Statistical Methods for Protecting Personally Identifiable Information in the Disclosure of Graduation Rates of First-Time, Full-Time Degree- or Certificate-Seeking Undergraduate Students by 2-Year Degree-Granting Institutions of Higher Education. Technical Brief. NCES 2012-151
Author: Chen, Xianglei
Date: 2011-10-00
Type: Guides - Non-Classroom
Subjects: Higher Education,Educational Opportunities,Federal Legislation,Disclosure,Undergraduate Students,Graduation Rate,Classification,Sex,Race,Ethnicity,Grants,Student Loan Programs,Two Year Colleges,Compliance (Legal),Confidentiality,Privacy,Statistical Data,School Statistics,Educational Indicators

The Higher Education Opportunity Act of 2008 (HEOA) requires that Title IV degree-granting institutions disclose annually the graduation rates of first-time, full-time degree- or certificate-seeking undergraduate students, disaggregated by gender, each major racial/ethnic subgroup, and receipt or non-receipt of a federal Pell grant or subsidized Stafford loan. The law requires that this information be made available, through appropriate publications, mail, or electronic media, to current and prospective students. All 4-year degree-granting institutions are expected to implement this mandated disclosure requirement immediately upon HEOA enactment, but a provision of the law requires this disclosure requirement to apply to 2-year degree-granting institutions beginning in the academic year 2011-12 (HEOA Section 488(a)(3)). The public disclosure of graduation rate data, while important, potentially risks disclosure of personally identifiable information. The challenge of meeting disclosure requirements lies in releasing as much information as required by the law, while also meeting legal requirements to protect each student's privacy under the Family Educational Rights and Privacy Act (FERPA) (34 CFR Section 99.3). Recognizing this, HEOA states that disaggregated graduation rates are to be disclosed only &quot;if the number of students in subgroups is sufficient to yield statistically reliable information and reporting will not reveal personally identifiable information about an individual student. If such number is not sufficient for such purposes, then the institution shall note that the institution enrolled too few of such students to so disclose or report with confidence and confidentiality&quot; (HEOA Section 488(a)(3)). The purpose of this brief is to provide technical guidance to Title IV 2-year degree-granting institutions in meeting the statutory disclosure requirement related to graduation rates while minimizing the risk of revealing the graduation status of individual students. Adapted from &quot;Statistical Methods for Protecting Personally Identifiable Information in Aggregate Reporting&quot; (Seastrom 2010b), this brief includes a summary of key definitions, a brief discussion of background information, a review of current disclosure practices used by institutions, and a discussion of some practices for balancing disclosure and confidentiality. The brief concludes with a set of recommended rules that post-secondary institutions can apply to disclosure of graduation rate data required by the HEOA. It is important to emphasize that disclosure rules described in this brief aim only to meet the requirements of HEOA for disclosure of graduation rates. These rules may not apply to other disclosure or reporting requirements. (Contains 6 tables and 13 footnotes.