Association for Institutional Research
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 #26 Update 2 |
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Student Unit Record Reporting Proposed for IPEDS
Prepared: April 2005 Type: Information Note: If the proposed student unit-record system is implemented, it would have broad implications for all higher-education institutions. The AIR Higher Education Data Policy Committee encourages you and others at your institution who are responsible for admissions, student records, financial aid, student financial records, athletics, general counsel, government relations, information technology, and any other area that is responsible for reporting financial aid and IPEDS student data to read and carefully review the almost 200-page final report from the feasibility study for a proposed Integrated Postsecondary Education Data System (IPEDS) student unit record database, referenced below. Summary The National Center for Education Statistics (NCES) sent to Congress the final report from a feasibility study for a proposed Integrated Postsecondary Education Data System (IPEDS) student unit record database: http://nces.ed.gov/pubsearch/pubsinfo.asp?pubid=2005160 See AIR Alert 26 and Update 1 for information about the feasibility study. The proposed system, which would require institutions to provide data for student-related IPEDS surveys in student unit record format (i.e., in individually identifiable student records) instead of the current institutional summary-level format, would be implemented by NCES only if:
Assuming authorizing legislation were enacted in the summer of 2005, the proposal calls for a pilot study in 2006-07 involving 1,200-1,500 institutions, and full implementation of the new system in 2007-08. Submission of other IPEDS surveys (the three faculty/employee surveys, Finance, and Institutional Characteristics) would continue in the traditional institutional summary-level format. The feasibility study was conducted in response to interest in Congress and in parts of the higher education community for information that is not provided by the current IPEDS. Information regarding net price, financial aid, transfer rates, time-to-degree, and graduation rates (e.g., graduation rate data for aided versus non-aided students, for part-time students, for students by academic program, and for periods longer than 150 percent of normal time) are among the issues of continuing and growing interest. The proposed student unit record system is intended to provide the federal government with the ability to do more detailed and consistent analyses on these issues and others that may arise in the future. For example, the student unit record system would allow the computation of new derived variables, including institutional accountability measures (of interest to some in Congress), and information for prospective students and their parents. Because data in the student unit record system could be used to create new analyses and aggregate summary reports about an institution in response to new information demands, it could lessen the need for new aggregate reporting by institutions. The challenges to the implementation of a student unit record system, including privacy and confidentiality of individual student data, institutional burden, coordination among institutions' offices, technical issues, and timing of the submissions also are addressed in the final feasibility report. The feasibility report concluded, "At the technical level, a UR system could be done at most institutions given time for implementation, and the problems associated with development of such a system are manageable." If the student unit record system were to be implemented, the proposed reporting system would have major implications for postsecondary education institutions. AIR plans to conduct an online survey in the next two months to solicit reactions from institutions to the student unit record proposal and feedback about concerns they may have about implementation at their institutions -- after the AIR members have had the opportunity to read and digest the almost 200-page report. If the proposed IPEDS student unit record system is not authorized and funded by Congress, and if Congress mandates the collection of accountability measures relating to enrollment, completions, price and financial aid, and graduation rates (e.g., graduation rate data for aided versus non-aided students, for part-time students, and for periods longer than 150 percent of normal time) NCES may have to expand current aggregate reporting requirements. Current Status (Note: information below will probably change because of deliberation by future Technical Review Panels) What Institutions May be Required to Do If the proposed system is authorized and funded by Congress, final decisions about the design of the system would be informed by a series of Technical Review Panels (TRPs). The feasibility study provides only a preliminary design and its language should not be construed as a final NCES decision about the future. The current proposal calls for the annual submission of at least three term enrollment student unit record files (records for each student enrolled at any time during the term, to be submitted at the end of each term), at least one completions file (in September), and at least one price and student financial aid file (October 1). Forty variables have been identified that would be collected for each student, including Social Security number (SSN), name, address, demographics, program-related information, enrollment status and dates, price and financial aid data, and completions-related variables (see http://www.airweb.org/images/alert26update2chart.ppt for details). Failure to submit IPEDS data carries with it a fine of up to $27,500. In the first year, institutions would be required to submit comprehensive "header records" for all students, and historical files for graduation-rate cohorts going back six years for four-year institutions and three years for two-year institutions. The other student IPEDS reports would require enrollment data for current students and completions and financial aid data for the prior-year students. Because of requirements from the Office of Management and Budget (OMB), all unit record data, including the current files and historical Graduation Rate Survey (GRS) files, must use the two-question format for race/ethnicity reporting mandated by the OMB in 1997 for federal agencies when they collect information from individuals (see AIR Alert # 6, New Federal Standards for Racial and Ethnic Data Collection and Reporting [April 1998]. This format allows individuals to identify themselves as belonging to more than one racial category (White, Black or African American, Asian, American Indian or Alaska Native, and Native Hawaiian or other Pacific Islander) in addition to indicating Hispanic/Latino ethnicity. The new OMB standards also redefine certain categories. Institutions selected for the pilot in Fall 2006 would be required to submit student data using student unit record files in addition to the traditional institutional summary-level IPEDS Fall Enrollment, Completions, Student Financial Aid, and Graduation Rate Surveys, and price of attendance. If the new race/ethnic format has not been implemented for aggregate IPEDS reporting, they would be required to submit race/ethnic data in the current (one-question) format for institutional summary-level reports and in the new two-question format for student unit record files. If selected, institutions must participate in the pilot. (The completion of all IPEDS surveys is mandatory for all institutions that participate in or are applicants for participation in Title IV Higher Education Act (HEA) student financial aid programs.) The tentative design suggests there might be variations across institutions in the number and timing of data submissions, but calls for locking enrollment data three months after the end of each term. Completions data would be locked by the end of November, and student financial aid and price data would be locked by the end of December. The NCES report suggests that future discussions will need to resolve how to deal with mid-term changes in student status (e.g., change from full-time to part-time enrollment, and how to determine enrollment information for the aggregate Fall Enrollment data). Edit Checks Keyholders would be required to resolve a series of edit checks both at the student unit record level and at the aggregate level. Edit checks look for internal inconsistencies/errors, potential record-matching problems (e.g., missing prior record), and data-inconsistency edits identified by matching newly submitted records with records on the master student unit record database (both from same and different institutions), differences between current summary reports and prior-year summary reports from the Peer Analysis System (PAS), state coordinator edits (if relevant), National Student Loan Data System (NSLDS) verification inconsistencies, PAS quality control, and full-year transaction edits. The NCES will provide the SQL code prior to data collection so that institutions may run their own edit checks before submitting their data to NCES. Examples of errors that would need to be resolved by the institutional keyholder include a financial aid or completions record without a corresponding enrollment record, a change in a name or demographic, or the discovery by NCES that a student an institution classified as "first-time" had a prior enrollment record at another postsecondary education institution. Resolution of edit checks requires resubmitting the student unit record file. The NCES estimates 4%-6% of file merges result in mismatches (i.e., around 50 mismatches per 1,000 records, and there could be multiple records per student), and mismatches are only one of the many types of edits that will need to be resolved. IPEDS Year All IPEDS student data would be based on a July 1 to June 30 year, which has several implications. Students in summer terms before July 1 would not be counted in the same IPEDS year (or enrollment file) as those beginning on or after July 1. The TRPs would have to develop guidelines for dealing with students enrolled in courses that span July 1. The census date for graduation rate calculations also would be changed. Currently, the IPEDS GRS follows students in each cohort through August 31 of the sixth year for four-year institutions, and the third year for two-year institutions. So, late summer graduates are counted as completers in calculating the institution's graduation rate (and because the report isn't due until April of the following year, it in effect allows institutions to include any degrees that are "retroactively posted" into the spring). But, with a cohort year of July 1 to June 30, degrees awarded to students after June 30 in the final year for the cohort, or "retroactively posted," would not be counted in the institution's graduation rate. The degree to which graduation rates would be lowered is expected to vary across institutions. Privacy, Confidentiality, and Security Issues The NCES report cites the confidentiality and security provisions under which NCES operates that would provide protection for the student data. However, concerns have been raised about intrusions into student privacy and the possibility that future Congressional actions could allow access to the data by other federal agencies. Other concerns that have been raised include the possibility that, in the future, student unit record data in the NCES system might be used to sanction students. The FERPA would have to be amended to allow for redisclosures of the data, including sending data back to the keyholder to resolve errors and mismatches, using the data for enrollment verification by NSLDS for loan repayment deferrals, and sending a file to institutions and state coordinators with subsequent enrollment and completions data for students who left the prior year (available to the keyholders for a predefined period). It is proposed that students would be given the opportunity to opt-out of the redisclosure to institutions, but not out of the student unit record database, enrollment verification for the NSLDS, or redisclosures permitted under the PATRIOT Act. Implications for Institutions
Institutions selected for the pilot would have to complete these steps by Fall 2006 (or according to any calendar that is mandated by Congress). Other institutions would have more time to prepare. All institutions would need to monitor the outcomes of the TRPs to be held beginning in Fall 2005.
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