Corrective Action Plans

Special Tests & Provisions – Return of Title IV (R2T4) 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 added additional resources to the R2T4 program by hiring a Senior Specialist to ensure R2T4 queries are frequently run, and accounts are reviewed on a weekly basis. CSN also contracted the services of a PeopleSoft consultant to assess, streamline, and automate R2T4 queries. Additionally, R2T4 staff, PeopleSoft Consultant and third-party vendor meet on an ongoing basis and implement necessary changes to meet compliance requirements. CSN is also providing professional development opportunities to staff through our trade organizations. ● How compliance and performance will be measured and documented for future audit, management and performance review. Under the direction of the Assistant Director, the newly hired Senior Specialist position runs queries and assigns identified files to staff twice a week to ensure accounts are reviewed within the federally mandated timeframe. CSN also continues to train staff on the processing of R2T4 and schedule regular team meetings to ensure updates and changes are communicated in real time and R2T4 procedures are applied accurately and consistently. CSN continues to perform quality control through the review of processed R2T4 files. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. CSN Director of Financial Aid will be responsible. 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

Eligibility Responses UNR – 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; The Financial Aid Office has implemented a daily query to check for awards not matching the academic program and level. The query is run by the data team and then again by the Compliance team to mitigate improper awarding due to manual changes. ● How compliance and performance will be measured and documented for future audit, management and performance review. This revised process ensures that any mismatched program awards are resolved without negatively impacting students and resolution occurs within established time frames. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The Assistant Director for Compliance and Processing, Program Manager of Federal Funding, and the Interim Financial Aid Director. 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

Cash Management Responses UNR – 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; The Financial Aid Office has implemented enhanced reconciliation and cash management procedures designed to strengthen internal controls and mitigate future risk. The monthly reconciliation process has been revised to ensure that each reconciliation clearly documents all outstanding items, including timing differences and variances. ● How compliance and performance will be measured and documented for future audit, management and performance review. Under the revised process, the Assistant Director for Compliance and Processing ensures drawdowns are supported by detailed reconciliation schedules, discrepancies are formally identified and tracked, and resolution occurs within established timeframes. The updated procedures have been fully implemented and are operating as designed. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The Assistant Director for Compliance and Processing and the Interim Financial Aid Director. 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

Finding 2025-005 Errors in Verification Reporting Condition: Northern Illinois University (University) did not properly code the verification status in the Common Origination and Disbursement (COD) System for students who were disbursed Pell Grant funds and later selected for verification and the internal controls in place did not prevent and detect the exceptions. Corrective Action Plan: University has taken the following corrective actions that will eliminate all material exceptions: 1) University procedures have been updated to ensure verification status updates are properly transmitted to the Common Origination and Disbursement (COD) system upon completion of verification. Relevant staff have been trained on the revised procedures. 2) University has implemented a process to periodically review records and confirm that verification statuses are accurately reflected in COD. All affected student records have been reviewed and corrected. It has been confirmed in the National Student Loan Data System (NSLDS) that none of the mis-reported statuses resulted in an overpayment. Individual(s) Responsible for Corrective Action: Registration and Records Staff Anticipated Completion Date: June 30, 2026

Finding 2025-003 Errors in Reporting for NSLDS Condition: Northern Illinois University (University) did not properly report enrollment changes for certain students who received federal student aid to the National Student Loan Data System (NSLDS) and the internal controls in place did not prevent and detect errors. Corrective Action Plan: University has taken the following corrective actions that will eliminate all material exceptions: 1. The University will review and strengthen its current enrollment reporting procedures to ensure Program-Level updates are completed consistently, particularly in cases involving unofficial withdrawals. 2. The University will develop a batch reporting process for unofficial withdrawals to facilitate accurate enrollment reporting at both the program and campus level. Additional verification steps will be implemented prior to submission to confirm that both campus-level and program-level enrollment statuses are properly updated. 3. The University will also reinforce staff training related to NSLDS reporting requirements and enhance supervisory review procedures to reduce the risk of similar errors occurring in the future. Individual(s) Responsible for Corrective Action: Registration and Records Staff Anticipated Completion Date: June 30, 2026

Incorrect Term Dates Used in R2T4 Calculations Auditor Description of Condition and Effect. During testing of Return to Title IV ("R2T4") calculations for students who withdrew during the academic year, we noted 1 of 2 student calculations tested had an incorrect term start date when determining the percentage of the payment period completed. We further noted that the University used an incorrect term start date for all R2T4 calculations performed for the Fall 2024 semester. Specifically, the start date used in the calculation did not agree to the official academic calendar approved for the applicable term. As a result of this condition, the University performed R2T4 calculations that included inaccurate percentages of the payment periods completed, which lead to the improper calculation of Title IV funds earned and unearned. Auditor Recommendation. We recommend that the University implement a control requiring reconciliation of term dates used in R2T4 calculations to the officially approved academic calendar prior to processing withdrawals. Additionally, management should review R2T4 calculations completed during the affected period to determine whether recalculations and any necessary adjustments or returns are required. Corrective Action. The University will establish formal procedures to review the term dates used in R2T4 calculations to the officially approved academic calendar prior to processing withdrawals. Responsible Person. Anne Van, Director of Financial Aid Anticipated Completion Date. June 30, 2026

Non-Compliance with Servicer to Deliver Title IV Credit Balances Auditor Description of Condition and Effect. The University does not have a formal Banking Services Agreement with its financial institution. In addition, the University has not posted the agreement online, lacks documentation of the required biennial review, has not reported the arrangement to Federal Student Aid, and does not maintain adequate internal controls over the Tier Two Arrangement. Failure to comply with federal regulations increases the risk of regulatory sanctions, reputational harm, and potential financial penalties. Auditor Recommendation. We recommend the University execute a formal Banking Services Agreement with the financial institution, publish the agreement on its website, document and perform biennial reviews, report the arrangement to Federal Student Aid, and implement appropriate internal controls to ensure ongoing compliance. Corrective Action. The University will create a formal Banking Services Agreement with the Financial Institution, publish the agreement on its website, document and perform biennial reviews, report the arrangement to Federal Student Aid, and implement appropriate internal controls. Responsible Person. Yah-Sheba Jenkins, Controller Anticipated Completion Date. June 30, 2026

March 11, 2026 The University acknowledges the finding and the recommendation from Baker Tilly regarding improving procedures. Finding: 2025-001 – Special Tests and Provisions – Return of Title IV Funding (R2T4) and Enrollment Reporting: Significant Deficiency in Internal Control over Compliance Improved Process of Protocol This finding stemmed from 4 (four) departments at the University: College of Science and Health, College of Nursing, Office of the Registrar and Office of Financial Aid. As such, each department’s corrective action plan is listed below. College of Science and Health (COSH) To address this finding, the office of the COSH Dean has implemented a formal attendance-monitoring and escalation process to improve internal controls and ensure timely intervention. The updated process clearly defines responsibilities for faculty, program coordinators, and program leadership. Program Coordinators will review attendance records regularly: before the add/drop deadline, prior to the last day of the withdrawal period, and biweekly afterward to identify students who are not attending or exhibiting patterns of repeated absence. The process also outlines escalation procedures and timelines for student outreach, documentation of communication efforts, and reporting to the Registrar when administrative actions are needed. These procedures help ensure that non-attendance is identified promptly and that appropriate enrollment status adjustments are made in line with institutional policies. The Office of the Dean will oversee compliance with these procedures by conducting regular reviews of attendance records, documenting outreach efforts, and verifying notifications from the Registrar. This corrective measure enhances oversight, promotes prompt intervention for atrisk students, and ensures consistent enforcement of institutional policies on attendance and enrollment status. The action plan will be implemented on March 13th, 2026, and reviewed every semester for quality improvement. *See Corrective Action Plan for included table* Contact Person Responsible for Corrective Action: Dr. Monica G. Ferini, Dean, COSH Anticipated Completion Date: March 13th, 2026 College of Nursing (CON) To address this finding, the office of the CON Dean has implemented the following corrective action plan as follows: • Faculty: consistent check of attendance • Program Coordinator (PC): to run reports before add and drop date to track student activity status, if not active, Program Director (PD) will send notification to Registrar to request to process "drop" from the course • Program Coordinators (PC): Run attendance data tracking every 2 weeks • If student is identified missing >2 classes: PC will notify Faculty then faculty reach out to student (within 2-3d) • If student does not respond to faculty or continues to miss class: Faculty to notify PD (within 3-5d) • If student does not respond to PD or continues to miss class: PD to notify registrar of "withdraw" or dismissal (within 3d) Contact Person Responsible for Corrective Action: Dr. Sheryl Antido, Associate Dean, CON Anticipated Completion Date: March 23rd, 2026 Office of the Registrar Upon receipt of the university administrative or withdrawal form from the college or student, the form is processed in PowerCampus by the Office of the Registrar within five business days. Once the student’s status has been updated from "Enrolled" to "Withdrawn" or "Dismissed," an email notification is sent to the Office of Financial Aid, Student Finance, and the respective academic program. Upon receipt of the notification from the Office of the Registrar that a student’s status has been updated to “Withdrawn” or “Dismissed,” an email notification is sent to the Office of Financial Aid, Student Finance, and the respective academic program as confirmation that the student enrollment status has been updated. Contact Person Responsible for Corrective Action: Raquel Munoz, Registrar Anticipated Completion Date: Current Workflow in Place Office of Financial Aid Upon notification from the Office of the Registrar, The Office of Financial Aid will review the student’s record to determine whether a Return of Title IV (R2T4) calculation is required. If applicable, the Office of Financial Aid will complete the R2T4 calculation and process the return of Title IV funds within the required federal timeframe in accordance with 34 CFR 668.22, ensuring that funds are returned no later than 45 days from the date the institution determines the student withdrew. The Office of Financial Aid maintains an internal tracking process to monitor students who withdraw and to ensure timely completion of R2T4 calculations and reporting requirements. We remain committed to this process and will continue to provide ongoing training throughout the year to ensure compliance and to keep academic departments informed of the procedures. Contact Person Responsible for Corrective Action: Henry Espinoza, Director of Financial Aid Anticipated Completion Date: Current Workflow in Place

The University experienced a mid-year leadership transition in the Registrar’s Office when the prior Registrar resigned, requiring a search for a new Registrar. At the time of the transition, the former Registrar was responsible for both routine office operations and oversight of enrollment reporting to the National Clearinghouse and NSLDS. During this period, incorrect data entries occurred. Corrective action has been initiated under the leadership of the newly appointed Registrar, who is conducting a comprehensive review of existing processes and internal controls within the office. This review includes evaluating data entry procedures and oversight practices to ensure greater accuracy and consistency. In addition, as part of the integration with Sentara College of Allied Health, the University is adding staff positions in both the Registrar’s Office and Financial Aid. The new staff members will allow for improved systems and process oversight and reduce operational strain on the Registrar’s Office. These corrective actions and staffing enhancements are expected to strengthen internal controls and prevent similar issues in the future.

Federal Pell Grant Program; Federal Stafford Loans Program; Federal Parents’ Loans Program for Undergraduate Students; Federal Graduated Plus Loan – Assistance Listing No. 84.063; 84.268 Recommendation: We recommend the University evaluate its procedures for sending enrollment information to the NSLDS, especially around graduated enrollment information. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University has updated its policies and procedures for NSLDS submissions via their third-party servicer to ensure relevant information is being captured and reported timely in accordance with applicable regulations. Name(s) of the contact person(s) responsible for corrective action: Kamla Singh-Ramoutar, University Registrar, (201) 761-6051 Planned completion date for corrective action plan: Completed

Student Financial Assistance Cluster— Assistance Listing Nos. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend the University review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Student Financial Services is working with the Registrar to update our reporting practices for students with student teaching requirements. The registrar has connected with the Clearinghouse to confirm and utilize a separate file type for this population, which should resolve the reporting date issue. Name of the contact person responsible for corrective action: Catherine Maun Planned completion date for corrective action plan: May 31, 2026

Program: AL 93.658 – Foster Care Title IV-E – Allowability Corrective Action Plan: The spreadsheet has been corrected and a journal entry will be completed to correct the amount billed to IV-E. Contact: Bryan Gilliland Anticipated Completion Date: February 28, 2026

Program: AL 93.658 – Foster Care Title IV-E – Allowability Corrective Action Plan: The Agency will evaluate and develop new processes to review and ensure that attendance records match billing documents, authorizations, and claims. An evaluation of the Provider Portal will be completed to identify enhancements to this area. The Agency will develop a new fraud prevention process for the Resource Development team to enhance controls over attendance, billing, and the auditing of provider claims, and to ensure compliance. A Provider Probation process will be implemented to address identified billing concerns. Contact: Nicole Vint Anticipated Completion Date: September 30, 2026

Finding number: 2025-001 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.007, 84.063, 84.268 Award year: 2025 The Registrar’s Office will perform a mandatory “Missing SSN Report” that picks up missing and invalid SSNs before every enrollment data submission to the National Student Clearinghouse (“NSC”). The Registrar will send the Financial Aid Office a list of students with missing SSNs and Financial Aid will verify if students in the report have a FAFSA on file. If there is a FAFSA on file for a student, Financial Aid will update the SSN in the Banner system and send an email confirmation to the Registrar to confirm all records on the report have been reviewed and/or updated. The next enrollment file submitted to the NSC will include the students with the correct data. Furthermore, the Registrar Office will send a written communication to the Provost/Vice President for Academic Affairs verifying that all student records sent the National Student Clearing House has a SSN number prior to any reporting deadline. This communication will be kept on file and available for review for the next audit period. As an additional step, when Financial Aid staff load initially unmatched ISIRs to active Westfield State student records, Banner is now set to automatically populate the student record with the social security number from the matched FAFSA. The goal is to reduce the number of missing social security numbers pulled by the Registrar when they run the “Missing SSN report.” Timeline for Implementation of Corrective Action Plan: Above corrections were implemented in November 2025. Contact Person: Monique Lopez, Registrar and Simone Backstedt, Director, Financial Aid

FINDING 2025-002 Name of Responsible Individual: Mary Mercer, Director Student Financial Services Corrective Action: Issue: The current refund report used to monitor Title IV refunds has limitations that affected the completeness of data reviewed. Reports rely on manual batch postings, which can delay or omit certain transactions at the time of report generation. This created gaps in monitoring and potential human error. Action Step Responsible Party Timeline Transition to new system – Implement refund reporting to reduce manual errors and improve completeness. Student Financial Services & IT (if needed) Full adoption by Academic Year 2026–2027 Staff training – Provide comprehensive training to Student Financial Services staff on new system processes, reporting, and controls for Title-IV refunding. Ellucian Consultant & Student Financial Services When training session is scheduled through first report in 2026-2027 Interim verification controls – Conduct weekly reconciliation of batch postings and verifications that all Title IV refunds are captured until the new system is fully operational. Student Financial Services & Controller’s Office Immediate until system adoption Validation & reconciliation process – Establish a formal process within the new system to ensure all refunds are accurately captured and reported. Student Financial Services By first full report in 2026–2027

FINDING 2025-001 Name of Responsible Individual: Kasi Turner Corrective Action: To prevent future occurrences of missing campus‑level student enrollment reporting, both the University Registrar and Assistant Registrar will participate in the upcoming NSClearinghouse Academy on Thursday, March 26. This session will provide a refresher on enrollment compliance reporting requirements and offer opportunities to connect with peers and Clearinghouse staff to discuss best practices. Additionally, I will begin collaborating with the MU Database Administrator, Mary Hupp, to compile and review all monthly enrollment reports prior to submission to the National Student Clearinghouse. As part of this strengthened workflow, we will implement a two‑person sign‑off to ensure that both the data extraction and the TXT file mapping are jointly reviewed and verified before transmission. This added step ensures a second review of both the database and the TXT file before transmission, strengthening accuracy,and reducing the likelihood of future omissions. Before the next reporting cycle, the Registrar’s Office will also review and update the current enrollment reporting process documentation in collaboration with Mary Hupp to ensure that all steps, and system validation points are clearly defined and consistently followed. Anticipated Completion Date: April 15, 2026

Finding: 2025-002 Federal Agency Name: U.S. Department of Education Assistance Listing Number(s): 84.063, 84.007, 84.268, 84.033 Program Name: Student Financial Assistance Cluster Finding Summary: Institutions that implement an affirmative confirmation process (as described in 34 CFR 668.165 (a)(6)(i)) must make this notification to the student or parent no earlier than 30 days before, and no later than 30 days after, crediting the student’s account at the institution with Direct Loan. Institutions that do not implement an affirmative confirmation process must notify a student no earlier than 30 days before, but no later than seven days after, crediting the student’s account and must give the student 30 days (instead of 14) to cancel all or part of the loan. Responsible Individuals: Frankie Everett, Director, Financial Aid Corrective Action Plan: The College implemented a new ERP system in the current year that caused delays in notifying students of their loan disbursements. PowerFAIDS allows documenting the email sent to students in the Communication Log, but a box has to be checked when the email batch is sent. This step was inadvertently missed in several batches so we cannot confirm the email was sent. The Department is working to automate the emails with a college-hired consultant. In the meantime, the Financial Aid Operations Coordinator (Jessica Jones) is double-checking that disbursement emails are going out each week. Anticipated Completion Date: June 2026

Finding: 2025-001 Federal Agency Name: U.S. Department of Education Assistance Listing Number(s): 84.007, 84.033, 84.063, and 84.268 Program Name: Student Financial Assistance Cluster Finding Summary: 34 CFR 690.83(b)(2) and 34 CFR 685.309 states that Institutions are responsible for accurate reporting of a student’s enrollment status and changes in those enrollment statuses, whether they report directly or via a third‐party servicer. The support provided by RCC for the students’ last date of attendance did not agree to the students’ withdrawal that had been submitted to NSLDS. Responsible Individuals: Danielle Crouch, Registrar and Analisa Gifford, Assistant Registrar Corrective Action Plan: During the 2023-2024 academic year, we were utilizing an outdated, homegrown Student Information System (SIS). A previously unidentified flaw in the system’s programming logic caused incorrect withdrawal dates to be populated in the National Student Clearinghouse (NSC) report. For the 2024-2025 academic year, we have transitioned to Jenzabar One, an industry-recognized SIS that includes built-in Enrollment Reporting functionality. To ensure accurate reporting moving forward, we are conducting audits of withdrawal dates at the end of each term. With the implementation of this new system and enhanced audit processes, this issue will be fully mitigated. Rogue Community College has implemented corrective actions to strengthen internal controls and ensure the accurate reporting of student enrollment statuses to the National Student Loan Data System (NSLDS). The College now utilizes withdrawal reports to systematically identify students who have withdrawn from all enrolled courses. These reports are reviewed to verify each student’s official withdrawal date prior to submission to NSLDS. For students who receive non-passing grades, the College reviews and reports the last date of attendance, when applicable, to ensure accurate determination of the student’s withdrawal date. As additional internal control, the College conducts term-end audits of withdrawal dates and last dates of attendance to confirm that enrollment status changes have been reported accurately and in accordance with federal requirements. Any discrepancies identified through this review process are corrected promptly. Additionally, the College utilizes graduation reports to verify that students who have completed all program requirements within their declared major are appropriately reported to NSLDS with an enrollment status of Graduated. Through these enhanced monitoring and verification procedures, Rogue Community College is confident that enrollment status changes are reported accurately and in compliance with the requirements outlined in 34 CFR 690.83(b)(2) and 34 CFR 685.309. Anticipated Completion Date: October 2025

The District acknowledges that deficiencies in internal controls over the Return to Title IV calculation process resulted in inaccurate calculations. The District has reviewed the identified calculations and corrected all errors. Return to Title IV policies and procedures will be updated and a standard process is to be completed for every calculation. The District will implement a mandatory secondary review of all Return to Title IV calculations prior to processing returns or post-withdrawal disbursements.

Finding - Special Reporting: Fiscal Operations Report and Application to Participate (FISAP) - Federal Work Study Program, Assistance Listing Number 84.033, Federal Supplemental Educational Opportunity Grants Program, Assistance Listing Number 84.007; June 30, 2025 Award Year; U.S. Department of Education Condition The graduate enrollment figure at Section D line 7(b) included an additional 51 students on the FISAP submitted on September 29, 2025. Corrective Actions During our compliance audit it came to light that New England Institute of Technology accidentally overstated the quantity of graduate students on our FISAP that was filed originally on September 29, 2025, by 51 students. We immediately revised the FISAP to make the correction and filed it with the Department of Education on December 9, 2025. New England Institute of Technology will implement a process to compare the system-generated enrollment reports to enrollment data to ensure enrollment information this is reported on the FISAP is accurate. Responsible Official: Denise Brindle, Financial Aid Director Completion Date: December 2025

FISAP Reporting Planned Corrective Action: At the time of preparation of the FISAP report by the Financial Aid Office, electronic database reports used for preparation will be archived and attached to the report. The report will be reviewed the Vice President of Enrollment Management and the Vice President for Finance and Operations/CFO. Both reviewers will be provided the detailed reports that agree to the data reported. The review will consist of ensuring that the data on the database source, PowerFAIDS, is accurate and agrees with the reported data. Reviewer will run directly from the PowerFAIDS system a report consistent with the time frame of the FISAP and determine that the report agrees with the report attached to the FISAP submitted for review. Person Responsible for Corrective Action Plan: Ms. Monique Rickenbaker, Director of Financial Aid Mr. Yohannis Job, VP for Enrollment Management Dr. Sharron T. Burnett, VP for Finance and Operations/CFO Anticipated Date of Completion: June 30, 2026

Management Views and Corrective Action Plans 2025-001 - Untimely submissions of Accurate Student Enrollment Change to the National Student Loan Data System (NSLDS) Point of Contact – Jennifer Spiegel Goldberg, University Registrar, (646-592-6275) Management agrees with the current year’s finding and recommendation to review its policies and controls for accurate and timely enrollment reporting by establishing a process to ensure that all required program and campus level status changes are reported to NSLDS and are reported within the required 60-day timeframe. Yeshiva University’s dual curriculum, multi-college undergraduate system, as well as some graduate programs allow students changes during enrollment that can result in extraneous degree records no longer linked to the student’s enrolled program. This circumstance and finding occurred because a graduation application was mistakenly applied to an extraneous record and carried through to conferred degree, which the NSC reporting system could not detect. A script has been in place since January 13, 2026, to run overnight to detect “orphan” degree records and ensure that only records that match current enrollment are available removing the potential for this to occur moving forward. The student identified during the audit as requiring remedy has been remedied in NSLDS as of November 19, 2025.

Finding 2025-001: Special Tests and Provisions - NSLDS Reporting (Significant Deficiency) U.S. Department of Education – Student Financial Assistance Cluster Federal Pell Grant Program (84.063) Federal Direct Loan Program (84.268) View of Responsible Officials and Planned Corrective Action: With respect to the findings relating to the timeliness of enrollment reporting, the University agrees with this finding and will take appropriate actions to improve processes to ensure enrollment status records are updated timely in the NSLDS at both the Campus-Level and Program-Level. Corrective Plan: • Reporting Calendar for All Branch Campuses o Ensure reporting calendar accommodates each branch campus at the University • Timely Enrollment Status Updates - Branch Campuses o Ensure completion is entered in SIS prior to the submission of the last enrollment file submitted for that term • Tracking Students Completing Outside of Original Cohort o Early completion o Late completion • Reporting Status Changes Outside the Standard Reporting Calendar o Process developed to report these students individually Name of Contact Person(s) Responsible for the Plan: Michael Lewis, Registrar Michael.lewis5@marist.edu Anticipated Completion Date: April 30, 2026

The College will ensure the accuracy of reports sent to NSLDS by making changes to their staffing structure and roles surrounding student leave of absences and withdrawals. The College hired a single administrator who assists students through the process of requesting a leave of absence or a withdrawal and processes all leaves, making the system more efficient. The Office of Financial Aid will continue to process Return to Title IV calculations immediately when notified about a Title IV recipient’s leave of absence or withdrawal.

Condition: The College did not send out the post-disbursement email notifications to a group of students. Planned Corrective Action: While the University has documented procedures in place for the disbursement of federal funds and required post-disbursement notifications to students, the finding identified related to only students who received both a Federal PLUS loan and a Federal Direct Loan during 2025. University did not properly send a post-disbursement notification to 117 out of 247 students who received both a federal PLUS loan as well as a Federal Direct Loan on a specific date during fiscal year 2024-2025. The University will adjust its internal processes to ensure all students who receive federal loans are sent post-disbursement email notifications by performing a review of the IT system and working toward fully automated notification settings to ensure all students are captured in the post-disbursement notification process. Contact person responsible for corrective action: Leah Alderink, Director of Student Financial Aid Anticipated Completion Date: Immediately