AIR Submits Comments on Admissions and Consumer Transparency Supplement (ACTS) Proposal

On October 14, 2025, AIR submitted formal comments to National Center for Education Statistics (NCES) regarding the proposed ACTS expansion to the Integrated Postsecondary Education Data System (IPEDS). The letter expresses broad appreciation for efforts to expand transparency around college admissions, but raises significant concerns about the current scope and design of the ACTS proposal.

AIR based its comments in part on a national survey of more than 580 higher-education data professionals, along with over two decades of experience administering IPEDS.

• Data Quality Risks: Many of the proposed new data elements — such as applicant race/ethnicity, test score quintiles, family income ranges — are not uniformly collected or maintained across institutions, may be stored in different systems, or may not be retained long-term. AIR also notes ambiguity in definitions for key items (e.g., “parental education,” “high school GPA,” “merit vs. need-based aid,” “student/final GPA”), which could lead to inconsistent reporting and reduce comparability across institutions. For graduate admissions especially, data are often decentralized at the program or department level — meaning institution-wide reporting may produce misleading comparisons.

• Challenges with Retrospective Reporting: The proposal would require institutions to submit five years of retrospective data. AIR argues that most institutions do not retain applicant-level data for that long, and older records (particularly from the COVID era) can be incomplete or incompatible — potentially undermining the reliability of longitudinal comparisons.

• Deviation from Proven Change Process: Historically, changes to IPEDS have followed a deliberate change-management process involving stakeholder consultation, pilot testing, clear definition of data elements, and sufficient time for institutions to prepare. The ACTS proposal — which would add more than 100 new questions and roughly 10,000 data fields — plans implementation within 120 days, a pace AIR argues is too compressed and risks undermining data validity and public confidence.

• Privacy and Confidentiality Risks: Because ACTS would combine multiple demographic, financial, and admissions-related characteristics at a highly granular level, AIR warns the risk of re-identifying individuals increases — especially when small subgroups are involved. Without clear guidance on minimum cell sizes, suppression thresholds, rounding rules, and other privacy safeguards, the proposal could compromise student confidentiality.

To address these issues and ensure that ACTS strengthens rather than weakens the national higher-education data infrastructure, AIR recommends:

1. Use a phased, managed implementation — following the standard IPEDS change-management process: That means consulting with data experts, pilot testing, clarifying definitions, and giving institutions time to adapt.

2. Start with limited, readily available undergraduate data elements, rather than collecting a broad array of new metrics and retrospective data all at once.

3. Drop or postpone collection of graduate admissions data, or substantially narrow the scope, given varied institutional practices and decentralized program-level admissions.

4. Eliminate historical reporting requirements, and instead collect data prospectively to avoid unreliable or incomplete retrospective data.

5. Establish strict privacy and confidentiality safeguards before collecting highly disaggregated data — including minimum cell-size rules, suppression or rounding, and clear documentation of disclosure limitations.

6. Restore technical-assistance capacity and institutional supports (training, validation tools, automated upload/validation, cross-system integration) to help institutions report accurately.