ACE and 37 other higher education associations submitted comments this week urging the Department of Education to significantly revise—or withdraw entirely—its proposed overhaul of federal admissions data collection.The proposal, known as the Admissions and Consumer Transparency Supplement (ACTS), was published in the Federal Register on Aug. 15 and stems from a memorandum issued by President Trump on Aug. 7. That directive ordered the department to collect expanded admissions data from colleges and universities, including race, sex, test scores, GPAs, and other academic and demographic details.
Institutions that participate in federal student aid programs would be required to report these data disaggregated by applicant, admit, and enrollment status—at both the undergraduate and graduate levels—through the Integrated Postsecondary Education Data System (IPEDS). Colleges that fail to comply could face “remedial action” under Title IV of the Higher Education Act.
"A Fishing Expedition"
ACE has voiced concerns about the administration’s rationale and the feasibility of the proposed reporting.
“This is a fishing expedition,” ACE President Ted Mitchell told The New York Times in August. He emphasized that students are not required to report their race when applying to college, which makes it extremely difficult to use the data to draw conclusions about institutional compliance with the Supreme Court’s decision in Students for Fair Admissions v. Harvard.
Although the administration claims the data will improve transparency, the comments submitted Oct. 7 argue that the proposed expansion would result in “unreliable and misleading data that is intended to be used against institutions of higher education.” The letter further notes that “the enormous complexity of the request… and the lack of sufficient time to revamp systems and gather data” make implementation virtually impossible.
The department is seeking more than 11,000 new data points annually, with institutions also expected to retroactively report nearly 70,000 additional fields covering the previous five academic years. Under the current timeline, colleges would have only 17 weeks—until early December—to comply.
Process, Privacy, and Purpose in Question
In their comments, the associations also raise procedural and legal concerns, noting that the Department failed to submit a full survey instrument as part of its information collection request—a key requirement under the Paperwork Reduction Act. They urge the Department to pause the process and convene a Technical Review Panel to assess the proposal’s feasibility, data integrity, and privacy implications.
The groups point to numerous unresolved challenges, including:
- The absence or inaccessibility of key data for graduate students.
- The inconsistency of definitions across data fields.
- The high burden on already-overstretched institutional research offices.
- The risk of student reidentification through small demographic subgroups.
In an Aug. 7 interview with NPR, Mitchell stressed that admissions decisions have never been based solely on numerical data. “This is why we have recommendation letters. This is why we care if someone’s been on an athletic team [or] if they’re a cellist,” he said. “Because we want to get a better picture of what those numbers mean.”
The reporting mandate would apply to all institutions receiving federal student aid, even though only about 15 percent of U.S. colleges and universities are considered selective in their admissions processes.
“There’s a huge net,” Mitchell told The Washington Post. “And it’s got a bunch of big holes.”