No doubt, some can’t. However, as the above-cited Washington Post article indicates, some can.
Consider “Student G” in that article. This student’s Parental Adjusted Gross Income is $213,421. His/her EFC is $57,901. S/he decided to attend F&M. Presumably, his/her family thought they could afford it.
For 2012-13, F&M awarded nearly $35M in institutional grant aid.
For the same year, Muhlenberg College awarded about $25M in institutional grant aid.
The two schools enroll approximately the same number of undergraduates.
For 2012-13 F&M claimed to meet 100% of demonstrated financial need.
Muhlenberg claimed to meet 91.8%, on average. So in both total volume of grant aid, and in average coverage of need, F&M appears to be much more generous (based on Common Data Set figures). However, Muhlenberg does award much more merit aid than F&M. For 2012-13, F&M only awarded 1 merit scholarship (worth $2500). Muhlenberg awarded 191 (averaging $9858).
Typically the richer, higher-ranked, more selective colleges do tend to emphasize need-based rather than merit aid. For a very well-qualified, low- to middle-income student, it may make sense to focus on need-based aid. For a higher income student who needs a discount, pursuing merit aid is the way to go.