Updating Federal Policy to Ensure That Hispanic-Serving Institutions Are Serving Latino Students

In our last blog post, we outlined what it means to be a Hispanic-Serving Institution (HSI) and how HSIs can better serve Latino students. In this blog post, we’ll look at how Titles III and V of the Higher Education Act of 1965 (HEA), which define HSIs and outline federal competitive funding for these institutions from the U.S. Department of Education (Education), can be updated to ensure that all HSIs meet the needs of their Latino students.

The HEA authorizes various federal assistance programs that provide aid and resources to higher education students and institutions. Under Titles III and V of the HEA, the Department of Education provides direct grants via multiple programs such as the Strengthening Institutions Program and the Developing Hispanic-Serving Institutions Program to colleges and universities that enroll large concentrations of students of color and students from low-income backgrounds.

The aim of these provisions is to provide federal funds to institutions for the purpose of “equalizing educational opportunity” for students of color and students from low-income backgrounds. Three competitive grant programs provide aid to colleges and universities that are designated as Hispanic-Serving Institutions — which are nonprofit institutions with a full-time equivalent (FTE) undergraduate student enrollment that is at least 25% Hispanic; have a student body where at least 50% of students receive federal financial assistance; and have low expenditures per student.

HSIs that meet this definition per HEA Title V must apply to the US Department of Education to receive official federal designation as an HSI. Once an institution receives the federal HSI designation, the institution can apply for the following federal competitive HSI grants outlined in HEA Titles III and V: the HSI STEM and Articulation Program (Title III, Part F); the Developing HSIs Program (Title V, Part A); and the Promoting Postbaccalaureate Opportunities for Hispanic Americans (PPOHA) Program (Title V, Part B). Institutions can apply for and receive funding from all three HSI programs simultaneously.

These programs were designed to ensure “that Hispanic students have an equal opportunity to pursue postsecondary opportunities.” While the mission of these programs continues to be necessary, the number of Latino students pursuing a higher education has skyrocketed, and as a result, there’s been an increase in the number of higher education institutions that are eligible for federal competitive HSI funds. Latino students now make up 1 in 5, or 20%, of all students enrolled in higher education, up from 1 in 10 or 10% of all students in 2000. In fall 2021, there were 571 higher education institutions that met the 25% undergraduate student enrollment threshold outlined in the federal HSI designation, up from 216 in 2000.

While academic scholars like Gina Garcia, a professor of education at the University of California, Berkeley, have created organizational frameworks to help higher education institutions transform their infrastructure to produce more equitable outcomes for Latino students, federal policy — under HEA Titles III and V — has yet to incorporate measures that would ensure that institutions use federal competitive HSI investments to serve Latino students and ensure their holistic success during and after college by centering racial identity, equity, and consciousness. Currently, federal competitive HSI program key performance measures, grant proposals, and mandatory grantee interim/annual performance reports don’t require grantees to demonstrate how federal HSI investments are being used to transform organizational practices and policies to center Latino students. We urge federal policymakers to change that and incorporate empirically developed metrics of “servingness” in competitive HSI programs to ensure that Latino students are receiving an equitable and liberatory postsecondary education.

Titles III and V have the potential to be powerful tools to encourage HSIs to better serve the Latino students they enroll and hold these institutions accountable. Requiring institutions that receive federal competitive HSI grant investments to track and meet metrics for servingness would help ensure that Latino students are able to capitalize on the economic, social, and personal benefits of earning a college degree and become healthy, engaged, and active citizens in a society that’s still grappling with discrimination against minoritized communities.

Updating Grant Applications for Federal Competitive HSI Funding to Encourage Servingness

The Department of Education has already outlined some key performance measures (linked below) to assess the effectiveness of federally funded HSI programs. Unfortunately, these are simply broad measures of effectiveness, and not institution-specific performance measures that could be used to hold higher education institutions receiving federal funds accountable; institutions are not required to demonstrate that the funds they’ve received are leading to a more equitable and liberatory education for Latino students. The U.S. Department of Education could and should require HSI program applicants for federal HSI competitive funding to include performance measures for servingness in their applications and describe how their proposal will transform organizational practices and policies for servingness. The Department should also require grantees to report on progress toward performance goals and benchmarks and organizational practice and policy improvements in their mandated interim and annual performance reports.

1. Require Applicants to Share How their Proposed Program Activities Will Lead to Institutional Transformation Centering Latino Students. We provide a list of recommended transformation measures for each federal competitive HSI program below.
2. Require Applicants to Outline Servingness Performance Measures for their Proposed Program. We provide a list of recommended project-specific performance measures for each federal competitive HSI program below.

HSI grant applicants should determine which of our recommended measures to include in their federal grant applications, based on their proposed grant activities and the needs of the diverse population of Latino students within their unique institutional environment.

Based on the current key performance measures for the HSI STEM and Articulation Program (HEA Title III, Part F) for assessing the effectiveness of the HSI STEM and Articulation Program under 34 CFR 75.110, we recommend the following project-specific performance measures for the HSI STEM and Articulation Program in the HSI STEM and Articulation grant application:

Transformation Measures

1. Develop a Hispanic-serving mission for the institution’s STEM department and proposed HEA Title III, Part F-funded project that centers Latino students and includes a specific commitment to serving them.
2. Develop a plan for recruiting and retaining STEM faculty of color and faculty that match the composition of students served by the grant.
3. Develop a plan for implementing curricular and co-curricular change across the STEM disciplines engaged in the funded program.
4. Require professional development for all STEM faculty on learning to understand, recognize, and disrupt microaggressions in the classroom and their courses.

Academic Outcomes for Latino Students

1. Measure the percentage change in the number of Latino degree-seeking students in STEM fields at the institution over the five-year grant period. The number of Latino degree-seeking students in STEM fields should be equal to or greater than the share of students from other demographic groups in STEM majors at the institution.
2. Measure the number and percentage of Latino degree-seeking students in STEM that enter the STEM workforce or are enrolled in STEM postbaccalaureate programs after college completion.
3. Measure salary earnings for Latino STEM degree graduates and their ability to repay their student loans after college completion.
4. Measure the number and percentage of Latino degree-seeking students in STEM that conducted STEM research alongside diverse faculty, administrators, and staff at their home institutions and at partnering program institutions.

Nonacademic Outcomes for Latino Students

1. Measure the number and percentage of Latino degree-seeking students in STEM that reported having positive experiences in their STEM department.
2. Measure the number and percentage of Latino degree-seeking students in STEM that participated in professional STEM associations and student organizations that are inclusive and representative of underrepresented students in STEM (e.g., the Society for Advancement of Chicanos/Hispanics and Native Americans in Science).
3. Measure the number and percentage of Latino degree-seeking students in STEM that participated in immersion opportunities through work, internships, and study-abroad opportunities that allowed them to engage with the Latino community.
4. Measure the number and percentage of Latino degree-seeking students in STEM that said they developed a positive STEM identity in relation to their racial, ethnic, and/or Indigenous identity.

Based on the current key performance measures for the Developing HSIs Program (HEA Title V, Part A) for assessing the effectiveness of the DHSI Program under 34 CFR 75.110, we recommend the following project-specific performance measures for the Developing HSIs Program in the Developing HSIs grant application:

Transformation Measures

1. Develop a Hispanic-serving mission for the institution and proposed project that centers Latino students and includes a specific commitment to serving them and their families.
2. Develop a plan for recruiting and retaining faculty and administrators of color to match the composition of the student body on campus.
3. Develop a plan for implementing curricular and co-curricular changes across the disciplines addressed by the proposed HEA Title V, Part A-funded project to enhance liberatory experiences and outcomes for students.
4. Require professional development for all faculty on learning to understand, recognize, and disrupt microaggressions in the classroom and their courses. Federal grant requirements for this performance measure would override state laws that outlawed diversity, equity, and inclusion initiatives at higher education institutions.

Academic Outcomes for Latino Students

1. Measure the percentage change in the number of Latino degree-seeking undergraduate students at the institution over the five-year grant period. The number of Latino degree-seeking undergraduate students should be equal to or greater than the number of Latinos in the locality in which the institution is based.
2. Measure the number and percentage of Latino degree-seeking undergraduate students retained from their first to second year.
3. Measure the number and percentage of Latino degree-seeking undergraduate students that enter the workforce or enroll in postbaccalaureate programs after completing college.
4. Measure earnings for Latino undergraduate degree-earners and their ability to repay their student loans after completing college.

Nonacademic Outcomes for Latino Students

1. Measure the number and percentage of Latino degree-seeking undergraduate students who report positive campus climate experiences.
2. Measure the number and percentage of Latino degree-seeking undergraduate students detailing cultural and linguistically validating experiences on campus.
3. Measure the number and percentage of Latino degree-seeking undergraduate students who have developed or furthered their racial-ethnic-Indigenous
4. Measure the number and percentage of Latino degree-seeking undergraduate students participating in political engagement activities as part of their curriculum.

Based on the current key performance measures for the Promoting Postbaccalaureate Opportunities for Hispanic Americans (PPOHA) Program (Title V, Part B) for assessing the effectiveness of the PPOHA Program under 34 CFR 75.110, we recommend the following project-specific performance measures for the PPOHA Program in the PPOHA Program grant application:

Transformation Measures

1. Develop a Hispanic-serving mission for the institution and HEA Title V, Part B-funded program that centers Latino students and includes a specific commitment to advancing their graduate degree attainment.
2. Assess barriers leading to inequities in graduate enrollment for Latino students and develop a plan for recruiting Latino graduate students.
3. Develop a plan for implementing graduate-level curricular and co-curricular changes to enhance the nonacademic and academic outcomes of graduate students and liberatory experiences on campus.
4. Require professional development for all graduate level faculty on learning to understand, recognize, and disrupt microaggressions in the classroom and their courses.

Academic Outcomes for Latino Students

1. Measure the percentage change in the number of Latino degree-seeking postbaccalaureate students at the institution over the five-year grant period. The number of Latino degree-seeking postbaccalaureate students should be equal to or greater than the number of students from other demographic groups enrolled in postbaccalaureate degree programs at the institution.
2. Measure the number and percentage of Latino degree-seeking postbaccalaureate students that were retained from their first to second year.
3. Measure the number and percentage of Latino degree-seeking postbaccalaureate students entering the workforce after completion.
4. Measure salary earnings for Latino postbaccalaureate degree-earners and their ability to repay their student loans after college completion.
5. Measure the number and percentage of Latino degree-seeking postbaccalaureate students that conducted research alongside diverse faculty, administrators, and staff.

Nonacademic Outcomes for Latino Students

1. Measure the number and percentage of Latino degree-seeking postbaccalaureate students engaged in professional mentorship opportunities with minoritized professionals in their field of study.
2. Measure the number and percentage of Latino degree-seeking postbaccalaureate students that reported having positive graduate school experiences, including cultural and linguistically validating and empowering experiences.
3. Measure the number and percentage of Latino degree-seeking postbaccalaureate students that participated in research, internship, and fellowship opportunities that allowed them to engage with the Latino community.
4. Measure the number and percentage of Latino degree-seeking postbaccalaureate students that participated in professional associations that have a support network for graduate students of color.
5. Measure the number and percentage of Latino degree-seeking postbaccalaureate students that said they developed a positive scholarly and research self-concept.