A new admissions data collection system proposed by the U.S. Education Department (ED) would result in a significant increase in reporting to the federal government and, for community colleges, data collection on students altogether.
In August, President Donald Trump issued a presidential memorandum on transparency and reporting of college admissions data for Title IV-participating institutions. It directed ED to make technological upgrades to the Integrated Postsecondary Education Data System (IPEDS) to: make IPEDS data more usable for students and families; institute a new audit system for data reported to IPEDS; and, most significantly, to require institutions to submit more detailed information on admissions to (per the memorandum) ensure that institutions are not using race-based admissions practices.
A wave of new info
Shortly afterward, ED isued a formal information collection request (ICR) on its vision for the new admissions data collection system, to be called the “Admissions and Consumer Transparency Supplement” (ACTS) survey. The ACTS will require all colleges and universities to report applied, admitted and enrolled cohorts by race-sex pair, further disaggregated by test scores, GPA, family income, Pell Grant eligibility and parental education. It will also require colleges to report the count and average amount of students receiving institutional grant aid, merit-based grant aid, need-based grant aid, and local, state or federal aid by race-sex pair, disaggregated by test scores, GPA, family income, and type of admission (early action, early decision or regular admissions.
The ACTS will require end-of-year reporting on average cumulative GPA, cost of attendance, graduation rates and graduates’ final GPA, again by race-sex pair and the same disaggregates. Finally, colleges will be expected to report data from the past five years to establish a baseline of admissions and aid practices.
This represents a significant increase in both reporting to the federal government and, for community colleges, data collection on students. It is not yet clear how institutions will be expected to gain access to and report all the data mentioned in the ICR and what efforts ED will take to protect personally identifiable information for small, disaggregated cohorts.
The ICR states that open-access institutions, such as community colleges, “have minimal or no risk for civil rights noncompliance in admissions,” opening the door for community colleges to be exempt from the admissions components of the ACTS reporting. However, the ICR does request comments on whether open-enrollment institutions should still be required to report financial aid information to prove that they are not illegally considering race in awarding aid.
A call to action
The American Association of Community Colleges (AACC) will submit comments on behalf of the sector, urging ED to exempt community colleges from both the admissions and financial aid components of the proposed ACTS survey. But, given the level of burden associated with the proposed reporting requirements, AACC is also urging member institutions to respond formally to the ICR as well. In formal comments, community colleges should emphasize:
- The proposed new IPEDS survey would be extraordinarily burdensome and costly for institutions, and a tremendous waste of resources. Hundreds of hours would go toward producing data that would shed no meaningful light on institutional behavior, and, in fact, would largely be irrelevant to it.
- Community colleges are aware of the specific legal requirements that apply to the award of scholarships and financial aid. These requirements are straightforward and have no direct or even indirect relationship to admissions policies.
- Community colleges are and always have been open-enrollment institutions. They do not engineer their classes to meet specific demographic goals.
ED is also seeking information on the anticipated amount of time it would take to provide the required data. It would be helpful also to provide the department with some estimate of the costs of producing the data.
Comments are due to ED by October 14. You should submit comments electronically through the Federal eRulemaking Portal by selecting Docket ID number ED-2025-SCC-0382. If the site is not available to the public for any reason, the department will temporarily accept comments at ICDocketMgr@ed.gov.
