• The U.S. Department of Education’s updated IPEDS data collection proposal clarifies that ACTS would only apply to selective four-year institutions.
• Institutions that both admit 100 percent of applicants and award no non-need-based aid in a given collection year would be exempt from the data collection for that year.
• The Education Department underscores the ACT’s purpose to identify race-based preferencing in admissions and non-need-based aid practices, signaling potential risk-based Title VI of the Civil Rights Act of 1964 scrutiny.
• Public comments are due December 15, 2025.

The Education Department’s notice proposes that ACTS would apply to four-year selective institutions and explicitly exempt otherwise eligible institutions that both admit 100 percent of applicants and do not award non‑need‑based aid for a given collection year. The changes stem from the public response to the Education Department’s Direct Questions in the prior sixty-day notice associated with the ACTS supplement, issued in August 2025. Comments on that proposal closed October 14, 2025.

The Education Department reiterated that ACTS is intended to collect information indicating whether institutions “are using race‑based preferencing in admissions,” citing the August 7, 2025, presidential memorandum directing expansion of required IPEDS reporting and the Education Department secretary’s same‑day directive to initiate changes in the 2025–26 school year.

Selective institutions—and competitive graduate...

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