Corrective Action Plans

Western Wyoming Community College experienced a transition in leadership within the Financial Aid Office, resulting in a change in the Director of Financial Aid position. This transition caused disruptions in communication and process continuity between the Financial Aid, Registrar, and Institutional Effectiveness offices. As a result, inconsistencies were identified in the timing and accuracy of enrollment reporting to the National Student Clearinghouse (NSC) and the National Student Loan Data System (NSLDS). Corrective Action Plan 1. Leadership and Process Realignment a. A new Director of Financial Aid has been appointed and is collaborating with the Institutional Effectiveness Office and the Registrar to define clear processes and timelines for Records & Registration and Financial Aid operations. b. The Director of Financial Aid and Registrar will maintain continuous communication to ensure timely and accurate enrollment reporting and prompt correction of any identified discrepancies. c. The Director of Financial Aid and Registrar will work together to develop a Standard Operating Process (SOP) to ensure if any future attrition occurs in either department that anyone else in those departments will be able to step in and continue processing without interruption ensuring timely and accurate enrollment reporting continues. 2. Implementation of Controls for Third-Party Reporting a. Recognizing the benefits and responsibilities of using the National Student Clearinghouse (NSC) for enrollment reporting, the institution has implemented controls to verify the accuracy of data transmitted through this third-party servicer. b. The Assistant Director (or the Director of Financial Aid in the Assistant Director’s absence) will generate the Summary Return of Funds Report (ROFS) from Colleague each term and provide a copy to the Registrar for enrollment verification and reconciliation. 3. Quarterly Reconciliation and Internal Review a. The Financial Aid Office will conduct a quarterly comparison between Colleague and NSLDS records to ensure consistency of enrollment and status dates. b. Any discrepancies identified will be communicated to the Registrar for prompt resolution. c. Results of the quarterly reviews will be documented and used for internal compliance monitoring and training. 4. Updated End-of-Term Procedure To ensure ongoing accuracy and compliance, the following revised steps will be followed each term: a. The Director or Assistant Director of Financial Aid will run an All F Report after final grades are posted. b. The Director and Assistant Director of Financial Aid will jointly calculate Return to Title IV (R2T4) funds. c. The Return of Funds Report (ROFS) will be provided to the Registrar monthly to verify last date of attendance and withdrawal dates against Colleague records. d. The Registrar will verify subsequent semester enrollments and continuously monitor student enrollment, reporting any changes to Financial Aid leadership. e. The Registrar will submit end-of-term enrollment data to the National Student Clearinghouse as usual, and one week before the next term begins, will submit the end-of-term R2T4 list to prevent overwriting by subsequent semester reporting. 5. Training and Internal Audit Enhancement a. The Financial Aid and Registrar’s Offices will use findings from this audit to develop staff training on identifying and correcting data discrepancies during the quarterly reconciliation process. b. The Director of Financial Aid will review 80% of R2T4 files during each semester for accuracy in reporting and documentation. 6. Graduation Data Accuracy a. The Registrar’s Office utilizes the Update Academic Credentials File (UACF) in Colleague to batch post student degrees and certificates three times per year (end of spring, summer, and fall terms). b. It was determined that the automatic graduation date populates correctly only when students have a single program with no changes. For students with multiple programs or program changes, the graduation date must be entered manually to ensure accuracy. c. The Registrar will oversee the upload of graduates and verification of accurate credential dates, ensuring these dates are correctly reflected in NSC and the Director or Assistant Director of Financial Aid will make sure the dates are correctly reflected in the NSLDS system. d. The Registrar and Director of Financial Aid will conduct joint reviews to verify that all graduation and enrollment data are reported correctly. Anticipated Completion Date: June 30, 2026 Contact Persons: DeeAnna Archuleta, Director of Financial Aid, and Kayla Miller, Registrar

Western Wyoming Community College experienced unexpected turnover in the Director of Financial Aid position, which impacted financial aid reporting and reconciliation processes. Due to access issues with federal systems required for conducting reconciliations and the departure of a consultant who did not retain documentation for completed reconciliations, no reconciliations were available for review for the 2024/2025 Academic Year and 2025 Fiscal Year. Corrective Action Plan 1. Staffing and Training a. A new Director of Financial Aid has been hired and has completed training on the reconciliation process for both Pell Grants and Direct Loans in collaboration with the Assistant Director of Financial Aid. b. Cross-training has been implemented to ensure continuity of operations in the event of future staff turnover. 2. Establishment of Standard Operating Procedures (SOP) a. The Financial Aid Office has worked with the Business/Bursar’s Office to develop and document a Standard Operating Procedure (SOP) governing: • The drawdown of Title IV funds. • The reconciliation process for Pell and Direct Loan programs. b. The SOP outlines responsible parties, required documentation, and timelines for reconciliation and reporting. 3. Monthly Reconciliation Schedule a. A reconciliation schedule has been established requiring completion of Pell and Direct Loan reconciliations by the 15th of each month, or as soon thereafter as federal reports become available. b. Once reconciliations are confirmed as accurate and complete with the Business/Bursar’s Office, drawdowns of funds will occur on or near the 15th of each month, depending on calendar dates and federal system availability. 4. Compliance Alignment a. This process ensures timely and accurate reconciliation of Pell Grant and Direct Loan funding in accordance with 34 CFR 685.300(b)(5) and related federal cash management requirements. Anticipated Completion Date: November 15, 2025 Contact Persons: DeeAnna Archuleta, Director of Financial Aid, Assistant Director of Financial Aid, Business/Bursar’s Office

Western Wyoming Community College experienced an unexpected turnover in the Director position which impacted the timeliness of reporting. 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 reporting to COD within the 15 day period after disbursing federal aid. • Any available funds are disbursed each Monday throughout the semester, except for when a holiday falls on a Monday. Funds are then disbursed on the next working business day. • The process to export these disbursements to the Department of Education are performed the same day or the following day after the Business office has ran the transmittal process. This process is completed by the Assistant Director or Director of Financial Aid. • Once the process is complete and funds have been exported to the Department of Education through the Common Origination and Disbursement (COD) portal the Assistant Director or Director of Financial will 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 until accepted by COD. This process will ensure the timely reporting to the Department of Education. Anticipated Completion Date: October 24, 2025 Contact Persons: DeeAnna Archuleta, Director of Financial Aid

Condition During our testing over direct loan disbursement notifications, we found that for twenty out of twenty students tested, City Colleges could not provide evidence that notifications were sent within the required timeframe informing the student, or parent, that a credit will be made to the student’s account for a direct loan disbursement. While City Colleges demonstrated that its system was configured to automatically send notification letters and confirmed that notifications were issued, City Colleges could not provide documentation showing the specific date each notification was sent in relation to the loan disbursement. Cause City Colleges’ system is designed to record the date notifications are sent to students; however, it does not retain a copy of the actual notification content that was transmitted. Corrective Action Taken or Planned City Colleges’ IT team, in collaboration with a consultant, will configure the system to bring all Direct Loan communication letters into the Financial Aid (FA) Status pages. Integrating these letters directly into the FA Status page will ensure they are easily accessible for FA staff. As part of this enhancement, City Colleges will be able to view a timestamp indicating when each communication was sent to the student, as well as view the information required to be communicated by 34 CFR 668.165. Contact Person: Leticia Garcia, District Director of Student Financial Aid Anticipated Completion Date: December 13, 2025

Condition For one out of forty students tested, City Colleges properly recalculated a return of Title IV funds for a student but did not subsequently adjust the student's account to perform the return or notify the student of the adjusted award amount. Cause The lack of return of Title IV funds was an oversight due to human error. Corrective Action Taken or Planned To strengthen internal controls, the District Office assigned an analyst to conduct a review of a random selection of files across all seven colleges scheduled for audit to help identify any discrepancies early and ensure compliance. All R2T4 specialists will receive yearly refresher trainings on R2T4 procedures and controls. Contact Person: Leticia Garcia, District Director of Student Financial Aid Anticipated Completion Date: December 13, 2025

Disbursements to or on Behalf of Students – Credit Balances Corrective Action Plan: We acknowledge and concur with the auditor’s finding. The delay in identifying the credit balance resulted from the manual nature of the account review process. The credit was generated prior to the “go-dark” period associated with the implementation of the new ERP software. During this transition, the system was offline for nearly two weeks, which further contributed to the delay. The refund was issued with the first batch of refunds after the new software became operational. Currently, the refund process within the new ERP system still relies on manual account reviews. At this time, the student information system does not support automated alerts or workflows to assist in identifying Title IV credit balances. In response, the Student Accounts team has conducted a thorough review of the refund process to improve efficiency and ensure compliance with federal regulations regarding the timely disbursement of Title IV credit balance refunds. With support from IT specialists, a new report has been developed to identify Title IV aid posted to student accounts and compare it against allowable charges. This enhancement enables the Student Accounts team to more readily identify credit balances resulting from Title IV aid. Additionally, refunds are now being processed on a weekly basis. These improvements, along with increased monitoring, are expected to significantly reduce the likelihood of future delays in refund processing. Contact Person Responsible for Corrective Action: Carol Summervill, VP for Finance Anticipated Completion Date: Corrective Action was completed as of the date of this report.

Corrective action has been completed. The Institute determined at the start of Academic Year 24-25 that transitioning to a third-party provider of financial aid solutions would be in its best interest. This engagement provides a team of professional financial aid operations and student service specialists, allowing for enhanced loan counseling and processing services, implementing additional checks and balances, and mitigating the potential for errors such as this incident. The error resulting in the finding was actually identified by the third-party provider, following which AFI immediately returned the erroneously awarded federal funds to G5. Individuals responsible for corrective action: Lang Fredrickson, Chief Financial Officer 323.856.8429

2025-001 - Non-Compliance with Timely Student Enrollment Change Submissions to the National Student Loan Data System (NSLDS) Grantor: U.S. Department of Education Cluster Name: Student Financial Assistance Cluster Award Name: Federal Direct Loan Program Award Year: 6/1/2024- 5/31/2025 Award Number: Not applicable Assistance Listing Number: 84.268 Corrective Action Plan The University acknowledges that the graduation reporting date was not adjusted to reflect changes in the academic calendar. This resulted in a compressed timeframe for both the NSC and the University to process and correct student records as needed. To address this, the University will revise its reporting schedule beginning with the Fall 2025 graduation date to ensure that status changes related to graduation are reported promptly. This adjustment will allow the NSC to verify data with the NSLDS and provide the University sufficient time to resolve any discrepancies. Additionally, the University will explore further options to enhance the timeliness of reporting student status changes and will strengthen its reconciliation process to ensure accurate and efficient communication of all status updates. Contact Person: Aida Shadfan, Vice President of Finance and University Controller Aida.shadfan@lmu.edu

Return of Title IV (R2T4) Calculations Planned Corrective Action: SEBTS will take the following steps to address the failure to properly complete R2T4 calculations and returns: We will redefine an FI grade as “Failure due to inactivity” in the Faculty Handbook and Academic Catalog. Students will earn an FI if they fail the class due to lack of attendance or participation. The Provost will remind faculty during the final Faculty Meeting of each academic semester about the FI grade. The Registrar’s Office will send an email to all Faculty and Faculty Support Specialists during the last week of classes to remind faculty about assigning an FI to students who failed the course due to inactivity. The Instructional Design Office will inform Faculty Support Specialists about the FI grade during scheduled training meetings throughout the semester. The Adjunct Faculty Support Specialist will inform adjunct faculty during the final week of classes about the FI grade. The Registrar’s Office has updated Self Service, so faculty must enter the last date of attendance/participation if they enter an FI or F grade. The Registrar’s Office will use this to audit and only request further details from faculty who assign an F and indicate that a student stopped attending/participating before the end of the semester. The Learning Activity Report will be adjusted so Academic Advising can send a check-in email after 2 weeks of inactivity, a warning email after 3 weeks of inactivity, and the professor can assign an FI after 4 weeks of inactivity. Person Responsible for Corrective Action Plan: David Phillips, Director, Student Resources & Financial Aid Anticipated Date of Completion: 12/19/2025

2025-001: Exit Counseling Notification Not Performed Timely Student Financial Aid Cluster Assistance Listing Number 84.007, 84.033, 84.063, 84.268, Grant Period – Year Ended June 30, 2025 Condition Found During our student file testing, we noted one student out of forty was not sent exit counseling notification within thirty days after the student withdrew. We consider the exit counseling notification not being performed in a timely manner to be an instance of noncompliance with the Eligibility Compliance Requirement. Corrective Action Plan The College has implemented two new procedures that query data to identify financial aid recipients that have withdrawn from classes. The first query identifies new loan borrowers that have dropped below half-time status and the second query identifies previous loan borrowers that have dropped below half-time status. These queries will be run bi-weekly to identify students that must be sent exit counseling notifications within thirty days of withdrawal. Responsible Person for Corrective Action Plan Jeffrey A. Heap, Sr. Director, Financial Services & Controller Deanna Hogan, Director, Financial Aid Implementation Date of Corrective Action Plan October 3, 2025

FINDING 2025-002: LATE RETURN OF TITLE IV FUNDS We concur with the finding and will implement procedures to ensure that, in the future, Title IV refunds are made in accordance with the federal regulations. The institution has implemented the following corrective measures: • A strengthened reconciliation process has been established between the Student Accounts, Financial Services, and the Registrar’s departments. This process ensures that student enrollment changes are communicated in real time and that Title IV funds are returned promptly upon the institution’s determination of a withdrawal or cancellation. • Formalized timelines and internal monitoring controls have been created to ensure returns are completed within the regulatory timeframes. • Staff cross-training has been implemented to minimize the impact of personnel changes on the execution of Title IV responsibilities. • Periodic reviews will be conducted each term to verify timely processing of R2T4 calculations and returns.

FINDING 2025-001: PELL GRANT AWARD We concur with the finding and will follow established procedures more closely to ensure that, in the future, Pell Grant awards are calculated and disbursed in accordance with the federal regulations. The following corrective actions have been implemented: • The institution has strengthened internal controls to ensure that all Pell Grant awards are calculated and disbursed in strict compliance with federal regulations. • A reconciliation process for Pell Grant awards has been implemented. Pell Grant awards and scheduled credits are now reviewed and reconciled at the conclusion of the institution’s add/drop period to ensure accuracy before any disbursement occurs. • The institution has discontinued the practice of early disbursements. Beginning with Winter quarter, Pell Grant funds will not be drawn down or disbursed prior to the close of the add/drop period.

Finding 2025-003 Name of Responsible Individual: Bryce Durbin, Director of Institutional Research & Registrar Corrective Action Plan: Management agrees with the finding that one student’s Program Begin Date was incorrectly reported to NSLDS. For this new student, the Program Begin Date was reported as 5/14/2021, the date the new student transitioned from admissions to registration, rather than the actual first day of the academic term in which the student began enrollment in the program, as required by Part 5 of the 2025 Compliance Supplement. Beginning with the 2020 OMB Compliance Supplement, enrollment reporting requirements were expanded to include additional compliance data elements for NSLDS. During the 2020-2021 award year, the National Student Clearinghouse (NSC), the College’s third-party servicer for enrollment reporting, encountered program level data integrity issues. In response, new warning codes were introduced in December 2021, including WC 1811 Series, which addresses mismatch flags in Program Begin Date. In this case, however, no warning flag was triggered for the student. The Registrar Office will follow up with NSC to identify why the warning flag did not trigger. Moving forward, Registrar Office staff will review enrollment reporting files to verify that each student’s Program Begin Date reflects the first day of the term in which the program enrollment began, unless the student’s enrollment in the program was on an earlier date. Anticipated Completion Date: December 31, 2025

Finding 2025-002 Name of Responsible Individual: Noemi Sarrion, Director of Financial Aid Corrective Action Plan: Management acknowledges that for one student, the required federal direct loan disbursement notification was not sent within the required timeframe. After the parent’s PLUS loan was denied in April 2025, the student was offered an additional unsubsidized loan, which was accepted on 5/7/2025. The manually generated notification for the 5/8/2025 disbursement was inadvertently missed being sent out. We believe this oversight was an isolated incident due to the OFA’s unusually demanding April/May as noted in the previous finding. To mitigate this issue going forward, the OFA will remove the need for manual intervention by implementing an automated notification process utilizing the built-in scheduler functionality in PowerFAIDS. Anticipated Completion Date: May 1, 2026

Finding 2025-001 Name of Responsible Individual: Noemi Sarrion, Director of Financial Aid Corrective Action Plan: Management agrees with the finding that the estimated Cost of Attendance (COA) for the summer term was calculated incorrectly for five students. Because the summer term includes multiple sessions, the COA multi-step programming process in PowerFAIDS, the College’s financial aid management software, including the review of COA selection metrics, are manual. In April 2025, the College migrated its ERP software and PowerFAIDS to cloud-based platforms. This transaction required significant time from Office of Financial Aid (OFA) staff to test system functionality and validate migrated data to ensure a smooth go-live. As these efforts coincided with summer COA programming, the capacity for thorough review and comprehensive functional testing of summer COA setup was reduced. Going forward, the OFA will assign a staff member, separate from the individual handling COA programming, to review the COA selection metrics. In addition, the OFA will evaluate the potential of automating COA programming processes. Anticipated Completion Date: May 1, 2026

Condition: The College did not accurately timely and accurately complete refund calculations for 1 out of 4 students (25%) tested. We consider this finding to be a significant deficiency in relation to the Special Tests and Provisions compliance requirement and is a repeat finding shown in Section IV of this report as prior year finding 2024-005. Corrective Action Plan: Cynthia Lawrence in the Business Office will conduct a secondary full review of each R2T4 form completed by Hannah Masters, the student’s account statement and balance in Jenzabar, the withdrawal form supplied by the Registrar, the withdrawal date reported in Jenzabar by the Registrar, and any last date of attendance documentation provided by faculty or the Registrar. If any discrepancies are identified, Cynthia will notify both Hannah Masters and the Registrar’s team by email, outlining the issue. Once corrections are submitted, Cynthia will review the updated materials to ensure accuracy and compliance. Responsible Person for Correction Action Plan: Hannah Masters, Executive Director of Financial Aid and Student Accounts Cynthia Lawrence, Accounts Receivable / Staff Accountant Implementation Date for Corrective Action Plan: October 15, 2025

Condition: During our testing of thirty-seven student files, we noted two individuals (5.4%) that were not properly awarded Direct Loans. Corrective Action Plan: Twice each Fall and Spring semester, Hannah Masters will request an updated report of enrolled student year status from the Registrar, Chayna Penney. She will compare these statuses to the year-in-school information reported by students on their FAFSA, which is housed in the PowerFAIDS software. If any discrepancies are identified, Hannah will submit a FAFSA correction on behalf of the student, import the correction into PowerFAIDS, and review and recalculate the student’s financial aid. The student will then be repackaged appropriately, and an updated aid offer will be generated. Finally, Hannah will notify the student by email regarding the changes made to their account and will connect them with the Business Office and Registrar’s Office for any additional follow-up. This process was completed on October 1, 2025, for the Fall 2025 term, and a second review for Fall 2025 is scheduled for December 1, 2025. Responsible Person for Correction Action Plan: Hannah Masters, Executive Director of Financial Aid Chayna Penney, Registrar Implementation Date for Corrective Action Plan: October 01, 2025

Finding 2025-002: Student Financial Aid Cluster – Reporting View of Responsible Officials and Planned Corrective Action: Root Cause Errors occurred because the data file transmitted from Anthology to COD did not consistently include the correct student information. It is not yet clear whether the issue arises from configuration problems, system design limitations, or both. Planned Corrective Action and Responsible Officials • Procedure review and update. The Financial Aid Office will review and revise procedures to ensure accurate, timely, and complete reporting to COD, including pre-submission and post-submission checks. • System-to-COD file analysis with Anthology. In partnership with Anthology's support and managed services teams, the College will: o o o Analyze how COD reporting files are created within Anthology. Identify why certain student data elements are not being transmitted correctly. Implement configuration changes or other system-level fixes to ensure accurate and complete reporting. • Enhanced manual validation until issues are resolved. If the file creation process is determined to be working "as designed" but still does not meet regulatory expectations, Financial Aid staff will perform manual review and correction of COD files prior to submission, and will monitor error and rejection reports from COD for follow-up. As with Finding 2025-001, the Vice President for Student Affairs and the Director of Financial Aid share responsibility for ensuring these corrective actions are implemented and sustained commencing on the date set forth above.

Finding 2025-001: Student Financial Aid Cluster – Eligibility View of Responsible Officials and Planned Corrective Action: Root Cause Shortcomings in the Anthology cost-of-attendance and auto-packaging/repackaging logic prevented consistent, accurate calculations based on enrollment level and other eligibility factors. These gaps increased the amount of manual intervention required by Financial Aid staff and contributed to human error. Planned Corrective Action and Responsible Officials • Policy and procedure updates. The Financial Aid Office will review and revise policies and procedures to ensure that the calculation of cost of attendance and awarding of aid are fully aligned with federal regulations and institutional policy. • System configuration and process review with Anthology. Working with Anthology's support and managed services teams, the College will: o Analyze the current cost-of-attendance component and related packaging logic. o Re-configure system settings or implement automated workarounds to ensure that: ■ Cost of attendance is calculated correctly based on enrollment level and other required factors. ■ Auto-packaging and repackaging correctly award and adjust aid when a student's enrollment level or other eligibility factors change. Strengthened manual review until system stability is confirmed. Despite vendor assurances that the product would reduce manual effort, two levels of Financial Aid staff will manually review students' cost-of-attendance calculations and awards each term until the SIS demonstrates consistent accuracy over multiple audit cycles. Commencing on the date set forth above, the Vice President for Student Affairs, in coordination with the Director of Financial Aid, will oversee implementation of the above corrective actions and report progress to the President and the Board.

Views of Responsible Officials and Corrective Action Plan The District submits the file with the required enrollment information to the National Student Clearinghouse (NSC) two weeks after the start of each term and subsequently on a monthly basis. Part of the reporting process includes running SFRTMST, a baseline process in Ellucian Banner, the District’s Enterprise Resource Planning system, to calculate or update a student’s enrollment time status, which is the date when a change occurred in the enrollment of a student due to either registering in a class(es) or withdrawing from a class(es). The enrollment time status date is included in the enrollment file submitted to NSC. NSC then submits the enrollment information to the National Student Loan Data System (NSLDS). The discrepancy identified for the nine students was between a withdrawal date in Banner versus the enrollment time status date reported to NSC/NSLDS, which was the Banner calculated date. Because of the timing of when the SFRTMST process was ran, some students’ enrollment time status date did not match the registration activity date/enrollment effective date in Banner. After conducting research using the Ellucian Customer Center, the District identified a resolution to address this issue and has already implemented it for Fall 2025. To ensure that the students’ enrollment time status date reported to NSC/NSLDS matches the students’ effective date of their registration activity in Banner, the District activated the Calculate Time Status (Indicator) in SOATERM, a Banner setup, for Fall 2025 and will do so for all terms moving forward. Per Ellucian, when this indicator is set to “Y” a dynamic time status calculation will take place. The District verified that this process works. The issue has been resolved. In addition, the dates for the nine students were corrected in NSLDS. It is important to note that this issue has had no financial impact on the District. The students have been disbursed the correct amount of financial aid. The calculation of financial aid to be disbursed is not based on the enrollment dates reported to NSC and NSLDS.

Finding Reference Number 2025-001 Contact Person: Mindi Thompson, Registrar Current Status: When a student withdrew from a course or two during a term but still remained a part-time student for that term, those withdrawn courses were being counted in the enrollment intensity levels by the student information system for the purpose of generating enrollment level reporting for NSC-NSLDS. Views of Responsible Officials & Planned Corrective Action: Enrollment reports are generated directly from our student information system and we identified a system setting that controls whether or not withdrawn courses should be included in these reports. That setting has been updated and the Registrar is manually reviewing all records for students that withdrew from one or more courses during the term before finalizing and submitting the reports to NSC-NSLDS. Records affected during the 2024-25 academic year were all manually reviewed and updated by the Registrar at NSLDS. Staff will review software system settings regularly to ensure they stay set the correct way for future reporting. Anticipated Completion Date: Prior records with issues have already been corrected and ongoing monitoring is taking place.

2025-001 - Student Financial Assistance Cluster - (a) Federal Supplemental Educational Opportunity Grants (b) Federal Work-Study Program (c) Federal Perkins Loan (d) Federal Pell Grant Program (e) Federal Direct Student Loans (f) Teacher Education Assistance for College and Higher Education Grants (TEACH Grants) (a) 84.007 (b) 84.033 (c) 84.038 (d) 84.063 (e) 84.268 (f) 84.379 - Year Ended June 30, 2025 Criteria: 34 CFR 668.162 (d) states: Under the heightened cash monitoring payment method, an institution must credit a student’s ledger account for the amount of Title IV, HEA program funds that the student or parent is eligible to receive, and pay the amount of any credit balance due before the institution submits a request for funds. Condition: We tested 40 students and credit balances were not paid in a timely manner for 8 students (20%). We consider this condition to be a material weakness for the Special Tests and Provisions compliance requirement and is not a repeated finding. Statistical Sampling was not used in making sample selections. Responsible Persons: Andra Butler and Jessica Justice Corrective Action Plan: Management agrees with the finding. Management has already implemented corrective actions to ensure that credit balances caused by federal funds are refunded prior to those federal funds being requested by the University. Financial Aid notifies the Business Office when all postings are complete. The Business Office then runs a disbursement roster and refunds those students with credit balances. Once the refunds have been delivered to the students, the Business Office draws in the funds per the disbursement roster totals. The disbursement roster is retained as support for the drawdown amount Implementation Date: Fall 2025

Incorrect Pell Calculations Condition: The University did not properly award Pell for the Summer term under the new enrollment intensity calculation requirements. Planned Corrective Action: This is an isolated error on the part of the Financial Aid Office staff. In review of the new Pell grant calculations staff members misinterpreted summer Pell regulations. During implementation of the new system software, Pell calculations were believed to be automatic. In subsequent years staff members will review policies for summer programs, participate in training sessions, seminars and workshops, to ensure they understand the rules, regulations and guidelines as they apply to enrollment intensity regulations, in order to manually adjust Pell amounts for part-time students. Person Responsible for Corrective Action Plan: Amanda McLaughlin, Assistant Vice President of Financial Aid; Miranda Lumley Associate Director of Financial Aid Anticipated Date of Completion: Fall of 2025 prior to end of the term and awarding aid for upcoming semesters in the 2025-26 award year.

Condition: The University did not have controls in place to ensure that the required due diligence review was completed in the last two-year period related to the current established contract. Planned Corrective Action: In order to ensure that the terms of the consumer accounts offered through UC’s Tier 1 banking agreement are not inconsistent with the best financial interest of students who choose to open an account, UC Campus Services will, at a minimum, every 2 years, beginning October 2025: a. Conduct a due diligence review to ascertain whether the fees imposed under the current agreement are consistent with or below prevailing market rates. a. This will be accomplished by downloading and comparing “consumer schedule of fees” documents from UC’s current provider as well as several local competitors (e.g. US Bank, Fifth Third Bank, Chase Bank, Superior Credit Union). b. Ensure that termination provisions are maintained in the active agreement. These provisions are listed in the current agreement under Exhibit G. 4. (g). (1). In addition, the university will organize a Title IV compliance working group to meet monthly to review any communications or new requirements published by the U.S. Department of ED, State of Ohio, or other regulatory agencies. This core working group will be comprised of members of the Student Financial Aid Office, the Office of the Bursar, and the Office of the Controller, the three offices primarily responsible for awarding, disbursing, and drawing down funds related to the Title IV programs. This group will be responsible for communicating any changes to institutional responsibilities to other university partners who may need to review or revise policies and procedures based on the regulatory changes. Contact person responsible for corrective action: Neal Stark for the specific remedy for the due diligence review, Leigh Jackson for the compliance working group. Anticipated Completion Date: 10/31/2025 and every 2 years thereafter

Finding 2025-003: In order to ensure proper compliance with the return of Title IV Funds, the CFO and Controller have updated the return to Title IV (R2T 4) workbook to include the correct rounding method per federal regulation and the Federal Student Aid Handbook. Documentation of each calculation will now include evidence of rounding verification as part of the R2T4 process. Additionally, the Controller will obtain annual training on current Department of Education requirements, including proper rounding and calculation methodologies.