Higher education institutions across the United States are voicing strong opposition to a proposed federal rule that would mandate the collection of extensive new admissions data. Citing concerns about student privacy, overwhelming administrative burdens, and the use of unclear metrics, colleges and universities argue the plan is unworkable in its current form.
The proposal, initiated by the Trump administration, aims to increase transparency in college admissions following the Supreme Court's 2023 ruling against affirmative action. However, feedback submitted during a public comment period reveals deep apprehension about the feasibility and potential negative consequences of the new requirements.
Key Takeaways
- The Department of Education has proposed a rule requiring colleges to submit detailed admissions data, including test scores, GPA, and family income for applicants, admitted students, and enrolled students.
- Universities and higher education groups warn of significant administrative burdens, especially for smaller institutions with limited staff.
- Major concerns include the potential violation of student privacy, the use of non-standardized metrics like high school GPA, and an unrealistic implementation timeline.
- Critics argue the data collection goes beyond the scope of the Supreme Court's ruling on affirmative action and could produce misleading information.
A Massive Expansion of Data Collection
The proposed regulation, known as the Admissions and Consumer Transparency Supplement (ACTS), would require institutions to report applicant, admitted, and enrolled student data. This information would be broken down by quintiles for standardized test scores and grade point averages, as well as by family income ranges, Pell Grant eligibility, and parental education levels.
Institutions would also be required to submit this data retroactively, going back to the 2020 admissions cycle. The Association for Institutional Research (AIR) described the proposal as “the single largest expansion in [Integrated Postsecondary Education Data System] history.” According to AIR, the rule would add over 100 new questions and approximately 10,000 new data fields for each institution to complete.
By the Numbers
In a survey conducted by the Association for Institutional Research, 91% of data professionals reported they would be unable to provide the required data by the proposed deadline. Additionally, 88% stated that providing retrospective data would be “untenable.”
The proposed timeline for compliance has drawn significant criticism. Once the rule is finalized, institutions would have only 120 days to submit their data for the 2025–26 application cycle, a deadline many have called impossible to meet.
Concerns from Institutions Large and Small
During the public comment period, which closed recently, numerous colleges and universities detailed their objections. A primary concern is the strain on institutional resources, particularly for smaller schools with limited administrative capacity.
The Burden on Staff
Campbellsville University, a private institution in Kentucky, noted that it does not currently collect some of the requested data points, such as the Pell Grant eligibility of every applicant. The university stated that a “uniform compliance model fails to reflect these differences and places disproportionate burden on institutions like ours.”
This sentiment was echoed in an anonymous comment from a staff member at a small Christian liberal arts college. “I am the only staff person to coordinate data. This role is also only a portion of my full-time job,” the commenter wrote, expressing fear that the added workload of 250-450 hours would overwhelm already busy departments like financial aid and admissions.
Legal and Political Context
The data collection initiative stems from a presidential executive order aimed at ensuring compliance with the Supreme Court's 2023 decision in Students for Fair Admissions v. Harvard, which effectively ended race-conscious admissions. A joint comment from 18 Democratic attorneys general argued the proposal exceeds the scope of that ruling, stating that pursuing campus diversity through lawful means is not prohibited.
Flawed Metrics and Vague Definitions
Beyond the logistical challenges, many institutions questioned the validity and clarity of the data being requested. The proposal uses terms like “selective admission” institution without providing a clear definition, leaving many colleges uncertain if the rule applies to them.
Nicole Sampson, provost at the University of Rochester, highlighted the problem with collecting high school GPA data. She noted that GPAs are not standardized, with some schools using a weighted 5.0 scale and others an unweighted 4.0 scale. This inconsistency, she argued, could lead to unreliable and misleading information.
“We are deeply concerned that the Department’s data collection proposal is fundamentally flawed in its approach and has the potential to produce unreliable information that could mislead, rather than inform, future higher education policy decisions,” Sampson wrote.
Furthermore, the rise of test-optional and test-free admissions policies means many institutions do not have standardized test scores for all applicants. The Association of American Universities (AAU) also pointed out that admissions decisions are often holistic, considering factors far beyond GPA and test scores. “Accordingly, data disaggregated solely by GPA, test scores, race, or gender would not provide a complete or accurate picture of institutional decision-making or student merit,” the AAU stated.
Student Privacy at Risk
A significant concern raised by multiple commenters is the potential for compromising student privacy. By breaking down data across numerous specific categories—such as GPA, test scores, income, and parental education—it could become possible to identify individual students within small subgroups.
The AAU noted this risk would be especially high depending on how much of the collected data is made publicly available, a detail the Department of Education did not clarify in its proposal. This raises serious questions about compliance with federal privacy laws like the Family Educational Rights and Privacy Act (FERPA).
Institutions have requested that the department explicitly outline how it plans to safeguard student data before moving forward with the rule.
A Path Forward: Calls for Revision
In their public comments, higher education advocates proposed several changes to make the rule more manageable and effective. Common suggestions include:
- Delaying Implementation: Pushing the start date back by at least one year to give institutions adequate time to prepare.
- A Pilot Program: Rolling out the survey with a small group of volunteer institutions first to identify and resolve issues.
- Reducing Data Scope: Limiting the number of data points collected to only what is most essential and feasible.
- Providing Funding: Allocating federal funds to help colleges, especially smaller ones, cover the costs of new data collection and reporting systems.
The Department of Education must now review and respond to the more than 3,400 comments it received. While nearly 90% of comments were supportive, they used nearly identical language traced to a right-wing nonprofit, suggesting an organized campaign. The vast majority of detailed, substantive feedback from educational institutions and their advocates has been overwhelmingly critical, urging a significant revision of the proposed rule.
