Almost Half of Colleges Haven’t Fully Submitted Student Data

The Education Department’s Office of Federal Student Aid is warning hundreds of institutions that their access to federal grants and loans could be at risk if they fail to properly submit required student outcomes data by early 2027.

Newly released data shows that of more than 4,640 colleges and universities with programs eligible for funding, about 1,930 are either missing or have underreported some or all of the data they are required to provide under federal accountability rules.

That’s about 42 percent of the institutions in the database department officials attached to the warning. A deeper Inside Higher Ed analysis of the data shows that 578 of those institutions—or roughly 30 percent—haven’t properly submitted any of the seven required files, which span three academic years.

Out of the 1,930 institutions missing some data, the largest groups are for-profit colleges and those focused on certificate programs. But some notable public four-year institutions are on the list, too, including the University of Montana, the University of Central Oklahoma, Texas Southern University and at least 28 historically Black colleges and universities. (Inside Higher Ed reached out to five of the four-year institutions for comment but did not hear back by publication time.)

The missing data is raising concerns among student advocates and those who want to see institutions held accountable, as it leaves FSA without the critical data needed to accurately measure whether college programs pass a new earnings test that took effect July 1. The first round of data and test results is slated for release next year.

“Any new data collection comes with some amount of growing pains, and so it is normal to see some amount of initial noncompliance,” said Clare McCann, a former Biden staffer and now managing director of the Postsecondary Education and Economics Research Center at American University. But “completing mandatory data reporting is absolutely a requirement of schools’ agreements with the Department of Education [in order to receive federal aid]. So if schools are unwilling to complete the data collections that they are required to complete, the secretary can and should take action.”

The American Council on Education, one of the largest lobbying groups for higher education, said that it’s talking to its member institutions to “better understand the issue.” But it seems to have a lot to do with institution size, an ACE spokesperson added.

“This could be a direct result of institutional capacity and potential confusion with changes in the reporting deadlines and requirements given the passage of the One Big Beautiful Bill for other institutions on the list,” they explained.

Since July 1, 2024, colleges have been required to submit new program-level data on an annual basis, including information about whether the program meets licensure requirements and the total cost of attendance. Colleges also have to report a student’s total debt when they exit a program and the amount of private loans students received, among other items. (Only programs with more than 30 completers are required to submit.)

That first batch of data was initially due July 31, 2024, and would include stats from 2022–23 and 2023–24. But the Education Department repeatedly pushed the deadline back until Sept. 30, 2025. Data from the 2024–25 academic year was due Oct. 1, 2025. In two months, on Oct. 1, 2026, institutions will have to submit data from 2025–26.

ED plans to use the data to compare the earnings of a program’s average graduate with those of a high school diploma holder in the same state. Programs that fail the test in two out of three consecutive years could temporarily lose access to federal loans.

The dataset from the Office of Federal Student Aid doesn’t specify what specific data points are missing. Rather, it lists the submission status for seven larger data files—one for 2022–23, and three each for 2023–24 and 2024–25.

McCann explained that the Office of Federal Student Aid has access to other data it can use to fill in the gaps—so this missing data shouldn’t block the Trump administration from enforcing its new accountability measures entirely. But if this trend continues and colleges still aren’t turning their data in after the first several rounds, then they could face larger consequences.

“I can’t speculate on what [punitive actions] the department plans to use, but they certainly have a lot of tools at their disposal, including [charging fines] against a school for failing to submit their required reporting,” she said. “I think colleges should have a strong interest in engaging in this process with the department to make sure that any information that is being produced under these rules is going to be as accurate as possible.”

Colleges with missing data have until Jan. 15, 2027, to comply with the reporting requirements. After that, department officials say, “incomplete or inaccurate submissions may raise concerns about an institution’s administrative capability to continue participating in the [federal student aid] programs.”

Breaking Down the Data

Michael Itzkowitz, who helped to develop the College Scorecard during the Obama administration, said it’s important to note the number of for-profit institutions that haven’t submitted some or all of their data. Roughly 1,400 for-profit institutions are listed in ED’s dataset, and 819 of them have at least one data file that wasn’t properly submitted—that’s nearly 60 percent.

By comparison, 526 public institutions are missing some data out of about 1,700 total—that’s about 30 percent.

“There’s more work to be done when it comes to getting a complete data file submitted and received through the department,” said Itzkowitz, who is now president of the HEA Group, a higher ed research organization. “Hopefully this notice will encourage institutions to re-evaluate their data and ensure that they’re submitting correct information to the right place.”

Inside Higher Ed’s analysis also shows that at least 415 of the 1,900 institutions missing some or all data are focused on cosmetology or massage therapy—many of which follow for-profit models. Department data has shown that cosmetology schools are predicted to have some of the highest fail rates of any type of institution under the earnings test.

Jordan Wicker, senior vice president of legislative and regulatory affairs at Career Education Colleges and Universities, a leading lobbying group for cosmetology schools and other for-profit institutions, said that CECU’s members represent “a small percentage” of the institutions with missing or underreported data.

“It can be challenging for institutions to determine exactly what information is missing because underreporting can encompass several different issues,” he said. “It is important to note that an institution’s inclusion on the list does not necessarily mean it intentionally failed to report or intentionally underreported its data.”

McCann from PEER also noted that the significant gap between colleges that are missing or have underreported just one file and those that haven’t turned in any may be a sign that some of the submission issues are rooted in confusion, as the deadlines and accountability rules have shifted over the last year.

“For a lot of institutions, I think they saw the Trump administration come in and begin to re-regulate on these issues and they took it as a pass on some of the reporting,” McCann said. The department’s recent announcement “is a good reminder to the schools of what they need to be doing. It offered some clarity.”

In addition to small for-profit institutions, McCann, Itzkowitz and others say the colleges most likely to struggle when submitting their data are the smaller institutions or those with low administrative capacity, many of which are private nonprofit colleges.

Out of the 578 institutions that are missing or underreported data files, 28 are HBCUs. That’s about a third of the 99 HBCUs recognized by ED. HBCUs have historically faced underfunding compared to other public and nonprofit four-year institutions, and the gap in resources could explain why so many appear on the department’s list.

“Compiling the necessary components for this reporting likely has and will continue to place an even more acute administrative burden on lower-resourced schools that were already stretched thin,” said Karen McCarthy, vice president of federal relations at the National Association of Student Financial Aid Administrators.

Public community and technical colleges also struggled to submit all the data, according to ED’s list. Although there were fewer community colleges on the list than for-profit institutions, they enrolled the largest number of undergraduate students.

Collectively, more than 492,600 undergraduate degree-seeking students attend an institution that hasn’t fully submitted any of the seven data files. Nearly 283,000 of them attend a public college that lists associate degrees or certificates as their predominant credential. All five of the top institutions that had missed or unreported all seven files when it came to enrollment were community colleges in Texas or California.

DeRionne Pollard, president of the American Association of Community Colleges, another higher ed lobbying group, said, “Community colleges are committed to complying with these requirements.”

She added that doing so will require close partnership with department staff “to ensure that all campuses have the support and guidance they need to provide these data records” and stressed that the department’s recent announcement only further reinforces the need for a better system to collect student outcomes data.