Doug Belkin of the Wall Street Journal has written two articles detailing the controversial practice of affluent parents transferring legal guardianship of their children in order to get more financial aid from colleges. This issue is particularly timely due to the phased roll-out of the College Board's "adversity score" for all SAT test-takers. It is conceivable that parents might investigate ways of raising their children's adversity score to improve their chances of acceptance at competitive colleges.

Belkin's first article lays out the guardianship transfer strategy and the potential response from colleges and the Department of Education:

College Financial-Aid Loophole: Wealthy Parents Transfer Guardianship of Their Teens to Get Aid

[Excerpts]

Amid an intense national furor over the fairness of college admissions, the Education Department is looking into a tactic that has been used in some suburbs here, in which wealthy parents transfer legal guardianship of their college-bound children to relatives or friends so the teens can claim financial aid, say people familiar with the matter.

The strategy caught the department’s attention amid a spate of guardianship transfers here. It means that only the children’s earnings were considered in their financial-aid applications, not the family income or savings. That has led to awards of scholarships and access to federal financial aid designed for the poor, these people said.

Several universities in Illinois say they are looking into the practice, which is legal. “Our financial-aid resources are limited and the practice of wealthy parents transferring the guardianship of their children to qualify for need-based financial aid—or so-called opportunity hoarding—takes away resources from middle- and low-income students,” said Andrew Borst, director of undergraduate enrollment at the University of Illinois. “This is legal, but we question the ethics.”

One Chicago-area woman told The Wall Street Journal that she transferred guardianship of her then 17-year-old daughter to her business partner last year. While her household income is greater than $250,000 a year, she said, she and her husband have spent about $600,000 putting several older children through college and have no equity in their home, which is valued at about $1.2 million, according to the property website Zillow. She said she has little cash on hand and little saved for her daughter’s education.

Transferring her daughter’s guardianship was largely a matter of paperwork, the mother said. Her business partner attended a court hearing with an attorney. She, her husband and her daughter didn’t even need to show up, she said. Once the guardianship was transferred, the teen only had to claim the $4,200 in income she earned through her summer job, the mother said.

Today, her daughter attends a private college on the West Coast which costs $65,000 in annual tuition, she said. The daughter received a $27,000 merit scholarship and an additional $20,000 in need-based aid, including a federal Pell grant, which she won’t have to pay back. The daughter is responsible for $18,000 a year, which her grandparents pay, the woman said.

The woman and another Chicago-area parent who spoke to the Journal said they followed the strategy laid out by a college consultant company called Destination College, based in Lincolnshire, Ill. The company says on its website it has saved families as much $40,000 a year per student.

The Education Department is looking at such transfers through its investigative arm, its Inspector General Office, said a person familiar with the matter. The office has suggested that the Education Department add clarifying language to the Federal Student Aid handbook. The suggested language, this person said, is:

“If a student enters into a legal guardianship, but continues to receive medical and financial support from their parents, they do not meet the definition of a legal guardianship and are still considered a dependent student.”

Belkin's second article takes a closer look at the college consultant who devised and implemented the guardianship strategy:

The College Financial-Aid Guardianship Loophole and the Woman Who Thought It Up

[Excerpts]

The college consultant who developed a strategy to help wealthy clients access scholarships designed for the poor said she came up with the idea after seeing how much debt parents were taking on to send their children to college.

The U.S. Education Department condemned Ms. Georgieva’s actions and said it was moving to stop them.

“Those who break the rules should be held accountable,” spokeswoman Liz Hill said Tuesday in a statement. “The Department is committed to assessing what changes can be made—either independently or in concert with Congress—to protect taxpayers from those who seek to game the system for their own financial gain.”

Colleges started receiving applications from Ms. Georgieva’s clients last year. The University of Illinois, where annual costs, including tuition, room and board, range from $32,000 to $36,000 for in-state students, said it spotted 15 students who may have used the strategy. “The university likely will withhold institutionally funded need-based financial aid until we are satisfied that students who have transferred guardianship don’t have other financial resources available,” said Andy Borst, director of undergraduate admissions of the University of Illinois.

“I don’t think I figured out a loophole,” Ms. Georgieva said. “Anybody that goes on the [federal financial-aid] website can find the criteria for being an independent student or a dependent student. It’s all right there.”

 
Many states have adopted or are considering the adoption of the SAT/ACT in place of statewide high school exams. An article in the Albany Daily Star relates that a report released the Rockefeller Institute of Government suggests that New York State consider using the SAT or ACT as a replacement for some of the state’s current high school Regents exams.

[Excerpts]

As leaders of New York's public education bureaucracy rethink their reliance on Regents exams, an Albany think tank is suggesting they be replaced by college admissions tests.

A new report issued by the Rockefeller Institute of Government suggests the SAT (formerly known as the Scholastic Assessment Test) and the ACT (American College Testing) could be stitched into New York's high school testing regimen.

The report's author, Brian Backstrom, noted that nearly two dozen states offer “ACT Days” or “SAT Days” during the regular school year, asking all public high school juniors to sit for the exams. The schools cover the fees for the college exams, he said.

It would be an opportunity for New York to avoid "having to reinvent the wheel," Backstrom pointed out in an interview.

The chancellor of the Board of Regents, Betty Rosa, declared in March that New York is open to adopting a new measurement, asking: “To what degree does requiring passage of Regents exams for a diploma improve student achievement, graduation rates and college readiness?"

In New York high schools now, students must pass at least four Regents exams to get Regents diplomas.

Niagara Falls City School District Superintendent Mark Laurrie said the Regents exams continue to provide a meaningful measurement. He noted some colleges have begun to drop reliance on SAT and ACT results when evaluating applicants, opting instead to put emphasis on their community involvement and work experience.

"The SAT and ACT are not aligned with school curriculum, and so we would be testing kids on things they haven't been taught," Laurrie said.

The Rockefeller Institute of Government report can be found here.

[Excerpts]

More than half of the states in the country currently use the SAT or ACT standardized college entrance exams as part of their high school testing systems. Whether requiring students to take the test to graduate or just making it an available option for all students, whether supplementing state testing requirements or replacing them entirely, more and more states are choosing to make the SAT and ACT a fundamental part of high school testing.

Saying it is time to “rethink our graduation requirements,” Chancellor of New York’s Board of Regents Betty Rosa recently posed the question, “To what degree does requiring passage of Regents exams for a diploma improve student achievement, graduation rates and college readiness?” Then in July 2019, the Board of Regents, the state’s governing body over P-12 schooling, formally called for the creation of a new commission to thoroughly study the role and effectiveness of Regents exams as high school competency and exit tests, including whether passing such tests should still be required.

As part of its investigation into New York State’s graduation requirements, the Board of Regents could consider using the SAT or ACT college entrance exams as a replacement for at least some of the state’s current high school Regents exams. New York allows students to substitute their math score on the SAT for a required Regents math exam if they score a certain level, and many other states allow students to meet state high school graduation requirements by substituting sufficient scores on the SAT or ACT, too, including Arizona, Florida, Idaho, and Ohio, among others. Essentially, New York and these other states already have adopted the policy position that performance on the SAT is an acceptable and equivalent measure of competency to state-administered high school exit exams.

The author of the Rockefeller Institute report has offered comments regarding his suggestion that the SAT and ACT be used as high school assessments in New York:

[Excerpts]

Brian Backstrom, director of education policy studies at the institute and author of the report, cited concerns of the “value and appropriateness” of Regents exams, and suggested the Board of Regents could consider using the SAT or ACT exams as a replacement for some of the state’s current high school Regents exams.

“New York allows students to substitute their math score on the SAT for a required Regents math exam if they score a certain level, and many other states allow students to meet state high school graduation requirements by substituting sufficient scores on the SAT or ACT…,” said Backstrom. “Essentially, New York and these other states already have adopted the policy position that performance on the SAT is acceptable and equivalent measure of competency to state-administered high school exit exams.”

Backstrom also argued that New York can offer high school juniors the SAT or ACT during a regular school day, with fees covered by the state. SAT Days are already administered in New York City public high schools. He said ACT or SAT Days increase access to college for students in states like Colorado and Illinois, and give all students the opportunity to go to college.

 
Arizona has attempted to grant individual school districts the ability to substitute the SAT or ACT for the state's current AzMerit high school exams, but the federal Department of Education has rejected its request for a waiver to do so. Arizona faces a loss of federal funding of up to $340 million if it does not comply with the mandates of the Every Student Succeeds Act. The ACT requires the peer-reviewed demonstration of an alignment between state standards and those of the SAT/ACT exam structures before such exams are administered, that states determine a score level for each exam that will be deemed to represent adequate demonstration of achievement, and that states administer the same exam to all high school students.

[Excerpts]

Arizona could lose $340 million in federal funding because the state hasn't followed the Every Students Succeeds Act's rules for testing its students, Frank Brogan, the assistant secretary for elementary and secondary education, told the state in a recent letter.

This spring, Arizona allowed its districts a choice of offering the ACT, the SAT, or the state's traditional test, the AzMerit test, at the high school level. ESSA allows states to offer districts the option of using a nationally-recognized college entrance exam in place of the state test, but first they must meet certain technical requirements.

For instance, states must make sure that the national recognized exam (such as the ACT or SAT) measures progress toward the state's standards at least as well as the original state test. They also must make sure that the results of the nationally-recognized exam can be compared to the state test. And they have to provide appropriate accommodations for English-language learners and students in special education. All of this is supposed to happen before the state ever allows its districts the option of an alternate test.

Arizona "hasn't provided evidence that it has completed any of this work," Brogan wrote.

 
Elaine Chen from Chalkbeat covers the reaction of ACT, Inc. to the College Board's winning another testing contract for the SAT with the state of Illinois. For many years, the state had given the ACT to all high school juniors until the College Board submitted a bid that caused Illinois to announce a switch to the SAT in 2016.

[Excerpts]

In a fight between two giant standardized test providers, the SAT again has won a multi-million-dollar contract for Illinois’ high-school tests — and the also-ran ACT is filing a protest with the Illinois State Board of Education. After obtaining documents from the state last week, the ACT is protesting the state’s decision to award a multi-year contract to the College Board, the company that runs the SAT.

Early this year, the state board requested a vendor to provide annual 9th-, 10th-, and 11th-grade tests. The request said the contract would last for three years, with the possibility of contract renewals for three additional years. In June, it selected the College Board to provide the SAT for 11th-graders and, for the first time, to provide the pre-SAT standardized test, known as the PSAT, for 9th- and 10th-graders.

The ACT is arguing that the College Board deviated from the state’s directions in how to calculate the cost of its bid. As a result, the winning bid was for $59.7 million, or $1.7 million lower than what it should have been using the state-provided formula. The ACT’s bid was actually less — $54 million — and that’s one of the points underpinning its protest. However, the $5.7 million difference between the two test providers’ bids, spread out over six years, would not make a large difference in the state’s annual budget for assessments.

The state is providing the SAT not only as a college entrance exam, but also as a measure of school achievement. Under Illinois’ Every Student Succeeds Act plan, which establishes ways of measuring school achievement and of helping under-performing schools, the SAT will make up 7.5 percent of state scores on school quality.

While Illinois has in effect underwritten the cost of taking the SAT — for one annual sitting — for its public-school students, this coming school year the state will also provide the PSAT for 9th- and 10th-grade students.

Education Dive examines recent developments related to the SAT and ACT and test optional admissions, and asks, "Is time up on standardized tests for college admissions?"

[Excerpts]

Bowdoin College, in Brunswick, Maine, was the first test-optional school in the U.S. Although the private liberal arts college's policy has been in place for 50 years, the admissions process has changed dramatically since, as its applicant pool grew from 3,500 in the 1980s to 9,300 today, said E. Whitney Soule, dean of admissions and financial aid. The college enrolls 1,800 undergraduates and this year accepted about 9% of applicants to add roughly 500 new students, she said.

While Bowdoin made the change explicitly to increase access, Soule said its holistic review of each application hasn't increased time demands on the admissions office.

"It really doesn't take longer to consider a student without a test score," she said. Even for students who submit test scores, she added, "testing doesn't hold enough weight to undo the more thorough evaluation we just completed."

"Even the testing agencies acknowledge aspects of testing that don't work well for every part of the population," Soule said. "We're not anti-test, we're just not relying on the test to do the work we're doing."

FairTest's [Robert] Schaeffer doesn't call standardized test scores "totally irrelevant." But, he added, the difference between an SAT score of 1400 and 1200 "isn't as significant as what a high school record captures."

Colleges considering going test-optional should think beyond admissions, said Annie Reznik, executive director of the Coalition for College, a group that aims to expand access to higher education by offering an alternative to the Common Application and more preparatory resources.

"Be clear about why you are going test-optional and build in support for those other goals," she said, noting that after dropping its standardized test requirement, U of Chicago increased support for students once they arrived on campus.

Across all colleges, exactly how many students withhold test scores is uncertain. FairTest's Schaeffer said the figure could range from 15% of students at a school that recently made the change to 50% at a school where such a policy has been in place for years.

One in three applicants to Bowdoin don't include test scores, Soule said, a percentage that hasn't changed over the years. First-generation students are more likely to withhold test scores, she added.

Even if low-income or first-generation students are already qualified to attend a school, Reznik said, dropping the test requirement might encourage them to apply. It lets students "take more control over the application process" and not worry peers will gain an advantage by taking a standardized test multiple times or using a private tutor, she said.

While this article by former tutor and current study guide author Erica Meltzer was written last year in the wake of the University of Chicago's announcement that it was adopting a test optional policy, it is well worth reading.

[Excerpts]

The University of Chicago has become the first of the truly elite schools to adopt a test-optional policy, which will take effect for the class of 2023.

Chicago’s justification for going test-optional is similar to that of other test-optional schools, but I do think that something a little more interesting is going on here – rhetorically at least.

Part of the problem with the current testing landscape is that elite colleges are, broadly speaking, dealing with two very different groups of applicants.

On one hand, there are well-off (primarily white and Asian) students from strong public and private schools – students for whom test scores do paint a generally accurate picture.

On the other hand, there are low-income, first-generation, largely African-American and Latinx students that colleges are trying very hard to recruit, and whose scores may be far less reflective of their academic potential.

The fact that colleges are trying to accommodate both of these groups in a holistic process means that there is essentially a two-tiered system, with different expectations for different groups of applicants. Officially, of course, colleges tend to shy away from admitting this, but it is an open secret.

What is striking about Chicago’s announcement is that it effectively admits as much, to an even greater extent than is the case for other test-optional schools. By explicitly linking the initiative not only to abstract notions of equity but to a larger, formal program designed to bring in particular groups of students (not just first-generation and underrepresented, but also rural students and children of veterans and service members), Chicago is making it abundantly clear just whom the policy is directed towards.

Indeed, an inspection of the language on UChicago’s admissions page confirms that “test-optional” does not mean “don’t send us your test scores”:

We encourage students to take standardized tests like the SAT and ACT, and to share your scores with us if you think that they are reflective of your ability and potential…

Translation: if you aren’t in a sought-after demographic and don’t have a damn good reason for going test-optional, you probably won’t get in without scores.

That isn’t to say that a handful of exceptionally bright, well-qualified, non-disadvantaged students who choose not to submit scores won’t be admitted, but they will almost certainly be the very rare exceptions that confirm the rule. That’s just how holistic admissions works.

And to state the obvious, there is clearly some self-interest involved here as well. Over the last 10-15 years, UChicago (along with Northeastern) has emerged as the poster-child for gaming the US News and World Report rankings. The university, once ranked around #15, climbed to the #3 spot – tied with Yale – this year. Chicago has been taking on the Ivies very effectively at their own game – and winning.

In addition to throwing down the test-optional gauntlet for the Ivies, Stanford, Duke, etc. (although not MIT or Caltech!) while simultaneously improving the school’s social justice creds, the move is guaranteed to win the university considerable publicity/plaudits, further driving applications up and acceptance rates down.

This is an area in which Chicago excels: when I was applying to college, in 1999, Chicago’s acceptance rate was around 40%; now it’s around 7%. With a test-optional policy in place, that number could easily dip to 5% or lower in the next few years.

This article in the Connecticut Post offers a detailed look at test optional policies and outcomes among state-based colleges.

[Excerpts]

New Haven’s Board of Education decided to reconsider a contract this month that would use instruction time to administer a practice SAT exam for eighth, ninth and 10th graders.

The decision to reconsider comes at a time when a growing number of colleges and universities are going “test-optional.”

“The test is at best a weak predictor of college performance,” said Bob Schaeffer, public education director of FairTest. “Test makers only correlate it to first-year grades, whereas independent researchers have found that, in terms of predicting outcomes that matter, like graduation and four-year grade point average, high school grades and records are stronger predictors of undergraduate success than the test is.”

A National Association for College Admission Counseling study of 28 test-optional institutions, black students were nearly twice as likely as their white peers — 35 percent to 18 percent — to not submit test scores.

The study found that non-submitters were admitted at lower rates but enrolled at higher rates and graduated at a similar — if not marginally higher — rate to students who submitted test scores.

Quinnipiac University went test-optional three years ago for all programs except for those with licensing requirements like health sciences and nursing.

One of the biggest drivers for Quinnipiac to adopt the policy, he said, was a desire to remain competitive with other schools who were going test-optional at the time.

Schaeffer said that, anecdotally, it’s not something he’s seen happen often.

“We believed that, through the domino effect, if big-name Ivy Leagues were to go test-optional, other schools would follow suit. I’ve stopped believing that,” he said. “The decisions are very individual.”

The number of test optional colleges has continued to expand over the past few months. Scott Jaschik of Inside Higher Ed shares the news (via FairTest) that 35 colleges have adopted test optional policies in the past 10 months, setting a record for a single year.

The following is a list of colleges that have recently announced the adoption of a test optional policy.

---Carroll College (US News-ranked #1 in Regional Colleges West; 1,350 undergraduates enrolled; 78% acceptance rate; ACT 25th-75th percentile of 22-28).

---College of Our Lady of the Elms (US News-ranked no. 99 among Regional Universities North; 1,200 undergrads enrolled; 79% acceptance rate; SAT 25th-75th percentile of 930-1130).

---Queens University of Charlotte (ranked #18 in Regional Universities South; 1,700 undergraduates; 79% acceptance rate; SAT 25th-75th percentile of 1010-1198).

---Spring Hill College (ranked in the 2nd tier of National Liberal Arts Colleges; 1,400 undergraduates; 46% acceptance rate; ACT 25th-75th percentile of 21-26).