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.