By Megan Walter, NASFAA Policy & Federal Relations Staff
The Department of Education (ED), in conjunction with the Census Bureau, hosted a webinar last Friday to provide information to colleges and universities on the applicability of the Family Educational Rights and Privacy Act (FERPA) regarding the disclosure of personally identifiable information from students’ education records to the Census Bureau. ED issued a letter on Jan. 29, 2020 regarding the information campus officials may share with Census Bureau representatives.
ED underscored the necessity that institutions complete the census to the best of their ability, as the “2020 census count is critical for determining representation and the allocations of federally-funded programs, including those in higher education.”
“The Census Bureau identifies all college students as a hard-to-count population because they are highly mobile, may live off-campus as renters, and often difficult to persuade to participate,” ED continued.
The Census Bureau provides institutions with four methods to choose from to count their Group Quarters (GQ) student populations, some of which implicate FERPA data. Group Quarters include residence halls or other buildings, including apartment-style housing, where residents enter into “by the bed” leases, and fraternity or sorority houses recognized by the college or university. The data being collected includes at a minimum the student’s full legal name, date of birth, and address (permanent address). This individual-level data ensures there is no duplication of data, as some parents may report their student or the student may self-report.
There are two methods institutions may use for data collection without FERPA implications, in which students provide their own information directly to the Census Bureau:
Drop-off/Pick-up: Census workers leave questionnaires with the GQ contact for distribution to residents living in student housing on April 1, 2020.
In-Person Interview: Census workers conduct a face-to-face interview with each student/resident in GQ housing on April 1, 2020.
There are two methods institutions may use for data collection with FERPA implications, in which the institution provides individual student data on behalf of the student (student must provide consent for institution*):
eResponse: Census sends institutions unique user ID and census IDs for each GQ facility on their campus; the institution’s GQ contact will upload individual-level data into an electronic template for each student living on campus on Census Day and submit back to the Census Bureau.
IHE-Provided Paper Response: The institution’s GP contact will provide census workers with a paper spreadsheet with student-level data for each student living on campus on Census Day.
*Information may be provided without student consent if census-requested information is designated as “Directory Information” and the student has not opted out of the disclosure. Information designated as “Directory Information” can vary from institution, but it can include name, date of birth, and address.
The 2020 census data collection for GQs has already begun, as the Census Bureau is urging institutions to commit to and report back with which of the methods of enumeration they plan to use before March 6, 2020. To prepare for the April 1, 2020 official count, institutions are also being asked to verify information about their GQs, such as the address, contact name, phone number, and business email address. Schools are also asked to provide an expected population count for April 1, 2020 (Census Day).
If you have questions about your institution's process for GQ census data collection and want to find out who your institution's GQ administrator is, NASFAA suggests reaching out to your external relations or communications offices as a starting point, as GQ contacts may reside in different offices depending on the institution.
Publication Date: 2/19/2020
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