As the Department of Education (ED) considers changes to the Integrated Postsecondary Education Data System (IPEDS) survey, ACE and three other higher education associations submitted comments raising concerns with the proposal.
The IPEDS survey is the main source of federal higher education data about U.S. colleges and universities and their students, and colleges and universities who receive Title IV funding are required to complete it annually.
While the department addressed some concerns previously raised, issues remain with the proposed changes to the reporting of gender; how non-resident students are reported; and expanding enrollment counts to include non-credit activity.
“We were encouraged by the Department’s responsiveness to institutions’ feedback in the previous comment period, as well as the careful attention given to striking an appropriate balance between an increased understanding of institutional characteristics and the burden changes in this area may impose,” the associations wrote.
The groups stress that they support ED’s efforts to expand options for reporting gender across multiple IPEDS survey components.
Currently, many institutions already collect more detailed information about students’ gender identities than IPEDS currently allows for. But while adding “another gender” and “gender unknown” to the survey forms would not be unduly burdensome for these institutions, for those that currently only collect two gender categories (i.e., “male” and “female”), this expansion will be difficult to implement on a short timeframe.
“Providing a one-year implementation period would allow institutions to modify their systems to meet the new requirement and accurately collect gender information for currently enrolled students,” the comments state.
The associations also support updating the existing language in the survey to eliminate outdated terminology such as “alien” but urge ED to “offer careful guidance on which groups of students should be categorized as nonresident. Adding the designation of ‘U.S. Nonresident’ aligns with existing institutional categorizations of students, distinguishes these students from U.S. citizens who reside in a different state, and provides clarity as to these students’ status.”
The associations note that, as with the proposed changes to the gender categories, institutions have expressed concerns regarding the importance of privacy protections in collecting this data, and urged ED to use caution in reporting small numbers of students.
Finally, they point out that there is a diversity of opinion within the higher education community about the merits of including non-credit enrollment to IPEDS.
While some institutions, including community colleges and those for which non-credit activity is an important part of their mission, would benefit by being able to more accurately report educational expenses, there is serious concern among all institutions about the burden this requirement would impose.
For this and other reasons, the associations urge ED to delay implementation and offer additional guidance on non-credit activity. In addition, they call on ED to create separate survey packages for institutions where non-credit activity is an important part of their mission to address concerns with burden at institutions for which the value of the additional information does not outweigh the costs it would impose.
Also signing the comments were the American Association of State Colleges and Universities, the Association of Public and Land-grant Universities, and the National Association of Independent Colleges and Universities.