Corrective Action Plans

Management will provide additional resources to the Financial Aid department to include training and assistance and will implement verification procedures to ensure that amounts awarded are accurate.

Finding Number: 2025-002 - Inadequate Internal Control over Return of Title IV Funds Condition: Western Illinois University (University) did not have adequate procedures in place to complete accurate and timely return of Title IV funds for all students within the required time period. Planned Corrective Action: From University Response: The University is committed to developing a comprehensive plan to ensure compliance with return of Title IV funds policies and procedures. From last year's CAP: The University has streamlined the process of R2T4 to prevent delays in processing. This enhanced process creates a countdown report to prioritize R2T4 calculation when staff resources as strained. Contact person responsible for corrective action: Roberta Smith Anticipated Completion Date: 06/30/2026

Finding Number: 2025-001 - Inadequate Internal Control over Student Enrollment Reporting Condition: Western Illinois University (University) did not have adequate procedures in place to complete accurate enrollment reporting for all students. Planned Corrective Action: The University is implementing enhanced internal controls to ensure enrollment status changes and degree confirmations are being appropriately submitted and reported. Contact person responsible for corrective action: Roberta Smith/Sarah Lawson Anticipated Completion Date: 06/30/2027

Corrective Action Plan for the Year Ending June 30, 2025 Finding 2025-001: Significant Deficiency – Lack of Documented Controls – Cash Management Program: Student Financial Assistance Cluster Assistance Listing Number: various Federal Agency: U.S. Department of Education Federal Award Identification Number: various Federal Award Year: June 30, 2025 Repeat Finding: 2024-001 Criteria: The Uniform Guidance requires recipients of federal awards to administer its federal programs with an adequate system of internal controls over applicable compliance requirements. Condition/Context: For six of eight selected G5/G6 Title IV drawdown transactions, there was no documented internal controls in place over cash management drawdowns. Despite the lack of documented controls over the cash drawdowns, there were no compliance exceptions noted. The sample was not a statistically valid sample. Cause: The College indicated the control of review was more informal/verbal and although had started documenting via email during the year, the documentation was not maintained. Questioned Costs: Not applicable Effect: The College could drawdown an incorrect amount although compensation controls/reconciliations would likely catch the error. Recommendation: The College should document controls in place to ensure cash drawdowns are complete and accurate. This should include a review by someone other than the preparer prior to the drawdown being requested in G5/G6. Action Taken: Management concurs with the finding and has taken the appropriate actions to remediate the significant deficiency. The team has made improvements to become more formal by implementing written communication among all members involved in the process. Each member of their respective roles are communicating through email presenting the step by step process of the review and approval before the drawdown of cash from G5/G6. Name(s) of Contact Person Responsible for Corrective Action: Kevin Brand, Director of Operations and Systems for Financial Aid; Laurie Klizos, Director of Student Accounts; Seong Nevins, Controller. Anticipated Completion Date: June 30, 2026 Signed by Charlie Faas and Jim Brooks

Cash Management - Excess Cash on Hand Auditor Description of Condition and Effect. During our testing of cash management for campus-based aid, we noted one instance out of six drawdowns tested, that the College drew down Federal Work Study funds that were not needed for immediate disbursement, and was not returned timely. As a result of this condition, the College was not in compliance with the Uniform Guidance cash management principles. Auditor Recommendation. We recommend the College strengthen its cash‑management controls to ensure Title IV drawdowns are limited to immediate disbursement needs, reconciled promptly, and any excess cash is identified and returned within required regulatory timeframes. Corrective Action. The College is enhancing its federal cash management practices by limiting drawdowns for campus‑based programs, including Federal Work‑Study, to immediate disbursement needs. Drawdowns are now based on a documented three‑day cash needs forecast to ensure compliance with federal requirements. A standardized drawdown checklist requires staff to reconcile all G5 activity to the general ledger and subsidiary ledgers on the same day funds are drawn or disbursed. Any excess cash identified through this process is returned to the Department of Education via G5 within one business day. Monthly management reviews monitor drawdown timing, cash balances, and reconciliation trends to ensure continued compliance. Staff have been retrained on updated cash management procedures, and quarterly monitoring reports are produced and retained as evidence of ongoing compliance with federal cash management standards. Responsible Person. Jennifer Stimson, Director of Financial Aid with support from Scott Kemmer-Slater, Director of Accounting. Anticipated Completion Date. June 30, 2026

Student Credit Balance Exceeding Fourteen Days Auditor Description of Condition and Effect. During our testing, we identified one instance in which a student’s credit balance remained outstanding beyond the required 14‑day timeframe. As a result of this condition, the College was not in compliance with the Uniform Guidance requirements governing the timely disbursement of student credit balances. Auditor Recommendation. We recommend the College implement procedures to ensure all voided refunds are reviewed and resolved within the fourteen day period to ensure there are no credit balances that are unaddressed. Corrective Action. The College is strengthening its procedures to ensure student credit balances are processed, refunded, or returned within the federally required 14‑day timeframe. When a student requests a stop payment, hold, or void, the student must now email both the Business Office and Financial Aid Office from their official MCC student email account. Requests must include the type of action needed and the reason for it. The Directors of Accounting and Financial Aid, or designated authorized personnel, review and approve each request before any action is taken. The Business Office then issues the stop payment, hold, or void in accordance with internal procedures, while Financial Aid returns funds to the appropriate agency when applicable. For internal staff‑initiated stop or void actions, employees must email the Directors with justification explaining why the request is being initiated by staff rather than the student. Both offices collaborate to determine appropriate action, ensure the disbursement is adjusted, coordinate the timing of any required return of funds, and communicate updates to the student. These procedures ensure all credit balance transactions are processed within the 14‑day limit and are documented consistently to maintain federal compliance. Responsible Person. Scott Kemmer-Slater, Director of Accounting and Jennifer Simson, Director of Financial Aid, jointly. Anticipated Completion Date. June 30, 2026

Cost of Attendance Calculation Inputs Auditor Description of Condition and Effect. During our testing of the College’s cost of attendance (COA) calculations, we identified inconsistencies between the COA component amounts recorded in the system and the amounts documented on the College’s COA calculation sheet. For instance, the College's tuition component was supposed to be based on credit intensity, but instead was being calculated using the student's enrollment status (e.g., full-time, half-time, etc.). Additionally, the College included direct loan fees in every students COA, even if they were not a direct loan receiving student. As a result, COA amounts used in awarding Title IV aid were being understated, preventing some students from potentially receiving additional aid they were entitled to. Auditor Recommendation. We recommend that the College establish and adhere to review procedures to ensure that all inputs used in the COA calculation are accurate, complete, and consistent with approved documentation. Corrective Action. Management is actively enhancing the College’s Cost of Attendance (COA) processes to ensure all inputs—particularly tuition, loan fees, and enrollment‑related components—accurately reflect approved documentation and federal requirements. The Financial Aid Office has reconfigured PowerFAIDS to calculate tuition based on credit intensity rather than enrollment status, and loan fees are now included only for students who actually borrow federal loans. An annual COA governance and approval process is now in place, requiring review and authorization by the Vice President of Finance and Administration before COA figures are built into the system. All COA entries in PowerFAIDS undergo an independent verification against the approved COA worksheet as part of a “build‑to‑proof” procedure. Spot checks are conducted at the start of each term to ensure accuracy across enrollment levels, and all mid‑year changes are documented using a formal change‑control log. Responsible Person. Jennifer Stimson, Director of Financial Aid Anticipated Completion Date. March 31, 2026

Fiscal Operations Report and Application to Participate (FISAP) Reporting Auditor Description of Condition and Effect. It was noted during our testing of the FISAP that the College did not have support for one of the eight key line items (information on eligible aid applicants) identified in the compliance supplement as critical information. As a result, the College is not in compliance with the Department of Education requirements that state the FISAP must be accurately reporting information. Auditor Recommendation. We recommend the College review their policies and procedures surrounding FISAP reporting. Corrective Action. The College is improving its documentation and retention processes to ensure all information used in preparing the annual FISAP report is fully supported and available for review. Moving forward, all data underlying the eight key line items identified in the compliance supplement will be saved, documented, and stored in a consistent and accessible manner. Information obtained from other departments will be retained in its original format, and any data extracted from PowerFAIDS or related systems will be saved at the time of report preparation. By implementing these documentation and retention procedures as standard operating practice, the College ensures FISAP submissions are accurate, verifiable, and compliant with federal audit requirements. Responsible Person. Jennifer Stimson, Director of Financial Aid Anticipated Completion Date. June 30, 2026

Ineligible Student Received Title IV Funding Auditor Description of Condition and Effect. During our testing, we noted that a student successfully appealed their academic dismissal in the Summer 2022–2023 semester. The student did not receive Title IV funding during that term and subsequently failed both attempted courses. Despite the lack of demonstrated academic improvement following the appeal, the student was awarded Title IV funding in the Spring 2024–2025 semester based on the appeal granted during the 2022–2023 academic year. As a result of this condition, one student received Title IV funding that who was not eligible based on the criteria outlined in the College's satisfactory academic policy (SAP). Auditor Recommendation. We recommend the College implement a formal review process to verify that students who were previously dismissed and granted an appeal in a prior academic year have demonstrated the required academic improvement before receiving subsequent Title IV funding, or alternatively, obtain a new appeal determination. Corrective Action. Management acknowledges this finding and is implementing strengthened Satisfactory Academic Progress (SAP) review procedures to ensure students who previously appealed an academic dismissal are properly evaluated before receiving Title IV funding. The Financial Aid Office is now working closely with the Registrar to ensure both Title‑IV and non‑Title‑IV students undergo appropriate SAP monitoring. Information Technology is developing a report that identifies students by financial‑aid track status, allowing Financial Aid to review aid‑receiving students while the Registrar evaluates all others. Students who require SAP follow‑up are contacted by the appropriate office, and SAP appeal forms are reviewed under updated criteria to ensure students demonstrate academic improvement before additional aid is awarded. These steps ensure the College remains compliant with federal SAP requirements and prevents ineligible students from receiving Title IV funds. Responsible Person. Jennifer Stimson, Director of Financial Aid Anticipated Completion Date. June 30, 2026

Finding 2025-003 Finding Summary: Some discrepancies were noted between the District and NSLDS. One student's data was not updated within the allowable time period. Responsible Individuals: Melissa Thornton, Financial Aid Manager Corrective Action Plan: We have worked within the department to ensure proper reporting on the financial aid systems. Anticipated Completion Date: July 1, 2026

The Registrar and Student Financial Aid Director will both ensure that any students that have updated their status are updated on a weekly basis. Registrar’s office will log into NSLDS to upload the file, and the CFO, Registrar, and Student Financial Aid Director will monitor updates monthly.

Student Financial Aid Cluster: Federal Supplemental Educational Opportunity Grant – Assistance Listing No. 84.007 Federal Work Study Program – Assistance Listing No. 84.033 Federal Pell Grant Program – Assistance Listing No. 84.063 Federal Direct Student Loans – Assistance Listing No. 84.268 Federal TEACH Grant Program – Assistance Listing No. 84.379 Recommendation: We recommend the University review current processes for reporting to NSLDS and implement additional procedures to ensure submissions are reported timely and accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: This is a repeat finding that was first presented to the University in conjunction with the release of the 2022 audit report in November 2023. While procedures had previously been implemented to address this issue, additional measures are being taken to ensure full compliance. The University will implement additional udates to its NSLDS reporting processes to ensure needed submissions are reported timely and accurately. Respective staff will receive additional training to ensure proper reporting to NSLDS occurs. Name(s) of the contact person(s) responsible for corrective action: Ms. Nacasaw Coppage, Director of Office of Financial Aid; Mr. Heath Burge, Assistant Vice President for Strategic Enrollment and Advising Services; and Mrs. Jeanese Outlaw-Gunter, University Registrar Planned completion date for corrective action plan: April 2026

Student Financial Aid Cluster: Federal Pell Grant Program – Assistance Listing No. 84.063 Federal Direct Student Loans – Assistance Listing No. 84.268 Recommendation: We recommend the University review its current procedures for Title IV funds and implement additional procedures to ensure refunds are returned timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University is evaluating its current Title IV funds procedures and implementing additional procedures to ensure timely return of refunds. This includes assigning additional staff to manage this process. Also, relevant staff have been reminded of the need to notify Financial Aid of student withdrawals timely. Name(s) of the contact person(s) responsible for corrective action: Ms. Nacasaw Coppage, Director of Office of Financial Aid Planned completion date for corrective action plan: March 2026

Federal Program: U.S. Department of Education Student Financial Assistance Cluster: Federal Direct Student Loans, Federal Assistance Listing 84.268 Criteria: The University must comply with 34 CFR 668.165(a). Condition: During our eligibility testing, 10 of 38 students who received Direct Loans were not notified of their disbursements timely by the University. Cause: The University did not have controls in place to ensure students were being notified of Direct Loan disbursements in a timely manner (within 30 days before or 30 days after crediting the students' account). Effect: The provisions of 34 CFR 668.165(a) were not followed and thus a total of 10 students were not notified of Direct Loan disbursements in a timely manner. Questioned Costs: There were no questioned costs associated with this finding. Recommendation: We recommend that the University update their internal controls related to Direct Loan disbursements and send required communications prior to crediting the students' accounts. Corrective Actions Taken or Planned: We agree with this finding and recommendation. The financial aid office has automated the process to send disbursement notifications. Disbursement notifications are sent the day after loans are posted to a student’s account. Responsible Parties: Daniel Donner, Director of Financial Aid Completion Date: November 05, 2025

Federal Program: U.S. Department of Education Student Financial Assistance Cluster: Federal Direct Student Loans, Federal Assistance Listing 84.268 Criteria: The University is required to comply with 36 CFR 685.309(b). Condition: During our testing of 40 students for NSLDS enrollment, we noted eight students' enrollment effective date was the commencement date instead of the last day of the term. One student's graduation status was not reported to the NSLDS and one student's graduation was not certified to the NSLDS within the 60-day requirement. Cause: The University did not have controls in place to ensure students' classification were being properly reported to the NSLDS or reported in a timely manner. Effect: There were ten student status changes that were either not reported, not reported accurately, or not reported within the required timeframe under federal regulations. The provisions of 34 CFR Section 685.309(b) were not followed and thus, students were subsequently not placed into loan repayment status in a timely manner. Questioned Costs: There were no questioned costs associated with this finding. Recommendation: We recommend that the University implement a control to ensure data is being reviewed for accuracy by the appropriate personnel before roster files are submitted to the NSLDS. In addition, we recommend that the University submit roster files on a regular basis. Corrective Actions Taken or Planned: We agree with this finding and recommendation. The Director of Institutional Research will report the last day of the term for NSLDS reporting. Responsible Parties: Margaret Sidle, Director of Institutional research Completion Date: March 4, 2026

Federal Program: U.S. Department of Education Student Financial Assistance Cluster: Federal Direct Student Loans, Federal Assistance Listing 84.268 Criteria: The University must comply with 34 CFR 668.22(a). Condition: During our testing of six official withdrawals, we noted one instance where the University incorrectly treated a student as withdrawn for Return of Title IV (R2T4) purposes. The student was enrolled in both modules for the Fall term, earned six credit hours in the first module and subsequently withdrew during the second module. The University reported the student as withdrawn to the National Student Loan Data System (NSLDS) and performed a R2T4 calculation using the total days of both modules in the denominator of the R2T4 calculation. However, since the student successfully completed six credit hours in the first module, which exceeds the coursework required for the University's definition of half time enrollment, the student should not have been classified as withdrawn nor had a R2T4 calculation performed. Upon further analysis from management, there were an additional five students that were enrolled in modules, earning half-time enrollment, who were reported as withdrawn to the NSLDS and a R2T4 calculation was erroneously completed for them. Cause: This error occurred due to inadequate internal controls over identifying withdrawal status for students enrolled in module courses, specifically related to assessing whether completed coursework met or exceeded the half-time enrollment threshold prior to performing an R2T4 calculation or reporting them as withdrawn to the NSLDS. Effect: The provisions of 34 CFR 668.22(a) were not followed and thus a total of six students had a R2T4 calculation erroneously performed. Six students were also erroneously reported as withdrawn to the NSLDS. Questioned Costs: There were no questioned costs associated with this finding Recommendation: We recommend that the University strengthen its internal controls related to R2T4 calculations by: (a) implementing a system control to evaluate whether or not completed module coursework meets the half-time threshold before classifying a student as withdrawn, (b) providing additional training to financial aid staff on withdrawal determinations and performing an R2T4 calculation for students enrolled in modules, and (c) performing a supervisory review of all R2T4 calculations related to module students. Corrective Actions Taken or Planned: We agree with this finding and recommendation. After further review of R2T4 rules for module programs, the University of Pikeville will no longer perform R2T4’s on any student that has met the Exemption rules per FSA handbook, Vol 5, Chapter 1, “R2T4 Withdrawal Exemptions”. Responsible Parties: Daniel Donner, Director of Financial Aid Completion Date: March 4, 2026

2025-003 Documentation of Review Recommendation: We recommend the University re-evaluate its procedures and review policies surrounding controls implemented for Title IV Aid. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: 1) The Office of Financial Aid will re-evaluate its current policies and procedures to clearly define internal control objectives and strengthen overall compliance. 2) The Office of Financial Aid has implemented – and will continue to maintain - a dual-review process (second-level review) for Return of Title IV Funds, federal award packaging, and the review of the FISAP report to ensure accuracy and regulatory compliance. 3) The Director and Assistant Director of Financial Aid will continue cross-training staff to promote operational continuity, reinforce internal controls, and maintain clear oversight of key processes. Name(s) of the contact person(s) responsible for corrective action: Vanesa Teran-Martinez, Jennifer Monroy Planned completion date for corrective action plan: June 30, 2026 If the Department of Education has questions regarding this schedule, please call Vanesa Teran-Martinez at 708-209-3338.

2025-002 National Student Loan Data System (NSLDS) Enrollment Reporting Recommendation: We recommend the University review and strengthen its reporting procedures to ensure that student statuses are accurately reported to NSLDS, as required by federal regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: 1) All enrollment reporting was submitted to the National Student Clearinghouse in a timely manner. The delay occurred during the National Student Clearinghouse’s processing and submission to NSLDS. 2) The Office of the Registrar will work with the Office of Financial Aid to learn more about NSLDS compliance requirements and gain a better understanding of their relationship with the National Student Clearinghouse. 3) The Office of the Registrar will work with the National Student Clearinghouse to confirm the submitted reporting schedule for academic year 2026 – 2027 complies with and meets their expectations and will adjust (if needed). 4) The Office of the Registrar will continue to work with the Enrollment Offices to remind them that students who are not enrolled (and not on leave of absence, graduated, and/or deceased) must be marked as withdrawn based on external reporting compliance requirements. 5) The Office of the Registrar continues to work with IT (Banner Team) to improve reporting to capture students who are not enrolled (and not on leave of absence, graduated, and/or deceased) to be marked as withdrawn to comply with the National Student Clearinghouse and NSLDS compliance reporting requirements. Name(s) of the contact person(s) responsible for corrective action: Ingrid Sorensen, Katarzyna Rodriguez Planned completion date for corrective action plan: June 30, 2026

2025-001 Pell Grant Under Award Recommendation: We recommend the University implement a review process that compares enrolled credits to Pell awards to ensure all students receive the correct Pell Grant amounts. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: 1) The Office of Financial Aid will continue to run monthly or bi-monthly enrollment reports for Pell Grant recipients to ensure awards are accurately determined based on enrollment status. 2) Financial Aid Counselors will continue to review the daily and weekly Hour Change Reports for each payment period to ensure Pell Grant awards are adjusted appropriately in response to enrollment status changes. 3) The Director and Assistant Director of Financial Aid will continue providing Banner (student information system) training to staff to ensure Pell Grant amounts are updated accurately within the system. Name(s) of the contact person(s) responsible for corrective action: Vanesa Teran-Martinez, Jennifer Monroy Planned completion date for corrective action plan: June 30, 2026

Finding: 2025-002 – Controls and Noncompliance Over Special Tests and Provisions: Return of Funds Management’s Response South Suburban College acknowledges this finding and has implemented corrective actions to strengthen compliance with established policies and procedures. These actions will ensure that Return of Title IV (R2T4) calculations are performed accurately, using correct term dates, and completed within required timeframes. Action Plan 1. Training The Director of Financial Aid will provide formal training to the Financial Aid Manager on federal Return of Title IV Funds (R2T4) calculation procedures, including the use of accurate term dates. Training of additional personnel will support the internal review process. 2. Control Process South Suburban College has established and will reinforce internal control processes to ensure compliance with federal Return of Title IV (R2T4) requirements. All Return of Title IV Funds R2T4 calculations prepared by the Financial Aid Director or Manager will have second review prior to final submission. This review process will ensure accuracy, timeliness, and compliance with Title IV regulations. Anticipated Date of Completion Note the audit found the error to be remedied as of Spring 2025 and the college continue its efforts. The additional actions noted above demonstrate South Suburban College’s commitment to ensuring Return of Title IV (R2T4) calculations are performed accurately and completed within required timeframes. Name of Contact Person: Yolanda Freemon Director of Financial Aid yfreemon@ssc.edu ext.5845

Finding 2025-001: Controls and Noncompliance Over Reporting - Pell Common Origination and Disbursement; Fiscal Operations Report and Application to Participate Management's Response: The College acknowledges this finding and has implemented the corrective actions outlined below to reinforce established policies and procedures. This will ensure the institution submits disbursement information to the Department of Education’s Common Origination and Disbursement (COD) site within the required 15-day timeframe. Corrective Action Plan: 1. Control Process South Suburban College has established an internal control process to ensure that all records are submitted in a timely manner. The Financial Aid Director and Manager now have access to be promptly notified of updates the Colleague software system. Notifications were previously accessible only to the IT Department. 2. System Upgrade South Suburban College is in the process of transitioning to new software by March 2026. Once the new software is in place, the South Suburban College ‘s IT department may no longer need to update the Colleague system to support the submission of Pell Grant disbursements. The transition to the new system is expected to streamline the process and improve reporting accuracy with automated reminders, updated calendars and other notification mechanisms in the College’s Colleague system to compliment manual. 3. Ongoing Monitoring and Training Regular system audits will continue to be conducted to ensure that personnel are well-informed and that policies are consistently followed. The retaining of documentation to support amounts within the FISAP has been implemented. The Financial Aid Department will also continue to monitor the COD site for compliance and address any discrepancies promptly. Anticipated Date of Completion Note the audit found the error to be remedied as of Spring 2025. However, with these corrective actions, South Suburban College is committed to ensuring that Pell Grant disbursements are reported accurately and submitted in compliance with federal regulations within the specified 15-day window. Name of Contact Person: Yolanda Freemon Director of Financial Aid yfreemon@ssc.edu ext.5845

Corrective Action Taken or Planned: A. Correction of "Day After" Reporting Logic The University previously identified a practice where the withdrawal (W) status was made effective the day following the student's notification. ● Process Update: This process was officially updated in April 2025 to align with the regulation, ensuring the withdrawal start date and the date of official notification are the same. The three findings all occurred prior to the April adjustment. ● Ongoing Diligence: The Registrar’s team is actively monitoring current and future records to ensure this logic is applied consistently going forward. B. Reporting Withdrawal Dates for Late-Term Requests To address students reported as withdrawn on the last day of the term rather than their actual date of request: ● Manual Tracking: For students who request a withdrawal between the official University withdrawal deadline and the end of the term, the Financial Aid Office will create a new process where they track students needing NSC manual corrections and share that information with the RO Team member doing the NSC reporting. ● NSC Overrides: The NSC reporting processor will utilize this information to perform manual date changes for these students, ensuring the reported date reflects the official date of notification rather than the term end date. C. Correlation of Withdrawal Date and Last Date of Attendance (LDA) To address findings where withdrawal dates did not correlate with the LDA: ● Faculty LDA Requirement: Although the University is a non-attendance-taking institution, a new requirement has been implemented for faculty to enter the Last Date of Attendance (LDA) for any student receiving a non-passing grade. ● Reporting Sync: The latest of the reported LDAs will be used by both the Financial Aid office (for calculations) and the NSC processor (for reporting) if a student is withdrawing from the University for the subsequent term and the student received all non-passing grades in the prior term. The Financial Aid office will notify the Registrar’s office if there are students with no passing grades and a LDA prior to the official withdrawal date to update their withdrawal date to match that LDA. ● Verification Workflow: The Registrar’s office will verify withdrawal information with the student, including the notification date, to ensure accuracy before manual NSC corrections are made. D. Internal Audit and Collaborative Controls To prevent recurrence and ensure compliance with federal reporting timelines: ● Collaborative Review: The Registrar and the Executive Director of Financial Aid & Scholarships will meet on a recurring basis to jointly review enrollment reporting procedures and ensure data alignment. ● Spot Checks: An internal audit process has been implemented to spot-check each submission file to verify that enrollment and withdrawal dates are accurate. The shared spreadsheet of manual dates will also be checked to ensure those dates are being changed. ● Petition and Request Review: The Registrar Team will carefully review all petitions and requests to determine which date to use as the original notification. ________________________________________ Person(s) Responsible for Corrective Action: University Registrar and Executive Director of Financial Aid & Scholarships. ________________________________________ Anticipated Completion: June 30, 2026 ________________________________________

Recommendation: Western Connecticut State University should strengthen internal controls to ensure that it submits enrollment status changes to the National Student Loan Data System in accordance with federal regulations. Corrective Action Plan as Reported by Western Connecticut State University: We agree with this finding. The discrepancy was originally identified during the first Gainful Employment / Financial Value Transparency (GE/FVT) submission in 2024, when Clearinghouse program lengths did not match NSLDS data. To ensure accurate reporting, the School Deans reported correct program lengths to the Registrar’s Office who implemented program-specific duration rules in the Program Duration Rules Form (SFACPLR). The corrected program lengths apply to all students with catalog terms beginning Fall 2025 and forward. Per system guidance, existing students will retain the prior six-year duration to prevent retroactive enrollment reporting errors in the Clearinghouse. This corrective action permanently resolves the program length discrepancy for future reporting and ensures compliance with GE/FVT and NSLDS requirements. Anticipated Completion Date: August 14, 2025 Western Connecticut State University Contact Person: Debra Zavatkay, Ed. D., Registrar (203) 837-8229

The University acknowledges the findings related to NSLDS enrollment reporting, including discrepancies involving OPEID reporting, program-level status effective dates, and other enrollment reporting data elements. The University agrees with the recommendation to enhance the precision of the control surrounding the review of enrollment status records, program-level data records, and campus-level data records included in NSLDS reporting submissions. Several corrective actions have already been implemented to address the identified exceptions. Updates have been made within the National Student Clearinghouse (NSC) reporting processes to ensure students are assigned to the appropriate branch codes and that campus-level records reflect the correct OPEID for each reporting entity. In addition, affected student records have been reviewed and updated to ensure program-level status records and effective dates are accurate within the NSC system. Going forward, the Registrar’s Office will monitor enrollment status changes and campus assignments within the NSC reporting process to ensure that status changes, program updates, and campus-level reporting elements are reflected accurately and transmitted in accordance with NSLDS reporting requirements. To further strengthen oversight and prevent recurrence, the Office of Student Financial Aid will implement documented post-submission reconciliation procedures following NSC reporting cycles. These reviews will focus on high-risk enrollment reporting elements, including campus changes, program status changes, and other updates affecting NSLDS reporting, and will validate the accuracy of OPEID assignments and program-level effective dates against institutional records. These enhancements are intended to improve the precision of the University’s existing controls and ensure the accuracy and completeness of future NSLDS enrollment reporting submissions.

2025-006 Federal Pell Grant Program, Federal Direct Student Loans – Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the University evaluate its policies and procedures around reporting student status changes to the NSLDS to ensure that all relevant information is being captured and reported in accordance with applicable regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Rider University concurs with the finding. The Registrar's Office will partner with Financial Aid to regularly correct students who have a mismatched SSN or other NSLDS / NSC information. In cases where students are unable or unwilling to provide Rider with correct SSNs, we will not be able to report their enrollment. This particular student is no longer enrolled at Rider, so no action will be taken in his particular case. Name(s) of the contact person(s) responsible for corrective action: Daniel Pavlick and Jacqueline Watford Planned completion date for corrective action plan: Effective Immediately