When it comes to Title IV compliance, most mistakes aren’t malicious, they’re mundane.  A missed file, a policy that was never updated, or a website link that points to last year’s SAP criteria can all trigger findings during an annual audit. At FAS, we’ve seen how small missteps can turn into major risks, especially when staffing is a challenge or internal processes haven’t been reviewed in months. The good news? Most of these pitfalls are entirely preventable. 

Below are the most common (and costly) compliance mistakes, ranked by frequency in federal audits and program reviews—and what your team can do to avoid them. These insights are based on recurring findings documented in the U.S. Department of Education’s FY 2022 Top Findings Companion Report, which highlights R2T4, verification, SAP, and consumer information as common areas of noncompliance.

Return to Title IV (R2T4) Files Missing or Incomplete

• Why it matters: R2T4 consistently ranks as one of the most frequent Title IV audit findings.
• Common Misstep: Withdrawal dates aren’t accurately recorded, or R2T4 calculations are missing from the student file.
• What to do: Build a workflow that flags withdrawals in real time and ensure completed R2T4 files are stored and reviewable.

Unverified ISIR Data Leading to Premature Disbursement

• Why it matters: Disbursing aid with unresolved conflicting information is a major compliance violation.
• Common Misstep: ISIRs contain missing or conflicting data, but funds are still disbursed before resolution.
• What to do: Integrate ISIR checks into your disbursement process. Create guardrails that prevent aid from being released until eligibility is verified.

Missing or Misfiled Verification Documentation

• Why it matters: Incomplete or lost verification records put aid disbursement into question and are a frequent audit issue.
• Common Misstep: Verification documentation is inconsistent, paper-based, or missing from digital systems.
• What to do: Use a centralized, auditable tracking system and review files regularly to ensure completion and retention.

Inconsistent Application of SAP Policies

• Why it matters: Failure to apply Satisfactory Academic Progress policies uniformly can result in findings and equity concerns.
• Common Misstep: Different staff use different timelines or documentation standards for SAP reviews.
• What to do: Train staff on SAP application annually and standardize documentation templates for appeals and status changes.

Outdated Consumer Information on Public Websites

• Why it matters: Website disclosures are a compliance requirement and among the easiest for auditors to spot.
• Common Misstep: Cost of attendance or SAP info is outdated, or links are broken or missing.
• What to do: Set a quarterly review cadence to check for accuracy across all public-facing pages. 

Want to take this a step further? Explore how cross-campus partnerships impact compliance. The strongest institutions align their communication, policy ownership, and timing across departments—not just within the aid office.

Policy & Procedure Manuals That Don’t Reflect Current Practice

• Why it matters: Auditors compare written policy to actual execution—and gaps are flagged quickly.
• Common Misstep: Manuals haven’t been updated after staffing changes, regulatory shifts, or system transitions.
• What to do: Review your policies annually and document updates to show continuous improvement. 

Pro Tip: Build your compliance habits around the timing that matters most. The riskiest audit findings often happen after aid is disbursed—when schools shift from packaging to proving. Read more in The Compliance Window: Higher Ed’s Most Overlooked Audit Risk.

Mistake to Watch For: Treating Compliance Like a Once-a-Year Event

The institutions that perform best in audits aren’t perfect—they’re prepared. They’ve built compliance into the daily rhythm of their financial aid operations, not just the months before a program review. Compliance isn’t just a requirement. It’s a system of trust. And the more intentional your team is about building that trust, the fewer surprises you’ll face during a review. 

Ready to Take Action?

No matter where your team and institution is in the compliance journey, FAS can help you turn compliance from a risk into a rhythm. Connect with a consultant to assess your biggest compliance vulnerabilities, and how to get ahead of them.

With federal oversight increasing, Title IV guidance evolving, and Return to Title IV (R2T4) updates drawing sharper scrutiny, audit readiness can no longer be treated as a once-a-year event. The institutions that will emerge stronger are those treating compliance as a daily discipline—and building it into the rhythm of their operations.

Why It’s Time to Shift from Reactive to Ready

In 2025, compliance isn’t a static checklist—it’s a moving target. Presentations at NASFAA 2025 and recent federal updates all point to increased oversight in areas like satisfactory academic progress (SAP), professional judgment, and data-sharing protocols. At the same time, financial aid teams are navigating staffing shortages, technology transitions, and unclear ISIR timelines—making it easy for compliance to slip into “reactive mode.” But here’s what we’re seeing: the institutions that build a culture of audit readiness aren’t just surviving—they’re gaining trust, efficiency, and long-term resilience.

Additional Reading from FAS:

Is your institution preparing for a program review? Don’t miss this blog, “I Will Survive a Program Review” which covers lessons learned, practical tips, and advice you can apply today.

Culture Is the Carrying Force for Compliance Readiness

Whether you’re scaling a million-dollar tech startup and need to spark innovation, or leading a higher ed institution preparing for an audit, success isn’t just about the strategy—it’s about the culture that carries it.

Healthy cultures that support audit readiness are rooted in:

• Shared Purpose
• Clarity of Roles and Expectations
• Accountability
• Trust and Transparency

What That Looks Like in Practice

In our consulting work, we’ve seen that the most successful institutions aren’t the ones with the largest teams—they’re the ones that encourage and reinforce shared responsibility. Below, we have outlined the key components to consider when you work on building (or rebuilding) a compliance-ready culture.

Quarterly Self-Audits

Instead of waiting for year-end audits, pull a random sample of files throughout the year. Vary aid types, student scenarios, and program categories. This isn’t just to flag issues—it gives your team practice operating under audit-like conditions.

Shared Responsibility Across Teams

Compliance isn’t a one-person or one-department job. Successful institutions define clear roles, document their processes, and foster shared ownership. You may have a designated audit liaison, but that individual should be backed by a well-prepared and aligned team.

Documentation That Enables Action

When core processes rely on institutional memory or outdated guides, transitions become risky. Leading institutions are investing in documentation that is actively maintained and easy to follow—so staff can act quickly and confidently.

Allocated Budget for Upgrades

It’s easy to say no to compliance investments—especially in tight budget cycles. But when the team has done the groundwork, funding becomes less of a cost discussion and more of an outcome and impact discussion.

Live Compliance Dashboards

From R2T4 calculations to SAP alerts, forward-thinking teams are building dashboards that offer real-time visibility. These tools turn reactive problem-solving into proactive monitoring—and help leadership stay informed without getting into the weeds.

The Case for Building it into Institutional Culture

When audit prep is built into your rhythm—not rushed when the deadline hits—you avoid:

• Costly errors that jeopardize Title IV eligibility
• Institutional reputation risks
• Strained team dynamics and last-minute stress

And you gain:

• Clearer decision-making
• Leadership confidence
• A more resilient operation overall

Audit Readiness is a Muscle, not a Moment

The campuses we support that perform best during audits don’t wait for the deadline. They’ve built compliance into the rhythm of their operations. If your team hasn’t updated its compliance documentation, R2T4 procedures, or audit prep strategy in the last six months—it’s time. Reach out to FAS and strengthen your compliance foundation—before the next audit cycle begins. 

The summer crunch is here, and institutions are looking for effective ways to reduce summer melt. At the same time, high school graduates and their families are navigating big decisions—identifying the best educational fit and finalizing a plan to cover the cost. 

For students from diverse socio-economic backgrounds, the period between graduation and move-in is often filled with uncertainty. Reversing the melt trend takes more than reminders—it demands strategic, student-centered outreach from every corner of the enrollment team. 

So what can enrollment management leaders—from admissions and advising to financial aid, the registrar, and student accounts—do to help students cross the enrollment finish line? This post outlines practical, high-impact strategies to reduce summer melt and support students through this critical transition. 

What Strategies Reduce Summer Melt?

The drivers of summer melt are often a mix of financial uncertainty and communication gaps. Students who commit in May quietly disengage by August—not because they’ve changed their minds, but because they’ve lost clarity, confidence, or connection. 

That’s why reducing melt starts with resources two key actions:  

• Ensuring resources are visible and accessible 
• Delivering outreach communication that feels personal and timely 

When institutions meet students where they are—and stay with them through every step—they build the trust and momentum needed to carry students from commitment to campus. 

Make Student Support Accessible

The specific needs of students may vary, but the accessibility of opportunities to engage should not be based on speculation or guessing. The short answer is always to meet the student where they are. 

Ask 10 students about their preferred method of communication and you might get 10 different answers.  That’s why a multichannel approach is the foundation for success. To stay engaged with students throughout the summer, focus on multiple forms of accessibility and communication – depending on the tools and capacity within your institution.  

Multi-channel means giving students options in how they communicate and receive information. In pre-cycle planning, review your CRM or Student Information Systems to set up preferred methods and use that data to tailor your approach. 

Use Polls and Surveys to Identify Student Concerns

Don’t speculate what students are concerned about, it today’s digital age, the access and anwsers are there, all you have to do is ask. Provide surveys or “polls” using social media or email to engage the student in identifying their biggest fears or questions around showing up in the fall.   

• What’s causing hesitation? 
• What are they unsure about?  

For example, fear of the unknown, fear of not fitting in, fear of lack of funding, etc. Respond to the identified areas on a one-on-one level using personalized video messaging, emails, phone calls, texts, and other methods to address their specific concerns and offer reassurance. 

Help Students Understand College Cost Breakdown

The saying “money talks” holds true in higher education, too—especially in the weeks between high school graduation and the first day of class. Even students that are academically prepared will hesitate in the face of financial uncertainty.  

Ellucian’s Student Voice Report reinforces how even modest aid changes matter: 

“Almost half of students say a $5,000 difference in scholarship aid would change their top school choice.” 

Financial aid clarity is a key factor to ensure follow through on enrollment. Institutions should go beyond award letters and offer transparent breakdowns of actual costs and what is due out of pocket. A simple “Plan to Pay” worksheet can help students and families understand the financial reality.

A variety of examples are available online to draw inspiration from: 

• Penn State Abington Example PDF 
• Trevecca Nazarene University Example 
• New York University Geneseo Example 

The goal is clarity. When students and families can visualize the financial path ahead, they’re more likely to stay on track. 

Offer Virtual One-on-One Financial Planning Sessions

When students have a clear cost breakdown, providing personalized support can make all the difference in getting them to take action.  

Financial aid is becoming more central to enrollment, but 80% of students who applied for financial aid say they never met one-on-one with an aid administrator. It’s often a capacity issue – with many financial aid professionals managing over 2,000 cases per year, it doesn’t leave a lot of time for personal outreach. That’s where virtual sessions become a great tool. 

High-Impact Virtual Session Checklist: 

• Keep it short and structured (15–30 minutes)
• Include both financial aid and student accounts staff 
• Review the award letter together 
• Confirm the itemized student bill 
• Use the “Plan to Pay” worksheet live with the student 
• Clarify payment options and deadlines 

Strategically using technology can create space for high-value touch points—especially students who are at risk of melt without them. 

Want to get more from your tech stack?
Read Build a Financial Aid Technology Strategy for Maximum ROI for actionable insights that help you align tools, teams, and timelines.

Connect Prospective Students with Peers

Providing opportunities for incoming students to connect with current students from a range of financial backgrounds can help reduce melt. Peer connections offer valuable insight into how others have successfully managed both academics and finances during their first year. 

These peer connections can take many forms: 

• In-person meetups with current students 
• Virtual Q&A panels or student-hosted webinars 
• Phone introductions or text-based welcome messages 
• AI-powered chatbots designed with real student stories and FAQs 

Want to see what this looks like in practice? 
Read FAS Consultant Sean Hudson’s experience as a first-year parent, as he and his family navigated Xavier University’s student engagement strategy—from stadium welcome events to ongoing peer-led engagement. 👉 Read the blog [at this link.]

Provide a Summer Task Checklist

Make a task checklist available via the student portal or an AI chatbot. This checklist should guide students through key steps, such as completing Loan Entrance Counseling and signing the Master Promissory Note for those using federal student loans. Ensure deadlines and requirements are clearly explained and easy to follow. 

Turn Down the Heat with Financial Aid Services

Don’t let the summer overwhelm your financial aid team. Let’s start a conversation on ways to help your team implement strategies to beat the summer melt and prepare for a strong fall term.  

According to the Brookings Institution, 10-20% of high school seniors who are admitted to a college and indicate that they intend to attend never actually show up on the first day of class. This drop in enrollment is well known in the higher ed industry as the summer melt phenomenon. According to the Enrollify.org Blog, “Some is just inevitable, but research shows that much of it can be prevented with strategic engagement and support.”

Reasons Behind Summer Melt

There are many reasons behind the Summer Melt. Simply put, some families are willing to sacrifice non-refundable tuition deposits to keep options open. This stresses the need for admissions offices to start recruitment as soon as a potential student submits an inquiry.

So why do students melt? Years of research data show that the reasons include:

• Student Stress Factors
  • Social anxiety
  • Teenage tendency to procrastinate
  • Financial concerns
  • Distance from the campus
  • Absence of parental guidance (especially among first-generation students)
• Financial Aid Process Friction
  • Unclear deadlines
  • Confusion over paperwork
  • Inconsistent communication

New Challenges with Summer Melt

In 2025, institutions are dealing with an even more challenging summer melt experience. Some colleges have adopted the term “Intentional Melt” in recent years to describe the trend of students who deposit at more than one school, giving them more time to decide and appeal for additional financial aid. At the same time, college applicants and their families are looking for a better student experience.

Institutions can meet these expectations and improve melt by offering:

• Faster financial aid packaging
• Personalized, consistent communication
• Robust online portals that are user friendly
• Guidance on FAFSA completion and next steps

When students feel informed and supported, they are more likely to follow through and show up in the fall.

Mitigating Melt

What have colleges done in the past to mitigate melt? Institutions have learned that they must start the recruitment process early and provide estimated financial aid awards faster, even if it is just a Merit scholarship to acknowledge student success.

Colleges can keep incoming students engaged by:

• Promoting alumni success stories
• Highlighting professor-to-student ratios
• Emphasizing great things about the campus
• Publishing faculty experiences & accomplishments

Admissions offices also realized that they must employ a multi-model approach and connect with potential students via different communication channels such as texts, emails, phone calls, and social media.

Schools started tracking things such as the number of emails opened, how many times the student visited campus, how much the student is logging into the college portal, have they completed items off a new student check list (such as speaking with advisement and completed dorm surveys, and finally have they completed the Free Application for Federal Student Aid (FAFSA).

Using AI to Estimate Melt

With recent advancements in artificial intelligence (AI), Admissions offices have a powerful tool to better estimate summer melt. AI enables financial aid departments with faster calculations and datapoints to generate predictive modeling, assign melt scores, and personalize communications to prospective students.  But AI is just one piece of the puzzle. Institutions can make an impact by aligning cross-functional teams, simplifying communications, and improving student follow-up.

Reducing Summer Melt: Georgia State University

One of the first colleges to utilize AI to help reduce summer melt was Georgia State University (GSU). As highlighted by the Brookings Institution, GSU implemented a chatbot named Pounce to answer student questions 24/7 via text messages.

GSU shares on their website, “In 2016, during the first summer of implementation, Pounce delivered more than 200,000 answers to questions asked by incoming freshmen, and the university reduced summer melt by 22%.  This translated into an additional 324 students sitting in their seats for the first day of classes at Georgia State rather than sitting out the college experience.”

GSU’s research showed how, nine years ago, a chatbot could make a substantial difference.  With the daily advancements in artificial intelligence now available, summer melt might not be the profane phrase it used to be.

Xavier University’s Strategy for Summer Melt

When colleges treat onboarding as more than just paperwork—and instead focus on human connection and student confidence—the impact is felt from day one. Lauren Parcell, Dean of Admissions at Xavier University, puts it this way:

“The leap from high school to college can feel daunting, and summer often amplifies that uncertainty. We believe a smooth transition is key to student success, which is why we’re dedicated to supporting both students and families from the moment they choose Xavier. Beyond our onboarding tools, we offer personal, human-centered guidance to ensure everyone feels like part of the family, right from the start.” – Lauren Parcell, Dean of Admissions 

I’ve worked in financial aid and student accounts for 23 years—and this fall, my own son will start as a freshman at Xavier University in Cincinnati. From both a professional and personal lens, I’ve been deeply impressed by how Xavier approaches summer melt: not as a problem to solve, but as a moment to support and engage.

Xavier makes onboarding a campus wide priority and it shows:

Local Outreach Events: We attended an Accepted Students event near us at Highmark Stadium, where alumni and parents of currently enrolled students from Western New York were present for Q&A. In the spirit of making it engaging, we also received a behind-the-scenes tour of the stadium.

Celebratory Commitment Moments: During Preview Day on campus for students who were ready to commit and deposit at the school did so in the Cintas Center, their basketball arena where they were treated like 5-star recruits – complete with mascots and photo ops.

Summer-long Engagement: Over the summer, Xavier offers bi-weekly webinars for students and parents on a wide range of topics, including financial aid, dorm selection, advisement, and registration.  If we are unable to attend, pre-recorded videos are available on the user-friendly student and parent portals.

Transparent, Accessible Information: Information portals provide easy access to financial aid award letters, payment plan information, and reminders of what needs to be completed next on a checklist.

At Xavier, it is evident that onboarding new students is a campus-wide priority, and all staff and faculty are bought in.  Xavier also offers a program for students who require additional support during the transition to college. This is a huge help to first-generation students.

Finally, I found Xavier and specifically my son’s program on LinkedIn and started following both.  The information on LinkedIn solidifies that my son made a great college choice, and we are proud he will be a Musketeer this fall.

Easing the Summer Melt Headache

Summer Melt used to be a headache for colleges. It made it difficult to predict the eventual class size, which is crucial information for colleges to plan accordingly, including housing and the number of faculty needed.  However, a new era of financial aid is here. Institutions like Xavier University and Georgia State University have demonstrated that summer melt can be mitigated by employing innovative approaches.

The summer melt challenge is an opportunity for institutions to adopt strategies that lead to:

• A better enrollment model
• A better operating model
• A better student experience
• Better peace of mind

Ready to go deeper?
Summer Melt is just one symptom of a larger challenge—and the institutions seeing real results are building smarter financial aid models from the ground up.

Explore our free eBook: The Domino Effect – Aligning Financial Aid for Maximum Impact.
Discover how your financial aid office can drive enrollment, protect capacity, and build trust that lasts beyond Decision Day.