FERPA Concerns for Sending and Honoring Electronic Requests for Student Transcripts SACRAO 2012 Tuesday, February 14 Covington, Kentucky SPEEDE – A Professional Development Committee of AACRAO American Association of Collegiate Registrars and Admissions Officers

Presentation Outline Electronic Transcript Request – What is it? Case Study: Experiences with the TS 146 Usage & Survey Results Common Trends FERPA Concerns and Third Party Electronic Request Questions

Electronic Request for Transcript ( EDI TS 146 or PESC XML) What is it? An Electronic Request sent/received for an Electronic Student Transcript Used within the context of EDI or XML environment, and now in PDF. Post-application transaction set used by educational institutions to request a transcript be sent back via EDI, XML or PDF. 3rd Party Institutional requests for student transcripts ANSI ASC x12 Transaction Set Standard/PESC Standard

Case Study: University of Phoenix Current TS 146 Experiences Benefits sending electronic requests for transcripts (TS146) Reduce administrative burden for receiving institution Enhances institutional relationships Decreases and phone follow up communication More secure delivery than USPS Decreased processing time Areas of opportunity with the process Not everyone honors this standard Transcript request fees are not handled through this technology Some institutions do not honor institution-to-institution (third party) requests

Case Study: University of Phoenix Future - Acceptance of TS146 Requests Plan IT is working on the outbound UoPx EDI transcript initiative Currently our Document Processing Team is building a list of institutions willing to send requests electronically Rolled out in Fall 2010 Perceived Benefits Optimize the return for building the electronic transcript queues Enhance institutional relationships by being a good trading partner (participating in all transaction sets for electronic transcript exchange)

Who is using the TS146 Institution Usage In February of 2009 the AACRAO Speede Committee sent a Survey to determine TS146 usage rates and acceptance Details to follow…generally we found a significantly lower usage of the electronic request (TS146) as compared to the electronic transcript(TS 130). Industry Awareness Based on survey results we determined institutional awareness can be improved Perceptions regarding the legality of the TS146 need to be underscored and dispelled

About the Survey Intent Collect information on trends involving the TS 146 and determine institutional preferences for requesting the TS 130 (EDI) transcript Gather insights from both a sender and receiver perspective Population Surveyed All Institutions on the Texas Server Registrant’s table as of February 2009 Responses 61 results were collected

Do institutions utilize the TS146 request for student transcripts with any secondary and/or postsecondary institution? 90.2% DO NOT send the TS 146 Request Common reasons indicated: Fees Charged Fees Charged Not included with vendor services Not included with vendor services Not set up to handle through SIS Not set up to handle through SIS Lack of technical support to troubleshoot Lack of technical support to troubleshoot Authorization/validation concerns for the receiving institution Authorization/validation concerns for the receiving institution A lack of EDI relationships to do this A lack of EDI relationships to do this Requests have to be student initiated for most receiving partners Requests have to be student initiated for most receiving partners Survey Results

Do institutions utilize the TS146 request for student transcripts with any secondary and/or postsecondary institution?...continued 9.8% DO send the TS 146 Request Common reasons indicated: Greater Security (Texas Server) Transcript Request form on application auto-generates the TS 146 (it can be student initiated) Faster and easier to process requests that are sent electronically Reduces man-hours for paper processing requests to be sent Survey Results

Do Institutions Accept/Honor the TS146 Request for Student Transcripts from other Institutions? 81.7% do NOT accept/honor the TS 146 Request Common reasons indicated: Vendor services do not support this application. Vendor services do not support this application. Do not know what it is; lack of technical support/knowledge Do not know what it is; lack of technical support/knowledge Is not compatible with workflow processes (SIS) Is not compatible with workflow processes (SIS) Requires a student signature and request/consent form before releasing transcript (FERPA concerns) Requires a student signature and request/consent form before releasing transcript (FERPA concerns) Just testing with EDI (Most institutions will not send a paper transcript in response to EDI request). Just testing with EDI (Most institutions will not send a paper transcript in response to EDI request). Survey Results

Do Institutions Accept/Honor the TS146 Request for Student Transcripts from other Institutions?...continued 18.3% DO accept/honor the TS 146 Request Common reasons indicated: Built into EDI processor (Auto generates TS 130 upon receiving a request if student has paid fees Built into EDI processor (Auto generates TS 130 upon receiving a request if student has paid fees Easier and faster to process strait from SIS and reduces manual workflow Easier and faster to process strait from SIS and reduces manual workflow Convenient for use to set up with high volume requester schools (usually with prearranged agreements if there are fees) Convenient for use to set up with high volume requester schools (usually with prearranged agreements if there are fees) Survey Results

Decisions to Either Accept or not Accept the TS 146 Request for Student Transcripts 8.9% stated that financial consideration of potential lost revenue from a TS 146 request plays a role in the decision making process 25% stated that FERPA regulation plays a role in the decision making process 28.6% stated that their institution utilizes other electronic methods to request transcripts 58.9% stated “other” reasons for not accepting the TS 146 request for student transcript. Survey Results

Of the “Other Reasons” the most common listed were: Time constraints with implementing this technology Lack of technical staff to set up the receiving process EDI is automated and having a person “search” student information found in TS 146 data would be time consuming if not automated No way to translate it and upload image of request to SIS currently exist at my institution Decisions to Either Accept or not Accept the TS 146 Request for Student Transcripts …continued Survey Results

Common Trends and Trading the TS 146 The TS 146 is commonly used as an institution-to-institution request for student transcripts for schools within “network” of each other. Most Likely to be Used By: 1. Institutions who trade electronically within the same state/region or district and do not charge transcript fees. 2. Institutions within “Network” of each other via a vendor service (prearranged or no fees). 3. Institutions who have made separate arrangements to send/receive the TS 146 (and consolidate fees for requests honored). Survey Results

FERPA Regulations Amended FERPA Exceptions to Student Consent for Release of Educational Records was Amended in December of 2008 “Amending § 99.31(a)(1) to ensure that teachers and other school officials only gain access to education records in which they have legitimate educational Interests” “Amending § 99.31(a)(2) to permit educational agencies and institutions to information and telecommunications technologies.’’

Ruling out FERPA Concerns Based on the amended FERPA Regulations… Based on the amended FERPA Regulations… is the TS146 a FERPA compliant transaction? FERPA regulations do not prohibit the use of electronic requests, including the TS 146 and the PESC XML standard. FERPA regulations do not prohibit the use of electronic requests, including the TS 146 and the PESC XML standard. The business process really determines if exchanging a request electronically is appropriate. These transactions are compliant as long as they are initiated from a trusted source TS 146 request is often “post-application” meaning that the student must complete his/her application and sign the consent/release form to authorize a request

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References PESC Website. EDI Implementation Guides (TS 146). Department of Education Website (FERPA). Dec /2008-4/120908a.pdf Thank you! This presentation is brought to you by the AACRAO Speede Committee

Last Resort For Help Rick Skeel University of Oklahoma