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Valerie Martin Conley, Ph.D.
Assistant Professor, Higher Education
388 McCracken Hall
Ohio University
Athens, OH 45701
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http://oak.cats.ohiou.edu/~conleyv/
-----Original Message-----
From: Institutional Researchers/University Planners
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Sent: Monday, March 08, 2004 2:49 PM
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Subject: Electronic AIR, 3/8/04, AIR Alert 20
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http://www.airweb.org/page.asp?page=516
SUBJECT: Use of Perturbation in IPEDS Data
PREPARED: March 8, 2004 by Kent Phillippe, Mary Sapp, & Peggye Cohen
TYPE: Informational
SUMMARY
-------
The National Center for Education Statistics (NCES) recently
implemented a "perturbation" process for data from four surveys
collected through the Integrated Postsecondary Education Data System
(IPEDS). Perturbation in this case means randomly altering the data
in cells with a small number of observations to protect the
confidentiality of personally identifiable data. The Salaries, Fall
Staff, Graduation Rates, and Student Financial Aid surveys are subject
to perturbation. As a result, the data NCES disseminates in the IPEDS
Peer Analysis System (PAS) may not precisely match the data submitted
by institutions.
CURRENT STATUS
--------------
The NCES must comply with nondisclosure regulations relating to
personally identifiable data, a requirement that has created the
long-standing issue of how to handle data in "small cells" that
might permit individuals to be identified. Perturbation makes random
changes to cells with a small number of observations. Therefore
perturbed IPEDS data released by NCES may not be exactly the same as
data submitted by the institutions. However, the perturbation process
and validity checks will preserve as much as possible row and column
totals, sub-totals, measures of central tendency, percentages, and
rates.
The NCES will not release details of its procedure (knowing which
cells have been changed would defeat the purpose of perturbation), and
NCES employees cannot disclose the process beyond what is described in
this Alert. The randomization makes figuring out which cells have been
perturbed more difficult.
The decision to introduce perturbation in IPEDS data is in response to
five acts: the Privacy Act of 1974, as amended; the Federal
Statistical Confidentiality Order of 1997; the U.S. Patriot Act of
2001; the Educational Sciences Reform Act of 2002; and the
E-Government Act of 2002. Originally NCES planned to suppress such
data, but so many cells ended up being suppressed (e.g., more than 90%
of the GRS data in cells related to sport-by-race/ethnicity, including
row and column totals) that some reports were useless. Suppression
also delayed availability of data and complicated the access process.
Perturbation, on the other hand, protects the confidentiality of
individual data without suppression, allows NCES to get the data out
quickly, and eliminates restricted data licensure problems.
IMPLICATIONS FOR INSTITUTIONS
-----------------------------
Institutions can share their data with other institutions and outside
agencies as long as:
a) they are not violating any privacy rights, in particular those
associated with the Family Educational Rights and Privacy Act and
any state restrictions that might be applicable and
b) they are not sharing data directly from the IPEDS collection
system.
Note: Institutions may share data or files prepared for input into the
IPEDS data collection system. They may also share data from the Peer
Analysis System. What institutions may not do is share printed copies
of the completed online IPEDS data collection forms or files that have
been downloaded from the IPEDS collection system for the four IPEDS
surveys subject to perturbation. According to the Educational Sciences
Reform Act of 2002, data in the IPEDS collection system may be
accessed only by the respondents themselves (and then only for their
own data) or by NCES and NCES contractors. Therefore institutions may
share their data only by using institutionally generated forms or
files, data from the PAS, or data on an IPEDS Forms Facsimile (a
feature that will be made available later this year through PAS).
Furthermore, institutions should NEVER advertise which of their data
have been changed by perturbation-it is UNLAWFUL TO DISCLOSE details
of perturbation.
The National Collegiate Athletic Association (NCAA) recently passed
legislation requiring Division I and Division II schools to submit
all graduation rates data directly to the NCAA. Beginning Spring
2004, the person who is responsible for submitting an institution's
graduation rates to the NCAA must submit the graduation rates data
prepared for input to IPEDS. Institutions must be careful to provide
a copy of the institution's graduation rate data from institutional
reports (but not directly from the IPEDS data collection system) and
send it to the NCAA on or before the IPEDS deadline. NCAA will send
member institutions instructions on how to submit the data directly
to them.
It is important that institutions always check prior year data and
use their ability to correct these data if they detect errors.
However, if in correcting the data, the institutions put in small
cells, the data will be subject to perturbation again.
TIMELINE
--------
Winter 2003/04 - Data from Salaries and Fall Staff are perturbed as
they are migrated to the PAS.
Spring 2004 - Data for Student Financial Aid and Graduation Rates
will be perturbed as they are migrated to the PAS.
Ongoing - Data from prior collections of Salaries, Fall Staff,
Graduation Rates, and Student Financial Aid surveys will be perturbed
and migrated to the PAS to eliminate the need for restricted files;
more recent years will be done first.
ADDITIONAL RESOURCES
--------------------
* IPEDS Peer Analysis System:
http://nces.ed.gov/ipedspas/index.asp
* NCES statistical standards glossary definition for perturbation:
http://nces.ed.gov/statprog/2002/glossary.asp
* Privacy Act of 1974, as amended:
http://www.usdoj.gov/04foia/privstat.htm
* Federal Statistical Confidentiality Order of 1997:
http://www.whitehouse.gov/omb/inforeg/conf-order.pdf
* U.S. Patriot Act of 2001:
http://frwebgate.access.gpo.gov/cgi-bin/getdoc.cgi?dbname=107_cong_publi
c_laws&docid=f:publ056.107.pdf
* Educational Sciences Reform Act of 2002:
http://www.ed.gov/policy/rschstat/leg/PL107-279.pdf
* E-Government Act of 2002:
http://www.cio.gov/documents/e_gov_act_2002.pdf
* Family Educational Rights and Privacy Act:
http://www.ed.gov/policy/gen/guid/fpco/ferpa/index.html
* NCAA Emergency Legislation Adopted by the Board of Directors,
January 12, 2004:
http://www1.ncaa.org/membership/governance/division_I/board_of_directors
/2004/January/Att_D_emergency.htm
Coordinated by the Higher Education Data Policy Committee. All
opinions expressed herein do not necessarily reflect the official
position of the Association for Institutional Research.
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