NASFAA Expresses Concerns Over ED’s Admissions and Consumer Transparency Supplement (ACTS) Survey
By Maria Carrasco, NASFAA Staff Reporter
NASFAA, along with other higher education organizations, sent a letter to the Department of Education (ED) outlining multiple concerns regarding the department’s proposed new IPEDS Admissions and Consumer Transparency Supplement (ACTS) survey.
Earlier in August, President Donald Trump directed ED to “expand the scope of required [IPEDS] reporting to provide adequate transparency into admissions” within 120 days. In response, ED proposed, via an information collection request through the Federal Register, to add a new IPEDS “Admissions and Consumer Transparency Supplement” (ACTS) survey component. This component would be applicable to all four-year institutions that utilize “selective college admissions,” since, according to ED, these institutions have an “elevated risk of noncompliance with the civil rights laws.”
Open-access institutions, such as community colleges and trade schools, would not be subject to this survey component since they have “minimal or no risk for civil rights noncompliance in admissions because they admit all (or the vast majority of) students who apply,” ED wrote in its notice.
The survey would collect data separately for undergraduate and graduate students. For undergraduate students, it would collect data by a race-sex pair on the count of institutions’ applied, admitted, and enrolled cohorts, both overall and further disaggregated by admission test score quintiles, GPA quintiles, ranges of family income, Pell Grant eligibility, and parental education. Many of these same data elements would be collected for graduate students, but the data would be further broken down by field of study since many graduate students apply for admission directly to institutional departments based on field of study.
In the letter, led by the American Council on Education, the organizations stated that while they support better data collection that will help students and families, the new survey component would instead result in “unreliable and misleading data that is intended to be used against institutions of higher education.”
ACE partnered with the Association for Institutional Research (AIR) on a survey to better understand and outline the concerns institutions have with ED’s proposed data collection.
Some of the concerns institutions shared regarding ED’s new ACTS survey include institutions having limited availability and accessibility of required data, a compressed timeline and resource constraints, and an increased burden on institutions due to retrieval of historical data. Other concerns include student privacy, questioning the accuracy of new metrics – such as test scores, GPA, income – and ambiguity in definitions and reporting guidance listed in ED’s notice.
The letter also highlights concerns about ED’s intent regarding the new survey and data collection.
“Utilizing hastily gathered, ill-defined, and unreliable data to try and direct those efforts is contrary to the public good and will result in erroneous and wasteful federal actions,” the letter reads.
In the survey conducted by AIR, the majority of respondents, 55%, reported that institutions would need 250 to more hours to comply with the additional data reporting required by ED’s proposed ACTS survey. In the Federal Register’s information collection request, ED estimates a total institutional burden of 740,511 hours.
The organizations stressed that institutions would need more time to prepare for this new survey and data collection. An implementation date in the 2026-27 academic year or later, could allow institutions time to prepare the data collections for the ACTS survey, and would ensure the most accurate data.
“The proposed new reporting requirements on institutions contained in the ACTS survey are being implemented on an unrealistic timeframe; request conflicting, nonexistent or noncomparable data elements; were developed without following the appropriate process; will be enormously burdensome and will lead to inaccurate and erroneous conclusions,” the letter reads. “We strongly urge the Department to reconsider its approach, and we appreciate your time and consideration of these comments.”
Publication Date: 10/17/2025
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