August 16: The proposed changes have been published in the Federal Register. I wrote about them here.
On August 7, the Trump Administration released an executive order (EO) on college admissions data collection. It joined a long list of EOs targeting higher education and efforts to increase campus diversity, equity, and inclusion efforts, or what the administration likes to call “illegal DEI.” The EO was quickly followed by a press release from the Secretary of Education announcing actions the agency would be taking to enact the president’s order.
What Does The EO Say
Trump’s EO is very short on detail, but it makes a few points clearly.
1. It claims that “greater transparency is essential to exposing unlawful practices and ultimately ridding society of shameful, dangerous racial hierarchies.” I actually think the president is correct, here. Greater transparency is important to expose and eliminate shameful, dangerous racial hierarchies, but it’s not just the unlawful ones that need to be exposed. It’s the perfectly lawful ones, too, such as legacy preferences, providing advantages to students who pay for expensive private high schools, and athletic recruiting, that need to be exposed, since they overwhelmingly benefit the richest students, as Opportunity Insights showed in an analysis of Ivy Plus admissions. There is no indication that the Trump Administration or the Department of Education is calling for data collection on these characteristics.
2. Trump calls on the Secretary of Education to “overhaul the IPEDS data collection portal” to make it more efficient and “revamp the online presentation of IPEDS data, such that it is easily accessible and intelligibly presented for parents and students.” IPEDS is the annual survey that the Department of Education requires almost all institutions of higher education to complete, from barber schools to research universities, public or private.
3. The EO calls for “enhanced reporting requirements,” starting with “expand[ing] the scope of required reporting to provide adequate transparency into admissions, as determined by the Secretary of Education.” That’s all it says. There is no clarification of what the expanded reporting entails. It also calls for “increase[d] accuracy checks of submitted data” and call on the Secretary to punish colleges and universities that “fail to submit data in a timely manner or are found to have submitted incomplete or inaccurate data.” The order says that these changes must be in place in the next 120 days, or by the first week of December, and be initiated in the 2025-2026 school year.
What the Secretary of Education Said
The Secretary of Education clarified some of the points made by the EO, but there are many unresolved issues.
1. “Institutions of higher education will now have to report data disaggregated by race and sex relating to their applicant pool, admitted cohort, and enrolled cohort at the undergraduate level and for specific graduate and professional programs.” This change is not new at all. In the wake of the SFFA decision, I worked in coalition with a lot of other researchers, higher ed groups, civil rights organizations, and members of Congress to push the federal government to start disaggregating application and acceptances by race and ethnicity. They agreed, and these changes were scheduled more than 18 months ago to take effect in the December IPEDS survey in 2025. The last Secretary of Education, Undersecretary, and the Commissioner of the National Center for Education Statistics (NCES), which administers IPEDS, deserve the credit here.
2. “This data will include quantitative measures of applicants’ and admitted students’ academic achievements such as standardized test scores, GPAs and other applicant characteristics.” This is a new change, and it is not at all clear what is actually going to be collected here. Lots more on this in a second.
3. Finally, the Secretary has directed NCES to develop a more rigorous audit process of IPEDS data.
What Is Good
1. It’s not a bad idea at all to audit IPEDS data and to hold institutions accountable when they fail an audit. IPEDS likely could be more efficient and, as last year’s FAFSA debacle made clear, the Department of Education is in severe need of technological updates.
2. Even if it was not their idea, disaggregating data by race and ethnicity for the entire admissions process is very important and valuable. In order to understand admissions better, increase accountability, and improve policy and practice, we need a clearer view of each step of admissions. It is good that the Trump Administration is committed to expanding data collection to increase transparency.
What is Not Clear
1. Who will carry out this order? The president and Secretary of Education are committed to closing the Department of Education, and they have already laid off half the agency’s employees, including almost everyone who worked at NCES and on IPEDS. This order and the Secretary’s press release will expand the work that the agency needs to do, perhaps massively (see the next item). The last I heard, there were three employees total at NCES.
It will also require a lot more guidance for institutions of higher education. Normally, when NCES makes a change to IPEDS, the contractor who does much of the technical work on the survey convenes a technical review panel of stakeholders and experts to discuss proposed changes well in advance before they are put through. I’ve been on those panels. They are multi-day meetings that get deep in the weeds about issues large and small. They’re really important. Clearly, there’s not time to run a technical review panel before December. Additionally, the Department of Education is required by law to provide a 60 day notice in the Federal Register of a comment period in which stakeholders can read the full description of the proposed changes and provide feedback.
Who is going to determine what the guidance should be? Getting this work done responsibly in 120 days with a fully staffed agency would be virtually impossible; with half a staff it’s impossible.
2. What is actually going to be collected? This is not a hard question to answer with respect to disaggregating the admissions process by race and ethnicity. Institutions that do not use an open admissions process (n.b., almost half of all institutions of higher education are open admissions) will report, for example, the number of Hispanic applicants they had each year, the number who were admitted, and the number who enrolled.
What is less clear is how “quantitative measures of applicants’ and admitted students’ academic achievements such as standardized test scores, GPAs and other applicant characteristics” will be reported. WIll this be aggregate data broken out by race and ethnicity, so colleges will have to calculate, for example, the average test scores and GPA of applicants who are Asian American, of admitted applicants who are Asian American, and of enrolled students who are Asian American? Aggregated data of this kind needs to be looked at with a lot of caution, because as the Boston University economist Joshua Goodman recently pointed out, “Mathematically, aggregate admissions data can’t be used to determine whether race is being used as a factor in college admissions.” I am under no illusion that any of this data will be used with caution.
Or will the Department of Education make every institution of higher education do what Columbia and Brown have to do, which is provide anonymized data revealing the race, test scores, and GPA of every single applicant this fall and share whether they were admitted or rejected? That data will not be made public for applicants and admits, according to the deals they signed with the government, but it will be for enrolled students. This will be a massive undertaking for many institutions and for the Department of Education.
There are other important unknowns in the Secretary’s order, starting with what the “other applicant characteristics” are. Will they include data on legacies? Early decision? Athletic recruiting? Type of high schools? Family income and wealth? Pell eligibility? Gender? All of these factors can play a significant role in admissions, but I have yet to hear anyone in the Trump Administration talk about these factors, even while they claim they want a return to merit-based admissions policies where ancestry plays no role.
Really getting into the weeds–the weeds matter! –the order does not recognize at all how much diversity there is in institutions of higher education. A very basic question is what institutions will be required to report this expanded data? How will schools that are test optional or test blind report their scores? And how will colleges calculate GPAs across different scales and systems for weighting grades by level of course work? What will the Department do with institutions, like MIT, that do not ask applicants about their race on their application? (MIT does not use the Common App.
None of these questions have been addressed yet. I fear that few have even been asked inside the administration and Department of Education.
3. What will be published? The EO and statement by the Secretary only say that more data will be collected. They say nothing about what will be published. I suspect, given the Secretary’s remarks about making IPEDS data more accessible, that it will all be made public as the data the Department of Education has long been, but it’s important to know what will be public.
What’s Bad
1. This expanded data collection is irresponsible and will likely be used irresponsibly to attack institutions of higher education. The expanded data collection replicates a basic mistake–a lie, in fact–that the plaintiff in the SFFA case made, which is that admissions decisions should be based on quantitative measures alone. The glaring problem in that analysis is that admissions have never ever been based on grades and test scores alone at practically any college or university. Big numbers are necessary conditions for admission at highly selective institutions, but they’re not sufficient. Highly selective colleges want students with strong grades in rigorous courses (which is not exactly the same as high GPAs) and most of them want to see high test scores, but they could never use those two factors alone to enroll a class, even if they wanted to. Places like Harvard and Duke have more applicants with high scores and grades than they have spots available.
Colleges also want to enroll athletes. And legacies. And first gen students. And people who can pay full freight. And people who can pay nothing. And people from their own state. And people from all 50 states. And people who have artistic talent. And people who want to enroll in less popular majors in departments where professors make a lot of money and want students. And people whose grandfathers donated a building. And celebrities. And on and on.
Using quantitative data alone cannot take care of the many priorities many colleges have (neither, by the way, can a lottery), so they have no choice but to be holistic in their admissions process. Holistic admissions is not going to go away, but this expanded data collection will make it even harder for the public to understand, since the Trump Administration seems to be focused on scores, grades, and race, and nothing else.
The Secretary of Education wants to treat what is basically a first cut in the admissions process–making sure students have the academic qualifications to succeed in college–as the only step. That means she either does not understand or does not care about the reality of college admissions. If she did she would be collecting much more than what she has indicated. In all likelihood, this data collection, tying test scores and grades to race, is intended to make colleges and universities vulnerable to disciplinary action and fines.
2. The timeline for these demands is a trap for colleges. The administration wants to rush these changes through by December and is threatening to punish institutions if they make mistakes or don’t have complete data. This is a nightmare for smaller institutions who rely on small, part-time, and/or temporary staff to help with this kind of reporting. It’s setting them up to fail.
3. The Department of Education appears to be on the path to creating racial quotas that were banned by the 1978 Bakke decision. It has long been illegal for institutions to set goals for the number or percentage of students the enroll of any race, but the Trump Administration is ostensibly trying to do just that, by suggesting that some colleges are not following the law post-SFFA, which implies that they believe there is a correct number and percentage of students of each race who should be admitted and enrolled each year.
4. The EO and Secretary of Education are creating incentives that will further benefit rich students and reduce diversity on campus. As a New York Times piece noted, an increased emphasis on quantitative data in admission will benefit students from wealthy families who attend expensive private schools or public schools in wealthy districts. Admissions offices have a strong motivation to max out test scores and GPAs for admitted students, in order to avoid getting attention from the Trump administration and others. Add that to the loss of international students due to the administration’s actions and loss of revenue for research and there are a lot of reasons for college presidents to tell admissions offices to find even more full-pay American students.
5. There is no need to make IPEDS data more accessible to non-expert audiences. The Department of Education already has two very user-friendly sites that do this: College Navigator and College Scorecard. You can see, for instance, how many Pell-eligible students Fairfield University enrolls right there on its College Scorecard page.
What’s Next
I think that what happens next is what happens with just about every Trump executive order. The affected parties–i.e., colleges and universities–will sue, and I suspect a court will issue a restraining order that will delay the order from taking effect this year, particularly given the considerable challenges of following the law on notification of proposed changes and required comment period. What will happen next year is a lot less certain. So, like pretty much everything else in American life now.
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