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Maryland Attorney General Anthony G. Brown is part of a coalition of 17 state attorneys general who have filed a lawsuit challenging new data reporting requirements imposed by the Trump administration on colleges and universities. According to the Office of the Maryland Attorney General, these new mandates, implemented through the Department of Education’s Integrated Postsecondary Education System (IPEDS), are alleged to jeopardize student privacy and could lead to unwarranted investigations of higher education institutions.

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The lawsuit centers on a new survey component added to IPEDS, which is a mandatory data collection system for institutions participating in federal student financial aid programs. This addition, prompted by a presidential memo issued in August 2025, aims to track how colleges and universities are complying with the Supreme Court’s decision in Students for Fair Admissions v. Harvard, which prohibits the use of race as a direct factor in admissions. The coalition of attorneys general contends that the rapid implementation of these new reporting requirements places institutions in a difficult position. They argue that the rushed rollout increases the likelihood of errors in the data submitted, potentially exposing universities to significant penalties and leading to baseless federal investigations.

Furthermore, the complaint highlights concerns regarding student privacy. The new IPEDS requirements demand that institutions disaggregate data by race and sex and retroactively report information from the past seven years. The attorneys general argue that this detailed personal information about individual students could make it easier for them to be identified, potentially compromising their privacy and placing institutions at risk of violating their own data protection obligations. The Department of Education finalized these new requirements on December 18, 2025, following a public comment period during which the coalition voiced strong opposition. Institutions are currently facing a March 18, 2026 deadline to submit this newly required data.

The coalition’s legal challenge asserts that the Department of Education’s expedited process for introducing these data demands fails to adequately consider the substantial burden placed upon educational institutions. A key argument is that the Department of Education has not provided clear definitions for crucial terms within the new requirements, leaving universities uncertain about the exact information they need to provide. This ambiguity, coupled with the potential for severe financial penalties for incorrect submissions, creates a challenging compliance environment. The lawsuit also points to the administration’s elimination of numerous positions within the Department of Education, including those tasked with offering guidance on such reporting requirements, as further evidence of the rushed and inadequately supported implementation.

The attorneys general involved in the lawsuit maintain that the Trump administration’s actions are unlawful and inconsistent with established legal procedures. They describe the implementation of the new data requirements as arbitrary and capricious, arguing that it imposes an undue burden on colleges and universities. The lawsuit seeks to halt these data demands, protecting both student privacy and the operational integrity of higher education institutions. The states joining Maryland in this legal challenge include California, Colorado, Connecticut, Delaware, Hawaiʻi, Illinois, Massachusetts, Nevada, New Jersey, New York, Oregon, Rhode Island, Vermont, Virginia, Wisconsin, and Washington.

This action by the state attorneys general could significantly impact how colleges and universities in Maryland and across the participating states collect and report data related to admissions and student demographics. Institutions will need to navigate these new, complex requirements under a tight deadline, while also safeguarding sensitive student information. The outcome of the lawsuit could set a precedent for future data collection mandates from federal agencies concerning higher education.

Article by Mel Anara, based upon information from the Maryland Attorney General’s Office.

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