AACRAO Takes the Lead for Higher Education to Ensure that the Census Does Not Overstep FERPA Regulations for Off-Campus Student Count

Michael V. Reilly |
June 18, 2020
  • Advocacy
  • census
  • covid-19
  • Federal relations

In a continued effort to ensure an accurate Census count during these difficult times, AACRAO remains engaged in conversations with the U.S. Census Bureau. The shift to distance learning due to the COVID-19 outbreak forced students living both on- and off-campus to return home, complicating this year's Census operations.

The Bureau has begun to reach out to institutions this week to discuss the collection of basic demographic information about students who live off-campus, a particularly hard-to-count population as a result of the pandemic. However, AACRAO has concerns about what information institutions will be asked to provide as directory information. While FERPA generally permits such disclosures, directory information must be limited to information that is not generally considered harmful or an invasion of privacy. It cannot include items such as social security numbers, race, gender, or ethnicity.

AACRAO, in conjunction, with other higher education associations, sent a letter to Census Bureau officials this week urging the agency to review and revise its request to institutions and to provide formal guidance, in writing, articulating the request for off-campus enumeration collection. We hope that doing so will minimize confusion and ensure that institutions comply with long-standing student privacy requirements. For those institutions that may be limited on what information to provide due to self-imposed directory information limitation, AACRAO has also recently provided guidance.

AACRAO also requested that the Census Bureau reconsider the deadline date for institutions to provide off-campus information to align with its group housing deadline in August. Doing so will provide institutions with additional time to comply with information requests, particularly those that may need to reclassify what they deem to be directory information, which will require student notification and the ability for students to opt-out. We all want to ensure an accurate Census, but we must adhere to long-standing student information request processes that have been in place for over 45 years.