Integrated Postsecondary Education Data System (IPEDS) 2013-2016

Docket: ED-2013-ICCD-0128 Comment On: FR Doc # 2013-24041

Public Comments Received During the Second 30-day Comment Period and NCES 

Responses

Comment	Related	to	Over-the-Counter	Data	Standards

Document: ED-2013-ICCD-0128-0005

Name: Jenny Grant Rankin, Ph.D.

It is paramount that the data system adhere to Over-the-Counter Data Standards, which relate to how the data is 

communicated (e.g., report design) to educators/stakeholders. Most educators misunderstand data generated by data 

systems, and these research-based standards help ensure the data is displayed/supported properly. Such research has 

been the focus/obsession of my career and research, so I know that educators and students will significantly benefit 

from IPEDS adherence to Over-the-Counter Data Standards. I humbly ask that you look into using them. Thank 

you for all you are doing to help students.

RESPONSE:

Dear Dr. Rankin,

Thank you for your comments submitted during the second 30-day review process, responding to a request for 

comments on proposed changes to the Department of Education’s Integrated Postsecondary Education Data System 

(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 National Center for Education Statistics (NCES) is committed to adhering to the statistical standards 

established through the federal statistical community and those established with NCES and the Department. A 

description of the statistical standards program at NCES can be found here: http://nces.ed.gov/statprog/. A history 

of the standards used by NCES and the history of their development can be found here: 

http://nces.ed.gov/statprog/2002/stdintro3.asp. 

Sincerely Yours,

Richard J. Reeves

Program Director, Postsecondary Institutional Studies Program

Comments	Related	to	Reporting	by	Title	IV	Programs

Document: ED-2013-ICCD-0128-0006

Name: Robert Kelchen

I would like to see IPEDS include graduation rate data for Pell Grant recipients, something which colleges are 

already required to disclose under the most recent HEOA reauthorization. This information is currently being 

collected from colleges by US News, but is not publicly available. The addition of Pell graduation rate data to 

IPEDS shouldn't result in a meaningful additional burden to institutions, but would provide useful information to 

students, their families, and policymakers alike. For that reason, IPEDS should include the data as soon as possible.

An additional, but less important, request would be to include the numbers of students in each income category 

(e.g. 0-30k) in the IPEDS Data Center instead of just in the institutional reports. This would make comparing the 

percentage of students from low-income families across colleges much easier. All this takes is a change in the Data 

Center, as the information is already required to be reported by colleges.

Thank you for your time and consideration. 
Robert Kelchen, Seton Hall University (opinions my own)

Document: ED-2013-ICCD-0128-0008

Name: Sarah Gomez

Pell-recipient-specific graduation rates are absolutely necessary in order to counsel our low-income, first-generation 

KIPP students to build a strong wishlist of schools, and ultimately to make the decision on where to enroll. While 

we currently can quickly locate overall graduation rates and 6-year minority completion rates as well as the percent 

of students on campus receiving Pell grant money, the graduation rate of those students specifically would be the 

final piece in the puzzle as to whether that particular school is serving KIPP-like students well. Since there are 

thousands of students out there who share the same characteristics as our KIPPsters, this information should be 

made widely available so that folks have it at their fingertips when making this important decision.

Document: ED-2013-ICCD-0128-0009

Name: Ruben Anonymous

Pell Grant Data should be released there is no reason not to share it. many program could benefit from this data. 

THis is America. Lets make this happen.

Document: ED-2013-ICCD-0128-0010

Name: Torin Hayes

Please collect and publish graduation rates for students receiving Pell Grants!

Document: ED-2013-ICCD-0128-0011

Name: Kristin Anonymous

I am in favor of collecting graduation rates from each institution for Pell recipients through IPEDS! This is vital 

information for students to know and understand - please make it a priority!

Document: ED-2013-ICCD-0128-0012

Name: Anonymous

Collect graduation rates from each institution for Pell recipients through IPEDS

Document: ED-2013-ICCD-0128-0013

Name: Linda Jensen

An institution’s Pell student graduation rate is a key piece of information that low-income students should consider 

before they apply to colleges. In order to make a well-informed decision, students need to know how many Pell 

students an institution enrolls and how many it graduates. Institutions should be held accountable for this 

information.

Document: ED-2013-ICCD-0128-0014

Name: Sarah Magnelia

As a college counselor to low-income students, it would be a great asset to me (and my students!) if colleges were 

required to publicly report their graduation rates for PELL-eligible students. Students need to ensure that they're 

attending institutions where they are likely to persist and graduate. In the long run, one semester or year of college 

does little to help students. A college degree - not some time spent in college - leads to more job security, greater 

wealth, better health, etc. As such, students need to ensure they're marking smart post-secondary decisions, that 

they are attending schools where they are likely to persist. Graduation data for PELL-eligible students would help 

my students make these decisions.
Document: ED-2013-ICCD-0128-0015 and ED-2013-ICCD-0128-0018

Name: Margaret Maudsley

I was doing a project for a data analysis class last Summer 2013 and am working currently on a Master's thesis 

about Pell and graduation rates. I found it very difficult to gather the data I wanted in IPEDS for this topic. I wished 

that the data was submitted every year, but then as I thought about it, it would be very difficult to ensure that each 

institution was submitting data for each student as a case every year, to ultimately get the graduation rate for a 

student receiving Pell at any time during their program. Pell eligibility requirements change every year and a 

student's EFC also fluctuates yearly. So, I am not sure how accurate, or how much time and effort would need to go 

onto matching each students' data from each year. But I hope to be doing it manually very soon at my university.

Document: ED-2013-ICCD-0128-0016

Name: Simon Moore

I am writing to strongly urge the Department of Education to require that colleges collect and report completion 

rates for Pell Grant recipients. As the director of a non-profit college access organization that supports 

disadvantaged students to enter, succeed in, and graduate from college, I can attest that this information would be 

instrumental in supporting our families to make informed college choices that promote completion. Thank you for 

your consideration.

Document: ED-2013-ICCD-0128-0017

Name: Emily Rodriguez

I am writing to strongly urge the Department of Education to require that colleges collect and report completion 

rates for Pell Grant recipients. As the program director of a college success program that supports disadvantaged 

students to persist and graduate from college, I can attest that this information would be instrumental in supporting 

our families to make informed college choices that promote completion. Thank you for your consideration.

Document: ED-2013-ICCD-0128-0019

Name: Carolyn Beyers

Submitter's Representative: Carolyn Beyers

Organization: On Point for College

Students thrive where there are other students who are uniquely different like them and face the same kind of 

challenges. Published graduation data will help students and College Access Programs know which institutions are 

sensitive to those unique barriers, and therefore, help students achieve their academic and life goals.

Document: ED-2013-ICCD-0128-0020

Name: Lenna Sliney

The inclusion of Pell graduation rates is essential, but I also urge that graduation rates for all Title IV programs be 

integrated into IPEDS. The inclusion of this data will allow students to find schools that are successful in 

graduating students similar to themselves. The data is already collected for Pell, but not publicly available. 

Therefore, it can be assumed that there would be no additional administrative burden to include Pell graduation 

rates.

Document: ED-2013-ICCD-0128-0021

Name: Sharon Thomas Parrott

To Whom It May Concern:

DeVry Education Group believes that reporting the graduation rates of Pell grant recipients via IPEDS would be 

important and necessary information to policy makers and the general public. While this data is currently only 

required to be disclosed on an institution’s website, or if asked, we do not believe it would pose an undue burden on 

either the Department or respondents to make this data more fully available through IPEDS.
Collecting this data is only the first step toward gaining meaningful insights into institutional performance. 

Graduation rates of Pell grant recipients should be examined in context against a predicted range of outcomes for 

institutions based on their percentage of Pell recipients. Whether or not a student has received a Pell grant is highly 

correlated to their eventual graduation, therefore colleges with a high percentage of Pell grant students should be 

viewed alongside peer institutions with similar demographics.

For example: institutions with 5% Pell students would have a predicted range of graduation rates that would be 

much different than colleges with 50% of its students receiving Pell grants. An institution with a seemingly low 

graduation rate could have a very high percentage of Pell recipients and might actually be graduating students at or 

above its predicted rate. Such information would be valuable to the Department and policy makers in evaluating the 

performance of institutions and their efficient use of taxpayer dollars. This information would also allow students, 

especially those pursuing career-focused education, more relevant insights than graduation rates currently provide.

In short, DeVry Education Group recommends that the Department, through IPEDS, collects information on an 

institution’s Pell grant graduation rate, rather than merely disclosing such information as per current HEA 

requirements.

Sharon Thomas Parrott

SVP External Relations & Global Responsibility

Chief Regulatory Compliance Officer, DeVry Education Group

Document: ED-2013-ICCD-0128-0025

Name: New America Foundation Education Policy Program

New America Foundation IPEDS Comments 11-14-2013

1899	L	Street,	NW	•	Suite	400	•	Washington,	DC	20036	•	Phone:	202-986-2700 •	Fax:	202-986-3696	•	

www.newamerica.net

Kate	Mullan, Acting	Director,	Information	Collection	Clearance	Division

Privacy,	Information	and	Records	Management	Services,	Office	of	Management

U.S.	Department	of	Education

400	Maryland	Ave	SW,	Washington,	DC	20202

Dear	Ms.	Mullan,

Thank	you	for	the	opportunity	to	submit	comments	on	the	information	collection	request	for the	2013-16	

Integrated	Postsecondary	Education	Data	System	(IPEDS).	The	IPEDS	database	is	the	most	crucial	and	bestmaintained	repository	of information	on	U.S.	higher	education.	The proposals	from	the	National	Center	for	

Education	Statistics	(NCES)	to	include	new	outcomes measures	stemming	from	the	Committee	of	Measures	

of	Two-Year	Student	Success	will	only make	it	more	so.	Issues	around	how	those	measures	will	add	

reporting	on	part-time	and	nonfirst-time	students	have	been	well	discussed,	so	the	comments	submitted	

today	only	consider	the	graduation	rate	disaggregation	requirements	that	Congress	added	in	Sec.	488(a)(3)	

of	the	2008	Higher	Education	Opportunity	Act	and	are	now	codified	in	Sec.	485(a)(7)(A).

Under	that	section,	institutions	of	higher	education	must	disclose	to	prospective	students information	on	the	

graduation	rate	of	students,	disaggregated	by	a	number	of	categories including	gender,	major	racial	or	ethnic	

subgroup,	Pell	Grant	recipients,	students	who	borrowed a	Subsidized	Stafford	Loans	and	did	not	receive	a	

Pell	Grant,	and	students	who	received	neither a	Pell	Grant	nor	a	Subsidized	Stafford	Loan.	The	first	two	types	

of	disaggregation—race	and	gender—are	already	recorded	annually	on	the	IPEDS	completion	survey,	but	the	

other	elements	are	not.	We	strongly	recommend	that	NCES	take	steps	to	add	in	elements	to	the	IPEDS	

completions	survey	that	require	colleges	to	report	graduation	rates	for	Pell	recipients,	Subsidized	Stafford	

Loan	recipients	without	Pell	Grants,	and	individuals	who	received	neither	Pell	Grants	nor	Subsidized	Stafford	

loans.	While	we	understand	that	past	comments	on	this	information	collection	have	also	made	this	request	

and	received	a	negative	response,	there	are	additional issues	worth	highlighting	for	the	first	time	or	

reiterating	that	we	think	make	clear	why	this	is	a	sensible	change.
There	is	no	added	burden	for	schools	because	they	are	already	required	to	furnish	this information:	Burden	

is	understandably	an	issue	frequently	raised	by	institutions	that	are concerned	about	the	cost	of	complying	

with	IPEDS.	But	unlike	the	additional	outcomes measures	or	changes	to	other	things	like	for-profit	finance,	

these	completion	rates would	not	increase	the	burden	faced	by	schools.	That	is	because	they	are	already	

legally required	to	provide	this	information	on	a	website	or	to	individuals	who	ask	for	it.	Since this	

information	is	already	supposed	to	be	collected	and	disclosed,	simply	adding additional	fields	to	IPEDS	

would	have	at	most	a	minimal	effect	on	burden.

Many	schools	are	already	reporting	this	information	on	other	surveys:	The	publication U.S.	News	and	World	

Report	already	asks	for	these	graduation	rates	on	the	surveys	it sends	to	institutions	for	its	annual	rankings.	

It	has	published	small	pieces	of	this information	on	its	blog,	which	it	is	labeling	as	exclusive	and	not	sharing.	

(See http://www.usnews.com/education/blogs/college-rankingsblog/2013/10/17/measuring-collegessuccess-graduating-low-income-students,	for example.)

The	fact	that	many	colleges	are	already	reporting	this	information	on	other	surveys reiterates	how	this	

expansion	of	the	completion	rate	survey	will	not	add	additional burden.	It	also	shows	that	a	provision	

Congress	intended	to	help	lower-income	students make	better	decisions	is	instead	being	held	by	other	

organizations	for	proprietary purposes,	a	condition	that	only	NCES	is	capable	of	fixing.

Schools	are	making	it	hard	for	students	to	get	this	information:	Despite	being	required by	law	to	comply	with	

this	graduation	rate	disaggregation,	many	colleges	are	not	being forthcoming	in	giving	students	these	legally	

mandated	data.	A	2011	survey	of	100 schools	by	Kevin	Carey	and	Andrew	Kelly	found	that	only	38	percent	

even	complied	with the	requirement	to	provide	these	completion	rates,	in	many	cases	only	after	repeated

phone	calls	and	messages.1	Forcing	students	to	go	through	multiple	rounds	of	contact with	an	institution	in	

order	to	get	this	information	is	unduly	burdensome	on	them	and risks	allowing	colleges	to	skirt	their	legal	

requirements.

These	data	are	necessary	for	Michelle	Obama’s	push	on	college	completion:	First	Lady Michelle	Obama	gave	

a	policy	speech	on	November	12	that	talked	about	the	importance of	college	going	for	low-income	students.	

She	also	emphasized	the	importance	of choosing	the	right	college	and	that	students	should	strive	to	pick	

more	challenging 1	Kevin	Carey	and	Andrew	Kelly,	“The	Truth	Behind	Higher	Education	Disclosure	Laws,”	

Education	Sector, November	2011,	http://www.educationsector.org/publications/truth-behind-highereducationdisclosure-laws. institutions—a	policy	goal	also	endorsed	by	a	meeting	of	high-level	presidential	

advisers that	same	day.	2

The	call	for	a	focus	on	college	selection	is	based	upon	multiple	research	studies	that have	shown	how	a	large	

number	of	low-income	students	end	up	choosing	colleges where	they	are	not	as	likely	to	graduate	as	other	

options,	and	that	those	who	pick colleges	for	which	they	are	academically	overqualified	are	less	likely	to	

graduate	than their	peers	who	pick	institutions	for	which	they	appear	underqualified.	But	there	are limited	

available	resources	to	address	this	problem	because	students	can	only	be presented	with	completion	rates	

overall	or	by	race	and	gender.	There	is	no	way	to	tell low-income	students	about	where	they	are	more	likely	

to	finish.	This	is	particularly important	if	one	of	the	barriers	for	poorer	students	to	choosing	a	college	is	fear	

of	high sticker	price.	Making	this	information	centrally	available	would	make	it	possible	to	add	it to	future	

iterations	of	the	College	Scorecard	and	empower	other	direct	service organizations	to	get	these	data	in	front	

of	students.	The	result	would	be	better	college choices	and	greater	rates	of	completion	that	are	aligned	with	

the	First	Lady’s	goal.

These	data	will	be	crucial	for	the	President’s	proposed	ratings	system:	The	centerpiece	of President	Obama’s	

plan	for	postsecondary	education	is	to	create	a	ratings	system	and ask	Congress	to	tie	it	to	student	financial	

aid.	Knowing	the	success	rate	of	students receiving	some	of	the	$150	billion	in	federal	student	aid	is	a	crucial	

element	for	building this	system	properly,	especially	to	ensure	that	colleges	are	adequately	serving	low	

income students.	Without	adding	these	data	to	IPEDS,	neither	the	Department	nor anyone	else	will	be	able	to	

produce	these	data,	potentially	ruining	or	severely	limiting the	entire	ratings	system	push.
These	graduation	rates	cannot	be	done	through	the	National	Student	Loan	Data	System (NSLDS):	In	previous	

responses	to	commenters,	NCES	noted	that	changes	made	to NSLDS	will	make	it	possible	to	calculate	Pell	

Grant	graduation	rates	without	needing	to resort	to	institutional	reporting.	Unfortunately,	our	

understanding	of	changes	to	NSLDS suggests	this	would	at	best	be	an	incomplete	solution	for	Pell	Grant	

graduation	rates and	is	not	a	feasible	solution	for	other	required	measures.

For	Pell	Grant	graduation	rates,	a	completion	flag	in	NSLDS	will	not	solve	issues	of properly	constructing	a	

cohort	of	recipients	for	the	purposes	of	determining	whether	or not	someone	finished	in	a	given	amount	of	

time,	since	students	may	not	get	Pell	Grants in	their	first	year	or	may	not	receive	them	each	year	until	they	

finish.	And	even	if	a	Pell 2	Michael	Statford,	“The	Obamas’	New	Focus,”	Inside	Higher	Ed,	November	13,	2013,

http://www.insidehighered.com/news/2013/11/13/michelle-obama-speech-signals-newadministrationfocus-boosting-low-income-college. recipient	cohort	could	be	constructed,	it would	not	be	

comparable	to	any	other completion	cohort,	limiting	its	value	for	comparison	purposes.	Finally,	because	

NSLDS only	contains	information	on	federal	student	aid	recipients	it	would	not	be	able	to calculate	the	

required	graduation	rate	of	students	who	did	not	receive	a	Pell	Grant	or	a Subsidized	Stafford	Loan.

These	data	could	be	calculated	using	existing	cohorts	that	institutions	already	report: Though	we	understand	

that	there	has	not	been	a	technical	review	panel	on	the	best	way to	calculate	these	measures,	colleges	could	

presumably	formulate	these	numbers	with the	existing	cohort	used	to	calculate	graduation	rates	under	the	

Student	Right	to	Know Act	(SRKA).	An	institution	could	take	the	denominator	it	already	uses	for	calculating

graduation	rates	under	SRKA	and	then	select	the	subset	of	students	within	that	group that	received	a	Pell	

Grant,	a	Subsidized	Stafford	Loan	and	no	Pell	Grant,	or	neither	of those	forms	of	aid	in	their	first	year.3	It	

could	then	calculate	the	completion	rate	for these	subsets	by	looking	at	how	many	of	them	show	up	in	the	

numerator	of	the	SRKA graduation	rate.	This	process	would	only	require	checking	a	roster	of	names	against	

aid receipt	information	and	leaves	the	vast	majority	of	the	legwork	around	cohort construction	to existing	

and	well	understood	processes.

A	Compromise	Solution:	Require	URL	Reporting

We	understand	that	adding	items	to	IPEDS	usually	involves	holding	a	technical	review	panel	and following	a	

number	of	steps	before	variables	are	added	to	the	surveys.	At the	same	time, colleges	have	been	required	to	

make	these	data	available	for	years	and	waiting	an indeterminate	amount	of	time	for	them	to	properly	

comply	with	a	federal	law	seems unreasonable.	Therefore,	we	recommend	NCES	balance	the	concerns	

around	timing,	burden, and	consumer	need	by	taking	two	steps.	First,	add	in	a	requirement	for	institutions	to	

provide through	IPEDS	a	URL	for	the	location	where	their	fulfillment	of	these	three	graduation	rates	can be	

obtained	immediately	for	the	next	IPEDS	reporting	period.	The	added	burden	of	including this	URL	would	be	

minimal,	since	it	is	a	single	item	that	does	not	require	any	calculation	by	the institution.	This	is	not	unusual	

IPEDS	practice—colleges	already	have	to	report	the	web	link	for their	net	price	calculators,	for	example.	

While	only	knowing	the	website	where	information	is stored	is	not	ideal,	it	does	provide	a	way	to	simply	give	

the	public	information	on	where	a college	is	fulfilling	its	legal	requirement	without	adding	more	work.

Second,	we	ask	NCES	to	add	these	graduation	measures	to	its	schedule	of	technical	review panels.	Adding	it	

to	the	agenda	will	start	the	process	for	adding	all	of	these	completion	rates— and	not	just	the	ones	for	Pell	

Grant	recipients—into	IPEDS.

Fulfill	Congressional	Intent

The	conference	report	accompanying	the	Higher	Education	Opportunity	Act	noted	that	Congress added	the	

disaggregation	requirements	because	it	believes	they	“will	yield	important information	regarding	the	degree	

to	which	different	types	of	students	are	completing postsecondary	education	programs.”4	Clearly	Congress	

thought	this	information	was	important to	put	in	the	hands	of	consumers,	which	is	why	it	kept	this	provision	

in	the	bill	after	a	decade’s worth	of	work,	specified	that	students	should	have	access	to	it,	and	called	for	an	

entire	special committee	to	meet	over	several	years	to	make	sure	the	rates	were	fair	to	two-year	colleges.

Adding	these	rates	into	IPEDS	is	the	single	best	way	to	ensure	that	Congressional	intent	is carried	out.
Thank	you	in	advance	for	your	consideration.

Sincerely,

The	Education	Policy	Program

New	America	Foundation

4	HEOA	Conference	Report,	Page	550:	http://www.gpo.gov/fdsys/pkg/CRPT-110hrpt803/pdf/CRPT110hrpt803.pdf

Response-Title	IV

Dear Mr. Gonzalez, Ms. Gomez, Ms. Hayes, Ms. Jensen, Ms. Magnelia, Ms. Maudsley, Mr. Moore, Ms. 

Rodriguez, Ms. Beyers, Ms. Sliney, Ms. Parrott, and anonymous commenters,

Thank you for your comments submitted during the second 30-day review process, responding to a request for 

comments on proposed changes to the Department of Education’s Integrated Postsecondary Education Data System 

(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.

Your suggestions for collecting data to calculate cumulative debt at graduation and graduation rate information for 

Pell recipients have been discussed at past meetings of the IPEDS Technical Review Panel (TRP) and the National 

Postsecondary Education Cooperative (NPEC), and have been carefully considered by NCES. Currently, much of 

this information is available at a national level through the National Postsecondary Student Aid Study (NPSAS) and 

its associated postsecondary longitudinal sample surveys. The Department of Education also feels that these are

important data to have at the institutional level—Federal Student Aid (FSA) has already begun to make changes to 

the National Student Loan Data System (NSLDS) 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 this information. Further, IPEDS would not be able to provide these data any 

sooner than it is expected to be available from the National Student Loan Data System (NSLDS). 

Sincerely Yours,

Richard J. Reeves

Program Director, Postsecondary Institutional Studies Program

Comment	Veterans

Document: ED-2013-ICCD-0128-0029

Name: Anonymous

We write to commend the Education Department for its proposals to improve its Integrated Postsecondary 

Education Data System (IPEDS) data collection.

First, we support the Department’s proposal to expand its database beyond “first-time, full-time” students by 

collecting information on returning (i.e., “non-first-time”) and part-time students similar to the information 

collected on first-time, full-time students. This is an important and long overdue change. Many students, including 

veterans, attend college part-time, and many return to college after military service or another break.

Second, we support the Department’s proposal to collect and make available data on veterans and military 

education assistance, especially:

• The Post-9/11 GI Bill

• Yellow Ribbon Program

• Credit for military training

• Dedicated point of contact for support services for veterans, military service members, and their families

• Recognized student veteran organization on campus

• Member of the Service members Opportunity Colleges
• URL for tuition policies specifically related to veterans and military service members

• Number of students receiving Post-9/11 GI Bill benefits and the total dollar amount of tuition and fee benefits 

awarded to them through the institution

• Number of students receiving DoD Tuition Assistance and the total dollar amount of DoD Tuition Assistance 

awarded to them through the institution

We concur with the Department’s IPEDS Technical Review Panel recommendation that these data points are 

“necessary for policy-making and analysis and to improve information available to veterans and military service 

members considering postsecondary education.”

In addition to capturing the data on students’ completion, retention, and graduation, the Department should also 

collaborate with the Departments of Defense and Veterans Affairs to make available more comprehensive data on 

the total dollar amounts and number of students utilizing G.I. Bill and military education aid. Please also ensure 

collection and cross-reference of VA facility codes (school code numbers) for GI Bill to ensure VA is able to 

regularly update its institutional crosswalk with the Department of Education, which is necessary to comply with 

the requirement in P.L. 112-249 and Executive Order 13607 that VA develop a school comparison tool for collegebound veterans.

Third, we support the Department’s decision to require for-profit colleges to submit the same data as non-profit 

colleges. We also support the Department’s proposal to disaggregate the data on expenses. A key data point is 

instructional expenses versus other costs. We agree with the Department’s rationale that this proposed change will 

increase data comparability across institutional sectors. More transparency is needed than exists today, not less.

Finally, please consider collecting data on students’ debt upon graduation. Students’ debt load is a key factor and is 

needed for full transparency to help students choose a college. As you may know, even students using the G.I. Bill 

may take on debt.

Thank you.

Signed,

Association of the U.S. Navy

Iraq & Afghanistan Veterans of America

Initiative to Protect Student Veterans, University of San Diego Law School

National Guard Association of the U.S.

Paralyzed Veterans of America

Student Veterans of America

Veterans Education Success

Veterans for Common Sense

Veterans Student Loan Relief Fund

VetJobs

VetsFirst, a Program of United Spinal Association

Vietnam Veterans of America

Document: ED-2013-ICCD-0128-0022

Name: Steve Gonzalez

Response-Veterans

Dear Ms. Rohan,

Thank you for your comments submitted during the second 30-day review process, responding to a request for 

comments on proposed changes to the Department of Education’s Integrated Postsecondary Education Data System 

(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.

NCES appreciates your comment regarding the desire to have IPEDS collect completion and retention data on 

veterans and service members in addition to the other proposed items. The November 2011 IPEDS Technical 

Review Panel (TRP) (TRP # 36, Collecting Data on Veterans) on this topic discussed the possibility of adding 

completion and retention information for veterans and service members, however the panel ultimately concluded 

that IPEDS is not the appropriate instrument for collection of this information. Given that service members are a 

particularly transient population due to the nature of their work, an institution level data collection such as IPEDS 

would not effectively capture their educational activity since it does not capture the movement of individual 

students between institutions. ED continues to work closely with the Department of Veterans Affairs (VA) and the 

Department of Defense (DoD) as they refine their existing data systems to provide this information. 

With respect to your 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 begun working on creating such a crosswalk. 

Your suggestions for collecting data to calculate cumulative debt at graduation and graduation rate information for 

Pell recipients have been discussed at past meetings of the IPEDS Technical Review Panel (TRP) and the National 

Postsecondary Education Cooperative (NPEC), and have been carefully considered by NCES. Currently, much of 

this information is available at a national level through the National Postsecondary Student Aid Study (NPSAS) and 

its associated postsecondary longitudinal sample surveys. The Department of Education also feels that these are 

important data to have at the institutional level—Federal Student Aid (FSA) has already begun to make changes to 

the National Student Loan Data System (NSLDS) 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 this information. Further, IPEDS would not be able to provide these data any 

sooner than it is expected to be available from the National Student Loan Data System (NSLDS). 

Thank you again for your comments and your interest in the IPEDS data collection.

Sincerely,

Richard J. Reeves

Program Director, Postsecondary Institutional Studies Program

Comments-Cohorts	and	Duration

Document: ED-2013-ICCD-0128-0007

Name: Tod Massa

Data collections should be expanded to include graduation rates for each Title IV program, for full and part time 

students, new and transfer. Students should be tracked for 10 years. Additional sub-cohorts of veterans, gender, 

race/ethnicity, family income ranges at entry, and prior academic achievement should also be included.

Ideally, these cohort reports would include ALL levels of students, undergraduate and graduate with term-based 

enrollment/completion status. This would allow elimination of the Fall Enrollment, Completions, and GRS Surveys 

as the same data could be derived from properly constructed cohort reporting.

An example can be found at http://research.schev.edu/?xIXP

Admittedly, this would be easier and more cost effective to do with a national unit record collection, particularly as 

envisioned in the Student Right-to-Know Before You Go Act (Wyden, Rubio, Warner).

Another solution, that could be very effective and cost efficient, would be to create partnership arrangements with 

states. Most states have postsecondary longitudinal unit record systems that cover most students in the state. These 

states could develop and submit aggregate cohort tracking reports with relative ease and submit those on behalf of 

the institutions.

Institutions not in a state's collection could chose to join the collection or that of another provider. Multi-state 
collaboratives cold also be developed.

Basically, IPEDS is inadequate and burdensome for today's needs. We need to fundamentally rethink its structure. 

If moving to a unit record system is not possible, we should move to a consolidated cohort model that would 

eliminate existing surveys and allow institutions to focus on just one model of data aggregation and submission - a 

model that would probably improve the focus of their own analysis for improved retention.

Document: ED-2013-ICCD-0128-0024

Name: Kent Phillippe

Ms. Kate Mullan,

We are writing in response to the request for comments on the Agency Information Collection Activities; 

Proposals, Submissions, and Approvals; Extension of Public Comment Period. Our comments can be found in the 

attached document.

Kent A. Phillippe

On behalf of the American Association of Community Colleges (AACC) and the more than 1,100 institutions we 

represent, I appreciate the thoughtful response and consideration that was given in developing the proposed 

changes to the IPEDS Outcomes Measures following our comments in the last round of review. However, AACC 

does not support the changes as recommended.

The inclusion of only one outcome measure at six years (graduation) is not a change AACC can endorse, and AACC 

continues to request NCES collect all of the outcome measures after a six-year, not eight-year tracking period, as 

is currently proposed. To put our position in better perspective, AACC would like to highlight the history and 

rationale for the new measures.

The newly proposed measures are the result of recommendations from the Committee on Measures of Student 

Success. The charge to this committee was “The Committee on Measures of Student Success will develop 

recommendations for the Secretary of education regarding the accurate calculation and reporting of completion 

or graduation rates of entering certificate- or degree-seeking, full-time, undergraduate students by two-year 

degree-granting institutions of higher education. The Committee may also recommend additional or alternative 

measures of student success that are comparable alternatives to the completion or graduation rates of entering 

degree-seeking full-time undergraduate students, taking into account the mission and role of two-year degreegranting higher education institutions.”

The recent proposal of alternate measures does not meet the standard of “taking into account the mission and 

role of two-year degree-granting institutions”. 

First, by only adding the graduation at six years, NCES is perpetuating a long held issue the community college 

sector has had with outcomes reporting by NCES—the failure to recognize the importance of transfer when 

reporting outcomes. In fact, the Student Right to Know legislation and regulations specifically include transfer as 

part of the completion measures defined. The proposed new data collection is clearly identified as “Outcome 

Measures” and to single out one measure (graduation) at a specified period minimizes the importance of the 
other mission appropriate measures. As a result, the inclusion of only graduation at a six-year time period is not a 

solution AACC can endorse. 

Second, AACC maintains that measures for community colleges do not need to be the same as those used for 

other sectors, and that the one size fits all approach will not best serve the interests of the colleges in measuring 

their ability to meet their mission and role in higher education. 

At no point does the charge of the commission specify that they are to develop measures for all of higher 

education. Of particular note, the charge to this commission specifically states that it was to develop alternate 

measures “taking into account the mission and role of two-year degree-granting higher education institutions.” It 

is troubling that NCES is choosing to proceed with measures that ignore this specific charge given to the 

commission, in favor of using the augment that “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 policymakers for 

guiding efforts to improve student outcomes and success in higher education.” 

AACC recognizes the desire for a Federal statistical agency to develop measures that are appropriate to all of 

higher education. However, AACC cannot support this when it clearly goes against the desires of a specific sector, 

and ignores the original intent and rational for the development of these measures. In the response it is stated 

that “Alignment with other measures like the VFA does not directly fit within the Department’s responsibility for 

this measure.” AACC acknowledges that NCES is not responsible for aligning measures with outside organizations; 

however, ignoring the desires of a sector to provide measures that the sector believes are mission and role 

appropriate is antithetical to the original intent of developing these measures. 

Community colleges have come to agreement on using a six-year cohort as the most mission appropriate 

timeframe for tracking outcomes for community college students, and this is being implemented in a wide variety 

of settings, not just the VFA. It is true, as stated in the recent response to comments that “... the additional 2 

years allows for more students, particularly those attending part-time, to be captured as completers in the OM 

component.” However, community colleges believe that a six-year time frame is more appropriate for policy and 

decision making for assessing outcomes for community college students given their mission and roles, and that 

eight years will not be acceptable to many state and local policy makers. 

AACC strongly encourages NCES to collect all the outcome measures at the end of a six year tracking period—this 

will be consistent with current practice in accountability for community colleges in a wide range of settings, 

including the Voluntary Framework of Accountability in which more than 140 Community college have 

participated, the California Scorecard with more than 110 community colleges, the National Community College 

Benchmarking project with over 250 community colleges, and many other state accountability reporting systems. 

AACC strongly encourages NCES to consider the mission and role of two-year degree granting institutions as was 

the charge of the Committee on Measures of Student Success, and allow a different standard for reporting 

outcomes that are endorsed by the sector rather than imposed as a ubiquitous measure for utility sake.

Kent A. Phillippe

Associate Vice President, Research and Student Success, American Association of Community Colleges

Response-Cohorts	and	Duration

Dear Mr. Massa and Dr. Phillippe,

Thank you for your comments submitted during the second 30-day review process, responding to a request for 

comments on proposed changes to the Department of Education’s Integrated Postsecondary Education Data System 
(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.

Your comments on the length of time a cohort should be tracked represent two of three distinct perspectives that 

have been conveyed to NCES during this comment process. Respondents have requested 6-, 8-, and 10- year 

outcomes. Rarely does a requester indicate a different cohort tracking duration than one of those three. NCES has 

selected to report final outcomes based on an 8-year tracking model for outcomes measures. There will be a place 

for institutions to report the counts of students that received an award at the 6-year point in time as well. We 

believe this method represents the best measure for student outcomes.

The concept of state level coordination is a valid suggestion and 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. Further, entire meetings of the IPEDS Technical Review 

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)

Some states do submit data for the institutions that are represented by the state higher education agency or 

coordinating authority. Often the institution then verifies and locks this information. However, not all states have a 

central office that is established for federal reporting. At this time, state level coordination of reporting is 

voluntary.

The present structure of IPEDS reporting satisfies current legislative and regulatory requirements. Movement to a 

cohort reporting model with more subgroups, or a unit record model, would require additional study and, in some 

cases, changes in law.

Sincerely Yours,

Richard J. Reeves

Program Director, Postsecondary Institutional Studies Program

Comment	Organization: IHEP,	CLASP,	DQC,	NCAN,	College	Board,	Chamber	of	Commerce,	SHEOO

Document: ED-2013-ICCD-0128-0023

Name: Mamie Voight

Submitter's Representative: Mamie Voight

Organization: IHEP, CLASP, DQC, NCAN

November 14, 2013 

Ms. Kate Mullan, Acting Director, Information Collection Clearance Division 

U.S. Department of Education 

400 Maryland Avenue SW, Washington, DC 20202-4537 

Dear Ms. Mullan: 

This letter is in response to the Department of Education’s notice of the collection (OMB Control Number: 1850-

0582), published in the Federal Register on October 2, 2013 and updated on October 23, 2013. The Institute for 

Higher Education Policy (IHEP) is a nonpartisan, nonprofit organization committed to promoting access to and 

success in higher education for all students, particularly those who have traditionally been underserved by our 

postsecondary system. We produce innovative and timely research to inform both policy and practice. 
Given IHEP’s contribution to the research community, we recognize the importance of data. Specifically, we 

recognize that data are key to understanding the challenges facing our postsecondary system, developing policy 

solutions to address them, and providing relevant and actionable information to consumers, policymakers, and 

institutions alike. IPEDS is a critical component of our postsecondary data infrastructure, providing detailed data 

at the institution level to inform institutional improvement efforts, consumer decisions, and to safeguard taxpayer 

dollars. We applaud the Department’s efforts to improve the outcome reporting within IPEDS, as to capture 

better data on actual student progression and success. For consistency and usability purposes, we highly 

recommend that these new outcome measures be reported in a way that allows for the calculation of graduation 

rates that are analogous to those already reported through the Graduation Rate Survey (GRS). Not only is this 

alignment essential to create usable, understandable data, but it also will help reduce complexity and reporting 

burden. Complementary to these specific suggestions about the alignment of the new outcome measures with 

the GRS survey, we also offer the following recommendations for making the IPEDS collection as useful as 

possible:

• Disaggregate the outcome measures by credential type, reporting outcomes for bachelor’s-seeking students 

separately from associate-seeking and certificate-seeking students. Institutions increasingly are offering a diverse 

array of credentials, and aggregating outcomes across these programs of differing lengths could create misleading 

results. 

• Include better information on transfer, including whether students transfer upward (e.g. two-year to four-year), 

laterally (e.g. two-year to two-year), or in reverse (e.g. four-year to two-year). This distinction will provide a far 

more robust understanding of student movement throughout the postsecondary system. 

• Minimize reporting burden and maximize usability by aligning the new outcome measures as closely as possible 

with the existing Graduation Rate Survey (GRS). Using slightly different definitions for the outcome measures than 

for the GRS likely will add complexity and decrease usability. 

• Require institutions to report graduation rates by financial aid status to IPEDS. While institutions are required to 

disclose these data upon request, they are not widely available or accessible in a central location. 

•	Require institutions to report graduation rates by military status to IPEDS. Institution-level data on the success 

rates of service men and women are unavailable, and IPEDS is the best tool available to collect this information. 

• Require institutions to report cumulative debt measures to IPEDS. Institutions should report data to IPEDS on 

cumulative federal debt and cumulative private debt, disaggregated by completion status. 

Outcome Measures 

Disaggregate Student Outcome Data by Credential Type 

The new outcome measures, as proposed, do not separate students in bachelor’s programs from those in 

associate programs or certificate programs. For four-year institutions, the current Graduation Rate Survey –

rightfully – allows for separating bachelor’s-seeking students from students in shorter programs in both the 

cohort specification and the counts of completers, thereby allowing for a variety of completion rates to be 

calculated. Institutions with substantial numbers of students in associate or certificate programs likely will have 

higher graduation rates than if they were to be measured on their bachelor’s programs only. For example, the 

University of Phoenix’s Online Campus has a total graduation rate of 17 percent, but a bachelor’s-seeking 

graduation rate of only 6 percent. Clearly, the 17 percent total graduation rate is masking the lower completion 

rates of students in bachelor’s programs. This distinction is vitally important to students who are considering a 

particular type of credential from an institution that offers a variety of award levels. Without the bachelor’sspecific data available in the GRS, a student considering a bachelor’s degree from the University of Phoenix’s 

Online Program could mistake their chance of completion for being nearly three times higher than it actually 

would be (17% vs. 6%). We strongly encourage the Department to disaggregate both cohort and completion data 

by level of credential sought and level of credential awarded. Additionally, these credential levels should be 

adjusted to align with the undergraduate credential levels reported in the Completions Survey: associate,

bachelor, less-than-one-year certificate, one-to-two year certificate, two-to-four year certificate. 
Certainly – as the Department has pointed out previously – success can be measured in a number of ways. 

However, disaggregating the outcome data by type of award does not preclude some awards from counting as 

“successes,” nor does it pass judgment on the quality or value of different credentials. Rather, this disaggregation 

would provide consumers and policymakers with more comprehensive, clear, and comparable data that can be 

used to inform decisions without inadvertently misleading. We do not suggest that some awards be counted and 

others omitted, but instead recommend that all awards be counted, but disaggregated. 

Include Better Information on Transfer 

By only providing data on the number of students who subsequently enroll at another institution, the Outcome 

Measures as proposed do not provide adequate information about student transfer. To get a complete 

understanding of student movement throughout the postsecondary system, institutions should report the 

number of students who subsequently enroll in a four-year institution, the number of students who subsequently 

enroll in a two-year institution, and the number of students who subsequently enroll in a less-than-two-year 

institution. This disaggregation by level of receiving institution does not pass judgment on the type of institution, 

but rather, provides a more robust and accurate picture of student outcomes and pathways. Students enter 

postsecondary education with a variety of goals in mind, and they should have access to information that clearly 

reflects their ability to achieve those various goals. 

While the Department has noted that disaggregating transfers by level of receiving institution could be overly 

burdensome for institutions, we disagree, and contend that this information is essential. The same data run that 

determines if a student enrolled at another institution, likely will determine which institution the student enrolled 

in, allowing the initial institution to report the level of receiving institution without a large additional burden. In 

fact, institutions and higher education systems across the country already are reporting transfer data with this 

level of detail through voluntary initiatives like Complete College America (www.completecollege.org) and Access 

to Success (http://www.edtrust.org/issues/higher-education/access-to-success) – an initiative led by The 

Education Trust and the National Association of System Heads. Finally, we understand that students may transfer 

into a program that does not match the institution’s level (e.g. an associate program at a four-year institution). 

However, this limitation should not preclude efforts to collect better data on upward and lateral transfers. Even if 

imperfect, transfer data disaggregated by level of receiving institution would represent a substantial improvement 

over current data sources and would greatly improve the quality of the proposed outcome measures. 

Minimizing Reporting Burden and Maximizing Usability 

Improved data on student outcomes in our postsecondary system are crucial, but we must balance this need for 

better information with the associated institutional burden and the usability of the data produced. By creating a 

new Outcome Measures component, rather than incorporating the outcome data on part-time and transfer 

students into the Graduation Rate Survey (GRS), this proposal risks increasing burden unnecessarily and reducing 

usability. 

Burden 

We realize that the Department is attempting to minimize burden by not requiring all of the disaggregations 

(race/ethnicity and gender) that are included in the current GRS. However, these disaggregated rates provide a 

crucial look at how well different students fare at individual institutions. A number of voluntary postsecondary 

data efforts – such as the Voluntary Framework of Accountability, Complete College America, and Access to 

Success – have recognized the importance of these disaggregations and incorporated them into their reporting 

mechanisms, proving that such data collection is not overly burdensome, but in fact worthwhile and highly 

desirable. 

Creating a new survey component that uses slightly different specifications may actually increase burden more 

than incorporating the new data points into the existing GRS. Under the current proposal, institutions will need to 

make calculations on both components separately – and those calculations will not fully align. For example, the 

GRS tracks student outcomes for 100%, 150%, and 200% of time, while the new outcome measures will track 
outcomes for six years and eight years. For four-year institutions, six years is equivalent to 150% of time and eight 

years is equivalent to 200%, but two-year and less-than-two year institutions will not benefit from this alignment. 

Instead, they will need to report completely new data. Furthermore, neither of these components aligns with 

IPEDS’ first-to-second-year retention rates, which are reported separately for first-time, full-time students and 

first-time part-time students, but not disaggregated by race/ethnicity, gender. At four-year institutions, the 

retention rates are reported only for first-time bachelor’s-seeking students, even if many students at the 

institution are pursuing other types of credentials. At less-than-four-year institutions, the retention rates are 

reported for a cohort of all first-time degree/certificate-seeking students.

Usability 

Under the proposed specifications, the new outcome data will not be directly comparable to the existing GRS 

data. As mentioned above, the timeframes will not align for less-than-four-year institutions. Also, as discussed at 

the beginning of this letter (under “By Degree Credential Type”), the new outcome measures will not create a 

completion rate for bachelor’s-seeking students that is analogous to the bachelor’s-seeking graduation rate in the 

GRS. Having a host of new outcome measures that cannot be compared directly to the existing graduation rates –

which the postsecondary community already is accustomed to using – will create usability and consistency 

challenges throughout the system. Minimally, college leaders should be able to use these data to understand how 

a cohort of students is progressing into and through their institutions; but they will not be able to do so with these 

data since the various survey cohorts do not align across the pipeline (e.g. enrollment, retention, 

completion/transfer, further enrollment, drop out). 

To address these issues of burden and usability, we recommend using 100%, 150%, and 200% timeframes instead 

of six and eight years as currently proposed in the new Outcome Measures. We also recommend that instead of 

creating an entirely new component, the Department should incorporate into the existing GRS: 

(1) the three new cohorts (first-time, part-time; non-first-time, full-time; and non-first-time, part-time), 

disaggregated by type of credential sought (associate, bachelor, less-than-one-year certificate, one-to-two year 

certificate, two-to-four year certificate), and 

(2) new outcome measures for all four cohorts. These outcome measures should include the number of students 

who – within 100%, 150%, and 200% of time:

a. Received a bachelor’s degree, 

b. Received an associate degree, 

c. Received a less-than-one-year certificate, 

d. Received a one-to-two-year certificate, 

e. Received a two-to-four-year certificate, 

f. Are still enrolled at the same institution, 

g. Are subsequently enrolled at another four-year institution, 

h. Are subsequently enrolled at another two-year institution, 

i. Are subsequently enrolled at another less-than-two-year institution, 

j. Have an unknown subsequent enrollment status, and 

k. Did not receive an award. 

Data are already available on the number of students who are still enrolled after 200% of time and on the number 

of students who transfer out (for institutions with a transfer mission or institutions that voluntarily report), so 

some of these recommended data points could be populated with data that already are being collected. 

Ideally, these new cohorts and outcomes should be disaggregated by race/ethnicity and gender to align with the 

existing first-time, full-time graduation rates. At the very least though, the Department should leverage the 

existing GRS survey to ensure alignment with current data collection efforts, even if the new metrics are not fully 

disaggregated at this time. 

Other Improvements to Graduation Rate Survey 
Better information on the success of transfer and part-time students through these new outcome measures is 

key, but other crucial revisions to IPEDS are necessary to provide a more complete picture of student success. 

Recommended improvements to IPEDS are outlined below. 

Graduation Rates By Financial Aid Status 

Current data do not provide information on how well various institutions are performing with students from 

different socioeconomic backgrounds. Disaggregating graduation rate data by race and gender has uncovered a 

host of inequities that would have remained hidden otherwise. These data also have uncovered bright spots of 

promise, where some institutions are performing particularly well with underserved student populations; 

provided students with useful information to inform their college decisions; and helped institutions identify 

populations on which to focus their improvement efforts. Graduation rate data by income level – or financial aid 

status, as a proxy – would provide another set of rich information. As such, we strongly recommend that the 

National Center for Education Statistics (NCES) require institutions to report graduation rates separately for (1) 

Pell Grant recipients, (2) Non-Pell Grant recipients who receive subsidized Stafford loans, and (3) Non-Pell Grant 

recipients who do not receive subsidized Stafford loans. This data collection would estimate institution-level 

graduation rate for low-income, middle-income, and high-income students and should be integrated into the GRS 

and the new Outcome Measures component. All institutions already are required to calculate these graduation 

rates to meet disclosure requirements,1 so reporting these data to IPEDS should not represent an additional data 

collection burden. Also, more than 500 institutions, 19 systems, and about 30 states already are collecting and 

reporting similar information through initiatives like Access to Success, Complete College America, and the 

Voluntary Framework of Accountability, proving that such data collection is indeed possible. 

1	“Information Required to Be Disclosed Under the Higher Education Act of 1965: Suggestions for Dissemination,” 

National Postsecondary Education Cooperative, October 28, 2009, http://nces.ed.gov/pubs2010/2010831rev.pdf 

2	“Report and Suggestions from IPEDS Technical Review Panel #36 Collecting Data on Veterans,” RTI International, 

https://edsurveys.rti.org/IPEDS_TRP/documents/Report%20and%20Suggestions%20from%20TRP36_final.pdf 

While the NCES sample surveys provide a glimpse into national level success rates of students from different 

socioeconomic backgrounds, they do not provide the necessary institution-level data to truly inform decisionmaking. Also, we understand that the Department is working to calculate graduation rates for Pell Grant 

recipients using the National Student Loan Data System (NSLDS). However, the data in NSLDS cannot be used to 

calculate an accurate comparison graduation rate for non-Pell/non-subsidized Stafford loan recipients because 

only Title IV aid recipients are included in the database. Furthermore, any data using the new completion flag in 

NSLDS are untested and rely on the accuracy, completeness, and adequacy of institutional reporting to NSLDS. At 

least until these new data are proven to be of high quality, IPEDS serves as a better data collection and reporting 

tool – particularly for this data element, which institutions are required to calculate under current law. 

Graduation Rates By Military Status 

Just as graduation rate data should be disaggregated by race/ethnicity, gender, and financial aid status, they also 

should be disaggregated by military status to measure the success rates of veterans and service members. 

Members of the military are increasingly seeking out educational opportunities in which to invest their Post-9/11 

GI Bill and Military Tuition Assistance Program funds – programs that funded 1.2 million students in Fiscal Year 

2010.2 We owe our servicemen and women access to accurate information that will help them select institutions 

that offer them the greatest chance of success. At the very least, IPEDS should collect data on 150% graduation 

rates of first-time, full-time (1) veterans, (2) service members, and (3) non-military students. Ideally, all outcome 

measures (first-time, full-time; first-time, part-time; non-first-time, full-time; non-first-time, part-time) should be 

disaggregated by military status. 

Cumulative Debt 
As concern mounts over the rising cost of college and the burdensome debt students are incurring to access and 

complete higher education, better information is necessary on how much students borrow. Currently, we do not 

know how much debt students take on to attain a credential from a particular institution. To make this 

information available, institutions should be required to report data to IPEDS on median federal debt and median 

private loan debt for completers and for non-completers. While the Department has signaled efforts to calculate 

these data using NSLDS, those data suffer from the same challenges as the Pell graduation rates: the completion 

flag is untested and relies on the accuracy, completeness, and adequacy of institutional reporting to NSLDS. 

Additionally, NSLDS only includes federal student loans, without providing any data on private borrowing. Until 

the NSLDS data are tested and include data on private student loans, IPEDS should act as a conduit for this crucial 

information. 

When reported to IPEDS – or even if calculated from NSLDS – these cumulative debt data must be disaggregated 

by completers and non-completers, so as not to present misleading information as is currently presented in the 

College Scorecard. If cumulative data is calculated for completers and non-completers, combined, then an 

institution with high costs and high dropout rates could appear to have the same debt levels as an institution with 

low costs and low dropout rates. Representing these institutions as having similar levels of debt could do a great 

disservice to prospective college students. Furthermore, while data on debt loads are available at the national 

level through NCES’ sample surveys, these surveys do not provide institution-specific information that could 

inform student decision-making or targeted policymaking. 

As noted below, these comments also are supported by the Center for Law and Social Policy (CLASP), Data Quality 

Campaign, and National College Access Network (NCAN). We appreciate the Department’s efforts to improve 

postsecondary data systems and strongly support efforts to compile better, more complete data on student 

outcomes. Thank you for the opportunity to comment on these crucial changes to IPEDS and for thoughtful 

consideration of our recommendations. If you have any questions, please do not hesitate to e-mail or call Mamie 

Voight (mvoight@ihep.org, 202-587-4967) 

Sincerely, 

Michelle Asha Cooper, Ph.D. Jennifer Engle, Ph.D. 

President Vice President for Policy Research, Institute for Higher Education Policy

Julie Strawn Aimee Guidera 

Senior Fellow Founder and Executive Director, Center for Law and Social Policy Data Quality Campaign 

Kim Cook 

Executive Director, National College Access Network 

Document: ED-2013-ICCD-0128-0027

Name: Karen Lanning

Dear Ms. Mullan,

Thank you for the opportunity to provide feedback on the data collection request. As a non-profit membership 

association working on educational issues across the secondary and post-secondary continuum, the College Board 

is grateful for the opportunity to provide feedback that can help to improve the Department of Education’s data 

collection efforts.

Our comments center on two major areas:

• Graduation rates

• Student transfer and mobility patterns

These recommendations are intended to increase our collective understanding of how different students navigate 

the higher education system and to improve the data available to students and families as they make the important 

decisions of where to apply and enroll in college.
Graduation Rates for Pell Grant Recipients:

The Pell Grant program is considered the nation’s bedrock federal student aid program and has received widespread 

support from both political parties in Congress. However, because of the recent increases in program costs and lack 

of clear evidence associated with post-secondary outcomes for Pell Grant recipients, there is an urgent need for data 

to demonstrate the impact of this important program.

Further, capturing and publicly reporting graduation rate data disaggregated by Pell Grant status will help students 

and families make more informed college enrollment decisions. It will enable students from low-income families in 

particular to personalize the data and thereby gauge their chances of success in the context of graduation rates of 

students from similar financial backgrounds. Because a majority of institutions currently report these data to other 

entities, we do not believe this reporting requirement will pose an undue burden on institutions.

With approximately 8.8 million Pell Grant recipients attending U.S. institutions and the 2012-2013 expenditures 

hovering around $32 billion, measuring the extent to which this investment leads to positive outcomes is essential 

to informing public policy and cannot be accomplished without more complete and disaggregated data for Pell 

Grant recipients.

We recommend that institutions be required to report graduation rates for Pell Grant recipients.

Graduation Rates By Military Status:

Military service members and veterans are an important and increasing segment of our postsecondary student 

population. Therefore, IPEDS should disaggregate graduation rates by military status. Members of the military and 

their families deserve the opportunity to make informed choices on where to best use the benefits they have earned 

through their military service. Disaggregating the data to show the outcomes of various military student populations 

(full-time/full-year, part-time, etc.) will indicate at which institutions these students are most likely to be 

successful.

Although we suggest that military students be tracked similarly to non-military students, we recognize that their 

mobility patterns differ from those of other students. Because members of the military often enroll in one college, 

change service stations, deploy and re-deploy, the Department of Education should carefully evaluate and 

determine the best metrics to track their postsecondary success.

We recommend that institutions be required to report graduation rates for military service members and veterans.

Student Mobility and Transfer Patterns:

According to the National Student Clearinghouse Research Center, approximately one in five students who 

complete college do so at an institution other than where they started. While this may speak to a student’s ability to 

move throughout the higher education system, our current reporting methods do not allow for accurate tracking of 

these student mobility patterns.

Efforts to improve institutional reporting, such as the Student Achievement Measure Project 

(www.studentachievementmeasure.org) put forth by the six higher education presidential associations, are a major 

start. However, they fail to capture the number of transfer students and the direction in which they transfer— from a 

4-year institution to a 2-year institution, a 2-year institution to a 4-year institution, or laterally. This missing piece 

of data is an important one, as the direction of student transfer provides a more accurate picture of what happens to 

students beginning at a particular institution. Several initiatives are currently reporting transfer data with this level 

of detail, so the reporting should not be an additional burden to institutions.

We recommend that institutions be required to include details on transfer students, including whether they transfer 

from a two-year to a four-year institution or another two-year institution, or from a four-year institution to a twoyear institution.

Sincerely,
Karen Lanning

Senior Director, Federal Relations, The College Board

Document: ED-2013-ICCD-0128-0028

Name: Jaimie Matthews

Submitter's Representative: Cheryl Oldham

Organization: U.S. Chamber of Commerce

Dear Ms. Mullan:

This letter is in response to the U.S. Department of Education’s notice of the Integrated Postsecondary Education 

Data System (IPEDS) 2013–2016 collection. The U.S. Chamber of Commerce, the world’s largest business 

federation representing the interests of more than 3 million businesses of all sizes, sectors, and regions, as well as 

state and local chambers and industry associations, and dedicated to promoting, protecting, and defending 

America’s free enterprise system, is pleased that the U.S. Department of Education is seeking input from 

stakeholders to improve the design and utility of IPEDS data collection.

Given the continuing rise in cost for accessing a postsecondary education—as well as the ever growing skills gap 

that employers struggle to fill—it is of the utmost importance that we fully leverage the power of data in a system 

that can benefit from more transparent and actionable information. The Chamber believes that data collected 

through IPEDS must be significantly improved upon in order to hold institutions accountable and drive institutional 

improvement, as well as increase transparency for consumers, policymakers, and institutions to make smarter 

decisions and investments. However, as many of the changes that need to be made to IPEDS have to be made 

legislatively, the Chamber strongly encourages the Administration to work with Congress in moving these changes 

through the proper legislative process.

In order to improve upon the accuracy of IPEDS reports, the system must capture additional data colleges and 

universities are already required to collect, but are not reported through IPEDS. With that in mind, the Chamber 

recommends that graduation data for all students—including full-time and part-time—are reported. This should 

include data on Pell recipients, Subsidized Stafford Loan recipients without Pell Grants, and individuals who 

receive neither. Including this information in IPEDS would be a significant step forward in increasing transparency 

in the higher education system without imposing additional burdens on institutions. It would also help empower 

consumers to make smarter, data-informed decisions about their college choice.

In addition to expanding the graduation rate data, the Chamber recommends that IPEDS allow for disaggregating 

data by credentials, as well as program. Colleges and universities are as diverse within their institutions as they are 

when compared to one another. To ensure that students make well-informed decisions, they need access to 

information specific to their academic goals, including the experience of other students seeking a particular 

credential, as well as what programs they went through.

Special populations, including transfer students, veterans and servicemen and women, should also be included in 

IPEDS. Given the growing rate of transfer students, the complexity involved in transferring, and the challenges in 

transitioning a successful transfer into program completion, it is paramount that information pertaining to the 

experience of this population be reported. Doing so would empower this population with useful information that 

cuts across institutions.

Along the same lines, ensuring that our veterans and servicemen and women can access and complete a college 

education—in addition to successfully transitioning to employment—is critical given their sacrifice and the service 

they provide the nation. Finding ways to better capture the higher education experience of these individuals should 

be explored to the fullest.

Lastly, the U.S. Chamber would like to call attention to the need for IPEDS to continue to adapt to and grow with 

innovations taking place in higher education. Currently, there is significant discussion around the need to define 

and measure postsecondary success through employment. While the Chamber agrees that capturing this data is 

important, as policies continue to be debated and refined, ensuring that the methodologies and mechanisms used to 

capture employment data do not create an extra burden on employers is important.
Likewise, the IPEDS system will need to adapt to other disruptive innovations in higher education, such as 

competency-based learning and alternative credentialing (e.g. digital badges), that may change how postsecondary 

institutions are accessed and paid for. These same disruptions would also impact how we define outcomes and 

success.

The Chamber recognizes and appreciates the U.S. Department of Education’s willingness to improve postsecondary 

data collection, and, as such, improve the higher education experience and outcomes for students. The Chamber 

also thanks you for the opportunity to submit comments and for your consideration. I may be reached at (202) 463-

5525 or coldham@uschamber.com should you have any questions regarding our submission or wish to discuss 

further.

Sincerely,

Cheryl Oldham

Vice President, Education Policy, U.S. Chamber of Commerce

Document: ED-2013-ICCD-0128-0030

Name: Hans Lorange

Kate Mullan 

Acting Director, Information Collection Clearance Division

Privacy, Information and Records Management Services

Office of Management

U.S. Department of Education

400 Maryland Ave SW

Washington, DC 20202

Dear Ms. Mullan,

The State Higher Education Executive Officers (SHEEO) appreciates the opportunity to respond to the Department 

of Education’s notice of the Integrated Postsecondary Education Data System (IPEDS) 2013-2016 collection (OMB 

Control Number: 1850-0582), published in the Federal Register on October 2, 2013 and updated on October 23, 

2013.

SHEEO is the national association of state higher education leaders who serve statewide coordinating and 

governing boards and other state policy agencies for higher education. SHEEO seeks to advance public policies 

and educational practices to achieve more widespread access and successful participation in higher education, 

more new discoveries through research, and more applications of knowledge that improve the quality of human 

lives.

As state higher education leaders, our central preoccupation is in meeting the growing need for advanced 

educational attainment in the United States. For several years SHEEO has advocated the development of more 

robust data systems for higher education so state, federal, and institutional leaders can better understand where 

policies and practices require attention in order to foster greater attainment. SHEEO has a long history of acting as 

a steward between state level IPEDS keyholders and coordinators and the National Center for Education Statistics 

(NCES). For almost 35 years, SHEEO did this through a partnership with NCES and our work with this network of 

state level data providers continues even as this formal partnership has changed. 

IPEDS is the most comprehensive source of institutional level higher education data and continues to grow in its 

role in providing accountability and transparency to the postsecondary education system as well as providing a 

valuable resource for improving the system. We would like to echo the comments and concerns submitted by 

other education associations about several of the components of the proposed Outcome Measures. We believe 

the proposed measures provide an opportunity to collect information that will help improve data driven decision-
making, particularly as it relates to some of the most overlooked populations in our postsecondary system. 

Specifically we would appreciate serious consideration of the following changes: 

 Include Financial Aid Status, particularly Pell Status, as a breakout for Outcomes Measures and/or 

Graduation Rates.

 Align the Outcomes Measures with the existing Graduation Rate Survey to ensure consistency, reduce 

confusion and reduce reporting burden. 

 Include Veteran Graduation Rate data in addition to the other Veteran elements proposed.

Include Financial Aid Status, particularly Pell Status, as a breakout for Outcomes Measures and/or Graduation 

Rates in IPEDS.

The financial model for funding postsecondary education has transitioned over the previous decade; states 

appropriations are covering a smaller portion of the cost of college which requires many students to rely more 

heavily on federal aid and personal resources to fund their education. Additionally, our institutions of higher 

education increasingly are serving students with very different financial backgrounds and there is some evidence 

to suggest that student socioeconomic status is a key indicator of their success. As the federal government invests 

more in students through Pell-grants and subsidized student loans, it becomes increasingly important to 

understand the success of students receiving that support. Additionally, states have a key interest in ensuring 

their institutions are serving students who have financial need. Many states and systems have voluntarily entered 

into data collection efforts from groups such as Complete College America and Access to Success to track the 

success of these students. 

We are disappointed that the current recommendations do not include collecting graduation rates or outcome 

measures by student’s financial aid status. Institutions are already required to calculate these rates under the 

Higher Education Opportunity Act, and external organizations such as CCA and Access to Success have found that 

collecting these data add little additional burden to their reporting processes. Although we have heard 

conversations over the last few years about how these rates may be calculated using the National Student Loan 

Data System, those efforts have not come to fruition and it’s likely that the data provided by this effort would not 

be comparable to that currently reported in IPEDS, adding additional confusion rather than clarity to the 

conversation around the effectiveness of the postsecondary education system.

Align the Outcomes Measures with the existing Graduation Rate Survey to ensure consistency, reduce 

confusion and reduce reporting burden. 

The new outcomes measures section introduces an entirely new IPEDS component that examines outcomes 

different from those currently generated as part of the IPEDS Graduation Rate Survey (GRS). While GRS collects 

graduation rates at 100%, 150% and 200% of degree-time, the proposed outcomes measures would collect data 

for students who complete in 6-years and 8-years regardless of what degree they are seeking. These new 

outcomes measures will be collected for all degree seeking students but will not be disaggregated by degree 

seeking type. Additionally, this section will collect data on students still enrolled at their current institution, 

students enrolled at other postsecondary institutions and students who are unknown. Finally, this data will be 

collected for four cohorts, full-time, first-time students (already collected as part of the GRS survey); part-time, 

first-time students; full-time, non-first-time students; and part-time, non-first-time students. 

Although we are not opposed to adding additional details such as a student’s current status within the institution, 

we are concerned that 1) combining all degree seekers into one cohort and 2) collecting awards based on specific 

time periods (6-years and 8-years) will lead to confusion when compared to the existing graduation rate data. 

Many of our state members express challenges when multiple data sources provide conflicting figures on the 

same topic. Inconsistent data introduces confusion for both lawmakers and consumers. Additionally, it makes it 

more difficult for education agencies to provide a clear picture of the postsecondary system and its outcomes. As 

we look to greater accountability for postsecondary institutions and systems, it will be essential to have clear and 
consistent measures. SHEEO believes new cohorts and slightly different measures could obstruct good efforts for 

states to help ensure greater accountability.

Rather than introduce an entirely new section, it would likely reduce burden to integrate these new measures into 

the existing GRS survey, since institutions would not have to define different cohorts and calculate new measures. 

The three additional students types (part-time, first-time students; full-time, non-first-time students; and parttime, non-first-time students) could be added and students grouped into cohorts based on the degree they are 

seeking (as is currently done for full-time first-time students). Additionally, the additional outcomes: Did not 

receive award, still enrolled at reporting Institution; Did not receive award, subsequently enrolled at another 

institution; Did not receive award, subsequent enrollment status Unknown could be collected at the same time as 

the 200% graduation rates. 

The additional outcomes could be enhanced further by adding more specific breakouts for students enrolled at 

other institutions. It is helpful to understand student mobility when looking at enrollment in another institution as 

an outcome. Therefore, this option could be split into: Did not receive award, subsequently enrolled at a four-year 

institution; Did not receive award, subsequently enrolled at a two-year institution; Did not receive award, 

subsequently enrolled at a less than two-year institution. This would measure the type of transfer activity of the 

student. 

In addition to the other Veteran elements proposed Graduation rate data should be collected.

Finally, interest is increasing on the effectiveness of institutions as they serve veterans. Although the current 

proposal recommends collecting a number of elements related to financial aid options available to veterans and 

veteran enrollment, there is nothing that will help our members understand how well their institutions are serving 

this population. Again, these students will already be defined as part of earlier reporting components. Reporting 

on their completion provides valuable information to policy makers about the effectiveness of the funding that we 

provide these students and the ability of our system to serve them.

Thank you to the department for all your efforts to ensure continuous improvement and modernization to the 

IPEDS data collection system and thank you for giving us the opportunity to comment on these changes. 

Sincerely, 

Hans P. L’Orange

Vice President for Research and Information Resources

State Higher Education Executive Officers

Response

Dear Dr. Cooper, Dr. Engle, Ms. Strawn, Ms. Guidera, Ms. Cook, Ms. Lanning, and Mr. L’Orange,

Thank you for your comments submitted during the second 30-day review process, responding to a request for 

comments on proposed changes to the Department of Education’s Integrated Postsecondary Education Data System 

(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.

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. Further, entire 

meetings of the IPEDS Technical Review Panel have been dedicated to the topic of IPEDS reporting burden. 
Your suggestion for collecting data on private borrowing for all undergraduates is one that may be considered by a 

future meeting of the IPEDS TRP. At past meetings of the TRP, institutions have made it clear that it is not always 

known to an institution if the student has taken a private loan in addition to Title IV, state, or institutional aid they 

may be receiving. In an effort to minimize reporting burden, the data on aid received by all undergraduates were 

kept to a minimum, as the data required to calculate an average net price for an institution per the Higher Education 

Opportunity Act substantially increased the reporting burden for the Student Financial Aid component of IPEDS.

With respect to your comments about the proposed new Outcome Measures (OM) component, two separate TRPs 

were held on this topic. After much discussion, the TRP suggested that distinguishing between transfer from a 2-

year to a different 2-year institution as opposed to transfer from a 2-year to a 4-year institution was unnecessarily 

burdensome for institutions. Because this information describes an institution’s offerings and not necessarily the 

program that the student enrolled in (i.e. a student transferring to a 4-year institution could be enrolled in a subbaccalaureate certificate program, an associate’s degree program, or a bachelor’s program), it may not be 

particularly meaningful for these purposes. Further, given the substantial increase in burden that this new collection 

already places on institutions, NCES has proposed that this information be collected only from degree-granting 

institutions and only at one-point in time—namely 8 years after a student’s entry. There will be a place for 

institutions to report the counts of students that received an award at the 6-year point in time as well. Asking 

institutions to provide status updates at two different points in time would further increase burden and make the 

number of different cohorts that an institution is reporting in a given year unwieldy. To completely align the 

cohorts used in the outcomes measures would require an alignment of current legislation and further study to 

understand any structural changes in time series published by the department. 

Your suggestions for collecting data to calculate cumulative debt at graduation and graduation rate information for 

Pell recipients and other Title IV programs have been discussed at past meetings of the IPEDS Technical Review 

Panel (TRP) and National Postsecondary Education Cooperative (NPEC), and have been carefully considered by 

NCES. At past meetings of the TRP, institutions have made it clear that it is not always known to an institution if 

the student has taken a private loan in addition to Title IV, state, or institutional aid they may be receiving. Much of 

this information that is known to the institution is available at a national level through the National Postsecondary 

Student Aid Study (NPSAS) and the postsecondary longitudinal sample surveys. 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 

System (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 this information. Further, IPEDS would not be 

able to provide this data any sooner than it is expected to be available from the National Student Loan Data System 

(NSLDS). If IPEDS were to collect this information, it would not be available in the IPEDS Data Center until late 

in 2015, at the earliest.

NCES appreciates your comment regarding the desire to have IPEDS collect completion and retention data on 

veterans and service members in addition to the other proposed items. The November 2011 IPEDS Technical 

Review Panel (TRP) (TRP # 36, Collecting Data on Veterans) on this topic discussed the possibility of adding 

completion and retention information for veterans and service members, however the panel ultimately concluded 

that IPEDS is not the appropriate instrument for collection of this information. Given that service members are a 

particularly transient population due to the nature of their work, an institution level data collection such as IPEDS 

would not effectively capture their educational activity since it does not capture the movement of individual 

students between institutions. ED continues to work closely with the Department of Veterans Affairs (VA) and the 

Department of Defense (DoD) as they refine their existing data systems to provide this information. 

NCES appreciates your thoughtful comments on how better data may be made available to veterans and service 

members 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 these students, especially given that service members 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. 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 systems.

Sincerely,
Richard J. Reeves

Program Director, Postsecondary Institutional Studies Program

Veterans	Comment

Document: ED-2013-ICCD-0128-0026

Name: Ryan Gallucci

Organization: Veterans of Foreign Wars of the U.S.

To Department of Education:

On behalf of the men and women of the Veterans of Foreign Wars of the United 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 continues to support the initiative by the National Center for Education Statistics 

(NCES) to ask six specific questions through which institutions of higher learning would report additional 

information to the Integrated Postsecondary Education Data System (IPEDS), as well as changing the scope of 

graduation rate tracking to include part-time students.

However, the VFW remains concerned that simply asking schools whether or not they participate in the Post-9/11 

GI Bill does not satisfy the needs of the veterans’ community, which will rely on this new information to deliver 

quality comparison tools for college-bound veterans.

To enhance the quality, utility, and clarity of the information to be collected, the VFW recommends that when 

IPEDS asks schools whether or not they participate in the Post-9/11 GI Bill or the Yellow Ribbon Program, schools 

should also be compelled to provide any Department of Veterans Affairs (VA) facility codes related to GI Bill 

participation.

Thanks to presidential Executive Order No. 13607 and P.L. 112-249, Department of Education and VA have 

worked closely to cross-reference school codes for Title IV and GI Bill eligibility, creating a highly-effective 

institutional crosswalk. Unfortunately, if IPEDS fails to collect VA facility codes from IPEDS participants, this 

newly-developed school crosswalk will quickly become obsolete.

The VFW believes that the institutional crosswalk is critical to ensuring veterans have access to quality information 

before choosing an academic institution. VA is on the cusp of launching its ground-breaking institutional 

comparison tool, which relies on the accuracy of this institutional crosswalk, before the end of the calendar year. 

The VFW believes that this tool will allow veterans to better understand the characteristics of the schools they plan 

to attend in only one click, without having to navigate 17 specific web sites across three federal agencies like they 

must today. Unfortunately, without a specific IPEDS collection clarifying VA facility codes, VA and Department 

of Education will not be able to regularly update their institutional crosswalk, failing to offer quality, up-to-date 

information to veterans through the comparison tool in compliance with P.L. 112-249.

The VFW was proud to play a role in the IPEDS Technical Review Panel that developed these potential new 

questions, and we continue to believe that this new collection of student veteran characteristics will offer greater 

transparency in higher education for college-bound veterans. We thank the Department of Education for taking our 

recommendations to heart and working to improve the kinds of information available on our student veterans. 

However, Department of Education now also has the obligation to keep the VA and Department of Education 

institutional crosswalk up to date, ensuring accuracy in VA’s new comparison tool. We hope IPEDS will consider 

this minor change to the Post-9/11 GI Bill and Yellow Ribbon Program eligibility questions to ensure that the 

crosswalk remains relevant through reasonable periodic updates.

Sincerely,

Ryan Gallucci

Deputy Legislative Director, Veterans of Foreign Wars of the U.S.
Response-Veterans

Dear Mr. Gallucci,

Thank you for your comments submitted during the second 30-day review process, responding to a request for 

comments on proposed changes to the Department of Education’s Integrated Postsecondary Education Data System 

(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.

IPEDS/NCES will work with the Veterans Administration toward a solution for updating the VA facility 

code/OPEID/IPEDS ID crosswalk in ways that will not increase the burden on IPEDS respondents. This approach 

will have the additional advantage of including non-IPEDS programs that are in the OPEID code system, 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 

service members 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 these students, especially given that service members 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 movement 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 systems. 

The Technical Review Panel meeting of November 2011 identified many issues that could compromise the quality 

of data about veterans that institutions could currently provide, including availability of data at institutions and 

states, definitional inconsistencies, and the suitability of IPEDS aggregate data collections as an appropriate data 

collection vehicle. While we do not anticipate expanding the IPEDS data collection beyond the published proposed 

changes at this time, progress is being made in some of the problematic areas.

Sincerely,

Richard J. Reeves

Program Director, Postsecondary Institutional Studies Program