In an Inside Higher Ed opinion piece published September 15, 2025, Bryan Cook, vice president of data and policy analysis at the American Council on Education, and Christine M. Keller, executive director and CEO of the Association for Institutional Research (AIR), warn that the Department of Education’s proposed Admissions and Consumer Transparency Supplement (ACTS)—a new component of IPEDS—risks producing admissions data that are unreliable and misleading, unless major revisions are made.

Key Concerns

• Ambitious timeline & scope: The proposal would require institutions with “selective admissions” to submit detailed data (including five years of historical data) by December 5—despite many colleges lacking that full historical record.
• Methodological challenges: Graduate admissions data are decentralized and vary widely across programs, making institutional-level reporting misleading. Many of the proposed data elements (e.g. parental education, consistent GPA measures) are not routinely collected.
• Data comparability & definitions: Without consistent definitions and reporting standards, institutions may interpret and report data differently, undercutting comparability.
• Privacy & burden: Breaking out data by multiple demographic and performance categories multiplies complexity, increases the burden on institutional researchers, and raises privacy concerns (especially at smaller institutions).

Cook and Keller argue for a phased approach: start with a narrower set of data elements (e.g. race, sex) using clear definitions, allow institutions time to stabilize reporting systems, and build toward more complex data collection only when systems and standards are ready.

By prioritizing data quality and reporting feasibility over speed and volume, they contend that the Department of Education can better serve students, families, and policy makers—without overtaxing the IR/IE professionals who enable these data collections.

Stay up-to-date on this topic at airweb.org/ACTS.