The American Immigration Council, along with 29 other organizations, submitted a comment to the Department of Education (DOE) detailing proposed changes to how higher education institutions report data to the National Center for Education Statistics (NCES) through the Integrated Postsecondary Education Data System (IPEDS).

 In February 2022, the DOE proposed changes for the IPEDS directing colleges and universities to report DACA recipients under the category of "nonresident," and report undocumented students without DACA as "Race/ethnicity unknown."

 The comment recommends that institutions report undocumented students who graduate from US high schools (or have a GED) and are enrolled at US colleges and universities with other domestic immigrant students with their self-reported race and ethnicity.