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Subject: Student Right-to-Know Act and IPEDS Graduation Rate Survey

Prepared: November 20, 2000

Summary:

In 1997, the National Center for Education Statistics (NCES) introduced the Graduation Rate Survey (GRS) within the Integrated Postsecondary Education Data System (IPEDS). The GRS collects the data necessary for the disclosures of graduation or completion rates required by the 1990 Student Right-to-Know Act (SRK). Final SRK regulations, effective July 1, 2000, were published November 1, 1999. The SRK regulations have two major parts: one applies to all institutions participating in the federal student financial aid programs under Title IV of the Higher Education Act (HEA), and the second applies to institutions that also award athletically-related student financial aid.

The GRS submission satisfies the SRK requirement for annual reports to the U.S. Department of Education (ED) by institutions that award athletically-related aid. The National Collegiate Athletic Association (NCAA) uses the GRS for its annual collection of graduation-rate data.
Institutions participating in the federal student financial assistance programs under Title IV of the HEA are required to submit all IPEDS surveys on time.

Current Status:

Student Right-to-Know Act (SRK)

Annual reports. Institutions participating in Title IV programs are required to make information about the institution available upon request to current and prospective students, including annual reports containing a completion or graduation rate and, if applicable, a transfer-out rate. (For more information about the required disclosures see AIR Alert 10 Update 2). Institutions are encouraged to provide additional information that could make the graduation rate reports more useful. The first report, containing information for students who entered the institution in the 1996-97 academic year, must be available by July 1, 2000, for institutions whose longest undergraduate program is two years; July 1, 2002, for institutions whose longest program is three years; July 1, 2003, for institutions whose longest program is four years; and July 1, 2005, for institutions whose longest program is five years.

Disclosures. In general, information may be disclosed through the institution’s Web site. Students must be provided the exact electronic address and a statement that a paper copy will be provided upon request. If a prospective student requests graduation or completion rate information, it must be made available prior to the student's enrolling or entering into any financial obligation with the institution.

Cohorts. Term-based institutions establish annual cohorts of full-time, first time, degree- or certificate-seeking undergraduate students who are enrolled as of October 15, the end of the institution’s drop-add period, or another official reporting date (as defined in the IPEDS Fall Enrollment Survey). Non-term-based institutions establish cohorts of full-time, first-time, degree- or certificate-seeking undergraduate students who enter the institution between September 1 and August 31.

Completion or Graduation. Students are counted as graduates if they complete or graduate within 150 percent of the normal time for completion or graduation from their programs. Two-year institutions also may count as graduates students who complete the "equivalent of an associate degree"-- students who complete, within three years, a two-year transfer program that is acceptable for full credit toward a bachelor’s degree and that qualifies a student for admission into the third year of a bachelor’s degree program. Students at four-year institutions may be counted as graduates if they complete an equivalent program within 150 percent of normal time, such as the first three years of a 3-2 formal transfer program.

Transfers-out. Institutions that determine their missions include providing substantial preparation for students to enroll in another Title IV eligible institution without having completed or graduated from the reporting institution must disclose transfer-out rates. Institutions are not required to establish any new processes for obtaining information on transfers-out, but they are required to report the transfers-out that are known to the institution through current processes. Students are counted as transfers-out if they did not complete or graduate from the reporting institution and transferred-out within 150 percent of the normal time for completion or graduation from their programs.
Exclusions. The SRK regulations permit institutions to exclude from graduation rate or transfer-out rate calculations students in the cohort that the institution can verify are deceased or totally and permanently disabled, or who have left school to serve in the armed forces, foreign aid service, or on official church missions.

Record-keeping. Institutions must maintain records related to disclosures for three years from the date of disclosure, including documentation supporting the calculation of graduation or completion rates.

Athletically-Related Student Aid. Institutions that award athletically-related aid in addition must calculate graduation or completion rates by race and gender for the total cohort, and by race and gender within each sport for students who receive athletically-related aid. If the institution determines its mission includes providing substantial preparation for students to enroll in another Title IV institution without having completed or graduated from the reporting institution, the institution must calculate, by race and gender within each sport, transfer-out rates (for the transfers-out that are known to the institution). The rates must be calculated annually and four-year averages must be provided. The sports categories are baseball, basketball, football, track and cross-country, and all other sports combined. The institution is not required to disclose the graduation rate or transfer-out rate for a race/gender/sport category that includes five or fewer students. The requirements for cohorts, completion, transfers-out, and exclusions noted above for the total cohort also apply to the data for students who receive athletically-related student aid.

These institutions must also report enrollment for the prior academic year for all full-time, degree- or certificate-seeking undergraduate students by race and gender, and for students receiving athletically-related aid by race and gender within each sport.

The information on enrollment, graduation rates and transfer-out rates must be submitted annually to ED (through the GRS), and disclosed to potential student-athletes and their parents, coaches, and high school counselors at the time an offer of aid is made. These disclosures may be made through electronic mail, but not by posting the information on the institution’s Web-site.
NCAA Member Institutions. Each year ED may grant the NCAA permission to disseminate the graduation rate information for its member institutions to high schools which will satisfy the requirement that the information be disclosed to high school coaches and counselors. The NCAA member institutions are responsible for the disclosures to prospective student athletes and their parents.

IPEDS Graduation Rate Survey (GRS)

Information Collected. Beginning this fall, all IPEDS data will be collected through a Web-based system. NCES budget constraints will require a reduced data collection during the 2000-2001 IPEDS year--items may be re-instituted in subsequent years as resources permit. (See AIR Alert 9 Update 9 for more information about changes to the IPEDS surveys.) The 2000-2001 GRS will collect the data necessary for the preparation of SRK reports and satisfy the requirement for institutions that award athletically-related student financial aid to submit enrollment and graduation rate data to ED and the NCAA. All data must be reported by race/ethnicity and gender.

Special GRS Requirements by Level and Control of Institution. Four-year institutions that have information about student intent report separately all data for students who enter the institution seeking a bachelor’s degree. The data for part-time cohorts previously collected from public two-year institutions will not be collected in the 2000-2001 GRS.

Completers. In 2000-2001, the GRS will collect the number of students who complete less-than-two-year programs, two-to-four year programs, or bachelor’s degrees within 150 percent of time-to-degree, with no detail for length of time to completion.
Transfers-Out. Institutions are instructed to complete the transfer-out section of the GRS only if they determine that their missions include providing substantial preparation for students who do not complete or graduate from the reporting institutions to enroll in other Title IV eligible institutions, and they have or receive data about transfers-out. If the institution does not have or receive such data, the institution is instructed to skip that section of the survey. In 2000-2001, the GRS will collect only the total number of transfers-out, with no detail regarding the level of the transfer institution.
Exclusions. In 2000-2001, the GRS will collect only the total number of exclusions, with no detail regarding the categories of exclusion.

Three-Year and Five-Year Programs. The GRS reporting schedule is based on the category of the institution: less than two year; two year; or four year. The GRS will collect data for each cohort after six years for all four-year institutions, and after three years for all two-year colleges. Supplementary data will be collected from institutions with longer programs: 7½-year graduation data for students enrolled in five-year programs, and 4½-year graduation data for students enrolled in three-year programs at two-year institutions.

Persisters. In 2000-2001, no data will be collected on persisters except for students enrolled in five-year programs at four-year institutions or three-year or longer programs at two-year institutions.
Athletically-Related Student Aid. The deletions noted above regarding detailed information for completers, transfers-out, and exclusions will also apply to the data collected for students who receive athletically-related student aid.

NCAA Member Institutions. NCES will collect the enrollment and graduation rate data required for NCAA members and will transmit the data to the NCAA. NCAA members who are not required to submit the GRS to NCES must send the data directly to the NCAA.

Implications for Institutions

The GRS collects, in a standard format, graduation and, if applicable, transfer-out data for all institutions participating in the federal student aid programs under Title IV of the HEA. These data will be publicly available. Institutions will have to provide in their disclosures the contextual information necessary to make the data more understandable to prospective students.
The amount of data collected in the 2000-2001 GRS is reduced because of NCES budget constraints. Institutions may be asked to produce certain items in future years if they are reinstated by NCES.

Timelines:

November 8, 1990–Student Right-to-Know Act enacted.

December 1, 1995--SRK regulations published in Federal Register (effective July 1, 1996).

Fall 1996--Institutions must begin collecting data for SRK cohort of students who enter in 1996-97 academic year.

July 1, 1997–First annual enrollment report due to Department of Education from institutions that award athletically-related aid. NCAA provided this report to the Department for its members.

June 1997--SRK technical amendment passed changing the cut-off date for 150 percent of normal time from June 30 to August 31.

October 1997–First GRS mailed to institutions (due March 1, 1998).

October 7, 1998–Higher Education Amendments of 1998 signed into law, including several changes to SRK provisions (effective October 1, 1998).

November 1, 1999–Final regulations published in Federal Register, implementing 1998 HEA amendments (effective July 1, 2000).

July 1, 2000--First SRK report must be made available to current and prospective students by institutions whose longest program is two years.

July 1, 2003--First SRK report must be made available to current and prospective students by institutions whose longest program is four years.

Additional Resources:

The SRK regulations are contained in Sec. 668.41, Sec. 668.45, and Sec. 668.48 of Subpart D–Institutional and Financial Information for Students of the Student Assistance General Provision regulations (34 CFR Part 668). These regulations are available at http://ifap.ed.gov/csb_html/regcompsnew.htm.

Final regulations for institutional and financial assistance information, including Student Right-to-Know requirements, were published in the Federal Register, Monday, November 1, 1999, pp. 59059-59073. (See AIR Alert #10 Update 2 for additional information.) The Federal Register notice is available at http://ocfo.ed.gov/fedreg.htm. The relevant sections for SRK are Sec. 668.41, Sec. 668.45, and Sec. 668.48.

For information about changes to the IPEDS surveys see AIR Alert 9 Update 9. Information about IPEDS is available at http://nces.ed.gov/Ipeds.

Authors: Carol Fuller

Coordinated by the Higher Education Data Policy and Publications Committees. Opinions expressed herein do not necessarily reflect the official position of the Association for Institutional Research. Readers are urged to review the regulations carefully to ensure they fully understand reporting requirements.