NASFAA Creates Toolkit to Reduce Implicit Bias in Financial Aid Policies

When Michael Birchett first started reading Satisfactory Academic Progress appeals as a financial aid administrator, he came across one student who was unable to attend class for an extended period due to a flat tire.

As someone who grew up in a middle-class family, he thought the reasoning was “silly” at first.

Dr. Christina TangalakisDr. Christina Tangalakis

But, after noticing cars in neighborhoods with flat tires not moving for months, Birchett, the director of financial aid counseling and outreach at the University of Kentucky, realized not everyone has money on hand to fix those issues immediately.

This is just one example of implicit bias that can exist at the institutional level, said Birchett.

“If you don’t have very diverse groups of folks from different backgrounds or socioeconomic levels looking at things and being able to actually empathize with students, you are not really making very good appeal decisions for those students,” he said.

To mitigate the negative impact of implicit bias, specifically in college financial aid offices, the National Association of Student Financial Aid Administrators (NASFAA) published the “Implicit Bias Toolkit.”

The toolkit offers best practices to financial aid administrators to address biases in policies related to institutional forms, communication, cost of attendance, scholarships, student worker programs, verification and professional judgment.

“It really challenges assumptions, challenges those biases and helps direct people on the critical steps to take to neutralize some of those forces,” said Dr. Christina Tangalakis, associate dean of student financial aid services at Glendale Community College and co-author of the toolkit.

She said that to make institutional changes, individuals must first recognize their own biases—which extends beyond race and ethnicity. Assessments, such as the Harvard Project Implicit Bias Test, are available online as an educational tool.

She said that learning can also take place by having conversations with others from different backgrounds, challenging underrepresentation in work environments, reading articles and participating in implicit bias training sessions.

“We all carry our own biases that are based on the life that we have lived and the things that we have been exposed to,” said Dana Kelly, vice president of professional development and institutional compliance at NAFSAA.

She added, “the realization that biases can be both positive and negative and the more aware you are of your own bias, the more likely you are to consider it whenever you are making policy decisions that impact a wide range of individuals.”

At the institutional level, the toolkit recommended financial aid offices reevaluate its forms to ensure inclusive language is used. For example, forms should use phrasing such as “parent 1” and “parent 2” rather than “mother” or “father” and gender-neutral pronouns.

Dana KellyDana Kelly

They recommend that both forms and scholarship applications be accessible to all students. Offering only online applications, for example, can be a barrier for those without access to technology or broadband internet.

“By making it an online form only, you have assumed that everyone has easy access to the online environment and those who don’t are likely to fall into a socioeconomic class that the scholarship itself would benefit,” said Kelly. “It was done inadvertently but you didn’t consider that it would negatively impact those without clear access to the process you just created.”

To bring more clarity to the scholarship selection process, institutions can implement rubrics for students and committee members. Applicant and recipient data can also be utilized to track trends and determine potential biases, according to the toolkit.

For financial aid offices, communication is key as it “builds trust, prevents or resolves problems, creates better relationships, provides clarity and direction, increases engagement, improves productivity and promotes team building,” the report noted.

Apart from scholarships, the Federal Work-Study (FWS) program provides another way for students to pay for college, though many are often unaware of the eligibility requirements. The toolkit recommends that colleges and universities focus on maintaining student outreach, including establishing ambassador and tutoring positions with FWS funding to assist with outreach efforts.

In terms of cost of attendance, the toolkit recommends separate budgets for categories of students with different circumstances and suggests that institutions survey their students to acquire cost and budget data.

The report suggested that appeal decisions be determined by diverse committees consisting of employees inside and outside financial aid offices. This can include diversity officers, faculty and staff. Additionally, institutions need to identify marginalized populations to make them aware of available appeal options, the report suggested.

“If you can go into every situation under the assumption that you carry certain preconceptions into a room with you, I think it starts kind of a lifelong journey of learning about yourself and learning how to compensate for those things,” said Birchett, who is also co-author of the toolkit.

Sarah Wood can be reached at swood@diverseeducation.com.