On Friday, April 3, 2026, the U.S. District Court for the District of Massachusetts preliminarily enjoined the Trump administration from requiring public colleges and universities in 17 states to submit seven years’ worth of Integrated Postsecondary Education Data System (IPEDS) Admission and Consumer Transparency Supplement (ACTS) survey data. The reporting deadline for the members of two intervenor organizations remains April 14, pending the outcome of a hearing scheduled for April 13.
In fall 2025, the U.S. Department of Education’s National Center for Education Statistics (NCES) announced a new ACTS component to supplement its existing IPEDS reporting requirements. The ACTS survey component seeks detailed demographic and academic data on admitted and enrolled students. The plaintiffs in this litigation, 17 state attorneys general, have criticized the new survey as hastily implemented and beyond the scope of the agency’s authority.
Massachusetts Federal Court Grants Preliminary Injunction
The court on April 3 concluded that the plaintiff states were likely to succeed on the merits of their argument that the survey’s implementation — and in particular, the administration’s “arbitrary and unexplained” compliance deadline — violated the Administrative Procedure Act. The court reasoned that NCES can likely lawfully collect and use the requested data for investigations and enforcement, but that the “rushed and chaotic manner in which the ACTS [survey] was promulgated … epitomizes arbitrary and capricious agency action.” Accordingly, the court granted plaintiffs’ motion for a preliminary injunction, preventing the administration from enforcing compliance with the ACTS survey, pending further order of the court. As of this publication, no briefing schedule or further hearings on the plaintiffs’ motions have been set.
The court limited the scope of its injunctive relief to public institutions of higher education in the 17 plaintiff states: California, Colorado, Connecticut, Delaware, Hawaii, Illinois, Maryland, Massachusetts, New York, Nevada, New Jersey, Oregon, Rhode Island, Vermont, Virginia, Wisconsin and Washington.
Additional Parties Move to Intervene
In a separate order issued March 31, the court extended the reporting deadline for members of two organizations that sought to intervene in this litigation — the Association of American Universities and the Association of Independent Colleges and Universities in Massachusetts — to April 14. The court also set a hearing on their respective motions for injunctive relief for April 13.
Three other organizations comprised of colleges and universities have since moved to intervene: the Connecticut Conference of Independent Colleges, the Maine Independent Colleges Association, North Carolina Independent Colleges and Universities, and the Oregon Alliance of Independent Colleges and Universities. As of this publication, the court has not yet acted on those motions.
For questions about how these developments impact your institution, contact the authors, your McGuireWoods contact, or a member of the firm’s Higher Education team.