Voices from the Field: How ACTS Compliance Strained Student Supports at the University of Findlay

Kristen Lindsay is the Director of Institutional Research (IR) and Assessment, and the sole dedicated IR professional, at the University of Findlay (UF). In late 2025, when the Department of Education launched the Admissions and Consumer Transparency Supplement (ACTS) data collection, she was forced to pivot projects and navigate its chaotic rollout and devote less time to vital student services. The rollout of ACTS, a supplement to the Integrated Postsecondary Education Data System (IPEDS), has sparked concern from researchers and practitioners alike.

ACTS requires institutions to report data on more than 100 new questions about undergraduate admissions, financial aid, and student outcomes in addition to new reporting on graduate programs. Institutions were initially given roughly three months to complete reporting or face noncompliance penalties including fines of up to $70,000 and loss of federal student aid eligibility. A report from the Association for Institutional Research found that more than 9 in 10 institutions faced staffing capacity and workload constraints because of ACTS. Ever evolving submission guidance, institutional data availability, and technical limitations made the submission exceedingly burdensome and complicated.

IHEP recently spoke with Lindsay to learn more about how the rushed ACTS collection affected campus operations and the student experience at UF and raised questions about ACTS data reliability. Our conversation has been edited for clarity.

IHEP: What was most challenging about the ACTS submission?

Lindsay: Two things stand out. The first is the sheer volume of data we were required to submit, including retroactive data going back six years. UF changed our student information system in 2021. Our old data system made tracking down the retroactive data required by ACTS—and matching it to previous IPEDS submissions—incredibly time consuming. Sometimes data were not retained when we transferred systems. When that was the case, we followed available guidance to fill in the gaps.

Second, I have been responsible for submitting IPEDS data for almost eight years, and IPEDS guidance is typically very detailed. ACTS did not have the same level of detail or clarity. In fact, ACTS definitions sometimes conflicted with IPEDS definitions and some guidance changed mid-collection. For example, there was unclear guidance on how to report deferred enrollments, which are handled one way in IPEDS and another in ACTS. That difference alone could lead to enrollment count discrepances.

IHEP: Can you share an example of ACTS guidance that was unclear?

Lindsay: ACTS required institutions to submit information from admissions applications, including unweighted high school GPA. This is problematic for a few reasons. It’s not always obvious whether a high school GPA is weighted or not. And at UF, we don’t collect information on whether a reported GPA is weighted or unweighted, and have no standard practice for recalculating weighted GPAs.

When I spoke with the IPEDS Helpdesk, a support line for institutions, I received conflicting responses. First, I was told to report the GPA as the applicant submitted it regardless of whether it was weighted or unweighted. Later, I was told to report our GPAs as missing data because we did not know whether applicants’ GPAs were weighted or unweighted. This guidance is now also included on the ACTS Frequently Asked Questions page.

Shifting guidance mid-collection does not instill confidence that ACTS data will support apples-to-apples comparisons across institutions. These data could be valuable for both comparisons and higher education research, and I strive to support both of those endeavors with accurate, representative submissions.

IHEP: How did the ACTS data collection impact student services on your campus?

Lindsay: ACTS has had quite a significant impact. Submitting ACTS data was all-consuming, which directly impacted my ability to support student success efforts.

One part of my job is leading assessments, which includes helping students submit coursework artifacts into our repository for general education assessment. These artifacts are crucial to students’ ability to progress in their coursework, and I strive to be as responsive as possible when students or faculty members have challenges with the submission process. The level of effort required for ACTS not only impacted my responsiveness, but it also meant I was unable to devote adequate time to prepare guides for using the new software we rolled out to improve the process.

I also help the student affairs team analyze data from microsurveys, which helps UF keep a real-time pulse on students’ experiences. Because of ACTS submission demands, I could not spend as much time with student affairs colleagues digging into that data and strategizing about improving specific student experiences. In the past, these data have informed staffing decisions and supported budget requests.

IHEP: What should policymakers understand about the impact of ACTS on your institution?

Lindsay: The typical process for updating IPEDS includes field engagement, including with IR professionals, responsible for submitting data via an open comment period. If ACTS followed that usual process, we could have shared questions and concerns about data definitions and ideas for how to clarify guidance before the collection opened. That upfront clarity paired with adequate time to prepare for the submission could have helped one-person IR offices like mine balance the new collection with the parts of our role that directly impact student success.

A federal judge halted the ACTS collection at public colleges and universities in 17 states, and more than 150 private institutions, including those represented by six higher education associations. The lawsuit continues and will have implications for the representativeness of the ACTS data when they are released. On September 11, 2026, the U.S. Department of Education published a Federal Register notice outlining its rationale for the accelerated ACTS implementation timeline.

Photo courtesy of University of Findlay.