Orderly Closure and Student Records Continuity Protocol
1. Purpose
This protocol establishes a standing institutional framework for protecting students, preserving records, and coordinating essential responsibilities in the unlikely event that Colby Community College determines that an orderly institutional closure is necessary. It is intended to connect existing College policies and responsible offices so that student needs, academic continuity, records access, regulatory obligations, and communications are addressed in a coordinated manner.
2. Scope and Relationship to Other Requirements
This protocol applies to a complete institutional closure and may be used, as appropriate, to guide planning for the closure or suspension of a campus, location, or educational program when student completion could be affected. Existing College policies governing records retention, privacy, information security, emergency operations, fiscal administration, and governance remain in effect throughout any closure or teach-out period.
This protocol is a standing administrative preparedness document. It does not replace any provisional plan, teach-out agreement, substantive change submission, or other notification or approval required by the Higher Learning Commission (HLC), the Kansas Board of Regents, the U.S. Department of Education, programmatic accreditors, licensing agencies, or other authorities. When such requirements are triggered, the College will follow the applicable external process.
3. Guiding Principles
- Student protection and reasonable opportunity for program completion will be the primary consideration in closure planning.
- Decisions and communications will be timely, accurate, transparent, and appropriate to affected student populations.
- Student and institutional records will remain protected, retrievable, and accessible in accordance with applicable retention, privacy, security, and accreditation requirements.
- Essential academic, financial, advising, technology, and records functions will be maintained until responsibilities have been completed or transferred to an appropriate custodian.
- Closure actions and final disposition decisions will be documented.
4. Activation and Coordination
The President, or designee, will activate this protocol when circumstances indicate that an institutional closure or comparable teach-out situation may become necessary. Upon activation, the President will establish a Closure Coordination Team and assign responsibilities based on the scope and circumstances of the closure.
At minimum, the Closure Coordination Team should include appropriate representation from the President's Office, Academic Affairs, Student Affairs, Finance and Operations, Registrar, Financial Aid, Information Technology, Institutional Effectiveness / Accreditation, Human Resources, Communications, and affected academic or operational areas.
5. Student Protection and Academic Continuity
Upon activation, the College will identify affected students and programs and develop an individualized and institution-wide approach to completion. Actions will include, as applicable:
- Produce an accurate inventory of affected programs, locations, and currently enrolled students, including students on approved leaves and students accepted but not yet enrolled when applicable.
- Determine whether students can complete their programs through CCC within a reasonable period and under continued accreditation, authorization, staffing, and resource requirements.
- If CCC cannot complete the teach-out independently, identify potential receiving institutions offering reasonably similar programs, modalities, scheduling, and any required programmatic accreditation or licensure alignment.
- Provide academic advising, transfer assistance, financial aid advising, and other student support appropriate to each affected population.
- Cease or limit new admissions to affected programs or locations when students cannot reasonably be assured of completion before closure.
- Review barriers to transcript and records access and address them consistent with applicable law, regulation, and College policy.
6. Student Records Continuity and Final Custody
The College will preserve required student records and establish their final disposition before discontinuing the offices, systems, or services necessary to maintain or access them. Records continuity planning will include, at minimum:
- Identify records requiring continued, long-term, or permanent retention, including academic transcripts and related academic history, enrollment and credential records, financial aid records, billing or student account records, and other records required by law, regulation, or retention schedule.
- Identify the current record owner or custodian and determine the final custodian, repository, state entity, successor institution, or approved service provider, as applicable.
- Create secure, validated exports, backups, or archival copies in formats that can be retrieved and interpreted after operational systems are discontinued.
- Preserve documentation necessary to interpret academic records, including catalogs, curriculum requirements, grading systems, course information, and other applicable academic documentation.
- Verify the process for requesting official transcripts and other student records after closure and communicate that process to current and former students.
- Ensure that records are not destroyed solely because of closure and that all applicable retention, confidentiality, security, legal-hold, and disposition requirements remain in effect.
7. Information Technology and Data Preservation
Information Technology will coordinate with each responsible records custodian to maintain systems, authentication, backups, security controls, and access necessary for records continuity. No student information system, document repository, financial system, or other essential records platform will be discontinued until the responsible office and Information Technology have verified that required records have been preserved, transferred, or otherwise made continuously accessible.
8. Financial, Regulatory, and Student Account Responsibilities
Finance and Operations, Financial Aid, and other responsible offices will coordinate student account resolution, applicable refunds, financial aid reconciliation, regulatory closeout, grant or contractual obligations, and required information for students. The College will notify and coordinate with HLC, the Kansas Board of Regents, the U.S. Department of Education / Federal Student Aid, programmatic accreditors, licensing agencies, and other entities as applicable to the circumstances.
9. Communications
The College will establish a coordinated communications plan for affected students, employees, governing authorities, partners, and the public. Student communications will provide clear and current information regarding expected timelines, program completion or transfer options, advising and financial aid resources, transcript and records access, and points of contact. Communications will be updated as material information changes.
10. Documentation, Completion, and Review
The Closure Coordination Team will maintain documentation of key decisions, notifications, student communications, teach-out or transfer arrangements, records disposition, system preservation or transfer, and completion of regulatory responsibilities. The protocol will be reviewed at least annually and revised when changes in College systems, responsible offices, external requirements, or institutional circumstances warrant.
Related Institutional Policies and External Requirements
- CCC Records Retention and Records Management Policy
- CCC Family Educational Rights and Privacy Act (FERPA) Policy
- CCC Gramm-Leach-Bliley Act (GLBA) Information Security Program
- CCC Emergency Operations Plan
- CCC Merger or Consolidation Policy
- HLC Assumed Practice D.7 - institutional planning for student needs, preservation of student records, and orderly closure protocols
- HLC Approval of Institutional Teach-Out Arrangements (FDCR.B.10.010) and current HLC provisional plan / teach-out procedures