Corrective Action Plans

Finding Number: 2025-006 Title: Policies and Procedures Related to Reporting To rectify these discrepancies, the College will implement a reconciliation and review process for the FISAP. The Chief Financial Officer (CFO) will review the FISAP to ensure that all reporting accurately reflects the current fiscal year’s totals in relation to drawdowns and expenditures. Specifically, it has been noted that the FISAP had incorrectly listed totals from the previous year rather than the accurate amounts recorded in the General Ledger (GL) and Common Origination and Disbursement (COD) system. This oversight will be addressed through the establishment of a detailed CFO review. A standardized procedure to reconcile the FISAP data with the drawdowns recorded in the G5 system and the actual expenditures will be created. This procedure will involve a systematic review of all financial aid programs, ensuring consistency and accuracy before submission of the FISAP. By enacting this corrective action plan, the College aims to ensure that its reporting practices meet federal guidelines and maintain the integrity of its financial aid programs. Management is committed to these actions and will ensure their timely and effective execution. Anticipated Completion Date: March 31, 2026

Finding Number: 2025-005 Title: Policies and Procedures Related to Packaging Student Financial Aid To enhance compliance and address these deficiencies, the College will implement a new procedure for documenting and retaining borrower notifications. A timestamped email notification system will be created to ensure that all required communications to students regarding federal direct loans are not only sent but also retained for auditing purposes. Additionally, a formal review process will be established to verify transfer students' grade levels and academic progressions. This will involve cross-referencing transfer credits and ensuring proper classification of students to prevent future errors. After all transcripts are evaluated, Financial Aid will repackage the aid offer, if required. Regular audits will be introduced to review the documentation of borrower notifications and the packaging process to ensure compliance with federal regulations. Furthermore, training sessions will be conducted for staff involved in the Financial Aid and Registrar Departments to reinforce the importance of accuracy in documenting communications and package decisions. By implementing these corrective actions, the College aims to enhance compliance with federal guidelines and improve the accuracy of Financial Aid packaging for all students. Management is committed to these changes and will ensure the timely execution of this plan. Anticipated Completion Date: March 31, 2026

Finding Number: 2025-004 Associated Criterion: 34 CFR 668.22 - Treatment of Title IV Funds When a Student Withdraws To effectively address the issues related to student withdrawals, a comprehensive action plan will be implemented. First, a thorough review of existing withdrawal policies and procedures will be conducted to identify any gaps in the notification process concerning withdrawn students. Building on this assessment, a timely notification procedure will be developed, which will standardize how all relevant departments, including the Registrar, Financial Aid, and Student Affairs, are notified whenever a student withdraws. This procedure will outline specific timelines and designate responsible parties for alerting each department. To maintain compliance, regular audits of withdrawal cases will be conducted, ensuring adherence to the newly established procedures. Quarterly reviews will also be set up to assess the effectiveness of the notification process. By implementing this Corrective Action Plan, Missouri Valley College aims to improve the timely notification of withdrawn students, ensuring compliance with federal regulations and minimizing the risks associated with late reporting of Title IV funds. Anticipated Completion Date: March 31, 2026

Finding Reference: 2025-004 - SFA - Special Tests - Disbursements to or on Behalf of Students (JSU) Responsible Official: Adrienne Walls, Bursar 601.979.0320 Adrienne.Walls@jsums.edu Corrective Action Planned: Jackson State University will update internal controls to ensure compliance with 34 CFR 668.165 related to required notifications for Direct Loan disbursements. The Bursar’s Office will be responsible for issuing required loan disbursement notifications to students and parents. The Bursar’s Office will work in coordination with the University’s Banner consultant to develop and implement an automated process to identify loan disbursements and trigger required notifications. At this time, system-generated notifications are not active. Until automation is implemented, the University will utilize a manual notification process to ensure compliance. Notifications will include (1) the date and amount of the disbursement, (2) the right to cancel all or a portion of the loan, and (3) the process and timeframe to request cancellation. Policies and procedures will be updated to document the notification process. A pre-disbursement control will be implemented prior to each disbursement cycle to verify that the notification process—manual or automated—is in place and functioning as intended. Monitoring procedures will be established to include weekly reviews of disbursement records and notification logs to ensure notifications are issued timely and accurately. Exceptions identified will be resolved promptly. The Assistant Bursar will serve as the control owner responsible for performing and documenting this review. Staff will receive training on regulatory requirements and updated procedures. A standard notification template has been developed and will be used to support the manual process and future automated communications. These actions address the cause of the finding, which resulted from notifications being inadvertently disabled in the financial aid system, and will strengthen controls to prevent recurrence. Estimated Completion Date: April 30, 2026

Finding Reference: 2025-003 - SFA - Special Tests - Using a Servicer to Deliver Title IV Credit Balances (ASU) Responsible Official: Charles Crump, Special Assistant to the VP for Finance (ccrump@alcorn.edu) Corrective Action Planned: The institution will update the E-App to accurately reflect the third-party servicer relationship. Additionally, the institution will implement periodic reviews of all third-party relationships involved in the delivery of Title IV credit balances to ensure they are properly reported on the E-App and remain in compliance. Estimated Completion Date: June 30, 2026

Finding Reference: 2025-002 - SFA - Special Tests - Enrollment Reporting (ASU) Responsible Official: Kisha Bond, University Registrar (khumphrey@alcorn.edu) Corrective Action Planned: Following consultation with a representative and audit resource team from the National Student Clearinghouse (NSC), it was confirmed that the student was certified as withdrawn on February 7, 2025, and that this information was transmitted by NSC to NSLDS on February 19, 2025 during Spring 2025 first term reporting because the student was not enrolled. Subsequently, the student graduated Fall 2024, however all degree requirements were not updated at that time which resulted in the delay of the graduation status being reported. As a result, the student was certified as graduated on March 10, 2025 and NSLDS received that certification on March 20, 2025. In response, we have evaluated this occurrence and are implementing enhanced internal monitoring procedures to ensure that enrollment changes are accurately captured and submitted within established reporting windows. These measures include conducting quarterly quality control reviews with both NSC and NSLDS to verify that enrollment statuses are properly reported and transmitted. These reviews will occur following the initial term reporting for each semester. Additionally, a standardized verification form will be developed to confirm successful transmission of enrollment data from NSC to NSLDS. Finally, all students who have completed degree requirements will have their status updated during end-of-term processing to ensure timely and accurate reporting. Estimated Completion Date: December 31, 2026 Finding Reference: 2025-002 - SFA - Special Tests - Enrollment Reporting (DSU) Responsible Official: Megan Smith, Director of Financial Aid (mlsmith@deltastate.edu) and Tammy Prather, Registrar (tprather@deltastate.edu) Corrective Action Planned: Delta State University recognizes that when degree conferral is delayed, students should be temporarily reported as withdrawn(W) and the status later updated to graduated(G) once the degree is officially conferred. Delta State University has reviewed our internal reporting timelines with the National Student Clearinghouse and will ensure all finalizations of reporting aligns with the policies. Delta State University understands that the Clearinghouse update to NSLDS did not occur on the student record until April even though our report cleared in February, resulting in an error. We are implementing an additional reconciliation step to verify that changes submitted to the Clearinghouse are reflected in NSLDS within the expected time required under policy. Estimated Completion Date: June 30, 2026 Finding Reference: 2025-002 - SFA - Special Tests - Enrollment Reporting (JSU) Responsible Official: Lakesha Tubbs, Registrar, 601.979.2807 (Lekesha.i.tubbs@jsums.edu) and Mr. Letherio H. Zeigler, Executive Director, 601.979.0227 (Letherio.h.zeigler@jsums.edu) Corrective Action Planned: A designated member from both the Office of the Registrar and the Department of Financial Aid will conduct a comprehensive review of the records sent to NSLDS via the NSC as well as ensure that all clearinghouse errors are resolved within a timely fashion not to exceed 4 business days. This partnership ensures that errors, including withdrawals, graduations, and changes in credit load, are updated in NSLDS in a timely manner. Moving forward, a monthly reconciliation process will be implemented between these two departments to prevent future reporting lags or data mismatches identifying reporting errors and executing the necessary data corrections directly that are submitted to NSLDS. Estimated Completion Date: May 5, 2026 Finding Reference: 2025-002 - SFA - Special Tests - Enrollment Reporting (MSU) Responsible Official: Emily Shaw, University Registrar emily.shaw@msstate.edu Corrective Action Planned: All procedures, beginning with data file from SIS, will be thoroughly reviewed to determine why the appropriate effective dates are not reflecting correctly. We are seeking assistance from our Information Technology Service and will then consult with Ellucian directly if there is an issue with our data file. Additional processes and protocols will be implemented for rejection errors that may be causing the appearance of not certifying within the required timeline. Estimated Completion Date: May 15, 2026 Finding Reference: 2025-002 - SFA - Special Tests - Enrollment Reporting (MVSU) Responsible Official: Jeffery Loggins, University Registrar (Jloggins@mvsu.edu) Corrective Action Planned: As part of our ongoing action plan, we will continue to work with our IT Department and external consultant to ensure less errors and timely reporting of data when submitting to NSLDS. Estimated Completion Date: June 30, 2026

Finding Reference: 2025-001 - SFA - Special Tests - Return of Title IV Funds (ASU) Responsible Official: Dr. Capetra Polk, Default Management Coordinator capetra@alcorn.edu Corrective Action Planned: Our prior corrective plan was to ensure that any post-withdrawal aid eligible for disbursement would be processed in a timely manner. Although corrective actions were implemented in response to the previous finding, the university unfortunately returned funds outside the required timeframe, resulting in the current finding. To address this issue, responsibility for the R2T4 process has been reassigned, and new staff have been trained and will assume these duties to prevent future oversights. Estimated Completion Date: June 30, 2026 Finding Reference: 2025-001 - SFA - Special Tests - Return of Title IV Funds (DSU) Responsible Official:Megan Smith, Director of Financial Aid (mlsmith@deltastate.edu) and Tammy Prather, Registrar (tprather@deltastate.edu) Corrective Action Planned: Delta State University understands that the spring break start date did not match the days of the break and have resolved the accuracy of those entries to policy. The Registrar and Director of Financial Aid will verify the input of the dates prior to processing withdrawals each year. Delta State University is implementing a weekly process to ensure all R2T4 reviews are conducted and funds returned within the required timeframe. Estimated Completion Date: June 30, 2026 Finding Reference: 2025-001 - SFA - Special Tests - Return of Title IV Funds (MVSU) Responsible Official: Angela Fant, Director of Financial Aid (Angela.Fant@mvsu.edu) and Jeffery Loggins, University Registrar (JLoggins@mvsu.edu) Corrective Action Planned: As part of ongoing corrective actions, the Office of Financial Aid will continue to verify the accuracy of data provided by the Registrar’s Office prior to processing and awarding aid. In addition, better coordination will be implemented to manage and ensure the submission of accurate data. Estimated Completion Date: June 30, 2026 Finding Reference: 2025-001 - SFA - Special Tests - Return of Title IV Funds (UMMC) Responsible Official: Davita Weary, Director Financial Aid (FinancialAid@umc.edu) Corrective Action Planned: To ensure accuracy, uniformity, and compliance across all UMMC schools, the following corrective actions will be implemented. All academic calendars must clearly state standardized semester start and end dates using the required language. In addition, standardized break and holiday language must be applied consistently for all holidays, recesses, and institutional closures. Oversight of the academic calendar will be provided by the UMMC Academic Affairs Council, and all academic calendars and associated verbiage must be submitted for review and approval by the Council. The Academic Affairs Council will conduct a full review prior to publication, provide feedback and required revisions during the review period, and return any non‑compliant submissions for correction. In addition to calendar requirements, Financial Aid Advisors will be required to participate in Return to Title IV (R2T4) training offered through the National Association of Student Financial Aid Administrators (NASFAA), and the Financial Aid Director will conduct periodic spot checks of R2T4 submissions throughout the year to ensure continued compliance. Estimated Completion Date: Immediately Finding Reference: 2025-001 - SFA - Special Tests - Return of Title IV Funds (USM) Responsible Official: David Williamson, Director of Financial Aid (david.williamson@usm.edu) Corrective Action Planned: The University of Southern Mississippi (USM) acknowledges the audit finding and agrees that controls surrounding Return of Title IV (R2T4) calculations must be strengthened to ensure full compliance with federal requirements. During the Spring 2025 semester, the institution experienced a two‑day weather‑related delay in the start of classes. As a result, the Registrar updated the academic calendar start date to align with the actual commencement of instruction. No in‑person or online classes were held, and no federal aid disbursements occurred prior to the revised start date. The Spring 2025 semester remained a standard academic term with at least 15 weeks of instructional time. While the institution believed the revised calendar reasonably reflected student attendance and instructional activity, the audit identified that the payment period start date used in Return of Title IV calculations did not align precisely with the approved term structure for purposes of federal aid calculations. This misalignment resulted in incorrect day counts for certain withdrawals. To address this issue and mitigate future risk, the University will implement the following corrective actions: •The Office of Financial Aid will formally coordinate with the Registrar prior to the start of each semester to confirm that academic calendar dates used for Title IV purposes align with approved payment periods and federal regulations. •Any future adjustments to the academic calendar regardless of instructional time impact will be reviewed for Title IV implications, and written guidance will be obtained from the U.S. Department of Education by contacting caseteams@ed.gov as appropriate. •Internal procedures for Return of Title IV calculations will be updated to require verification of calendar day inputs against the institution’s final, approved academic calendar prior to processing. These actions are intended to reinforce internal controls over compliance and ensure consistent application of federal requirements across all withdrawals. Estimated Completion Date: March 18, 2026

Student Financial Assistance Cluster– Assistance Listing No. 84.063, 84.007, 84.033, 84.268 Recommendation: We recommend the College 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. Action planned in response to finding: NEO will perform an internal audit of enrollment reports sent to the National Student Clearinghouse (NSC) monthly to ensure NSC is submitting records on behalf of NEO in a timely manner. Name(s) of the contact person(s) responsible for corrective action: Amy Ishmael Planned completion date for corrective action plan: April 1, 2026 If the U.S. Department of Education has questions regarding this plan, please call Amy Ishmael at 918- 540-6212.

Student Financial Assistance Cluster– Assistance Listing No. 84.063, 84.007, 84.033, 84.268 Recommendation: We recommend that the College review policies and procedures related to R2T4 calculations to ensure calculations are performed correctly and timely. We also recommend the College implement formal review procedures to document the Return of Title IV calculations are being performed to minimize the likelihood that errors may go undetected and not be corrected in a timely manner. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: NEO will check the scheduled break days before the beginning of each semester to make sure the correct number of days is entered into SOATBRK. Documentation will be retained to confirm that a check was performed. NEO performed the recalculations and is working with FSA to make corrections. Name(s) of the contact person(s) responsible for corrective action: David Fisher and Ashley Mayfield Planned completion date for corrective action plan: March 14, 2026.

SIGNIFICANT DEFICIENCY 2025-001 Student Financial Assistance Cluster– Assistance Listing No. 84.063, 84.007, 84.033, 84.268 Recommendation: We recommend the College 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 planned in response to finding: NEO will develop a separate report in addition to the RRREXIT report to identify students that need to be notified of their responsibility to complete exit counseling. Name(s) of the contact person(s) responsible for corrective action: David Fisher Planned completion date for corrective action plan: March 15, 2026.

The College acknowledges that a submission error occurred in Spring 2023, resulting in several students not being included in the routine semester enrollment submissions to the National Student Clearinghouse (NSC). Beginning in Spring 2024, our Institutional Research department initiated a comprehensive process to resubmit corrected enrollment files to the NSC, covering Spring 2023, Summer 2023, and Fall 2023. In collaboration with NSC, we followed their established process to rectify the error, which required reloading each submission one at a time in succession from the original submission with the error. This process caused delays in our subsequent submissions until the corrections were fully completed. To prevent recurrence, we have implemented enhanced checks and controls prior to each submission to review the file and file size to ensure the correct number of students are submitted to NSC. Additionally, all submissions post-Spring 2023 have been reviewed, and we have confirmed that this was an isolated incident. Due to the timing of when the College was notified by NSC, this item carried forward into audit year 2025.

Finding Number: 2025-001 Considering Subsidized Loans First Planned Corrective Action: The financial aid office concurs with this finding. We have received guidance from our annual audit partners and will install updated processes to ensure that consideration of subsidized loans is prioritized during the awarding process. Person Responsible for Corrective Action Plan: Brice Baumgardner, Vice President of Enrollment Management Anticipated Date of Completion: 4/1/2026

Federal Agency: U.S. Department of Health and Human Services State Department/Agency: Kansas Department for Children and Families (KDCF) Federal Program Name: Adoption Assistance Title IV-E Assistance Listing Number: 93.659 Award Number: 2402KSADPT, 2502KSADPT Award Period: July 1, 2024 through June 30, 2025 Compliance Requirement: Eligibility Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Condition: During testing of eligibility requirements, it was noted that three participants out of forty tested did not have supporting documentation in their case files for nonrecurring adoption expenses paid on their behalf. Recommendation: We recommend that KDCF strengthen internal controls to ensure that supporting documentation for nonrecurring adoption expenses is obtained, reviewed, and retained prior to payment to mitigate the risk of noncompliance in the future. Views of responsible officials: There is no disagreement with the audit finding. Action taken in response to finding: KDCF policy requires that all case files contain documentation supporting state expenditures and all associated payments, in accordance with Policy #0430 Contents of Foster Care, Adoption and Independent Living Services Case Records. Additionally, staff must follow the procedures outlined in Policy #6924 Payment Procedures for Non-Recurring Expenses. Non-recurring expense payments are made according to the authorization provided on forms PPS 6140 or PPS 6130. A PPS 2833 Client Purchase Agreement must be completed by PPS staff, with a copy of the PPS 6130 or PPS 6140 attached to document the authorization for payment. An itemized bill should also be attached when available. While this policy is in place, this finding indicates the need to reinforce internal controls to ensure full compliance. To address the deficiency and prevent recurrence, KDCF will implement the following corrective actions: 1. Reinforcement of Documentation Requirements: Adoption program and I-VE program leadership will review the audit findings with regional adoption staff, I-VE payment specialists, Regional I-VE Administrators and Regional Foster Care Administrators. During this meeting Adoption program and I-VE program leadership will review the corrective action plan and emphasize the importance of the need for complete and accurate documentation in regard to adoption assistance. 2. Enhanced File Review Process Prior to Payment: KDCF will implement a detailed Adoption Assistance Packet Checklist. This is an internal double-check step requiring staff to verify that all required supporting documents for non-recurring adoption expenses are present before submitting or approving payment. This verification will be incorporated into the existing payment workflow to ensure consistency across regions. 3. Targeted Training and Guidance: Updated reminders and written guidance will be issued to all adoption staff outlining specific documentation requirements and the procedures for retaining them. Training will emphasize the allowable cost requirements under Title IV-E and the purpose of maintaining complete records for federal compliance and audit readiness. 4. Ongoing Monitoring: Program leadership will conduct periodic spot checks of adoption subsidy files to validate that required documents are consistently included and will address any identified gaps with staff promptly. These actions will strengthen internal controls and help ensure that documentation supporting nonrecurring adoption expenses is properly obtained and retained in all adoption case files moving forward. Name(s) of the contact person(s) responsible for corrective action: Adoption Program Manager and Kim Fay, I-VE Program Manager Planned completion date for corrective action plan: January 1, 2027

Federal Agency: Department of Education Federal Program: Student Financial Assistance Cluster Assistance Listing Numbers: • 84.063 – Federal Pell Grant Program • 84.268 – Federal Direct Student Loans Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matter Recommendation: We recommend that the University strengthen its internal controls over reporting student enrollment changes to NSLDS to ensure that enrollment effective dates are reported to NSLDS within 60 days of an enrollment status change and that enrollment is being properly certified every 60 days. Explanation of Disagreement with Audit Finding: The University agrees with the audit finding. Action in Response to Finding: To prevent recurrence, the Office of the Registrar has implemented the following controls effective immediately: 1. Procedural Update: A mandatory coordination meeting between the College of Law and the Office of the Registrar is now scheduled to occur four weeks post-term to finalize degree verification. 2. Role Assignment: The Student Systems Analyst (Office of the Registrar) has been assigned ownership of this submission. They are responsible for proactively verifying the completion of Law awarding and executing the subsequent data submission to the Clearinghouse. Name of the Contact Person Responsible for Corrective Action: Nathan Bauer, Associate Vice Chancellor for Enrollment, Director of Financial Aid. Planned Completion Date for Corrective Action Plan: January 2026

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

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

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

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

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

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

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

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

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

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

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