Administrative Holds: Aiding or Preventing Student Persistence?

Thanks to the critical and thoughtful analysis and reporting of organizations like Ithaka S+R and The Hechinger Report, higher education practitioners and policy makers are starting to recognize the role of administrative hold policies in student persistence and completion patterns. An estimated 6.6 million learners are affected by “stranded credits”—credits that students have earned but are not able to access for transfer or re-enrollment due to financial holds placed on their accounts for unpaid balances.

Individual student stories of losing access to credits, and the financial and emotional costs of overdue accounts, interest expenses, collections fees and damaged credit, are providing a fuller picture of the compounding penalizing effects of these policies. And yet, as financial hold policies are necessarily grabbing attention, the path toward reform is complex and warrants thoughtful attention to the entire range of administrative hold policies and their function in higher education.

Earlier this year, Sova and the Education Commission of the States had an opportunity to dig deeply into administrative holds, just as a spotlight was being shined on these policies for their effects on students. We undertook a landscape scan with the goals of better understanding where administrative hold policies originate within an institution or system, how they are implemented at institutions, and their impact on students. In our analysis, we were struck by the practical and ethical complexity of administrative hold policies—which we believe contributes to the challenge of reform. Based on what we learned, we encourage equity-minded leaders to examine the complexity of administrative hold policies in their work and to share what they are learning to support broader reforms. Three elements of this complexity are highlighted here.

1. Registration and transcript holds for overdue financial accounts are the focus of research and media reporting but represent just one of many types of administrative holds. The use of “administrative hold” as an umbrella term masks the breadth and diversity of holds that are in use at many institutions. According to AACRAO’s new analysis of holds at 14 institutions in academic years 2017–18 and 2018–19, debt-related holds were only around 30 percent of the holds placed during that period. An institution may have dozens of types of administrative holds that can be placed on student accounts from just as many offices or departments. In browsing a student FAQ page on one public university website, we noticed that the response to “What Does this Hold Mean?” included descriptions of over 40 different holds.

   Further complicating the issue, students can have multiple holds placed on their account at once, and many are likely to have multiple holds during their time as students. This makes understanding the source of holds and how to resolve them a real challenge for students. It also complicates tracking for institutions. Another recent AACRAO study, which surveyed representatives from 295 institutions, found that 95 percent of respondents reported withholding undergraduate transcripts for one or more reasons. Fewer than one-third of respondents were able to provide an estimate or count of the number of students that were impacted by a transcript hold at their institution during the 2019–20 academic year. The sheer variety of administrative holds complicates reform efforts.

2. Some administrative holds are essential tools for student support. Administrative holds are used to drive a student to take an action—like providing a medical record or meeting with an adviser if they appear to be off track or at risk of dropping out. Administrators that we spoke with during our research view some administrative holds as critical student success tools—levers to initiate conversations with students about their needs and to connect them with additional support, especially in cases where reminder emails and other forms of communication have failed. When students owe a balance, a hold ostensibly acts to compel a student to resolve the debt, but it may also be used to spur a conversation about options like enrolling in a payment plan or accessing emergency financial resources to help that student stay enrolled.

   While there is no doubt that some holds are having lasting detrimental effects on current and former students, the vast majority of holds are resolved—92 percent of debt-related holds and 85 percent of non-debt-related holds were resolved over the two years reviewed in AACRAO’s new analysis. Understanding the potential for positive impact complicates the examination of when and how to use holds.

3. Policies that shape administrative holds can be set at the institution, system, state and federal levels, yielding a complex and layered regulatory framework to navigate in reform efforts. For holds related to outstanding financial accounts, some institutions set their own policy. With the increased attention on transcript holds this year, we’ve seen a handful of institutions drop their policy of withholding transcripts for overdue student accounts altogether. Others have made changes like raising the debt floor that would trigger a hold, or using federal aid funds to help pay off student debts that were incurred during the pandemic.

   Despite these laudable institutional actions, many institutions are governed by system-level policies or state-level regulation that mandate transcript withholding, making change more complex. For example, Florida state statute requires that “No individual borrower who has been determined to be in default in making legally required scholarship loan, student loan, or guaranteed loan repayments shall be furnished with his or her academic transcripts or other student records until such time as the loan is paid in full or the default status has been removed.” Making large-scale change will require navigating this web of policies and identifying reforms that are appropriate for the local regulatory context.

While we’re encouraged by the hard work underway to reform hold policies that often create barriers to student success, our analysis suggests that policy and postsecondary leaders would be well served by developing a deeper understanding of the complexity of the administrative hold landscape. By building a more nuanced understanding of the origins and impacts of administrative holds on students, these leaders and practitioners will be more effective in reviewing and revising those policies that may not support students and often reinforce inequities.

For more on the administrative hold landscape, please look for a policy brief by the Education Commission of the States that will be released in early 2022.