Dawn Medley is the new vice president for enrollment management at Missouri State University. In her 30 years of working with higher education data across the country, she has spearheaded programs to forgive student debt, expand free tuition and allow for student re-enrollment.
However, during these 30 years, she has never seen a request as big as the one incited by the Department of Education last year.
In August, President Donald Trump issued a memorandum demanding that Title IV federally funded universities upload student enrollment data from the last six years with hundreds of new data points that have never been asked before. The memo was followed by another memorandum from Secretary of Education Linda McMahon asking schools to pinpoint more specific student data broken down by race, gender, standardized test scores, high school GPA and family income.
They were originally given just 120 days to get this done. Now, they have until mid-March.
“I would have liked for there to be higher education folks at the table as some of these decisions and thought processes were being developed,” Medley said. “I think that folks who did not have a lot of higher education experience were like, okay, we can do this in four months.”
The National Center for Education Statistics (NCES) has collected student admissions data from universities since the 1960s. This used to be done through the Higher Education General Information Survey (HEGIS), until it was replaced by the Integrated Postsecondary Education Data System (IPEDS) in 1986. Its intention is to collect information on students, faculty, policy and financial aid to describe higher education in the United States.
But these recent memoranda from the Trump administration have placed universities across the nation on a deadline much shorter than what’s standard for collecting and uploading university data.
So, under Medley’s guidance and student government approval, Missouri State has secured technology from a vendor- Edvisorly, a third-party company that allows MSU staff to use AI to scrape old transcripts and merge it with admissions data to gather the required reporting data elements.
Schools such as Missouri State and the University of Missouri are some of 2,200 schools racing the clock to upload the data by the March 18 deadline.
Universities that do not meet the deadline will be fined up to $71,545 for each violation of any provision of Title IV and can lose financial eligibility.
“Just in general, they look to fine you double what your last year’s allocation of Title IV federal financial aid dollars were. And so for us, that'd be about $200 million,” Medley said. “It would kill institutions.”
Intent behind the memo
In 2023, the U.S. Supreme Court – now with a 6-3 conservative majority after Trump named three justices in his first term in office – ruled in Students for Fair Admissions v. Harvard that using affirmative action practices in college admissions violated the Equal Protection Clause of the U.S. Constitution’s Fourteenth Amendment, deeming it unconstitutional.
Language in McMahon’s memo states that “data collected by IPEDS should be enhanced to capture information that could indicate whether institutions of higher education are using race-based preferencing in their admissions processes.”
But Erin Dunlop Velez, vice president of research at the Institute for Higher Education Policy, doesn’t believe this data will offer any evidence to suggest whether universities are complying with the Supreme Court decision.
Velez said the Trump administration assumes that if race is no longer considered, the percentage of underrepresented minority students will decrease, because they believe it was high only when race was a factor.
But after affirmative action practices were axed, the number of students of color at elite institutions dropped significantly. This led to an increase of minority students at state level flagship universities, indicating that these students ended up at their safety schools.
Experts say misconstrued conclusions about a university's admission process can be drawn from this data, causing schools to be subject to investigations.
“I worry about a cooling effect,” Velez said. “If you’re a university, you don’t want the Department [of Education] looking at you. There’s admissions practices that can keep your student body diverse but you might be nervous about using those…even post- [the Students for Fair Admissions decision].”
Before the Trump administration’s memo, all the information uploaded by universities was non-personally identifiable. In the past, if a school had 100 female students, that’s all they would have to report. With the extra data that the Department of Education is requiring to be reported, it will be easier to pinpoint students more specifically.
“A lot of us in the data community assume that this data will be made publicly available,” said Christine Keller, the executive director and CEO of the Association for Institutional Research . “There are real concerns about its accuracy, its comparability, and whether the data collected is going to be able to answer the questions the administration would like to.”
Gaps in data collection
Even if universities meet the mid-March deadline, there will be large chunks of missing data.
For example, the Department of Education wants schools to break down student data by gender. However, the survey only lists options for “male” and “female." This overlooks the students that apply to college as “non-binary” or without disclosing gender.
“Those students will have to indicate whether they are male or female,” Medley said. “Or else there will be scrutiny if there are not enough data points reported.”
This survey also asks universities for data that's not in best practice to keep over long periods of time, such as family education, various standardized test scores and unweighted GPA.
“Many high schools only submit weighted GPAs,” Keller said. “There’s no way to unweight it, so schools are going to have to report it missing.”
Administrative burden
“This one IPEDS component is two-and-a-half times the burden of all the other IEPDS components put together,” Velez said. “That’s five weeks of a full-time person working eight hour days.”
Many institutions hired additional staff members and temporary workers to meet the March deadline.
“I did not believe that was the best path forward for us as an institution because there’s too much room for error,” Medley said. “When you hire temporary workers, they’re temporary by nature, so therefore they leave. If they did poor data entry, we’re going to continue to struggle cleaning that up for years to come.”
Despite the gravity of the deadline, there has been no communication about progress from the Department of Education to universities.
“Normally, that large of a collection takes the Department of Education a year or two to plan and implement and involves a lot of consultation with the community,” Keller said. “With ACTS (the Trump administration’s Admissions and Consumer Transparency Supplement survey), to do that in a matter of weeks and not years is putting real pressure on institutions.”
There have, however, been live changes made to the survey as March rolls closer, asking schools to change types of data required — and making it harder for schools who have already started reporting data.
No room for feedback
IPEDS data collection happens every single year, and any changes made to the survey have typically been phased in over years, with ample time for feedback and questions. The proposed Admissions and Consumer Transparency Supplement survey, however, does not follow this precedent.
According to Velez, there has been no time for field engagement since the memo was released.
“The most important thing about IPEDS is that every single institution is reporting data in the exact same way that allows this true apples to apples comparison,” Velez said. “They’ve rolled out this collection before a lot of questions were answered. I think that’s what’s really going to affect the data quality because schools have to make a judgement call.”
Velez said confusion about unclear definitions and unanswered questions leads to data discrepancies. If schools across the country report data differently, it becomes harder to compare numbers and draw conclusions.
Last December, the PostSecondary Data Collaborative, an IHEP-led coalition, wrote a formal letter to the Department of Education addressing concerns about data reporting guidance, the unusually fast timeline of demands and limited technical assistance resources.
Federal education officials offered no response or changes.
“There’s typically some give-and-take in the community and a lot of trust, listening to make sure the research data is good and useful,” Keller said. “That has not occurred with this data collection, unfortunately.”
On top of a fast deadline, there’s now fewer staff to meet it.
Since the Trump Administration took office, it has laid off around 90% of the Institute for Education Sciences staff, and it did not renew an IPEDS training program. The training program has historically provided prescriptive guidelines on what data points to count. Without it, institutional research offices may be left to answer questions on their own, causing differences in data collection.
The data the Department of Education collects will be sent to RTI International, a North Carolina nonprofit research institute which has also been slammed by federal funding cutbacks.
According to Velez, there is supposed to be a Python script that universities can use to aggregate data and run tables. This script is valuable because it allows universities to run the code themselves and all institutions will have data aggregated the same way.
However, at the time of this article’s publication – about a month before the deadline – this script was not ready.
“Normally, when a data collection window opens, like everything's ready to go,” Velez said. “Due to the rushed rollout, things just have not been ready.”
Medley compared this process to submitting homework with a tight deadline. Whether it’s good or not, it just has to be turned in.
University of Missouri spokesperson Chrisopher Ave denied an interview with KBIA but said in a written statement, “The university is gathering the data necessary to comply with the new reporting requirements.”
