Responding last week to the Department of Education's report on civil rights compliance by Southern colleges and universities, Mary Frances Berry of the U.S. Civil Rights Commission said that "higher education in the South remains racially segregated" and that the report "compounds the problem" by eliminating "even the hope of any kind of pressure" to change that condition. To an extent she is right on both counts; but her criticism of the department's ruling, like that of others who leaped to attack it, gets only part of the way to the truth.

Eighteen years after 10 Southern and border states were informed by the federal government that their systems of public higher education were in violation of the Civil Rights Act of 1964, Secretary of Education William Bennett has found that four -- Arkansas, North Carolina, South Carolina and West Virginia -- are in "full compliance" with its regulations and that the other six -- Delaware, Florida, Georgia, Missouri, Oklahoma and Virginia -- are only in "partial compliance." Overall, though, Bennett said that "in any one of these 10 states, a black student who graduates from high school has opportunities to go to college and will find, if he has qualifications, many institutions eager to have him."

That is true; it is also true, as Bennett's critics claim, that the six offending states will have to correct only trivial violations in order to be declared in compliance, which is to say that the Reagan administration gives every sign of pulling away from a vigorous role -- as if it had ever pursued one in the first place -- in enforcing the desegregation of higher education. As a symbolic action this is regrettable, especially at a time when college enrollment of black males is declining and when campus racial tensions are increasing; but as governmental and education policy it is, if not exactly laudable, entirely understandable.

The main reason for this is that segregation -- or benign neglect, or discrimination, or whatever one cares to call it -- in higher education is anything but a Southern problem; it is a national one, and to single out the Southern states for federal supervision can no longer be justified, now that de jure segregation has been eliminated in the region and de facto is steadily diminishing. Though a case can certainly be made that concentration on a single region, even if unfair, is better than concentration on no region at all, it remains that to focus all federal attention on the South is to deny (quite conveniently, for many people in both politics and education) the far larger and broader pattern of discrimination.

The unpleasant fact is that nearly a quarter-century after passage of the great civil rights legislation of the 1960s, there remain two worlds of American higher education. One is that of predominantly black colleges and universities, in which black enrollment runs between 80 and 90 percent -- or even more at some institutions. The other is the world of colleges and universities that are nominally open to all but that are, in fact, overwhelmingly -- almost exclusively -- white or, these days, white and Oriental.

Consider the dreary facts. Here (from the 17th edition of "Lovejoy's College Guide") are the black enrollments at several prominent state universities in the South: South Carolina, 15.1 percent; Virginia, 10 percent; Georgia, 4.5 percent; Arkansas, 5 percent; Mississippi, 7 percent; North Carolina at Chapel Hill, 8.4 percent. And here are the figures for comparable institutions in the North and West (in some parts of which, of course, black population is relatively low): New York at Stony Brook, 6 percent; Arizona, 2 percent; Nebraska, 1.7 percent; Michigan, 6 percent; Wisconsin, 2 percent; Illinois, 3 percent; Colorado, 1 percent; Pennsylvania, 3.3 percent.

At the University of Nevada-Las Vegas, which customarily has five black basketball players on its starting basketball team and at least as many on the bench, black enrollment is 6 percent; at the University of Oklahoma, which fields a predominantly black football team, black enrollment is 4 percent. The inescapable truth is that although a number of public (and private) colleges and universities have made genuine good-faith efforts to bring more black students and faculty to their campus, the picture overall is that of a system in which blacks are welcomed, and exploited, for their athletic skills, but otherwise are permitted only a token presence.

Discrimination has a great deal to do with this, but it is by no means the only explanation. Critics of Bennett's ruling do well to bear in mind that the loyalty of the black middle class to its own institutions is intense, and helps explain the preference that many of its children express for predominantly black colleges and universities. A child whose parents attended Morgan State or North Carolina A&T may lean to that university just as a child whose parents attended Purdue or Auburn may lean in that direction; the black institutions may have begun as the offspring of discrimination, but they exist now as invaluable and treasured parts of the black community.

Thus Bennett has done well to place his strongest emphasis, in laying out terms by which the offending states can achieve "full compliance," on commitments by these states to give full support to the publicly financed black colleges within their borders. To do so is not to capitulate to prejudice or separatism, but to recognize the crucial role these institutions have played, and will continue to play, in black American culture. Black Americans do not want these schools eliminated or even absorbed into multiracial statewide systems; as reactions to efforts to close or merge them have shown over and again, political sentiment for their perpetuation is powerful -- and, in some Southern states, irresistible.

It is quite true that in a better world than the one we inhabit all colleges and universities -- indeed, all institutions of all kinds -- would precisely reflect that world's racial, ethnic and social composition. But in the real world in which we live, that is a virtual impossibility: Even when, as is sometimes the case, intentions are of the very best and the laws are enforced with the utmost precision, social engineering never produces the pristine results that its adherents envision. If anything, the case can be made that our system of higher education accurately reflects the society of which it is a part: racially divided but trying, honestly if intermittently, to be otherwise.

As an old-fashioned integrationist I take no pleasure in this reality, but Bennett's appraisal of the situation strikes me as correct: Black students have better and broader opportunities than they did a quarter-century ago, and the process of improvement is far from complete. But his critics also have a point: This is no time to be pulling away from the national commitment to a fully open educational system. Though I am disinclined to question Bennett's own bona fides on civil rights, it is quite undeniable that he is a spokesman -- a vocal, ardent and highly visible one -- for an administration that has made manifold expression of its indifference to, if not contempt for, black Americans. The proof of the pudding will lie in whether Bennett now lets civil rights slip "out of the loop," or whether he uses his bully pulpit to press the universities to be as open in fact as they claim to be in name.