Policy rhetoric, realities, and burdens: Using critical policy analysis to center at-promise student success in the McNair program Journal website: http://epaa.asu.edu/ojs/ Manuscript received: 27/4/2024 Facebook: /EPAAA Revisions received: 12/9/2024 Twitter: @epaa_aape Accepted: 21/10/2024 education policy analysis archives A peer-reviewed, independent, open access, multilingual journal Arizona State University Volume 32 Number 71 November 12, 2024 ISSN 1068-2341 Policy Rhetoric, Realities, and Burdens: Using Critical Policy Analysis to Center At-Promise Student Success in the McNair Program1 Nathan A. Hutcherson & Raquel Muñiz Boston College United States Citation: Hutcherson, N. A. & Muñiz, R. (2024). Policy rhetoric, realities, and burdens: Using critical policy analysis to center at-promise student success in the McNair program. Education Policy Analysis Archives, 32(71). https://doi.org/10.14507/epaa.32.8715 Abstract: Educational policies designed to benefit students from first-generation, low-income, and racially minoritized backgrounds do not always consider the realities these students experience during college. Instead, students participating in compensatory education programs can endure further marginalization. Using critical policy analysis’ core tenets as guiding principles to frame our study and guide our analysis, we conducted a three-phase qualitative analytic study. We examined interviews with students and McNair program policy documents to interrogate policymakers’ hidden assumptions and the (de)centering of minoritized student perspectives in the McNair program policy. Students in the program discussed varied and conflicting definitions of success, such as learning they did not want to attend graduate school—a primary goal and measure of success for the federal government. They also highlighted advisors as a source of support. By centering the 1 This project was supported by Boston College's Research Incentive Grant and Research Expense Grant. http://epaa.asu.edu/ojs/ https://doi.org/10.14507/epaa.32.8715 Education Policy Analysis Archives Vol. 32 No. 71 2 experiences of students, our findings highlight this critical gap and draw attention to the administrative burdens placed on at-promise students, emphasize the need for holistic socio- emotional support in federal policy, and underscore the powerful role of supportive faculty and staff. Keywords: critical policy analysis; at-promise students; student success; administrative burdens; McNair Retórica política, realidades y cargas: Uso del análisis crítico de políticas para centrar el éxito de los estudiantes at-promise en el programa McNair Resumen: Las políticas educativas diseñadas para beneficiar a estudiantes de primera generación, de bajos ingresos y de grupos raciales minorizados no siempre consideran las realidades que estos estudiantes experimentan durante la universidad. En cambio, los estudiantes que participan en programas de educación compensatoria pueden sufrir una mayor marginación. Utilizando los principios fundamentales del análisis crítico de políticas como guía para enmarcar nuestro estudio y orientar nuestro análisis, realizamos un estudio analítico cualitativo en tres fases. Examinamos entrevistas con estudiantes y documentos de política del programa McNair para interrogar las suposiciones ocultas de los responsables políticos y la (des)centralización de las perspectivas de estudiantes minorizados en la política del programa McNair. Los estudiantes en el programa discutieron definiciones variadas y conflictivas de éxito, como aprender que no querían asistir a la escuela de posgrado, que es un objetivo principal y medida de éxito para el gobierno federal. También señalaron a los asesores como una fuente de apoyo. Al centrar las experiencias de los estudiantes, nuestros hallazgos destacan esta brecha crítica y llaman la atención sobre las cargas administrativas impuestas a los estudiantes en situación de vulnerabilidad, enfatizan la necesidad de un apoyo socioemocional integral en la política federal y subrayan el papel fundamental de profesores y personal de apoyo. Palabras-clave: análisis crítico de políticas; estudiantes at-promise; éxito estudiantil; cargas administrativas; McNair Retórica política, realidades e encargos: Usando análise crítica de políticas para centralizar o sucesso dos alunos at-promise no programa McNair Resumo: As políticas educacionais projetadas para beneficiar estudantes de primeira geração, baixa renda e de grupos raciais minorizados nem sempre consideram as realidades que esses estudantes enfrentam durante a universidade. Em vez disso, os estudantes que participam de programas de educação compensatória podem sofrer uma marginalização adicional. Utilizando os princípios fundamentais da análise crítica de políticas como orientação para estruturar nosso estudo e guiar nossa análise, realizamos um estudo analítico qualitativo em três fases. Examinamos entrevistas com estudantes e documentos de políticas do programa McNair para questionar as suposições ocultas dos formuladores de políticas e a (des)centralização das perspectivas dos estudantes minorizados nas políticas do programa McNair. Os estudantes do programa discutiram definições variadas e conflitantes de sucesso, como descobrir que não queriam cursar a pós-graduação, que é um objetivo principal e medida de sucesso para o governo federal. Eles também destacaram os orientadores como uma fonte de apoio. Ao centrar as experiências dos estudantes, nossos achados destacam essa lacuna crítica e chamam a atenção para os encargos administrativos impostos aos estudantes vulneráveis, enfatizam a necessidade de um apoio socioemocional holístico nas políticas federais e ressaltam o papel fundamental dos professores e funcionários de apoio. Palavras-chave: análise crítica de políticas; alunos at-promise; sucesso estudantil; encargos administrativos; McNair Policy rhetoric, realities, and burdens 3 Policy Rhetoric, Realities, and Burdens: Using Critical Policy Analysis to Center At-Promise Student Success in the McNair Program “I don’t think we should see [not getting a Ph.D.] as a failure, even though I guess the program [that is] giving us money see[s] it as a failure.” For Ian, a Mexican-American, first- generation college student in the Ronald E. McNair Postbaccalaureate Achievement Program (McNair), a federal program designed to prepare undergraduate students for doctoral programs, success in the program has varied meaning. When asked what success for the McNair program is, he responded, “for the government, I guess it’s Ph.D. students….” But when asked how he defined success in the program, he said, “for us in the cohort, it’s just having the [research] paper done… how well we can do on our paper… [and] getting through the program is something that we’re proud of.” So, for Ian, as for many participants in the McNair program, there is a difference between the federal government’s definition of success and students’ definition of success in the program. These differences can create barriers to students’ personal and academic success, which is antithetical to the program’s overarching goals to prepare and increase the number of underrepresented students in graduate education. The McNair program prepares undergraduates from underrepresented backgrounds to pursue and attain an advanced degree to enter careers in research and academia (Office of Postsecondary Education, 2024a). McNair programs engage promising minoritized2 students in research activities and mentorship toward graduate school. Generally, students from first-generation, low-income, and ethnic/racially minoritized backgrounds, or collectively “at-promise” students,3 qualify for participation in the McNair program (Kezar et al., 2022). The federal government outlines specific requirements and metrics to measure an institution’s programmatic success, but broader conceptualizations of success are generally not included in these metrics (Office of Postsecondary Education, 2017). In a study examining students’ perceptions of success, Zepke et al. (2010) suggest a similar mismatch exists between the factors students identify as mediating their success (e.g., family and finances) from the factors that policymakers promote as influencing student success. Through a qualitative critical policy analysis of the McNair program, we identified multiple themes that expose the differences between how students perceive success is defined because of federal and institutional requirements and how students define success in the program, as well as the critical role of faculty and staff advisors in helping them navigate these differences. Previous studies capture the positive and negative experiences minoritized students have in the McNair program (Gittens, 2014; Hanson et al., 2016; Posselt & Black, 2012; Renbarger, 2019). This study centers at- promise students’ experiences as a source of expertise to critique the current policy and inform policy and practice, while acknowledging the important work of the McNair Scholars program (e.g., 2 In this study, we use “minoritized as opposed to the noun ‘minority’ . . .”, including racially minoritized, to describe “the process by which certain . . . groups are assigned minority status through the actions and non- actions of more dominating groups” and that leads to marginalization, “a dynamic process, rooted in power imbalance and systematically directed toward specific groups and individuals. Marginalization results in peripheral or disadvantaged unequal societal membership and disparate treatment for those specific groups and individuals” (internal quotations omitted, Wright et al., 2023, p. 14). 3 We join with scholars in using the term “at-promise” when referring to students from first-generation, low- income, and racially minoritized backgrounds (Kezar et al., 2022). This framing emphasizes students’ strengths and shifts away from the deficit framing language of the “at-risk” moniker. Education Policy Analysis Archives Vol. 32 No. 71 4 Renbarger et al., 2021a). Aligned with a long legacy of critical scholars across fields (Crenshaw, 1991; Stefancic, 2013), including in education (Ladson-Billings, 1998; Welton et al., 2023), a critical approach, where we center the perspectives of at-promise students, is prioritized in this study to offer a nuanced perspective on a well-established federal program. In doing so, our goal is to center marginalized students’ voices and offer meaningful feedback based on their voices and experiences. The implications of this critical inquiry can further strengthen the program to better serve students in a way that builds on the important work and contributions the program has on the students’ lives. One research question guided our study: “What do McNair students’ perceptions of federal program requirements and discussion of their personal definitions of success reveal about their experiences in the program and the policy itself?” By attending to the research question, and offering a novel methodological approach by using critical policy analysis as conceptual framework, we found student definitions of success were quite different from how the federal government defined success for students in the McNair program, as outlined in McNair program policy. This translated to fraught experiences where students felt heightened pressure from the same program staff that provided essential support. Additionally, we found faculty and staff advisors, who function as mentors in the McNair program, play a pivotal role in helping students navigate the aforementioned gap. The findings speak to the disconnect between federal policies and the students they are meant to serve, a vexing problem in higher education. The findings highlight the burdens placed on at-promise students due to misaligned policy structures, the importance of emphasizing holistic support for at-promise students in the federal policy governing the McNair program, and the powerful role faculty and staff advisors play in supporting at-promise students. Policy Context Federal Educational Policy Developments While the McNair program was first introduced toward the end of the 20th century, earlier concerns with educational quality and access motivated policymakers to enact new legislation. The context of these policy developments is necessary to better understand the roots, foundations, and assumptions embedded in the McNair program. The Higher Education Act (HEA) of 1965, a major piece of federal higher education legislation, was introduced to improve access and retention in higher education. This legislation established the TRIO programs, which provided outreach and student services programs to at-promise students. Years later, in 1983, the Reagan administration established the National Commission on Excellence in Education (NCEE) to assess the quality and state of education and provide recommendations for educational improvement (NCEE, 1983). Of particular relevance to our study is the way in which the NCEE’s (1983) recommendations shifted P-20 educational policy toward standards-based reform at a systemic level. In 1986, through the reauthorization of the HEA, Congress increased the scope of the original TRIO programs to include the McNair program and improve educational outcomes for low-income and racially minoritized students across the country (e.g., Gittens, 2014). The 1992 HEA reauthorization created additional regulations for the McNair program. Policymakers’ ideas about these added regulations are detailed in the 138 Congressional Record 2908 (1992) from February 21, which includes a transcript of the floor debate by members of the Senate. The transcript, which we analyze as part of this study, contains commentary on the 1992 reauthorization of the HEA and the adoption of outcomes-based standards more broadly. Congressional discourse reflected in this document provides context about the creation of programmatic goals for the McNair program, as well as other components in the proposed reauthorization legislation. Policy rhetoric, realities, and burdens 5 After the McNair program was established by Congress, further regulatory changes in 2010 defined the required and permissible services for McNair programs (Higher Education Act of 1965, 20 U.S.C. § 1070a-14). The legislation codified the preparation of underrepresented students for doctoral study as the singular focus of this program and outlined a specific set of evaluation measures. These measures for McNair programs were likely the result of policymakers’ long- developed perspectives about educational outcomes, where fixed measures were based on educational outcomes rather than broader conceptions of success that account for participants’ perspectives. Overview of the Current McNair Program Policy The U.S. Department of Education oversees the distribution of federal funds for McNair programs (approximately $45 million annually) and ensures programs report on evaluation measures and implement program-specific activities. Higher education institutions can apply for grant funding every five years (Office of Postsecondary Education, 2017). Through the program, institutions can provide a variety of resources and programming to support students, but their McNair programs are required to provide research opportunities, summer internships, seminars about doctoral study, academic counseling, and assistance and financial support in applying to graduate programs (Office of Postsecondary Education, 2022). While not required, McNair program administrators can also provide financial literacy programs, mentoring programs involving faculty members, as well as cultural activities (Office of Postsecondary Education, 2022). Like in most federal grant-funded programs, accountability and measurement through annual reporting ensures programmatic alignment with the aims and goals written into the legislation that established this program (Office of Postsecondary Education, 2017). Institutions that receive funding from the U.S. Department of Education Office of Postsecondary Education must submit annual reports about the activities and participants involved in the McNair program on their campus (Office of Postsecondary Education, 2017). Section I, Part 2 of the performance evaluation outlines the required and permissible services on which McNair programs are evaluated; additionally, staff must provide specific information regarding student research activity (e.g., “to what extent did the student participate in research activity”?) and graduate school enrollment status (e.g., “what type of assistantship did the first-year graduate student receive in this reporting period?”) (Office of Postsecondary Education, 2022, p. 11, 16). Based on these reports, the U.S. Department of Education annually reports two outcome measures for the McNair program to Congress: graduate school enrollment and graduate school persistence (Office of Postsecondary Education, 2024b). We now turn to a review of the literature relevant to the experiences of at-promise students in higher education. Literature Review College student success is a widely discussed and well researched topic in higher education scholarship. Yet, policymaking endeavors often lack clear connections to this important work (Wiseman, 2010). A review of the literature on at-promise student success and critical perspectives on student success is helpful to understand how success is framed, what barriers exist in at-promise student success, and what helps at-promise students be successful, including the support offered in the McNair program. More specifically, identifying critical perspectives on student success can help identify potential equity gaps in the implementation of policy and (re)center the perspectives and experiences of students from historically minoritized populations. Education Policy Analysis Archives Vol. 32 No. 71 6 At-Promise Student Success First-generation college students, or students whose parents have not received a baccalaureate degree, comprise nearly a third of all college-going students (Higher Education Act of 1965; Ives & Castillo-Montoya, 2020). Yet, typically only half of this cohort will earn a degree within 6 years as compared to nearly 75% of students with a parent who attended college (Forrest Cataldi et al., 2018). Students from low-income families are also disadvantaged in attending college and graduate at lower rates than those coming from higher-income families (Bassett, 2021). Considering the intersectionality of these identities, scholars suggest degree attainment rates are even lower, with only 21% of low-income, first-generation college students earning a bachelor’s degree within 6 years, which is substantially lower than the average graduation rate for low-income, continuing-generation students (37%), and for higher-income, continuing-generation students (66%; Bassett, 2021). Racially minoritized students complete a bachelor’s degree at lower rates than White students due, in part, to systemic inequalities (e.g., exclusionary campus environments and limited social, emotional, and academic supports, etc., Erwin & Thomsen, 2021). These systemic inequities lead to disparate educational outcomes and prohibit equitable graduate school participation. An NCES report showed an even larger disparity between postbaccalaureate enrollment among White students (63%) and racially minoritized students (Black: 14%; Hispanic: 11%; Asian/Pacific Islander: 8%, and American Indian/Alaska Native: 1%; Husser et al., 2020, p. 136). Given these trends attributed to structural barriers, it is not surprising that at-promise college students are underrepresented among doctoral recipients (Renbarger et al., 2021b). Undergraduate-to-graduate school pipeline programs serve as an important and successful approach to increasing graduate school enrollment among at- promise students (e.g., Myers & Pavel, 2011; Stephenson -Hunter et al., 2021). To successfully improve the pipeline toward doctoral degree attainment, which the McNair program seeks to address, it is crucial to understand the barriers this group of students confront upon entering college. At-promise students are certainly not a monolithic group; the backgrounds, experiences, and dispositions of each student form unique opportunities and perspectives on their journey into and through higher education. For example, Burger and Naude (2018) found students’ backgrounds influenced their self-perceptions of academic success and that students’ definitions of success were, at times, at odds with institutional definitions or metrics of success. In another study, students reported that non-institutional factors, such as family, finances, and work commitments, were influential on their sense of success (Zepke et al., 2010). To better understand the nuanced experiences of at-promise students, it is important to employ critical frameworks (e.g., critical policy analysis and administrative burdens) that center at-promise students’ perspectives (Burger & Naude, 2018). Such frameworks are important, because as DeRosa and Dolby (2014) suggest the issues at- promise students face can have a deficit framing, “in which poor student outcomes are attributed to the shortcomings of the student,” both in the literature and in practice (p. 3). Using a variety of frameworks, including critical ones, scholars have identified common influences that shape the success of at-promise students, especially when these students possess multiple intersecting identities (e.g., first-generation and low-income and racially minoritized). These influences include financial factors and experiences of marginalization, especially when enrolled at predominantly White institutions (Adams & McBrayer, 2020; Bassett, 2021; Pascarella & Terenzini, 2005). Finances play an important role in at-promise students’ access to and success in higher education, including influencing what institution they choose to attend, their overall success during college, and their completion (Adams & McBrayer, 2020; Pascarella & Terenzini, 2005). For students from lower socioeconomic backgrounds, the costs of higher education, especially beyond tuition (housing, books, etc.), remain a barrier to student access and success, which is reflected in the Policy rhetoric, realities, and burdens 7 completion rates introduced above (DeRosa & Dolby, 2014). Financial aid award packages not only influence where students attend college but also are positively associated with their experiences during college (Adams & McBrayer, 2020). For instance, increased off-campus employment is associated with decreased persistence and graduation rates and the need to have constant employment to pay for school is detrimental for student success (Adams & McBrayer, 2020; Pascarella & Terenzini, 2005). At-promise students also often experience marginalization and isolation on college campuses, which significantly impacts their success during college. At-promise students from racially minoritized backgrounds often experience racial stereotyping and microaggressions, which diminishes their sense of belonging (Adams & McBrayer, 2020). Importantly, their experiences are not only tied to racialized institutional cultures but also to historical contexts of racial discrimination and economic elitism yielding unwelcoming campus environments (Gándara et al., 2023). Jayakumar and Museus (2012) propose that institutions with an inauthentic commitment to diversity (e.g., espousing support for diversity, while dismantling ethnic studies programs) negatively influence the experiences and outcomes of at-promise college students. Prior research on at-promise students indicates they might struggle to ask for help if they feel support resources (e.g., academic tutoring, mental health counseling) were not designed for them (Bassett, 2021). Other critical scholars note institutional policies play an important role in shaping educational access and success of at-promise students (DeRosa & Dolby, 2014; Museus, 2014). Therefore, it is important to review research showing the influence of the McNair program on at-promise students’ success. McNair’s Influence on At-Promise Student Success While the specific experiences of at-promise students participating in the McNair program varies by institution, research on the impact of this program suggests at-promise students benefit both academically and personally. As students work on research projects and attend graduate school application seminars, studies show a positive association between these activities and graduate school admission and enrollment when students graduate with their bachelor’s degree (Gittens, 2014; Renbarger & Beaujean, 2020; Renbarger et al., 2021a). In another set of studies, students reported feeling more prepared for graduate school and having improved presentation skills (Posselt & Black, 2012; Renbarger, 2019). By participating in the McNair program, students benefited personally from the development of new relationships with peers, as well as with faculty and staff (Gittens, 2014). These relationships are valuable for students since they provide encouragement, networking opportunities, support with financial struggles, and role models (Cokley, 2000; Hanson et al., 2016; Renbarger et al., 2021b). Together, these studies highlight the importance of graduate school preparation and support networks for at-promise students. While the majority of research on the impact of the McNair program is positive and lays a strong foundation regarding the important and vital work of the program (e.g., Renbarger et al., 2021a; Renbarger & Beaujean, 2020), only a few studies highlight the obstacles students face while in the program. Across multiple studies, students reported feeling intimidated and overwhelmed by being among high-achieving peers (Posselt & Black, 2012), and feeling underprepared for graduate school, struggling with finances, and not feeling accepted while in graduate school (Willison & Gibson, 2011; see also Renbarger, 2019). Another study found McNair students’ enrollment in graduate school differed by racial/ethnic groups and by gender, suggesting that students’ intersectional identities meaningfully influence their experience in and throughout the program, with White and Black/African-American males yielding higher enrollment rates than Black females (Breen & Newsome, 2022). So, while the McNair program provides beneficial opportunities for at- promise students to develop academically and personally, the same opportunities can also become an obstacle for their success. While current research focuses on whether McNair is effective in Education Policy Analysis Archives Vol. 32 No. 71 8 increasing the number of students applying to and preparing for doctoral programs, there is a lack of research examining the McNair policy from a critical perspective. In this study, we apply a critical lens by interrogating how federal measures of success in the program shape student’s experiences as they progress and develop through the program and map their post-graduation pathways. In doing so, we center students’ perspectives to identify gaps in policy design and implementation. The findings point to areas of policy that can be strengthened to better support at-promise students in this crucially important federal program. Conceptual Framework We used the core tenets of critical policy analysis (CPA) as guiding principles to frame our study and guide our analysis. To further expand on one of the tenets of CPA, Gándara et al.’s (2023) administrative burdens in higher education policy framework (‘administrative burdens’) helped us make sense of the data as students’ tensions with federal policy emerged during analysis. We describe these in detail next. CPA outlines the following tenets: (a) analyzing policies’ roots, foundations, and assumptions; (b) paying attention to differences between policy rhetoric and reality; (c) highlighting the distribution of power, resources, and knowledge; (d) exploring the effect policies have on (in)equity, (in)equality, and privilege; (e) and, ensuring racially minoritized and underrepresented individuals’ and groups’ perspectives are centered (Diem et al., 2014; see also Diem & Brooks, 2022; Martínez-Alemán, 2015). Each tenet offers a distinct vantage point on the policymaking process and the implementation of enacted policies. For instance, by analyzing policies’ roots, scholars can identify the historical developments preceding the legislation of a policy and better understand the context in which it was implemented, exposing how these might (mis)align with equity. Further, each tenet of CPA is intertwined and therefore collectively useful for policy analysis. Scholars have used CPA’s tenets to inform methodological decisions, including identifying a suitable theoretical framework (e.g., Carpenter et al., 2014; Castro et al., 2022; Diem & Brooks, 2022; Diem et al., 2014; O’Malley & Long, 2017). Apple (2019) notes the value and potential of CPA to give theoretical direction and aid the analysis itself, since CPA is “grounded in the belief that it is absolutely crucial to understand the complex connections between education and the relations of dominance and subordination in the larger society” (p. 276). This belief undergirds our use of the tenets. Traditional methods of policy analysis often do not go far enough to uncover inequity (Chase et al., 2014). In contrast, analyzing the roots, intentions, and assumptions embedded in policies can reveal whether those policies are benefiting underrepresented students or not (Apple, 2019; Diem et al., 2014). CPA also provides a lens to “illuminate the ways in which power operates through policy by drawing attention to hidden assumptions or policy silences and unintended consequences of policy practices” (Allan et al., 2010, p. 24). This form of policy analysis considers how the intentions of policies might be overlooked or how policies can have unintended consequences and negative side effects on those the policies seek to benefit (Diem & Brooks, 2022). CPA interrogates not only whether a policy produces effective outcomes but also how the policy might be furthering social inequities and systemic barriers through policymakers’ assumptions about educational outcomes and success in practice (Diem et al., 2014). To further explore the fourth tenet (exploring the effect policies have on (in)equity, (in)equality, and privilege), we drew on Gándara et al.’s (2023) administrative burdens framework to make sense of students’ experiences. Administrative burdens are the organizational practices and processes—produced through policy implementation—that prevent intended beneficiaries from reaping the benefits of the policy, such as resources and services (Herd & Moynihan, 2018). Policy rhetoric, realities, and burdens 9 Administrative burdens not only prevent access to public goods but also create systemic barriers to policy benefits, especially for racially minoritized individuals (Gándara et al., 2023). And within higher education, administrative burdens can impact multiple stakeholders, including faculty, staff, and students. In their framework, Gándara et al. (2023) contextualize three types of administrative burdens, or costs, to higher education that we use in tandem with CPA to guide our study. These costs are: (a) learning about a policy, its eligibility requirements, and potential benefits (e.g., financial aid eligibility); (b) complying with a policy’s rules and requirements to maintain eligibility and access to benefits (e.g., maintaining minimum grade point average requirements for financial aid); and, (c) facing the psychological and emotional burdens of accessing and maintaining policy requirements and benefits. Guided by CPA’s core tenets and the three costs of administrative burdens, we began the study with the assumption that McNair provided important support to the students, and that the students could experience inequities as well. Then, the core tenets and costs drew our attention to specific aspects of the policy and its implementation (see Table 3, columns one and two). More specifically, we considered the program policy’s roots, foundations, and assumptions, as well as its current mandates and requirements—the policy rhetoric. Focusing on at-promise students’ perspectives and lived experiences (their reality), we interrogated embedded inequities and costs in the policy rhetoric and its implementation. This enabled us to identify where students were centered or burdened and in what ways the program policy can be strengthened to further support them. To this end, CPA and administrative burdens provide lenses to consider how the policy accounts for students’ expressed needs in the allocation of resources and the (de)centering of at-promise student perspectives in federally-structured definitions of success for the McNair program. Aligned with CPA’s commitment to center minoritized populations, we amplify and center the voices of historically minoritized students in this study. We attended to these critical areas in our analysis by operationalizing the tenets as part of our initial set of codes, and using the tenets as orientation during the iterative analysis process, including the comparative process we employed in the third phase of analysis. In this phase, we compared the policy rhetoric to the students’ lived experiences (their reality). We describe this process in detail below. Methodology Cordeiro and colleagues (2017) suggest that “methods spell out the ‘action’ of the research, the techniques that are used to gather and analyze the data,” whereas “methodology poses the theoretical [or conceptual] framework of the research or project in order to increase understanding of what stance the researcher is taking when designing the research” (p. 399). So, methodology provides a unifying link between theory and methods by clarifying the assumptions underlying the study (Cordeiro et al., 2017). We employed a critical qualitative approach, using CPA tenets and administrative burdens as guiding principles to frame our study and analyze our data. CPA enabled us to interrogate the differences between policymakers’ and at-promise students’ assumptions and definitions of success. Administrative burdens enabled us to expand on CPA’s fourth tenet to consider what costs students bear as they experience the implementation of McNair program policy. Using our conceptual framework to guide analysis, we analyzed data from student interviews, the McNair policy, and congressional discourse about the policy. We view the policy creation and implementation process critically, based on our assumptions that these processes do not always have equitable outcomes for minoritized people, such as people of color, and because policy actors developing the policies typically occupy a dominant role in society (Cordeiro et al., 2017; Horsford, 2019). We engaged a critical approach and a reflexive process throughout the study to see the way policies (re)produce outcomes of inequity and power Education Policy Analysis Archives Vol. 32 No. 71 10 imbalance for at-promise students (Allan et al., 2010; Martin et al., 2022). CPA, as a critical lens, functions as both a conceptual framework and an analytical tool to expose the decentering of minoritized populations, specifically people of color, and does so by interrogating a particular policy or practice (Horsford, 2019; Howarth, 2010). From this perspective, we now describe the institutional context of the study before turning to the actions taken (i.e., methods) and processes we engaged to answer the research question that guided our study: What do McNair students’ perceptions of federal program requirements and discussion of their personal definitions of success reveal about their experiences in the program and the policy itself? Institutional Context In this study, we focused on the experiences of at-promise students in a McNair program housed at a private research-intensive university in the Northeast of the United States (hereafter, Northeast College). Northeast College has an average undergraduate enrollment of approximately 9,500 students. Approximately 35% of undergraduate students at Northeast College identify as racially minoritized students, including African, Hispanic or Latinx, Asian, and Native American students. Northeast College received its first federal grant for the McNair program in the early 2000s, and the program has operated continuously since its inception. The College’s McNair program supports approximately 25 participants each year. Importantly, it was the only federally-funded TRIO program offered at the institution at the time the data were collected. Data Collection We collected the data in this study as part of a larger grant-funded project that was focused on systemic change and examined how, if at all, programs in higher education, like the McNair Scholars Program, further equity for minoritized students. Prior to the IRB-approved study, the lead researcher of the project built rapport and trust with the program leaders by building relationships and learning about the multiple aspects of the work that the office furthers to support underrepresented college students (Bhattacharya, 2021). The larger project was born in collaboration and discussion with the office staff leaders. The relationship made the research project possible, as the research team learned alongside the program staff and the students. While we entered the project without assumptions about the gaps between policy and student experiences, throughout the overall project, it became clear that the students experienced the program in unique ways that called attention to the limitations of the federal policy and need for policy change to enable practices that support students. While we focus on the tensions that students surfaced in their discussions, elevating the voices of the students and centering their perspectives, the students shared a range of experiences that reflected the complexity of being part of a program dedicated to supporting their undergraduate experiences while also preparing them to enter graduate school. Thus, in this article, we focus on the students’ needs as we consider their success. The data comprise 10 one-on-one in-depth interviews with students in the institution’s McNair Program (see Table 1). All but one of the students interviewed were first-generation college students and 9 of the 10 participants identified as racially minoritized students of color. The student interviews elicited participants’ experiences in the program (“what has support looked like in the program?”), their perceptions of the program’s goals regarding their participation therein (“how do you think the program defines success?”), their descriptions of what success can look like (“how could success in the program be defined?”), and the participants’ challenges in the program (“what challenges, if any, have you faced while in the program?”). The interviews concluded with an opportunity for participants to describe their gender or sex, race/ethnicity, and status as a first- generation college student. We include the verbatim identities students provided in our findings as a Policy rhetoric, realities, and burdens 11 way to center and honor these individuals, which reflects our belief in the importance of situating identities authentically in research. The interviews, which were conducted in Fall 2019, lasted between 60-90 minutes and were transcribed verbatim with participant permission. Participants received a gift card for their participation. Table 1 Demographic Information about Student Participants Name Self-Identified Race/Ethnicity Self-Identified Gender/Sex Self-Identified First-Generation Status Alice Korean American Female Yes Ana Ecuadorian Female Yes Cassandra Mexican Woman Yes Danielle Kenyan American Female Yes Ian Mexican Man Yes Jackie Dominican Female No Julian Hispanic Male Yes Katrina Hispanic/Latina Woman Yes Larissa Black/Brazilian Female Yes Nick White Male Yes Note. Students’ racial/ethnic, gender/sex, and first-generation status represents the way each participant identified themselves at the conclusion of their interview. We do not conflate race and ethnicity, or gender and sex but rather honor participants’ verbatim responses. We used the McNair program policy as outlined in the 1992 reauthorization of the Higher Education Act of 1965 (HEA) and the 138 Congressional Record from session two of the 102nd Congress (see Table 2) to both contextualize the policy’s foundations and situate participants’ experiences and perceptions in the policy’s embedded assumptions. The 113-page transcript of the Senate floor debate in the Congressional Record provides policymakers’ commentary as they considered reauthorizing the HEA. We also used the 2020-2021 McNair program annual performance report supplied by the Department of Education to identify the policy’s measures of success. Education Policy Analysis Archives Vol. 32 No. 71 12 Table 2 Information about Policy Documents Document Source Year Number of Pages in Corpus McNair Program policy Higher Education Act of 1965, 20 U.S.C. § 1070a-14 1992 2 Senate floor debate on Higher Education Act 138 Congressional Record 2908 1992 113 McNair Program Annual Performance Report template Office of Postsecondary Education 2021 19 Coding and Analysis We coded the data qualitatively in three phases through an iterative process (Saldaña, 2021). Aligned with CPA’s tenets that call on researchers to center minoritized students’ perspectives and experiences (Diem et al., 2014), the first phase involved data-driven, open coding and analysis of student interviews, focusing on their experiences in the program as they worked towards being successful. We labeled interview excerpts with descriptive labels that captured the issues the excerpts highlighted (e.g., “individual measure of success” or “stressors experienced”). Then, we coalesced the codes into parent codes that substantively encompassed multiple codes (e.g., “self-discovery as a measure of success”). Lastly, we examined the parent codes, grouped them into similar categories, and identified salient themes that captured the nuanced complex experience of students in the program. The second phase involved deductive coding and analysis of the federal policy documents (i.e., McNair program policy, the 138 Congressional Record, and the McNair annual performance report). We drew on each tenet of CPA and the three costs of administrative burdens in our analysis and literature on student success (e.g., Adams & McBrayer, 2020; Bassett, 2021) to create our initial set of deductive codes (see Table 3, Example Codes). Thus, deductive codes informed by the conceptual framework and the literature included “consideration for students’ needs,” “discussion of standards-based outcomes,” and “barriers to success.” The conceptual framework and the literature helped us interrogate the potential assumptions about success embedded in the reauthorization of the Higher Education Act and the gap between policymakers’ intentions and the measures of success fixed within the policy. Moreover, we focused on the motivations for adopting the policy and its requirements, the measures of success explicitly or implicitly embedded in the policy (e.g., by identifying where resources were allocated), and the overall framework of the policy as captured by the policy rhetoric and its silences in implementation. In the iterative process of coding, we refined the codes to better reflect the data, grouped codes into conceptual categories that encompassed multiple codes, and identified themes across the categories. Policy rhetoric, realities, and burdens 13 Table 3 Codes Based on a Critical Policy Analysis of McNair Program Tenets of Critical Policy Analysis (CPA) CPA of the McNair Program Example Codes 1. Analyze policies’ roots, foundations, and assumptions Consider the McNair program policy’s roots, foundations, and assumptions, as well as the current programmatic requirements—the policy rhetoric. • Discussion of standards-based outcomes • Discussion of academic success • Focus on minoritized students’ needs 2. Pay attention to differences between policy rhetoric and reality Consider students’ lived experiences (reality) compared to/contrasted with the policy rhetoric. • Benefits and burdens of academic programming • Non-academic programming 3. Highlight the distribution of power, resources, and knowledge Consider the allocation of resources (e.g., time and attention) based on federally- structured definitions of success and students’ perceptions of the McNair program’s intended goals. • Resources allocated for academic programming • Resources allocated for non- academic programming • Perception of program staff 4. Explore the effect policies have on (in)equity, (in)equality, and privilege and costs associated with administrative burdens Consider differences between policy rhetoric and students’ realities to interrogate embedded inequities and burdens in the policy and its implementation. • Discussion of complying with McNair requirements • Discussion of academic and personal needs 5. Ensure racially minoritized and underrepresented individuals’ and groups’ perspectives are centered Consider and center students’ perspectives on and experiences within the McNair program to inform policy and practice. • Consideration of students’ perspectives • Self-discovery as a measure of success Education Policy Analysis Archives Vol. 32 No. 71 14 In the third phase, we engaged in a comparative process in which we found where the students’ perceptions of program requirements and personal definitions of success aligned or diverged from the federal policy. For instance, guided by CPA, we centered the students’ perspectives and paid particular attention to the distribution and concentration of power (e.g., resource allocation) as well as how the policy rhetoric and silences could reify the marginalization of a historically minoritized student population against students’ articulated needs (Diem et al., 2014; Diem & Brooks, 2022). Through this iterative comparative analysis, we refined the codes and categories and ultimately identified the themes that constitute our findings. To build the trustworthiness of our findings, we used additional sources of data to triangulate and interrogate our findings (Saldaña, 2021), namely, staff interviews (n = 5) and observations of summer programming (n = 5). These additional sources of data were used to confirm or augment our findings from our analysis of student interviews and federal policy documents as well as the comparative process between findings. We also met periodically during a 1- year period to discuss the findings and address differences in interpretation until we reached full consensus. Findings Students’ perceptions of the McNair program requirements at their institution played an important role in understanding the experiences and aspirations of those in the program. As the McNair program and other TRIO programs were developed during a time when national attention shifted to outcomes-based standards in education, students’ broader perceptions were often in tension with the policy requirements. We present the findings from our critical policy analysis, namely our analysis of participant interviews, the McNair program’s policies, and the gap between at-promise student experiences and the policy. We found McNair program participants often situated themselves within two dichotomous definitions of success in the program: federal definitions of success and personal definitions of success within their institutional context. Based on students’ discussions of these varied definitions of success it was apparent that students’ perception of federal definitions of success were informed by their understanding of federally-mandated program reporting requirements. Additionally, the students’ institutional context, a predominately White institution with predominantly wealthy students and few first-generation students, where racial hostility was palpable, contributed significantly to the students’ experiences. Their experiences at Northeast College also influenced the ways they defined success, and the tensions they felt with the program’s definition of success. Program observations, which reflected a programmatic focus on graduate school applications, and interviews with McNair staff, who also shared about the pressures from federal reporting requirements, underscored these findings. Students’ personal definitions of success, however, were informed by their academic and personal needs within Northeast College. In many cases, students described programmatic success as instances when the McNair program served to meet their academic and personal needs, such as support in selecting classes or socio-emotional check-ins with their advisors. The gap between students’ perception of federal definitions of success and their personal definitions of success led to pressures and stressors for students on the ground that complicated their experiences and shaped their feelings of success. Students identified their faculty and staff advisors as important sources of support, while navigating the pressures of the program and varied definitions of success. Policy rhetoric, realities, and burdens 15 Student Challenges in Policy Implementation Policymakers’ discussions about the McNair program revealed a fundamental focus on performance outcomes and program accountability, with this focus further concretized in the McNair annual performance reporting document. While an analysis of amendments to the Higher Education Act of 1965 showed the McNair program is “designed to provide disadvantaged college students with effective preparation for doctoral study,” our critical analysis of these amendments and policymakers’ commentary revealed little consideration for minoritized students’ needs beyond narrow metrics (Higher Education Act of 1965, 20 U.S.C. § 1070a-14, 1992). For instance, during floor debate about these amendments, Senator David Durenberger (R-MN) argued, “[W]e can be placing a higher priority as a nation on assuring broad and equal access to colleges… [B]ut we must also pay much more attention to what we get from a college” (138 Cong. Rec. 2908, 1992). Sen. Durenberger’s commentary reflects a broader consensus among policymakers at the time where educational standards and outcomes were highly valued to account for student success in college. So, while access was a meaningful goal for policymakers, program outcomes and accountability were given significant attention. By critically analyzing the McNair annual performance report (Office of Postsecondary Education, 2022), we found the federal government’s current programmatic requirements only measure academic performance, graduate school application, and graduate school enrollment and completion across 13 categories. In contrast, students’ participation in McNair program activities—including research participation—are measured across four categories. Additionally, the policy does not define a minimum or maximum percentage requirement for graduate school attainment, which could result in McNair program staff striving to approximate 100% attainment. In sum, the policy itself and implementation of the policy requirements both reveal an underlying and central focus on academic performance outcomes. Students felt achieving the McNair program’s performance outcomes was the primary way the federal government and program administrators on their campus defined success. For instance, when asked what the definition of success was for the program, Katrina, a female, Hispanic student replied, “definitely just getting into grad school and then going to grad school. That’s the biggest goal of the program.” A critical analysis of the McNair program annual performance report supported students’ interpretation of the federal government’s definition of success for the McNair program. For instance, one question on the report asked, “Did the participant complete a graduate school admissions test?,” but the annual performance report did not account for student academic development, personal growth, or career development in other directions (Office of Postsecondary Education, 2022, p. 12). Additionally, participation in fellowship programs, like Fulbright, or attending a professional degree program, like law school, were not counted toward McNair program requirements. Multiple students highlighted the pressure they felt to meet the program requirements, even after realizing through their McNair experience they no longer wanted to attend graduate school or pursue a terminal degree. Interviews with program staff confirmed that students often struggled with the pressures of program requirements to apply to multiple graduate schools. Several students discussed the role McNair program administrators played in excessively pushing students to apply for graduate programs. They saw administrators’ requirement-focused encouragement as an extension of the performative pressure on program staff to achieve quantifiable results and thereby ensure continued funding of the program. The quantifiable requirements program administrators must document are outlined in Section I, Part 2 of the McNair program performance evaluation of required and permissible services; McNair programs are evaluated on data on student research activity (e.g., “to what extent did the student participate in research activity?”) and graduate school enrollment status (e.g., “what type of assistantship did the Education Policy Analysis Archives Vol. 32 No. 71 16 first-year graduate student receive in this reporting period?”; Office of Postsecondary Education, 2022, p. 11, 16). As an example of the pressure on program staff to achieve performance outcomes, student participants often highlighted the pressure they felt from program administrators to apply for and attend graduate school programs immediately after graduating. For instance, Alice, a Korean- American female, offered: I understand why they’re [pushing us to apply to grad school], because it’s like part of the government McNair requirements—that like 50% of the people have to be in grad school within X amount of years after they’re done with the program. But if I had to say, I’d say it’d be nice if they stop pushing us to go immediately. Other students shared this sentiment as well. Cassandra offered her insight as a Mexican-American woman at Northeast College and suggested she felt excessively pushed by the program staff to apply for graduate programs even when she knew that was the direction she was already headed. Talking about the pressure of program requirements, Ian said, “we all know that they get funding for that and that’s the measure of success that we’re sending back to keep this program going.” McNair program participants felt pushed by the program staff to achieve the programmatic requirements for the continued success and benefit of Northeast College’s McNair program as a whole, even if it was not necessarily their personal definition of success. The program’s focus on graduate school attainment also posed a challenge for students as they framed other measures of success outside of applying and attending graduate school in negative or deficit terms. For instance, Ian thought the federal government would likely see a McNair participant not getting a Ph.D. as a failure rather than a change of path. As a first-generation Mexican-American man in the program, Ian felt added pressure to achieve and make his family proud while also pursuing a path that was meaningful to him. While the McNair program is meant to serve at-promise students, the specific academic and personal needs of these students were not necessarily centered in the development of the program requirements as evident in the lack of discussion by policymakers during Congressional debate and discourse concerning reauthorization of the HEA. Students, however, had a broader definition of success as it related to their academic and personal development in the McNair program; we expand on this finding in the next section. Student Personal Definitions of Success While students critiqued the narrow focus of the McNair program requirements imposed by the federal government, they also offered a broadened definition of success they wished the program integrated more intentionally and explicitly. Their conceptualizations revealed the value they placed on holistic support and in self-discovery, support that the program staff provided, albeit without the policy allocating the necessary resources to do this work. These personal definitions of success were most often offered in antithesis to the program’s strict rules and programmatic requirements. Students shared how their participation in McNair activities and involvement in the program benefited their personal growth. For instance, when asked what ought to be the definition of success in the program, Nick, a White, first-generation male student said, “fostering personal growth and [giving] them a better understanding of what education looks like after undergrad.” Jackie, who is Dominican, offered a similar definition of success, “I think it is the personal growth, like how they came into the program, and how they’re leaving it.” Based on their experiences in the McNair program, students shared consistently about their personal growth and development, such as feeling they belonged. However, despite nearly all of the participants’ being first-generation students at Northeast College, they mentioned varied experiences with feeling a sense of belonging and growth Policy rhetoric, realities, and burdens 17 at Northeast College because of their racial and ethnic identities. For example, while Nick, a first- generation, White student at Northeast College, rarely discussed his sense of belonging, several participants shared about feeling they did not belong within their campus environment because of their minoritized racial and ethnic identities. Students also shared how their experiences of self-discovery in the program were a valuable way to define their success in the program. Ian shared how applying to graduate schools helped him know more clearly what he was interested in, and then he focused on those interests throughout his undergraduate studies. Similarly, as a Hispanic woman, Katrina mentioned that figuring out if “graduate school is something I actually want to do should be success in and of itself.” In this sense, the journey of being part of the program helped students develop critical skills, learn about the academy, and learn about themselves. McNair participants grew through their involvement in activities associated with the federal requirements, though sometimes these came in tension. For example, some students, perhaps at odds with the program requirements, learned that graduate school was not for them or that a different type of schooling, such as law school, was a better fit for their career plans. Students counted that discovery as success, as did the staff. However, the experiences they shared suggested the stigma and stress that such a realization may not be seen as a success within the federal program requirements lingered in the background. Program staff still highly encouraged students in this position to apply to graduate school; future funding and the continuity of the program depends on students applying and attending graduate school. Additionally, students’ definitions of success were often informed by their racial and cultural identities and experiences, especially as it related to navigating Northeast College, a predominantly White institution. Jackie felt success in the program could look like making meaningful contributions to minoritized student communities on campus through, for example, starting a new club or being a mentor to other minoritized women like herself. She recognized the need for community-building within the institutional context and the need to support other similarly positioned students in navigating the same contexts. Jackie was not alone in this, Ana felt the McNair program created space for her to feel comfortable as an Ecuadorian, first-generation college student “where otherwise in this predominantly White institution you would not be able to find that space in the classroom.” Multiple students talked about how the McNair program became a place of safety and community for them as minoritized students with multiple minoritized identities (e.g., race, socioeconomic status) at Northeast College. Students suggested they remained in the McNair program, despite tensions with program requirements, because of the holistic support they received and for the opportunity to build a welcoming community for minoritized students—meaningful examples of success in the McNair program. Role of McNair Advisors in Supporting Students’ Holistic Success At the same time students in the McNair program highlighted a gap between federal and personal definitions of success and the pressure they felt from McNair staff to meet program requirements, they also identified faculty’s and staff’s role in helping them navigate the varied definitions. In doing so, these students expressed the academic and personal needs they had during their time in McNair and how faculty and staff helped them meet those needs through holistic support. McNair participants had academic needs such as learning to do research, picking appropriate classes, and identifying activities in which to participate. Faculty and staff advisors played an important role in supporting students’ academic needs, especially as students were paired for mentoring with faculty in a field of interest. For instance, Katrina noted, “they paired me with a mentor in the biology field. She’s been really helpful in picking my classes and what activities I should be doing… Faculty mentors are huge in [helping you find success in the program].” Education Policy Analysis Archives Vol. 32 No. 71 18 Identified as a permissible service in the McNair program annual performance report, mentoring provided an important resource for McNair participants. However, a critical policy analysis of McNair policies and policymakers’ discourse about those policies suggests that mentorship is meant to serve the academic outcomes of the program, not necessarily to support students’ holistic success. So, while students navigated the tension between program requirements and their personal definitions of success, their advisors helped students with academic needs and supported their sense of success apart from the actual program requirements. Faculty and staff advisors also played an important role in supporting students’ personal needs. The personal needs that McNair participants mentioned having to navigate involved financial issues (an issue particularly salient for first-generation, low-income students), having multiple jobs, stress from relationships, and campus racial climates (which often included overt racist acts and covert racism, e.g., passive aggressive comments). For instance, Danielle, who is a Kenyan American, Black female, talked about how her McNair advisor would “check in to see how everything is going and offer advice for things that I’m going through…. She helped me with some issues I had with my job and with financial aid.” Jackie similarly said she appreciated how the faculty and staff advisors she had were from similar backgrounds, because “the advising and those resources that they are giving to us has made it easier for me to engage and be open about my academic and social experiences.” Even though the faculty and staff were partnered with students to support the academic outcomes of the McNair program, students mostly talked about their advisors as people who helped them in a variety of ways and provided insight on collegiate expectations. For instance, as Cassandra was considering her future, she said her faculty advisor helped her “learn our own interests and genuine wants for the future, especially what in the future will help you get there.” Program participants shared about both academic and personal issues and the ways advisors helped them discover and define success for themselves both in their programs and post-graduation. The faculty and staff advisors played a pivotal role in helping students navigate the gap between federal performance outcomes and participants’ personal definitions of success. Discussion and Implications The success of students historically excluded from and minoritized in higher education is an imperative for higher education policy and practice. Minoritized students experience unique challenges, such as less than welcoming racial campus climates that impact their well-being, and they must navigate these challenges while making sense of and learning about the postsecondary experience as, often, the first in their family to attend college (e.g., Adams & McBrayer, 2020, Bassett, 2021; Jayakumar & Museus, 2012). Federal programs, such as McNair, can serve as critical levers that support minoritized students’ undergraduate experience and prepare them to succeed post-graduation (Gittens, 2014). Students in the McNair know that McNair program policies set up the program to serve as a pipeline to graduate school. However, these policies cannot be divorced from the lived realities of those they serve. Doing so can risk further marginalization. Employing CPA’s core tenets as guiding principles (Diem et al., 2014), we found a tension between the McNair program policies and students’ experiences in the program. We discuss this tension in relation to misaligned policy structures and the powerful role of faculty and staff advisors in supporting students navigating this tension. The findings in this study are based on 10 students’ experiences in the McNair program at Northeast College and therefore have limitations. Nonetheless, as Ladson-Billings (2024) notes in her chapter, It Turns out 8 is Enough, small sample sizes in qualitative research can unearth important insights and illuminate our understanding of broader phenomena. We conclude with implications for policy and research that, while limited, help us understand how alignment of policy structures and Policy rhetoric, realities, and burdens 19 resources, and changes in the policy to value holistic support could meaningfully improve the McNair program for at-promise students at Northeast College and similarly situated programs. Misaligned Policy Structures At-promise students’ descriptions of varied definitions of success in the McNair program highlighted differences between policy rhetoric and students’ experienced realities (see Diem et al., 2014). While students’ highlighted tensions between the program requirements and their own success in the program, this could be the result of implementation issues. However, prior literature on tensions between policy intentions and policy realities suggests our findings reveal a broader phenomenon that points us to areas of inquiry for future research to investigate how broad of an issue it is (Diem et al., 2014; Gándara et al., 2023). The combination of policymakers’ focus on outcomes, the resulting allocation of resources, and the lack of research that centers students' voices within educational policy creates a gap. This gap further marginalizes the students the policy is meant to serve. Aligned with a critical approach (e.g., Crenshaw, 1991; Welton et al., 2023), it is important that these gaps can be meaningfully improved to support the students and strengthen the vital work in which the program is already engaging (e.g., Renbarger & Beaujean 2020). Misaligned Policy Resources and Administrative Burdens The tension we found furthers the research on administrative burdens in higher education. The tension between administrative requirements and student needs represents the trickle-down effect that administrative burdens have on at-promise student success. Administrative burdens are defined as barriers and burdens people experience as a result of the “bureaucratic rules and processes embedded within policy design and implementation that prevent the policy’s intended beneficiaries from gaining access to public goods, resources, and services” (Gándara et al., 2023, p. 3). Scholars posit that administrative burdens in higher education occur in federally-funded programs, prevent students from accessing or keeping goods, resources, or services, and are disproportionately experienced by racially minoritized individuals (Gándara et al., 2023). We extend the research on administrative burdens in higher education by identifying the compliance and psychological costs—two of the three types of administrative burdens that participating students face as a result of misaligned policy resources. More specifically, given the policy structures, program staff resources, including time and energy, are directed towards complying with the narrow measures of success defined and prioritized by the McNair policy. Federal policy for the McNair program provides resources for program staff to help students meet the federal definitions of success (e.g., applying to graduate school). Policymakers’ discourse and the policy itself suggested policymakers had a desire to support students’ academic success. However, as we found, students’ experiences of McNair program requirements suggests a misalignment between student needs and the resources program staff receive to achieve performance outcomes. So, students bear the burden of administrators’ attempts to comply with federal policy, despite their expressed desires to support students holistically. Yet, these burdens are especially pronounced when program staff are directing limited resources to narrow definitions of success. Our findings highlighted the emotional stress students felt when the experiences they deemed to merit success were at odds with McNair policy. For instance, students discussed the stigma they felt when their self-discovery that attending graduate school was not right for them was associated with failure according to the federal government’s narrow definitions of success. Still, students remained in the program because they appreciated the support they received. The support was critical given the institutional context, where students faced isolation based on their race/ethnicity or socioeconomic status (see Adams & McBrayer, 2020; Bassett, 2021). Students’ Education Policy Analysis Archives Vol. 32 No. 71 20 emotional stress and stigma are indicative of the psychological costs resulting from narrow definitions of success. It is important to note that the analysis is focused on the lived experiences of the students against the rhetoric and structure of the program. Yet, there are other social forces that shape the students' experiences and perceptions in education, including racism, classism, and sexism. While this is beyond the scope of our study, we urge other scholars to further study and focus on these dynamics in the context of the McNair program. While the study is limited to an elite predominantly White institution, the literature more broadly shows similar burdens across other institutional types, which suggests administrative burdens are exacerbated when the racialized experiences of historically minoritized students are not considered in educational policy development and implementation (DeRosa & Dolby, 2014; Gándara et al., 2023; Museus, 2014). In sum, the policy structures, revealed in the McNair program requirements and allocation of program staff resources, place administrative burdens on students in the program and can be a detriment to their success. As the findings build on existing literature, additional inquiry is needed to determine whether these 10 students’ experiences in McNair at Northeast College are isolated or if students in McNair programs at other institutions might be experiencing similar burdens through misaligned policy structures (see Ladson-Billings, 2024). Need to Account for Holistic Support in Federal Policy Our findings also further the research on the urgent need for federal policy to promote holistic support for minoritized students at elite institutions. Research has found that students develop multiple skills in their educational trajectory and that non-academic, socio-emotional skills are germane to their academic and overall success (e.g., Durlak et al., 2011; Moreno et al., 2019). Additionally, we recognize other higher education TRIO programs (e.g., Student Support Services, Upward Bound, etc.) are also well-positioned to provide holistic support, such as socio-emotional skill development, to minoritized students. While most of the research in this area is in the P-12 context, we similarly found that socio-emotional skills were crucial to students’ overall wellbeing as they developed throughout the program. Our findings showed that holistic support informed students’ academic and professional development, and that resources for holistic support were lacking. So, while accounting for holistic support in federal policy is not a be-all and end-all approach to supporting students’ needs, we suggest that doing so, coupled with allocating necessary resources, can be one way to offer material support for the important work that McNair program staff are already doing. The McNair program was initially developed to support at-promise students’ pursuit and attainment of advanced degrees so they could enter careers in research and academia. This is a worthwhile goal, given the barriers that at-promise students face in attending graduate school. However, centering students’ perceptions of the policy through a critical policy analysis revealed how the federal government has narrowly defined success for students in the program (see Diem et al., 2014). While our findings highlighted this at Northeast College, it is not an isolated issue. Prior studies have shown that these TRIO federal programs provide holistic support but struggle to meet those needs when the federal policy values narrow metrics of success (Muñiz, 2020). The lack of holistic definitions of success in policy development and implementation is disassociated from both traditional and critical perspectives on at-promise student success (DeRosa & Dolby, 2014; Museus, 2014; Zepke et al., 2010). Powerful Levers of Support Lastly, our findings extend the research on the important role faculty and program staff play in helping students navigate policy misalignments and administrative burdens. The social network of at-promise students can provide these individuals with a rich system of familial support (Museus, Policy rhetoric, realities, and burdens 21 2014). Yet, for some of these students, as the first in their family to attend college, they might not have relationships with people who know how to navigate the collegiate environment (DeRosa & Dolby, 2014). Relationships with faculty outside the classroom can play a meaningful and important role in the success of historically minoritized students (Hanson et al., 2016; Hurtado & Carter, 1997). Prior research has also found students’ advisors and support staff play a significant role in supporting students in navigating social issues and supporting their emotional wellbeing (Hurtado & Carter, 1997). We extend this prior research into the McNair program context at predominantly White, wealthy institutions. We found the faculty and staff advisors that students were provided through the McNair program became important members of students' social networks. They offered valuable insight ranging from advice about research to what classes might benefit their development to how to address racial tensions on campus. In an academic and social environment that was not necessarily designed for at-promise students, faculty and staff advisors are influential people in students’ networks. We further extend the research on support systems by identifying the role that faculty and program staff play in helping students navigate administrative burdens in the program. We recognize the duality students identified when they discussed how McNair staff excessively pushed them to apply for graduate programs, which we attribute to misaligned policy structures. While students felt that McNair program staff excessively pushed them to apply for graduate programs, they recognized the staff did so to maintain the program’s funding and their actions were not at odds with being supportive. For example, when students discovered through the program that they no longer wanted to attend graduate school, faculty and staff advisors affirmed students’ process of identifying their interests and shared insight on how to develop those interests. An important way faculty and staff advisors supported the students in this study is through validating their growth, guiding their thinking about the future, and ultimately helping students conceptualize success beyond McNair program requirements. Through these interactions and holistic support, faculty and staff can counter the negative effects of policy inequities (Cokley, 2000; DeRosa & Dolby, 2014; Hanson et al., 2016; Renbarger et al., 2021b). When federal program requirements do not center the lived realities of students in the program, faculty and staff advisors play an important role in centering the academic and personal needs of students and validating the experiences of at-promise students. Implications The prevalent need for holistic support of students in the program reflects the need for structural changes in the federal policy framework so that McNair programs can engage in this work as an integral part of their programming, not as a secondary (often demanding) concern. One focus area to effectuate this change is at the U.S. Department of Education level. The U.S. Department of Education officials can review and refine the McNair performance evaluation to define socio- emotional skill development as either a required or permissible service to be provided by McNair program staff. Currently, when TRIO program staff engage in holistic skill-building as a secondary concern, they are often met with few resources (e.g., time, money, and ongoing professional development) to do so effectively (Muñiz, 2020). Policymakers at the state and federal level have codified socio-emotional skill building standards and requirements, but the focus of these policies is mainly at the P-12 level (CASEL, n.d.). As demonstrated in this study, funding priorities need to be aligned by allocating more resources (e.g., time, money, or professional development) toward student success in general and through the McNair program specifically. Otherwise, the lack of policy support can reinforce the same inequities it aims to address, marginalizing the needs of at- promise students in the McNair program. Education Policy Analysis Archives Vol. 32 No. 71 22 In addition to policy development focused on holistic support, policymakers should center the experiences and perspectives of the students who will be affected by the policy (see Diem et al., 2014). This is especially true for policies meant to serve minoritized students since “racial and cultural contexts [are] critical factors in explanations of student success” (Museus, 2014, p. 192). Students in this study shared critical challenges and tensions that they experienced within the current construction of the McNair policy and its implementation at their institution. Their perspectives focus on a more holistic approach that would not only further the policy goals of enrollment in a graduate program but also foster some of the skills that students value and that the program has (with limited resources) supported. If policymakers intend to support at-promise students through the McNair program, they should center at-promise students by including their perspectives and experiences. For example, policymakers might invite the testimony of former McNair program participants to elaborate on their experiences and academic and personal development through committee hearings for reauthorization of HEA and, therefore, the program. Additionally, the broad body of critically oriented student success research can inform the next reauthorization of the HEA, specifically, and in the development and outcomes of programs for minoritized students, like McNair, broadly. More specific to McNair, the reauthorization offers an opportunity to broaden what counts as success to support at-promise students’ pursuit and attainment of advanced degrees. Related to the influence of advisors evidenced in the findings, policymakers could add additional measures of success that account for and devote resources toward faculty and staff support for at-promise students. Finally, to support policymakers’ efforts in centering at-promise student perspectives, more critically-oriented research is needed that elucidates the gaps between current education policies and students’ needs, perspectives, and experiences; further, this research should be translated into accessible publications upon which policymakers can rely (Hillman et al., 2015). We encourage critical scholars to use CPA to guide the framing of their studies about education policies and minoritized students, as we did in this study. We used the five tenets of CPA as guiding principles in our conceptual framework, which drew our attention to particular aspects of the policy, its implementation, and students’ perceptions of the policy. Further, we encourage scholars to think critically about how each tenet of CPA might be operationalized within the coding schemes of education policy studies to elucidate the gap between current education policies and students’ needs, perspectives, and experiences, thereby expanding upon this work. Researchers can provide additional insight on what programs, opportunities, and experiences program administrators are offering at-promise students that afford them holistic support. Applying critical lenses, researchers should also extend current scholarship about administrative burdens (Gándara et al., 2023) to consider the trickle-down effect of administrative requirements, the burden it places on staff to serve students’ holistic development, and the impact these burdens have on at-promise students (e.g., emotional burden that comes with stigmatizing their perceptions of success). Conclusion The gap between policy rhetoric and reality can negatively affect those whom a policy is meant to serve, namely students, and especially students from historically minoritized backgrounds. Critical policy analysis provides a helpful lens to consider how students’ perceptions of educational policy reveal the differences between policy rhetoric and policy realities (i.e., implementation). Specifically, a critical policy analysis of a McNair program in the northeast US allowed us to foreground the unique experiences and perspectives of at-promise students who participated in the program and compare their experiences to the program policy’s rhetoric. Policy rhetoric, realities, and burdens 23 Through our analysis, we found that narrow federally-structured definitions of success in the McNair Postbaccalaureate Achievement Program differed from students’ personal definitions of success. These differences created challenges for the students as they progressed through the McNair program. We also found the holistic support that McNair advisors provided through the program helped students navigate the narrow definitions of success implemented through McNair program policies. The gap between McNair policy structures focused on achievement outcomes and students’ need for holistic support had a tangible impact on students in the program, which added stressors, pressure, and stigma, as they attempted to navigate a predominantly White institution, where most students were wealthy. By centering the experiences of students, our findings highlight this critical gap and draw attention to the administrative burdens placed on at-promise students, emphasize the need for holistic socio-emotional support in federal policy, and underscore the powerful role of supportive faculty and staff. 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Studies in Higher Education, 36(2), 227–242. https://doi.org/10.1080/03075070903545074 https://www2.ed.gov/programs/triomcnair/index.html https://www2.ed.gov/programs/triomcnair/performance.html https://doi.org/http:/dx.doi.org/10.1108/17597511211278634 https://doi.org/10.32674/hepe.v5i1.1139 https://www.mdpi.com/2227-7102/10/1/16 https://doi.org/10.1177/08959048211042569 https://heinonline.org/HOL/P?h=hein.journals/upitt75&i=497 https://doi.org/10.1089/heq.2020.0126 https://eric.ed.gov/?id=EJ1413221 https://doi.org/10.1080/10665684.2011.558416 https://doi.org/10.3102/0091732X09350472 https://doi.org/10.1080/09518398.2023.2181431 https://doi.org/10.1080/03075070903545074 Policy rhetoric, realities, and burdens 27 About the Authors Nathan A. Hutcherson Boston College hutchern@bc.edu https://orcid.org/0000-0002-5241-6804 Nathan A. Hutcherson is a doctoral candidate in higher education at Boston College. His research focuses on advancing educational equity for minoritized students by exploring the relationship between education, law and policy, and higher education leadership. Raquel Muñiz Boston College munizcas@bc.edu https://orcid.org/0000-0002-9052-3969 Raquel Muñiz, JD, PhD, is an associate professor at Boston College. She studies how law and policy shape educational equity and how the use of knowledge, including research, can improve law and policy in education. education policy analysis archives Volume 32 Number 17 November 12, 2024 ISSN 1068-2341 Readers are free to copy, display, distribute, and adapt this article, as long as the work is attributed to the author(s) and Education Policy Analysis Archives, the changes are identified, and the same license applies to the derivative work. More details of this Creative Commons license are available at https://creativecommons.org/licenses/by-sa/4.0/. EPAA is published by the Mary Lou Fulton Teachers College at Arizona State University. Articles are indexed in CIRC (Clasificación Integrada de Revistas Científicas, Spain), DIALNET (Spain), Directory of Open Access Journals, EBSCO Education Research Complete, ERIC, Education Full Text (H.W. Wilson), QUALIS A1 (Brazil), SCImago Journal Rank, SCOPUS, SOCOLAR (China). About the Editorial Team: https://epaa.asu.edu/ojs/index.php/epaa/about/editorialTeam Please send errata notes to Jeanne M. Powers at jeanne.powers@asu.edu mailto:hutchern@bc.edu https://orcid.org/0000-0002-5241-6804 mailto:munizcas@bc.edu https://orcid.org/0000-0002-9052-3969 https://creativecommons.org/licenses/by-sa/4.0/ http://www.doaj.org/ https://epaa.asu.edu/ojs/index.php/epaa/about/editorialTeam mailto:mailtojeanne.powers@asu.edu