FERPA Concerns for Sending and Honoring Electronic Requests for Student Transcripts

SACRAO 2012

Tuesday, February 14

Covington, Kentucky

SPEEDE – A Professional Development Committee of AACRAOAmerican Association of Collegiate Registrars and Admissions Officers

Presentation OutlineElectronic 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 institutionEnhances institutional relationshipsDecreases email and phone follow up communicationMore secure delivery than USPSDecreased processing time

Areas of opportunity with the processNot everyone honors this standardTranscript request fees are not handled through this

technologySome institutions do not honor institution-to-institution

(third party) requests

Case Study: University of Phoenix Future - Acceptance of TS146

RequestsPlan

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 BenefitsOptimize 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 AwarenessBased 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 SurveyIntent

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 SurveyedAll Institutions on the Texas Server Registrant’s

table as of February 2009

Responses61 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 Not included with vendor services Not set up to handle through SIS Lack of technical support to troubleshoot Authorization/validation concerns for the receiving

institution A lack of EDI relationships to do this Requests have to be student initiated for most

receiving partnersSurvey 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.Do not know what it is; lack of technical

support/knowledge Is not compatible with workflow processes (SIS)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).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 Easier and faster to process strait from SIS and

reduces manual workflowConvenient 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 146The TS 146 is commonly used as an institution-to-institution

request forstudent 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 AmendedFERPA 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 ConcernsBased 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.

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

Questions?

Please fill out your evaluation form:

ReferencesPESC Website. EDI Implementation Guides (TS 146). http://www.pesc.org/interior.php?page_id=146

Department of Education Website (FERPA). Dec. 2008.

http://www.ed.gov/legislation/FedRegister/finrule/2008-4/120908a.pdf

Thank you! This presentation is brought to you by the

AACRAO Speede Committee

Last Resort For Help

Rick SkeelUniversity of Oklahoma

rskeel@ou.edu405-325-6196