After the 2023 Supreme Court decision banning affirmative action in college admissions, the Trump administration suspected that colleges could continue to covertly grant racial preferences. To monitor compliance, the White House directed the Department of Education to collect detailed admissions data from colleges across the country.
The data collection was unusual not only in its scope, but also in its speed. Federal education data collections often take years to design, with multiple rounds of analysis, technical review panels, and revisions. This went from announcement to launch in a matter of months.
An urgent job
A small hint that this was an urgent job is in the Federal Register Notice. Both enforcement and admissions are poorly written in a proposal that deals exclusively with admissions enforcement. Those words are spelled “admssions” and “enforce.”
one december presentation with the Office of Management and Budget incorrectly lists the number of institutions that are subject to the new data collection. It’s almost 2,200, not 1,660, according to the Association for Institutional Research, which advises universities on how to properly report data. Community colleges are exempt, but four-year institutions with selective admissions or those that award their own financial aid must comply. Postgraduate programs are also included. This adds up to about 2,200 institutions.
In another filing with the Office of Management and Budget, the administration revealed that none of the Department of Education’s five remaining career officials with statistical expertise had reviewed the proposal, including Matt Soldner, the acting commissioner of the National Center for Education Statistics. Most departments Statistical staff were laid off. earlier this year as the first step toward eliminating the Department of Education, one of Trump’s campaign promises. RTI International, the federal contractor in North Carolina that already manages other higher education data collections for the Department of Education, is also handling the day-to-day work of this new college admissions collection.
During two public comments For various periods, universities and higher education trade groups raised concerns about data quality and missing records, but there is little evidence that those concerns substantially altered the final design. One change expanded the retrospective data requirement from five to six years so that at least one cohort of students would have a measurable graduation rate in six years. A second relieved teachers of the burden of doing hundreds of complex statistical calculations themselves, and instead instructed them to upload students’ raw data into an “aggregator tool” that would do all the calculations for them.
The Trump administration’s goal is to generate comparisons across race and sex categories, and large gaps could trigger greater scrutiny.
missing dates
The results are unlikely to be reliable, experts told me, given how much underlying data is missing or incomplete. in public comment letterMelanie Gottlieb, executive director of the American Association of Collegiate Registrars and Admissions Officers, warned that full years of applicant data may not exist at many institutions. Some states advise colleges to delete the records of applicants who never enrolled after one year. “If institutions continue to comply with their state policies, they will not have five years of data,” Gottlieb wrote.
The organization’s own guidance recommends that four-year colleges retain admissions records for only one year after an application cycle. One reason is privacy. Applicant files contain sensitive personal information and deleting unnecessary records reduces the risk of exposing this data to breaches.
In other cases, especially at smaller institutions, admissions offices may download applicant data simply to make room for new student records. Duncan said John Brown University has the required seven years of data, but a change to a new computer system in 2019 made it difficult to recover the first year.
Even when historical records are available, key details may be missing or inconsistent with federal requirements, said Christine Keller, executive director of the Association for Institutional Research, which previously received a federal contract to train university administrators in collecting accurate data until DOGE eliminated it. (The organization now receives some private funding for a small amount of training.)
Standardized test scores are not available for many students admitted under test-optional policies. The department is asking colleges to report an unweighted GPA on a four-point scale, although many applicants only submit weighted GPAs on a five-point scale. In those cases, and there may be many, colleges must report the GPA as “unknown.”
Some students refuse to report their race. Many gaps are expected for family income. Colleges generally have income data only for students who completed federal financial aid forms, which many applicants never submit.
Ellen Keast, a representative for the Department of Education, said in an email: “Schools are not expected to provide data they do not have.” He added: “We know that some schools may have missing data for some data elements. We will review the extent of the missing data before conducting further calculations or analysis.”
Male or female
Even the category of sex poses problems. The Department of Education’s spreadsheet only allows two options: male or female. However, universities may collect sex or gender information using additional categories, such as non-binary.
“In my opinion, that data is going to be pretty useless when it comes to really showing the different experiences of men and women,” Keller said. She insists that the department add a “missing” option to avoid misleading results. “I think some people in the department may have misunderstood that what is needed is a missing data option, not another sex category.”
The new “aggregator tool” itself is another source of anxiety. Designed to prevent colleges from calculating quintile groups for grades and test scores by race and sex, it can feel like a black box. Universities are supposed to fill rows and rows of detailed student data in spreadsheets and then upload the spreadsheets to the tool. The tool generates grouped summary statistics, such as the number of Black applicants and admitted students who score in the top 20 percent at the university. Only aggregated data will be reported to the federal government.
At John Brown University, Duncan worries what those summaries might imply. Your institution is predominantly white and has never practiced affirmative action. But if high school grades or test scores differ by race (as they often do across the country), the aggregate results could suggest bias where none was intended.
“That’s concerning,” Duncan said. “I’m hoping that looking at multiple years of data doesn’t show that. There could be an anomaly in one year.”
The problem is that disparities are not anomalies. Standardized Test Scores and Transcripts They usually vary by race and sexmaking it difficult for almost any institution to avoid showing loopholes.
A vicious circle for universities
There is a lot at stake. In an emailed response to my questions, the Department of Education noted Trump’s August 7 memowhich directs the agency to take “corrective action” if universities do not submit data on time or submit incomplete or inaccurate information.
Under federal law, each violation of these educational data reporting requirements may result in a fine of up to $71,545. Repeated noncompliance can ultimately lead to loss of access to federal student aid, meaning students would no longer be able to use Pell Grants or federal loans to pay for tuition.
That leaves conferences in a bind. Failure to comply is costly. Compliance, meanwhile, could produce erroneous data that suggests bias and invites greater scrutiny.
The order itself contradicts another administrative objective. President Trump campaigned on reducing federal bureaucracy and red tape. However, ACTS represents a significant expansion of paperwork for universities. The Office of Management and Budget estimates that each institution will spend approximately 200 hours completing the survey this year, a figure that higher education officials say may be insufficient.
Duncan hopes to be able to finish the report in less than 200 hours, if there are no hiccups when loading the data. “If I get errors, it could take twice as long,” he said.
For now, he’s still gathering and cleaning up old student records and waiting to see the results… all before the March 18 deadline.
