Improving Statewide Transfer

The Colorado Commission on Higher Education (CCHE) is considering revisions to two Commission policies: 

• CCHE Policy I, Part L: Statewide Transfer and GT Pathways
• CCHE Policy I, Part X: Prior Learning Assessment

We invite you and your community to review the proposed revisions and provide feedback through the surveys linked below. Your feedback will help inform CCHE's consideration of the proposed changes, many of which address recommendations from both the 2025 OSA Performance Audit on Higher Education Transfer Credits and our CCHE Transfer Subcommittee members. These surveys are intended to gather feedback on the proposed revisions and are not intended for suggesting new policy topics or initiatives. Public Comment Deadline: Sunday, August 23, 2026 at midnight. 

Statewide Transfer and GT Pathways Policy

• Current Policy
• Proposed Draft
• Submit Feedback

Prior Learning Assessment

• Current Policy
• Proposed Draft
• Submit Feedback

Public Comment Notice

Comments submitted through these surveys are intended to inform the Colorado Commission on Higher Education's consideration of proposed policy changes. Consistent with public records requirements and Commission practices, responses are not anonymous. The name and organizational affiliation provided by respondents, along with the content of submitted comments, may be publicly posted, shared with the Commission, and disclosed in response to public records request. Please do not include confidential or personally sensitive information in your comments. 

If you have questions regarding either policy revision or trouble accessing any documents, please contact Brad Griffith. 

Senate Bill 24-164: Strengthening Transfer Guarantees

Background

Senate Bill 24-164 modified the Student Bill of Rights (Colorado Revised Statute [C.R.S.] 23-1-125) for the first time since its inception in 2001 to improve transfer fairness and accountability. Students will benefit from faster credit evaluations, clearer policies, and enhanced appeals processes for Guaranteed Transfer (GT) Pathways courses. 

View Full Bill

Key Actions Completed

• Held over 65 stakeholder meetings to date to implement the bill;
• Expanded the General Education Council to include all 31 public institutions;  
• Revised CCHE Policy I, Part L to require institutional notification of transfer credit within thirty (30) days;
• Delivered recommendations to improve transfer within the Guaranteed Transfer (GT) Pathways course matrix to CCHE;
• Developed a student appeals process for GT Pathways course transfers; and,
• Promulgated rules to bring enforcement action on behalf of the state against IHEs for violations of C.R.S. 23-1-108.5;
• Report on transfer activity, including student completion data.
  • Data Files Available to Download:
    • Average attempted credits, credits to degree, and time to degree for transfer students compared to non-transfer students
    • Summary of students transferring to and from institutions of higher education
    • Accepted and Applied GT Pathways Credit Hours Data by Institution
    • Institution Reports of Most Common GT Pathways Course Transfer Issues

Rulemaking Process to Implement SB 24-164

Current Status

CDHE is conducting rulemaking to implement provisions of SB24-164 related to statewide transfer and transfer transparency. 

Upcoming Milestones

• October 6, 2026: Stakeholder meeting
• October 10, 2026: Publication of proposed rules by the Colorado Secretary of State
• November 3, 2026: Public rulemaking hearing

Register for November 3 Virtual Hearing

Overview

SB24-164 expanded CDHE's authority related to the implementation and oversight of certain statewide transfer requirements. To carry out these responsibilities, the Department is promulgating rules pursuant to the authority granted by the legislation and in accordance with the Colorado State Administrative Procedure Act. 

The proposed rules identify the statutory transfer requirements subject to enforcement and establish processes to support consistent implementation across Colorado's public institutions of higher education. The rulemaking effort is intended to promote transparency, accountability, and the effective administration of Colorado's statewide transfer system.

Stakeholder Engagement

The Department is committed to a transparent and collaborative rulemaking process. Development of the proposed rules has included consultation with representatives from Colorado's higher education community, including academic affairs professionals, admissions officers, registrars, institutional researchers, faculty representatives, and statewide transfer governance groups.

Stakeholder feedback has informed revisions to the draft rules and will continue to be considered throughout the rulemaking process.

Rulemaking Timeline

October 6, 2026
Stakeholder meeting to review the proposed rules, discuss the rulemaking process, answer questions, and receive additional feedback.

October 10, 2026
Publication of the proposed rules and Notice of Rulemaking on the Colorado Secretary of State's website.

Access Colorado Register

November 3, 2026 | 2:00-3:00 p.m.
Public rulemaking hearing to receive public comments, views, and arguments regarding the proposed rules.

Register for Virtual Hearing

Public Participation

The Department encourages institutions, students, faculty, staff, and other interested parties to participate in the rulemaking process.

Members of the public may review the proposed rules and provide feedback through the formal rulemaking process. Information regarding hearing participation, public comment procedures, and related materials will be posted as they become available.

Rulemaking Documents

The following materials will be posted throughout the rulemaking process:

• Proposed Rules*
• Notice of Rulemaking*
• Stakeholder Meeting Materials
• Public Hearing Information*
• Public Comment Resources
• Final Adopted Rules*

*Will be available on the Colorado Secretary of State portal.

Statutory Authority

This rulemaking is being conducted pursuant to C.R.S. 23-1-108.5, as enacted by SB24-164, and following the Colorado State Administrative Procedure Act. The proposed rules implement provisions of state law related to statewide transfer requirements and transfer transparency.

Additional Resources

• SB24-164
• Improving Statewide Transfer Initiative 
• Colorado Rulemaking Portal
• CCHE Policies and Procedures
  • Refer to Statewide Transfer & GT Pathways and Prior Learning Assessment policies for relevant context.

CDHE Implementation Leads

• Carl Einhaus, Chief Student Success and Academic Affairs Officer (Main Lead)
• Michael Vente, Deputy Chief Research and Policy Officer
• Brad Griffith, Senior Director of Academic Pathways and Innovation
• Christina Carrillo, Director of Transfer and Student Advocacy

House Bill 25-1038: Colorado Transfer Platform

Background

House Bill 25-1038 created Colorado Transfer, a centralized, online, statewide resource for students to explore transfer options. Initially prioritizing GT Pathways, credit-by-exam, and statewide transfer agreements, CDHE is charged with growing the site as a resource for current and prospective college students. The site does not offer admissions functionality or guarantees and is intended only to be a source of information and connection to institutions. 

View Full Bill
 

CDHE Implementation Leads

• Christina Carrillo, Director of Transfer and Student Advocacy
• Ezekiel (Zeke) Clark, Web Developer/Project Manager
• Kennedy Evans, Budget and Policy Analyst
• Brad Griffith, Senior Director of Academic Pathways and Innovation 

Progress to Date

• Colorado Transfer was officially launched in September 2025 with Statewide Internet Portal Authority (SIPA) grant funding and incorporated:
  • Statewide GT Pathways course offerings;
  • GT Pathways credit-by-exam opportunities (i.e., Advanced Placement [AP], International Baccalaureate [IB], College-Level Examination Program [CLEP]); and
  • Streamlined navigation to Statewide Transfer Degrees and military credit for prior learning.
• Features on the website were designed with input from students, registrars, and academic advisors.
• Defined vision and funding needs for Phase 2 development of a standalone site to potentially include:
  • Enhanced credit transfer guidance tools for students;
  • Scalable data sharing for institutions;
  • Showcasing of industry-recognized credentials and apprenticeship certificates

OSA Performance Audit on Higher Education Transfer Credits 

Background

The Colorado Office of the State Auditor (OSA) conducted a comprehensive review of transfer credit processes during October 2024 to September 2025 at the request of the General Assembly. The audit examined whether statutory guarantees for GT Pathways, Statewide Transfer Articulation Agreements (STAAs), and military learning and experience credits are working as intended. The goal was to identify gaps that cause students to lose credits during transfer. 

Read the Full Report

Key Findings:

• Overall Performance: GT Pathways, STAAs, and military credit for prior learning generally functions as expected, but some students are still at risk of losing credits.
• Credit Loss Causes:
  • 13% of students (23 out of 176) lost credits because they failed to submit additional documentation or complete required review processes for prior learning or previously transferred credit.
  • 21% of students (37 out of 176) lost credits because they never submitted transcripts.
• Institutional Practices: Colleges had inconsistent follow-up practices for missing documentation, creating inequities for students.
• Military Credit: Most military students received some credit for prior learning, but processes varied widely.
• Recommendations: OSA issued 19 recommendations to improve transfer processes, including better communication with students, standardized follow-up procedures, and clearer documentation requirements.

CDHE Implementation Leads

• Carl Einhaus, Chief Student Success and Academic Affairs Officer (Main Lead)
• Brad Griffith, Senior Director of Academic Pathways and Innovation
• Christina Carrillo, Director of Transfer and Student Advocacy 

Next Steps

CDHE is reviewing all recommendations with the Commission and will publish an implementation plan in early 2026.

Colorado Commission on Higher Education (CCHE) Transfer Subcommittee

Background

CCHE reestablished this subcommittee under the Student Success and Workforce Alignment Standing Committee to address audit findings and strengthen statewide transfer policy and student success. The group serves as a collaborative forum for institutions, policymakers, and stakeholders to recommend improvements. Its initial objectives are to:

• Review OSA audit recommendations and advise on implementation strategies.
• Identify broader policy changes to improve transfer equity and efficiency.
• Provide input on legislative compliance and student-facing resources.

Members were identified and nominated to participate in the transfer subcommittee by Commissioners and Advisors of the CCHE in addition to CDHE staff. 

Subcommittee Members
 

Representatives include commissioners, public colleges and universities, school districts, education advocacy organizations, and CDHE staff:

• Berrick Abramson, Chair – Colorado Commission on Higher Education
• Nicole McWhirter, Commissioner - Colorado Commission on Higher Education 
• Brittny Blechar, Partner of Advanced Academics, Cherry Creek Schools
• Miki Brooks, Director, Transfer Success Initiatives – University of Colorado Boulder
• Robert Cackler, Registrar – Colorado Mesa University
• Michelle Camacho Liu, Director, Programs & Policy – The Attainment Network
• Gabriela Chavez - Rocky Mountain Partnership
• Kristie Duran, High School Counselor - Sanford Schools
• Theresa Groff, Registrar – Arapahoe Community College
• Dr. Joe Horan, Teaching Professor of Humanities, Arts, and Social Sciences - Colorado School of Mines
• Carrie Knudson, Director of Concurrent Enrollment – Northeastern Junior College
• Peter Lindstrom, Interim President & Provost - Community College of Denver
• Richard Maez, Executive Director - Ednium
• Tamara McCool, Registrar – Metropolitan State University of Denver
• Shannon Nicholas, Senior Vice President, Policy and Advocacy – Colorado Succeeds
• Dr. Bobby Pace, Interim Vice Chancellor for Academic and Student Affairs - Colorado Community College System
• Travis Parkhurst, Faculty – Pueblo Community College
• Dr. Kathryn Regjo, Vice President of Academic Affairs - Colorado Mountain College
• Dr. Michelle Romero, Director, Office of Postsecondary and Workforce Readiness – Colorado Department of Education
• Debbie Shackelford - Apprenticeship Colorado
• Patrick Tally, Assistance Dean of Academic and Curricular Affairs - University of Colorado Boulder
• Dr. Linda Van Doren, Vice President of Education – Emily Griffith Technical College
• Carl Einhaus, Chief Student Success and Academic Affairs Officer – Colorado Department of Higher Education
• Brad Griffith, Senior Director of Academic Pathways and Innovation – Colorado Department of Higher Education
• Christina Carrillo, Director of Transfer and Student Advocacy – Colorado Department of Higher Education
   

Transfer Subcommittee Meeting Schedule

The CCHE Transfer Subcommittee will meet monthly through 2025-2026.

Date	Agenda & Minutes	Meeting Location
December 10, 2025 2:00 pm – 3:00 pm	Agenda / Minutes	December 10 Recording
January 14, 2026 10:30 am - 12:00 pm	Agenda / Minutes	January 14 Recording
January 26, 2026 1:00 pm - 2:30 pm	Agenda / Minutes	January 26 Recording
February 12, 2026 1:00 pm - 2:30 pm	Agenda / Minutes	February 12 Recording
February 24, 2026 10:30 am - 12:00 pm	Agenda / Minutes	February 24 Recording
March 17, 2026 1:00 pm - 2:30 pm	Agenda / Minutes	March 17 Recording
April 7, 2026 1:00 pm - 2:30 pm	Agenda / Minutes	April 7 Recording
April 28, 2026 1:00 pm - 2:30 pm	Agenda / Minutes	April 28 Recording
May 19, 2026 1:00 - 2:30 pm	Agenda / Minutes	May 19 Recording
June 10, 2026 1:00 - 2:30 pm	Agenda / Minutes	June 10 Recording
June 30, 2026 1:00 - 2:30 pm	Agenda / Minutes	This meeting has been canceled.
July 21, 2026 1:00 - 2:30 pm	Agenda / Minutes	July 21 Recording
August 12, 2026 1:00 - 2:30 pm	Agenda / Minutes	August 12 Recording
September 1, 2026 1:00 - 2:30 pm	Agenda / Minutes	September 1 Recording
September 22, 2026 1:00 - 2:30 pm	Agenda / Minutes	September 22 Recording