Toward a More Equitable Future for Postsecondary Access

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Toward a More Equitable Future for Postsecondary Access
Toward a More Equitable Future
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Toward a More Equitable Future for Postsecondary Access
Table of Contents

        Executive Summary.......................................................................1

        Methodology.................................................................................5

        Introduction and Context............................................................10

        Institutional Selectivity................................................................15

        The Application Process...............................................................20

        The Federal Financial Aid Application Process...........................28

        How We Make Admission Decisions..........................................33

        The Admission Staff.....................................................................41

        Combating Implicit Biases in the Financial Aid Office...............46

        Conclusion and Future Work......................................................49

© 2022. All rights reserved. National Association for College Admission Counseling and
          the National Association of Student Financial Aid Administrators.
Toward a More Equitable Future for Postsecondary Access
Acknowledgements

We would like to thank Lumina Foundation for                 • Kristen Harris, senior director of college and
their generous support of this important research.             career success, New York City Department
We would also like to thank the students who                   of Education
participated in interviews and the members of the            • Emily House, executive director, Tennessee
thought leadership panel:                                      Higher Education Commission and Tennessee
  • Kendra Allen, associate director of financial              Student Assistance Corporation
    aid special programs, Northern Virginia                  • Janet Marling, executive director,
    Community College                                          National Institute for the Study of
  • Tanya Ang, senior advocacy director,                       Transfer Students (GA)
    Higher Leading Advocates (DC)                            • Stephanie McGencey, executive director,
  • Daniel Barkowitz, assistant vice president                 American Youth Policy Forum (DC)
    of financial aid and veterans’ affairs,                  • Joseph Montgomery, vice president for
    Valencia College (FL)                                      enrollment management and student success,
  • José Bowen, senior fellow, Association of                  Tuskegee University (AL)
    American Colleges and Universities (DC)                  • David Page, vice president for enrollment
  • Alexander Clark, founder and chief executive               management, Dillard University (LA)
    officer, Technolutions (CT)                              • Daniel Phelan, president, Jackson College (MI)
  • Art Coleman, managing partner and                        • OiYan Poon, associate professor affiliate of
    co-founder, EducationCounsel (DC)                          educational policy studies, University of Illinois
  • Shirley M. Collado, Ph.D., President Emerita,              at Chicago
    Ithaca College, President & CEO,                         • Brian Sponsler, vice president of policy,
    College Track                                              Education Commission of the States (CO)
  • Youlonda Copeland-Morgan, vice provost,                  • Michaele Turnage Young, senior counsel,
    enrollment management, University of                       NAACP Legal Defense and Educational
    California, Los Angeles                                    Fund, Inc. (NY)
  • David Follick, dean of admission, Nassau                 • Don Yu, chief operating officer, Reach Higher
    Community College (NY)                                     at The Common Application (VA)

                                                     TOWARD A MORE EQUITABLE FUTURE FOR POSTSECONDARY ACCESS    i
Toward a More Equitable Future for Postsecondary Access
ACKNOWLEDGEMENTS

      In addition, we are grateful to the team at Hearken            About NASFAA: The National Association of
      for their work on this project.                                Student Financial Aid Administrators is a nonprofit
                                                                     membership organization representing more than
      The financial aid policy considerations contained              32,000 financial aid professionals at nearly 3,000
      within are those of the National Association of                colleges, universities, and career schools across the
      Student Financial Aid Administrators (NASFAA)                  country. NASFAA member institutions serve nine
      and do not necessarily reflect positions or policies of        out of every 10 undergraduates in the United States.
      Lumina Foundation, the thought leadership panel,               Based in Washington, DC, NASFAA is the only
      or NACAC. The admission policy considerations                  national association with a primary focus on student
      contained within are those of the National                     aid legislation, regulatory analysis, and training for
      Association for College Admission Counseling                   financial aid administrators.
      (NACAC) and do not necessarily reflect positions
      or policies of Lumina Foundation, the thought                  About Lumina Foundation
      leadership panel, or NASFAA.                                   Lumina Foundation is an independent, private
                                                                     foundation in Indianapolis that is committed to
      About NACAC: The National Association for
                                                                     making opportunities for learning beyond high
      College Admission Counseling (NACAC),
                                                                     school available to all. Lumina envisions a system
      founded in 1937, is an organization of more
                                                                     that is easy to navigate, delivers fair results, and
      than 25,000 professionals from around the world
                                                                     meets the nation’s need for talent through a broad
      dedicated to serving students as they make
                                                                     range of credentials.
      choices about pursuing postsecondary education.
      NACAC’s mission is to empower college                          Research Support
      admission counseling professionals through
                                                                     This report is based on research funded
      education, advocacy, and community.
                                                                     by Lumina Foundation. The findings and
                                                                     conclusions contained within are those of the
                                                                     authors and do not necessarily reflect positions or
                                                                     policies of Lumina Foundation.

                     The effects of systemic racism touch every element of
                    college admission—a process that, at its origin, was not
                          fundamentally designed to promote equity.

      ii    NATIONAL ASSOCIATION FOR COLLEGE ADMISSION COUNSELING • NATIONAL ASSOCIATION OF STUDENT FINANCIAL AID ADMINISTRATORS
Toward a More Equitable Future for Postsecondary Access
Executive Summary

In 2020, American society encountered a flashpoint.          historical reckoning related to the treatment of
Racism, both individual and systemic, was laid bare          Black Americans that reached a crescendo in 2020.
by an environment in which racist attitudes and              This exclusive focus is not intended to minimize
beliefs became prevalent, by violence against Black          or diminish the effects of racism on Indigenous
Americans, and by the COVID-19 pandemic. These               peoples, Asian American students, Latinx students,
seismic events exacerbated the enduring effects of           or other marginalized student populations. Rather,
systemic racism in all areas of life, from health care       we hope that this report opens the door to more
to housing to employment to education.                       honest acknowledgements of the paths that all of
                                                             these students follow, as well as more constructive
College admission and financial aid officers—and             conversations about how racism taints our efforts to
indeed all higher education professionals committed          build a more just society.
to equity, fairness, and inclusion—believe this
is a time when it is incumbent upon all of us, as            To embark on this critical journey of self-
individuals and as professionals, to question the            examination, the National Association for College
assumptions about our work, having witnessed the             Admission Counseling (NACAC), in partnership
insidious effects of racism in all of society’s systems.     with the National Association of Student Financial
The effects of racism extend into postsecondary              Aid Administrators (NASFAA), collaborated
education, as we have known for decades thanks               on this Lumina-funded project. We considered
to the tireless efforts of researchers, advocates,           entry challenges to postsecondary education for
practitioners, and, most importantly, students. The          traditional-aged and adult students of color and
effects of systemic racism touch every element of            develop a framework that uses racial equity as the
college admission—a process that, at its origin, was         primary objective for college enrollment, mapping
not fundamentally designed to promote equity.                out practical outcomes for institutions as well as
                                                             policy directions for institutional, state, and federal
In this report, admission recommendations focus              policymakers. Our collaboration involved:
on Black students first and foremost, and financial
                                                               • Convening of a thought leadership panel,
aid recommendations focus on all underserved
populations more broadly. To be sure, racism                   • Conducting interviews with panel members
casts destructive effects on many populations in                 and students, and
American society. This report’s focus on Black                 • Hosting a one-day virtual workshop of the
students is a direct outgrowth of the need for a                 thought leadership panel.

                                                       TOWARD A MORE EQUITABLE FUTURE FOR POSTSECONDARY ACCESS     1
Toward a More Equitable Future for Postsecondary Access
EXECUTIVE SUMMARY

       The results of these efforts were reviewed and                    • Institutional Recommendation: Reconcile
       synthesized into the recommendations presented                      institutional prestige and equity goals.
       in this paper. Our intent in providing these                      • State/Federal Recommendation: Rethink the
       recommendations is to create a foundation of broad-                 meaning of selectivity in the public context.
       based questions that can be expanded and explored
       in light of the vast diversity of postsecondary                 The Application Process
       institutions in the United States. The probing
                                                                       Key Design Observation: The more complex the
       questions raised by these recommendations should
                                                                       application process, the less equitable it becomes.
       be explored both in the aggregate and in the
       individual institutional context. Our intent is not to          To Improve Design for Equity: Radically rethink
       dictate specific practices, but to provide a framework          the concept of the college application so that
       so that both current and future practices may be                the burden on the student is minimized and the
       evaluated and considered against a backdrop of                  information stored regarding the student’s K-12
       comprehensive, inclusive thought.                               experience is maximized through systems that
                                                                       facilitate simplified sharing of information.
       As a result of this work the following
       recommendations are put forth:                                  Recommendations

       Institutional Selectivity                                         • Admission Office Recommendations:
       Key Design Observation: Selectivity exerts a                         – Explore alternatives to the current application
       fundamentally inequitable influence on the path                        process to minimize the burden on students.
       to postsecondary education. It does so not because                   – Reduce or eliminate application fees.
       the system is designed on a complete definition
                                                                         • Institutional Recommendation: Develop
       of “merit,” which remains elusive and ill-defined,
                                                                           or strengthen professional development
       but because in many cases it is designed to exclude
                                                                           opportunities for school counselors and college
       even highly qualified students and because its
                                                                           advisers serving students of color.
       current configuration relies upon an inequitable
       system of inputs.                                                 • State/Federal Recommendations:
                                                                            – Investigate the potential for developing a
       To Improve Design for Equity: For institutions
                                                                              postsecondary application infrastructure.
       that choose to exercise a degree of selectivity in their
       enrollment process, develop methods for entry that                   – Invest in programs aimed at hiring, training,
       are, to the extent possible, least susceptible to the                  and equipping school counselors and college
       influence of systemic racism.                                          advisers for schools serving large numbers of
                                                                              students of color.
       Recommendations

           • Admission Office Recommendation:
             Rethink the meaning of selectivity in
             the institutional context.

       2      NATIONAL ASSOCIATION FOR COLLEGE ADMISSION COUNSELING • NATIONAL ASSOCIATION OF STUDENT FINANCIAL AID ADMINISTRATORS
Toward a More Equitable Future for Postsecondary Access
EXECUTIVE SUMMARY

The Federal Financial Aid                                      To Improve Design for Equity: Radically rethink
Application Process                                            the criteria upon which we make admission and
                                                               financial aid decisions to minimize the steps
Key Design Observation: The more complex
                                                               students need to take outside of their K-12
the financial aid application, the less equitable
                                                               experience.
it becomes.
                                                               Recommendations
To Improve Design for Equity: Rethink the
financial aid application process into one that is less          • Admission Office Recommendation: Re-center
burdensome for students and families, and no longer                the process of evaluating students to focus on a
requires them to continue to “prove they are poor.”                recognition of the array of strengths, skills, and
                                                                   abilities students demonstrate during the K-12
Recommendations                                                    educational experience.
  • Financial Aid Office Recommendations:                        • Institutional Recommendation: Allocate greater
     – Add FAFSA availability to financial aid                     care, attention, and resources to the application
       materials.                                                  review process to provide more time/space
                                                                   for the institution to review applications for
     – Make financial aid offers available as
                                                                   admission in a more contextual fashion.
       quickly as possible.
                                                                 • State/Federal Recommendation: Consider
  • Federal Recommendations:
                                                                   state policies that afford institutions the
     – Prohibit unwarranted use of student and                     opportunity to maximize the focus on K-12
       parent FAFSA data.                                          experiences and minimize the focus on
     – Codify the Oct. 1 release of the FAFSA.                     external requirements or assessments.

     – Extend the 2021–22 verification waiver.
                                                               The Admission Staff
     – Collect data following expiration of the                Key Design Observation: Students need to see
       verification waiver.                                    themselves reflected in the face of postsecondary
                                                               education. The more diversity we can encourage
How We Make Admission                                          in postsecondary admission offices, the greater
Decisions                                                      our ability to attract and relate to a diverse
Key Design Observation: A student’s body of work               student population.
in K-12 education should be the nearly exclusive
focus when taking the next step to postsecondary               To Improve Design for Equity: Present an interface
education. Each additional requirement beyond a                with students that will be widely understood and
student’s work in secondary school acts as a toll,             accessible by students from different racial, social,
which exerts a negative effect on equity.                      and cultural backgrounds.

                                                          TOWARD A MORE EQUITABLE FUTURE FOR POSTSECONDARY ACCESS   3
Toward a More Equitable Future for Postsecondary Access
EXECUTIVE SUMMARY

       Recommendations                                                 Combating Implicit Biases in
           • Admission Office Recommendations:                         the Financial Aid Office
             – Prioritize racial equity in admission staff             Key Design Observation: Institutions that do
               composition and practice, with an emphasis              not do proactive work to acknowledge the implicit
               on data-informed practice.                              biases of their processes and employees are
                                                                       fostering inequity.
             – Conduct regular listening sessions with
               current and prospective Black students                  To Improve Design for Equity: Encourage an
               to better evaluate and assess admission                 environment where implicit biases are explored and
               communications, publications, outreach, and             acknowledged in order to combat behavior and
               recruitment practices.                                  practices that have perpetuated systemic racism.
           • Institutional Recommendation: Regularly revisit
                                                                       Recommendations
             the institutional commitment to racial equity
             to ensure that processes, staffing, budgets, and            • Financial Aid Office Recommendations:
             priorities are aligned with equity goals.
                                                                            – Develop priority deadlines for aid or
           • State/Federal Recommendation: Support                            work opportunities.
             regular research and engagement that solicits
                                                                            – Review internal policies for institutionally
             information about the Black student experience
                                                                              selected verification.
             with college admission.
                                                                         • Institutional Recommendation: Ensure fairness
                                                                           and equity for institutional aid or scholarships.

                        Encourage an environment where implicit biases are
                      explored and acknowledged in order to combat behavior
                       and practices that have perpetuated systemic racism.

       4      NATIONAL ASSOCIATION FOR COLLEGE ADMISSION COUNSELING • NATIONAL ASSOCIATION OF STUDENT FINANCIAL AID ADMINISTRATORS
Toward a More Equitable Future for Postsecondary Access
Methodology

Thought Leadership Panel: Since many major                  heart of the educational endeavor. For this project,
challenges and barriers to admission and financial          we focused on the importance of listening to the
aid are already well-researched and documented, we          lived experiences of students, practitioners, and
focused on listening to students and practitioners,         others who work in higher education—experiences
which we then mapped with what we already                   that informed the recommendations included
know to be true in the established body of research         in this report. By approaching the challenge this
surrounding access issues. This ensures that the            way we ensured that those most central and most
recommendations are both data-supported, as well            affected by these recommendations are at the heart
as central to the actual experiences of students,           of the solutions,
practitioners, and others in higher education. To do        facilitating a process
this, NACAC and NASFAA worked together to                   that allows students,
                                                                                                  Those who suffer
brainstorm a list of practitioners, scholars, and other     practitioners, and                most from systemic
professionals. After deliberation between the two           others in higher                racism in the context
associations, NACAC formed a thought leadership             education closest                       of the transition
panel, convening more than 20 admission, financial          to the issue to have
                                                                                                 to postsecondary
aid, and other higher education professionals. These        a more heavily
professionals provided industry-specific insights,          weighted influence in                education are the
critiques, and recommendations for reducing and             how these challenges                              students.
eliminating race-based barriers to admission and            are addressed.
financial aid. Panelists were asked to participate
in this work through two distinct avenues: focus            We adopted this approach for several reasons:
group sessions and a “flare and focus session,” both          • Those who suffer most from systemic racism in
facilitated by Hearken Consulting.                              the context of the transition to postsecondary
                                                                education are the students. Given that
Hearken Consulting Work: To inform this work,                   admission and financial aid processes are the
NACAC hired Hearken. Hearken is a design                        paths students follow to enter postsecondary
consultancy that recommends a human-centered                    education, our goal was to examine that
approach to design, test, and implement new                     pathway and understand the student experience
strategies and workflows that put those who we                  in combination with our professional
serve at the front and center of organizational                 experience and expertise.
transformation—in this case, the students at the

                                                      TOWARD A MORE EQUITABLE FUTURE FOR POSTSECONDARY ACCESS   5
Toward a More Equitable Future for Postsecondary Access
METHODOLOGY

          • There is an abundance of research that                         of the thought leadership panel, along with
            demonstrates the sustained effects of                          those of the students, informed the report’s
            systemic racism in our entire educational                      recommendations. The recommendations
            system, including the transition to and                        expressed by NACAC in the area of admission,
            through postsecondary education. While                         and NASFAA in the area of financial aid, are
            more research can and should be done,                          intended to prompt further discussion rather
            there remain few elements of the admission                     than serve as prescriptive directives.
            and financial aid processes that have gone
            unexamined by the critical eye of objective               Hearken’s efforts focused on three areas:
            research. Throughout this report, we will refer             • Conducting small group sessions with panel
            to such research where it aligns closely with                 members and student interviews,
            our process and recommendations, though we
                                                                        • Conducting one virtual meeting of the full
            cannot capture the full depth and breadth of
                                                                          thought leadership panel, and
            the decades of work of committed researchers
            and advocates. This report is therefore not                 • Conducting two executive whiteboarding
            intended as a comprehensive overview or                       sessions with NACAC and NASFAA staff.
            summary of all research that has contributed,
                                                                      Thought Leadership Panel Listening Sessions:
            and will continue to contribute, to our
                                                                      Hearken Consulting conducted virtual small group
            understanding of systemic racism.
                                                                      listening sessions with all thought leadership
          • For this project, we wanted to gather input               panelists in June and July 2021. During these
            and encourage thinking that was unbounded                 listening sessions Hearken prompted panelists to
            from the limitations of the current system,               provide structured feedback to a series of prompts
            while simultaneously recognizing how the                  about the admission and financial aid processes
            current system affects students of color. As              from the perspective of students of color. Listening
            such, the recommendations included in this                sessions were then synthesized and shared with
            report encourage us to think about what                   NACAC and NASFAA.
            a system that is designed for racial equity
            could look like. If we set markers for a more             Student Interviews: Hearken Consulting conducted
            equitable future, the possibility of designing            interviews with 17 students of traditional college-
            systems that steer us toward that future may              age and adult learners in May 2021. Students
            become more attainable.                                   were recruited by the NACAC, NASFAA, and
                                                                      members of the thought leadership panel. These
          • Finally, it is important to note that the
                                                                      participants were indispensable in highlighting the
            recommendations that accompany this
                                                                      real-life hurdles they faced in their college-going
            report do not necessarily reflect unanimous
                                                                      process—most of which aligned with research
            consensus of the thought leadership panel.
                                                                      already conducted. Despite the modest size of our
            Unlike many projects that involve a guiding
                                                                      panels, consistent patterns emerged as they discussed
            committee or task force, we did not want
                                                                      their experiences and challenges in our system of
            this project to shrink the universe of what is
                                                                      admission and financial aid.
            possible to only those items on which there
            was uniform agreement. Rather, the viewpoints

      6      NATIONAL ASSOCIATION FOR COLLEGE ADMISSION COUNSELING • NATIONAL ASSOCIATION OF STUDENT FINANCIAL AID ADMINISTRATORS
METHODOLOGY

Full Thought Leadership Panel “Flare and Focus”                    Challenges and Considerations
Meeting: This convening, in June 2021, was
                                                                   One important observation from this process was
facilitated by Hearken Consulting and brought
                                                                   that a significant challenge to making substantial,
together thought leadership panelists. Panelists
                                                                   sustained advances toward racial equity for admission
were led through a presentation by Hearken on
                                                                   and financial aid leaders was the difficulty in “getting
the findings from listening sessions and interviews
                                                                   on the balcony,” or gaining an elevated perspective
and then broken up into groups to discuss ideas
                                                                   to see the larger picture and avoid the traps of
for either admission or financial aid. These two
                                                                   groupthink, inertia, and the grind of everyday work.1
smaller groups were facilitated by Hearken and also
                                                                   As one thought leader participant put it:
included NACAC and NASFAA staff.
                                                                      “ I run into this seemingly every day—the question of
Specific outcomes from the thought leadership                           budget and resources. We don’t have enough time to do
panel listening sessions, student interviews, and full                  this, or we don’t have enough staff to do it that way.
thought leadership panel “flare and focus” meeting                      And it really raises the fundamental question: Where
are not shared in this report but folded into the                       are your priorities? It’s both the time and money. The
recommendation sections outlined later.                                 question of the competing other priorities and how
                                                                        this gets understood, I would argue, as legitimately
Executive Whiteboarding Sessions: Two executive
                                                                        mission-central, embedded part and parcel of
whiteboarding sessions were conducted by Hearken
                                                                        the institution...I think it’s actually a question of
to inform this project. The first, in April 2021, was
                                                                        psychology and approach that’s overlaying in the ether
composed of staff from NACAC and NASFAA.
                                                                        about the approach, intentionality, and transparency
The goal of this session was to discuss the overall
                                                                        associated with these issues.”
project and prepare for the work. The second was
                                                                                   – Thought leadership panel participant
in June 2021 and was again composed of NACAC
and NASFAA staff. The goal of this session was
                                                                   This participant highlighted that a common
to discuss the aggregated outcomes from all
                                                                   challenge in rethinking the design of a system is
research efforts and begin an initial conversation on
                                                                   the tendency to assume that the system’s current
recommendations.
                                                                   design is fixed or a “given.” That tendency was
                                                                   underscored in this grant process as discussions
After Hearken concluded its work, both NACAC
                                                                   often turned to how we can better adapt students
and NASFAA authored the admission and
                                                                   to the system, rather than better adapting the
financial aid sections, respectively. The full set of
                                                                   system to students. As a core component of the
recommendations was presented to the thought
                                                                   design approach, a culture of continuous learning
leadership panel in October 2021 for feedback
                                                                   is a critical element of any transformation process.
before being moved to finalization and publication
                                                                   To be successful, strategies for change need to
by NACAC.
                                                                   be sustained by a set of initiatives to fast-track
                                                                   transformation and sustain long-term behavior-
                                                                   change across an organization or profession.
___________________

1
    Heifetz, Ronald A., and Linsky, Marty. “Get on the Balcony. (Why Leaders Need to Step Back to Get Perspective),”
    Harvard Business Review Press, 2002. https://www.hbsp.harvard.edu/product/1667BC-PDF-ENG

                                                             TOWARD A MORE EQUITABLE FUTURE FOR POSTSECONDARY ACCESS        7
METHODOLOGY

      Finally, this project underscored the importance               This is an issue that admission offices have grappled
      of listening. The national political and social                with for many years, though the language sometimes
      environment in which this discussion took place is             becomes blurred when referring to under-
      defined by an imbalance in our tendency to talk, or            represented students, students of color, and students
      shout, rather than to listen. What is clear is that not        who are first in their families to go to college. The
      enough people are listening. The ability of higher             admission recommendations and considerations
      education to achieve equity will therefore depend,             in this report specifically focus on considering the
      in part, on our ability to listen to the people who we         harmful effects of racism on Black students in the
      are trying to serve and on whose behalf we seek a              context of the US postsecondary education system.
      greater accountability for breaking through calcified          There are other issues and groups that are deserving
      policies, practices, attitudes, and perceptions.               of study whose barriers parallel those of Black
                                                                     students, so there are portions of this paper where
      Terminology and Scope                                          their challenges are also represented.
      In this report, admission recommendations focus
                                                                     One cannot paint all Black students, or to a larger
      on Black students first and foremost, and financial
                                                                     extent, students of color, with the same brush.
      aid recommendations focus on all underserved
                                                                     Differences in personality, skills, interests, traits, etc.
      populations more broadly. To be sure, racism
                                                                     are as numerous within racial/ethnic populations
      casts destructive effects on many populations in
                                                                     as they are in the population at large. In this
      American society. This report’s focus on Black
                                                                     project, following larger societal trends, there are
      students is a direct outgrowth of the need for a
                                                                     commonalities between, for instance, low-income
      historical reckoning related to the treatment of
                                                                     students, students who are the first in their families
      Black Americans that reached a crescendo in 2020.
                                                                     to attend college, and Black students. But we wish to
      This exclusive focus is not intended to minimize
                                                                     make clear that this project was designed specifically
      or diminish the effects of racism on Indigenous
                                                                     to address race and racism without regard to a
      peoples, Asian American students, Latinx students,
                                                                     student’s socioeconomic background. One of our
      or other marginalized student populations. Rather,
                                                                     thought leadership panelists reminded us:
      we hope that this report opens the door to more
      honest acknowledgements of the paths that all of                 “ Not all students of color are poor. Not all students of
      these students follow, as well as more constructive                color are low-resourced.”
      conversations about how racism taints our efforts to
                                                                                    – Thought leadership panel participant
      build a more just society.

                   One cannot paint all Black students, or to a larger extent,
                           students of color, with the same brush.

      8     NATIONAL ASSOCIATION FOR COLLEGE ADMISSION COUNSELING • NATIONAL ASSOCIATION OF STUDENT FINANCIAL AID ADMINISTRATORS
METHODOLOGY

Unfortunately, the hurdles for Black and                     The report that follows outlines how the system of
underrepresented student populations don’t end               selective postsecondary admission contains design
after gaining admission to an institution. Once the          elements that were originally intended to exclude,
stress surrounding admission ends, for many, the             rather than include, many people, including non-
stress around financing begins. While there have             white students. Although significant efforts have
been great strides over the past several decades in          been made to eliminate overtly racist elements, the
providing access to an affordable college education,         legacy that remains in its place continues to bear
we know that disparities still exist between who             the effects of exclusion. NACAC and NASFAA,
is able to navigate the financial aid process. Of            together with the project’s thought leadership panel
particular concern found across the entire college-          and the students involved, hope to stimulate further,
going lifecycle is the disparity that exists by race,        careful consideration of how changing these design
which is the focus of this report.                           elements could lead to improvements in racial equity
                                                             in college access.

                                                        TOWARD A MORE EQUITABLE FUTURE FOR POSTSECONDARY ACCESS   9
Introduction and Context

Original Design Flaws:                                               Higher education flourishes because the value of
A History of Inequity                                                a postsecondary degree remains high. The payoff
                                                                     includes higher earnings, greater efficacy in political
    “ If you are making policies that take care of the               and personal life, greater satisfaction with life, and
      most vulnerable populations, the non-vulnerable                a host of other benefits. And society benefits from
      population loses nothing, and it becomes better                citizens with advanced education—more skills,
      for everyone.”                                                 greater political engagement, better earnings (and
                      – Thought leadership panel participant         therefore taxes), improved self-sufficiency, less
                                                                     imprisonment, and a reduced need for some social
As a precursor to addressing how systemic racism                     safety net programs.3
affects the transition to postsecondary education, it
is worth a brief review of broad structural challenges               Yet while many Americans view higher education as
that inhibit equity in many forms. There are as                      a means for upward mobility, America’s public policy
many pathways to and through higher education as                     has not corrected for calcified social stratification
there are students. The increase in enrollment has                   and has increasingly treated postsecondary
transformed college admission into a mass market.                    education as a private good. Moreover, the reduced
The imperative of enrolling a sufficient number                      state/federal role in funding higher education
of students to meet bottom-line considerations                       and corresponding reliance on tuition revenue
generates billions of dollars in tuition and revenue                 by publicly assisted institutions places additional
for colleges and universities, much of that flowing                  demands on many colleges’ ability to support
through public and private student loan providers                    students with financial assistance.4 In a system that
due to a shift in public policy toward higher                        is increasingly reliant on private wealth for access
education as a private good. 2                                       and for institutional survival, students who have the
                                                                     fewest resources to contribute are most at risk of
                                                                     being excluded.
___________________

2
    Excerpted from the National Association for College Admission Counseling Ad Hoc Committee on Leadership in College
    Admission “Process, Findings, and Recommendations 2020”
3
    College Board, Trends in Higher Education Series: “Education Pays,” December 2019. https://research.collegeboard.org/trends/
    education-pays
4
    “Funding Down, Tuition Up,” Center on Budget and Policy Priorities, August 2016. https://www.cbpp.org/research/state-budget-
    and-tax/funding-down-tuition-up

10        NATIONAL ASSOCIATION FOR COLLEGE ADMISSION COUNSELING • NATIONAL ASSOCIATION OF STUDENT FINANCIAL AID ADMINISTRATORS
INTRODUCTION AND CONTEXT

While not all students of color lack financial                          enrollment rates were not measurably different
resources, centuries of exploitation and                                between 2019 and 2010. However, for Black
discrimination have left a disproportionate number                      students, the immediate college enrollment rate
of Black Americans at or near the poverty line.5 In                     was lower in 2019 (57 percent) than in 2010
addition, the legacy of discrimination against Black                    (66 percent). In 2019, the immediate college
Americans continues to cast a wide shadow over all                      enrollment rate for White students was higher
of society, including higher education. According to                    than the rate for Black students in every year
the American Council on Education, gains in equity                      since 2011.8
over time “are too often overshadowed by outcomes
that reflect the effects of systemic and structural                  While this trend reflects deep inequities at all
barriers that can limit or eliminate opportunity for                 levels of society, those committed to postsecondary
Black students, families, and communities, as well                   education have consistently attempted to study
as for our nation at large.”6 Likewise, among adults,                and reflect on how it can be better. This was the
“African-Americans and Hispanics are less likely to                  case, for instance, in the period after World War
say they have pursued personal learning activities                   II when higher education expanded exponentially
in the prior year by margins that differ significantly               to serve students from many more socioeconomic
from white adults,”7 according to data from the Pew                  backgrounds. It was also the case after the civil
Research Center.                                                     rights movement, a time period that saw improved
                                                                     access for women and students from racial and
The US Department of Education reported that                         ethnic minority backgrounds. A similar impetus to
the college enrollment rate for Black students                       surmount the persistent legacy of racial inequity
who recently graduated from high school actually                     propels us today.
declined over the past decade.
                                                                     Although the ways in which students are excluded
     In 2019, the immediate college enrollment rate                  from postsecondary education are numerous, the
     for Asian students (82 percent) was higher than                 primary point of interest to this project are those
     the rates for White (69 percent), Hispanic (64                  barriers that make it difficult for students to gain
     percent), and Black (57 percent) students, and                  entry to a college or university in the first place.
     the rate for White students was also higher than                Barriers to entry constitute a critical first hurdle
     the rate for Black students. For White, Asian,                  that many students must clear to have any chance
     and Hispanic students, the immediate college                    of success.

___________________

5
    “Inequalities Persist Despite Decline in Poverty For All Major Race and Hispanic Origin Groups,” United States Census Bureau,
    September 20, 2020. https://www.census.gov/library/stories/2020/09/poverty-rates-for-blacks-and-hispanics-reached-historic-lows-
    in-2019.html
6
    “Race and Ethnicity in Higher Education,” American Council on Education, 2019. https://www.equityinhighered.org/resources/
    report-downloads/
7
    Pew Research Center, “Lifelong Learning and Technology,” March 22, 2016. https://www.pewresearch.org/internet/2016/03/22/in-
    addition-to-socio-economic-class-there-are-differences-in-adult-learning-with-respect-to-race-and-ethnicity/
8
    US Department of Education, Condition of Education, 2020. See https://nces.ed.gov/programs/coe/indicator/cpa

                                                               TOWARD A MORE EQUITABLE FUTURE FOR POSTSECONDARY ACCESS         11
INTRODUCTION AND CONTEXT

       With this context as a starting point, the goal                           colleges that dramatically reduce their chances
       of this project was to envision how admission                             of ultimately obtaining a bachelor’s degree.
       and financial aid systems should be designed if                           This is not a meritocracy. Nor is it an evil plot
       racial equity was the primary objective. We did                           by universities. It is a rational response to
       so to begin a much broader and more sustained                             incentives created by government disinvestment
       conversation, knowing that many thousands of                              in public higher education. Policymakers at
       perspectives will be needed to address systemic                           both the federal and state levels should give
       racism and that there are macro-issues that are far                       consideration to how they can apply policy
       outside of our control and that require other actors                      levers to provide sustainable financial pathways
       from many different sectors to solve.                                     that enable public research universities to
                                                                                 flourish by serving the mission of social mobility
       A Note About Public                                                       that they were founded to serve.9
       Investment in Postsecondary
       Education                                                             Admission officials frequently must grapple with
                                                                             conversations with institutional administrators
       The ability of admission and financial aid offices
                                                                             that involve statements such as, “How do we fund
       to single-handedly effect change is circumscribed
                                                                             our ambitious plans?” and “We can’t cut into the
       by institutional, state, and federal policies that
                                                                             full-paying students.” In such environments, we
       often render strategies aimed at improving equity
                                                                             are mindful that simply addressing admission and
       impossible for financial reasons.
                                                                             financial aid practices in isolation will be largely
            State policymakers often rationalize funding                     ineffective, as the locus of control over policies and
            cuts to public research universities based on the                institutional priorities that drive such disparities
            assumption that these universities can generate                  are often far beyond the reach of practitioners. As
            their own revenues through tuition. Our                          such, this report will provide recommendations that
            research finds that while most public research                   should be considered together as a comprehensive
            universities do successfully grow tuition revenue                means for untangling the complex web of
            to compensate for state budget cuts, forcing                     policies that result in sustained racial inequity in
            universities to finance their survival through                   postsecondary education.
            tuition revenue compels them to prioritize
            customers who pay the most. As a result, public                  Our Responsibility
            flagship universities may expend substantial                     It is important to note that this project and this
            resources recruiting and offering “merit” aid to                 report contain painful, difficult acknowledgements
            mediocre out-of-state students who are rejected                  of the limitations of the system in which admission
            from public universities in their own state, while               and financial aid professionals work. The struggle
            high-achieving, low-income in-state students                     to achieve a more equitable future even within
            are neglected and often funneled to community                    these parameters is evident, as college admission

       ___________________

       9
           Jaquette, Ozan and Han, Crystal. “Follow the Money: Recruiting and Enrollment Priorities of Public Research Universities.”
           Third Way, 2020. https://www.thirdway.org/report/follow-the-money-recruiting-and-the-enrollment-priorities-of-public-research-
           universities

       12        NATIONAL ASSOCIATION FOR COLLEGE ADMISSION COUNSELING • NATIONAL ASSOCIATION OF STUDENT FINANCIAL AID ADMINISTRATORS
INTRODUCTION AND CONTEXT

and financial aid professionals strain to implement                           access to resources or individuals, such as
practices that are, for many reasons, constrained                             school counselors, who can assist them in the
from succeeding. While this report will prompt                                complicated tasks involved in the application
difficult questions, it is important to acknowledge                           process. School counselors and college advisers
the commitment that NACAC, NASFAA, and                                        can make a substantial difference. Lack of
our members have to improving equity in higher                                access to school counselors is a civil rights
education—a commitment that has lasted for                                    challenge,10 in part because many students
decades and will continue for many more.                                      lack access to college guidance.11 Adult
                                                                              learners—both first-time and those with some
Acknowledging the deep roots of these systems, as                             postsecondary coursework—have access to
well as the ground in which the roots are planted,                            significantly less postsecondary guidance.12
was essential in envisioning design principles                                In addition, unscrupulous institutions have
oriented toward racial equity. College admission                              preyed on adult learners for their financial aid
and financial aid processes have undergone                                    eligibility, leaving them with unmanageable
multiple iterative changes, including many aimed                              debt. 13Such institutions disproportionately
at improving equity outcomes. Yet underlying                                  target students of color, further exacerbating
constructs, including application processes, selective                        racial inequities in educational attainment and
admission practices, financial aid rules, and                                 student debt.14
procedures—plus the criteria by which institutions
                                                                           • Complexity: Our admission and financial
evaluate students—continue to constrain our ability
                                                                             aid processes are complex, cumbersome, and
to effect change.
                                                                             bureaucratic. Research shows that many
     • Process Challenges: For many students,                                students don’t complete the process due to
       the prospect of applying to college can be                            its navigational difficulty.15 In addition, adult
       intimidating, and many students of color lack                         students often find it very difficult to make

___________________

10
     https://www2.ed.gov/about/offices/list/ocr/docs/CRDC2013-14-first-look.pdf
11
     “Student-to-Counselor Ratios by School District,” National Association for College Admission Counseling, 2019.
     https://www.nacacnet.org/news--publications/Research/student-to-counselor-ratios-by-school-district/
12
     For example, see WICHE, “Bringing Adults Back to College: Designing and Implementing a Statewide Concierge Model,”
     https://www.wiche.edu/blog/resources/bringing-adults-back-to-college-designing-and-implementing-a-statewide-concierge-model/; and
     “Colleges Should Cultivate More Equitable Transfer Pathways,” https://www.insidehighered.com/views/2020/04/23/colleges-should-
     do-more-create-equitable-transfer-opportunities-students-opinion
13
     “How For-Profit Colleges Sell ‘Risky Education’ To The Most Vulnerable,” National Public Radio, March 27, 2017.
     https://www.npr.org/2017/03/27/521371034/how-for-profit-colleges-sell-risky-education-to-the-most-vulnerable.
14
     “Worse Off Than When They Enrolled: The Consequence of For-Profit Colleges for People of Color,” The Aspen Institute,
     March 19, 2019. https://bit.ly/3k3gh4H
15
     “Complexity in College Admission: The Barriers Between Aspiration and Enrollment for Lower-Income Students,”
     College Board, October 2011. https://secure-media.collegeboard.org/digitalServices/pdf/advocacy/admissions21century/complexity-in-
     college-admission.pdf

                                                                  TOWARD A MORE EQUITABLE FUTURE FOR POSTSECONDARY ACCESS           13
INTRODUCTION AND CONTEXT

               the transition into postsecondary education,                         • Financial Constraints: State and federal
               whether for the first time or as a returning                           financial aid are insufficient to cover the cost
               student.16 Removing unnecessary barriers will                          of attending most colleges and universities,
               require a fundamental reimagining of the entire                        constituting a significant and systemic barrier
               college application process.                                           to many students.17 Adding to this considerable
            • Entry Criteria: A great deal of inequity results                        affordability barrier is the requirement that
              from the access advantaged students have                                students prove they are in need through the
              to the resources needed to augment their                                complicated process of completing a FAFSA
              secondary school record, including (but not                             and, in some cases, a CSS Profile or other
              limited to) multiple standardized test sittings,                        institutional application requirement.
              test preparation activities, essay assistance,
                                                                                 A mindset that consistently challenges assumptions
              and private college counseling. Black students,
                                                                                 is critical to the work of improving equity in
              on the whole, have less access to college
                                                                                 postsecondary educational access. The following
              preparatory coursework and fewer school
                                                                                 sections of this report examine elements of the
              counselors, as well as fewer financial resources
                                                                                 admission and financial aid processes where
              to take or retake admission tests, thereby
                                                                                 professionals, institutional leaders, and policymakers
              lacking access to the very levers students must
                                                                                 can explore ways to center equity in the practices
              pull to enter selective postsecondary education.
                                                                                 and policies involved in recruiting and enrolling
                                                                                 students in postsecondary institutions.

       ___________________

       16
            “Going Back to College as an Adult? Here’s What You Need to Know” MarketWatch, February 1, 2019.
            https://www.marketwatch.com/story/going-back-to-school-as-an-adult-heres-what-to-know-2019-01-31
       17
            See https://research.collegeboard.org/pdf/trends-college-pricing-student-aid-2020.pdf

       14        NATIONAL ASSOCIATION FOR COLLEGE ADMISSION COUNSELING • NATIONAL ASSOCIATION OF STUDENT FINANCIAL AID ADMINISTRATORS
Institutional Selectivity

                                 Reconciling Exclusivity with Equity
                            More                                                                        Less
                           Equitable                                                                  Equitable

                              Less                                                                     More
                            Selective                                                                 Selective

     Key Design Observation

     Selectivity exerts a fundamentally inequitable influence on the path to postsecondary
     education. It does so not because the system is designed on a complete definition of “merit,”
     which remains elusive and ill-defined, but because in many cases it is designed to exclude
     even highly qualified students and because its continued design relies upon an inequitable
     system of inputs.

     “[T]he race for numbers is over, and…the race for
                                                                           To Improve Design for Equity
      quality has begun. A few years ago our colleges and
      universities were competing for students, and great                  For institutions that choose to exercise a
      emphasis was laid upon ‘healthy growth.’ Now we                      degree of selectivity in their enrollment
      are beginning to limit our numbers, to compete only                  process, develop methods for entry that
      for the best students, and to point with pride to the                are, to the extent possible, least susceptible
      multitude we turn away.”                                             to the influence of systemic racism.
                           – Frank Aydelotte, president,
                        Swarthmore College (PA), 192818

___________________

18
     Wechsler, Harold S. The Qualified Student: A History of Selective College Admission in America. Transaction Publishers,
     New Brunswick, NJ. 2014. p. 230.

                                                                 TOWARD A MORE EQUITABLE FUTURE FOR POSTSECONDARY ACCESS       15
INSTITUTIONAL SELECTIVITY

        The “Reputational Model” of higher education                          legal battles culminating with Supreme Court
        is based on a fundamental preoccupation with                          cases—they do so in a system that is, at best, only
        exclusivity. The roots of selective college admission                 minimally designed to facilitate equity. Many of
        are deep and extend to the very origins of the                        the processes and criteria associated with highly
        modern institution. For many institutions that                        selective admission are designed to exclude, not
        were transforming in the early 20th century, “[s]                     include. The central challenge, as pondered by
        elective admissions would present the discovery                       both students and the thought leadership panel,
        of the best material from among all applicants                        is that since the fundamental inputs associated
        and the University would prepare them for                             with selective admission are themselves tainted by
        positions of responsibility.”19 This viewpoint was                    racial inequity, making high-stakes decisions based
        rooted in a time when eugenics and racism were                        on these flawed criteria results in fundamentally
        openly accepted as facts of life. Since that time,                    inequitable outcomes.
        our understanding of human abilities, social
                                                                                 “How do you determine who has merit and potential
        influences—most importantly for this project:
                                                                                  when you’re admitting [students] to college,
        racism, systemic inequities, and education—has
                                                                                  when people have not had equal opportunities to
        progressed to a point where these old assumptions
                                                                                  demonstrate merit?”
        about “the best material” no longer apply.
                                                                                              – Thought leadership panel participant
             “If you’re stepping back and saying where is the search
              process beginning, I don’t know if it’s going to be             As this project has illuminated, adding variables
              successful just to eliminate all the barriers that are          outside of the context of the high school
              there, because I think the barriers, for a lot of colleges,     experience creates “tolls” on the road to college,
              are purposeful, and they put them up as a way to                each of which has a regressive influence on
              connote value—that they are being selective, that they          equity. NACAC’s research on the factors in the
              are creating this microcosm of an environment.”                 admission decision confirms through correlation
                              – Thought leadership panel participant          analysis that the more selective the college, the
                                                                              more weight is placed on added variables, which
        Put bluntly, institutions make a choice to be                         are not equally attainable by all.20 By adhering
        exclusive. The choice to be exclusive, by definition,                 to a selective process that favors variables only
        and, as the quote from former university president                    some students can attain, these highly selective
        Frank Aydelotte above illustrates, places institutions                institutions validate an admission model that is
        in a position where it is much more difficult to be                   designed to admit students who are able to access
        inclusive due to the “multitudes that [they] turn                     these extracurricular variables and exclude those
        away.” As such, while highly selective institutions                   who can’t. Regardless of intention, the design
        have expressed an admirable commitment to racial                      of this type of system prioritizes students with
        equity—indeed, many have endured protracted                           access over those without.

        ___________________

        19
             Ibid., p. 233.
        20
             Clinedinst, M, and Hair, C. State of College Admission, National Association for College Admission Counseling, 2019.
             https://www.nacacnet.org/globalassets/documents/publications/research/2019_soca/soca2019_ch3.pdf

        16        NATIONAL ASSOCIATION FOR COLLEGE ADMISSION COUNSELING • NATIONAL ASSOCIATION OF STUDENT FINANCIAL AID ADMINISTRATORS
INSTITUTIONAL SELECTIVITY

Admission offices balance a juggling act of                            students who apply. Indeed, the average acceptance
institutional interests as they attempt to meet the                    rate for selective colleges (the population of four-
institution’s tuition needs, achieve a mix of students                 year colleges minus open-enrollment institutions)
from varying walks of life, and recruit students                       has hovered around 65 percent for the last two
who will enable the institution to sustain academic                    decades.24 As a result, both students and thought
departments as well as quasi-extracurricular and                       leaders questioned whether our current terminology
extracurricular activities. This model is reinforced                   about entrance to college, much of which is modeled
by legal considerations as well, including in-state                    on the elitist model developed in the early 1900s, is
recruitment mandates for public colleges, Title IX                     well-suited to equity.
considerations for sports teams, and federal and state
                                                                          “It starts by saying we have got to get rid of the word
legal considerations for ensuring that institutions
                                                                           ‘admissions’ and the whole idea of being selective. We
do not violate civil rights laws. With that said, there
                                                                           know that most colleges are not highly selective.”
have been many proposals over the years calling for
a more randomized approach to higher education                                          – Thought leadership panel participant
admission.21 Public K-12 schools where attendance
                                                                       That said, roughly half of all colleges turn away
is not defined by neighborhood frequently employ                       a third or more of their applicants, which means
randomized admission to ensure equity. Some states                     that there must always be a focus on whether those
allow “weighted” lotteries to ensure that underserved                  being excluded are disproportionately students of
students have access to resources that have been                       color. In addition, the most highly selective colleges
specially designed to serve them.22                                    exercise outsized influence on policy, practice, and
                                                                       the national conversation about college admission.
While selective institutions began their current
                                                                       Media attention is weighted heavily toward highly
trajectory in the 1920s, others took a more
                                                                       selective colleges, selective colleges are the subject
democratic approach. The president of the University
                                                                       of regular lawsuits over admission policies, and
of Wisconsin, Alexander Meiklejohn, noted in 1927
                                                                       admission policies at highly selective colleges have
that the university’s primary task was “taking all
                                                                       long-served as the model for other institutions.
types of young people and discovering their talents,”
                                                                       Indeed, the popular perception of college admission
an important acknowledgement that talents are
                                                                       still remains wedded to the idea that entrance to
manifold and up to postsecondary institutions to
                                                                       postsecondary education is an exclusive endeavor.
discover.23 The thought leadership panel noted that
a large majority of four-year colleges in the United                   Importantly, rankings of colleges and universities
States accept more than half of all applicants, and a                  was a topic close to a number of people’s minds in
substantial portion of that majority accept nearly all                 the thought leadership panel. Although rankings

___________________

21
     See Poon, OiYan, “Dismantling the Hunger Games: Exploring a Match System in Selective Admissions,” Hack the Gates
     Initiative, August 2020. https://hackthegates.org/wp-content/uploads/2020/08/Poon-Match-HTGreport.pdf
22
     See “State Laws on Weighted Lotteries and Enrollment Policies,” National Alliance for Public Charter Schools, 2015.
     http://www.publiccharters.org/sites/default/files/migrated/wp-content/uploads/2015/06/NPC035_WeightedLotteries_Digital_rev.pdf
23
     Wechsler, p. 230
24
     National Association for College Admission Counseling, State of College Admission, 2005-2019.

                                                                 TOWARD A MORE EQUITABLE FUTURE FOR POSTSECONDARY ACCESS              17
INSTITUTIONAL SELECTIVITY

        publications can provide some helpful reference                      level, institutional awareness of who is likely to
        information, their primary influences end up                         be excluded is essential to an understanding of
        (1) preserving the status quo, which is heavily                      racial inequity. Institutions must then examine the
        dependent upon the exclusivity of the institution,                   grounds upon which the institution makes decisions
        and (2) providing a highly visible incentive for                     to exclude. At this level, systemic elements discussed
        institutions to adhere to the status quo or be                       in this report, as well as other aspects of admission
        penalized. Recent proposals to rethink rankings to                   decisions that tend to perpetuate privilege and
        emphasize equity are important to pursue,25 though                   racial inequity, will require institutions to ascertain
        the ultimate responsibility will rest with institutions              whether their hand-selection of classes beyond
        to understand how their acceptance rates can act as a                a certain eligibility threshold results in equitable
        deterrent to equity.                                                 outcomes. Conversely, could another system that is
                                                                             less subject to bias, particularly racial and ethnic bias,
        The question about exclusivity in admission is                       serve their racial equity ends more optimally?
        indeed a formidable one. The right of an institution
        to admit who it wants and by which standards is a                    If all qualified students had an equal chance of being
        long-held legal principle that has often been used to                admitted—however low—the correlation between
        defend efforts to recruit a diverse student body. But                selectivity and inequity would be significantly
        in accordance with the scope of this project, if racial              reduced (though not eliminated, given systemic
        equity is our primary goal, then even the cherished                  challenges). But based on the current design of
        mantle of “selective” admission must be on the table.                selective admission processes, institutions that decide
                                                                             to exclude large numbers of students will inevitably
             “Either you redesign the whole institution around
                                                                             face serious challenges in achieving racial equity.
              equity, or you don’t. That’s big. But now is the moment
              that enough institutions are actually saying, ‘you             Recommendations:
              know, we might actually…be racist.’ That just wasn’t
              happening a couple of years ago.”                              Admission office:

                              – Thought leadership panel participant            • Rethink the meaning of selectivity in the
                                                                                  institutional context. Examine whether
        Given the entrenched nature of systemic racism,                           the purposes of selective admission policies
        institutions wishing to reexamine their policies                          can be equally well-served by methods of
        and practices through a racial equity lens should                         student selection that minimize the ways
        begin with why they decide to exclude students.                           in which racial bias enters the process of
        The reasons may be many, varied, and ultimately                           selecting qualified students for enrollment.
        justifiable, whether based on the knowledge needed                        For institutions without selective admission
        to succeed or limitations on the ability to serve                         policies or with substantially open admission
        more than a set number of students. At this high                          policies, explore new ways to characterize the
                                                                                  application process to provide greater clarity as
                                                                                  to students’ prospects for enrollment.

        ___________________

        25
             See Ngo, Frederick, “The Equity Rankings: An Alternative Assessment of U.S. Higher Education,” Hack the Gates Initiative,
             August 2020. https://hackthegates.org/wp-content/uploads/2020/08/Ngo-EquityRankings_HTGreport3.pdf

        18        NATIONAL ASSOCIATION FOR COLLEGE ADMISSION COUNSELING • NATIONAL ASSOCIATION OF STUDENT FINANCIAL AID ADMINISTRATORS
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