The U.S. Education Department’s new IPEDS admissions survey will exclude most two-year colleges, but it’s unclear if community colleges that offer bachelor’s degrees would remain on the hook for new reporting requirements.
The Education Department (ED) last week released revised changes to the 2025-26 Integrated Postsecondary Education Data System (IPEDS) surveys, including the new Admissions and Consumer Transparency Supplement (ACTS). There is good news and not-so-good news, and the latter requires action from the community college field.
The ACTS survey was proposed in August to align with a presidential memorandum on transparency in higher education. It will require eligible institutions to report a massive amount of student-level data on admissions and financial aid. These data will include applied, admitted and enrolled cohorts by race-sex pair, further disaggregated by test scores, GPA, family income, Pell Grant eligibility, parental education and other variables.
ACTS 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.
In addition, colleges will have to report data from the past five years to establish a baseline of admissions and aid practices before Students for Fair Admissions v. Harvard banned the consideration of race in college admissions. Subsequent actions from the Trump Administration applied this precedent to higher education activities beyond admissions.
The initial information collection request (ICR) on the ACTS survey stated that open-enrollment institutions, including community colleges, “have minimal or no risk for civil rights noncompliance in admissions,” opening the door for exemption from the admissions reporting. However, the ICR asked whether open-access institutions should still be required to report financial aid information under ACTS to prove that they are not illegally considering race in the awarding of institutional aid.
Burdensome and irrelevant
Public comments from the American Association of Community Colleges (AACC) emphasized that community colleges are open-enrollment institutions that do not engineer their classes to meet specific demographic goals. AACC also said that community colleges understand the legal requirements around the awarding of aid, and that the ACTS requirements would impose a high burden cost on its institutions to produce data that is fundamentally irrelevant to their operations.
Reflecting AACC’s comments and those from many community colleges across the country, the ACTS survey currently included in the proposed 2025-26 IPEDS exempts two-year institutions from both the new admissions and financial aid reporting. Four-year institutions are also exempt if they are 100% open-enrollment and do not award non-need-based aid.
Some murkiness
It is a tremendous relief that most community colleges will be exempt from this new reporting scheme. However, questions remain whether the nearly 200 community colleges that award bachelor’s degrees will also be exempt.
The proposed 2025-26 IPEDS Glossary defines a two-year institution – and therefore exempted from the ACTS requirements – as a “postsecondary institution that offers programs of at least 2 but less than 4 years duration.” A four-year institution – subjected to the ACTS requirements – is a “postsecondary institution that offers programs of at least 4 years duration or one that offers programs at or above the baccalaureate level.”
The glossary categorizes roughly 200 community colleges as schools that award baccalaureates as four-year institutions, thereby requiring them to report under the ACTS if they offer any non-need-based aid. It is difficult to imagine that ED meant to include community colleges offering a small number of bachelor’s programs in the ACTS survey. Community colleges that offer these limited programs do so to meet industry and community needs. The institutions are not discernibly different from community colleges classified as two-year institutions in either their admissions or aid awarding practices.
Member action needed
AACC will ask ED to clarify whether and how the ACTS survey will apply to two-year colleges that offer a limited number of bachelor’s degree programs. We hope that there is an opportunity to further refine institution types to capture community colleges that confer bachelor’s degrees as distinct from bona fide four-year institutions.
If it is not possible to wholly exempt what is commonly accepted as a community college, AACC will ask that community colleges subjected to the ACTS only be required to report on their baccalaureate-seeking students.
Given the extraordinary burden associated with the proposed reporting requirements, AACC urges its member colleges that award bachelor’s degrees to respond to ED. They should emphasize:
- They are still open-enrollment institutions and do not engineer their classes to meet specific demographic goals.
- Community college aid awarding practices do not change based on whether the institution offers a select number of bachelor’s degree programs to meet local industry or community needs.
- The new ACTS survey would be extraordinarily burdensome and costly for them, and a tremendous waste of resources. Hundreds of hours would go toward producing data that would shed no meaningful light on institutional behavior.
Comments are due to ED by December 15. Submit comments electronically through the Federal eRulemaking Portal by searching Docket ID number ED-2025-SCC-0382.
Contact AACC at ogr@aacc.nche.edu for more information.
