Report Details Administrative Burden of Institutional ACTS Reporting
By Maria Carrasco, NASFAA Staff Reporter
The majority of institutions have had to allocate more staffing hours than the Department of Education’s (ED) estimate to complete the new Admissions and Consumer Transparency Supplement (ACTS) reporting requirements, says a new report from the Urban Institute and Association for Institutional Research (AIR) detailing how a quarter of colleges’ collection efforts have required 400 hours or more, double the department’s projected estimate.
The ACTS survey was added in August, 2025 to institutions’ existing Integrated Postsecondary Education Data System (IPEDS) reporting, following an executive order calling for greater transparency in college admissions.
The additional reporting requires “certain four-year institutions with selective admissions to submit disaggregated data on applications, admissions, enrollment, and aid that’s broken down by race-sex pairings, GPA quintiles, test-score quintiles, family income ranges, Pell-grant eligibility, parental education (first-generation status), application round (e.g., early action/decision vs. regular), and more.”
Roughly a year after the announcement of ACTS creation, the Urban Institute released a report outlining the administrative burden this new reporting supplement has cost institutions, along with several issues in the reporting process. This also came after the survey faced legal challenges, which also brought much confusion to institutions.
The report from the Urban Institute draws on data from a survey that received 596 eligible responses from individuals at four-year institutions that were required to report ACTS data. Of these 596 responses, approximately 63% represented private nonprofit institutions, 35% represented public institutions, and the remainder represented “other” institution types, including for-profit institutions. The report also draws on information from in-person listening sessions held at the 2026 AIR Forum in May, which involved approximately 70 participants, and three virtual focus groups conducted in July with 25 participants.
Key takeaways from the Urban Institute include that 67% of all respondents reported that their institutions spent at least 200 staff hours on ACTS – which is the hours ED estimated it would take for an institution to submit these data requirements. However, 52% reported spending at least 250 hours, 28% reported spending 400 hours or more, and 6% were unsure of how many hours their institutions had spent.
Notably, 98% of all respondents reported that ACTS required somewhat or much more time from staff for regular IPEDS reporting. Additionally, 94% of respondents agreed that staffing and time constraints contributed to the administrative burden of completing ACTS reporting.
Respondents reported issues with ACTS data availability, with only 17% of respondents reporting that they had all undergraduate data, and 15% reporting that they had all the necessary graduate-level data. Data that were most commonly reported missing or unavailable included data on student characteristics, admissions data, and financial aid data.
Additionally, 52% of survey respondents reported that they were very or extremely concerned about the accuracy of ACTS data, with the report noting that definitional ambiguity and changing guidance were widespread concerns among institutions. Notably, 64% of respondents disagreed that ACTS accurately reflects their institution’s admissions practice.
The report also touched on concerns related to legal and institutional risk, student privacy, the purpose and use of ACTS data, and more. For example, 68% of respondents said legal and compliance review required somewhat or much more staff time when it came to completing reporting, and 59% agreed that legal and privacy concerns contributed to their overall reporting burden. Additionally, 69% of respondents said they were very or extremely concerned about possible regulatory or legal consequences, and 86% said they were similarly concerned about the risk of misinterpretation or misuse.
“Study participants described compiling and submitting ACTS data under significant time pressure, working with definitions and guidance that changed during the collection, and reconstructing years of historical information from systems and records that had changed,” the report reads. “These conditions raise important questions about the resulting data’s accuracy and comparability. This cycle of ACTS data should therefore be interpreted with caution, particularly when used for trend analysis or comparisons across institutions.”
The report lists several recommendations that ED could take to improve the ACTS reporting process. One possible solution is that the department could use definitions that align with other existing reporting into ACTS reporting, such as IPEDS, and that ED ensures ACTS metrics have clearer definitions and guidance.
Other possible solutions include that ED incorporates ACTS requirements into existing IPEDS surveys and reporting processes, rather than maintaining ACTS as a stand-alone collection. And to reduce burden, ED could ensure that any aggregation tool shows all data validation errors at one time. ED should also state in writing exactly how student confidentiality will be protected and how crosswalks and identifier files will be secured or destroyed, respondents said.
“The findings do not argue against using IPEDS to increase transparency in college admissions,” the report reads. “Rather, they underscore the importance of pursuing that goal in ways that avoid the burden and data-quality concerns identified in this study. The recommendations outlined in this report offer the Department of Education a starting point for improving future ACTS collections while strengthening data quality and reducing the burden on the people responsible for reporting the data.”
Publication Date: 10/20/2026
You must be logged in to comment on this page.