Comment Letter on Proposed Changes to IPEDS

Comment Letter on Department of Education Proposed Changes to IPEDS

In late February, the Department of Education proposed changes for the Integrated Postsecondary Education Data System (IPEDS), directing colleges and universities to report DACA recipients under the category of “nonresident,” and report undocumented students without DACA as “Race/ethnicity unknown.” Our comment letter outlines concerns with the proposed guidance and proposes alternative guidance. The letter recommends that institutions are directed to report undocumented students who graduate from U.S. high schools (or have a GED) and are enrolled at U.S. colleges and universities with other domestic immigrant students with respect to their self-reported race and ethnicity.

Update June 29, 2022:

Response Comment on Updated IPEDS

In June, the Department of Education released updated guidance for IPEDS, following our exact recommended language. This will allow institutions to report aggregate demographic information on their “domestic” or “eligible non-citizen” students, including all “students who completed high school or equivalency within the United States and were not on an F-1 visa at the time of high school graduation.” By reporting the demographics of these students, undocumented students and DACA recipients will thus be classified in their respective race and ethnicity categories, generating the accurate and comprehensive information needed to measure enrollment, persistence, and other student success metrics across race/ethnicity lines.