August 11, 2025

New Admissions Data Reporting Requirements for Higher Education Institutions

Holland & Knight Alert
Nancy Anderson | Paul G. Lannon | Lauren M. Maddox

The U.S. Department of Education (ED) announced it will require institutions of higher education to report additional data relating to admissions processes. The announcement follows President Donald Trump's executive order "Ensuring Transparency in Higher Education Admissions." The stated goal of these changes is to inform students and parents whether the institutions to which they apply are admitting students based on an objective assessment of merit and achievement.

Institutions already report significant school- and student-level data to the ED through the Integrated Postsecondary Education Data System (IPEDS) survey process administered by the National Center for Education Statistics (NCES), a division of the ED's Institute for Education Sciences (IES). However, the ED states the existing survey does not adequately capture information needed to determine if institutions are using race-based preferencing in their admissions process. The ED's announcement therefore directs NCES to collect additional data from institutions through the existing survey process beginning with the 2025-2026 school year. NCES must also develop a quality assurance process for any reported data to ensure that information provided by institutions is accurate and consistently reported.

More specifically, the ED will now collect data disaggregated by race and sex relating to each institution's applicant pool, admitted cohort and enrolled cohort. Institutions have historically reported such data for enrolled cohorts only. Institutions will also need to report certain quantitative data for applicants and admitted student cohorts, including their academic achievement record such as, for example, standardized test scores, grade point averages (GPAs), first-generation college student status and other applicant characteristics.

The announcement also expands existing reporting requirements related to enrolled cohorts, requiring institutions to include data regarding graduation rates, final GPAs, financial aid offered and provided, and other relevant measures. NCES has flexibility to determine if other data points are needed.

For institutions, timely and accurate IPEDS survey reporting to the satisfaction of the ED is a requirement to participate in the federal student aid programs, and it is a condition of each institution's underlying program participation agreement with the department.

Under both the executive order and the ED's announcement, NCES has 120 days to develop and implement these changes. It is likely that there will be further announcements and guidance from the department in the coming weeks regarding the required data and procedures for reporting, which institutions should closely monitor.

Conclusion

If you have any questions about how your institution should respond to this announcement, please contact the authors or a member of Holland & Knight's Education Team.


Information contained in this alert is for the general education and knowledge of our readers. It is not designed to be, and should not be used as, the sole source of information when analyzing and resolving a legal problem, and it should not be substituted for legal advice, which relies on a specific factual analysis. Moreover, the laws of each jurisdiction are different and are constantly changing. This information is not intended to create, and receipt of it does not constitute, an attorney-client relationship. If you have specific questions regarding a particular fact situation, we urge you to consult the authors of this publication, your Holland & Knight representative or other competent legal counsel.


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