(Originally published in Inside Higher Ed on September 2, 2025)
The Trump Administration has stepped up government scrutiny of college admission. Settlements reached with Brown and Columbia included a requirement that they pursue “merit-based” admission policies. On August 7, President Trump issued a memorandum requiring colleges and universities to submit data to IPEDS (the Integrated Postsecondary Education Data System) demonstrating that they are not considering race in admission decisions. The Department of Education has since published in the Federal Register details about the planned data collection, with the public having 60 days to comment. Attorney General Pam Bondi has entered into the fray by publishing a memo outlining what constitutes unlawful discrimination.
I will leave it to others to rail against the unprecedented federal attack on higher education and the incursion into admission policies at individual institutions. I would prefer to examine some of the issues and underlying assumptions suggested by these documents.
The August 7 Presidential Memorandum
Trump’s memorandum calls for increased transparency to expose practices that are “unlawful” and to rid society of “shameful, dangerous racial hierarchies.” For some reason it doesn’t say that all racial hierarchies are shameful and dangerous. Is that an oversight or a meaningful omission? The memorandum also asserts without explanation that race-based admission policies threaten national security.
The call to get rid of “shameful, dangerous racial hierarchies” is ironic. It is easy to imagine previous administrations using the same phrase to defend the very race-based admission policies that the executive order now seeks to abolish. Shameful and dangerous are in the eye of the beholder, and may not be color-blind.
What is not clear is how the administration intends to collect and analyze the data, given its efforts to gut the Department of Education. As Inside Higher Ed has reported, the National Center for Educational Statistics had been decimated, with a staff of more than 100 reduced to a skeleton crew of three employees.
The Bondi Memo
Attorney General Bondi’s July 29 memorandum offered guidance to federal agencies about practices that may constitute illegal discrimination at colleges and other entities receiving federal funds. A lot of it is rehashed, targeting popular straw men/persons like DEI programs and transgender athletes (and bathrooms).
What is interesting is Bondi’s take on what she calls “unlawful proxy discrimination,” defined as the use of “facially neutral criteria” that function as “proxies” for race or other protected characteristics. Per the memo, examples in higher education may include things like requiring diversity statements in hiring or essay questions asking applicants to reflect on their unique identity or to write about obstacles they have overcome.
On a surface level, Bondi is right that those can become back doors to identify an individual’s race. At the same time, knowing the obstacles an individual has overcome is essential to understanding his or her unique story, and race would seem to be one of the factors that can heavily influence that story.
Where Bondi goes off the rails is in maintaining that what she calls “geographic targeting” may constitute a potentially unlawful proxy. She is suggesting that recruitment or outreach in schools and communities with high levels of racial minorities may be illegal. That is preposterous. Trying to expand access to education through outreach is in no way comparable to reverse engineering an admission process to arrive at a desired class composition.
Taken to its logical extreme, Bondi’s guidance would prevent colleges from recruiting not only at inner-city schools with a large percentage of Black students, but also at suburban schools with a large percentage of affluent white students. Both could be examples of what she calls “geographic targeting.” For that matter, colleges might be in violation for asking for an applicant’s address, since ZIP code information can be used as a proxy for determining race and socioeconomic status.
New Data For IPEDS
As for data collection for IPEDS, the administration has proposed a new “Admissions and Consumer Transparency Supplement,” or ACTS. ACTS will require targeted colleges and universities to report data in the following categories, disaggregated by race and sex:
Admissions test score quintile
GPA quintile
Family income range
Pell Grant eligibility
Parental education
It will also ask for information to be broken down for early decision, early action, and regular admission as well as institutional need-based aid and merit aid. What’s missing? Legacy status and athletic recruits, both categories that benefit white applicants. At some of the Ivies, between 10 and 20 percent of the undergraduates are recruited athletes, many in “country club” sports where most of the competitors are wealthy and white, and the proportion of athletes is even higher at the highly selective liberal arts colleges that make up the New England Small College Athletic Conference. Discovery in SFFA v. Harvard revealed that recruited athletes had an 86 percent admit rate. You don’t have to have had an uncle who taught at MIT to know that is substantially higher than the overall admit rate.
ACTS will apparently apply only to “all four-year institutions who utilize selective college admissions,” which the administration maintains “have an elevated risk of noncompliance with the civil rights laws.” That may at first glance seem to be singling out elite, “name” colleges, and that’s probably the intent, but it also reflects a recognition that the vast majority of institutions couldn’t practice race-based admission even if they wanted to because they are too busy filling the class to worry about crafting the class.
The focus on selective institutions will both make it easy to score political points and hard to derive meaning from the data. Selectivity, especially at the 5-10 percent level, makes it impossible to know why any individual is or isn’t admitted. Admission deans at the highly-selective (or rejective) universities report that they could fill several additional freshman classes from among those applicants who have been waitlisted or denied.
Merit-Based Admission
The real target of the push for “merit-based” admission may be holistic review. A holistic admission process allows colleges to take into consideration nuances in an individual’s background and life experiences. It can also be frustrating for applicants, since different individuals are admitted for different reasons. The government may be pushing consciously or unconsciously for a more formulaic selection process.
But would that be any better? Even if you focus only on grades and test scores, should you put more weight on a three-hour test or on four years of high school? How do you compare applicants from schools with different grading scales and levels of academic rigor? Should a test score obtained after thousands of dollars in test prep count the same as an identical score without coaching?
How do we distinguish between merit and privilege? Those who have strong test scores may be more likely to believe that test scores are a measure of merit, and yet test scores are strongly correlated with family income. Those who are born into wealth and privilege may come to believe that their good fortune is a proxy for merit, buying into a perverse and self-serving interpretation of John Calvin’s doctrine of the elect. They may see themselves as deserving rather than lucky.
Proxies in Admission
We need a larger discussion about proxies in college admission. Advanced Placement courses are a proxy for a rigorous curriculum. GPA is a proxy for academic accomplishment, and yet means little without understanding context. Similarly, SAT scores are often seen as a proxy for ability, despite the fact that the College Board long ago abandoned the pretense that the SAT measures “aptitude.” The U.S. News college rankings have always relied on proxies, such as alumni giving as a proxy for alumni satisfaction when it may be more a measure of the effectiveness of the development office. Selectivity is a proxy for academic quality, feeding into the belief that the harder a place is to get in, the better it must be. Are proxies for race any more problematic than these other proxies?
The larger question here is what should the selective college admission process be a proxy for. Should we seek to reward students for past performance? Predict who will earn the best grades in college? Identify those students who will benefit the most from the college experience? Or predict who will make the greatest contribution to society after college?
I’m waiting for an executive order or memo or even a discussion among college admission professionals about what the selective admission process should represent and what proxies will support those goals.