PostsecData Shares Major Concerns With ED’s Admissions Data Collection Implementation

Washington, DC (December 15, 2025) – Today, the Institute for Higher Education Policy (IHEP) led a coalition of 34 members and partners of the Postsecondary Data Collaborative (PostsecData) in sharing significant concerns with the U.S. Department of Education’s approach to implementing the new Admissions and Consumer Transparency Supplement (ACTS) to the Integrated Postsecondary Education Data System (IPEDS).

The coalition cautioned that the implementation is rushed, enormously complex, and poised to generate data that are easily misused and hard to interpret.

Read the full letter and list of signatories.

___

December 15, 2025  

 

Ross Santy 

U.S. Department of Education 

Office of Planning, Evaluation, and Policy Development 

400 Maryland Ave., SW 

5th Floor 

Washington, DC 20202 

 

CC: Matt Soldner, Acting Director, Institute of Education Sciences and Acting Commissioner, National Center for Education Statistics 

Re: Docket ID number ED-2025-SCC-0382 

To Whom It May Concern:  

This letter is submitted on behalf of the 34 undersigned members and partners of the Postsecondary Data Collaborative (PostsecData) in response to the Department of Education’s (ED) proposed addition of the Admissions and Consumer Transparency Supplement (ACTS) survey component to the Integrated Postsecondary Education Data System (IPEDS). PostsecData is a nonpartisan coalition of organizations committed to the use of high-quality postsecondary data to improve student success.  

In October 2025, members of PostsecData offered five recommendations to ensure ACTS data meet the same high data quality standards as other IPEDS survey components. The first of those recommendations was to establish clear data definitions and reporting guidance in collaboration with the field. We thank ED for taking steps to partially address this recommendation by providing additional details about the ACTS collection in the documents released on November 13, 2025. The IPEDS Glossary, ACTS Data Codebook, and ACTS FAQs, among other materials, offer important technical information about the collection. We also appreciate the development of the Python script that produces the aggregated calculations for institutions and is intended to reduce institutional burden. 

These are important steps in the right direction for supporting institutions with their reporting and reducing the burden associated with the collection. However, we remain concerned that ACTS data will not adhere to IPEDS’ high data quality standards due to outstanding questions about data definitions and reporting guidance, the accelerated rollout and lack of field engagement to answer technical questions, and the limited technical assistance available to those responsible for submitting these data. 

Outstanding questions about data definitions and reporting guidance: While we appreciate the additional information ED provided, there are outstanding questions about how to define or report several key data elements. These questions include the following: 

• How should institutions report available data from prior years on students’ “sex” without using the previously available “unknown” and “another” categories?  

• How should institutions unweight high school GPA if a student or transcript only reports a weighted GPA? 

• For students who submit multiple test scores, which test scores will institutions be required to report?  

If ACTS data are to be trustworthy and useful to the Administration and IPEDS stakeholders, these and other technical questions should be answered—informed by field input—before requiring institutions to submit data. 

Accelerated rollout and lack of field engagement to answer technical questions: IPEDS is a trusted source of high-quality data largely because of its deliberate process for adding or revising data elements. Updates to IPEDS survey components typically go through a careful vetting, planning, and implementation process that includes soliciting community input to uncover and answer technical definition and reporting questions. Institutions also are given advance notice of IPEDS reporting changes so they have time to prepare and adjust their data systems as needed. By prioritizing field engagement, this rigorous process helps ensure data collections are aligned with practical, on-the-ground realities and each institution has the guidance needed to report data in a consistent manner. ED has a long history of meaningfully engaging with the field to develop answers to challenging, technical questions, including during the first Trump Administration. In the past, ED used the National Postsecondary Education Cooperative and Technical Review Panels to strategically leverage the expertise of higher education practitioners, leaders, researchers, and advocates to ensure institutions have the necessary information to report accurate and reliable data to IPEDS. Forgoing the typical vetting, planning, and implementation process, including opportunities to meaningfully engage with field experts to answer questions like those highlighted above, jeopardizes the quality and utility of the ACTS collection.  

Limited technical assistance resources: Training and support for IPEDS data reporters are essential to ensure all data are reported consistently. Unfortunately, the IPEDS training contract that served this purpose was canceled earlier this year. ED is pursuing an aggressive schedule for the new ACTS collection. This means institutions and state agencies are working on an accelerated timeline to submit an unprecedented amount of data using an entirely new process. ED’s own estimates of the average time reporting burden for this year’s ACTS data collection (200 hours) is more than double the estimated burden for all other IPEDS survey components combined (78.5 hours). Given this substantial effort and exceedingly fast timeline, technical assistance support is more crucial than ever. We strongly recommend ED reinstate key contracts to ensure sufficient technical assistance and reporting of consistent data.  

These concerns about data quality and consistency cast doubt on the reliability of conclusions drawn from these data. Without clear data definitions and reporting guidance informed by field experts and appropriate technical assistance, apples-to-apples comparisons between institutions are compromised, as is the ability of policymakers, institution leaders, and researchers to feel confident relying on ACTS data to make informed decisions. For example, requiring institutions to assign a gender to students who do not (or did not historically) indicate one without clear guidance on how to do so compromises one of the collection’s primary reporting units—the race-sex pair. Likewise, using high school GPA to assess academic preparedness is compromised without clarity on how institutions should calculate and report an unweighted GPA when a student’s transcript only provides a weighted GPA. Finally, institutions practicing good data hygiene are unlikely to retain data for six years on applicants who were not admitted to the institution. This means those institutions only retain data on applicants who were admitted, limiting the ability to compare historical pools of applicants and admits.  

Moreover, ACTS data cannot be used for the stated purpose of assessing “whether institutions of higher education are using race-based preferencing in their admissions processes.” This would be an inaccurate and misleading use of the data because institutions make admissions decisions based on many factors, including those not represented in existing IPEDS data or the proposed ACTS collection. For example, in 2022, nearly 1 in 3 selective four-year institutions considered legacy status in admission decisions. These policies grant admissions preferences based on applicants’ relationship to alumni or donors. The proposed ACTS collection does not include disaggregated information on students admitted through these policies, which research shows typically benefit White and wealthy students. Taking steps to improve transparency into admissions processes through the collection of high-quality and meaningful data can deepen public understanding. But, given the complexities of college admissions, the proposed ACTS collection cannot reveal whether race was a determining factor in admissions decisions.  

In sum, we appreciate the steps ED has taken to address questions about data definitions and reporting guidance. However, we continue to have serious concerns about the quality, consistency, and usability of ACTS data, including that these data cannot be used for the stated purpose of determining whether institutions are using race-based preferencing in their admissions processes.  

If you have any questions about this comment, please contact Erin Dunlop Velez, Vice President of Research at the Institute for Higher Education Policy, at evelez@ihep.org.   

Sincerely, 

 

Organizations:  

AACTE: American Association of Colleges for Teacher Education 

American Association of Collegiate Registrars and Admissions Officers 

American Association of University Women (AAUW) 

American Educational Research Association 

American Statistical Association 

Applied Learning Insights 

Association for Institutional Research 

California Competes: Higher Education for a Strong Economy 

Community College Research Center, Teachers College, Columbia University 

Complete College America 

Council for Opportunity in Education 

Data Quality Campaign 

EdTrust  

Education Reform Now Advocacy 

Excelencia in Education 

Georgetown University Center on Education and the Workforce 

InnovateEDU 

Institute for Higher Education Policy 

NASPA – Student Affairs Administrators in Higher Education  

National Association for College Admission Counseling 

National Association of Student Financial Aid Administrators 

National College Attainment Network (NCAN) 

NCHEMS 

New America Higher Education Program 

New America’s Open Technology Institute 

Prismatic Research & Strategy 

Public Insight 

The Institute for College Access & Success (TICAS) 

The Study Group 

Today’s Students Coalition 

uAspire 

Yes We Must Coalition 

 

Individuals: 

James Murphy, Senior Fellow, Class Action 

Thomas Weko, Former National Center for Education Statistics Associate Commissioner for
Postsecondary Education