Department of Education Seeks Input on Expanding Scope of Integrated Postsecondary Education Data System

On Aug. 7, 2025, President Donald Trump issued a presidential memorandum entitled “Ensuring Transparency in Higher Education Admissions,” directing the Secretary of Education to “expand the scope of required Integrated Postsecondary Education Data System [IPEDS] reporting to provide adequate transparency into admissions.” Subsequent to this memorandum, the Department of Education issued a notice in the Federal Register entitled “Agency Information Collection Activities; Comment Request; Integrated Postsecondary Education Data System (IPEDS) 2024-25 Through 2026-27,” proposing the revision of a currently approved information collection request to add the new IPEDS “Admissions and Consumer Transparency Supplement” (ACTS) survey component. The Department proposed this component, applicable to all four-year institutions that utilize selective college admissions, based on the Department’s assertion that these institutions “have an elevated risk of noncompliance with the civil rights laws.” None of these proposed reporting requirements will apply to open-access institutions such as community colleges or trade schools.

Undergraduate Students

The Department contemplates requiring the following data by race and sex on undergraduate students:

  1. The count of the institutions’ applied, admitted and enrolled cohorts, overall and disaggregated by factors (e.g., admission test score quintiles and ranges of family income)
  2. The average high school GPA and admission test score quintiles for the institutions’ applied, admitted and enrolled cohorts
  3. The count of students admitted via early action, early decision or regular admissions

For newly enrolled undergraduate students, the Department plans to collect data by race and sex on the count and average number of students receiving:

  1. Any institutional grant aid
  2. Merit-based institutional grant aid
  3. Need-based institutional grant aid
  4. Any local, state or federal government aid, both overall and disaggregated by various factors (e.g., admission test score quintiles and ranges of family income)

The Department also anticipates collecting data by race and sex on:

  1. Students’ average cumulative GPA at the end of the academic year
  2. The average cost of attendance, further disaggregated by various factors (e.g., admission test score quintiles and ranges of family income)
  3. Graduates’ final cumulative GPA
  4. Additional data that could help the Department better understand remedial or other noncredit coursework for newly enrolled students

Graduate Students

With respect to graduate students, the Department contemplates requiring data by race and sex for many of the aforementioned data elements. Such data is to be further disaggregated by CIP codes, which correspond to specific disciplines and subjects, including:

  1. Arts and humanities
  2. Education
  3. Public service
  4. Agriculture, consumer services and trades
  5. Business
  6. Other social sciences
  7. Economics/political science
  8. STEM
  9. Health
  10. Medical residencies
  11. Other residency programs
  12. Law

The specific CIP codes implicated are listed in the notice.

Directed Questions

The Department invites comments on the proposed data collection and responses to the following questions:

  1. Applicable institutions — The Department seeks feedback on the types of institutions that should be required to complete the ACTS components, including whether there are other objective characteristics that the Department could use to identify institutions that have a low-risk or high-risk of noncompliance with Title VI.
  2. Time burden — The Department seeks feedback on the anticipated amount of time that it will take for institutions of higher education to compile and submit the anticipated data elements in ACTS.

Public comments are due on or before Oct. 14, 2025.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations. Attorney Advertising.

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