Colorado learners are earning more college credit in high school, at community colleges, and through military service, but too many lose ground when they transfer between institutions. A new state audit offers a clear look at where Colorado’s transfer system works, where it breaks down, and how the state can make every credit count.
The Office of the State Auditor (OSA) recently released an audit on Higher Education Transfer Credits, identifying key gaps that limit students’ ability to transfer credits smoothly. When credits don’t transfer as expected, it costs learners time and money, and delays their entry into the workforce.
This audit provides important insights to create a more efficient, learner-centered higher education system that benefits both learners and Colorado’s workforce.
Background
This audit was requested in 2023 to evaluate whether Colorado’s statewide transfer system works as intended for students. The OSA reviewed Statewide Transfer Articulation Agreements (STAAs), Guaranteed Transfer (GT) Pathways, and credit for prior learning through military service. The audit analyzed student transcript data, interviewed institutions, reviewed policies across all 28 of Colorado’s public higher education institutions, and analyzed 176 student cases.
Audit Recommendations
The audit generally concluded that the system works as intended: most students who submit transcripts and documentation successfully transfer credits toward their degrees.
However, the audit identified several breakdowns, including unclear documentation rules and inconsistent institutional practices, which caused approximately 13 percent of sampled students to lose credits. The report also found inconsistent approaches to evaluating military experience and noted cases where four-year colleges did not honor AP and other exam credits previously awarded by two-year institutions.
The audit grouped findings into three areas where clearer policies and stronger oversight can better support students.
Statewide Transfer Agreements (STAAs) are voluntary agreements in which public 4-year institutions agree to accept students who earn an associate degree from a public 2-year Colorado college into the same degree path with junior standing.
Four recommendations address STAAs:
- Strengthen reporting and oversight on transfer student outcomes
- Clarify when original exam documentation is required, even when exam credits already appear on a prior transcript
- Improve policies for how elective credits and foreign credits transfer
- Review specific student cases identified in the audit to ensure learners receive the credits they earned
Guaranteed Transfer (GT) Pathways is a statewide list of lower-division general education courses that automatically transfer among all Colorado public colleges and universities.
Five recommendations focus on GT Pathways:
- Clarify how GT Pathways credits apply to different associate degree types, particularly applied degrees
- Provide clearer guidance for colleges on how to handle GT Pathways credits not needed for a student’s major
- Guarantee courses transfer and apply regardless of course prefix variation
- Improve communication with students about submitting final transcripts
- Review specific student cases identified in the audit to ensure those learners receive the credits they earned
In 2017, Colorado required colleges to adopt policies for awarding credit for learning acquired through military service. All service members can receive a Joint Services Transcript (JST) documenting their training and college credit recommendations from the American Council on Education. Military learning can also be demonstrated through discharge forms (DD214), standardized exams like CLEP, or other records. The Department of Higher Education also maintains Prior Learning Assessment tables showing how GT Pathways credit can be awarded to service members, though these tables were last updated in 2018.
The remaining recommendations address credit for military service:
- Clarify when colleges can use documentation other than a JST to award credit
- Determine how exam-based credits should appear on transcripts
- Decide whether students must provide extra paperwork to receive credit for exams like CLEP
- Set clearer expectations for how Defense Language Proficiency scores qualify for world-language credit
- Guide colleges on helping military students submit documentation
- Confirm every institution has a compliant policy for awarding military credit
- Determine whether to update or replace the outdated Prior Learning Assessment tables for GT Pathways credit
- Ensure military students denied GT Pathways credit receive it
- Train colleges to correctly enter military-experience data into the statewide system
View the full audit and detailed recommendations here.
Why it Matters
Seamless transfer credit is essential to affordability and completion rates in higher education. The audit estimates an additional year of college costs a student $73,000 when accounting for tuition and lost wages. The audit also highlights the responsibility of the state to ensure more consistent fidelity of policy implementation across our state’s public institutions. Transfer breakdowns also disproportionately impact low-income, first-generation, and rural learners who rely more heavily on community colleges and concurrent enrollment to begin their degrees.
The audit estimates an additional year of college costs a student $73,000 when accounting for tuition and lost wages.
What’s Next
The Colorado Commission on Higher Education (CCHE) and the Department of Higher Education (DHE) have accepted the audit’s nineteen recommendations. Full implementation is expected by October 2026, with some actions required earlier. Specifically, the commission will reinstitute its Transfer Subcommittee to lead these efforts.
Colorado Succeeds’ top priorities stemming from this audit:
- Align more credits through GT Pathways to employer-aligned Career and Technical Education (CTE) programs to create stronger connections between concurrent enrollment and career readiness, creating more postsecondary options for all students.
- Use public reporting and data more regularly to monitor progress and improve credit transfer across institutions.
- Support consistent definitions and policies across our public institutions for prior learning credit—especially for military students—to ensure work and service experience translate into recognized, transferable college credit.
- Leverage technology and statewide best practices to reduce transcript processing burden on students and institutions to make credit acceptance more transparent and efficient across institutions.
Together, these changes will help ensure every credit counts, saving students time and money while strengthening the pipeline of educated, skilled talent that drives Colorado’s economy.