Trump’s college admissions data collection puts pressure on school administrators
After the Supreme Court’s 2023 decision banning affirmative action in college admissions, the Trump administration suspects colleges may continue to implicitly grant racial preferences. To monitor compliance, the White House directed the Department of Education to collect detailed enrollment data from colleges across the country.
The data collection was unusual not only in its scope, but also in its speed. Federal education data collections typically take years to design and undergo multiple rounds of analysis, technical review panels, and revisions. It took just a few months from announcement to launch.
rush work
There’s a tiny hint in the Federal Register notice that this is an emergency effort. In a proposal on enrollment enforcement, both enforce and enrollment were misspelled. The words are spelled “admssions” and “enforce.”
A December filing with the Office of Management and Budget incorrectly listed the number of agencies receiving the new data collection. The number is closer to 2,200, not 1,660, according to the Institutional Research Association, which is advising universities on how to properly report the data. Community colleges are exempt, but four-year institutions with selective admissions or institutions that provide their own financial aid must comply. Postgraduate courses are also included. Altogether there are approximately 2,200 institutions.
In a separate filing with the Office of Management and Budget, the administration disclosed that none of the Department of Education’s five remaining career officials with statistical experience had reviewed the proposal, including Matt Soldner, acting commissioner of the National Center for Education Statistics. Earlier this year, most of the Department of Education’s statisticians were laid off, the first step toward eliminating the Department of Education, one of Trump’s campaign promises. RTI International, a federal contractor in North Carolina that already manages other higher education data collections for the Department of Education, is also handling the day-to-day work of this new college admissions collection.
During two public comment periods, universities and higher education trade groups raised concerns about data quality and missing records, but there was little evidence that those concerns materially changed the final design. One of the changes would expand retroactive data requirements from five to six years so that at least one cohort of students has a measurable six-year graduation rate. The second approach relieves universities of the burden of performing hundreds of complex statistical calculations themselves, instead instructing them to upload raw student data to an “aggregation tool” that does all the math for them.
The Trump administration is targeting comparisons between racial and gender categories, and wide disparities could trigger further scrutiny.
missing data
Experts told me that the results are unlikely to be reliable given that much of the underlying data is missing or incomplete. Melanie Gottlieb, executive director of the American Association of Collegiate Registrars and Admissions Officers, warned in a public comment letter that a full year of applicant data may not exist at many institutions. Some states recommend that colleges delete the records of applicants who never enrolled after one year. “If agencies continue to comply with state policy, they will not have five years of data,” Gottlieb wrote.
The organization’s own guidelines recommend that four-year colleges retain admissions records for only one year after the application cycle. One reason is privacy. Applicant files contain sensitive personal information, and purging unnecessary records can reduce the risk of these data breaches.
In other cases, especially at smaller institutions, admissions offices may offload applicant data simply to make room for new student records. Duncan said John Brown University has all seven years of required data, but after switching to a new computer system in 2019, it was difficult to retrieve data from the first year.
Christine Keller, executive director of the Institutional Research Association, said even if a history is available, key details may be missing or not meet federal requirements. The association previously had a federal contract to train college administrators in accurate data collection until DOGE canceled the contract. (The organization now receives some private funding to reduce the amount of training.)
Many students admitted under test-optional policies do not have access to standardized test scores. The department requires colleges to report an unweighted GPA on a four-point scale, although many applicants submit only a weighted GPA on a five-point scale. In this case (and there may be many such cases), colleges are instructed to report the GPA as “unknown.”
Some students declined to report their race. Many shortfalls in household income are expected. Colleges often only have income data on students who fill out federal financial aid forms, and many applicants never submit those forms.
Education Department spokesperson Ellen Kester said in an email that “schools should not provide data they do not have.” She added, “We are aware that some schools may be missing data for certain data elements. We will review the extent of missing data before conducting further calculations or analyses.”
male or female
Even the category of gender can pose problems. The Department of Education’s spreadsheet allows only two choices: male or female. However, universities may collect sex or gender information using other categories, such as non-binary.
“In my opinion, these data are of no value in really showing the different experiences of men and women,” Keller said. She urged the department to add a “missing” option to avoid misleading results. “I think some people in the sector may have misunderstood that what was needed was an option for missing data rather than another gender category.”
New “aggregation tools” themselves are another source of anxiety. Designed so that colleges don’t have to calculate quintiles of grades and test scores by race and gender, it feels like a black box. Universities are supposed to populate rows and rows of detailed student data into a spreadsheet and then upload the spreadsheet into the tool. The tool generates summary statistics such as the number of black female applicants and the number of admitted students who were in the top 20 percent of college grades. Only aggregate data will be reported to the federal government.
At John Brown University, Duncan worried about what the abstracts might mean. Her institution was predominantly white and had never had affirmative action. But if high school grades or test scores vary by race — as often happens nationwide — aggregating the results could hint at unintentional bias.
“This is a concerning issue,” Duncan said. “I would hope that looking at the data over multiple years wouldn’t show that. You might have an anomaly in one year.”
The problem is that the differences are not anomalies. Standardized test scores and academic performance often vary by race and gender, making it difficult for almost any institution to avoid disparities.
College’s Catch-22
The stakes are high. In an emailed response to my questions, the Department of Education pointed to Trump’s Aug. 7 memo instructing the agency to take “remedial action” if colleges fail to submit data on time or submit incomplete or inaccurate information.
Under federal law, each violation of these education data reporting requirements is punishable by fines of up to $71,545. Repeated noncompliance may ultimately result in a loss of access to federal student aid, meaning students can no longer use Pell Grants or federal loans to pay for tuition.
This puts the university in a difficult position. The cost of non-compliance is high. At the same time, compliance can produce flawed data that suggests bias and invites further scrutiny.
The order itself contradicts another government goal. President Trump campaigned on reducing federal red tape and bureaucratic burdens. However, ACTS represents a significant expansion of university paperwork. The U.S. Office of Management and Budget estimates each institution will spend about 200 hours completing the survey this year — a number that higher education officials say may be an understatement.
Duncan hopes that if nothing goes wrong when uploading the data, she can complete the report within 200 hours. “If I made a mistake, it could have taken twice as long,” she said.
Currently, she’s still collecting and cleaning out old student records and waiting to see the results…all before the March 18 deadline.
