Report to Congressional Requesters

United States Government Accountability Office

GAO

October 2005 TRANSFER 

STUDENTS 

Postsecondary 

Institutions Could 

Promote More 

Consistent 

Consideration of 

Coursework by Not 

Basing Determinations 

on Accreditation 

GAO-06-22 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

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

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Cornelia Ashby, 

(202) 512-7215, ashbyc@gao.gov. 

Highlights of GAO-06-22, a report to 

congressional requesters 

October 2005

TRANSFER STUDENTS

Postsecondary Institutions Could 

Promote More Consistent Consideration 

of Coursework by Not Basing 

Determinations on Accreditation 

When deciding which credits to accept from transfer students, receiving 

institutions consider the sending institution's type of accreditation, whether 

academic transfer agreements with the institution exist, and the 

comparability of coursework. However, institutions vary in how they 

evaluate and apply a student’s transferable credits. Many officials from 

postsecondary institutions with regional accreditation told GAO that they 

would not accept credits earned from nationally accredited institutions. To 

streamline the transfer process, most institutions have transfer agreements 

with other institutions that generally provide for the acceptance of credits 

from the other institution without further evaluation. In some instances, 

institutions review student credits—not rejected for other reasons, such as 

accreditation—to determine comparability to their academic offerings. 

 

State legislation, statewide initiatives, and the accreditation standards that 

accrediting agencies set help facilitate the transfer of academic credits from 

one postsecondary institution to another. Among other things, states support 

the establishment of statewide transfer agreements, common core curricula, 

and common course numbering systems. Accrediting agencies facilitate the 

transfer process through the standards they set. The accrediting agencies 

that GAO reviewed generally adhere to the principle that institutions should 

not accept or deny transfer credit exclusively on the basis of a sending 

institution’s type of accreditation. 

Potential Outcomes for Students Seeking Transfer of Academic Credits 

Source: GAO analysis and Art Explosion.

Receiving 

institution

Sending institution

Admissions Academic 

department

Accept Reject Accept Reject

? ?

Transcript

Rejects

Accept all;

graduate

on time

Accept some

Accept 

none Must start

over

May need additional 

coursework 

to graduate

A student’s inability to transfer credit may result in longer enrollment, more 

tuition payments, and additional federal financial aid, but current data do not 

allow GAO to quantify its effects on the students or the federal government. 

Data are not available on the number of credits that do not transfer, making 

it difficult to assess the actual costs associated with nontransferable credits. 

Each year thousands of students 

transfer from one postsecondary 

institution to another. The credit 

transfer process, to the extent that 

it delays students’ progress, can 

affect the affordability of 

postsecondary education and the 

time it takes students to graduate. 

Seeking information on the 

processes and requirements that 

postsecondary institutions have in 

place to assess requests to transfer 

academic credits, Congress asked 

GAO to examine (1) how 

postsecondary education 

institutions decide which credits to 

accept for transfer, (2) how states 

and accrediting agencies facilitate 

the credit transfer process, and (3) 

the implications for students and 

the federal government of students’ 

inability to transfer credits. 

What GAO Recommends

GAO suggests that Congress 

consider further amending the 

Higher Education Act of 1965 to 

require postsecondary institutions 

eligible for Title IV funding to not 

deny the transfer of credit on the 

basis of a sending institution’s type 

of accreditation. 
Page i GAO-06-22 Transfer Students 

Letter 1

Results in Brief 3 

Background 4 

Institutions Consider Accreditation, Transfer Agreements, and 

Coursework Equivalency when Making Credit Transfer 

Decisions, but Policies Vary 8 

Some States and Accrediting Agencies Facilitate the Credit 

Transfer Process 15 

Students’ Inability to Transfer Credits May Have Cost Implications, 

but Financial Effects on Students and the Federal Government 

Are Unknown 21 

Conclusions 22 

Appendix I Scope and Methodology 24 

Appendix II State Legislation Related to Transfer of Academic 

Credit 28 

Appendix III Comments from the Department of Education 35 

Appendix IV GAO Contacts and Staff Acknowledgments 36 

Tables 

Table 1: Information from Regional Accrediting Agencies on the 

Role of Accreditation in Credit Transfer Decisions 20 

Table 2 : Source and Response Rate of GAO’s Sampling of 

Education’s IPEDS Database 25 

Figures 

Figure 1: Types of First-Time Transfers between 1995 and 2001 5 

Figure 2: Percentage of Enrolled Postsecondary Students Enrolled 

in Public, Private Nonprofit, and Private For-Profit 

Institutions Participating in Title IV 7 

Contents 
Page ii GAO-06-22 Transfer Students 

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

Type 7 

Figure 4: The Evaluation Process for Transfer Credits 14 

Abbreviations 

AACC American Association of Community Colleges 

AACRAO American Association of Collegiate Registrars and 

 Admissions Officers 

BPS Beginning Postsecondary Students 

CCA Career College Association 

CHEA Council for Higher Education Accreditation 

CSU California State University 

FACT Florida Academic Counseling and Tracking for Students 

HEA Higher Education Act 

IPEDS Integrated Postsecondary Education Data System 

IHEP Institute for Higher Education Policy 

NATN National Articulation and Transfer Network 

NCES National Center for Education Statistics 

NELS National Educational Longitudinal Study 

SUNY State University of New York 

UC University of California 

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

United States. It may be reproduced and distributed in its entirety without further 

permission from GAO. However, because this work may contain copyrighted images or 

other material, permission from the copyright holder may be necessary if you wish to 

reproduce this material separately. 
Page 1 GAO-06-22 Transfer Students 

October 18, 2005 

The Honorable Michael B. Enzi 

Chairman 

Committee on Health, Education, Labor, and Pensions 

United States Senate 

The Honorable John A. Boehner 

Chairman 

Committee on Education and the Workforce 

House of Representatives 

The Honorable Howard P. “Buck” McKeon 

Chairman 

Subcommittee on 21st Century Competitiveness 

Committee on Education and the Workforce 

House of Representatives 

Because thousands of students transfer each year from one postsecondary 

institution to another, the credit transfer process, to the extent that it 

delays students’ progress, can affect the affordability of postsecondary 

education and the time it takes students to graduate. As of 2001, 40 

percent of students entering college in the 1995-1996 academic year 

attended at least two institutions during the next 6 school years. Annually, 

the federal government invests billions of dollars—$21 billion in 2004—in 

student financial aid under the Higher Education Act of 1965, as amended 

(HEA). Because of the federal government’s large investment in student 

financial aid, it is in the best interest of taxpayers that transfer students do 

not unnecessarily repeat coursework, since such repetition could result in 

additional financial aid awards. 

Postsecondary institutions, state governments, and accrediting agencies 

all play critical roles in the transfer process. As part of the transfer 

process, receiving institutions must decide whether the credits of 

incoming students are equivalent to those of their own course offerings. 

States can influence the transfer process through legislation and 

regulation, and accrediting agencies provide general guidelines regarding 

the transfer of credit. Congress requires postsecondary institutions to be 

accredited by an accrediting agency recognized by the Department of 

Education (Education) before its students can become eligible for federal 

financial aid. 

 

United States Government Accountability Office

Washington, DC 20548 
Page 2 GAO-06-22 Transfer Students 

In recent years, the ability of students to transfer credits has taken on 

added importance because of increasing numbers of transfer students and 

the changing nature of the types of institutions they attend. In general, 

Education recognizes two main types of accrediting agencies—regional 

and national. Regional accrediting agencies review institutions in a region 

of the United States that includes at least three states that are reasonably 

close to one another. National accrediting agencies review programs or 

specialized institutions, such as acupuncture schools or private business 

schools, on a national basis. In recent years, some nationally accredited 

institutions have broadened their curricula to bring their course offerings 

into line with those of traditional 4-year academic institutions. Yet 

students from these types of institutions have complained that they have 

been denied transfer credits on the basis of accreditation. 

As Congress considers the reauthorization of HEA, it has requested 

information on the processes and requirements that postsecondary 

institutions have in place to assess requests to transfer academic credits. 

You asked us to provide information on the credit transfer process, 

including how and when decisions are made to accept or reject credits for 

transfer. Specifically in this report, we examined (1) how postsecondary 

education institutions decide which credits to accept for transfer, (2) how 

states and accrediting agencies facilitate the credit transfer process, and 

(3) the implications for students and the federal government of students’ 

inability to transfer credits. 

To answer these questions, we reviewed transfer of credit policies from a 

nationally representative random sample of 2-year public and 4-year public 

and private institutions. In addition, we conducted site visits in California, 

Florida, Missouri, New Jersey, and New York, where we interviewed 

officials from public, private nonprofit, and private for-profit 

postsecondary institutions that were nationally and regionally accredited. 

In order to get a broad perspective on the challenges that students face 

when transferring credit, we selected states with large transfer student 

populations and varying levels of involvement in the credit transfer 

process. We also interviewed officials from state education agencies 

regarding institutional transfer policies and state initiatives to facilitate 

credit transfer. We also interviewed officials from accrediting agencies and 

national experts on credit transfer. Further, we reviewed state legislation 

and accrediting agencies’ standards concerning transfer of credits. Finally, 

we examined Education’s databases on postsecondary institutions. We 

reviewed documentation about the various methodologies used to collect 

the data in the databases and conducted interviews to establish the 

reliability of the data. We conducted our work from January 2005 through 
Page 3 GAO-06-22 Transfer Students 

September 2005 in accordance with generally accepted government 

auditing standards. For a more detailed explanation of our methodology, 

see appendix I. 

When deciding which credits to accept from transfer students, receiving 

institutions consider the sending institution’s type of accreditation, 

whether academic transfer agreements with the sending institution exist, 

and the comparability of coursework, but policies vary in how they 

evaluate and apply a student’s transferable credits. About 84 percent of 

institutions consider whether the sending institution is accredited, and 

many consider the type of accreditation—national or regional—when 

determining which transfer credits to accept. Many institutions’ transfer 

policies specify that they only accept credits from a regionally accredited 

institution. As a result, students from nationally accredited institutions 

may have their credits denied on the basis of their previous institution’s 

type of accreditation. About 69 percent of the institutions have agreements 

with other institutions to streamline the transfer process. In these 

agreements, receiving institutions, after reviewing the sending institution’s 

coursework and faculty credentials, agree to accept credits directly from 

the sending institution without further evaluation. If agreements do not 

exist, many institutions review student coursework to determine its 

equivalency and applicability toward a degree. The processes institutions 

follow when evaluating the transferability of prior coursework and 

accepting credits for transfer vary. Specifically, institutions vary in how 

they evaluate credits, who makes the decisions to accept credits, and 

when credit transfer decisions are made. For example, some institutions 

evaluate transfer credits prior to student transfer, while others make final 

credit transfer decisions after student enrollment. 

State legislation, statewide initiatives, and the accreditation standards that 

accrediting agencies set help facilitate the transfer of academic credits 

from one postsecondary institution to another. Some states facilitate the 

transfer of credit among their public institutions through a variety of 

statewide legislation and initiatives that, among other things, support the 

establishment of statewide transfer agreements, common core curricula, 

and common course numbering systems, and encourage institutions and 

others to make transfer information available to the public. Accrediting 

agencies facilitate the transfer process through the standards they set. The 

accrediting agencies we reviewed set standards for accreditation that 

require institutions to review the educational quality of the sending 

institution, the comparability of credit to be transferred to the receiving 

institution, and applicability of the credit in relation to the programs being 

Results in Brief 
Page 4 GAO-06-22 Transfer Students 

offered at the receiving institution. In addition, the six regional accrediting 

agencies that we reviewed generally encourage member institutions not to 

use the sending institution’s type of accreditation as the sole factor in 

determining which credits to accept for transfer. 

A student’s inability to transfer credit may result in longer enrollment, 

more tuition payments, and additional federal financial aid, but the full 

extent to which these occur cannot be determined because institutions 

told us that they do not collect specific data on students unable to transfer 

credit. If the receiving institution decides that few or no credits earned at 

the sending institution are equivalent to its course offerings, the student 

may need to repeat coursework that could result in enrolling for one or 

more additional terms. National data indicate that graduates who 

transferred from a community college take on average 10 more credits and 

3 more months than nontransfer graduates. Transfer graduates may take 

more credits for reasons, such as changing majors, which are not related 

to their decision to transfer. We could not determine the extent to which 

transfer students differ from nontransfer students in these areas. However, 

a student taking additional credits as a result of being unable to transfer 

credits will likely have to pay additional tuition, ranging from $150 per 

credit hour at public institutions to $520 per credit hour at private 

institutions. The extent to which these costs are borne by the student or 

the federal government varies depending on the student’s eligibility for 

financial aid. 

In this report, we suggest that Congress consider amending the Higher 

Education Act of 1965 to require postsecondary institutions eligible for 

federal financial aid to issue a statement in their transfer of credit policy 

that they will not deny the transfer of credit on the basis of a sending 

institution’s type of accreditation. 

Patterns of enrollment in postsecondary education reflect that students 

frequently enroll in more than one postsecondary institution. Education’s 

National Center for Educational Statistics (NCES) found that 40 percent of 

students who entered college in the 1995-1996 academic year attended at 

least two institutions in the following six years. Many students enroll in 

community colleges with a plan for eventually transferring to a 4-year 

baccalaureate program. As a result, 4-year institutions face pressure to 

award transfer credit for coursework taken at another institution. 

Data show that students transfer in numerous directions. Traditional 

transfer is typically from a 2-year institution to a 4-year institution. 

Background 
Page 5 GAO-06-22 Transfer Students 

However, students also transfer from 4-year institutions to 2-year 

institutions, known as reverse transfer, as well as laterally between similar 

institutions (e.g., 2-year to 2-year or 4-year to 4-year). As shown in figure 1, 

traditional transfer accounts for at least one-third of first transfer activity. 

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

When students want to transfer their earned academic credits from one 

institution to another, they must submit a transcript showing their 

coursework and earned grades to the receiving institution. The receiving 

institution may then evaluate the transcript and assess the educational 

quality of the student’s learning experience, compare the level and content 

of the learning experience with those of the learning experience offered by 

the receiving institution, and determine the applicability of the student’s 

coursework to the degree or programs offered at the receiving institution. 

To help streamline the evaluation process, sending and receiving 

institutions enter into voluntary transfer agreements, which contain 

criteria for credits to transfer. 

Today, many students who begin their studies at private, for-profit 

institutions transfer to public or private nonprofit 4-year institutions. To 

meet this demand, many private, for-profit institutions have revamped 

their curricula, transforming what had chiefly been vocational training 

35%

16%

16%

11%

4%

18%

Source: Beginning Postsecondary Students.

• Public 2-year to public 2-year

• 4-year to 4-year

• 4-year to public 2-year

•

•

•

For-profit to public or not-for-profit

All others

Public 2-year to 4-year
Page 6 GAO-06-22 Transfer Students 

aimed at job placement to a core educational curriculum that prepares 

students to pursue associate’s, bachelor’s, and even graduate degrees. 

The Department of Education administers federal postsecondary 

education programs, including the Title IV federal financial aid programs 

under the Higher Education Act of 1965, as amended. To be eligible for 

federal financial aid, a postsecondary institution must be accredited by an 

accrediting agency recognized by the Secretary of Education. Accrediting 

agencies are private educational associations of regional or national scope 

that develop evaluation standards and conduct site visits to evaluate 

postsecondary institutions. To become recognized, an accrediting agency 

must submit a written application to Education that lays out its standards 

for accrediting institutions as well as its procedures for ensuring that 

institutions follow those standards. Education requires accrediting 

agencies to set standards that instruct institutions to have the resources 

and policies in place to provide a quality education. Education applies the 

same requirements to both regional and national accrediting agencies. 

Education has recognized eight regional accrediting agencies that 

generally accredit academic degree granting institutions in their specific 

region of the country, and about 50 national accrediting agencies that 

accredit various kinds of specialized postsecondary institutions, such as 

technological or religious institutions, and programs such as nursing and 

engineering. 

The most current national data on students show that in September 2003, 

an estimated 15.2 million students were enrolled in postsecondary 

institutions; 77 percent of these students were enrolled in public 

institutions, 17 percent in private nonprofit institutions, and 6 percent 

enrolled in private for-profit institutions.1

 Additionally, about 6,900 degreeand non-degree-granting postsecondary education institutions had 

students that were receiving federal financial aid. Figure 2 shows the 

percentage of students attending public, private nonprofit, and private forprofit institutions, and figure 3 shows the type of institutions receiving 

these funds. 

 1

 Integrated Postsecondary Education Data System, U.S. Department of Education. 
Page 7 GAO-06-22 Transfer Students 

Figure 2: Percentage of Enrolled Postsecondary Students Enrolled in Public, 

Private Nonprofit, and Private For-Profit Institutions Participating in Title IV 

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

Source: GAO analysis of Integrated Postsecondary Education Data System 

17%

77%

6%

• Public

• Private nonprofit

•

Private for-profit

Source: GAO anaysis of Integrated Postsecondary Education Data System.

38%

31%

31%

Private for-profit

Public

Private nonprofit •

•

•
Page 8 GAO-06-22 Transfer Students 

In order to acquire federal financial aid, students are required, among 

other things, to demonstrate financial need, demonstrate qualifications to 

enroll in postsecondary education, be working toward an eligible degree 

or certificate, be a U.S. citizen or eligible noncitizen, and maintain 

satisfactory academic progress while in school. Education uses a formula 

to determine the amount of a student’s financial need and his or her 

expected family contribution toward tuition, taking into account a number 

of factors including the student’s or family’s resources and the costs of 

attending an institution. In their financial aid packages, students may 

receive federal grants or loans, with the neediest students receiving about 

$4,000 per year in a Pell grant and up to $4,000 in loans under the Perkins 

loan program. Additionally, all students qualify to receive Stafford loans 

for which the government may subsidize or defer the loan interest while 

students remain enrolled in school. 

Prior to granting credit for courses taken at another institution, 

institutions may consider a variety of criteria, such as accreditation, 

transfer agreements, and course equivalency. Many institutions consider 

the accreditation of the sending institution, including the type of 

accreditation—national or regional—when determining which transfer 

credits to accept. Institutions may also assess the equivalency of 

coursework taken at other institutions, either through establishing transfer 

agreements covering a number of courses or on a course-by-course basis. 

Though reviewing courses can be time-consuming and maintaining 

transfer agreements requires an ongoing commitment, officials said that 

transfer agreements do facilitate the transfer process. Institutions also 

vary in who makes the final decision on which credits to accept—

administrative official or departmental faculty—and when they inform a 

student of their decision. 

Institutions Consider 

Accreditation, 

Transfer Agreements, 

and Coursework 

Equivalency when 

Making Credit 

Transfer Decisions, 

but Policies Vary 
Page 9 GAO-06-22 Transfer Students 

We found that when making decisions about whether or not to accept 

transfer credits, institutions often used the sending institution’s 

accreditation as the initial measure of the quality of the institution and its 

coursework. We found that about 84 percent of postsecondary institutions 

had policies to consider the accreditation of the sending institution when 

assessing transfer credits.2 About 63 percent of these institutions specified 

that accreditation from any regional accrediting agency was acceptable, 

and about 14 percent specified that they accepted national accreditation.3

Institutions indicating that they accepted regional accreditation told us 

that they also provide students with other options for getting their credits 

transferred, such as passing a competency examination before their 

credits would be granted. Many also said that they would allow any 

student to appeal a decision, and an appeal would result in a more 

thorough review of the student’s transcript. 

Several officials from postsecondary institutions with regional 

accreditation told us that as a rule, they did not accept credits earned at 

institutions with national accreditation. For example, an official at one 

institution told us that the institution did not accept credits from 

nationally accredited institutions because the coursework was technical 

and not academic. Similarly, an official at a regionally accredited 

institution told us that the institution could not accept credits from 

nationally accredited institutions unless the accrediting standards of the 

sending institution paralleled their own standards. One reason given by 

regional accrediting agency official for the incomparability of credits 

earned at nationally accredited institutions was that these institutions 

follow less stringent standards regarding such factors as faculty 

qualifications and library resources. However, our review of the standards 

from the regional accrediting agencies found that no regional accrediting 

agency explicitly stated in its written policy that credits from nationally 

accredited institutions should be denied. 

 2

 Less than 1 percent of postsecondary institutions specified that accreditation is not 

considered, while about 15 percent did not specify whether or not accreditation was 

considered or the information was not available. 

3

 Many institutions’ policies toward national accreditation were unclear and did not 

specifically refer to national accreditation as unacceptable. For example, one institution’s 

credit transfer policy said, “The institution will consider courses from postsecondary 

institutions that are regionally accredited or are candidates for regional accreditation.” In 

this case (and in cases that were similar to this), we considered the policy on national 

accreditation to be unspecified. 

Institutions Consider 

Accreditation when 

Deciding Which Transfer 

Credits to Accept and 

Commonly Accept Credits 

Earned at Regionally 

Accredited Institutions 
Page 10 GAO-06-22 Transfer Students 

We found that about 11 percent of institutions have policies that explicitly 

state that they will accept both regionally and nationally accredited 

credits. For example, one institution’s credit transfer policy states that it 

will accept credits from “universities and colleges with accreditations by 

one of the regional accrediting associations,... community and technical 

colleges with accreditation by one of the regional accrediting 

associations,... and technical colleges, business colleges and other schools 

lacking regional accreditation but having accreditation by another agency 

recognized by the Council for Higher Education Accreditation [CHEA].”4

Officials from a regionally accredited institution told us that they would 

accept credits regardless of accreditation and would review all credits the 

same way. However, this process was more time-consuming than relying 

solely on accreditation. To save time, some institutions had developed 

databases to track previously approved courses in order to remove the 

need to reevaluate them. 

Officials at a nationally accredited institution told us that their students 

often have difficulty transferring credits and that they are taking actions to 

assist their prospective transfer students. They told us that regionally 

accredited institutions did not always accept courses taken at the 

nationally accredited institution. They advised students to assume that 

credits would not transfer to regionally accredited institutions. Two 

nationally accredited institutions we visited have responded to the credit 

transfer difficulties by attaining, or seeking to attain, regional 

accreditation in order to improve their students’ ability to transfer credits. 

One of the three nationally accredited institutions we visited—the 

institution with dual national-regional accreditation—reported having no 

problems with transferring its students to 4-year institutions. In lieu of 

seeking dual accreditation, another nationally accredited institution we 

visited is reaching out to regionally accredited institutions to develop 

transfer agreements to facilitate the transfer process. 

 4

 CHEA is a nonprofit organization that certifies accrediting agencies. 
Page 11 GAO-06-22 Transfer Students 

While many institutions use accreditation as a factor to assess transfer 

credits, about 69 percent of postsecondary institutions have entered into 

voluntary transfer agreements with other institutions.5

 Typically, 

institutions we visited establish transfer agreements with institutions that 

send large numbers of transfer students. For example, Columbia College 

in Missouri—a college with campuses in 11 states—has transfer 

agreements with 18 community colleges throughout the country. In these 

agreements, receiving institutions review a number of courses from 

sending institutions and agree to accept comparable credits from that 

institution. For example, the State University of New York system has a 

transfer agreement among all of its institutions specifying that all 4 year 

universities will accept associate degrees from community colleges within 

its system, thus guaranteeing a baccalaureate degree with the completion 

of 60 additional credits. Agreements can also cover individual courses, 

such as mathematics and science courses that are required prerequisites 

for upper-level courses. 

Institution officials told us that although maintaining transfer agreements 

requires considerable commitment, these agreements are useful because 

they make the transfer process more transparent and allow it to operate 

more smoothly. The agreements require receiving institutions to review 

the course content of each partner institution to determine its 

comparability and applicability to meeting the degree program 

requirements. Maintaining these agreements requires regular ongoing 

communication between participating institutions to keep apprised of all 

new course offerings or any changes to current courses or degree 

requirements. According to officials from several of the schools we visited, 

the process of establishing the agreements and keeping them current 

requires considerable commitment because institutions frequently revise 

their courses and degree requirements. For example, it took one private 

institution in New Jersey a full year to review courses for every 

community college with which it had established new transfer agreements. 

At another institution we visited, the official responsible for credit 

evaluation told us that the time required for maintaining transfer 

agreements had led the institution to reduce the number of its transfer 

agreements by about 25 percent. While transfer agreements can be timeconsuming, they help make the transfer process more transparent. For 

example, in New Jersey, many 4-year institutions have established transfer 

 5

 About 29 percent of institutions had not specified whether they had transfer agreements, 

and the rest, about 2 percent, had no transfer agreements. 

Institutions Said That 

Transfer Agreements, 

though Time-Consuming, 

Do Facilitate Transfers 
Page 12 GAO-06-22 Transfer Students 

agreements with community colleges in the state. Community college 

students may also access a Web page listing courses at their institution 

that will transfer to participating 4-year institutions in New Jersey, 

allowing students to know which credits will transfer before they apply to 

a new institution. One official told us that the transfer agreements, once 

established, allow the credit transfer process to operate smoothly between 

the partnering institutions, because it becomes a matter of checking a list 

to determine which credits to accept or deny. 

Officials offered a variety of reasons for pursuing transfer agreements. In 

some instances, transfer agreements were mandated in state law or 

facilitated by state agencies, but these types of agreements were usually 

between public institutions only. In other instances, institutions sought to 

establish transfer agreements out of convenience because of the 

significant number of students that moved between their institutions. In 

addition to states and institutions, another organization we visited is also 

involved in facilitating the establishment of transfer agreements. To 

improve access to baccalaureate programs for certain populations of 

minority students, the National Articulation and Transfer Network has 

facilitated transfer agreements between community colleges and minorityserving institutions across the country. 6

Some institutions review students’ transcripts to determine the 

comparability of the students’ coursework. Specifically, institutions 

consider the characteristics of individual courses, such as the similarity of 

courses on a student’s transcript to courses offered at the receiving 

institutions and the applicability of the courses to the student’s intended 

major. Institutions may ask for a course description or a class syllabus to 

support their assessment. To expedite this review, some institutions 

maintain a historical list of transfer courses that they have accepted in the 

past. While not always a guarantee of transferability, listed courses have a 

greater likelihood of acceptance than unlisted courses. 

 6

 Participating organizations include the American Association of Community Colleges 

(AACC), American Council on Education (ACE), American Indian Higher Education 

Consortium (AIHEC), Council of the Great City Schools (CGCS), Hispanic Association of 

Colleges and Universities (HACU), National Association for Equal Opportunity in Higher 

Education (NAFEO), American Association of State Colleges and Universities (AASCU), 

and the United Negro College Fund (UNCF). 

Institutions Review the 

Comparability of 

Coursework but Vary in 

How They Administer This 

Process 
Page 13 GAO-06-22 Transfer Students 

At the institutions we visited, two groups of reviewing officials are 

generally responsible for determining which courses to accept for transfer: 

(1) an admissions or other administrative officer, who determines which 

courses meet general requirements, and (2) academic department faculty 

members, who determine which courses meet degree requirements within 

their departments. When reviewing officials consider the student’s official 

transcript, they may review transfer agreements and historical lists of 

accepted courses, request the syllabus or a list of books used in the 

course, or discuss the course with a representative from the sending 

institution or use an Internet service, such as the one maintained by the 

American Association of Collegiate Registrars and Admissions Officers, to 

obtain a syllabus and description of the course, among other things. This 

process is shown in figure 4. 
Page 14 GAO-06-22 Transfer Students 

Figure 4: The Evaluation Process for Transfer Credits 

Some 4-year institutions, citing time constraints and a significant backlog, 

have taken steps to limit the number of courses they review. Some 

institutions have established criteria for transferable courses, such as 

Receiving institution

Sending institution

Admissions Academic 

department

Accept Reject Reject Accept

? ?

Transcript

Rejects

Accept all;

graduate on time

Accept

 some

Accept 

none

Must

start

over

May need additional 

coursework to graduate

Source: GAO analysis and Art Explosion.
Page 15 GAO-06-22 Transfer Students 

determining the minimum grade or course level for which credits will be 

accepted. Several 4-year institutions told us that they did not accept for 

transfer any remedial (developmental) courses, technical courses, or 

upper-level courses taken at a 2-year institution. Because of the backlog 

created by the number of transcripts to review, not all institutions succeed 

in providing students with an official report of transfer credits accepted 

before classes begin. Officials at one institution told us that they provide 

the report within 1 year of the student’s matriculation and encourage 

students to take upper-level general education courses in the interim until 

the report is received. 

To facilitate the transfer of academic credits, states enact a variety of 

legislation and implement statewide initiatives covering primarily public 

postsecondary institutions, and accrediting agencies set accreditation 

standards. Many states have passed legislation that requires public 

community colleges and 4-year public institutions to establish transfer 

agreements and authorizes common curricula to ease the transfer of 

credits. Some states have established a common course numbering system 

for public institutions within the state and created statewide committees 

to oversee the transfer of credit process within the state. In other states, 

state law requires university systems to initiate and form transfer 

agreements with institutions within the system to enhance the 

transferability of credits. Some states have also launched statewide 

initiatives to encourage transfer between 2-year and 4-year public 

institutions, including offering guarantees that credit will transfer. For 

their part, accrediting agencies facilitate the transfer process through the 

standards they set for affiliated institutions. Accrediting agencies that we 

reviewed have set standards for accreditation that require institutions to 

make their credit transfer policy publicly available. The six regional 

accrediting agencies that we reviewed generally encourage their member 

institutions not to accept or deny transfer credit exclusively on the basis of 

the accreditation of the sending institution. Some accrediting agencies 

have incorporated this criterion into their standards; others have issued 

policy or position statements. 

States facilitate the transfer of credits among public institutions through 

various statewide legislation and initiatives that, among other things, 

support the establishment of statewide transfer agreements, common core 

curricula, and common course numbering systems, and encourage 

institutions and others to make transfer information available to the 

public. We identified 39 states that had legislation pertaining to the 

Some States and 

Accrediting Agencies 

Facilitate the Credit 

Transfer Process 

Some State Legislation and 

Statewide Initiatives Ease 

Credit Transfer 
Page 16 GAO-06-22 Transfer Students 

transfer of credit between postsecondary public institutions. In general, 

most of the legislation focuses on facilitating the transfer of credit for 

students transferring from community colleges to 4-year public 

institutions. 

Some states require or encourage the establishment of statewide transfer 

agreements. For example, a Massachusetts statute empowers its board of 

higher education to develop and implement a statewide transfer 

agreement to facilitate the transfer of students without the loss of 

academic credit or standing from one public institution to another. 

Arizona law requires institutions to cooperate in operating a statewide 

transfer network to facilitate the transfer of community college students to 

Arizona public universities without a loss of credit toward a baccalaureate 

degree. An Indiana statute requires the state’s Commission for Higher 

Education to develop statewide transfer of credit agreements for courses 

that are most frequently taken by undergraduates. Colorado’s statewide 

transfer policy guarantees that as many as 37 credits of approved general 

education courses taken at a Colorado public college or university will 

transfer among all 2-year and 4-year institutions in the state. 

Some states require or encourage the establishment of common core 

curricula. A California statute directed the governing boards of the 

University of California, the California State University, and the California 

community colleges to jointly develop and adopt a common core 

curriculum in general education for the purpose of transfer. These efforts 

led to California’s general education transfer curriculum, which identifies 

courses that community college students may complete to satisfy general 

education requirements at campuses of both the University of California 

and California State University systems. An Arkansas statute requires the 

Arkansas Higher Education Coordinating Board to consult with colleges 

and universities to establish a minimum core of courses that applies 

toward the general education core curriculum requirements and is fully 

transferable between state institutions. 

Some states require or encourage the establishment of a common course 

numbering system. Florida has developed a statewide course numbering 

system that provides a database of equivalent postsecondary courses at 

public vocational technical centers, community colleges, universities, and 

participating nonpublic institutions. More than 100 institutions in Texas 

participate in the state’s voluntary course numbering program, which 

provides a shared, uniform set of course designations for students and 

their advisers to use in determining both course equivalency and degree 

applicability of transfer credits on a statewide basis. 
Page 17 GAO-06-22 Transfer Students 

Some state statutes identify the types of courses or blocks of courses that 

are transferable. For example, Missouri officials told us that they interpret 

their state law as requiring all institutions to accept associate degrees from 

any source as evidence that general education courses have been 

completed. Additionally, to facilitate student transfer among Missouri 

institutions and to increase institutions’ accountability for student 

performance in general education, the Coordinating Board for Higher 

Education designed a 42-semester-hour block of general education.7

Similarly, a Texas statute states that if a student successfully completes a 

field-of-study curriculum developed by the state’s board of higher 

education, that block of courses may be transferred and must be 

substituted for the receiving institution’s lower division requirements for 

the comparable degree program, and the student must receive full 

academic credit. Likewise a Kentucky statute mandates that all lower 

division academic courses offered by community colleges be transferable 

for academic credit to any and all 4-year public colleges and universities in 

the state. 

Some state higher education agencies make information on transfer 

agreements and course equivalency guides available to the public. For 

example, some states, such as California, Maryland, and Florida, have 

placed course equivalencies online for easy access and reference. 

California maintains an online student transfer system called ASSIST that 

serves as the official repository of transfer agreements for all public 

postsecondary institutions in California and facilitates transfer from a 

California community college to a University of California or California 

State University campus. Maryland’s interactive online transfer 

information source called ARTSYS allows students to find course 

equivalencies between institutions, evaluate their transcripts, search for 

majors, and explore recommended transfer programs. In addition, it 

provides faculty access to update courses and provide course evaluations. 

The Florida Academic Counseling and Tracking for Students (FACTS) 

system offers a comprehensive range of transfer services, including a 

transfer student bill of rights, links to statewide transfer agreements, and 

 7

 The 42-hour block of general education is required of public institutions and 

recommended for private institutions in the state. 
Page 18 GAO-06-22 Transfer Students 

an interactive transfer evaluation tool.8 A Pennsylvania statute supports 

the implementation of a Web-based application that makes all transfer 

agreements among higher education institutions available on the Internet. 

Similarly, Virginia requires its state council of higher education to 

publicize all general education courses offered at public 2-year 

institutions, designating the courses accepted for transfer credit at 4-year 

public and private postsecondary institutions in Virginia. Ohio 

implemented a framework that guarantees students a statewide transfer 

and published a transfer assurance guide to advise students of the 38 

different baccalaureate degree pathways available for them to pursue 

anywhere within the public higher education system and in Ohio’s 

participating private institutions, and to identify which courses are 

guaranteed to transfer and apply to requirements within the system. 

While state legislation regarding credit transfer is generally intended to 

facilitate the transfer of credits among public institutions, a few state 

statutes require or encourage the involvement of private institutions. For 

example, the Louisiana Board of Supervisors of Community and Technical 

Colleges is required to continue development of articulation agreements 

between institutions under the management of the board and institutions 

managed by other postsecondary management boards, both public and 

private. A Minnesota statute requests the governing boards of private 

institutions that grant associate and baccalaureate degrees and have a high 

frequency of transfer students to participate in the development of 

required course equivalency guides. A West Virginia statute requires the 

state’s Council for Community and Technical College Education to 

establish and implement policies and procedures that ensure that students 

may transfer and apply the credits earned at any regionally accredited instate or out-of-state higher education institution. 

 8

 Unlike California’s and Maryland’s systems, which are devoted to transfer information, 

Florida’s FACTS system assists users in determining career objectives, choosing the major 

and institutions that are best suited for them, applying for admission and financial aid, and 

tracking their progress toward a degree or certificate. In addition, it allows students to 

access their grades and transcripts online. 
Page 19 GAO-06-22 Transfer Students 

Accrediting agencies’ standards for evaluating transfer credit generally 

reflect the three criteria specified in a 1978 joint national statement on the 

transfer and award of credit: the educational quality of the sending 

institution, the comparability of credit to be transferred to the receiving 

institution, and applicability of the credit in relation to the programs being 

offered at the receiving institution.9 These agencies’ accrediting standards 

generally require receiving institutions to consider if courses are 

equivalent with their own curricula and standards. In 2000, CHEA issued 

an updated statement that offered four additional criteria that accrediting 

agencies and institutions should consider when making decisions about 

transfer of credit and academic quality. Specifically, these criteria 

emphasized the need for institutions and accrediting agencies to 

(1) ensure that transfer decisions are not solely based on the 

source of accreditation of a sending program or institution, 

(2) reaffirm that the considerations that inform transfer decisions 

are applied consistently in the context of changing student 

attendance patterns and emerging new providers of higher 

education, 

(3) ensure that students and the public are fully and accurately 

informed about their respective transfer policies and practices, and 

(4) be flexible and open in considering alternative approaches to 

managing transfer when these approaches will benefit students. 

The accrediting standards and transfer policies of the 6 regional and 10 

national accrediting agencies that we reviewed generally reflect the 

original criteria included in the 1978 joint statement.10 In addition, some 

accrediting agencies incorporated into their standards the CHEA criteria 

added in 2000 that the institutions’ process for accepting transfer credit be 

fair, consistently applied, and publicly communicated. 

 9

 The joint statement was developed by the three national associations whose member 

institutions are directly involved in the transfer and award of academic credit: the 

American Association of Collegiate Registrars and Admissions Officers, the American 

Council on Education, and the Council for Higher Education Accreditation. 

10 We reviewed accrediting standards of the 6 regional accrediting agencies that accredit 

senior institutions (i.e., those that grant bachelor’s degrees) and the 10 national accrediting 

agencies that accredit degree-granting institutions, rather than programs. 

Accrediting Agencies Set 

Accreditation Standards, 

and Some Encourage 

Institutions to Promote the 

Consistent Evaluation of 

Transfer Credit 
Page 20 GAO-06-22 Transfer Students 

The 6 regional accrediting agencies that we reviewed all support CHEA’s 

statement on the role of accreditation in the credit transfer decisionmaking process. As shown in table 1, some accrediting agencies have 

incorporated this criterion into their standards; others have issued policy 

or position statements. 

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

Agency Information source Specific language 

Middle States Commission on 

Higher Education 

Standards “The acceptance or denial of transfer credit will not be determined 

exclusively on the basis of the accreditation of the sending institution 

or the mode of delivery, but rather will consider if the course is 

equivalent, including expected learning outcomes with those of the 

receiving institution’s curricula and standards. Such criteria will be 

fair, consistently applied, and publicly communicated.” 

New England Association of 

Schools and Colleges 

Standards “Accreditation speaks to the probability but does not guarantee that 

students have met acceptable standards of educational 

accomplishment. . . . Since accreditation does not address 

[comparability and applicability], the information must be obtained 

from catalogs and other materials and from direct contact between 

knowledgeable and experienced faculty and staff at both the 

receiving and sending institutions.” 

North Central Association of 

Colleges and Schools 

Position Statement “The Commission does not dictate organizational policies and 

procedures for accepting transfer credits, but it holds that good 

practice requires the consideration of more than the source of the 

accreditation of a sending program or institution.” 

Northwest Commission on 

Colleges and Universities 

Standards “Accreditation speaks to the probability but does not guarantee that 

students have met acceptable standards of educational 

accomplishment. . . . Since accreditation does not address 

[comparability and applicability], the information must be obtained 

from catalogs and other materials and from direct contact between 

knowledgeable and experienced faculty and staff at both the 

receiving and sending institutions.” 

Southern Association of Colleges 

and Schools 

Position statement “The accreditation standards do not mandate that institutions accept 

transfer credit only from regionally accredited institutions. When an 

institution relies on another institution’s regional accreditation as an 

indicator for acceptability of credit, it should not be the only criterion 

used for acceptability nor should it be represented as a requirement 

of this accreditation agency, which it is not.” 

Western Association of Schools 

and Colleges 

Policy “Accreditation speaks to the probability but does not guarantee that 

students have met applicable standards of educational 

accomplishment. . . . Since accreditation does not address 

[comparability and applicability], the information must be obtained 

from catalogs and other materials and from direct contact between 

knowledgeable and experienced faculty and staff at both the 

receiving and sending institutions.” 

Source: GAO analysis of regional accrediting agencies’ standards. 
Page 21 GAO-06-22 Transfer Students 

Regional accrediting agencies recognize that the institutions are 

responsible for determining their own policies and practices with regard 

to the transfer and award of credit. Accrediting agencies will not know 

whether an institution is following the standards and general guidelines 

until the institution is reviewed. Officials at one accrediting agency told us 

that because of the nature of the review cycle, it could take several years 

to review all of the institutions and thereby ensure that they had 

implemented the standards. 

The inability to transfer credits may result in longer enrollment, more 

tuition payments, and additional federal financial aid awards, but the full 

extent to which such results occur cannot be determined because 

institutions told us they do not collect specific data on students that are 

unable to transfer credit. For example, a 1996 study of Arizona’s public 

university transfer practices found that community college transfer 

students may be required to take additional courses in order to complete 

their degrees because academic departments do not always accept 

community college courses as prerequisites.11 The study found that the 

accumulation of excess college credit hours could lead to additional years 

in school, added taxpayer expense such as financial aid awards, or a 

failure to complete a degree. Officials at selected nationally accredited 

institutions also told us that denials based on accreditation can result in 

students taking additional coursework in order to graduate. For example, 

one nationally accredited institution told us that one of its recent 

graduates had been required to repeat 2 years of coursework at a 

regionally accredited institution before he could be admitted to a graduate 

program. While credit transfer denials likely affect transfer students in a 

number of ways, the effect that these denials have on students’ enrollment 

duration, success in completing a baccalaureate program, or the 

affordability of postsecondary education cannot be determined with 

available data. Institution officials told us that they did not maintain data 

on the number of credits they have denied for transfer because it would be 

too cumbersome to maintain these files. 

Our analysis of Education’s postsecondary education data found that 

transfer students fare differently from nontransfer students. The national 

 11 Wright, M. Irene, and others, Articulation and Transfer: Definitions, Problems, and 

Solutions. Tempe, Arizona: Maricopa County Community College District (January 

1996).The study was published prior to the enactment of Arizona’s legislation that required 

state institutions to operate a statewide transfer network. 

Students’ Inability to 

Transfer Credits May 

Have Cost 

Implications, but 

Financial Effects on 

Students and the 

Federal Government 

Are Unknown 
Page 22 GAO-06-22 Transfer Students 

data indicate that, on average, transfer graduates take about 10 more 

credits12 and 3 more months13 to complete their baccalaureate degree than 

nontransfer graduates. However, transfer students could take longer to 

graduate for a variety of reasons that may or may not be related to their 

decision to transfer. For example, a student who changes majors may need 

to take additional courses in order to graduate. We could not determine 

the extent to which transfer students differ from nontransfer students in 

these areas. Nonetheless, students taking additional credits as a result of 

being unable to transfer credits will likely have to pay additional tuition. 

Based on national averages, these tuition payments could range from 

about $150 per credit hour for students attending public institutions to 

about $520 for those attending private schools. The extent to which these 

costs are borne by the student or the federal government would vary 

depending on the student’s eligibility for financial aid. 

Postsecondary institutions differ in how they assess transfer credits, and 

as a result, the current credit transfer process does not ensure the 

consistent consideration of student coursework. To facilitate the credit 

transfer process, many states have enacted legislation and implemented 

statewide initiatives covering primarily public postsecondary institutions 

within their respective states. However, state efforts have limited 

influence over students transferring to and from the nation’s private 

institutions or institutions located outside state boundaries. Also, all 

regional accrediting agencies subscribe to the principle that credits should 

not be accepted or denied on the basis of the type of accreditation, but not 

all of them have set standards requiring their member institutions to do so. 

When such standards have been set, it takes accrediting agencies years to 

review their member institutions’ policies to confirm their compliance. 

To preserve their institutional reputations and maintain quality, 

postsecondary institutions want their graduates to meet certain academic 

standards. The federal government sets the same standards for regional 

and national accrediting agencies to ensure that postsecondary 

institutions provide a quality education. At the same time, it is in the 

federal government’s interest to ensure that students receiving assistance 

 12 National Education Longitudinal Study, 1988–1994, U.S. Department of Education, 

National Center for Education Statistics. 

13 Beginning Postsecondary Students Longitudinal Study: 1996–2001, U.S. Department of 

Education, National Center for Education Statistics 

Conclusions 
Page 23 GAO-06-22 Transfer Students 

through federal aid programs, who have earned credits at an approved 

accredited institution, do not have to repeat coursework when transferring 

to another institution meeting the same standards. However, some 

institutions continue to deny credits from institutions with national 

accreditation without reviewing student coursework despite the fact that 

these institutions are accredited by federally recognized national 

accrediting bodies. Consequently, qualified students could be denied 

credit for comparable coursework, leading them to incur further 

educational costs that they may need to offset with additional federal 

financial aid. 

In order to ensure consistent consideration of students’ previous 

coursework, Congress should consider further amending the Higher 

Education Act of 1965 to require postsecondary institutions eligible for 

Title IV funding to not deny transfer credits on the basis of the type of 

accreditation. 

We provided a draft of this report to the Department of Education for 

review and comment. In its written response, included as appendix III, 

Education said our report was useful and informative. 

As arranged with your offices, unless you publicly announce its contents 

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

issue date. At that time, we will send copies of this report to the Secretary 

of Education, interested congressional committees, and other interested 

parties. We will also make copies of this report available to others on 

request. In addition, the report will be available at no charge on GAO’s 

Web site at http://www.gao.gov. 

If you have any questions about this report, please contact me at (202) 512-

7215 or ashbyc@gao.gov. Staff acknowledgments are listed in appendix IV. 

Cornelia M. Ashby 

Director, Education, Workforce, and 

 Income Security Issues 

Matter for Congressional 

Consideration 

Agency Comments 
Appendix I: Scope and Methodology 

Page 24 GAO-06-22 Transfer Students 

To describe how the transfer of credit operates among postsecondary 

institutions, we examined transfer of credit policies for a nationally 

representative sample of institutions and interviewed officials responsible 

for credit transfer evaluations from public, private, nonprofit, and private 

for-profit institutions. At each institution, we interviewed officials and 

asked them questions related to their policies and practices on transfer of 

credit, such as their criteria for accepting transfer credits, their process for 

evaluating transcripts, and if students had appeal rights once a decision 

was made. We also interviewed officials from the Council for Higher 

Education Accreditation (CHEA), the American Association of Collegiate 

Registrars and Admissions Officers (AACRAO), and the Institute for 

Higher Education Policy (IHEP). We reviewed publications and studies 

conducted by these organizations, the American Association of 

Community Colleges (AACC), and the Career College Association (CCA). 

To learn about how states and accrediting agencies facilitate the transfer 

of credit process, we searched legal databases for state statutes in all 50 

states to determine if the states had legislation related to transfer of credit. 

We also interviewed officials responsible for higher education from five 

states, officials from national and regional accrediting agencies, and the 

Department of Education (Education). We reviewed standards for 

accreditation from 10 national accrediting agencies that accredit 

institutions that grant degrees and the 6 regional accrediting agencies that 

accredit senior or 4-year institutions. The 5 states we visited were 

California, Florida, Missouri, New Jersey, and New York. In order to get a 

broad perspective on the challenges that students face when transferring 

credit, we selected states based on their varying levels of involvement in 

the credit transfer process and with large transfer student populations. 

To understand the implications for students and the federal government of 

students’ inability to transfer credit, we reviewed some of Education’s 

national databases to describe the typical transfer student. We reviewed 

the Integrated Postsecondary Education Data System (IPEDS) database to 

analyze the average cost of attendance at various types of institutions and 

the Beginning Postsecondary Students (BPS) database to learn about the 

transfer trends. We also used data from the National Educational 

Longitudinal Study of 1988 (NELS). In addition, we spoke with national 

experts and reviewed national studies related to the implications for 

students and the federal government of student’s inability to transfer 

credits. 

Appendix I: Scope and Methodology 
Appendix I: Scope and Methodology 

Page 25 GAO-06-22 Transfer Students 

In order to collect information about the ways in which institutions of 

higher education treated transfer credits, we undertook a data collection 

effort from a random sample of 270 institutions of higher education. The 

sample was obtained from the IPEDS database. The IPEDS data were from 

the 2000-2001 time period. IPEDS is the Department of Education’s core 

postsecondary education data collection program. It is a single, 

comprehensive system that encompasses all identified institutions with 

the primary purpose of providing postsecondary education. IPEDS is 

designed to produce national-, state-, and institution-level data for most 

postsecondary institutions. 

We conducted a stratified random sample from the IPEDS database. The 

sample represented 270 institutions, with 90 institutions from each of 

three categories of postsecondary institutions. The three categories we 

sampled included 4-year public, 4-year private nonprofit, and 2-year public 

institutions. These three types of institutions represent 3,096 institutions 

and over 95 percent of students attending higher education institutions. 

GAO did not sample 4-year private, for-profit institutions and 2-year 

private institutions. These types of institutions represented 1,264 

institutions but less than 5 percent of students attending higher education 

institutions. 

Of the 270 institutions that were randomly selected, 6 were found to be out 

of scope because our research indicated that they did not grant degrees or 

granted only graduate degrees. These 6 institutions were not included in 

the eventual results. Table 2 describes our source and response rates for 

our sample of institutions. 

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

Database 

Type of institution 

Total institutions

 in IPEDS database

GAO 

 sample size 

Response rate

 for GAO Web or 

telephone data 

collection instrument

4-year public 624 90 100%

4-year private 

nonprofit 

1,326 88 100%

2-year public 1,146 86 100%

Source: GAO analysis of IPEDS database. 

Survey results based on probability samples are subject to sampling error. 

Our sample of 264 institutions is only one of a large number of samples we 

Sampling Strategy 
Appendix I: Scope and Methodology 

Page 26 GAO-06-22 Transfer Students 

might have drawn from the total population of postsecondary institutions. 

Since each sample could have provided different estimates, we express 

our confidence in the precision of our three results as 95 percent 

confidence intervals. These are intervals that would contain the actual 

population values for 95 percent of the samples we could have drawn. As a 

result, we are 95 percent confident that each of the confidence intervals in 

this report will include the true values of the study population. All 

percentage estimates from this survey of 4-year public institutions, 4-year 

private nonprofit institutions, and 2-year public institutions have sampling 

errors not exceeding plus or minus 7 percentage points. 

We collected data from the 264 schools primarily through a data collection 

instrument that we filled out after examining the Web sites of the sampled 

schools. Before deploying the Web site data collection instrument, we 

conducted pretests with Web sites from 5 randomly sampled schools. We 

followed up these Web site examinations with telephone calls to ensure 

that the information we were obtaining from the Web sites accurately 

reflected the transfer credit policies of the respective schools. 

The extent of an institution’s policies on transferring credit from sending 

institutions varied widely, and the policies were found under different 

categories on the institutions’ Web sites. For example, some institutions 

listed their policies under links to transfer student information or 

admissions information, while others listed their policies only in the 

college catalog/bulletin that was available at the Web site. Most college 

catalogs/bulletins listed the transfer credit policy. In almost all cases, we 

printed proof of answers and highlighted, underlined, or numbered the 

answers to match the question number. All results obtained from the Web 

site data collection instrument were verified by a second GAO reviewer 

who independently examined documentation from the Web site or the 

information on the Web site itself. 

All but 8 of the 264 institutions had Web sites that we were able to 

examine. For those institutions that did not have Web sites, we spoke with 

officials from the institutions and asked questions from a telephone data 

collection instrument. The results of these telephone interviews were 

recorded by GAO interviewers. 

For this report we used data from the Integrated Postsecondary Education 

Data System database, the National Educational Longitudinal Study of 

1988, and the Beginning Postsecondary Students longitudinal study 

Data Collection Methods 

Data Reliability 

Assessments 
Appendix I: Scope and Methodology 

Page 27 GAO-06-22 Transfer Students 

database. We reviewed technical and methodological documentation for 

all three databases, and in the case of NELS also spoke with a research 

methodologist who had worked on the study. We found the data from the 

databases to be sufficiently reliable for the purposes of this engagement. 
Appendix II: State Legislation Related to 

Transfer of Academic Credit 

Page 28 GAO-06-22 Transfer Students 

Alabama Ala. Code § 16-5-8. Mandates a statewide articulation agreement under which all applicable credits transferred 

from a 2-year institution to a 4-year institution shall fulfill degree requirements at the 4-year institution as if they 

were earned at the 4-year institution. 

Alaska None found 

Arizona Ariz. Rev. Stat. § 15-1824. Requires that community college districts and universities cooperate in operating a 

statewide articulation and transfer system, including the process of transfer of lower division general education 

credits, general elective credits, and curriculum requirements for approved majors, to facilitate the transfer of 

community college students to Arizona public universities without a loss of credit. 

Arkansas Ark. Code Ann. § 6-53-205. Requires that the Arkansas Higher Education Coordinating Board develop a plan 

to maximize transfer credits of students from institutions within the system, including the development of a core 

transfer program for students desiring to obtain a baccalaureate degree after transferring from an institution 

within the 2-year system to the 4-year system. 

Ark. Code Ann. § 6-61-218. Requires the Arkansas Higher Education Coordinating Board to establish in 

consultation with the colleges and universities a minimum core of courses that shall apply toward the general 

education core curriculum requirements and that shall be fully transferable between state institutions. 

A.C. Ark. Code Ann. § 6-61-505. Gives the State Community College Board the duty and power to work with 

senior institutions of the state to develop the criteria for transfer of credits of students entering senior 

institutions from community colleges. 

California Cal. Ed. Code § 66720. Requires the Board of Governors of the California Community Colleges, the Regents of 

the University of California, and the Trustees of the California State University to jointly develop, maintain, and 

disseminate a common core curriculum in general education courses for the purposes of transfer. 

Cal. Ed. Code § 66730 and note. Directs the Regents of the University of California (UC), the Trustees of the 

California State University (CSU), and the Board of Governors of the California Community Colleges to have as 

a fundamental policy the maintenance of a healthy and expanded student transfer system. Community college 

students must have access to a viable and efficient transfer agreement program to the California State 

University and the University of California for upper division work toward a baccalaureate degree. 

Cal. Ed. Code § 66738. Holds the governing board of each public postsecondary education segment 

accountable for the development and implementation of formal systemwide articulation agreements and 

transfer agreement programs. 

Cal. Ed. Code § 66739.5. States the intent of the legislature as ensuring that community colleges students who 

wish to earn the baccalaureate degree at California State University are provided with a clear and effective 

path to this degree. 

Cal. Ed. Code § 66740. Requires each department, school, and major in UC and CSU to develop, in 

conjunction with community college faculty in appropriate and associated departments, discipline-specific 

articulation agreements and transfer agreements for those majors that have lower-division prerequisites. 

Appendix II: State Legislation Related to 

Transfer of Academic Credit 
Appendix II: State Legislation Related to 

Transfer of Academic Credit 

Page 29 GAO-06-22 Transfer Students 

Colorado Colo. Rev. Stat. § 23-1-108. Requires the Colorado Commission on Higher Education to establish, after 

consultation with the governing boards of institutions, and enforce student transfer agreements between 2-year 

and 4-year institutions and among 4-year institutions. Such transfer agreements shall include provisions under 

which institutions shall accept all credit hours of acceptable coursework for automatic transfer to another statesupported institution of higher education in Colorado. The commission shall also establish and enforce student 

transfer agreements between degree programs offered on the same campus or within the same institutional 

system. 

Colo. Rev. Stat. § 23-1-125. Directs the Colorado Commission on Higher Education, in consultation with each 

Colorado public institution of higher education, to outline a plan to implement a core course concept that 

defines the general education course guidelines for all public institutions of higher education. 

Colo. Rev. Stat. § 23-5-122. Requires the governing board of every state-supported institution of higher 

education to have in place and enforce policies regarding transfers by students between undergraduate degree 

programs that are offered within the same institution or within the same system. 

Colo. Rev. Stat. § 23-13-104. Lists statewide expectations and goals for higher education, including ensuring 

that no student’s graduation is delayed due to lack of access to or availability of required and core courses and 

ensuring that students who change degree programs lose only those credit hours that clearly and justifiably 

cannot apply in the degree programs to which the student transfers. 

Connecticut Conn. Gen. Stat. § 10a-19a. Directs the Commissioner of Higher Education, in consultation with the Higher 

Education Coordinating Council, to establish a statewide Advisory Council on Student Transfer and Articulation 

to maximize the transferability of course credits. 

Delaware None found 

Florida Fla. Stat. Ann. § 1007.01. Requires the State Board of Education, in order to improve and facilitate articulation 

systemwide, to develop policies and guidelines with input from statewide K-20 advisory groups established by 

the Commissioner of Education relating to a number of issues, including articulation agreements, admissions 

requirements, and the transferability of credits among institutions. 

Fla. Stat. Ann. § 1007.22. Authorizes university boards of trustees and community college boards of trustees to 

establish intrainstitutional and interinstitutional programs to maximize articulation. These may include transfer 

agreements that facilitate the transfer of credits between public and nonpublic postsecondary institutions and 

the concurrent enrollment of students at a community college and a state university. 

Fla. Stat. Ann. § 1007.23. Requires the State Board of Education to establish in rule a statewide articulation 

agreement, which must among other things specifically provide that every associate in arts graduate of a 

community college shall have met all general education requirements and must be granted admission to the 

upper division of a state university, except for certain listed programs. The articulation agreement must also 

guarantee the statewide articulation of appropriate courses within associate in science degree programs to 

baccalaureate degree programs. 

Georgia None found 

Hawaii None found 

Idaho None found 

Illinois 110 Ill. Comp. Stat. 805/2-11. Empowers the State Board in cooperation with the 4-year colleges to develop 

articulation procedures to the end that maximum freedom of transfer among community colleges and between 

community colleges and degree-granting institutions be available. 
Appendix II: State Legislation Related to 

Transfer of Academic Credit 

Page 30 GAO-06-22 Transfer Students 

Indiana Ind. Code Ann. § 20-12-0.5-8. Requires the Commission for Higher Education to, among other things, develop 

through the committee statewide transfer of credit agreements for courses that are most frequently taken by 

undergraduates; develop through the committee statewide agreements under which associate degrees 

articulate fully with related baccalaureate degree programs; and publicize by all appropriate means, including 

an Internet Web site, a master list of course transfer of credit agreements and program articulation 

agreements. 

Ind. Code Ann. § 20-12-17-2. Requires all state-supported universities to accept the transfer credit of all 

appropriate courses successfully completed by any student at any other state-supported postsecondary 

educational institution having the same level of accreditation. 

Iowa None found 

Kansas Kans. Stat. Ann. § 72-4454. Requires the state board of regents to adopt a policy requiring articulation 

agreements among area vocational schools, area vocational-technical schools, community colleges, technical 

colleges, and state educational institutions. 

Kentucky Ky. Rev. Stat. Ann. § 164.580. Requires the Kentucky Community and Technical College System to be 

responsive to the needs of students and employers to support the lifelong learning needs of Kentucky citizens 

in order to, among other things, facilitate transfers of credit among certificate, diploma, technical, and associate 

degree programs. 

Ky. Rev. Stat. Ann. § 164.583. Requires all lower-division academic courses offered by the community colleges 

to be transferable for academic credit to any and all 4-year public colleges and universities. 

Louisiana La. Rev. Stat. Ann. § 17:3129.1. Requires postsecondary management boards to adopt and implement in the 

institutions under their jurisdiction common core courses that articulate from any institution of public higher 

education to any other such institution, taking into consideration the accreditation criteria of the institution 

receiving the credit. 

La. Rev. Stat. Ann. § 17:1871. Requires the Board of Supervisors of Community and Technical Colleges to 

continue development of articulation agreements between institutions under the management of the board and 

institutions managed by other postsecondary management boards, both public and private. 

Maine Me. Rev. Stat. Ann. tit. 20-A, § 10902. States that one of the fundamental policies in the state’s public higher 

educational planning is to provide for a uniform system of transferring credits for equivalent courses among the 

various units of the University of Maine system. 

Me. Rev. Stat. Ann. tit. 20-A, § 10907. Requires the Chancellor of the University of Maine system to form a 

committee that shall, among other things, establish a uniform system to facilitate the transfer of credits for 

equivalent courses among the various units of the University of Maine system. 

Maryland Md. Code Ann., Education § 11-207. Lists among the duties of the Maryland Higher Education Commission the 

establishment of procedures for transfer of students between the public segments of postsecondary education 

and the establishment, in conjunction with the governing boards, of standards for articulation agreements. 

Massachusetts Mass. Gen. Laws ch. 15A, § 9. Gives the board of higher education the duty and power to, among other things, 

develop and implement a transfer compact for the purpose of facilitating and fostering the transfer of students 

without the loss of academic credit or standing from one public institution to another. 

Michigan None found 
Appendix II: State Legislation Related to 

Transfer of Academic Credit 

Page 31 GAO-06-22 Transfer Students 

Minnesota Minn. Stat. Ann. § 135A.052. Recognizes as one of the missions of postsecondary institutions that community 

colleges shall offer lower-division instruction in occupational programs in which all credits earned will be 

accepted for transfer to a baccalaureate degree in the same field of study. 

Minn. Stat. Ann. § 136F.05. Requires the Minnesota State Colleges and Universities Board of Trustees to 

develop administrative arrangements that make possible the efficient use of the facilities and staff of the 

technical colleges, community colleges, and state universities so that students may have the benefit of 

improved and broader course offerings, ease of transfer among schools and programs, integrated course 

credit, coordinated degree programs, and coordinated financial aid. 

Minn. Stat. Ann. § 135A.08. Requires the regents of the University of Minnesota and the trustees of the 

Minnesota State Colleges and Universities shall develop and maintain course equivalency guides for use by 

institutions that have a high frequency of transfer. The governing boards of private institutions that grant 

associate and baccalaureate degrees and that have a high frequency of transfer students are requested to 

participate in developing these guides. 

Mississippi None found 

Missouri Mo. Rev. Stat. § 173.005. Requires the coordinating board for higher education to establish guidelines to 

promote and facilitate the transfer of students between institutions of higher education within the state. 

Montana None found 

Nebraska Neb. Rev. Stat. Ann. § 85-1413. Requires the Coordinating Commission for Postsecondary Education to 

incorporate into the comprehensive statewide plan for postsecondary education, among other things, the 

facilitation of statewide transfer-of-credit guidelines to be considered by institutional governing boards. 

Neb. Rev. Stat. Ann. § 85-963. Encourages the community college areas to work in cooperation with the 

University of Nebraska and the state colleges for the articulation of general academic transfer programs of the 

six community college areas. 

Nevada Nev. Rev. Stat. Ann. § 396.568. Requires that all credits earned by a student in a course at a community 

college within the system must be accepted and applied toward the coursework required of the student in his 

major or minor for the award of a baccalaureate degree upon graduation from any university or state college 

within the system if certain criteria are met. 

New Hampshire N.H. Rev. Stat. Ann. § 188-F:6. Requires the department of regional community-technical colleges and the 

university system of New Hampshire to develop mutually agreed upon transfer articulation agreements. 

New Jersey N.J. Stat. Ann. § 18A:3B-8. Gives responsibility to the New Jersey Presidents’ Council to encourage the 

formation of regional or other alliances among institutions, including interinstitutional transfers, program 

articulation, cooperative programs and shared resources and the development of criteria for full faith and credit 

transfer agreements between county colleges and other institutions of higher education. 

New Mexico N.M. Stat. Ann. § 21-1B-3. Requires the commission on higher education to establish and maintain a 

comprehensive statewide plan to provide for the articulation of educational programs and facilitate the transfer 

of students between institutions. The commission shall define, publish, and maintain modules of lower-division 

courses accepted for transfer at all institutions. 

N.M. Stat. Ann. § 21-1B-4. Requires each institution to accept for transfer course credits earned by a student at 

any other institution that are included in a transfer module. 

N.M. Stat. Ann. § 21-1B-5. Requires the commission on higher education to establish and maintain a process 

to monitor and improve articulation through frequent and systematic consultation with institutions. The 

commission shall establish a complaint procedure for transfer students who fail to receive credit and investigate 

all articulation complaints and render decisions as to the appropriateness of the actions of the participants. 

New York N.Y. Educ. Law § 351. Lists as one of the missions of the state university system to exercise care to develop 

and maintain a balance of its human and physical resources that promotes appropriate program articulation 

between its state-operated institutions and its community colleges as well as encourages regional networks 

and cooperative relationships with other educational and cultural institutions. 
Appendix II: State Legislation Related to 

Transfer of Academic Credit 

Page 32 GAO-06-22 Transfer Students 

North Carolina 1995 Sess. Laws, c. 287, §§ 1-3. Provides for the development, by the Board of Governors of the University of 

North Carolina and the State Board of Community Colleges, of a plan for the transfer of credits among the 

institutions of the North Carolina Community College System, and between those institutions and the 

constituent institutions of the University of North Carolina, the intention of the General Assembly to adopt a 

plan for the transfer of credits, and the implementation, by the State Board of Community Colleges, of a 

common course numbering system. 

1995 Sess. Laws, c. 625. Provides that the Board of Governors of the University of North Carolina and the 

State Board of Community Colleges shall develop a plan to provide students with information regarding the 

transfer of credits among community colleges and between community colleges and the University of North 

Carolina and shall develop a timetable for development of guidelines. 

North Dakota None found 

Ohio Ohio Rev. Code Ann. § 3333.16. Requires the Ohio board of regents to establish policies and procedures 

applicable to all state institutions of higher education that ensure that students can begin higher education at 

any state institution of higher education and transfer coursework and degrees to any other state institution of 

higher education without unnecessary duplication; the board must also develop and implement a universal 

course equivalency classification system for state institutions so that the transfer of students and the transfer 

and articulation of equivalent courses are not inhibited by inconsistent judgment about the application of 

transfer credits. Coursework completed within such a system at one state institution of higher education and 

transferred to another institution shall be applied to the student’s degree objective in the same manner as 

equivalent coursework completed at the receiving institution. The board of regents shall develop a system of 

transfer policies that ensure that graduates with associate degrees shall be admitted to a state institution of 

higher education. The board of regents shall study the feasibility of credit recognition and transferability to state 

institutions of higher education for graduates who have received associate degrees from a career college. 

Oklahoma Okla. Stat. Ann. tit. 70, § 3207.1. States that the intent of the legislature is that credits earned by students in 

any institution of higher education within the Oklahoma State System of Higher Education be fully accepted at 

any other institution of higher education within the system. 

Oregon Or. Rev. Stat. § 348.470. Declares that it is the policy of the state to encourage cooperation between the 

Oregon University System and community colleges on issues affecting students who transfer between the two 

segments and that all unnecessary obstacles that restrict student transfer opportunities between the two 

segments shall be eliminated. 

1997 Or. Laws ch. 653, § 1. Requires the State Board of Higher Education to continue to work with the State 

Board of Education to develop policies and procedures to ensure maximum transfer of academic credits 

between community colleges and state institutions of higher education. 

Pennsylvania 24 Pa. Cons. Stat. Ann. § 15-1504-A. Requires the Department of Education and the Office of Administration to 

establish management teams to distribute funds appropriated for the researching, planning, and development 

of the Pennsylvania Education Network, which can include, when appropriate, implementing a Web-based 

application that makes all articulation agreements among higher education institutions available on the Internet.

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

educational levels. 

South Carolina S.C. Code Ann. § 59-52-100. Requires the State Board of Technical and Comprehensive Education and the 

Council of College Presidents, through the Commission on Higher Education, to clarify and strengthen 

articulation agreements between associate degree programs and baccalaureate degree programs. 

South Dakota S.D. Codified Laws § 13-53-43. Requires that all general education credit hours fulfilling graduation 

requirements in institutions accredited by the North Central Association of Colleges and Secondary Schools be 

transferable between the universities under the control of the South Dakota Board of Regents and the technical 

institutes governed by the South Dakota Board of Education. General education course credit hours are 

transferable between the technical institutes and universities only for credit for general education courses. 
Appendix II: State Legislation Related to 

Transfer of Academic Credit 

Page 33 GAO-06-22 Transfer Students 

Tennessee Tenn. Code Ann. § 49-7-202. Requires the Tennessee Higher Education Commission to establish and ensure 

that all postsecondary institutions in Tennessee cooperatively provide for an integrated system of 

postsecondary education. The commission shall guard against inappropriate and unnecessary conflict and 

duplication by promoting transferability of credits and easy access of information among institutions. 

Texas Tex. Educ. Code Ann. § 61.822. States that if a student successfully completes the core curriculum at an 

institution of higher education, that block of courses may be transferred to any other institution of higher 

education and must be substituted for the receiving institution’s core curriculum. A student shall receive 

academic credit for each of the courses transferred and generally may not be required to take additional core 

curriculum courses at the receiving institution. 

Tex. Educ. Code Ann. § 61.823. States that if a student successfully completes a field of study curriculum 

developed by the board, that block of courses may be transferred to a general academic teaching institution 

and must be substituted for that institution’s lower division requirements for the degree program for the field of 

study into which the student transfers, and the student shall receive full academic credit toward the degree 

program for the block of courses transferred. 

Tex. Educ. Code Ann. § 61.831. States that it is the purpose of the statutory subchapter on transfer of credit to 

develop a seamless system of higher education with respect to student transfers between institutions of higher 

education, including student transfers from public junior colleges to general academic teaching institutions. 

Utah Utah Code Ann. § 53B-6-105.5. Requires the Technology Initiative Advisory Board to provide the State Board 

of Regents with an assessment and reporting plan that includes an analysis of program articulation among 

higher education institutions in engineering, computer science, and related technology. 

Utah Code Ann. § 53B-16-105. Requires the Board of Regents to facilitate articulation and the seamless 

transfer of courses within the state system of higher education; develop, coordinate, and maintain a transfer 

and articulation system within the state system of higher education that allows students to transfer courses 

among institutions of higher education to meet requirements for general education and lower-division courses 

that transfer to baccalaureate majors and facilitates student acceleration and the transfer of students and 

credits between institutions; and identify common prerequisite courses and course substitutions for degree 

programs across all institutions of higher education. 

Vermont None found 

Virginia Va. Code Ann. § 23-9.6:1. Gives the State Council of Higher Education the duty, responsibility, and authority to 

facilitate the development of dual admissions and articulation agreements between 2- and 4-year public and 

private institutions of higher education in Virginia. Such agreements shall be subject to the admissions 

requirements of the 4-year institutions. 

Va. Code Ann. § 23-9.14:2. Requires the State Council of Higher Education to develop, in cooperation with the 

governing boards of the public 2- and 4-year institutions of higher education, a State Transfer Module that 

designates those general education courses that are offered within various associate degree programs at the 

public 2-year institutions that are transferable for credit or admission with standing as a junior to the public 4-

year institutions. In developing such module, the council shall also seek the participation of private institutions 

of higher education. The council shall also facilitate the development of dual admissions and articulation 

agreements between the state’s public and private 2- and 4-year institutions of higher education, which are 

subject to the admissions requirements of the 4-year institutions. The council shall make public all general 

education courses offered at public 2-year institutions and designating those that are accepted for purposes of 

transfer for course credit at 4-year public and private institutions of higher education in Virginia. 
Appendix II: State Legislation Related to 

Transfer of Academic Credit 

Page 34 GAO-06-22 Transfer Students 

Washington Wash. Rev. Code Ann. § 28B.45.014. Requires higher education branch campuses to collaborate with the 

community and technical colleges in their region to develop articulation agreements to ensure that branch 

campuses serve as innovative models of a two plus two educational system. Areas of collaboration include 

joint development of curricula and degree programs. 

Wash. Rev. Code Ann. § 28B.76.240. Requires the higher education coordinating board to adopt statewide 

transfer and articulation policies that ensure efficient transfer of credits and courses across public 2- and 4-year 

institutions of higher education. The intent of the policies is to create a statewide system of articulation and 

alignment between 2- and 4-year institutions. 

Wash. Rev. Code Ann. § 28B.76.2401. States that the statewide transfer of credit policy and agreement must 

not require or encourage the standardization of course content or prescribe course content or the credit value 

assigned by any institution to the course. Policies adopted by public 4-year institutions concerning the transfer 

of lower-division credit must treat students transferring from public community colleges the same as students 

transferring from public 4-year institutions. 

Wash. Rev. Code Ann. § 28B.76.250. Requires the higher education coordinating board to convene work 

groups to develop transfer associate degrees that will satisfy lower-division requirements at public 4-year 

institutions of higher education for specific academic majors. Each transfer associate degree developed under 

this section must enable a student to complete the lower-division courses or competencies for general 

education requirements and preparation for the major that a direct-entry student would typically complete in the 

freshman and sophomore years for that academic major. Completion of a transfer associate degree does not 

guarantee a student admission into an institution of higher education. 

Wash. Rev. Code Ann. § 28B.720. Requires the higher education coordinating board, in consultation with the 

state board for community and technical colleges and the council of presidents, to recruit and select institutions 

of higher education to participate in a pilot project to define transfer standards in selected academic disciplines 

on the basis of student competencies. Under the pilot project, participants shall develop standards, definitions, 

and procedures for quality assurance for a transfer system based on student competencies. 

West Virginia W. Va. Code Ann. § 18B-2B-6. Lists among the powers and duties of the West Virginia Council for Community 

and Technical College Education to establish and implement policies and procedures to ensure that students 

may transfer and apply toward the requirements for a degree the maximum number of credits earned at any 

regionally accredited in-state or out-of-state higher education institution; to cooperate with the governor’s P-20 

council of West Virginia to remove barriers relating to transfer and articulation between and among community 

and technical colleges, state colleges and universities, and public education, and to implement a policy jointly 

with the commission whereby any course credit earned at a community and technical college transfers for 

program credit at any other state institution of higher education and is not limited to fulfilling a general 

education requirement. 

Wisconsin Wis. Stat. Ann. § 36.11. Lists among the powers and duties of the board of regents to establish policies for the 

appropriate transfer of credits between institutions within the system, to establish policies for the appropriate 

transfer of credits with other educational institutions outside the system, and to establish and maintain a 

computer-based credit transfer system that shall include all transfers of credit between institutions within the 

system and other courses for which the transfer of credits is accepted. 

Wyoming Wyo. Stat. Ann. § 21-16-602. Requires the Wyoming Education Planning and Coordination Council to facilitate 

cooperative arrangements among state education institutions in the sharing of facilities, personnel, and 

technology or otherwise assist in articulation between the institutions. 

Source: GAO analysis of state legislation. 
Appendix III: Comments from the Department 

of Education 

Page 35 GAO-06-22 Transfer Students 

Appendix III: Comments from the 

Department of Education 
Appendix IV: GAO Contacts and Staff 

Acknowledgments 

Page 36 GAO-06-22 Transfer Students 

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

Bryon Gordon, Assistant Director 

Anjali Tekchandani: Analyst-in-Charge 

In addition to those mentioned above, Elizabeth Bax, Richard Burkard, 

Sara Edmondson, Jonathan S. McMurray, John Mingus, James Rebbe, 

Walter Vance, and Ann T. Walker made significant contributions to this 

report. 

Appendix IV: GAO Contacts and Staff 

Acknowledgments 

GAO Contacts 

Staff 

Acknowledgements 

(130441) 
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