In today's climate, and based soley on National Scholarship direct from High School, your probably right.
My point is that there are many other ROTC Scholarship opportunities besides the National Scholarship.
The OP asked why the minimum was so low and if there were scholarship awardees with the minimum ACT score. The min. is set this low as a benchmark, when recruiting is good the bar is set higher, when recruiting is poor, the bar is set lower. The minimum ACT also sets a number for those that are eligible to receive campus scholarships.
Cadets can receive a campus scholarship, their ACT score in these cases are not a major factor other then the minimum. The battalion looks at how the cadet is performing in college.
School choices can make a big difference for AROTC, applicants with low ACT scores (The Minimum) could still have a shot at some schools that have difficulty filling their scholarship numbers.
The ACT scores, while a big part of the Academice section of the application, is not the only part. AROTC looks at the Whole Person Score. When my son applied he had a 24 ACT, most on this board said he had a very slim chance of receiving a scholarship due to his low ACT. As it turned out, he received a 4 year scholarship to 5 schools on the first board of the year. The entire application as well as school choices is what determines a scholarship award. Don't get me started on standardized testing, that's a whole different discussion. If one was to believe the experts, my son should be struggling in college due to his lower ACT scores, this is not the case.
So, are there cadets currently on scholarship that had a 22 ACT, I would assume there are. They may not have received the National Scholarship, but a scholarship is a scholarship.