These written comments are in response to the U.S. Department of Education’s notice of the Integrated Postsecondary Education Data System (IPEDS) 2013-16 collection (OMB Control Number: 1850-0582), published in the Federal Register on Oct. 2, 2013 and updated on Oct. 23, 2013. The Institute for Higher Education Policy (IHEP) is a nonpartisan, nonprofit organization committed to promoting access to and success in higher education for all students, particularly those who have traditionally been underserved by our postsecondary system. We produce innovative and timely research to inform both policy and practice.
Given IHEP’s contribution to the research community, we recognize the importance of data. Specifically, we recognize that data are key to understanding the challenges facing our postsecondary system, developing policy solutions to address them, and providing relevant and actionable information to consumers, policymakers, and institutions alike. IPEDS is a critical component of our postsecondary data infrastructure, providing detailed data at the institution level to inform institutional improvement efforts, consumer decisions, and to safeguard taxpayer dollars. We applaud the Department’s efforts to improve the outcome reporting within IPEDS, as to capture better data on actual student progression and success. For consistency and usability purposes, we highly recommend that these new outcome measures be reported in a way that allows for the calculation of graduation rates that are analogous to those already reported through the Graduation Rate Survey (GRS). Not only is this alignment essential to create usable, understandable data, but it also will help reduce complexity and reporting burden. Complementary to these specific suggestions about the alignment of the new outcome measures with the GRS survey, we also offer the following recommendations for making the IPEDS collection as useful as possible:
- Disaggregate the outcome measures by credential type, reporting outcomes for bachelor’s-seeking students separately from associate-seeking and certificate-seeking students. Institutions increasingly are offering a diverse array of credentials, and aggregating outcomes across these programs of differing lengths could create misleading results.
- Include better information on transfer, including whether students transfer upward (e.g. two-year to four-year), laterally (e.g. two-year to two-year), or in reverse (e.g. four-year to two-year). This distinction will provide a far more robust understanding of student movement throughout the postsecondary system.
- Minimize reporting burden and maximize usability by aligning the new outcome measures as closely as possible with the existing Graduation Rate Survey (GRS). Using slightly different definitions for the outcome measures than for the GRS likely will add complexity and decrease usability.
- Require institutions to report graduation rates by financial aid status to IPEDS. While institutions are required to disclose these data upon request, they are not widely available or accessible in a central location.
- Require institutions to report graduation rates by military status to IPEDS. Institution-level data on the success rates of service men and women are unavailable, and IPEDS is the best tool available to collect this information.
- Require institutions to report cumulative debt measures to IPEDS. Institutions should report data to IPEDS on cumulative federal debt and cumulative private debt, disaggregated by completion status.