Checklist · Education

Choosing a Program, Transferring Credits, and Surviving a School Closure: A Practical Checklist

20 U.S.C. § 1099

Type
Checklist
Jurisdiction
National
Date
2026-03-18
Topic
Education

A sequenced checklist for choosing a program, protecting credits, and responding when a school closes. Section A verifies accreditation and licensure eligibility before enrollment, and Section B locks down cost and transfer terms. Section C is the document file to build on day one. Section D covers what to do each term while enrolled. Section E handles a withdrawal and the return-of-funds calculation. Section F handles a transcript hold, and Section G handles transfer credit evaluation. Section H is the first week after a closure announcement, and Section I works the teach-out versus discharge decision. Section J assembles a misrepresentation record, and Section K covers state remedies. Section L is a closure-readiness audit for institutions.

Choosing a Program, Transferring Credits, and Surviving a School Closure: A Practical Checklist

Education > Higher Education Accreditation and School Closure | Published 18 March 2026 - Updated 4 June 2026 | UpLaw - uplaw.us

How to use this

Sections A through D are preventive and take about an hour. Sections E through K are for when something has gone wrong. Section L is for institutions. The single most consequential item is number 3 — verifying licensure eligibility with the licensing board rather than the school prevents the most damaging outcome in this field.

SECTION A — VERIFY BEFORE YOU ENROLL

☐ 1. Confirm the school's institutional accreditation and that its accreditor is recognized under 20 U.S.C. § 1099b and 34 C.F.R. Part 602. Screenshot it with the date.

☐ 2. Check for adverse actions — warning, probation, show cause, deferred decision, or monitoring — and read the commission's published action letter.

☐ 3. ⚠️ Call the state licensing board for your intended profession and ask whether graduates of this specific program at this specific school are eligible to sit for the examination. Do not accept the school's answer.

☐ 4. Confirm programmatic accreditation separately from institutional accreditation. They are different, and licensure usually depends on the former.

☐ 5. Confirm the school is authorized in your state, and if you are enrolling in a distance program, that it is authorized where you live — 20 U.S.C. § 1099a, 34 C.F.R. Part 600.

☐ 6. Obtain the licensure alignment disclosure for your state in writing.

☐ 7. Confirm the school is certified for federal aid under 20 U.S.C. § 1099c, and ask whether it is under provisional certification, heightened cash monitoring, or a letter of credit requirement.

☐ 8. Review the school's completion and placement disclosures under 20 U.S.C. § 1092, and ask in writing how placement is calculated — whether unrelated or part-time employment counts, and how non-responders are treated.

☐ 9. Check the most recent audited financial statement for a going-concern qualification, where available.

☐ 10. Check for recent campus closures, program terminations, or a change of ownership.

SECTION B — LOCK DOWN COST AND TRANSFER TERMS

☐ 11. Get the total cost in writing: tuition, fees, books, equipment, and the number of terms required to complete.

☐ 12. Get the transfer-of-credit policy in writing, as required to be disclosed by 20 U.S.C. § 1092.

☐ 13. Get any articulation agreement in writing, naming the receiving institution and the covered courses. ⚠️ A recruiter's oral assurance that credits "generally transfer" is worth nothing.

☐ 14. If you intend to transfer later, contact the target institution now and ask whether it accepts credit from this school's accreditor.

☐ 15. Read the enrollment agreement's cancellation and refund terms, and look up the state refund statute, which may be more generous and is mandatory where it applies.

☐ 16. Ask what happens if the school closes — whether teach-out agreements exist and with whom.

☐ 17. Ask where academic records would be permanently housed on closure.

☐ 18. Compare the aid package's grant versus loan composition, and total the borrowing required across all terms.

SECTION C — BUILD THE FILE ON DAY ONE

☐ 19. The enrollment agreement, signed, as executed.

☐ 20. The catalog in effect at matriculation, downloaded as a file. Not bookmarked — downloaded.

☐ 21. Every recruiting communication: emails, brochures, texts, and dated notes of oral statements with names.

☐ 22. Every disclosure provided under 20 U.S.C. § 1092.

☐ 23. Any articulation agreement relied on.

☐ 24. Every financial aid award letter and promissory note.

☐ 25. A screenshot of the accreditation status page with the date.

☐ 26. The licensure alignment disclosure for your state.

☐ 27. The student handbook and academic policies in effect.

☐ 28. Keep this file for at least ten years.

SECTION D — EACH TERM WHILE ENROLLED

☐ 29. Request an official transcript at the end of every academic year and keep it.

☐ 30. Save every account statement and receipt.

☐ 31. Re-check the school's accreditation status annually and screenshot it.

☐ 32. Save evidence of attendance and academic activity — submitted assignments, learning management system logs. This becomes the withdrawal-date evidence if it is ever needed.

☐ 33. Confirm your satisfactory academic progress standing under 20 U.S.C. § 1091 before it becomes an aid problem.

☐ 34. Re-confirm licensure alignment if you move to another state.

☐ 35. Review your FERPA rights and check your education record for accuracy — 20 U.S.C. § 1232g, 34 C.F.R. Part 99.

☐ 36. Consider whether to opt out of directory information disclosure.

☐ 37. Track total borrowing to date against the total cost estimate from item 11.

SECTION E — WITHDRAWING, AND THE RETURN CALCULATION

☐ 38. Withdraw officially, in writing. An unofficial withdrawal produces a worse calculation and a worse record.

☐ 39. Ask whether an approved leave of absence is available instead. An approved leave meeting the regulatory requirements is not a withdrawal.

☐ 40. Record your last date of academically related activity, with supporting evidence.

☐ 41. Request the return of Title IV funds worksheet — the mechanics live in 34 C.F.R. Part 668 and interact with 34 C.F.R. Part 685, 34 C.F.R. Part 682, 34 C.F.R. Part 674, and 34 C.F.R. Part 690.

☐ 42. Request the withdrawal date used and its documentary basis. ⚠️ A wrong date by two weeks can change the balance by thousands of dollars.

☐ 43. Request the institutional refund policy applied and the state refund statute the school believes governs. These are separate computations from the federal return.

☐ 44. Request an itemized ledger showing every charge, every disbursement, and every return.

☐ 45. Check for module or non-standard-term rules if your program uses them.

☐ 46. Compare the state refund statute's pro-rata schedule against what the school applied. State statutes are frequently more generous and are mandatory where they apply.

☐ 47. Dispute errors in writing, with the specific line items identified.

SECTION F — A TRANSCRIPT HOLD

☐ 48. Demand an itemized statement of the balance.

☐ 49. Ask whether the balance arose from a return of Title IV funds calculation, and work Section E.

☐ 50. Check whether the balance relates to periods covered by federal student aid, where restrictions on withholding apply — 34 C.F.R. Part 668.

☐ 51. Check your state's transcript statute. A growing number restrict or prohibit holds, especially for employment, transfer, or licensure. Cite it in writing.

☐ 52. Request a partial release for completed terms, or an official transcript sent directly to a receiving institution.

☐ 53. Distinguish the transcript from the diploma; a school may release one and not the other.

☐ 54. Assert your FERPA inspection right under 20 U.S.C. § 1232g to obtain the underlying record even if an official transcript is withheld.

☐ 55. Escalate: bursar → registrar → financial aid director → ombudsperson → compliance officer, in writing at each step.

☐ 56. If unresolved, file with the state authorization agency and the accreditor.

SECTION G — TRANSFER CREDIT EVALUATION

☐ 57. Request a pre-admission credit evaluation in writing from the receiving institution before you apply.

☐ 58. Provide course syllabi, not just the transcript. Equivalency decisions are made on content.

☐ 59. Ask which department makes the decision for your major, and address the request there.

☐ 60. Ask about the residency requirement — the minimum credits that must be earned in residence.

☐ 61. Ask about recency limits on credits in your field.

☐ 62. Ask whether pass/fail or credit-by-examination credits transfer.

☐ 63. Get the evaluation in writing before enrolling, and confirm whether it is binding.

☐ 64. If credits are denied, ask about the appeal process; many institutions have one and it is rarely used.

☐ 65. Note that transfer denial is not a legal claim against the receiving school. Your claim, if any, is against the sending school for misrepresenting transferability.

SECTION H — THE FIRST WEEK AFTER A CLOSURE ANNOUNCEMENT

☐ 66. ⚠️ Download everything today. Catalog, enrollment agreement, all disclosures, transfer policy, program pages, and every recruiting email. The website goes dark within days.

☐ 67. Request an official transcript and a complete academic record immediately, before the registrar's office ceases to exist.

☐ 68. Request an itemized account statement and any return-of-funds worksheet.

☐ 69. Establish your last date of attendance and document it.

☐ 70. Ask in writing whether a teach-out agreement exists, which institutions are parties, and which programs are covered.

☐ 71. Find out where academic records will be permanently housed and write down the address.

☐ 72. Obtain your federal loan servicing history and gather all private loan documents separately.

☐ 73. Call the licensing board and confirm whether the credential, if completed, would qualify you. This one call frequently decides everything.

☐ 74. ⚠️ Do not accept any transfer offer until Section I is complete. Competing schools recruit aggressively in these weeks, and their interest is enrollment.

SECTION I — TEACH-OUT OR DISCHARGE

☐ 75. Is the credential worth completing? Verified with the licensing board, not the school.

☐ 76. How much of the program remains? Terms completed: [ ] of [ ].

☐ 77. What is already borrowed? Federal: $[ ]. Private: $[ ].

☐ 78. What would completion cost? Additional tuition, time, and borrowing.

☐ 79. Understand that closed-school discharge under 20 U.S.C. § 1087 cancels federal loans for students enrolled at closure or who withdrew within the applicable window and did not complete — and generally refunds payments made.

☐ 80. ⚠️ Understand that completing through a teach-out, or transferring credits into a comparable program, generally extinguishes discharge eligibility.

☐ 81. Understand that discharge does not reach private loans. Analyze those separately.

☐ 82. If the teach-out institution has the same accreditation or licensure problem, it solves nothing.

☐ 83. Confirm the exact enrollment and withdrawal windows for discharge eligibility before acting.

☐ 84. If pursuing discharge, file the application and keep proof of filing.

☐ 85. If pursuing teach-out, get the terms in writing, including tuition, credit acceptance, and completion timeline.

SECTION J — MISREPRESENTATION AND BORROWER DEFENSE

☐ 86. Assemble every recruiting communication with dates and names.

☐ 87. Assemble the catalog and enrollment agreement in the versions in effect.

☐ 88. Assemble the 20 U.S.C. § 1092 disclosures as published at your enrollment.

☐ 89. Identify the specific representations at issue: placement rates · transferability · licensure eligibility · total cost · program length · accreditation status.

☐ 90. Identify how each representation was false or misleading, with the contrary evidence.

☐ 91. Note that 20 U.S.C. § 1094 prohibits substantial misrepresentation regarding the program, financial charges, and employability of graduates.

☐ 92. Note that the same section prohibits incentive compensation for recruiters — evidence of commission-based recruiting supports the pattern.

☐ 93. Document your reliance and your resulting loss.

☐ 94. File the borrower defense application with the supporting record.

SECTION K — STATE REMEDIES AND COLLECTION

☐ 95. Check whether your state has a tuition recovery fund. Claim windows are short and these funds are badly underused.

☐ 96. File a complaint with the state authorization agency.

☐ 97. File a complaint with the accreditor where the issue is systemic.

☐ 98. Consider a state consumer protection claim, which reaches pre-enrollment representations that a contract claim may not — see Consumer Protection Law.

☐ 99. Consider small claims for refunds within the jurisdictional limit.

☐ 100. If federal loans are in default, address administrative wage garnishment under 20 U.S.C. § 1095a — there is a hearing right — and tax refund offset under 31 U.S.C. § 3720A.

☐ 101. Use rehabilitation, consolidation, or income-driven repayment under 20 U.S.C. § 1098e to exit default. Nothing happens automatically.

☐ 102. Calendar every filing deadline the day you learn of it.

SECTION L — CLOSURE READINESS AUDIT FOR INSTITUTIONS

☐ 103. Version-control catalogs, handbooks, and enrollment agreements, archived by effective date and retrievable by matriculation date.

☐ 104. Assign one owner for 20 U.S.C. § 1092 disclosures, with an annual verification and an archive of each year as published.

☐ 105. Adopt a rule that no outcome claim may be made that is not traceable to a figure in the published disclosures, and bind marketing vendors to it with audit rights.

☐ 106. Review the compensation methodology annually against the incentive compensation prohibition in 20 U.S.C. § 1094.

☐ 107. Audit return-of-funds withdrawal-date determinations and worksheets periodically.

☐ 108. Track state authorization and licensure alignment for every state where students are located or placed.

☐ 109. Maintain a programmatic accreditation calendar with early warning of any lapse.

☐ 110. Draft the teach-out plan, records custodianship arrangement, and communications plan while solvent. They do not get written during a collapse.

☐ 111. Track student complaints and their root causes; accreditors and regulators read patterns.

☐ 112. Monitor the composite score and categorical triggers for financial responsibility, and model the cash effect of a letter of credit requirement before it is imposed.

☐ 113. Remember that everything in the accreditation record is public and will be read by students, competitors, lenders, and reporters.

SECTION M — QUESTIONS TO ASK, VERBATIM

Ask these in writing and keep the answers. Institutions answer specific written questions far more often than general complaints, and each answer either resolves the issue or creates a document.

☐ 114. "Please identify the accrediting agency for this institution and for the [program] program, and provide the current accreditation status and the date of the most recent commission action."

☐ 115. "Is the institution currently subject to provisional certification, heightened cash monitoring, or a letter of credit requirement?"

☐ 116. "Please provide the institution's transfer-of-credit policy and a list of all articulation agreements applicable to the [program] program, as disclosed under 20 U.S.C. § 1092."

☐ 117. "Does the [program] program satisfy the educational requirements for licensure as a [profession] in [state]? Please provide the licensure alignment disclosure."

☐ 118. "Please provide the total cost of the [program] program, including tuition, fees, books, equipment, and the number of terms required for a full-time student to complete."

☐ 119. "Please state how the job placement rate disclosed for this program is calculated, including whether unrelated or part-time employment is counted and how non-responding graduates are treated."

☐ 120. "Please provide the catalog in effect for students matriculating in [term], and confirm that its degree requirements govern my program."

☐ 121. "Please provide an itemized statement of my account showing every charge, every disbursement of financial aid, and every return of funds, by date."

☐ 122. "Please provide the return of Title IV funds worksheet for my withdrawal, the withdrawal date used, and the documentary basis for that date."

☐ 123. "Please identify the institutional refund policy applied to my withdrawal and the state refund statute the institution considers applicable."

☐ 124. "Please identify the basis for the hold on my transcript, the specific amount claimed, and the periods to which it relates."

☐ 125. "In the event of institutional closure, where will academic records be permanently maintained, and what teach-out agreements are currently in effect?"

SECTION N — RED FLAGS

Any one of these justifies more diligence. Three or more should stop an enrollment.

☐ 126. The recruiter will not put an outcome claim in writing. ☐ 127. The school's placement rate is far above the field average and the calculation method is not disclosed. ☐ 128. The transfer answer is "credits generally transfer" with no articulation agreement. ☐ 129. The licensing board has not heard of the program. ☐ 130. Institutional accreditation exists but programmatic accreditation is "in progress." ☐ 131. The accreditor has issued a warning, probation, or show cause within three years. ☐ 132. There has been a change of ownership within two years. ☐ 133. Campuses have closed or programs terminated recently. ☐ 134. The enrollment agreement must be signed today for a discount that expires today. ☐ 135. The total cost cannot be stated in a single number. ☐ 136. The aid package is presented as "covered" without separating grants from loans. ☐ 137. The school's audited financials carry a going-concern qualification. ☐ 138. Faculty turnover is high and full-time faculty are few. ☐ 139. Complaints to the state agency or accreditor show a pattern. ☐ 140. The school is unwilling to identify where records would go if it closed.

SECTION O — QUICK REFERENCE

☐ 141. Three gates: state authorization · accreditation · federal eligibility. All three are required; none supervises the others. ☐ 142. Credits transfer only if the receiving school says so. Get an articulation agreement. ☐ 143. Licensure depends on programmatic accreditation. Verify with the board. ☐ 144. The catalog at matriculation is contract evidence. Download it. ☐ 145. Withdrawal creates a balance through the return-of-funds calculation. Get the worksheet. ☐ 146. A transcript hold is leverage. Demand the itemized statement and check the state statute. ☐ 147. Teach-out and discharge are mutually exclusive. Decide before transferring. ☐ 148. Discharge reaches federal loans only. Private loans need a separate theory. ☐ 149. State tuition recovery funds exist in many states with short windows. ☐ 150. The evidence is on a website that will disappear. Download it now.

SECTION P — A NOTE ON SEQUENCING COMPLAINTS

Filing in the wrong place wastes months, and each of the available forums has a different scope. Use them in this order.

☐ 151. The institution's own process first. Bursar for billing, registrar for records, financial aid for aid calculations, ombudsperson or compliance officer for everything else. Put each request in writing and keep the response. This step is not optional in practice — every later forum will ask whether you tried it.

☐ 152. The state authorization agency for consumer-type complaints: refunds, misrepresentation, records, and closure. This is the designated venue in the triad for exactly these issues, and it has authority the accreditor does not.

☐ 153. The accreditor where the problem is systemic rather than individual — a program that does not meet its own published standards, a pattern of unresolved complaints, or a disclosure that is false. Accreditors generally do not resolve individual grievances, and they say so, but they do record them.

☐ 154. The federal complaint process for Title IV administration issues — aid that was not disbursed, funds returned incorrectly, or a program participation problem.

☐ 155. The state attorney general for deceptive practices, particularly where a pattern affects many students.

☐ 156. The licensing board where the issue is program eligibility for licensure; the board's determination is authoritative and can be decisive evidence.

☐ 157. Courts last, with a specific theory: contract on the catalog and enrollment agreement, state consumer protection for pre-enrollment representations, small claims for refunds within the limit, or administrative review of an agency decision. See Small Claims and Self-Representation.

📌 The most effective single document in any of these forums is the itemized ledger. It resolves most disputes outright and exposes the errors in the ones it does not.

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