Comments on Docket ID ED-2025-SCC-0382 — Integrated Postsecondary Education Data System (IPEDS) 2024-25 through 2026-27.

Dear Acting Chief Data Officer Fu:

The Presidents Forum is a coalition of 19 nonprofit, accredited institutions serving more than one million learners nationwide. Our members share a deep commitment to expanding access, advancing workforce opportunity, and achieving measurable student outcomes through a focus on innovation. Together, we represent the full spectrum of today’s learners—including working adults, military-connected students, and others historically overlooked in the design of higher education policy and regulation. Each of our institutions serves as a laboratory for student-centered innovation, testing and scaling models that make education more affordable, attainable, and aligned with the needs of learners and employers alike.

Open-Access Institutions

We respectfully recommend that institutions meeting the Department’s definition of open admission be exempt from ACTS admissions and scholarship reporting. These institutions do not employ selective admissions practices and therefore present minimal risk of noncompliance with Title VI. Requiring reporting from open-admission institutions would yield data of limited analytical value while diverting effort from the core mission of providing opportunity to all learners.

Highly Inclusive Institutions

If the Department determines that additional data elements beyond race-sex reporting should be collected, any such new requirements should not apply to institutions that accept a high percentage of applicants, such as over 85 percent. This threshold would maintain transparency while recognizing the inclusive mission of access-oriented colleges and universities. For institutions with high acceptance rates, the additional data would not offer meaningful differentiation but would pose substantial feasibility challenges. 

Feasibility and Data Quality

The proposal to require retrospective reporting of five years of admissions and scholarship data presents significant feasibility and data-quality concerns. Most access-oriented institutions do not maintain historical data in the structure or granularity contemplated by ACTS. Reconstructing these data would be technically impractical, and any partial information obtained would likely be incomplete or inconsistent across years. For these reasons, the Department should limit ACTS implementation to prospective data collection only, ensuring that future reporting is accurate, standardized, and aligned with common definitions.

Privately Funded Scholarships

We further recommend that privately funded institutional scholarships—those supported entirely through non-federal and non-state resources—be excluded from ACTS reporting requirements.

Conclusion

The Presidents Forum and its member institutions remain committed to advancing transparency and accountability in ways that genuinely serve students. We urge the Department to ground ACTS implementation in feasibility, data quality, and institutional context—exempting open-admission institutions, limiting additional requirements to those with less than 85 percent selectivity, excluding privately funded scholarships, and applying new reporting prospectively. These adjustments will strengthen the quality and utility of ACTS while supporting institutions’ shared mission to expand educational opportunity.

Sincerely,

Wesley Smith

Executive Director
Presidents Forum