After President Trump issued an August 2025 Presidential Memorandum calling for “greater transparency” in higher education admissions practices, the Department of Education swiftly moved to revamp the IPEDS data collection requirements, stating that “American taxpayers and aspiring college students deserve to know if the institutions they fund and to which they apply are discriminating on the basis of race.”
About a week later, the National Center for Education Statistics issued a proposal to add the “Admissions and Consumer Transparency Supplement (ACTS)” to the IPEDS, with public comments due by October 14, 2025. If finalized, the far-ranging changes would impact the 2025-2026 reporting cycle.
With shifting federal priorities and greater scrutiny around how colleges and universities admit students, institutions must prepare for elevated transparency requirements. Berkshire Associates’ recent webinar, “How to Prepare Your University for More Admissions Transparency Requirements,” offered guidance on the proposed changes and how universities can prepare. Here are some key take-aways for higher education to consider.
If the proposed changes move forward (and they likely will), colleges and universities will need to submit more granular admissions metrics (well beyond traditional summary acceptance rates and demographics) as part of their IPEDS reporting. With an additional federal oversight component, the focus will not simply be on compliance with reporting requirements, but also on ensuring data accuracy and demonstrating defensibility of your admissions practices when audited.
Expect rigorous review of the submitted data during the Trump Administration. College and university reporting teams will want to dig into how the requested data is captured, cleaned, and reconciled across multiple internal departments. Any discrepancies or missing fields may raise red flags. We also expect the Trump Administration to analyze the submitted data for evidence of race-based admissions practices, so ensuring data accuracy takes on greater importance.
Next step: Convene a cross-functional team (Admissions, Institutional Research, IT, Compliance) to map current data flows, identify gaps, and plan enhancements to data validation, QA, and reconciliation processes. Begin creating the policies and processes for compiling, and submitting, the proposed data.
Given the heightened scrutiny, higher education institutions must be able to clearly articulate the decision rules that underlie their admissions models. If regulators challenge why patterns exist or certain students were accepted or rejected, the institution should be able to show a documented, consistent approach rather than relying on ad hoc judgments.
To manage these challenges, higher education institutions should consider documenting admissions rubrics, ensure consistent application across years and reviewers, and avoiding hidden proxies or ambiguous criteria (which could be interpreted as proxies for protected classes).
Next step: Review your admissions rubric, scorecards, reviewer guidelines, and decision protocols. Where criteria are subjective, incorporate checks or review processes. Document any discretionary adjustments and rationale.
Transparency is not just about the final class profile — it spans the full admissions funnel: from initial outreach and recruitment, waitlist practices, deferrals, and transfer admissions. Institutions should think holistically about how applicants enter, move through, and exit the admissions process, and to capture data accordingly.
For example, if you use early decision, legacy weighting, demonstrated interest, or holistic assessments, you should track how those features affect applicant flow and outcomes. Waiting-list movement and transfer admissions rules should also be documented and subjected to scrutiny.
Next step: Map every stage of your admissions funnel. For each stage, define the data you collect (and should collect), the decisions made (and by whom), and how those decisions are tracked/documented and reconciled back to final enrollment.
Colleges and universities would be wise to consider evaluating the data they are submitting before providing it to the government. Organizations will obviously want to confirm the accuracy of reported data. But just as important is understanding what the data says about an organization’s admissions practices.
Higher education institutions should develop internal controls around admissions analytics, modeling, and reporting. If your admissions model changes from year to year, those changes should be documented and justifiable.
Next step: Establish a clear process for IPEDS/ACTS admissions data collection, compilation, and proactive analytics.
Given the Trump Administration’s oversight of higher education admissions practices, particularly where DEI (diversity, equity, inclusion) is involved, institutions may face investigations/audits, inquiries, media scrutiny, and political pressure. To manage this risk, higher education institutions should be ready to explain their admissions policies in plain language to prospective students, trustees, regulators, and the media.
Next step: Develop a communications plan. Prepare a narrative document (1–2 pages) for external audiences describing your admissions philosophy, high-level criteria, guardrails, and commitment to fairness for all applicants. Use that as a communications baseline when inquiries arise.
The governance and reporting expectations around admissions are shifting decisively. Colleges and universities that proactively invest in data integrity, well-documented decision frameworks, strong analytics modeling and governance, and transparent communication will be best positioned to weather external audits, regulatory scrutiny, and public expectations.