Corrective Action Plans

Finding 2025-002 - 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 - Based on documentation provided for the 2024–2025 award year, the College disbursed Title IV funds to a student whose ISIR contained Comment Code 325, indicating that the student’s unaccompanied homeless youth status required resolution prior to awarding and disbursing aid. The College did not provide documentation from an authorized entity, nor evidence of a documented Financial Aid Administrator case-by-case determination, to support the student’s independent status. As a result, the student’s dependency status remained unresolved at the time Title IV funds were disbursed. Views of Responsible Officials – The College accepts the recommendation Although a recommendation was noted, the Financial Aid Management System (FAMS) was not programmed as expected for the 2024– 2025 FAFSA application year. The issue was anticipated to be addressed by the third-party vendor through system updates; however, because of the programming oversight, no system flag was generated to request self-supporting documentation or validation of a student’s homelessness or risk of homelessness. In addition, the Department of Education’s FAFSA application did not generate a comment code requiring further action on the student’s record. The Institution has since worked with its third-party vendor to correct the programming oversight to ensure that required documentation is requested for students who indicate homelessness or risk of homelessness. Additionally, at the direction of the FAMS vendor, the Financial Aid Office implemented an internal edit to ensure a system flag alerts staff when documentation is required to resolve such cases. With these corrections, the conditions that caused the error have been addressed. 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).To ensure ongoing compliance, the Financial Aid Office will monitor student records for appropriate flags and required documentation. 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 2025-001 - 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– It was noted that the College did not perform the required reconciliations between: a. The Student Financial Aid (SFA) Office records, b. The Business Office/General Ledger (SEFA), and c. The Common Origination and Disbursement (COD) System. In additional, unreconciled figures from the College’s internal records were used in preparing and submitting the Fiscal Operations Report and Application to Participate (FISAP) submitted to the U.S. Department of Education for the most recent award year. As a result, the College could not demonstrate that Title IV activity reported to ED was accurate or fully supported. Subsequent to the identification of this exception, management provided additional documentation intended to support reconciliation activities; however, the documentation did not demonstrate that reconciliations were performed timely or as part of established internal control procedures during the period under audit. Views of Responsible Officials - The College accepts the recommendation. Beginning with future monthly Title IV reconciliations, the Institution will complete all required reconciliations no later than five (5) days after the COD reconciliation reports are made available. The Financial Aid Office will provide the reports to the Business Office for reconciliation. Following reconciliation by the Business Office, the reports will be returned to the Financial Aid Office when resolution of discrepancies is required. Once discrepancies are resolved, the Financial Aid Office will submit the updated reports back to the Business Office, and the resolution will be documented. If no resolution is required, the reports will be retained for the applicable month. All monthly reconciliations will be maintained and made available for review during the yearend audit by the Business Office 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.

Student Financial Assistance Cluster Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: As a corrective action, the unit has strengthened internal controls by implementing a dual-review process for all submissions. Following Nikki Stork’s promotion to assistant registrar, submissions are now reviewed by two qualified staff members prior to final approval, providing appropriate segregation of duties and an added level of oversight. Although the specific cause of the incorrect date entry could not be conclusively identified, this enhanced review process mitigates the risk of similar errors and supports continued compliance with federal program requirements. Name(s) of the contact person(s) responsible for corrective action: Erin Moore Planned completion date for corrective action plan: January 30, 2026

2025-003 - Student Financial Aid Cluster - (a) Federal Supplemental Educational Opportunity Grants (b) Federal Work Study Program (c) Federal Perkins Loan Program - Federal Capital Contributions (d) Federal Pell Grant Program (e) Federal Direct Student Loans (f) Teacher Education Assistance for College and Higher Education (TEACH), Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.038 (d) 84.063 (e) 84.268 (f) 84.379 - Year Ended June 30, 2025 Condition: We tested forty files and enrollment statuses were incorrectly reported to the National Student Loan Data System (NSLDS) for three students (7.5%). We consider this to be an instance of noncompliance relating to Special Tests and Provisions compliance requirement and is not a repeat finding. Statistical sampling was not used in making sample selections. Management Response: We agree with this finding. Corrective Action Plan: Review of new academic programs that allow graduate courses for undergraduate credit will be complete to ensure that enrollment is reported correctly. This specific case was for our MSAT program. The students involved were in their transition year from undergrad to grad. Graduate courses were not coded to report as undergrad towards full time status. Responsible Person: Registrar Implementation Date: January 2026

2025-002 - Student Financial Aid Cluster - (a) Federal Supplemental Educational Opportunity Grants (b) Federal Work Study Program (c) Federal Perkins Loan Program - Federal Capital Contributions (d) Federal Pell Grant Program (e) Federal Direct Student Loans (f) Teacher Education Assistance for College and Higher Education (TEACH), Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.038 (d) 84.063 (e) 84.268 (f) 84.379 - Year Ended June 30, 2025 Condition: The University did not accurately complete refund calculations for official withdrawals. In review of the Fall 2024 official calculations the number of days in the break was not calculated correctly, resulting in the incorrect number of days in the calculation. The Title IV amounts for all withdrawn students were incorrectly calculated and returned for 5 out of the population of 5 (100%) Fall official withdrawal calculations. However, the No Passing Grade Sample for Fall unofficial withdrawals total number of days was calculated correctly. A sample of Spring official withdrawal calculations identified 2 calculation errors however the total days were calculated correctly. We noted 2 out of 4 (50%) Spring students tested in the Return of Title IV sample had incorrect calculations. Additionally, a sample of No Passing Grades students for unofficial withdrawals noted 2 out of 9 (22%) students tested did not have refund calculations completed timely. We consider this finding to be a material weakness in relation to Special Tests and Provisions and a repeat of prior year finding 2024-001. Statistical sampling was not used. Management Response: We agree with this finding. Corrective Action Plan: This error was caused in a staff interpretation of a Saturday course being offered for one program. However, Saturday's are not on the academic calendar as a class day prior to the Thanksgiving break. Due to staff turnover, this was a change made in calculations in January 2025 that does not count that Saturday as a course day in regards to the length of Thanksgiving break. The change in days per semester calculation is now in line wiht the academic calendar posted by the institution. Responsible Person: Financial Aid Director/Registrar Implementation Date: January 2025

2025-001 - Student Financial Aid Cluster - (a) Federal Supplemental Educational Opportunity Grants (b) Federal Work Study Program (c) Federal Perkins Loan Program - Federal Capital Contributions (d) Federal Pell Grant Program (e) Federal Direct Student Loans (f) Teacher Education Assistance for College and Higher Education (TEACH), Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.038 (d) 84.063 (e) 84.268 (f) 84.379 - Year Ended June 30, 2025 Condition: During our testing of forty individuals receiving federal work study, we noted four individuals (10%) working during scheduled class hours. We consider this condition to be an instance of noncompliance relating to Activities Allowed or Unallowed compliance requirement and is not a repeat finding. Statistical sampling was not used in making sample selections. Management Response: We accept this finding. Corrective Action Plan: Additional planning is ongoing to correct timecards to not allow students to clock work hours during their scheduled classes. Additional training will also be provided to timecard approval staff for departments with student workers receiving Federal Work Study. Responsible Person: Student Employment/Financial Aid Implementation Date: January 2026

Finding 2025-002 Student Status Changes Condition The College did not notify the National Student Loan Data System (NSLDS) with an accurate effective date for 9 students with status changes in our sample of 25 students. Additionally, the College did not notify the NSLDS in a timely manner for 1 student with status changes in our sample of 25 students. The sample was not a statistically valid sample. Corrective Action Plan All records for the students identified in the audit have been manually corrected in the NSC and NSLDS systems to match their actual graduation or last date of attendance. A comprehensive review was completed for all students graduating in June 2025. We are working with NSC to verify the changes we made to our reporting will resolve the issue. Name(s) of Contact Person(s) Responsible for Corrective Action: Mark Badarraco, Executive Director of Enrollment Services and Information Systems Thomas Camillo, Registrar Anticipated Completion Date: 6/30/26 Polices & Procedures update was completed during FY26 Software training for existing staff will continue through FY26

Finding 2025-001 Disbursement Notification Condition 25 students in a sample of 25 were not given notifications that met the required criteria. Students were notified of awards throughout the academic year, but notifications did not meet the required criteria. Additionally, the required information on the timing and procedures for canceling loans was made available to students on the College’s website and financial aid office. The sample was not a statistically valid sample. Corrective Action Plan Corrective Action Planned: Upon identification a permanent, automated daily notification process has been successfully developed, tested, and implemented. Name(s) of Contact Person(s) Responsible for Corrective Action: Mark Badarraco, Executive Director of Enrollment Services and Information Systems Kyle Armstrong, Director of Financial Aid Anticipated Completion Date: 11/14/25 Polices & Procedures update was completed during FY26 Software training for existing staff will continue through FY26

Finding 2025-001 N. Special Tests and Provisions – N6. NSLDS Reporting Identification of the federal program: Federal Grantor: United States Department of Education Federal Cluster: Student Financial Assistance (SFA) Cluster Assistance Listing Nos.: 84.063, Federal Pell Grant Program, and 84.268, Federal Direct Student Loans Award Period of Performance: July 1, 2024–June 30, 2025 Condition: Internal controls over the review and approval of the enrollment report sent to the third-party servicer, National Student Clearinghouse (NSC), were not adequately designed or operating effectively as follows: • A record count reconciliation between the enrollment report submitted to the NSC and the number of files received by the NSC, and documentation over how any rejected records were addressed, is not performed as part of the internal control. • Details of the validation of student information included in the enrollment report for accuracy prior to being sent to the NSC were not retained by Mercy Health. • Details of the NSC error report and corrections made were not retained by Mercy Health. Views of Responsible Officials and Planned Corrective Actions: 1. Corrective Action: Record Count Reconciliation & Rejected Records • Implement a mandatory, documented reconciliation process for every submission. 2. Corrective Action: Pre-Submission Validation Documentation • Formalize the validation process and retain evidence of accuracy checks. 3. Corrective Action: Retention of NSC Error Reports & Corrections • Establish a procedure for downloading and retaining error reports. By implementing these actions, Southeast Missouri Hospital College of Nursing & Health Sciences will ensure compliance with federal regulations regarding the accuracy and timeliness of student enrollment reporting to the NSC and NSLDS. Responsible Party: Steve Ritter, Registrar and/or Deanna Sells, Business Officer Date of Completion: Phased implementation began in January 2026 and our action plan will be fully implemented as of the March 2026 enrollment reporting process.

Views of Responsible Officials: The College acknowledges the audit finding that Return of Title IV (R2T4) calculations were not accurately completed for nine of the sixty students sampled, and that Title IV funds were not returned timely for fifteen of the sixty students sampled. During the audit period, R2T4 tracking and oversight processes were in transition, which resulted in insufficient monitoring of calculation accuracy and timeliness. In addition, for several end-of-term cases involving unofficial withdrawals, the institution could not initiate R2T4 calculation until final grades were posted and an unofficial withdrawal determination was made based on non-passing (F) grades, in accordance with federal regulations governing unofficial withdrawals. The Fall 2024 semester ended on December 21st. The college was closed for the winter break and reopened January 2, 2025. Therefore, the Date of Determination (DOD) was not two days after the end of the semester but in January with the earliest available processing date being January 2, 2025. Corrective Action: The College has implemented enhanced internal controls to ensure compliance with Return of Title IV (R2T4) requirements. Responsibility for monitoring R2T4 calculations and timeliness has been assigned to the Director of Financial Aid and Compliance. A R2T4 tracking log has been established and is reviewed on a weekly basis to ensure that all official withdrawals are identified and processed within the required regulatory timeframe. For unofficial withdrawals, R2T4 calculations are initiated after the end of term once final grades are posted and an unofficial withdrawal date of determination (DOD) is made based on non-passing (F) grades, consistent with federal regulations. End-of-term R2T4 reviews for the fall semester are conducted upon return from winter break after the New Year to ensure complete and accurate academic records are available. Internal staff have received additional training on R2T4 regulatory requirements, timelines, and documentation standards. To ensure operational continuity, a senior specialist has been trained to manage R2T4 processing in the Director's absence. These corrective actions will strengthen internal controls and ensure accurate and timely processing of R2T4 calculations.

Views of Responsible Officials: After consultation with the College’s Information Technology department, management determined that the file was processed and submitted on time. However, the NSLDS discrepancy resulted from a data processing issue during the March 2025 enrollment status download. Specifically, while the NSLDS file was being generated, staff from another office were simultaneously accessing the same student records. These concurrent activities caused the affected students’ enrollment statuses to default to data from a prior download, resulting in incorrect reporting for the two records of the sixty examined. Corrective action: The College has revised its NSLDS data reporting process to prevent a recurrence of concurrent access. A static, saved population list is now used to generate NSLDS enrollment status downloads, eliminating conflicts caused by concurrent system access. This change ensures that enrollment status data is not impacted and remains consistent at the time of submission. Management believes this corrective action adequately addresses the identified issue, strengthens controls, mitigate this issue for future status change reports, and allows for accurate submission within the required 60-day timeframe.

Condition The Federal Pell Grant for one student out of 27 sampled was calculated incorrectly, and the student received excess aid. Corrective Action Plan La Roche University concurs with the finding. The Office of Financial Aid has implemented enhanced controls to ensure accurate Federal Pell Grant calculations in accordance with Title IV regulations and U.S. Department of Education Pell Grant payment and disbursement guidance. Immediate Correction of Identified Error The affected student’s Pell Grant award was recalculated using the correct Scheduled Pell amount and enrollment intensity. The overaward was resolved in accordance with federal overpayment and reconciliation requirements, and the Common Origination and Disbursement (COD) system was updated accordingly. Pell Calculation Verification Control A mandatory secondary review process has been implemented for all Pell-eligible students prior to disbursement to prevent future occurrences noted in this finding. This control collectively mitigates the risk of recurrence and strengthen institutional compliance with federal eligibility and disbursement requirements. Name(s) of Contact Person(s) Responsible for Corrective Action • Lawrence Britton, Executive Director of Financial Aid • Ron Elmore, Associate Director of Financial Aid Anticipated Completion Date All corrective actions were implemented as of February 9, 2026.

Condition The federal aid disbursed resulted in a credit balance for one of the 25 students tested were not returned within 14 days of the date the credit balance occurred. Corrective Action Plan La Roche University concurs with the finding. The University’s procedures did not allow for timely payment of the funds to the student due to holidays that occurred. The Office of Student Accounts has implemented enhanced controls to ensure that credit balances are reviewed and issued refunds in a timely manner. Name(s) of Contact Person(s) Responsible for Corrective Action • Frank Corona, Controller • Dayna Tinkey, Director of Student Accounts Anticipated Completion Date All corrective actions were implemented as of February 12, 2026.

Condition The University did not notify the National Student Loan Data System (NSLDS) in a timely manner for 1 student with status changes in the sample of 25 students selected. Corrective Action Plan La Roche University concurs with the finding. The Office of the Registrar has implemented a new standard operating procedure regarding the reporting of students who have notified us of their withdrawal from the University at the end of spring term/early summer. Identified Error: La Roche University reports enrollment through the National Student Clearinghouse (NSC), which then reports to NSLDS. Because summer is not a mandatory reporting period, if a student is not enrolled they are not coded as withdrawn until they do not return in the fall; only on the first of fall enrollment report would they be coded as withdrawn. This does not meet the reporting timeline to NSLDS if we know a student is not planning to return. This only presents as an issue with the length of time between the end of spring and start of fall term; this is not an issue between the end of fall and start of spring term. New Procedure: If a student submits a Withdrawal form at the end of spring term through the first week of August, we must manually report them as withdrawn in NSC, as we know their intention to not return. Any forms submitted beginning in mid to late August will be picked up on the first of fall enrollment report as withdrawn and still fall within the reporting timeline. Name(s) of Contact Person(s) Responsible for Corrective Action • Katie Elverson, Registrar Anticipated Completion Date Implementation begins in May 2026 and will continue being implemented in all summers going forward.

Management Response: The University agrees with the finding. The identified issue was isolated and only impacted fall graduates. This issue was fully addressed when the university filed its fall 2025 enrollment reporting. The university has conducted an internal audit to identify students that were reported incorrectly and has manually updated files to ensure dates were properly reflected. At current state, internal monitoring and manual edits are made if discrepancies appear. The university has been in contact with PeopleSoft software related to the issue. Should the software issue not be resolved, the university plans to continue with manual edits to ensure proper reporting. Contact Person: Stacy Ramsey, University Registrar srramse@ilstu.edu Completion Date: December 2025

Uniform Guidance Corrective Action Plan Year ended June 30, 2025 Federal Finding #2025-002 Enrollment information, including the effective date of separation from the institution, must be accurately reported within 30 days whenever attendance changes for a student, unless a roster will be submitted within 60 days. The changes include reductions or increases in attendance levels, withdrawals, graduations, and approved leaves of absence. It is the institution’s responsibility, as a participant in the Title IV aid programs, to monitor and report these changes to the National Student Loan Data System (“NSLDS”). (NSLDS Enrollment Reporting Guide November 2022, and 34 CFR 685.309(b)) Quinnipiac University agrees with the finding. An enrollment roster of students that graduated during the 2024-2025 academic year was reported to NSLDS outside the maximum 60-day window. As a result of this finding, Management implemented steps on January 5th, 2026, within the Registrar’s production calendar to run a graduate report along with monthly enrollment reports so that changes in enrollment status are reported on a timely basis. In addition, the Registrar’s office has adjusted the transmission with the National Student Clearinghouse to receive reminders of when file transmissions are coming due. If the Office of Management and Budget have questions regarding this plan, please reach out to Amy Terry, University Registrar, who is responsible for ensuring this corrective action plan is implemented, at 203-582-3933.

Uniform Guidance Corrective Action Plan Year ended June 30, 2025 Federal Finding #2025-001 Direct Loans are determined based on the criteria noted in 34 CFR 685.203(a),(b),(c). Students should be allocated the appropriate potion of subsidized loan funds before being awarded unsubsidized loan funds. Quinnipiac University agrees with the finding. In one instance, a student was under-awarded Subsidized Direct Loans. The student was awarded the appropriate annual amount of direct loans, however received only unsubsidized direct loans. The student should have been allocated a portion of subsidized loan funds before being awarded all unsubsidized loan funds. In another instance, a student was under-awarded Subsidized Direct Loans. Based on their demonstrated financial need, the student should have received additional subsidized loan funds before being awarded unsubsidized loan funds. As a result of this finding, Management implemented an exception report on December 9th, 2025, that will identify students who were awarded less than their maximum subsidized eligibility but have remaining need eligibility. This report will be run at least monthly to identify those students and will allow for their loans to be revised on a timely basis. In addition, the University is in the process of a software modernization project and while working with software consultants, the University plans to review all processes in accordance with best practice recommendations so that they are designed to meet current regulations. If the Office of Management and Budget have questions regarding this plan, please reach out to Kelly Osorio, University Director of Financial Aid, who is responsible for ensuring this corrective action plan is implemented, at 203-582-7446.

Federal Operations Report and Application to Participate (FISAP) –Assistance Listing No. 84.007, 84.033, 84.038 Recommendation: The University should review its policies and procedures on reviewing underlying FISAP data prior to submission to be in compliance with regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Widener University is committed to ensuring the accuracy and integrity of all data reported in the annual FISAP. To support this commitment, additional data-validation measures and internal review procedures will be implemented. These enhancements will help ensure that all information is thoroughly verified and approved prior to final submission by the Director of Financial Aid Services. Name(s) of the contact person(s) responsible for the corrective action: Colleen Shinkle, Director of Financial Aid Services Planned completion date for corrective action plan: February 2026

Upon Notification of the situation by Wipfli, Western had identified several new processes to assure our students are being reported to NSLDS within the 60-day period. 1. Resolved: Western worked with Ellucian Services to review and update our savedlist for National Student Clearinghouse reporting. We discovered the savedlist excluded a subset of student, which prevented their enrollment from being updated correctly. The savedlist is now updated. 2. Update our Admissions Policy (E0200) and Procedure (E0200p9(1)) to direct students on how to officially withdraw from the College. This will help us identify students who do not plan to return to the College. We will create a report of students who officially withdraw from the College and update their status on National Student Clearinghouse website in a timely manner. 3. Identify a process to update the enrollment status for students who receive an extenuating drop for courses. We will develop a report to monitor and update on the National Student Clearinghouse website. 4. Identify a process to update the enrollment status for students who unofficially withdraw from a session 1 course which impacts their enrollment status. We will develop a report to monitor and update the National Student Clearinghouse website. Person Responsible: Lyndsey Thomas, Registrar Projected Completion Date: June 1, 2026

Westminster College Corrective Action Plan (CAP) Federal Program: SFA Cluster, Finding 2025-002: Policies and Procedures Related to Withdrawals (significant deficiency) In accordance with 34 CFR 668-22 Treatment of Title IV Funds When a Student Withdrawals, Westminster College has implemented the following Corrective Action Plan: Name of Contact Person: Dr. Annette Roberts, Assistant Dean of Institutional Research and Registrar Specific Corrective Action: Management has developed written policies and procedures to document the steps put in place to ensure that changes in student status are reported in a timely manner. A critical excerpt from that language is included below: After receiving post-notification from EIPC, the Registrar contacts faculty to confirm the student’s last date of attendance. Using this information, the Registrar determines the withdrawal date, exit date, and records these in Jenzabar. The Registrar then notifies Financial Aid, the Business Office, Institutional Research, Residence Life, Advancement, and IT/Help Desk. Institutional Research subsequently pulls the data from Jenzabar and cross references it with the notifications from these offices, once verified. Institutional Research submits the finalized data to the National Student Clearinghouse. Anticipated Completion Date: The Corrective Action Plan

Finding 2025-002 Reporting Department’s Response: Management agrees with this finding. Corrective Action: This issue arose during the onboarding of students admitted through a teach-out arrangement with a closing institution. Because these students entered under program structures that differed from NUNM’s standard enrollment models, some of the information initially received did not align with NUNM’s financial aid packaging assumptions. In two cases, cost of attendance calculations reflected full-time status when the program design required three-quarter-time treatment. While the situation was limited to a small number of students within a unique population, management recognizes that our internal coordination processes did not sufficiently account for the complexity of the teach-out transition. In particular, clearer confirmation of enrollment status and program structure should have occurred before aid was packaged and originated. Management is strengthening procedures for any future teach-out, transfer, or non-standard admissions cohorts to ensure accurate and compliant packaging from the outset. Going forward, NUNM will implement the following controls: • A standardized handoff process from Admissions to Financial Aid for special populations that documents program structure, term length, and expected enrollment level prior to packaging. • A secondary review requirement for initial aid awards for new program types or cohorts before loans are originated. • Regular cross-functional checkpoints between Admissions and Financial Aid during the setup of non-standard programs. Management views this experience as an opportunity to improve coordination and compliance during periods of institutional transition and is committed to maintaining strong controls over Title IV packaging and cost of attendance calculations. Contact: Jerry Bores Anticipated Completion Date: Immediately

A. Incorrect Calculation of Return of Title IV Funds The District’s Central Financial Aid Unit will collaborate with the Office of Information Technology (OIT) to utilize the last date of academically related activity (also known as the last date of participation) as the withdrawal date for R2T4 (Return to Title IV) calculation purposes. Personnel Responsible for Implementation: Steve Giorgi Position of Responsible Personnel: District Financial Aid Systems Manager Expected Date of Implementation: Fall 2026 B. Distance Education (DE) Courses – Implementation of Formal Process to Determine Accuracy of Student Withdrawal Date – Partial Implementation of Prior Year Corrective Action Plan (CAP) The District’s Educational Program & Institutional Effectiveness office (EPIE) will continue to provide updated guidance and resources to enable faculty to identify academic participation in online classes and to accurately determine the last date of academically related activity. For distance education courses, the process will consistently translate instructor-documented last dates of academic participation, as captured on instructor exclusion rosters, into the withdrawal dates recorded in SIS for R2T4 calculation purposes. Personnel Responsible for Implementation: Mily Kudo Position of Responsible Personnel: Associate Vice Chancellor, Educational Programs and Institutional Effectiveness Expected Date of Implementation: Fall 2026

The District’s Educational Programs & Institutional Effectiveness (EPIE) and Information Technology (IT) divisions will continue reviewing the current programming, analyzing test cases, and studying the more complex system changes required to address the misalignment between the student status effective date reported to the NSC and the date recorded in the PeopleSoft enrollment reporting system. Because the necessary programming updates are more intricate than initially anticipated, additional analysis and testing will be needed before implementing a long-term solution. EPIE will continue to monitor post-submission errors and warning reports to assess the effectiveness of the programming changes. Personnel Responsible for Implementation: Mily Kudo, Andrew Alvarez, Stan Levin Position of Responsible Personnel: Associate Vice Chancellor, IT Business Analyst, Research Analyst Expected Date of Implementation: March 2026

Special Tests & Provisions – Gramm-Leach-Bliley Act – Student Information Security Responses UNLV agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; UNLV Office of Information Technology (OIT) notes that all safeguards noted within the finding are in place and operating effectively. The action necessary relates to an update within the written information security program. This corrective action was taken immediately at the beginning of the current fiscal year, with the updated UNLV written information security program effective July 2025. ● How compliance and performance will be measured and documented for future audit, management and performance review. The UNLV Chief Information Security Officer will review the written information security program at least annually, to occur by the end of each fiscal year, to ensure documentation matches the control environment in practice. Additionally, UNLV engages a third party to perform a robust review of the overall GLBA environment to ensure the institution is appropriately addressing risk areas (most recently in FY25). ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The GLBA regulation requires designation of a Qualified Individual within the organization who is responsible for overseeing and implementing the Information Security Program. At UNLV, this is the Chief Information Security Officer and this individual is the responsible party to exercise oversight and accountability in this area. Official Contact: Rhett R. Vertrees, Assistant Chief Financial Officer 2601 Enterprise Road, Reno NV 89512-1666 Phone: (775)784-3409, Fax: (775)784-1127 Email: rvertrees@nshe.nevada.edu

Special Tests & Provisions – Enrollment Reporting Responses CSN – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; CSN is implementing additional validation steps in the monthly learinghouse report submission process to ensure all required information is accurate and complete. In addition, a monthly quality control review will be conducted on submitted data. Ongoing professional development will also be provided through scheduled monthly and annual trainings, as well as on an ad hoc basis as needed. ● How compliance and performance will be measured and documented for future audit, management and performance review. Under the direction of the Assistant Registrar, the Program Officer II responsible for processing enrollment reporting submissions will distribute error report data. The Assistant Registrar will also conduct a monthly validation by reviewing a random sample of files on the Clearinghouse website to ensure accurate submissions. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. CSN Registrar will be responsible. NSU – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; NSU has reviewed the finding and continues to monitor measures that have been put in place to ensure compliance. Also, some additional procedures have been identified and others further refined. All processes will be fully in place within the next 30 to 45 days. o Continue bi-weekly enrollment reporting schedule to the National Student Clearinghouse (NSC). o Maintain bi-weekly calendar reminders to ensure timely submission of enrollment updates, supplementing NSC notifications. o Establish end-of-term calendar reminders to ensure prompt reporting of graduated statuses. o Continue coordination with NSC to identify students included in submitted enrollment reports whose statuses were not updated. o Review NSC response and reject files following each submission to identify discrepancies. Address any identified discrepancies promptly, even if students do not appear in the reject file. Confirm that updated enrollment statuses are reflected within the National Student Loan Data System (NSLDS). o Maintain documentation of submission dates and communications with NSC. ● How compliance and performance will be measured and documented for future audit, management and performance review. To ensure compliance and strengthened performance in reporting changes in student enrollment status, Nevada State University (NSU) will continue and enhance the following tracking, monitoring, and documentation measures: o NSU will conduct documented monthly reconciliations of enrollment status reports to verify the accuracy, completeness, and timeliness of submissions to the National Student Clearinghouse (NSC). These reviews will include confirmation of submission dates, validation of reported status changes, and resolution of any identified discrepancies prior to the next reporting cycle. o Detailed logs of all enrollment status submissions and NSC notifications will be maintained and centrally retained. Documentation will include timestamps, submission confirmations, reconciliation records, exception reports, and evidence of follow-up actions to ensure a clear and complete audit trail. o Periodic internal compliance reviews will be conducted to assess adherence to the bi-weekly and end-of-term reporting schedule. Review results will be formally documented and provided to management to support oversight and continuous process improvement. o Key performance indicators (KPIs) will continue to be tracked and formally reviewed on a quarterly basis. These KPIs will include:  Percentage of reports submitted within required timelines  Accuracy rate of enrollment status updates  Timeliness of discrepancy resolution o Any discrepancies identified during monthly reconciliations or internal reviews will be addressed promptly, with documented corrective actions, assigned responsible parties, and established resolution timelines. o NSU will compile an annual compliance summary outlining monitoring activities, audit results, corrective actions implemented, and overall performance metrics. This report will be maintained for executive oversight and future audit and management review. o Beginning in March 2026, these measures outlined above will be formally documented and maintained to ensure ongoing compliance. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The Student Information and Scheduling Systems Analyst is primarily responsible for ensuring accurate and timely enrollment status reporting. A new Registrar assumed the role at the start of FY2026 and has begun overseeing compliance with established internal controls, including bi-weekly and end-of-term reporting requirements. Official Contact: Rhett R. Vertrees, Assistant Chief Financial Officer 2601 Enterprise Road, Reno NV 89512-1666 Phone: (775)784-3409, Fax: (775)784-1127 Email: rvertrees@nshe.nevada.edu