By David Cohen, Joanna Colosimo, and Mike Aamodt
BLOG OVERVIEW:
The Department of Education is proposing major changes to the Integrated Postsecondary Education Data System to include new data on undergraduate and graduate admissions. The move, meant to increase transparency and prevent discrimination in the admissions process, could result in a huge increase in reporting requirements for higher education institutions.
On August 7, 2025, President Trump sent a memo to the Secretary of Education directing her to overhaul the Integrated Postsecondary Education Data System (IPEDS) data collection portal, not only to streamline the data collection process but also expand the scope of data collected starting with the 2025-2026 academic year. As part of this memo, the Secretary of Education, in coordination with the National Center for Education Statistics (NCES), was directed to collect information related to race-based admissions in higher education. Approximately a week later, on August 15, 2025, a Notice under the Paperwork Reduction Act (PRA) was issued in the Federal Register outlining a revision to the information collection request outlining the details related to this presidential memo.
In the PRA request, the administration justified the additional data requests as follows:
In 2023, the Supreme Court ruled in Students for Fair Admissions v. President and Fellows of Harvard College (SFFA v. Harvard) that discrimination on the basis of race in admissions violates the Equal Protection Clause of the Fourteenth Amendment and Title VI of the Civil Rights Act of 1964. Despite the ruling in SFFA, the continued widespread emphasis on ‘‘diversity, equity, and inclusion’’ (DEI) in higher education causes concerns that unlawful practices may persist because DEI has been used as a pretext to advance overt and insidious racial discrimination. The federal government does not currently collect racial data on admissions and scholarships and has limited tools to ensure widescale compliance with Title VI. Greater transparency through the collection of this type of information will help to expose unlawful practices, enable the Department to better enforce Title VI, and create good incentives for voluntary compliance.
Public comments on the proposed changes are due on October 14, 2025. Once the comment period has ended, the Office of Management and Budget (OMB) will review the proposed changes along with the submitted comments and either revise or approve the new data requirements. These changes could be approved as soon as the end of the year, which could coincide with the winter reporting cycle that opens on December 3, 2025.
Proposed Changes to IPEDS Data Collection
All postsecondary institutions that receive Title IV Higher Education Act (HEA) funds and sign a Program Participation Agreement with the Department of Education (DOE) are required to complete and submit IPEDS survey data in a timely and accurate manner. In 2024, approximately 5,889 institutions submitted the survey reports.
The proposed new data components, collectively called the Admissions and Consumer Transparency Supplement (ACTS), are expected to capture data from the 2025-26 academic year and the five prior academic years to “establish a baseline of admissions practices before the Supreme Court decision in SFFA v. Harvard.” Information will be collected for both undergraduate and graduate admissions.
If ACTS is approved, academic institutions will be required to submit disaggregated applicant data regarding a variety of admissions factors for each race-sex pairing (e.g., White-men; Black-women). These factors include the numbers of applicants, students admitted, and students enrolled; average GPA and standardized test scores; first-generation college student status; and any other factors used to make admission decisions.
For each race-sex pairing, academic institutions will also be required to provide graduation rates, average grade point average (GPA) at that institution, percent receiving financial aid (broken down by four broad categories of aid), percent offered financial aid, and “other relevant measures.”
The data on graduate students will be disaggregated by broad fields of study defined by specific Classification of Instructional Programs (CIP) codes. These broad fields include Arts & Humanities, Education, Public Service, Agriculture, Business, Social Sciences, STEM, Health, Medical Residencies, and Law.
This data will be further disaggregated by admission test score quintiles, GPA quintiles, family income, and enrollment type.
Proposed Burden Estimates
The Federal Register notice states that the Department of Education estimates approximately 65,868 responses in the first year of data collection (2025/26 academic year plus five prior years), with a total annual burden to academic institutions of about 740,511 hours, equating to slightly more than 11 hours per response each year. (Note: It is unclear how the DOE estimated the total number of responses at 65,868. As stated above, the total number of responses in 2024 was approximately 5,889.)
For the typical university, the estimated burden for the initial data collection would be 132 hours (6 years of data for undergraduate admissions and 6 years of data for graduate admissions). It is important to note that the Federal Register did not explain how these estimates were calculated.
Considering the quantity of admissions data being requested from both undergraduate and graduate schools, the burden estimate appears to be significantly lower than what will actually be necessary to comply with this new data requirement. To date, concerns commonly noted in public comments regarding ACTS include:
To alleviate these concerns, commenters have suggested that the Department of Education:
What will the DOE do with this Data?
After the Department of Education receives the initial six years of admissions data (including applicant demographics and selection criteria), the agency will likely conduct a deep analysis of the numbers to create a baseline of admission rates by race and sex. With this information, DOE can run disparity analyses using traditional methods such as statistical tests to compare admissions rates amongst protected groups. The Department can also utilize advanced tools like logistic regression that help predict who might have been admitted based on academic factors such as grade point averages, SAT scores, or Graduate Record Examinations (GRE) scores and whether there are unexplained race/ethnicity differences after controlling for the admissions factors. The agency might also compare the factors used in years prior to and after the SFFA v. Harvard decision to determine whether universities have made changes to their admissions process to comply with the Court’s decision. DOE will most likely use this data to develop enforcement protocols to determine which institutions to investigate for illegal admission practices.
How Should Higher Ed Prepare?
As higher education institutions prepare for the evolving demands of reporting and accountability with the potential of new IPEDS admissions data, it is clear that meaningful action must begin now. The possibility of 2026 reporting that requires retrospective analysis stretching back five years underscores this urgency. Universities should closely examine the scope and nature of proposed data requests, considering not only how to collect information, but also how to thoughtfully aggregate and disaggregate data to meet NCES requirements.
A strategic approach includes engaging legal counsel to perform a privileged, comprehensive review of admissions data over the past five years, with a particular focus on selection rates and admissions criteria. This inclusion of legal counsel ensures the institution is prepared to navigate complex regulatory landscapes while safeguarding the privacy of its analyses and internal discussions.
Finally, institutions should consider conducting rigorous logistic regression analyses that control for relevant admissions criteria and examine selection rates by race/ethnicity. Such analyses will provide not only clarity and insight into admissions processes but also help institutions build actionable strategies for equitable and data-driven decision-making.
By taking these steps, universities position themselves at the forefront of transparency, responsibility, and readiness for future reporting expectations.
DCI will continue to monitor this developing situation and will provide updates as they occur.