By Catherine Brown, Senior Director, Policy and Advocacy
Reading time: Three minutes
On August 15, the US Department of Education (ED) announced its intention to
add a new IPEDS “Admissions and Consumer Transparency Supplement” (ACTS) to IPEDs, the Integrated Postsecondary Education Data System that collects data from more than 1,000 schools annually. This supplemental survey would collect admissions and enrollment data at selective colleges and universities by race and sex categories. This proposal follows on the heels of the US Department of Justice’s memo describing prohibitions on diversity, equity, and inclusion initiatives.
Under the new ACTS survey, colleges would be required to report: admission test score quintiles, GPA quintiles,
ranges of family income, Pell Grant-eligibility, and parental education, for institutions’ applied, admitted, and enrolled cohorts and the count of students admitted via early action, early decision, or regular admissions.
Institutions would need to submit this data not just for the current year, but for the previous five years as well, a requirement that schools provide over 100,000 data fields to in the next six months.
Greater transparency in college admissions is a worthy goal; the system is rife with inequities. But gathering more data is worthless if it can't be trusted. And ACTS, as currently proposed, is setting institutions up to submit flawed data that could
have serious consequences.
President Trump's executive order directed the US Secretary of Education to "take remedial action" against institutions that submit
incomplete or inaccurate data. The order doesn't define remedial action, but given the administration's recent moves, it's not hard to imagine flawed ACTS data becoming ammunition for investigations or enforcement actions. It’s also not hard to imagine accurately submitted data being weaponized against schools with gaps in admissions by race and ethnicity that the Trump Administration deems suspect.
IPEDS has a decades-long reputation as a trusted data source because changes go through a rigorous vetting process. The Paperwork Reduction Act requires federal agencies to follow specific steps before adding new data collections that are designed to minimize burden and maximize data quality. Agencies are required to provide multiple opportunities for
public comment, to read and respond to all comments, and to offer a comment period longer than 60 days when the full survey isn't provided alongside the announcement. As of this writing, the proposed ACTS instrument has not been released.
For IPEDS data to be reliable, institutions need clear definitions of the data fields they are required to submit and more. Right now, ACTS raises more questions than it answers, starting with: which colleges are required to submit this supplement, and
what race and income definitions should they use? Without clear answers, institutions will report data differently, making comparisons meaningless.
Asking for five years of retrospective data creates its own challenges. Many institutions don't have this data because they weren't collecting it. Others collected it in formats that don't match the new requirements. The past five years also include the
COVID-19 pandemic, when many schools went test-optional, and the 2024-25 Free Application for Federal Student Aid (FAFSA) debacle. Using this period for benchmarking is comparing apples to oranges to something that might not even be fruit.
Also unknown is who will process and analyze the data collected through the survey. 90% of staff members at the Institute for Education Sciences were terminated in March and only three people are currently employed at the National Center for Education
Statistics, which houses IPEDS.
If ACTS launches in December, as currently proposed, we'll get incomplete, inconsistent, and unreliable data. Institutions will face impossible burdens with unclear guidance. Furthermore, students could ultimately pay the price if flawed data triggers
investigations or aid cuts.
We will be making our collective voice heard on this issue by joining an effort led by the Institute for Higher Education Policy, and we encourage you to submit an individual comment if you have the capacity. The deadline to submit comments on this proposal is October 14, 2025,
and comments can be submitted here.
Questions? Don’t hesitate to reach out. As always, we will keep you informed as this issue progresses.
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