Corrective Action Plans

2025-001 Student Financial Aid Cluster – Assistance Listing Numbers 84.063 and 84.268 In general, Cheyney University continues its trajectory of cross-functional and interrelated institutional improvements, particularly those impacting the National Student Loan Data System (NSLDS) that is reported through National Student Clearinghouse (NSC). Cited in the CLA Single Audit, nonetheless, are instances of inaccurate, late, or not reported enrollment and program level data to NSLDS. This response is intended to explain these reporting deficiencies and offer a corrective plan of action including timelines. Point Of Contact: • Dr. Denise Pearson, Provost – dpearson@cheyney.edu • Stephanie Stevens, Associate Registrar – sstevens@cheyney.edu • Jean Dixon, Associate Registrar – jedixon@cheyney.edu Explanations: This section represents Cheyney University’s effort to explain the causes for CLA Single Audit finding. Although the reporting deficiencies span multiple years, it is instructive to note that they are attributed to various and differing circumstances. While Cheyney University was on HCM2, the delay in Claims processing impacted the reporting in Common Origination and Disbursement (COD) and the reporting to NSLDS. The delays in approved claims caused an impact on NSLDS postings for enrollment reporting. This required Cheyney University administration to transfer from NSC to manual enrollment entry into NSLDS. The idea was to manually enter students’ records in NSLDS so that students’ enrollment could be reported more quickly. This is referenced in Single Audit Report, June 30, 2022; page 132. Cheyney is acutely focused on working toward compliance with NSLDS reporting requirements. Through this lens, it was discovered that during the 2024-2025 conversion to the Ellucian Banner system certain decisions were made regarding the conversion of student academic histories. During the research of errors and warning records received from the NSC upload, it was determined that program level information was not properly ported over to the new system. Cheyney University is pursuing a corrective course of action to improve this data to ensure accuracy in reporting. In May 2025, Cheyney University and NSC amended its agreement resulting in a shift in reporting student enrollment and program level data back to NSC from NSLDS that resulted in an additional delay in reporting. Due to these circumstances, the university dedicated significant resources to building capacity and capability in the Office of the Registrar, the functional area responsible for NSLDS reporting. These resources are being deployed in a variety of ways as noted in the Corrective Action Plan below. Corrective Action Plan Overview: 1. Hired a season University Registrar with superior, proven, leadership and technical skills. Emphasis has been placed on performance metrics that align with operational goals and objectives. STATUS: Anticipated March 2026. 2. Targeted professional development for Office of the Registrar and other staff including Banner training, NSC/NSLDS Reporting, and other dependencies. STATUS: Ongoing 3. Establishment of a dedicated compliance unit to support the university’s policies, standards, and procedures ecosystem. STATUS: Completed December 2025. 4. Hired a dedicated Chief Information and Technology Officer (as opposed to the use of third-party vendors). STATUS: Completed, March 2026. 5. Prioritized strengthening communication and collaboration with other enrollment management areas to establish cross-functional responsibilities and timelines (e.g., financial aid, admissions, and bursar offices). STATUS: Ongoing. Key Performance Indicators: During the Spring and Fall 2026 semesters: 1. The University Registrar will show outcomes-driven leadership practices that foster improved departmental performance, including audit citations. 2. Registrar and adjacent staff will demonstrate comprehensive capability and capacity in all areas related to NSC and NSLDS operations and reporting on a timely schedule. An organizational calendar is being developed to ensure this goal is met. 3. Utilizing the NSLDS instructional guide, train the Registrar and adjacent staff to improve the knowledge of the step-by-step process procedures for enrollment reporting, error correction, warning management, and internal audit review of NSLDS files. 4. Develop NSC instructional guide on reporting, error and warning management, and submission of monthly reporting data. 5. The Director of Policy and Compliance will collaborate with the Office of the Provost and Registrar Office staff to create and maintain a policy, procedures, and standards environment that supports operational excellence and efficiency (including more timely and accurate reporting). 6. The Chief Information and Technology Officer will conduct a comprehensive assessment of technology needs in the Office of the Registrar, including outcomes driven recommendations. 7. The Provost will establish Office of the Registrar protocols for collaboration with the Office of Communications to reinforce clarity, consistency, and transparency in all related matters. 8. The University Registrar will demonstrate that all staff have the requisite knowledge and skills to effectively mitigate future reporting deficiencies. Cheyney University acknowledges and affirms that this corrective action will be implemented, assessed, and become a standard operating procedure.

Recommendation: The University should review its reporting procedures to ensure that students’ statuses are timely reported to NSLDS as required by Federal regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Increased frequency of NSC Submissions. Completing the error files returned to NSC quickly within the first 1-4 days of receipt after sending the files back. • We met with another PASSHE school on 4/22/25 and they helped us to strategize ensuring we meet the 60-day window for withdrawals by individually updating the withdrawal information in NSC on a weekly basis using our withdrawal report to identify each student withdrawal between our regular submissions. (Because we met with them so late in the audit cycle, we were not able to correct course for FY25 in time.) • We have adjusted our degree verification timeline, ensuring that the large bulk of our degree verification submission to NSC is completed within 2 weeks of the end of the graduating semester, ensuring that the bulk of our graduating students are moved from NSC to NSLDS sooner. • We updated our change of major policy to ensure that students are not changing majors after the end of the drop/add period. Prohibiting mid-semester major changes for the current semester will greatly reduce the number of status change errors reflected in NSC. This cleaner approach ensures less risk of error or delay related to volume. This was formalized with KU Policy ACA-029, approved at Senate on 9/4/25. Name(s) of the contact person(s) responsible for corrective action: Ben Trout, Registrar Planned completion date for corrective action plan: June 30, 2026

Centre College has further evaluated its policies and procedures for student status change reporting. We are implementing an additional student enrollment reporting from our Registrar to NSC/NSLDS during our non-compulsory January term to ensure timely reporting of students who graduate or withdraw between our final fall and initial spring semester reports. We will also provide ongoing training for sustained compliane with applicable procedures and monitor the additional reporting cycle during implementation.

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) monthly and perform monthly data 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 and visibility of reporting issues in the future. Timeline for Implementation of Corrective Action Plan: The procedure was implemented starting with the Spring 2026 semester and has continued since. Contact Person: Alex Jean-Jacques, Director of Financial Aid Operations

Student Financial Assistance Cluster – Assistance Listing No. 84.033 Recommendation: We recommend the University review current processes for calculating and tracking the students employed in community service activities for its Federal Work Study funds to meet the minimum 7% requirement. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University is prepared to return the FY25 FWS Unspent portion of the 7% Community Service required spending (7% of Final FWS Funding of $742,211 = $51,954.77 (rounded to $51,955) [Community Service spending requirement] minus $25,061 (FWS funds spent in community service as reported on FISAP) = $26,894 (Unspent portion of 7% to be returned to ED). Since the pandemic year, ISU’s off-campus (community service) participation has been dwindling and overall FWS participation has suffered since many students and employers are opting to be involved in the University’s Career Path Internship (CPI) program over FWS. Due to the struggles in recent years to meet the 7% Community Service requirement, ISU has been applying for a waiver of the Community Service requirement but thus far our waiver requests have been denied. The Financial Aid Office is reviewing current processes related to tracking FWS Community Service spending and partnering with the Career Center to proactively identify off-campus participants and looking at ways to cooperate with the University’s CPI program participants who are FWS-eligible and who are working in Community Service activities and plan to expand on-campus FWS Community Service opportunities to meet the minimum 7% community service requirement. Name(s) of the contact person(s) responsible for corrective action: James Martin, Director of Financial Aid and Katheryn Wareing, Senior Accountant for Financial Aid/FWS Administrator Planned completion date for corrective action plan: 08/24/2026

Student Financial Assistance Cluster – Assistance Listing No. 84.033, 84.268, 84.063 & 84.007 Recommendation: We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Reason for 2024-004 Finding’s Recurrence: Related to case identified where a corrected Last Date of Attendance (Effective Date in Banner System on SFAWDRL input by the Financial Aid Office for a fully online student during the Unofficial Withdrawal [post term] Return of Title IV processing) was not carried over to Status Date in Banner maintained by the Registrar’s Office and to NSC/NSLDS so that all are reporting the accurate Last Date of Attendance, the University found that corrected dates during the semester aligned and were being reported to NSC/NSLDS in a timely manner, but that corrected dates after end of term were not being transmitted to NSC and NSLDS. Related to case identified of not reporting Graduated status to NSLDS in a timely manner: Typically, it takes approximately 2–3 weeks after commencement to clear degree audits and begin awarding degrees, as commencement occurs before final grades are released. The Graduate-only upload to NSC was completed on May 21, 2025.However, due to limitations with the National Student Clearinghouse (NSC) system, which does not accept multiple awards being posted simultaneously, we received an error report affecting approximately 60% of our graduates. Records included in this report must be corrected manually, which is a time-consuming process. We actively work to correct these records as quickly as possible within our current human resource limitations. The corrected error file related to the 2025-002 finding was uploaded to NSC on July 11, 2025, and sent to NSLDS on 7/12/2025. Action taken in response to finding: The University reviewed its procedures and implemented steps in our Unofficial Withdrawal [post term] Return of Title IV business process to include an email communication plan between the Financial Aid staff and the Office of the Registrar along with documentation sharing and added review steps to ensure the post-term corrected Last Date of Attendance is updated in all affected institutional and federal systems in a timely manner. The Office of the Registrar will correct errors returned from NSC within four weeks of receiving the file. To ensure this task is completed in a timely manner, we will allocate additional human resources as needed. Name(s) of the contact person(s) responsible for corrective action: Hala Abou Arraj, Registrar, and Jody Finnegan, Associate Director of Financial Aid Completion date for corrective action plan: 08/06/2025

Student Financial Assistance Cluster – Assistance Listing No. 84.268 Recommendation: We recommend the University review reporting processes to ensure all students that require exit counseling receive it in a timely manner. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University reviewed its procedures and reporting processes and added calendar reminders to run queries around our census day each term (since the case identified in the audit was due to a timing issue of a student’s aid period revision and when our automated Exit counseling processes are turned on) to find students who were missed by our automated processes for the adding of EXIT tracking requirement and ensuring timely notifications to the students. Name(s) of the contact person(s) responsible for corrective action James Martin, Director of Financial Aid and Jody Finnegan, Associate Director of Financial Aid Completion date for corrective action plan: 8/12/2025

Finding Number: 2025-004 Condition: The University did not provide notifications to certain students related to Pell grants. Planned Corrective Action: During the implementation of Anthology Student, the University did not receive sufficient system configuration support or training from Anthology to properly establish automated Financial Aid Offer and Title IV notification workflows. As a result, the institution did not have the required functionality in place to automatically notify students of their Pell Grant eligibility, scheduled disbursement amounts, and the timing of those disbursements as required under 34 CFR 668.165(a). This lack of configuration and training created gaps in communication and ultimately led to instances in which students did not receive timely notifications before Pell Grant funds were disbursed. Once the University identified these deficiencies, immediate corrective measures were implemented to ensure short-term compliance. Beginning in May 2025, the Financial Aid Office instituted a formal manual notification process. Staff now generate Packaging Status and Disbursement reports on a weekly basis, and these reports are reviewed and acted upon at least bi-weekly to ensure that all upcoming disbursements are captured. Individualized Title IV and Pell Grant notifications are sent to students prior to the crediting of funds. To strengthen internal controls, a secondary review was added so that another staff member verifies that all required notifications have been issued before any Title IV disbursement occurs. These interim procedures and safeguards will remain in effect until the automated notification workflow is fully configured, tested, and implemented. Contact person responsible for corrective action: Chad Curley, Director of Financial Aid Anticipated Completion Date: Corrective Action is currently implemented, starting May 2025

Finding Number: 2025-003 Condition: The University did not have controls in place to ensure appropriate reporting to COD. Planned Corrective Action: The primary cause of this issue was the significant lack of training and support provided during the implementation of Anthology Student. Similar to the challenges experienced with Return to Title IV (R2T4) processing, University staff did not receive adequate instruction on how to perform Title IV reconciliations within the system or how to extract the data needed to compare internal records with COD. This lack of foundational training made it extremely difficult for staff to understand required reconciliation procedures, identify discrepancies, or troubleshoot system-related issues. In addition, the technical limitations of Anthology Student significantly hindered the University’s ability to perform timely and accurate reconciliations. Anthology Student does not provide a comprehensive or efficient reporting tool that allows users to pull Title IV awarding and disbursement data in a format that aligns with COD records. Staff must manually compile information from multiple system screens and reports, a process that takes several hours and still does not produce a clean, fully reconcilable output. Discussions with other Anthology client institutions confirmed that they are experiencing similar challenges with timely reconciliations due to the system’s reporting limitations. Compounding these reporting challenges, the batch transmission functionality between Anthology Student and COD has been unreliable. Files routinely fail or become “stuck” during transmission, but Anthology offers limited visibility into batch processing status. Until February 2026, the University relied on a system report to identify failed or stalled batches; however, an Anthology system update removed this report and the capability altogether. Without access to this tool, staff have had little ability to monitor or verify successful COD transmission, further complicating reconciliation efforts. Another contributing factor is staffing capacity. The Financial Aid Office has limited personnel, and the extensive time required to manually pull data, consolidate reports, and investigate discrepancies has made it challenging to dedicate the uninterrupted hours required for reconciliation—especially without adequate system training or tools. The University is taking the following steps to address this finding: 1. Scheduled Reconciliation Intervals: Calendar reminders and dedicated appointment blocks will be established every 30–60 days to ensure staff have protected time to complete Title IV reconciliations. 2. Staff Training and Support: The Financial Aid Office will continue working with Anthology Support to obtain the training necessary to understand where and how to locate all required Title IV data within the system. We will also pursue additional training and documentation from Ellucian/Anthology on proper reconciliation procedures. 3. Enhanced Manual Oversight: Until system reliability improves, staff will continue performing manual reviews of Title IV disbursements, adjustments, and COD submissions to confirm accuracy and identify unresolved transmission issues. These actions will remain in place until Anthology Student provides reliable reporting capabilities and complete, consistent training, enabling the University to perform reconciliations accurately and on time. Contact person responsible for corrective action: Chad Curley, Director of Financial Aid Anticipated Completion Date: Scheduled reconciliation intervals were implemented beginning with the Spring 2026 semester on February 19, 2026. Staff training and the pursuit of additional system support will continue on an ongoing basis as part of the University’s continuous improvement efforts.

Finding Number: 2025-002 Condition: The University did not return all Title IV funds in a timely manner to the Department of Education for certain students who withdrew during the year. Planned Corrective Action: The primary underlying cause of this issues was the significant lack of training, guidance, and onboarding support provided by Anthology during the implementation of the Anthology Student system. Prior to golive, the University was unable to fully test the Title IV awarding, disbursing, and adjustment processes because file transmissions to COD (Common Origination and Disbursement) can only be executed using live data. This limitation prevented staff from validating system behavior in a testing environment and further hindered the understanding of the required processes, procedures, and communication workflows between Anthology Student and COD. As a result, staff lacked critical knowledge needed to ensure Title IV transactions—including those tied to Return to Title IV (R2T4) calculations—were correctly generated and transmitted. Corrective action has already been implemented. The Financial Aid Office now manually reviews and verifies all Title IV awarding, disbursement, and adjustment transactions—including those related to R2T4—to ensure successful submission to COD. Once the R2T4 calculation has been completed in COD, the Financial Aid Advisor manually updates the student’s account in Anthology Student. The Business Office then posts the corresponding adjustment to the student ledger. After the Business Office posts the Title IV activity, the Financial Aid Advisor manually processes the related adjustments and disbursements through COD to ensure the timely return and/or disbursement of funds associated with the R2T4 calculation. These manual oversight procedures will remain in place until the University receives additional and adequate training from Anthology that ensures consistent and reliable electronic transmission between Anthology Student and COD. Contact person responsible for corrective action: Chad Curley, Director of Financial Aid Anticipated Completion Date: Corrective Action Plan was implemented in February 2025

Finding Number: 2025-001 Condition: The University of Rio Grande did not report student status changes accurately for certain students who withdrew during the year. Planned Corrective Action: The Director of Financial Aid and the Registrar will establish a formal communication and notification process to review enrollment statuses and status changes for all students who begin attendance each semester. Recurring meetings and calendar reminders will be scheduled every 30 days to ensure this review is conducted consistently and collaboratively. The University is also in the process of updating its student withdrawal process from a paper/PDF form to a fully electronic submission process. This new system will automatically notify all pertinent departments when a student initiates a withdrawal, ensuring timely communication and reducing the likelihood of missed or delayed reporting. Implementing this electronic workflow will further strengthen internal controls and directly support the corrective action plan. The Director of Financial Aid will receive direct access to the National Student Clearinghouse and will be enrolled in automated email alerts to support timely and accurate reporting of all enrollment changes. In the event the Director of Financial Aid is unavailable for the scheduled 30-day review, a designated member of the Financial Aid Office will participate in the review to ensure the process is completed without interruption. Contact person responsible for corrective action: Chad Curley, Director of Financial Aid Anticipated Completion Date: Corrective action implemented on 2/13/2026. The electronic withdrawal process is set to be implemented by end of May 2026.

Finding: 2025-001: Special Tests and Provisions – Eligibility – Significant Deficiency in Internal Control over Compliance Corrective Action Plan – The University conducted a review of affected students and identified 19 additional students with enrollment intensity that was incorrectly calculated. The University has returned a total of $2,448 to the Pell Grant program and has written off the corresponding balances on the affected students’ ledgers. In January 2025, the University fully implemented a new, integrated Student Information and Financial Aid System that automates enrollment intensity calculations based on real-time data from the Registrar’s Office. This eliminates manual entry and ensures Pell Grant disbursements are automatically and accurately calculated. There is no option to manually change the Pell enrollment intensity or award amount in the new system. The Financial Aid staff involved in Pell packaging and processing have been retrained on enrollment intensity calculations and system functionality. Contact Person Responsible for Corrective Action: Sally Mickelson, Director of Financial Aid Completion Date: November 13,2025

Management is formalizing written enrollment reporting procedures to ensure timely and accurate reporting to NSLDS. Until implementation of a new student information system, enrollment reporting will continue to be performed manually, with monthly supervisory review and documentation of submissions. Automation of enrollment reporting is expected upon implementation of the new SIS.

Management has implemented formal monthly reconciliation procedures between the Financial Aid Office, Registrar, and Accounting Department to ensure the accuracy of the FISAP data. Reconciliations include review of enrollment status, aid disbursements, and supporting documentation, with documented supervisory review and retention of reconciliation evidence.

Management has implemented additional review procedures over Pell Grant calculations, including documented manual recalculations and supervisory approval prior to disbursement. These controls will remain in place until Pell calculations are automated through the planned SIS implementation.

Finding 2025-004 Name of Responsible Individual: Cinnamon Bradley, Assoc Dean Student Affairs Corrective Action: The Registrar prepares the program calendars with input from the programs on an annual basis. MSM has a diversity of programs with different start and end dates. We understand that this needs to be accurately reflected in our calendars and in the Banner system or other enrollment platform. Academic calendars will be reviewed by the Registrar and program staff on an annual basis. Any changes to the academic calendars will need to be communicated to all members of the team. Updated calendars will be posted annually on the website and in the student handbook. After the Registrar’s Office confirms the academic start date and academic end date, Student Fiscal Affairs will continue to input this information in our Student Information System Banner to allow accuracy in our student records sent to the Department of Education Common Origination and Disbursement. If there is a change in the academic start dates and/or academic end dates, the Registrar’s Office will notify Student Fiscal Affairs, Admissions, and Student Accounts to allow for updates within the institution. Anticipated Completion Date: March 1, 2026

Finding 2025-001 Name of Responsible Individual: Cinnamon Bradley, Assoc Dean Student Affairs Corrective Action: Due in part to frequent turnover in the Registrar's Office, there have been reporting errors in Clearinghouse which have been reflected in NSLDS. In addition to changes in personnel, the Office of the Dean will provide joint oversight with the Office of Student Affairs on matters impacting regulatory requirements. Specifically, there will be a monthly review of the NSLDS database on the second Monday of each month with a regular tracking system. The Registrar, Associate Dean of Students and Dean’s Office representative will provide quarterly “audits” to the Dean on accuracy of data and reporting compliance. Annual NSLDS training, appropriate to the role, will be provided for all team members in the Registrar's Office and others as appropriate. Anticipated Completion Date: March 31, 2026

Finding No. 2025-001 Corrective Action Plan: The University concurs with this finding. The Financial Aid office is in the process of tightening its policies and procedures to identify all students subject to the required exit counseling, with the goal of delivering said counseling within the prescribed 30-day window. Responsible Official: Dane Fuhrman, CFO Anticipated Completion Date: June 2026

Finding 2025-001: Special Tests and Provisions: Enrollment Reporting Context/Condition: Of the 40 students selected for enrollment reporting testing, one (1) student graduation was reported to NSLDS outside the maximum 60-day window. Recommendation: The auditor recommended that the College review and update internal controls to ensure student enrollment status in the National Student Loan Data System (NSLDS) is updated in a timely manner to ensure compliance with Federal requirements. Persons Responsible for Corrective Action: Registrar Liz Force Planned Corrective Action: The Registrar will update NSLDS reporting processes and controls to include detection controls to ensure all student graduations, including those occurring outside the traditional reporting window, are accurately and timely reported to the NSLDS within the maximum 60-day window. Anticipated Completion Date: December 31, 2025

Develop a Strategic Plan of Action ensuring data accuracy and timely transmission of Enrollment Status Reports & Degree Verification Reports to the National Student Clearinghouse for further submission to NSLDS. The plan will establish a structured, repeatable process to:  Validate the accuracy of student enrollment and degree data prior to NSCH submission.  Ensure timely transmission of Enrollment Status Reports (ESRs) and Degree Verification Reports (DVRs).  Strengthen internal controls, documentation, and audit readiness with system-generated audit reports and dual review.  Improve communication among Registrar, IT, Institutional Research, and Financial Aid. Susan W. Gibson, University Registrar James Stotts, Associate VP Financial Aid Tansha Gillins, Principal Analyst June 30, 2026 Due to BANNER SaaS system upgrade in progress, this action will be completed by June 30, 2026, to allow for report writing in the new reporting tool postimplementation Immediate action: To ensure timely reporting to National Student Clearinghouse and NSLDS, reports will be generated bi-weekly. ISE scheduler will be used to extract baseline data from BANNER for uploading the Enrollment Status Report to National Student Clearing biweekly with off-cycle adjustments as needed. Initial errors will be identified and corrected using a dual-review process before uploading the report to NSCH. Martha Henderson, Associate Registrar Tansha Gillins, Principal Analyst On-going activity Beginning March 30, 2026 The Degree Verification Report will be generated monthly to ensure that graduation status is reported within the timeframe required by NSLDS. Graduation lists will be forwarded to the Office of Financial Aid for dual review and validation to confirm the accuracy of the data and the timeliness of certification to NSLDS. Martha Henderson, Associate Registrar Palmira Wakhisi, Financial Aid On-going activity Beginning May 20, 2026

Finding Summary During the recent Federal and State Single Audit report, completed by WIPFLI, it was identified that the institution did not accurately report Last Date of Attendance (LDA) information to the National Student Loan Data System (NSLDS) for the unofficial withdrawal population. Specifically, adjusted end dates were not being properly communicated to the National Student Clearinghouse (NSC), which is responsible for enrollment reporting to NSLDS. As a result, students’ withdrawal dates were not accurately reflected. Issue Identified Upon notification of the finding, the Financial Aid and Registration & Records offices met to review existing procedures. It was determined that when grades of “F” were assigned, the LDA was updated in our ERP. Since internal systems had the updated last day of attendance, R2T4 calculations were done correctly. However, an enrollment file was not resubmitted to NSC to reflect the revised LDA for enrollment reporting to NSLDS. Corrective Action Taken The institution has implemented the following corrective measures to assure updated Reporting to NSC: o Once the correct LDA is confirmed by the Financial Aid Office the Registrar’s Office updates the student record in the student information system. o The updated LDA is reported to the National Student Clearinghouse (NSC), which in turn updates NSLDS. Internal Controls Implemented To prevent recurrence, the following controls are now in place:  Written procedures have been updated to clearly define: o Roles and responsibilities of Financial Aid and Registrar staff o Timeline for reporting updates to NSC  Staff training was conducted with both departments to ensure understanding of federal reporting requirements. Implementation Date The revised process was implemented immediately upon identification of the issue and is fully operational. Fall 2025 unofficial withdrawals were accurately updated to NSC on 1/15/26. Persons Responsible: Jennifer Anderegg, Dean of Strategic Enrollment Kim Yoder, Director of Financial Aid Jess Schwartz, Registrar

Finding 2025-006 - U.S. Department of Education (USDE, Title IV Student Financial Aid Programs (significant deficiency): Information on the federal program: Federal Direct Student Loans, FAL No. 84.268, June 30, 2025; Federal Pell Grant Program, FAL No. 84. 063, June 30, 2025; Federal Supplemental Educational Opportunity Grant, FAL No. 84.007, June 30, 2025; Federal Work-Study Program, FAL No. 84.033, June 30, 2025. Condition - During review of enrollment reporting procedures, we noted that one (1) student record requested for testing was not provided, and two (2) sampled student records were not updated to reflect current enrollment status changes in NSLDS. As a result, the College could not demonstrate that enrollment reporting was complete, accurate, or timely for the students tested. Views of Responsible Officials –The College accepts the recommendation. The Institution has reviewed the finding and acknowledges that one student record was not submitted for review. The Institution has provided the NSLDS enrollment verification for that student. For the remaining two students, enrollment reporting was not updated within the required 30-day timeframe. The Institution has since updated their enrollment statuses in NSLDS and has provided updated records for review. The Institution respectfully requests that the finding be formally updated, if applicable, upon the auditor’s review and acceptance of all submitted NSLDS enrollment documentation. In response, the institution has updated its processes and procedures regarding student enrollment reporting with NSLDS, by ensuring accurate enrollments status matches the student transcript. Along with continuing to update within the 30 days established timeframe within NSLDS. Responsible Officials -The Registrar, the Financial Aid Office under the direction of the Vice President of Student Affairs, and Business Office under the direction of the Vice President for Business and Finance plans to have the finding resolved by its next fiscal year end audit (between July – October 2026). The College is aware of the need to review and mitigate compliance risks in this area and will use the described corrective action plan to reduce those risks and eliminate the potential for future audit findings.

Finding 2025-005 - U.S. Department of Education (USDE, Title IV Student Financial Aid Programs (significant deficiency): Information on the federal program: Federal Direct Student Loans, FAL No. 84.268, June 30, 2025; Federal Pell Grant Program, FAL No. 84. 063, June 30, 2025; Federal Supplemental Educational Opportunity Grant, FAL No. 84.007, June 30, 2025; Federal Work-Study Program, FAL No. 84.033, June 30, 2025. Condition - Testing of student withdrawals revealed that for three (3) students, Title IV funds identified as unearned through the Return of Title IV (R2T4) process were not returned to the U.S. Department of Education within the required timeframe. The returns were made between 209 and 349 days after the College’s date of determination (DOD), which is well beyond the 45-day requirement established by federal regulations. Views of Responsible Officials – The College accepts the recommendation. The Institution has reviewed the finding and acknowledges that one student record was not submitted for review. The Institution has provided the NSLDS enrollment verification for that student. For the remaining two students, enrollment reporting was not updated within the required 30-day timeframe. The Institution has since updated their enrollment statuses in NSLDS and has provided updated records for review. The Institution respectfully requests that the finding be formally updated, if applicable, upon the auditor’s review and acceptance of all submitted NSLDS enrollment documentation. In response, the institution has updated its processes and procedures regarding student enrollment reporting with NSLDS, by ensuring accurate enrollments status matches the student transcript. Along with continuing to update within the 30 days established timeframe within NSLDS. Responsible Officials -The Registrar, the Financial Aid Office under the direction of the Vice President of Student Affairs, and Business Office under the direction of the Vice President for Business and Finance plan to have the finding resolved by its next fiscal year end audit (between July – October 2026). The College is aware of the need to review and mitigate compliance risks in this area and will use the described corrective action plan to reduce those risks and eliminate the potential for future audit findings.

Finding 2025-004- U.S. Department of Education (USDE, Title IV Student Financial Aid Programs (significant deficiency): Information on the federal program: Federal Direct Student Loans, FAL No. 84.268, June 30, 2025; Federal Pell Grant Program, FAL No. 84. 063, June 30, 2025; Federal Supplemental Educational Opportunity Grant, FAL No. 84.007, June 30, 2025; Federal Work-Study Program, FAL No. 84.033, June 30, 2025. Failure to Provide Student-Level Documentation to Support FISAP Reporting (significant deficiency) Condition - The College did not provide the requested student-level records (ISIRs) to substantiate the number of eligible applicants reported on the FISAP submitted to the U.S. Department of Education. As a result, we were unable to verify the accuracy and completeness of the eligible applicant data reported for the applicable award year. Views of Responsible Officials - The College accepts the recommendation. The institution acknowledges that this request was initially overlooked during the audit review. The requested sample testing of ISIRs has now been completed, and a total of 34 ISIR records have been provided and uploaded to the shared file for the auditor’s review. The institution respectfully requests a formal update to this finding (if applicable), once all submitted ISIR documents have been reviewed and deemed acceptable by the auditor Responsible Officials - The Financial Aid Office under the direction of the Vice President of Student Affairs plans (to have the finding resolved by its next fiscal year end audit (between July – October 2026). The College is aware of the need to review and mitigate compliance risks in this area and will use the described corrective action plan to reduce those risks and eliminate the potential for future audit findings.

Finding 2025-003 - U.S. Department of Education (USDE, Title IV Student Financial Aid Programs (significant deficiency): Information on the federal program: Federal Direct Student Loans, FAL No. 84.268, June 30, 2025; Federal Pell Grant Program, FAL No. 84. 063, June 30, 2025; Federal Supplemental Educational Opportunity Grant, FAL No. 84.007, June 30, 2025; Federal Work-Study Program, FAL No. 84.033, June 30, 2025. Condition – During testing of student account activity, we identified that nine (9) out of sixty (60) sampled students had Title IV -created credit balances that remained on their accounts for more than 14 days without being released to the student or parent. Views of Responsible Officials - The College accepts the recommendation. The institution has reviewed the audit finding and acknowledges that student refunds were not consistently issued within the required 14-day timeframe due to students’ incomplete admissions requirements. The institution recognizes this as a compliance deficiency and has implemented revised processes and internal controls to ensure timely and compliant issuance of student refunds going forward. Effective immediately, the Registrar’s Office provides a weekly roster of students with incomplete admission requirements to the Financial Aid Office and the Business Office prior to the release of federal student aid. These offices meet weekly to review the roster, ensure timely communication, and document all actions taken. This control ensures that federal student aid is not disbursed when admissions requirements have not been met and prevents the creation of improper student credit balances. Under the revised refund process, the Business Office staff identify student credit balances and prepare refund requests. These requests are reviewed by the Registrar’s Office to reconfirm when admission requirements have been met and by the Financial Aid Office to confirm that federal student aid has been properly originated and disbursed through the Common Origination and Disbursement (COD) system. If it is determined that a student’s admissions requirements are incomplete and a refund has been created, the Business Office notifies the Financial Aid Office to cancel all applicable federal student aid and return the funds to the U.S. Department of Education through COD. When a student’s admissions requirements have been met, then the Business Office completes the refund process by transmitting the approved refund file to the institution’s third-party refund vendor and submitting funds for release to students. These revised procedures strengthen oversight, improve interdepartmental coordination, and ensure compliance with federal refund timelines. College administrators for each department (Vice President for Student Affairs and Vice President for Business and Finance) will be responsible for informing staff of changes in campus operations that may have an impact on their ability to process refunds. Responsible Officials - The Registrar, the Financial Aid Office under the direction of the Vice President of Student Affairs, and Business Office under the direction of the Vice President for Business and Finance plan to have the finding resolved by its next fiscal year end audit (between July – October 2026). The College is aware of the need to review and mitigate compliance risks in this area and will use the described corrective action plan to reduce those risks and eliminate the potential for future audit findings.