Corrective Action Plans

Recommendation: We recommend the University review the GLBA Safeguards Rule and implement appropriate processes and controls to ensure compliance with all applicable provisions. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The IT Department, in conjunction with Human Resources and individual directors and department heads, will institute an annual system inventory of data classification and owner, ensuring job roles and position descriptions are mapped to access profiles. The CIO will review the current classification process for assigning role-based access and the related IT ticketing process for access to ensure existence of documented approvals for provisioning and role changes through a defined access request and approval workflow. IT will also work with HR to establish onboarding/position change/separation controls and timelines triggered by HR provisioning with same-day termination (within 24-hours) upon termination and role change reviews with transfers. IT will also enforce multi-factor authentication (MFA) administrative access where feasible. The relevant Policy and Procedure Manuals will be updated to define access privileges and approval processes, and staff will be trained annually and with onboarding. Name(s) of the contact person(s) responsible for corrective action: Russ Fagan, Chief Information Officer Planned completion date for corrective action plan: March 31, 2026

Student Financial Assistance Cluster – Assistance Listing No. 84.268, 84.063, 84.007, 84.033, 84.379 Recommendation: We recommend that the University implement a key control to ensure that enrollment data, changes in status, and effective dates within NSLDS match the records of the institution and are reported timely, and to store evidence of the key control having occurred. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University reports enrollment more frequently than the required 60 days to capture status changes in a timely manner. Reporting occurs each term at the end of the second week, the Tuesday after Census, Monday of week 7, and the end of the term. The Registrar and Financial Aid Office created a process to communicate accurate last dates of academic engagement (LDAs) for unofficial withdrawals so that withdrawal dates match LDAs used in Return of Title IV (R2T4) calculations and unofficial withdrawals are reported to NSLDS through the regular NSC process. The Offices have also instituted a shared tracking and review process to regularly spot-check enrollment reports to ensure that data reported in Banner matches NSC reports and is correctly uploaded to NSLDS. Documentation of unofficial withdrawals, LDAs, error reports, and tracking of sampling outcomes with any needed corrections are maintained in the school’s files and shared between offices. The Registrar’s Office will review Banner and NSC submissions to ensure accurate and matching LDAs and status dates; the Financial Aid Office is responsible for confirming NSC submittals have successfully uploaded to NSLDS and reflect correct data that matches R2T4 and unofficial withdrawal info. Manual reporting to NSLDS will only be used for emergency updates to meet timeliness requirements, with multiple follow-up verification for NSC or roster file overwrites. Policy and Procedures Manuals will be updated accordingly, and staff in both offices will be trained annually and with onboarding. Name(s) of the contact person(s) responsible for corrective action: Emily Sharratt, Registrar; Jason Hibbert, Director of Financial Aid Planned completion date for corrective action plan: March 31, 2026

Upon identification of the configuration error, the University corrected its National Student Clearinghouse (NSC) file submission settings to ensure enrollment status changes are properly processed and transmitted to NSLDS. The University has implemented a new monitoring control whereby an employee independent of the enrollment reporting function performs a review of NSLDS to verify that data submitted through NSC has been accurately and timely transmitted in accordance with required timeframes. This control is designed to provide timely detection of any future transmission failures and ensure corrective action is taken within the required reporting windows.

U.S. Department of Education Mount Mary University respectfully submits the following corrective action plan for the year ended June 30, 2025. Audit period: July 01, 2024 - June 30, 2025 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FINANCIAL STATEMENT AUDIT Our audit did not disclose any matters required to be reported in accordance with Government Auditing Standards. FINDINGS—FEDERAL AWARD PROGRAMS AUDITS U.S. Department of Education 2025-001 Student Financial Aid Cluster – Assistance Listing No. 84.063 & 84.268 Recommendation: We recommend that the University reviews withdrawals monthly to ensure that the students are reported correctly to NSC and subsequently to NSLDS. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University has submitted and reviewed the four students and have submitted corrections for incorrect statuses and effective dates. Name(s) of the contact person(s) responsible for corrective action: Brian Olson, Vice President of Finance and Administration Planned completion date for corrective action plan: June 30, 2026 *** If the U.S. Department of Education has questions regarding this plan, please call Brian Olson, Vice President of Finance and Administration, at 414-930-3139.

Condition: Out of 40 students tested for return to Title IV, we identified 2 students whose calculation were performed outside of the required timeframe. Planned Corrective Action: Once the report identifying students who have completely withdrawn from their classes is ran, the calculations are done (currently by the Dean) The completed report is given to the FA Specialist to review and send the letters. The specialist then gives the report to the Assistant Director who then prints off a Return of Title IV summary report showing the calculations and charges for final review. Had this last step been done previously, it would have been identified that the Institutional Charges were missing and not requiring corrections. Contact person responsible for corrective action: Nikki Jewell Anticipated Completion Date: June 30, 2026

Condition: Out of 22 students tested for Pell eligibility we identified one student whose student aid index (formerly known as expected family contribution) was changed, however the additional award was never disbursed to the student. Planned Corrective Action: System generated ISIR’s and corrections will be reviewed for changes and then given to the Director for weekly review to ensure the updates and awards are accurate and complete Contact person responsible for corrective action: Nikki Jewell Anticipated Completion Date: June 30, 2026

Student Financial Assistance Cluster – Assistance Listing No. 84.007 (Federal Supplemental Educational Opportunity Grants Program), 84.033 (Federal Work Study Program), 84.038 (Federal Perkins Loan Program), 84.063 (Federal Pell Grant Program), 84.268 (Federal Direct Student Loans Program), 93.364 (Nursing Student Loans) Recommendation: We recommend that the Institution strengthen internal controls over verification, including implementing a secondary review of all verified files, enhancing staff training, and ensuring timely submission of all corrections Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Financial Aid Office will no longer use the Verified Status Code of “S” to track a completed verification without the documented approval of the both the Director and Assistant Director. In addition, a secondary review of a select group of verified students mid-way through the year will be completed to ensure that verification was properly followed. Name(s) of the contact person(s) responsible for corrective action: Andrew Reddington, Director of Financial Aid Planned completion date for corrective action plan: This process will be implemented starting with the Spring 2026 semester. If the Department of Education has questions regarding this plan, please call Craig Maynard, Vice President of Business and Finance at 309-556-3021.

Finding No. 2025-001 Special Tests and Provisions – NSLDS Reporting Corrective Action Students on the reject detail from the National Student Clearinghouse (NSC) enrollment submission who receive a 253 or 290 error will be reviewed using a Financial Aid provided report to determine if any have been awarded Title IV aid. Financial Aid will provide the FAFSA or Social Security Number (SSN) confirmation backup to correct the NSC error for students who have received aid. We will also manually report those student statuses to the National Student Loan Data System while the errors are being corrected by NSC for anyone receiving Title IV aid so we are timely in our reporting of student status. For students that do not have FAFSA or SSN confirmation information with Financial Aid, we will contact those students directly for documentation to correct or affirm their SSN information to resolve any future 253 or 290 errors. Persons Responsible for Corrective Action Evan Koegl, Registrar and Director of Academic Records Completion Date All changes have been implemented as of March 2026.

Finding 2025-004 Name of Responsible Individuals: Mrs. Tiffany Grandy, Assistant Director of Financial Aid, Mr. Jared Peterson, Financial Aid Counselor, Mrs. Terri Grice, Associate Registrar, and Mrs. Vicky Warrick, Registrar Corrective Action: As a result of Audit Finding 2025-004, Financial Aid has generated a report specifically for the Registrar’s Office that indicates enrollment plans for students who stop attending or withdraw from all courses for a single semester. The Registrar’s Office will be using this report for reporting enrollment status changes for students via NSLDS. Anticipated Completion Date: March 19, 2026

Finding 2025-003 Name of Responsible Individuals: Mrs. Tiffany Grandy, Assistant Director of Financial Aid and Mr. Jared Peterson, Financial Aid Counselor Corrective Action: As a result of Audit Finding 2025-003, Financial Aid will originate direct loans at least one week prior to the scheduled disbursement date. For large origination files at semester starts, financial aid administrators will run simulation originations to work through origination and/or disbursement rejections prior to sending real originations at least one month prior to semester starts. Anticipated Completion Date: March 19, 2026

Finding 2025-002 Name of Responsible Individuals: Mrs. Tiffany Grandy, Assistant Director of Financial Aid and Mr. Jared Peterson, Financial Aid Counselor Corrective Action: As a result of Audit Finding 2025-002, Financial Aid will use a daily credit change report generated automatically from academic records to make any manual credit updates in the PowerFAIDS financial system. Additionally, Financial Aid will use selection sets within PowerFAIDS to identify any credit hour mismatches between what is manually reported versus what is integrated from Power Campus, the academic records database. Anticipated Completion Date: March 19, 2026

Student Financial Aid Cluster – Assistance Listing No. 84.063 Recommendation: We recommend that the University verifies the enrollment intensity for each student receiving the Federal Pell Grant prior to finalizing their award package. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University is working with a PowerFAIDS consultant to ensure that the correct number of credits populates based on the courses inputted. The issue has also been added to their procedures to check the Class Load and Credits field whenever packaging or revising a student’s aid. Name(s) of the contact person(s) responsible for corrective action: Michael Moos, Vice President of Finance Planned completion date for corrective action plan: June 30, 2026

Finding Number: 2025-001 Federal Agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 & 84.007 Award Year: 2025 Corrective Action Plan: Berkshire Community college agrees with this finding, and upon its review of the affected students and the college’s policies and procedures. The Student Financial Services Office will work with the Registrar and use reports delivered by Institutional Effectiveness to monitor and determine withdrawals on a regular basis. Timeline for Implementation of Corrective Action Plan: Immediately Contact Person: Karrie Trautman, Director of Financial aid

Condition: Of the 25 students selected for enrollment reporting, the University did not update the student enrollment information for four students accurately. Planned Corrective Action: Upon learning of these errors during the audit, the University conducted a review of all 2024–2025 records to ensure that all other reports were accurate. The University uses a third party provider to perform these actions and while the University is responsible for verification, concrete controls have been put in place. The University will examine and compare NSLDS data three times per year to identify and resolve any inconsistencies in a timely manner. Additionally, the third party provider has indicated it is reviewing its internal practices to help ensure similar reporting issues do not occur in the future. Contact person responsible for corrective action: Data & Insights Analyst Anticipated Completion Date: Implemented as of 3/1/2026

Finding number: 2025-001 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 and 84.268 Award year: 2025 Corrective Action Plan The College will ensure sufficient processing time for the National Student Clearinghouse (NSC) to report graduates to the National Student Loan Data System (NSLDS) within the required federal reporting timeframe. During Fall 2024, the College was required to submit a second graduate file. By the time this file was processed by NSC and transmitted to NSLDS, it exceeded the 45-day reporting deadline. To prevent recurrence, the College will implement earlier internal processing deadlines and enhanced monitoring of graduate file submissions. In addition, the College will promptly review and correct any graduate records rejected by NSC and ensure that all statuses are accurately updated in the NSC system prior to transmission to NSLDS. For withdrawal reporting, the College applies the following standards: • If a student withdraws from the College after completing all courses in the final sub-term of a semester, the effective date reported is the semester end date. • If a student withdraws from the College and withdraws from all courses during the final sub-term, the effective date reported is the official date the student submits withdrawal from both the College and the courses. Conferral dates are established by the College and may differ from the semester end date. The College maintains three conferral dates annually: Spring, Summer, and Fall. Enrollment reporting for graduates will reflect the official conferral date as determined by the institution. Timeline for Implementation of Corrective Action Plan End of Fiscal Year 2026 Contact Person Stephanie King Executive Director of Student Financial Services

Finding number: 2025-002 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 and 84.268 Award year: 2025 Corrective Action Plan This discrepancy resulted from a data entry error during the enrollment reporting process. Upon identification, the record was corrected and resubmitted to NSLDS with the accurate effective date. To prevent recurrence, the institution is evaluating its procedures to ensure the correct effective date for enrollment changes are reported correctly to the National Student Clearinghouse and NSLDS. Timeline for Implementation of Corrective Action Plan Management anticipates implementing the corrective action as soon as possible, with completion expected by June 30, 2026. Contact Person Stephanie King Executive Director of Student Financial Services

Finding number: 2025-001 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 Award year: 2025 Corrective Action Plan This occurred due to a manual review oversight during the enrollment status verification process prior to disbursement. Upon identification, the award was reviewed, and corrective action was taken to adjust the Pell Grant to the appropriate part-time amount. The institution has since reinforced its review procedures by implementing an additional verification step to ensure enrollment status is accurately confirmed before Pell Grant disbursements are finalized, thereby reducing the risk of similar errors in the future. We have completed a review to ensure no other students were in this situation and we found no additional students. Timeline for Implementation of Corrective Action Plan Management anticipates implementing the corrective action as soon as possible, with completion expected by June 30, 2026. Contact Person Stephanie King Executive Director of Student Financial Services

Student Financial Assistance – Assistance Listing No. Various Recommendation: We recommend the College evaluate its procedures and policies surrounding NSLDS reporting to ensure all status changes are reported timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Erikson Institute’s Registrar’s Office has worked with National Clearinghouse representatives to identify and correct specific issues to ensure all students are reported properly and prevent additional errors. Names of the contact persons responsible for corrective action: Gilbert Martinez, Registrar and Leanne Beaudoin-Ryan, Executive Director of Institutional Effectiveness.

Student Financial Assistance – Assistance Listing No. Various Recommendation: We recommend the College evaluate its procedures and policies around reporting Unsubsidized Loan disbursements to COD to ensure that student information is reported accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Financial Aid Department will no longer disburse loans or report disbursements to the Department of Education multiple times weekly. Effective December 2025, Erikson Institute Financial Aid department only makes disbursements and reports them to the Department of Education on Fridays of each week. This is to ensure that the disbursement date in both Erikson’s student information system, Jenzabar, and COD match. Names of the contact persons responsible for corrective action: Monique Foster, Director of Financial Aid Planned completion date for corrective action plan: 12/2025

The College implemented a new financial aid system in FY26 which includes built in controls to detect and flag disbursement date discrepancies throughout the disbursement process. The reconciliation files generated from the new system include a comparison of disbursement dates which makes any differences easy to see and rectify.

The Town should review the restricted reserve requirements and establish a separate account to hold the funds.

Condition: The audit identified instances in which enrollment status changes for withdrawn students were not reported to the National Student Loan Data System (NSLDS) within the required 60-day timeframe and in some cases the withdrawal date reported did not reflect the student’s actual Last Date of Attendance (LDA). Cause: The discrepancies occurred because the academic term end date was used instead of the student’s actual Last Date of Attendance for certain withdrawn students. In addition, in limited cases enrollment status changes for students who did not return for a subsequent term were not reported within the required 60-day window due to the timing of non-returning student reporting cycles. Corrective Action Plan: Sauk Valley Community College will implement revised procedures and additional monitoring controls to ensure that enrollment reporting to NSLDS complies with federal requirements. The College submits enrollment reporting through the National Student Clearinghouse, which transmits enrollment data to NSLDS on the College’s behalf. The College utilizes an internal system to generate enrollment reporting files based on institutional enrollment and withdrawal data. The Registrar reviews the file prior to transmission to the National Student Clearinghouse for submission to NSLDS. Enrollment reporting is currently submitted on a monthly basis. To address the reporting discrepancies identified in the audit, the College will implement the following corrective actions: 1. Accurate Withdrawal Date Reporting Procedures will be updated to ensure that the effective withdrawal date reported to NSLDS reflects the student’s actual Last Date of Attendance (LDA) recorded in institutional records rather than the academic term end date or administrative processing date. 2. Monthly Reconciliation Process The Registrar and Financial Aid Office will perform a monthly reconciliation of institutional withdrawal records to NSLDS enrollment reporting data to confirm that enrollment status changes and withdrawal dates have been reported accurately and within the required reporting timeframe. 3. Monitoring of Potential Unofficial Withdrawals Students who receive all “F” or “W” grades will be reviewed as potential unofficial withdrawals to ensure that the correct Last Date of Attendance is identified and reported when applicable. 4. Monitoring of Non-Returning Students Students who do not return for the summer or fall term following the spring semester will be reviewed by the end of June to determine whether a withdrawal status must be reported to NSLDS. The College will follow the National Student Clearinghouse guidance regarding non-required term enrollment reporting to support accurate status reporting. 5. Ongoing Compliance Oversight Financial Aid and the Registrar will work collaboratively to review enrollment reporting data on an ongoing basis to ensure compliance with federal reporting requirements, including the 60-day reporting requirement for enrollment status changes. 6. Staff Training and Procedural Reinforcement The Registrar and the Financial Aid Office will review NSLDS enrollment reporting guidance and applicable federal requirements with relevant staff to reinforce proper reporting procedures and ensure consistent understanding of withdrawal date reporting requirements and timelines. These procedures will provide additional oversight to ensure that withdrawal dates are reported accurately and that enrollment status changes are transmitted to NSLDS within the required timeframe. Responsible Officials: Jennifer Schultz, Dean of Student Services, Lizzie Harper, Director of Financial Assistance, and Meagan Rivera, Registrar Planned Implementation Date: The revised procedures will be implemented immediately, beginning with the current enrollment reporting cycle, and will continue as an ongoing compliance control.

The College is dedicated to ensuring the accuracy of reporting to the NSLDS. The following is how the College plans to verify the integrity of NSLDS reporting: The staff responsible for correcting records will receive targeted instruction emphasizing accuracy, verification and accountability. A secondary verification process is planned to be put in place to ensure that a secondary review is performed to confirm reported information and address any discrepancies. Name(s) of Contact Person(s) Responsible for Corrective Action: Victoria Stozek, Director of Financial Aid, vstozek@dccc.edu Anticipated Completion Date: 6/30/26

The institution acknowledges the reporting discrepancy related to Spring 2025 enrollment reporting. While the final Spring 2025 enrollment file should have been submitted prior to the start of the Summer 2025 term, it was instead submitted on May 29, 2025, after the Summer term began on May 20, 2025. As a result, the file was processed with summer enrollment data rather than final spring enrollment data, including the appropriate graduation statuses. Although a Graduation (DegreeVerify) file was submitted on May 15, 2025, this file updates the National Student Clearinghouse (NSC) degree database for verification purposes only and does not update the enrollment database used for reporting to NSLDS unless specific services are enabled. At the time, the institution was not participating in NSC’s “G from Degree” functionality, which would have facilitated the automatic application of graduation statuses to the enrollment database. Additionally, delays and inaccuracies in Fall 2025 First of Term reporting (including incorrect term begin dates in files submitted on August 25 and September 15, 2025) further delayed the accurate reporting of raduated students. The corrected file was successfully processed on October 14, 2025. During Fall 2025, the institution was also engaged in FVT/GE reporting corrections. These corrections triggered system-generated enrollment updates, which ultimately resulted in the reporting of affected graduates to NSLDS; however, this occurred later than required. The institution recognizes that timely and accurate enrollment reporting is critical to ensuring that borrowers do not incorrectly enter repayment or lose in-school deferment status. Corrective Action Plan To prevent recurrence, the institution has implemented the following corrective actions: 1. Established Reporting Calendar and Internal Deadlines A formal enrollment reporting calendar has been implemented requiring: o End-of-Term files to be submitted after final grades are posted and degrees conferred, but prior to the start of the next term. o First-of-Term files for the fall and spring semesters must be submitted to NSC no later than three (3) business days before month-end. This timeline allows sufficient time to identify and resolve errors prior to NSLDS reporting. For the summer semester, First-of- Term file submission may extend through mid-June, which is acceptable given that student enrollment during a summer term is not required. 2. Implementation of NSC “G from Degree” Functionality As of February 11, 2026, the institution is actively utilizing NSC’s “G from Degree” service to ensure that graduation records submitted through DegreeVerify are evaluated and, when eligible, automatically applied to the enrollment database. 3. Review of “G Not Applied” Reports A required reconciliation process has been established: o After each DegreeVerify submission, staff will review the “G Not Applied” report. o Any students not automatically assigned a graduation status will be manually reviewed and, if appropriate, reported correctly on the next enrollment file. 4. Data Validation Controls Prior to Submission The Registrar’s Office has implemented a pre-submission validation checklist that includes: o Verification of term begin and end dates o Confirmation of degree conferral status o Review of enrollment status accuracy Files will not be submitted until all validation steps are completed. 5. Monitoring and Quality Assurance o Enrollment reporting submissions will be logged and reviewed each term for timeliness and accuracy. o Any errors identified will be documented and addressed through corrective follow-up. 6. Staff Training and Documentation Staff responsible for enrollment reporting have received updated training on: o NSC reporting requirements o NSLDS timing expectations o Use of NSC tools including DegreeVerify and “G from Degree” Written procedures have been updated and standardized. Responsible Official: Jill Johnson, Registrar (864) 587-4232 johnsoj@smcsc.edu

Recommendation: The University should review its policies and procedures around COD reporting to ensure students’ information is reported timely and accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: • Implementation of a monthly process where the Associate Director of Financial Aid Technical Operations will pull and review, on the 15th of each month, the Pell Reconciliation Report from the Common Origination and Disbursement (COD) website to ensure timely and accurate reporting to COD regarding Pell disbursements. • In addition to the Pell Reconciliation Report, the School Account Statement (SAS) would then be shared with the Disbursement Accounting Manager in Accounts Payable to compare their internal student disbursement records with the U.S. Department of Education’s official data, ensuring funds drawn down match those awarded. • This process will ensure that disbursement reviews occur more frequently and within the 15-day window from any given disbursements. It will also help identify discrepancies in student Pell Grant and Direct Loan amounts to maintain compliance and provide a consistent approach that minimizes risk of error or delay in disbursements. Name(s) of the contact person(s) responsible for corrective action: Leida Nieves, Executive Director of Financial Aid Services Planned completion date for corrective action plan: June 30, 2026