Corrective Action Plans

Finding 2024-001 – Special Tests and Provisions – Exit Counseling – Significant Deficiency Name of Federal Agency: U.S. Department of Education Federal Program Name: Federal Direct Student Loans Assistance Listing Number: 84.268 Federal Award Identification Number and Year: P268K243382 2024 Name of Pass-through Entity: N/A Planned Corrective Action: The failure to document the exit conference of one student borrower in the Federal Direct Loans Program, as noted in the auditor’s findings, was an administrative oversight. In May 2025, the Institute reviewed and revised its current procedures to ensure that all exit conferences are documented. Under the revised procedures, an employee independent from the exit conference process is to review that any student that has not enrolled in a new semester or that is enrolled at less than half time status has received proper exit conferencing and that the exit conferencing has been properly documented.

Finding NO. 2024-0006 – Reporting View of the University of Guam and Correction Action Plan: An agreed upon timeline for generating data will be established for use in the annual FISAP. The Admissions and Records Office will generate the school enrollment for the relevant academic year. The data snapshot will be taken immediately after the end of the summer semester. For the enrollment data for AY24-25, the snapshot will be taken during the first week of September 2025 with a similar timeline for subsequent years. Once that data snapshot is generated, the Office of Information Technology will generate a report of collected tuition and fees corresponding to the snapshot data from Admissions and Records. In testing, this was found to be the most accurate process in generating the required data for the FISAP. Name of Contact Person: Mark Duarte, Director, Financial Aid and Triton One Stop Office Proposed Completion date: Next Reporting Period

Finding NO. 2024-005 Special Tests and Provisions – Enrollment Reporting View of the University of Guam and Corrective Action Plan: The University of Guam has signed a service agreement with the National Student Clearinghouse (NSC) to assist the University with enrollment reporting. The Admissions and Records Office (A&R) will submit an enrollment report to the NSC at least four times per semester. A first of term report, and three other subsequent reports within the semester. This report will be sent to the National Student Loan Database System (NSLDS) in fulfillment of the federal regulations requirement for enrollment reporting. Name of Contact Person: Mark Duarte, Director, Financial Aid and Triton One Stop Office Proposed Completion date: Next Reporting Period

Finding NO. 2024-003 Cash Management View of the University of Guam and Corrective Action Plan: The Financial Aid Office (FAO) will conduct both internal and external monthly reconciliations to ensure the accuracy of financial aid disbursements and compliance with federal regulations. Internally, the FAO and the Business Office will reconcile actual disbursements and adjustments against drawdowns, drawdown adjustments, refunds of cash, and returns weekly or bi-weekly, following each transmittal to the Business Office. Any discrepancies will be documented and resolved promptly. Externally, the FAO will reconcile with the COD system by the 10th of each month, comparing all disbursements, adjustments, and refunds to the balances reported in COD. A copy of the completed monthly reconciliation will be forwarded to Accounts Receivable as official documentation. Name of Contact Person: Mark Duarte, Director, Financial Aid and Triton One Stop Office Proposed Completion date: Ongoing

Finding NO. 2024-002 Special Tests and Provisions – Disbursements to or on Behalf of Students (Credit Balances) View of the University of Guam and Corrective Action Plan: To comply with federal regulations regarding the timely disbursement of Title IV credit balances, the University’s Business Office established a payment log in October 2024 to monitor and document all related transactions. Furthermore, to ensure ongoing compliance, the University will create a Standard Operating Procedure to be distributed among the Business Office staff. Name of Contact Person: Abigail Martin, Comptroller Proposed Completion date: September 30, 2025

Action taken in response to finding: Admissions training manuals have been updated to ensure that the date the student first indicated a desire to withdraw from a course is used as the date of withdrawal rather than the date that the withdrawal was processed in Colleague. Admissions staff members have been trained on the updated procedure for processing student course withdrawals. The Office of Institutional Research has reviewed and updated the procedures used to generate reports sent to National Student Clearinghouse. IR staff members will ensure that the last date of attendance is reported for student course withdrawals. The office of Institutional Research has contacted National Student Clearinghouse for guidance on the enrollment reports needed to ensure that student enrollment is reported to NSLDS accurately and timely. An additional enrollment report will now be sent to National Student Clearinghouse for reporting graduated students. This will ensure that students that have graduated are reported as no longer enrolled within the required reporting timeframe.

Action taken in response to finding: As a result of the 2023 audit, which concluded in May of 2024, adjustments were made to reflect a five day fall break for Fall 2024. R2T4 calculations for Fall 2024 have been reviewed and the use of a five-day break for the term has been verified. The Fall 2025 term has already been built in Colleague to reflect a five day fall break. The Fall 2023 term was built in Colleague by the previous Director of Financial Aid. The current Director of Financial Aid has recognized a five-day break when building the fall terms in Colleague and will continue this practice for future terms. In following our recently updated R2T4 process, all Financial Aid staff members have been trained and are able to perform R2T4 calculations. R2T4 calculations for the 2024-2025 academic year have been performed by Financial Aid staff and have been reviewed for accuracy and approved by the Director of Financial Aid.

Finding #2024-001 – Significant Deficiency and Other Noncompliance. Applicable federal program: U. S. Department of Education, Student Financial Assistance Programs Cluster, Assistance Listing #84.063, Federal Pell Grant Program, Assistance Listing #84.268, Federal Direct Student Loans, Contracts #003556 and G03556, Contract years: 05/05/21 – 12/31/26. Recommendation: Emphasize the importance of accurately reporting enrollment status. Planned corrective action: Management agrees with audit finding #2024-001. The Financial Aid Coordinator is responsible for reporting enrollment status changes, certifying enrollment every 60 days, and responding to NSLDS Roster files within 15 days, all through the NSLDSFAP website. To enhance the accuracy of these enrollment reports, the Institute is implementing a new double-check process. Henceforth, the Financial Aid Coordinator will print all enrollment status changes or enrollment report rosters prior to making any online updates or certifications. These printed reports will then be given to the Director of Operations for verification. Only after this verification will the Financial Aid Coordinator proceed with the necessary changes or certifications on the NSLDSFAP website. All printed reports will be retained by the Financial Aid Coordinator for documentation. Responsible officer: Cody Lopasky, President. Estimated completion date: June 1, 2025.

At the time that the last FISAP was completed, the Financial Aid office was severely understaffed. As a result, an oversight occurred in reporting dependent undergraduate students with Baccalaureate degrees. In thi instance, the correct information was retrieved, however it was reported incorrectly. Staffing in the Financial Aid office has been addressed by hiring an Advisor and Assistant Director. Moving forward, the Assitant Dean will continue to complete the FISAP. However, prior to submission, the application will be reviewed by both Assistant Directors of Financial Aid. Contact person(s) responsible for corrective action: Yvette McGhee, Assistant Dean of Financial Aid. Anticipated completion date: Immediate

2024-004 – Disbursing Funds (Significant Deficiency) Department of Education, SFA Cluster, Special Tests and Provisions Criteria: Except for paying a student under the Federal Work Study program or unless 34 CFR 685.303(d)(4)(i) applies, an institution must disburse during the current payment period the amount of Title IV, HEA program funds that a student enrolled at the institution is eligible to receive for that payment period. (34 CFR 668.164 (b)(1). Condition: From a population of 679 students that received the Pell grant, we tested 24 students and noted that two students did not receive the Pell awards for which they were eligible, and one student received an incorrect Pell award. Cause: Controls to ensure accurate disbursements to students are not functioning properly. Effect: Two students did not receive Pell awards they were eligible for during the payment period and one student received more Pell funds than they were entitled to. Recommendation: We recommend that procedures are put in place to ensure timely and accurate payment of Title VI awards. Action Taken: Shortages in staffing did not allow for double checking student enrollment post census. To correct this situation, we have added an additional counselor. We are working with a consultant to automate manual processes to free up more counselor time. Responsible Party and contact information: Daisy Tabachow, Director of Financial Aid. Expected Date of Correction: Beginning with the summer 2025 trimester and ending at the end of the fiscal year.

2024-003 – Incorrect Calculation of Title IV Refunds (Significant Deficiency) Department of Education, SFA Cluster, Special Tests and Provisions Criteria: The total number of calendar days in a payment period or period of enrollment includes all days within the period that a student was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period (34 CFR Section 668.22(f)(2)(i)). For a student that ceases attendance at an institution that is not required to take attendance, the student’s withdrawal date is the date that the student provided official notification to the institution, in writing or really, of his or her intent to withdraw (CFR Section 668.22(c)(1)(ii)). Condition: From a population of 130 students that officially or unofficially withdrew during the term, we tested 15 students and noted that four students required refund calculations. From these calculations we noted the following: Spring break of nine days was deducted incorrectly as seven days instead of nine for the three students who withdrew during spring semester. One student’s date of withdrawal was incorrect on the refund calculation. Cause: Controls to ensure proper calculation of Title IV refunds did not function as related to the conditions listed above: The University’s spring break was for the period of February 24, 2024 through March 3, 2024, a nine consecutive calendar day period. However, the University did not include the first two weekend days and calculated the break as seven days instead of nine. Due to this error, the correct number of days for the break was not deducted from the total number of calendar days properly for purposes of calculating refunds. One student’s withdrawal date was entered incorrectly in the R2T4 calculation. Effect: Refunds were calculated incorrectly for three of the four students that required refund calculations resulting in an incorrect amount of funds returned to the student and the Department of Education. Recommendation: We recommend procedures are put in place to ensure accuracy of R2T4 calculations. Action Taken: The Director of Financial Aid as well as the Data Analyst who is responsible for calculating the Return of Title 4 refunds have retaken the training module on calculating R2T4’s and counting days. This process was done manually allowing for marginal errors. Currently we have moved the process to be calculated automatically within our financial aid system which will reduce the margin of errors immensely and dates would be calculated correctly. This too will be affected by the revision of the new attendance policy. Responsible Party and contact information: Valerie Souza, FA Business Systems Analyst and Daisy Tabachow, Director of Financial Aid. Expected Date of Correction: The process has been instituted and has gone into effect immediately.

2024-002 – Return of Title IV Funds (Significant Deficiency) Department of Education, SFA Cluster, Special Tests and Provisions Criteria: Return of Title IV funds are required to be deposited or transferred into the SFA account or electronic fund transfers initiated to the department of Education as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew in accordance with 34 CFR Section 668.173(b). Condition: From a population of 130 students that officially or unofficially withdrew during the term, we tested 15 students and noted that four students required refund calculations. Funds were returned more than 45 days after the date of determination for all students that required refunds. Cause: Controls are not functioning properly to ensure timely return. Effect: Funds were not timely returned to students or the Department of Education as required. Recommendation: We recommend procedures are put in place to ensure R2T4 calculations are performed timely following the University’s date of determination.Action Taken: Due to a significant change/shortage in staff some R2T4’s were not calculated in a timely manner, however we are currently running the report biweekly avoiding delays in the return of Title IV funds. Reminders are placed on calendars. Attendance policy is undergoing a revision to allow for more consistent totals when calculating the number of days. In addition the process has been automated in Financial Aid software so it will no longer be a manual calculation. Responsible Party and contact information: Lynda Swanson, Asst. Director of Financial Aid, Valerie Souza, FA Business Systems Analyst, and Daisy Tabachow, Director of Financial Aid. Expected Date of Correction: Trimester reconciliation-completion date-end of fiscal year.

Improve budget monitoring and reporting accuracy for grant funds. Ensure district records reflect amounts available for expenditure. Effective July 1, 2025, the district will be implementing LINQ, a web-based financial and human resources management system.

Corrective Actions: The Financial Aid Supervisor will check the monthly V4/V5 report to ensure timely submission. However, according to the May 23, 2024, Electronic Announcement (GENERAL-24-63), the V4/V5 reporting deadlines are impacted by 2024-25 FAFSA processing and FAFSA Partner Portal (FPP) functionality delays. Personnel Responsible for Implementation: Ludwig Perez, Financial Aid Manager, Los Angeles Harbor College Marisol Velazquez, Financial Aid Manager, Los Angeles Technical Trade College Vernon Bridges, Financial Aid Manager, Los Angeles Valley College Expected Date of Implementation: When FPP becomes available

Corrective Actions: A. Perform Timely Access Revocation and Strengthen User Access Reviews ‐ The District implemented a new automated solution to terminate SSO and PS SIS access. This was implemented October 2024. ‐ The District’s plan is, upon implementation of the automated solution to deprovision SSO and PS SIS access, our team is planning on performing annual user access for SSO and PS SIS reviews beginning Q1 2025. The District is also implementing Pathlock that will introduce user access reviews. ‐ For SAP access revocation the SAP Team is looking into options to deprovision users and audit user access through internal or third-party tools. The District anticipates selection of the tools by June 30, 2025. Upon implementation of the selected SAP tools the District will perform periodic access reviews for regular users. Personnel responsible for Implementation: Carmen V. Lidz, Vice Chancellor & Chief Information Office Expected Date of Implementation: June 30, 2025 B. Maintain and Review Logs of Users' Activity for both SAP and PS SIS ‐ Upon implementation of Pathlock, the District will perform periodic access reviews for regular users. ‐ Upon implementation of the selected SAP tools, the District will perform periodic access reviews for regular users. Personnel responsible for Implementation: Carmen V. Lidz, Vice Chancellor & Chief Information Office Expected Date of Implementation: June 30, 2025 C. Implement Data-at-Rest encryption for SAP and PS SIS Servers ‐ The District is in the process of upgrading PS SIS PeopleTools after which we will determine the most expedient path to implementing database encryption. The target completion for the PS SIS database encryption is Q3 of 2025 ‐ The District is currently evaluating the feasibility of adding the encryption of the SAP database to the HANA upgrade project. If the District determines that it’s not feasible, we will engage a third party to encrypt the SAP database. The target completion for the SAP database encryption is Q3 of 2025. Personnel responsible for Implementation: Carmen V. Lidz, Vice Chancellor & Chief Information Office Expected Date of Implementation: Q3 of 2025

Corrective Actions: A. Incorrect Calculation of Return of Title IV Funds Los Angeles Harbor College The District’s Central Financial Aid Unit (CFAU) R2T4 Unit centralized the R2T4 process at all nine colleges during the 2023-24 aid year. CFAU is currently processing R2T4 calculations for Los Angeles Harbor College. Personnel Responsible for Implementation: Ludwig Perez, Financial Aid Manager, Los Angeles Harbor College Steve Giorgi, Financial Aid Manager, Central Financial Aid Unit Expected Date of Implementation: Already Implemented B. Distance Education (DE) Courses – Implementation of Formal Process to Determine Accuracy of Student Withdrawal Date – Partial Implementation of Prior Year Corrective Action Plan (CAP) EPIE will share the most recent annual internal audit review with each college team and require each college to develop a corrective action plan. EPIE will submit a request to add a pop-up message to the faculty roster directly tied to completion of the mandatory exclusion roster (census roster), supplemental roster, and active enrollment roster. The pop-up message will continue to be displayed until the faculty member successfully submits their roster. EPIE will work with the distance education (DE) faculty coordinators to create professional development training geared toward using Canvas to determine an online student’s last date of academic engagement and will offer the training annually. Additionally, EPIE will conduct training for administrators on the use of queries to monitor pending rosters. Personnel Responsible for Implementation: Nicole Albo-Lopez, Vice Chancellor, EPIE Expected Date of Implementation: June 30, 2025

Corrective Action: The District’s Educational Programs & Institutional Effectiveness (EPIE) and Information Technology (IT) divisions will analyze the current programming and test cases and develop programming to correct the misalignment of the student status effective date reported to the NSC and student status date in PeopleSoft. EPIE will continue to monitor post-submission errors and warning reports to review the effectiveness of the programming change. Personnel Responsible for Implementation: Maury Pearl, Associate Vice Chancellor Andrew Alvarez, IT Business Analyst Stan Levin, Senior Research Analyst Expected Date of Implementation: March 31, 2025

Audit Firm: RSM US LLP 30 S Wacker Drive, Suite 3300 Chicago, IL 60606 Audit Period: 1/1/2024 – 12/31/2024 Comments on Findings and Recommendations: Finding 2024-002 – Eligibility - Pell Finding: Herzing University did not properly award Pell funding to an eligible student in the Spring 2024 semester. Condition: A student was eligible to receive Pell funding but did not receive Pell funds due to an employee error. For one out of 40 students tested for eligibility, we noted 1 student (2.5%) who was eligible to receive Pell funding but did not receive Pell funds due to an employee error. Action Taken: The identified student withdrew from the University on May 8, 2023. The student’s 2023-24 Pell award was cancelled during the required R2T4 process that was completed on May 23, 2023. The 2023-24 Pell award for the Spring 2024 semester was not manually reinstated upon the student’s return to an Active status on June 28, 2023. The employee who was responsible for updating the student’s financial aid package upon the student’s return to an Active status erroneously neglected to reinstate the 2023-24 Pell award for the Spring 2024 semester. This finding is attributed to human error. In April 2025, Herzing University created an internal compliance checkpoint for Pell awarding. This checkpoint will identify any students with a Pell eligible SAI for the Federal Award year that do not have Pell packaged for the semester. This checkpoint was completed for the Spring 2025 semester on April 7, 2025, and will be completed each semester going forward. Any affected students identified during the completion of this semester-based checkpoint will have their financial aid package revised to include Pell funding for the applicable semester, prior to the end of the semester. Herzing University’s Policy Manual was updated in April 2025 to reflect the addition of the Pell Awarding compliance checkpoint. For the identified student, Herzing University has provided a tuition waiver for the amount of the Pell funds that the student was eligible for and should have received for the Spring 2024 semester. The required corrective action for Finding 2024-002 listed in the SFA audit for the period 1/1/2024 – 12/31/2024 was completed on 5/7/2025. The person responsible for completion of the corrective action was Kevin McShane, Vice President of Financial Aid & Compliance. ____________________________________ _______________________ Kevin McShane Date Vice President of Financial Aid & Compliance Herzing University 275 W. Wisconsin Ave., Ste. 210, Milwaukee, WI 53203 Email Address: kmcshane@herzing.edu

Audit Firm: RSM US LLP 30 S Wacker Drive, Suite 3300 Chicago, IL 60606 Audit Period: 1/1/2024 – 12/31/2024 Comments on Findings and Recommendations: Finding 2024-001 – Eligibility - SEOG Finding: Herzing University did not properly award SEOG funding to an eligible student in the Fall 2024 semester. Condition: A student was eligible to receive SEOG funding but did not receive SEOG funds due to an employee error. For one out of 40 students tested for eligibility, we noted 1 student (2.5%) who was eligible to receive SEOG funding but did not receive SEOG funds due to an employee error. Action Taken: On May 1, 2024, a Financial Aid Advisor manually cancelled the identified student’s 2024-25 SEOG award in Regent (Herzing University’s Financial Aid Management Software), with a notation that the student had an ineligible Student Aid Index (SAI). The student had an SAI of -117 on their 2024-25 ISIR, and in accordance with Herzing University’s FSEOG policy were eligible for 2024-25 SEOG in the Fall 2024 semester. The award was incorrectly manually canceled by the advisor because of human error. In April 2025, Herzing University created an internal compliance checkpoint for FSEOG awarding. This checkpoint will serve as a safety net to identify any students who have a Pell award for the Federal Award year, have an SAI that is FSEOG eligible according to Herzing University’s FSEOG policy, and do not correctly have FSEOG packaged for the semester. Any affected students identified during the completion of this semester-based checkpoint will have their financial aid package reviewed and if necessary revised to include FSEOG funding for the applicable semester, prior to the end of the semester. This checkpoint was completed for the Spring 2025 semester on April 4, 2025, and will be completed each semester going forward. Herzing University’s Policy Manual was updated in April 2025 to reflect the addition of the FSEOG Awarding compliance checkpoint. For the identified student, Herzing University has provided a tuition waiver for the amount of the FSEOG funds that the student was eligible for and should have received for the Fall 2024 semester. The required corrective action for Finding 2024-001 listed in the SFA audit for the period 1/1/2024 – 12/31/2024 was completed on 5/7/2025. The person responsible for completion of the corrective action was Kevin McShane, Vice President of Financial Aid & Compliance. ____________________________________ _______________________ Kevin McShane Date Vice President of Financial Aid & Compliance Herzing University 275 W. Wisconsin Ave., Ste. 210, Milwaukee, WI 53203 Email Address: kmcshane@herzing.edu

Finding 2024-002: Common Origination and Disbursement (COD) Reporting Cluster Name: Student Financial Assistance Federal Awarding Agency: Department of Education Award Name: Federal Pell Grant Program, Federal Direct Loans Award Number: Various Award Year: 10/1/2023-9/30/2024 Assistance Listing Title: Federal Pell Grant Program, Federal Direct Student Loans Assistance Listing Number: 84.063, 84.268 Pass-Through Entities: Not applicable As described in finding 2024-002, 1 of the 25 selections was not reported to the COD system within 15 calendar days of the disbursement to the student. The noted disbursement was reported 5 calendar days late. Caltech confirmed it had additional instances of late reporting beyond the audit selection. To address this finding, Caltech created a Disbursement Checklist to ensure that all steps in the process are followed, including generating common record files of disbursement information and transmitting those files to COD the same day as the funds are disbursed to the student accounts. The checklist was created in May 2025. Malina Chang, Director, Financial Aid Office, is responsible for this corrective action plan. Caltech also performs Pell monthly reconciliations to capture discrepancies between internal information and that which is reported by COD. Any discrepancies are investigated via this monthly reconciliation process, and errors are corrected. In addition, Caltech requests Pell funds from the Department of Education on a quarterly basis (quarterly EDCAPS draws), significantly reducing the risk of the Institute needing to return funds.

Finding 2024-001: E-Sign Act Cluster Name: Student Financial Assistance Federal Awarding Agency: Department of Education Award Name: Federal Supplemental Educational Opportunity Grant, Federal Work Study Program, Federal Pell Grant Program, Federal Perkins Loan, Federal Direct Loans Award Number: Various Award Year: 10/1/2023-9/30/2024 Assistance Listing Title: Federal Supplemental Educational Opportunity Grants, Federal Work-Study Program, Federal Pell Grant Program, Federal Perkins Loan Program, Federal Direct Student Loans Assistance Listing Number: 84.007, 84.033, 84.063, 84.038, 84.268 Pass-Through Entities: Not applicable As described in finding 2024-001, in examining 25 student records, a statement prompting voluntarily consent to participate in electronic transactions was not included in the list of terms and conditions. To address this finding, in March 2025, Caltech revised the Financial Aid Terms and Conditions, found under the student portal, which students must agree to before accepting their financial aid, to include language about voluntarily consenting to participate in electronic transactions. Malina Chang, Director, Financial Aid Office, is responsible for this corrective action plan.

2024-002 • Material Weakness in Internal Control over Compliance Condition: During our eligibility assessment, we examined 40 files from Community Umbrella Agency 3 (CUA) foster care children to ensure they contained required documents by the City of Philadelphia and Pennsylvania's Department of Human Services (DHS). Our review found missing documents, time gaps between submissions, or untimely paperwork, including the following: (a) 29 CUA Safety Assessments, (b) 30 CUA Safety Plans, (c) 7 CUA PA Model Risk Assessments, (d) 3 CUA Documented Client Visits (Structure Case Notes), (e) FAST Family Advocacy Forms, (f) 17 Life Skills Assessment/ Biopsychosocial Evaluation/ IEP or Ages & Stages Questionnaire (ASQ), (g) 11 School Aged Report Cards, (h) 6 CUA Authorization to Release Information, (i) 9 CUA Immunizations, (j) 3 DHS Court Order Sheets, (k) 14 Child’s Photo, (l) 10 Initial CUA Single Case Plan, (m) 7 Monthly Updates to CUA Single Case Plan, (n) 17 Initial CUA Case Service Conference Summary Report, and (o) 16 Six Month Ongoing CUA Services Conference Summary Report. Furthermore, each child's file needed to contain specific documents from the DHS, which had to be supplied by the department or shown evidence of request by the CUA. Missing documents consisted of: (a) 34 DHS Service Authorization Forms, (b) 21 DHS CUA Provider Referral Forms, and (c) 30 DHS CUA In-Home Services Referral Forms. Recommendation: We recommend that management continue to develop policies and procedures in order to properly include all pertinent documentation within each client file as required by the City of Philadelphia, Department of Human Services. In addition, we recommend that program leadership and/or quality control department performs periodic audits of the client files to ensure all required documentation is included. Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. FINDINGS – FEDERAL AWARD PROGRAM AUDITS (CONTINUED) Action taken in response to finding: 1. Hiring of Chief Compliance Officer to oversee Concilio Quality Assurance and Compliance process 2. Staffing of Quality Assurance department 3. Monthly review of client files for accuracy and completeness 4. Additional training of staff to review audit findings and implement corrective action Name of the contact person responsible for corrective action: Albert Essilfie, Chief Financial Officer albert.essilfie@elconcilio.net (215) 627-3100 Planned completion date for corrective action plan: June 30, 2025

Management’s Response: The University has undertaken several initiatives to enhance compliance and accuracy: (1) Collaboration with External Financial Aid Experts a. In 2025, the University engaged an external financial aid contractor to optimize system usage within its database, ensuring more accurate and timely reporting. (2) Appointment of a New Financial Aid Director a. A new Financial Aid Director has been hired, commencing their role on March 1, 2025. This leadership is expected to prioritize and address the issues identified in the audit finding. (3) Process Enhancement and Staff Training a. A comprehensive assessment of current enrollment reporting procedures has been conducted to identify and rectify gaps. b. Staff members in the Registrar’s Office have undergone targeted training to ensure accurate and timely updates to the National Student Loan Data System (NSLDS). (4) Policy and Procedure Development a. New policies and procedures have been established to verify that correct effective dates and status changes are reported to NSLDS within the required timeframes. b. Regular audits and reviews are now in place to ensure ongoing compliance and to promptly address any discrepancies. These initiatives demonstrate the University’s commitment to maintaining accurate student enrollment records and ensuring compliance with federal regulations, thereby safeguarding the interests of its students and the institution.

1. Strengthening Timely Submission of Enrollment Reporting Rosters  The Institution will implement a structured tracking system to monitor all incoming enrollment roster files and ensure timely response within the required 15-day period.  A compliance calendar with automated reminders will be established to notify financial aid staff of upcoming roster submission deadlines and the 10-day correction requirement. 2. Designating Accountability & Oversight  A dedicated staff member within the financial aid office will be assigned sole responsibility for monitoring, reviewing, and submitting NSLDS enrollment rosters.  A dual-verification process will be introduced, where a second staff member will confirm that roster files are submitted on time and corrections are made within the 10-day resubmission window. 3. Enhancing Training & Compliance Awareness  Financial aid personnel will undergo training on NSLDS enrollment reporting procedures, including: a) The importance of timely enrollment certification and reporting compliance. b) How to efficiently process and submit enrollment roster files via SAIG and the NSLDS website. c) Best practices for reviewing, correcting, and resubmitting enrollment records within the required 10-day correction window.  Staff will participate in annual refresher training to stay updated on any regulatory changes and process improvements. 4. Internal Audits & Process Improvements  The Institution will conduct quarterly internal audits of NSLDS enrollment reporting to ensure compliance with submission timelines.  A compliance checklist will be developed to ensure that each roster file is reviewed, corrected, and resubmitted within the 10-day requirement.  A monthly reconciliation process will be introduced to cross-check institutional records against NSLDS enrollment reporting to identify and correct discrepancies proactively. Personnel Responsible for Implementation: Danielle Skinner Position of Responsible Personnel: President Expected Date of Implementation: Immediate

1. Corrections to NSLDS Program-Level and Campus-Level Data Reporting: The Institution has conducted a full review of its NSLDS records and is correcting all program-level data discrepancies, including the published program length for the Machine Tool Technology/Machinist program. We are updating the "Weeks in Title IV Academic Year" field to ensure that NSLDS correctly calculates program length. A dedicated NSLDS Compliance Checklist will be implemented to ensure that all program-level and campus-level data is aligned with institutional records before submission. 2. Strengthening Accuracy in Campus-Level Enrollment Reporting: A mandatory second-level review process will be implemented for all graduation and withdrawal status updates to prevent misreported enrollment dates or statuses. NSLDS data will be cross-checked monthly against the Institution’s internal student records to proactively detect and correct any discrepancies. 3. Improving Timeliness in Certification of Enrollment Status: The Institution will implement a structured 60-day certification schedule to ensure that all enrollment changes are reported to NSLDS within federal timeframes. A compliance tracking system will be introduced to flag students requiring enrollment status updates, allowing for proactive monitoring and timely submission 4. Staff Training and Process Improvement: The Institution will train financial aid and student records personnel on NSLDS reporting standards, including: a) Accurate program length calculations and Title IV academic year reporting. b) Timely certification of enrollment changes to remain within the 60-day requirement. c) Common reporting errors and best practices for NSLDS data management. Annual refresher training sessions will be held to ensure staff remain up to date on NSLDS reporting regulations and procedural improvements. 5. Internal Compliance Monitoring & Quality Assurance: A quarterly audit of NSLDS reporting will be conducted by a designated compliance officer to identify and correct discrepancies before regulatory deadlines. The Institution will establish internal controls and reporting checklists to ensure consistency, accuracy, and compliance with federal requirements. Personnel Responsible for Implementation: Danielle Skinner Position of Responsible Personnel: President Expected Date of Implementation: Immediate