Corrective Action Plans

Action Plan - These errors were the result of a new student information system. As part of the implementation process, CIP codes were incorrectly migrated over from our legacy system to the new system (Colleague). This resulted in program enrollment status errors. Corrective Actions Completed: The Registrar's Office conducted a comprehensive review of all active program CIP codes and corrected all identified discrepancies within the student information system. The Registrar's Office is coordinating with Student Financial Services to verify that the 22 sampled students' enrollment and program statuses are accurately reflected in NSLDS. Corrective Actions in Progress: The Registrar's Office is obtaining direct NSLDS access to ensure the office responsible for enrollment reporting can independently review and validate reported data. Access is expected to be finalized by February 27th, 2026. Preventative Controls: Beginning Spring 2026, the Registrar's Office will implement a recurring end-of-term ntrol review. A sample of 12 students will be selected each semester to verify that enrollment status, program status, and CIP code reporting are accurate between the student information system and NSLDS. Results of this review will be documented and retained, and any discrepancies will be corrected prior to the subsequent enrollment submission. The Registrar believes these corrective measures address the root cause of the finding and strengthen internal controls to ensure ongoing compliance with federal reporting requirements. Responsible Official: Danielle Jeffress, University Registrar Estimated Completion Date: May 30, 2026

The College implemented additional procedures to allow earlier detection of fraud.

The College will perform the mass processing for COD reporting on a more frequent basis to ensure reporting is timely.

Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) Planned Corrective Action: Report training has been implemented and will continue on an ongoing basis to ensure compliance. We will implement periodic spot checks to prevent this issue from recurring and to ensure that all students are properly enrolled each semester. Person Responsible for Corrective Action Plan: Registrar, Elena Majerowicz Anticipated Date of Completion: Already Implemented

Late Return of Title IV Funds Calculations Planned Corrective Action: We have implemented a document processing system in collaboration with our third-party administrator and the Student Accounts Office to ensure that funds required to be returned as part of the R2T4 process are processed on time. Person Responsible for Corrective Action Plan: Giselle Atenco, Director of Financial Aid Anticipated Date of Completion: Already Implemented

Need Analysis Planned Corrective Action: System-generated notifications have been implemented within our student information system to flag any academic year changes or required reviews. In addition, a periodic review process of student award packages has been established to ensure funds are awarded accurately and in accordance with applicable awards. Person Responsible for Corrective Action Plan: Giselle Atenco, Director of Financial Aid Anticipated Date of Completion: Already Implemented

Views of Responsible Officials and Planned Corrective Actions – While the Financial Aid Office does have two personnel reviewing each R2T4 calculation, the same was not done with the online calendars setup in COD. The Director will now review each online calendar before they are utilized. The Office of Financial Aid performed a review of the population of 672 students, noting an incorrect amount of funds was returned to the Department of Education for 32 of those students. The College has corrected and sent back the additional funds that the students were not eligible to receive.

Views of Responsible Officials and Planned Corrective Actions– The National Student Clearinghouse (NSC) Graduation Status submission calendar will be updated to reflect the necessary reporting timeline. NSC graduation status submission reports will be completed after verification of graduation requirements and credentialing are completed in Jenzabar by the Registrar's Office. Submission of graduation status to NSC will occur after each academic session and semester, to capture both traditional and non-traditional conferrals.

Student Financial Aid Cluster – National Student Loan Data System (NSLDS) Reporting Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We have reviewed and updated our documentation, as needed; we have worked with our vendor to locate one source of errors and have corrected those issues in our database; we have started a two-person check on our enrollment and graduation uploads. Name(s) of the contact person(s) responsible for corrective action: Kelly Rowett-James Planned completion date for corrective action plan: We have completed the documentation review and the work with the vendor. We have started our two-person check on enrollment uploads and will continue to do so going forward; our first graduation upload will be done in May and we will start our two-person check for that type of transmission with that upload. If the U.S. Department of Education has questions regarding this plan, please call Jennifer Gallagher at 410-778-7765.

Eligibility Student Financial Assistance Cluster – Assistance Listing No. 84.063, 84.033, 84.268, 84.007 Recommendation: We recommend the University review its procedures to ensure that title IV funds is awarded correctly. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Pell Grant awards are reviewed prior to each disbursement. SCU has strengthened this control to ensure award amounts are adjusted to accurately reflect each student’s enrollment intensity at the time of disbursement. This review is documented and completed by the Director of Financial Aid before funds are released to ensure compliance with federal requirements. Name(s) of the contact person(s) responsible for corrective action: Laney Morales, Director of Financial Aid Planned completion date for corrective action plan: 12/1/2025

Return of Title IV (R2T4) Returning of Funds Student Financial Assistance Cluster – Assistance Listing No. 84.063, 84.033, 84.268, 84.007 Recommendation: We recommend the University review its procedures to ensure that title IV funds required to be returned are done within 45 days after the date of the institution's determination that the student withdrew. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The existing Return of Title IV (R2T4) process was evaluated, and an additional oversight control was implemented to ensure timely returns of funds. All R2T4 calculations are reviewed weekly by the Assistant Director of Financial Aid. During this standing review, the return process is initiated through Jenzabar Financial Aid and confirmed on Common Origination and Disbursement (COD). This control provides documented oversight and ensures returns are completed within required timeframes, mitigating the risk of delays or batch processing errors. Name(s) of the contact person(s) responsible for corrective action: Janeth Chaidez, Assistant Director of Financial Aid. Planned completion date for corrective action plan: 12/1/2025

NSLDS Enrollment Reporting Student Financial Assistance Cluster – Assistance Listing No. 84.063, 84.033, 84.268, 84.007 Recommendation: We recommend the University review its reporting procedures to ensure that enrollment and program information is accurately reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: A complete review of CIP code usage will be reviewed and ensure that there is alignment across academics, registrar, and financial aid. The last review was done in 2024 but with changes alignment fell out of sync. We are also working with our SIS vendor, Jenzabar, to continue to identify areas where the SIS is out of sync with compliance and how best to e􀆯ectively address them if it is a data issue or an issue with internal SIS logic. We are also actively engaging with the National Student Clearinghouse to identify issues and clean them up proactively. Registrar updated internal processes to ensure enrollment status reporting aligns with NSLDS guidance by using the Date of Determination (DOD), rather than the graduation or term end date, as the exit date for graduates. This approach is consistent with federal guidance and has been implemented. Name(s) of the contact person(s) responsible for corrective action: Robert Boggs, EdD, University Registrar Planned completion date for corrective action plan: 3/6/2026 for the CIP audit; 8/31/2026 for SIS and NSC; internal process changes are complete.

2025-002 Initial Fiscal Year End, 2025 Summary of Finding- During the audit, it was noted the University could not provide support for the last day of attendance to complete the return of Title IV funds for one of the students tested. This lapse in communication between departments led to a variance in the reported last day of attendance, which in turn did not provide a firm last day for calculating return of funding. Name and Title of Responsible Contact Person(s)- Jane Hodgkins, Vice President for Finance Corrective Action Plan Summary- The Finance Department will implement a compliance checklist to be used when a student begins the withdrawal process or when their absence becomes noticed. This checklist will comply with the Federal Student Aid handbook. This procedure will ensure compliance between Academic and Financial Aid Departments. This data path will begin with notification of respective departments and initiation by the Academic Department passing to Financial Aid with parallel communication with the Finance Department for compliance and accuracy of dates and ultimately the return of the accurate amount of Title IV funds. Anticipated Completion Date- Feb 28, 2026

2025-001 Initial Fiscal Year End, 2024 Summary of Finding- During the audit, it was noted that the University did not return the determined unearned Title IV funds for one student within the prescribed timeframe which resulted in non-adherence to the 45-day window. Name and Title of Responsible Contact Person(s)- Jane Hodgkins, Vice President for Finance Corrective Action Plan Summary- The finance department has been building back proper procedures and protocol after experiencing several transitions in key departments. The university will institute a compliance checklist that will ensure adherence to the dates for Title IV funding to be returned. This checklist will have the oversight of the Finance department to ensure that action and calculations are done accurately and in a timely manner adhering to the Financial Aid handbook. Anticipated Completion Date- Feb 28, 2026

Identifying Number: 2025-004 Finding: The Academy did not report student enrollment changes within the timeframe outlined by the Department of Education. Name of Contact Person: Alice Herrick, Director of Fiscal Operations; Ryan French, Director of Financial Aid Corrective Actions Taken or Planned: Root Causes Analysis: Upon internal review, several key factors contributing to this deficiency were identified: a. Clearinghouse Processing Gaps: Enrollment reporting at the Academy is managed through the National Student Clearinghouse (NSC), which transmits enrollment updates to the National Student Loan Data System (NSLDS). A review of discrepancies highlighted cases where: o Student withdrawals were not consistently updated within the mandated timeframe. b. Quality Control Mechanism: o There is currently no established process to cross-check NSC submission data with NSLDS and Student Information System (SIS) records to confirm that all changes were processed correctly. Corrective Measures: To address this deficiency, the Academy will implement the following corrective actions: a. Enhanced Collaboration & Process Review (Owner: FA/IT/Registrar, Deadline: April 30, 2025): o The Financial Aid Office will collaborate with the Registrar’s Office and IT to conduct a thorough review of the NSC reporting process. o IT will analyze report generation to determine if student records that should be included in NSC updates are being omitted due to system logic or timing of data extraction. b. Quality Control Implementation (Owner: FA/IT, Deadline: May 15, 2025): o A monthly QC report will be developed to identify students with the NSLDS status “Z – No Record Found” and verify that their enrollment data has been appropriately updated in NSLDS. o A secondary review of withdrawals, LOAs, and “no-shows” will be completed to confirm their enrollment status changes were transmitted correctly to NSLDS. c. Manual NSLDS Updates for Withdrawals (Owner: FA, Deadline: Immediate): o As a temporary solution, the Financial Aid Office will manually update student enrollment statuses in NSLDS following an R2T4 calculation. o This manual review will act as a safeguard to catch the majority of unreported status changes while a more automated verification process is developed. Future Process Improvements & Next Steps a. Automated Data Integrity Checks (Owner: IT, Deadline: June 30, 2025): o IT will determine whether a custom “NSLDS Status” flag can be implemented in the Academy’s SIS to help identify students whose records do not agree with NSLDS or the NSC report. b. Ongoing Compliance Monitoring (Owner: FA/IT/Registrar, Deadline: July 30, 2025): o Academy staff from the Registrar’s Office, Financial Aid, and IT will meet to discuss and document NSC reporting best practices – Internal Procedures, Operational Workflow, Compliance and QC Measures. o A bi-annual audit of enrollment reporting timeliness will be conducted to ensure continued compliance. Conclusion: Maine Maritime Academy is committed to ensuring compliance with U.S. Department of Education regulations and providing accurate and appropriate financial aid awards to students. The corrective actions outlined in this plan address the deficiencies identified in the Uniform Guidance audit and aim to prevent similar issues in the future. The corrective action above for student enrollment was underway during the fiscal year 2025 period under audit. We appreciate the audit findings and remain dedicated to continuous improvement in our financial aid procedures.

Finding number: 2025-001 Federal agency: U.S. Department of Education Programs: Student Financial Assistance (SFA) Cluster Assistance Listing Number: 84.007, 84.033, 84.268, 84.063 Award year: 2025 Corrective Action Plan The Colleges hired a new Chief Information Security Officer (CISO), who has begun overhauling the information security policies to reflect current practices. The CISO has also created a preliminary draft of a WISP that reflects the Colleges current policies and procedures. This WISP is expected to be completed and implemented during fiscal year 2026, pending board review and approval. Timeline for Implementation of Corrective Action Plan Immediately. Contact Person Sharron Scott, CFO

Student Financial Assistance Cluster – Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Recommendation: We recommend the College implement an internal control that ensures timely and accurate reporting. We also recommend the College implement changes in processes and procedures for NSLDS enrollment reporting and implement an internal control that ensures reporting is both timely and accurate. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: An Ellucian consultant provided us with customized process documentation for our new SIS (Ellucian Colleague) which is saved in a shared drive to ensure consistency in the process. The Interim Dean of Students / Financial Aid Director is currently completing the reporting with our Director of Institutional Research receiving the reports and verifying completeness through National Student Clearinghouse, ensuring that there is an internal control. Name(s) of the contact person(s) responsible for corrective action: Sarah Geleynse & Ian Wilson Planned completion date for corrective action plan: Implemented

Student Financial Assistance Cluster – Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Recommendation: We recommend the College return the funds related to unclaimed Title IV–funded checks that are older than 240 days. In addition, we recommend that the College review applicable requirements and implement effective controls and procedures to monitor outstanding Title IV–funded checks throughout the year to ensure timely compliance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Business Office provides a list monthly of the uncashed financial aid checks to the Financial Aid Office. The Financial Aid Office is contacting the students to remind them to cash their checks. The funds for the uncashed checks are returned to the College after 90 days and then returned to the source of the funding. Name(s) of the contact person(s) responsible for corrective action: Margaret Antilla and Layla Solar. Planned completion date for corrective action plan: Already implemented.

U.S. Department of Education 2025-005: Special Tests and Provisions - NSLDS Enrollment Reporting Student Financial Aid Cluster -Assistance Listing No. 84.063, 84.268 Condition: Enrollment status changes were either not reported to NSLDS within 60 days or did not match the College's records for a portion of the sampled students. Recommendation: The institution should evaluate their procedures and policies related to reporting status changes and effective dates to NSLDS and enhance as deemed necessary to ensure that accurate information is reported to NSLDS. Explanation of disagreement with audit finding : There is no disagreement with the audit finding. The Institution acknowledges that while reporting was completed within a timely manner by HCC, NSC did not update within the time allotted to be compliant. HCC remains committed to continuous improvement and compliance. Action taken in response to finding: As noted in the prior year's response, the College committed to full implementation of corrective actions by June 30, 2026, aligned with the conclusion of the 2025-2026 academic year. The institution is currently and actively working on the corrective action plan previously submitted. Actions underway or in progress include: Formal clarification of interdepartmental roles and responsibilities, establishing the Records, Registration and Veteran's Affairs (RRVA) as the primary enrollment reporting authority, with defined review and compliance support from Financial Aid Services. Enhanced reconciliation and quality control procedures, including routine cross-checks between RRVA and Financial Aid Services records prior to each enrollment reporting submission. Standardized review protocols for program-level enrollment changes, including graduates, withdrawals, and subsequent reenrollments in different academic programs. Ongoing monitoring and documentation of NSC errors and warning reports, with timely resolution and escalation when discrepancies appear to originate outside of the College's student information systems. Targeted training for RRVA and Financial Aid staff on enrollment reporting regulations, NSLDS requirements, and audit-risk mitigation. The College believes these actions, coupled with existing reporting practices, sufficiently address the concerns raised and will further strengthen enrollment reporting accuracy and documentation. Full implementation of the corrective action plan remains on schedule for completion by June 30, 2026, as originally committed. Name(s) of the contact person(s) responsible for corrective action: Detra Hooper, Financial Aid Director and Jessica Peterson, Registrar Planned completion date for corrective action plan: June 30, 2026 If the U.S. Department of Education has questions regarding this plan, please call Detra Hooper, Financial Aid Servies Director at 443-518-4776.

Corrective Action Plan Finding No. 2025-001 – Eligibility (Federal Work Study Program) Federal Program: Student Financial Assistance Cluster – Federal Work Study (ALN 84.033) Federal Agency: U.S. Department of Education Audit Period: July 1, 2024 – June 30, 2025 Finding Summary During testing of student eligibility, auditors identified one instance in which a student’s Cost of Attendance (COA) was increased by $2,810 due to participation in the Federal Work Study (FWS) program. Federal regulations do not permit an institution to increase COA solely to accommodate FWS eligibility. Although the adjustment did not result in the student receiving aid exceeding financial need, the adjustment occurred due to a misunderstanding of guidance related to the FWS program. Corrective Action Plan Management agrees with the finding. To address the finding and ensure compliance with federal regulations governing the Federal Work Study program, the Office of Financial Aid will implement the following corrective actions: 1. Policy Clarification and Documentation The Office of Financial Aid will revise its internal awarding policies and procedures to clearly state that the standard practice of awarding Federal Work Study funds must fit within the student established Cost of Attendance (COA). Additionally, the revised policy will explicitly include flexibility to increase the Cost of Attendance only because of approved Special Circumstance appeals, consistent with federal guidance and institutional professional judgment policies. Federal Student Aid Handbook: Application and Verification Guide: Chapter 5 – Special Cases 2. Award Adjustment Procedures When a student’s aid package exceeds need due to the addition of FWS, staff will take the following steps: • Reduction of loan awards, when applicable, to allow FWS funding to be added within the student’s financial need limits.A Loan Adjustment Form will be required for all downward adjustments to loan awards to ensure documentation and transparency. These procedures will ensure that aid adjustments remain compliant with federal need-analysis requirements. Implementation Timeline • Policy updates and procedural documentation: Within 60 days • Process implementation: Beginning with the 2026-2027 academic year packaging cycle

Corrective Action Plan for Current Year Findings 2025-001 Special Tests & Provisions – Return of Title IV Funds This Corrective Action Plan has been established by the Financial Aid and Registrar’s Offices to resolve findings related to Return of Title IV (R2T4) calculation errors. The goal of this plan is to ensure 100% data integrity through enhanced system logic, multi-tier manual verification, and cross-departmental reconciliation. Identify and Analyze Errors: The institution conducted a root-case analysis of the identified findings and determined the following: R2T4 Transposition Errors: For five (5) student records, the "Date of School’s Determination" (DOD) and the "Date of Withdrawal/Last Date of Engagement" (LDE) were inadvertently switched during manual entry into the COD system. Corrective Standard: The Withdrawal Date must be verified as the actual Last Date of Engagement (LDE), while the Date of Determination must remain the Banner-stamped withdrawal date. Develop and Implement Data Verification Processes: To prevent recurrence, the following "intrusive checks and balances" system has been implemented: Multi-Tier R2T4 Review (Financial Aid) - A four-point verification process is now mandatory for all Pro-rata calculations: a. Preparation: Financial Aid Specialist calculates the return based on Banner data. b. Validation: Financial Aid Coordinator validates the LDE and DOD against the academic record. c. Confirmation: Financial Aid Manager reviews and confirms previous calculations based on LDE and Banner data. d. Final Oversight: The Director of Financial Aid performs the final verification check before and after the data is committed to the Common Origination and Disbursement (COD) system. e. Standardization: All calculations must include employee initials and date within the Pro-rata Calculation Form, based on the 4-point verification process above, to ensure internal record reconciliation. Person(s) Responsible: Christine Genenbacher-Leinbach, Director of Financial Aid Brittany McKeown, Head of Enrollment, Registrar, Financial Aid Services Timing for Implementation: Currently implemented, as well as a retroactive check of prior R2T4 submissions, starting September 1, 2025. New verification tiers are active as of the current term to ensure immediate compliance without further incidents.

2025-001: Late Return of Title IV Financial Aid - Student Financial Aid Cluster - Assistance Listing #s 84.007, 84.033, 84.063- Grant Period - Year Ended June 30, 2025 Condition Found During our Return of Title IV Fund testing, we noted that the College did not calculate or return Title IV Student Financial Aid for two out of twenty-five students tested until after 45 days when the student ceased attendance. We consider the untimely calculation and Return of Title IV Student Financial Aid to be an instance of noncompliance relating to the Special Tests and Provisions Compliance Requirement. This is a repeat finding of prior year finding 2024-001. Corrective Action Plan In the first instance, the Return to Title IV (R2T4) calculation was completed timely; however, the associated disbursement was not processed within the required timeframe. Going forward, Title IV aid disbursements related to R2T4 calculations will be processed manually at the time the calculation is completed. The institution will no longer wait for regularly scheduled system disbursement dates in these circumstances. In the second instance, the student withdrew from the 8-week-1 courses but remained registered for the 8- week-2 courses; therefore, an R2T4 calculation was not initially completed. The student ultimately did not begin attendance in the 8-week-2 courses, and the 45-day timeframe elapsed. To prevent future occurrences, RLC will complete an R2T4 calculation at the time of withdrawal from the 8-week-1 courses and will reverse the calculation if the student subsequently attends the 8-week-2 courses. Responsible Person for Corrective Action Plan - ReAnne May, Director of Financial Aid Implementation Date of Corrective Action Plan - January 16, 2026

Responsible Person(s): Ida Witherspoon, Chief Financial Officer; William Carter, Federal Reporting Manager Corrective Action Planned: Grants now uses a financial system created report to perform a perfunctory audit, matching submission data received from the various Program and Budget staff against each individual upload into the federal system. Vendors are filtered by ALN by each analyst responsible for monitoring the various ALN's that make up the DSS portfolio. Once the lists are cross checked, DSS reaches out again to the sub awarding authority responsible within the agency to ask for additional FFATA information. Estimated Completion Date: 6/30/2026

Finding 2025-002 - Significant Deficiency in Internal Control over Compliance - Student Financial Condition Found: One undergraduate student had aggregate subsidized loans over the aggregate limit. Corrective Action Plan: Previously, Antioch College utilized loan history data from Free Application for Federal Student Aid (FAFSA). FAFSA data was utilized because National Student Loan Data System (NSLDS) loan history data was not always available when Antioch College prepared financial aid award letters. Due to the potential loan history discrepancies between data reported via FAFSA versus NSLDS, at the start of each academic year, Antioch College now uses NSLDS data to update loan history of each student to ensure Antioch College has the correct loan balances for each student. This procedural change was put into effect with the start of the 2025-2026 academic year. Person Responsible for Corrective Action Plan Implementation: Director of Financial Aid

MSU Denver manages enrollment reporting within the Office of the Registrar. We develop a schedule each calendar year and semester with NSC to identify scheduled reporting dates for each term in alignment with critical semester dates (start, end, drop, etc.). In Fiscal Year 2025, there was a technical issue in which we had to work with our ERP vendor, Ellucian, to provide a solution. The Office of the Registrar will strengthen its internal controls to ensure enrollment changes are reported within the required 60-day timeline.