In the Room

A few weeks ago, at the close of Law or Lore, I told you I was moving to something new. That series taught me how strong the appetite is among our institutions for straight talk about what accreditation actually requires versus what people assume it requires. In the Room is going to do something a little different. Instead of correcting misconceptions after the fact, I want to bring you into the room while the work is still being shaped, the issues we are wrestling with and the initiatives we are building at The Commission, before they are finished products. If you know me, you know where the name comes from. This first installment is about one of the most consequential ideas on our table right now: a Credit Transfer Consortium. Let’s start with why it matters.

The Issue

Every year, roughly 38 million Americans carry some college credit and no credential, what researchers call the ‘some college, no credential’ population. A significant share of that group stopped out or transferred between institutions, only to discover that credit they had already earned did not travel with them. The Government Accountability Office found that students who transfer lose an average of 43 percent of their earned credits. That number is higher among military and student athletes. Over a third of all undergraduates transfer at least once in their academic career, so this is not an edge case. It is a structural feature of how students actually move through higher education, and it costs them time, money, and often the momentum that keeps them enrolled at all.

Accreditation standards have historically said almost nothing about whether an institution accepts transfer credit. That silence was not neutral. It left the decision entirely to institutional discretion, and institutions, understandably, have used transfer policy to protect enrollment, tuition revenue from required courses, and, in some cases, a sense of academic prestige. None of that makes institutions wrong to have acted that way. It makes clear that credit loss is a systems problem, not a bad-actor problem, and systems problems need a structural remedy.

That is why The Commission is exploring a voluntary Credit Transfer Consortium: member institutions would commit to recognizing general education credit earned at other member institutions, subject to agreed equivalency standards. It is voluntary. It asks institutions to accept real constraints on their autonomy in exchange for something valuable in return. And it is, I think, one of the most promising structural remedies available to us. Let’s be clear, states have already done great work with their institutions on transfer. What I believe we can do is expand that work across state lines to best support and represent a very mobile student population.

The Discussion

A voluntary consortium only works if institutions have real reasons to join, so we have spent the last several months mapping what those reasons could be. They fall into four categories: enrollment and revenue (guaranteed transfer pathways, a shared marketing network, priority access to transfer-ready student data), accreditation and regulatory relief (a formal transfer-friendly designation, streamlined substantive change review, favorable treatment near sanctions thresholds), academic and reputational recognition (national awards, thought-leadership platforms at Commission events), and operational relief (shared equivalency frameworks so registrars are not rebuilding the wheel institution by institution).

On the standards side, the draft framework we are testing includes a 90 percent credit-acceptance floor for equivalent coursework between member institutions, a publicly posted and annually updated equivalency guide, a 30-day evaluation timeline with written explanations for any credit not accepted, a formal appeals process, and non-discrimination protections so acceptance decisions cannot turn on where a student came from. Institutions still retain 10 percent discretionary judgment, and faculty senates still control curriculum. The floor governs the transfer evaluation process, not what a course has to look like to exist.

We have also been honest with ourselves about where institutions will push back: fear of lost tuition revenue, concern about accepting credit from ‘weaker’ programs, worry about diluting academic standards, and unease about what this means for faculty governance. Every one of those concerns deserves a real answer, not a dismissal, and we are building the framework with those answers built in rather than bolted on afterward.

There is also a reason this conversation cannot wait. On May 21, the U.S. Department of Education’s Accreditation, Innovation, and Modernization committee, the same negotiated rulemaking process I have been tracking with you since the spring, reached consensus on a package of regulatory changes, including new federal requirements on transfer of credit. Under the agreed language, accreditors will be required to ensure institutions maintain policies that presume undergraduate credit will be awarded for coursework completed at another accredited institution with comparable content and learning outcomes, unless the institution can provide a written, student-specific rationale for denying it. Institutions will also face new disclosure obligations: telling students before they enroll or commit financially what credit will transfer, explaining any denial, estimating the cost and time to replace denied credit, and providing a real appeal. The Department is expected to publish a formal proposed rule this summer, with a final rule targeted for November 1 and an effective date of July 1, 2027.

I want to be clear about what that means for us. This has been a prevalent issue in higher education for a very long time. We are at an inflection point and have the opportunity to show the world that we are about students first and solve this issue on our own. I believe we have the strongest argument yet for building this Consortium well, and building it now. The federal floor that is coming will apply whether or not institutions have had any hand in shaping how it works in practice. A Consortium of our members with faculty driving the equivalency decisions gives our institutions a running start, a framework designed with them rather than handed down to them, and infrastructure already in place before compliance becomes mandatory rather than voluntary.

Progress Update

As of this writing, 195 institutions ranging from the very large to the small have joined us in developing the framework for the Consortium with our largest numbers being our Level I (associate degrees as their highest degrees) and our Level VI (four or more doctorates as their highest degrees). In July, we brought this conversation directly to the people who will have to live inside whatever we build. At the Summer Institute, department chairs, registrars, institutional effectiveness staff, and faculty content experts from across our membership worked through three questions using live polling, and we let the room vote in real time rather than asking them to react to a proposal we had already written.

On governance, the clear preference was a steering committee paired with subject-area committees, with representation across states, institutional levels, and public and private lines, and real opportunities for input rather than a seat at the table for show. On incentives, the runaway favorite was visible recognition: a ‘transfer-friendly institution’ seal that shows up on the website, on recruitment materials, and on the transcript itself, not a plaque nobody sees. And on the question of faculty trust, which drew the most decisive response of the day, the room asked us to create a formal Commission’s Fellows program that names and credits the faculty who do the actual work of evaluating equivalencies.

The Pruitt Perspective

Strip away the acronyms and the vote counts, and this comes down to two forms of trust that have to hold at the same time. Institutions have to trust that a consortium will respect their autonomy and their academic judgment, not override it. And students have to trust that a credit they worked hard to earn will not simply vanish the moment they walk onto a different campus. Right now, we are asking institutions to extend trust toward a structure that does not fully exist yet, which is exactly why the design work matters as much as the eventual standard.

The AIM rulemaking changes the calculation, but it does not change the principle. A federal floor on transfer credit is coming regardless of what we do. We can wait and let the Department define, entirely on its own, what compliance looks like for our institutions. Or we can build something better first, something shaped by the registrars and faculty who actually do this work, something that treats transfer credit as a matter of academic judgment and student trust rather than a checklist item. I know which one I would rather hand our institutions.

This is also, at its core, the same argument I made about negotiated rulemaking a few months ago. Accreditation should not become a federal compliance exercise. It is a peer-driven process grounded in professional judgment, institutional mission, and continuous improvement. A Credit Transfer Consortium, built with our institutions rather than around them, is how we keep that true even as the federal landscape shifts underneath us.

Students first. Always. That is the whole case for this Consortium, and it is why I think it is worth getting right, not just getting done.

Thanks for joining me In the Room. 

Dr. Stephen L. Pruitt