## 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. Itis 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 ed ucators 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)

**Docum ent:**  ED - 2013 - ICCD - 0128 - 0008 **Name:** Sarah Gomez Pell -recipient - specific graduation rates are absolutely necessary in order to counsel our low - income, first - ge neration 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 f inal 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 - 00 14 **Name:** Sarah Magnelia As a college counselor to low - inco me 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 s mart 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 o n 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 graduatio n 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 Dep artment, 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	best maintained	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	disagg regation — 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	re quest 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	furn ish	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	compl etion	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	disclose d,	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	surv eys	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 - col leges success - 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	i nformation: 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	on ly	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,” E ducation	Sector, November	2011, http://www.educationsector.org/publications/truth - behind - higher educationdisclosure - 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	co llege	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	academ ically	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 ove rall	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	rat es	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 stud ents.	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	Studen t	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 properl y	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	P ell 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 - new administrationfocus - 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	studen ts	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	ra tes	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	s ubsets	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	ca lculators,	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	NC ES	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	a re	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 - 1 10hrpt803/pdf/CRPT 110hrpt803.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 a nonymous c ommenters , 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 Na tional 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 re lated 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- maki ng and analysis and to improve in formation available to veterans and military service me mbers 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 coll ege bound 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 instruction al 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 Veteran s 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 Registe r. The National Center for Education Statistics (NCES) appreciates yourinterest 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 s ervice 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 leve l 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 S tudent 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, Comp letions, 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 c ollection, 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 posts econdary 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 coll ection could chose to join the collection or that of another provider. Multi - statecollaboratives 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; Ex tension 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 me asure 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 S tudent 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 stud ents, taking into account the mission and role of two - year degree granting 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 institu tions”. 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 sp ecified period minimizes the importance of theother 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 missi on 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 a ugment 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, AAC C 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 colle ge 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 cap tured 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 c olleges 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 Stu dent 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 Associatio n 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. Ra

rely 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 plac e 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 be st 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 rep orting 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 Pro gram 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 i n 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 taxp ayer 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 measure s 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 h elp 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 co llection 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 aggre gating 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 re verse (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 a s 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 fe deral 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 asso ciate 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 com pleters, 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 ra tes 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’s specific data available in the G RS, 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 disag gregate 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 compa rable 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 Transfe r 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 l ess - 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 e ducation with a variety of goals in mind, and they should have access to information that clearly reflects their ability to achieve those various goals. W hile 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 th e 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 init iatives 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 un derstand 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 transfe rs. 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 an d 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 Outc ome 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 st udents 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 inco rporated 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 burd en 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 o utcomes for 100%, 150%, and 200% of time, while the new outcome measures will trackoutcomes 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 - tha n - 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 - t ime, 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 institutio n 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 n ot 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 wil l 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 posts econdary 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 t heir 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 th e 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. R eceived 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 subse quently 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 stu dents 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 al ready 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 existi ng 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 gen der 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 i nformation. 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 loan s, 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 n ew 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 insti tutions, 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 inde ed 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 glimps e into national level success rates of students from different socioeconomic backgrounds, they do not provide the necessary institution - level data to truly inform decision making. Also, we understand that the Department is working to calculate graduation r ates 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 di saggregated 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 opportuniti es 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 institut ions 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 dis aggregated by military status. Cumulative DebtAs concern mounts over the rising cost of college and the burdensome debt students are incurring to acc ess 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 borrowi ng. 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 com pleters 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 r ates 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 support ed 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 complet e 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.o rg, 202 - 587 - 4967) Sincerely, Michelle Asha Cooper, Ph.D. Jennifer Engle, Ph.D. President Vic e President for Policy Research, Instit ute 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 Ed ucation’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 reco mmend 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. Theref

ore, 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 simi larly 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 mo ve 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 high er 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 instituti on, 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 two year 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 postseconda ry 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 pa ramount 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 c an 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 individual s 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 - 00 30 **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 edu ca tional 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 lead ers 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 Stat istics (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 conc erns 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 Meas ures 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 i n addition to the other Veteran elements propos ed. **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 ve ry 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 stu dent’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 bur den 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 provid ed 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 existin g 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 n ew 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 po stsecondary 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 bas ed 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 ins titutions and systems, it will be essential to have clear andconsistent 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 n ew 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 st udents; full - time, non - first - time students; and part time, 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% grad uation 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 o ption 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. T his 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 popu lation. 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 abilit y 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 repor ting 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 reporti ng 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 -ye ar institution was unnecessarily burdensome for institutions. Because this information describes an institution’s offerings and not necessarily t he program that the student enrolled in (i.e. a student transferring to a 4 -year institution could be enrolled in a sub baccalaureate certificate program, an associate’s degree program, or a bachelor’s program), it may not be particularly meaningful for th ese 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 year s 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 ne cessary 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 C enter 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 me mbers as well as providing policymakers and the public more information about the education benefit programs offered to these students. The IPEDS TRP held on this topic suggested that IPEDS is not the appropriate vehicle for collecting graduation rate information for th ese students, 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 GIBill 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 pro vide 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 IVand 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 site s 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 mino r 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 - IP EDS 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