Corrective Action Plans

Condition: The School District relies on two-third party vendors to manage key financial aid systems, including student information, eligibility determinations, disbursement calculations, and reporting. During the audit period, the institution did not perform any oversight activities or testing to verify the integrity, accuracy, or compliance of the systems managed by the vendor. There were no documented controls, service-level agreements, or monitoring procedures in place. Planned Corrective Action: The School District will establish formal oversight procedures for all third-party vendors supporting financial aid functions. This will include developing and maintaining service-level agreements, implementing documented monitoring and testing protocols, and conducting periodic reviews to verify system accuracy, data integrity, and federal compliance. Staff will be trained on these updated processes to ensure ongoing accountability. Contact Person Responsible for corrective action: Almir Hodzic Anticipated Completion Date: June 30, 2026

Condition: The School District is eligible to participate in Title IV federal student aid programs; however, it does not conduct an annual review of its institutional eligibility requirements nor maintain documentation supporting such assessments. Planned Corrective Action: The School District will implement an annual review process to verify its institutional eligibility for participation in Title IV programs. Procedures will include maintaining thorough documentation of all eligibility assessments and required approvals. Staff responsible for compliance will be trained on these updated requirements to ensure accurate and timely completion each year. Contact Person Responsible for corrective action: Almir Hodzic Anticipated Completion Date: June 30, 2026

Condition: The institution does not have a process or controls in place for a timely review of program eligibility, ECAR. Planned Corrective Action: The School District will establish a formal process to ensure timely and documented reviews of program eligibility in accordance with federal requirements. Staff will be trained on the new procedures, and the School District will implement internal controls to monitor program eligibility on a regular schedule. These steps will help ensure ongoing compliance and accurate determinations moving forward. Contact Person Responsible for corrective action: Almir Hodzic Anticipated Completion Date: June 30, 2026

Condition: The institution did not reimburse students with credit balances within 14 days of the balance being posted to their student ledger. Planned Corrective Action: The School District will strengthen its procedures to ensure all student credit balances are identified and refunded within the required 14-day timeframe. Staff will receive training on the updated process, and the District will implement regular monitoring to verify timely issuance of refunds going forward. Contact Person Responsible for corrective action: Almir Hodzic Anticipated Completion Date: June 30, 2026

Condition: The institution’s policy maintains that any unchased check must be returned to the State of Colorado after the financial statement year-end to the Great Colorado Payback program and does not include a carve-out for uncashed Title IV aid checks. Planned Corrective Action: The School District will revise its policy to ensure uncashed Title IV aid checks are returned to the U.S. Department of Education in accordance with federal regulations, rather than to the State of Colorado. The updated policy will include a specific carve-out for Title IV funds, and staff will be trained on the revised procedures to ensure accurate handling and timely returns. Contact Person Responsible for corrective action: Lisa Bollers Anticipated Completion Date: June 30, 2026

Condition: The School District does not calculate or process any post-withdrawal disbursements for students that have withdrawn from the institution. Planned Corrective Action: The School District has implemented procedures to ensure post-withdrawal disbursements are calculated and processed in accordance with federal Return of Title IV (R2T4) requirements. Staff have been trained to identify eligible students, complete the required calculations, and issue timely notifications and disbursements. The School District will also conduct periodic reviews to ensure that all post-withdrawal disbursements are consistently met. Contact Person Responsible for corrective action: Almir Hodzic Anticipated Completion Date: October 2025

Condition: The School District did not report the status changes of certain students to the NSLDS in an accurate and timely manner during the fiscal year. Planned Corrective Action: The School District will update its procedures to ensure all student status changes are reported to NSLDS accurately and within required federal timelines. Staff responsible for reporting will be retrained on the updated process and monitoring requirements. The School District will also implement a periodic internal review to verify the timely and accurate submission of information going forward. Contact Person Responsible for corrective action: Almir Hodzic Anticipated Completion Date: June 30, 2026

Condition: The School District did not utilize the cost of attendance when determining the maximum amount of aid a student is eligible to receive. The School District also does not maintain updated cost of attendance calculations for its programs. Planned Corrective Action: The School District will implement procedures to ensure the cost of attendance (COA) is used when determining each student’s maximum eligible aid in accordance with federal requirements. The District will also develop and maintain updated COA calculations for all programs and review them annually. Staff will be trained on these processes to ensure accurate and compliant aid determinations moving forward. Contact Person Responsible for corrective action: Mary Cooper Anticipated Completion Date: June 30, 2026

Condition: The School Districts awarded aid to students using the full-time, three-quarter time, half-time, etc, schedule and improperly recorded students under a credit program versus appropriately recording them under a clock hour program, for which students would have been considered full-time in their enrollment status if they did not attend less than half-time. Planned Corrective Action: The School District has revised its policies to ensure students in clock-hour programs are correctly classified and awarded according to federal requirements. As a result, we are now awarding full aid to all eligible students based on proper enrollment status determinations. Staff have been retrained on the updated procedures to ensure ongoing compliance. Contact Person Responsible for corrective action: Amy Beruan Anticipated Completion Date: November 2025

Finding – Special Tests and Provisions: Enrollment Reporting – Federal Direct Student Loan Program, Assistance Listing Number 84.268; June 30, 2025 Award Year; U.S. Department of Education Criteria or Specific Requirement Enrollment information, including the effective date of separation from the institution, must be accurately reported within 30 days whenever attendance changes for a student, unless a roster will be submitted within 60 days. The changes include reductions or increases in attendance levels, withdrawals, graduations, and approved leaves of absence. It is the institution’s responsibility, as a participant in the Title IV aid programs, to monitor and report these changes to the National Student Loan Data System (“NSLDS”). (NSLDS Enrollment Reporting Guide November 2022, and 34 CFR 685.309(b)) Condition Of the twelve students selected for enrollment reporting testing, eleven students within the sample were reported to NSLDS outside the maximum 60-day window. This was not a statistically valid sample. Views of Responsible Officials and Planned Corrective Actions The College concurs with the finding. The College will continue to remain vigilant in its oversight over timely communication of enrollment reporting detail to NSLDS. In both instances, the data we had sent to the National Student Clearinghouse (NSC) was not received by NSLDS in a timely fashion. We will review our reporting schedule and make the appropriate changes to our reporting timeline to ensure the data we report to the NSC is subsequently received by NSLDS within regulations. Names of Contact Person Responsible for Corrective Action: Annette MacMullin, Director of Financial Aid Anticipated Completion Date: September 18, 2025

Department of Education – Direct Programs ALN # 84.268, 84.063, 84.007, 84.033 Student Financial Assistance Cluster – Special Tests and Provision – Disbursement on Behalf of Students Finding Summary: Two students were identified who were not awarded the full amount of Pell for which they were qualified. Both students were registered in the summer session. Responsible Individual: Director of Financial Aid Corrective Action Plan: The College will implement a control process to ensure all semesters are properly identified and taken into account when creating a financial aid package for students. An evaluation will be done to ensure that no students who are eligible for Pell are precluded from receiving it. Anticipated Completion Date: Spring 2026

Department of Education – Direct Programs ALN # 84.268, 84.063, 84.007, 84.033 Student Financial Assistance Cluster – Special Tests and Provision – NSLDS Reporting Finding Summary: During review of student statuses on NSLDS, 3 students were noted with a status of “no record found”, and 18 students where the status change was not submitted within the required timeframe established by DOE. Responsible Individuals: Director of Financial Aid and Registrar Corrective Action Plan: The College is coordinating efforts between the Office of Financial Aid and the Registrar’s Office to ensure that timely and accurate reporting of student status is made to NSLDS. Anticipated Completion Date: Spring 2026

Department of Education – Direct Programs ALN # 84.268, 84.063, 84.007, 84.033 Student Financial Assistance Cluster – Special Tests and Provision – Disbursement on Behalf of Students Finding Summary: School is required to provide specific and timely notification when direct loans are being credited to a student’s account. During the review of the direct loans disbursed to students, it was noted that notifications were not sent to students and parents as required. Responsible Individual: Director of Financial Aid Corrective Action Plan: The College is aware of the requirement and the timing of the notification. The College will create a control process to ensure proper notification of loans is sent as required. Anticipated Completion Date: Fall 2025

Department of Education – Direct Programs ALN # 84.268, 84.063, 84.007, 84.033 Student Financial Assistance Cluster – Special Tests and Provision – Disbursement on Behalf of Students Finding Summary: During the review of the calculation of student disbursements, a student was noted whose awards exceed the unmet needs. This over award that was created was in the form of non-Title IV scholarships. Responsible Individual: Director of Financial Aid Corrective Action Plan: The Office of Financial Aid is refining and validating the process for monitoring unmet need and potential over-awarding. The College will put extra effort on ensuring that this situation does not re-occur and ensure that all staff are following the established process to evaluate unmet need. Anticipated Completion Date: Fall 2025

Federal Agency Name: Department of Education – Direct Programs ALN #84.268, 84.063, 84.007, 84.033 Student Financial Assistance Cluster – Special Tests and Provisions – Returns to Title IV Finding Summary: During the review of the return to Title IV funds, there were eleven instances out of thirty in which the Title IV funds to be returned were not calculated and returned if required within the 45-day maximum timeframe allowed. The R2T4 calculations for fall 2024 were not performed until February 2025. Responsible Individual(s): Director of Financial Aid Corrective Action Plan: This finding was due to the turnover of key personnel in the financial aid office during the academic year. Staffing in the office is currently stable and properly trained on regulations and the timing requirements and calculation of Return to Title IV. College is developing and refining a process to review and return Title IV funds in a timely manner. The calculations for subsequent semesters have been made in a timely manner. Anticipated Completion Date: Fall 2025

The independent auditor identified certain concerns as set forth in the SFA Enrollment Reporting Control Deficiency, dated June 30, 2025. All concerns appear to relate to mid-semester withdrawals of students; all will be resolved by the continued implementation of previous corrective action plan (CAP) and the facilitation of the additional plan details set forth herein. As background to these issues, Eastern Wyoming College (EWC) experienced unique circumstances related to the transmission of student information as a result of its status on Heightened Cash Monitoring (HCM2). Simply, the systems in place between the college, the federal government, and a third-party vendor did not communicate accurately, principally due to timing issues of student information and EWC's requests for reimbursement of financial aid. In the previous audit (2023-24), these types of issues were identified and remedied through EWC's corrective action plan. At that time, EWC committed to manually updating the Clearinghouse/NSLDS systems to ensure timely enrollment reporting. This effort was put in motion beginning in October 2024. EWC submits the concerns identified in the latest report were largely being corrected by the previous plan and the resolution of the timing issues due to EWC's move from HCM2 to HCM1 statuses. As part of EWC's continued effort, it is worthwhile to note additional information, issues and resolutions. Enrollment reporting at EWC has been historically managed by the Data Analyst. This singular reporting has allowed data to be reported consistently and efficiently. However, because the analyst does not work in either the Registrar or Financial Aid Offices, the reporting has not been able to adeptly identify and address unusual cases. The current reporting structure requires additional review and oversight. Therefore, as part of corrective actions, the Registrar or designee will manage enrollment statuses for all mid-semester college withdrawals. The Registrar is in the best position see the student's enrollment and to identify the accurate dates. The Registrar will be the final decision maker regarding the reporting of information. In addition, the Financial Aid Office, as part of their R2T4 calculation checklist when an official withdrawal form exists, will ensure that any completed courses from Block A do not impact the student's reported status of withdrawn. The Financial Aid Director, either as part of the initial calculation or the follow-up internal audit, will confirm whether any credits are earned prior to a student's withdrawal. Further, the director will ensure that any withdrawal is separately reported because current, standard reporting may not identify this status change. Delayed reporting as noted in the associated finding, will no longer be an issue now that all systems are aligned following the college's move from HCM2 to HCM1 status. This allows National Student Loan Data System (NSLDS) to be notified of awarded aid, which will then allow the National Student Clearinghouse to effectively report all students, as required. In addition to the systems working as designed, EWC will conduct an internal audit each semester and will review students who withdrew during the term to ensure that all systems were updated correctly, and all offices reported accurate dates. In addition, all offices involved will create a collective Standard Operating Procedure manual related to enrollment reporting in addition to each office's separately documented procedures. Anticipated Completion Date: September 2025 Contact Person: Rebecca McAllister/Xi Feng/Dave Bluemel

2025-002 Significant Deficiency over Activities Allowed and Unallowed and Allowable Costs/Cost Principles The auditors recommend that the County implements a review control over weekly timesheets to ensure the timesheets include all program time coded on the day sheets. NCDHHS policy requires program salaries to be allocated and supported by payroll and attendance records for individuals. There is no disagreement with this audit finding. Annual day sheet training is now required for all staff that submit day sheets. Additionally, all new hires are required to complete day sheet training prior to submitting their first entry. A PowerBI dashboard has been created and released in June 2025 to pull data from both Workday (the County’s system of record) and our daysheet system, ISSI that provides supervisors the ability to show discrepancies between entries in real time. The County will also conduct random reviews monthly. Any discrepancies identified will be provided to staff leadership for support and correction. Additional reviews will be conducted for those staff with identified errors until released by leadership. Semi-annual reports will be provided to HHS Senior Leadership members to show trends and compliance with day sheet and timesheet entries. These reports will be created in December and June of each year. Person responsible for correction action: Leigh Anderson, HHS Business Administrator Completion date: The County has already implemented these changes.

The Director of Financial Aid will review the dates reported to COD at the end of each semester. The current software is set up where manual adjustments to amounts and dates reported to COD are required, the transition to new software should automate part of this process.

Response: According to the student sampling conducted as part of the audit, several withdrawal records were reported incorrectly. The source of the inconsistencies was unknown at the time of notification by the auditors. However, progress had been made since the 2023-24 audit when little to no withdrawal records were being reported correctly. The purpose of this report submitted to NSLDS through NSC, is to notify lenders of students who have dropped below half time status and therefore should be entering their six month grace period prior to loan repayment. All students are included in the withdrawal report, regardless of whether they have a loan with Vernon College or any other institution. It is important to note, internal records are accurate and loan processes are in compliance. Vernon College is pleased to report that recently the Registrar’s Office has discovered the source of the withdrawal reporting errors and has implemented a solution. The source and subsequent solution involve entering certain dates in designated areas in our student information system, Colleague. If errors occur in the future, the Registrar’s Office has developed a backup manual review process to use to ensure reporting will remain consistent and correct. The Registrar’s Office will run an “Enrollment Activity Report” to identify all course withdrawals within a designated time period as outlined by the NSC First of Term and Subsequent Term reports. The reporting official will then audit the Colleague produced NSC report against the Enrollment Activity Report to ensure accuracy and update manually as needed. This will occur prior to submission to the NSC/NSLDS. Moving forward, the manual process will only be used if needed.

This Repeat Finding has been acknowledged. Union has taken several steps towards making the required changes to ensure compliance with our enrollment reporting responsibilities. This includes implementing process improvements related to our National Clearing House (NSC) submissions and reviewing our academic policies related to academic leaves of absence and withdrawals. Timeliness of Enrollment Reporting Rosters: As of January 2024, Union completed the setup and configuration of our enrollment reporting services with NSC as our third-party service provider. The new process is administered by the school Registrar, with back-up responsibilities handled by the Assistant Dean, Director of Financial Aid, and the Vice President of Admissions and Views of Responsible Officials: This Repeat Finding has been acknowledged. Union’s Academic Office is in the late stages of implementing a multi-year action plan to implement the required system, policy, and procedural changes to ensure compliance with all enrollment reporting regulations. As of January 2024, Union completed our migration to the National Clearinghouse (NSC) as our third service provider for enrollment reporting services. We have already experienced a strong positive impact on the timeliness of our enrollment reporting. For example, we have fully addressed the timeliness of our NSLDS Roster response, which is due within 15 days. This year’s testing sample yielded zero (0) errors, demonstrating our ability to successfully address enrollment reporting issues. The steps outlined below will allow us to address the enrollment reporting issue identified in this year’s testing sample. Earlier this academic year, Union revised both our Academic Leave of Absence and Term Withdrawal policies to ensure alignment with our compliance obligations. Due to these changes, Union has already noted a reduction in reporting errors and inconsistencies. The FY25 Single Audit finding is related to the reporting of withdrawal/dismissal actions that took place in summer, a non-required term for students in our programs. Our corrective action will be to: (1) further modify our policies and procedures to specifically address non-required and interim terms; and (2) increase the number of batch enrollment updates to NSC/NSLDS during non-required terms to ensure that all summer withdrawals are communicated within 60 days.

Enforce the organization's R2T4 refund calculation proceedures

All graduate and withdrawn student files will be reviewed on a monthly basis to verify any status changes are reported to NSLDS within regulatory timeframes. Training and professional development will be required for responsible staff to ensure a compliance schedule is developed. Personnel will be evaluated to ensure existing policies, procedures, and processes are followed and supported through corrective action where needed.

When processing unofficial withdrawals through the R2T4 process, an additional step to the withdrawal process has been added. Financial Aid staff will use the NSLDS Enrollment History Update feature to submit the unofficial withdrawal date directly to NSLDS. This ensures that the date has been reported to NSLDS avoiding any potential that the student being reported has missed the regular NSC enrollment reporting rosters.

Condition: For one student, the School District used an incorrect number of days attended in the return to Title IV calculation, resulting in an inaccurate refund amount. Planned Corrective Action: We have conducted on-going training, created R2T4 Quick References, Term Calendar Calculators, R2T4 Decision Trees as well as other tools to assist R2T4 team members. These are supplemental to the body of regulations related to R2T4 found in the Student Aid Handbook. We will also perform and document a sample-based review of R2T4 calculations on a semester by semester basis. Contact person responsible for corrective action: Adrian Robson, Director of Financial Aid Anticipated Completion Date: 11/01/2025

Western Wyoming Community College experienced an unexpected turnover in the Director position and had a consultant from Dynamic Campus and an Interim Director of Financial Aid step in to help assist staff during this time. Due to lack of communication, reporting of a return of Title IV funds for the one student found in the audit did not occur as it normally would. Corrective Action A new Director of Financial Aid has been hired and has worked with the Assistant Director of Financial Aid to train on the process of Return to Title IV and timely reporting. • Each day the total withdrawal list is checked to determine the students who are receiving federal aid and may need to have a Return of Title IV calculation performed. • The students who are determined to require a Return of Title IV calculation are then processed for the Return of Title IV funds. This process is completed by the Assistant Director or Director of Financial Aid. • Once the process is complete and funds have been adjusted appropriately the Assistant Director or Director of Financial immediately run the process to export the files and funds out to the Common Origination and Disbursement (COD). • The next day COD is checked to ensure no reject(s) of the file(s) have occurred. If there are errors/rejects of the file the issue is researched and fixed to be accepted by COD. This process will ensure the timely reporting and return of funds to the Department of Education. Anticipated Completion Date: October 24, 2025 Contact Persons: DeeAnna Archuleta, Director of Financial Aid