Registrar’s Office Audit Kaplan University Chicago, IL May 5-6, 2009 Reid Kisling, Senior Consultant

2 Registrar’s Office AuditKaplan UniversityMay 5-6, Role of the Registrar: Philosophy The mission statement for a Registrar’s Office drives all decision making and relationships with other offices. The Registrar’s Office at Kaplan University, while discussions of mission have occurred in the past, does not have an explicit mission statement. The office should be commended for a good working relationship with the academic enterprise at the institution (this is not a common occurrence at other higher education institutions). Observations

3 Registrar’s Office AuditKaplan UniversityMay 5-6, Role of the Registrar: Organization Office staff should be empowered at the lowest level possible in the organizational structure to make decisions that affect their work. This includes the ability to make exceptions to policy when interacting with faculty, staff, or students and should be in the student’s best interest in line with office and institutional mission. The level at which some decisions can and should be made is unclear amongst staff. Observations

4 Registrar’s Office AuditKaplan UniversityMay 5-6, Role of the Registrar The mission statement for the office should be clarified and communicated explicitly to all staff. Decisions should be tied to office mission as the mission of the office is tied back to that of the institution. The office should clarify who has authority for making specific decisions and empower staff to make those decisions in the best interest of students. Recommendations

5 Registrar’s Office AuditKaplan UniversityMay 5-6, Communication: General Different departments throughout the institution office training to their staff (i.e., orientation) regarding data entry and policy for student records. However, in most cases, this training has not been reviewed fy the Registrar’s Office to insure compliance with institutional policy and procedure. The office does not have a defined process for proactive communication to students, faculty, and staff (i.e., deadlines). Observations

6 Registrar’s Office AuditKaplan UniversityMay 5-6, Communication: General The office does not have recent student satisfaction data that can be used to assess effectiveness of efforts from the perspective of students themselves (however, plentiful operational data exist for assessment). The institution does not clearly communicate the need for submission of official transcripts submitted prior to admissionfor its Master’s and advanced start students. Observations, continued

7 Registrar’s Office AuditKaplan UniversityMay 5-6, Communication: Catalog Course frequency (e.g., every fall, every semester) is not communicated clearly in the catalog or other advising document from which students can make appropriate advising decisions. Observations

8 Registrar’s Office AuditKaplan UniversityMay 5-6, Communication Student record training offered by different departments throughout the institution should be vetted by Registrar’s Office staff to insure compliance with policies and procedures. The department should consider a triggered communication calendar (can be as sophisticated as a defined CRM system) that communicates key messages to faculty, staff, and students on a predefined calendar (date or process driven). Recommendations

9 Registrar’s Office AuditKaplan UniversityMay 5-6, Communication The office does consider delivering student satisfaction survey(s) to assess effectiveness of efforts directly from students. The institution must clearly communicate the need for submission of official transcripts for admission. The institution should consider where best to communicate course frequency information (catalog or other document). Recommendations, continued

10 Registrar’s Office AuditKaplan UniversityMay 5-6, Student Records: Transcript Processes and Procedures The transcript legend is unique to each Kaplan University college based on institutional history and some policies peculiar to each location. Credits awarded for prior learning are not necessarily clearly defined on student transcripts but are instead coded as the course for which credit was awarded at the university. Credit is only awarded for equivalency to existing catalog courses (in both content and credit hours). Observations

11 Registrar’s Office AuditKaplan UniversityMay 5-6, Student Records: Transcript Processes and Procedures The university does not have a defined policy regarding what dismissal status—disciplinary vs. academic—should and can appear on the institutional transcript. Grade changes submitted subsequent to degree conferral (sometimes a year later) can retroactively change a student’s GPA post-conferral. Institutional plans to implement an honors track for health sciences has implications for transcripts. Observations, continued

12 Registrar’s Office AuditKaplan UniversityMay 5-6, Student Records: Records Management and Retention The office does not have a specific record retention policy that identifies all types of documents that should be maintained in the student file and the retention schedule for each (including the time at which they should be purged, if ever). The university does not have a policy regarding what documents are necessary to process a student’s name change request. Observations

13 Registrar’s Office AuditKaplan UniversityMay 5-6, Student Records: Records Management and Retention Documentation of student records (specifically, advising comments) in Artemis differs by staff member or department, leading to disparities in the kind of information included in the system. Some of this information may not be intended by the person entering the data as viewable to the student (which is governed by FERPA). Exceptions granted for student curricular changes may not be documented consistently in all cases. Observations

14 Registrar’s Office AuditKaplan UniversityMay 5-6, Student Records The university should standardize, to the extent possible, the information included on the transcript legend for each Kaplan institution. The university should consider labeling prior learning credit based on work as presented (not awarded). Though it is an institutional decision, credit may be awarded credit hours that may not exactly meet minimum credits of specific university courses (which may allow awarding credit for elective hours). Recommendations

15 Registrar’s Office AuditKaplan UniversityMay 5-6, Student Records The university should consider and define policy regarding what student status (i.e., probation, good standing, dismissal) appears on the institutional transcript. The institution should consider a length of time during which to consider grade changes for students who graduate which may result in “freezing” a student’s GPA upon graduation. Recommendations, continued

16 Registrar’s Office AuditKaplan UniversityMay 5-6, Student Records The institution must consider the manner in which the honors track for health sciences will appear on student transcripts. Possibilities range from no notation to specific honors courses (noting the honors designation in the course title) to a notation of a student’s involvement in the program (on a term- by-term basis). Consideration should be given to students who may leave the program mid-stream and how the information will be displayed on their transcripts appropriately. Recommendations, continued

17 Registrar’s Office AuditKaplan UniversityMay 5-6, Student Records The office should create an explicit record retention policy in which all types of documents are identified for the office and the student file and listing how long they are to be maintained (or key times when they are purged). Special attention should be paid to the following types of existing records: –Admissions reference forms –Advising communications Recommendations, continued

18 Registrar’s Office AuditKaplan UniversityMay 5-6, Student Records The university should define what documents are necessary (e.g., Social Security card) to process a student’s name change request. Training should be provided to staff entering advising comments in Artemis to promote consistent information included in the system. Curricular exceptions should also documented consistently in all cases. Staff should understand that such comments are viewable to students upon request. Recommendations, continued

19 Registrar’s Office AuditKaplan UniversityMay 5-6, Advising/Degree Audit/Graduation/Commencement: Transfer Evaluation The institution currently does not allow students to submit transfer coursework or prior learning evaluations once in the program. However, students may be able to earn such credit while also enrolled in a program at Kaplan. Observations

20 Registrar’s Office AuditKaplan UniversityMay 5-6, Advising/Degree Audit/Graduation/Commencement: Graduation Currently, the Registrar approves graduates versus formal approval by the faculty or board of trustees. Current policy requires that students must complete 25% of coursework at the university to be considered for graduation honors. The university has precedent for awarding posthumous degrees. However, no policy exists describing when such a degree may be awarded (e.g., number of hours or percentage of program). Observations

21 Registrar’s Office AuditKaplan UniversityMay 5-6, Advising/Degree Audit/Graduation/Commencement: Diplomas Diplomas are official documents signifying the completion of the student’s program. The university does not have an explicit policy regarding the name students may select to place on their diploma. The office does not have a stated policy regarding reprinting of diplomas and under what circumstances may a reprint be provided (are second copies of the document permissible?). Observations

22 Registrar’s Office AuditKaplan UniversityMay 5-6, Advising/Degree Audit/Graduation/Commencement: Diplomas The institutional database does not currently have the ability to differentiate names for each student (though it does allow for recording of a “nickname”). One primary data field typically included in many database systems is the “attended as” name or the the student’s preferred name for the diploma. Diploma reprints often contain current signatures and dates which can lead to the appearance that the degree was conferred recently. Observations, continued

23 Registrar’s Office AuditKaplan UniversityMay 5-6, Advising/Degree Audit/Graduation/Commencement: Diplomas International students often have need to provide a notarized diploma as documentation of the completion of a degree program (other cultures do not consider a transcript as sufficient documentation as they would a diploma). Observations, continued

24 Registrar’s Office AuditKaplan UniversityMay 5-6, Advising/Degree Audit/Graduation/Commencement The institution should consider if the current policy of restricting transfer and prior learning evaluations once in the program is in the best interest of students and best matches their needs. If changed, the policy of final deadline for submission must be communicated clearly to students and advisors. The institution should review its charter (or state law) and determine who must approve graduates prior to degree conferral (registrar, faculty, or trustees). Recommendations

25 Registrar’s Office AuditKaplan UniversityMay 5-6, Advising/Degree Audit/Graduation/Commencement The institution should review its current policy that requires that students must complete 25% of coursework at the university to be considered for graduation honors to determine if students have completed enough resident hours to be considered. The university must develop policy describing when a posthumous degree may be awarded. The institution should consider awarding an honorary degree in such instances (which grants more flexibility). Recommendations, continued

26 Registrar’s Office AuditKaplan UniversityMay 5-6, Advising/Degree Audit/Graduation/Commencement The university should develop policy regarding the name students may select to place on their diploma (e.g., must be a form of student’s legal name). The office develop policy clarifying under what circumstances the reprint of a diploma is permissible (including if the original should be returned if possible). The institution should consider the addition of a diploma name database field to track this data. Recommendations, continued

27 Registrar’s Office AuditKaplan UniversityMay 5-6, Advising/Degree Audit/Graduation/Commencement Diploma reprints, if containing current signatures and dates, should include a statement on the diploma indicating the original information has changed. The institution should consider providing a second notarized diploma (may also need an apostille) to some international students who may need the notarized copy for documentation. This may require the institution to define the students to whom this will be provided (i.e., all international students?). Recommendations, continued

28 Registrar’s Office AuditKaplan UniversityMay 5-6, Information Technology and Support Equipment: General The university currently operates two student records database systems which contain redundant data. The CVue system (now considered by the institution as the primary data source) was implemented to replace the aging KCC system. Both systems have been “mirrored” for several years. The continued use of both systems requires dual entry by staff and requires significant human resources to maintain. Some staff still consider KCC to have primary data. Observations

29 Registrar’s Office AuditKaplan UniversityMay 5-6, Information Technology and Support Equipment: General Due to staff data entry preferences in one system over the other, student record data discrepancies may be introduced. Due to changes in IPEDS racial classification, cleanup of system data will be necessary for a future IPEDS reporting period. Security to student database records appears to be open to all staff who have access to each database module rather than based on a defined “role.” Observations, continued

30 Registrar’s Office AuditKaplan UniversityMay 5-6, Information Technology and Support Equipment: General The university community must recognize the CVue as the primary database which will require significant coordination and communication. Staff must be trained on data entry in the CVue system, specifically for academic advising information. Discrepancies betweeen KCC and CVue must be identified and resolved. The university must determine a reasonable “mothball” process for KCC to recapture staff time. Recommendations

31 Registrar’s Office AuditKaplan UniversityMay 5-6, Information Technology and Support Equipment: General The office should consider how to address the IPEDS racial classification changes (including needed modifications to current system data structure) and plan for migration for a future IPEDS reporting period. Security to student database records must be defined based on one’s “role.” Definition of each “role” should include which records and what level of access is appropriate (e.g., view vs. update access). Recommendations, continued

32 Registrar’s Office AuditKaplan UniversityMay 5-6, Legal: FERPA The institution does not currently define “directory information” nor how it may be released. The institution does not currently define the point at which an applicant becomes a “student” at which time the student record is created (according to FERPA). This may differ by institution but must be no later than the date of beginning coursework. The institution does not currently define the process by which a student may view their student record(s). Observations

33 Registrar’s Office AuditKaplan UniversityMay 5-6, Legal: FERPA FERPA training for faculty and staff is inconsistent with the exception of staff in the Registrar’s Office. The Registrar’s Office currently restricts release of information unless signature release is submitted. However, the institution is considering submission of enrollment data to the National Student Clearinghouse at which time definitions of directory information and release of information guidelines must be explicit. Observations, continued

34 Registrar’s Office AuditKaplan UniversityMay 5-6, Legal: FERPA The office does not have a clearly defined process for release of student records upon receipt of subpoena. The institution provides annual notification of FERPA rights to students in the institutional catalog. Observations, continued

35 Registrar’s Office AuditKaplan UniversityMay 5-6, Legal: FERPA The institution must appropriately define “directory information” including the provisions under which such information may be released. The institution may choose to allow students to restrict all or part of their records for release but must define to faculty and staff how such a restriction is identified in the student record database. The institution must define the point at which the student record is created. Recommendations

36 Registrar’s Office AuditKaplan UniversityMay 5-6, Legal: FERPA The institution must define the process by which a student may view his/her record and provide annual notification to students as required by the FERPA regulations. Annual notification included in the catalog should be reviewed to determine if it is the appropriate notification process for students. The institution should consider policy for restriction of student record release and what is allowable (all or part of the record). Recommendations, continued

37 Registrar’s Office AuditKaplan UniversityMay 5-6, Legal: FERPA The institution should define the process for submission of records following receipt of a subpoena. As the institution moves forward with enrollment information submissions to the Clearinghouse, the office must consider FERPA restrictions in the CVue system and restricting data on reports. The office should review the FERPA training (and confidentiality agreements) provided to faculty and staff at the institution to insure appropriateness. Recommendations, continued

38 Registrar’s Office AuditKaplan UniversityMay 5-6, Thank you! Reid Kisling consulting.aacrao.org