While state higher education leaders juggle response to a variety of long-term enrollment and equity questions, they now also appear to be staring down what one expert called "the college-going gap of 2021."

The rate of high school students preparing higher education financial aid applications dropped nationwide this fall amid the COVID-19 pandemic, and in Massachusetts, the declines are even more pronounced in districts with larger low-income populations or communities of color.

Those student groups already face disproportionate challenges, and the difference in financial aid applications has raised concerns among state officials that the public health crisis could widen existing gaps in access to the resources necessary to attend college or university.

"We're not going to change the direction of this without an extraordinary effort," said Chris Gabrieli, chair of the state's Board of Higher Education, during a Tuesday presentation on the trend. "Business as usual, as impeded as it is by the year's circumstances, seems likely to me -- not certain, it's all guesswork -- to lead to a lot of missed opportunities."

Education officials identified the potentially worrisome trend by analyzing rates of completion for the Free Application for Federal Student Aid, or FAFSA, which is a key indicator of whether high school seniors intend to pursue college the following fall.

Through Thanksgiving, the FAFSA completion rate was about 16 percent lower nationwide and 18 percent lower in Massachusetts than during the same span in 2019, according to data presented at Tuesday's board meeting by Department of Elementary and Secondary Education Chief Strategy and Research Officer Matt Deninger.

The change is more pronounced among more vulnerable populations: for the 50 Massachusetts high schools with the largest populations of minority and low-income students, FAFSA completion rates were down about 25 percent -- more than a third higher than the statewide figure -- from last year through Thanksgiving.

"This is not an indictment of staff or our schools not doing their jobs," Deninger said. "Rather, we believe this is a clear reflection of just an extremely challenging and disruptive year and huge levels of uncertainty as to what the future holds."

The COVID-19 pandemic has upended education across the country, shifting students abruptly to remote learning in the spring and then placing them in an array of different in-person, hybrid or virtual models this fall.

In addition to the major education and economic stressors many families are facing during the upheaval, officials said remote learning in particular could be a key factor behind the disparate decline in FAFSA rates.

Many of the largest urban school districts in Massachusetts remain in models where most students are learning from home every day, where they have less access to guidance counselors and other support staff that play a key role in determining post-high school plans.

"My colleagues that are fully remote just say it is so hard to even have the students engage in their academics, so I can only imagine with a guidance counselor trying to reach out and promote FAFSA being completed just must be an enormous task," said Sheila Harrity, the Board of Higher Education's vice chair and Superintendent-Director at the Montachusett Regional Vocational Technical School District.

Behind the trend, Deninger said, the difference in FAFSA completion rates by individual school varies significantly.

Most of the schools on the list of 50 with the largest nonwhite and low-income populations saw completion rates drop in the sample timeframe, six by more than 60 percent. Several others, though, saw their rates increase.

Deninger also stressed that the trend could still change over the next few months. High school seniors can fill out the FAFSA "well into the spring," he said, so the gap could grow or shrink.

State education officials plan to work with school counselors over the next few months, aiming to connect with both the statewide association of counselors and with individual departments in districts where the impacts are most significant.

Gabrieli noted that the drop in financial aid applications could create significant ripple effects, potentially exacerbating challenges that many community colleges and state universities face to enroll enough students to make ends meet.

"Today's FAFSA problem is tomorrow's enrollment problem, and more importantly, is our moral problem," he said.