On March 14, 2023, the US Department of Education announced that the Enforcement Office of Federal Student Aid (FSA) will use secret shoppers as a tool to monitor compliance with the laws and regulations governing federal student aid programs. These secret shoppers will evaluate recruitment, enrollment, financial aid, and other practices to help identify potentially deceptive or predatory practices used to recruit and enroll students. This may seem foreboding to some college leadership, but it doesn’t have to be viewed as a liability – especially if you have already done a Secret Student exercise to proactively identify any challenges or gaps in your students’ experience.  Some may view Secret Students as a negative “gotcha” moment, but the reality is that there is always room for improvement as communities and student populations change – and their needs evolve. It is our belief that Secret Students give you an opportunity to get a first-hand look at how a prospect, applicant, and new student interpret their interactions with your college, including: 

• The recruitment and application process 
• A student’s perspective of completing the steps to enroll 
• Effectiveness of onboarding activities and curriculum 
• How the mission and values of your college are communicated to students and their families

Completing a Secret Student exercise before the FSA Secret Shoppers are deployed will not only help flag potential federal compliance challenges, but will benefit your student population as a whole. Through our Secret Student work with clients like Morgan State University and Northeast Wisconsin Technical College, we’ve been able to help college leadership answer questions such as: 

1. Does our student experience make our students feel valued, supported and encouraged? 
2. Are our college processes set up to benefit the student or to support business processes? 
3. How are my prospective students engaged before they apply? 
4. What is the customer service experience for new students and their families? 
5. Does my college clearly explain the enrollment steps and guide students through the process? 
6. How are we sharing the resources and support systems in place to help students be successful?

Now is the time to make sure that you feel confident with how your college is moving students through the enrollment funnel. But time and human resources are always limited; if Swim can help you complete this analysis or you’d like to learn more, you can contact us for an introduction. 

Preparing for Secret Shopper Oversight

When BridgeValley issued a call for consulting support on a wide-ranging Student Experience project, we understood immediately that this was a partnership rooted in purpose. The college’s leadership had already laid important groundwork and was seeking a team that could bring structure, strategy, and real-world execution. From our first meetings on campus, we took time to understand the college’s landscape. We reviewed legacy processes, met with frontline staff, and asked questions that got to the heart of how students were experiencing BridgeValley. That work led to a shared plan built not around theory, but around the people and processes that make the college move. As President Dr. Casey K. Sacks said, “We wanted a seamless experience for our students from the first touchpoint to the first day of class.” That clarity helped guide every phase of the project. Amid shifting landscapes in federal student aid oversight, the U.S. Department of Education recently rolled out a nationwide fraud-prevention initiative aimed at strengthening protections for both institutions and students. Beginning with the Fall 2025 FAFSA cycle, Federal Student Aid (FSA) will require live identity validation for certain first-time applicants—either in-person or via video—to curb a rising wave of stolen-identity fraud and safeguard taxpayer dollars. While this effort is not a replacement for secret shopper evaluations, it underscores the DOE’s broader commitment to accurate, transparent enrollment processes, reinforcing the same institutional integrity that Secret Student exercises help colleges uphold and exceed. For some college leaders, the idea of federal secret shoppers still feels daunting. But it doesn’t have to be viewed as a liability—especially if your institution has already conducted a Secret Student exercise to proactively identify challenges or gaps in the student journey. Too often, Secret Student work is seen as a negative “gotcha” moment. In reality, it is an opportunity. Communities evolve, student populations change, and their needs shift over time. A Secret Student exercise offers a firsthand perspective on how prospective and new students interpret their interactions with your college, including:

• The recruitment and application process 
• The experience of completing enrollment steps 
• The effectiveness of onboarding activities and curriculum 
• How your mission and values are communicated to students and families

Completing this work prior to the deployment of FSA secret shoppers allows leaders to not only flag potential compliance challenges but also strengthen the student experience overall. Through our Secret Student projects with institutions such as Morgan State University and Northeast Wisconsin Technical College, we have helped college leaders explore critical questions, including:

• Do our students feel valued, supported, and encouraged? 
• Are our processes designed to benefit students—or primarily to support business operations? 
• How are prospective students engaged before they apply? 
• What is the customer service experience for new students and their families? 
• Are enrollment steps clearly explained and guided? 
• Are students aware of the resources and support systems available to help them succeed?

Now is the time to ensure confidence in how your institution moves students through the enrollment funnel. Recognizing that time and human resources are often limited, Swim stands ready to support you in conducting this analysis. If you’d like to learn more, we invite you to connect with us for an introduction.