Corrective Action Plans

Name of Responsible Individual: Carmela Goodall, Manager, Systems and Administration (Office of the Bursar); Robin Whitfield, Associate Vice President for Finance & Bursar; Ben Carmichael, Associate Director for Compliance, Enrollment Management; Linda Coles, Director of Cash Management, Treasury Operations; Keynesha Wilson, Treasury Specialist; Kathleen Harrod, Accounts Payable Disbursement Manager; Rawle Howard, Assistant Vice President, Procurement Corrective Action: There was one credit balance in the sample (from early August 2023) that was not processed within 14 days. The Title IV refund was delivered the 19th day after the credit balance was created on the student’s account. The student in question did not appear on the Bursar’s refund report until August 2, 2023. Once the student’s refund did show up, a loan adjustment was required to ensure the Bloomberg scholarship the student received did not cause an overaward. After this adjustment to prevent the overaward was made, the refund was delivered on August 8, 2023. The Associate Director for Compliance performed five Fall 2023 and Spring 2024 reviews of 375 Title IV refunds sent to students and found zero students who had a Title IV credit balance disbursed after 14 days. Bi-semester reviews such as this are intended to catch students who may have a Title IV credit balance delivered after the 14-day timeline. In the future, there will be a sample size of one hundred students for each review and will encompass the smaller cohort of Title IV refunds sent to medical students in late July and early August. The Title IV credit balance that was not delivered within 14 days was in the Doctor of Medicine cohort who began classes a month before undergraduate students begin the Fall 2024 semester. Anticipated Completion Date: Howard feels this finding has been mitigated and there will be no further findings where students received a Title IV credit balance check past the 14-day deadline. Semester or bi-semester reviews will be completed by Financial Aid to ensure the University is sufficiently meeting the federal requirements for students and/or parents to receive the Title IV credit balance check within 14 days.

Name of Responsible Individual: Ben Carmichael, Associate Director for Compliance, Enrollment Management; Sarah Mariner, Assistant Director for Compliance, Financial Aid; Robin Whitfield, Associate VP for Finance & Bursar; Guillermo Creamer, Collections Manager; Robert Muhammad, Executive Director of Financial Aid; Brenda Willis, Senior Executive Director of Financial Grants & Contracts; Educational Computer Systems, Inc. Corrective Action: Discrepancies in the area of the Perkins Loan program (Perkins) – unfortunately – are not unusual at any institution. This is due to the nature and complexity of the program being historically paper-based and required since inception to be administered and tracked by institutions. Institutions as a whole are not (have not been) adequately and equitably equipped to properly monitor decades-old and now-ended programs. To our knowledge the U.S. Department of Education (ED) did not (does not) have an issue with the response to errors provided by Howard University. Howard University is currently liquidating the Perkins program and have assigned all outstanding Perkins loans to the ED, as well as notified borrowers their loans have been assigned to ED. The University has not originated Federal Perkins Loans since the end of the 2017-2018 award year. The majority of the fields represented in Part III Section A on the FISAP remain static and should not be changed. Educational Computer Systems, Inc. (ECSI) provides these values on the FISAP report they provide as of June 30 of each year. The only field in Part III Section A the University should tie back to the General Ledger at this time are Fields 1.1 and 1.2, which are the Cash on Hand amounts on June 30 and October 31 of each year. Parity is difficult to obtain because the vast majority of the fields in Part III Section A are static. Cash on Hand as of October 31 is calculated based on a FISAP report provided by ECSI. The report shows in Column H the change in Cash on Hand from June 30, which will be entered on the FISAP as the Cash on Hand as of October 31. Educational Computer Systems, Inc., the University’s third-party Perkins servicer, has also stated to Howard University that mismatches on FISAP values such as Cash on Hand, Federal Capital Contribution (FCC)/ Institutional Capital Contribution. (ICC), Administrative Cost Allowance, Collection Costs and Cumulative Loan Advance and Principal Collected can frequently occur. Most ECSI clients do not attempt parity between ECSI and their ledger, so because parity is difficult to obtain, not being able to tie back data in Part III of the FISAP is not unusual. Educational Computer Systems, Inc. collaborates with schools that do not have their General Ledger match what is on the FISAP in Part III. Awareness of what data does not match and why is more important than parity. It was discovered in December 2021 that Part III Perkins portion of the FISAP had experienced data conversion issues after the conversion from ACS Loan Servicing to ECSI as the University’s third-party servicer. There were Perkins Loans disbursed to students not included in the conversion, so the data provided annually by ECSI had accuracy issues. ECSI has stated to Howard that most institutions do not attempt to reach this parity, as it can be difficult to accomplish. Howard is liquidating the Perkins program, and assuming the University can assign all Federal Perkins Loans to ED, the Cash on Hand will then be reported as $0 in the FISAP. The tuition and fees discrepancy on the 2526 FISAP and Financial Reporting Audit is explained by the Tuition & Fees amounts reported as of FY24 including a portion of Summer 2023 that was recognized in FY24, and a portion of Summer 2024. The charged tuition and fees amounts will not exactly agree to the financial statements due to the related GAAP deferrals and revenue recognition. Prior to the September 30, submission of the FISAP during the upcoming year, the tuition and fees will be reconciled with the tuition and fees that is reflected on the Financial Reporting audit. The tuition and fees will then be reviewed and reconciled again with the amounts reflected on the Financial Reporting Audit prior to final submission of the FISAP on December 15. Anticipated Completion Date: Summer 2025 is the date the University anticipates having liquidated the Perkins program. Cash on Hand will be reported as of June 30 and updated again on October 31. Completion of the FISAP is due September 30, 2025 and final edits to the FISAP are due December 15, 2025. Howard will update the Cash on Hand and tuition and fees as of December 15, 2025 for final submission. The U.S. Department of Education will then review the submitted FISAP for errors or inconsistencies. Should there be no errors or inconsistencies from ED’s review, they will accept the FISAP and begin basing any Excess Liquid Capital return request on the Cash on Hand reported.

Finding 2024-002 - U.S. Department of Education (USDE), Title IV Student Financial Aid Programs (Significant Deficiency): We observed the following conditions in connection with our testing of the various U.S. Department of Education, Title IV, Student Financial Assistance Programs: 1. Per 34 CFR 685.300(b)(5), the College provided reconciliations for the following programs, however the reconciliations were not correct and therefore the programs were not properly reconciled, monthly or annually. a. Federal Pell Grant Program b. Federal Direct Loan Program c. Federal FSEOG Program d. Federal Work Study Program 2. The Office of Financial Aid submitted unreconciled expenditures within the Fiscal Operations Report and Application to Participate (FISAP) for the Federal Pell Grant Program. 3. The College distributed the Annual Security and Fire Report (ASR) on October 10th, 2024. PER 34 CFR 668.41, By October 1 of each year, an institution must distribute the ASR to all enrolled students and current employees as described in § 668.46(b). 4. Per HEA, Section 484B and 34 CFR 668.22, one (1) out of 6 students tested for withdrawals and the return of Title IV funds did not have their Title IV program funds returned within the 45-day requirement that the college determined the student withdrew. 5. Per HEA, Section 484B & 34 CFR 668.22, three (3) out of 6 students tested for withdrawals and the return of Title IV funds did not have their Title IV program post-withdrawal disbursement funds disbursed within the 45-day requirement that the college determined the student withdrew. 6. Per HEA, Section 484B & 34 CFR 668.22, five (5) out of 6 students tested for withdrawals and the return of Title IV funds (R2T4) and the school did not complete the R2T4 calculations correctly. As a result of these inaccuracies, two (2) students were overpaid Pell and Direct Loan (DL) funds in the amount of $612 and one (1) student was underpaid $866 in Pell funds. The following errors occurred: a. Incorrect withdrawal dates were used b. Incorrect dates of determination were used c. Funds that could have been disbursed were incorrectly recorded as funds disbursed The College should implement corrective actions to ensure that the above findings are resolved and will not recur in future periods. Corrective Action – Title IV reconciliations were prepared. They have been provided to WPG. The College hired an experienced Director of Financial Aid on February 18, 2025. She will ensure the proper reconciliation and management of all financial aid programs and the accurate and timely submission of program reports. The Director of Campus Security has been advised of the deadline for distribution of the Annual Security and Fire Report (ASR).

The Business Office has implemented measure to ensure that all key items reported on the FISAP are accurate and if there have been changes or updates made after the initial FISAP reporting then a reconciliation will be performed so that the updates values will be reported prior to the deadline in December. To ensure that all key items per the FISAP are properly reported the Business Office will: • Implement reconciliation and review processes to ensure compliance. • Following any update or reconciliation performed over FISAP reportable items the office will perform a check to ensure no key item amounts have changed. In the case that they do an updated FISAP will be reported. Contact Person: Kevin Doherty, Interim Controller Telephone: 305.628.6518 Email: kdoherty@stu.edu Anticipated Completion Date: 6/15/2025

Corrective Action Plan – Thorough Review of FWS Payroll All timesheets are electronically saved, in the event an employee submits a paper time sheet due to a missed time period, the document is scanned and saved in the shared payroll file. On a bi-monthly basis FWS payroll is reviewed and reconciled to ensure students are getting paid for amounts earned. Contact Person: Neville Bates, Payroll Manager Telephone: 305.474.6702 Email: nbates@stu.edu Completion Date: 9/30/2024

FINDING 2024-001: UNDERAWARDED FEDERAL DIRECT SUBSIDIZED LOANS- the auditor tested forty files, thirty-six of which were Federal Direct Loan recipients, and two students did not receive the full amount of their Federal Direct Subsidized Loans. It is recommended the College reclassify $2,124 from unsubsidized to subsidized and increase controls over packaging direct loans. Comments on Finding and Recommendation(s): We concur with the finding and we believe that these account represent a unique situtation. Actions Taken or Planned: For A1, Valor was able to rectify the account because it was within the 180-day limit. We have implemented an internal audit process that takes place twice each semester to reconcile federal aid awarded with the appropriate aid based on enrollment status and grade level. For A-2, Value is unable to reallocate subsidized and unsubsidized awards for the second student as the 180-day limit has passed. The student was awarded the correct total amount of aid. Moving forward, Valor will generate an NSLDS report whenever a 258 ISIR code appears on the ISIR to ensure proper aid allocation.

Management accepts this finding. The error on the verification (1 student) was made by a former staff that did not verify the student wages. Clarkson’s procedure clearly states the income is required to be verified, however the former staff member made an error in processing this verification. Improvements to the training process have been implemented including emphasis on the requirement that staff verify income as part of the review process. A multi-tier review system has been implemented whereby after the initial review process has been completed, verification documents are submitted to the Director who then performs a second review to ensure that the initial review process was correctly followed and that the data is reliable. Anticipated Completion Date December 2024 - completed Responsible Person Nicole Adner, Director of Financial Aid

Management accepts this finding and notes there were issues with the disbursement records that prevented them from being sent to COD. Unexpected turnover in the workforce resulted in 25% normal processing capacity during the timeframe in question. Staffing levels in that area have been fully restored with appropriate training to the employees. A formal schedule has been developed whereby records are reconciled and sent to COD on a weekly basis to reduce the risk of late filings. In addition, the University is considering methods of improved redundancy and backup to prevent systemic issues going forward. Anticipated Completion Date December 2024 - completed Responsible Person Nicole Adner, Director of Financial Aid

Corrective Action Plan The University acknowledges this finding and is committed to immediate corrective measures to ensure compliance with federal regulations. The following actions will be undertaken: 1. Enhance Procedures and Internal Controls: The University will strengthen its procedures and internal controls related to the submission of origination and disbursement records to the COD system. This includes implementing stricter monitoring mechanisms to ensure all records are submitted within the required timeframes. 2. Implement Advanced Technology Solutions: To improve the efficiency and accuracy of financial reporting, the University will adopt advanced technology solutions. These tools will facilitate timely and accurate submission of required data to the COD system. The newly established internal audit team will oversee the implementation and management of these corrective actions until the issue is fully resolved. The University is dedicated to enhancing its procedures and internal controls to ensure full compliance with federal origination and disbursement requirements. By taking these steps, the University aims to rectify the identified deficiency and prevent future occurrences, thereby maintaining the integrity of its financial reporting processes. Anticipated Completion Date: September 1, 2025

Corrective Action Plan The University acknowledges this finding and is committed to implementing immediate measures to ensure compliance with federal financial aid regulations. The following steps will be undertaken: 1. Strengthen Financial Aid Coordination: The Financial Aid team will enhance coordination among various programs and between federal and non-federal aid sources to ensure that total aid awarded does not exceed a student’s financial need or cost of attendance. This aligns with federal regulations requiring institutions to prevent over awards by adjusting aid packages accordingly. 2. Implement Advanced Technological Solutions: The University will collaborate with technology support teams to develop data platforms and scripts that monitor and control award amounts, ensuring they do not surpass students’ cost of attendance. This proactive approach will aid in preventing future over award situations. The internal audit team will oversee and manage these corrective actions until the issue is fully resolved. The University is dedicated to enhancing its procedures and internal controls to ensure full compliance with federal financial aid regulations and to uphold the integrity of its financial aid programs. By implementing these measures, the University aims to rectify the identified over award issue and prevent similar occurrences in the future, thereby maintaining compliance with Title IV funding requirements. Anticipated Completion Date: September 1, 2025

Corrective Action Plan The University acknowledges this finding and during its liquidation of the Federal Perkins Loan Program completed the buyback of certain loans for which the University was not able to provide adequate documentation to assign these loans to the Department of Education. Subsequent to June 30, 2024, the University has completed the following steps in the closeout of its Federal Perkins Loan Program: 1. Notified the Department of Education of the intent to liquidate. 2. Assigned outstanding Perkins loans to the Department of Education and updated NSLDS throughout the assignment process. 3. Purchased loans not qualifying for assignment and submitted cash on hand (Intent and Closeout Form Phase 3 in COD) 4. Remitted the federal share to the Department 5. Submitted final FISAP data (Intent to Closeout Form Phase 4 in COD) The final remaining step for the University to complete closeout of its Federal Perkins Loan Program is to submit a Perkins closeout audit to the Department. This will be submitted as part of the Single Audit for the year ended June 30, 2025, which is due March 31, 2026. Anticipated Completion Date: June 30, 2025

Corrective Action Plan The University acknowledges this finding and is committed to implementing immediate measures to ensure compliance with federal regulations regarding the Return of Title IV Funds (R2T4). The following steps will be undertaken: 1. Establish an Internal Audit Function: The University has requested a position from the State of South Carolina Human Resources Office to create an internal auditor role. A dedicated budget line item is being developed to support this function, which will oversee all corrective action plans and serve as the primary contact for audit-related matters, providing onsite management for compliance issues within the University and its affiliated agencies. 2. Enhance Communication Between Departments: The Financial Aid team will strengthen coordination with the Registrar’s Office to ensure timely identification of student withdrawals. This collaboration is essential to initiate the process promptly and adhere to the required deadlines. 3. Implement Technological Solutions: The University will engage technical support to develop alert systems that notify relevant departments of impending compliance deadlines and requirements related to Title IV funds. This proactive approach will facilitate timely actions and reduce the risk of non-compliance. The internal audit team will oversee and manage these corrective actions until the issue is fully resolved. The University is dedicated to enhancing its procedures and internal controls to ensure full compliance with federal regulations governing the return of Title IV funds. By implementing these measures, the University aims to rectify the identified deficiency and prevent similar occurrences in the future, thereby upholding the integrity of its financial aid programs and maintaining compliance with federal requirements. Anticipated Completion Date: September 1, 2025

Corrective Action Plan The University acknowledges this finding and is committed to implementing immediate measures to ensure compliance with federal enrollment reporting requirements. The following steps will be undertaken: 1. Establish an Internal Audit Function: The University is actively seeking to fill a newly approved internal auditor position, with a dedicated budget line item to support this function. This role will provide leadership on all corrective action plans and serve as the primary contact for audit-related matters, ensuring onsite management for compliance issues within the University and its affiliated agencies. 2. Engage External Expertise: The Office of the Registrar will engage with the internal auditor and the National Student Loan Clearinghouse to review critical processes. This ongoing collaboration aims to assess the department’s strengths, weaknesses, opportunities, and threats, facilitating continuous improvement and compliance. 3. Enhance Staffing and Technological Resources: The University has made necessary staffing changes and will continue to evaluate the efficiency of the enrollment reporting process. This includes hiring additional staff as needed and incorporating advanced technology solutions to address this recurring issue. The implementation of enhanced technology will assist the Registrar in receiving alerts and status reports, ensuring timely and accurate processing. 4. Implement Robust Monitoring Systems: The University aims to generate necessary information and update systems to improve its capability to monitor student enrollment statuses, thereby enhancing compliance. This initiative will address challenges associated with certifying these enrollment status changes in a timely manner. 5. Strengthen Reporting Processes: Given the recurrence of this finding, the University will implement an enhanced reporting process, requiring the filing of transfer student status reports on a semester basis until the issue is resolved. The internal audit team will lead this reporting cycle, ensuring accountability and compliance. The internal audit unit will oversee and manage these corrective actions until the matter is fully resolved. The University is dedicated to enhancing its procedures and internal controls to ensure full compliance with enrollment reporting requirements. By implementing these measures, the University aims to rectify the identified deficiencies and prevent similar occurrences in the future, thereby upholding the integrity of its financial aid programs and maintaining compliance with federal regulations. Anticipated Completion Date: September 1, 2025

The University concurs with the finding. The University is working with the Clearinghouse and consultants to correct system errors within Banner, so we do not have these concerns in the future. The Architect students mapping issue was corrected by the Registrar Office in March 2025. The Registrar’s Office has created a new program code that will reflect next semester’s registrations and updated previous majors.

Corrective action: There is a process in Banner that creates a file containing graduates for degree verification submission to the National Student Clearinghouse. There was a systematic error with that process in Spring 2024 rendering the process unable to generate a file. The error was not resolved until May 2024, which is when the submission for these students was completed. This was a one-time specific system failure occurrence which has been resolved and the process has been working correctly since May 2024. The Offices of the Registrar and Student Financial Services are working in conjunction with the University compliance team and Office of Institutional Research to enhance review and checks/balances of reporting deadlines to ensure that files are submitted within the required deadlines. Further, the Office of the Registrar will work with internal IT staff to research and implement backup reporting procedures for creating enrollment and graduation files in the event of another system issue. Proposed Completion Date: May 31, 2024

Assistance Listings number and program name: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study Program 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans This finding initially occurred in fiscal year 2024. Name of Contact Person: David Donderewicz, M. Ed., Executive Director of Financial Aid and Scholarships Anticipated completion date: June 30, 2025 Corrective Action: 1. Perform calculations for all students who received Title IV funds and withdrew during the period November 2023 through June 2024 and immediately return all unearned aid to ED. 2. Review and update the student information system’s automated controls to properly identify and flag all students who receive Title IV funds and withdraw from the District. 3. Test any changes made to the student information system and verify controls are operating as designed to comply with the SFA cluster’s requirements. The College concurs with the recommendations from the Arizona Auditor General. The College will conduct an additional review to identify any students who may have impacted financial aid adjustments and will enact any necessary corrections (estimated completion, 3/31/25). Additionally, the College will review the automated controls process to ensure the accuracy of the enrollment change data and will conduct assessments at the end of each term to ensure R2T4 calculations are processed correctly (estimated completion 6/30/25).

The University should take steps to ensure that its procedures to submit enrollment information to NSLDS in a timely manner are strictly followed.

The University should correct the enrollment status information in NSLDS for the students noted above. In addition, the Institution should take steps to ensure that its procedures to accurately submit information to NSLDS are strictly followed

Views of Responsible Officials: The college agrees with this finding with explanation. These occurrences were anomalies related to a rare misalignment of the academic calendar for summer session for the 2023/2024 academic year. The calculation findings for five of the seven students were related to a schedule misalignment for the summer semester. The academic calendar for the 2023/2024 award year had 106 days of enrollment during the summer semester. There was a gap of six days between the Summer 2 and Summer 3 terms skewed the calculations. The College has not identified a similar alignment gap for any previous award year. The Financial Aid Office will actively monitor the development of the academic calendar. Additionally, the Financial Office will review and revise existing procedures to identify areas for improvement to ensure that all withdrawn students who began attendance will have their Return to Title IV calculations accurately completed. The Financial Aid Office has taken steps to retrain relevant financial aid personnel and developed internal checks for accuracy in the calculation process.

Views of Responsible Officials: The College has noted that this finding may not align with the unique nature of our summer session, which has three terms included. There are four non-standard summer terms that do not follow the same reporting structure as the Fall and Spring Terms. The College interprets the 60-day reporting requirement to apply to the standard terms for Fall and Spring only. Historically, the college has reported summer enrollments in August, which has been treated as compliant by the Clearinghouse. However, after further review, the College will adjust its reporting schedule to align with recommendations from this finding. This adjustment will ensure that summer reporting aligns with the 60-day timeframe that is consistent with the Fall and Spring terms.

Name of contact person responsible for corrective action: Marguerite Lane, Associate Vice President Enrollment Management Mlane@molloy.edu 516-323-4014 Corrective action: Molloy University understands the finding and has devised a process to ensure that the correct withdrawal date is recorded National Student Loan Data System (NSLDS) with the 60-day window from the date of determination. In the finding, the withdrawals were reported within the window, but the effective dates reported were incorrect. We identified the issue and made the corrections, but the corrections were made outside the 60-day window. To address this, we will utilize our current practice of relying on error reports to address such errors, but we will run these reports at an increased frequency (bi-weekly) and have an additional staff member review the information. We will keep a file for each student withdrawal to show that our dates align in our system, the National Student Clearinghouse, and NSLDS within the required timeframe. Proposed Completion Date: March 31, 2025

Trinity College of Florida will develop, implement and maintain a written information security program in accordance with GLBA compliance

Student Financial Assistance Cluster - Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Recommendation: We recommend the University implement additional internal controls to ensure proper segregation of duties. This includes hiring additional staff or redistributing responsibilities to separate the functions of authorizing, processing, and reviewing transactions. Additionally, ongoing training should be provided to financial aid staff on the importance of internal controls and compliance with Title IV regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Financial Aid Office has expanded staffing and continues to provide ongoing training through NASFAA, NCASFAA, CFNC, and Ellucian. Roles and responsibilities are now clearly defined to ensure proper segregation of duties, and cross-training is underway to provide continuity during vacancies. These efforts support the implementation of enhanced internal controls and Title IV compliance. Name(s) of the contact person(s) responsible for corrective action: Damon Wade, VP for Enrollment Management and Marketing Planned completion date for corrective action plan: June 2025

Student Financial Assistance Cluster - Assistance Listing No. 84.268 Recommendation: The University should ensure all necessary employees receive proper training, support, and time to follow the University’s policies and federal requirements related to monthly reconciliations. There should be a process to maintain all reconciliations as support of performance monthly. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Business Office will complete monthly reconciliations in addition to the reconciliation at the time of draw of federal funds to comply with federal requirements. Name(s) of the contact person(s) responsible for corrective action: Belinda Burke, VP for Finance and Administration, CFO Planned completion date for corrective action plan: April 2025

Student Financial Assistance Cluster - Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the University evaluate its procedures and policies around reporting to the COD to ensure that student information is reported timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Financial Aid Department will evaluate its policies and procedures around reporting to the COD to ensure that student information is reported timely. Name(s) of the contact person(s) responsible for corrective action: Damon Wade, VP for Enrollment Management and Marketing Planned completion date for corrective action plan: April 2025