Title VI Oversight Meets Data Reality: Comments On The ACTS Proposal Analyzed—Key Takeaways For Higher Education

With the comment period now closed on the U.S. Department of Education's proposed Admissions and Consumer Transparency Supplement (ACTS) to its Integrated Postsecondary Education Data System (IPEDS), more than 3,400 submissions reflect broad participation across higher education and the public. Announced on August 15, 2025, the proposed data collection would add a supplement to IPEDS requiring six years of disaggregated admissions, aid, and outcomes data from selective four-year institutions to support transparency and compliance with Title VI of the Civil Rights Act of 1964.

Quick Hits

• The comment period on the Education Department's proposed Admissions and Consumer Transparency Supplement (ACTS) to IPEDS closed on October 14, 2025, drawing thousands of comments by universities, higher education associations, community and technical colleges, career schools, graduate and professional programs, civil rights and policy organizations, researchers, and individual citizens.
• Commenters recommended limiting ACTS to truly selective institutions and treating graduate/professional programs separately.
• Institutions anticipate risk-based reviews tied to new admissions and scholarship data if ACTS advances, especially at selective programs and professional schools.

Background

As proposed, the ACTS supplement would require selective four-year institutions to report six years of retrospective data (2020–21 through 2025–26) on applicants, admits, and enrollees, disaggregated by race and sex and further broken down by grade point average (GPA) and test score quintiles, income, Pell grant eligibility, first‑generation status, application round, aid offered/received, and graduation outcomes. Graduate reporting would be by Classification of Instructional Programs (CIP).

An analysis of the comments reveals broad support for transparency. However, the majority of commenters urged the Education Department to narrow the scope to genuinely selective institutions and to treat graduate/professional programs separately. Core concerns centered on burden and feasibility, unclear definitions, test‑optional data gaps, GPA variability, privacy risks from small cells (i.e., heightened risks that cells of data with few student counts may increase the likelihood that students are identified in violation of their privacy rights), and cybersecurity. Many asked the Education Department to delay until 2027–28, pilot with volunteers, publish detailed technical specs, and provide funding or targeted assistance. Stakeholders also urged alignment with existing IPEDS components and standards to reduce duplication.

Next Steps

Higher education institutions—particularly selective four-year schools and competitive graduate/professional programs—may want to prepare now for some level of enhanced admissions and scholarship transparency. Even if ACTS is narrowed or gradually implemented, the trajectory points toward expanded risk-based Title VI oversight anchored in detailed data. The next steps by the Education Department will determine the precise contours of reporting and enforcement. Institutions that have clarity on data availability, privacy controls, and program-level selectivity will be best positioned to adapt to whatever form ACTS ultimately takes.

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