On Nov. 13, 2025, the U.S. Department of Education released a notice in the Federal Register proposing that four-year institutions that admit 100% of their applicants and do not award non-need-based aid will be exempt from new reporting requirements concerning admissions. This notice follows the Department’s original August 2025 notice, which proposed revising an information collection request to add the new Integrated Postsecondary Education Data System (IPEDS) “Admissions and Consumer Transparency Supplement” survey component.
The August 2025 notice followed a presidential memorandum, “Ensuring Transparency in Higher Education Admissions,” which directed the Secretary of Education to “expand the scope of required [IPEDS] reporting to provide adequate transparency into admissions” to post-secondary institutions. The August 2025 notice proposed collecting additional elements to track undergraduate and graduate student admissions and enrollments, with some elements disaggregated by race and sex.
The Department originally proposed, at a minimum, that all institutions of higher education that utilize selective college admissions should report data pursuant to the proposed additional elements, based on the Department’s assertion that these types of institutions “have an elevated risk of noncompliance with civil rights laws.” However, based in part on public comment, the Department announced that it is limiting collection of such information to only four-year institutions and is exempting eligible institutions that admit 100% of their applicants and do not award non-need-based aid.
Additionally, in the Nov. 13, 2025, notice, the Department solicits additional public comment; specifically, the Department seeks responses to the following prompts:
- Whether this collection is necessary to the proper functions of the Department;
- Whether this information is processed and used in a timely manner;
- Whether the estimate of burden is accurate;
- How might the Department enhance the quality, utility and clarity of the information to be collected; and
- How might the Department minimize the burden of this collection on the respondents, including through the use of information technology.
Public comments are due on or before Dec. 15, 2025.
For help in responding to this notice, or for additional questions related to admissions; financial aid; or diversity, equity and inclusion, contact the authors, your McGuireWoods contact or a member of the firm’s Higher Education Enforcement & Regulatory Counseling Practice Group.