Since the Supreme Court’s 2023 decision banning affirmative action in college admissions, the Trump administration has suspected that colleges may secretly continue to give racial preferences. To comply with police demands, the White House ordered the Department of Education to collect detailed college admissions data 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, with multiple rounds of analysis, technical review panels, and revisions. This one moved from announcement to launch in a few months.
Urgent business
A small indication that this was a rush job is in Federal Register Notice. Both enforce and admissions are misspelled in a sentence that deals with the enforcement of admissions. These words are spelled “admssions” and “forece.”
December one filing with the Office of Management and Budget incorrectly lists the number of institutions that are subject to the new data collection. That’s nearly 2,200, not 1,660, according to the Association for Institutional Research, which advises colleges on how to properly report the data. Community colleges are exempt, but four-year institutions with selective admissions or those that provide their own financial aid must comply. Masters programs are also included. That makes about 2,200 institutions.
In another filing with the Office of Management and Budget, the administration disclosed that none of the career education division’s five remaining staff members with statistical expertise had reviewed the proposal, including Matt Soldner, acting commissioner of the National Center for Education Statistics. Most of the department statistics officials were dismissed earlier this year as a first step toward eliminating the Department of Education, one of Trump’s campaign promises. RTI International, the 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 on this new college admissions collection.
During the two public comments periods, colleges and higher education trade groups raised concerns about data quality and missing records, but there is little evidence that these concerns materially changed the final design. One change extended the requirement for retrospective data from five to six years so that at least one cohort of students has a measurable six-year graduation rate. The second relieves colleges of the burden of doing hundreds of complex statistical calculations themselves, instead instructing them to upload raw student data to an “aggregation tool” that will do all the math for them.
The Trump administration’s goal is to generate comparisons between racial and gender categories, with large gaps potentially triggering further scrutiny.
Missing data
The results are unlikely to be reliable, experts told me, given how much of the underlying data is missing or incomplete. In public comment letterMelanie Gottlieb, executive director of the American Association of College Registrars and Admissions Officers, cautioned that at many institutions, full years of applicant data may not exist. Some states advise colleges to delete records for applicants who never enrolled after a year. “If institutions continue to follow their state policies, they won’t have data for five years,” Gottlieb wrote.
The organization’s own guidelines recommend that four-year colleges keep admissions records for only one year after an application cycle. One reason is privacy. Applicant files contain sensitive personal information and purging unnecessary records reduces the risk of this data being exposed in a breach.
In other cases, particularly at smaller institutions, admissions offices may offload applicant data simply to make room for new student records. Duncan said John Brown University has the data it needs for all seven years, but switching to a new computer system in 2019 made it difficult to retrieve the first year.
Even when historical records are available, key details may be missing or inconsistent with federal requirements, said Christine Keller, executive director of the Association for Institutional Studies, which previously received a federal contract to train college administrators to accurately collect data until DOGE eliminated it. (The organization now receives private funding for a reduced amount of training.)
Standardized test scores are not available to many students admitted under the test-optional policy. The department asks colleges to report an unweighted GPA on a four-point scale, although many applicants submit only weighted GPAs on a five-point scale. In these cases, and there may be many, colleges are instructed to report the GPA as “unknown.”
Some students refuse to report their race. Many holes in family income are expected. Colleges typically have income data only for students who have filled out federal financial aid forms, which many applicants never file.
Ellen Keast, a spokeswoman for the Department of Education, said in an email: “Schools are not expected to provide data they do not have.” She added: “We are aware that some schools may have missing data for some data items. We will review the extent of missing data before making further calculations or analyses.”
Male or female
Even the category of gender creates problems. The Ministry of Education’s spreadsheet only allows for two options: male or female. Colleges may, however, collect information on sex or gender using additional categories, such as non-binary.
“That data is going to be, in my view, pretty useless when it comes to really showing the different experiences of men and women,” Keller said. She is calling on the department to add a “missing” option to avoid misleading results. “I think some people in the department maybe don’t understand that what’s needed is a missing data option, not another gender category.”
The new “aggregator tool” itself is another source of concern. Designed to save colleges from calculating quintile buckets for grades and test scores by race and gender, it can feel like a black box. Colleges have to fill in rows and rows of detailed student data spreadsheets and then upload the spreadsheets to the tool. The tool generates aggregate summary statistics, such as the number of black female applicants and admitted students who scored in the top 20 percent in college. Only aggregate data will be reported to the federal government.
At John Brown University, Duncan worries about what these generalizations might mean. Her institution is predominantly white and never practiced affirmative action. But if high school grades or test scores differ by race — as they often do across the country — the aggregated results could suggest bias where it wasn’t intended.
“It’s a cause for concern,” Duncan said. “Hopefully looking at years of data won’t show that. You could have an anomaly after a year.”
The problem is that inconsistencies are not anomalies. Standardized test scores and academic records routinely vary by race and gendermaking it difficult for almost any institution to avoid showing gaps.
Catch 22 for colleges
The stakes are high. In an emailed response to my questions, the Department of Education stated Trump’s August 7 will be rememberedwhich directs the agency to take “corrective action” if colleges fail to submit the data on time or submit incomplete or inaccurate information.
Under federal law, any violation of these educational data reporting requirements can carry a fine of up to $71,545. Repeated noncompliance can ultimately result in the loss of access to federal student aid, meaning students can no longer use Pell Grants or federal loans to pay for tuition.
This leaves colleges in a bind. Non-compliance is costly. Meanwhile, compliance can lead to erroneous data that suggests bias and invites further scrutiny.
The order itself runs counter to another goal of the administration. President Trump campaigned on reducing federal red tape and red tape. Still, ACTS represents a significant expansion of college paperwork. The Office of Management and Budget estimates that each institution will spend approximately 200 hours completing the survey this year, a figure that higher education officials say may be an underestimate.
Duncan hopes he can complete the report in less than 200 hours if there are no hiccups when he uploads the data. “If I get errors, it can take twice as long,” she said.
For now, she’s still collecting and cleaning up old student records and waiting to see the results… all before the March 18 deadline.
