondary 

education institutions.

Letter
Page 2 GAO-17-574 College Credit Transfer

3. To what extent are students provided with information about transfer 

policies to help them plan their college path?

To address these questions, we used a variety of methods. To estimate 

how many college students transfer, we analyzed transfer rate data from 

the Department of Education’s (Education) most recently completed 2004 

to 2009 Beginning Postsecondary Students Longitudinal Study (BPS) and 

mid-point data from the 2012 to 2017 BPS study, which has not yet been 

completed. To examine any challenges students face in transferring 

credits, we obtained perspectives from a range of knowledgeable 

stakeholders from 25 higher education organizations and schools. 

Specifically, we interviewed representatives from 17 higher education 

organizations and officials from eight schools.2 We selected higher 

education organizations based on their expertise in researching or 

developing guidance on transfers and their representation of relevant 

groups, including students. To ensure we obtained perspectives from 

different types of schools, we selected a mix of public, private nonprofit, 

and private for-profit schools, and 2- and 4-year schools. We then 

interviewed admissions/advising staff, registrar officials, and transfer 

offices, as appropriate, from the eight selected schools. In addition to 

these interviews with stakeholders from higher education organizations 

and schools, we collected some first-hand accounts from several 

individual transfer students who were identified for us by stakeholders 

from higher education organizations. The views we obtained were not 

generalizable.

To analyze any potential financial implications associated with 

transferring credits, we estimated credit loss rates and financial aid 

receipt for transfer students using the most recent available transcript 

data from the 2004 to 2009 BPS study. We supplemented this data with 

mid-point data from the ongoing 2012 to 2017 BPS study, as appropriate. 

We used the Integrated Postsecondary Education Data System (IPEDS) 

to calculate average tuition by school type to inform illustrative examples 

of potential cost implications of credit loss. We assessed the reliability of 

BPS and IPEDS data by reviewing survey documentation and 

interviewing officials knowledgeable about the data. We determined that 

the data were sufficiently reliable for our purposes.

 2 In this report, higher education organizations refer to organizations or associations that 

conduct relevant higher education policy research or represent relevant groups involved in 

the transfer process. For example, selected organizations included higher education 

research centers; associations that represented certain school types, such as community 

colleges; and organizations that work with state policymakers.
Page 3 GAO-17-574 College Credit Transfer

To determine the extent to which schools provided students with transfer 

information to help them plan their college path, we reviewed the 

websites for a nationally-representative stratified random sample of 214 

schools participating in federal student aid programs. We also reviewed 

relevant federal law and Education’s guidance and regulations on credit 

transfer disclosure requirements and consumer information for college 

students, and we compared Education’s practices to federal internal 

control standards. Lastly, we reviewed relevant studies and interviewed 

Education officials. See appendix I for more information on our objectives, 

scope, and methodology.

We conducted this performance audit from March 2016 to August 2017 in 

accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.

Students’ pursuit of a college degree may include transferring from one 

school to another. Students typically transfer from a 2-year school to a 4-

year school, a direction known as a vertical transfer. Students can also 

transfer from a 4-year school to a 2-year school, known as a reverse 

transfer, or laterally transfer between similar schools (e.g., 2-year to 2-

year or 4-year to 4-year). Students can transfer for different reasons, 

depending on their goals and the type of transfer involved. For example, if 

a student is seeking to obtain a degree from a relatively expensive 

school, transferring credits from a less expensive school could help them 

save on tuition costs. Students may transfer vertically to facilitate 

completion of a bachelor’s degree. Alternatively, students may initiate a 

reverse transfer in order to complete an associate’s degree. Further, 

students who transfer laterally may do so to find a better institutional fit or 

a degree program that more closely aligns with their goals.

Colleges also vary with respect to governance structure, length of degree 

programs, and other characteristics. Public schools are generally 

operated by publicly elected or appointed officials. Private schools are 

operated by individuals or agencies other than governmental entities. 

Further, private schools can be nonprofit or for-profit entities. Private 

nonprofit schools are traditionally operated by independent or religious 

organizations and earnings do not benefit any shareholder or individual, 

whereas private for-profit schools are owned and operated by private 

Background
Page 4 GAO-17-574 College Credit Transfer

organizations and earnings can benefit shareholders or individuals. 

Schools are also classified by whether they offer degree programs that 

are 4 years or 2 years in duration. In this report, we refer to six school 

types: 2-year public, 2-year private nonprofit, 2-year private for-profit, 4-

year public, 4-year private nonprofit, and 4-year private for-profit.

A student who wants to transfer credits generally must provide the 

destination school with a transcript of previously earned credit. 

Destination schools generally have discretion in determining whether to 

accept these credits and use various criteria to evaluate them. Criteria 

can include, for example, a minimum grade requirement, the quality of the 

student’s coursework, the level and content of the coursework compared 

to similar courses at the destination school, and the applicability of a 

course to the degree or programs at the destination school.

Many schools enter into voluntary transfer agreements or partnerships 

with each other—broadly referred to as articulation agreements—which 

specify how transferred course credits meet program or degree 

requirements among those schools. Additionally, states can establish 

statewide articulation agreements as well as credit transfer policies that 

are generally applicable to schools within the state. Our prior work found 

that states had enacted a variety of legislation and implemented 

statewide initiatives, primarily covering public schools, that established 

transfer agreements and common curricula to facilitate credit transfer.3

For example, in 2005, we reported that some states identified a block of 

general education courses for which credits were fully transferable across 

public schools within that state. We previously reported that, at that time, 

39 states had legislation pertaining to transfer of credit between colleges.

The Higher Education Opportunity Act requires schools participating in 

any program authorized under Title IV, which contains various student 

financial assistance programs, to publicly disclose their credit transfer 

policies. Specifically, the Act requires schools to publicly disclose, in a 

readable and comprehensible manner, a statement of their credit transfer 

policies that includes, at a minimum: (1) any established criteria the 

school uses regarding the transfer of credit earned at another school and 

 3 GAO, Transfer Students: Postsecondary Institutions Could Promote More Consistent 

Consideration of Coursework by Not Basing Determinations on Accreditation, GAO-06-22 

(Washington, D.C.: Oct. 18, 2005).
Page 5 GAO-17-574 College Credit Transfer

(2) a list of schools with which the school has established an articulation 

agreement.4

The cost of attending college generally includes tuition, room and board, 

books and school supplies, fees, travel costs, and other miscellaneous 

expenses. As costs increase, college may become less affordable for 

many students and their families.5 To help students cover these costs, 

according to Education, in fiscal year 2016, $125 billion was available to 

students primarily through the Federal Pell Grant (Pell Grants) program 

and William D. Ford Federal Direct Loan program (Federal Direct Loans). 

Pell Grants, which do not have to be repaid, are awarded to 

undergraduate students based on financial need.6 Federal Direct Loans, 

either subsidized or unsubsidized by the government and which generally 

have to be repaid, are available up to the cost of attendance as 

determined by a student’s school and in accordance with federal limits. 

Pell Grants and Federal Direct Loans also have eligibility limits based on 

lifetime use or program length (see table 1).

 4 Pub. L. No. 110-315, § 488(g), 122 Stat. 3078, 3298 (2008), codified at 20 U.S.C. § 

1092(h).

5 According to Education data, average published tuition increased 40 percent from 

academic years 2003-04 to 2015-16, after adjustment for inflation.

6 According to Education, there are certain circumstances under which students may have 

to repay federal grants, such as withdrawing early from a program for which the grant was 

received. 
Page 6 GAO-17-574 College Credit Transfer

Table 1: Select Federal Student Aid Program Characteristics in Fiscal Year 2016 

Student Aid 

Program

Amount of Aid 

Available 

Number of Student 

Awards

Award and Eligibility 

Limits Per Student

Federal Pell Grants - are 

available to low income 

undergraduate students and 

generally do not have to be 

repaid. 

$27 billion 7.2 million Annual Maximum Award: up to $5,775a

Limit: up to 12 semesters or equivalent 

Subsidized Direct and 

Unsubsidized Direct Loans -

provides loans to students that 

must generally be repaid.

$46 billion for 

undergraduate 

students

13.8 million (new awards) 

for undergraduate 

students

Annual Maximum Award for Undergraduate 

Students:

• Subsidized:

b $3,500-$5,500

• Unsubsidized:

c $5,500-$12,500 (less 

any subsidized amount)

Limit: Generally 150% of published length 

of program for subsidized loans (e.g., if the 

published length for a bachelor’s degree 

program is 4 years, the limit would be 6 

years). The aggregate loan limit is $31,000-

$57,500 for undergraduates, and no more 

than $23,000 of this amount may be in 

subsidized loans.

Source: Department of Education budget and financial aid documents. | GAO-17-574

a

This is the maximum Pell Grant award amount for award year 2015-2016 which runs from July 1, 

2015 through June 30, 2016.The maximum Pell Grant award amount for award year 2016-2017 is 

$5,815.

b

To receive subsidized loans, where the federal government pays the loan interest while the student 

is in school, students must demonstrate financial need.

c

Students do not have to demonstrate financial need to receive unsubsidized loans. The federal 

government does not pay interest on unsubsidized loans while students are in school.
Page 7 GAO-17-574 College Credit Transfer

An estimated 35 percent of first-time students transferred schools over a 

6-year period, according to Education’s most recent BPS data on 

students who started in academic year 2003-04 (2004 cohort).7 Transfer 

patterns are similar for the cohort of students in the ongoing BPS study 

who started in academic year 2011-12 (2012 cohort).8 In addition, the 

transfer rate among students who originally attended a private for-profit 

school was lower than among students who attended public or private 

nonprofit schools (see table 2).

 7 Each cycle of BPS follows a cohort of students enrolling in postsecondary education for 

the first time. BPS tracks these students over a 6-year period and collects both survey and 

transcript data. The most recently completed BPS study tracked a cohort that first enrolled 

in postsecondary education in the 2003-04 academic year. The final follow-up with this 

cohort group was the 2008-09 academic year. Unless otherwise noted, all percentage 

estimates from the BPS data analysis have 95 percent confidence intervals within +/- 10 

percentage points of the estimate. For the purposes of our data analysis, we define 

students who transferred as those who moved from one school to another for a period 

longer than 4 months, with estimates reflecting only the student’s first transfer.

8 For example, based on mid-point data, 20 percent of students in the 2004 cohort 

transferred within 3 years and 17 percent of students in the 2012 cohort transferred within 

3 years. 

About a Third of 

College Students 

Transferred Schools 

from 2004 to 2009; 

Students May Face 

Challenges in 

Transferring Credits

An Estimated 35 Percent 

of College Students 

Transferred, with Most 

Transferring Between 

Public Schools from 2004 

to 2009
Page 8 GAO-17-574 College Credit Transfer

Table 2: Estimated Percentage of First-Time College Students Who Transferred by Type of First School, Academic Years 

2003-04 to 2008-09 

All Students Public Private Nonprofit Private For-Profit

Transferred at Least Once 35% 37% 44% 16%

Did Not Transfer 65% 63% 56% 84%

Total 100% 100% 100% 100%

(Estimated Number of Students 

Enrolled)

(3,742,889) (2,664,632) (569,443) (508,814)

Source: GAO analysis of 2004-2009 Beginning Postsecondary Students Longitudinal Study. | GAO-17-574

Note: This table shows the estimated relative percentage of all students who did or did not transfer, 

by type of first school attended. The 95 percent confidence intervals for these estimates are within +/-

4 percentage points of the estimate itself.

Of the students who transferred, an estimated 62 percent of them 

transferred between public schools. The most common transfer path was 

from a 2-year public to 4-year public school (see fig. 1). Transfer patterns 

for the 2012 cohort also show that students transferred between public 

schools at a higher rate than among other types of schools, based on 

mid-point data.
Page 9 GAO-17-574 College Credit Transfer

Figure 1: Estimated Percentage of Transfer Students by Transfer Path, Academic Years 2003-04 to 2008-09

Note: Transfer paths included in this figure include only paths taken by more than 2 percent of 

students.

Additionally, of the students who transferred, a majority (about 75 

percent) originally attended a public school. Fewer transfer students 

originally attended a private nonprofit or private for-profit school, an 

estimated 19 and 7 percent, respectively.9

 9 Percentages do not add to 100 due to rounding.
Page 10 GAO-17-574 College Credit Transfer

Successful transfer of course credits can be hampered when the two 

schools involved have not established an agreement that specifies how 

credit transfers will occur. As we previously reported, many schools enter 

into transfer agreements or partnerships, often referred to as articulation 

agreements, which specify which course credits meet program or degree 

requirements at one or more schools (see app. II for an example of a 

transfer guide based on an articulation agreement).10 Based on our 

review of school websites, articulation agreements were more commonly 

listed among public schools, but private nonprofit and for-profit schools 

also establish articulation agreements.11 This level of clarity helps 

students better plan their college path by helping them understand how 

specific earned credits will transfer. Stakeholders we interviewed from 16 

of 25 higher education organizations and schools said it is more difficult to 

transfer credits when there is no articulation agreement between schools 

or state policy outlining how credits will transfer.12

It is often easier for students to transfer credits when transferring to a 

school in the same state, especially in states that have policies outlining 

how credits should transfer, according to stakeholders we interviewed 

from 7 of 25 higher education organizations and schools. For example, 

according to the National Conference of State Legislatures, Florida has a 

statewide articulation agreement which generally guarantees that 

students who earn an associate’s degree from a Florida community 

college can transfer at least 60 credits to one of the 4-year public schools 

in the state. However, nearly one in five students who started at a 2-year 

public school and one in four who started at a 4-year public school 

transfer to a school in a different state, according to a recent National 

Student Clearinghouse report.13 One program designed to facilitate 

successful transfers for students across state lines is the Western 

 10 GAO-06-22.

11 All of the schools from our interviews had articulation agreements. Additionally, 

according to our website review analysis, an estimated 68 percent of schools that 

participated in federal student aid programs had articulation agreements listed on their 

website. See appendix I for more information on our website review methodology.

12 We interviewed higher education organizations and schools individually, and in total we 

spoke with stakeholders from 17 higher education organizations and 8 schools.

13 D. Shapiro, A. Dundar, P.K. Wakhungu, X. Yuan, and A. Harrell, Transfer and Mobility: 

A National View of Student Movement in Postsecondary Institutions, Fall 2008 Cohort, 

Signature Report No. 9. (Herndon, VA: National Student Clearinghouse Research Center, 

2015).

Stakeholders Said 

Students Can Face 

Challenges Transferring 

Credits between Schools 

without Agreements or 

Schools of Different Types

One Student’s Perspective

One student wished that his school took 

greater care to ensure students know exactly 

which classes they should take to avoid losing 

credits and incurring additional costs as a 

result of transferring schools. He is worried 

that he might have to pay twice for classes he 

has already taken.

Source: Student story collected from a higher education 

organization. | GAO-17-574
Page 11 GAO-17-574 College Credit Transfer

Interstate Commission for Higher Education’s Interstate Passport 

program. According to its description, the program accomplishes this by 

focusing on common learning outcomes across schools in different states 

rather than determining how individual courses compare to each other. 

Specifically, faculty and others in the field, such as registrars and 

advisors, in schools across multiple states agreed upon student learning 

outcomes and proficiency criteria in different skill areas for general 

education courses intended to be completed during the first half of a 

bachelor’s degree program. Students who achieve these learning 

outcomes are then able to transfer their lower division general education 

credits to any of the other schools participating in the program. Currently 

there are 21 schools that are members of the Interstate Passport 

Network.

The type of school is also a factor in successfully transferring credits 

between schools, according to stakeholders we interviewed from 18 of 25 

higher education organizations and schools. For example, according to 

stakeholders, transferring credits from private for-profit schools can be 

more difficult than transferring credits from other types of schools. Private 

for-profit schools are typically nationally accredited whereas public and 

private nonprofit schools are historically regionally accredited, and we 

previously reported that regionally accredited schools usually prefer to 

accept credits only from other regionally accredited schools.14

Stakeholders from several higher education organizations and schools 

said national accreditation is seen as less stringent than regional 

accreditation, though Education recognizes and applies the same 

standards to both types of accreditors. Additionally, according to one 

stakeholder, nationally accredited schools tend to offer more technical or 

vocational degrees where the coursework may be difficult to transfer to 

other schools. According to our analysis of BPS data, a relatively small 

percentage of students who originally attended private for-profit schools 

transfer to another school (16 percent).

 14 We previously reported in GAO-06-22 that destination schools often considered the 

type of accreditation held by origin schools when deciding which credits to accept. 

National accreditors operate nationwide and regional accreditors operate in a particular 

geographic region. Education requires recognized accrediting agencies, which are 

generally nongovernmental, nonprofit organizations, to set and enforce standards to 

ensure that the courses or programs offered by schools are of sufficient quality to achieve 

their objectives. We previously reported that Education applies the same requirements to 

both regional and national accrediting agencies.
Page 12 GAO-17-574 College Credit Transfer

Students transferring from a 2-year school, such as a community college, 

can face similar challenges transferring credits. For example, credits 

earned at 2-year schools may in some cases be seen by 4-year schools 

as less academically rigorous or more technical in nature than credits 

earned at the 4-year school, according to stakeholders we interviewed 

from 12 of 25 higher education organizations and schools. Students can 

also face challenges transferring credits between public and private 

schools. According to our prior work, statewide transfer policies generally 

applied only to public schools.15 Therefore, when transferring within the 

public school system, students potentially lose fewer credits compared to 

transferring between public and private schools.

Students may experience challenges in obtaining adequate advising or 

information about transfers to help plan their path, according to 

stakeholders we interviewed from 17 of 25 higher education organizations 

and schools. One study based on student interviews in Illinois also found 

that advising quality was inconsistent across the schools that students 

transferred between, and stakeholders we spoke with similarly cited such 

challenges for students.16 One stakeholder provided an example of a 

student who received inconsistent information about transfer credits from 

advisors at two different schools. This student met with an advisor at her 

origin school, a community college, to plan which courses were needed to 

transfer to a 4-year business degree program. After she transferred, this 

student met with an advisor at the 4-year school only to learn that much 

of her coursework would not apply to her intended degree because the 

business classes she previously took were not in an applicable field. 

Further, stakeholders from some higher education organizations and 

schools cautioned that the mere existence of an articulation agreement is 

not sufficient to prevent students from encountering challenges when 

attempting to transfer. They said that schools also need to provide 

students with adequate advising and transfer resources as early as 

possible to maximize the chances a student will transfer successfully. 

Students may also need advice on what to expect when they transfer, 

according to stakeholders from one higher education organization. For 

 15 GAO-06-22.

16 Lisa Hood, Erika Hunt, and Lynne M. Haeffele, “Illinois Post-Secondary Transfer 

Students: Experiences in Navigating the Higher Education Transfer System,” Planning 

and Changing 40 (1) (2009): 116.The findings from this study are applicable to the 32 

participating students who transferred in 2007 from one private and three public 

universities in Illinois.

Stakeholders Said 

Students Have Limited 

Access to Adequate 

Advising and Transfer 

Information, and 

Transferred Credits May 

Not Apply Toward Their 

Degrees
Page 13 GAO-17-574 College Credit Transfer

example, these stakeholders said that advisors should provide students 

with information to help them transition to the destination school and 

adjust to a new campus, in addition to helping them understand how their 

credits will transfer.

Some schools may be under-resourced when it comes to providing 

quality advising to students, according to stakeholders we interviewed 

from 13 of 25 higher education organizations and schools. According to 

our analysis of BPS data, students most commonly transferred from 

public 2-year—such as community colleges—to public 4-year schools. 

Some of the stakeholders we spoke with specifically mentioned resource 

challenges faced by community colleges. One stakeholder at a 

community college said that it can be challenging for schools to identify 

which students intend to transfer in order to connect them with available 

advisors to help plan their path. According to stakeholders from one 

school, 4-year schools can also face resource challenges. Specifically, 

they identified multiple efforts to help transfer students, but said that their 

registrar and admissions staff do not have the capacity to meet with every 

student individually, and that students could go without advising as a 

result.

Stakeholders from some of the higher education organizations and 

schools we interviewed said that the timing of advising and transfer 

information is also important. Specifically, they said that much of the 

transfer process is influenced by student decisions made early during 

their college career. For example, without early information about the 

transfer process, students may change majors or sign up for technical 

courses at their origin school without being aware of the implications such 

choices have on the transferability of their credits. Stakeholders also said 

that it is important for students to meet with advisors from both schools. 

Ultimately, the destination school generally has the final say on how 

credits are evaluated and accepted, so it is important for students to 

confirm with the destination school that the information they receive from 

their origin school is accurate, according to one stakeholder. The timing of 

when the destination school completes an official credit evaluation can 

also pose challenges for students, according to stakeholders from some 

higher education organizations and schools. Students may not know prior 

to enrollment at the destination school whether their credits will transfer 

because some schools do not complete an official credit evaluation until 

after the enrollment deadline.

Even if a student’s credits transfer, they may not apply toward fulfilling 

degree requirements for their intended major, according to stakeholders 

One Student’s Perspective

One student said that he met with an advisor 

prior to transferring so that he could plan his 

coursework appropriately; however, he did not 

learn about some of the degree requirements 

until after he transferred. This resulted in 

taking an additional semester of classes to 

fulfill lower-level requirements.

Source: GAO Interview with student.| GAO-17-574
Page 14 GAO-17-574 College Credit Transfer

we interviewed from 12 of 25 higher education organizations and schools. 

Some stakeholders saw this as a more important issue than the ability to 

transfer credits. Destination schools may determine that the courses the 

student wants to transfer are not equivalent to the requirements of the 

major at their school or may prefer their own curriculum, according to 

some stakeholders. For example, according to one stakeholder, a biology 

course may count as a general science elective but not count toward the 

science requirement for a degree in biology. In these cases, a student will 

likely have to take additional courses at the destination school, which 

could potentially delay graduation. One study that conducted student 

focus groups at two Indiana higher education systems similarly found that 

some students experienced challenges with credits applying toward 

degree requirements.17

 17 Public Agenda, Indiana Regional Transfer Study: The Student Experience of Transfer 

Pathways Between Ivy Tech Community College and Indiana University (San Francisco, 

CA: 2014). The findings from this study are based on themes from focus groups 

conducted between November 2012 and May 2013 with 333 individuals from eight Indiana 

University regional campuses and eight Ivy Tech campuses. The study did not identify the 

prevalence of the reported themes, and findings apply only to the group of students 

studied. 
Page 15 GAO-17-574 College Credit Transfer

Students lost an estimated 43 percent of college credits when they 

transferred, or an estimated 13 credits, on average, according to our 

analysis of BPS data on students who started in academic year 2003-04 

and were tracked over a 6-year period.18 Typically, semester courses are 

awarded three credits each, so the average credits lost during transfer 

(13) is equivalent to about four courses, which is almost one semester of 

full-time enrollment for students taking 15 credits per semester.19 Credit 

loss among the 2004 cohort varied greatly by the types of schools 

involved in a transfer (see fig. 2). For example, students who transferred 

between public schools—which accounted for almost two-thirds of 

transfer students—lost 37 percent of their credits, on average. In 

comparison, students who transferred from private for-profit schools to 

public schools—which accounted for 4 percent of students who 

transferred—lost an estimated 94 percent of their credits, on average.20

 18 For the purposes of our data analysis, we define students who transferred as those who 

moved from one school to another for a period longer than 4 months in the 2004 to 2009 

study period, and we analyzed data only for a student’s first transfer. Unless otherwise 

noted, all percentage estimates from the BPS data analysis have 95 percent confidence 

intervals within +/-10 percentage points of the percent estimate, and other numerical 

estimates have confidence intervals within +/-10 percent of the estimate itself. We define 

credit loss as credits earned at the origin school that were not accepted by the destination 

school. Our analysis does not address the reasons why credits were not accepted.

19 Credit hours per course can vary by institution. Bachelor’s degree programs generally 

require at least 120 credits to graduate if courses are offered on a semester basis, so fulltime students would need to take 15 credits per semester to graduate in 4 years.

20 The credit loss estimate for students transferring between public schools is statistically 

different from the credit loss estimates for transfers between the other school types 

presented in this report.

Credits Lost in a 

School Transfer 

Could Result in 

Additional Tuition 

Costs and Limited 

Financial Aid 

Eligibility for Students

Almost Half of Credits 

Earned Were Lost During 

Transfer from 2004 to 

2009, and the Extent of 

Loss Varied by Type of 

School
Page 16 GAO-17-574 College Credit Transfer

(See table 3 in app. III for more information). Our analyses provide 

descriptive information on credit loss and do not control for certain factors 

that may be related to the ability to transfer credits, including whether 

students informed the school of possible credits eligible for transfer based 

on previous attendance at another school.

Figure 2: Estimated Percentage of Credits Lost in Transfer, on Average, by School Type, Academic Years 2003-04 to 2008-09

Note: All estimates presented in this figure are statistically different from the public-to-public school 

comparison group. Transfer students are defined as those who moved from one school to another for 

a period longer than 4 months, and estimates in this graphic reflect a student’s first transfer only. Our 

analysis did not control for certain factors that may be related to the ability to transfer credits, 

including whether students informed the school of possible previously earned credits eligible for 

transfer.

a

The upper bound for some estimates was capped at 100 percent.

b

The 95 percent confidence interval is greater than +/-10 percentage points.

Credit loss also varied by transfer direction. For example, based on our 

analysis of the 2004 cohort, students who transferred vertically from 2-

year to 4-year schools lost an estimated average of 26 percent of their 

credits, while those who transferred laterally between 2-year schools lost 

an estimated average of 74 percent of their credits. Vertical transfers from 

2-year to 4-year schools accounted for 40 percent of transfer students, 

whereas lateral transfers between 2-year schools accounted for 17 

percent of transfer students (see table 4 in app. III for more information).

While academic performance can be an important determinant in the 
Page 17 GAO-17-574 College Credit Transfer

transferability of credits, we did not assess how such factors affected the 

extent of credit loss.21

Our analysis also showed a wide range of credit loss when taking into 

account both the type of school and direction of transfer, or transfer path 

(see fig. 3).22 For example, students transferring from 2-year public to 4-

year public schools, which was the most common transfer path and 

accounted for 26 percent of transfer students, lost an estimated average 

of 22 percent of their credits. This was a lower rate of credit loss than the 

overall average for all transfer students. In addition, students transferring 

between 2-year public schools—another common transfer path that 

accounted for 13 percent of transfer students—lost an estimated average 

of 69 percent of their credits. Students who took some of the less frequent 

transfer paths lost a relatively higher percentage of their credits. For 

example, students who transferred from 2-year private for-profit to 2-year 

public schools lost an estimated average of 97 percent of their credits. 

Similarly, students who transferred from 2-year public to 2-year private 

for-profit schools lost an estimated average of 95 percent of their credits. 

Each of these transfer paths accounted for about 1 percent of transfer 

students. (See table 5 in app. III for more information).

 21 Based on an analysis of BPS data, Education’s National Center for Education Statistics 

(NCES) found that grade point average (GPA) was as predictive as the direction of 

transfer in terms of the student’s level of credit loss. Specifically, NCES found that a one 

point increase in GPA yielded 22 percent more credits transferred. For more information, 

see S. Simone, Transferability of Postsecondary Credit Following Student Transfer or 

Coenrollment, NCES 2014-163 (Washington, D.C.: August 2014)

22 Transfer path accounts for the combination of the origin and destination school types 

(i.e., public, private nonprofit, or private for-profit) and the level of degree programs the 

schools offer (i.e., 2-year or 4-year programs).
Page 18 GAO-17-574 College Credit Transfer

Figure 3: Estimated Percentage of Credits Lost in Transfer, on Average, by Transfer Path, Academic Years 2003-04 to 2008-09

Note: All estimates presented in this figure are statistically different from the 2-year public to 4-year 

public transfer path comparison group. Transfer students are defined as those who moved from one 

school to another for a period longer than 4 months, and estimates in this graphic reflect a student’s 

first transfer only. Our analysis did not control for certain factors that may be related to the ability to 

transfer credits, including whether students informed the school of possible previously earned credits 

eligible for transfer.

a

The upper bound for some estimates was capped at 100 percent.

b

The 95 percent confidence interval is greater than +/-10 percentage points.

Stakeholders from about half of the higher education organizations and 

schools we interviewed said some students may seek to save on tuition 

costs by starting at a less expensive school and then transferring to a 

more expensive school to complete a degree. However, stakeholders 

from about the same number of higher education organizations and 

schools told us that some students face additional tuition costs due to 

repeated coursework or additional time to degree as a result of lost 

Potential Tuition Cost for 

Transfer Students 

Depends, in Part, on 

Number of Credits Lost 

and Tuition Rates
Page 19 GAO-17-574 College Credit Transfer

credits. See figure 4 for examples of the transfer process and its potential 

outcomes.23

 23 Available data do not allow us to estimate actual costs to the student because the data 

do not identify which credits are paid with financial aid versus out-of-pocket, and available 

tuition data do not account for variation in the structure of tuition charges (e.g., whether 

tuition is charged on the basis of a credit hour or the program as a whole) or reflect actual 

tuition charges incurred. 
Page 20 GAO-17-574 College Credit Transfer

Figure 4: Examples of Potential Outcomes for Students Transferring from a Less Expensive to a More Expensive School

Note: These examples assume that the student takes 15 credits per semester, all transferred credits 

count toward degree requirements, and retaking lost credits results in additional time to earn a 

degree.
Page 21 GAO-17-574 College Credit Transfer

If a student is seeking to obtain a bachelor’s degree from a relatively 

expensive school, transferring could help the student save on tuition 

costs. Specifically, if a student is able to successfully transfer all credits 

from the less expensive school, and those credits count toward his or her 

degree program, then the student saves on tuition costs by having earned 

a portion of the credits at the lower-cost origin school. If a student loses 

some credits during the transfer, then the student’s overall tuition costs 

depend on the combined effect of the credit loss and the difference in 

tuition rates between the two schools. However, with any level of credit 

loss, the student will likely need to stay in school longer to complete 

degree requirements and pay tuition for repeated coursework. If a student 

loses all of his or her transfer credits, then the cost of completing a 

degree is generally higher because the student not only incurs tuition 

costs from the origin school but must also retake credits required for a 

degree at the more expensive destination school. This also extends the 

time to complete a degree.

The direction of transfer also affects college affordability. Stakeholders we 

interviewed from 12 of 25 higher education organizations and schools 

said that students transferring vertically may achieve savings because 2-

year schools are relatively low cost. Based on our analysis of 2013-2014 

IPEDS tuition data, average net tuition per year—which is the cost of 

attendance minus financial aid and non-tuition costs, such as room and 

board—varied by school type and ranges from about $1,900 for a 2-year 

public school to about $13,800 for a 4-year private nonprofit school (see 

table 6 in app. III for more tuition data).24 However, net tuition may 

underestimate costs for transfer students because, according to 

Education, schools often do not offer the same amount of institutional aid 

to transfer students compared to first-time, non-transfer students. 

Transfer may be more difficult when transferring laterally. In comparison 

to vertical transfers, students who transferred laterally experienced higher 

rates of credit loss, according to our analysis of BPS data for the 2004 

cohort. Stakeholders we spoke with from one school said that students 

who are transferring between 4-year schools may not have been planning 

to transfer, and it is more difficult to advise students about which credits 

will transfer laterally. One stakeholder from another school said that if 

 24 Net tuition would be lower than the “sticker price,” which represents published tuition 

and fees and does not reflect what students and families actually pay once financial aid 

has been taken into account. Net tuition is based on first-time, full-time undergraduate 

students. At some schools, these students may represent a small proportion of the total 

student population. See appendix I for more details on our methodology. 
Page 22 GAO-17-574 College Credit Transfer

students transferring laterally switch their degree program, few of their 

courses will transfer. Students who lose more credits during transfer 

would typically incur additional tuition costs by paying for repeated or 

additional coursework. To illustrate some potential financial implications 

for students, we created examples of several different transfer scenarios 

(see fig. 5 and fig. 10 in app. III).25

 25 Assumptions for credit loss and net tuition are based on estimated averages from BPS 

and IPEDS data. See appendix I for more details on our methodology. 
Page 23 GAO-17-574 College Credit Transfer

Figure 5: Transfer Scenarios and Potential Financial Implications for Students

Notes: Credit loss and net tuition assumptions are based on estimated averages for each specified 

transfer path from the 2004-2009 Department of Education’s (Education) Beginning Postsecondary 

Students Longitudinal Study (BPS) and 2013-2014 Integrated Postsecondary Education Data System 

data. The scenarios assume that the student transfers after 2 years and all transferred credits apply 

to degree requirements, the student pays tuition on a per-credit basis to retake credits lost during 

transfer, and the student pays in-state tuition if attending a public school. The financial implications for 

students do not account for how students may use financial aid to offset out-of-pocket tuition costs. 

Net tuition is based on data for first-time, full-time undergraduate students and may underestimate 

costs for transfer students because, according to Education, schools often do not offer the same 

amount of institutional aid to transfer students compared to first-time, non-transfer students. Based on 

our analysis of BPS data on students who transferred, 26 percent transferred from 2-year public to 4-

year public schools; 11 percent transferred between 4-year public schools; 9 percent transferred from 
Page 24 GAO-17-574 College Credit Transfer

2-year public to 4-year private nonprofit schools; and 4 percent transferred from 4-year private 

nonprofit to 4-year public schools.

Credit loss data do not reflect the reasons why credits were not accepted, 

though there are a variety of reasons why credits may not transfer 

successfully. In some cases, the credits students attempt to transfer may 

not be applicable or comparable to the coursework at the destination 

school.26 For example, vocational or remedial coursework from a 2-year 

school may not be transferable to a 4-year degree program.27 Further, 

factors that are not entirely within a school’s control, such as students’

decisions and academic performance, also affect credit transfer and the 

time it takes to complete a degree. For example, students may not ask to 

have their credits evaluated or they may decide to change majors. Our 

analysis does not reflect certain student decisions or characteristics, 

which can also factor into the extent of credit loss.28 Further, aside from 

tuition, other factors can affect a student’s costs, such as changes in cost 

of living or forgone earnings while attending school, according to 

stakeholders from several higher education organizations and schools.

 26 In some cases, schools may accept transfer credits as elective credits but not allow the 

credit to be used toward a specific degree program. 

27 Remedial courses are designed to help students learn developmental skills so they are 

adequately prepared for college-level coursework. Many schools do not accept remedial 

coursework for transfer of credit, according to our review of school websites.

28 For more information on Education’s analysis of factors related to credit transfer, see S. 

Simone, Transferability of Postsecondary Credit Following Student Transfer or 

Coenrollment, NCES 2014-163 (Washington, D.C.: August 2014).
Page 25 GAO-17-574 College Credit Transfer

Almost half of transfer students received Pell Grants and almost twothirds received Federal Direct Loans, according to our analysis of BPS 

data collected between 2004 and 2009.29 According to mid-point data 

from the more recent BPS cohort, many transfer students who started 

school in academic year 2011-12 also received Pell Grants (55 percent) 

and Federal Direct Loans (62 percent) in their first 3 years.30 Access to 

such aid is affected by the length of time needed to complete a degree. 

The Pell Grant program imposes a lifetime limit of 12 semesters (6 years) 

of eligibility. Direct Subsidized Loans, which are loans in which the 

government pays part of the interest, are limited to a maximum timeframe 

of 150 percent of the published length of a program at a school (e.g., 150 

percent of a 120-credit, 4-year degree program would be 6 years).31

According to our analysis of both BPS cohorts during their first 3 years in 

school, an estimated 48 percent of students in the 2004 cohort received 

Direct Subsidized Loans and an estimated 57 percent of students in the 

2012 cohort received Direct Subsidized Loans.32

According to stakeholders we interviewed from higher education 

organizations and schools, transfer students may exhaust available aid 

before they complete their degree. Transfer students who lose credits 

must pay for and spend additional time to retake credits needed to 

graduate, which may make them exceed time frames for financial aid 

 29 According to our BPS analysis, transfer students received Pell Grants which totaled an 

estimated average of $7,400 per student and Federal Direct Loans which totaled an 

average of $13,100 per student over the 2004-2009 period. In our analysis, Federal Direct 

Loan includes receipt of both subsidized and unsubsidized loans. 

30 For mid-point data, we define the transfer population based on students who reported 

transferring rather than those who moved schools based on transcript data because 

transcript data are not available at the mid-point. Estimates based on mid-point data are 

therefore not directly comparable to estimates for the entire study period.

31 Federal Direct Subsidized Loans are structured so that the government generally pays 

the interest that accrues while the borrowers are in school and during a 6-month grace 

period after leaving school. The student pays the interest that accrues during other 

periods.

32 According to our BPS analysis, transfer students received Direct Subsidized Loans 

which totaled an estimated average of $4,700 per student over the 2004-2009 period.

Many Transfer Students 

Received Federal 

Financial Aid from 2004 to 

2009, and Credit Loss Can 

Limit Students’ Eligibility 

and Result in Additional 

Costs to the Federal 

Government
Page 26 GAO-17-574 College Credit Transfer

eligibility.33 BPS data do not indicate whether students exhausted their 

financial aid eligibility before obtaining a degree. However, many transfer 

students who started college in academic year 2003-04, an estimated 40 

percent, did not obtain any type of degree within a 6-year time period.34

Further, while available data do not provide enough information to 

adequately identify a student’s intention to obtain a specific type of 

degree (e.g., 2-year associate’s degree versus 4-year bachelor’s degree), 

about a third of students who chose to transfer from a 2-year to a 4-year 

school did not ultimately obtain a bachelor’s or other type of degree within 

the 6-year time period (see table 7 in app. III for more information). In 

cases where students lose access to aid, they may be financially 

unprepared or unable to earn their degree. Additionally, stakeholders 

from some higher education organizations and schools told us that 

schools may not offer as much scholarship funding for transfer students 

as they do for new, first-time students.

Credits lost in a transfer also can result in additional costs for the federal 

government in providing student aid. The government’s costs may 

increase if transfer students who receive financial aid take longer to 

complete a degree as a result of retaking lost credits. Education’s data 

do not identify whether particular funding sources, such as Pell Grants 

or other financial aid, are used to pay for credits taken or to pay for other 

costs. Therefore, we used an example to show how lost credits can result 

in potential additional costs in student aid to the federal government 

 33 The Department of Education allows schools to stipulate through their own satisfactory 

academic progress policy whether full-time students can use Pell Grants and Direct Loans 

to pay for repeated coursework. A satisfactory academic progress policy establishes 

conditions students must meet to continue receiving federal financial aid. In cases where a 

student wants to retake previously passed courses, Education allows students to use Pell 

Grant and Direct Loan funds to pay for repeated coursework as long as the student 

repeats a given course only once. 

34 An estimated 50 percent of all students in the 2004 cohort did not obtain any type of 

degree in 6 years, and an estimated 56 percent of non-transfer students did not obtain any 

type of degree in 6 years.
Page 27 GAO-17-574 College Credit Transfer

(see fig. 6).35 Actual costs to the federal government would vary.36

Figure 6: Transfer Scenario and Potential Costs to the Government in Student Financial Aid

Note: Credit loss and net tuition assumptions are based on estimated averages for each specified 

transfer path from the 2004-2009 Department of Education’s Beginning Postsecondary Students 

Longitudinal Study and 2013-2014 Integrated Postsecondary Education Data System data. The 

scenario also assumes that the student transfers after 2 years, takes at least 15 credits per semester, 

all transferred credits apply to degree requirements, the student pays tuition on a per-credit basis to 

retake credits lost during transfer, the student pays in-state tuition if attending a public school, and the 

student is eligible for the same amount of Pell Grant each semester. To the extent that a student 

needs to stay in school longer to re-take additional lost credits and receive additional semesters of 

Pell Grant funding up to the student’s lifetime eligibility limit, the government could incur additional 

Pell Grant program costs and the student could incur additional out-of-pocket tuition costs.

Some students may transfer as a result of the closure of their current 

school, and they face additional challenges and financial aid 

considerations. In recent years, multiple school closures have affected 

large numbers of students and resulted in costs to the federal 

government. School closures pose financial risks to students who wish to 

 35 The example depicts the possible financial cost to the government of a student 

completing a degree with a transfer compared to a student completing a degree having 

attended the destination school for the whole program. Assumptions for credit loss, net 

tuition, and Pell Grant receipt are based on estimated averages from BPS and IPEDS 

data. This example focuses only on Pell Grants; however, lost credits can also result in 

additional costs related to the provision of Federal Direct Loans. 

36 Actual costs to the federal government would vary based on how many students use 

Pell Grant funds, the amount they receive, program restrictions, and the number of credits 

students must retake to meet degree requirements. 
Page 28 GAO-17-574 College Credit Transfer

continue their education because of the potential difficulty in transferring 

credits from a closed school.

When a school closes, students must decide whether to complete their 

degree at another school—which can include transferring credits—or stop 

pursuit of that degree and, according to Education policy, apply for a 

discharge of their federal student loans. Education policy states that 

students are eligible to discharge (i.e., not pay) 100 percent of their 

federal student loans if they (a) did not complete their program because 

of a closure, and (b) did not continue in a comparable program at another 

school.37 Education officials said some students who have requested 

discharges of their student loans after their private for-profit school closed 

said they were unable to transfer their credits. For students who transfer 

to a comparable program at another school, their existing Direct 

Subsidized Loans continue to count in calculating eligibility (150 percent 

of published program length). Students with Pell Grants who are unable 

to complete their program at the closed school can restore the portion of 

their lifetime eligibility for grants used at the closed school, according to a 

December 2016 Education announcement. Closures can pose a financial 

risk for the government and taxpayers to the extent that federal student 

loans are forgiven and students reset their Pell Grant eligibility.

 37 According to Education policy, students may be eligible to discharge their federal 

student loans under certain circumstances, including if they continue in a comparable 

program and do not transfer credits from their closed school. Education policy also states 

that students who continue their education through a closing school’s teach-out 

agreement—an agreement with another school that in the event of a closure students can 

complete their program at the other school—cannot discharge their student loans. In 

addition, Education policy states that students who withdraw more than 120 days before 

the school closes or who have completed all the coursework for their program, but have 

not yet received a diploma or certificate, also cannot discharge their student loans. 
Page 29 GAO-17-574 College Credit Transfer

Under federal law, schools participating in any Title IV program are 

required to publicly disclose the transfer of credit policies established by 

the school, including a list of schools with which they have articulation 

agreements.38 According to Education officials, schools must disclose 

credit transfer policies on their website,39 but the list of schools can be 

disclosed through a website or other appropriate publications or 

mailings.40 Based on our review of websites for a nationally 

 38 20 U.S.C § 1092(h)(1).

39 Education officials cited 20 U.S.C. § 1015a(i)(1)(V)(iv) as the source of this 

requirement. This provision requires Education to make publicly available on the College 

Navigator website various information about schools that participate in programs under 

Title IV, including a link to the school’s website that provides, in an easily accessible 

manner, the policies of the school related to transfer of credit from other institutions.

40 See 34 C.F.R. §§ 668.41(d) and 668.43(a)(11). 

Almost All Schools 

Provided Credit 

Transfer Policies on 

Websites, but 

Comprehensiveness 

of Information Varied

Almost All School 

Websites Disclosed Credit 

Transfer Policies, but Not 

All Were Clear About 

Agreements with Other 

Schools on Transfers
Page 30 GAO-17-574 College Credit Transfer

representative stratified random sample of 214 schools,41 an estimated 99 

percent contained the school’s credit transfer policies.42

Of those websites with credit transfer information, an estimated 68 

percent listed the names of partner schools with which they have 

articulation agreements.43 An estimated 29 percent of websites did not 

provide such a list, while an estimated 4 percent explicitly stated that the 

school did not have any articulation agreements.44 In addition, the 

prevalence of websites listing partner schools varied by school type. 

While most (89 percent) public school websites with credit transfer 

information listed partner schools with which they have articulation 

agreements, fewer private nonprofit and for-profit school websites had 

such a list (see fig. 7).45 In some cases, school websites included 

information on statewide articulation policies, such as the Illinois 

Articulation Initiative, where, according to its website, over 100 

participating schools in the state have agreed to accept a package of 

 41 Using Education’s 2014-2015 IPEDS, we drew a stratified random sample of 214 

schools from a universe of 4,309 schools to determine the extent to which schools 

included transfer information on their websites. Unless otherwise noted, all overall 

population estimates from the website review have 95 percent confidence intervals within 

+/- 7 percentage points of the estimate itself, and any overall estimates in this report are 

based on sample counts greater than 20 schools. See appendix I for additional 

information about the website review methodology.

42 The estimated percentage of schools that include credit transfer policies on their 

websites applies to schools for which we could locate transfer information. During our 

review, we could not locate credit transfer information online for three schools. One of 

these schools did not have a website. Education officials told us that they regard schools 

without websites as not being subject to this requirement. Officials from the other two 

schools said that credit transfer policies were available to students in a course catalog, 

and we were unable to locate the catalog on the website. Education officials told us that if 

a school’s website lacks this information, it would not be in compliance with the 

requirement for inclusion on the website. We did not, as a part of our review of school 

websites, make any attempt to assess the schools for legal compliance with disclosure 

requirements. Instead, this review was intended to understand what information is made 

accessible to students. We provided Education with information on these two schools for 

further review.

43 We refer to the list of schools with which there are articulation agreements as a list of 

“partner schools.”

44 Percentages do not add to 100 due to rounding. The sample count for the estimate of 

websites that stated the school did not have any articulation agreements is 8 schools, and 

the 95 percent confidence interval for the percentage of school websites that state the 

school does not have articulation agreements is between 2 and 7 percent. 

45 The 95 percent confidence interval for the percentage of public school websites that 

listed partner schools is between 80 and 95 percent. 
Page 31 GAO-17-574 College Credit Transfer

general education courses in lieu of their own general education 

classes.46 Students have access to varying levels of detail about credits 

covered by articulation agreements. Of the websites that listed partner 

schools, an estimated 63 percent provided the agreement’s provisions, 

and an estimated 21 percent provided a link to partner school websites.47

Figure 7: Estimated Percentage of School Websites Listing Partner Schools for Transfer Articulation Agreements, by School 

Type

Note: This figure shows the percentage of schools with websites that listed other schools with which 

they have articulation agreements. The 95 percent confidence intervals for these estimates are within 

+/- 15 percentage points of the estimate itself. All estimates are based on sample counts greater than 

20 schools. Although schools participating in Title IV programs are required to publicly disclose a list 

of the schools with which they have articulation agreements, they do not have to disclose this 

information specifically on their websites but may choose to do so in another appropriate publication

or mailing. For schools that did not provide a list of partner schools on their website, it is difficult to 

determine, without further follow-up, whether the lack of information indicated that the school did not 

have such agreements or that the school was not providing the list of partner schools.

For the schools that did not provide a list of partner schools on their 

website or explicitly note that they had no such agreements, it was 

difficult to determine, without further follow-up, whether the lack of 

information indicated that the school did not have such agreements or 

that the school was not providing the list of partner schools. Based on 

targeted follow-up with officials at 10 schools, we found that some did not 

 46 About 38 percent of school websites included information about state policies or 

programs related to transfer, though the policies mentioned were not necessarily related 

to statewide articulation. For example, some of the state policies mentioned are common 

course numbering systems, which is a uniform system for numbering courses across 

schools. 

47 The 95 percent confidence interval for the percentage of websites with a description of 

articulation agreements is between 55 and 71 percent. The 95 percent confidence interval 

for the percentage of websites with links to partner schools is between 15 and 29 percent. 
Page 32 GAO-17-574 College Credit Transfer

have articulation agreements while others had articulation agreements 

but their partner schools were not listed on the website.48 Specifically, 

officials at 5 of the schools said that their school did not have, or they 

were unaware of, established articulation agreements. Officials at 3 

schools said that they had articulation agreements and they were listed in 

publications available onsite at the school or by contacting school staff. 

(We did not verify the physical presence of publication copies at school 

locations or the information included). Officials at 2 schools said that they 

were currently reviewing articulation agreements and planning to update 

the school website.

Although schools participating in any Title IV program are required to 

publicly disclose a list of the schools with which they have articulation 

agreements, they do not have to disclose this information specifically on 

their websites but may choose to do so in another appropriate publication 

or mailing. In addition, Education officials stated that it is unclear whether 

the department has the authority to require schools to post the list of 

articulation-agreement schools online because federal law does not 

specify the means of disclosure. The purpose of this disclosure 

requirement is for schools to share transfer information with students, and 

selecting an appropriate means of disseminating this information 

enhances the effectiveness of such communication. Furthermore, 

Education officials told us that schools are increasingly using websites to 

share consumer information and that the department already requires that 

credit transfer policies and other disclosures, such as net price 

calculators, be posted on school websites. Awareness of articulation 

agreements can benefit students because such agreements clarify how 

credits transfer between schools. Posting this information online would 

make it more easily accessible to prospective students and their families 

than restricting it to publications located on campus, particularly since 

almost all school websites already include information on credit transfer 

policies.

In circumstances where the school does not have articulation agreements 

with other schools, Education’s guidance does not specify how or whether 

 48 Based on the results of our website reviews, we conducted targeted follow-up to obtain 

additional information from two groups of schools: schools whose websites appeared not 

to include transfer policy information, and schools whose websites did not list partner 

schools. Schools in the second group were a subset of the first, and were also selected to 

represent a range of school types. For more information on our follow-up methodology, 

see appendix I. 
Page 33 GAO-17-574 College Credit Transfer

to document this. According to Education officials, federal law and related 

regulations do not require schools to disclose the fact that they do not 

have articulation agreements, and the officials stated that it is unclear 

whether the department has the authority to require such a disclosure. 

Online information on the presence of articulation agreements would 

make it easier to determine whether schools are disclosing a list of 

partner schools as required. Clarification on what a school should depict 

on its website when it does not have articulation agreements could also 

help provide more information to students and enhance their 

understanding of potential transfer options. Moreover, one of Education’s 

goals is to increase college completion and affordability, and adequate 

communication with transferring students supports this goal.49 More 

complete information on school websites about articulation agreements 

on transfers could help students fully weigh alternatives when making a 

transfer decision.

Aside from the required school transfer policies noted earlier, school 

websites varied in the extent of any additional information they provided 

on transfers. An estimated 60 percent of school websites had some 

general information about how students could initiate the process of 

having their course credits evaluated for transfer (see fig. 8). In addition, 

about half of school websites included resources to help students 

understand the transfer process. These resources were more common on 

websites for public schools than for other school types. Some websites, 

for example, had course equivalency databases where students could 

input their prior coursework to see how it would translate into earned 

credits at the destination school. In addition, some school websites 

provided information on transfer-related resources, such as transfer fairs 

and other in-person activities at which students could meet with school 

representatives to learn more about the transfer process.

 49 U.S. Department of Education, Fiscal Year 2015 Annual Performance Report and Fiscal 

Year 2017 Annual Performance Plan (Washington, D.C.: 2016). 

Extent of Additional 

Information Provided on 

Transfers Varied by 

School
Page 34 GAO-17-574 College Credit Transfer

Figure 8: Estimated Percentage of School Websites with Additional Transfer-Related Information 

Note: The 95 percent confidence intervals are within +/- 7 percentage points of the percentage 

estimate. Credit evaluation process information includes school websites that provided general 

information on how students can initiate the process of having courses evaluated for transfer. 

Transfer-related resources include information that helps students understand the transfer process, 

such as course equivalency databases, or website information on school-hosted activities, such as 

transfer workshops. All estimates are based on sample counts greater than 20 schools. The transferrelated information in this figure represents information that is in addition to what schools are required 

to disclose.

An estimated 47 percent of school websites published transfer deadlines 

and 43 percent published transfer-specific financial aid information. 

Knowing deadlines in advance can help students ensure that they do not 

miss key steps of the transfer process, such as submitting admissions or 

credit evaluation applications. Financial aid information, including whether 

a school awards transfer scholarships, can help students identify transfer 

options that are financially feasible. Fewer schools provided listings of 

transfer-related frequently asked questions or transfer-specific contacts. 

Such information can help students more easily navigate to applicable 

transfer information if they have questions and identify relevant school 

staff for assistance.

The format of transfer information also varied on school websites. Threequarters of school websites used multiple formats to convey transfer 

information, including various combinations of webpages or websites 

(including external sites) and downloadable documents, such as copies of 

course catalogs. In comparison, an estimated 25 percent provided credit 
Page 35 GAO-17-574 College Credit Transfer

transfer information in a single format, either through a single webpage or 

document. Nevertheless, it may still be difficult to access transfer 

information, even if it is provided in a single format, if the transfer material 

is not easy to locate on the school’s website. For example, we found one 

school’s credit transfer policies in a course catalog that we downloaded 

from the website. However, the school website’s search function did not 

show the location of this material and it was not obvious that a student 

would need to download the course catalog to access transfer 

information. In other instances, schools listed credit transfer policies on 

their consumer information disclosure webpages, but if a student is 

unaware that consumer disclosures include credit transfer policies, they 

may not know to look on that particular page for transfer information.

In addition to school websites, Education’s websites also provide college 

students and their families with information on transfers, but it is limited. 

We found that the transfer information was neither focused nor targeted 

toward transfer students. In particular, Education’s StudentAid.gov 

website highlights descriptions of school types and things to consider 

when choosing a school, and while these pages briefly refer to transfer 

information, it is presented in the context of other topics rather than 

having a substantive focus on transfer. For example, as part of a broad 

description of community colleges, it is noted that many community 

colleges have articulation agreements and students from this type of 

school often transfer. Education officials said that they do not see a need 

to develop consumer information on transfers because students typically 

would not seek transfer information from Education, and they see little 

demand based on the volume of transfer-related searches of the 

department’s website. However, even for students who seek transfer 

information, it would be difficult for them to access relevant information 

given Education’s limited offerings on the topic. Providing additional 

transfer-focused information could encourage more students to access 

the department’s website for this purpose. Education also includes some 

transfer information for students affected by school closures in a 

frequently-asked-questions page on Education’s website. While this 

information is helpful, it does not address the broader population of 

transfer students, which accounted for over a third of first-time students, 

according to our analysis of transfer data. Finally, according to student 

complaint data, Education officials sometimes provided general 

information on the transferability of credits in response to complaints 

about transfer issues. Although such information could broadly apply to all 

Education’s Information 

about Transfers Is Limited
Page 36 GAO-17-574 College Credit Transfer

transfer students, it is provided infrequently and is limited to students who 

happen to submit a complaint.50

Other reasons Education officials cited for not developing consumer 

information on transfers are that resources for transfer students are 

mostly provided by schools, transfer is school specific, and the federal 

government does not oversee schools’ curriculums. However, we found 

that close to half of school websites are not providing transfer resources 

that can help students understand the process beyond the minimal 

required information. This could compound the challenges we noted 

earlier of students potentially not obtaining adequate advising and 

information. In addition, while transferring is ultimately based on a 

student’s unique circumstances coupled with a school’s transfer policy, 

there are nevertheless general considerations that apply across schools. 

Education already provides consumer guidance, such as on college 

applications, which applies across schools. Similarly, Education could 

provide guidance on college transfers, such as common credit evaluation 

criteria, tips for locating transfer resources, and the potential effect of 

transferring on financial aid eligibility.51 Furthermore, while Education 

does not oversee schools’ curriculums, it oversees federal financial aid 

programs that provide over $125 billion to students. The department also 

has a goal of promoting college affordability. Given the substantial 

number of students who transfer and the effect of credit loss on potential 

costs to the student and the federal government, general consumer 

information on factors to consider when transferring could be valuable. 

According to federal internal control standards, agencies should 

externally communicate the necessary quality information to help achieve 

their goals.52 Transfers can affect the time and cost of completing a 

degree. Knowledge of key considerations could help students and their 

families make better-informed transfer decisions.

 50 According to Education officials, student complaints submitted about transfer credits 

comprised 2 percent of the student complaints received from April through November 

2016.

51 Education officials cautioned that consumer information for students in this area should 

not discourage students from transferring. However, general information on key transfer 

considerations could help students navigate the process.

52 GAO, Standards for Internal Control in the Federal Government, GAO-14-704G 

(Washington, D.C.: Sept. 10, 2014).
Page 37 GAO-17-574 College Credit Transfer

About one-third of students transferred schools on their path toward a 

college degree based on our analysis of Education’s data. While for 

some, transfer can provide an avenue for saving on tuition costs, many of 

the credits that students earn may not ultimately help them earn a degree 

after they transfer. As tuition rises and college becomes less affordable 

for many, the financial implications of losing credits during transfer are 

particularly salient for students, their families, and the federal 

government.

Articulation agreements between schools can facilitate credit transfers 

because they detail how and which credits will transfer from one school to 

another. When schools make information about these agreements 

accessible on their websites, students can more easily understand their 

transfer options. In addition, since many school websites do not provide 

helpful transfer resources for students, consumer guidance from 

Education that includes key factors to consider when transferring could 

help students more easily navigate the process. With such guidance, 

students can more accurately weigh their options and make an informed 

decision about transferring schools that takes into account how much 

time and money they must invest in pursuit of a college degree.

To help improve students’ access to information so that they can make 

well-informed transfer decisions, we recommend the Secretary of 

Education take the following two actions:

• Require schools to (1) disclose the list of schools with which they 

have articulation agreements online if the school has a website, and 

(2) clearly inform students, on the school’s website if it has one, when 

no articulation agreements on credit transfer are in place. If the 

department determines that it does not have the authority to require 

this, it should nonetheless encourage schools to take these actions 

(through guidance or other means).

• Provide students and their families with general transfer information, 

for example by developing a consumer guide and posting it on 

Education’s website or augmenting transfer information already 

provided on the website, to help increase awareness of key 

considerations when transferring schools.

Conclusions

Recommendations for 

Executive Action
Page 38 GAO-17-574 College Credit Transfer

We provided a draft of this report to Education for its review and 

comment. Education’s comments are reproduced in appendix IV. In its 

written comments, Education disagreed with our recommendation to 

require schools to disclose on their websites the list of partner schools 

with which they have articulation agreements and inform students when 

there are no agreements in place. Education reiterated that it already 

requires schools to disclose a list of other schools with which they have 

established articulation agreements. Given that the purpose of required 

consumer disclosures on articulation agreements is to inform students, 

we believe that posting this information online would make it more 

accessible to prospective students compared to publications located 

physically on a school’s campus. The increased accessibility would be 

especially beneficial for prospective students who live far away from the 

school. Education also said that students should contact specific schools 

to obtain accurate and updated information. While it is important for 

students to contact schools, we found that not all schools listed transferspecific contacts on their websites. Therefore, it is particularly important 

that the required consumer information on articulation agreements be 

easily accessible to students. Moreover, according to Education, online 

disclosure is already required with respect to a school’s credit transfer 

policies if the school has a website, and schools are increasingly using 

their websites to provide other consumer information to students.

Education also cautioned that placing special emphasis on articulation 

agreements could mislead students because the agreements—or lack 

thereof—do not fully reflect the transferability of credits. Specifically, 

Education said that if the few schools with articulation agreements are 

listed on the school’s website or if a school notes that it has no 

articulation agreements, students may erroneously believe that their 

credits will transfer only to those few schools or that none of their credits 

will transfer. However, regardless of the number of articulation 

agreements a school may have, schools are already legally required to 

disclose the list of partner schools. We found that a majority of schools 

already disclose a list of partner schools on their websites, and it is 

unclear why posting this required information online would be more 

confusing than disclosing this information through publications or other 

means. Further, according to Education, schools are also legally required 

to disclose their credit transfer policies online, in effect, outlining the 

circumstances under which students can generally transfer credits. 

Therefore, using a school’s website to disclose the list of other schools 

with which there are articulation agreements, or the fact that there are no 

Agency Comments 

and Our Evaluation
Page 39 GAO-17-574 College Credit Transfer

agreements, would enhance students’ understanding of their transfer 

options and help reduce confusion rather than mislead students. 

Education agreed that it would assist students to have more general 

transfer information when students are considering transferring to other 

schools, and said that it plans to include this information on its 

studentaid.gov website. Education also provided technical comments, 

which we incorporated in our report as appropriate. In its technical 

comments, Education proposed that we address the relevance of 

academic performance to the transferability of credits. We agree that this 

is an important factor that can affect credit loss and provided additional 

clarification and references to Education’s research on this topic.

As agreed with your offices, unless you publicly announce the contents of 

this report earlier, we plan no further distribution until 30 days from the 

report date. At that time, we will send copies to the appropriate 

congressional committees, the Secretary of the Department of Education, 

and other interested parties. In addition, the report will be available at no 

charge on the GAO website at http://www.gao.gov. If you or your staff 

have any questions about this report, please contact me at (617) 788-

0534 or emreyarrasm@gao.gov. Contact points for our Offices of 

Congressional Relations and Public Affairs may be found on the last page 

of this report. GAO staff who made key contributions to this report are 

listed in appendix V.

Melissa Emrey-Arras, Director

Education, Workforce, and Income Security
Appendix I: Objectives, Scope, and 

Methodology

Page 40 GAO-17-574 College Credit Transfer

This report examines: (1) How many college students transfer and what 

challenges, if any, do they face in transferring credits? (2) What are 

possible financial implications associated with transferring credits? and 

(3) To what extent are students provided with information about transfer 

policies to help them plan their college path? To address these questions, 

we interviewed stakeholders from 25 higher education organizations and 

schools, analyzed transfer and tuition data from Education’s Beginning 

Postsecondary Students Longitudinal Study (BPS) and Integrated 

Postsecondary Education Data System (IPEDS), and reviewed websites 

for a nationally-representative stratified random sample of schools. We 

assessed the reliability of BPS and IPEDS data by reviewing existing 

information about the data and the system that produced them and 

interviewing officials knowledgeable about the data. We determined that 

the data were sufficiently reliable for the purposes of describing transfer 

students and credit loss rates. We also reviewed Education’s guidance 

and regulations on credit transfer disclosure requirements and consumer 

information for college students, and we compared Education’s practices 

to federal internal control standards. Finally, we reviewed relevant 

literature, federal laws, and interviewed Education officials. This appendix 

provides a detailed description of the methodology used to (1) gather 

testimonial evidence through interviews, (2) analyze Education’s transfer 

and tuition data, and (3) conduct website reviews.

We conducted this performance audit from March 2016 to August 2017 in 

accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.

To understand what challenges, if any, students face in transferring 

credits, we interviewed stakeholders from a non-generalizable sample of 

25 higher education organizations and schools. More specifically, we 

interviewed representatives from 17 higher education organizations and 

officials from eight schools that have expertise in transfers and represent 

a range of viewpoints. We selected higher education organizations that 

met one or more of the following criteria: (1) published relevant research 

or other work, (2) developed guidelines for credit transfer processes, (3) 

developed tools or state policies to help facilitate credit transfers, or (4) 

represented relevant groups involved in the transfer process such as 

Appendix I: Objectives, Scope, and 

Methodology

Overview

Interviews
Appendix I: Objectives, Scope, and 

Methodology

Page 41 GAO-17-574 College Credit Transfer

associations for students, admissions or advising staff, school systems, 

accrediting agencies, and/or state or regional higher education bodies.1

Further, we interviewed stakeholders from eight selected schools to 

obtain additional perspectives from those directly involved in the credit 

transfer process. At each school, we interviewed stakeholders involved in 

the credit evaluation process, such as admissions/advising staff, registrar 

officials, and relevant transfer offices, as appropriate. To ensure we 

obtained perspectives from different school types, we selected a mix of 

public, private nonprofit, and private for-profit schools, and 2- and 4-year 

schools. While we selected a diverse range of schools, we did not equally 

select schools among each school type since some school types have a 

low prevalence or are not typically part of a transfer path. For example, 

we did not interview stakeholders from a 2-year private nonprofit school 

because this school type represents a small segment of schools and, 

correspondingly, a small number of students who transfer to or from that 

type of school. In our selection, we included at least one pair of schools 

with articulation agreements. We chose schools in different geographic 

locations and that represent different transfer environments. For example, 

we identified schools in states with a variety of statewide transfer policies 

and student transfer rates. We used state transfer rate data from the 

National Student Clearinghouse Research Center to inform our selection 

of schools to conduct interviews. We interviewed National Student 

Clearinghouse Research Center officials and reviewed the methodology 

to determine if there are any limitations associated with using the total 

state transfer rate, and determined these data to be reliable for our 

purposes.

For these interviews with stakeholders from 25 higher education 

organizations and schools (stakeholders), we used semi-structured 

interview protocols. To summarize results, we identified commonly 

mentioned themes regarding challenges in the transfer process. We used 

the following terms to summarize themes mentioned by stakeholders: 

“some” or “a few” higher education organizations and schools represent 3 

to 5; “several” represents 6 to 10; and “many” represents 11 to 15. For 

themes mentioned by stakeholders from more than 15 higher education 

organizations and schools, we generally specified the number of groups 

in the text. We corroborated testimonial evidence on transfer challenges 

 1 Speaking with stakeholders from national-level associations allowed us to collect 

perspectives from organizations that represent large numbers of our targeted groups. 
Appendix I: Objectives, Scope, and 

Methodology

Page 42 GAO-17-574 College Credit Transfer

with findings from our analysis of Education’s transfer data and 

documentary evidence from transfer literature or publications.

In addition to the interviews with 25 higher education organizations and 

schools, we collected first-hand accounts from several individual transfer 

students identified by stakeholders from higher education organizations. 

The students provided non-generalizable illustrative examples of 

experiences with the transfer process.

BPS: To estimate the extent to which students’ credits transfer the first 

time they change schools and to identify other characteristics of transfer 

students, we analyzed transfer data from Education’s Beginning 

Postsecondary Students Longitudinal Study (BPS). To estimate the 

extent of credit loss among students, we analyzed transcript data from the 

2004 cohort, the most recently completed. Each cycle of BPS follows a 

cohort of students enrolling in postsecondary education for the first time. 

BPS tracks these students over a 6-year period and collects both survey 

and transcript data. The most recently completed BPS cohort first 

enrolled in postsecondary education in the 2003-04 academic year. The 

final follow-up with this cohort group was the 2008-09 academic year. For 

the purposes of our data analysis, we define transfer students as those 

who moved from one school to another for a period longer than 4 months, 

and the analyses reflect a student’s first transfer only. We define credit 

loss as credits earned at the origin school that were not accepted by the 

destination school. The sector variable was used to categorize schools 

according to whether they were public, private nonprofit, or private forprofit schools at the 2-year or 4-year level. The sector variable reflects the 

level of the highest degree offered at the school. The highest degree 

offered may be different from the predominant degree obtained at the 

school. To incorporate more recent data into the analysis and to further 

understand the potential implications for federal financial aid, we also 

used BPS mid-point data from the cohort of students who began school in 

academic year 2011-12—the 2012 cohort—to describe the number of 

transfers and the financial aid characteristics of more recent transfer 

students. This will only represent data collected midway through the study 

period, and transfer characteristics will change over the remainder of the 

study period as students continue to progress through their 

undergraduate studies and the 6-year time period. While we used 

transcript data to estimate transfer data for the full 6-year study period of 

the 2004 cohort, transcript data are not yet available for the 2012 cohort. 

As a result, to calculate mid-point transfer and financial aid receipt rates 

in the first 3 years of the study, we used BPS data based on transfers 

Data Sources and 

Analysis
Appendix I: Objectives, Scope, and 

Methodology

Page 43 GAO-17-574 College Credit Transfer

reported in student interviews. Estimates based on transcript data may 

differ from estimates based on student interview data because interviews 

represent one point in time, whereas transcript data cover an entire study 

period.

To better understand any potential implications for federal financial aid, 

we determined the extent to which transfer students received federal 

financial aid, including Pell Grants and Federal Direct Loans. Federal 

financial aid is awarded based on a student’s total costs, which can 

include non-tuition expenses. Available data do not identify whether the 

cost of credits are covered by Pell Grant, Federal Direct Loans, or other 

financial aid funds specifically.

Because the BPS data are based on probability samples, estimates are 

calculated using the appropriate sample weights provided and reflecting 

the sample design. Each of these samples follows a probability procedure 

based on random selection, and they represent only one of a large 

number of samples that could have been drawn. Since each sample 

could have provided different estimates, we express our confidence in the 

precision of our particular sample’s results as a 95 percent confidence 

interval. This is the interval that would contain the actual population value 

for 95 percent of the samples we could have drawn. Unless otherwise 

noted, all percentage estimates from the BPS data analysis have 95 

percent confidence intervals within +/-10 percentage points of the percent 

estimate, and other numerical estimates have confidence intervals within 

+/-10 percent of the estimate itself. We compared 95 percent confidence 

intervals to identify statistically significant differences between specific 

estimates and the comparison groups.

While the BPS data illustrate the extent to which credits transfer, the data 

do not track the reason why credits did not transfer or the academic 

quality of those credits. The data also do not distinguish whether credits 

accepted counted toward degree requirements for a student’s major. This 

means that credit acceptance cannot be equated with progress toward a 

degree, which would also have financial implications for students. 

Additionally, student decisions may also affect credit transfer and the time 

it takes to complete a degree. For example, students may not ask to have 

their credits evaluated or they may decide to change majors, which would 

make it difficult to attribute the costs of lost credits to the transfer process.

Given these limitations, the potential financial effects associated with lost 

credits are not solely attributable to schools’ credit transfer policies. 

Similarly, differences in financial outcomes for transfer versus non-
Appendix I: Objectives, Scope, and 

Methodology

Page 44 GAO-17-574 College Credit Transfer

transfer students may be due to multiple reasons and not just the credit 

transfer process.

IPEDS: To provide information on tuition by school type (i.e., public, 

private for-profit, and private nonprofit) and level of degree program (i.e., 

2-year, 4-year), we calculated average net tuition by analyzing the tuition 

and non-tuition portions of the 2013-2014 academic year cost of 

attendance obtained from the institutional characteristics component of 

the Integrated Postsecondary Education Data System (IPEDS). We 

chose the 2013-2014 period because it contained the most recent net 

price data available at the time of our analysis. IPEDS gathers data from 

every college, university, and technical and vocational institution that 

participates in federal student aid programs, so the data cover the 

population of interest for this study. Net tuition is the cost of attendance 

minus financial aid and non-tuition portions of attendance.2 To estimate 

net tuition, we started with the net price variable, which is equal to the 

cost of attendance (i.e., tuition, fees, room and board, books and other 

expenses) minus financial aid. We then used other IPEDS variables to 

calculate the non-tuition portion of the cost of attendance and subtracted 

that value from the net price to estimate net tuition. We used net tuition 

data instead of published tuition because it is a more realistic portrayal of 

what students might actually pay. IPEDS net price data is collected at the 

school-level based on average charges for first-time, full-time 

undergraduate students, and does not account for variation in the tuition 

charged to individual students at the same school. In addition, many 

schools charge tuition by program or have different fees based on the 

specific major, which is not accounted for in the per-credit net tuition 

average estimates. Further, net tuition may underestimate costs for 

transfer students because, according to Education, schools often do not 

offer the same amount of institutional aid to transfer students compared to 

first-time, non-transfer students. 

Transfer Scenarios: To describe possible financial implications for 

students and the federal government associated with transferring credits, 

we present a variety of example transfer path scenarios. To create 

scenarios illustrating financial implications for students, we selected the 

transfer paths that were among the most common paths based on our 

 2 Non-tuition portions of cost of attendance include books and supplies, room and board, 

and other expenses. Net tuition is based on first-time, full-time undergraduate students. At 

some schools, these students may represent a small proportion of the total undergraduate 

student population. 
Appendix I: Objectives, Scope, and 

Methodology

Page 45 GAO-17-574 College Credit Transfer

transfer frequency analysis of each school control type (public, private 

nonprofit, and private for-profit).3 These transfer scenarios vary in the 

number of credits lost during transfer, type of transfer, type of school, and 

average net tuition. To create a scenario to illustrate the financial 

implications of transfer for the government, we assume the student 

received the average per credit Pell Grant receipt based on BPS data. 

For both types of transfer scenarios (showing possible financial 

implications for students and the government), we base credit loss 

assumptions on 2004-2009 BPS transcript data. The assumption for the 

number of credits lost is informed by the average percentage of credits 

lost for the relevant transfer path. We base tuition assumptions on 2013-

2014 IPEDS data on tuition by school type, and tuition values are from 

the 2013-2014 academic year. Because these scenarios are used for 

illustrative purposes and we are not estimating tuition costs of a particular 

cohort of students, we chose assumptions that were reflective of the 

higher education environment using the best available data. Accordingly, 

we used the most recently available data from BPS and IPEDS, though 

the time periods do not match because the datasets have different 

collection periods.

We calculated the financial implications for students in the transfer 

scenarios by comparing the potential tuition for completing a degree at 

the origin and destination schools for a transfer student to the potential 

tuition for completing the same (120) credits for a degree at the 

destination school. We made various assumptions for these calculations. 

The scenarios assume that all students would pay tuition on a per-credit 

basis to retake credits lost during transfer, and that students attending 

public schools would pay in-state tuition. The financial implications of 

transfer would be impacted by whether a student attending a public 

school pays in-state or out-of-state tuition. We also assume that credits 

that are transferred will count toward graduation requirements. However, 

it is important to note that schools can accept transfer credits as elective 

credit but not allow the credit to be used toward a specific degree 

program. The calculations for the financial implications for students do not 

account for how students may use financial aid to offset out-of-pocket 

tuition costs, so the identified costs may not all be borne by the students. 

 3 The two transfer paths we selected for each school control type are: 2-year public to 4-

year public and 4-year public to 4-year public (for public schools); 2-year public to 4-year 

private nonprofit and 4-year private nonprofit to 4-year public (for private nonprofit 

schools); and 2-year public to 4-year private for-profit and 2-year private for-profit to 2-

year public (for private for-profit schools).
Appendix I: Objectives, Scope, and 

Methodology

Page 46 GAO-17-574 College Credit Transfer

The calculations also do not account for the opportunity cost of staying in 

school longer, in the form of lost wages, or other factors that may affect a 

student’s decision to transfer, such as differences in room and board, 

expected lifetime earnings, quality of life, etc. Lastly, we apply average 

credit loss rates for the purposes of these scenarios. It is important to 

note that schools may have legitimate reasons to not accept some 

transfer credits, such as insufficient quality of prior instruction or lack of 

applicability to the chosen program of study, among other reasons.

To determine the extent to which schools provide students with 

information on transfers to help them plan their college path, we reviewed 

websites from a nationally-representative sample of 214 schools 

participating in federal student aid programs. The sample was stratified 

and randomly drawn from Education’s 2014-2015 IPEDS, which contains 

data for all schools that participate in federal student aid programs 

authorized under Title IV of the Higher Education Act of 1965, as 

amended. Our sampling frame consisted of all public, private nonprofit, 

and private for-profit 2-year and 4-year degree granting schools that 

participated in Title IV federal student aid programs, had undergraduate 

programs, were not U.S. military academies, and had at least 100 

students, yielding a universe of 4,309 schools. We dropped schools from 

our sample that were no longer operational at the time of our review. 

During our review period, several schools selected for our sample closed. 

To ensure that we had an adequate sample size for each school type, we 

drew an additional sample of schools from IPEDS that excluded the 

schools from our original sample and the closed schools. We created six 

strata to stratify the sampling frame by school type (public, private 

nonprofit, and private for-profit) and level of degree program (2-year and 

4-year). This sample of schools allowed us to make national estimates 

about the availability of transfer information, as well as estimates by 

school type. The percentage estimates for website review results for the 

overall population reported from this review have 95 percent confidence 

intervals of +/- 7 percentage points unless otherwise noted.

In order to review comparable information across the sampled schools, 

we developed a standardized web-based data collection instrument that 

we used to examine on each website the availability of credit transfer 

policies, articulation agreement lists, and other transfer information, such 

as contacts and tools to help transfer students, frequently asked 

questions, and deadlines for submitting information. We used a 

combination of information from our interviews, transfer literature, and 

relevant federal laws, regulations, and website usability guidelines to 

Website Review
Appendix I: Objectives, Scope, and 

Methodology

Page 47 GAO-17-574 College Credit Transfer

develop the questions included in the data collection instrument. We 

reviewed websites from September 2016 through February 2017. One 

analyst recorded information in the data collection instrument. The 

information was then checked and verified by another analyst. We 

collected complete information for all 214 schools in our sample. We then 

analyzed the information across schools. We did not, as a part of our 

review of school websites, assess the schools for compliance with legal 

disclosure requirements. Instead, this review was intended to understand 

what information is made accessible to students.

Based on the results of our website review, we conducted targeted followup with school officials to obtain additional information related to course 

credit transfer disclosures. We followed up with two groups of schools. 

For the first group, we prioritized schools whose websites we initially 

determined did not include credit transfer policies or criteria for evaluating 

transfer credits. We contacted all schools in this group and asked school 

officials about how they provided students with information on credit 

transfer policies. For the second group, we contacted a select group of 

schools that did not list partner schools online. We selected schools in the 

second group based on whether they were already selected for follow-up 

in our first group as well as on their representation of different school 

types.
Appendix II: Example of Implementing an 

Articulation Agreement through a Transfer 

Guide

Page 48 GAO-17-574 College Credit Transfer

The following figure depicts information that a school provided on its 

website and illustrates how the school implemented its articulation 

agreement. In this example, a destination school created transfer guides 

specific to origin schools with which it established an articulation 

agreement. These guides show how courses from the origin school would 

transfer into one of the destination school’s degree programs. The format 

of information provided about articulation agreements and the specifics of 

their provisions vary from school to school.

Figure 9: Example of a Transfer Guide Based on an Articulation Agreement

Appendix II: Example of Implementing an 

Articulation Agreement through a Transfer 

Guide
Appendix III: Additional Information on Credit 

Loss and Tuition Averages, and Additional 

Examples of Transfer Scenarios

Page 49 GAO-17-574 College Credit Transfer

This appendix provides estimates of the percentage of credits lost by 

school type, transfer direction, and transfer path; average net tuition by 

school type; the percentage of transfer students who did not obtain a 

degree; and two additional transfer scenario examples that illustrate 

transfer paths that include private for-profit schools.

Table 3: Estimated Percentage of Credits Lost in Transfer, on Average, by School Type, Academic Years 2003-04 to 2008-09

School Type

Percentage of 

Credits Lost

Lower Bound of 

95 Percent 

Confidence 

Interval

Upper Bound of 

95 Percent 

Confidence 

Interval

Percentage of 

Students 

Transferring 

between These 

School Types

Overall Average 43% 40% 45% Not Applicable

Private for-profit to public 94% 86% 100% 4%

Private for-profit to private for-profit 83% 70% 95% 2%

Public to private for-profit 73% 63% 83% 6%

Private nonprofit to private for-profit 71% 50% 92% 1%

Private nonprofit to public 54% 46% 62% 9%

Private nonprofit to private nonprofit 50% 39% 60% 3%

Public to public 37% 34% 40% 62%

Source: GAO analysis of 2004-2009 Beginning Postsecondary Students Longitudinal Study. | GAO-17-574

Note: All estimates presented in this table are statistically different from the public-to-public school 

comparison group. Percentage of students refers to the percentage of the total transfer student 

population in each category. Transfer students are defined as those who moved from one school to 

another for a period longer than 4 months, and estimates in this graphic reflect a student’s first 

transfer only. Our analysis did not control for certain factors that may be related to the ability to 

transfer credits, including whether students informed the school of possible previously earned credits 

eligible for transfer. The upper bound for some estimates was capped at 100 percent.

Appendix III: Additional Information on Credit 

Loss and Tuition Averages, and Additional 

Examples of Transfer Scenarios
Appendix III: Additional Information on Credit 

Loss and Tuition Averages, and Additional 

Examples of Transfer Scenarios

Page 50 GAO-17-574 College Credit Transfer

Table 4: Estimated Percentage of Credits Lost in Transfer, on Average, by Transfer Direction, Academic Years 2003-04 to 

2008-09 

Transfer Direction

Percentage of 

Credits Lost

Lower Bound of 95 

Percent Confidence 

Interval

Upper Bound of 95 

Percent Confidence 

Interval

Percentage of 

Students 

Transferring in 

This Direction

Overall Average 43% 40% 45% Not Applicable

4-year to 2-year 79% 75% 83% 14%

2-year to 2-year 74% 67% 80% 17%

4-year to 4-year 33% 29% 38% 25%

2-year to 4-year 26% 22% 29% 40%

Source: GAO analysis of 2004-2009 Beginning Postsecondary Students Longitudinal Study. | GAO-17-574

Note: All estimates presented in this table are statistically different from the 2-year to 4-year transfer 

direction comparison group. Percentage of students refers to the percentage of the total transfer 

student population in each category. Transfer students are defined as those who moved from one 

school to another for a period longer than 4 months, and estimates in this graphic reflect a student’s 

first transfer only. Our analysis did not control for certain factors that may be related to the ability to 

transfer credits, including whether students informed the school of possible previously earned credits 

eligible for transfer.
Appendix III: Additional Information on Credit 

Loss and Tuition Averages, and Additional 

Examples of Transfer Scenarios

Page 51 GAO-17-574 College Credit Transfer

Table 5: Estimated Percentage of Credits Lost in Transfer, on Average, by Transfer Path, Academic Years 2003-04 to 2008-09

Transfer Path

Percentage of 

Credits Lost

Lower 

Bound of 95 

Percent 

Confidence 

Interval

Upper Bound 

of 95 Percent 

Confidence 

Interval

Percentage of Students 

Using This Transfer Path

Overall average 43% 40% 45% Not Applicable

2-year private for-profit to 2-year public 97% 91% 100% 1%

2-year public to 2-year private for-profit 95% 89% 100% 1%

4-year private for-profit to 2-year public 93% 76% 100% 1%

4-year private nonprofit to 2-year public 79% 71% 87% 4%

4-year public to 2-year public 77% 72% 82% 9%

4-year public to 4-year private for-profit 70% 56% 84% 1%

2-year public to 2-year public 69% 61% 77% 13%

2-year public to 4-year private for-profit 56% 40% 71% 2%

4-year private nonprofit to 4-year private 

nonprofit

49% 38% 61% 3%

4-year public to 4-year private nonprofit 37% 30% 44% 4%

2-year public to 4-year public 22% 18% 27% 26%

Source: GAO analysis of 2004-2009 Beginning Postsecondary Students Longitudinal Study. | GAO-17-574

Note: All estimates presented in this table are statistically different from the 2-year public to 4-year 

public transfer path comparison group. Percentage of students refers to the percentage of the total 

transfer student population in each category. Transfer students are defined as those who moved from 

one school to another for a period longer than 4 months, and estimates in this graphic reflect a 

student’s first transfer only. Our analysis did not control for certain factors that may be related to the 

ability to transfer credits, including whether students informed the school of possible previously 

earned credits eligible for transfer. The upper bound for some estimates was capped at 100 percent.
Appendix III: Additional Information on Credit 

Loss and Tuition Averages, and Additional 

Examples of Transfer Scenarios

Page 52 GAO-17-574 College Credit Transfer

Table 6: Estimated Average Net Tuition by School Type, Academic Year 2013-14

School Type

Estimated Average

Net Tuition Per Year

Estimated Average

Net Tuition Per Credit

Overall Average $ 8,980 $ 300

Private nonprofit 4-year $ 13,830 $ 460

Private for-profit 4-year $ 12,730 $ 420

Private for-profit 2-year $ 11,290 $ 380

Private nonprofit 2-year $ 10,640 $ 360

Public 4-year $ 4,820 $ 160

Public 2-year $ 1,880 $ 60

Source: GAO analysis of 2013-2014 data from the Integrated Postsecondary Education Data System (IPEDS). | GAO-17-574

Note: Net tuition was calculated by using IPEDS tuition data to estimate the non-tuition portion of the 

cost of attendance and subtracting that value from the net price. Net price is the cost of attendance 

(i.e., tuition, fees, room and board, books, and other expenses) minus financial aid. Tuition values are 

from the 2013-2014 school year.
Appendix III: Additional Information on Credit 

Loss and Tuition Averages, and Additional 

Examples of Transfer Scenarios

Page 53 GAO-17-574 College Credit Transfer

Table 7: Estimated Percentage of Transfer Students Who Did Not Obtain a Degree by Transfer Direction, Academic Years 

2003-04 to 2008-09 

Transfer Direction

Percentage of Students 

Who Did Not Obtain a 

Degree

Lower Bound of 95 Percent 

Confidence Interval

Upper Bound of 95 Percent 

Confidence Interval

All Transfer Students 40% 38% 42%

2-year to 2-year 57% 52% 63%

4-year to 2-year 55% 51% 60%

4-year to 4-year 34% 31% 38%

2-year to 4-year 32% 29% 35%

Source: GAO analysis of 2004-2009 Beginning Postsecondary Students Longitudinal Study. | GAO-17-574

Note: Transfer students are defined as those who moved from one school to another for a period 

longer than 4 months, and estimates in this graphic reflect a student’s first transfer only. The types of 

degrees accounted for are certificate, associate’s degree, and bachelor’s degree.

The transfer scenarios in the following figure illustrate possible financial 

implications of additional transfer paths for students.1 More specifically, 

these transfer scenarios illustrate potential financial implications for two 

transfer paths that are among the most common and involve private forprofit schools, based on our BPS analysis. Nonetheless, each of these 

transfer paths accounted for 2 percent or less of transfer students. In the 

transfer from 2-year public to 4-year private for-profit school example, the 

student accrues savings compared to attending the destination 4-year 

private for-profit school for the entire degree program because the 

student is able to transfer almost half the 60 credits earned at the less 

expensive 2-year public school. Net tuition at the 4-year private for-profit 

school is approximately seven times more expensive than at the 2-year 

public school. In the transfer from 2-year private for-profit to 2-year public 

school example, the student incurs additional costs compared to 

attending the destination 2-year public school for the entire degree 

program because the student has to repeat almost all of the 30 credits 

earned at the 2-year private for-profit school. This transfer path has a high 

credit loss rate. In addition, the credits the student lost from the 2-year 

private for-profit school were relatively expensive compared to the cost of 

credits at the destination 2-year public school.

 1 Assumptions for credit loss and net tuition are based on estimated averages from BPS 

and IPEDS data. See appendix I for more details on the methodology and table 6 for net 

tuition averages by school type. 

Additional Transfer 

Scenarios
Appendix III: Additional Information on Credit 

Loss and Tuition Averages, and Additional 

Examples of Transfer Scenarios

Page 54 GAO-17-574 College Credit Transfer

Figure 10: Additional Transfer Scenarios and Potential Financial Implications for Students

Notes: These scenarios base credit loss and net tuition assumptions on estimated averages for each 

specified transfer path from the 2004-2009 Department of Education’s (Education) Beginning 

Postsecondary Students Longitudinal Study (BPS) and 2013-2014 Integrated Postsecondary 

Education Data System data. The scenarios assume that all transferred credits apply to degree 

requirements, the student pays tuition on a per-credit basis to retake credits lost during transfer, and 

the student pays in-state tuition if attending a public school. Financial implications for students do not 

account for how students may use financial aid to offset out-of-pocket tuition costs. Net tuition is 

based on data for first-time, full-time undergraduate students and may underestimate costs for 

transfer students because, according to Education, schools often do not offer the same amount of 

institutional aid to transfer students compared to first-time, non-transfer students. Based on our 

analysis of BPS data on students who transferred, 2 percent transferred from 2-year public to 4-year 

private for-profit schools, and 1 percent transferred from 2-year private for-profit to 2-year public 

schools.
Appendix IV: Comments from the Department 

of Education

Page 55 GAO-17-574 College Credit Transfer

Appendix IV: Comments from the 

Department of Education
Appendix IV: Comments from the Department 

of Education

Page 56 GAO-17-574 College Credit Transfer
Appendix V: GAO Contact and Staff 

Acknowledgments

Page 57 GAO-17-574 College Credit Transfer

Melissa Emrey-Arras, (617) 788-0534 or emreyarrasm@gao.gov

In addition to the contact named above, Meeta Engle (Assistant Director); 

Amrita Sen (Analyst-in-Charge); Elizabeth Hartjes, Connor Kincaid, Jean 

McSween, John Mingus, and Dae Park made key contributions to this 

report. Also contributing to this report were Susan Aschoff, James 

Bennett, Deborah Bland, Alicia Cackley, Evelyn Calderon, Yue Pui Chin, 

Michelle Duren, Gustavo Fernandez, Alexander Galuten, Timothy 

Guinane, Sharon Hermes, Laura Hoffrey, Bill Keller, Sheila McCoy, 

Jennifer McDonald, Jeffrey Miller, Amy Moran Lowe, Alexandra Rouse, 

Katherine Siggerud, Alexandra Squitieri, and Christopher Zbrozek.

Appendix V: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments

(100724)
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