STATEMENT OF POLICY

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In alignment with the Enterprise Information Management framework, this policy outlines the process for reviewing and releasing strategically important or sensitive external reports that involve academic data. The policy separates responsibilities for preparation and technical and strategic review and provides a framework regarding the minimum time needed for each of these processes. The intent of this policy is to confirm that sensitive external submissions use consistent data definitions and sources except when variances are required by the intent of the requesting agency, and that any variances are appropriately documented.

The Office of Institutional Research is responsible for reviewing and certifying data models and sources used in the preparation of the report before submission, and confirming that variations in reporting definitions are appropriately documented. The Office of Institutional Research will also certify that analysts preparing submissions are appropriately prepared and supported to collect, verify, and report data from each relevant academic data domain. The Office of Institutional Research serves as the Data Trustee for external reporting of academic data.

SCOPE OF POLICY

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All external reporting where accuracy is expected at the level of fiduciary responsibility. This includes, but is not limited to Integrated Postsecondary Education Data System (IPEDS) and New York State Education Department (NYSED), accreditation reports, financial disclosure statements where academic data is mentioned, and major public rankings like US News & World Report.

TO WHOM THE POLICY APPLIES

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University-wide policy that applies to all units, schools, centers, institutes, etc. The policy applies to all administrators involved in the preparation of external submissions of academic data flagged as requiring strategic review and centralized tracking, and those in university leadership involved in approving additional external submissions. External submissions related to data sharing agreements that do not need to align with official university metrics are not covered by this policy.

PROCEDURES

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  1.  Identification of external reports requiring strategic review

Before the beginning of each academic year, each school dean or relevant unit head should submit the following to the University’s Office of Institutional Research:

  • Calendar of deadlines for external submissions that have been identified by Enrollment Management as requiring strategic review, using prior year deadlines as estimates if new deadlines are not available.
  • List of personnel responsible for creating, reviewing, approving, and transmitting each submission (see Responsible Parties below)

As they emerge, new submissions that are likely to require strategic review should be reported to the Office of Institutional Research. Changes in responsible parties should also be communicated to the Office of Institutional Research as they occur.

    2. Responsible Parties

  • Responsible parties are NYU personnel (e.g., Employees and Affiliates acting in an official capacity) who: (i) create a submission; (ii) conduct a technical review of a submission; or (iii) conduct a strategic review and approval for release of a submission.
  • Responsible parties for creating a submission include analysts who extract and prepare data, and who serve as a point of contact with rankings publisher or accreditation agency, with technical access to finalize a data submission.
  • Responsible parties for conducting technical review of a submission include analysts, staff, or leadership who are qualified to provide technical assistance and confirm proper methodology in report preparation. These could include a member of a school’s institutional research department or an analyst authorized by the head of the University’s Office of Institutional Research, and should always be distinct from those involved in the initial creation of the submission.
  • Responsible parties conducting strategic review and approval for release should be appointed by the appropriate school dean or senior leader. Strategic reviewers are expected to ensure reporting methodology is in compliance with external instructions and reflects the most favorable representation of NYU’s performance.

3. Reporting Process

Responsible Parties creating a submission should prepare an inventory of all released data elements for the technical reviewer at least three weeks before the external deadline, including:

A.  The technical system (Database table, UDW+ query, etc.) or Office initially sourcing each reported element

B.  Changes in methodology that were required due to shifts in university operations, external agency definition changes, or data points newly requested.

C.  Any concerns about data integrity that may have emerged during the preparation of the report, and recommendation for changes to data documentation (such as in the Collibra Data Governance System)

Responsible Parties conducting technical review of a submission should prepare a summary of key metric, methodology, or definition changes to memorialize the resolution of interpretive issues at least two weeks before the external deadline for both the strategic reviewer and the University’s Office of Institutional Research, including:

A.  A summary of procedural changes in reporting methodology and confirmation that changes in operations are accurately reflected in the reported data.

i.  Definition, methodology, and code changes should be highlighted and summarized, and prepared against potential external or internal audits.

ii.  Suspected or potential inaccuracies in source data must be resolved or flagged for escalation.

B.  A variance report of key metrics compared to prior submissions

i.  Key data points that impact expected ranking results should be flagged and annotated

ii.  Notable variations or data points that may draw external scrutiny should also be flagged and annotated (specific thresholds will vary, but variances out of direction or scale compared to prior observed year over year changes greater each require a brief explanation)

C.  A compilation of anticipated and strategically important questions and potential responses that may relate to the submission, including, where appropriate and available, peer institution data.

Responsible Parties conducting strategic review and approval for release should compare each new submission against past and peer submissions to confirm reported trends appropriately reflect university operations.

A. Changes in definitions and methodologies should be weighed against external instructions, past practices, and potential new best practices to meet external agency intent.

B. Final approval for release should be communicated to the other responsible parties with sufficient time to submit before the external deadline.

Submission of the data for release must be dependent on full documentation of final approval, and all supporting documentation for the submission, including all elements of the technical review, should be retained in accordance with the NYU Retention and Destruction of Records Policy.


Notes
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  1. Dates of official enactment and amendments: Mar 1, 2024
  2. History: March 1, 2024 - Original Document; New Policy
  3. Cross References: N/A