Human-Centered Eligibility Design

EXOTELL

Working Paper Series

Human-Centered Eligibility Design

Principles and Practice for Financial Aid and Beyond

Working Paper | exotell.com | June 2026

This paper is part of Exotell's Working Paper Series on eligibility, access, and the design of guidance systems for students and families navigating financial aid.

Abstract

Human-centered design (HCD) has transformed the development of consumer products and digital services. Its application to government eligibility systems is more recent, more contested, and more consequential. This paper develops a framework for human-centered eligibility design—an approach that applies HCD principles specifically to the design of criteria, processes, and communications through which eligibility is determined and communicated. Drawing on research in administrative burden, public sector HCD, and higher education policy, the paper articulates design principles, illustrates their application in the financial aid context, and addresses the institutional and political challenges that complicate their adoption.

1. Introduction: The Design Turn in Eligibility

For most of the history of social program administration, eligibility was understood as a legal and bureaucratic matter—the translation of legislative criteria into administrative process. Design, to the extent it was considered at all, was understood as the design of forms and procedures, not as a fundamental choice about how criteria should be defined, communicated, and administered. The assumption, often unstated, was that the rules were given and the task was efficient implementation.

This assumption is increasingly recognized as inadequate. Research on administrative burden has demonstrated that how eligibility systems are designed—not just what the rules say—determines who is able to access programs and who is not. The design of a form, the sequencing of required steps, the language of a notice, the availability of assistance, and the consequences of non-compliance all shape access in ways that are empirically measurable and normatively significant. Eligibility is a design problem, and it can be approached with design methods.

Human-centered design offers a particularly powerful set of methods for this challenge. HCD begins with the user—not the administrator, not the policy designer, but the person who must navigate the system—and works outward from that starting point. It emphasizes direct research with users, iterative testing of design solutions, and ongoing evaluation of whether the system is achieving its intended outcomes. Applying HCD to eligibility means asking, persistently and rigorously, whether the system is working for the people it is supposed to serve.

2. Core Principles of Human-Centered Eligibility Design

2.1 Start with the Applicant's Experience. The foundation of HCD is research: direct, structured engagement with the people who use a system to understand their experience, their challenges, and their goals. For eligibility systems, this means talking with applicants—not just processing their data—to understand where they get stuck, what they misunderstand, what they give up on, and what would help them succeed. The Better Government Lab at Georgetown University has developed validated instruments for measuring the experience of administrative burden in public benefit programs, providing a methodological foundation for this kind of research in the eligibility context.

Starting with the applicant's experience does not mean giving applicants whatever they say they want—users' stated preferences and revealed behaviors do not always align, and policy goals constrain design choices. But it does mean that the applicant's experience is the primary data source for diagnosing design problems and evaluating solutions. An eligibility system that administrators find efficient but applicants find impenetrable is a poorly designed system, regardless of its procedural correctness.

2.2 Reduce Friction at Every Touchpoint. Friction in eligibility processes is not neutral. It functions as a filter that systematically disadvantages applicants with fewer resources, less time, and less familiarity with bureaucratic processes. Human-centered eligibility design treats friction reduction as a primary design goal: every step that can be eliminated should be; every piece of information that can be pre-populated should be; every decision that can be made once rather than repeatedly should be made once.

The federal government's experience with IRS data exchange in the FAFSA context illustrates both the potential and the complexity of friction reduction. Automating the transfer of tax information from the IRS to the FAFSA system eliminates a significant compliance burden for applicants. But it also requires applicant consent, introduces new failure modes when data does not transfer correctly, and creates dependencies on IRS system availability. Effective friction reduction requires careful attention to the points at which automation introduces new complications, and proactive design to address those complications before they reach applicants.

2.3 Make Eligibility Legible. Applicants cannot effectively navigate a system they do not understand. Human-centered eligibility design prioritizes legibility: the degree to which applicants can understand what they need to do, why they need to do it, and what will happen as a result. Legibility is not the same as simplicity—complex eligibility rules can be made legible through clear communication, visual design, and contextual guidance without being simplified away. Legibility is about the relationship between the system and the applicant's capacity to understand and act.

In the financial aid context, legibility requires clear communication about the SAI calculation and what it means for a student's aid package; plain language in all notices, forms, and communications; proactive explanation of what happens at each stage of the eligibility process; and guidance about what to do when circumstances change or when the initial determination does not reflect the student's actual situation. Exotell's core principle—that complexity should not require obscurity—is a statement about legibility as a design goal.

2.4 Design for the Full Range of Applicants. Human-centered design in the public sector must account for the full diversity of the intended population—not design for an idealized median applicant and expect outliers to seek exceptions. This principle has particular force in financial aid, where the intended population includes students with highly varied citizenship statuses, family configurations, documentation histories, and prior experiences with institutional systems.

Designing for the full range means building alternative pathways for students who cannot follow the standard path; ensuring that exceptions and professional judgment processes are accessible, not just theoretically available; testing design solutions with diverse user groups rather than only with applicants who most resemble the system's implicit default; and evaluating outcomes disaggregated by relevant population characteristics to identify where design failures are concentrated.

2.5 Support Agency and Dignity. Eligibility systems carry inherent power asymmetries—the institution holds resources; the applicant must demonstrate eligibility to receive them. Human-centered eligibility design does not eliminate this asymmetry, but it can mitigate its most dehumanizing effects. Exotell's principle that individuals should maintain meaningful participation in decisions that affect them, and that systems should support understanding rather than create dependency, reflects a design commitment to applicant agency.

In practice, this means designing systems that explain determinations rather than just announcing them; that provide meaningful opportunities for applicants to correct errors and provide additional information; that treat the act of applying for support as normal and dignified rather than stigmatizing; and that support applicants in understanding their options rather than simply routing them through a predetermined decision tree.

3. The Evidence Base for Human-Centered Eligibility Design

The argument for human-centered eligibility design is not merely theoretical. A growing body of evidence from government reform initiatives, academic research, and policy evaluation demonstrates that HCD approaches to eligibility produce measurable improvements in access, participation, and user experience.

Research by Moynihan, Herd, and colleagues on Medicaid enrollment and renewal has found that automatic renewal processes—a form of friction reduction—significantly increase coverage rates among eligible individuals. Their research on SNAP has found that reducing administrative checkpoints, including mandatory interviews that serve primarily a verification function, increases program participation without meaningful increases in error rates. These findings suggest that administrative burden in eligibility systems is not a necessary feature of program integrity, but a design choice with costs that fall disproportionately on applicants.

StateScoop's coverage of a 2024 Georgetown University Beeck Center convening on government benefits delivery documented emerging consensus among researchers and state officials that agencies embracing HCD are breaking down internal silos and encouraging cross-department collaborations, listening to front-line staff, and learning from the people who use the services they provide. This cultural shift—from eligibility administration as bureaucratic compliance to eligibility administration as service design—is the institutional foundation for human-centered eligibility design at scale.

The UK Government Digital Service (GDS) has provided perhaps the most extensively documented example of HCD applied to government services at scale. GOV.UK, which redesigned government information and services around user research and plain language, has been cited as a model of what user-centered government looks like in practice. In the U.S., the Digital Government Hub at the Beeck Center has compiled a growing library of HCD resources and case studies focused specifically on benefits access and eligibility.

4. Institutional and Political Challenges

Human-centered eligibility design faces significant institutional and political obstacles. Eligibility rules are not merely administrative—they reflect legislative judgments about who deserves assistance and under what conditions. Changing them requires political agreement, not just good design. And even where design improvements are within institutional discretion, they may face resistance from administrative cultures oriented toward fraud prevention rather than access, from technology vendors with interests in maintaining complexity, or from political actors who view eligibility friction as a feature rather than a bug.

Herd and Moynihan's research has documented that administrative burden in benefit programs is often politically purposeful—that friction is sometimes designed into systems to suppress participation, not just a side effect of administrative complexity. This finding does not undermine the case for HCD, but it does clarify that design improvements in eligibility systems often require political as well as technical work. Reducing administrative burden requires advocates who can make the case that access, not just integrity, is a program goal worth designing for.

There are also genuine tensions within HCD as applied to eligibility. User preferences and policy goals do not always align: applicants may prefer fewer documentation requirements than program integrity requires; institutions may prefer more flexibility than standardized federal criteria allow; different applicant populations may have different and sometimes competing needs. Navigating these tensions requires design judgment, not just user research—an understanding of the policy goals that eligibility systems are intended to serve, and a commitment to finding design solutions that serve both applicants and those goals.

5. A Framework for Evaluation

Human-centered eligibility design requires ongoing evaluation to be more than aspiration. A framework for evaluating eligibility systems against HCD principles would include the following dimensions:

• Access rate: What share of the intended population actually receives the benefit or service for which they are eligible?
• Burden experience: How do applicants experience the process of applying and maintaining eligibility? Are burdens distributed equitably across the population?
• Legibility: Do applicants understand the criteria, the process, and the outcomes of the eligibility system? Can they anticipate what will happen and why?
• Error rate and consequences: When errors occur in eligibility determination, how are they identified and corrected? Who bears the cost of administrative errors?
• Equity in outcomes: Are eligibility determinations and access rates consistent across demographic groups, or are there systematic disparities that reflect design failures?

Regular evaluation against these dimensions provides the feedback loop that makes human-centered design human-centered in practice rather than only in aspiration. Exotell's guidance system is designed as a contribution to improving access and legibility for individual students—but it is also a source of data about where the eligibility-access gap is largest and where system design most needs to improve.

6. Implications for Financial Aid

Applied specifically to financial aid, human-centered eligibility design has several concrete implications. At the federal level, it supports continued simplification of the FAFSA, expansion of automatic data exchange, and reform of the verification selection methodology to reduce burdens on low-income applicants. At the institutional level, it supports investment in financial aid counseling capacity, plain language in aid notices and award letters, proactive outreach to students who may qualify for professional judgment adjustments, and systematic evaluation of whether aid packaging practices serve the full range of enrolled students.

For guidance systems like Exotell's, HCD principles support an approach to navigation that begins with the student's situation rather than with the system's structure; that makes eligibility legible without making it seem more simple than it is; that connects students with institutional resources—financial aid counselors, institutional advocates, peer navigators—rather than substituting for them; and that treats every interaction as an opportunity to reduce the learning costs that currently prevent eligible students from accessing the aid they are owed.

7. Conclusion

Human-centered eligibility design is not a technical fix for a political problem. It will not, by itself, resolve the fundamental inequities in how financial aid resources are distributed or the structural barriers that exclude some students from federal eligibility altogether. But it represents a genuine and significant contribution to closing the gap between eligibility and access—a gap that costs eligible students resources they need and costs the higher education system the full participation of students it is designed to serve.

The principles developed in this paper—starting with the applicant's experience, reducing friction, making eligibility legible, designing for the full range of applicants, and supporting agency and dignity—are not ideals for a distant future. They are actionable design choices available to policymakers, institutions, and guidance system designers today. The evidence that they work is growing. The question is whether the institutions that administer financial aid will choose to apply them.

References

1. Herd, P., & Moynihan, D. (2018). Administrative burden: Policymaking by other means. Russell Sage Foundation.
2. Moynihan, D., Herd, P., Jilke, S., & Rodden, K. (2025). Administrative checkpoints, burdens, and human-centered design: Increasing interview access to raise SNAP participation. Journal of Policy Analysis and Management. https://onlinelibrary.wiley.com/doi/full/10.1002/pam.70007
3. Herd, P., Moynihan, D., & Widman, S. (2024). Identifying and reducing burdens in administrative processes. The Regulatory Review. https://www.theregreview.org/2024/07/01/herd-moynihan-widman-identifying-and-reducing-burdens-in-administrative-processes/
4. Administrative Conference of the United States. (2023). Identifying and reducing burdens on the public in administrative processes. https://www.acus.gov/document/identifying-and-reducing-burdens-public-administrative-processes
5. StateScoop. (2024). Future of government benefits delivery is 'human-centered,' say researchers, officials. https://statescoop.com/state-government-benefits-delivery-human-centered-design-2024/
6. Digital Government Hub / Beeck Center for Social Impact and Innovation. (2025). Human-centered design resources. Georgetown University. https://digitalgovernmenthub.org/topics/human-centered-design/
7. Eubanks, V. (2018). Automating inequality: How high-tech tools profile, police, and punish the poor. St. Martin's Press / Picador.
8. Exotell. (2026). Principles. Exotell.com. https://www.exotell.com/principles