THE Department of Education proposal to prohibit colleges that receive federal money from giving out scholarships on the basis of race should not, in theory, stop black students from getting aid.The new rules proposed by Secretary of Education Lamar Alexander refine a controversial proposal offered a year ago by department official Michael Williams. That proposal was later withdrawn by the White House. Mr. Alexander's plan purports to bring scholarship criteria into accord with Title VI of the 1964 Civil Rights Act, which outlaws discrimination based on race or national origin. If adopted, the ban would take effect in four years. It would not apply to special scholarship categories created by Congress - for example, a program to develop black or Hispanic engineers. Nor would it reverse scholarships awarded on the basis of past discrimination - such as those at numerous Southern schools that are under c ourt order to desegregate. What the change means is that schools may not create separate "race based" categories for awards. In practice, the difference would largely be administrative. Schools would have to come up with more complex criteria for scholarships - not a bad idea if carefully done. Rather than tailoring scholarships to blacks, schools could award them on, say, a flexible point system - making "need" 1 point, "academics" 1 point, and "race" 2 points. The goal can be achieved without making race the only criterion. Still, what does the administration gain by refining the rules just now - other than gratifying some conservatives? Is that worth deepening the popular perception of a White House out of touch with blacks? The argument that the new rules hew closer to the race-neutral Civil Rights Act is technically correct. But the spirit of that law was against exclusion, whereas race-based scholarships were set up to promote inclusion of minorities in higher education. The White House should correct the impression that fewer scholarships are available to blacks. Given the amount of money available today, any guidance counselor unable to find a scholarship or aid for an African-American (especially a male) with a credible academic record and a proven need probably should be looking for another job. Civil-rights leaders and educators must not, for their own political reasons, put out the word that aid is now harder to get, if it isn't. That's a disservice to minorities. The often-made argument that blacks need separate scholarships because they don't do well "filling out paperwork" itself smacks of racism. Yet in line with civil rights gains over the past two decades, young blacks from families on the margins of the middle class should get extra attention. Any rule change hampering these youngsters is wrong. The country needs to better educate its minority students, which will constitute an ever larger part of its work force. President Bush should see to it that the proposed rule doesn't work against this.