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#26 Update 1Feasibility Study -- Proposed IPEDS Student Unit Record Collection Prepared: November 2004 Type: Information Note: This topic will have broad implications for institutions. The AIR Higher Education Data Policy Committee recommends that you share copies of this Alert with individuals at your institution who are responsible for admissions, student records, financial aid, student financial accounts, IRS reporting, athletics, general counsel, government relations, information technology, and any other area that is responsible for reporting IPEDS student data. Summary A feasibility study is currently underway for a proposed Integrated Postsecondary Education Data System (IPEDS) student unit record collection system. A report of the study will be submitted to Congress in February 2005. If ultimately (1) found feasible by Congress, (2) mandated in the reauthorization of the Higher Education Act (anticipated as early as 2005), and (3) provided with adequate development and implementations funds directed to the Department of Education (ED) in the federal appropriations process, the new collection system will have broad implications for postsecondary institutions. As part of the study, three Technical Review Panels were held on October 28-29, November 3-4, and November 9-10 to provide feedback and suggestions regarding the feasibility of this proposed change in the IPEDS student record system (the subject of AIR Alert #26). More details about the potential scope, salience, and complexity of an IPEDS student unit record data system were presented and discussed at these technical review panels. (See http://www.highered.org/ipeds for notes from each of the panels.) The currently proposed schedule includes a field test in 2006-07 and implementation in 2007-08, assuming Congressional approval and funding in summer of 2005. To strengthen the feasibility study, the contractor (John Milam at HigherEd.org, jmilam@highered.org or ipeds@highered.org) seeks input from postsecondary institutions. HigherEd.org is expected to submit its draft report to the National Center forEducation Statistics (NCES) at the end of December 2004, and must have your response by December 15, 2004. Input is sought on two issues especially:
Current Status Background materials, the October 2004 proposal, and detailed notes from each of three TRPs are available at: http://www.highered.org/ipeds. The TRP Meeting Notes provide useful information about the reasons underlying the idea to move to student unit records, as well as more information regarding the current proposal. Currently Proposed Student Unit Record Submissions If the student unit record proposal becomes law, the NCES will convene a series of TRPs to develop procedures and the data elements that would be part of the system. The current proposal is for at least three submissions of student unit record enrollment data each year. The number and timing would differ for institutions depending on their calendars (as reported in the IPEDS Institutional Characteristics Survey). Minimally, one completions file and one student financial aid file would also be submitted each year. The timing may be affected by institutional calendars and also by NCES' desire to spread the workload for the IPEDS Help Desk evenly across 12 months. Proposed student finance data elements include tuition and fees, total price of attendance, dependency status, out-of-state/on-campus/off-campus without family/off-campus with family flag, federal grants, state grants, institutional grants, loans, and assistantships. The NCES is in discussions with the Department of Treasury and if the NCES can do enrollment verifications for Treasury, then the proposal may be expanded to require that institutions submit the 1098-T data additionally to the NCES. As part of the student unit-record collection, the NCES would collect race/ethnicity information in the format 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 (from a specific list of 5) in addition to indicating Hispanic/Latino ethnicity. The five racial categories are: White, Black or African American, Asian, American Indian or Alaska Native, and Native Hawaiian or other Pacific Islander. This requirement would reflect a departure from the 2002 NCES recommendation that institutions do nothing to change their current race and ethnicity reporting systems and formats. Purpose of Unit Record Collection Proposed enrollment record files are intended to serve multiple purposes, e.g.: (1) generate the tables currently reported in the IPEDS Fall Enrollment Survey; (2) identify the cohort for the Graduation Rate Survey (GRS); (3) provide more information about enrollment by program; (4) track student persistence in and across institutions in and across states; (5) calculate instructional student credit for varying types of students; and (6) verify enrollment status for student loan recipients to Department of Education's National Student Loan Data System (to determine eligibility for deferral of repayment). By linking the enrollment files with the currently proposed completions and student finances unit record files, the student unit record submissions also would serve to: (1) calculate graduation rates and time-to-degree for different types of students matriculating through one or more institutions; and (2) calculate net price, other federal grants/ scholarships, other state grants/ scholarships, other institutional grants/ scholarships, and federal, state, and institutional loans for different types of students matriculating through one or more institutions. Social Security number, Individual Tax Identification Number (ITIN), name, date of birth, and possibly permanent address will be used to match records. Apparent mismatches will have to be resolved by the institutional IPEDS keyholder in consultation with the IPEDS Help Desk. Illustration of Student Unit Enrollment Record Submissions An example serves to illustrate the student unit record enrollment submission envisioned for a traditional semester campus. The campus would initially submit unit records with student identifiers and header information at the census date, along with other information necessary to create IPEDS Fall Enrollment reports (including number of courses and number of credit hours/ units) and to distinguish non-matriculating students (e.g., high school students in special advancement programs). During the fall semester, additional flagged enrollment change/verification updates (identifiers, number of courses, number of credit hours/ units) would be submitted, consistent with the need to determine eligibility for deferral of loan repayment and to correspond with expectations regarding federal financial aid awards, adjustments and pricing changes. Thus, the initial submission would be most akin to an analytic "census file," while the updates would be shorter transactional snapshots. Flexibility was stressed with regard to updates; however, the 0% federal refund date and end-of-term were discussed as possible required update points within the term. Catch-Up Student Unit Records for IPEDS Graduation Rates Under the current proposal, the NCES would have institutions provide during the implementation year "catch-up" student unit records for prior IPEDS GRS cohorts (e.g., six cohorts for institutions with four-year programs, three cohorts for institutions with two-year programs). These would not be complete enrollment files, but would include all the data elements necessary to generate the GRS reports, such as gender, race/ethnicity, bachelor's degree intent (for four-year institutions) and athletic scholarships by sport. Confidentiality and Privacy The laws governing the NCES provide strong protections for the confidentiality of the data. However, state and institutional representatives to the TRPs worried about possible erosion of those protections if the NCES develops such a comprehensive file and expressed concern about the possibility of significant intrusion into students' privacy rights. Reportedly, many institutions and certain states have been moving away from using the Social Security number (SSN) as an identifier in student records to protect against identity theft, and students are increasingly refusing to voluntarily provide it. Concerns were raised at the TRPs about privacy regulations, including Family Educational Rights and Privacy Act (FERPA) and human research subjects. Existing legislation will not allow the NCES to give institutions any of the individual unit record information, which could provide a potential benefit to the institutions, in tracking transfers for example. These restrictions can be modified in the HEA legislation authorizing the new system, which could include amendments to the FERPA as necessary. The feasibility study contractor seeks feedback about the idea of redisclosure of unit-record data on their students back to institutions, similar in operation to the National Student Clearinghouse model. Burden Institutions and state systems would face start-up costs and additional ongoing costs under the proposal. Costs include possible personnel changes, re-training, IT changes, the effort required for coordination across institutional components, creation and submission of multiple student unit-record files, and significant time resolving problems identified in edit checks. Institutions may need to do substantial work prior to data submission to be able to resolve all the problems and lock the data within the time allowed. Institutions will need to consider FERPA, state laws, and institutional policy in evaluating their notifications to students about the use of their data. Three specific requirements will create additional burden at start-up. First, institutions selected for the field test will be required to submit both the traditional IPEDS aggregate reports and student unit record data. Assuming HEA reauthorization is completed by fall 2005, and the student unit record system is authorized and funded, the NCES would select a sample of 1200-1500 Title IV HEA institutions to test the new system in 2006-07. The data submitted would not have to be complete, but must be sufficient to test the system for its multiple uses. The NCES will make an effort to give these pilot institutions as much advance notice as possible, but institutions selected must participate or be subject to a fine for failure to complete an IPEDS survey. Second, institutions selected in the field test will have to provide race/ethnicity using the new format on the unit records they submit for enrollment and for prior-year completions while at the same time providing aggregate data on the traditional IPEDS surveys using the old format for these same students. Third, the "catch up" files for prior-year GRS cohorts will require extra files based on old datasets, and race/ethnicity for students in these prior-year cohorts will need to be in the new format even though the students cannot be resurveyed. The OMB requires clearance of all surveys that go to more than nine (9) entities and, because clearance can take up to six month, the feasibility study will not include a survey to estimate institutional burden and cost. We encourage institutions to provide this information along with any other comments they may have when providing feedback on this proposal to the contractor. In providing estimates of burden, it would be useful for respondents to indicate whether:
Hopefully, this type of information will help the contractor assess the incremental burden to institutions. Moreover, respondents that currently report student unit record data should indicate whether or not what they currently maintain satisfies NCES' needs. Implications for Institutions A move to a student unit record system has a number of ramifications for institutions. At many campuses, information technology systems would need to be changed to provide for integrating student data across institutional units, implementing the new race/ethnicity standards, and producing the records in the required format for submission to the NCES. The institutional burden in preparation for the first year of implementation would be significant. Concerns also may arise about data reliability if aggregate reports produced by the institution for internal and external purposes, such as governing boards, accreditation agencies, unions, bond agencies, state governmental agencies, and college guidebook surveys do not match the data published by the NCES (for reasons including the NCES perturbation of data when there are small cells). Ways to check the accuracy of the unit-record data and/or compare IPEDS summaries with institutional reporting would need to be developed. Privacy notifications to students may need to be considered. Timing of the release of IPEDS reports may also prove to be an issue. The IPEDS coordination may be affected if state systems and other state agencies that currently provide IPEDS data to the NCES for institutions decide to no longer provide that function. Agencies in other states that do not currently serve as coordinators may wish to assume that role in order to be able to capture the student unit record data as it flows from the institutions to the NCES. Institutions that do not currently submit student unit record data to state agencies will want to consider the implications of state agencies wanting to obtain copies of the IPEDS student unit record data. Institutions that do submit student unit records to states may find themselves submitting one set of files to the state and a different set to the NCES. A list of potential sources of incremental burden developed by the institutional TRP can be found in the TRP notes on page 10 at:http://www.highered.org/ipeds/trp2summary.pdf. Proposed Timeline Three Technical Review Panels were held in late October and early November 2004. Institutional feedback is sought from the feasibility study contractor no later than December 15, 2004, for a draft report due to the NCES at the end of December 2004. A final report is scheduled for submission to Congress in February 2005. If the IPEDS student unit record system were to be authorized and funded by summer 2005, TRPs would be held beginning in fall 2005, and schools would be notified in fall 2005 that they were to participate in a pilot study in 2006-07. Full implementation would be scheduled for 2007-08. Additional Information AIR Alert #26 provided information about the forthcoming technical review panel meetings Information about the proposal and notes from the TRPs are available at http://www.highered.org/ipeds Complete information about IPEDS, including the Peer Analysis System (PAS) and the College Opportunities OnLine Web site (COOL) is available at http://nces.ed.gov/ipeds. AIR Alert # 6, New Federal Standards for Racial and Ethnic Data Collection and Reporting (April 1998). Information about the Family Educational Rights and Privacy Act (FERPA) is available at: http://www.ed.gov/policy/gen/guid/fpco/index.html. Information about the National Student Clearinghouse is available at: http://www.nsic.com. Authors: 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. |