Corrective Action Plans

Management agrees with the auditors’ finding and their recommendation. The CFO has worked with the registrar and other University personnel to file the NSLDS reports. Eventually, the CFO updated enrollment status manually. A report was filed in July 2025. Going forward, the NSLDS enrollment status roster reports will be filed timely. If there is a technology issues, enrollment status changes will be input manually by University personnel. Anticipated Completion Date: The corrective action was completed in July 2025. Contact Person: Tasha Young, CFO 816-425-6151

Corrective Action Planned: The Financial Aid department will distribute an email to the relevant departments upon completion of each financial aid transmittal process, prompting the Information Technology (IT) department to generate direct loan disbursement notifications via email. After emails are distributed, IT will provide Financial Aid with a report of the notifications sent. The Financial Aid Director or Assistant Director will review and compare the data from the IT notifications report to the financial aid disbursement records to ensure accuracy and completeness. Anticipated Completion Date: June 30, 2026 Responsible Person: Tasha Campbell, Director of Financial Aid campbellt68@morainevalley.edu

Corrective Action Planned: Responsibility for reporting has been reassigned to a senior staff member. A secondary review process has been established, requiring managerial verification before submission. Additionally, monthly reconciliations will be conducted to ensure that all status changes are reported accurately and within the required timelines. Timeline: Reassignment of reporting responsibility: Effective immediately. Establishment of secondary review and reconciliation procedures: Within 30 days. Monthly reconciliation review: No later than November 30, 2025. Anticipated Completion Date: June 30, 2026 Responsible Person: Tasha Campbell, Director of Financial Aid campbellt68@morainevalley.edu

2025-001 Inaccurate and Untimely Return of Title IV Funds (R2T4) Planned Corrective Action: The current process for completing the Return of Title IV aid is to have the Title IV counselor review and complete the calculation. Then send it to the Director of Financial aid for final review. We have implemented an internal control as of 09/01/2025, that at the close of every month the Office of Financial Aid verifies with registrar’s office that we have been notified of all withdrawn students to ensure that the process has been completed within the 45 days. The misunderstanding with the 49% exemption has been clearly understood, and proper execution of that rule will be implemented. Person Responsible for Corrective Action Plan: Kenneth Piester, Director of Financial Aid Anticipated Date of Completion: 09/01/2025

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Records & Registration will now submit modified enrollment files as Graduates Only records to ensure accurate and timely graduation status updates. This solution has been confirmed by NSC. Additional staff have been trained on the updated procedures, and new processes are in place to ensure discrepancies and error flags are resolved promptly. Records & Registration and the Financial Aid Office continue to collaborate to identify and address discrepancies that may affect Title IV eligibility. Person(s) Responsible: Assistant Registrar, Director of Financial Aid Timing for Implementation: Immediate

Return of Title IV Fund Calculations Condition/Context: For two of the six students selected in the sample, the amount of the Title IV refund was calculated incorrectly due to using the incorrect number break days for students that withdrew in the Spring term. This results in too much being returned to the U.S Department of Education. Recommendation: The University should modify its procedures for refunding awards to ensure proper data computations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The scheduled break days for the spring semester accidentally failed to include the weekend before the week of Spring Break. The school calendar profile for the Return of Title IV Funds Calculation will now be reviewed by both the Director of Scholarships and Financial Aid and the Assistant Director of Financial Aid before being created in the COD Return of Title IV Funds Tool each term. Contact person: Tom Ochsner, Director of Scholarships and Financial Aid Planned completion date for corrective action plan: August 27, 2025 If the Department of Education has questions regarding this plan, please call Tom Ochsner at (402) 465- 2212.

Enrollment Reporting Condition/Context: For one out of 25 students selected in the sample, the effective date that was reported to NSLDS did not match the date that the student changed status. For a second student, the student's enrollment status was not correctly reported within the 60 day requirement Recommendation: The University should review its procedures to ensure that all effective dates for enrollment status chan•;Jes are updated accurately in NSLDS. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: To prevent future occurrences: • We have implemented an additional verification step in our status update workflow. • We are reviewing how major changes interact with enrollment status updates in Colleague. • We will implement a validation step to ensure that effective dates reflect the original action date when multiple updates occur in close succession. Contact person: Tom Ochsner, Director of Scholarships and Financial Aid Planned completion date for corrective action plan: August 27, 2025 If the Department of Education has questions regarding this plan, please call Tom Ochsner at (402) 465- 2212.

Midland University Corrective Action Plan For the Year Ended May 31, 2025 Finding 2025-002: Significant Deficiency - NSLDS Enrollment Reporting Condition: Of the 25 students tested, two students had incorrect or late information reported. One student's withdrawn date reported in spring 2025 did not agree to the University's documentation to support the date of determination. A second student's status' certification date was reported 71 days after their date of determination. Corrective Action Plan: Beginning in Summer 2025, the new Financial Aid Director and Registrar have been meeting bi-weekly to discuss all aspects of enrollment reporting. This will ensure that both offices are aware of reporting requirements and timelines. Name(s) of Contact Person(s) Responsible for Corrective Action: Jon Dechant, Director of Financial Aid & Joseph Harnisch, CFO Anticipated Completion Date: Finding 2025-002: Completed in July 2025

Midland University Corrective Action Plan For the Year Ended May 31, 2025 Finding 2025-001: Significant Deficiency- Return of Title IV funds (R2T4) Condition: Of the 16 students tested in the sample, one student did not have an R2T4 completed during Summer 2024. Subsequent to the auditor identifying this exception in July 2025 the University completed the calculation and returned the required funds. The auditor reviewed the calculation and student's account statement confirming that corrective action was taken. Corrective Action Plan: Beginning in Summer 2025, the new Financial Aid Director and Registrar have been meeting bi-weekly to discuss all changes of enrollment including withdrawals. This process ensures that all students are reviewed and R2T4's are completed on all students who withdraw from Midland University and have Title IV funding. Name(s) of Contact Person(s) Responsible for Corrective Action: Jon Dechant, Director of Financial Aid & Joseph Harnisch, CFO Anticipated Completion Date: Finding 2025-001: Completed in July 2025

Corrective Actions: The University has implemented the following measures with respect to enrollment reporting (“ER”) to strengthen internal controls and ensure full compliance with federal regulations, University policy, and the requirements of NSLDS: 1. Review of ER Systems and Updates Implemented: The University has contracted with external consultants to assist the University in reviewing and reinforcing its ER systems and processes. This work is ongoing and intended to supplement the prior review of the University’s SIS noted in the Response above, which determined a delay in the chronological processing of reports in NSC due to configuration issues in the SIS contributed to the untimely/inaccurate reporting. As a result, the University updated those parameters within its SIS to ensure accurate configuration in Spring 2025. Through this Finding response and the internal and external reviews initiated by the University, Texas Wesleyan has built upon that prior examination to include an analysis of the specific deficiencies noted by auditors and ensure the same have been cured, as well as to implement any necessary compliance measures to safeguard all future ER. In addition to completing any updates required to student-level data in NSC, the University reviewed each deficiency and corresponding student record to discern the cause of the inaccurate data and made necessary systems and/or procedural changes to cure each. First, the University determined that for two of the students with ER errors, additional processes were necessary to capture students enrolled in compressed terms. In collaboration with external consultants and NSC, the Registrar’s Office is developing new processes to ensure accurate ER for these students. This process development is being overseen by Registrar and Associate Provost with a target date for implementation during the initial Spring 2026 7-week compressed terms beginning on January 12th and March 23rd, respectively, subject to testing being conducted with NSC. Second, with respect to graduation status, the University has reviewed the students noted in this Finding with its external consultants and NSC. To ensure that graduation statuses are timely and accurately reported according to University policy and federal requirements, the University is adopting updated procedures to include reporting “G” or “W” status in accordance with guidance from the NSLDS Enrollment Reporting Guide, Section 4.4.4. These procedural updates are being made by the Registrar, overseen by the Associate Provost, and are expected to be finalized by December 5, 2025 Third, together with IT and external consultants, the Registrar’s Office is continuing its review and testing of parameter settings through a comparison of SIS and NSC data to confirm that parameters are accurately configured for ER. The data for this review has been compiled as of the date of this submission and the Registrar is reviewing the data to prepare a comparative report that will be provided to the Working Group (described in Section 2 below) overseen by the Associate Provost. The Registrar’s comparative report to the Working Group is expected to be delivered on January 20, 2026. Finally, as noted below, to ensure timely and accurate reporting and the reconciliation of error reports, the University has implemented several preventive and detective measures with ongoing monitoring and review measures to ensure its compliance. 2. Preventative Measures and Monitoring: The University has integrated, and continues to integrate, updated detective and preventative controls on ER to safeguard the University’s compliance for future reporting by expanding existing reporting controls through regular monitoring efforts to test and review compliance at each reporting level. These preventative measures, monitoring and reconciliation requirements are being overseen by the Associate Provost and include the establishment of a Working Group with external consultants and service providers, as well as stakeholders from the Provost, Registrar, Information Technology, and Financial Aid offices, that meets frequently to review ER, complete the work described in these Corrective Actions, and to ensure discrepancies are discovered and resolved timely and accurately. The Registrar and the Director of Financial Aid also meet monthly to conduct reconciliations of ER which is then reported to the Provost and Associate Provost. In addition to updating its graduation ER procedures, the University has updated its reporting schedule in NSC to provide additional reporting opportunities during the end of the term to ensure all graduation information is timely reported. Finally, the University has met with NSC to review this Finding and its ER practices generally. As a result of that meeting, the University has received from NSC its “Enrollment Reporting Compliance Best Practices Checklist” which the Registrar has provided to all staff in the Registrar’s Office as a guidance document and reference tool for ER. In addition, the Registrar is conducting an office-wide review of the NSC “Enrollment Reporting Compliance Best Practices Checklist” on December 4th, 2025. 3. Staff and Training: In conjunction with this Finding and the internal and external reviews, the University has and continues to review staffing within the Registrar’s Office to ensure appropriate changes have been made as deemed necessary by management. To ensure compliance and accuracy, beginning December 9, 2025, all personnel in the Registrar’s Office will participate in a weekly “Power-Hour” meeting wherein they will complete ER training through NSC, Federal Student Aid, and other resources. This training will continue in accordance with the 2026 training plan and schedule being developed by the Registrar. The training plan and schedule will be delivered to the Associate Provost by January 1, 2026, and is subject to their review and approval. All training and participation will be documented in a report to the Associate Provost. The University has also engaged external consultants to assist staff in ER to ensure compliance and provide secondary review for the Registrar’s Office as needed. Responsible Official: Dr. Helena Bussell, Associate Provost Estimated Completion Date: April 24, 2026

Corrective Actions: To strengthen internal controls and ensure full compliance with federal regulations, the University has implemented the following measures: 1. Secondary Review Implementation: The University has contracted with an external consultant to serve as a secondary reviewer. In the interim, an internal staff member is receiving comprehensive R2T4 training and will complete the NASFAA Return of Title IV Funds Certification Program in March 2026. Upon completion of the NASFAA Program coursework, the staff member will complete an examination on or before May 31, 2026. Once certification is achieved and the University has full confidence in the internal review process, the secondary review function will transition from the external consultant to an in-house process. 2. Documentation Retention Enhancement: The University has reinforced procedures, including those document retention protocols, by adding this as an additional checklist item on the R2T4 checklist, to ensure that all post-withdrawal disbursement notifications are properly retained in each student’s financial aid record, either electronically or within the designated document management system. The checklist is meant to be a roadmap for the reviewer to ensure each step is completed in the calculation process and that documentation is retained for post-withdrawal disbursement. 3. Staff Training: All financial aid staff involved in the R2T4 process have received updated training on the correct handling of loan returns and post-withdrawal notifications in accordance with 34 CFR 668.22 and current FSA Handbook guidance. Staff involved with R2T4 administration include the Financial Aid Business Analyst and a Financial Aid Advisor. Both team members have completed either official NASFAA or FSA training. The Financial Aid Advisor will be completing the NASFAA Certificate training on R2T4. Additionally, the Assistant Director will also complete the program at the same time, increasing the depth of knowledge for the team around this topic. Responsible Official: Doug Cleary, Director of Financial Aid Estimated Completion Date: May 31, 2026

Attached to this document is a new Summer Pell Policy and Procedures that we developed after the Pell finding was brought to our attention this past summer. A mentor from another private institution that uses Colleague (the same system we use) was recommended to our team to help guide us when awarding summer Pell using the Pell Grant Enrollment Intensity formula. We implemented training on the Enrollment Intensity formula and had various calculation scenarios tested by our new mentor. We then awarded all summer term students who were entitled to the Pell Grant award and disbursed aid to those students by the required deadline. For the future, we will follow the newly developed Summer Pell Policy and Procedures. We will engage with the Registrar's Office to determine and verify when students register, drop and/or change courses for the summer term. In addition, running weekly Informer reports will be another safety net for our office when determining Pell eligibility for summer students. The Financial Aid staff will also immerse themselves in various forms of training available to us on all aspects of processing and awarding aid. We will do this via webinars, TASFAA and NASFAA training opportunities, internal cross-training and various FSA training programs. This year, two members of our team are new to financial aid and the remaining two, including myself, are new to our positions and responsibilities. We feel taking advantage of the plethora of training resources available in our industry will be vital to our growth and success while navigating higher education's rapidly changing regulations. Person ResponsibLe for Corrective Action PLan: Hayley Jordan - Director of Financial Aid Anticipated Date of Completion: Implemented.

The College acknowledges that it did not have a full understanding of the differences between and purpose of the NSC reporting file types “Subsequent of Term,” “End of Term,” and “Degree,” which lead to the incorrect file being submitted at the conclusion of Spring 2025. As a result, NSLDS records for 433 students were not updated in a timely fashion. In order to remediate the NSLDS records, the College worked with the NSC to recall and resubmit all files for period May to September 2025. As of October 2025, all Spring 2025, Summer 2025, and Fall 2025 to-date data reported to the NSLDS properly reflects student statuses. The College will continue to work with the NSC to ensure that “Pre Term”, “Subsequent of Term”, “End of Term,” and “Degree” files are being transmitted in an orderly, timely, and automated manner that minimizes the need for staff intervention. The College will follow NSC’s best practices guidance on data file management. The Planned Corrective Action will be implemented immediately.

Return of Title IV (R2T4) Calculations Planned Corrective Action: OFA will implement a process where an additional person will review R2T4 student records to ensure proper return of funds and calculations. OFA and VPAA will develop a process for instructors and Registrar to identify students that did not begin attendance. Person Responsible for Corrective Action Plan: Stephanie Castillo, Director of Financial Aid Penny Hayes, Vice President of Academic Affairs Anticipated Date of Completion: Spring 2026

Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) Planned Corrective Action: Financial aid will be working closely with the Registrar and the Vice President of Academic Affairs to clean up all current records and CIP codes. The OFA and VPAA will maintain a schedule for updates of student statuses and CIP codes. The OFA will also use a secondary person to view reports before transmission. OFA will work with NCH to update CIP codes. Person Responsible for Corrective Action Plan: Stephanie Castillo, Director of Financial Aid Penny Hayes, Vice President of Academic Affairs Anticipated Date of Completion: Fall 2026

CONDITION: During uring testing of 40 Pell Grant recipients, two awards were miscalculated--one over-award and one under-award--due to data-entry error and lack of secondary review. Corrective Action: The College has reviewed all Pell awards for the 2024-2025 award year to identify and correct any additional errors. Effective immediately, the Financial Aid Office will: 1. Implement a secondary review of all Pell award calculations prior to disbursement. 2. Reconcile ISIR data to the financial-aid system each term. 3. Provide annual staff training on Pell payment schedules and data accuracy. Documentation of the secondary review will be retained in each student's electronic record.

Department of Education 2025-001 NSLDS Reporting Recommendation: We recommend FSC have a process in place to review the information NSC provides to NSLDS for accuracy. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: A report has been developed in Jenzabar that, when executed, identifies any program enrollment status date discrepancies (null or mismatched dates). Once identified, the dates are corrected on the Jenzabar report prior to the data being uploaded to NSC. Name(s) of the contact person(s) responsible for corrective action: Megan Herring Planned completion date for corrective action plan: 8/1/2025

Enhance Controls over Enrollment Reporting Process: We will conduct periodic reconciliations (at least quarterly) between our internal records and NSLDS data to identify discrepancies and implement follow-up procedures for discrepancies, including timely investigation and resolution. lmprove Data Transmission and Reporting: We will review and update our current data transmission processes to ensure accurate and timely reporting of graduation data to NSLDS. Additionally, we will provide training to staff responsible for enrollment reporting on updated procedures. Monitoring and Quality Control: The Office of the Registrar (MS. Cristian Martinez, University Registrar) will work with the Office of Institutional Research (Ms. Alexandra Purdy, Institutional Research Associate) on enrollment reporting to the National Student Clearinghouse so that accurate records are then submitted to NSLDS to ensure compliance with federal regulations. Regular reviews of NSLDS data will be conducted to ensure accuracy and completeness by the Office of Financial Services (Mr. Preston Wheeler, Associate Director of Financial Aid and Students Accounts) once data are submitted. Responsible Personnel: The Office of the Registrar (Ms. Cristian Martinez, University Registrar) in conjunction with the Office of Financial Services (Mr. Preston Wheeler, Associate Director of Financial Aid and Student Accounts) will be responsible for implementing and overseeing the corrective action plan. The expected date for completion is December 15, 2025.

lmplement a Secondary Review Process: We will designate a financial aid staff member to perform a secondary review and approval of all Return of Title IV funds calculations to ensure accuracy. The Office of Accounting & Business Services will verify the calculations prior to issuing any payments. This process will be implemented within 30 days of the date of this letter. Enhance Documentation: We will develop standardized documentation procedures to accurately record withdrawal dates and payment period parameters including modifications to both PowerFAIDS and Jenzabar systems. This will be completed within 60 days of the date of this letter. Staff Training: We will provide training to staff within the following offices (Financial Services, Accounting & Business Services, Registrar) on the regulatory requirements association with Return to Title IV funds and the updated procedures and calculation processes within 30 days of the date of this letter. Quality Control: We will establish a quality control process to monitor and review Return of Title IV funds calculations on a regular basis, starting immediately. This includes installation of additional technology available to automate the calculation process in our systems. The University will also ensure the Office of Financial Services reviews system configurations at the start of each term. Responsible Personnel: The Office of Financial Services Director of Financial Aid and Student Accounts, Mr. Preston Wheeler, and Vice President for Enrollment Management, Mr. Alan Liebrecht will be responsible for implementing and overseeing the corrective action plan. In addition, the Assistant Vice President for Finance, Dr. Kaisa Holloway-Cripps will verify the implementation of the secondary review process, enhanced documentation procedures, and staff training and completed. Monitoring and Reporting: We will review the effectiveness of the corrective action plan to ensure compliance with federal regulations by mid fall 2025 semester and continue the review throughout the academic year. The Office of Financial Services will maintain records of the corrective actions taken and provide updates to the University's administration as necessary. The expected completion date of this corrective action plan is December 15, 2025.

Finding 2025-004: Student Financial Aid – Enrollment Reporting Finding: For four out of forty (10%) student enrollment reporting selections, the student's status change at the campus level and program was not properly reported to NSLDS with the required timeframe. Cause: The student's status change was after the last scheduled reporting transmission file of the semester, therefore their status change was not captured in the NSLDS reporting submission. Corrective Actions Taken or Planned: During the Summer of 2024, the Registrar’s Office was undergoing a period of transition. The newly appointed Registrar, Mai Aly, had just started in her role, and the Associate Registrar was out on medical leave. This staffing disruption contributed to delays in identifying and processing student status changes, which in turn impacted the timeliness of NSLDS reporting. To address this issue and strengthen compliance with NSLDS reporting requirements, the College has implemented the following measures: 1. Operations Calendar: The Registrar’s Office has developed and implemented a comprehensive Operations Calendar. As part of this calendar, withdrawal reporting tasks have been scheduled at the beginning of June, July, and August to ensure timely identification and submission of summer enrollment changes. 2. Designated Responsibility: The Associate Registrar has been assigned as the primary staff member responsible for reporting summer withdrawals to the National Student Clearinghouse (NSC), ensuring continuity and accountability in the reporting process. 3. Staff Training and Documentation: Relevant staff have been retrained on NSC/NSLDS reporting requirements to reinforce procedures for monitoring and reporting enrollment changes during the summer months to prevent future summer enrollment reporting issues. Contact Person Responsible: Jennifer Kenworth, Associate Registrar Lake Forest College Completion Date: 11/1/2025

Finding 2025-003: Student Financial Aid – Excess Cash Finding: Lake Forest College had excess cash for the FDL program ranging from $24,903 to $3,683,698 during the period of January 30, 2025 through February 7, 2025. In this situation, the excess cash exceeded one percent of total prior year drawdowns, and the amount was not returned within a seven-day period. Cause: The College drew down funds in advance of the Spring semester which is allowed based on the College’s cash management method. However, due to timing differences, the funds were not ultimately disbursed to students until 8 days after the drawdown was made. Corrective Actions Taken or Planned: On January 27, 2025, the Office of Management and Budget issued a directive pausing the disbursement of federal grants and loans, effective the following day. With uncertainty surrounding whether this pause applied to the FDL program, its duration, and the potential impact on the College’s cash flow, the Business Office made a one-time exception to its longstanding best-practice process. Instead of using finalized disbursement data, the College opted to draw funds based on preliminary disbursement information to mitigate potential financial disruption. To prevent recurrence and ensure compliance with federal cash management regulations, the College has implemented the following corrective measures: 1. Return to Standard Practice: The Business Office has resumed its standard drawdown procedure, which utilizes finalized disbursement data after the College’s add/drop date to ensure alignment with actual student disbursements. 2. Contingency Protocol for Exceptional Circumstances: In the event of future extraordinary circumstances, the Business Office will implement a conservative drawdown buffer, limiting initial draws to no more than 66% of preliminary disbursement estimates. This approach will reduce the risk of excess cash while maintaining operational flexibility. 3. Enhanced Coordination and Communication: The Business Office will maintain close coordination with the Office of Financial Aid, along with federal agencies and monitor guidance during periods of uncertainty to ensure timely and compliant decision-making. Contact Person Responsible: AJ Rodino, AVP for Business Lake Forest College Completion Date: 11/1/2025

Corrective action for the 2024-25 academic year has been completed. The Annual Cost information will be updated automatically by Herring Bank by August 30th each year to our website. The director of student accounts or her assignee will review the fees charged by Herring Bank at least every two years to ensure they are at or below market value.

Corrective Actions: Management acknowledges the audit finding related to the timing of the Title IV credit balance refunds during FY25. Beginning in FY26, the University has transitioned to a new student information system, Workday, which significantly enhances our ability to manage financial aid disbursements and credit balance refunds in compliance with federal regulations. In the new system, financial aid disbursements will occur after the add/drop period, which better aligns with federal compliance timelines. Workday also provides automated reporting capabilities that allow the Student Financial Services office to easily identify students who have received Title IV funds, enabling staff to prioritize those accounts and ensure refunds are issued within the required timeframe. The system automates many manual processes, which increases efficiency and reduces the likelihood of delays. In addition, staff have received training on the new system and procedures, and an internal monitoring process now in place to ensure continued compliance with refund requirements. Contact Clara Wells at cwells1@trinity.edu or (210)999-7333.

Finding Number: 2025-001 Untimely Returns of Title IV Funds (R2T4) Planned Corrective Action: Shorter University has reviewed its policies and procedures related to the timely Return of Title IV financial aid. On October 24, 2025 the Provost will meet with the SU faculty to review the importance of reporting a student's non-attendance to the Office of Student Engagement and Success. The Director of Student Engagement and Success is responsible for identifying students who have not attended classes in the last 14 calendar days. Upon identification, the non-attending students will be forwarded to the Office of the Registrar who will withdraw them from the University. The Director of Financial Aid runs the withdrawal report weekly and will verify that the last date of attendance and the date of notification are 14 days apart. The Director of Information Technology will modify the withdrawal report by adding a Notification Date that is 14 days from the last date of attendance. The late returns were a result of using an incorrect date of determination. The new amended withdrawal report will provide the actual date of notification based on the last date of attendance rather than the date manually entered into the system of record. Beginning with the 2026-2027 academic year Shorter University will no longer be an attendance taking institution for the traditional student population. Person Responsible for Corrective Action Plan: Colleen Lassiter Anticipated Date of Completion: 10/31/25