ln early 2025, the U.S. Department of Education issued a deceptively bureaucratic document: a "Dear Colleague" letter clarifying how colleges should interpret the Supreme Court's 2023 decision in Students for Fair Admissions v. Harvard. On its face, the letter simply restated existing law.
But within its footnotes, examples, and omissions, the federal government declared open season on the architecture of holistic admissions.
Essays? Risky. ZIP codes? Suspect. Even activities like being a first-generation student or captain of a debate team could, if interpreted as racial proxies, expose a university to investigation.
This is a regulatory revolution, not a mere reinterpretation of law. And its implications are now rippling outward, reshaping not only how colleges admit students, but how they justify their missions, quantify their values, and shield themselves from enforcement.
Welcome to the age of merit by audit.
The Quiet Collapse of Holistic Review
For nearly three decades, holistic review was higher education's best answer to a complex question: how do you fairly select a class from a nation beset with various equalities?
Holistic admissions was never perfect. Essays favored the well-coached. Extracurriculars rewarded those with time and access. But in its best moments, it allowed admissions officers to see something beyond the numbers: Context. Story. Grit. Aspiration.
That scaffolding is now collapsing.
The new interpretation of SFFA does not merely forbid explicit consideration of race. It casts suspicion on any input that might indirectly reveal race. That includes not only narrative elements like personal statements and recommendation letters, but also the use of data fields like ZIP code, school attended, or even "overcoming adversity" prompts.
The result: a systematic shift toward anonymized, quantifiable inputs. GPAs, adjusted for school decile. SAT/ACT scores, percentile-normalized. Verified activities, stripped of prose.
Consider: We're entering a world where it may be acceptable for an applicant to list their role as Captain of their school’s debate team, but it would be unacceptable to mention even the subject of the state championship finals debate round they won, because it may reveal something verboten. Forget about an essay that discusses their inspiration for spending years on the debate team, or their passion for x, y, and z topics. All off-limits.
In this system, merit is not a judgment. It is a data field.
Universities Are Not Just Adapting. They're Preemptively Complying.
The federal government is not (yet) enforcing these standards through court cases. It is enforcing them through audits, threats of funding loss, and a pervasive regulatory chill.
Under the proposed College Admissions Accountability Act, a new Special Inspector General would audit Title IV schools for noncompliance with federal anti-discrimination statutes. Penalties include up to 200% recoupment of federal grants.
Universities, particularly those with large endowments, are not waiting to be punished. They are actively considering how to reengineer their admissions systems in advance:
Eliminating essays or rewriting the prompts to avoid any identity-adjacent language
Using anonymization platforms like Appily Match to strip identifying information
Shifting from narrative review to point-based scoring systems focused on GPA, test scores, and validated activity checklists
The interview? Forget about it
This is risk management by redesign.
And in the process, the moral calculus of admissions is shifting from "Who do we believe in?" to "What can we defend on paper?"
The New Geography of Advantage
The advocates of blind, quantitative admissions frame this shift as a return to fairness: no more preferences, no more proxies, just merit.
But what is "merit" in a data-only world?
SAT scores? We know they track closely with income. GPA? Subject to grade inflation and unequal school resources. AP course counts? A function of district wealth. Verified activities? More accessible in affluent communities where documentation is routine.
The anonymized application does not eliminate bias. It re-encodes it in machine-readable form.
And for applicants without polished resumes or digital breadcrumbs—first-generation students, immigrants, rural kids, and those whose stories were their strength—there are now fewer windows through which they can be seen.
In the name of neutrality, we may be building an admissions regime that is quietly the most class-stratified in modern history.
The Commercial Realignment
This policy shift will not just reshape universities. It will rearrange the entire education economy.
Winners:
- The SAT and ACT, and test prep firms - the usuals like The Princeton Review and Kaplan, will see renewed demand as test scores reclaim their centrality. State-specific assessments or those specific to an academic-field may appear, especially in STEM-focused admissions.
- AI-driven tutoring platforms like Khanmigo, Socratic and Squirrel AI that deliver personalization of concept mastery, slashing prep time.
- Credential verification services, perhaps with blockchain-backed systems down the road, to verify activity claims in the absence of essays or letters. Parchment, Credly… perhaps even National Student Clearinghouse?
- Admissions analytics firms that build scoring rubrics that help universities build legally defensible point-based reviews. Perhaps Niche will pivot to serve institutions as well as consumers.
Losers:
- College counseling generally, will lose much of its relevance. This includes the in-house counselor at high schools, large players like Crimson, and hundreds of independent experts. Essay coaching providers like prompt.com and Collegewise in particular, will collapse, as personal statements disappear or become dangerously constrained. (Full disclosure: my amazing wife is an experienced college counselor).
- Video interview platforms like Kira Talent, Spark Hire and VidCruiter will need to hard pivot to the corporate market.
- DEI consulting firms, especially those focused on admissions offices as their clients, will either pivot to some remaining corporate clients, or fold outright. Some may even pivot to auditing institutional compliance for lack of DEI considerations!
- Holistic CRM platforms like Slate, built to manage narrative-based review processes will rapidly become obsolete.
This is a gold rush for quantifiers.
And an extinction event for storytellers.
What This Means for Higher Ed Institutions
No two colleges face this landscape in quite the same way. Selectivity tier, applicant demographics, regional context, mission orientation—these factors all shape the risks and strategic options ahead.
For some institutions, especially those with large endowments or highly selective admissions, the imperative is legal defensibility. Admissions practices must now pass not just internal review, but the imagined scrutiny of a federal investigation where potential penalties carry hundreds of millions of dollars worth of consequence.
For others, particularly regional universities or mission-driven institutions, the challenge is different: how to preserve a commitment to access and context when the tools to see applicants fully are being removed. Will this erode HBCUs’ ability to serve their historic mission?
This entire scheme is being driven by the current administration’s desire to ensure ‘merit’ prevails at highly selective institutions. But there are no more than 200 of those institutions even though they receive most of the attention.
A more complex reality acknowledges there are ~3,500 degree-granting institutions, and for many, there isn't necessarily more supply than demand.
Going forward, selective and less-selective institution alike will lack the tried and tested tools of their trade to gauge student interest, commitment and ‘fit’. This carries major implications for enrollment and yield management.
Many institutions will struggle with this for several years, until they collect enough datapoints to understand the impact of the new system.
Others may seek external expertise to design strategies, systems and models.
There are no one-size-fits-all solutions. But tailored strategies are possible:
- Rebalancing scoring systems to incorporate rigor-adjusted GPA models and predictive validity studies
- Rebuilding yield models to account for anonymization, which reduces yield prediction accuracy by nearly 30%
- Reframing access goals using data inputs that remain permissible but still correlate with institutional mission
- Retooling donor narratives in the absence of essays that once served as story-rich touchpoints
These are not cosmetic changes. They are structural redesigns of how merit is defined, how diversity is pursued (if at all), and how risk is managed.
This will require strategic work that allows institutions to navigate uncertainty with custom diagnostics, sound frameworks, and decision-ready insights tailored to each institution's applicant pool, market position, and mission. We can help.
The Soul Question
Higher education has always lived in tension. It is meant to reward excellence, but also expand opportunity. To select, but also to serve.
The new meritocracy flattens those tensions. It reduces admissions to a system of defensible rules and quantifiable filters.
Even if that makes for sound policy, it makes for a thin and impoverished process.
Because behind every anonymized transcript and test score combo is a human being. And admissions officers will know even less about who they are.
Most businesses wouldn’t hire someone from a resume scan alone. If the job interview still matters, how can we pretend a student’s story doesn’t?
If an institution can no longer ask who a student is, it isn’t selecting for potential.
It’s filtering for compliance.
A blindfold doesn’t make you see more clearly.
