The Department of Education is mandating that unless they admit all applicants, every four-year college and university will need to submit a new report on all applicants by March of 2026 and then annually thereafter.
The Admissions and Consumer Transparency Supplement (ACTS) was created in response to a White House executive order that called out the need to “expos[e] unlawful practices and ultimately [rid] society of shameful, dangerous racial hierarchies.”
As it plans to require every campus to invest enormous resources to prove that it's not using "DEI" in admissions, DOE opened a required comment period on these new policies and got 3,000 responses, most pointing out flaws in the instrument and especially in the timeline. DOE is not required to act on this feedback and is still planning to require the reports in a few months.
James Murphy summarizes many of the many challenges of this poorly-designed instrument, and readers of this space will be particularly interested in how this new reporting potentially upends decades of data on "first-generation student".
Parental Education
The question about parental education will be a yes/no question about whether a parent “completed college,” rather than asking what their highest level of attainment was. This is basically a question to identify first generation applicants. If you’re reading this post, you’ve probably already asked yourself, “What do they mean by college?”
When people in college admissions talk about first generation status, it usually means that neither of the applicant’s parents attained a bachelor’s degree. That is not going to be the case for ACTS. According to the codebook, completing college means getting “an award” and it does not have to be from a college or university. According to this definition, an applicant whose father has a certificate from a barber’s academy would be grouped with someone whose mother has a PhD. Also problematic is the assumption that the Department of Education is making that admissions offices will have this information about all applicants because it is included in the FAFSA. As I’ve noted in other posts, colleges frequently do not have FAFSAs for applicants.

There is no justification in making this a yes/no question to the defined "award" by a "post-secondary institution". There is no justification for DOE to create this schism in data reporting about first-generation students. Whether they are doing this out of deep ignorance of how colleges and scholars understand the significance of having parents with four-year college degrees or out of some misguided statement about that significance, it's recklessness.
These new reporting requirements on all applicants will cost campus millions, will not inform equity-driven reforms, and while diminish the value of the data that colleges already collect and report.
Meanwhile, there are no questions about legacy applicants and admissions.
Meanwhile, there are no questions requiring colleges to report whether applicants and admission decisions related to campus donors.