Institutions Might Face Extensive New Mandate for 2025–2026 Data: What Questions Should Boards Be Asking?

On August 7, 2025, the Trump Administration issued an executive memorandum stating in part, “Greater transparency [in admissions data] is essential to exposing unlawful practices and ultimately ridding society of shameful, dangerous racial hierarchies. … It is therefore the policy of my [a]dministration to ensure institutions of higher education receiving [f]ederal financial assistance are transparent in their admissions practices.”¹

The memorandum in part calls for “enhanced reporting requirements” and directs that, “Within 120 days of the date of this memorandum, and to be initiated this 2025–2026 school year, the [s]ecretary of [e]ducation, in coordination with [the National Center for Education Statistics] NCES, shall expand the scope of required reporting to provide adequate transparency into admissions, as determined by the [s]ecretary of [e]ducation, consistent with applicable law.”²

Governing boards need to be aware of the significant legal and financial implications of this executive action. This would mean, as stated by the secretary of education’s subsequent memorandum and the required request for public comment published in the Federal Register with a deadline of October 14, 2025, a considerable expansion of the admissions data schools are required to report to the Integrated Postsecondary Data System (IPEDS) system. It would include a mandatory submission of five years’ worth of prior disaggregated data at once, along with current-year data. The expansion would take effect this academic year.^{3 4}

The U.S. Department of Education (ED) expects, according to the Federal Register notice, to apply this expanded data collection to “all four-year institutions who utilize selective college admissions, as these institutions have an elevated risk of noncompliance with the civil rights laws.”⁵ According to the most recent IPEDS data, the count of four-year institutions (public, independent, and for-profit) that do not have an open admissions policy is 1,762. Those institutions, at least according to the language in the Federal Register notice, are likely to be required to comply.⁶ The Federal Register notice asks for public comment on whether this reporting should apply to open-enrollment institutions as well. As a reminder, IPEDS reporting is mandatory for institutions to receive federal support for financial aid programs under Title IV of the Higher Education Act of 1965.

See Chart 1, which is adapted from information provided in the Federal Register notice, for details of the disaggregated data to be reported.

Experts in the field quickly made clear their concerns about the expansion, specifically related to data integrity and quality, immediately after the Federal Register notice was published. Public comments in the Federal Register as this post is being written—submitted by institutional research (IR) officers, college presidents, and others—also point out many problems with the proposed expansion.

The technical issues cited thus far in public comments include the inability of the data to fully capture the nuances of college admission (that is, the relationship of a student’s high school GPA to the strength of their high school curriculum is impossible to discern just by looking at the isolated data point of GPA itself); insufficient time to ensure correct reprogramming of computer systems both at ED and on the institutional level; lack of available data (including on transfer students and students who applied but did not enroll); cost and burden on staff (particularly at small institutions with correspondingly small staffs); the potential to expose individual student identities by being required to submit disaggregated data on small populations; among other issues.⁷

One comment particularly germane to boards notes that, “Presidents and trustees are accountable for compliance and risk. Expanding IPEDS requirements without resources increases exposure and forces our board to divert attention from strategy and mission to compliance management.”⁸

According to ED, “Since 1867, NCES has been the federal statistical agency responsible for collecting, analyzing, and reporting data on the condition of U.S. education—from early childhood to adult education—to help improve student outcomes.”⁹ The Trump Administration’s firings of 40 percent of the workforce at ED and termination of many training contracts has “gutted” not only the larger department, but also eliminated most workers in NCES.¹⁰

Firing the majority of NCES staff and cancelling contracts has affected congressionally required projects and cancelled a federally funded subcontract to train the college and university staff required to report data to IPEDS.¹¹ Thus, just as a complex expansion of IPEDS data is proposed in an abnormally compressed time frame, the federal training for institutions to correctly report data has been cut. Given the staff reductions, it begs the question of ED’s capacity to adequately and accurately handle such an expansion.

Implications: Significant Potential New Costs and Burdens for Institutions and Systems

NCES’ current estimate of campuses’ IPEDS data-collection/submission burden varies depending on the type of institution and the experience of the person responsible for reporting the data.¹² The Office of Information and Regulatory Affairs, which is the part of the Office of Management and Budget to which federal agencies submit their burden-estimate calculations regarding grantees’ reporting requirements, advises agencies to include wage and benefit costs across four labor categories, along with capital and annualized costs (for example, in this case, maintaining data storage/retrieval systems).¹³

Generally, under the previous requirements, at a four-year institution with a new “keyholder” (the term for a responsible data reporter), NCES estimated an average workload of 193 hours. For an experienced keyholder, NCES estimated 157 hours. That includes the “time it takes to review instructions, query and search data sources, complete and review the components, and submit the data through the Data Collection System.”¹⁴

However, by ED’s own estimate in the Federal Register, the expanded data collection could add an additional 740,511 annual burden hours in the 2025–2026 academic year. In a departure from previous procedure, no IPEDS survey instrument containing the proposed questions and data points has yet been provided for review. This makes it extremely difficult to accurately map the proposed new requirements onto current data systems to gauge the full scope and impact of this expansion—including work hours needed to comply.

As comments thus far in the Federal Register indicate, not only is it difficult to gauge impact without seeing data definitions, survey questions, and so forth, but IR staff are currently wrestling with other large data-collection changes made to the IPEDS data-collection system. These offices are often small, as comments also point out. In 2023, the Association for Institutional Research (AIR) found that only 46 percent of IR leaders at public four-year institutions and only 33 percent of IR leaders at private independent four-year institutions considered their staffing levels adequate to meet institutional expectations. Overall, only 39 percent of the IR leaders surveyed considered their staffing levels adequate to meet institutional expectations.¹⁵ This new potential burden presents yet another staffing problem—and a potential compliance risk for boards.

Many Unsettled Questions

As of this post’s date of publication, this federal decision raises more questions than it answers. Some include:

• How can colleges comply with a federal mandate to supply data they have historically not collected on applicants?
• How will pandemic-era effects on data reporting, admissions, and enrollment be accounted for in the data? (For example, if an institution went standardized-test-optional in 2021–2022 in response to the pandemic, then resumed requiring standardized tests for admission in 2024-2025, how will their data be interpreted?)
• How will the Common App, a platform that allows students to submit applications to multiple colleges, be handled in this expanded data reporting?
• How will outliers be handled in this expanded data reporting? (For example, if a system of four-year public institutions reports as one unit to IPEDS, will it have to disaggregate its IPEDS reporting to provide individual institution-level data?)
• How will personally identifiable data be secured given the possibility of exposing individual students’ information due to the number of disaggregations being performed on the data?
• Given the firings at ED, who will be handling data checking, technical queries, and training on new data fields for IPEDS keyholders?
• What does the sentence in the Federal Register notice, “Data alone is not determinative as to whether institutions are engaging in unlawful discrimination, but the department may use data to develop risk-based enforcement practices,”¹⁶ mean in practice for institutions—and boards?
• How can the public and institutions adequately comment on this proposed IPEDS expansion given that the actual data fields have not yet been defined and published, so their parameters are unknown (for example, how institutional changes in standardized test policy will be accounted for)?

This is a rapidly developing situation. Readers can consult the following sources for more technical details:

• Association for Institutional Research (AIR)
  • See a differently formatted summary of the proposed metrics at ACTS
• Federal Register: Agency Information Collection Activities; Comment Request; Integrated Postsecondary Education Data System (IPEDS) 2024-25 Through 2026-27
• IPEDS Data Center (NCES)
  • Timing Of IPEDS Data Collection, Coverage, And Release Cycle

Questions for Boards

Perhaps there will be more clarity after the Federal Register comment period ends, when public questions posed by commenters might be answered. Until then, given the potential financial impact, boards should at a minimum be aware and ask questions about how these new requirements might apply to their institutions, who needs to be informed, and what resources and policy changes are potentially necessary.

• Does your board have a 30,000-foot-level understanding of what admissions data are already collected—or not collected—by your institution and how they correlate with the proposed Federal Register notice’s data requirements?
• Does your institution/system have sufficient resources—not only staff, but computing capacity—to fulfill this additional burden on top of already required federal, state, and local data-reporting mandates?
• What changes might need to be made to vendor contracts, if your institution/system uses purchased data software? Will those vendors be able to comply in the time proposed by the Federal Register notice?
• Are the appropriate stakeholders adequately familiar with how much Title IV aid affects your institution or system’s revenue model? What might happen to institutional cash flow and student enrollment numbers if ED deemed your institution noncompliant with these proposed new IPEDS reporting requirements and immediately rescinded eligibility for Title IV aid as a result?

Lesley McBain, PhD, is AGB’s senior director of research.

Notes