Responses to American College Test College Outcome Measures Program (ACT-COMP) items by 481 black and 9,237 white students at the University of Tennessee (Knoxville) were analyzed using F. Samejima's graded model to determine the level of differential item functioning (DIF). Students had been tested using Form 8 of the ACT-COMP objective test either as freshmen or as seniors. The test contains 60 multiple-choice items, each of which has two correct answers. The model developed by Samejima (1969) for graded responses, which uses a series of binary models to describe polychotomous data, was used to assess the data. Student response patterns were fitted to the graded model and five items that did not fit the model were dropped. The remaining items were analyzed using threshold parameters and their standard errors to calculate difficulty-shift coefficients. Results indicate that: (1) for 32 of the 55 remaining items, significant instances of DIF are present; (2) instances of DIF are not evenly distributed among the six subscales of the ACT-COMP test; (3) questions designed to assess explanation skills produce higher rates of DIF than do questions designed to assess skills related to identification and description; and (4) activities that rely on blueprints, require interpretation of satire, or use a radio news format to produce high levels of DIF. Four data tables and nine graphs are provided. (TJH)