The federal government counts them all the same way. A third-generation Mexican American student from El Paso, a Puerto Rican student who grew up on the island, a Dominican student from Washington Heights, and a Venezuelan student who arrived in Miami two years ago as an asylum seeker. On the enrollment forms that determine whether a college qualifies as a Hispanic-Serving Institution, they are the same category. One box. One threshold. Twenty-five percent.
That single number has reshaped higher education. There are now 631 HSIs across 29 states, the District of Columbia, and Puerto Rico, institutions that make up just 21 percent of the nation’s colleges and universities but enroll 65 percent of all Latino undergraduates, according to Excelencia in Education, the Washington-based research and advocacy organization that has tracked the sector for two decades.
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The federal government counts them all the same way. A third-generation Mexican American student from El Paso, a Puerto Rican student who grew up on the island, a Dominican student from Washington Heights, and a Venezuelan student who arrived in Miami two years ago as an asylum seeker. On the enrollment forms that determine whether a college qualifies as a Hispanic-Serving Institution, they are the same category. One box. One threshold. Twenty-five percent.
That single number has reshaped higher education. There are now 631 HSIs across 29 states, the District of Columbia, and Puerto Rico, institutions that make up just 21 percent of the nation’s colleges and universities but enroll 65 percent of all Latino undergraduates, according to Excelencia in Education, the Washington-based research and advocacy organization that has tracked the sector for two decades.
But the number that earns a campus its federal designation — and its access to Title V grant dollars — treats Hispanic and Latino identity as if it were interchangeable. It is not. The Code of Federal Regulations defines the population an HSI serves as people of Mexican, Puerto Rican, Cuban, Central or South American, or “other Spanish culture or origin, regardless of race”—a definition that folds together histories with almost nothing in common, from a Puerto Rican student’s birthright citizenship to a Cuban family’s refugee protections to a Dominican community concentrated overwhelmingly in one metro area.
For years, that aggregation was treated as a technical footnote — a Census Bureau convention imported into federal higher-education policy because it was already there. Increasingly, it is being treated as a question worth asking directly: what does a college actually know about who it’s serving well, and who it’s serving by accident?
Dr. Gina Ann Garcia, a professor at the Berkeley School of Education and faculty director of its Latinx Thriving Initiatives, has spent much of the past decade arguing that the 25 percent threshold was never meant to be the measure of whether a campus is serving Latino students, and that fixating on disaggregation risks missing a larger point. Garcia coined the concept of “servingness” to describe what should happen once a college crosses the enrollment line — not a data project, but an institutional transformation.
“The idea of servingness removes the focus from the arbitrary 25% enrollment threshold, and to be clear, it is an arbitrary number that is much higher than other enrollment-based MSIs,” Garcia says. She points to the 10 percent threshold for an institution to be an Asian American and Native American Pacific Islander-Serving Institution or a Black-Serving Institution as evidence, though the latter is a state-level recognition in California. “The focus of servingness is institutional transformation, from the mission statement to the curriculum offered. Disaggregating data wouldn’t change the essence of servingness since servingness is not about enrollment targets.”
Garcia’s own research distinguishes between institutions that are merely “Latinx-enrolling” and those that are “Latinx-serving” in a deeper, structural sense. Asked whether that distinction tends to track subgroup lines of a campus serving its Mexican American students well while merely enrolling its Central American or Caribbean ones — she was careful not to overstate the evidence.
“No, I have not seen a campus disaggregate the Latine category into subgroups for the sake of servingness of HSI identity,” she says, cautioning that more research would have to be done to give a definitive answer on the data practices of HSIs as a whole. Where she has seen disaggregation happen in practice, it has run more often along income lines than country of origin.
“There are in fact differences between low-income Latines and middle- and high-income Latines,” Garcia continues. She also says race, more than country of origin, plays a part.
That points to a harder truth about why disaggregation happens at all. It rarely happens out of pure curiosity.
“I think disaggregation is more likely if policy requires it,” Garcia says, pointing to California, where community colleges must submit equity plans that commonly include disaggregated data. HSIs pursuing Excelencia in Education’s “Seal of Excelencia” certification are disaggregating too, she notes, for a comparable reason: “extrinsic motivation, in the same way policy is.”
Heritage University, in Toppenish, Washington, offers one of the more instructive cases in the country of what it looks like when the data is disaggregated. Heritage carries the rare distinction of being both an HSI and a federally recognized Native American-Serving Non-Tribal Institution, sitting on the Yakama Reservation with a student body that is roughly three-quarters Hispanic and more than a tenth Native American. Rather than a complication, its president, Dr. Chris Gilmer, treats that overlap as the clearest expression of the university’s mission.
“We resist labeling students, but support them to self-identify with any group or groups they choose,” Gilmer says. “The current federal classification system, not unlike any classification system I know, does not take into account the complexity of most people.”
In Heritage’s service area, he says, that complexity often shows up as blended families where students “who might primarily identify as Hispanic/Latino or Native American, [are also] products of cross-cultural unions and who honor aspects of both cultures.”
Heritage’s response has been to build a campus that holds space for all of it. The university intentionally preserves Ichishkiin, the language of the Yakama people, through its curriculum and community classes, while nearly all students identify English or Spanish as a first language.
On language and origin, Gilmer’s students break from the pattern Garcia describes at more urban campuses, a sign, in Heritage’s case, of how tightly its community holds together rather than how fragmented it is. Spanish fluency is common among Heritage’s Hispanic students “regardless of their region of familial origin,” Gilmer says. It is often parents and grandparents working in agriculture who are most comfortable only in Spanish, with students stepping in as translators for older relatives. Most trace their roots to Mexico and Central America and remain connected to family there, even as many were born in the United States.
“Our students and their families are largely place-based within a relatively small geographical area,” Gilmer says, “so what is true for Heritage is likely not the case for more urban universities.”
But Gilmer says immigration status is another consideration, when it comes to knowing how to serve students well.
“Immigration status is a major factor in the lives and the daily challenges of our Hispanic/Latino students and their families,” he says. “It is difficult, sometimes impossible, to focus on algebra or biology if you live in constant fear of someone you love being deported or detained.”
Heritage tries to address that reality with what Gilmer describes as extensive wraparound support built for a student body that is 85 percent first-generation, more than 90 percent “new majority,” and 97 percent dependent on the highest level of financial aid available.
Gilmer wears those numbers as a point of pride rather than a burden.
“We wear this designation with no shame, but as a badge of honor,” he says. “The most important word in our mission is ‘access,’ and access is only real and meaningful if it is reinforced by the tools needed to succeed in college. It is not the primary responsibility of the student to be college ready. Ultimately, it is our responsibility to be student-ready for all students.”
At a moment when many HSIs are still working out what disaggregation should even measure, Heritage’s answer is less a data strategy than a standing institutional posture: know your students specifically enough to serve them, and build the support to match, whatever category they happen to check.
None of this argues for abandoning the HSI designation, which remains one of the most visible tools the federal government has for funding access to higher education. But Garcia’s research and Heritage’s example both suggest the deeper work was never going to be captured by the enrollment count alone. It happens inside institutional research offices, in the design of advising caseloads, and, as Gilmer puts it, in the daily decision to be student-ready rather than to wait for students to arrive ready-made. The 25 percent threshold got Latino students into the federal funding conversation, but it was never built to describe who they are.
This story originally ran in The EDU Ledger's October 1, 2026 edition. Subscribe here for full access.














