AIR Submits Additional Comments on Proposed ACTS Survey

On December 15, 2025, the Association for Institutional Research (AIR) submitted additional written comments to the U.S. Department of Education in response to new documentation released for the proposed Admissions and Consumer Transparency Supplement (ACTS) to the Integrated Postsecondary Education Data System (IPEDS).

The comments follow the Department’s November 13, 2025, release of the ACTS Data Codebook, FAQs, and related technical materials. AIR acknowledged these materials as helpful steps toward clarifying reporting expectations and reducing burden, including the introduction of a Python script and aggregation tool.

Based on its experience providing IPEDS training and its engagement with institutional research, institutional effectiveness, admissions, and registrar professionals, AIR’s comments note that significant questions remain unresolved that could affect data quality, consistency, and comparability. Since the release of the updated materials, AIR staff and institutional experts have reviewed the documentation and fielded hundreds of technical questions from nearly 900 professionals preparing for potential ACTS reporting.

The comments identify several areas where additional clarification is needed, including which institutions are required to report, how undergraduate and graduate applicant cohorts are defined, and how multiple test scores for the same applicant should be reported. AIR also raised technical concerns related to recalculating high school GPAs, reporting missing sex data, and the availability of historical applicant-level data given common data-retention practices.

AIR further noted that the accelerated implementation timeline, the absence of a formal technical review process, and limited technical assistance capacity could increase the likelihood of inconsistent interpretation and reporting across institutions. Collectively, these issues may limit the reliability of analyses or conclusions drawn from ACTS data.

AIR’s submission emphasizes the importance of resolving foundational questions, allowing missing data to be reported as such, and providing sufficient time and guidance to support consistent reporting. AIR remains engaged in monitoring developments related to ACTS and supporting members through training, resources, and community discussion.