Electronic AIR Volume 26, Number 44 (8/22/2006) E-AIR ALERT 14 - UPDATE 2: U.S. Department of Education Issues Proposed Guidance on Collecting, Maintaining, and Reporting Data on Race and Ethnicity http://www.airweb.org/page.asp?page=956 _________________________________________________________________ TITLE: U.S. Department of Education Issues Proposed Guidance on Collecting, Maintaining, and Reporting Data on Race and Ethnicity PREPARED: August, 2006 TYPE: Request for Comments by September 21, 2006 =============================================== Note: This topic will have broad implications for institutions. AIR¡¯s Higher Education Data Policy Committee recommends that you share copies of this Alert with general counsel and individuals at your institution who are responsible for information technology, admissions, student records, financial aid, human resources, affirmative action, athletics, and any other area that may be affected. Institutional responses should be coordinated. =============================================== SUMMARY The U.S. Department of Education (ED) has announced proposed guidelines for how institutions will collect and maintain race and ethnicity data for students and employees, and how those data will be aggregated for reporting to the Integrated Postsecondary Education Data System (IPEDS), using the racial/ethnic standards issued by the Office of Management and Budget (OMB) in 1997 (see AIR Alert #6, New Federal Standards for Racial and Ethnic Data Collection and Reporting (April 1998): http://www.airweb.org/page.asp?page=109). After final guidance is published, INSTITUTIONS MUST IMPLEMENT THE REQUIREMENTS BY THE FALL OF 2009, based on data for the 2009-2010 school year. To comply with the final guidelines, institutions may have to revise their admissions, employment, and registration forms; change data storage and retrieval software, and modify reports and analyses. Institutions should not make changes in forms, databases, or computer programs until final guidance has been issued and IPEDS reporting processes have been finalized. The Department is soliciting comments on the proposed guidance, issued on August 7, 2006 in the Federal Register (Volume 71, Number 151, pp. 44865-44871), and available at http://a257.g.akamaitech.net/7/257/2422/01jan20061800/edocket.access.g po.gov/2006/pdf/06-6695.pdf. Comments must be received by SEPTEMBER 21, 2006. Internet comments may be submitted at the Web site: http://www.regulations.gov (Document ID ED-2006-0280-0001) or at comments@ed.gov. Paper documents should be addressed to Patrick J. Sherrill, U.S. Department of Education, 400 Maryland Avenue, SW., Room 6C103, Washington, DC 20202-0600. You must include the phrase "Guidance for Data on Race and Ethnicity" in the text of your paper document or the subject line of your electronic message to ensure that your comments will be considered. The National Center for Education Statistics (NCES) will convene a Technical Review Panel (TRP) meeting to discuss issues involving implementation of new race/ethnicity categories within the IPEDS data collection. If you are interested in participating on the TRP, contact the IPEDS Program Director, Elise Miller, at Elise.Miller@ed.gov no later than August 31, 2006. CURRENT STATUS The proposed guidance includes both requirements for how institutions would collect, maintain, and report race and ethnicity data, and actions that institutions are "encouraged" to take. Requirements ------------ COLLECTION OF DATA FROM EMPLOYEES AND STUDENTS: Institutions would be required to collect data using a two-question format. The notice states that institutions should include instructions that encourage individuals to answer both the ethnicity and the race questions. The first question would ask whether or not the individual is Hispanic/Latino (a person of Cuban, Mexican, Puerto Rican, South or Central American, or other Spanish culture or origin, regardless of race). The term, "Spanish origin," can be used in addition to "Hispanic or Latino." The second question would ask the respondent to select one or more races from the following five racial groups: * American Indian or Alaska Native: A person having origins in any of the original peoples of North and South America (including Central America), and who maintains a tribal affiliation or community attachment. * Asian: A person having origins in any of the original peoples of the Far East, Southeast Asia, or the Indian subcontinent including, for example, Cambodia, China, India, Japan, Korea, Malaysia, Pakistan, the Philippine Islands, Thailand, and Vietnam. * Black or African American: A person having origins in any of the black racial groups of Africa. * Native Hawaiian or Other Pacific Islander: A person having origins in any of the original peoples of Hawaii, Guam, Samoa, or other Pacific Islands. * White: A person having origins in any of the original peoples of Europe, the Middle East, or North Africa. ===================================================== Note: Institutions may collect additional information regarding sub- categories within these categories, such as tribal affiliation. ===================================================== IPEDS REPORTING: Aggregate race and ethnicity data would be reported using seven categories: 1) Hispanics of any race FOR NON-HISPANICS ONLY: 2) American Indian or Alaska Native 3) Asian 4) Black or African American 5) Native Hawaiian or Other Pacific Islander 6) White 7) Two or more races In addition, the IPEDS system would continue to use the category of race and/or ethnicity unknown and the category of non-resident alien (of any race or ethnicity), creating a total of nine reporting categories. The notice states that institutions should ensure that a respondent who does not provide race/ethnicity information is refusing to self- identify rather than overlooking the question. According to the proposed guidance, if the institution has provided adequate opportunity for the respondent to self-identify, and he or she still leaves the items blank or refuses to complete them, OBSERVER IDENTIFICATION IS NOT REQUIRED but may be used by postsecondary education institutions. RETENTION OF DATA: The notice states that instructions for reporting will include how long institutions would be required to keep the original individual responses from employees and students, including responses to both the Hispanic/Latino and the race questions. The ED may request detailed information (such as required by an Office for Civil Rights (OCR) investigation or compliance review) about individuals in the "two or more races" category, or the racial identification of Hispanics. BRIDGING DATA TO PRIOR YEARS' DATA: The proposed guidance discusses alternative bridging methods for linking the new data to data collected under prior requirements. The notice indicates that institutions should document any bridging methods they may adopt and make them available for ED review, and, if a bridging technique is adopted, the same bridging technique must be used when reporting data throughout the institution. Actions that are Encouraged (but not required) --------------------------------------------- COLLECTION OF DATA FROM EMPLOYEES AND STUDENTS: Prior to the Fall 2009 required implementation, the notice states that, after final guidance is issued, institutions are encouraged, but not required, to re-survey students and employees. The ED "expects" that most institutions will provide the opportunity for individuals to re- identify themselves under the new standards. IPEDS REPORTING: The notice states that, after final guidance is issued, institutions that are already collecting data in the manner specified in the final guidance are encouraged, BUT NOT REQUIRED, to "immediately" begin reporting aggregate data to ED in accordance with the guidance. The NCES will convene a TRP meeting to discuss issues involving implementation of new race/ethnicity categories within the IPEDS data collection. Recommendations from the TRP will be posted for comment on the NCES Web site under What's New in IPEDS? ( http://nces.ed.gov/ipeds/whatsnew.asp). The NCES will announce final implementation plans on the NCES Web site and send messages to IPEDS keyholders. IMPLICATIONS FOR INSTITUTIONS Institutions will want to review the proposed requirements and consider submitting comments, and, possibly, alternative proposals. After final guidance is issued, the new OMB standards are likely to require institutions to make considerable investments of both time and money. Coordination among a number of offices (e.g., Admissions, Registrar, Financial Aid, Human Resources, Affirmative Action or EEO, Information Technology, and Institutional Research) will be necessary. The ED is enforcing full compliance with IPEDS reporting requirements. The proposed guidance would lead to changes in institutional IPEDS data. The count for each race would drop as individuals are reclassified as Hispanic/Latino or as "two or more races." Admissions, registration, and employment forms (both hardcopy and on- line) would have to be changed to conform to the new standards. Adopting the new standards will result not only in new data, but also in a different structure for institutional databases to support multiple race/ethnic categories for each individual. Such a structure may require considerable programming changes in campus-based systems and state-level systems. Institutions also should keep the "old" field for race/ethnicity, especially for the IPEDS Graduation Rate Survey (GRS) cohorts. The IPEDS GRS presents a particular challenge in implementing the new standards because it tracks entering cohorts of students during a period of up to six years (or up to 7.5 years for five-year programs) following initial enrollment, is based on opening fall enrollment racial/ethnic data, and students who graduated or withdrew can't be resurveyed. The computer programs used to generate reports relating to race/ethnicity would need to be modified to accommodate the new data structure as well as the new reporting formats, although the ability to use the old categories for GRS reporting would need to be maintained. In addition to the data collection, storage, analysis, and reporting implications of the new standards, interpretation of institutional data will be more complex. The proposed guidance calls for aggregate reporting of only 6 of the possible 64 combinations of responses (and grouping the other 58 into ¡°Hispanic of any race¡± and "Two or more races"±). Institutions may wish to use different categories for some (or all) of their internal reporting (for example, including students who indicate "Black or African American" in combination with Hispanic and other race categories when supplying a count of Black/African American graduates). A major complication is that, because of multiple responses, the sum of counts for racial/ethnic categories that include individuals indicating multiple responses will produce a total greater than the total number of individuals in the population. Reports grouping multiple responses into a single race/ethnic category will have to be prepared and explained carefully. TIMELINE October 30, 1997 ¡ª The OMB published final Revisions to the Standards for the Classification of Federal Data on Race and Ethnicity. December 15, 2000 ¡ª The OMB issued Provisional Guidelines on the Implementation of the 1997 Standards for Federal Data on Race and Ethnicity: http://www.whitehouse.gov/omb/inforeg/re_guidance2000update.pdf January 1, 2003 ¡ª Original date for new federal data collection and reporting. Not enforced because reporting guidelines were not available. August 7, 2006 ¨C Federal Register notice of Proposed Guidance on Maintaining, Collecting and Reporting Data on Race and Ethnicity August 31, 2006 ¡ª Deadline for notifying Elise Miller, IPEDS Program Director, of interest in participating on IPEDS TRP. September 21, 2006 ¨C Deadline for submitting to ED comments on proposed guidance. Fall 2009 ¨C Required implementation of final guidance ADDITIONAL RESOURCES For further information, contact Patrick J. Sherrill, U.S. Department of Education, 400 Maryland Avenue, SW, Room 6C103, Washington, DC 20202-0600, (202) 708-8196, or Edith K. McArthur, U.S. Department of Education, National Center for Education Statistics, 1990 K Street, NW, Room 9115, Washington, DC 20006, (202) 502-7393. Complete information about IPEDS is available at http://nces.ed.gov/ipeds. * The OMB¡¯s Revisions to the Standards for the Classification of Federal Data on Race and Ethnicity (Federal Register, October 30, 1997, pp. 58781-58790) is available at http://www.whitehouse.gov/omb/fedreg/1997standards.html. Related Air Alerts ------------------ Alert #6, New Federal Standards for Racial and Ethnic Data Collection and Reporting (April 1998): http://www.airweb.org/page.asp?page=109 Alert #6, Update #1, Executive Summary of Proceedings for the Policy Panel on Racial/Ethnic Data Collection March 17-18, 1998 (April 1998): http://www.airweb.org/page.asp?page=127 Alert #14, Update on Federal Race and Ethnicity Reporting Changes (July 2002) http://www.airweb.org/page.asp?page=136. Alert #24, OMB Reporting Standards for IPEDS Student and Employee Racial and Ethnic Data Will Not Be Implemented in 2004-05 (August 2004): http://www.airweb.org/page.asp?page=593. ========================================================== Coordinated by the Higher Education Data Policy Committee. All opinions expressed herein do not necessarily reflect the official position of the Association for Institutional Research. ========================================================== ________________________________________________________________ Electronic AIR Volume 26, Number 44 (8/22/2006) Editor: Meihua Zhai, University System of Georgia (mailto:meihua.zhai@usg.edu) Associate Editor: Marne Einarson, Cornell University (mailto:mke3@cornell.edu) Current Subscribers: 6837 Next Issue Copy Deadline: 8/20/2006 Next Issue Target Publication Date: 8/26/2006 Get Back Issues at: http://www.airweb.org/page.asp?page=173 Please send your news submission to Meihua Zhai ________________________________________________________________ Send a note to Gail Fishman gfishman@mailer.fsu.edu to subscribe or unsubscribe. ________________________________________________________________ Electronic AIR is the electronic newsletter of the Association for Institutional Research (AIR) serving Institutional Research professionals and those engaged in Management Research, Policy Analysis & Planning