1



## Public Comments Received **During the First 30 -**  **day Comment Period and NCES Responses**  **Comments	related	to Outcome	Measures**  **10 -**  **years Comment	Numbers:		52,	49,	47	&	50**  **Docket:** ED - 2013 - ICCD - 0029 Integrated Postsecondary Education Data S ys tem (IPEDS), Web - Based Collection Sy stem **Comment On:** ED - 2013 - IC CD - 0029 - 0010 Agency Information Collection Activities; Submission to the Office of Management and Budget for Review and Approval; Co mment Request; Integrated Postsecondary Education Data Sy stem (IPEDS) 2013 - 2016 **Document:** ED - 2013 - IC CD - 0029 - 0052 Comment on FR Doc # 2013 - 19107



## Submitter Information **Name:** Anon ym ous **Address:** United States, 

## General Comment I have been a facult y member at a comprehensive urban school and have also been a frequent accreditation visitor. In both my roles, I have seen many

students "stop out" for 4 - 6 y ears for various reasons and th en come back successfull y for th e same or a different degree. These ought to be considered completers. I have also seen half - time students at 5 - ye ar schools complete their degree and go on to robust careers. I would advocate a 10 - year period for completion, or at least a 10 - year completion period specificall y for 5 - ye ar schools. This will best capture the variet y and success of American Higher Education. **Docket:** ED - 2013 - ICCD - 0029 Integrated Postsecondary Education Data S ys tem (IPEDS), Web - Based Collection Sy stem **Comment On:** ED - 2013 - IC CD - 0029 - 0010 Agency Information Collection Activities; Submission to the Office of Management and Budget for Review and Approval; Comment Request; Integrated Postsecondary Education Data Sy stem (IPEDS) 2013 - 2016 **Document:** ED - 2013 - IC CD - 0029 - 0049 Comment on FR Doc # 2013 - 19107



## Submitter Information **N am**  **e:** Anon ym ous **Address:** United States, 

## General Comment2

I feel badly

for those community

colleges that say

they will have a great reporting burden, but I also think it is shame if students like me get lost in the shuffle. Before I completed m y undergraduate degree, I took a number of ye ars “off” of my program for a unique, non - credit study abroad program followed by a research stint in the U.S. I also was sidetracked pursuing a major that I found wasn’t right for me. When all was said and done, it was around ten ye ars by the time Igot m y B.A. I went on to successfull y achieve my master’s as well. Iknow others like me, and I think it is short - sighted not to figure out a way to capture our successes. Has an yone considered the possibility of looking at 10 y e ar graduation rates as an alternative to, or in addition to, the 8 y ears proposed here? **Docket:** ED - 2013 - ICCD - 0029 Integrated Postsecondary Education Data S ys tem (IPEDS), Web - Based Collection Sy stem **Comment On:** ED - 2013 - IC CD - 0029 - 0010 Agency Information Collection Activities; Submission to the Office of Management and Budget for Review and Approval; Comment Request; Integrated Postsecondary Education Data Sy stem (IPEDS) 2013 - 2016 **Document:** ED - 2013 - IC CD - 0029 - 0047 Comment on FR Doc # 2013 - 19107



## Submitter In **formation Name:**  anon ym ous **Address:** United States, 

## General Comment I see that man y community colleges have an issue with the 8 y ear cohort and think a 6 y ear cohort would better suit the community college sector. While Ican’t comment on that, I understan d their concern that it does not make sense to have a “one size fits all” approach. I would suggest that an 8 year cohort does not work for all BA programs either. Not all bachelor degree programs fit into the cookie cutter mold and are 4 y ear programs. Th ere are five ye ar bachelor’s programs as well. If the goal is to have an accurate portray al of students who finish their degree, the cohort should be equall y reflective of all institutions. I assume that the 8 year cohort is being proposed because it repre sents 200% of the 4 y ear BA. This makes sense for 4 ye ar programs; it allows for part students to be counted and for a student to take a ye ar off and come back and complete his degree. It does not make sense for 5 ye ar bachelors programs. It does not allow the same for the students attending those programs to be counted as completers. I suggest having 3 rates, 6 ye ars for community colleges as they

have requested. 8 y ears for 4 y ear BA programs, and 10 ye ars for 5 y ear BA programs. Alternativel y, just use 2 00% of the degree length. **Docket:** ED - 2013 - ICCD - 0029 Integrated Postsecondary Education Data S ys tem (IPEDS), Web - Based Collection Sy stem **Comment On:** ED - 2013 - IC CD - 0029 - 0010 Agency Information Collection Activities; Submission to the Office of Management and Budget for Review and Approval; Comment Request; Integrated Postsecondary Education Data Sy stem (IPEDS) 2013 - 2016 **Document:** ED - 2013 - IC CD - 0029 - 0050 Comment on FR Doc # 2013 - 191073 

## Submitter Information **Name:** C Jacobowitz **Address:** United States, 

## General **Comment** The effort b y NCES to capture comprehensive student outcomes in regards to degree attainment is laudable, and the proposed methodology is an important step forward. However, the bottom line is students, parents, the media, government and other stak eholders often focus primarily on the “graduation rate” as a key

indicator of institutional effectiveness. As such, a comprehensive overview of completion rates should be structured in a manner that assures that all completions can be captured accurately . Focusing on the 8 - ye ar outcomes of an entering student cohort does not allow for capture of all student outcomes. It is crucial to separate the consequences of students’ personal choice from those factors that reflect a higher level of institutional control. Students take time off in the midst of their educational programs for many reasons such as volunteer service; for non - credit y ear abroad; because they run out of money

and must work in order to afford additional tuition and living expenses; and to ful fill family obligations, including raising children, caring for elderl y parents, and supporting a spouse’s education or career development. Students’ need to “stop out” of college for several ye ars should not be counted against institutions in weighing the ir relative success in regards to student completion. This is especially important in light of the fact that students from disadvantaged backgrounds are more likely to need to “stop out” due to financial constraints, work schedules, or family obligations. These students may not graduate within the 8 ye ar time frame due to time lost to “stopping out.” thereby unfairl y skewing the completion rates of those institutions that outreach to the population that student aid targets for assistance. The most accurate way

to weight for “factors beyond the institution’s control” is to develop a method for counting onl y actual time in college. Once a student “stops out” of school and then subsequently returns

– he no longer belongs in his original cohort; rather he belon gs in a later cohort that reflects the gap during which he was not in school. IPEDS alread y allows for some adjustment of cohorts based on military service or other limited factors; we suggest expanding this allowance to include any student who stops out and then returns to school. We further suggest that this method be allowed but not required of all schools, as some institutions may find the burden of managing such movement between cohorts to be excessive, while many others will appreciate the chance to demonstrate accurate completion rates for their students. A simpler way

of ensuring the capture of completions on students who “stop out” would be to assess completion rates on cohorts after 10 ye ars, instead of 8 y ears. This would also have the advanta ge of addressing another issue

– students who attend five - year bachelor’s programs on a part - time basis will only complete their degree in 10 y ears, and these completions are not captured b y the proposed 8 - year cut - off. 

### RESPONSE: Dear C Jacobowitz et al., Thank y ou for y our comments submitted during the 30 - day review process, responding to a request for comments on proposed changes to the Department of Education’s Integrated Postsecondary Education4

Data Sy stem (IPEDS) published in the Federal Register. The National Center for Education Statistics (NCES) appreciates your interest in IPEDS. The Paperwork Reduction Act (PRA) provides an opportunity

for an open and public comment period where comments on collections can be made. The Outcome Measures component represents a new collection for I PEDS and the postsecondary education community . During its multiy ear development process , the Department of Educat ion established committees and Technical Review P anels comprised of industry representatives. The cr eation of a single output measure for postsecondary education has great value to institutions of higher education for institutional research and improvement, prospective students and their families for decision - making about postsecondary

education, and pol icy

makers for guiding efforts to improve student outcomes and success in higher education . I t is true that this outcome measure will not allow for 200% of a 5 - ye ar bachelor degree program, but this measure is not intended to represent 200% of normal time to any particular kind of award. Instead, the TRP was quite adamant that this new measure simply reflect student cohort statu s at a particular point in time . The 8 - year point in time represents a balance between collecting as many awards as possible while keeping the length of time elapsed to a minimum. Based on input from the postsecondary community

and that of policy

makers, NCES will propose to add a column to allow for the accounting of the number of awards granted 6 - ye ars after matriculation , and then again at 8 - ye ars. To keep burden low, both the 6 - ye ar and 8 - ye ar counts will be collected at 8 - ye ars. NCES will continue to study the utility

of the new OM component of IPED S . Sincerel y Yours, Richard J. Reeves Program Director Postsecondary Institutional Studies Program 

### Comments	related	to **Outcome	Measures 6	year**  **Comment	Numbers:		41,	40,	39,	37,	36,	35,	34,	33,	32,	31,	30,	28,	27,	26,	25,	24, 23,	22,	21	&	20**  **Docket:** ED - 2013 - ICCD - 0029 Integrated Postsecondary Education Data S ys tem (IPEDS), Web - Based Collection Sy stem **Comment On:** ED - 2013 - IC CD - 0029 - 0010 Agency Information Collection Activities; Submission to the Office of Management and Budget for Review and Approval; Comment Request; Integrated Postsecondary Education Data Sy stem (IP EDS) 2013 - 2016 **Document:** ED - 2013 - IC CD - 0029 - 0041 Comment on FR Doc # 2013 - 19107 **Submitter Information Name:**  Troy

Vermeer **General Comment** Department of Education Staff: I encourage the use of a 6 - ye ar cohort vs. an 8 - ye ar cohort for future IPEDS collections. As a community college stakeholder I find the 6 - ye ar rate far more useful given that few students graduate after six y ears. And as an IPEDS Key

holder I would find data collection for a 6 - year cohort much easier than for 8 - year.5

Finally , using a 6 - ye ar coh ort accords with other research endeavors such as Voluntary Framework for Accountability

and National Community College Benchmark Project. Thanks for y our time. **Docket:** ED - 2013 - ICCD - 0029 Integrated Postsecondary Education Data S ys tem (IPEDS), Web - Based Collection Sy stem **Comment On:** ED - 2013 - IC CD - 0029 - 0010 Agency Information Collection Activities; Submission to the Office of Management and Budget for Review and Approval; Comment Request; Integrated Postsecondary Education Data Sy stem (IPEDS) 2013 - 2016 **Docu ment:**  ED - 2013 - IC CD - 0029 - 0040 Comment on FR Doc # 2013 - 19107 **Submitter Information Name:**  Anon ym ous **Address:** United States, **General Comment** Our community

college has a rather extensive part - time student population, I urge y ou to consider a six ye ar rather than the proposed eight - year timeframe. A six - year c ycl e would be more appropriate and would align with VFA guidelines and other voluntary benchmarking reports (such as the National Community

College Benchmark Project.). The proposed eight - year model shoul d only appl y to four - ye ar institutions or none at all if the goal is a single standard. An ything more than six years is a waste of resources and overl y burdensome on reporting institutions, in my opinion. Thank y ou. **Docket:** ED - 2013 - ICCD - 0029 Integrated Postsecondary Education Data S ys tem (IPEDS), Web - Based Collection Sy stem **Comment On:** ED - 2013 - IC CD - 0029 - 0010 Agency Information Collection Activities; Submission to the Office of Management and Budget for Review and Approval; Comment Request; Integrated Pos tsecondary Education Data Sy stem (IPEDS) 2013 - 2016 **Document:** ED - 2013 - IC CD - 0029 - 0039 Comment on FR Doc # 2013 - 19107 **Submitter Information Name:**  Todd Schwarz **Address:** United States, **General Comment** In response to the Dear Colleague communique of August 30, each of the three Idaho community colleges were consulted. The unanimous response was in favor of keeping IPEDS reporting cohorts consistent with the VFA 6 - year cohort. Below you will find the separate institutional responses from each of the three school s: College of Southern Idaho Twin Falls, Idaho The College of Southern Idaho (CSI) is concerned that a number of existing outcome measures for higher education do not accurately represent the outcomes for community college students. Because of this6

concer n, CSI is investing time and resources to help develop better measures and outcome data through the Voluntary

Framework of Accountability (VFA) data s ys tem. We are encouraged that the new IPEDS Outcome Measures generally align with the VFA sy stem, with one notable exception: the eight - ye ar cohort model is not well - suited to the community college student population. Furthermore, it runs counter to the current VFA efforts with the six - ye ar cohort model that have been developed and adopted b y leading community college researchers across the country . We respectfully request that y ou utilize a six ye ar cohort model for the community college student outcomes. College of Western Idaho Nampa, Idaho The College of Western Idaho is in support of the proposal to align IPEDS Measures with the VFA. As yo u are aware, the three community colleges including CWIare participating in the VFA process. Although CWIis in favor of the alignment, as a two y ear institution, we would not be supportive of an eight ye ar cohort but wo uld support maintaining the direction of the VFA which includes a two ye ar and six year cohort. We believe that an eight ye ar cohort would place an added burden on the institutions and would compromise the beta group work that has been and is underway by the VFA. Thank you for the opportunity

to provide this input and let us know if y ou require any thing else related to this subject. North Idaho College Coeur d’Alene, Idaho I am a Director of Institutional Effectiveness at a 2 - ye ar public community college and support the efforts to add an outcome measures component to IPEDS data collection but would suggest that a six - ye ar cohort be used for community

colleges. Our institution is participating in the Voluntary Framework of Accountability

(VFA) beta testing and they have chosen to follow the student for six y ears instead of eight ye ars. I trust the work that has gone into the development of the VFA and support their design choices. Todd Schwarz, Ph.D . Administrator Id aho Division of Professional - Technical Education **Docket:** ED - 2013 - ICCD - 0029 Integrated Postsecondary Education Data S ys tem (IPEDS), Web - Based Collection Sy stem **Comment On:** ED - 2013 - IC CD - 0029 - 0010 Agency Information Collection Activities; Submission to the Office of Management and Budget for Re view and Approval; Comment Request; Integrated Postsecondary Education Data Sy stem (IPEDS) 2013 - 2016 **Document:** ED - 2013 - IC CD - 0029 - 0037 Comment on FR Doc # 2013 - 19107 **Submitter Information Name:**  Anon ym ous **Address:** United States, **General Comment** In cluding the new Outcomes Measures in the IP EDS data collection is an appropriate next step in this age of greater accountability

for higher education. However, the recommendation to keep the eight - ye ar7

tracking period, regardless of the ty pe of institution, is disa

ppointing to say

the least. Managing a one - size fits all approach is often easier for the owner of the process but it rarel y delivers the intended results. We wouldn’t expect to utilize a one - size fits all approach when it comes to teaching our students or managing our health, in fact it would be frowned upon. Why then, is it acceptable to revert back to a one - size fits all approach when it comes to reporting outcomes metrics for 4 - yr and 2 - yr colleges to IPEDS? We not only

live in an era of greater acc ountability , we live in an era of scare resources and reduced funding. There is an expectation to do more with less. The IPEDS Outcomes Measures and the VFA have the opportunity

to compliment, rather than compete against, each other but only if the eight - y ear timeline is changed to six for community colleges. The eight - ye ar timeline is less meaningful for community colleges and creates undue burden to those colleges already participating in the VFA or those that have state mandates tied to a six - ye ar tracki ng cy cle. Jackson College urges the Department of Education to reverse its decision to pursue the eight - ye ar tracking model for community colleges and go with the six - year tracking approach instead. **Docket:** ED - 2013 - ICCD - 0029 Integrated Postsecondary Edu cation Data S ys tem (IPEDS), Web - Based Collection Sy stem **Comment On:** ED - 2013 - IC CD - 0029 - 0010 Agency Information Collection Activities; Submission to the Office of Management and Budget for Review and Approval; Comment Request; Integrated Postsecondary Educat ion Data Sy stem (IPEDS) 2013 - 2016 **Document:** ED - 2013 - IC CD - 0029 - 0036 Comment on FR Doc # 2013 - 19107 **Submitter Information Name:**  Anon ym ous **Address:** United States, **General Comment** While Iappreciate that extended tracking time will benefit two - year schools, like mine, that have large part - time student populations, Iurge y ou to consider a six - ye ar collection timeframe rather than the proposed eight - ye ar timeframe. A six - ye ar cy cle would be more appropriate to existing practices within our field and would align with VFA guidelines and other voluntary benchmarking reports (such as the National Community

College Benchmark Project.). Thank y ou. **Docket:** ED - 2013 - ICCD - 0029 Integrated Postsecondary Education Data S ys tem (IPEDS), Web - Based Collection Sy stem **Comment O n:**  ED - 2013 - IC CD - 0029 - 0010 Agency Information Collection Activities; Submission to the Office of Management and Budget for Review and Approval; Comment Request; Integrated Postsecondary Education Data Sy stem (IPEDS) 2013 - 2016 **Document:** ED - 2013 - IC CD - 0029 - 003 5 Comment on FR Doc # 2013 - 191078 **Submitter Information Name:**  Victoria Ichungwa **General Comment** Thank y ou for y our invaluable work in the proposed I PEDS Outcome Measures. I believe that the two ye ar communit y colleges would reall y benefit and appreciate your review of the 8 year cohort recommendattion. The Voluntary Framework of Accountability (VFA) is one comprehensive national accountability

s ys tem created for community colleges as a communit y college measure of effectiveness. The VFA framework utilizes the 6 y ear cohort and maintaining this consistency is vital in adequately measuring the unique mi ssion of community colleges. Thank y ou and we hope that y ou will reconsider your recommendation of 8 y ear cohort and select the 6 ye ar cohort instead. **Docket:** ED - 2013 - ICCD - 0029 Integrated Postsecondary Education Data S ys tem (IPEDS), Web - Based Collection Sy stem **Comment On:** ED - 2013 - IC CD - 0029 - 0010 Agency Information Collection Activities; Submission to the Office of Management and Budget for Review and Approval; Comment Request; Integrated Postsecondary Education Data Sy stem (IPEDS) 2013 - 2016 **Document:** ED - 2 013 - IC CD - 0029 - 0034 Comment on FR Doc # 2013 - 19107 **Submitter Information Name:**  Maureen Pettitt **General Comment** While Iapplaud the proposed redesign, I do have a grave concern that the introduction of an eight - year cohort is inappropriate, as noted below, a s well as adding an unnecessary institutional burden for 2 - year colleges. Six - year cohorts are for good reasons more appropriate for predominantly 2 - ye ar degree offering institutions; thus, this metric was selected for the VFA and other national accountabi lity standards. While the eight - ye ar model may be fine for 4 - ye ar institutions, measures focused on traditional 4 - ye ar institution metrics remained largel y useless for the 2 - ye ar sector. I urge the Department of Education to reconsider and select the six - y ear cohort framework instead. **Docket:** ED - 2013 - ICCD - 0029 Integrated Postsecondary Education Data S ys tem (IPEDS), Web - Based Collection Sy stem **Comment On:** ED - 2013 - IC CD - 0029 - 0010 Agency Information Collection Activities; Submission to the Office of Manageme nt and Budget for Review and Approval; Comment Request; Integrated Postsecondary Education Data Sy stem (IPEDS) 2013 - 2016 **Document:** ED - 2013 - IC CD - 0029 - 0033 Comment on FR Doc # 2013 - 19107 **Submitter Information Name:**  Nathan Wilson **General Comment**9

The Illinois Community

College Board (ICCB) greatly appreciates the efforts by the Department of Education in the redesign of IPEDS outcome metrics. However, there is concern about utilizing an eight ye ar cohort instead of a six - ye ar cohort in tracking community colleg e credential completion. Tracking community

college completion with the six - ye ar instead of an eight - ye ar cohort allows for alignment between the American Association of Community Colleges (AACC) Voluntary Framework of Accountability

(VFA) and I PEDS. A number of Illinois community colleges participate in VFA and the initiative continues to gain momentum nationally due to the metrics accurately reflecting the mission of community

colleges. AACC went through an extensive vetting and pilot process in establish ing the VFA metrics. Please also consider reporting burden and additional cost involved in tracking community college graduates for eight ye ars instead of six. Nathan Wilson Senior Director for Research and Policy Studies Illinois Community

College Board **Docket:** ED - 2013 - ICCD - 0029 Integrated Postsecondary Education Data S ys tem (IPEDS), Web - Based Collection Sy stem **Comment On:** ED - 2013 - IC CD - 0029 - 0010 Agency Information Collection Activities; Submission to the Office of Management and Budget for Review and Ap proval; Comment Request; Integrated Postsecondary Education Data Sy stem (IPEDS) 2013 - 2016 **Document:** ED - 2013 - IC CD - 0029 - 0032 Comment on FR Doc # 2013 - 19107 **Submitter Information Name:**  Kristi Barnett **Address:** United States, **General Comment** Bevill State Community

College is pleased to learn of the redesign with the exception of one aspect, the 8 ye ar cohort for all institutions. An eight - ye ar cohort vs. a six - year cohort adds an unnecessary institutional burden and produces less useful data for community coll eges. The six - ye ar cohort is the standard for 2 ye ar institutions and was even selected as the featured reporting measure by the Voluntary Framework of Accountability . Trying to push for a one size fits all solution seems to defeat the purpose of the redes ign, as many old measures were so focused on traditional 4 - ye ar institutions that they remained largel y useless for the two - ye ar sector. We urge the Department of Education to reconsider and select the six - ye ar cohort framework instead. Two year and four y ear institutions are very different models. They

simply cannot use the same time frames for measurements. It is inappropriate and highlights a lack of understanding of two ye ar colleges. **Docket:** ED - 2013 - ICCD - 0029 Integrated Postsecondary Education Data Sy stem (IPEDS), Web - Based Collection Sy stem **Comment On:** ED - 2013 - IC CD - 0029 - 0010 Agency Information Collection Activities; Submission to the Office of Management and Budget for Review and Approval; Comment Request; Integrated Postsecondary Education Data Sy s tem (IPEDS) 2013 - 201610

**Document:** ED - 2013 - IC CD - 0029 - 0031 Comment on FR Doc # 2013 - 19107 **Submitter Information Name:**  Anon ym ous **Address:** United States, **General Comment** "While the redesign is overdue, I believe that the introduction of an eight - year cohort v s. a six - ye ar cohort adds an unnecessary

institutional burden and produces less useful data. Six - ye ar cohorts are for good reasons more appropriate for predominantl y 2 - ye ar degree offering institutions; that's why this measure was selected for the VFA and other national accountability standards at the first place. Research has shown that the greatest educational return is within the 6 y ear period; that after that time, little more is captured. Trying to push for a one size fits all solution seems to defeat the purpose of the redesign, as many old measures were so focused on traditional 4 - ye ar institutions that they remained largel y useless for the two - ye ar sector. I urge the Department of Education to reconsider and select the six - ye ar cohort framework inste ad. Facilitating the ease of data use at the cost of data usability and comparability

does not make much sense, and requiring community colleges to support y et another ill - designed measure seems wasteful." **Docket:** ED - 2013 - ICCD - 0029 Integrated Postsecondary Education Data S ys tem (IPEDS), Web - Based Collection Sy stem **Comment On:** ED - 2013 - IC CD - 0029 - 0010 Agency Information Collection Activities; Submission to the Office of Management and Budget for Review and Approval; Comment Request; Integrated Postsecondary Education Data Sy stem (IPEDS) 2013 - 2016 **Document:** ED - 2013 - IC CD - 0029 - 0030 Comment on FR Doc # 2013 - 19107 **Submitter Information Name:**  Todd Carter **Address:** Li beral, KS , 67901 **Email:** todd.carter@sccc.edu **Submitter's Representative:** Todd Carter **Organization:** Se ward County Community

College and Area Technical School **General Comment** Seward County

Community

College and Area Technical School believes that an eight - ye ar cohort adds an unnecessary

institutional reporting burden and results in less useful data. Six - year cohorts are more appropriate for 2 - ye ar degree offering institutions which is why the measure was selected for the Voluntary

Framework of Accountability . We urge the Department of Education to reconsider and select the six - year cohort framework. R equiring community colleges to support a measure that has no practical value for improvement of student learning and quality improvement of the institution is not a responsible use of public resources. **Docket:** ED - 2013 - ICCD - 0029 Integrated Postsecondary E ducation Data S ys tem (IPEDS), Web - Based Collection Sy stem11

**Comment On:** ED - 2013 - IC CD - 0029 - 0010 Agency Information Collection Activities; Submission to the Office of Management and Budget for Review and Approval; Comment Request; Integrated Postsecondary Education Data Sy stem (IPEDS) 2013 - 2016 **Document:** ED - 2013 - IC CD - 0029 - 0028 Comment on FR Doc # 2013 - 19107 **Submitter Information Name:**  Brad Eldredge **Address:** Kalispell, MT , 59901 **Email:** beldredge@fvcc.edu **General Comment** While Iam pleased that the department is redesigning the IPEDS data set, I would urge that the proposed eight - ye ar graduation cohort be replaced with a six - year cohort for community colleges. Man y Community

Colleges, including Flathead Valley Community

College, are participating in AACC's Vol untary

Framework of Accountability . After careful thought, AACC determined that a six - ye ar cohort was most appropriate for measuring community college students' outcomes. Creating a separate eight - ye ar cohort for IPEDS would amount to a significant additio nal compliance burden. Our experience is that very few students who haven't graduated or transferred in six - ye ars will go on to graduate and/or transfer in eight - ye ars. Thank yo u for your consideration. **Docket:** ED - 2013 - ICCD - 0029 Integrated Postsecondary Education Data S ys tem (IPEDS), Web - Based Collection Sy stem **Comment On:** ED - 2013 - IC CD - 0029 - 0010 Agency Information Collection Activities; Submission to the Office of Management and Budget for Review and Approval; Comment Request; Integrated Postsecondary Edu cation Data Sy stem (IPEDS) 2013 - 2016 **Document:** ED - 2013 - IC CD - 0029 - 0027 Comment on FR Doc # 2013 - 19107 **Submitter Information Name:**  Kent Phillippe **Address:** Washington, DC, 20036 **Email:** kphillippe@aacc.nche.edu **General Comment** On behalf of AACC, and the more than 1,100 colleges we represent, I would like to thank the department for reviewing and responding in a thoughtful manner to the last round of comments submitted on the IPEDS redesign. However, I was disappointed to see the recommendation to keep the 8 - y ear cohort for all institutions, regardless of the t ype of institution for the Outcome Measures (OM) section of the redesign. This one - size fits all approach is in direct conflict with the purpose of the redesign

— creating measures that are more appropriate to the institutions. In particular I disagree with one of the statements in the response “This was done to keep the burden to12

respondents low and to facilitate ease of use b y data users.” The 8 - ye ar cohort for colleges already reporting on a 6 - ye ar coho rt for accountability purposes does not decrease burden

— rather it increases burden. It will also add to confusion in the use of data, when national data and state data will not agree with Federal data due to unwillingness for the Federal data collection to follow widely accepted data procedures in outcomes reporting for community colleges. Right now more than 160 community colleges are reporting 6 - ye ar outcome data as part of the Voluntary Framework of Accountability beta testing phase, and all California c ommunity colleges have publically

available data using a six - ye ar cohort. In addition, the argument that “If the Outcomes Measures section allowed for different durations to degree by t ype of institutions, we had difficult y reconciling how to explain the impetus for giving a student seeking the same award different amounts of time based on the institutional ty pe” is not a valid argument. The measures are not about time to earn specific award t ypes, but measures of student outcomes at an institutional level . As such, comparing a community college and a four - ye ar college on the same metrics is a flawed perception even with similar times for the cohort. There are a lot of variables that impact these measures, and time allowed to earn an award is only one of th em. Other equally important factors are: the number of credits required for the award; the attendance patterns of the students at the institution; the credits earned prior to entry ; and the distribution of the levels of awards given in the institution. The cohort time is more about what is meaningful to the institution for accountability purposes, and for community

colleges the 6 - ye ar cohort is the meaningful time frame. It provides enough time for most students to attain an outcome while providing data that is timely enough for policy

and decision making. AACC strongl y urges NCES to use a 6 - ye ar cohort for community colleges in the new Outcome Measures of I PEDS. Kent A. Phillippe Associate Vice President for Research and Student Success American Associat ion of Community Colleges **Docket:** ED - 2013 - ICCD - 0029 Integrated Postsecondary Education Data S ys tem (IPEDS), Web - Based Collection Sy stem **Comment On:** ED - 2013 - IC CD - 0029 - 0010 Agency Information Collection Activities; Submission to the Office of Management and Budget for Review and Approval; Comment Request; Integrated Postsecondary Education Data Sy stem (IPEDS) 2013 - 2016 **Document:** ED - 2013 - IC CD - 0029 - 0026 Comment on FR Doc # 2013 - 19107 **Submitter Information Name:**  Lo ri Sundberg **Address:** Galesburg, IL , 61401 **Email:** lsundberg@sandburg.edu **General Comment** Carl Sandburg College, a two y ear communit y college in Galesburg, Il linois would like to comment on the proposed eight ye ar cohort being proposed. This will be a burden for community colleges and for other two year colleges and will provide little useful data. The six - ye ar cohort framework is more appropriate which is wh y the Voluntary Framework for Accountability (VFA) identified a six y ear13

benchmark as the more appropriate benchmark for 2 - ye ar degree offering institutions. We urge the Department of Education to reconsider and select the six - year cohort framework instead. **Docket:** ED - 2013 - ICCD - 0029 Integrated Postsecondary Education Data S ys tem (IPEDS), Web - Based Collection Sy stem **Comment On:** ED - 2013 - IC CD - 0029 - 0010 Agency Information Collection Activities; Submission to the Office of Management and Budget for Review and Approval; Comment Request; Integrated Postsecondary Education Data Sy stem (IPEDS) 2013 - 2016 **Document:** ED - 2013 - IC CD - 0029 - 0025 Comment on FR Doc # 2013 - 19107 **Submitter Information Name:**  Joseph Baumann **General Comment** Aligning metrics across IPEDS, VFA, etc., is not only a good practice at the national level, it is the only way that an institution can be effective - we cannot serve our students and the public if we are faced with a barrage of performance metrics that are subtl y different. That said, I do not believe that IPEDS should change to tracking completion among student cohorts for eight ye ars rather than the six years tracked b y the VFA and other state - level metrics. It would add to the reporting burden for community colleges and would not add value over and above the six - ye ar tracking that is alread y being done. **Docket:** ED - 2013 - ICCD - 0029 Integrated Postsecondary Education Data S ys tem (IPE DS), Web - Based Collection Sy stem **Comment On:** ED - 2013 - IC CD - 0029 - 0010 Agency Information Collection Activities; Submission to the Office of Management and Budget for Review and Approval; Comment Request; Integrated Postsecondary Education Data Sy stem (IPEDS) 2013 - 2016 **Document:** ED - 2013 - IC CD - 0029 - 0024 Comment on FR Doc # 2013 - 19107 **Submitter Information Name:**  Anon ym ous **Address:** United States, **General Comment** I appreciate most of the changes made in the redesign. However, as an employ ee at a community college, I am concerned about the choice of an eight - ye ar cohort vs. a six - year cohort. Many community colleges have adopted the Voluntary Framework of Accountabi lity , which uses a six - year cohort. Thus, the new IPEDS cohort places an additional collection and reporting burden on these colleges. Additionally , my state (North Carolina) has instituted a six - year cohort for state communit y college reporting, largel y a s a result of 'best practices' for community colleges suggested by

the VFA, AACC, and others. I strongl y recommend that two - ye ar colleges be allowed to use a six - year cohort in IPEDS, rather than forcing them into an eight - ye ar one. The eight - year one not only creates additional work for the colleges, but results in14

data that is not comparable with most other measures of student outcomes in community colleges. Essentially , it would be wasted effort that wouldn't lead to institutional improvements. **Docket :**  ED - 2013 - ICCD - 0029 Integrated Postsecondary Education Data S ys tem (IPEDS), Web - Based Collection Sy stem **Comment On:** ED - 2013 - IC CD - 0029 - 0010 Agency Information Collection Activities; Submission to the Office of Management and Budget for Review and Approval; Comment Request; Integrated Postsecondary Education Data Sy stem (IPEDS) 2013 - 2016 **Document:** ED - 2013 - IC CD - 0029 - 0023 Comment on FR Doc # 2013 - 19107 **Submitter Information Name:**  Lisa Smith **Address:** United States, **General Comment** Thank y ou for y our work and intent in making data as useful as possible while keeping the burden low for reporting parties. I would like to request a change to your recommendation of using an 8 - year cohort for community colleges. A 6 - ye ar cohort is a more meaningful time frame for c ommunit y colleges and is more commonly

used alread y i n measurements. For example, the American Association of Community Colleges' Voluntary

Framework of Accountability (VFA) uses the 6 - ye ar cohort, and a number of institutions are alread y participating in this collection, even though the VFA is still in the beta - testing phase, because we believe in the intent of the VFA and think the data will be meaningful. It is beneficial to keep data collection methods and definitions as consistent as possible for insti tutions of a given institution ty

pe (community

colleges vs. universities) to reduce public confusion of the meaning of data. Community

colleges and universities differ in many way s (length of time to completion being one of the most notable way s), and a si ngle time frame for measuring this is not very useful or meaningful because the institution ty

pes are not comparable in this aspect. A 6 - ye ar cohort also allows data to be available sooner for community

college leadership so they can make decisions that ar e based on more recent data. Please consider using separate cohort lengths for community colleges and universities. **Docket:** ED - 2013 - ICCD - 0029 Integrated Postsecondary Education Data S ys tem (IPEDS), Web - Based Collection Sy stem **Comment On:** ED - 2013 - IC CD - 0 029 - 0010 Agency Information Collection Activities; Submission to the Office of Management and Budget for Review and Approval; Comment Request; Integrated Postsecondary Education Data Sy stem (IPEDS) 2013 - 2016 **Document:** ED - 2013 - IC CD - 0029 - 0022 Comment on FR D oc # 2013 - 19107 **Submitter Information Name:**  Anon ym ous15 **General Comment** I am a Director of Institutional Research at a 2 - ye ar public community college, and would like to express my support and agreement with the following well - articulated comment submitted b y a colleague in the field: "While the redesign is overdue, Polk State College and the Association of Florida Colleges (AFC) believe that the introduction of an eight - ye ar cohort vs. a six - ye ar cohort adds an unnecessary institutional burden and produces less useful data. Six - year cohorts are for good reasons more appropriate for predominantly 2 - ye ar degree offering institutions; that's why this measure was selected for the VFA and other national accountability

standards at the first place. Trying to push for a one size fits all solution seems to defeat the purpose of the redesign, as many old measures were so focused on traditional 4 - ye ar institutions that they remained largel y useless for the two - ye ar sector. We urge the Department of Education to reconsi der and select the six - ye ar cohort framework instead. Facilitating the ease of data use at the cost of data usability and comparability

does not make much sense, and requiring community colleges to support y et another ill - designed measure seems wasteful". In addition, Iwould like to stress the importance of the availability of meaningful and useful IPEDS data for 2 - ye ar institutions. These colleges provide training and education to the vast majority of the skilled workforce, and the VFA measures have come into existence to pro - activel y establish accountability measures for these institutions. The proposed IPEDS redesign to report completion on an eight - ye ar cohort undermines the work that has been done by the VFA and will weaken the research on two - year in stitutions by

forcing researchers to choose between two discrepant data sources for completion measures. Please also consider how the data will best serve the needs of a broad range of stakeholders invested in meeting the workforce demands, and in improvin g student success. Thank y ou for y our consideration and y our review of this most important topic. Respectfully

submitted, **Docket:** ED - 2013 - ICCD - 0029 Integrated Postsecondary Education Data S ys tem (IPEDS), Web - Based Collection Sy stem **Comment On:** ED - 2013 - I CCD - 0029 - 0010 Agency Information Collection Activities; Submission to the Office of Management and Budget for Review and Approval; Comment Request; Integrated Postsecondary Education Data Sy stem (IPEDS) 2013 - 2016 **Document:** ED - 2013 - IC CD - 0029 - 0021 Comment on FR Doc # 2013 - 19107 **Submitter Information Name:**  Laura Massell **Address:** Winooski, VT , 05404 **Email:** lmassell@uvm.edu **General Comment** I believe the eight - year cohort vs. a six - year cohort time frame adds an unnecessary institutional burden and produces less useful data. Six - year cohorts provide appropriate measures for both 4 - ye ar and for predominantly

2 - year degree offering institutions ; hence the selection of this measure for VFA and other national accountability

standards. I urge the Department of Education to reconsider and select the six - ye ar16

cohort framework instead. Doing so would facilitate the meaningful use, high value, and appropriate burden to cost ratio we should be aiming for in our commitment to continuous improvement in US Higher Education. **Docket:** ED - 2013 - ICCD - 0029 Integrated Postsecondary Education Data S ys tem (IPEDS), Web - Based Collection Sy stem **Comment On:** ED - 2013 - IC CD - 0029 - 0010 Agency Information Collection Activities; Submission to the Office of Management and Budget for Review and Approval; Comment Request; Integrated Postsecondary Education Data Sy stem (IPEDS) 2013 - 2016 **Document:** ED - 2013 - IC CD - 0029 - 0020 Comment on FR Doc # 2013 - 19107 **Submitter Information Name:**  Peter Usinger **Address:** United States, **General Comment** While the redesign is overdue, Polk State College and the Association of Florida Colleges (AFC) believe that the introduction of an eight - ye ar cohort vs . a six - ye ar cohort adds an unnecessary institutional burden and produces less useful data. Six - year cohorts are for good reasons more appropriate for predominantly 2 - ye ar degree offering institutions; that's why this measure was selected for the VFA and o ther national accountability

standards at the first place. Trying to push for a one size fits all solution seems to defeat the purpose of the redesign, as many old measures were so focused on traditional 4 - ye ar institutions that they remained largel y usele ss for the two - ye ar sector. We urge the Department of Education to reconsider and select the six - ye ar cohort framework instead. Facilitating the ease of data use at the cost of data usability and comparability

does not make much sense, and requiring commun ity colleges to support y et another ill - designed measure seems wasteful. 

### RESPONSE: Dear Mr. Vermeer, Mr . Schwarz, M s. Ichungwa, Ms. Pettitt, Mr. Wilson, Ms. Barnett, Mr. Carter , Mr. Eldredge, Mr. Phillippe, Ms. Sundberg, Mr. Baumann, Ms. Smith, Ms. Massell, Mr. Usinger, et al, Thank y ou for y our comments submitted during the 30 - day review process, responding to a request for comments on proposed changes to the Department of Education’ s Integrated Postsecondary Education Data Sy stem (IPEDS) published in the Federal Register. The National Center for Education Statistics (NCES) appreciates your interest in IPEDS. The Paperwork Reduction Act (PRA) provides an opportunity

for an open and public comment period where comments on collections can be made. The Outcome Measures component represents a new collection for I PEDS and the postsecondary education community . During its multiy ear development process , the Department of Educat ion establ ished committees and Technical Review P anels comprised of industry representatives. Alignment with other measures like the VFA does not directly fit within the Department’s responsibility for this measure. The creation of a single output measure for post secondary education has great value to institutions of higher education for institutional research and improvement, prospective students and their familie s for decision - making about postsecondary education, and policy makers for guiding efforts to improve student outcomes and success in higher education .17

It is common practice for postsecondary education instituti ons to verify the degrees and certificates conferred for their alumni indefinitely . For virtually all institutions completing the OM component of IPEDS, these award records are digitized in a student information sy stem with an award date. It is not clear how extracting historical information at an 8 - ye ar point in time will impose a greater burden than at a 6 - year point in time. Further, the additional 2 years allows for more students, particularl y those attending part - time, to be captured as completers in the OM component. NCES will continue to dedicate itself to better underst and the burden of the OM component and find way s to reduce it. After careful consideration and extensive discussion within the Department and with the AACC, NCES has decided to add a 6 - ye ar reference column in addition to the 8 - year. To keep burden low, both the 6 - ye ar and 8 - ye ar counts will be collected at 8 - ye ar point in time. NCES will continue to study the utility

of the new OM component of IPED S . This change will result in an additional comment period. Sincerel y yours, Richard J. Reeves Program Director Postsecondary

Institutional Studies Program 

### Career	Education	Corporation **Comment	#51 Docket:**  ED - 2013 - ICCD - 0029 Integrated Postsecondary Education Data S ys tem (IPEDS), Web - Based Collection Sy stem **Comment On:** ED - 2013 - IC CD - 0029 - 0010 Agency Information Collection Activities; Submission to the Office of Management and Budget for Review and Approval; Comment Request; Integrated Postsecondary Education Data Sy stem (IPEDS) 2013 - 2016 **Document:** ED - 2013 - IC CD - 0029 - 0051 Comment on FR Doc # 2013 - 19107



## Submitter Information **Name:** Anon ym ous **Address:** United States , 

## Attachments CEC Comment 9 - 9 - 13 Career Education Corporation appreciates having this second opportunity to comment on the proposed changes to the Integrates Postsecondary Data System. As stated in our original comment, while we support the inclusion of all students in the IPEDS database, we do not believe that the Department of Education has the authority to make the proposed modifications to the IPEDS database through the regulatory process . Instead, it remains our belief that the Department should mak e its recommendations to the United States Congress for their consideration during the next reauthorization of the Higher Education Act of 1965 . In the Department’s response to our earlier comment, staff cited Section 153 of the Education Sciences Reform Act of 2002 (P.L . 107 - 279) which authorizes NCES to “collect, report, analyze and disseminate statistical data related to education in the U.S . and other nations.” While it is true that the Education Sciences Reform Act establishes NCES as the entity re sponsible for conducting statistical analyses related to education, the specific elements included in the IPEDS database are clearly defined not in that Act, but instead in18

the Higher Education Act of 1965, as amended, the Civil Rights Act of 1964 and the Carl D . Perkins Vocational Education Act . As such, we believe it is clear that despite the general authorities granted to NCES, Congress has been explicit with respect to IPEDS that it will dictate through legislation the nature of the collection, the st udent population to be included and the data elements to be required and reported to the public. For example, the collection and reporting of race/ethnicity and gender data is established by Title VI of the Civil Rights Act of 1964 (34 CFR 100), in Title I X of the Education Amendments of 1972 (34 CFR 106) and Section 421(a)(1) of the Carl D . Perkins Vocational Education Act . Section 132 of the Higher Education Opportunity Act of 2008 (P.L . 110 - 315) provides an even greater level of specificity regarding information to be collected and made available to consumers by NCES . In this case, statute provides a complete and comprehensive list of data elements to be collected via IPEDS and reported by NCES through College Navigator, and this list appears in the f orm of a full, detailed and exclusive list of data elements . The list is not illustrative of Congressional intent, but is instead explicit in this regard, serving as further evidence that Congress intends to determine the specifics of IPEDS through the le gislative process. During the 2008 HEA reauthorization process, the Secretary of Education sought to make a number of changes to the IPEDS database including the expansion of the IPEDS database to include all students and not just first - time full - time stud ents . This request was explicitly denied by the then leaders of the U.S . House of Representatives Committee on Education and Labor who expressed concern that such significant changes would render useless the earlier information collected by IPEDS for the purpose of monitoring higher education trends over time . These leaders emphasized that any changes to the IPEDS database had to be accomplished via the legislative process and they were purposeful in denying the request to expand the IPEDS database to in clude a larger population of students . In fact, the statute specifically states that IPEDS is to collect information regarding first - time - full - time students, including the new requirement to collect information regarding costs incurred by and financial s upport provided to first - time - full - time students in order to inform the net price calculator . In addition, Title XI, Section 1103 of the Higher Education Opportunity Act specifically requires the Comptroller General of the United States to conduct a study about both the institutional burden of submitting required data to IPEDS as well as the feasibility of collecting additional information within the database, and to submit both an interim and a final report to the relevant authorizing committees . This r eporting requirement further clarifies the intent of Congress to engage the Department of Education and the Comptroller General in conducting a study to inform subsequent legislative debate and decision regarding the expansion of IPEDS . The legislation ne ither instructs of permits the Department of Education to take direct action to implement the recommendations of the Comptroller General or the Department’s Technical Review Panels with regard to expanding the database or adding additional items to the col lection . Therefore, while we are not challenging the general authority of NCES to collect data necessary to analyze and report on education, we are asserting that this general authority does not trump the specific requirements dictated via statute to NCE S with regard to the data elements to be collected via IPEDS and reported to the public, including through College Navigator and the College Scorecard. Is This Collection Necessary to the Proper Functions of the Department? In the August 8, 2013 Federal Re gister solicitation for a second round of comments regarding the continuation and expansion of the IPEDS database, the Department of Education asked if this collection is necessary to the proper functions of the Department . Clearly these additional data elements are not necessary to the proper function of the Department since the Department has managed to administer Title IV programs since 1965 without access to these data . The Department obtains the information it needs to administer the Title IV progr am through the Free Application for Federal Student Aid, institutional Cost of Attendance data, and institutional and programmatic accreditation results . In addition, NCES has a number of tools that it uses routinely to monitor the condition of higher ed ucation more generally, including the Beginning Postsecondary Students (BPS) survey and the National19

Postsecondary Student Aid Study (NPSAS) . As a result, we do not believe that the expansion of IPEDS is necessary either in order for NCES to fulfill its statutory mission or the Department to administer its Title IV programs . It is unfortunate that IPEDS data informs so many public policy debates and decisions given that it excludes the majority of students currently enrolled in postsecondary education . However, Congress has been clear in its legislative prohibition against a federal student unit record data system and in its sole and exclusive authority to expand or modify IPEDS data collection . So while we agree with the Department’s intent, we believ e that the Department must rely upon the legislative process to enact the proposal in law . Will this information be processed and used in a timely manner? The Department received a number of public comments attesting to the challenges that institutions w ill face if the Department moves forward with its currently proposed, retrospective reporting model . It can be extremely challenging to go back in time to create new records, and doing so can require extensive changes to data systems as well as additional data input, which can be costly and time consuming . The Department’s response to these comments was that it would delay the implementation by one year so that institutions could have more time to prepare for these changes and so that the retrospective co llection of data would go back to 2007 rather than 2006 . While we appreciate this small concession on the part of the Department, we continue to believe that the proposal represents a retroactive application of new standards which will require institution s to go back in time to modify potentially tens of thousands of records that were originally created many years ago . Retroactive application of new standards is expressly prohibited by the Administrative Procedure Act . While the Department is quick to p oint to the rising cost of higher education as a barrier to student success, the Department continues to add to those costs rather than working to help contain them . Each time it adds a new reporting requirement, institutions must respond by hiring additi onal staff, modifying existing data systems or implementing new data systems that can track and collect the necessary data . Even more burdensome are regulations that require institutions to go back in time and adjust old records while also collecting add itional information to complete new records . The Department must recognize that for many institutions, these additional reporting requirements for IPEDS come on the heels of significantly expanded reporting requirements that were included in the persisti ng sections of the recently promulgated Gainful Employment regulations . This reporting requirement forced some institutions to make significant changes to their website design and architecture in order to allow for posting of data directly on program page s, which was extremely burdensome in terms of cost and personnel resources . Since the Department seems reticent to eliminate old requirements as it implements new ones, the growing reporting burden coupled with the intensified focus on additional student services to promote higher student outcomes has resulted in a national trend in administrative cost structures that have, or will soon, exceed the cost of instructional delivery . The Department does need to provide institutions time to make the necessar y modifications in their databases, but it must also implement the collection of additional data elements in a **prospective** manner. While it is true that doing so will delay the publication of outcomes data until 2022, given that the Department has failed to provide any evidence that the proposed data elements will influence student decisions in a positive way or improve student outcomes, there appears to be no justification for the additional burden the proposal would impose upon already resource - constrain ed institutions . We believe it is in the best interest of students, institutions , and the Department for the Department to conduct a comprehensive study to determine which data elements are actually of interest and importance to students when selecting an institution of higher education, and which data elements lead to improved student outcomes . It is quite possible that for the growing majority of non - traditional students, information regarding parking availability at campus locations, the ability to co mplete a credential by attending class on the same days and at the same time each semester or online (so that working students can attend without requiring adjustments to their work or childcare schedule every semester), access to required classes and stud ent services in the evening and on weekends and level of faculty “real - world” experience in their field (as opposed to just their academic credentials) may be more relevant than graduation rates since non - traditional students typically understand that thei r overall life demands will likely dictate their academic pace . Besides, data collected on students who enrolled20

in 2007 is likely to have little relevance to a student who enrolls in college in 2015 or 2016 and will graduate in 2022 given how the economy and job market demands are likely to change several times within that 15 year time period . Is the estimate of burden accurate? We believe that the projected time burden underestimates the extra time it will take for institutions to extract new budget an d finance information required for the new Finance Form and Academic Libraries component . We are concerned that the lack of clarity around definitions accompanying the voluntary time burden reporting element in this past year’s survey resulted in inaccura te and inconsistent reporting that likely underestimated the full time burden . Instructions should take into account the varying institutional management structures that exist among institutions, including those that have centralized administrative suppor t functions that serve a number of campuses as opposed to embedding all administrative support functions within each institution . How might the Department enhance the quality, utility and clarity of the information to be collected? It is not uncommon amo ng institutions working to increase their selectivity ranking to admit a substantially different population of students in the Fall cohort as compared to the Spring cohort, and as 1 st time students versus transfer students . This is especially true if the Fall cohort serves as the basis for measurement of institutional selectivity . As a result, the proposal to administer the admissions survey as part of the Winter collection and to include only those students enrolled in the Fall semester could yield infor mation that is misleading and that artificially inflates the selectivity of the institution and the academic qualifications of the students it serves . This schedule also ignores the growing trend for institutions to provide multiple points of entry throug hout an academic year in order to serve the needs of non - traditional students, which may not align with the traditional Fall/Spring academic calendar . With respect to the FASB for For - Profit Finance Form, we believe that all Federal, state and local taxe s paid by all institutions should be captured and recorded as institutional Expenses . The current proposal appears to limit reported tax expenses to income tax expenditures, but proprietary institutions pay a number of taxes in addition to income tax (som e of which, in turn, support subsidies provided to public institutions), and all should be reflected in the reported statement of expenses . Finally, the Department of Education has empirically identified 8 risk factors that serve as significant barriers to student success . These risk factors include: delayed entry to college, student age over 25, financial independence, having dependents, being a single parent, working full - time while attending college, attending part - time, and enrolling in college havi ng not completed a high school diploma . In earlier work, the Department determined the statistical impact of each of these risk factors on student graduation rates and even provided estimates of adjusted outcomes when taking into account the risk factors exhibited by various groups of students . For example, the Department determined that if students have one or more child and graduate at a rate of 49.1%, this is statistically equivalent to a graduation rate of 70.1% among a traditional student population . While the Department did not perform multi - variant analysis, it can be assumed that the rate adjustments would be even greater in order to make fair comparisons of outcomes at institutions serving large numbers of low risk students versus those that serv e a large population of students who have three or more risk factors, which is not uncommon among open - enrollment institutions and those that cater to the needs of working adult students . We believe that in order to enable students make “apples - to - apples ” comparisons of institutional outcomes and to help students better understand their likely outcomes based on the outcomes of other students with the same demographic background and risk characteristics, the Department must transition all of their data col lections to include information about each institution’s student risk profile . Coupling the Department of Education’s work with a recent Department of Labor study (Adult Learners in Higher Education: Barriers to Success, ETA Occasional Paper 2007 - 03) about workforce preparation and adult education, we believe that to make the data NCES collects more meaningful and useful, the Department must include as a required data element a measure of the percentage of students in each cohort that have zero or one of the 8 Department of Education published risk factors (low risk students), two or three of these published risk factors (moderate risk students) and/or three or more risk factors (high risk students) .21

Without adjustments for student risk profile, publi shed outcomes will continue to serve as unsound justification for the shifting of precious federal resources away from the students who need them most (and for whom the Higher Education Act of 1965 was originally written and passed) in order to subsidize m ore affluent and traditional students who have the luxury of attending higher cost, selective institutions . In addition, outcomes taken out of context of the population enrolled will continue to incentivize increased institutional selectivity, which furth er reduces educational access by those who have been underserved in the past . Again, we thank the Department for their efforts to create a more inclusive IPEDS database and for this second opportunity to provide comments, but we encourage the Department to work with the appropriate Congressional committees to make these changes through the appropriate legislative process. 

### R **ESPONSE :**  Dear Career Education Co r poration , Thank y ou for y our comment dated September 9, 2013, responding to a request for comments on the proposed changes to the Department of Education’s Integrated Postsecondary Education Data Sy stem (IPEDS) published in the Federal Register. The National Center for Education Statistics (NCES) appreciates your interest in IPEDS. The Paperwork Reduction Act (PRA) provides an opportunity for an open and public comment period where comments on collections can be made. In addition to administering and monitoring T itle IV programs, the Department (specifically NCES) has the responsibility

of describing the condition of all area of education in the United States , including postsecondary

education ( Education Sciences Reform Act of 2002 ). The Department has these resp onsibilities and others for which the IPEDS collection is used to satisfy . It is true that the HEOA did prohibit development, implementation, or maintenance of a Federal database of personall y identifiable information on individuals (with some exceptions for the tracking of students receiving federal student aid) . However, this does not prevent the addition of aggregate data items to the existing IPEDS data collection. In addition to prescribing specific items to be added to IPEDS, the 2008 HEOA explic itly called for a committee that may , among other things, consider additional or alternative measures of student success. Where specified, IP EDS collects information as directed in statute. However, where information constructs are not specified , NCES and our various data collection contractors utilize a process to establish the most appropriate method to collect the new information. A Technical Review Panel ( TRP ) is often employ ed to inform and advise o ur contractors and, in turn, NCES on several as pects of development of new measurement constructs including but not limited to their utility , limitations, and availability

from postsecondary institutions . In this particular case, a TRP recognized the importance of making this information available as s oon as possible, and therefore suggested that NCES move forward with a retrospective method. This process and the resulting metric do not violate the Administrative Procedures Act. To say that IPEDS does not include the majority of students is not an accurate statement. There are particular items in IPEDS that are limited to full - time, first - time students as specificall y defined in statue , such as institutional average net price from the 2008 HEOA, and the Student Right to Know Act graduation rates collec ted through IPEDS. Conversel y, there are man y other components to IPEDS that are not limited to this student population and have never been limited in such a way . For example, IPEDS collect s data on total enrollments and degrees/certificates awarded to a ll students, not only first - time, full time undergraduate students. Infact, the “Consumer Information” section of the HEOA specifically details that College Navigator must display “The number of certificates, associate degrees, baccalaureate degrees, mast er's degrees, professional degrees, and doctoral degrees awarded by the inst itution.”22

As stated in detail in the response to comments during the 60 - day Federal Register Notice (FRN), NCES is sensitive to reporting burden and discusses this at each TRP. Th e burden of the I PEDS data collection has been and remains a crucial factor in decision making surrounding the collection. NCES is very sensitive to the need to balance increased reporting burden with the utility of the data requested. Each Technical Rev iew Panel meeting, regardless of the topic being discussed, is specificall y charged with the task of minimizing the additional institutional burden as a result of increased I PEDS reporting requirements. Further, entire meetings of the IPEDS Technical Revi ew Panel have been dedicated to the topic of IPEDS reporting burden. TRP #41, Managing Reporting Burden (March 2013) TRP #30 - Tools and Resources for Reducing IPEDS Burden (March 2010) These meetings of the TRP have had a significant impact in how the IPEDS collection is designed and implemented. This is evident in the citations provided in the Supporting Statement Part A. NCES is aware of the careful balance that must be made between the burden of the collection on postsecondary institutions and the value of the information collected for regulatory purposes. Although there is no formal method established for the calculation of burden, NCES has employed the recommended practice of working with respondents to better understand burden and the respondent experience. NCES strives to provide accurate burden estimates based on these interactions and empirical data from the collection sy stems. In response to GAO’s stud y ( http://www.gao.gov/products/GAO - 10 - 871 ), IPEDS added the question at the end of each survey component about the amount of time it took to complete, and burden estimates wi ll be adjusted accordingl y in the future. The ty pe of studies and data collection you suggest related to “risk factors” are likel y more appropriate for a national sample survey

than a full institutional collection like IPEDS. Many of the “risk factors” discussed are obtained through student interviews , and statistics such as the percent of the cohort that are financiall y independent, have dependents, etc., are things that the institution would know only for students who filed a FAFSA. Further, i nformati on like whether the student is working full - time while attending college may

not be known by

the institution at all, regardless of whether the student filed a FAFSA. We do appreciate y our thoughts on this topic as well. Sincerel y yours, Richard J. Reeves Program Director Postsecondary

Institutional Studies Program 

### TICAS **Comment	Number:	46 Docket:**  ED - 2013 - ICCD - 0029 Integrated Postsecondary Education Data S ys tem (IPEDS), Web - Based Collection Sy stem **Comment On:** ED - 2013 - IC CD - 0029 - 0010 Agency Information Collection Activities; Submission to the Office of Management and Budget for Review and Approval; Comment Request; Integrated Postsecondary Education Data Sy stem (IPEDS) 2013 - 2016 **Document:** ED - 2013 - IC CD - 0029 - 0046 Comment on FR Doc # 2013 - 1910723 

## Submitter In **formation Name:**  Lauren Asher **Address:** Oakland, CA , 94612 **Email:** ljasher@ticas.org **Submitter's Representative:** Matthew Reed **Organization:** The Institute for College Access & Success 

## Attachments TI CAS IPEDS Comments - final 09 - 09 - 13 Septe m ber 9, 2013 Ms. Kate M ullan Acting Director, Information Collection Clearance Division U.S. Department of Education 400 Maryland Avenue S W ., LBJ, Room 2E103 Washington, DC 20202 - 4537 ICDocketMgr@ed.gov (sub mitted e l ectroni c ally via: www.regulations.gov ) Dear Ms. M ulla

n : We are writing in response to the request for com ments on the proposed revision of the Integrated P ostsecondary Education Data System (I PEDS), published in the Federal Register on August 8, 2013, docket num ber ED - 2013 - ICCD - 0029. The Institute for College Access & Success (TICAS) is an independent, nonprofit organization that works to make higher education more available and affordable for people of all backgrounds. By conducting and supporting nonpartisan re search and analysis, TICAS a i m s to i m prove the processes and public policies that can pave the way to successful educational outco mes for students and for society. As TICAS has long recommended, incre mental ch a nges to IPEDS could result in substantial i m prov e ments in th e availability of meaningful data about stu d ent borrowing and outco mes, as interest in t h ese data from all quarters co ntin u es to grow. The rece nt efforts of the U.S. Department of Education (ED) to make better data available to students and consume rs through the College Scorecard and the Financial Aid Shopping Sheet underscore the urgent need for better infor mation on these fronts. F or exam ple, without cum

ulative debt at graduation for all colle g es, the College Sc o recard co m p ares median debt figures that are apples - to - oranges, not distinguishing between colleges where few or all students borrow, or where few or all students graduate . 1 We appreciate the detailed response to our May 2013 comm e nts on this proposal, included in the supporting documents of the current request for comments. 2 In particular, we acknowledge the need to mi ni mi ze reporting burden, but point o u

t below where our recom

mendations would not constitute an additional b urden or w h ere th e ben ef its to st u d e nts, f amilies, and polic ymak ers justify li mited additional reporting. In several cases, IPEDS is the best vehicle for collecting the data and making them widely available in a ti mely fashion. In this sub mission, we respond to ED’s concerns about selected recommendations and provide additional c o mments on changes to ED’s proposals. **Cumulative debt at graduation** There is an urgent need for better data on cum ulative student loan debt at graduation, and coll e cting th ese data in I PEDS is the only way to m ake co m prehensive in s titutio n - lev e l debt d ata widely av a i lable in the n ear f uture. While we commend ED for working toward obtaining cum ulative debt data through the National Student Loan Data System (NSLDS), such data will not be available until late 2014 at the earlie s t. They wil l also b e inco m plete, since p ri v ate (no n - federal) student loans are not included in that database. ED’s response also mentions the availability of cum

ulative debt data in the National Postsec o ndary Student Aid Study (NPSAS) and the24

postsecondary longitudinal sam ple surveys. Although those data are helpful for analyzing national student - l evel patterns, the data cannot be b r oken out by institution or state and are not available every y ear. W ith a new version of the College Scorecard due to be releas ed this fall and the second annual release of the Financial Aid Shopp i ng Sheet due to be released this winter, co m prehensive data on cum

ulative debt at graduation are needed as soon as possible. Therefore, we continue to recommend that IPEDS immediate l y st art collecting data on cum

u lative d ebt at grad

u ation f or co m pleters of undergraduate certificates, associate ' s degree s , and bachelor ' s degrees. **Graduation rates f** 

**o r**  **P ell Grant recipients**  Si milarly, c olle c ting gr a duation rat e s f or Pell Gr ant recipients in IPEDS is the best way to mak e that in f ormation wid e ly available in the ne a r future. While we commend ED for working toward the collection and reporting of co m p r ehensive data on this topic using N S LDS, such data may not be available for several years, and the utility of these data cannot be evaluated until they are available . 3 Also, as mentioned above, NPSAS does not have d ata at the in s tit ution level. Additionally, collecting these data in IPEDS wou l d not constitute an additional reporti ng burden because c o lleges are already requ i red to calculate and disclose graduation rates for Pell Grant recipients, Subsidized Stafford Loan recipie nts without Pell Grants, and all other students . 4 Unfortunately, an investigation found that many colleg es do not make these data available . 5 This uneven compliance and the decentralized nature of the data that are disclosed ham per the ability of researchers, policyma kers, and consumers to understand w hich colleges not only enroll substanti a l num be rs of low - inco m e Pell Gra nt recipients, but also gr aduate the m . The only colle g es f or which this r eporting re quire ment would constitute additional burden are those that are not already calculating and d i sclosing the data, and as such are not complying with federal law. The a d ditio n al burden on nonco m pliant c o lleges sho u ld not be of concern to the Department, and in fact, bringing them into co m p liance should be a goal. Therefore, IPEDS should immediately begin collecting graduation rates for Pell Grant recip ients. **Annual private (non -**  **federal) loan data for all undergraduates** We strongly urge ED to discuss options f o r collecting data on private borrowing for all undergraduates, not just first - ti me, full - ti me s tudents, at a me e ting of the IPEDS Technical Review Panel (TRP), as suggested in NCES’ response to our May 2013 comments . 6 W ith more students following non - traditional pathways thr ough higher education and private student loan volume beginning to rise again, it is crucial t h at consumers and policymakers have ti mely data about private student loans for all u n dergrad u ates at each sc h ool. The value of these n ew data would justify the additi o nal rep o rti n g, particularly because I P EDS is uniquely positi o ned to collect data that are available to colleges but not otherwise av aila b l e to ED . At this ti me, colleges are still the best source of data on private student loan usa g e at the instit ution level. L enders currently require school ce rtification for the vast majority of private loans, so schools do have informati on on most such loans. A TRP would prov i de a valuable opportunity to discuss the best ways colleges can overco me any challenges to r eporting based on the information available to them and provide the most helpful data on their students’ private loan borrowing. **Reporting better graduation -**  **rate data** ED has taken a num

ber of pro mising steps to imple ment the recommendations of the Committee on Measures of Student Success ( C MSS), but we are disappointed to learn that the D epartment has decided to postpone collection of the expanded outco mes measures from 2014 - 15 to 2015 - 16. Consumers, policymakers, and colleges all need these new data to in f orm ongoing decisions and cannot afford to wait four years for these new data to beco me available. In our May 2013 comments, we recommended that only “vertical transfer” (e.g., 2 - yr to 4 - yr institutions) be inclu d ed in succe s s measures b ecause subseq u ent enr o ll ment at any o t

h er institution o f higher ed u cation, regardless of level, is not n ecessarily a si gn of student s uccess. We agree with ED and the TRPs that it would be more help f

ul to c o lle c t d ata on t

h e l e vel of program students transfer into r at h er than the lev e l of the college’s overall offerings, but that degree of fine - grained data collection would be too burden so me at this ti me. Howev e r, that li mitation d oes not preclude making any changes to the student success measures. Although i m per f ect,25

including o n ly “vertic a l t

ra ns f ers” bas e d on institution level is st ill more meaning f ul than counting all subsequent transfers in determining what counts as a student success . 7 Furthermore, reporting the institution level of a transfer student’s new school would not constitute a significant burden. Since colle g es rep orting tra n s f er data already document that a fo rmer student has subsequently enrolled at another school, there is very little additional burden to record the level of the student’s new school as listed in IPEDS. In addition, we concur with comments sub mitted by repre s entatives of community colleges that 2 - y ear schools should report the outco me measures six years aft e r a student’s entry. T his would reduce burden on these schools by aligning with other reporting requirements. W e agree with ED’s proposal to collect outco m e m e asures eight ye ars after a student’s entry at 4 - ye ar schools. **Better data about and for veterans and service members** We recommend that IPEDS also collect data on c o m pletions and retenti o n in addition to the d ata on veteran and service me mber enroll m ent and access to s ervices included in the c urrent proposal. As noted in E D ’s response to our M a y 2013 comm e nts, collaboration between ED, the Departm ent of Veterans Affairs (VA), and the D epartm ent of Defense (DoD) is ultimately the best way

to collect these data and prov i de them to consum ers and policy m akers . 8 However, until such data are available, IP EDS is still th e best ve hicle f

or c o llecting d ata o n these s tu d ent populations so the data can be included in ED’s consum er infor

m ation tools as soon as possible. **Data integration** We continue to strongl y urge ED to address in a concrete way the problems created by

the lack of a comm on identifier for colleges across different federal datasets . 9 W e a cknowledge that the identifiers w ere created for d i fferent purposes, but believe that ED still can, and should, at a m i n i m um create a definitive crosswalk and m apping tools to help users integrate Federal Student Aid (FSA) data with IPEDS data using OPE I D numbers. In a June 2012 presentation, NCES staff indicated that work was progressing o n tho s e tools, y et no such tools have been made available . 1 0 We strongl y urge NCES, FSA, and the O f

fice of Postsecondary

Education (OPE) to move forw ard with this project as quickl y as possible. Ulti m ately , ED should continue to work toward common identifiers for colleges acro s s all federal agencies, i n cluding identifying and m aking public any statutory or regulatory

changes that m ay be needed to m ake this possible. Thank y ou for the opportunity to share our suggestions and concerns on this i m portant topic. Please feel f ree to contact m e or my colleagu e Matthew Reed via e m ail at ljas h er@tic a s.org or mreed@ticas.org , or b y phone at (510) 318 - 7900, with any questions. Sincerel y, Lauren Asher Preside nt 1 TI C AS. F e bruary 13, 2013. Blog post. “N e w Coll e ge S c orecard: T wo S t eps Forw ar d, One Step Back.” h tt p ://v iews.ticas.or g/ ? p=982 . 2 U.S. D epartment of Ed

ucation, N ational C enter for Education Statistics. 2013. “Public C o mments Received Dur i ng a 60 - d ay C o mme n t Period and NCES Respo n ses.” h tt p ://1. u sa.g ov/ 17 RgV8 9 . 3 NSLDS rece n tly

re v ised reporti n g r

u les to help facilitate calc u lati o n o f gra du ation rates f o r fi n an cial aid reci p i e n ts. T h e first f u ll y ear after th ese re v isio n s we n t i n to effect is 2 0 13 - 1 4 , w h ich mean s six - ye ar gradu ation rat es f o r stud e n ts e n ter i n g fo ur - year c o lle g es t h is year wi ll no t b e av aila b le un til at least 2 01 9 . 4 2 0 U. S .C. 1 09 2 ( a ) ( 7 )( A). 5 Edu cation Sect o r and th e American E n terprise I n stitute. 2 0 1 1 . T h e Tru t h Behin d Hi

gh er E d u c ati o n Dis clo sure Laws. h tt p ://www.edu catio n s ect o r. o r g/sites/ d efa u lt/files/ p ub licati on s/H i gh erEdDiscl o s ure

_RELEASE. p d f .26

6 U.S. D epartment of Ed

ucation, N ational C enter for Education Statistics. 2013. “Public C o mments Received Dur i ng a 60 - d ay C o mme n t Period and NCES Respo n ses.” h tt p ://1. u sa.g ov/ 17 RgV8 9 . 7 O n e way to further r e fine t h i s in fo rmation i s to i d e n tify t h e scho o l th e s t

ud e n t tran s fers to by the predo minant cred e n tial it awards, rat h er t h an the h i ghest aw ard it offer s . T h e pr e do minant c r e d e n tial is alrea dy u sed for se v eral institutional co m p arisons i n t

h e C o llege S c orecard an d Financial Aid Shopp ing Sheet. 8 U.S. D epartment of Ed

ucation, N ational C enter for Education Statistics. 2013. “Public C o mments Received Dur i ng a 60 - d ay C o mme n t Period and NCES Respo n ses.” h tt p ://1. u sa.g ov/ 17 RgV8 9 . 9 F o r mo re i nf

o rm ation, see T I CAS. Mar c h 2, 2 0 1 2 . Bl o g p o st. “Re p ort f ro m Education D epartment A dv isory Gr o u p Calls for I m

p r ove m ents to Financial Aid D ata.” h tt p ://v iews.ticas.or g/ ? p= 8 4 2 . 10 U . S. D e partm ent o f Educati o n, Nati o nal C enter f o r Educati o n Statistics. Jun e 4, 2 01 2 . Prese n tati o n at 2 0 12 For um o f th e Ass o ciati o n f

o r I n stituti on al Research (AIR), New Orlean s, LA. “IPEDS R&D: An Upd ate on C M SS, NP EC, and TRP s .” 

### RESPONSE: Dear Ms. Asher, Thank y ou for y our comment dated September 9, 2013, responding to a request for comments on the proposed changes to the Department of Education’s Integrated Postsecondary Education Data Sy stem (IPEDS) published in the Federal Register. The National Center for Education Statistics (NCES) appreciates your interest in IPEDS. NCES has carefully

considered y our suggestions to collect data on cumulative student loan debt at gr aduation and graduation rates for Pell Grant recipients through IPEDS. The Department of Education also feels that this is important data to have at the institutional level, and as noted, the National Student Loan Data S ys tem (NSLDS) has already made the necessary

changes to its processes in order to provide this information in the future. Adding items to collect this information through IPEDS would be duplicating efforts both for the Department of Education and for the Title IV institutions reporting thi s information. Further, IPEDS would not be able to provide this data any sooner than it is expected to be available from the National Student L oan Data Sy stem (NSLDS). If IPEDS were to collect this information, it would not be available in the IP EDS Data Center until late in 2015, at the earliest. Your comment about differentiating between transfer from a 2 - ye ar institution to a different 2 - ye ar institution as opposed to transfer from a 2 - ye ar to a 4 - year institution in the proposed new Outcome Measures c omponent was an issue that was discussed and carefull y considered b y the two IPEDS Technical Review Panels held on this topic. The IPEDS TRP felt that this would impose an unnecessary reporting burden on institutions. The Outcome Measures component represents a new collection for I PEDS and the postsecondary education community . During its multiy ear development process , the Department of Educat ion established committees and Technical Review P anels comprised of industry representatives. Alignment with other measures like the VFA does not directly fit within the Department’s responsibility for this measure. The creation of a single output measure for postsecondary education has great value to institutions of higher education for institutional research and improvement, prospective students and their families for decision - making about postsecondary education, and policy makers for guiding efforts to improve student outcomes and success in higher education . It is common practice for postsecondary education instituti ons to verify the degrees and certificates conferred for their alumni indefinitely . For virtually all institutions completing the OM component of IPEDS, these award records are digitized in a student information sy stem with an award date. It is not clear how extracting historical information at an 8 - ye ar point in time will impose a greater burden than at a 6 - year point in time. Further, the additional 2 years allows for more students, particularl y those attending part - time, to be captured as co mpleters in the OM component. NCES will continue to dedicate itself to better underst and the burden of the OM component and find way s to reduce it.27

After careful consideration and extensive discussion within the Department and with the AACC, NCES has deci ded to modify

the proposed information collection review (I CR) for I PEDS. The resulting modification will allow for a reporting of the number of students that received an award at the 6 - ye ar point in time in addition to the 8 - ye ar point in time. This inf ormation will only

be collected once after the 8 - ye ar time period. NCES appreciates your comment regarding the desire to have completion and retention data on veterans and servicemembers collected in IPEDS in addition to the other proposed items. Howeve r, the November 2011 IPEDS TRP on this topic discussed the possibility of adding completion and retention information for veterans and servicemembers and the TRP ultimately suggested that IPEDS is not the appropriate instrument for collection of this infor mation. As mentioned in NCES’ previous response, given that servicemembers are a particularly transient population due to the nature of their work, an institution level data collection, such as IPEDS, would not capture their educational activity well. Th at is, IPEDS does not capture the movement of individual students between institutions. ED continues to work closel y with the Department of Veterans Affairs (VA) and the Department of Defense (DoD) as they work with their alread y existing data sy stems to provide this information. With respect to y our comment about the need for a definitive crosswalk between the various institutional identifiers to aid in integrating data from NCES, the Office of Federal Student Aid (FSA), and the Office of Postsecondary Education (OPE), NCES has been working on creating this ty pe of crosswalk. The complexity

of the work impacts the speed at which a resource like this may be made available, however NCES does recognize the utility that such a resource would bring. Thank y ou again for your comments and your interest in the IPEDS data collection. Sincerel y, Richard J. Reeves Program Director Postsecondary

Institutional Studies Program 

### Comment	Number **:		1 8**  **Docket:** ED - 2013 - ICCD - 0029 Integrated Postsecondary Education Data S ys tem (IPEDS), Web - Based Collection Sy stem **Comment On:** ED - 2013 - IC CD - 0029 - 0010 Agency Information Collection Activities; Submission to the Office of Management and Budget for Review and Approval; Comment Request; Integrated Postsecondary Education Data Sy stem (IP EDS) 2013 - 2016 **Document:** ED - 2013 - IC CD - 0029 - 0018 Comment on FR Doc # 2013 - 19107



## Submitter Information **Name:** Braden Hosch **Address:** Wethersfield, CT , 06109 **Email:** bjhosch@gmail.com 

## General Comment The Outcomes Measures (OM) Survey valuably responds to policy concerns about capturing student outcomes over time and including transfers when known. The Technical Review Panel (TRP) recommended that these data be reported at summary level for four cohorts but not to disaggregate data28

by gender or race/ethnicity

as r equired on the Graduation Rate (GR) Survey. This recommendation was well - intentioned to reduce institutional burden but misguided. Institutions will alread y have to gather unit - record data to report on these measures, and the gender and race/ethnicity

of these students at the unit - record level is readil y available (because required on other IPEDS survey s). The added reporting burden of an hour to report these data for disaggregated groups (x 7,500 institutions) is significantly outweighed by

the value to institutions and policy makers to see the data disaggregated b y gender and race/ethnicity given the extensively

documented differences in outcomes among these populations. The OM survey should be modified to include collection of these data disaggregated b y gender and by race/ethnicit y. 

### RESPONSE: Dear Mr. Hosch, Thank y ou for y our comment dated August 20, 2013, responding to a request for comments on proposed changes to the Department of Education’s Integrated Postsecondary Education Data Sy stem (IPEDS) pub lished in the Federal Register. The National Center for Education Statistics (NCES) appreciates y our interest in IPEDS. The Paperwork Reduction Act (PRA) provides an opportunity for an open and public comment period where comments on collections can be m ade. In particular, we appreciate y our support of the new proposed Outcome Measure (OM) component. The decision to not collect these data disaggregated by race/ethnicity

or gender was made in an effort to allow for expanded data on student outcomes in IPEDS while minimizing the increased institutional reporting burden as much as possible. At the two meetings of the Technical Review Panel (TRP) held on the topic of expanded outcome data, this issue was discussed at length and ultimately the TRP suggested that the data not be collected at this level of detail. As the new OM component matures, this is a topic that a future meeting of the TRP may wish to address. Sincerel y Yours, Richard J. Reeves Program Director Postsecondary

Institutional Studies Program 

### Comments	related	to **Department	of	Veterans	Affairs	facility	codes Comment	Numbers:		19	&**  **4 8**  **Docket:** ED - 2013 - ICCD - 0029 Integrated Postsecondary Education Data S ys tem (IPEDS), Web - Based Collection Sy stem **Comment On:** ED - 2013 - IC CD - 0029 - 0010 Agency Information Collection Activities; Submission to the Office of Management and Budget for Review and Approval; Comment Request; Integrated Postsecondary Education Data Sy stem (IPEDS) 2013 - 2016 **Document:** ED - 2013 - IC CD - 0029 - 0019 Comment on FR Doc # 2013 - 19107



## Submitter I **nformation Name:**  Ry an Gallucci **Address:** Washington, DC , 2220129

**Email:** rgallucci@vfw.org **Organization:** Veterans of Foreign Wars of the U.S. 

## General Comment To Department of Education: On behalf of the men and women of the Veterans of Foreign Wars of the Un ited States (VFW) and our Auxiliaries, we would like to offer comment on Department of Education’s plan to collect information on student - veterans in higher education. The VFW generall y supports the initiative by the National Center for Education Statistic s (NCES) to ask six specific questions through which institutions of higher learning would report additional information to the Integrated Postsecondary Education Data Sy stem (IPEDS). The VFW has one recommendation to enhance the quality , utility , and cl arity of the information to be collected. IPEDS plans to ask schools which benefits are available to potential students to include Post 9/11 GIBill and the Yellow Ribbon Program. IPEDS should instead ask a more directed question to improve the quality

of information collected. The VFW recommends the following language: “If your school is eligible for GI Bill program participation, please disclose Department of Veterans Affairs facility

codes and any

Yellow Ribbon tuition - matching agreements.” The VFW be lieves that this specific collection will enable VA to regularl y update its institutional crosswalk with Department of Education to comply with P.L. 112 - 249, which directed VA to develop a school comparison tool for college - bound veterans. Thanks to presid ential Executive Order No. 13607 and P.L . 112 - 249, Department of Education and VA have worked closel y to cross - reference school codes for Title IV and GI Bill eligibility . However, if IPEDS does not collect this data, this newly - developed school crosswalk will quickly become obsolete. The VFW believes that the institutional crosswalk is critical to ensuring veterans have access to qualit y information before choosing an academic institution. The VFW was proud to play a role in the recent IPEDS Technical Re view Panel that developed these potential new questions, and we believe that they will offer greater transparency in higher education for our student - veterans. We hope IPEDS will consider this minor change to the GI Bill eligibility question to ensure that the VA - Department of Education institutional crosswalk can remain relevant through periodic updates. Sincerel y, Ry an Gallucci Deputy L egislative Director Veterans of Foreign Wars of the U.S. **Docket:** ED - 2013 - ICCD - 0029 Integrated Postsecondary Education Data S ys tem (IPEDS), Web - Based Collection Sy stem **Comment On:** ED - 2013 - IC CD - 0029 - 0010 Agency Information Collection Activities; Submission to the Office of Management and Budget for Review and Approval; Comment Request; Integrated Postsecondary Education Data Sy stem (IPEDS) 2013 - 2016 **Document:** ED - 2013 - IC CD - 0029 - 0048 Comment on FR Doc # 2013 - 1910730 

## Submitter Information **Name:** Robert Worley **Address:** Washington, DC , 

## General Comment September 9, 2013 Subject: Docket No. ED - 2012 - IC CD - 0029: Comment Request: Integrated Postsecondary Education Data Sy stem (IPEDS) 2013 - 2016 (DUE SEP 9th, 2013) Dear Director, Department of Veterans Affairs (VA), Education Service respectfull y requests that the Department of Education (ED) include the collection of VA facility codes under ED - 2012 - ICCD - 0029 updated to the Integrated Postsecondary Education Data S ys tem (IPEDS) 2013 - 2016. BACKGROUND Over the past two ye ars VA and ED have been working together to implement Executive Order 13607, Establishing Principles of Excellenc e for Educational Institutions Serving Servicemembers, Veterans, Spouses, and Other Family Members. The Executive Order requires VA and ED to, “develop a comprehensive strategy for developing Servicemember and Veteran student outcome measures that are co mparable, to the maximum extent practicable, across Federal military and Veterans educational benefit programs.” As part of those efforts VA and ED have been developing a data crosswalk that links ED’s database of schools to VA’s lists of approved programs. An effective crosswalk will allow VA and ED to share data about educational institutions across agencies, improve consumer information available to education beneficiaries, and allow VA to track outcome measures that compare education benefit programs. However, because the two lists of schools are so different the process of creating the crosswalk has been resource intensive for both agencies. Additionally , due to addition of newl y approved programs and changing of old programs the crosswalk will requi re considerable resources to maintain and keep it up to date. ED - 2012 - ICCD - 0029 already asks if a school is GI Bill approved. The proposed IPEDS collection will ask educational institutions if the “Post - 9/11 GIBill” and “Yellow Ribbon” program are “avail able to veterans, military service members or their families”. In order for a student at a particular educational institution to be eligible for the Post - 9/11 GIBill a program at the institution must be approved for the VA education benefits. All institutions with approved programs are assigned a VA facility code. VA respectfull y proposes adding an additional question to this collection that says the following, “Please list all VA facility

codes associated with y our institution.” Alternativel y, if ED does not want to add an additional question, VA recommends modifying the current question “Is the Post - 9/11 GI Bill available to veterans, military service members or their families?31

Yes/No” to read “I s the Post - 9/11 GIBill available to veterans, military service members or their families? I f so, please list all VA facilit y codes associated with your institution.” Adding facility

codes to this collection will enhance the qualit y, utility and clarity

of the collection. By adding the collection of VA facili ty codes to the IPEDS database, both VA, ED and the public at large will have access to an effective crosswalk between both lists of approved programs. That list will be updated and validated annually by the educational institutions themselves. Currently , there is no process for ED and VA to maintain or validate the crosswalk they are developing. The addition of facility

codes to the IPEDS collection will ensure that VA and ED will be able continue to share data about educational institutions across agenci es, improve consumer information available to education beneficiaries, and allow VA to track outcome measures that compare education benefit programs. Burden on the schools will be minimal. Over 90% of educational institutions only have one corresponding VA facility code and 98% of institutions have less than four facility codes. Those facilit y codes rarely change and once entered into IPEDS will likely

not require any

additional work by

the school y ear to y ear. Respectfully

Submitted, Robert M. Worley , II Director, Education Service Veterans Benefits Administration U.S. Department of Veterans Affairs 

### RESPONSE: Thank y ou for y our comment dated August 23, 2013, responding to a request for comments on proposed changes to the Department of Education’s Integrated Postsecondary Education Data Sy stem (IPEDS) published in the Federal Register. The National Center for Education Statistics (NCES) appre ciates y our interest in IPEDS . IPEDS/NCES will work with the Veterans Administration toward a solution for updating the VA facility code/OPEID/IPEDS ID crosswalk. Ideally this work will result in a solution that will not increase the burden on IPEDS responders. This approach will have the additional advantage of including non - IPEDS programs that are in the OP EID code s ys tem, as well as IPEDS Unit IDs . If this approach is not successful, we would welcome the opportunity to revisit this request for consideration b y the IPEDS Technical Review Panel for inclusion in the next round of revisions. Sincerel y yours, Richard J. Reeves Program Director Postsecondary

Institutional Studies Program 

### Comment	Number **: 45**  **Docket:** ED - 2013 - ICCD - 0029 Integrated Postsecondary Education Data S ys tem (IPEDS), Web - Based Collection Sy stem **Comment On:** ED - 2013 - IC CD - 0029 - 0010 Agency Info rmation Collection Activities; Submission to the Office of Management and Budget for32

Review and Approval; Comment Request; Integrated Postsecondary Education Data Sy stem (IPEDS) 2013 - 2016 **Document:** ED - 2013 - IC CD - 0029 - 0045 Comment on FR Doc # 2013 - 19107



## Subm **itter Information Name:**  Chris Cate **Address:** Washington, DC , 20006 **Email:** research.director@studentveterans.org 

## General Comment Student Veterans of America (SVA) would like to offer comment on the Department of Education's plan to collect information on student veterans in higher education. The proposal to collect information regarding student veterans is a positive step forward fr om previous IPEDS survey s. However, there are still specific items that should be discussed and included that would add quality , utility , and clarity of the information to be collected. We would like to encourage the IPEDS survey s to expand the scope of the proposed questions to include veteran specific services that the institution may offer to student veterans and military personnel. Much research and advocacy

has occurred since the Technical Review Panel focusing on best practices and institutional pol icies for veterans in higher education which should be reflected and included in the IPEDS survey s. This includes research found in the American Council on Education’s (ACE) Veteran Friendly Tool - Kit, Operation College Promise (OCP) reports, Association of Private Sector Colleges and University 's (APSCU) Blue Ribbon Taskforce Best Practices Guide, and GI Jobs Military Friendl y Schools L ist. In addition, the SVA would like to request that the Department of Education include the collection of VA facility cod es in the updated I PEDS survey s expanding the current survey s which only asks if the institution is GIBill approved. The inclusion of VA facility codes provides the potential for more accurate data and improved measurement of student veteran and service m ember outcomes by strengthening the data crosswalk program between the Department of Education and the Department of Veterans Affairs alread y in development as a result of Executive Order 13607. By not asking for the VA facility codes, it increases the pos sibility

that the crosswalk program could rapidly become outdated and of little resource to future beneficiaries. We would also like to take the opportunity to comment on the Measures of Success proposed changes to increase the inclusion of veteran and mi litary personnel and the qualit y of their data. To better measure the proportion of veterans and military service members who withdraw from school, we propose a qualifying question asking the number of veterans or military personnel who withdrew from their programs due to being activated or a service related medical condition. Also, expanding the questions of 2 - ye ar college outcomes to include the number of transfers from 2 - ye ar to 4 - ye ar colleges and/or questions on the 4 - ye ar college survey s asking the number of student veterans transferring from other 2 - ye ar will add considerable depth and breadth to the student veteran academic outcomes. Finall y, including separate questions for veteran and military personnel on retention, transfer, course completion, an d graduation/program completion will allow institutional researchers and other data users to conduct peer comparisons in serving these students. SVA would like to thank the National Center for Educational Statistics (NCES) for having a Technical33

Review Panel on veterans in higher education. We were grateful to be included and pleased to participate in the Technical Review Panel. It is our hope that the proposed additions to the IPEDS survey as well as all the public comments will begin to meet external and institutional researchers, veteran and military service members, and policy makers demand for more information on veterans in higher education. We hope IPEDS will consider our comments and proposed changes to the IP EDS survey to ensure that the best possi ble data on veterans in higher education is collected. 

### RESPONSE: Thank y ou for y our comments responding to a request for comments on proposed changes to the Department of Education’s Integrated Postsecondary Education Data Sy stem (IPEDS) published in the Federal Register. The National Center for Education Statistics (NCES) appre ciates your interest in IPEDS . IPEDS/NCES will work with the Veterans Administration toward a solution for updating the VA facility code/OPEID/IPEDS ID crosswalk, in way s that wi ll not increase the burden on I PEDS responders. This approach will have the additional advantage of including non - IP EDS programs that are in the OPEID code s ys tem, as well as IPEDS Unit IDs . If this approach is not successful, we would welcome the opportunity

to revisit this request for consideration by the IPEDS Technical Review Panel for inclusion in the next round of revisions. NCES also appreciates your thoughtful comments on how better data may be made available to veterans and servicemembers as well as providing policymakers and the public more information about the education benefit programs offered to these students. The IPEDS TRP held on this topic suggested that IPEDS is not the appropriate vehicle for collecting graduation rate information for th ese students, especiall y given that servicemembers are a particularly transient population due to the nature of their work, and IPEDS, as an institution level data collection, would not capture this activity well. That is, IPEDS does not capture the moveme nt of individual students between institutions. ED is working closely with the Department of Veterans Affairs (VA) and the Department of Defense (DoD) as they work towards providing this information from their already existing data s ys tems. The Technica l Review Panel meeting of November 2011 identified many issues that could compromise the quality of veterans data that institutions could currently provide, including availability of data at institutions and states, definitional inconsistencies, and the su itability of IPEDS aggregate data collections as an appropriate data collection vehicle. While we do not anticipate expanding the IPEDS data collection bey ond the published proposed changes at this time, progress is being made in some of the problematic areas, and the IPEDS Technical Review Panel may suggest additional items for collection in the future. Sincerel y yours, Richard J. Reeves Program Director Postsecondary

Institutional Studies Program 

### Comment	Number **: 29**  **Docket:** ED - 2013 - ICCD - 0029 Integrated Postsecondary Education Data S ys tem (IPEDS), Web - Based Collection Sy stem **Comment On:** ED - 2013 - IC CD - 0029 - 0010 Agency Information Collection Activities; Submission to the Office of Management and Budget for34

Review and Approval; Comment Request; Int egrated Postsecondary Education Data Sy stem (IPEDS) 2013 - 2016 **Document:** ED - 2013 - IC CD - 0029 - 0029 Comment on FR Doc # 2013 - 19107



## Submitter Information **Name:** Sue Day - Perroots **Address:** Morgantown, WV , 26506sue **Email:** sue.day - perroots@mail.wvu.edu 

## General **Comment** As a member of two national organizations that represent Summer Session, we have struggled with collecting consistent data on Summer enrollments and headcount at institutions across the U.S. Summer enrollment often varies greatl y from the Fall and Spring terms and b y institution and is estimated to fluctuate. In recent y ears with declining financial support, many institutions have targeted Summer as a means to increase revenue as well as time to graduation. Summer may even provide a greater indicato r of college going rates and economic times than standard terms. In addition to enrollment data, it would be beneficial if this data were collected on undergraduate, graduate, professional levels as well as online and campus based. 

### RESPONSE: Thank y ou for y our comment dated September 2, 2013, responding to a request for comments on proposed changes to the Department of Education’s Integrated Postsecondary Education Data Sy stem (IPEDS) published in the Federal Register. The National Center for Education Statistics (NCES) appreciates your interest in IPEDS. The Paperwork Reduction Act (PRA) provides an opportunity for an open and public comment period where comments on collections can be made. We appreciate your suggestion to expand the I PEDS data collection to include summer session enrollment metrics. Changes to I PEDS are made through the mandate of legislation, or the suggestions of the IPEDS Technical Review Panel, which is charged with addressing emerging areas of importance and concern in postsecondary

education. The TRP works to decrease IPEDS reporting burden and retain the federal data necessary for policy

making and anal ys is, and has not y et discussed the possibility of including summer session items in I PEDS. We will pass y our sugg estion along to the panel for consideration. Sincerel y yours, Richard J. Reeves Program Director Postsecondary

Institutional Studies Program 

### Comment	Number **:		1 5**  **Docket:** ED - 2013 - ICCD - 0029 Integrated Postsecondary Education Data S ys tem (IPEDS), Web - Based Collection Sy stem **Comment On:** ED - 2013 - IC CD - 0029 - 0010 Agency Information Collection Activities; Submission to the Office of Management and Budget for35

Review and Approval; Comment Request; Integrated Postsecondary Education Data Sy stem (IPEDS) 2013 - 2016 **Docu ment:**  ED - 2013 - IC CD - 0029 - 0015 Comment on FR Doc # 2013 - 19107



## Submitter Information **Name:** Max Ketterman **Address:** Tallahassee, FL , 32399 - 0400 **Email:** max.ketterman@fldoe.org 

## General Comment I have made some editorial edits to the content of the I PEDS site My suggested changes are - The IPEDS is a web - based data collection s ys tem designed to collect basic data from all Title IV - eligible postsecondary

institutions in the United States and the other jurisdictions. IPEDS enables the Department to report on ke y dimensions of postsecondary education such as student enrollment, graduation rates, degrees and other credentials earned, tuition and fees, institution’s average net price, student financial aid, institution’s revenues and expenditures, facult y salaries, and staff employ ed. 

### RESPONSE: Thank y ou for y our comment dated August 19, 2013, responding to a request for comments on proposed changes to the Department of Education’s Integrated Postsecondary Education Data Sy stem (IPEDS) published in the Federal Regis ter. The National Center for Education Statistics (NCES) appreciates y our interest in IPEDS. As y our comments refer to text from the I PEDS OMB Paperwork Reduction Act Submission, and not text from the IPEDS website, we will take your comments into consideration when we prepare our next OMB submission. Sincerel y yours, Richard J. Reeves Program Director Postsecondary

Institutional Studies Program 

### Comment	Number **:		1 3**  **Docket:** ED - 2013 - ICCD - 0029 Integrated Postsecondary Education Data S ys tem (IPEDS), Web - Based Collection Sy stem **Comment On:** ED - 2013 - IC CD - 0029 - 0010 Agency Information Collection Activities; Submission to the Office of Management and Budget for Review and Approval; Comment Request; Integrated Postsecondary Education Data Sy stem (IPEDS) 2013 - 2016 **Document:** ED - 2013 - IC CD - 0029 - 0013 Comment on FR Doc # 2013 - 19107



## Submitter Information36

**Name:** jean public **Address:** not available, NJ , 08822 **Email:** jeanpublic1@y ahoo.com 

## General Comment s dept of labor alrad y has mos tof this information. i see no need at all for further collection by the us dept of education. what do they need this information for. this project should be shut down immediately . the taxpay ers are being assaulted and gouged fo rhigh taxes for information that the us govt alread y has. why d o taxpay ers need to pay

taxes so two different agencies can do practicall y the same thing. what a stupid unnecessary

wasteful way

to govern. 

### RESPONSE: Thank y ou for y our comment dated August 8, 2013, responding to a request for comments on proposed change s to the Department of Education’s Integrated Postsecondary Education Data Sy stem (IPEDS) published in the Federal Register. The National Center for Education Statistics (NCES) appreciates y our interest in IPEDS. The Paperwork Reduction Act (PRA) provide s an opportunity for an open and public comment period where comments on collections can be made. IPEDS is a web - based data collection sy stem designed to collect basic data from all postsecondary institutions in the United States and the other jurisdicti ons. I PEDS enables NCES to report on key dimensions of postsecondary education such as enrollments, degrees and other awards earned, tuition and fees, average net price, student financial aid, graduation rates, revenues and expenditures, facult y salaries, and staff emplo yed. The National Center for Education Statistics devotes considerable effort to assure that IPEDS does not duplicate other federal data collection activities involving postsecondary education providers. In developing IP EDS, NCES continues to assess the data collection efforts of other Federal agencies (e.g., National Science Foundation, Department of Agriculture, Department of Defense, Census Bureau, Equal Employ ment Opportunity

Commission, Bureau of Labor Statistics, Veterans Adm inistration) through an examination of their forms. In addition, NCES has in - depth discussions with the Department of Labor, as well as other Education Department offices (e.g., OCR, FSA, OPE, OVAE) to ascertain their needs for data and the role IPEDS can play in meeting those needs. Through meetings, workshops, and TRPs, NCES works closely

with other stakeholders including the State Higher Education Executive Officers (SHEEO), the National Association of College and University Business Officers (NACUBO), the American Association of Collegiate Registrars and Admissions Officers (AACRAO), the National Association of Independent Colleges and Universities (NAICU), the American Association of Community

Colleges (AACC), the Association of Private Sector College s and Universities (APSCU), the American Council on Education (ACE), the Consortium on Financing Higher Education (COFHE), the American Association of State Colleges and Universities (AASCU), the Western Interstate Commission for Higher Education (WICHE), the Southern Regional Education Board (SREB), and others. Duplication is avoided as various federal agencies, groups within the Department of Education, and other agency representatives share access to I PEDS data. Sincerel y yours, Richard J. Reeves Program Director Postsecondary

Institutional Studies Program 

### Comment	Number **: 44** 37

**Docket:** ED - 2013 - ICCD - 0029 Integrated Postsecondary Education Data S ys tem (IPEDS), Web - Based Collection Sy stem **Comment On:** ED - 2013 - IC CD - 0029 - 0010 Agency Information Collection Activities; Submission to the Office of Management and Budget for Review and Approval; Comment Request; Integrated Postsecondary Education Data Sy stem (IPEDS) 2013 - 2016 **Document:** ED - 2013 - IC CD - 0029 - 0044 Comment on FR Doc # 2013 - 19107



## Submitter Information **Name:** Richard Hershman **Organization:** National Association of College Stores 

## General Comment On behalf of the National Association of College Stores (NACS), I write to express our views on how might the Department of Education enhance the quality , utility , and clarit y of the information to be collected under IPEDS. Thank you for the opportunity to submit comments. Headquartered in Oberlin, Ohio NACS is the professional trade association representing the collegiate and K - 12 bookstore community . We represent more than 3,000 collegiate and elementary and secondary bookstores including school owned and operated bookstores, affiliated non - profit and student owned cooperatives, small privately owned bookstores, and contract managed bookstore companies. NACS membe r stores serve nearly all college students while supporting the academic missions of education institutions. Specificall y we wish to raise the “books and supplies” data element collected and presented in IPEDS’ "cost of attendance." Books and supplies has become the most misunderstood and misquoted statistic in higher education today . It is frequently miscited in the press, by

policy makers and others as solel y college textbook spending. However, the recent Student Watch survey and other studies suggest req uired course materials may

onl y make up an estimated 56% of average books and supplies cost estimates at man y schools. As the GAO discovered in their recent report to Congress “College Textbooks: Students Have Greater Access to Textbook Information,” GAO - 13 - 368, June, 2013: “While the Bureau of Labor Statistics publishes data annuall y on college textbook pricing, there are no comparable, nationally representative [government] data sources that estimate student spending.” Books AND supplies as a bundled cost category (does not exist in HEA’s Cost of Attendance definition) has become a catch - all miscellaneous account line in I PEDS. For example, most public colleges and universities in California include textbooks, supplies, equipment, lab and other course fees, software, and computer hardware other than a computer in this category of “books and supplies.” This data is supplied by the California Student Aid Commission based on a student survey that was last conducted in 2007 and inflation adjusted since. Whi le the commission breaks down spending through its survey questions and estimates for each category that makes up books and supplies, institutions provide students the information as simply

“books and supplies.” Due to this approach b y California instituti ons in what they include in books and supplies, they report within IPEDS some of the highest average budgets for books and supplies than an y other state.38

State legislatures in a number of states have incorrectl y used IPEDS “books and supplies” estimates to calculate sales and use tax revenue from the sales of college textbooks. The inflated and inaccurate cost estimates, have subsequently helped defeat tax relief legislation for students and parents in more than a dozen states, resulting in as much as a 10% increase in costs for students in the 24 states that continue to tax textbooks. The US Department of Education provides little standards or guidance in how to calculate these budget estimates for books and supplies and what is allowable and how they shou ld be presented. The U.S. Department of Education presents the data itself with no explanation as to what may or may not be included in this cost of attendance category . Even the most casual review of the College Navigator website leads to wildly

different book and suppl y numbers for seemingl y similar ty pes of institutions. The result is the current data collection and reporting in IPEDS is not as helpful as it could and should be for prospective and existing students comparing college costs and budgeting for college. The way the data is presented also leads to broad misunderstanding by policy makers in higher education and elected officials over the actual dollar impact of textbook spending b y students versus other more significant cost factors that may

de serve greater attention as policy makers and institutions work to make college more affordable and accessible. We urge the Department to explore non - burdensome common sense approaches to improve how course materials are included in the cost of attendance I PEDS data set and how the Department presents the data. Sincerel y , Richard Hershman Vice President of Government Relations National Association of College Stores 

### RESPONSE: Thank y ou for y our comment dated September 9, 2013, responding to a request for comments on proposed changes to the Department of Education’s Integrated Postsecondary Education Data Sy stem (IPEDS) published in the Federal Register. The National Center for Education Statistics (NCES) appreciates your interest in IPEDS. The Paperwork Reduction Act (PRA) provides an opportunity for an open and public comment period where comments on collections can be made. Estimates of expenses for books and supplies reported to I PEDS are those from the Cost of Attendance report used b y the institut ion’s financial aid office in determining financial need. Instructions for calculating all cost of attendance amounts, including books and supplies, are included in the Financial Student Aid Handbook, available at http://www.ifap.ed.gov/ifap/byAwardYear.jsp?type=fsahandbook . We instruct respondents to talk to their financial aid office to get these numbers, to ensure that they are reporting correctl y. However, we appreciate your concern for the accurate and comparable reporting of this item, and we will pass along your comments to the Office of Federal Student Aid. Sincerel y yours, Richard J. Reeves Program Director Postsecondary

Institutional Studies Program39 

### Comment	Number **:		1 7**  **Docket:** ED - 2013 - ICCD - 0029 Integrated Postsecondary Education Data S ys tem (IPEDS), Web - Based Collection Sy stem **Comment On:** ED - 2013 - IC CD - 0029 - 0010 Agency Information Collection Activities; Submission to the Office of Management and Budget for Review and Appr oval; Comment Request; Integrated Postsecondary Education Data Sy stem (IPEDS) 2013 - 2016 **Document:** ED - 2013 - IC CD - 0029 - 0017 Comment on FR Doc # 2013 - 19107



## Submitter Information **Name:** Daniel Suvak **Address:** North Canton, OH , 44720 **Email:** dsuvak@walsh.edu 

## Genera **l Comment** "Circulation" on the library form will have to be carefull y defined: Does it include renewals? Does it includes reserves? Similarly , for "circulation" of digital materials, is this defined as full - text downloads? Also, many

databases do not c ontain full - text, but their use is important. It may be useful to request information about the number of "searches" in databases. 

### RESPONSE: Thank y ou for y our comment dated August 30, 2013, responding to a request for comments on proposed changes to the Department of Education’s Integrated Postsecondary Education Data Sy stem (IPEDS) published in the Federal Register. The National Center for E ducation Statistics (NCES) appreciates y our interest in IPEDS. The Paperwork Reduction Act (PRA) provides an opportunity for an open and public comment period where comments on collections can be made. We are currentl y writing the Academic L ibraries component instructions, which will be based on the current Academic L ibraries Survey instructions. Thank y ou for y our suggestions for clarification. The preview materials (survey form and instructions) will be available upon the approval of this Information Collection Review (I CR). We do not anticipate expanding the IP EDS data collection bey ond the published proposed changes at this time. The Technical Review Panel carefull y considered how to balance the collection of useful information and respondent burden. However, the TRP may suggest additional items for the Academic Libraries component in the future. Sincerel y yours, Richard J. Reeves Program Director Postsecondary

Institutional Studies Program 

### Comment	Number **: 38** 40

**Docket:** ED - 2013 - ICCD - 0029 Integrated Postsecondary Education Data S ys tem (IPEDS), Web - Based Collection Sy stem **Comment On:** ED - 2013 - IC CD - 0029 - 0010 Agency Information Collection Activities; Submission to the Office of Management and Budget for Review and Approval; Comment Request; Int egrated Postsecondary Education Data Sy stem (IPEDS) 2013 - 2016 **Document:** ED - 2013 - IC CD - 0029 - 0038 Comment on FR Doc # 2013 - 19107



## Submitter Information **Name:** Chip Stewart **Address:** New York, 10031 **Email:** cstewart@ccny .cuny .edu 

## General Comment In the Academic Li braries (AL) component, under Question 2 -- Library Collections/Circulation, "Serial Titles" is listed. Isuggest this be dropped, since the concept has proven very elusive recently , because of increasing multi - faceted electronic database access to articles. It is for this reason that the major library survey s recentl y dropped this question, including the Department of Education's own Academic Library Survey for 2012. This development occurred AFTER the TRP for Academic Libraries, so I suggest this proposal n ow be brought up to date. This will save libraries and the Census Bureau many annual burden hours trying to clarify confusions. Thank y ou for y our serious consideration of this suggestion. 

### RESPONSE: Thank y ou for y our comment dated September 6, 2013, respo nding to a request for comments on proposed changes to the Department of Education’s Integrated Postsecondary Education Data Sy stem (IPEDS) published in the Federal Register. The National Center for Education Statistics (NCES) appreciates your interest in IP EDS. The Paperwork Reduction Act (PRA) provides an opportunity for an open and public comment period where comments on collections can be made. We also appreciate your bringing this to our attention. We will remove the Serial Titles item from the IP EDS Academic Libraries component. Sincerel y yours, Richard J. Reeves Program Director Postsecondary

Institutional Studies Program 

### Comment	Number **: 42**  **Docket:** ED - 2013 - ICCD - 0029 Integrated Postsecondary Education Data S ys tem (IPEDS), Web - Based Collection Sy stem **Comment On:** ED - 2013 - IC CD - 0029 - 0010 Agency Information Collection Activities; Submission to the Office of Management and Budget for41

Review and Approval; Comment Request; Integrated Postsecondary Education Data Sy stem (IPEDS) 2013 - 2016 **Document:** ED - 20 13 - IC CD - 0029 - 0042 Comment on FR Doc # 2013 - 19107



## Submitter Information **Name:** Elizabeth Morgan **Address:** Claremont, CA , 91711 **Email:** emorgan@cmc.edu 

## General Comment We need explicit rules on how to report shared library facilities and resources to I PEDS. I work for one of the Claremont Colleges, in which 7 distinct institutions support a shared library s ys tem through a complex financial formula, which is paid into a central services agency (Claremont University

Consortium) which in turn provides all library services and employ s the library staff, supports its facilities, etc. All 7 institutions can't claim an equal portion of the library or divide up specific employ ees or resources on a per - college basis. We will be utterly at sea about how to accuratel y repr esent this very important and very expensive shared resource without highl y detailed instructions which take our unique situation into account. 

### RESPONSE: Thank y ou for y our comment dated September 7, 2013, responding to a request for comments on proposed c hanges to the Department of Education’s Integrated Postsecondary Education Data Sy stem (IPEDS) published in the Federal Register. The National Center for Education Statistics (NCES) appreciates your interest in IPEDS. The Paperwork Reduction Act (PRA) pr ovides an opportunity for an open and public comment period where comments on collections can be made. We are currentl y writing the Academic L ibraries component instructions, which will be based on the current Academic L ibraries Survey instructions. Thank y ou for y our suggestions for clarification. We will make sure that this issue of shared library resources is addressed in detail. The preview materials (survey form and instructions) will be available later this fall when this Information Collection R eview (I CR) is approved. Sincerel y yours, Richard J. Reeves Program Director Postsecondary

Institutional Studies Program 

### Comment	Number **: 43**  **Docket:** ED - 2013 - ICCD - 0029 Integrated Postsecondary Education Data S ys tem (IPEDS), Web - Based Collection Sy stem **Comment On:** ED - 2013 - IC CD - 0029 - 0010 Agency Information Collection Activities; Submission to the Office of Management and Budget for Review and Approval; Comment Request; Integrated Postsecondary Education Data Sy stem (IPEDS) 2013 - 201642

**Document:** ED - 2013 - IC CD - 0029 - 0043 Comment on FR Doc # 2013 - 19107



## Submitter Information **Name:** Linda Miller **Address:** United States, 

## General Comment Dear Richard Being unfamiliar with how this sy stem works, I just recentl y found your response to our comment of 5/13/13 (both cop ied below); please excuse my delay . While we did answer some of the questions in 2010, we were not able to in 2012, and that is still the case. Many thanks, L inda 

### RESPONSE: Thank y ou for y our comment dated September 9, 2013, responding to a request for c omments on proposed changes to the Department of Education’s Integrated Postsecondary Education Data Sy stem (IPEDS) published in the Federal Register. The National Center for Education Statistics (NCES) appreciates your interest in IPEDS. The Paperwork R eduction Act (PRA) provides an opportunity for an open and public comment period where comments on collections can be made. We would appreciate the opportunity to discuss in detail y our suggestions for clarifying the instructions for the Academic Libraries component. Guidance which would aid y ou in reporting would, no doubt, be useful to others as well. Please contact the IP E DS help desk at 877 - 225 - 2568 and at ipedshelp@rti.org . The preview materials (survey form and instructions) will be available upon the approval of this In formation Collection Review (ICR). Sincerel y yours, Richar d J. Reeves Program Director Postsecondary

Institutional Studies Program 

### Comment	Numbers **: 14	&	16**  **Docket:** ED - 2013 - ICCD - 0029 Integrated Postsecondary Education Data S ys tem (IPEDS), Web - Based Collection Sy stem **Comment On:** ED - 2013 - IC CD - 0029 - 0010 Agency In formation Collection Activities; Submission to the Office of Management and Budget for Review and Approval; Comment Request; Integrated Postsecondary Education Data Sy stem (IPEDS) 2013 - 2016 **Document:** ED - 2013 - IC CD - 0029 - 0014 Comment on FR Doc # 2013 - 19107



## Submitter Information **Name:** Frank Carey **Address:** Amherst, NY, 14226 **Email:** fcarey@daemen.edu 

## General Comment43

Any changes seem to be in order, and not undul y burdensome. **Docket:** ED - 2013 - ICCD - 0029 Integrated Postsecondary Education Data S ys tem (IPEDS), Web - Based Collection Sy stem **Comment On:** ED - 2013 - IC CD - 0029 - 0010 Agency Information Collection Activities; Submission to the Office of Management and Budget for Review and Approval; Comment Request; Integrated Postsecondary Education Data Sy stem (IPEDS) 2013 - 2016 **Document:** ED - 2013 - IC CD - 0029 - 0016 Comment on FR Doc # 2013 - 19107



## Submitter Information **Name:** Emily Dibble -- Keyholder **Address:** United States, 

## General Comment (1) Is this collection necessary to the proper functions of the Department: Yes (2) will this information be processed and used in a timely manner: Every

y ear the timeliness of processing is improving -- keep up the good work *AND* the necessary funding for these improvements. (3) is the estimate of burden accurate: This is worth updating annually , perhaps with end - of - survey items that specify

the current official estimate of burden and provide KeyHolders with the opportunity to indicate what their institutions estimated burder was. (4) how might the Department enhance the quality, utility , and clarit y of the information to be collected: Quality , utility

and clarity

have been improving steadily . Perhaps the instructions/examples for uploading data files (Key - Pair and the other way) could be presented separatel y instead of being lumped togeth er. (5) how might the Department minimize the burden of this collection on the respondents, including through the use of information technology . *L et key holders and others keep the same password for the entire reporting y ear. I believe we had to change p asswords halfway through the 2012 - 2013 reporting y ear. *For Financial Aid reporting, consider offering a sample (raw data) spreadsheet lay out that would ensure all the data elements and categorization is attended to. Iunderstand that IPEDS doesn't collec t unit record data, but institutions must work with unit records in order to aggregate at the multiple levels required for reporting. 

### RESPONSE: Thank y ou for y our comment s , responding to a request for comments on proposed changes to the Department of Education’s Integrated Postsecondary Education Data Sy stem (IPEDS) published in the Federal Register. The National Center for Education Statistics (NCES) appreciates your inte rest in IPEDS. The Paperwork Reduction Act (PRA) provides an opportunity for an open and public comment period where comments on collections can be made. NCES is very

sensitive to the need to balance increased reporting burden with the utility of the data requested. Each Technical Review Panel meeting, regardless of the topic being discussed, is specifically charged with the task of minimizing the additional institutional burden as a result of increased IPEDS reporting requirements. In addition, IPEDS r espondents are asked to estimate the amount of time it took to complete IPEDS and these data are reviewed annually and changes to burden estimates are made when44

necessary . Your insight into how the instructions may be improved is appreciated. NCES will work t o review the instructions and determine if future versions of IPEDS should have the instructions/examples for uploading data files presented separatel y instead of together. In addition, we will review the password reset policy

and determine if allow ing key holders to keep the same one will result in less burden. The idea of creating a worksheet that will facilitate the organization and reporting of financial aid data is one that NCES has considered before. Ultimately , the engineering and support of another technology to help with the submission of I PEDS data has been found to be an inefficient use of government resources. We will continue to consider the creation of this tool and hope that advances in technology will allow for an efficient solution in the near future. Sincerel y yours, Richard J. Reeves Program Director Postsecondary

Institutional Studies Program