by Dick Hall-Sizemore

President Trump has directed the Secretary of Education to expand the reporting requirements of institutions of higher education in order to determine if any of those bodies are still using race as an admissions criterion.

Accordingly, the Secretary has directed the National Center for Education Statistics (NCES) to collect the following data from each higher ed institution, disaggregated by race and sex:

For applicants and admitted students:

1. Standardized test scores
2. Final grade point averages
3. First-generation-college student status

For enrolled cohorts:

• Graduation rates
• Financial aid offered
• Financial aid provided

In her directive, the Secretary directed NCES “to develop a rigorous assurance process for reported data” in order to “ensure the information collected by the Department is accurate and reliable.”

These directives raise a host of questions and policy issues.

Data Collection and Analysis

As of the first of March, 1.4 million first-year applicants had submitted a total of 8.6 million Common App applications for admission to the higher-ed institutions this fall. Although it is the most-used form of college application, the Common App is not the only method of applying for college admission. Approximately 170 colleges and universities accept Coalition Applications. Many accept both. Data for the submission of applications solely through the Coalition Application process are not available. Finally, many schools use neither the Common App nor the Coalition App, but their own application portals. The total number of applications submitted to these schools is not available. However, preliminary data from the University of California system show that the nine institutions in that system received 930,724 applications from 205,158 individuals for the fall 2025 incoming class. In summary, the Dept. of Education is liable to receive data regarding over 10 million applications involving close to two million applicants in response to the Secretary’s directive.

Who is going to design the data collection forms for, collect, ensure the accuracy of, and analyze this mountain of data? President Trump noted in his directive to the Secretary that NCES and the Integrated Postsecondary Education Data System (IPEDS) play “a critical role in promoting transparency in American higher education.” However, he complained that IPEDS needs upgrading. Therefore, he directed the Secretary to “revise and, if necessary, overhaul the [IPEDS] data collection system portal to remove inefficiencies and better streamline the process to more efficiently organize and utilize the data received from the institutions.” Therefore, the answer is that NCES, using an upgraded IPEDS, would implement the directive to collect and analyze all this data to determine if any higher ed institutions were still using race as an admissions criterion.

There is one major problem with this scenario. President Trump and the Secretary of Education have made it clear that they intend to eliminate the Department of Education and have been systematically dismantling it, especially the research components of the agency. On March 11, the Secretary announced a reduction in force affecting nearly 50 percent of the department’s workforce. In July, after the U.S. Supreme Court allowed the administration to proceed with its reductions, the Secretary, who had earlier declared her intention to eliminate the department, said she was “embarking on its ‘final mission.’”

As for NCES, specifically, the unit charged with collecting, verifying, and analyzing this admissions data, according to one report, there were only four employees remaining in the office at the beginning of August.

Inconsistent Data

According to the Secretary, the administration wants standardized test scores and GPAs, along with race and sex data, to identify “whether they [higher ed institutions] are discriminating against hard-working American applicants.” Leaving aside the question of how many applicants are not “hard-working Americans,” the data that will be submitted will complicate any effort at analysis.

More than 2,000 colleges and universities did not require applicants to submit SAT or ACT scores for consideration for admission this fall. On the Common App, applicants have the option of not answering the question regarding race. Furthermore, higher-ed institutions have the option of hiding the “race boxes” on the Common App. during their consideration for admission. Finally, for the “legal sex” box on the Common App, in addition to “male” and “female,” applicants can choose “X or another legal sex.” Any analysis of whether a higher-ed institution discriminated on the basis of race or sex will need to factor in these variables.

Data Needed, but Not Readily Available

Among the data that must be submitted by colleges and universities is “financial aid offered” and “financial aid provided.” Presumably, the administration wants to ensure that institutions’ financial aid decisions are not racially motivated.

Financial aid programs and policies vary widely among colleges and universities.  =Some financial aid is based on merit; some on financial need. Also, a lot of financial aid is restricted to specific categories. For example, a university in South Carolina provides scholarships to students studying organ and to students studying music education. To determine whether an institution is using race as a criterion in providing financial aid, the Department of Education would need to take all these factors into account and the administration does not seem to have asked for this type of information.

To determine whether there is any racial bias in the distribution of need-based financial, the administration would need data on the financial conditions of applicants or their parents. The Department of Education does have access to such information for likely most applicants—the infamous FAFSA form. However, FAFSA data is separate from IPEDS data. In order to determine whether the provision of financial aid is discriminatory, those two systems must be able to talk to each other. Setting up such interoperability can be time-consuming and tricky.

Policy Issues

Setting aside for the moment the question of who is going to collect and analyze this information submitted by higher ed institutions and the difficulties inherent in any analysis, there are serious policy issues involved.

One important function of higher education has been to foster social mobility. This effort to enhance social mobility has led to diversity in higher education student populations, which is generally considered advantageous for all concerned. As a website for Purdue University explains, “Diverse environments can help people develop empathy, build meaningful relationships, expand their worldviews, and become more innovative through collaboration…. Diversity in colleges and universities is crucial as it sets the stage for one’s future.”

In attempting to accomplish their roles of improving social mobility and encouraging diversity, colleges and universities also need to consider merit when considering applications for admissions. Has this applicant demonstrated the ability to master college material? Has this applicant demonstrated the personal characteristics desired of college students, such as diligence, perseverance, responsibility, willingness to work hard, ability to get along with others, etc.? 

For many years, colleges and universities have attempted to achieve the goals of social mobility and diversity by giving preferences to applicants from minority groups that demonstrate merit. With this approach, minority applicants (primarily Black applicants) would be able to get a college education that would open financial and social doors for them, while their inclusion in the student body would add diversity. However, in the Students for Fair Admissions v. Harvard and the University of North Carolina case in 2003, the U.S. Supreme Court struck down the use of race as a factor in determining college admissions.

There are race-neutral alternatives that could be used by colleges and universities to continue promoting social mobility and diversity. One scholar, who was aligned with the groups that challenged the affirmative action policies of Harvard and the University of North Carolina and won in the Supreme Court, has proposed a “class-based affirmative action program that gives preferences to students who have lower incomes, less generational wealth, and come from poor neighborhoods.”

Another race-neutral alternative used by many institutions to improve social mobility and add diversity to a student population is to give preference to first-generation college students. 

Stil another approach is to give preferences to students from certain areas or high schools. Texas law provides for automatic admission to a state-supported college or university to any high school student who finishes in the top ten percent of his or her high school class. (Depending on the number of applicants, the qualifying percentage may be lower for the University of Texas at Austin.) Florida has a similar program that “guarantees admission to one of the 12 state universities” to students who are ranked in the top 20 percent of their graduating class.

As for merit, there are different ways to define or measure it. The traditional way has long been to use standardized test scores, the well-known College Board exam or SAT (some colleges use the ACT). However, many analysts assert that high-achieving, low-income students have the deck stacked against them with regard to standardized tests. Responding to what they regard as a bias against disadvantaged students, many schools do not consider standardized test scores at all and rely on a holistic approach. With this method, “reviewers are provided with in-depth contextual information about each applicant’s home and school and charged with assessing the student’s accomplishments in light of what supports they were given and what obstacles they have overcome.”

On the other hand, influential analysts contend that standardized tests have an important role to play in the admissions process because they are the best predicters of  college grades, chances of graduation and post-college success. Rather than working against disadvantaged students, these researchers argue that the tests can work to their advantage. “Test scores can be particularly helpful in identifying lower-income students and underrepresented minorities who will thrive. These students do not score as high on average as students from affluent communities or white and Asian students. But a solid score for a student from a less privileged background is often a sign of enormous potential.” Therefore, they argue in favor of making test scores one factor in the admissions process, along with SES factors.

The Trump administration is quite clear about how it defines merit—student standardized test scores and GPAs. Those are the only merit measures the Secretary will be asking higher ed institutions to submit; nothing about applicants’ SES factors. In his directive to the Secretary, Trump made it clear that he considered any other method of defining merit to be “overt and hidden proxies” intended to enable race to be “actually used in practice.” As recently reported by the Wall Street Journal, Attorney General Pam Bondi listed geography and applicant essays on overcoming hardship as examples of “unlawful proxies” for race.

An intriguing question is how the Trump administration would apply this “test scores only” approach to states in which college admission is based partly on high school rank. Consider Texas, for example. If the Hispanic students in the upper five percent of their classes in high schools situated in low-income areas, and who were admitted to the University of Texas at Austin (UTA), had lower SAT scores than some students from schools in higher-income neighborhoods of Dallas and Houston, but who were not admitted to UTA because they did not rank within the top five percent of their classes (the level set for UTA that year), would the Trump administration launch an investigation into whether UTA was using a “race proxy” and thereby violating Title VI of the Civil Rights Act? (Keep in mind that the administration is collecting only SAT scores and GPAs and not anything about the admission policies and laws governing higher ed institutions.)

If the Trump administration were able to collect and analyze all this data in a timely manner and begin to implement the administration’s desire, as the Secretary put it, to “ensure that meritocracy and excellence once again characterize higher education,” admissions officers at colleges and universities may choose to default to standardized test scores as the only criterion for admission. If an institution intends for its incoming class to have 3,000 students, for example, it would rank its applicants by SAT score and offer admission to the top 3,500 students (allowing for some students choosing to go elsewhere). That would certainly make their jobs easier and keep the feds off their backs.

If institutions of higher education move to considering only standardized test scores as the criterion to use in reviewing applications, either because it would be easiest way to avoid scrutiny by the Trump administration or in response to pressure from the administration, there could be a significant change in the demographics of the entering college classes, especially for highly selective institutions. High-achieving, low-income students (white and Black) would be even less likely to be admitted. Furthermore, these selective institutions, which produce a disproportionate share of the nation’s corporate and government leaders, would become even more elitist.

There is a substantial body of research that shows a positive relationship between family income and SAT scores:  the higher the family income, the higher the SAT score. Digging deeper, one study found that while the relationship is present for white students, it is even more pronounced for Black students.

Even under current conditions, high-achieving students from lower-income families are at a disadvantage in being admitted to selective schools. One recent study found that “Ivy-plus colleges admit students from the highest income families at much higher rates than lower-income students with the same SAT/ACT scores.” [Emphasis added] The study attributed this disparity to three factors: legacy preferences; non-academic ratings (weight placed on extracurricular activities, leadership capacity; and personal traits); and athletic recruitment. Also, the type of high school matters for the non-academic ratings: “Among students with similar SAT/ACT scores, those who attend private high schools tend to obtain much higher non-academic ratings than students attending public high school.”

If the Trump administration’s template—primary weight placed on standardized scores a prohibition on the use of any criteria that seem to be a proxy for race, such as family income, first-generation college status, holistic factors such as obstacles overcome, etc. —becomes the standard, it could be much harder for students from middle- and low-income families to gain admission to highly selective colleges and universities in the nation, as well as selective state-supported schools in Virginia, such as UVa and William and Mary. If this turns out to be the case, students from high-income families in Northern Virginia and other urban areas in and outside of Virginia will make up an even greater proportion of the student bodies of those schools. With less diversity, those students from privileged backgrounds will have even less exposure to students with different perspectives and life experiences.  That is probably not a result that Trump backers would be hoping for.