Corrective Action Plans

Views of responsible officials and planned corrective actions: The University agrees with the auditors' finding and recommendations. The following corrective actions have been taken: During the 2023-2024 academic year, EngageKY implemented a new process for recordkeeping related to the recruitment and selection of Kentucky College Coaches. As part of the implementation, site supervisors and program staff began to use Salesforce to maintain notes from screening interviews and general interviews. The missing documentation referenced in this finding was for individuals hired prior to the new process. EngageKY will continue to use Salesforce to document the recruitment and selection of Kentucky College Coaches.

Finding 2025-001 Budget Violations Name of contact person: Jen Waterhouse, Chief Financial Officer Corrective Action: Proposed completion date: Finding 2025-002 Inaccurate Information Entry Name of contact person: Sabrina Magedanz, Medicaid Program Manager Corrective Action: Proposed completion date: Corrective Actions for Finding 2025-002 also apply to State Award Findings. Corrective Action Plan For the Year Ended June 30, 2025 Section II - Financial Statement Findings Training for understanding Subscription Based Information Technology Agreements (SBITA) is a priority and will be conducted immediately. In FY26, SBITA’s will be reviewed and recorded quarterly via a budgeting worksheet to capture payments throughout the year for GASB 96 agreements. In May, the list will be monitored closely, and Finance staff will follow up with departments to confirm anticipated expenditures falling under GASB 96 are taken into consideration. Reports will be reviewed by the Chief Financial Officer for correctness, and the budget amendment will be in place in the first Board of Commissioner’s meeting in June 2026. In addition to the Budget Amendment taking place in early June; staff will also reconcile debt book GASB 96 reports to ensure complete records and agreement with prior year balances are intact. 6/8/2026 Section III - Federal Award Findings and Questioned Costs Training will be conducted with staff specifically concerning the finding areas , ensuring all required request for information and electronic verification sources are used, ensuring all verified information is appropriately updated in NC FAST evidence and ensuring all timeframes are adhered to when processing actions. Second party reviews will be enhanced to ensure those conducting the review verify that proper procedures are being followed with regard to these policies. Section IV - State Award Findings and Questioned Costs 12/5/2025 􀀔􀀚􀀕

The financial aid office is under new leadership as of January 1, 2025. During 2025, department leadership began its review of departmental policies and procedures, focusing on remediating compliance weaknesses within the department while moving toward best practice in federal and state aid delivery. Department leadership has put structures in place at multiple points of potential failure to prevent inaccurate aid calculations. These structures include new policy and procedure documentation, enhanced optimization in the Banner system, staff training in multiple modalities including intradepartmental training, asynchronous independent training, off-site training, and a monthly reconciliation program with AVC’s fiscal office. We have also begun a system of cross training to ensure that expertise persists within the department during times of staffing changes, extended leaves of absence, and vacancies.

Lack of Review Documentation (Significant Deficiency) Condition: Four participants were selected for eligibility test work for the Upward Bound Math and Science (UBMS) program. All four of these participants applications did not have any indication that they were reviewed or approved by the appropriate program director before receiving services from the program. Criteria: Based on the clients controls over TRIO eligibility, the program directors obtain various documents from the participant in order to make a determination of eligibility prior to the participant receiving services from the program. It was noted during the testing of the Talent Search – Upward Bound Math and Science program (UBMS) program eligibility that there is no documentation to indicate that applications were formally reviewed or approved by the program director. Cause: Required internal control review procedures were not documented and hence, no evidence was available to support that such review was performed. Effect: Although the students tested appear to be eligible to receive program services, this lack of program director review could’ve led to students that weren’t eligible receiving program services. Identification of repeat finding: No. Recommendation: The University should increase in efforts through training to ensure that all controls related to eligibility for all TRIO programs are properly followed. Views of Responsible Officials: As noted in the audit finding, auditor sample testing disclosed no instances of noncompliance related to participant eligibility to receive program services. While the University’s internal controls over compliance were not fully documented (lack of support proving eligibility review), at a minimum, University staff were aware of program eligibility requirements and first level internal controls functioned properly (no compliance sample errors). Going forward, the University will more stringently adhere to its procedures that include documentation of program eligibility review. Corrective Action: To strengthen internal controls, the TRIO program has implemented a corrective action plan requiring that all application forms be thoroughly reviewed for completion and proper authorization prior to submission. Each form must now include a verified approval signature from the designated supervisor or administrator. Furthermore, all approved TRIO application forms are securely uploaded and stored in the University's OneDrive system, allowing authorized personnel to view, track and confirm approvals in real time. This corrective action ensures documentation integrity, promotes transparency, and supports continuous program readiness for internal and external review. The following documentation protocols will ensure full compliance and transparency for all application forms. *Be thoroughly completed with no missing fields or attachments. *Include a verified approval signature from the designated supervisor or authorized administrator before acceptance. *Be uploaded immediately to the University's secure OneDrive system for real-time viewing, tracking and audit accesss by authorized personnel by the 15th of every month. This process creates a standardized worflow that ensures every TRIO form is accurately documented, authorized, and available for verification at all stages of the review cycle. Responsible Person(s): Stephanie White, AVP/Comptroller swhite@vuu.edu 804 257-5745 Linda Jackson, VP Sponsored Research and Innovation lrjackson@vuu.edu 804 257-5807 Gloria Foote, Grant Accountant gjfoote@vuu.ed 804 257-5781. Planned date of Completion of Corrective Action: December 31, 2025

Finding No: 2025-004 Condition: The District receives Title I funding and determines eligibility for schoolwide programs based on attendance numbers derived from free and reduced lunch counts. During the audit, we noted that the district’s process for compiling these attendance numbers involves the grant manager obtaining a report from the Business Office, which is generated from the food service platform as of a specific day. However, the district was unable to reproduce the report used to complete the Title I application and supporting documentation for the reported figures was not available for review. Plan: The District will maintain all reports used to compile attendance figures for the Title I grant. Anticipated Date of Completion: June 30, 2026 Name of Contact Person: Mark Orszula, CSBO

U.S. Department of Agriculture Passed Through the North Dakota Department of Public Instruction and the Minnesota Department of Human Services Federal Financial Assistance Listing # 10.568 All Awards Federal Financial Assistance Listing # 10.569 All Awards Food Distribution Cluster Finding Summary: As part of the audit done by Eide Bailly LLP, a lack of internal controls were identified in eligibility determinations and reviews for The Emergency Food Assistance Programs. Responsible Individuals: Kate Molbert, COO David Stachon, CFO Corrective Action Plan: The GPFB will ensure all documents for TEFAP programs have proper signatures by necessary parties going forward. An electronic signature process has been implemented to make the dissemination, review and storage of this process easier. Also, additional staffing has been hired to manage this process in the form of a Programs and Operations Compliance Manager with substantial compliance experience. Anticipated Completion Date: Immediate

Condition & Criteria: For three aviation program students, cost of attendance calculations were based on expected high-cost courses, but actual enrollment differed, resulting in overstated costs and excess aid disbursement. Auditor’s Recommendation: Adjust cost of attendance based on actual courses attended and fees incurred. Corrective Action: The Financial Aid Department now verifies actual course enrollment prior to disbursement for specialized programs, ensuring accuracy and compliance. Beginning Winter term 2026, mid-term audits for the aviation program have been implemented to strengthen oversight. Additionally, policy updates now require real-time cost of attendance adjustments for all individualized programs to maintain consistency and alignment with federal regulations. Responsible Person: Director of Financial Aid, with support from Aviation Program Director. Anticipated Completion Date: Begin implementation immediately and accomplish full implementation by Spring 2026; ongoing monitoring.

The District will implement additional internal controls to ensure that all household income is properly included in the eligibility determination process for free and reduced-price meals. The Food Service Director (or authorized designee) will perform a second-level review of all applications prior to final approval, focusing on verification that all sources of income - including income earned by students - are included in the total household calculation. The District will update its internal checklist and train staff responsible for reviewing meal applications to verify that each application is complete, income sources are clearly identified, and supporting documentation (if applicable) has been properly considered. The Food Service Director will conduct a mid-year self-audit of eligibility determinations to confirm accuracy and compliance with 7 CFR 245.6 requirements. The District will maintain documentation of reviews and training to support compliance efforts in furter audits.

2025-001 – ALN 14.850 – Public Housing Operating Fund – Eligibility Current management acknowledges the finding and is following the auditor’s recommendations. Person Responsible for Correction of Exception: Mr. Tony Webster, Executive Director Projected Completion Date: June 30, 2026

A. Finding Finding 2025-001 – Moving to Work Resident Files – Eligibility – Rent Calculations & HAP Disbursements Noncompliance & Material Weakness – ALN #14.881 B. Condition and Cause The auditor reviewed fifteen (15) Housing Choice Voucher (HCV) project-based voucher (PBV) participant files and twenty (20) HCV tenant-based voucher (TBV) participant files for a total of thirty-five (35) participant files. It was noted that fourteen (14) TBV files were non-compliant. C. Background Information The HCV Department has had numerous staff turnover in recent years. Due to organizational restructuring, Shannon Walters was moved from HCV Manager to Multi-Family Housing Director in March 2024 and Todd James was promoted to Interim HCV Manager in March 2024. Todd was moved to the HCV Operations Administrator position in February 2025, and Charlotte Bowen was hired as HCV Manager in March 2025. Mary Cameron was hired as HCV Caseworker (TBV) in December 2023 and received extensive one-on-one training. Due to performance concerns, she was given a Performance Improvement Plan. Upon completion, her performance was found to be unsatisfactory. Mary was transferred to Property Manager at the LaFayette Housing Authority site in October 2025. D. Controls to Correct the Deficiency To correct the finding noted above, the Auburn Housing Authority (AHA) will proceed as follows: a. The HCV Manager will perform a comprehensive audit of all TBV files and correct appliable deficiencies. b. Implement other internal control measures to eliminate future audit findings. E. Person Responsible: Sharon N. Tolbert, CEO F. Anticipated Completion Date: June 30, 2026

Address weaknesses in eligibility verification and waiting list management: 1. Policy Review: Review and verify that the Admissions and Continued Occupancy Policy (ACOP) clearly states the requirement that all admissions originate from the approved waiting list and what documentation is required to be in the participate file as waitlist verification 2. Staff Training: Provide refresher training for Public Housing staff on eligibility verification and waiting list procedures. Require dual staff sign-off on all new admissions to confirm eligibility and waiting list documentation before lease execution. 3. Waiting List Audit: Conduct a semi-annual audit of waiting list transactions to ensure documentation accuracy and selection order compliance. 4. Software Updates: Review and select a new software to assist with income item collection. Software should allow residents to upload and store documentation. This will allow greater transparency as the residents and staff will view the same information. In addition, all information would be date and time stamped to ensure tasks were completed in a timely manner.

Corrective Action: The Public Housing Authority (PHA) will strengthen eligibility determination procedures for the Housing Choice Voucher Program by implementing the following measures: 1. Policy Reinforcement: Review and update, if necessary, the Administrative Plan to explicitly outline required eligibility documentation and verification steps. 2. Staff Training: Conduct training sessions for HCV Specialists on verifying income, assets, and household composition. Staff to begin using HUD’s CPD calculator to calculate income. 3. Quality Control Review: Implement a quarterly supervisory review, by the Housing Manager, of a random 10% sample of tenant files to ensure accuracy in income calculation and documentation. 4. File Checklist: Implement file checklists in each file to ensure all items are collected correctly and available for compliance review. 5. Software Updates: Review and select a new software to assist with income item collection. Also implement the use of DocuSign to obtain signatures.

Oversight Agency for Audit, Senior Citizens Housing Development Corporation of Los Angeles respectfully submits the following corrective action plan for the year ended June 30, 2025. Name and address of independent public accounting firm: Bellows Associates, P.A., 5401 N University Drive, Suite 201, Coral Springs, Florida 33067. Audit period: July 1, 2024 through June 30, 2025 The finding from the June 30, 2025 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. SECTION III – FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAMS AUDIT FINDING No. 2025-001: Section 202 Supportive Housing for the Elderly, ALN 14.157 Recommendation: The Project should implement procedures to ensure that initial and ongoing tenant eligibility documentation is obtained timely and properly maintained. Action Taken: Staff training has been provided with additional HUD training inclusive of EIV reporting and tenant file maintenance and included in monthly report procedures. If the Oversight Agency for Audit has questions regarding these plans, please call Irene Phillips at 954-835-9200. Sincerely yours, Irene Phillips CFO

Corrective Action Plan December 18, 2025 Massachusetts Department of Elementary and Secondary Education Office of Charter Schools and School Redesign 135 Santilli Highway Everett, MA 02149 Lawrence Family Development Charter School respectfully submits the following corrective action plan for the year ended June 30, 2025: AAF CPAS 50 Washington Street Westborough, MA 01581 Audit period: July 1, 2024 to June 30, 2025 (Fiscal Year 2025) The findings from the December 22nd schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS - FINANCIAL STATEMENT AUDIT FINDINGS SIGNIFICANT DEFICIENCY 2025-01 Massachusetts Teachers' Retirement Board (MTRB) Remittances Regulations outlined in DESE's Charter School Audit Guide require Massachusetts Teachers' Retirement System (MTRS) payroll withholdings to be remitted to the MTRB within ten days of the following month. During our compliance testing, we noted nine instances, out of twelve months tested, for which the MTRS payroll withholdings were not remitted to the MTRB within ten days of the following month. Recommendation: In order to comply with Commonwealth of Massachusetts' MTRB regulations and charter school compliance requirements established by DESE, management should ensure that controls are in place to ensure all MTRS payroll withholdings are remitted timely. Action Taken: We concur with the recommendation, and LFDCS has implemented a policy requiring all MTRS payments to be completed within the first ten calendar days of each month. Effective Date: December 1, 2025 SIGNIFICANT DEFICIENCY 2025-02 Payroll Records The Federal government requires Form I-9's be maintained for all eligible employees. Out of the twenty-five selections tested, we noted one 1-9 form which was not properly completed by the School. We also noted four additional selections where the 1-9 form was unable to be located. We also noted there was no supporting documentation maintained for two W-4 forms. The School experienced turnover in the accounting and finance department during fiscal year 2025. Review of required document was not performed on a timely basis. Because of the failure to maintain required forms, ineligible employees may be added to payroll. Recommendation: Procedures should be implemented requiring the completion of required forms and the formal review and approval should be performed prior to adding employees to payroll. Action Taken: We concur with the recommendation, and LFDCS has implemented procedures to review personnel files for completeness and accuracy before new employees begin working at the school. Effective Date: December 1, 2025 2025-03 General Ledger Maintenance During fiscal year 2025, several general ledger accounts were not properly reconciled to their respective subsidiary ledgers, journals, or supporting schedules. In certain instances, reconciliations were prepared; however, variances were not clearly identified, investigated, or resolved. In other cases, reconciliations were performed in an untimely manner. The accounts affected included revenue and the related Federal expenditures, cash, accounts receivable, accounts payable, and due from Lawrence Prospera (the Fund). Unreconciled variances were also noted in various expense and accrued expense balances. Recommendation: Management should implement policies and procedures to ensure that all general ledger accounts are reconciled to the respective subsidiary ledgers, journals, or supporting schedules on a timely basis. Any variances identified during the reconciliation process should be promptly investigated and resolved to maintain the accuracy and reliability of the financial statements and ensure compliance with Federal grant reporting requirements. Implementing these procedures will strengthen internal controls, help prevent potential misstatements in the financial statements, and facilitate a smoother and more efficient audit process. Action In-Process: We concur with the auditor's recommendation. The LFDCS is in the process of implementing an accounting system while also developing accounting policies that set comprehensive standards and procedures to ensure the integrity and accuracy of the General Ledger (GL). The completed policy will include internal controls to safeguard financial data, prevent errors, and reduce the risk of fraud. It will also require segregation of duties by defining distinct roles for authorization, data entry, and review so that no individual is responsible for both recording transactions and reconciling accounts. These measures will provide accurate verification of assets and liabilities through monthly balance sheet account reconciliations and will enable timely and reliable financial reporting and budget-to-actual variation analysis. Anticipated Effective Date: March 1, 2026 2025-04 Bank Reconciliations During the fiscal year 2025 audit, we noted that the School's operating bank account reconciliations had not been prepared for several months after month end and did not agree to the reconciled bank balance. As a result, a large year-end adjustment was required before the audit to record previously unrecorded transactions in the general ledger. When bank reconciliations are not performed consistently and in a timely manner, there is an increased risk of unauthorized transactions or bank errors going undetected. Management should prepare bank reconciliations immediately upon receipt of the monthly bank statement, further, any outstanding checks which have not cleared within a reasonable time should be investigated upon completion of the monthly reconciliation. Recommendation: There is a lack of segregation of duties as it relates to the bank reconciliation process. The same employee who prepares the bank reconciliations also records the related journal entries in the general ledger. In addition, we did not observe evidence of management review or approval of the bank reconciliations prior to recording activity in the accounting records. This lack of segregation of duties increases the risk of errors or potentially resulting in misstatements of cash balances or unauthorized transactions. Action In-Process: We concur with the auditor's recommendation. Once the accounting system implementation is complete, LFDCS will adopt a reconciliation policy that ensures all cash transactions are properly recorded, complete, and any differences are resolved within ten days of the bank statement closing date. High-volume accounts will be reconciled weekly or more frequently as needed. To maintain sufficient segregation of duties, the Finance Team will prepare the reconciliations while the Director of Finance or another designated approver review and approve them. Under no circumstances will the same person prepare and approve the reconciliation. Additionally, the School will set up an integration between its bank and QuickBooks Online so that bank-cleared transactions are automatically downloaded, reducing manual data entry and increasing the efficiency and accuracy of the reconciliation process. Any discrepancies identified during the process will be investigated and corrected within ten days of month-end, and all reconciliations will be securely saved and readily available. Anticipated Effective Date: March 1, 2026 MATERIAL INSTANCE OF NONCOMPLIANCE 2025-05 Certified Procurement Officer Regulations outlined in the Massachusetts Department of Elementary and Secondary Education's (DESE) Charter School Audit Guide require a charter school administrator who serves as procurement officer to have a valid Massachusetts Certified Public Purchasing Official (MCPPO) designation. During fiscal year 2025, we noted that the School does not have any administrator who has MCPPO designation. Recommendation: In order to comply with DESE's procurement requirements, management should ensure that proper controls are in place and operating effectively to ensure that a designated individual has enrolled and receives a valid MCPPO designation. Management should also develop a checklist that tracks expiration date for MCPPO eligible employees to ensure timely renewal. Action In-Process: We concur with the auditor's recommendation. LFDCS acknowledges the requirement outlined in the Massachusetts Department of Elementary and Secondary Education's (DESE) Charter School Audit Guide that a charter school administrator serving as the procurement officer must hold a valid Massachusetts Certified Public Purchasing Official (MCPPO) designation. To comply with this requirement, the directors of facilities and finance in addition to the grant accountant will enroll in the MCPPO certification program offered by the Massachusetts Office of the Inspector General and ensure they complete the training if not certification process. LFDCS will also implement internal controls to track MCPPO certification status and expiration dates to ensure compliance and timely renewal. The Finance Director completed the initial course, Public Contracting Overview, on December 17th, 2025. Anticipated Effective Date: May 1, 2026 If the Department of Education and Secondary Education has questions regarding LFDCS's plans, please call Mark Ventre, Director of Finance, at 978.216.0461, extension 185. Sincerely yours, Signature : Mark Ventre Email: mventre@lfdcs.org Mark Ventre Director of Finance Lawrence Family Development Charter School

Name of Contact Person: Tonya Vannasdall, Director. Recommendation: We recommend that the Council perform a file review on all recipients to ensure that documentation of eligibility is retained. Secondarily, we recommend that Council strengthen its procedures to ensure that all required eligibility documentation is obtained and retained prior to authorizing program participation and charging costs to the federal award. Corrective Action: The Executive Director will implement a file review process and a process to ensure each file contains documentation of eligibility. Proposed Completion Date: Immediately.

Recommendation #1: We recommend the District develop a system to review the maintenance of effort )MOE) calculations with all supporting documentation before submitting it to NYSED. Response: The District accepts this finding and has trained the new staff members on implementing this recommendation to gather the Maintenance of Effort (MOE) calculations. Anticipated Completion Date: March 2026 Person Responsible for Corrective Action Plan: Jerel Cokley - Asst. Supt. For Business

Finding 2025-002: Eligibility Responsible Individuals: Kari Williams, Chief Financial Officer Corrective Action Plan: The Organization reviewed the attendance form and made changes so it is easier to read. The Organization will review reimbursement requests and watch for errors. Anticipated Completion Date: December 31, 2025

The County will complete a quarterly review of errors in income and documentation. For those staff identified by the targeted review with errors in these areas, supervisors will provide refresher training on Medicaid policy requirements. Additional targeted reviews will be completed monthly until the deficiencies are corrected.

Management has set up training to address all issues regarding the wait list and how to go about selecting those off the waitlist. This training will take place in January of 2026 And it will help those on site to have a full understanding of what is needed when it comes to our wait list.

Management have put together a recertification team that will oversee our recertifications and we will bring staff on site in to train going forward in the future This will help to ensure that all documents are signed all consent forms there will also be training that deals with tenant selection on the wait list as well as training with maintaining tenant files.

2025-001 Federal Work Study - Student Financial Aid Cluster Assistance Listing Number 84.007, 84.033, 84.063, 84.268, Grant Period - Year Ended June 30, 2025 Condition Found During our Federal Work Study testing, we selected twenty-five students and noted that one student was paid for hours they did not work and was overpaid $420. The College did not review federal work study hours worked against class hours scheduled and timesheets to ensure the student was not working during a scheduled class and that they were paid for the correct number of hours. We consider this condition to be an instance of non-compliance to the Eligibility compliance requirement. Corrective Action Plan The Financial Aid Department is collaborating with Career Services to implement improved oversight and training for Federal Work-Study. This includes required online training for both student employees and their supervisors, which must be completed prior to hiring any student employees within a department. Additionally, a campus-wide Standard Operating Procedure (SOP) has been developed, along with a Quick Guide for Supervisors of Student Employees, to ensure consistent processes and expectations related to scheduling, timesheet review, and compliance. Responsible Person for Corrective Action Plan Program Manager — Student Employment/Veteran Affairs Director of Career Services and Job Placement Implementation Date of Corrective Action Plan 08/22/2025

Title and AL Number of Federal Program: 14.181 Supportive Housing for Persons with Disabilities (Section 811) Federal Award Agency: U.S. Department of Housing and Urban Development Name of Contact Person: Barry Gault, Chief Financial Officer Corrective Action: 1) Management will assign a secondary review by the Compliance Manager and establish controls in place to ensure that recertifications are performed timely. Date of Planned Corrective Action: 09/15/2025 Submitted by: Barry Gault

Title and AL Number of Federal Program: 14.181 Supportive Housing for Persons with Disabilities (Section 811) Federal Award Agency: U.S. Department of Housing and Urban Development Name of Contact Person: Barry Gault, Chief Financial Officer Corrective Action: 1) Management will assign a secondary review by the Compliance Manager and establish controls in place to ensure that recertifications are performed timely. Date of Planned Corrective Action: 09/15/2025 Submitted by: Barry Gault

2025-001: Missing Exit Counseling Documentation Student Financial Aid Cluster Assistance Listing Number 84.007, 84.033, 84.063, 84.268, 84.379 Grant Period – Year Ended June 30, 2025 Condition Found Condition/Context: During our student file testing, we noted two students out of forty did not have documentation in their file that exit counseling was sent thirty days after the student withdrew. We consider the missing exit counseling to be an instance of noncompliance with the Eligibility Compliance Requirement. Corrective Action Plan Concordia has created new reporting and updated its Exit Counseling policy to put any students without concurrent semester enrollment, excluding traditional undergraduates who are not required to take summer, into "EXIT". Responsible person for corrective action plan: Kevin Sheridan Implementation Date of Corrective Action Plan: December 11, 2025

2025-001 Significant Deficiency: Awards in Excess of Aggregate Limits (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268) The University awarded and disbursed Federal Direct Loans beyond aggregate limits. Management Response Management concurs with the auditors’ finding. Due to delays and changes in the National Student Loan Data System (NSLDS) post-screening process for the 2024–25 award year, Federal Direct Loans were inadvertently awarded and disbursed to students who had previously exceeded Federal Direct Loan aggregate limits. Responsible Person(s) Alex Campbell, Director of Financial Aid, and Kaitrin Parrett, Assistant Director of Financial Aid, are designated as the individuals responsible for implementing the corrective action. Corrective Action Plan Upon identifying deficiencies in loan aggregate reporting and over-award status, the Financial Aid Office initiated communication with the identified students to inform them of their overaward status and the process for resolving inadvertent overborrowing. In collaboration with software engineers, the Financial Aid Office is developing updated reporting to ensure proper identification of students who are ineligible due to meeting or exceeding aggregate limits set by the U.S. Department of Education. The Financial Aid Office tested and reviewed NSLDS post-screen data and student loan aggregates prior to the disbursement of Fall 2025 Federal Direct Loans to ensure students were not awarded or disbursed aid for which they were ineligible. Reviews of NSLDS post-screen data confirm that the Student Information System (SIS) accurately identifies student aggregate borrowing flags. The Financial Aid Office is also monitoring designated mailboxes to ensure any additional NSLDS post-screen data is reviewed and aggregate limits on student accounts are updated accordingly. All financial aid staff involved in awarding federal loans completed additional training on NSLDS review requirements, aggregate limit monitoring, and reaffirmation procedures prior to Fall 2025 disbursements. Training will continue on a quarterly basis to ensure proper procedures are followed by Financial Aid staff. Compliance reviews will be conducted on a semester basis to ensure that Title IV aid is not awarded to students in excess of their annual or aggregate limits. The Director and Assistant Director of Financial Aid will review aggregate limit reports monthly as part of the University’s internal operational calendar. Expected Completion Date This corrective action plan was implemented in September 2025, prior to Fall 2025 aid disbursements, which began on September 12, 2025.