Corrective Action Plans

Corrective Action Plan for Finding 2026-001 – In May 2025, the University executed a contract to implement a new and modern Student Information System. This multi-year implementation project is expected to be completed by Fall 2029. The University is on track to complete the implementation as scheduled. During the interim period, the University will continue to emphasize data validation and accuracy through staff training and monitoring. To further support the reporting process, the University engaged a former employee on a contractual basis during the fiscal year ended May 31, 2026. This individual brings extensive experience in enrollment reporting to both the National Student Clearinghouse (NSC) and the National Student Loan Data System (NSLDS), providing valuable expertise during this transitional phase.

Finding 2026-001 – Management’s Corrective Action Plan | To whom it may concern: | U.S. Department of Education | Award Year 2025-2026 | Student Financial Assistance Cluster (ALN: 84.268) | Management concurs with the finding. The student's required withdrawal for academic performance was a University-initiated decision that fell outside the standard withdrawal process managed by the Registrar's Office. Because the decision letter was not forwarded to the Registrar's Office at the time the student was notified, the withdrawal was not recorded in Banner or reported to NSLDS within the required 60 days. The student's status has since been corrected in NSLDS. | To prevent this from recurring, the University will require that any office issuing a student status decision, including required withdrawals for academic performance, send a copy of the decision to the Registrar's Office on the same day the student is notified. Steps are being taken to automate the notification process. The Registrar's Office will record the change in Banner so that it is included in the next Enrollment Reporting Roster submission. In addition, the Registrar's Office will compare academic standing decisions against enrollment status before each roster certification to confirm that all University-initiated withdrawals have been reported. | The anticipated completion date of June 1, 2027, reflects the implementation of the automated notification process and the completion of roster certifications under the new review procedure. | Leadership Responsible: Andy Marx, Ph.D., University Registrar, Clark University, 508-793-7426 | Anticipated Completion Date: June 1, 2027

Corrective Action Plan Audit Finding Reference: 2026 – 001 Planned Corrective Action: The College agrees with this finding and will formalize transfer student monitoring in a stand-alone written procedure. Specifically: • The Director of Student Financial Services will document a written procedure identifying every transfer student subject to NSLDS Transfer Student Monitoring, using admissions and registrar records, at the time the financial aid file is established. • Each identified transfer student will be added to NSLDS Transfer Student Monitoring, and resulting alerts cleared, before any Title IV funds are disbursed. • Completion of the transfer monitoring step will be documented in the student's file separately from the NSLDS financial aid history review. • A second financial aid staff member will review and document this step for each transfer student before disbursement is released. • The Director will train financial aid staff on the distinction between the NSLDS history review and Transfer Monitoring, and will review the transfer student population each term for compliance. Name of Contact Person: Kim Balentine, Director of Student Financial Services, kbalentine@occ.edu Anticipated completion date: The stand-alone written transfer student monitoring procedure will be completed prior to the start of the spring semester, with the monitoring and documentation steps applied to all transfer students beginning immediately.

Finding 2026-002: Significant Deficiency – Enrollment Reporting Program: Student Financial Assistance Cluster – Federal Direct Loans and Pell Grants Assistance Listing Number (ALN): Various Federal Agency: U.S. Department of Education Federal Award Identification Number: Various Federal Award Year: June 30, 2026 Condition: For one of 25 students who were tested, the student’s withdrawal status was reported to NSLDS late, 71 days after the date of determination. For one of 25 students who were tested, the student’s graduation date was reported incorrectly to NSLDS. The College’s controls over enrollment reporting did not detect the errors. The sample was not a statistically valid sample. Corrective Action Plan Management agrees with the finding and is committed to strengthening its procedures to avoid similar issues in the future. Beginning in September 2026, a second and new Registrar’s Office staff member will be trained in to complete an additional review of the National Student Clearinghouse status for all students withdrawing after a particular semester. This secondary review will be completed at the end of January and at the end of June to ensure the 60-day reporting period is met. We will manually update the graduated enrollment status start date for the impacted student to the correct date through the National Student Clearinghouse. We will reach out to the National Student Clearinghouse to determine why the graduation date that was reported on the degree file does not match the date that was used when the student’s enrollment record was updated by the Clearinghouse using the graduated enrollment status from the degree verified process. Completion Date: November 1, 2026 Name(s) of Contact Person(s) Responsible for Corrective Action: Nathan Engle, Controller Email: Engle1@stolaf.com

Finding 2026-001: Significant Deficiency – Return of Title IV Funds Program: Student Financial Assistance Cluster – Federal Direct Loans and Pell Grants Assistance Listing Number (ALN): 84.268 and 84.063 Federal Agency: U.S. Department of Education Federal Award Identification Number: Various Federal Award Year: June 30, 2026 Condition: 2 of the 2 students in the sample selected that required a return of Title IV funds had an amount returned by the College that was incorrect due to an incorrect number of days for the term being used in the R2T4 calculation. For the fall term, the College incorrectly omitted 2 break days, and for the spring term the College used an incorrect end of term date that was 7 days earlier than the actual end of period per the academic calendar. The student from the fall term had $18 too much and the student from the spring term had $50 less returned than required, both of Federal Direct Unsubsidized Loans. The College’s controls over the term dates input and R2T4 calculation reviews did not detect the errors. The sample was not a statistically valid sample. Upon learning of these exceptions the College corrected the days used in the calculation for the 2 students noted above and the auditor viewed the corrected R2T4 calculations, student accounts and COD screen prints. The College performed a review of all other withdrawn students noting an additional 7 students impacted from each term. For the fall term an additional $70 too much was returned ($8 Direct Loans and $62 Pell Grants). For the spring term an additional $434 ($220 Direct Loans and $214 Pell) was required to be returned. The College corrected these amounts for all but 1 student ($3 direct loans). The auditor viewed the corrected R2T4 calculations, student accounts and COD screen prints for the 13 students. Corrective Action Plan Management agrees with the finding and considers this to be an isolated incident that will not re-occur in future years. Since discovering this error in the 25-26 Academic Year, three staff members have reviewed the 26-27 Academic Calendar to ensure that start dates, end dates and breaks are correctly entered into PowerFAIDS. Additionally, the staff member who managed this process in the 25-26 Academic Year is no longer employed by the College. A new staff member will be responsible for this process and will receive supplemental training to ensure knowledge and accuracy. Completion Date: September 30, 2026 Name(s) of Contact Person(s) Responsible for Corrective Action: Nathan Engle, Controller Email: Engle1@stolaf.com

As of the issuance of the May 31, 2026 financial statements, the University has provided the proper formatted reports to the National Student Clearinghouse and NSLDS statuses are able to be updated by the University staff. The University expects to be in compliance with this regulation in the future.

NORTHWEST UNIVERSITY Corrective Action Plan For the Year Ended May 31, 2026 Finding Number 2026-001: Significant deficiency in internal controls over compliance with verification requirements. Significant deficiency in internal controls over compliance with verification requirements: For the two students who received Pell grants of five total students selected for verification testing, verification status was not correctly coded in Common Origination and Disbursement (COD) system. This was the result of an issue in PFAIDS in which verification status code is only reporting for Pell recipients who were selected for verification by the FPS, not for students selected by the school. SFS has reviewed the scope of this issue and determined that these were the only two Pell recipients who were school-selected and verified, and the Verification Status Code for both students has been updated in COD as of 8/11. Contact Person(s): Cynthia Kennedy, Director of SFS; Ryan Porter, CFO; and Bernie Rundquist, Controller Explanation and specific reasons for disagreement with the audit finding or that corrective action is not required (if applicable): N/A Corrective action planned: The compliance issue was the result of a reporting error within the University’s current financial aid management system. Student Financial Services (SFS) is transitioning to a new financial aid management system in October 2026 and has ensured that the verification status flows correctly through COD reporting. The University goes live with the new system for the 2027-2028 award year. For the remainder of the current 2026-2027 reporting cycle, SFS has implemented a regularly scheduled manual review of COD reporting for students who are school-selected for verification to ensure correct reporting. This review will continue through the duration of processing in the current system. Anticipated completion date: October 2026

Return of Title IV (R2T4) Calculations Planned Corrective Action: The Financial Aid Office (FAO) has reviewed the R2T4 process and implemented additional procedures to strengthen the accuracy and documentation of withdrawal calculations, particularly for students enrolled in module-based programs. The Financial Aid Office (FAO) has implemented the following enhanced procedures: • The internal R2T4 policy document has been reviewed for accuracy to ensure that all required steps are noted. • R2T4 calculations involving module enrollment, withdrawal exemptions, or Post-Withdrawal Disbursements will receive a second-level review before the calculation is finalized and funds are returned to the Department of Education. • The FAO will maintain a tracking process to monitor R2T4 calculations, required return amounts, and return deadlines to ensure that required returns are completed accurately and within the applicable federal timeframe. • The Financial Aid counselors will receive refresher training on R2T4 requirements, with particular emphasis on withdrawals from module-based programs, the 49% withdrawal exemption, Post-Withdrawal Disbursements, and determining which modules and aid must be included in the calculation. The Director of Financial Aid will periodically review a sample of completed R2T4 calculations to verify compliance with federal requirements and the institution's procedures. Any errors identified through this monitoring will be corrected promptly and used to determine whether additional staff training or procedural changes are necessary. Person Responsible for Corrective Action Plan: Cindi Patterson, Director of Financial Aid Anticipated Date of Completion: October 1, 2026

Need Analysis Planned Corrective Action: North Greenville University recognizes that this finding represents a recurrence of the prior-year need analysis finding. Although procedures were implemented after the prior finding, the current-year audit identified a specific gap in monitoring changes to the Cost of Attendance (COA) and their impact on subsidized loan eligibility. The enhanced procedures described below address this risk by identifying instances where a student's subsidized loan exceeds remaining financial need after changes to COA. The Financial Aid Office (FAO) has implemented the following enhanced procedures: • The FAO has developed a targeted PowerFAIDS report to identify students whose subsidized loan award exceeds their remaining financial need. The report will be used as a specific exception report to identify potential subsidized loan over-awards resulting from changes to a student's financial aid eligibility. • The targeted PowerFAIDS report will be reviewed as part of the FAO’s pre-disbursement compliance process. Student records identified by the report will be reviewed to determine whether a change in COA, enrollment, or other financial aid resulted in a subsidized loan over-award. • The Financial Aid staff responsible for packaging, COA adjustments, loan adjustments, and disbursement review will receive additional guidance regarding the relationship between COA, remaining need, and subsidized loan eligibility. Staff will be specifically instructed to reevaluate loan eligibility when changes to housing status or other components of COA affect a student's remaining need. The PowerFAIDS exception report identifying subsidized loan awards that exceed remaining financial need will be reviewed each term and as part of the pre-disbursement review process. Additionally, the FAO will monitor significant changes to COA, particularly housing status changes, to ensure that changes in need are appropriately reflected in federal loan eligibility. Any exceptions identified will be reviewed and corrected promptly. Documentation of the review and any resulting adjustments will be retained as evidence of the control being performed. Regarding the one locked student record identified, PowerFAIDS currently has a task that identifies students in DR (Data Review) status and assigns the record to a Financial Aid counselor for review. As an enhancement to this existing control, counselors will verify the student's ISIR processing status and confirm that applicable ISIR fields are unlocked when an updated ISIR is expected. This additional verification is intended to ensure that a subsequent ISIR can successfully upload and update the student's financial aid record. Counselors will review the student's record to determine whether the locked ISIR prevented updated FAFSA information from being received or processed and will take the appropriate corrective action before finalizing the student's eligibility. As part of the DR review, counselors will verify that the student's most recent ISIR has processed correctly and that applicable federal aid eligibility, including Pell Grant eligibility, has populated appropriately. If the student's record remains in DR because of an ISIR processing issue, the counselor will resolve the issue and document the review before the student's aid is finalized. Person Responsible for Corrective Action Plan: Cindi Patterson, Director of Financial Aid Anticipated Date of Completion: October 1, 2026

Process Revision: The Registrar’s Office has updated its standard operating procedures (SOP) to include an annual review of all active academic programs to ensure they are properly configured and reported to the National Student Clearinghouse. Control Enhancement: Management will conduct an annual review of the active program inventory and validate that reporting queries accurately capture all required program and CIP code data prior to submission. Implementation Status and Timeline: All affected program records have been corrected, and the reporting query has been updated to ensure accurate data submission to the NSLDS moving forward. The revised SOP has been implemented and will be formally reviewed again in April 2027 as part of the annual compliance review process.

Untimely Returns of Title IV Funds (R2T4) Planned Corrective Action: At the end of each semester and once final grades are posted all students who earned 0 credit hours will be reviewed. Any determined to have unofficially withdrawn from all courses during the term based on reported last date of attendance will be reviewed to determine if a return calculation is necessary. Policies and procedures related to R2T4 will be updated in the Financial Aid Policy and Procedure manual. Person Responsible for Corrective Action Plan: Niki Stinson, Director of Financial Aid Anticipated Date of Completion: The report has already been created.

Finding #2026-001 Context Finding #2026-001 indicates that the University did not have effective internal controls to ensure required Federal Direct Loan disbursement notifications were sent to parents or students within the regulatory timeframe. 1. Interim Manual Processing of Nightly Communications Effective June 6, 2026, all nightly communications will be manually reviewed and processed until the associated PeopleSoft PSJob has been fully audited and the process changes described in this corrective action plan have been implemented and validated by multiple staff members. This interim control will remain in place until management determines that the automated process has been adequately validated and that the associated monitoring controls are operating effectively. 2. Weekly Audit of Federal Direct Loan Disbursement Notifications The Financial Aid Office will conduct a weekly audit of Direct Loan disbursement notifications using the PeopleSoft PSQuery XCFA_LN_DISB_NOTICE_AUDIT_QRY. The query will be run at the beginning of each week, normally on Monday or, when Monday is a holiday, on the next business day. The review will cover the preceding Sunday through Saturday. The reviewer will examine the results to identify Direct Loan disbursements for which the required notification was not generated or for which the notification date falls outside the applicable regulatory timeframe. Any communication for which the date of the disbursement exceeds 30 days from the date of the notification will be flagged for further review and resolution. The completed query results will be saved to: J:\PeopleSoft\Communications\Disbursement Notice Audit The file name will identify the beginning and ending dates of the period reviewed. 3. Additional Review When the Disbursement Audit Report Is Blank If the XCFA_LN_DISB_NOTICE_AUDIT_QRY produces no results for a weekly review period, an additional audit will be performed to confirm that disbursement activity occurred and that the absence of Direct Loan notifications is not the result of a system or query-processing issue. The additional report will include surrounding disbursement transactions, including non-Direct Loan disbursements, to determine whether disbursements were processed during the review period but no Direct Loan transactions were included in the notification audit. This report will be saved in the same location: J:\PeopleSoft\Communications\Disbursement Notice Audit The report will use the same date convention as the primary audit report and will have a distinct file name identifying it as the supplemental or anomalous activity review. Any unexpected result will be investigated and documented. 4. Enhanced Controls for Nightly Communication Processing Communication selection queries will be modified to include defined processing time parameters. For example, revisions older than 14 days will not be selected for automatic processing without additional review. For each communication type, a report will identify communications that fall outside the established processing window and have not already been satisfied by a successfully processed communication. A separate report will provide the communication's add date and processing status following the nightly selection and processing of the communication batch. Following completion of each communication's processing job, the applicable reports will be distributed by email to: • Alexander Musser (amusser) • Lauren Musser (musser) • Jenni Swindell (jswindel) Email subject lines will clearly identify the communication type and report type. The email body will describe the applicable processing activity and identify any exceptions requiring review. The reports and associated documentation will be reviewed and retained in: J:\PeopleSoft\Communications\Weekly Communications Files will be named using the applicable communication type, report type, and processing date. 5. Monthly Audit of Automated PeopleSoft PSJobs All automated PeopleSoft PSJobs supporting financial aid communications will be subject to a monthly control audit. The monthly review will include a manual review of each step within the applicable PSJob to verify that: • Each step remains properly configured; • Selection criteria and processing parameters remain appropriate; • The correct processes and queries are being executed; • The PSJob is running under the appropriate user account; • No unauthorized or unexplained changes have been made; and • The overall sequence and configuration of the PSJob remain consistent with the intended business process. The review will be documented in the PSJob Log, maintained in: J:\PeopleSoft\PSJobs The PSJob Log will contain a separate worksheet for each applicable PSJob and will document the PSJob's current status, configuration changes, the individual making each change, the user account under which the automation operates, and the date and time of changes. Monthly reviews, system configuration adjustments, and user-related adjustments will be documented in the log. 6. Management Monitoring Management will review the results of the weekly Direct Loan disbursement notification audits and monthly PSJob audits to identify recurring exceptions, processing failures, or trends that could indicate a deficiency in the underlying automated process. Exceptions identified through these reviews will be investigated and corrected. Where appropriate, corrective actions will include modification of the automated process, additional staff review, or modification of the monitoring control. Documentation of the reviews, exceptions, and corrective actions will be retained in accordance with the University's established record-retention practices. Expected Outcome These corrective actions are designed to provide multiple levels of control over Federal Direct Loan disbursement notifications. The combination of automated processing, weekly transaction-level review, exception reporting, supplemental review when expected activity is absent, and monthly PSJob configuration audits is intended to provide reasonable assurance that required Direct Loan disbursement notifications are generated and provided within the applicable federal timeframe and that failures in automated processing are identified promptly. Responsible Parties Jenni Swindell, Associate Director Alex Musser, Business Analyst

Finding #2026-002 Context Finding #2026-02 indicates the University did not have effective internal controls over the review of Federal Pell Grant disbursements and did not report Pell Grant program data to the Common Origination and Disbursements (COD) system within the required timeframes. 1. Weekly Monitoring of Pell Disbursement Reporting Beginning with the 2026-27 academic year, the Grants and Scholarships Specialist will perform a weekly reconciliation at the beginning of each week to confirm that Pell Grant disbursements are being reported to COD within the required 15-calendar-day reporting period. The review will reconcile the applicable Pell disbursement activity against the corresponding COD reporting activity and identify any disbursements that have not been reported within the required timeframe. This control is intended to provide an ongoing, timely review of Pell reporting compliance rather than relying solely on the underlying automated reporting process. 2. Exception Review and Resolution The Grants and Scholarships Specialist will investigate all exceptions identified through the weekly reconciliation. Each exception will be documented, including the nature of the exception and the corrective action taken. The Specialist will ensure that identified records are reported to COD before the next reporting cycle, as appropriate. This process will provide a documented exception-management process and establish clear responsibility for resolving reporting discrepancies. To strengthen documentation and traceability going forward, we will implement the following measures: Retain all reconciliation reports on a shared drive, organized by date and year, to maintain a clear historical record of each weekly cycle. A column will be added to each report capturing the resolution finding for every identified discrepancy. A comment will be added to each affected student's Financial Aid status page in PeopleSoft (PS) documenting the resolution. 3. Monitoring of Federal and State Regulatory Changes The Assistant Director of Compliance is responsible for monitoring federal and state regulatory changes affecting financial aid programs and for evaluating changes that may affect University policies, procedures, and reporting requirements. The Assistant Director of Compliance will update the Financial Aid Office’s policy and procedure manual as necessary and will communicate applicable regulatory changes to the areas affected by those changes. Attention will be given to temporary guidance, waivers, extensions, and other regulatory provisions that have defined award-year applicability or expiration dates. 4. Management Review of Regulatory Changes To provide an additional level of oversight, the Assistant Director of Compliance will bring regulatory changes to the Financial Aid management team for review prior to implementation. The management review will provide an opportunity to confirm the applicability of new or revised guidance to the appropriate award year and to ensure that temporary provisions or reporting extensions are not inadvertently carried forward after their expiration. This additional review is intended to strengthen the University’s internal control over the interpretation and implementation of federal reporting requirements. Expected Outcome The combination of weekly Pell reporting reconciliation, documented exception management, designated responsibility for monitoring regulatory changes, and management review of significant regulatory changes is designed to provide reasonable assurance that Pell Grant disbursements are reported to COD within the required 15-calendar-day timeframe. These controls also strengthen the University’s process for identifying changes in federal guidance and ensuring that temporary or award-year-specific provisions are appropriately applied and discontinued when no longer applicable. Responsible Parties Chauncey Piazza, Assistant Director Christopher Shane, Grants and Scholarships Specialist

FINDING 2026-003 Name of Responsible Individual: Courtney Thompson-Ballard, Director of Financial Aid Corrective Action: Upon review of the data that was reported inaccurately, it was determined that updating this data point, the earliest enrollment date for the award year, via a systems integration was not the most reliable way to update the value. An internal system within the Financial Aid Management System (FAMS) will be used to populate this date going forward. The Financial Aid Office will add an additional quality check post origination as well to ensure accuracy. Anticipated Completion Date: September 30, 2026

FINDING 2026-002 Name of Responsible Individual: Alex Putzer, AVP for Business & Finance Corrective Action: The University has implemented enhanced controls over Federal Pell Grant cash draws to ensure compliance with federal cash management requirements. The University will maintain an approximate $50,000 cushion between cumulative eligible financial aid disbursements and cumulative funds drawn through the G5 portal. Prior to each draw, cumulative financial aid awarded and recorded in the University’s general ledger will be reconciled to cumulative G5 draws to ensure funds requested do not exceed eligible disbursements. Additionally, the AVP for Business and Finance will review and approve each draw prior to submission to provide an additional level of oversight and ensure continued compliance with applicable federal cash management requirements. Anticipated Completion Date: September 30, 2026

FINDING 2026-001 Name of Responsible Individual: Sharon Hush, University Registrar Corrective Action: As of mid-June 2026, the Registrar’s Office is fully staffed. Multiple staff within the office have now been trained to complete the enrollment and degree reporting process for the National Student Loan Data System (NSLDS). One additional high-level information technology personnel has also been trained to complete the reporting processes. As part of this training, staff has participated in enrollment reporting webinars offered through the National Student Clearinghouse and in conjunction with NSLDS. This training will be an on-going process so that staff can stay abreast of any necessary reporting updates. Also, multiple staff members in the Registrar’s Office and several administrators are now included in the communications from the National Student Clearinghouse that provide reminders of due dates for enrollment and degree reporting to ensure that reporting happens in the appropriate time. To ensure that staff know the specific time periods for enrollment and degree reporting, information has been added to the Standard Operating Procedures (SOP) for “National Student Clearinghouse Reporting.” This document, which provides all instructions for enrollment and degree reporting, is housed in a shared file that is accessible to all staff in the Registrar’s Office and the high-level information technology personnel. This collection of personnel are those with access to complete the enrollment and degree reporting. Finally, we have added a report “NSC Error Report – Program Data” to check for enrollment program and status errors. This report will be run prior to every reporting submission to check for errors and to fix any errors prior to the file submission. Anticipated Completion Date: September 30, 2026

Student Financial Assistance Cluster– Assistance Listing Nos. 84.268 Recommendation: We recommend Augsburg University implement controls to ensure that disbursement dates reported to COD are aligned with the actual date funds are credited to the student’s account. This could include system controls that delay COD reporting until disbursements are fully processed or periodic reconciliations between COD records and the student ledger to identify and correct discrepancies in a timely manner. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Student Financial Services will conduct bi-weekly reconciliations between COD records and the student ledger to identify and correct any discrepancies. Name(s) of the contact person(s) responsible for corrective action: Catherine Maun Planned completion date for corrective action plan: May 31, 2027

Finding Reference Number: 2026-001 Finding Title: Nonmaterial Noncompliance Federal Program: Student Financial Aid Cluster, Assistance Listing #: 84.007, 84.033, 84.063, 84.268 College Corrective Action Plan: Ringling College has migrated to a new administrative system—Workday. As a result, the workflow for R274 notifications has changed significantly. Workday will automatically notify us of any withdraws with the necessary prepopulated information based on the institutional system configurations. Any changes to the calendar would automatically update any processes that need to be revisited. Anticipated Completion Date: August 17, 2026 Lee Harrell - Director of Financial Aid

View of Responsible Officials The University agrees with the findings and recommendation. Management reviewed the identified exceptions and determined they resulted from the use of incorrect institutional charges and failure to exclude a scheduled break of five or more consecutive calendar days in certain Return of Title IV calculations. The University has implemented enhanced procedures to validate institutional charges, identify and exclude qualifying scheduled breaks, provide additional staff training, and require secondary review of Return of Title IV calculations.

Action Taken: Brescia University will establish a review system to verify that direct loan reconciliations are being completed monthly. This system will include: (1) monthly scheduled file requests between Financial Aid, Registrar (who pulls the data files from COD), and the Business Office. The file requests will be scheduled for the earliest date of the month possible based on the college calendar and completed within 10 business days. (2) Each monthly reconciliation will be double checked by a senior financial aid counselor upon completion and will be signed off on as a log/confirmation of completion of the reconciliation. (3) The logs/confirmations will be mainted by the Director of Financial Aid.

Action Taken: Brescia University will establish a review system to verifiy the number of semester days utilized in return of funds calculations by instituting a double check system. The double check will be completed by a senior financial aid counselor (other than the director) to ensure accurate dates are being used.

Verification Planned Corrective Action: Mid-America Christian University has updated its verification policies and procedures to ensure proper collection, review, and retention of secondary tax documentation. For students whose Federal Tax Information (FTI) cannot be retrieved via the Direct Data Exchange (FA-DDX) or whose data is incomplete/unverified, Financial Aid Counselors are required to obtain and retain official IRS Tax Return Transcripts or signed tax returns prior to finalizing aid eligibility. The Financial Aid staff has received comprehensive training on FA-DDX exception handling and acceptable secondary documentation. To ensure ongoing accuracy, the Financial Aid Director (or designee) will perform a 100% Quality Assurance (QA) secondary review of all completed verification files prior to disbursement during the initial rollout phase, transitioning to a structured random sampling protocol once error rates remain at zero. A formal Quality Control Checklist has been incorporated into the operational workflow. Person Responsible for Corrective Action Plan: Tammy Comalander, Interim Director of Financial Aid Anticipated Date of Completion: 07/01/2026

Common Origination and Disbursement (COD) Reporting Planned Corrective Action: Mid-America Christian University (MACU) has revised its Title IV disbursement and ledger posting workflow to ensure alignment between internal financial records and Common Origination and Disbursement (COD) reporting. Previously, student ledger postings were dated using the G5 deposit date rather than the COD disbursement date. To resolve this issue and prevent future recurrence: 1. Alignment of Disbursement Dates: MACU has updated its workflow in PowerFAIDS and the Jenzabar to ensure disbursements are posted to student accounts using the disbursement date reported to COD rather than the /G5 drawdown/deposit date. 2. Timely COD Reporting: Actual disbursement records generated in PowerFAIDS will be transmitted to the COD System within 15 calendar days of the actual disbursement date, in full compliance with 34 CFR 668.164. 3. Reconciliation & Controls: The Financial Aid Office and Bursar Office will perform a monthly three-way reconciliation between G5 drawdown records, PowerFAIDS disbursement data (alongside student ledgers), and COD actual disbursement records to guarantee date consistency and compliance across all systems. Person Responsible for Corrective Action Plan: Bobbie Spurgeon-Harris, Executive Vice-President and Chief and Dean Meadows, VP / CFO Anticipated Date of Completion: 10/01/2026

Inaccurate and Untimely Return of Title IV Funds (R2T4) Planned Corrective Action: Mid-America Christian University (MACU) has conducted a comprehensive audit of all students who earned zero credits during the 2025–2026 academic year to identify any unrecorded unofficial withdrawals and ensure all necessary Return of Title IV (R2T4) calculations were performed. For any identified deficiencies, funds were processed and returned immediately. To ensure ongoing compliance, MACU has established a standardized protocol between Academic Affairs, the Registrar, and the Financial Aid Office to accurately track the Last Date of Participation /LDP: 1. Faculty Grade & LDP Mandate: Academic Affairs has updated grading procedures to require faculty to record the LDP directly into the Jenzabar whenever a student receives a failing grade or incomplete due to non-attendance/non-participation. 2. Automated Reporting: A term exception report identifies all students with zero earned credits or unearned grades across term modules, enabling the Financial Aid team to promptly verify LDP via Canvas and process R2T4 calculations within federal deadlines. 3. Timeline Enforcement: The Financial Aid Office will enforce standard operating procedures to ensure unofficial withdrawal determinations are completed within 30 calendar days following the term end, and any required Title IV returns are executed within 45 calendar days of the withdrawal determination date (34 CFR 668.22). Person Responsible for Corrective Action Plan: Bobbie Spurgeon-Harris, Executive Vice-President and Chief of Staff Anticipated Date of Completion: 09/30/2026

Corrective Action Plan: With respect to the incorrect enrollment effective dates identified for three students in the current year testing, the Office of the Registrar and the Office of Financial Aid will conduct a manual review of effective enrollment dates against each term's official start date prior to NSLDS submission to identify and correct discrepancies before transmission. In the interim, the Registrar and Financial Aid offices are working directly with the College of Business to identify and resolve the underlying issues affecting the accuracy of program-level enrollment data for that college's programs. Responsible Parties: The University has identified the Registrar – Paula Brown, along with the Director of the Office of Financial Aid – James Hubener, as the responsible parties to ensure continued monitoring of the activity on these types of items, including oversight of the manual review process and the ongoing work with the College of Business described above, to ensure timely and accurate reporting to NSLDS. Estimated Completion Date: The manual review process is already in effect. A firm completion date for full implementation of the systematic verification process will be established by February 2027.