On October 19, 2007, the U.S. Department of Education posted to the Federal Register the "Final Guidance on Maintaining, Collecting, and Reporting Racial and Ethnic Data to the U.S. Department of Education." (See the Federal Register, Volume 72, Number 202, pp. 59266-59279: http://edocket.access.gpo.gov/2007/pdf/E7-20613.pdf ) (PDF, 200 KB). The proposed changes are necessary for the Department to implement the Office of Management and Budget's (OMB) 1997 Standards for Maintaining, Collecting and Presenting Federal Data on Race and Ethnicity. IPEDS will adopt new aggregate categories for reporting R/E data in accordance with the final guidance.

The guidance issued by the Department covers two separate issues: (1) the collection of R/E data by institutions and (2) the reporting of aggregate data to the Department. For collecting R/E data, institutions must use a two-question format, and the Department encourages institutions to re-survey students and staff (the two-question format is as follows: The first question is whether the respondent is Hispanic/Latino. The second question is whether the respondent is from one or more races from the following list: American Indian or Alaska Native, Asian, Black or African American, Native Hawaiian or Other Pacific Islander, White). For further details on the guidance for collecting data, please see the full Federal Register notice. For reporting aggregate data to the Department, the guidance identifies nine categories that will be used for IPEDS. The current and new race/ethnicity categories for reporting data to IPEDS are outlined below:

Current IPEDS Reporting Categories	New IPEDS Reporting Categories
1) Non-Resident Alien 2) Race and Ethnicity unknown 3) Black, non-Hispanic 4) American Indian/Alaskan Native 5) Asian/Pacific Islander 6) Hispanic 7) White, non-Hispanic	1) U.S. Nonresident 2) Race and Ethnicity unknown 3) Hispanics of any race For non-Hispanics only: 4) American Indian or Alaska Native 5) Asian 6) Black or African American 7) Native Hawaiian or Other Pacific Islander 8) White 9) Two or more races

Educational institutions will be required to implement this guidance in order to report data for the 2010-2011 school year. Under the guidance, although not required to do so, educational institutions already collecting individual-level data in the manner specified by the notice are encouraged to immediately begin reporting aggregate data to the Department. However, because the 2007-08 IPEDS data collection year is already underway, the new R/E reporting categories will not be available for reporting in IPEDS until the 2008-09 collection year, which begins in Fall 2008.

The IPEDS Technical Review Panel (TRP) discussed the implementation of changes to race/ethnicity reporting in IPEDS in November 2006 after the Department issued preliminary guidance on August 6, 2006. Based on suggestions from that meeting of the TRP, changes to reporting race/ethnicity in IPEDS will be fully implemented as outlined below.

• 2008-09 and 2009-10 Collection Years
  Optional years for all components: Reporting using new race/ethnic categories will be voluntary: All five relevant IPEDS components (Fall Enrollment, Human Resources, Completions, 12-Month Enrollment, and Graduation Rates) will allow a combination of current and new race/ethnic submissions, and therefore IPEDS components would have five current race/ethnic categories plus seven new race/ethnic categories plus two remaining categories ("Race and Ethnicity Unknown" and "Non-resident alien") - a combined "5+7+2 format". Although the desire is that institutions will be able to collect and report the new race/ethnic data at this time, institutions would have the option to submit data using any of the following approaches:
  1. Exclusively use seven new race/ethnic categories for everyone at the institution
  2. Exclusively current five race/ethnic categories for everyone at the institution
  3. Use "mixed reporting" - current categories for some individuals and new categories for others. The anticipation is that few institutions would select this option since it will be the most complex.
• 2010-11 Collection Year
  • Mandatory year for Fall Enrollment and Human Resources: Reporting using new race/ethnicity categories will be required.
  • Optional year for Completions, 12-Month Enrollment, and Graduation Rates Reporting using the new categories will remain optional; data in these components will be collected using the 5+7+2 format.
• 2011-12 and Beyond Collection Years
  Mandatory years for all IPEDS components: Institutions will be required to report using only the new race/ethnicity categories.

In the years with components that have optional reporting, institutions can report one way for one IPEDS component and another for other IPEDS components. The expectation is that most will report using new race/ethnic categories for Completions, 12-Month Enrollment, and Graduation Rates the year after they report using new race/ethnic categories for Fall Enrollment and Human Resources. The following table summarizes the proposed reporting timeline.

IPEDS Collection Year	Fall Enrollment and Human Resources	Completions, 12-Month Enrollment, and Graduation Rates
2008-09 and 2009-10	mixed format (5+7+2)	mixed format (5+7+2)
2010-11	new format (7+2) only	mixed format (5+7+2)
2011-12 and beyond	new format (7+2) only	new format (7+2) only
"5" includes: Black, non-Hispanic; American Indian/Alaska Native; Asian/Pacific Islander; Hispanic; White, non-Hispanic "7" includes: Hispanics of any race; For non-Hispanics only: American Indian or Alaska Native, Asian, Black or African American, Native Hawaiian or Other Pacific Islander, White, Two or more races "2" includes: Race and Ethnicity Unknown and U.S. Nonresident

Additionally, the IPEDS TRP made suggestions for how IPEDS will make data collected using the combined 5+7+2 format available through the various IPEDS reporting tools. Accordingly, race/ethnicity data during the transition years will be displayed within IPEDS tools in the following way:

• College Navigator: only "selected race/ethnic categories" (Hispanic, American Indian or Alaskan Native, Black non-Hispanic, White non-Hispanic, Asian or Pacific Islander) will be displayed since data for other categories would not be comparable across institutions.
• Peer Analysis System (PAS): the selected categories reported in College Navigator will be provided as well as the raw data submitted plus a flag indicating whether data were submitted using the old, new, or mixed categories.
• Data Feedback Reports and Executive Peer Tool (ExPT): new race/ethnicity categories will be used when available and selected College Navigator categories during years when combined format is used.
• Data Analysis System (DAS) and First Looks (formerly E.D. Tabs): data will be reported as they are displayed in College Navigator.

What are the implications of this proposal for postsecondary institutions?

New IPEDS R/E reporting will be available beginning in the next collection year (2008-09) and will be mandatory for data reported on the 2010-11 school year. Institutions are encouraged to make the transition to the new racial categories for the 2008-09 IPEDS collection year in conjunction with their state reporting systems, as appropriate. To prepare, institutions are encouraged to begin to have internal and system level discussions regarding how and when to collect R/E data under the new formats to allow for reporting to IPEDS under the timeframe outlined above. Consideration should be given to how the data will be stored; whether any mapping or bridging strategy is appropriate; how the data will be aggregated for reporting to IPEDS; how related decisions and changes in systems and processes will be documented. Institutions need to determine whether to, and if so, when they will re-survey students and employees, including whether this will be a one-time re-survey or make it part of all future registrations. They will need to determine procedures for maintaining and updating their files, as well as how to handle any missing data for students and employees who may not be at the institution at the time of the re-survey.