Understanding

Holistic Review in
Higher Education
Admissions
Guiding Principles and Model Illustrations

Arthur L. Coleman
Jamie Lewis Keith
Executive Summary
Individualized holistic review is a cornerstone of admissions among institutions with varying
levels of selectivity. Despite the remarkable variability among institution types—with respect
to mission, setting, and more—key points of effective practice continue to guide the field.

Individualized holistic review optimally reflects three common characteristics:

§§ Mission alignment, which is focused on advancing the institution’s core educational

goals through the admissions process.

§§ A two-part inquiry regarding applicants: attention to their likely ability to succeed and
thrive at a given institution and attention to their ability to enhance the educational
experiences of their peers in and out of the classroom.

§§ Consideration of multiple, often intersecting, factors—academic, nonacademic,

and contextual—that, in combination, uniquely define and reflect accomplishments
and potential contributions of each applicant in light of his or her background and
circumstances.

Additionally, such practices are most effective when they are part of a comprehensive,
coordinated enrollment management process, including outreach and recruitment, financial
aid and scholarships, capacity building (including first-year transitions), and curricular and
cocurricular alignment.

The processes associated with individualized holistic review should reflect:

§§ Integrity, with a focus on rigor, consistency, and fairness when applying valid criteria
in selection, which should include multiple reviews, clear protocols, calibration, and
ongoing professional development for enrollment staff and application readers.

§§ A process of continuous improvement that involves a periodic evaluation of success in

light of all relevant evidence inclusive of institutional goals, changing circumstances, and
resource capacity issues.

Additionally, engagement with leaders throughout the institution on key policy and practice
issues is a hallmark of success of holistic review in admissions.

Finally, appropriate transparency with proactive, collaborative, and sustained

communications and engagement efforts with both internal and external audiences is a key
element of holistic admission and is essential in engendering stakeholder and public trust.
Contents
2 Foreword

4 Part One: Key Features and Elements of

Individualized Holistic Review
4 I. Introduction and Overview
5 II. Key Elements
5 A. Mission Alignment
6 B. A Focus on an Applicant’s Likely Success and
Contribution to the School Community
6 C. Many Factors That Shape the Admission Decision
11 III. Alignment and Coherence Within the Institution

12 Part Two: Process Management: Integrity and Accountability

for Individualized Holistic Review
12 I. Introduction and Overview
12 II. Key Elements
12 A. Rigor, Consistency, and Fairness
15 B. Development and Periodic Evaluation of Evidence Regarding
Relative Success as a Foundation for Continuous Improvement
16 III. Engaged Leadership

17 Conclusion
18 Appendix A: Principal Resources
20 Appendix B: Federal Nondiscrimination Law in a Nutshell
22 Appendix C: Admissions Protocols
23 Appendix D: The College Board’s Access & Diversity Collaborative
26 About the College Board and About EducationCounsel

1
Foreword
Few topics in higher education generate the sustained Grounded in a robust body of research, experience, and
attention that surrounds questions about student law, we have written this guide to provide admissions
admissions, particularly when matters of diversity are professionals and their campus partners with evidence-
present. For decades, as policies and practices have based practical insight into the practice of admissions.
evolved to keep pace with evolving institutional identities Our principal goal is to help explain the values, logic, and
and missions and changing demographics, the question rigor that drive effective admissions practices associated
of “who gets admitted” has been center stage. Press and with a multifactored holistic review. In our view, there is a
social media headlines, voter initiatives, and court rulings need to recognize both the unique practices among higher
all contribute questions and opinions about admissions. education institutions, as well as the underlying common
Unfortunately, much of the rhetoric that has shaped public framework that the specific practices rely on. And, along the
perception has been, at best, ill-informed; and at worst, the way, we think it is critical to acknowledge that the process of
product of ideology divorced from institutional goals, the admissions remains one not of perfection, but of rationality
complexities of institutional context, and evidence-informed and fairness, grounded in a commitment to continuous
deliberation. Thus, the myths of a “black box” associated improvement.2
with admissions and holistic decision-making persist and
serve no one well. To achieve these aims, this guide addresses two sets of
issues central to success for admissions practitioners:
Properly understood, the admissions process of institutions
§§ To answer the question of “just what is individualized
with any degree of selectivity is central to their identity—the
holistic review,” Part One explains key features
class of applicants they admit is a manifestation of who they
and elements of the practice. While recognizing
are.1 The principles, aspirations, and judgments of education
the strength of myriad designs reflecting the wide
leaders about excellence in education are inextricably
range of institutions in American higher education, it
linked with the composition and climate of their student
provides baseline information regarding the practice,
communities. Despite the vast variability of postsecondary
amplified with an articulation of some key elements
institutions and their admission policies, many of the
generally associated with effective holistic review and
fundamentals are shared and consistent.
illustrations.

§§ Part Two addresses the question of how to advance

holistic review goals as a matter of process and process
management. It offers an overview of key protocols
and procedural steps, including examples of the kind of
rigor associated with well-designed and well-executed
admissions policies for integrity and accountability.

1. See also Gretchen W. Rigol, Admissions Decision-Making Models 2. This guide focuses on institutions that use holistic review in
(College Board, 2003), at 5–7, available at https://research. admissions. It also may be helpful to those institutions with open
collegeboard.org/publications/content/2012/05/admissions- admissions policies, where students who satisfy publicized course
decision-making-models-how-us-institutions-higher-education. and grade prerequisites are automatically admitted. The principles
discussed here can be adapted to practices such as financial aid or
 Not all institutions of higher education conduct holistic review in those involving participation in experiential learning opportunities.
their admission process. For instance, in “open access” admissions,
finite, objective criteria (e.g., specific course prerequisites, grades
achieved, and the like) may alone determine whether a student
matriculates. Open access admission fulfills the mission of many
institutions, particularly certain state or community colleges whose
purpose is strongly focused on serving local residents.

2
In concluding this guide, we renew a challenge for the entire Second, for four decades, the federal courts have helped
higher education community to think differently about shape policy and practice, particularly where institutional
communications—to fully own and relay the importance of interests in student diversity associated with race and
professional judgment as part of the admissions process, ethnicity have been concerned. The weighty precedent of
and to more forcefully reject misguided notions that 40 years of Supreme Court nondiscrimination decisions that
mechanics trump human judgment. set forth core principles, frameworks, and kinds of evidence
required to justify consideration of race are important to
Throughout this guide, we offer important general principles, reflect in any resource of this type.3
bolstered with examples that can inform each institution in
ways that will best serve its mission. To be very clear: This Finally, we are grateful for the insight and wisdom shared
guide isn’t intended to prescribe a limited number of ways by many in the production of this guide. In particular, our
for holistic review to be effective and legally sustainable. colleagues, who provide support to the College Board’s
Access & Diversity Collaborative, have contributed in
Important empirical foundations shape this guide. significant ways to its design and substance.4 Indeed, the
wisdom reflected here is theirs, not ours.5 We merely had
First, decades of experience in the field, which have been the privilege of attempting to channel their passions and
subject of much study and evaluation, provide key baselines perspectives. Any errors in representing this highly complex
for this guide. Over time, as policies and practices have landscape are ours alone.
evolved, lessons have been learned—from successes and
from setbacks. We attempt to embed those lessons as part of Art Coleman
this resource—many shared by our colleagues in the field. Jamie Lewis Keith
November 2018

3. Court rulings and federal agency policy have continuously review in conclusions regarding the educational benefits of
affirmed that the compelling educational benefits for all students diversity in undergraduate admissions). See also Parents Involved
associated with student diversity can support appropriately in Community Schools v. Seattle School Dist. No. 1, 551 U.S. 701
designed and justified policies that reflect considerations of race (2007) (recognition in dicta by all nine Justices that the educational
and ethnicity. See, e.g., University of California Regents v. Bakke, benefits of diversity have been recognized by the Court as a
438 U.S. 265 (1978) (Powell, J.) (benefits of broad diversity in compelling interest in higher education that can support the
medical school); Grutter v. Bollinger, 539 U.S. 306 (2003) (benefits consideration of race in admissions).
of diversity justify individualized holistic review involving the
consideration of race and ethnicity in law school); Gratz v. Bollinger, 4. For additional information on the College Board’s Access &
539 U.S. 244 (2003) (grounding decision in recognition of the Diversity Collaborative, see Appendix D.
educational benefits of diversity in the undergraduate student 5. We are particularly grateful for the idea-generating research and
body and against mechanical consideration of race); Fisher v. Univ. editorial assistance of David Dixon and Emily Webb. We are also
of Texas at Austin, 570 U.S. ___ (2013) (recognizing the compelling very appreciative of the valuable feedback and thought-provoking
interest in educational benefits of diversity as a foundation for insight provided by external reviewers including David Hawkins,
discussion of strict scrutiny of race-conscious practices); Fisher Jerry Lucido, Rachelle Hernandez, and Frank Trinity, as well as
v. Univ. of Texas at Austin, 579 U.S. ___ (2016) (grounding decision Connie Betterton and Wendell Hall from The College Board.
upholding consideration of race and ethnicity as part of holistic

3
PART ONE

Key Features and Elements of

Individualized Holistic Review
Second, holistic review typically reflects a duality of
“It is the business of a university to provide that institutional aims centered on judgments about particular
atmosphere which is most conducive to speculation, students’ likely ability to succeed and thrive at a given
experiment and creation. It is an atmosphere in institution and, as importantly, a student’s potential to
which there prevails ‘the … essential freedom’… contribute to the teaching and learning experience of their
to determine … who may be admitted to study.” peers and ultimately to affect contributions of the institution
—JUSTICE FELIX FRANKFURTER, SWEEZY V. NEW HAMPSHIRE (1957) to society.

Third, to attain these aims, holistic review involves

consideration of multiple, intersecting factors—
I. Introduction and Overview academic, nonacademic, and contextual—that enter
Individualized holistic review is a cornerstone of admissions the mix and uniquely combine to define each individual
among institutions with varying levels of selectivity, applicant. A robust consideration of quantitative and
embodying a rigorous evidence-based and data-informed qualitative factors, all considered in context of the
exercise in expert human judgment that seeks to attain applicant’s background and circumstances—and how they
particular institutional goals. Broadly speaking, it is a relate to one another in a particular applicant’s profile—
“flexible, highly individualized process by which balanced shape admission decisions.
consideration is given to the multiple ways in which With these key elements present, holistic review will
applicants may prepare for and demonstrate suitability” as most likely achieve its aims if it is integrated as part of the
students at a particular institution.6 And, although no single institution’s overall enrollment strategy, with connectivity
definition can fully capture the legitimate variability among among outreach, recruitment, admissions, and aid policies
colleges and universities that manifest varied missions and practices; and its design reflects the strengths and needs
and admissions aims, the policy and practice landscape associated with the educational experience, curricular and
(informed by guiding federal court decisions) provide insight cocurricular, of the students who are admitted.
into key elements typical of effective practices.

First, holistic review is mission aligned, meaning that the

unique history, character, aims, vision, and educational and
societal contributions of an institution set a critical stage for
decision-making in admissions.

6. Association of American Medical Colleges, Roadmap to Diversity:

Integrating Holistic Review Principles into Medical School
Admission Processes (AAMC, 2010), at 5, available at
https://www.aamc.org/initiatives/holisticreview/resources/.

4
II. Key Elements other statements of institutional vision/direction a clear set
of goals and objectives, and the underlying rationales that
A. MISSION ALIGNMENT support those aims. It is also important to be explicit about
the relevance and importance of student body diversity to
Higher education mission and related policy statements achieving such goals, with implications for the selection of
reflect the educational aims, and educational and societal entering students.8
roles central to an institution’s investment and action. As an
institution’s “formal, public declaration of its purposes and In schools large and small, urban and rural, research, private,
its vision of excellence,” mission statements, or other policy public, and land grant (and more), admission decisions are
statements expressing important aims and character of the grounded in the unique history, character, aims, and vision that
institution (whatever their label), are “the necessary condition define an institution. Moreover, differences within institutions—
for many different individuals to pull together through a between undergraduate and graduate/professional programs,
myriad of activities to achieve central shared purposes.”7 and among schools within undergraduate institutions, for
Well-developed mission and policy statements—particularly instance—also have distinct goals that affect admission.9 What
when institutional mission statements are carried forward works for one institution (or department or professional school
to aligned department and unit statements—can have within an institution) in light of its mission and processes won’t
operational effects. They provide important clarity to inform necessarily work for another.10
decision-making among all actors toward the excellence the “There are almost as many different approaches to selection
institution seeks, establishing coherence, alignment, and as there are institutions.”11 Institutions routinely adapt a
synergies among various units, schools, and departments holistic review to make it their own, as a natural extension
within individual institutions. Mission statements are typically of their institutional mission and a tool to achieve the
broad, so it is important to derive from mission statements or institution’s educational and societal goals.12

7. Jerry Gaff and Jack Meacham, Learning Goals in Mission from college to college within [North Carolina State] University.
Statements: Implications for Educational Leadership, 92 Liberal OCR considered that some colleges are less in demand than
Education (Association of American Colleges and Universities, others and that virtually all who apply to those colleges are
2006), https://www.aacu.org/publications-research/periodicals/ admitted. On the other hand, some colleges and programs within
learning-goals-mission-statements-implications-educational. those colleges are very popular with applicants. Within those
(To ensure that a mission statement is effective as a driver of selective colleges, the procedures and factors considered in
institutional goals, it’s important to involve a range of stakeholders in deciding whether to grant or deny admission to students who do
its development, and that the mission statement be endorsed by the not automatically qualify under the presumptive admit criteria
governing board and communicated broadly across the institution.) vary. Consequently, diversity factors such as race also receive
different emphasis. For example, a representative from the
8. AAMC, supra 6, at 5. College of Management stressed the importance of preparing
In a 2003 survey, the National Association for College Admission students to work in a global marketplace, including international
Counseling (NACAC) identified the strong interest that institutions settings, and placed greater emphasis on diversity factors
of higher education have in broad student body diversity that than the College of Design, where students’ demonstrated
includes but isn’t limited to race and ethnicity, including geography, design or artistic talents are of nearly exclusive importance.
socioeconomic status, gender, age, religion, first-generation … Representatives from the College of Engineering and the
students, international students, and special talents. This College of Management indicated that they consider applicants’
connection of mission to a broad diversity interest is captured in the contributions to diversity, including race, life experiences, rural
amicus brief of the College Board in which the American Association background, international experiences, and family background.”
of College Registrars and Admissions Officers (AACRAO), the Law 10. Specific considerations that drive admission judgments typically
School Admission Council (LSAC), and NACAC joined, “To continue include the institution’s unique roles, mission characteristics
as academic, economic, and civic engines for excellence, colleges and goals, academic approach and philosophy, nonacademic
and universities must be able to define and pursue their education programs, financial resources, and the likely “yield” of admitted
missions and education goals, within appropriate parameters. students, to name a few. Jerome A. Lucido, “How Admission
Admitting classes of students who are best able to contribute and Decisions Get Made,” in Handbook of Strategic Enrollment
succeed is a vital exercise of institutional identity and autonomy Management, 147–173 (2015) at 147-49; Melissa Clinedinst, State
because mission is achieved through the student bodies that of College Admission (National Association for College Admission
institutions admit and educate.” See Brief for the College Board, et Counseling, 2015) at 31, available at http://www.nxtbook.com/
al. as Amici Curiae Supporting Respondents, Fisher v. University ygsreprints/NACAC/2014SoCA_nxtbk/.
of Texas at Austin, 579 US _ (2016) (no.14-981), available at http://
educationcounsel.com/?publication=fisher-v-university-of-texas-u- 11. Rigol, supra 1.
s-supreme-court-amicus-brief-2015).
12. For example, Princeton Univ., Compl. No. 02-08- 6002
9. See for example, North Carolina State University, Compl. 11-04- (U.S. Dep’t of Educ. Sept. 9, 2015) (compliance resolution),
2009 (U.S. Department of Education, November 27, 2012) (letter available at https://www2.ed.gov/about/offices/list/ocr/docs/
of resolution), available at https://www2.ed.gov/about/offices/list/ investigations/02086002-a.pdf; Rice Univ., Compl. No. 06-05-
ocr/docs/investigations/11042009-a.pdf. The letter of resolution 2020 (U.S. Department of Education, Sept. 10, 2013) (compliance
of the U.S. Department of Education Office for Civil Rights stated: resolution), available at http://www.ed.gov/about/offices/list/ocr/
“The manner in which race may be taken into account varies docs/investigations/06052020-a.html (last modified Jan. 14, 2015).

5
Because institutions realize their mission-oriented goals Admissions committee members and screeners can
through the wide range of intellectual and personal contribute to shaping the diverse class the institution seeks
experiences and pursuits of their students, they take great by giving thoughtful consideration to each applicant’s
care as they create entering classes. Although mission, portfolio. They can do this by assessing how each
resource limitations, and sometimes state constitutional and applicant may contribute to, and benefit from, the learning
legislative charters influence admissions policies and goals, environment of the institutions. … Ultimately, the committee
the goal of providing all students opportunities to engage must think about the range of criteria it needs in a class,
in and out of the classroom with a diverse community not just in individual applicants, to achieve the institution’s
of peers is broadly recognized as a critical element of mission and goals … One responsibility of the committee,
excellence in higher education. As then-president Shirley then, is to weight and balance these different factors when
Tilghman explained to Princeton’s class of 2009 on their screening, interviewing, and selecting applicants.16
first day, “Never again will you live with a group of peers
that was expressly assembled to expand your horizons and C. MANY FACTORS THAT SHAPE
open your eyes to the fascinating richness of the human THE ADMISSION DECISION
condition.”13
The examination of student qualifications includes
a myriad of factors. To be sure, detailed applications
B. A FOCUS ON AN APPLICANT’S LIKELY
submitted by students include transcripts, high school
SUCCESS AND CONTRIBUTION TO THE
profiles, standardized test scores, essays, and letters of
SCHOOL COMMUNITY
recommendation. But, academic factors represent only one
In light of an applicant’s accomplishments, talents, dimension of qualification and, therefore, of the ultimate
experiences, and potential to succeed, as well as his or decision to admit. For example, considering the context
her potential to contribute to the institution’s community,14 in which the achievement took place is also important, as
the universally defining feature of holistic review is its are personal qualities such as creativity, determination,
flexible framework that allows for the institution-specific teamwork, intercultural competence, and ethical behavior.17
consideration of a range of intersecting factors. As
reflected here, “merit” for admission is not limited to any
“Intangible qualities are often apparent only when
one factor and cannot be determined out of context of the
an applicant is given the opportunity to express
barriers, advantages, and experiences in each applicant’s
his or her own personal story. The quality of our
life journey. Flexibility to consider intersecting factors
students would be immeasurably poorer if we were
allows the institution to make individualized admissions
to select them ‘only on the numbers.’… [A]lso,
decisions informed through a “dual lens”—those centered
our pedagogical responsibility as educators is to
on the applicant and those reflecting broader institutional
select an entering class which, when assembled
interests.15 The potential of students to contribute to the
together, will produce the best possible educational
learning experience of their peers is a vital element in
experience for our students.”
holistic review. As the American Association of Medical
—POST AND MINOW AMICUS BRIEF IN FISHER II DESCRIBING
Colleges has explained:
HARVARD AND YALE LAW SCHOOL POLICIES

13. Princeton Univ., Compl. No. 02-08-6002, supra 12. 15. Arthur L. Coleman, et al., A Diversity Action Blueprint: Policy
Parameters and Model Practices for Higher Education Institutions
14. See for example, Brief for Amherst Coll. et al. as Amici Curiae (College Board, 2010), at 15.
Supporting Respondents, Gratz v. Bollinger, 539. U.S. 244 (No.
02-516), Grutter v. Bollinger, 539 U.S. 309 (No. 02-241) at 9–12 16. AAMC, supra 6, at 13. Not all students are equally able to contribute
(discussing the range of factors considered by small, highly selective to the educational experience of their peers.
schools and identifying 12 categories of factors relied upon by
Amherst in its quest to “assess each student’s likely success and 17. Lucido, supra, at 156–157.
contribution”); Brief for Carnegie Mellon Univ. et al. as Amici Curiae
Supporting Respondents, Gratz v. Bollinger, 539. U.S. 244 (No. 02-
516), Grutter v. Bollinger, 539 U.S. 309 (No. 02-241) at 4a–5a.

6
Criteria generally fall into two overarching categories In considering and weighing grade point average (GPA) and
aimed at creating a comprehensive understanding of each class rank, institutions typically consider:
applicant’s suitability for admission, each understood in the
§ A student’s grade trajectory during his or her secondary
context of the applicant’s life story and opportunities (or
education as well as the final average;
lack thereof): (1) academic accomplishment and promise
(not always the same criterion), and (2) personal attributes. § Knowledge of the rigor and quality of the high school’s
educational program, including a high school’s
ACADEMIC CRITERIA, APPROPRIATELY reputation for grade inflation or deflation, and the
WEIGHTED IN RELATION TO MISSION difficulty and load of courses taken; and

Academic accomplishment and preparation are usually § Whether AP®/IB/honors courses were available and
evaluated based on high school curriculum, grade point taken, among other special circumstances.
average (overall and in particular courses relevant to
An academic index of some kind is often calculated based
proposed major and program rigor), class rank, and
on these quantitative data, calibrated in light of relevant
standardized test scores, and/or other performance
context. In addition to standardized test scores and class
assessments (e.g., products of academic and creative
rank,18 GPA is considered, either taken at face value from
endeavors). Intellectual capability and promise require
the transcript or restated after calibration to reflect the
a more nuanced assessment, considering quantitative
rigor of the high school academic program and grading.
measures, grade trends, and some understanding of an
A good practice is to base the weight of each component
applicant’s opportunities and barriers relative to the context
within the overall academic index score on evidence-based
of their high school. The weight given to these quantitative
predictions of college GPA, using data on the performance
academic measures should produce the outcomes sought
of enrolled students.19 Although not a uniform or necessary
by the institution to achieve its mission. (That assessment
practice at all institutions, some institutions establish a
should involve consideration of whether a student has
minimum threshold or guideline for an overall academic
taken maximum advantage of the opportunities available to
index score, below which the institution determines it is
them, recognizing that not all students attend schools that
unlikely a student can successfully complete the academic
provide the same opportunities.) Even for highly selective
work. Others conduct predictive success modeling on a
institutions, weighing these measures with an overreliance
highly individualized basis, considering the entire profile
on the effect on national rankings can undermine other
of each student; some combine minimum thresholds with
mission-critical goals.
individualized assessment. Among selective institutions, the
number of applicants who are able to do the work exceeds
the spaces available in a class, with that number typically
increasing as selectivity increases.20

18. Standardized test scores have value when used with other indicia, at 20–21 and 44, 45 (“the use of standardized-test scores as the
but alone they aren’t a good measure of success in college or sole measure of merit is scientifically indefensible and the claim
of merit for college admissions. See Steering Committee for the that a higher score should guarantee admission over another is not
Workshop on Higher Education Admissions, Myths and Tradeoffs: justifiable on empirical grounds”).
The Role of Tests in Undergraduate Admissions (Alexandra S. Beatty,
Robert L. Linn, and M. R. C. Greenwood eds., 1999); Guidelines on 19. Rigol, supra 1, at 15.
the Uses of College Board Test Scores and Related Data (College 20. Brief for Massachusetts Institute of Technology, Leland Stanford
Board, 2011); Brief for Massachusetts Institute of Technology, Junior University, E. I. du Pont de Nemours and Company,
Leland Stanford Junior University, E. I. du Pont de Nemours and International Business Machine Corp., National Academy of
Company, International Business Machine Corp., National Academy Sciences, National Academy of Engineering, and National Action
of Sciences, National Academy of Engineering, and National Council for Minorities in Engineering, Inc. as Amicus Curiae
Action Council for Minorities in Engineering, Inc. as Amicus Curiae Supporting Respondents, Grutter v. Bollinger 539 U.S. 306 (2003)
Supporting Respondents, Grutter v. Bollinger 539 U.S. 306 (2003) (no. 02-241) and Gratz v. Bollinger 539 U.S. 244 (2003) (no. 02-516).
(no. 02-241) and Gratz v. Bollinger 539 U.S. 244 (2003) (no. 02-516)

7
PERSONAL CRITERIA CONTEXT
Personal attributes and accomplishments are also Students are often considered both on the face value of
considered to better understand an applicant’s promise their achievements and the barriers they scaled or on the
and capacity to benefit from and contribute to the manner in which they took advantage of the opportunities
institution’s educational program and overall mission. While presented to them. As one noted expert has opined: “Given
baseline academic data may establish minimum ability and unequal educational opportunity, it is incumbent upon
preparation for success, whether an individual contributes admission [officers] to strive to understand the conditions
significantly to the institution’s educational goals and under which each applicant has performed and to make
actually succeeds—both in the academic program and in judgments based on the context of those conditions.”21
fulfilling other aspects of the institution’s mission—may Moreover, “[n]umbers without context say little about
depend to a significant extent on whether they exhibit character. They do not reveal the drive or determination
desirable personal qualities evaluated in the process. to become a leader or to use the advantages of one’s
education to give back to society.”22 As Pomona College
Personal criteria may include:
has explained, “We have different expectations for different
§ Quality of leadership; students: the exam scores from a daughter of two college
professors are viewed in a different context than the scores
§ Record, authenticity, and depth of contributions
from a first-generation college student who attends an
to community;
underfunded high school.”23
§ Commitment to inclusion and helping others
scale barriers;

§ Demonstrated intellectual curiosity and creativity;

§ Special talents (e.g., musical, athletic);

§ Life experiences, lessons learned, opportunities

received, and whether they were used to
maximum impact;

§ Socioeconomic status;

§ Burdensome job and family responsibilities balanced

with school demands;

§ Geographical context; and

§ Experience associated with one’s own and others’ race,

ethnicity, gender, etc.

21. Lucido, supra, at 157. 23. Brief for Amherst College, et al. supporting respondents,
p. 14, Fisher v. Univ. of Texas at Austin et al., 579 U.S. ___ (2016).
22. Brief of Dean Robert Post and Dean Martha Minow as Amici Curiae in See also description of Princeton University admissions
Support of Respondents, in Fisher v. University of Texas at Austin et policy in Princeton Univ., Compl. No. 02-08- 6002 (U.S.
al. 579 U.S. _ (2016) (no. 14-981), at http://www.scotusblog.com/wp- Department of Education Sept. 9, 2015) (compliance resolution),
content/uploads/2015/11/14-981_amicus_resp_DeanRobertPost available at https://www2.ed.gov/about/offices/list/ocr/docs/
.authcheckdam.pdf. investigations/02086002-a.pdf. (University admissions staff
reviewed applicants in the context of their secondary school in
order to compare their accomplishments given the resources
available to those of applicants from similar settings.)

8
The College Board’s Admissions Models Project
The College Board’s landmark Admissions race than self, civic awareness, concern
Models Project, the product of summits of for others, creativity, determination/grit,
admissions deans in 1998 and 1999, identified evidence of persistence, maturity)
nearly 30 academic factors and almost 70
§ Extracurricular activities, service, and
nonacademic factors, including:
leadership (e.g., awards and honors,
Academic Achievement, Quality, and Potential community service, work experience)

§ Direct Measures (e.g., class rank, core § Extenuating circumstances (e.g., family
curriculum grades, test scores) problems, health challenges, frequent
moves, responsibility for raising a family)
§ Caliber of High School (e.g., average
SAT® scores, competitiveness of class, A series of recent case studies conducted by the
percentage attending four-year colleges) College Board builds on this body of work with
the following observations:
§ Evaluative Measures (e.g., artistic talent,
evidence of academic passion, intellectual § “High school and student contextual
curiosity, grasp of world events) factors play a more important role than
other nonacademic factors in the review
Nonacademic Characteristics and Attributes
processes at our case study sites.”
§ Geographic background (e.g., academically
§ “The importance of nonacademic factors in
disadvantaged school, economically
college admissions, which are associated
disadvantaged region, from far away, school
with institutional type and selectivity, varies
with few or no previous applicants)
widely.”
§ Personal background and attributes
§ “Beyond academic and contextual factors,
to understand the full context of each
the additional types of nonacademic
individual’s life and potential to benefit
factors that are most frequently used
and contribute (e.g., cultural diversity, first
are performance factors and attitudinal
generation to go to college from family,
constructs.”
personal disadvantage, societal experience
as and self-determined identity as a member
of an underrepresented minority group
or with individuals who are of a different

Sources: Gretchen W. Rigol, Admissions Decision-making Diversity: Integrating Holistic Review Principles into Medical
Models (College Board, 2003), at Appendix D https:// School Admission Processes (AAMC, 2010), at 9-10,
research.collegeboard.org/publications/content/2012/05/ available at https://www.aamc.org/initiatives/holisticreview/
admissions-decision-making-models-how-us-institutions- resources/ (describing an “Experiences, Attributes, and
higher-education. More recent studies affirm these Metrics” model recommended for individual medical school
conclusions. See for example, Lorelle Espinosa, Matthew policy development, with a collection of 26 factors that may
Gaertner, and Gary Orfield, Race, Class, and College Access: be considered); and College Board, Insight into Nonacademic
Achieving Diversity in a Shifting Legal Landscape (American Factors and Practice, Future Admissions Tools and Models
Council on Education, 2015) at 31-32, available at https:// Initiative (College Board, 2018), at https://professionals.
www.acenet.edu/news-room/Documents/Race-Class- collegeboard.org/higher-ed/future-admissions-tools-
and-College-Access-Achieving-Diversity-in-a-Shifting- and-models-initiative. See also Jerome A. Lucido, “How
Legal-Landscape.pdf (reporting results of undergraduate Admissions Decisions Get Made,” in Handbook of Strategic
admissions survey inquiring about 19 admission factors); Enrollment Management 147-173 (2015) at 151-156.
American Association of Medical Colleges, Roadmap to
THE INTERSECTIONALITY OF MULTIPLE FACTORS The approach outlined here—with multiple, intersecting
AS A KEY FACET OF DECISION-MAKING factors shaping professional judgment about whom
to admit—is highly relevant to institutional efforts to
Importantly, various factors considered by admissions
assure the admission of an appropriately diverse class
officers to advance institutional interests intersect or
of students, both as a matter of policy and as a matter
inform others, and they are not weighted separately or
of federal law. (Indeed, the clear, authentic extension of
evaluated in isolation. For example, factors like character
holistic review principles to obtain beneficial educational
and perseverance are assessed based on multiple elements
experiences for all students is essential under prevailing
of an application.24 New measures pursued by some
federal nondiscrimination laws when race and ethnicity are
institutions further add depth to the traditional file, including
considered.)
assessments of “noncognitive” abilities.25
What does this mean? Concretely, and as a matter of
Moreover, background qualifications and personal
good policy design and legal compliance, it means that
information also aren’t considered in isolation. For
the effective application of holistic review principles
example, a student who took one AP course at his or her
to considerations of race and ethnicity is not single-
elite, urban high school with dozens of AP options might
factor focused and requires that the decisions involving
well be considered differently than a student who took
those factors are not overly mechanical or formulaic.26
the only AP class available at his or her rural or under-
Consideration of such factors should not reflect adoption
resourced school or produced an exceptional project on
of quotas, a “thumb on the scale,” or other types of
a complex issue in a school with no AP courses. Similarly,
categorical classifications.
a U.S.-born student who did not work during high school
and participated in international service ventures during Rather, as recognized by the Association of American
summers, funded by parents, may be acknowledged for Medical Colleges, race should be “considered flexibly as just
commitment to others, as well as travel, and possibly even one of the many characteristics and pertinent elements of
multicultural, interests. However, that student might be seen each individual’s background. Characteristics that make an
differently than a U.S.-born student who had to work after individual particularly well suited for the medical profession,
school due to family responsibilities and couldn’t travel, such as resilience or the ability to overcome challenges,
but was able to demonstrate an even greater dedication may in some cases be intertwined with an individual’s
to help others in need and a multicultural commitment race or ethnicity. When candidates have overcome great
through strong, sustained, and mature actions to guide race-related challenges, obscuring or denying the realities
younger siblings and help immigrant families in their church of these challenges will hinder a full appreciation of their
community. Differences may be weighed as equivalent in potential contributions.”27
accomplishment (or not) depending on the context.

24. See for example, Michelle Sandlin, “The ‘Insight Resume:’ Oregon 26. Gratz v. Bollinger, 539 U.S. 244 (2003) (Striking down as
State University’s Approach to Holistic Assessment,” in College unconstitutional the automatic and mechanical assignment of
Admissions Officer’s Guide (Barbara Lauren ed., 2008) at 99–108 points to a student on the basis of race).
(describing Oregon State University’s application process that
requires answers to six questions designed to measure eight 27. Brief for Association of American Medical Colleges et al. as
“noncognitive variables” as part of its unique holistic review Amicus Curiae Supporting Respondents, in Fisher v. University
process); Brief for Amherst College, et al., supra 14, at 9–12. of Texas at Austin et al. (“Fisher II”) 579 U.S. ___ (2016)
(no. 14-981) at 26. https://www.aamc.org/download/447744/data/
25. See William E. Sedlacek, “Noncognitive Measures for Higher aamcfilesamicusbriefinfishervutaustin.pdf
Education Admissions,” in International Encyclopedia of Education,
845 (Penelope Peterson, et al., eds., 3rd ed., 2010), and portfolios of
academic work starting in ninth grade, e.g., Press Release, Coalition
for Access, Affordability, and Success, Diverse Group of Universities
Form Coalition to Improve College Admission Process (Sept. 28,
2015), at 14, available at http://www.coalitionforcollegeaccess.org/
press-release.pdf; Lucido, supra, at 151–56; Rigol, supra 1, at 19–20.

10
The intersectionality of contextual background factors III. Alignment and Coherence
reflected here has, in fact, been a hallmark of U.S. Supreme
Court decisions that have affirmed the limited consideration
Within the Institution
of race or ethnicity in admissions. In its most recent Ultimately, well-designed holistic review admissions
pronouncement, in Fisher v. University of Texas [Fisher II], processes are most often part of a comprehensive,
the Supreme Court upheld the University of Texas’s (UT) coordinated enrollment management process that includes
consideration of a student’s race or ethnicity as part of the recruitment and outreach, financial aid and scholarships,
holistic review process, which was at all times contextual. and transition to the first year (e.g., registration, orientation,
Under UT’s policy, all background qualities and characteristics first-year experiences). Correspondingly, they are also
of a given applicant were considered in light of all other aligned with curricular, cocurricular, and experiential
qualities and characteristics. As a consequence, UT could not learning, mentoring, and community-building programs.
“provide even a single example of an instance in which race It is a good practice for all enrollment management
impacted a student’s odds of admission.”28 In fact, when asked functions to work in concert toward a specific, coherent set
if she could provide “an example [in the admissions process] of priorities and outcome-focused goals associated with the
where race would have some impact on an applicant’s personal institution’s educational and societal mission. The goal is for
achievement score,” the admissions director at UT responded: admission criteria to correlate well with all students’ success
“To be honest, not really … [I]t’s impossible to say—to give you and experiences at the institution and beyond, as reflected
an example of a particular student because it’s all contextual.”29 in positive educational outcomes including, but not limited
to, retention rates, graduation rates, campus climate, and
even alumni success and contributions to society.
Illustrations
Assembly of multidisciplinary teams, reflective of the
§ Rice University’s admission process “is an breadth of institutional knowledge and expertise, fosters this
individualized and holistic … process which alignment and coherence of process and goals, and informs
examines the entirety of an applicant’s academic policy and practice judgments.30
prowess, creativity, motivation, artistic talent,
leadership potential, and life experiences.”

§ The California Institute of Technology has

explained its process: “Instead of simply
putting your grades and test scores into a
computer to calculate admissibility, we read
every application—and every essay—to get a
sense of who you are and whether you would
be a good fit at Caltech.”

§ Williams College “seeks students with

strong intellectual skills who will benefit the
most from the education offered at Williams
and then, in turn, benefit society by filling
leadership positions in local and national life.”

§ North Carolina State University relies on a 28. Fisher v. Univ. of Texas at Austin, 579 U.S. ___ (2016), citing Appendix.
220a available at http://www.supremecourt.gov/opinions/15pdf/
holistic review of all applicants, with “each 14981_4g15.pdf (Alito, dissenting).
admission decision individual to the specific
29. Id. At UT, as elsewhere in such a flexible, individualized process,
circumstances of the applicant.” white students may also be admitted because of their contribution
to diversity. In OCR Case No. 11-04-2009, OCR found that North
Sources: See Brief of California Institute of Technology, et al. as Amici
Carolina State University favorably considered “lower scoring white
Curiae in Support of Respondents, in Fisher v. University of Texas at
applicants” who “could be admitted because of a contribution to
Austin et al. 579 U.S. _ (2016) (no. 14-981) at 12; Brief of Amherst et al.,
diversity, such as having come from a low-socioeconomic status or
Amici Curiae Supporting Respondents, in Fisher v. University of Texas
first-generation college status.”
at Austin et al. 579 U.S. _ (2016) (no. 14-981) at 12; North Carolina
State University, Compl. 11-04-2009 (U.S. Department of Education, 30. Particularly when race, ethnicity, and gender are considered as
November 27, 2012) (letter of findings), available at https://www2. factors in the process, legal counsel should be engaged in an
ed.gov/about/offices/list/ocr/docs/investigations/11042009-a.pdf. advisory role so that law-attentive design parameters can inform
and support program design and execution.

11
PART TWO

Process Management:
Integrity and Accountability for
Individualized Holistic Review
I. Introduction and Overview II. Key Elements
Despite the wide variability with respect to institutional
interests and points of focus associated with holistic review, A. RIGOR, CONSISTENCY, AND FAIRNESS
one common and critical element of effective practice Consistent application of admissions criteria is an essential
emerges across institutional type: a commitment to rigor element of a holistic review process that is both fair and
and ongoing evaluation as part of process management. effective. This doesn’t mean mechanical application of
That focus helps assure sustained integrity of admissions criteria, but rather that the same baseline criteria and
decision-making and success regarding desired outcomes. the same process should govern the review of each
At the core of a successful holistic review admissions applicant’s file—even as particular criteria may apply
program—or any admissions program—is rigor, consistency, differently in different circumstances. For example, an
and fairness. Because admissions touches so many applicant’s leadership potential may be assessed differently
stakeholders and is a foundational element of an institution’s depending on the opportunities (or lack thereof) provided
educational quality and contributions, the overall integrity of by each applicant’s high school, family circumstances,
the admissions program, as defined by consideration of valid and financial context; leadership respecting significant
criteria that are applied consistently, is essential. family obligations for one student may equate to another
student’s service as president of the student body. And,
The vital role of professional judgment in a holistic review exemplary “engineering creativity and problem-solving
process does not obviate the importance of establishing, ability” may be evidenced by a national science medal for
documenting, and reassessing over time the criteria to one student from a private prep school and by the ingenuity
be considered in making admissions decisions through of a student who is the child of migrant workers creating a
holistic review. Thus, emphasis and staff investments in solar-powered chili roaster used in the fields to cook lunch.31
the development and periodic evaluation of evidence Similarly, if race is a consideration in holistic review, it is
regarding relative success in achieving mission-aligned one of many considerations for every applicant and may
goals are essential. benefit an applicant of any race; there isn’t a separate or
Finally, institutional leaders should model integrity of the additional criterion or review track or automatic plus based
process, oversee its legitimacy in relation to goals, empower on the racial status of an individual. This aim for procedural
and appropriately resource those responsible for carrying consistency also extends to the establishing of baseline
out the process, and charter collaboration among relevant thresholds, such as bands of test scores that may trigger
functions within the institution. acceptance, rejection, or the need for further review with
prospects for admission.32

31. Brief for Massachusetts Institute of Technology, Leland Stanford chilies for lunch in the fields, may tell as much about his creative
Junior University, E. I. du Pont de Nemours and Company, engineering drive and motivation to be of service, as a national
International Business Machine Corp., National Academy of science medal does for another applicant.”)
Sciences, National Academy of Engineering, and National Action
Council for Minorities in Engineering, Inc. as Amicus Curiae 32. Reader rubrics are useful in helping assure that all readers
Supporting Respondents, Grutter v. Bollinger 539 U.S. 306 (2003) understand the values of the admissions process and how each
(no. 02-241) and Gratz v. Bollinger 539 U.S. 244 (2003)(no. 02-516). value may be evaluated. However, rather than simply adding up the
(“Thus, to take a real life example, the design and construction of a points from an admissions rubric to arrive at a decision, the rubric
solar-powered chili roaster by an applicant to meet the needs of his should instead be used to guide readers’ consistent application
community of migrant farm workers in the Texas panhandle to cook of thinking as they review applications and to queue them to
institutional values.

12
Baselines of clear, mission-driven admissions criteria Good practices for consistency in application of selection
depend on an underlying rigor and fairness in process criteria also include reader protocols, which vary by
design—which is led by professionals in the field who institution. Availability of resources, the numbers of
“bring significant experience and expertise to the decision- applications, and the selectivity of the institution factor into
making process.”33 That rigor and fairness is most often determining the application review approach that best suits
demonstrated through a process involving multiple reviews an institution’s mission.
by different admissions personnel; clear protocols for
decision-making; and ongoing professional development
and process and performance assessment that address any Common Protocols Reflective
issues of reader variability. of Good Practice
Multiple reviews and clear protocols. Integrity of the § Multiple reviews of the same application
process may be achieved differently, depending on the by multiple readers, with further review if
complexity and number of factors considered in holistic outcomes are significantly divergent;
review, as well as practical considerations such as the
§ Use of a first reader to make a
volume of applications and resource constraints. In any
recommendation on an application, and a
event, a review by well-trained professionals and staff is a
second reader to make the final decision;
hallmark of effective holistic review practices. Applications
often go through different phases of review, with a § Use of two readers whose recommendations,
“preliminary recommendation to admit, defer, or deny,”34 if the same, are final, with a third reader making
followed by further review and ultimate decision-making, the final decision if the first two disagree; and
which may be done by additional readers or a committee
§ Use of two simultaneous readers to make a
(who are sometimes “blind” to earlier reviews).35
recommendation on an application, and a third
Such reviews may include a numerical assessment on reader or committee making the final decision.
multiple ratings scales and/or decision indices, along with
Variations on these basic models exist. Appendix B
written summaries of the applicant’s accomplishments,
includes illustrations of such models.
personal characteristics, and ability to contribute to the
Sources: Gretchen W. Rigol, Admissions Decision-Making Models
college community.36 Then, after each application is
(College Board, 2003), at 40, https://research.collegeboard.org/
evaluated, anywhere from one to three times, to reach a publications/content/2012/05/admissions-decision-making-
preliminary individualized decision, admissions leaders start models-how-us-institutions-higher-education; and Gretchen W.
Rigol, Selection Through Individualized Review (College Board, 2004),
the final decision process. At this stage, the composition at 21, available at https://research.collegeboard.org/publications/
of the class and how it meets institutional goals play a content/2012/05/selection-through-individualized-review.

significant role. In the end, teams of admissions leaders and

senior managers must work through “a complex calculus”
across a broad set of considerations that include academic
quality, tuition revenue, heterogeneity in its many forms,
and support for academic and nonacademic programs.37 All
of this occurs in the context of the education and societal
outcomes sought by the institution to achieve its mission.

33. Gretchen W. Rigol, Selection Through Individualized Review 37. Brief for the College Board, AACRAO, NACAC, and LSAC as Amici
(College Board, 2004), at 17–18, 21–22, available at https://research Curiae Supporting Respondents, Fisher v. University of Texas at
.collegeboard.org/publications/content/2012/05/selection-through- Austin, 579 US _ (2016) (no.14-981) at 16–17, available at http://
individualized-review. educationcounsel.com/?publication=fisher-v-university-of-texas-
u-s-supreme-court-amicus-brief-2015.
34. Lucido, supra, at 162–163.

35. Id.

36. Id.

13
 On the Horizon: Committee-Based Evaluation
First implemented at the University of Pennsylvania in § The passenger considers student voice or
2013 in response to the ballooning application volume nonacademic factors (e.g., essays, interviews,
in college admissions, committee-based evaluation and talents).
(CBE) reflects an evolution of the traditional one-reader-
§ The two readers discuss and “contextualize the
at-a-time model, which employs two readers for the
applicant’s achievements,” write brief notes
first read. Over 30 institutions of higher education
(instead of the lengthier summaries/narratives in
have embraced CBE as part of their holistic review
the traditional model), and make a recommendation
process. The primary aims of this new evaluation
for a final third reader or committee.
model are excellence in alignment with institutional
mission, efficiency, professional development and staff CBE’s approach provides cross training when more
retention, context for evaluators, and fairness, as well as experienced and less experienced readers are paired,
reducing the effects of any implicit bias. enhances contextual knowledge when readers with
different knowledge are paired, and reduces the time in
Process
the reading process (allowing more time for outreach)
§ CBE uses two simultaneous readers, a “driver” and while deepening the understanding of applicants
a “passenger,” who sit together while focusing on through dialogue.
different aspects of the applicant. Sources: Korn, Melissa, “Some Elite Colleges Review an Application in 8
Minutes (or Less),” The Wall Street Journal (January 31, 2018), retrieved from
§ The driver is typically the geographic territory https://www.wsj.com/articles/some-elite-colleges-review-an-application-
manager—having more intimate knowledge of in-8-minutes-or-less-1517400001; “Working Smarter, Not Harder, in
Admissions: A Team-Based Approach to Initial Reviews Can Often Save Time
the high school—who reviews the applicant’s and May Allow for Better Evaluations,” The Chronicle of Higher Education
academic credentials (e.g., transcript, test scores, (March 12, 2017). retrieved from https://www.chronicle.com/article/Working-
Smarter-Not-Harder/239456?cid=cp99; Jaschik, Scott. “The New Way
recommendation, and course rigor). Colleges Review Applications,” Inside Higher Ed (June 12, 2017). retrieved
from https://www.insidehighered.com/admissions/article/2017/06/12/some-
colleges-adopt-new-committee-based-system-doing-first-review; “‘A Belief
Change’ in Admissions,” The Chronicle of Higher Education (March 12, 2017),
retrieved from http://www.chronicle.com/article/A-Belief-Change-in/239452.

Professional development and reader training. group of applications, but rather to ensure “composite
Holistic review is strengthened when the process of reliability” (consistency overall) in review by different readers
review and decision-making is carried out with integrity by of the same group of files, ratings within an acceptable
professionals in the field who have the requisite expertise, range among readers of the same file, and calibration of
ethics, and training, and whose decisions are assessed and leniency or severity of different readers.38 Specific attention
calibrated for effectiveness and consistency. to calibration of reader severity or leniency in rating
applications is important, particularly where only one reader
As part of reader calibration, “interrater reliability” may
is assigned to an application or where there is a significant
be used. The aim of interrater reliability is not for every
divergence in ratings.39
reader to have the same opinion about an application or

38. Emily J. Shaw and Glenn B. Milewski, Consistency and Reliability in the
Individualized Review of College Applicants (College Board, 2004) at 1,
available at https://files.eric.ed.gov/fulltext/ED562634.pdf.

39. Rigol, supra 34, at 21.

14
Calibration of readers may be achieved by: To sustain an effective admissions process, it is important
to establish and implement a formal, deliberative, periodic
§ Appropriately frequent meetings among readers of
evaluation of the process with the objectives of:
a cluster of applications to explore their ratings and
rationales, to identify any significant differences of § Examining and documenting outcomes in light of the
approach/valuation/opinion, and to enable policymaking institution’s mission, relevant strategic plans, and
on how the differences should be resolved;40 related admissions goals and objectives;

§ Development and continuous, experience-based § Determining the changing demographics, other

improvement of rules on how each component environmental factors, and legal landscape that
of an application (transcript, essays, letters of may portend a need to adjust goals or the means of
recommendation, etc.) will be weighted, a good practice achieving them;
for any approach to reader protocols;41 and
§ Considering staffing levels, quality and consistency of
§ Rigorous annual training prior to each admission cycle performance, as well as adequacy of training and other
or ongoing at another appropriate time to support its resources to maximize performance; and
effectiveness.
§ Determining and making any warranted changes
in goals, processes, or resources to advance the
B. DEVELOPMENT AND PERIODIC EVALUATION OF institution’s mission, make the admissions process
EVIDENCE REGARDING RELATIVE SUCCESS AS A more successful in supporting such advancement,
FOUNDATION FOR CONTINUOUS IMPROVEMENT and fulfill requirements for legal compliance.
An admissions approach is only valuable if it is successful
in advancing desired institutional mission-associated
outcomes.42 Documenting and evaluating process Illustration
design up front and as it is implemented over time, on
a periodic ongoing basis, to determine whether the Princeton University’s admission process involves
intended outcomes are being achieved and if there are any application reviews by multiple readers at multiple
unintended consequences are important in holistic review. stages. Each application is read by a “first reader”
Such documentation and evaluation “can help admission and then by a team coordinator (“second reader”),
officers and committees assess whether the school’s who then selects the most promising applications
admission process has changed or is needed, whether the for consideration by regional admission
school is genuinely using a holistic review process, and the committees and the dean or director of admission.
extent to which the policies and process are aligned with the Source: Princeton Univ., Compl. No. 02-08- 6002 (U.S.
Department of Education, Sept. 9, 2015) (compliance resolution),
institutional mission and goals.”43 available at https://www2.ed.gov/about/offices/list/ocr/docs/
investigations/02086002-a.pdf.

40. Shaw and Milewski, supra, at 4.

41. Shaw and Milewski, supra, at 2.

42. G. W. Rigol states, “it should be acknowledged that research and

evaluation are an essential part of any admissions decision-making
process. There can be many reasons why an institution has adopted
a certain approach; however, it is ultimately valid only if it produces
the desired results.” Rigol, supra 2, at 47.

43. AAMC, supra, at 23.

15
III. Engaged Leadership An institution’s board of trustees is often keenly interested
in admissions. Trustees receive inquiries from friends,
Committed, engaged, informed leadership, beginning
associates, and members of the public at the front and
with the president and the board of trustees and extending
back end of the process, raising questions about the
across the institution at every level, is key to the success
nature and fairness of the process. While trustees should
of holistic admissions. Leaders are important to:
not be involved in administering the process or making
§ Empower and inspire commitment and collaboration specific admissions decisions, as members of the ultimate
across the enrollment management spectrum; governance authority of the institution it is important
for trustees to understand admissions ethics and the
§ Align admissions with curricular and cocurricular
governing board’s role in maintaining high standards of
programs, as well as legal design parameters;
integrity throughout the process. In their institutional
§ Ensure implementation of a deliberative process, oversight role, trustees also need a good grounding in
regular evaluation, and associated adjustments in the nature, complexity, fairness, and evidence-based
the admissions program’s goals, processes, and decision-making that define the process: the connection
documentation; of holistic admissions to institutional mission, the relative
role of quantitative and qualitative factors, the considerable
§ Make decisions and resource allocations that are
expertise that guides decision-making, the steps taken
evidence based; and
to ensure consistency and fairness, and the disciplined,
§ Maintain consistent messaging, internally and evaluative process that ensures process corrections when
externally, about institutional mission and goals and needed for successful, mission-driven outcomes.
how admission, holistic review, and broad-based
diversity support them.
Illustration
Rice University’s Board of Trustees and Faculty
Council separately adopted resolutions confirming
the educational benefits of diversity, based on
research and the experiences of Rice’s faculty. Both
resolutions supported the necessity of continued
efforts to foster diversity.
Source: Rice Univ., Compl. No. 06-05-2020 (U.S. Department
of Education, Sept. 10, 2013) (compliance resolution),
available at http://www.ed.gov/about/offices/list/ocr/docs/
investigations/06052020-a.html (last modified Jan. 14, 2015).

16
CONCLUSION That level of communications and engagement implicates
new terrain for many, as postsecondary institutions have not
Effective and sustainable holistic review policies and
consistently communicated the vision, rationale, and logic of
practices are dependent on clear, mission-driven factors
their admission decisions to the public, to federal and state
that are important to consider when making judgments
legislators, and even to the extended campus community
affecting student admissions. Processes that reflect
of alumni and donors. Indeed, somewhat ironically, it is
integrity, rigor, fairness, and accountability for results
only within defensive litigation contexts that institutions
in implementation also define effective holistic review.
have most effectively told their admissions stories,
However, more than good design and implementation
including design rationales, descriptions of calibrated
are required to engender stakeholder and public trust in
and fair processes, and the steadfast commitment of
admissions programs—and, more generally, in institutions
higher education professionals to student and institutional
of higher education.
success. It is also within this limited context that we’ve
Any seasoned professional in the field of admissions knows heard most loudly and clearly from industry and military
the importance of having a well-developed communications leaders about their support of diversity and holistic higher
and engagement strategy. No admissions cycle passes education admissions policies that are critical to economic,
without disappointed students (and parents). By definition, civic, and national security interests of the nation. Good
admissions decisions result in acceptances and rejections; policy counsels a broader approach—with proactive,
and such consequential decisions—viewed through a lens collaborative, and sustained communication efforts meeting
of immediate, short-term individual interest, rather than high standards of effectiveness.
longer-term effects and interests—often generate claims
In sum, the public would be better positioned to support
of unfairness in the process. In some instances, those
higher education’s judgment on admissions criteria and
claims make their way to the public sphere, including in
processes (and funding for higher education, for that
court litigation or agency investigation. Even without legal
matter) if the public had a clearer understanding of the basic
consequences, the perception of admission as a “black
objectives of the admissions process, what criteria and
box” raises questions of process integrity and, at worst, can
processes are used, and why the criteria and process are
undermine public trust in higher education.
both fair and serve critical national and societal interests, as
To be sure, complete transparency to the public is well as the interests of all students.
impossible to achieve. Indeed, the real question is one of
The value of transparency and an effective communications
“how much” and “in what detail” to share information on
strategy, focused on resonating with the campus
the process and reasoning of decisions. There isn’t an
community, the general public, and federal and state
easy answer, but in this time of cynicism and distrust,44 a
legislatures; and carried out in an ongoing collaboration
broad imperative associated with better communications
among higher education, industry, and military sectors,
and engagement exists: Greater transparency would
cannot be understated.
present important opportunities to better achieve the
mission-driven objectives of admission by building public
understanding of the broadly beneficial objectives and
fairness of the process for all students and for society
at large. With that increased understanding would come
opportunities to build public support of higher education
more generally.

44. There is considerable and increasing societal misperceptions available at http://www.people-press.org/2017/07/10/sharp-

of, distrust in, and devaluation of higher education in American partisan-divisions-in-views-of-national-institutions/; and Molly
society. See Peter Salovey, “How to Sway Higher Ed's Skeptics,” Corbett Broad, “Educating the Public on the Value of a College
The Chronicle of Higher Education (February 2018), available Degree,” The Chronicle of Higher Education (May 2017), available
at https://www.chronicle.com/article/How-to-Sway-Higher-Ed- at https://www.chronicle.com/article/Educating-the-Public-on-
s/242645?cid=wcontentgrid_40_2; Pew Research Center, Sharp the/240005.
Partisan Divisions in Views of National Institutions (July 2017),

17
APPENDIX A

Principal Resources
§ The “Rigol series,” published by the College Board: § Espinosa, L. L., M. N. Gaertner, and G. Orfield (2015).
Race, Class, and College Access: Achieving Diversity in
w Toward a Taxonomy of the Admissions Decision-
a Shifting Legal Landscape. Washington, DC: American
Making Process (1999) https://research.
Council on Education. http://www.acenet.edu/news-
collegeboard.org/publications/content/2012/05/
room/Documents/Race-Class-and-College-Access-
toward-taxonomy-admissions-decision-making-
Achieving-Diversity-in-a-Shifting-Legal-Landscape.pdf
process
§ Coleman, A. L. and T. E. Taylor (2017). Building an
w Best Practices in Admissions Decisions (2002)
Evidence Base: Important Foundations for Institutions
https://research.collegeboard.org/publications/
of Higher Education Advancing Education Goals
content/2012/05/best-practices-admissions-
Associated with Student Diversity. Washington, DC: The
decisions
College Board. https://professionals.collegeboard.org/
w Admissions Decision-Making Models (2003) pdf/building-evidence-base.pdf
https://research.collegeboard.org/publications/
§ Grutter v. Bollinger, 539 U.S. 306 (2003)
content/2012/05/admissions-decision-making-
models-how-us-institutions-higher-education § Gratz v. Bollinger, 539 U.S. 244 (2003)

w Selection Through Individualized Review (2004) § Fisher v. Univ. of Texas at Austin, 570 U.S. ___ (2013)
https://research.collegeboard.org/publications/
§ Fisher v. Univ. of Texas at Austin, 579 U.S. ___ (2016)
content/2012/05/selection-through-individualized-
review § Brief for the College Board, AACRAO, NACAC, and LSAC
as Amici Curiae Supporting Respondents, Fisher v.
§ College Board (2017), Future Admissions Tools and
University of Texas at Austin, 579 US _ (2016) (no.14-
Models. https://professionals.collegeboard.org/higher-
981). http://educationcounsel.com/?publication=fisher-
ed/future-admissions-tools-and-models-initiative
v-university-of-texas-u-s-supreme-court-amicus-
w This document is published as part of the College brief-2015
Board’s Future Admissions Tools and Models
§ Brief for American Council on Education and 37 Other
Initiative and contains five parts: Introduction,
Higher Education Organizations as Amici Curiae
Exploring a New Framework for Sorting Applicants,
Supporting Respondents, Fisher v. University of
Data-Driven Models to Understand Environmental
Texas at Austin, 579 US _ (2016) (no.14-981). http://
Context, Insights into Nonacademic Factors and
www.acenet.edu/news-room/Documents/Amicus-
Practice, and Innovative Practices of Interest on
Brief-US-Supreme-Court-FisherII.pdfBrief for the
Campus
Association of American Medical Colleges et al. as
§ Lucido, J. A. (2015), “How Admission Decisions Amici Curiae Supporting Respondents, Fisher v.
Get Made.” In Handbook of Strategic Enrollment University of Texas at Austin, 579 US _ (2016) (no.14-
Management (pp. 147–173). San Francisco: Jossey- 981). https://www.aamc.org/download/447744/data/
Bass, A Wiley Brand. aamcfilesamicusbriefinfishervutaustin.pdf

§ Association of American Medical Colleges (2010). § Amicus briefs filed in Fisher II, available at http://www.
Roadmap to Diversity: Integrating Holistic Review scotusblog.com/case-files/cases/fisher-v-university-of-
Practices into Medical School Admission Processes. texas-at-austin-2/
https://members.aamc.org/eweb/upload/Roadmap%20
to%20Diversity%20Integrating%20Holistic%20
Review.pdf

18
§ Amicus briefs filed in Grutter and Gratz, including Brief
for Massachusetts Institute of Technology, Leland
Stanford Junior University, E. I. du Pont de Nemours
and Company, International Business Machine Corp.,
National Academy of Sciences, National Academy of
Engineering, and National Action Council for Minorities
in Engineering, Inc., as Amicus Curiae Supporting
Respondents,

§ U.S. Department of Education Office for Civil Rights

Case Resolutions:

w Princeton Univ., Compl. No. 02-08- 6002 (U.S.

Department of Education, Sept. 9, 2015)
(compliance resolution), available at https://
www2.ed.gov/about/offices/list/ocr/docs/
investigations/02086002-a.pdf;

w Univ. of North Carolina, Compl. No. 11-07-2016 (U.S.

Dep’t of Educ. November 27, 2012) (letter of findings),
available at https://www2.ed.gov/about/offices/list/
ocr/docs/investigations/11072016-a.pdf;

w Rice Univ., Compl. No. 06-05-2020 (U.S. Department

of Education, Sept. 10, 2013) (compliance
resolution), available at http://www.ed.gov/about/
offices/list/ocr/docs/investigations/06052020-a.
html (last modified Jan. 14, 2015);

w North Carolina State University. Compl. No. 11-04-

2009 (U.S. Department of Education, November
27, 2012) (letter of findings), available at https://
www2.ed.gov/about/offices/list/ocr/docs/
investigations/11042009-a.pdf; and

w University of Virginia, Compl. No. 11-03-2072 (U.S.

Department of Education, March 19, 2013) (letter of
findings).

19
APPENDIX B

Federal Nondiscrimination
Law in a Nutshell
Federal nondiscrimination laws govern the consideration § Evidence of need. The institution’s opinion regarding
of race, ethnicity, and other factors in higher education diversity goals and policy designs isn’t enough.
in admissions. Public and private institutions that receive Evidence should demonstrate that considering race
federal funding are subject to the same basic standards in the manner contemplated or pursued is necessary
of review. State laws that impose greater restrictions or because (1) race-neutral strategies, while used and
additional requirements may also apply. having an impact, alone aren’t adequate to meet
diversity-associated institutional goals, (2) the diversity
With respect to considerations of race and ethnicity in
already existing at the institution or in clusters of
admissions, federal courts apply a “strict scrutiny” standard
relevant courses/settings isn’t adequate (e.g., where
of review.45 Cases reflect the expectation that such policies
students still feel isolated based on race and lack
will be supported by:
substantial diverse learning opportunities), and (3)
§ Clear, research- and experienced-based goals, with those strategies that do involve consideration of race
rationales. The institution should explain the specific are effective, but not overly burdensome on others.
diversity-associated educational outcomes sought
to benefit all students; and why, in the institution’s
experience and judgment, broadly defined student
body diversity (including, but not limited to race and
ethnicity) is needed to achieve those outcomes.

§ Well-designed means. Holistic review in admissions

should involve the application of the same criteria,
standards, and process to every applicant—even as
various factors may apply differently with different
applicants. Race should be considered flexibly and
individually, not mechanically or rigidly, for every
applicant, as a context to understand the applicant’s
experiences, challenges, and accomplishments. (Race
should not be considered in the same way or given
the same weight for all individuals who are of the same
race.) Admissions should not reflect, with respect to
race and ethnicity:

w Numerical quotas;

w Mechanically applied points;

w Separate processes/tracks or opportunities for

review; or

w A thumb-on-the-scale preference.

Race-neutral considerations should dominate across

the enrollment management spectrum, with race being
considered in a limited, contextual manner only where 45. This distillation of portions of federal nondiscrimination law is
needed to achieve desired goals. not intended to provide a full or comprehensive overview of all
potentially relevant factors that an institution may need to consider
when evaluating legal exposure. Enrollment officials should consult
with their attorneys on issues presented here.

20
Evidence and the requirements of federal nondiscrimination law.
When race and ethnicity, and likely gender, are If the institution can articulate and document a
considered in a holistic review of the admissions logical, reasonable explanation of its compelling
process, applicable law—and good policy education-outcome-based goal and the core
supporting effective strategies and efficient connection of broad diversity to that goal, it has
resource allocation—requires an institution to provided the necessary evidence base for goals.
develop a quantitative and qualitative evidence
Note, however, that building an evidence base
base that demonstrates the need to consider
is not a static process; it is one that must be
race, ethnicity, and gender as a means to
repeated on an ongoing, periodic basis, so that
advance the institution’s diversity-associated
evidence-based judgments can be affirmed
educational and societal goals. This requires
or changed to meet institutional, societal, and
consideration of both the goals themselves
other relevant contextual changes. Building an
and the means of achieving the goals—in
Evidence Base provides guidance on the existing
relation to the student experience. The College
documents and processes that institutions
Board’s Building an Evidence Base, available at
can use for this purpose, including mission
https://collegeboard.org/accessanddiversity,
statements, strategic plans, leader and faculty
provides guidance on how to build, assess on an
statements, etc.
ongoing basis, and use the necessary evidence
base, which is grounded in research and good
practices of institutions of higher education
whose race-conscious processes have survived
legal challenges.

Sources: See the following Access & Diversity Collaborative See also, University of California Regents v. Bakke, 438 U.S.
resources at https://professionals.collegeboard.org/higher-ed/ 265 (1978); Grutter v. Bollinger, 539 U.S. 306 (2003); Gratz
access-and-diversity-collaborative/resource-library, including: v. Bollinger, 539 U.S. 244 (2003); Fisher v. Univ. of Texas at
Austin, 570 U.S. ___ (2013); Fisher v. Univ. of Texas at Austin,
■ Unpacking Fisher II and its Possible Implications for 579 U.S. ___ (2016). Note that the goal of mirroring in the
Institutions (2016); student body the same percentage of racial minorities as
■ Understanding Fisher v. University of Texas: Policy exist in the state or nation, has been held by the Supreme
Implications of What the U.S. Supreme Court Did (and Court to be unconstitutional “racial balancing,” and is not a
Didn’t) Say About Diversity and the Use of Race and legally legitimate or sustainable goal. Awareness of societal
Ethnicity in College Admissions (2013); demographics is still relevant to educational-outcome-
focused goals; however, as all students must learn to work,
■ Bridging the Research to Practice Gap: Achieving Mission- live, and socialize with a broad diversity of peers if they
Driven Diversity and Inclusion Goals (The College Board, are to contribute productively as citizens, serve diverse
2016); constituencies in their particular professions or jobs,
and fulfill workforce and civic needs.
■ A Policy and Legal “Syllabus” for Diversity Programs at
Colleges and Universities (The College Board, 2015); and

■ The Playbook: A Guide to Assist Institutions of Higher

Education in Evaluating Race- and Ethnicity-Neutral Policies
in Support of the Mission-Related Diversity Goals (2014).
APPENDIX C

Admissions
Protocols
Common protocols reflective of good practice include: § Use of one or more readers who prepare a summary,
including specifically required information, with the one
§ Multiple reviews of the same application by multiple
or the lead reader presenting the file to a committee
readers, with further review if outcomes are significantly
that makes the final decision by vote (an approach used
divergent;
by selective institutions, with adequate resources to
§ Use of a first reader to make a recommendation on devote this level of review);48
an application, and a second reader to make the final
§ Team readers, each of whom has a particular focus, with
decision; and
the team ultimately assigning a rating, or team readers
§ Use of two readers whose recommendation, if the who make the decision when there is consensus among
same, is final, with a third reader making the final sufficient numbers in the team (an approach used
decision if the first two disagree. by selective institutions of varying sizes, public and
private);49 and
Adaptations of these protocols may reflect:
§ Use of two readers to assign ratings to an application,
§ Use of one senior staff reader, who reviews a “summary
with a third reader becoming involved if there is
card” for all applicants or who must give final approval
deviation between the first two readers’ ratings that is
of all decisions through some other means, or use
significant (e.g., more than .5 or 1.0 points).50
of a small number of senior team leaders who must
give final approval of all decisions in their respective
team clusters—in any such model, with an eye toward
consistency and integrity in relation to criteria;46

§ Use of one senior reader per region who makes the

decision on applicants who aren’t automatically
admitted based on fixed, quantitative criteria (an
approach used by moderately selective private and
public institutions (admitting 50%–90% of applicants);47

46. Gretchen W. Rigol, supra 34, at 21.

47. Rigol, supra 1, at 41.

48. Rigol, supra 34, at 39-40.

49. Id., at 40.

50. Rigol, supra 1, at 21.

22
APPENDIX D

The College Board’s Access

& Diversity Collaborative
The College Board’s Access & Diversity Collaborative In each of these roles, the ADC will continue its tradition
(ADC), now in its 14th year, continues to provide national of leadership driven by research and sound educational
leadership and institutional support focused on higher practice—informed by ongoing, multifaceted engagement
education diversity goals. Working with core partner with educators and policy leaders committed to principles
institutions of higher education and national organizations, of expanding and enhancing access, opportunity, and
the ADC addresses key issues that surface in the full range meaningful educational experiences for all students as they
of enrollment policies and practices through a convening, prepare for careers and citizenship in the 21st century.
stakeholder outreach and engagement, actionable research,
The Access & Diversity Collaborative relies heavily on
policy and practice publications, and web-based tools
the support and guidance of its 57 institutional and 13
and resources.
organizational sponsors in identifying challenges and
The ADC is poised to continue and enhance its strategic opportunities and making recommendations regarding
aims and service to higher education institutions and strategic direction for ADC’s work. Other primary benefits
organizations in coming years, as: of sponsorship are:

§ A voice of national advocacy, grounded in balance and § Receipt of regular sponsor-only updates of relevant
reason, for the continuation of robust, research/practice policy, legal, and research developments and an
based, and lawful access and diversity policies that are invitation to an annual sponsors-only meeting at the
aligned with 21st-century career and citizenship goals. College Board Forum; and

§ A resource for sophisticated and pragmatic policy § Recognition as a sponsor on the ADC website and
and practice guidance and actionable research to in other relevant College Board program materials,
support institutional mission-based goals in light of including the College Board’s annual Forum and Higher
relevant law, including a focus on the promotion and Ed Colloquium promotional materials.
expansion of pathways and more robust opportunities
§ For additional information, see
for historically underserved youth (including minority,
diversitycollaborative.collegeboard.org.
low-income, and disadvantaged youth).

§ A convener for thought leadership and collaborative

engagement on policy and practice development,
with a focus on:

w The effective use of data and support for research

connected to “real-world” policy and practice issues
(nationally and as a matter of institutional policy);

w The identification and development of replicable

best practices that reflect sound policy and that are
legally sustainable; and

w The facilitation/mitigation of polarizing positions in

pursuit of meaningful common ground—to support
the development of a principled and pragmatic
policy and practice agenda.

23
ADC INSTITUTIONAL SPONSORS
§ Austin College* § University of Arizona

§ Barnard College § University of California, Irvine*

§ Boston College § University of California, Los Angeles

§ Bryn Mawr College § University of California, Office of the President*

§ Cornell University § University of California System

§ Dartmouth College § University of Connecticut

§ Davidson College § University of Florida

§ Emerson College § University of Georgia

§ Florida International University § University of Illinois

§ Florida State University § University of Maryland, College Park*

§ Guilford College § University of Michigan*

§ Hamilton College § University of Minnesota, Twin Cities

§ Indiana University § University of North Carolina at Chapel Hill

§ James Madison University* § University of the Pacific

§ Kenyon College § University of Pennsylvania

§ Miami University of Ohio § University of San Francisco

§ Mount Holyoke College § University of Southern California*

§ Northeastern University § The University of Texas at Austin*

§ The Ohio State University § University of Tulsa

§ Pomona College* § University of Vermont

§ Princeton University § University of Virginia*

§ Purdue University § University of Washington

§ Rice University § Vanderbilt University

§ Rutgers, The State University of New Jersey § Vassar College*

§ Smith College* § Virginia Tech

§ Southern Methodist University § Washington University in St. Louis

§ Stanford University § Wellesley College*

§ Syracuse University § Wesleyan University

§ Texas A&M University

*Representatives from these institutions are 2018 ADC Advisory Council Members

24
ADC ORGANIZATIONAL SPONSORS
§ American Association for the Advancement of Science
(AAAS)

§ American Association of Collegiate Registrars and

Admissions Officers (AACRAO)

§ American Council on Education (ACE)*

§ American Dental Education Association (ADEA)

§ Association of American Colleges & Universities

(AAC&U)

§ Association of American Medical Colleges (AAMC)

§ Center for Institutional and Social Change at Columbia

Law School

§ Law School Admission Council (LSAC)

§ National Association for College Admission Counseling

(NACAC)*

§ National Association of College and University

Attorneys (NACUA)

§ National Association of Student Financial Aid

Administrators (NASFAA)*

§ National School Boards Association (NSBA)

§ University of Southern California Center for Enrollment

Research, Policy, and Practice

*Representatives from these organizations are 2018 ADC Advisory Council Members

25
About the College Board
The College Board is a mission-driven not-for-profit organization that connects students to
college success and opportunity. Founded in 1900, the College Board was created to expand
access to higher education. Today, the membership association is made up of over 6,000 of the
world’s leading educational institutions and is dedicated to promoting excellence and equity
in education. Each year, the College Board helps more than seven million students prepare
for a successful transition to college through programs and services in college readiness and
college success—including the SAT® and the Advanced Placement Program®. The organization
also serves the education community through research and advocacy on behalf of students,
educators, and schools.

For further information, visit collegeboard.org.

About EducationCounsel
EducationCounsel is a mission-driven education consulting firm that works with leading nonprofit
organizations, foundations, education leaders, and policymakers to help significantly improve
education opportunity and outcomes, with a focus on equity issues. We work with education
partners at the state, federal, and institutional or local levels to advance evidence-based
innovations and systems change. We do this by leveraging policy, strategy, law, and advocacy to
help transform education systems, from early learning to K–12 to higher education.

For further information, visit educationcounsel.com.

© 2018 The College Board. College Board, Advanced Placement Program, AP, SAT, and the acorn logo
are registered trademarks of the College Board. All other marks are the property of their respective
owners. Visit the College Board on the web: collegeboard.org. 00997-056 160852538