Corrective Action Plans

Student Financial Aid Cluster – Assistance Listing No. 84.063 Recommendation: We recommend that the University verifies the enrollment intensity for each student receiving the Federal Pell Grant prior to finalizing their award package. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University is working with a PowerFAIDS consultant to ensure that the correct number of credits populates based on the courses inputted. The issue has also been added to their procedures to check the Class Load and Credits field whenever packaging or revising a student’s aid. Name(s) of the contact person(s) responsible for corrective action: Michael Moos, Vice President of Finance Planned completion date for corrective action plan: June 30, 2026

Finding Number: 2025-001 Federal Agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 & 84.007 Award Year: 2025 Corrective Action Plan: Berkshire Community college agrees with this finding, and upon its review of the affected students and the college’s policies and procedures. The Student Financial Services Office will work with the Registrar and use reports delivered by Institutional Effectiveness to monitor and determine withdrawals on a regular basis. Timeline for Implementation of Corrective Action Plan: Immediately Contact Person: Karrie Trautman, Director of Financial aid

Condition: Of the 25 students selected for enrollment reporting, the University did not update the student enrollment information for four students accurately. Planned Corrective Action: Upon learning of these errors during the audit, the University conducted a review of all 2024–2025 records to ensure that all other reports were accurate. The University uses a third party provider to perform these actions and while the University is responsible for verification, concrete controls have been put in place. The University will examine and compare NSLDS data three times per year to identify and resolve any inconsistencies in a timely manner. Additionally, the third party provider has indicated it is reviewing its internal practices to help ensure similar reporting issues do not occur in the future. Contact person responsible for corrective action: Data & Insights Analyst Anticipated Completion Date: Implemented as of 3/1/2026

Finding number: 2025-001 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 and 84.268 Award year: 2025 Corrective Action Plan The College will ensure sufficient processing time for the National Student Clearinghouse (NSC) to report graduates to the National Student Loan Data System (NSLDS) within the required federal reporting timeframe. During Fall 2024, the College was required to submit a second graduate file. By the time this file was processed by NSC and transmitted to NSLDS, it exceeded the 45-day reporting deadline. To prevent recurrence, the College will implement earlier internal processing deadlines and enhanced monitoring of graduate file submissions. In addition, the College will promptly review and correct any graduate records rejected by NSC and ensure that all statuses are accurately updated in the NSC system prior to transmission to NSLDS. For withdrawal reporting, the College applies the following standards: • If a student withdraws from the College after completing all courses in the final sub-term of a semester, the effective date reported is the semester end date. • If a student withdraws from the College and withdraws from all courses during the final sub-term, the effective date reported is the official date the student submits withdrawal from both the College and the courses. Conferral dates are established by the College and may differ from the semester end date. The College maintains three conferral dates annually: Spring, Summer, and Fall. Enrollment reporting for graduates will reflect the official conferral date as determined by the institution. Timeline for Implementation of Corrective Action Plan End of Fiscal Year 2026 Contact Person Stephanie King Executive Director of Student Financial Services

Finding number: 2025-002 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 and 84.268 Award year: 2025 Corrective Action Plan This discrepancy resulted from a data entry error during the enrollment reporting process. Upon identification, the record was corrected and resubmitted to NSLDS with the accurate effective date. To prevent recurrence, the institution is evaluating its procedures to ensure the correct effective date for enrollment changes are reported correctly to the National Student Clearinghouse and NSLDS. Timeline for Implementation of Corrective Action Plan Management anticipates implementing the corrective action as soon as possible, with completion expected by June 30, 2026. Contact Person Stephanie King Executive Director of Student Financial Services

Finding number: 2025-001 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 Award year: 2025 Corrective Action Plan This occurred due to a manual review oversight during the enrollment status verification process prior to disbursement. Upon identification, the award was reviewed, and corrective action was taken to adjust the Pell Grant to the appropriate part-time amount. The institution has since reinforced its review procedures by implementing an additional verification step to ensure enrollment status is accurately confirmed before Pell Grant disbursements are finalized, thereby reducing the risk of similar errors in the future. We have completed a review to ensure no other students were in this situation and we found no additional students. Timeline for Implementation of Corrective Action Plan Management anticipates implementing the corrective action as soon as possible, with completion expected by June 30, 2026. Contact Person Stephanie King Executive Director of Student Financial Services

Student Financial Assistance – Assistance Listing No. Various Recommendation: We recommend the College evaluate its procedures and policies surrounding NSLDS reporting to ensure all status changes are reported timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Erikson Institute’s Registrar’s Office has worked with National Clearinghouse representatives to identify and correct specific issues to ensure all students are reported properly and prevent additional errors. Names of the contact persons responsible for corrective action: Gilbert Martinez, Registrar and Leanne Beaudoin-Ryan, Executive Director of Institutional Effectiveness.

Student Financial Assistance – Assistance Listing No. Various Recommendation: We recommend the College evaluate its procedures and policies around reporting Unsubsidized Loan disbursements to COD to ensure that student information is reported accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Financial Aid Department will no longer disburse loans or report disbursements to the Department of Education multiple times weekly. Effective December 2025, Erikson Institute Financial Aid department only makes disbursements and reports them to the Department of Education on Fridays of each week. This is to ensure that the disbursement date in both Erikson’s student information system, Jenzabar, and COD match. Names of the contact persons responsible for corrective action: Monique Foster, Director of Financial Aid Planned completion date for corrective action plan: 12/2025

The College implemented a new financial aid system in FY26 which includes built in controls to detect and flag disbursement date discrepancies throughout the disbursement process. The reconciliation files generated from the new system include a comparison of disbursement dates which makes any differences easy to see and rectify.

The Town should review the restricted reserve requirements and establish a separate account to hold the funds.

Condition: The audit identified instances in which enrollment status changes for withdrawn students were not reported to the National Student Loan Data System (NSLDS) within the required 60-day timeframe and in some cases the withdrawal date reported did not reflect the student’s actual Last Date of Attendance (LDA). Cause: The discrepancies occurred because the academic term end date was used instead of the student’s actual Last Date of Attendance for certain withdrawn students. In addition, in limited cases enrollment status changes for students who did not return for a subsequent term were not reported within the required 60-day window due to the timing of non-returning student reporting cycles. Corrective Action Plan: Sauk Valley Community College will implement revised procedures and additional monitoring controls to ensure that enrollment reporting to NSLDS complies with federal requirements. The College submits enrollment reporting through the National Student Clearinghouse, which transmits enrollment data to NSLDS on the College’s behalf. The College utilizes an internal system to generate enrollment reporting files based on institutional enrollment and withdrawal data. The Registrar reviews the file prior to transmission to the National Student Clearinghouse for submission to NSLDS. Enrollment reporting is currently submitted on a monthly basis. To address the reporting discrepancies identified in the audit, the College will implement the following corrective actions: 1. Accurate Withdrawal Date Reporting Procedures will be updated to ensure that the effective withdrawal date reported to NSLDS reflects the student’s actual Last Date of Attendance (LDA) recorded in institutional records rather than the academic term end date or administrative processing date. 2. Monthly Reconciliation Process The Registrar and Financial Aid Office will perform a monthly reconciliation of institutional withdrawal records to NSLDS enrollment reporting data to confirm that enrollment status changes and withdrawal dates have been reported accurately and within the required reporting timeframe. 3. Monitoring of Potential Unofficial Withdrawals Students who receive all “F” or “W” grades will be reviewed as potential unofficial withdrawals to ensure that the correct Last Date of Attendance is identified and reported when applicable. 4. Monitoring of Non-Returning Students Students who do not return for the summer or fall term following the spring semester will be reviewed by the end of June to determine whether a withdrawal status must be reported to NSLDS. The College will follow the National Student Clearinghouse guidance regarding non-required term enrollment reporting to support accurate status reporting. 5. Ongoing Compliance Oversight Financial Aid and the Registrar will work collaboratively to review enrollment reporting data on an ongoing basis to ensure compliance with federal reporting requirements, including the 60-day reporting requirement for enrollment status changes. 6. Staff Training and Procedural Reinforcement The Registrar and the Financial Aid Office will review NSLDS enrollment reporting guidance and applicable federal requirements with relevant staff to reinforce proper reporting procedures and ensure consistent understanding of withdrawal date reporting requirements and timelines. These procedures will provide additional oversight to ensure that withdrawal dates are reported accurately and that enrollment status changes are transmitted to NSLDS within the required timeframe. Responsible Officials: Jennifer Schultz, Dean of Student Services, Lizzie Harper, Director of Financial Assistance, and Meagan Rivera, Registrar Planned Implementation Date: The revised procedures will be implemented immediately, beginning with the current enrollment reporting cycle, and will continue as an ongoing compliance control.

The College is dedicated to ensuring the accuracy of reporting to the NSLDS. The following is how the College plans to verify the integrity of NSLDS reporting: The staff responsible for correcting records will receive targeted instruction emphasizing accuracy, verification and accountability. A secondary verification process is planned to be put in place to ensure that a secondary review is performed to confirm reported information and address any discrepancies. Name(s) of Contact Person(s) Responsible for Corrective Action: Victoria Stozek, Director of Financial Aid, vstozek@dccc.edu Anticipated Completion Date: 6/30/26

The institution acknowledges the reporting discrepancy related to Spring 2025 enrollment reporting. While the final Spring 2025 enrollment file should have been submitted prior to the start of the Summer 2025 term, it was instead submitted on May 29, 2025, after the Summer term began on May 20, 2025. As a result, the file was processed with summer enrollment data rather than final spring enrollment data, including the appropriate graduation statuses. Although a Graduation (DegreeVerify) file was submitted on May 15, 2025, this file updates the National Student Clearinghouse (NSC) degree database for verification purposes only and does not update the enrollment database used for reporting to NSLDS unless specific services are enabled. At the time, the institution was not participating in NSC’s “G from Degree” functionality, which would have facilitated the automatic application of graduation statuses to the enrollment database. Additionally, delays and inaccuracies in Fall 2025 First of Term reporting (including incorrect term begin dates in files submitted on August 25 and September 15, 2025) further delayed the accurate reporting of raduated students. The corrected file was successfully processed on October 14, 2025. During Fall 2025, the institution was also engaged in FVT/GE reporting corrections. These corrections triggered system-generated enrollment updates, which ultimately resulted in the reporting of affected graduates to NSLDS; however, this occurred later than required. The institution recognizes that timely and accurate enrollment reporting is critical to ensuring that borrowers do not incorrectly enter repayment or lose in-school deferment status. Corrective Action Plan To prevent recurrence, the institution has implemented the following corrective actions: 1. Established Reporting Calendar and Internal Deadlines A formal enrollment reporting calendar has been implemented requiring: o End-of-Term files to be submitted after final grades are posted and degrees conferred, but prior to the start of the next term. o First-of-Term files for the fall and spring semesters must be submitted to NSC no later than three (3) business days before month-end. This timeline allows sufficient time to identify and resolve errors prior to NSLDS reporting. For the summer semester, First-of- Term file submission may extend through mid-June, which is acceptable given that student enrollment during a summer term is not required. 2. Implementation of NSC “G from Degree” Functionality As of February 11, 2026, the institution is actively utilizing NSC’s “G from Degree” service to ensure that graduation records submitted through DegreeVerify are evaluated and, when eligible, automatically applied to the enrollment database. 3. Review of “G Not Applied” Reports A required reconciliation process has been established: o After each DegreeVerify submission, staff will review the “G Not Applied” report. o Any students not automatically assigned a graduation status will be manually reviewed and, if appropriate, reported correctly on the next enrollment file. 4. Data Validation Controls Prior to Submission The Registrar’s Office has implemented a pre-submission validation checklist that includes: o Verification of term begin and end dates o Confirmation of degree conferral status o Review of enrollment status accuracy Files will not be submitted until all validation steps are completed. 5. Monitoring and Quality Assurance o Enrollment reporting submissions will be logged and reviewed each term for timeliness and accuracy. o Any errors identified will be documented and addressed through corrective follow-up. 6. Staff Training and Documentation Staff responsible for enrollment reporting have received updated training on: o NSC reporting requirements o NSLDS timing expectations o Use of NSC tools including DegreeVerify and “G from Degree” Written procedures have been updated and standardized. Responsible Official: Jill Johnson, Registrar (864) 587-4232 johnsoj@smcsc.edu

Recommendation: The University should review its policies and procedures around COD reporting to ensure students’ information is reported timely and accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: • Implementation of a monthly process where the Associate Director of Financial Aid Technical Operations will pull and review, on the 15th of each month, the Pell Reconciliation Report from the Common Origination and Disbursement (COD) website to ensure timely and accurate reporting to COD regarding Pell disbursements. • In addition to the Pell Reconciliation Report, the School Account Statement (SAS) would then be shared with the Disbursement Accounting Manager in Accounts Payable to compare their internal student disbursement records with the U.S. Department of Education’s official data, ensuring funds drawn down match those awarded. • This process will ensure that disbursement reviews occur more frequently and within the 15-day window from any given disbursements. It will also help identify discrepancies in student Pell Grant and Direct Loan amounts to maintain compliance and provide a consistent approach that minimizes risk of error or delay in disbursements. Name(s) of the contact person(s) responsible for corrective action: Leida Nieves, Executive Director of Financial Aid Services Planned completion date for corrective action plan: June 30, 2026

2025-001 Student Financial Aid Cluster – Assistance Listing Numbers 84.063 and 84.268 In general, Cheyney University continues its trajectory of cross-functional and interrelated institutional improvements, particularly those impacting the National Student Loan Data System (NSLDS) that is reported through National Student Clearinghouse (NSC). Cited in the CLA Single Audit, nonetheless, are instances of inaccurate, late, or not reported enrollment and program level data to NSLDS. This response is intended to explain these reporting deficiencies and offer a corrective plan of action including timelines. Point Of Contact: • Dr. Denise Pearson, Provost – dpearson@cheyney.edu • Stephanie Stevens, Associate Registrar – sstevens@cheyney.edu • Jean Dixon, Associate Registrar – jedixon@cheyney.edu Explanations: This section represents Cheyney University’s effort to explain the causes for CLA Single Audit finding. Although the reporting deficiencies span multiple years, it is instructive to note that they are attributed to various and differing circumstances. While Cheyney University was on HCM2, the delay in Claims processing impacted the reporting in Common Origination and Disbursement (COD) and the reporting to NSLDS. The delays in approved claims caused an impact on NSLDS postings for enrollment reporting. This required Cheyney University administration to transfer from NSC to manual enrollment entry into NSLDS. The idea was to manually enter students’ records in NSLDS so that students’ enrollment could be reported more quickly. This is referenced in Single Audit Report, June 30, 2022; page 132. Cheyney is acutely focused on working toward compliance with NSLDS reporting requirements. Through this lens, it was discovered that during the 2024-2025 conversion to the Ellucian Banner system certain decisions were made regarding the conversion of student academic histories. During the research of errors and warning records received from the NSC upload, it was determined that program level information was not properly ported over to the new system. Cheyney University is pursuing a corrective course of action to improve this data to ensure accuracy in reporting. In May 2025, Cheyney University and NSC amended its agreement resulting in a shift in reporting student enrollment and program level data back to NSC from NSLDS that resulted in an additional delay in reporting. Due to these circumstances, the university dedicated significant resources to building capacity and capability in the Office of the Registrar, the functional area responsible for NSLDS reporting. These resources are being deployed in a variety of ways as noted in the Corrective Action Plan below. Corrective Action Plan Overview: 1. Hired a season University Registrar with superior, proven, leadership and technical skills. Emphasis has been placed on performance metrics that align with operational goals and objectives. STATUS: Anticipated March 2026. 2. Targeted professional development for Office of the Registrar and other staff including Banner training, NSC/NSLDS Reporting, and other dependencies. STATUS: Ongoing 3. Establishment of a dedicated compliance unit to support the university’s policies, standards, and procedures ecosystem. STATUS: Completed December 2025. 4. Hired a dedicated Chief Information and Technology Officer (as opposed to the use of third-party vendors). STATUS: Completed, March 2026. 5. Prioritized strengthening communication and collaboration with other enrollment management areas to establish cross-functional responsibilities and timelines (e.g., financial aid, admissions, and bursar offices). STATUS: Ongoing. Key Performance Indicators: During the Spring and Fall 2026 semesters: 1. The University Registrar will show outcomes-driven leadership practices that foster improved departmental performance, including audit citations. 2. Registrar and adjacent staff will demonstrate comprehensive capability and capacity in all areas related to NSC and NSLDS operations and reporting on a timely schedule. An organizational calendar is being developed to ensure this goal is met. 3. Utilizing the NSLDS instructional guide, train the Registrar and adjacent staff to improve the knowledge of the step-by-step process procedures for enrollment reporting, error correction, warning management, and internal audit review of NSLDS files. 4. Develop NSC instructional guide on reporting, error and warning management, and submission of monthly reporting data. 5. The Director of Policy and Compliance will collaborate with the Office of the Provost and Registrar Office staff to create and maintain a policy, procedures, and standards environment that supports operational excellence and efficiency (including more timely and accurate reporting). 6. The Chief Information and Technology Officer will conduct a comprehensive assessment of technology needs in the Office of the Registrar, including outcomes driven recommendations. 7. The Provost will establish Office of the Registrar protocols for collaboration with the Office of Communications to reinforce clarity, consistency, and transparency in all related matters. 8. The University Registrar will demonstrate that all staff have the requisite knowledge and skills to effectively mitigate future reporting deficiencies. Cheyney University acknowledges and affirms that this corrective action will be implemented, assessed, and become a standard operating procedure.

Recommendation: The University should review its reporting procedures to ensure that students’ statuses are timely reported to NSLDS as required by Federal regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Increased frequency of NSC Submissions. Completing the error files returned to NSC quickly within the first 1-4 days of receipt after sending the files back. • We met with another PASSHE school on 4/22/25 and they helped us to strategize ensuring we meet the 60-day window for withdrawals by individually updating the withdrawal information in NSC on a weekly basis using our withdrawal report to identify each student withdrawal between our regular submissions. (Because we met with them so late in the audit cycle, we were not able to correct course for FY25 in time.) • We have adjusted our degree verification timeline, ensuring that the large bulk of our degree verification submission to NSC is completed within 2 weeks of the end of the graduating semester, ensuring that the bulk of our graduating students are moved from NSC to NSLDS sooner. • We updated our change of major policy to ensure that students are not changing majors after the end of the drop/add period. Prohibiting mid-semester major changes for the current semester will greatly reduce the number of status change errors reflected in NSC. This cleaner approach ensures less risk of error or delay related to volume. This was formalized with KU Policy ACA-029, approved at Senate on 9/4/25. Name(s) of the contact person(s) responsible for corrective action: Ben Trout, Registrar Planned completion date for corrective action plan: June 30, 2026

Centre College has further evaluated its policies and procedures for student status change reporting. We are implementing an additional student enrollment reporting from our Registrar to NSC/NSLDS during our non-compulsory January term to ensure timely reporting of students who graduate or withdraw between our final fall and initial spring semester reports. We will also provide ongoing training for sustained compliane with applicable procedures and monitor the additional reporting cycle during implementation.

The College will be looking at making some business process changes to review files submitted to NSC (National Student Clearing House) and NSLDS (National Student Loan Data Service) monthly and perform monthly data reconciliation between responsible offices to ensure students are accurately reported to ED/NSLDS. This new implementation will allow the College/Office to better verify each student’s enrollment status and visibility of reporting issues in the future. Timeline for Implementation of Corrective Action Plan: The procedure was implemented starting with the Spring 2026 semester and has continued since. Contact Person: Alex Jean-Jacques, Director of Financial Aid Operations

Student Financial Assistance Cluster – Assistance Listing No. 84.033 Recommendation: We recommend the University review current processes for calculating and tracking the students employed in community service activities for its Federal Work Study funds to meet the minimum 7% requirement. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University is prepared to return the FY25 FWS Unspent portion of the 7% Community Service required spending (7% of Final FWS Funding of $742,211 = $51,954.77 (rounded to $51,955) [Community Service spending requirement] minus $25,061 (FWS funds spent in community service as reported on FISAP) = $26,894 (Unspent portion of 7% to be returned to ED). Since the pandemic year, ISU’s off-campus (community service) participation has been dwindling and overall FWS participation has suffered since many students and employers are opting to be involved in the University’s Career Path Internship (CPI) program over FWS. Due to the struggles in recent years to meet the 7% Community Service requirement, ISU has been applying for a waiver of the Community Service requirement but thus far our waiver requests have been denied. The Financial Aid Office is reviewing current processes related to tracking FWS Community Service spending and partnering with the Career Center to proactively identify off-campus participants and looking at ways to cooperate with the University’s CPI program participants who are FWS-eligible and who are working in Community Service activities and plan to expand on-campus FWS Community Service opportunities to meet the minimum 7% community service requirement. Name(s) of the contact person(s) responsible for corrective action: James Martin, Director of Financial Aid and Katheryn Wareing, Senior Accountant for Financial Aid/FWS Administrator Planned completion date for corrective action plan: 08/24/2026

Student Financial Assistance Cluster – Assistance Listing No. 84.033, 84.268, 84.063 & 84.007 Recommendation: We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Reason for 2024-004 Finding’s Recurrence: Related to case identified where a corrected Last Date of Attendance (Effective Date in Banner System on SFAWDRL input by the Financial Aid Office for a fully online student during the Unofficial Withdrawal [post term] Return of Title IV processing) was not carried over to Status Date in Banner maintained by the Registrar’s Office and to NSC/NSLDS so that all are reporting the accurate Last Date of Attendance, the University found that corrected dates during the semester aligned and were being reported to NSC/NSLDS in a timely manner, but that corrected dates after end of term were not being transmitted to NSC and NSLDS. Related to case identified of not reporting Graduated status to NSLDS in a timely manner: Typically, it takes approximately 2–3 weeks after commencement to clear degree audits and begin awarding degrees, as commencement occurs before final grades are released. The Graduate-only upload to NSC was completed on May 21, 2025.However, due to limitations with the National Student Clearinghouse (NSC) system, which does not accept multiple awards being posted simultaneously, we received an error report affecting approximately 60% of our graduates. Records included in this report must be corrected manually, which is a time-consuming process. We actively work to correct these records as quickly as possible within our current human resource limitations. The corrected error file related to the 2025-002 finding was uploaded to NSC on July 11, 2025, and sent to NSLDS on 7/12/2025. Action taken in response to finding: The University reviewed its procedures and implemented steps in our Unofficial Withdrawal [post term] Return of Title IV business process to include an email communication plan between the Financial Aid staff and the Office of the Registrar along with documentation sharing and added review steps to ensure the post-term corrected Last Date of Attendance is updated in all affected institutional and federal systems in a timely manner. The Office of the Registrar will correct errors returned from NSC within four weeks of receiving the file. To ensure this task is completed in a timely manner, we will allocate additional human resources as needed. Name(s) of the contact person(s) responsible for corrective action: Hala Abou Arraj, Registrar, and Jody Finnegan, Associate Director of Financial Aid Completion date for corrective action plan: 08/06/2025

Student Financial Assistance Cluster – Assistance Listing No. 84.268 Recommendation: We recommend the University review reporting processes to ensure all students that require exit counseling receive it in a timely manner. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University reviewed its procedures and reporting processes and added calendar reminders to run queries around our census day each term (since the case identified in the audit was due to a timing issue of a student’s aid period revision and when our automated Exit counseling processes are turned on) to find students who were missed by our automated processes for the adding of EXIT tracking requirement and ensuring timely notifications to the students. Name(s) of the contact person(s) responsible for corrective action James Martin, Director of Financial Aid and Jody Finnegan, Associate Director of Financial Aid Completion date for corrective action plan: 8/12/2025

Finding Number: 2025-004 Condition: The University did not provide notifications to certain students related to Pell grants. Planned Corrective Action: During the implementation of Anthology Student, the University did not receive sufficient system configuration support or training from Anthology to properly establish automated Financial Aid Offer and Title IV notification workflows. As a result, the institution did not have the required functionality in place to automatically notify students of their Pell Grant eligibility, scheduled disbursement amounts, and the timing of those disbursements as required under 34 CFR 668.165(a). This lack of configuration and training created gaps in communication and ultimately led to instances in which students did not receive timely notifications before Pell Grant funds were disbursed. Once the University identified these deficiencies, immediate corrective measures were implemented to ensure short-term compliance. Beginning in May 2025, the Financial Aid Office instituted a formal manual notification process. Staff now generate Packaging Status and Disbursement reports on a weekly basis, and these reports are reviewed and acted upon at least bi-weekly to ensure that all upcoming disbursements are captured. Individualized Title IV and Pell Grant notifications are sent to students prior to the crediting of funds. To strengthen internal controls, a secondary review was added so that another staff member verifies that all required notifications have been issued before any Title IV disbursement occurs. These interim procedures and safeguards will remain in effect until the automated notification workflow is fully configured, tested, and implemented. Contact person responsible for corrective action: Chad Curley, Director of Financial Aid Anticipated Completion Date: Corrective Action is currently implemented, starting May 2025

Finding Number: 2025-003 Condition: The University did not have controls in place to ensure appropriate reporting to COD. Planned Corrective Action: The primary cause of this issue was the significant lack of training and support provided during the implementation of Anthology Student. Similar to the challenges experienced with Return to Title IV (R2T4) processing, University staff did not receive adequate instruction on how to perform Title IV reconciliations within the system or how to extract the data needed to compare internal records with COD. This lack of foundational training made it extremely difficult for staff to understand required reconciliation procedures, identify discrepancies, or troubleshoot system-related issues. In addition, the technical limitations of Anthology Student significantly hindered the University’s ability to perform timely and accurate reconciliations. Anthology Student does not provide a comprehensive or efficient reporting tool that allows users to pull Title IV awarding and disbursement data in a format that aligns with COD records. Staff must manually compile information from multiple system screens and reports, a process that takes several hours and still does not produce a clean, fully reconcilable output. Discussions with other Anthology client institutions confirmed that they are experiencing similar challenges with timely reconciliations due to the system’s reporting limitations. Compounding these reporting challenges, the batch transmission functionality between Anthology Student and COD has been unreliable. Files routinely fail or become “stuck” during transmission, but Anthology offers limited visibility into batch processing status. Until February 2026, the University relied on a system report to identify failed or stalled batches; however, an Anthology system update removed this report and the capability altogether. Without access to this tool, staff have had little ability to monitor or verify successful COD transmission, further complicating reconciliation efforts. Another contributing factor is staffing capacity. The Financial Aid Office has limited personnel, and the extensive time required to manually pull data, consolidate reports, and investigate discrepancies has made it challenging to dedicate the uninterrupted hours required for reconciliation—especially without adequate system training or tools. The University is taking the following steps to address this finding: 1. Scheduled Reconciliation Intervals: Calendar reminders and dedicated appointment blocks will be established every 30–60 days to ensure staff have protected time to complete Title IV reconciliations. 2. Staff Training and Support: The Financial Aid Office will continue working with Anthology Support to obtain the training necessary to understand where and how to locate all required Title IV data within the system. We will also pursue additional training and documentation from Ellucian/Anthology on proper reconciliation procedures. 3. Enhanced Manual Oversight: Until system reliability improves, staff will continue performing manual reviews of Title IV disbursements, adjustments, and COD submissions to confirm accuracy and identify unresolved transmission issues. These actions will remain in place until Anthology Student provides reliable reporting capabilities and complete, consistent training, enabling the University to perform reconciliations accurately and on time. Contact person responsible for corrective action: Chad Curley, Director of Financial Aid Anticipated Completion Date: Scheduled reconciliation intervals were implemented beginning with the Spring 2026 semester on February 19, 2026. Staff training and the pursuit of additional system support will continue on an ongoing basis as part of the University’s continuous improvement efforts.

Finding Number: 2025-002 Condition: The University did not return all Title IV funds in a timely manner to the Department of Education for certain students who withdrew during the year. Planned Corrective Action: The primary underlying cause of this issues was the significant lack of training, guidance, and onboarding support provided by Anthology during the implementation of the Anthology Student system. Prior to golive, the University was unable to fully test the Title IV awarding, disbursing, and adjustment processes because file transmissions to COD (Common Origination and Disbursement) can only be executed using live data. This limitation prevented staff from validating system behavior in a testing environment and further hindered the understanding of the required processes, procedures, and communication workflows between Anthology Student and COD. As a result, staff lacked critical knowledge needed to ensure Title IV transactions—including those tied to Return to Title IV (R2T4) calculations—were correctly generated and transmitted. Corrective action has already been implemented. The Financial Aid Office now manually reviews and verifies all Title IV awarding, disbursement, and adjustment transactions—including those related to R2T4—to ensure successful submission to COD. Once the R2T4 calculation has been completed in COD, the Financial Aid Advisor manually updates the student’s account in Anthology Student. The Business Office then posts the corresponding adjustment to the student ledger. After the Business Office posts the Title IV activity, the Financial Aid Advisor manually processes the related adjustments and disbursements through COD to ensure the timely return and/or disbursement of funds associated with the R2T4 calculation. These manual oversight procedures will remain in place until the University receives additional and adequate training from Anthology that ensures consistent and reliable electronic transmission between Anthology Student and COD. Contact person responsible for corrective action: Chad Curley, Director of Financial Aid Anticipated Completion Date: Corrective Action Plan was implemented in February 2025

Finding Number: 2025-001 Condition: The University of Rio Grande did not report student status changes accurately for certain students who withdrew during the year. Planned Corrective Action: The Director of Financial Aid and the Registrar will establish a formal communication and notification process to review enrollment statuses and status changes for all students who begin attendance each semester. Recurring meetings and calendar reminders will be scheduled every 30 days to ensure this review is conducted consistently and collaboratively. The University is also in the process of updating its student withdrawal process from a paper/PDF form to a fully electronic submission process. This new system will automatically notify all pertinent departments when a student initiates a withdrawal, ensuring timely communication and reducing the likelihood of missed or delayed reporting. Implementing this electronic workflow will further strengthen internal controls and directly support the corrective action plan. The Director of Financial Aid will receive direct access to the National Student Clearinghouse and will be enrolled in automated email alerts to support timely and accurate reporting of all enrollment changes. In the event the Director of Financial Aid is unavailable for the scheduled 30-day review, a designated member of the Financial Aid Office will participate in the review to ensure the process is completed without interruption. Contact person responsible for corrective action: Chad Curley, Director of Financial Aid Anticipated Completion Date: Corrective action implemented on 2/13/2026. The electronic withdrawal process is set to be implemented by end of May 2026.