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 email 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
 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
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.
 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 workflow
 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
Decisions to Either Accept or not Accept the TS 146
Request for Student Transcripts …continued
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
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.
2.
3.
Institutions who trade electronically within the same state/region
or district and do not charge transcript fees.
Institutions within “Network” of each other via a vendor service
(prearranged or no fees).
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…
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:
References
PESC 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 Skeel
University of Oklahoma
[email protected]
405-325-6196