Corrective Action Plans

To save the current and future FISAP, financial aid will proceed as follows: 1. An Argos report based on Banner data that permits the data to be exported to Excel. This will filter data for various sections of the application. 2. A shared folder in OneDrive to which the associate director of information processes and financial aid assistant vice-president have access. 3. Creation of a "FISAP preparation guide” that describes each part of the application, the corresponding data, and its sources. Each source will have its supporting documents. 4. Once the FISAP process begins, the documents that are going to be stored are: a. Original Banner and Excel Data b. Tuition report by category issued by the accounting Office (Accounting Director). c. Pell expenditures per enclosure issued by the accounting office (Associate Director of External Funds). d. Draft of FISAP (before submission) e. Submitted FISAP f. Final FISAP that is exported from COD that contains the information when the CEO filed the signature. g. Notification by venue when COD receives the request. h. Notification of discrepancies or review from the USDE. i. Updates or changes in FISAP application, if applies.

Finding 2023-041 – Corrective Action Plan There is no disagreement with the audit finding. The financial aid office has identified the position within the department that is responsible for completing monthly reconciliation or the Direct Lending program. This position has been given the policy and procedures related to reconciliation and has immediately begun following these procedures. This position will also seek out additional resources and trainings to ensure compliance moving forward. The director will support the process by allowing the time for these processes to be done on a monthly basis as well as provide support for future trainings. Anticipated Completion Date: January 2024 Contact Person: Jennifer Burke, Interim Director of Financial Aid, Rhode Island College jburke1@ric.edu

Finding 2023-042 – Corrective Action Plan There is no disagreement with the audit finding. The University has enacted an Information Security Policy, “URI Information Technology Standard”, which was issued on December 6, 2023. This standard defines the minimum information security requirements for the University of Rhode Island. The full standard can be found at the following URL: https://uri0.sharepoint.com/sites/URIInformationTechnologyServicesCommunication/SitePages/ITS-Security.aspx?ga=1. Anticipated Completion Date: December 6, 2023 Contact Persons: Gabrile Fariello, Interim Chief Information Officer, University of Rhode Island gfariello@uri.edu Michael Khalfayan, Chief Information Systems Officer, University of Rhode Island mkhalfayan@uri.edu

Finding 2023-040 – Corrective Action Plan There is no disagreement with the audit finding. The College has designated the Director of Information Security to oversee the information security function. The College has contracted with a firm to function as a virtual Certified Information Security Officer (vCISO) to support compliance as well as provide training and consulting services. The Assistance Vice President, Chief Information Officer is tasked with ensuring that the Written Information Security Program is updated annually and that compliance is maintained. Anticipated Completion Date: June 2024 Contact Person: Pamela Christman, Assistance Vice President, Chief Information Officer, Rhode Island College pchristman@ric.edu

Name of Responsible Individual: Vice President of Finance and Administration (David Byrd) and Controller (Michelle Lane) Corrective Action: The University concurs with the finding. The University will make disbursements as soon as they are available, but no later than the three (3) business days following receipt of funds. University policies and procedures will be followed closely to ensure there is no excess cash. All funds will be returned in a timely manner. Anticipated Completion Date: June 30, 2024

Name of Responsible Individual: University Registrar (Charee Ellison), Vice President of Academic Affairs (Dr. Renata Dusenbury) Corrective Action: The University concurs with this finding. This action is completed through a third party service (National Student Clearinghouse) which updates the NSLDS automatically. As student enrollment changes and awards are adjusted, the Director of Financial Aid updates the Registrar who makes adjustments in NSC and those adjustments are noted in NSLDS. The University Registrar will check behind NSC on a monthly basis to ensure that enrollment dates are correct and have been submitted to NSLDS in a timely manner. Anticipated Completion Date: June 30, 2024

Name of Responsible Individual: Director of Financial Aid (Dr. OJ Ifegwu) Vice President of Enrollment Management (Dr. Stacey Sowell) Corrective Action: The University concurs with this finding. The CARES Act allowed FWS funds to be transferred above the 10% threshold to SEOG. This program expired on May 11, 2023. The documentation for this program can be found on fsapartners.ed.gov, communication CB-22-13 and is dated August 1, 2022. The University did not complete the form in COD for this extended portion of the CARES Act. However, it was properly reported on the FISAP. This program has expired and the University will be at or below the 10% threshold going forward. Anticipated Completion Date: June 30, 2024

Name of Responsible Individual: Director of Financial Aid (Dr. OJ Ifegwu) Vice President of Enrollment Management (Dr. Stacey Sowell) Corrective Action: The University concurs with finding and will monitor internal controls to ensure that all student disbursement data occurs within 15 calendar days after payment or the University becomes aware of the need to make an adjustment. Internal controls will be maintained by reporting on a daily basis as disbursements are posted. Anticipated Completion Date: June 30, 2024

2023-003 Allowable Cost- Payroll Recommendation We recommend that the schools develop internal controls and procedures to ensure the documentation is consistently maintained and readily available to support compliance with grantor’s requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: 1. Requirements to support documentation of payroll expenditures will be reviewed with school staff annually as part of grant support visits, resource materials provided and other technical assistance sessions. 2. As part of Spring 2024 site visits to be completed prior to June 30, 2024, Title I specialists will review with school staff requirements for documentation to support payroll expenditures using Title I funds. Documentation of stipend and temporary staff payroll will be collected and saved in the school’s grant monitoring folder. This activity will also occur in September 2024 for summer stipend/temp staff payments. 3. Charter schools utilizing Title II and/or Title IV funds will continue to participate in twice annual monitoring by the Office of Data Monitoring and Compliance to review support documentation for any stipend/temporary staff payments. 4. Schools leveraging ESSER funds in SY23/24 for stipend/temporary staff payments will be requested to upload support documentation to a district established SharePoint site prior to June 30, 2024. 5. By April 30, 2024 requirements for payroll expenditure documentation will be reviewed with district offices implementing grant funded district initiatives. These meetings include Title I, Title II, Title III, Title IV, Perkins and COVID relief grant funds. All district offices will be required to save support documentation for stipend and temporary staff payments for district level and/or district coordinated activities to a SharePoint folder to ensure accessibility for future monitoring activities. The district staff person from the Office of Data Monitoring and Compliance assigned to support the federal grant will review uploaded materials to ensure the documentation supports payroll expenditures. Name(s) of the contact person(s) responsible for corrective action: Kimberly Hoffmann Planned completion date for corrective action plan: June 2024.

Identifying Number: Finding No. 2023-002: Special Tests – Enrollment Reporting and Gramm-Leach-Bliley Act Compliance/Material Weakness Finding: Instances of noncompliance have been identified around major compliance requirements Enrollment Reporting and Gramm-Bleach-Bliley Act, which are both part of special tests identified in the 2023 Compliance Supplement. ¬ Corrective Actions Taken or Planned: Responsible Official: Iman Riddick, Registrar, Dean Lane, Chief Information Officer (CIO) Anticipated Completion Date: 06/30/2024 View of Responsible Individuals: Management agrees with the assessment and finding. Dean Lane, CIO, will review the annual updates to the Student Financial Assistance Cluster within the OMB Compliance Supplement to ensure the Institute has policies, procedures, and controls in place for all required compliance requirements. For the noncompliance identified around the Gramm-Leach Bliley Act, the Institute will ensure compliance by establishing a formal written policy that will be created by Dean Lane, CIO, that addresses all required elements for a written information security program listed in the OMB Compliance Supplement. The CFO will review the policy once completed to ensure all required elements within the Compliance Supplement are included. For the noncompliance identified around the Enrollment Reporting special test, the Institute plans to have the Registrar attend comprehensive trainings around enrollment reporting offered by the National Student Clearinghouse (NSC) to further educate and enhance their understanding around the enrollment reporting compliance requirement. In addition, the Institute will have each month’s enrollment data submission by the Registrar to the National Student Clearinghouse reviewed by the Director of Financial Aid to verify completeness, accuracy, and timeliness of reporting. This will allow the Institute to correct any inaccurate reporting and verify timely submissions.

2023-001 - Non-Compliance with Timely Student Enrollment Change Submissions to the National Student Loan Data System (NSLDS) Management View and Corrective Action Plan February 9, 2024 Inaccurate Graduated Student Enrollment Reporting Management View and Opinion NYU Registrar reports a student's enrollment, withdrawal and graduation status to the National Student Clearinghouse (NSC) weekly, per term, which includes a few weeks before and after the term has ended. NSC transfers this data to the National Student Loan Data System (NSLDS). During the degree/graduation reporting period to NSC, the graduation records for some students are not processed prior to NSC's calculated withdrawal which occurs at the start of the subsequent enrollment reporting period. As such, some students are reflected as withdrawn from a term, when in fact they graduated. This impacts the accuracy of student data reported to the National Student Loan Data System. Corrective Action Plan Currently, students self-identify when their loan servicer reflects an incorrect enrollment or loan repayment status. In these cases, the Office of Financial Aid or Registrar manually adjust the NSLDS/NSC file. NSC procedural timelines impact and limit NYU staff’s access to make manual adjustments. Going forward, the Office of Financial Aid and Registrar will collaborate to upload an NYU Graduated Student file directly to NSLDS to update the records of all students to ensure their graduation status are reported accurately and in a timely manner. This upload will be done through the Enrollment Spreadsheet Submittal function on the NSLDS website. The file will include graduated status information for each conferred student in our most recent conferral period. Timeline for Action Plan The corrective action plan will be implemented as follows: Starting in March 2024, the Office of Financial Aid will provide the NSLDS Graduated Student file template to the Registrar. At the close of each conferral period, the Registrar will populate the template spreadsheet with required data points for all graduating students. After the Office of Financial Aid securely receives the completed spreadsheet from the Registrar, it will be uploaded, within the required 60 days, to NSLDS for processing of the students’ graduation records. Responsible Individual: Jason Crowe Email: Jason.Crowe@nyu.edu

Finding Number: 2023-002 Condition: The College did not follow all the Tier Two arrangement requirements and disclosures. Planned Corrective Action: The College will ensure that regulations related to Tier Two arrangements are reviewed. On a semiannual basis, the College will review all arrangements service providers for compliance with regulations. In addition, the College will review cash management regulations and references such as Dear Colleague letters on the subject matter to remain current with requirements. Contact person responsible for corrective action: Ms. Taranne Roberts and Dr. Sharron T. Burnett Anticipated Completion Date: 06/30/2024

Finding Number: 2023-015 Federal Program: 14.218 – U.S. Department of Housing and Urban Development (HUD) – Community Development Block Grant (CDBG) – Entitlement Grants Cluster 93.563 – Title IV-D, U.S. Department of Health and Human Service - Child Support Enforcement (CSE) 10.557, U.S. Department of Agriculture – WIC Special Supplemental Nutrition Program for Women, Infants, and Children Condition Per Auditor: Controls in place were not adequate to ensure compliance with 2 CFR 200 Appendix V submission requirements for the County’s self insurance cost allocation process and annual chargeback plan. Planned Corrective Action: Management communicated with the cognizant agency which confirmed in November 2021, OMB issued guidance relating to CARES Act funding and its effect on indirect cost. Part of this guidance stated that “CARES Act funding should not be included toward the threshold amount for indirect cost submission required in 2 C.F.R. part 200, Appendix VII, paragraph D.1.b”. Therefore, County governments that met the $100 million threshold as a result of CARES Act funding are not required to submit their Central Service Cost Allocation Plan for approval. The CARES Act funding would have increased the County’s funding in excess of $100 million, which should not have been a part of the determination for the original finding. However, since CSLFRF funds were also received increasing the County’s funding in excess of $100 million the annual chargeback plans were submitted to the cognizant agency and U.S. Treasury in 2023 for implementation in FY 24 and will continue to submit subsequent plans to federal cognizant agency, as required by 2 CFR 200 Appendix V. Anticipated Completion Date: 9/30/24 Responsible Contact Person: Shauntika Bullard and Michael Bridges

2023-008 – Eligibility – Material Weakness in Internal Controls over Compliance and Material Noncompliance Student Financial Assistance Cluster U.S Department of Education Federal Assistance Listing Number: 84.063, 84.268, 84.007, 84.033, 84.379 Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans, Federal Supplemental Educational Opportunity Grants, Federal Work-Study Program Finding Summary: The College did not have adequate controls in place to ensure the appropriate and reasonable amounts were included in each eligible cost of attendance category for its students, that awards were properly calculated, refunds were disbursed timely and student records were accurate. The auditors were not able to conclude that the College is in compliance with eligibility requirements in the OMB compliance supplement. Repeat finding: No Responsible Individuals: Michael N. Espinoza, Vice President of Student Services Views of responsible officials and planned corrective actions: The college entered into a third-party contract to manage financial aid packaging and awarding. Calculation and reporting completed by prior Financial Director submitted national average as the college calculations instead of college service area specific calculations. The college worked with the third-party provider to ensure policies and processes adopted in July 2023 to ensure cost of attendance (COA) reporting and calculations are complete and accurate going forward. Corrective Action: The College will review their policies, procedures and controls to ensure that annually a cost of attendance schedule is approved, and that the approved schedule is used in packaging student financial aid. Rationale for adjustments made to the budgeted cost of attendance for individual students should be documented and support maintained. The College will review all processes and procedures related to eligibility to ensure controls are well documented and to properly adhere to requirements for eligibility of Title IV aid. Anticipated Completion Date: to be completed by June 30, 2024

2023-007 – Reporting – Material Weakness in Internal Controls Student Financial Assistance Cluster U.S Department of Education Federal Assistance Listing Number: 84.063, 84.268 Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans Finding Summary: The College did not have adequate and/or functioning controls in place to ensure the reporting of disbursements to students on COD was submitted in a timely way and that the dates and amounts agreed. The administration of the Title IV programs depends heavily on the accuracy and timeliness of the disbursement information reported by institutions. The College is not in compliance with the federal COD reporting requirements described in the OMB Compliance Supplement and required by the Department of Education. Repeat finding: Yes, 2022-004 Responsible Individuals: Michael N. Espinoza, Vice President of Student Services Corrective Action: The college will conduct ongoing training to develop reporting and process steps to prevent reporting errors and improve accuracy in reporting in identifying student’s assistance needs. The College has entered into an agreement with a third-party financial aid provider to service and administer financial aid awards, COD reporting and reconciliation.  The College will implement a process to review, update, and verify student disbursements are reported to COD accurately and timely.  Prevention to include creation of reports for awards pending and detailed disbursement and reconciliations schedules, and system back-end processes. 108  Implemented a tracking log starting in July 2023 between Financial Aid and the Business Office to ensure distribution in compliance with Common Origination and Disbursement (COD). Anticipated Completion Date: to be completed by June 30, 2024

2023-006 – Gramm-Leach-Bliley Act – Student Information Security – Material Weakness in Internal Controls over Compliance and Material Noncompliance Student Financial Assistance Cluster U.S Department of Education Federal Assistance Listing Number: 84.063, 84.268, 84.007, 84.033, 84.379 Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans, Federal Supplemental Educational Opportunity Grants, Federal Work-Study Program 107 Finding Summary: Staffing shortages have contributed to the delay in the implementation of this standard. The absence of a well-designed and documented policy addressing the standards set forth under the act could put the security, confidentiality, and integrity of student information at risk. Responsible Individuals: Andrew Burke, Chief Information Officer Corrective actions Plan: The college released a Request for Proposal (RFP) to contract with outside information technology services to guide the development and implement a comprehensive information security program and address staffing gaps. Outside Chief Information Officer, information security, and technical partnership completed and contracted effective April 2024. Outside service will guide the college in the review and implementation of procedures and policies necessary for the required controls to be completed through the following phase:  Assessment and gap analysis of current infrastructure and cybersecurity measures.  Develop necessary policies and procedures based on NIST guidelines and GLBA requirements.  Detect and respond to ongoing training and incident response planning. Anticipated Completion Date: to be completed by June 30, 2024

2023-005 – Special Tests and Provisions – Return of Title IV Funds (R2T4) – Material Weakness in Internal Controls over Compliance and Material Noncompliance Student Financial Assistance Cluster Department of Education Finding Summary: This occurred because of lack of controls and processes in place to ensure supporting documentation is maintained for student’s withdrawal dates, and a lack of understanding of compliance requirements. This resulted in a failure to properly identify students requiring calculation for return of funds to the federal government, or eligibility for post withdrawal disbursement. As a result, the auditors were unable to determine if the College is remitting unearned funds to the federal government, or offering eligible students post withdrawal disbursements if available to them. Responsible Individuals: Michael N. Espinoza, Vice President of Student Services Corrective Action Plan: The college entered into a third-party contract to manage financial aid packaging and awarding. Integration and processes for the R2T4 calculation with the third-party processer was not completed correctly. New integrations, policies, and processes to be adopted in fiscal year 2023-24.  Develop and implement ongoing tracking and reporting for all financial aid reporting.  Financial Aid and Student Accounts work to regularly review and action student account files.  Continue to work with third-party service to review and promptly return Title IV funding in compliance with federal rulings. Anticipated Completion Date: to be completed by June 30, 2024

over Compliance and Material Noncompliance Student Financial Assistance Cluster Department of Education Federal Assistance Listing Number: 84.063, 84.268 Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans Finding Summary: The College did not have controls in place to ensure the reporting of enrollment information under the Pell grant and Direct loan programs via NSLDS was completed. Due to the way the College’s software pulls the roster information, the Clearing House is unable to send the data to NSLDS. While the College has been working with the software vendor to correct this issue, the reporting process for NSLDS stopped in the prior award year and has not resumed. Management did not implement other processes or procedures to deal with the issues encountered with the software to fulfill their responsibility to ensure accurate and timely reporting and submission of student status during the year. The College is not in compliance with the federal enrollment reporting requirements described in the OMB Compliance Supplement and required by the Department of Education. Repeat finding – Yes, 2022-003 Responsible Individuals: Mary Martin, Registrar Michael N. Espinoza, Vice President of Student Services Corrective Action Plan: Enrollment reporting is the responsibility of the Columbia Gorge Community College (CGCC) Registrar. Reporting of enrollment information in a timely manner for the year ended June 30, 2023, was impacted by the implementation of a new Student Information System (SIS) in May 2021. The SIS included significant changes to student recording procedures and a new enrollment reporting process. In response to the Enrollment Reporting Finding for the year ended June 30, 2023, the Registrar continues working to mitigate any issues negatively impacting enrollment reporting by:  working with the Vice President of Student Services and Director of Financial Aid to establish internal checks and balances to ensure reporting is being done in a timely manner.  working with SIS system support staff and internal IT staff to promptly address technical issues and/or other issues impacting enrollment reporting. 106  working with National Student Clearinghouse representative to ensure reporting schedule meets required timeframes.  consistent review of enrollment files prior to submission to ensure correct student enrollment statuses and program information are being reported.  prompt resolution of reporting errors.  identifying and training of additional staff on enrollment reporting. Anticipated Completion Date: to be completed by June 30, 2024

Enrollment Reporting Cluster: Student Financial Assistance Federal Awarding Agency: Department of Education (ED) Award Name: Federal Pell Grant Program, Federal Direct Student Loans Award Number: Not applicable Award Year: 2022-2023 Assistance Listing Title: Federal Pell Grant Program, Federal Direct Student Loans Assistance Listing Number: 84.063 and 84.268 Pass-through entities: Not applicable Facts of Finding: The University uses National Student Clearinghouse (NSC) to help report enrollment status changes to National Student Loan Data System (NSLDS). For students that had a gap in enrollment and were no longer with the University, the NSC system recognized these students as “withdrawn” regardless of whether they were reported as “withdrawn” or “graduated.” The University confirmed these students were properly reported to NSC as “graduated”; however, when the reporting from NSC to NSLDS occurred, it was based on the information recognized by NSC, and as such these students were reported as “withdrawn.” Acceptance of Finding: We agree with the above finding and will implement the corrective plan of action as described below: Corrective Plan of Action: After submission of enrollment information to the NSLDS, the University has not historically verified that the NSLDS has updated students’ enrollment status accurately. The University will formalize a process and establish procedures to regularly identify students whose enrollment status is improperly reported to NSLDS, particularly those reported as “withdrawn” instead of “graduated.” To the extent there are discrepancies between the University’s records and these students’ enrollment status in NSLDS, the University will correct the enrollment status of such students in NSLDS accordingly. This process and related procedures will be established and implemented by the close of the current fiscal year, July 31, 2024.

I will ensure the Financial Aid Office works closely with the Accounts Payables department to monitor that all Title IV refund checks have been cashed after 30 days of issuance of the refund. If a check has not been cashed a new check will be reissued immediately. If, after 30 days of the reissuance, the check has not been cashed then the funds will be returned to the Department of Education within the mandated 45-day period.

We recently completed the transition and onboarding of departmental staff which would allow the University to fully enact its plan to ensure both the financial aid and the Registrar's office will perform prompt review of processing University withdrawals. The Registrar's office will develop process and procedures documentation as an internal control measuring tool to ensure that Administrative Withdrawals (AW) and Withdrawals for lack of attendance (WA) that affect student emollment are identified immediately. Staff in the Financial Aid and the Registrar's office will actively take part in training workshops and webinars provided by the Depatiment of Education and NASF AA for continuing education to stay abreast of new developments and best practices in the industry.

Finding 2023-002 - U.S. Department of Education (USD), Title IV Student Financial Aid Programs (material weakness): We observed the following conditions in connection with our testing of the various U.S. Department of Education, Title IV, Student Financial Assistance Programs: (a) The College did not reconcile the following programs between the Office of Financial Aid and the Business Office. Per 34 CFR 685.300(b)(5). i. Federal Pell Grant Program ii. Federal Direct Student Loans iii. Federal SEOG (b) The Office of Financial Aid submitted unreconciled expenditures within the Fiscal Operations Report and Application to Participate (FISAP) for the programs below: i. Federal Pell Grant Program ii. Federal Work Study (FWS) Program (c) One (1) out of 6 students tested for withdrawals and the return of Title IV funds did not have their Title IV program funds returned within the 45-day requirement. HEA, Section 484B & 34 CFR 668.22. (d) One (1) out of 60 students had a credit balance on their account created by Title IV program funds longer than 14 days. 34 CFR 668.164(h)(1). (e) One (1) out of 60 students tested did not make satisfactory academic progress (SAP) for the academic year. The College did not provide supporting documentation for successful appeals and allowed the students to receive Title IV funding. 34 CFR 668.34. Questioned cost for this finding is: $6,198. (f) Five (5) out of 60 students tested did not have high school/GED to prove eligibility for the program they were enrolled within the College. HEA Section 484(d) and 34 CFR 668.32. Questioned cost for this finding is $41,443. (g) Four (4) out of 60 students tested were accepted as transfer students but did not have official (transfer) transcripts to prove eligibility for the program they were enrolled within the College. HEA Section 484(d) and 34 CFR 668.32. Questioned cost for this finding is $40,383. The College should implement corrective actions to ensure that the above findings are resolved and do not recur in future periods. Moreover, internal controls over compliance with federal program regulations should be revisited to ensure adequate supervisory controls, quality assurance reviews of processes, and policies and procedures are being updated and adhered to for compliance purposes. Corrective Actions – Philander Smith College concurs with this finding, and the following action has been taken. Philander Smith College improved the efficiency of reconciling between the Financial Aid Office and COD by standardizing procedures. Staff-wide calendar events have been set to standardize routine processing of reconciliation data. Direct Loan SAS files are imported into the COD "DL SAS Disb On Demand Reader" tool and converted to Microsoft Excel files. Pell SAS/ Reconciliation files are imported into the COD "Pell Recon Reader" tool and converted to Microsoft Excel files. The SAS files and financial aid management system (FAMS) files are imported into Microsoft Access tables and Microsoft Access queries are run to determine discrepancies between SAS file data and FAMS data. This standardization provides an efficient procedure for staff members to follow. Staff have been cross trained to reduce processing delays. This system, incorporating efficient technology, calendar reminders, and cross training has improved the efficiency of reconciliation activities. Financial Aid staff coordinate with Business Office staff for notification after the Financial Aid to COD reconciliation is complete. Financial Aid staff are updating the policies for SAP supporting documentation submission that require students to submit documents via the student financial aid portal where documents will be securely stored and backed up within the College servers. Financial Aid staff are updating processes among Financial Aid, the Registrar's Office, and Academic Affairs to strengthen timely identification of both official and unofficial withdrawals for timely Return to Title IV Funds processing. Finally, during the pandemic, the College experienced some difficulties obtaining official high school transcripts due to school closings. The College is continuing to work to review files to ensure this is fully addressed.

Description: Special Tests & provisions – Return of Title IV Funds Corrective action: The University’s finance office has reviewed the finding presented by FORVIS and agrees with their evaluation that the R2T4 calculation. As the University has closed and there are no additional R2T4 calculations to be made, this problem has self‐corrected. Person Responsible for Implementation: Kenneth M. Macur, VP for Business and Finance Status: Fully corrected

Federal Award Findings and Questions Costs Corrective Action Plan Year Ended August 31, 2023 Finding No. 2023-001: Inaccurate Enrollment Reporting CFDA Numbers: Various Program: Student Financial Assistance Cluster Corrective Action: Students will be required to request special permission to re-enroll, thus ensuring that their graduation is reported before any additional enrollment or withdrawal. Additionally, a thorough assessment of the management review process will be performed to identify areas that will help ensure the accurate submission of data to the NSLDS. We anticipate revised processes in the Spring of 2024. Contact Person: Jaci Casazza Expected Implementation: April 30, 2024

Going forward, all students who withdrawal from the College will be forwarded to the financial aid team to review whether a student is still eligible for the full funding of the specific semester in question or whether funding needs to be returned based on the withdrawal date. If it is deemed that funds need to be returned, the Bursar will provide the financial aid team with a copy of the student charges for that period and the Registrar will provide proof of the withdrawal date and the financial aid team will determine the amount of funding that needs to be returned. Financial Aid will then complete the return through the student's account and notify the Controller and VP of Finance and Administration to process the return to G5.