1. Educause Live! NCES Proposal on Student Unit Record Data Collection Educause Live! NCES Proposal on Student Unit Record Data Collection January 11, 2005Barmak Nassirian

2. IPEDS Unit-Record Data Collection Slide2 IPEDS: Distinct Audiences for the Data Researchers, Federal and State Policymakers Institutional Decision Makers Students and Families Two Data Look-Up Portals: Peer Analysis System (PAS) College Opportunities On-Line (COOL)

3. IPEDS Unit-Record Data Collection Slide3 Context for the Unit Record Proposal Pending HEA Reauthorization The Return of Budget-driven Higher Education Policy (federal and state levels) The New Political Mantra: “Accountability”

4. IPEDS Unit-Record Data Collection Slide4 Case Study: Graduation Rates Data-driven accountability or feel-good policy outcomes on the cheap? Tendency to replace access with graduation as the main object of public policy Political proclivity to blame colleges for behavior of students (transfer among multiple schools, drop-out, stop- outs) A simple statistic for six-year graduation rate: 60% “Only” 60% (The Education Trust: A Matter of Degrees) Or, “as high as” 60%? (Eight-year graduation rates in the United States nearly constant for high school classes of 1972, 1982, and 1992, while the number of students fluctuated significantly)

5. IPEDS Unit-Record Data Collection Slide5 Could It Be Done? Aggregate reporting methodology has inherent limitations Incremental improvements to the current system would be costly New technology makes unit-record collection possible

6. IPEDS Unit-Record Data Collection Slide6 Should It Be Done? Three broad concerns need to be addressed: Individual privacy Campus work burdens Policy uses and misuses of more granular data

7. IPEDS Unit-Record Data Collection Slide7 Who Owns the Record? The information in question, while in possession of the school, “belongs” to the individual. “Ownership” Rights Include: Right to review, correct, and amend the record Prior consent for any disclosures Restrictions on subsequent uses and/or re- disclosures

8. IPEDS Unit-Record Data Collection Slide8 Privacy Concerns Unit-record would require data on ALL enrolled students, including those who seek no federal assistance. The data fields would include directory (generally public) as well as non-directory (private) data- elements to be submitted to the NCES. Data-warehousing, data-mining, and potential cross-matching with other databases would enable the federal government to track individuals over time and across various programs.

9. IPEDS Unit-Record Data Collection Slide9 Privacy Concerns (Cont.) Advocates for the Unit-Record Approach Point Out That: All Title IV institutions currently report on ALL enrollments to the IRS (IRC 6050S). The vast majority of collegiate institutions report on ALL enrollments to a private data warehouse (National Student Clearinghouse) that conducts data-matching. NCES has an unblemished history of protecting student privacy, having never allowed legally protected data to be released to third parties. NCES has legal and technological resources to ensure data security.

10. IPEDS Unit-Record Data Collection Slide10 The Most Serious Privacy Concern: “If you build it they will come” A comprehensive data warehouse will be the immediate target of as-yet-unforeseen interests. No assurance that data collected for one reason would not be put to subsequent uses without student authorization. Pressure for access will range from national security and law enforcement authorities to social service agencies and sate and local governments. No legal guarantees written into the law authorizing unit-record data collection can tie the hands of future legislators.

11. IPEDS Unit-Record Data Collection Slide11 Campus Work Burdens Change is always burdensome. At issue is whether any new short-term burdens will pay off in the long run. Proposed unit-record model will require file uploads for all institutions. The quality of campus data is an issue that deserves careful study. The ability of schools to generate data will be limited by software capabilities and level of technical expertise. Problem resolutions and edits may prove more costly and more complicated than anticipated.

12. IPEDS Unit-Record Data Collection Slide12 Campus Work Burdens (Cont.) Full assessment of campus consequences is not possible until system architecture, data-fields, and data- flows are better defined in the feasibility study. Very likely that any proposed change would result in an internal shifting of responsibilities within different campus units, which would take time for institutions to implement. Any move to unit-record data collection would require significant involvement of affected campus officials in system design, training and technical assistance. Software vendors should be given time to modify administrative systems for compliance.

13. IPEDS Unit-Record Data Collection Slide13 Implementation Timeline/Costs NCES has indicated it would not act on the unit- record approach without legislative authorization. Assuming the inclusion of the proposal in a 2005 reauthorization, NCES would field-test the system in 2006-2007, and fully implement in 2007-2008. Schedule may prove too aggressive from an institutional perspective. While a fully-implemented unit-record system may prove cost-neutral for NCES to operate, it might actually cost institutions more.

14. IPEDS Unit-Record Data Collection Slide14 Also Disturbing: Uses and Misuses of Data The collection of vast amounts of new data will enable the federal government to publish information at a more granular level. Such information, while technically accurate, could easily leave the substantively incorrect impression about institutions. Areas of particular concern include statistical data on net pricing, which could be accurately reported by NCES, but which may mislead prospective applicants who don’t fully understand the variation in individual packaging.

15. IPEDS Unit-Record Data Collection Slide15 Concerned... About Another Ranking Scheme In an era of limited federal resources, a comprehensive data system may quickly degenerate into a ranking scheme. Accountability is often attempted through simplistic misuses of data, and a centralized data system may become the instrument with which federal and state policymakers can demand more of schools without providing adequate resources. Punitive misuses of data could limit opportunity for students.

16. IPEDS Unit-Record Data Collection Slide16 The Process Thus Far, and What Comes Next NCES has been open to institutional input and has included all stakeholders in discussions. The feasibility study is intended to answer the narrow question of whether a unit-record system is feasible, not whether it is advisable. The Administration and Congress have yet to go on the record with their respective positions. The upcoming reauthorization will provide ample opportunity for all stakeholders to argue their position before Congress.