FERPA and Dual Enrollment: Institutional Practice and Policy Considerations

FERPA and Dual Enrollment: Institutional Practice and Policy Considerations

Matthew Ison, Joy Cobb, Molly C Ward, Samantha Hollback

Journal of Applied Research in the Community College Fall 2023

Spotlight authors: Jessie Steiger and John Fink, CCRC

Dual enrollment blurs the lines between college and high school, and thus complicates the Family Educational Rights and Privacy Act (FERPA) obligations of postsecondary institutions. Ison et al’s practice brief provides guidance to community colleges leaders in navigating FERPA obligations for high school students pursuing dual enrollment. The authors offer practical recommendations for college leaders to improve institutional policy and practices in connection with two distinct populations: parents/guardians and secondary institutions:

For parents/guardians, Ison et al recommend that colleges standardize and digitize processes whereby students waive their FERPA rights and provide proxy access to a parent or guardian to access their student records. They recommend that college leaders need to explain differences between privacy rights of students between postsecondary and secondary institutions, and that colleges should proactively create and communicate policies and procedures around proxy access, communication to students and parents, and release of college transcripts. At the same time, authors stress that it is important for students to understand that they are responsible for their college education and that participating in dual enrollment coursework will require more autonomy than college coursework – even if their parent/guardian technically has access to their educational records.

For secondary institutions, Ison et al recommend ensuring Memorandums of Understanding (MOUs) outline a process for secure and timely transfer student records at the end of each semester without requiring the express permission of students for each course (especially important for dual enrollment models where the college course concurrently counts as high school credit). Authors cite Department of Education guidance that doing so falls within the FERPA framework for sharing educational records with other parties with a “legitimate educational interest.”

For additional information about FERPA and dual enrollment, including strategies for practitioners, see this 2019 brief from Career Ladders Project.