Response: The Coordinating Board agrees that the Texas Transfer Framework provides greater flexibility for institutions to ensure that transfer students credits are applied toward the major, while still fulfilling the same degree requirements as native, non-transfer students.

The Coordinating Board recognizes the statutory requirement in Texas Education Code §61.823 for institutions to apply the block of courses to the major, if the student is deemed Texas Transfer Framework Field of Study complete by the receiving university. To implement this section, the credit hours that comprise a Texas Transfer Framework Field of Study Curriculum will transfer and satisfy major-specific lower-division requirements of corresponding baccalaureate degrees at the receiving institution. The transfer student may take additional lower-division courses to satisfy requirements, including courses in the Core Curriculum, that are not major-specific requirements.

The proposed framework:

(1) Each Texas Transfer Framework Field of Study Curriculum will consist of Selected Major Specific Core Courses, Discipline Foundation Courses, and Directed Electives. Staff reviewed majors and found that the proposed framework would work for a majority of high-transfer majors, and

(2) General Academic Institutions have the authority to determine if a transferring student is Texas Transfer Framework Field of Study-complete. This means that if a transferring student did not complete the Directed Electives for a specific major, as required by Coordinating Board rule, Chapter 4. 32(b) (D) and (E), then the receiving institution can make the determination that the student is not Texas Transfer Framework Field of Study-complete and additional lower-division courses for that major can be required by the receiving institution.

Comment: The University of North Texas (UNT) raised concern related to a limit on the Discipline Foundation Courses and the Directed Electives and requested that greater flexibility be provided in the total number of semester credit hours included in a Field of Study Curriculum. UNT provided an example of Music as a discipline that would need to have additional lower-division courses taken in the major, prior to transferring.

Similar comments were received from four additional institutional representatives and the Texas Association of Schools of Music.

Del Mar College in a memo which was then forwarded to the Coordinating Board, expressed concern that as constructed the proposed Texas Transfer Framework could not accommodate the required Music curriculum and would not benefit students pursing Music degrees.

Odessa College, raised additional concerns about the Music Field of Study Curriculum and future Transfer Framework/Agreement. The memo was then forwarded to the Coordinating Board.

The Texas Association of Schools of Music commented noting his concern that the Music Field of Study would be negatively impacted by the new Texas Transfer Framework.

Texas A&M University-Corpus Christi also commented noting her concern that the Music Field of Study, along with other arts programs, would be negatively impacted by the new Texas Transfer Framework.

Amarillo College, commented noting her concerns related to the proposed Texas Transfer Framework and the Music Field of Study. They provided a detailed overview of the curriculum music students complete and stated that the existing Field of Study Curriculum currently in effect was working well for many institutions.

Response: The Coordinating Board agrees and recognizes that all disciplines may not fit into the proposed Texas Transfer Framework. Specifically, the language in proposed §4.32(b)(3)(B) limits the Discipline Foundation Courses and the Directed Electives to not exceed 18 semester credit hours. Music is an example of a discipline that may not align with the proposed Texas Transfer Framework. Importantly, the existing Fields of Study remain in effect, including the Music Field of Study, which became effective in September 2018.

A key aspect of the proposed rules is the establishment of the Texas Transfer Advisory Committee (TTAC). The TTAC would work with subcommittees comprised of faculty experts in the discipline, much like the important work that was done on the Music Field of Study Advisory Committee, to review the existing Music Field of Study and recommend if appropriate, how it could be revised to fit into the new Texas Transfer Framework. The proposed rules provide an ample transition time for existing Field of Study Curricula to be remain in effect while TTAC decides which Field of Study to consider for inclusion under the new Texas Transfer Framework. The proposed effective dates are as follows:

(g) Effective Dates.

(1) Unless repealed or replaced, Field of Study Curricula in effect as of March 1, 2021 will remain in effect until August 31, 2025, upon which date those Field of Study Curricula expire by operation of law. For Field of Study Curricula that are repealed, replaced, or expire by operation of law, the following transition or "teach out" provisions apply:

(A) A student who has earned credit on or before August 31, 2022, in one or more courses included in a Field of Study Curriculum that exists on March 1, 2021, is entitled to complete that Field of Study Curriculum on or before August 31, 2025.

(B) A student who has not, on or before August 31, 2022, earned any course credit toward a Field of Study Curriculum in effect on March 1, 2021, is not entitled to transfer credit for that Field of Study Curriculum.

(2) After an institution's Spring 2026 enrollment deadline, a receiving institution is not required to transfer a complete Field of Study Curricula that expired prior to that date. A receiving institution may, at its discretion, choose to accept a complete or partial Field of Study Curricula that has expired.

Comment: The Texas Association of Community Colleges and the Texas Association of Chief Academic Officers submitted a joint letter in support of the Coordinating Board's efforts. Specifically, the groups are supportive of the following:

The Texas Transfer Advisory Committee with equal representation of public junior colleges and general academic teaching institutions will oversee the development of Field of Study Curricula through Discipline-Specific Subcommittees. (Texas Administrative Code, Title 19, Chapter 1, Subchapter V, §§1.237-1.243)

To fulfill the requirement of Education Code §61.823, Field of Study Curriculum will include the 42-semester credit hour Texas Core Curriculum (Texas Education Code §61.822), 12 semester credit hours of Discipline Foundation Courses (Texas Administrative Code, Title 19, Chapter 4, Subchapter B, §4.23(4)), and 6 semester credit hours of Directed Electives (Texas Administrative Code, Title 19, Chapter 4, Subchapter B, §4.23(5)). (Texas Administrative Code, Title 19, Chapter 4, Subchapter B, §4.23(7))

If a student successfully completes an approved Field of Study Curriculum, a general academic teaching institution must substitute that block of courses for the receiving institution's lower-division requirements for the degree program for the corresponding Field of Study Curriculum into which the student transfers. Upon enrollment, the general academic teaching institution must grant the student full academic credit toward the degree program for the block of courses transferred. (Texas Administrative Code, Title 19, Chapter 4, Subchapter B, §4.32(c))

General Academic Teaching Institutions that wish to create an alternative list of Discipline Foundation Courses under the exceptional circumstances specified in the rule must seek approval from the Commissioner of Higher Education (Texas Administrative Code, Title 19, Chapter 4, Subchapter B, §4.32(b)(2)(E))

Courses listed in the Lower Division Academic Course Guide Manual are fully transferable among public institutions and shall be substituted for the equivalent course at the receiving institution. (Texas Administrative Code, Title 19, Chapter 4, Subchapter B §4.24(a))

A process to dispute a receiving institution's denial of credit transfer will be available to students and to sending institutions. (Texas Administrative Code, Title 19, Chapter 4, Subchapter B §4.27)

The associations strongly urged the Coordinating Board to fully consider the following comments:

It is our understanding that the current Field of Study Curricula will be used as a foundation for creating Discipline Foundation Courses, and the term Field of Study will now encompass all elements of a full 60-semester credit hour associate degree and the lower division component of baccalaureate degrees at general academic teaching institutions.

The associations respectfully request the THECB make explicit in its explanation of the new rules that the full 60 semester credit hours that comprise a Field of Study Curriculum will transfer and satisfy major-specific lower division requirements of corresponding baccalaureate degrees.

Proposed Texas Administrative Code Title 19, Chapter 4, Subchapter B §4.32(c) indicates a receiving general academic teaching institution shall determine whether a transfer student is Field of Study Curriculum complete upon the transfer student's enrollment. As part of the graduation audit process, public junior colleges will indicate completion of Field of Study Curricula on student transcripts.

Response: The Coordinating Board appreciates the letter of support for the proposed rules. The Coordinating Board concurs with the clarification that the current Field of Study Curricula will be used as the foundation for creating the Discipline Foundation Courses. The Texas Transfer Framework Field of Study will encompass the following components:

Selected discipline-specific Texas Core Curriculum courses, of an unspecified number of hours,

Up to 12 SCH of Discipline Foundation Courses, and

At least 6 SCH of Directed Electives (see Rule 4.32).

The Coordinating Board agrees that the credit hours that comprise a Texas Transfer Framework Field of Study Curriculum will transfer and satisfy major-specific lower-division requirements of corresponding baccalaureate degrees. The Coordinating Board agrees that it is the responsibility of the receiving general academic institution to determine whether a transfer student is Field of Study Curriculum complete upon the transfer student's enrollment and the public junior colleges may indicate completion of Field of Study Curricula on student transcripts.

Comment: The University of Texas at Dallas, submitted a letter expressing her concerns related to the ability of a student to take lower-division courses when they transfer to the university. They stated, "The interpretation that all lower-division courses, rather than common lower-division courses, must be substituted has the unintended consequence of curricular misalignment that ultimately disadvantages transfer students who are prohibited by the state from following the same curricular path as native students, resulting in transfer students not having sufficient lower-division prerequisites and content knowledge for their subsequent courses."

They raised concern regarding the ability of transfer students to take lower-division courses if they are Texas Transfer Framework Field of Study complete. They state, "Specifically, the proposed rules appear to prohibit a four-year university from requiring additional lower-division courses beyond the Field of Study Curricula."

They also expressed her concern that transfer students would be required to take only upper-division courses upon transfer to the university. They pointed out that many university upper-division courses have prerequisites and that transfer students would be disadvantaged if they could not take the prerequisite courses. The credit hours that comprise a Texas Transfer Framework Field of Study Curriculum will transfer and satisfy major-specific lower-division requirements of corresponding baccalaureate degrees. The transfer student may take additional lower-division courses to satisfy requirements, including the Core Curriculum, that are not major specific requirements.

They also raised concern regarding faculty buy-in and participation in the new framework. They also stated that the goals of the Transfer Framework are to assist students to seamlessly transfer from a two-year to a four-year institution in a cost-effective and efficient manner. They stated that this could be achieved with the ability of a four-year institution requiring additional lower-division courses and providing transfer students the same advantages in upper-division coursework as their native peers.

Response: The Coordinating Board appreciates the comments and recognizes the need for clarity to ensure faculty-buy in and to appropriately structure the Texas Transfer Framework Field of Study to affirm that transfer and native students are afforded the same opportunities. The proposed rules provide a new structure of governance that will allow discipline specific subcommittees, comprised of faculty experts in that discipline, to collaboratively develop a thoughtful and meaningful approach to transfer and to identify majors and courses that fit into the proposed Texas Transfer Framework. The Texas Transfer Advisory Committee (TTAC) would provide a cohesive approach to govern the process that will provide students with a seamless path for transfer based on transfer data, enrollment patterns, and course completions. The Coordinating Board staff are confident that this new framework and governance structure will be able to address the concerns raised.

The proposed Texas Transfer Framework provides greater flexibility for institutions to ensure that transfer students credits are applied toward the major, while still fulfilling the same degree requirements as native, non-transfer students. The credit hours that comprise a Texas Transfer Framework Field of Study Curriculum will transfer and satisfy major-specific lower-division requirements of corresponding baccalaureate degrees. The transfer student may take additional lower-division courses to satisfy requirements, including courses in the Core Curriculum, that are not major specific requirements.

The Coordinating Board recognizes the statutory requirement for institutions to apply the block of courses to the major, if the transfer student is deemed Texas Transfer Framework Field of Study complete by the receiving university.

Comment: Texas A&M University submitted a letter requesting clarification of the bolded language in two proposed rules in Chapter 4:

4.23(7) Field of Study Curriculum--a set of courses that will satisfy the lower-division requirements for a baccalaureate degree in a specific academic area at a general academic teaching institution. The Field of Study Curriculum has three components: (a) selected discipline-relevant Texas Core Curriculum courses, (b) the Discipline Foundation Courses, and (c) the Directed Electives.

4.32 (c) A receiving general academic teaching institution shall determine whether a transfer student is Field of Study Curriculum complete upon the transfer student's enrollment. If a student successfully completes an approved Field of Study Curriculum, a general academic teaching institution must substitute that block of courses for the receiving institution's lower-division requirements for the degree program for the corresponding Field of Study Curriculum into which the student transfers. Upon enrollment, the general academic teaching institution must grant the student full academic credit toward the degree program for the block of courses transferred.

They stated, the language could be interpreted to mean that transfer students would be prohibited from taking additional lower-division coursework to satisfy baccalaureate degree programs. They further stated that this could result in a loss of curricular flexibility noting that the majority of Texas A&M University degree programs require students to complete additional lower-division courses.

Response: The Coordinating Board appreciates the comments and recognizes the need for clarity to ensure faculty-buy in and to appropriately structure the Texas Transfer Framework Field of Study to affirm that transfer and native students are afforded the same opportunities. The proposed rules provide a new structure of governance that will allow discipline specific subcommittees, comprised of faculty experts in that discipline, to collaboratively develop a thoughtful and meaningful approach to transfer and to identify majors and courses that fit into the proposed Texas Transfer Framework. The Texas Transfer Advisory Committee (TTAC) would provide a cohesive approach to govern the process that will provide students with a seamless path for transfer based on transfer data, enrollment patterns, and course completions. The Coordinating Board staff are confident that this new framework and governance structure will be able to address the concerns raised.

The proposed Texas Transfer Framework provides greater flexibility for institutions to ensure that transfer students credits are applied toward the major, while still fulfilling the same degree requirements as native, non-transfer students. The credit hours that comprise a Texas Transfer Framework Field of Study Curriculum will transfer and satisfy major-specific lower-division requirements of corresponding baccalaureate degrees. The transfer student may take additional lower-division courses to satisfy requirements, including courses in the Core Curriculum, that are not major specific requirements.

The Coordinating Board recognizes the statutory requirement for institutions to apply the block of courses to the major, if the transfer student is deemed Texas Transfer Framework Field of Study complete by the receiving university.

The new rules are adopted under Texas Education Code §61.027, which provides the Coordinating Board with general rulemaking authority; Texas Education Code §61.002, which establishes the Coordinating Board as the agency charged to provide leadership and coordination for the Texas higher education system; Texas Education Code §61.051, which provides the Coordinating Board with authority to coordinate institutions of public higher education in promoting quality education; and Texas Education Code §§61.821, 61.8221, 61.823-61.828, 61.830, 61.059(l), 61.059(p), and 61.0593, which provide for the development and implementation of Field of Study Curricula, authorize the Board to form advisory committees to assist the Board, and authorize the Board to adopt rules as necessary. Texas Education Code §61.028(a) authorizes the Board to delegate duties to the Commissioner of Higher Education.