Corrective Action Plans

Finding 1201469 (2025-001)

Material Weakness 2025

WI

Student Financial Aid Eligibility Significant Deficiency

U.S. Department of Education Maranatha Baptist University (the University) respectfully submits the following corrective action plan for the year ended June 30, 2025. Audit period: July 01, 2024 to June 30, 2025 The findings from the schedule of findings and questioned costs are discussed below. The...

U.S. Department of Education Maranatha Baptist University (the University) respectfully submits the following corrective action plan for the year ended June 30, 2025. Audit period: July 01, 2024 to June 30, 2025 The findings from the 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 Our audit did not disclose any matters required to be reported in accordance with Government Auditing Standards. FINDINGS—FEDERAL AWARD PROGRAMS AUDITS U.S. Department of Education 2025-001 Student Financial Assistance Cluster – Assistance Listing No. 84.007, 84.063 & 84.268 Recommendation: We recommend that the University maintain documentation of both formal and informal award notifications in their financial aid software to ensure all necessary communications are made. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University Financial Aid Office will add a step in the awarding process to verify that award emails are sent and are documented in the system. Name of the contact person responsible for corrective action: Donald Donovan, Chief Financial Officer Planned completion date for corrective action plan: June 30, 2026 *** If the U.S Department of Education has questions regarding this plan, please call Donald Donovan, Chief Financial Officer, at 920-206-2314.

View Audit 396040

Finding 1201461 (2025-001)

Material Weakness 2025

Edgewood College, Inc.

WI

Special Tests & Provisions Student Financial Aid Reporting

Condition: We selected a sample of 25 students that had a change in status. One of the students information was not reported to NSLDS timely, however the College’s controls did detect the error outside the required timeframe, and the error was corrected. We expanded our sample to 50 students. We fou...

Condition: We selected a sample of 25 students that had a change in status. One of the students information was not reported to NSLDS timely, however the College’s controls did detect the error outside the required timeframe, and the error was corrected. We expanded our sample to 50 students. We found another instance of a student’s information not reported timely, however management did eventually detect and correct the error outside the required timeframe. Corrective Action planned: Management agrees and has implemented necessary procedures/controls to ensure the College is in compliance with enrollment requirements. Management has corrected the student’s change status not previously reported. Name(s) of Contact Person(s) Responsible for Corrective Action: {Jennifer Young, Director of Financial Aid and Edgewood Central, and Katelyn Peters, Student Service Specialist.} Anticipated Completion Date: Has already began as of the audit. Staff turnover occurred, have replaced the Student Service Specialist position - now have second point on NSC reporting.

View Audit 396008

Finding 1201455 (2025-001)

Material Weakness 2025

New York Law School

NY

Student Financial Aid

Finding No. 2025-001 – Special Tests and Provisions – NSLDS Reporting – Compliance and Internal Control (Significant Deficiency) Corrective Action Plan: The School agrees with the finding. The Registrar will work with Ellucian to update reporting process to National Student Clearinghouse to include ...

Finding No. 2025-001 – Special Tests and Provisions – NSLDS Reporting – Compliance and Internal Control (Significant Deficiency) Corrective Action Plan: The School agrees with the finding. The Registrar will work with Ellucian to update reporting process to National Student Clearinghouse to include the two program lengths for same CIP code. Anticipated Completion Date: Our expected remediation date is June 15, 2026. If we are unable to remediate by June 15, 2026, we will correct enrollment reporting to reflect accurate program length by September 1, 2026. Person(s) Responsible for Corrective Action: Michelle T. Weller Registrar 212-431-2300

View Audit 396004

Finding 1201454 (2025-002)

Material Weakness 2025

Coe College

IA

Student Financial Aid Reporting Significant Deficiency

Finding: The change in student status for 2 of 25 students tested was not reported to the National Student Loan Data System (NSLDS) timely when the student withdrew or changed status during the fiscal year. The change in student status for an additional 2 of 25 students tested was not reported to th...

Finding: The change in student status for 2 of 25 students tested was not reported to the National Student Loan Data System (NSLDS) timely when the student withdrew or changed status during the fiscal year. The change in student status for an additional 2 of 25 students tested was not reported to the National Student Loan Data System (NSLDS) accurately when the student graduated during the fiscal year. Explanation for Finding: The Registrar's data collection was not reviewed after submission to National Student Clearinghouse (NSC) by another responsible individual to ascertain the accuracy of graduate, withdrawal and status change dates of students being reported. The College received a response from NSC of no errors, therefore the withdrawn student in question was not reported in a timely manner. Corrective Actions Taken or Planned: The Registrar will run a report on the 15th of the month to verify any students that have exited the institution from the prior two submission periods (last two months) have valid exit dates in the National Student Loan Clearinghouse. The Assistant Registrar will review the work of the Registrar and verify any discrepancies between Coe’s records and those stored in the National Student Clearinghouse for correction. The Registrar will then ensure timely and accurate submission of student records from the Clearinghouse to NSLDS after all the data has been reviewed. When there are staffing changes in the future that impact a person on the staff in the Office of the Registrar who has been responsible for the verification and reporting of valid exit dates in the National Student Loan Clearinghouse, it is the responsibility of the Registrar, unless the Registrar has left, in which case it shall be the responsibility of the Assistant Registrar, to appoint another specific staff member in the Office of the Registrar to take the actions required by the written policy for the verification and reporting of this data. Persons Responsible and Completion Date: Registrar, Assistant Registrar. The actions outlined above has been added to the Withdrawal & Exit Procedure (NSC-NSLDS) as of 10/28/2025

View Audit 396003

Finding 1201400 (2025-001)

Material Weakness 2025

Amda, Inc. and Subsidiary (the American Musical and Dramatic Academy)

NY

Student Financial Aid

Corrective actions include: 1. Enhanced Monitoring Procedures o A weekly aging report of all withdrawn students will be generated by the Financial Aid Office to track the number of days elapsed since the withdrawal determination date. o The report will clearly flag any files approaching 30 days to e...

Corrective actions include: 1. Enhanced Monitoring Procedures o A weekly aging report of all withdrawn students will be generated by the Financial Aid Office to track the number of days elapsed since the withdrawal determination date. o The report will clearly flag any files approaching 30 days to ensure timely processing. 2. Documented Supervisory Review o All R2T4 calculations will be reviewed and signed off by a supervisory-level staff member prior to submission. o Evidence of review will be retained in the student’s file. 3. Holiday and Break Coverage Planning o The Financial Aid Office will establish a written coverage plan during holiday periods and institutional breaks to ensure R2T4 calculations and returns continue to be processed within required timelines. o Cross-training of at least one additional staff member has been implemented to prevent delays due to staffing constraints. 4. Periodic Internal Reconciliation o On a quarterly basis, the CFO or designee will review a summary reconciliation of all withdrawals and related R2T4 returns to verify compliance with the 45-day requirement.

View Audit 395972

Finding 1201389 (2025-004)

Material Weakness 2025

Southern Oregon University

OR

Student Financial Aid Eligibility Significant Deficiency

Eligibility - Direct Loan Awarding Federal Direct Student Loans (84.268) Recommendation: We recommend that the University enhance its policies and procedures related to the packaging and awarding of financial aid, particularly in situations requiring manual calculations or professional judgment, to ...

Eligibility - Direct Loan Awarding Federal Direct Student Loans (84.268) Recommendation: We recommend that the University enhance its policies and procedures related to the packaging and awarding of financial aid, particularly in situations requiring manual calculations or professional judgment, to ensure student eligibility is accurately determined and awards are properly calculated. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Effective immediately, we've added a required review step for any aid package that is adjusted using professional judgment. This review focuses specifically on confirming that annual loan limits and subsidized eligibility are recalculated correctly after any change. Staff has also received refresher training on subsidized loan eligibility and amounts, and how to verify that the correct amount is awarded when appropriate. In addition, we will incorporate periodic spot checks of files involving manual adjustments to ensure calculations are accurate and consistent. Name(s) of the contact person(s) responsible for corrective action: Erica Riggs Planned completion date for corrective action plan: Spring 2026, ongoing.

View Audit 395962

Finding 1201388 (2025-003)

Material Weakness 2025

Southern Oregon University

OR

Student Financial Aid Significant Deficiency

Special Tests - Return to Title IV Funds (R2T4) Federal Direct Student Loans (84.268), Federal Pell Grant Program (84.063), Federal Supplemental Educational Opportunity Grants (84.007), and Teacher Education Assistance for College and Higher Education Grants (84.379) Recommendation: We recommend tha...

Special Tests - Return to Title IV Funds (R2T4) Federal Direct Student Loans (84.268), Federal Pell Grant Program (84.063), Federal Supplemental Educational Opportunity Grants (84.007), and Teacher Education Assistance for College and Higher Education Grants (84.379) Recommendation: We recommend that the University strengthen internal controls over the R2T 4 process by implementing standardized procedures, ensuring system calculations are accurate, and establishing consistent and documented review of R2T4 calculations prior to the return of Title IV funds. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Effective immediately, all R2T4 calculations will undergo a secondary review prior to funds being returned. The review will be documented via a shared document to ensure staff are consistently verifying withdrawal date, percentcompleted, return amounts per program, and timeliness. This document will be retained for audit purposes. We've also set internal deadlines to ensure funds are being returned within the 45-day requirement under Title IV. Calculations will be completed within 25 days of determining a withdrawal, and returns will be processed within 35 days. This will be tracked in a shared document that will also be retained for audit purposes. SOU is implementing a new Student Information System (SIS) beginning with the 2026-2027 academic year. Until we transition to the new SIS, known issues in the current SIS will be documented, and staff will manually review and override calculations where discrepancies are identified. As part of the new SIS implementation, we'll validate all R2T4 calculations to ensure system accuracy. All financial aid staff responsible for R2T4 processing will receive refresher training on calculation requirements, withdrawal date determination, and return timelines. We will also provide cross-training to additional staff to ensure continuity if there are additional staffing changes. Name(s) of the contact person(s) responsible for corrective action: Erica Riggs Planned completion date for corrective action plan: Fall 2026 and ongoing

View Audit 395962

Finding 1201384 (2025-002)

Material Weakness 2025

Southern Oregon University

OR

Student Financial Aid § 200.303

Special Tests - Enrollment Reporting Federal Direct Student Loans and Federal Pell Grant Program - Assistance Listing No. 84.268 and 84.063 Recommendation: We recommend that the University enhance its policies and procedures regarding enrollment reporting including additional monitoring over the thi...

Special Tests - Enrollment Reporting Federal Direct Student Loans and Federal Pell Grant Program - Assistance Listing No. 84.268 and 84.063 Recommendation: We recommend that the University enhance its policies and procedures regarding enrollment reporting including additional monitoring over the third-party service provider to ensure that reporting is completed accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: New registrar hired 9/2025 has enhanced policies and procedures regarding enrollment reporting by initiating regular and frequent (weekly/biweekly) contact with the National Student Clearinghouse (NSC) to ensure that reporting is completed accurately and timely. Names of the contact person responsible for corrective action: Jennifer Bratz Planned completion date for corrective action plan: Correction action plan involves ongoing regular communication with NSC and regular monitoring of reports for timeliness and accuracy, no completion date.

View Audit 395962

Finding 1201321 (2025-002)

Material Weakness 2025

University of San Diego

CA

Eligibility Student Financial Aid Material Weakness

Corrective Action Plan – Management concurs with this finding. During the student system set-up for academic year 2024-25, the appropriate screen was not properly updated with the new ISIR codes to set the tracking requirements to be posted for ISIR C Flags. Because the appropriate tracking document...

Corrective Action Plan – Management concurs with this finding. During the student system set-up for academic year 2024-25, the appropriate screen was not properly updated with the new ISIR codes to set the tracking requirements to be posted for ISIR C Flags. Because the appropriate tracking documents were not posted, the system allowed the students to pass through packaging and disbursement. The Law School Financial Aid Office will implement a structured verification process as part of the student system setup for each academic year. Every step of the setup will be documented. To ensure accuracy, one staff member will complete the setup, and a separate staff member will independently review and verify the configuration. Management believes these enhancements will be sufficient to prevent future errors. Completion date: November 2025 Persons responsible: Vonda Garcia, Director of Law School Financial Aid

View Audit 395955

Finding 1201312 (2025-001)

Material Weakness 2025

University of San Diego

CA

Special Tests & Provisions Student Financial Aid Reporting

Corrective Action Plan – Management concurs with this finding. The exceptions resulted from two distinct scenarios: 1) An official withdrawal processed manually outside the standardized workflow. 2) An unofficial withdrawal triggered by a grade change submitted after the final grade deadline. In Fal...

Corrective Action Plan – Management concurs with this finding. The exceptions resulted from two distinct scenarios: 1) An official withdrawal processed manually outside the standardized workflow. 2) An unofficial withdrawal triggered by a grade change submitted after the final grade deadline. In Fall 2024, an undergraduate student’s official withdrawal was completed late in the semester. The Dean requested a Torero Hub Counselor to manually remove the course, bypassing the standardized workflow. While the Counselor notified the Registrar’s Office, the Office of Financial Aid was not included in the communication chain. To address this gap, the Office of Financial Aid will implement a biweekly report to monitor and verify any changes to student withdrawal statuses that fall outside the automated workflow. Management believes this enhancement will effectively prevent similar errors in the future. The second exception involved a Professional and Continuing Education (PCE) student. After the final grade submission deadline, the instructor updated the student’s grade to an ‘F’, which retroactively classified the student as an unofficial withdrawal. This change occurred after the Office of Financial Aid had already run the final Fall 2024 unofficial withdrawal report. PCE has been notified that grade changes are not permitted after the final grade deadline. Additionally, the Office of Financial Aid will now run the unofficial withdrawal report biweekly beyond the final grade due date to identify and verify any late changes to student withdrawal statuses. Management believes these measures will mitigate the risk of future occurrences. Completion date: September 2025 Persons responsible: Kellie Nehring, Director of Financial Aid and Diana Hannasch-Haag, Director of Retention – Online Degree Programs

View Audit 395955

Finding 1191774 (2025-006)

Material Weakness 2025

Northeastern Illinois University

IL

Student Financial Aid

Condition: Northeastern Illinois University (University) did not have adequate procedures and controls in place to ensure student that unofficially withdrew during the semester were accurately reported to the National Student Loan Data System (NSLDS). Planned Corrective Action: Registrar’s office to...

Condition: Northeastern Illinois University (University) did not have adequate procedures and controls in place to ensure student that unofficially withdrew during the semester were accurately reported to the National Student Loan Data System (NSLDS). Planned Corrective Action: Registrar’s office to utilize the financial aid’s last date of attendance report and withdrawal determinations at the end of each semester to back date the effective enrollment reported date for unofficially withdrawn students at the end of each term. Contact person responsible for corrective action: Enrollment Management: Rahshida Walker, Registrar’s Office and Maureen Amos, Financial Aid Office Anticipated Completion Date: 6/30/2026

View Audit 395581

Finding 1191768 (2025-001)

Material Weakness 2025

Gwynedd Mercy University

PA

Student Financial Aid

Action Taken: The Registrar's Office is working with the NSC administrator to address concerns with submitted reports being updated in NSLDS. Each error was corrected within the system. Going forward, the Registrar's Office is working with IT on updated internal reports to track and review the statu...

Action Taken: The Registrar's Office is working with the NSC administrator to address concerns with submitted reports being updated in NSLDS. Each error was corrected within the system. Going forward, the Registrar's Office is working with IT on updated internal reports to track and review the status changes and start dates to ensure they are being accurately reported. Responsible Individual for Corrective Action: Registrar - Jennifer Melon Anticipated Completion Date: June 30, 2026 If there are any questions regarding this corrective action plan, please call Jennifer Ginnetti, Sr. Associate VP/ Deputy CFO, at 215-641-5506 or email Ginnetti.j@gmercyu.edu.

View Audit 395574

Finding 1191738 (2025-002)

Material Weakness 2025

Siena Heights University

MI

Student Financial Aid

Condition: Of the 40 students selected for enrollment reporting testing, 2 students did not have their status change updated appropriately and 3 students did not have their Classification of Instructional Programs (CIP) code updated appropriately. Planned Corrective Action: The Director of Student F...

Condition: Of the 40 students selected for enrollment reporting testing, 2 students did not have their status change updated appropriately and 3 students did not have their Classification of Instructional Programs (CIP) code updated appropriately. Planned Corrective Action: The Director of Student Financial Services now oversees enrollment reporting to the third-party servicer. The director reviews enrollment reporting to the third party and also reviews reporting to the third-party servicer to ensure accurate and timely reporting to NSLDS. Contact person responsible for corrective action: Callie Zake, Director of Student Financial Aid Anticipated Completion Date: June 19, 2026

View Audit 395532

Finding 1191675 (2025-004)

Material Weakness 2025

Kalamazoo Valley Community College

MI

Student Financial Aid Subrecipient Monitoring Reporting

Condition: Of the 40 students selected for enrollment reporting, the College did not update the student enrollment information for 3 students accurately. Planned Corrective Action: The College will modify its process and update its documented procedures to include periodically running an Enrollment ...

Condition: Of the 40 students selected for enrollment reporting, the College did not update the student enrollment information for 3 students accurately. Planned Corrective Action: The College will modify its process and update its documented procedures to include periodically running an Enrollment Reporting Graduated/Withdrawn Report from NLSDS and review for accuracy and make timely corrections, if necessary. Contact person responsible for corrective action: Director of Financial Aid Anticipated Completion Date: June 30, 2026

View Audit 395523

Finding 1191673 (2025-003)

Material Weakness 2025

Kalamazoo Valley Community College

MI

Student Financial Aid Subrecipient Monitoring Reporting

Condition: The College did not have appropriate segregation of duties in place to ensure the reporting to COD is being reviewed by an individual separate from the process of preparing the reconciliations. Planned Corrective Action: The College will modify its process and update its documented proced...

Condition: The College did not have appropriate segregation of duties in place to ensure the reporting to COD is being reviewed by an individual separate from the process of preparing the reconciliations. Planned Corrective Action: The College will modify its process and update its documented procedures to include an appropriate review of the reconciliation by an individual separate from the process of preparing the reconciliations. Contact person responsible for corrective action: Director of Financial Aid Anticipated Completion Date: June 30, 2026

View Audit 395523

Finding 1191671 (2025-002)

Material Weakness 2025

Kalamazoo Valley Community College

MI

Student Financial Aid Subrecipient Monitoring Significant Deficiency

Condition: The College did not provide notifications to certain students related to direct loan disbursements. Planned Corrective Action: The Director of Financial Aid will work with our information technology department to ensure the criteria used for triggering the notification emails is correct a...

Condition: The College did not provide notifications to certain students related to direct loan disbursements. Planned Corrective Action: The Director of Financial Aid will work with our information technology department to ensure the criteria used for triggering the notification emails is correct and capturing all the necessary students. Additionally, an exception report will be created to identify students who have not been sent the notification email for the financial aid department to review and then send the appropriate notification. The department procedures will be updated to reflect these changes in process. Contact person responsible for corrective action: Director of Financial Aid Anticipated Completion Date: March 31, 2026

View Audit 395523

Finding 1191669 (2025-001)

Material Weakness 2025

Kalamazoo Valley Community College

MI

Student Financial Aid Subrecipient Monitoring Material Weakness

Condition: Out of 60 students tested for return to Title IV, we identified 4 students whose calculations were performed outside of the required time frame. Planned Corrective Action: The College will work with its Director of Financial Aid to ensure the semester end procedures include steps to ident...

Condition: Out of 60 students tested for return to Title IV, we identified 4 students whose calculations were performed outside of the required time frame. Planned Corrective Action: The College will work with its Director of Financial Aid to ensure the semester end procedures include steps to identify those students who unofficially withdrew. Once the students are identified, individuals with appropriate skills and knowledge will be able to determine if a return of Title IV calculation is necessary and appropriately return any funds, as necessary. Contact person responsible for corrective action: Director of Financial Aid Anticipated Completion Date: March 31, 2026

View Audit 395523

Finding 1191653 (2025-004)

Material Weakness 2025

Hawaii Pacific University

HI

Special Tests & Provisions Student Financial Aid

The officials responsible for Student Accounts acknowledge that certain student financial aid refunds were processed outside the 14-day federal deadline, primarily due to insufficient Title IV training during the initial transfer of responsibilities to Student Accounts. While a standard operating pr...

The officials responsible for Student Accounts acknowledge that certain student financial aid refunds were processed outside the 14-day federal deadline, primarily due to insufficient Title IV training during the initial transfer of responsibilities to Student Accounts. While a standard operating procedures (SOP) exists within the current refunds training, it is limited, focusing primarily on the reports and some of federal requirements but does not provide sufficient detail on regulations, reviews, approvals, and timelines. Student Accounts has already taken steps to address and correct the misinformation, but additional improvements are still needed. The SOP for refunds is currently in progress to fully incorporate all necessary items to ensure better and clearer training guidelines. Mandatory Title IV refund training will be provided to all Refund Representatives and included in onboarding for new hire. We shall set established expectations set for all individuals involved in the process, including their delegates, to ensure accountability and consistent application of procedures. Ongoing collaboration with Financial Aid will ensure procedures are consistently applied, questions are addressed, and staff remain current with requirements. These actions are expected to ensure compliance with the 14-day federal requirement, strengthen staff competency, and support continuous improvement in refund processing. Person(s) Responsible: Student Accounts Manager (training), Associate Vice President & Controller Targeted Correction Date: June 30, 2026

View Audit 395499

Finding 1191652 (2025-003)

Material Weakness 2025

Hawaii Pacific University

HI

Student Financial Aid Special Tests & Provisions Reporting

At the end of the 2023–24 award year, responsibility for generating Return of Title IV (R2T4) withdrawal lists transitioned from the Business Office to the Financial Aid Office. The Financial Aid Office began producing both official withdrawal and unofficial (non-passing grade) reports through Elluc...

At the end of the 2023–24 award year, responsibility for generating Return of Title IV (R2T4) withdrawal lists transitioned from the Business Office to the Financial Aid Office. The Financial Aid Office began producing both official withdrawal and unofficial (non-passing grade) reports through Ellucian Banner. Because the two reports produced nearly identical student listings, it was assumed that the Banner-generated unofficial withdrawal report was effectively identifying all students who had received non-passing grades.During an internal audit conducted at the end of the Spring 2025 semester, the University identified one student who had failed all courses and was not included on either of the R2T4 lists. Upon further review, the issue was traced to a reporting limitation within Banner that excluded some students with all failing grades from the population used for R2T4 review. To resolve this, the Financial Aid Office coordinated with the Registrar’s Office to obtain a complete list of students who officially withdrew and students with all non-passing grades once final grades were submitted. R2T4 calculations were subsequently performed for applicable students identified in this additional list. Since Spring 2025, the University has institutionalized this revised procedure. The Registrar’s Office now provides the Financial Aid Office with a list of all students with non-passing grades at the end of each semester once grades are submitted. The Financial Aid Office reviews both reports to identify potential unofficial withdrawals and performs R2T4 calculations as required. To strengthen oversight and prevent future omissions during staffing transitions or process changes, the University will: • Document the revised R2T4 identification and review process in the Financial Aid operations manual. • Clearly assign responsibility for report generation, review, and follow-up between the Registrar’s Office and Financial Aid Office. • Implement a quarterly internal cross-check to confirm all required R2T4 reviews are completed. Person(s) Responsible: Associate Director of Financial Aid and Director of Financial Aid. Correction Date: January 31, 2026. This issue is resolved.

View Audit 395499

Finding 1191651 (2025-002)

Material Weakness 2025

Hawaii Pacific University

HI

Subrecipient Monitoring Student Financial Aid Reporting

The University has made substantial progress toward completing the remaining elements required under the Gramm-Leach-Bliley Act (GLBA) and aligning its program with the FTC Safeguards Rule. Full implementation timelines are primarily constrained by current staffing capacity within ITS/Cybersecurity ...

The University has made substantial progress toward completing the remaining elements required under the Gramm-Leach-Bliley Act (GLBA) and aligning its program with the FTC Safeguards Rule. Full implementation timelines are primarily constrained by current staffing capacity within ITS/Cybersecurity and Legal, as well as certain technical tool limitations (e.g., data discovery and validation). Despite these constraints, notable progress has been achieved across the required FTC Safeguards Program elements as summarized below: • Element 1 – Designate a Qualified Individual: Completed. Qualified individual appointed to implement and supervise the company’s information security program; reporting mechanisms to the Board established. Completion is confirmed based on oversight and execution of subsequent program elements. • Element 2 – Conduct a Risk Assessment: Completed. Initial risk assessment conducted to identify reasonably foreseeable threats; controls and priorities for Elements 3–9 is being guided by this assessment. • Element 3 – Access Controls & Data Classification: 70% complete. Policies finalized; multi- factor authentication (MFA) implemented; initial asset inventory completed. Data owner assignments and detailed access reviews are in progress. • Element 4 – Vulnerability Management: Complete. Latest penetration testing identified no critical findings. • Element 5 – Information Security Policies: Drafted and pending Legal review; Board acceptance scheduled for March 2026. • Element 6 – Third-Party Oversight: 70% complete. Policy and workflow developed; Board acceptance scheduled for March 2026. • Element 7 – Periodic Risk Assessments: 80% complete. Updated risk assessment currently in progress. • Element 8 – Incident Response Plan: 90% complete. Final reporting and approval scheduled for March 2026. • Element 9 – Qualified Individual & Board Reporting: 90% complete. Annual report scheduled for March 2026. • Red Flags Rule (Identity Theft Prevention): 50% complete. Policy drafted, complete comprehensive program, formal procedures and additional trainings still required. Next Steps: Remaining actions will be completed as Legal and Board approvals are obtained and staffing capacity allows. HPU will continue to develop and retain documentation supporting the completion and implementation of each safeguard element, as prescribed by GLBA. Periodic internal assessments of the Information Security Program will be scheduled following full implementation, with consideration given to engaging an independent third party for future reviews. Person(s) Responsible: Information Security Officer; Vice President of Operations and Chief Information Officer. Targeted Correction Date: March 31, 2026.

View Audit 395499

Finding 1191562 (2025-012)

Material Weakness 2025

Leech Lake Tribal College

AZ

Internal Control / Segregation of Duties Student Financial Aid Material Weakness

The College will enforce policies and procedures to ensure that compliance with the requirements. New internal controls are expected to be implemented to address these findings.

View Audit 395432

Finding 1191560 (2025-011)

Material Weakness 2025

Leech Lake Tribal College

AZ

Student Financial Aid

The College will enforce policies and procedures to ensure that compliance with the requirements. New internal controls are expected to be implemented to address these findings.

View Audit 395432

Finding 1191558 (2025-010)

Material Weakness 2025

Leech Lake Tribal College

AZ

Internal Control / Segregation of Duties Student Financial Aid Material Weakness

The College will enforce policies and procedures to ensure that compliance with the requirements. New internal controls are expected to be implemented to address these findings.

View Audit 395432

Finding 1191556 (2025-009)

Material Weakness 2025

Leech Lake Tribal College

AZ

Student Financial Aid Material Weakness

The College will enforce policies and procedures to ensure that compliance with the requirements. New internal controls are expected to be implemented to address these findings.

View Audit 395432

Finding 1191554 (2025-008)

Material Weakness 2025

Leech Lake Tribal College

AZ

Student Financial Aid Eligibility Reporting

Annual performance reports will be submitted on time as required by the funding agency. Management has developed a comprehensive listing of all reporting requirements and will utilize this information to ensure all reporting requirements are met.

View Audit 395432

Corrective Action Plans

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