Colorado College is test optional starting this year.
I don’t know enough about your D’s application to make a recommendation, but the 28 is below the 25%ile per the 2018/19 CDS (mid 50%=29-33). Typically a not-insignificant proportion of students below the 25%ile are hooked in some manner such as legacy, URM, low SES, athlete, etc…is your D hooked in any manner? https://www.coloradocollege.edu/offices/ipe/common-data-set.html