1. GRS and Confidentiality

2. NCES
Title V, Section 501(a), Education Amendments of 1974 (P.L )
NCES shall develop and enforce standards designed to protect confidentiality of persons in the collection, reporting, and publishing of data

3. FERPA
Family Educational Rights and Privacy Act (FERPA) (20 U.S.C. 1232g, 34 CFR Part 99)
Protects privacy of student education records
Generally prohibits nonconsensual disclosure of “personally identifiable” information derived from education records

4. FERPA
Exception is directory information (designated as such by institution)
Not generally considered harmful or an invasion of privacy if disclosed
Dept of Ed has ruled that race/ethnicity/gender should not be designated directory information because it is not like the types of information specified as directory information in the statute

5. FERPA Personally identifiable information
Would make the student’s identification easily traceable
List of personal characteristics
Other information
Thus, any information from education records that could lead a reasonable person to ascertain the identification of the student from information reported – such as could be the case with small cell reporting – is not permitted under FERPA

6. Disclosure Guidelines - SRK
34 CFR Section (a)(3) of the Student Assistance General Provisions says that if a category within an athletic subcohort contains 5 or fewer students, the institution need not disclose information on that category.

7. Suppressed GRS File Adjusted cohort (revised cohort minus exclusions)
Total completers
Total completers within 150% of normal time
Calculated cohort graduation rate
Total cohort only (no race/ethnicity/gender; no athletic subcohorts)

8. 4-yr Av Grad Rate > 100% 2-yr school: collect yr cohort 1997 1994
School gets new 4-yr program 2000/01

9. 4-yr Av Grad Rate > 100% How to report:
Section I – total cohort goes in Col 1 and Col 3 (other than bachelor’s seeking cohort)
Section III – report all cohort data here

10. 4-yr Av Grad Rate > 100% Why are the 4-yr av rates > 100%?
4-yr av worksheet takes cohort for 4-yr schools from Section I, Col 1
2-yr form doesn’t have Section I
So, no cohort #s preloaded for “1991,” “1992,” “1993” – only 1994
But completers are preloaded for all 4 yrs
So, if 4 yrs of completers > 1 yr of cohort, rate is > 100%