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Sen. Bill Would Make State Data Systems, Not IPEDs, Focus of Student Data Reporting

Earlier this month, U. S. Senator Ron Wyden (D-OR) introduced the “Student Right to Know Before You Go” Act (Senate Bill 2098), which proposes to give students, their families, and the public at large a clearer understanding of what the relative costs and economic benefits are from pursuing particular courses of study at given institutions. The bill would achieve this by requiring colleges and universities to report individual student educational records to “statewide individual-level integrated postsecondary education data systems,” which would most likely be existing statewide longitudinal data systems (SLDSs). That would allow the data to be combined with K-12 and workforce data on individuals to permit public reporting of:

  • “Rates of remedial education, credit accumulation, and postsecondary completion by high school completion status.”
  • “…data on average individual annual earnings, disaggregated by educational program, degree received, educational institution, employment sector, and State.”

To implement this requirement without increasing the reporting burden on institutions, the bill would make the reporting of postsecondary student data to the Integrated Postsecondary Education Data System (IPEDS) a responsibility of the SLDSs, not of the institutions. In other words, institutions would submit the required student data to their SLDS or other similar system (for example, the bill envisions the possibility of regional data systems) and that would complete their reporting responsibility for student data in relation to IPEDS. (Under the Act, SLDSs would have to incorporate all of the student data elements required by IPEDS.) The state data system would then be responsible for reporting the student data to IPEDS “in a manner that does not disclose any personally identifiable information…” Colleges and universities would still bear direct responsibility for reporting the other data elements required by IPEDS.

The bill proposes to address data and privacy concerns and existing legal requirements (e.g., those stemming from the Federal Educational Rights and Privacy Act (FERPA)) by mandating that state data systems implement:

  • A “unique individual identifier system” that would assign “a one-way secure identifier that can be used in data systems in other States and cannot be reverse-engineered,” ensuring that system users (e.g., analysts, researchers) cannot individually identify anyone from the records available in the system.
  • A “data governance system, operated at the State or regional level… with the participation of representative educational institutions, to ensure compliance with Federal and State standards of data quality and privacy.” (The Illinois P-20 Council may serve as an example, particularly in terms of its work on data assessment and accountability.)
  • Policies mandating non-disclosure of personally identifiable information, full compliance with FERPA and other relevant federal or state privacy laws, and effective oversight of data use by departments, organizations, research institutions, and “other entities.”

State data systems would also be required to incorporate “the most recent version of the Common Education Data Standards” to the extent they are applicable.

The U.S. Department of Education would be authorized under the Act to provide institutions and state data systems with grants to help them absorb the costs of meeting its requirements, but the Act does not propose a funding level for a possible grant program. Any funding to implement it would have to emerge from the normal appropriations process during tight fiscal times.

Since the bill’s introduction, companion legislation (House Resolution 4061) has been submitted in the U.S. House of Representatives by Rep. Duncan Hunter (R-CA), and both versions of the bill have been referred to the respective House and Senate education committees for consideration. While the prospects for passage of the “Student Right to Know Before You Go” Act remain unclear, EDUCAUSE will continue to monitor its progress given its far-reaching implications for what, how, and where colleges and universities would report student data.