Corrective Action Plans

2025-005 Federal Pell Grant Program, Federal Direct Student Loans, Federal Supplemental Educational Opportunity Grants – Assistance Listing No. 84.063, 84.268, 84.007 Recommendation: We recommend the University review and strengthen its policies and procedures for completing R2T4 calculations to ensure accurate inputs. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Rider University concurs with this finding. After review the University noted this was an isolated instance of human error. The effective date for the withdrawal was imputed incorrectly as 2/27/2025, however, the correct effective date was 2/17/2025. Rider University will ensure the Financial Aid Administrator completing this task is attentive to eliminate any errors. Name(s) of the contact person(s) responsible for corrective action: Jacqueline Watford Planned completion date for corrective action plan: Effectively Immediately

2025-004 Federal Pell Grant Program, Federal Direct Student Loans, Federal Supplemental Educational Opportunity Grants, Federal Work-Study Program – Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Recommendation: We recommend the University implement policies and monitoring procedures to ensure Title IV credit balances are either refunded to students in a timely manner or supported by documented written authorization. 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. This was an isolated instance due to prorated tuition charge that was excluded during the Title IV credit balance assessment. The University will work with OIT to ensure the systemic review process is inclusive of all prorated charges. Rider has updated the university’s frequency in their Reporting procedures to ensure this process is completely accurately and timely. Name(s) of the contact person(s) responsible for corrective action: Jacqueline Watford Planned completion date for corrective action plan: Effectively Immediately

2025-003 Federal Pell Grant Program – Assistance Listing No. 84.063 Recommendation: We recommend the University review and enhance its policies and procedures related to COD reporting to ensure all disbursement information is reported accurately and within required timeframes. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Rider University concurs with this finding. The University will implement a bi-weekly Pell Reconciliation process and procedure to ensure timely reporting to COD. Rider has updated the University’s frequency in their reporting procedures to ensure this process is completed accurately and timely. Name(s) of the contact person(s) responsible for corrective action: Jacqueline Watford Planned completion date for corrective action plan: Effectively Immediately

2025-002 Federal Direct Student Loans - Assistance Listing No. 84.268 Recommendation: We recommend the University strengthen its review procedures over student award packages, including a review at the start of each academic year, to ensure Direct Loans are awarded in accordance with grade level and dependency status limits. We also recommend the University review all ISIR codes and resolve any that are necessary. 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 University will ensure all student award packages and ISIR codes are reviewed and resolved prior to disbursing any Title IV funding. No additional Unsubsidized Loan will be awarded without a Parent PLUS Loan denial received from COD and on file with the Financial Aid Office. Rider has updated the University’s packaging procedures to ensure this process is implemented. Name(s) of the contact person(s) responsible for corrective action: Jacqueline Watford Planned completion date for corrective action plan: Effective Immediately

ENROLLMENT REPORTING PROCEDURES SHOULD BE STRENGTHENED. STUDENT FINANCIAL AID CLUSTER PROGRAM ALN# 84.268,84.007,84.033, 84.063, and 84.038 (Questioned Costs - None) Views of Responsible Officials and Planned Corrective Actions The university will strengthen coordination between the Registrar, Financial Aid, and the Business Office to ensure that SAP status is evaluated and communicated before financial aid is disbursed. Procedures will be implemented to ensure timely receipt of grade reporting and academic alerts from faculty and Academic Affairs. Financial Aid staff will review SAP eligibility after each academic evaluation period and maintain documentation of SAP determinations. Students who do not meet SAP requirements will be appropriately flagged to ensure financial aid eligibility is addressed prior to disbursement, strengthening compliance with federal financial aid regulations. Date to be implemented: On-going and completed by June 1, 2026. Persons responsible: Vice President of Business & Finance and Office of Financial Aid.

Special Tests and Provisions – Return of Title IV Funds Condition: During the testing of the return of Title IV funds, it was noted that one (1) of eight (8) tested calculation of funds to be returned had no documentation to determine if returns were completed timely as the College did not retain the lists of students associated with drawdowns and/or returns and one (1) of eight (8) tested. Recommendation: Policies and procedures should be written to provide internal control over the documentation used to complete the drawdowns, including returns, from the Department of Education. We recommend the College establish a communication and record retention process that allows for the notification of students withdrawing and a control in place that allows the financial aid department to know that the student financial aid was returned to the Department of Education within the required timeframe. Views of responsible officials and planned corrective action: Areas of focus will be to put in place written policies and procedures for the Financial Aid office, including the area of disbursements that includes additional controls and documentation of such. Our objectives will be that all current and incoming Financial Aid staff will be required to maintain documentation of any drawdowns of funds related to student financial aid. We have put in place a shared an electronic folder with restricted access to provide confidentiality and provide documentation of the shared communication between offices. Documentation of drawdowns and/or returns will be maintained within this folder. Staff will be trained on using the daily generated reports from J1 to watch for students who have withdrawal on their records so that this can be updated and proper calculations done. Measurable targets will be achieved by documenting the records within a shared secure electronic drive between the Financial Aid Office and the Business Office. The Financial Aid Office utilizes system-generated reports to identify student withdrawals on a biweekly basis, or as needed ensuring timely processing of R2T4 calculations. The Business Office processes all returns of funds, and a specific general ledger account has been designated to track R2T4 transactions

Special Tests and Provisions – Payment to Students Condition: During our testing of the financial aid disbursements, it was noted the College is not maintaining records of what students the drawdowns were for, therefore we were unable to determine if the amounts were posted to the student accounts within the required time frame and subsequently were paying out any credit balances created on student accounts. Recommendation: Policies and procedures should be written to provide internal control over the documentation used to complete the drawdowns from the Department of Education. We recommend the College establish a communication and record retention process that allows for the notification of the student financial aid proceeds and a control in place that allows the financial aid department to know the student financial aid was applied to the student’s account timely. Views of responsible officials and planned corrective action: The College has established formal procedures governing the documentation, approval, and processing of financial aid drawdowns from the Department of Education. A segregated and controlled workflow has been implemented through the use of a secure shared electronic folder with restricted access to provide confidentiality and provide documentation of the shared communication between the Financial Aid office who approves the aid, the Business Office who ultimately pulls down from the Department of Education, and with the Cashier who distributes any refunds. The Financial Aid Office prepares and approves disbursement amounts and communicates them via documented reporting; the Business Office reconciles disbursement amounts to individual student accounts prior to drawdown; the CFO initiates drawdowns after documented review and approval; and the Cashier processes student refunds, where applicable. The documentation is being retained and backed up. Measurable targets will be to do this weekly or as batches are prepared for draw-down. This documentation can be found in the secure shared electronic folder, which has already been implemented. Financial aid disbursements are processed on a weekly or batch basis, and funds are applied to student accounts in compliance with federal requirements, generally within three (3) business days of receipt.

Title: Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University evaluate their procedures and review policies surrounding reporting status changes to NSLDS to ensure timely and accurate reporting. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Registrar’s Office and the Financial Aid Office jointly reviewed the processes and data-entry practices related to enrollment reporting to ensure they are applied consistently and accurately. A plan has been implemented to provide ongoing training for employees responsible for managing reporting data. In addition, both offices established clearer communication channels to support timely and accurate updates and agreed to conduct an annual review of these processes to maintain continued alignment. Name(s) of the contact person(s) responsible for corrective action: Stephen Field Planned completion date for corrective action plan: 3/18/2026

Waldorf University was surprised by this finding. In response, several meetings were held, and a clear process was designed to mitigate issues related to uncashed checks. The University accepts the findings and believes the new software will aid in producing accurate reports. Waldorf University is also reorganizing its departmental structure to strengthen oversight and ensure a thorough review of financial reports and account records.

Finding 2025-001 – Enrollment Reporting To address this repeated finding, the following action items have been put into place: 1) The University conducted a reorganization of the student services unit that resulted in a shift of oversight to new personnel. Beginning July 2025, the Office of the Registrar, the unit responsible for enrollment reporting is under the direction of Sonia Gutierrez-Mendoza, Associate Vice Chancellor of Student Services, and Jorge Salas Lizarraga, University Registrar. 2) There were three main NSLDS reporting data errors identified and noted below. For each one, the requirements, source documents, cause of error and corrective action plan are noted. Campus Level Data Errors o Requirements:  NSLDS data elements must include accurate Student Enrollment Status (Full- Time, Three-Quarter Time, Half Time, Less Than Half Time, Withdrawal, Graduation, Leave of Absence) and the Effective Date of student changes. o Source Document/s:  Data source documents are provided through the Banner/Ellucian Campus Level Data delivered reporting. (Requires accurate parameter setup prior to processing). o Cause of error:  Incorrect student data parameters setup/used within Banner/Ellucian Campus Level Data reporting. o Corrective Action Plan:  Correct the Banner/Ellucian reporting parameters to match the NSLDS enrollment data reporting requirements for campus level/student status.  Engage Banner/Ellucian subject matter consultant to advise/provide additional expertise on setup/successful implementation of required campus level data reporting.  Implement controls over the Campus Level Data reporting process to ensure correct data submission to NSLDS. Program Level Data Errors o Requirements:  NSLDS data elements must include accurate Student Enrollment Status (Full-Time, Three-Quarter Time, Half Time, Less Than Half Time, Withdrawal, Graduation, Leave of Absence) and the Effective Date of student changes. o Source Document/s:  Data Source documents are provided through the Banner/Ellucian Program Level Data delivered reporting. (Requires accurate parameter setup prior to processing). o Cause or error:  Incorrect student data parameters setup/used within Banner/Ellucian Program Level Data reporting. o Corrective Action Plan:  Correct the Banner/Ellucian reporting parameters to match the NSLDS enrollment data reporting requirements for program level/student status.  Engage Banner/Ellucian subject matter consultant to advise/provide additional expertise on setup/successful implementation of required program level data reporting.  Implement controls over the Program Level Data reporting process to ensure correct data submission to NSLDS. Timely Reporting Errors O Requirements:  Timely reporting to NSLDS within 60 days of all student enrollment status changes at the campus and program levels. o Source Documents:  Data source documents are provided through the Banner/Ellucian delivered reporting. (Requires accurate parameter setup prior to processing). o Cause of error:  Incorrect reporting student data parameters setup/used to cause student enrollment status changes to be omitted and or skipped. o Corrective Action Plan:  Correct the student data parameters to accurately include all student changes within the Banner/Ellucian report.  Ensure that the student enrollment changes are reported to NSLDS within the 60-day time status requirements.  Engage Banner/Ellucian subject matter consultant to advise/provide additional expertise on setup/successful implementation of the required timely data reporting.  Implement controls over the 60 days timely submission reporting requirement to the NSLDS. 3) The following data from the NSLDS Enrollment Reporting guide will serve as the basis for each revised report: • Student current SSN • OPEID • CIP Code • CIP Year • Credential level • Published Program Length Measurement • Published Program Length • Weeks in Title IV Academic Year • Program Begin Date • Special Program Indicator • Program Enrollment Effective Date Anticipated Completion Date: July 1, 2026 Person Responsible: Jorge Salas Lizarrage, University Registrar

2025-001 - Miscalculation of Reconnect Scholarship Awards. Auditor Description of Condition and Effect. For 3 out of 12 students tested, the incorrect amounts of Michigan Reconnect scholarships were calculated and awarded to students. As a result, the College had a total of 16 students whereby the Michigan Reconnect scholarships awarded during the fiscal year were miscalculated, resulting in $16,101 in under-awarded scholarships and $288 in over-awarded scholarships to students. The College corrected under-awarded scholarships by adjusting student accounts to reflect accurate award amounts and issued refunds to students as applicable on March 18, 2026. The college corrected over-awarded scholarships by adjusting the student accounts and updating the Michigan Student Scholarships Grants ("MiSSG") reporting system to refund MiLEAP on August 6, 2025. Auditor Recommendation. We recommend that the College implement a formal review process for Michigan Reconnect scholarship award calculations, ensuring that each calculation receives a second, independent review to verify its accuracy. Corrective Action. The College recalculated the awards for the students impacted, adjusted their student accounts, notified the students of these corrections and returned $288 in over-awarded scholarships to MiLEAP by updating the MiSSG reporting system. Additionally, the College plans to conduct additional training of stafff on the Michigan Reconnect Expansion program, including the last-dollar calculation methodology, and will implement a review of the calculations by a second individual of all disbursements. Responsible person. Maryann DeCaire, Director of Financial Aid. Anticipated Completion Date. March 31, 2026.

Recommendation We recommend implementing a Program Improvement Plan between the Title IV-E team and Fostering Connections to ensure that adoption cases potentially eligible for extended subsidies are processed promptly upon consideration, with the necessary agreements executed in a timely manner, i.e., before the children in question turn 18. Management Response Corrective Action The Office of Performance and Accountability Director will work with the Adoption and Kinship Unit Supervisor to establish a biannual review of payments to adoptive parents to verify if cases need to be closed. Due Date of Completion: June 30, 2026 Responsible Person(s) Office of Performance and Accountability Director

Recommendation We recommend a Program Improvement Plan with documentation retention and file checklist, training, implementation, and monitoring process. There should be accountability for non compliance with these requirements. Management Response Corrective Action Missing Documentation The CYFD Adoption Subsidy unit will continue to organize its filing system. The Eligibility Manager and Office of Performance and Accountability Director will work with the Adoption and Kinship Unit Supervisor to review and ensure appropriate checklists, training, and processes are in place. In addition, the Eligibility Manager, OPA Director, and Adoption and Kinship Unit will conduct an additional case review to ensure required documentation is present and establish a biannual cadence of self-assessment checks to ensure no missing documentation. Criminal Records Mitigation The agency continues to ensure that workers, supervisors, and managers follow proper procedures for mitigating criminal records checks. The agency addresses this by creating a supervisor checklist to ensure licensure documentation is complete and accurate. The supervisor will conduct an initial placement review; the checklist will include verification by the supervisor of the completed level of care documentation. Supervisors and Managers will address work performance with employees through corrective actions or employment evaluation. Due Date of Completion: June 30, 2026 Responsible Person(s) Office of Performance and Accountability Director

FINDING 2025-009 Name of Responsible Individual: Lisa Simon, CPA, CFO, Terri Helt, Senior Accountant, Tracy Jenkins, Student Account Billing Coordinator, & Dylan J. Nowakowski, Director of Financial Aid Corrective Action: The University acknowledges the FISAP report was filed with incorrect data and not amended in a timely manner. The University has developed a series of internal controls and procedures to ensure that the data provided for the FISAP will be accurate going forward. Wheeling University worked with ECSI regarding Perkins information. With the Perkins program ending, we realized that we needed to move in the direction of closing out Perkins files/information. ECSI has been updated with the Cash on Hand documents that we have from the Department of Education. The University is currently working with ECSI so that we are able to submit Perkins information/files to the Department of Education. Anticipated Completion Date: June 2026

FINDING 2025-008 Name of Responsible Individual: Tracey Jenkins, Student Account Billing Coordinator/Lisa Simon, CPA, CFO Corrective Action: Wheeling University worked with ECSI regarding Perkins information last year. With the Perkins program ending, we realized that we needed to move in the direction of closing out Perkins files/information. The University is currently working with ECSI so that we can submit Perkins information/files to the Department of Education. We have gathered information (promissory notes, bankruptcy details, payment information, etc.) as we have been able to locate it, and and we have sorted account in alpha order to assist ECSI with the process. We will continue to update this process. Anticipated Completion Date: June 2026

FINDING 2025-007 Name of Responsible Individual: Lisa Simon, CFO, Terri Helt, Senior Accountant, & Dylan J. Nowakowski, Director of Financial Aid Corrective Action: Wheeling University acknowledges that we were not in compliance with the 15-day reporting window for a couple of the students in question. This is due to the fact that the University is on HCM1 and has to do refunds prior to the export to COD. We know this is a finding for multiple departments and internal controls. With that, there was a delay on these two students that were outside the 15-day window. We now have a policy and procedure in place for the HCM1 work flow. Also, have new staff in place to regulate this, so that we always are following the regulations and staying compliant. The procedure is to make sure we do not have this finding again and that we stay in compliance with the Department of Education reporting requirement. Anticipated Completion Date: September 2025 and Ongoing

FINDING 2025-006 Name of Responsible Individual: Rachel Heavilin, HR Generalist/Payroll Corrective Action: The payroll Process for Federal Work Study: Student punches in on a computer or cell phone to log in and out when working at the start of their shift and the end of their shift. Timecards can be approved by their supervisor/manager daily, weekly, or by the pay period which is every two weeks. The pay period ends on a Friday with the payroll processing to begin on the following Monday. On that Monday, all timecards must be corrected/updated and approved before they can be processed. Timecards with errors cannot be processed. Once the new HR and Payroll leader arrived, she instituted this approval process and requirement and checks and balances. Staff are trained in these processes upon hiring as well. Anticipated Completion Date: November 2025

FINDING 2025-005 Name of Responsible Individual: Dylan J. Nowakowski, Director of Financial Aid Corrective Action: After Colleague was properly set up for Financial Aid for R2T4’s, the Director discovered that the calendars did not match the actual publicized academic calendar. Had the calendar been accurate with the correct dates of breaks of five days or more, then the R2T4 would have been accurate. The R2T4 process has been working correctly following our R2T4 policy to make sure the days are correct in the system before the R2T4 is submitted. For the years moving forward this will be verified before any R2T4 is calculated and submitted. All breaks that are five days or more are accurate. At Wheeling, we have a comprehensive R2T4 policy. This policy outlines how to count calendar days in a semester and provides clear instructions on what to do when a student withdraws during a break. Anticipated Completion Date: July 2025

FINDING 2025-004 Name of Responsible Individual: Tracy Jenkins, Student Account Billing Coordinator Corrective Action: We recognized that students were not receiving the Right to Cancel notifications in a timely manner. We also understood the need for students to receive this information to make an important educational/fiscal decision. As of September 2023, on a monthly basis, notifications were sent to student University emails and parent’s personal email (Plus Loan recipients) informing them of their Right to Cancel. There was one student that was at 31 days and this process has been updated. Anticipated Completion Date: January 2025

FINDING 2025-003 Name of Responsible Individual: Shelia Yates-Mattingly, Registrar Corrective Action: In response to Finding 2025-003, Wheeling University will continue the enrollment reporting process that was implemented in October 2023, which was in response to Finding 2022-005, Finding 2023-005 and continued with the Finding 2024-003. With the stability of staffing in the Registrar’s Office and Financial Aid Office and the level of experience and competence of this staff, enrollment reporting has been completed within the parameters of regulatory guidelines. The Registrar’s Office submits enrollment reports as scheduled and subsequent error resolution reports as appropriate. The Financial Aid Office reviews identified NSLDS errors, corrects and resubmits them timely. Regularly scheduled meetings, including the Registrar’s and Financial Aid Offices, continue as noted in corrective actions for Findings 2022-005, 2023-005, and 2024-003. These meetings serve as the platform to discuss and address identified enrollment reporting concerns/issues timely, resulting in improved accuracy in enrollment reporting and timeliness in error resolution. In addition, attendance through Census will be monitored in an effort better identify registered but not enrolled students for administrative action and timely reporting. Institutional enrollment reports will be used to identify students who have chosen not to continue their studies at the University but without withdrawing from the institution to alert departments to execute their operational protocols for students who have discontinued enrollment. Students who officially withdraw pursuant to established University protocols will be required to consult with Financial Aid during this process. University departments will continue to be informed of student withdrawals as they occur to inform their practices. Anticipated Completion Date: Processes in place since October 2023; new measures implemented January 2025

FINDING 2025-002 Name of Responsible Individual: Terri Helt, Senior Accountant Corrective Action: The University has formalized and documented financial processes to establish internal controls to ensure accurate, timely, and consistent reporting. In addition, this has created a reasonable transition plan during employee turnover, as well as ensures proper and timely filings. The corrective action involves drawing down the funds from the G5 federal website and issuing refunds to students that day. There is a checks and balance process built in, so multiple staff members are involved with the process. The financial aid department calculates the amount of a federal drawdown and relays that information to the business department. The senior accountant draws the appropriate amount of federal financial aid. The student accounts billing coordinator applies aid to the various student accounts in the software. After the aid has been applied, the student accounts billing coordinator determines if a refund is due to the students. Any student that is entitled to a refund will be cut for a refund check that day. The students will then have a window of opportunity to come pick up the refund checks. Within two business days, any students who have not picked up their refund checks will have them mailed to their address on file with the University. This process has been developed to ensure that students receive their refunds in a timely and accurate manner. Anticipated Completion Date: Completed July 2025 and Ongoing

The University will more closely review the data submitted regarding tuition and fees being reported on the FISAP. This will include validating and reconciling the amounts reported on the FISAP to the University's general ledger. This has been completed as of March 2, 2026 for fiscal year 2024-2025.

The Financial Aid staff will receive ongoing training on accurate determination of withdrawal date, last date of attendance (LDA), and correct payment period start and end dates. The Director and Assistant Director will review all R2T4 calculations for accuracy prior to finalization, including verification of withdrawal date, LDA, and payment period start and end dates. The Director and Assistant Director will ensure that all applicable funds are returned to the Department of Education and properly removed from the students' accounts within the required time frame.

The East Central University Records Office reports enrollment to the National Student Clearinghouse (NSC). The NSC then transmits that data to the National Student Loan Data System (NSLDS) where it becomes part of the financial aid record. The graduate student enrollment status issue was addressed in March 2025 as a result of the 2024-year audit. Importantly, because that correction was made in March of 2025, it was expected that the 2025-year audit identified Spring 2025 semester students prior to when the correction was made. The Records Office is confident this particular issue was fully resolved in March 2025 in accordance with the action plan put forward at the time. With regard to the student's status effective date differing between NSLDS and Colleague, considerable time has been devoted to investigating this case. This includes a one-hour consultation with Strata information Group (SIG) on 3/6/2026. However, ECU is not able to determine where the date reported to NSLDS came from. Much review of the Colleague to NSC reporting procedures has taken place since Fall 2024, which gives the Records Office confidence that whatever the cause of this data discrepancy, it is unlikely to represent a current systemic problem. However, the Records Office will add to the list of preliminary data checks (i.e. , prior to submitting the Colleague file to NSC), to randomly select students who have a within-term change of status and verify that the date in the NSC file matches what we expect to see in Colleague. With regard to Spring graduated status effective dates exceeding the end of the term, while working with the SIG consultant to review procedures for NSC reporting, it was noticed that Colleague requires NSC reporting period dates to not exceed the end of term. This caused the Records Office to raise the question of the award date. ECU was able to determine that NSC does expect the last day of term and the award date to match. Campus stakeholders were notified that the historic practice was ending. Beginning with Fall 2025, the award date and end of term match. While the Records Office is confident much progress has been made, minor findings through 2026 are possible.

Finding number: 2025-001 Federal agency: U.S. Department of Education (“ED”) Programs: Federal Pell Program and Federal Direct Student Loans Assistance listing #’s: 84.063, 84.268 Award year: 2025 The College will be looking at making some business process changes to review files submitted to NSC (National Student Clearing House) and NSLDS (National Student Loan Data Service) on a monthly basis and perform monthly reconciliation between responsible offices to ensure students are accurately reported to ED/NSLDS. This new implementation will allow the College/Office to better verify each student’s enrollment status, status changes and related effective date visibility of reporting issues in the future. Timeline for Implementation of Corrective Action Plan Implemented Fall 2025 Contact Person: Alaina Marcotte, Director Financial Aid