Article

Oversight of institutional data reporting

Jan. 14, 2021 · Authored by Adrienne Larmett, Katlyn Andrews

Higher education institutions regularly produce and publish data about their students, programs, operations and finances to meet compliance requirements, increase enrollment and/or encourage alumni/donor giving. This reporting, commonly known as institutional data reporting, is a comprehensive process of collecting, analyzing and interpreting, and submitting quantitative and qualitative data to select governmental entities (e.g., U.S. Department of Education, Integrated Postsecondary Education Data System [IPEDS]), ranking bodies (e.g., U.S. News and World Report, Princeton Review) and accrediting associations (e.g., Middle States) to produce an accurate analysis of the institution.

Opportunities and risks in data reporting

Rankings data has been shown to have a correlation with an institution’s reputation and appeal. The more selective an institution appears in rankings publications, the more opportunity it has to attract applicants and tuition dollars. However, when an institution misreports its selectivity data (i.e., acceptance rates, class rank, test scores) or any data, whether intentionally or by error, it places the institution at risk for reputational damage, increased governmental inquiry and compliance requirements, and legal fines and penalties.

As the impact and fallout of misreporting can be significant, it is critical that institutions establish an effective infrastructure and oversight for institutional data reporting to address and mitigate the associated risks.

Potential risks include:

• Reputational damage due to negative publicity
• Misrepresentation
• Loss of accreditation
• Removal of institution’s name in rankings and/or guidebooks
• Legal actions for the parties involved
• Financial implications due to potential lawsuits or sanctions

Data reporting challenges

Colleges and universities face a number of challenges in overseeing the accurate reporting of external data, including:

• Challenges with systems utilized to maintain data and generate information
• Decentralized preparation of information and reports
• Lack of awareness surrounding roles and responsibilities for data reporting
• Ambiguity regarding the definitions of certain terms
• Inadequate monitoring of information submitted externally
• Insufficient quality control processes
• Failure to retain submitted information and supporting queries, reports or data

Addressing and managing risks

Institutions can implement a number of controls to mitigate the risks of misreporting data to external constituents.

• First, ownership of the process must be clearly defined, along with roles and responsibilities between and among offices responsible for reviewing and/or submitting data externally (i.e., to accrediting bodies, survey distributors, etc.).
• Next, institutions should ensure that they are communicating the procedures in place for submitting data to external parties. Additionally, schools should work to formally document institution-wide rules, expectations and procedures around their internal review processes.
• Lastly, institutions should store backup files on a consistent basis to support the data reported at a specific point in time in the event that information needs to be subsequently verified.

Examples of external agencies include:

• Department of Education (ED)
• Environmental Protection Agency (EPA)
• Department of Health and Human Services (HHS)
• Department of Labor (DOL)
• Internal Revenue Service (IRS)
• National Science Foundation (NSF)
• U.S. News and World Report (U.S. News)

Questions to consider when evaluating the current state of your institution’s data reporting process:

• Who is responsible for submitting data to external parties?
• Are process owners educated on appropriate reporting procedures?
• Which system(s) is used for reporting data? Are multiple systems used?
• Are procedures in place to ensure the data within these systems are complete and accurate? How is information input into system(s) (i.e. manually vs. automated)?
• How can we ensure that externally reported data is complete and accurate?
• Is there a formal review process for the data reported? If so, how is the review process documented and managed?
• How can we ensure compliance with survey requirements and submissions?

Baker Tilly can help

Our specialized higher education risk advisory team can help your institution take a proactive approach to managing high-risk external data reporting.

For more information, or to learn how we can help, contact us.