Corrective Action Plans

MSU Denver IT Security will update its written information security program to address the necessary requirements of the Gramm-Leach-Bliley Act. The WISP will be reviewed and updated at least once each year, with updates being based on risk assessments, audits, changes to the environment, and any incidents which indicate a need for changes to the WISP. The updated WISP will include existing policies as well as new policies that describe standards for: • Periodic inventory of data • Multi-Factor Authentication, Single Sign-On, and passwords • Assessment of applications developed by the institution • Testing our safeguards The updated WISP will be formally reviewed and approved by the Chief Financial Officer by June 30, 2026.

The Colorado State University and Colorado State University – Pueblo campuses will strengthen their internal controls to ensure enrollment changes are reported within the required 60-day timeline for newly enrolled students. Additionally, the Colorado State University and Colorado State University – Pueblo campuses will improve the documentation provided as part of compliance testing as both students referenced within the finding were unique situations. In both instances referenced, additional context was not provided during compliance testing for both students that was not captured on the provided National Student Loan Data System Campus Enrollment Details webpage that showed the appearance of reporting an enrollment status change outside of the 60-day requirement. For the Colorado State University, the student was reported with an effective date of the beginning of the Fall 2024 Semester but did not complete verification procedures until February 2025 and was then disbursed the Fall 2024 portion of their Pell Grant. For Colorado State University – Pueblo, the student was reported with an effective date of the beginning of the Fall 2024 Semester, but corrections were required on the student’s FAFSA before federal student financial aid could be disbursed. The campuses will improve documentation provided during compliance testing for when these unique situations with enrollment reporting occur.

Subject: Corrective Action Plan for Federal Direct Student Loans Program Compliance The University of the Pacific acknowledges the findings outlined in the audit related to the reporting of student enrollment status to the National Student Loan Data System (NSLDS) for the Federal Direct Student Loans Program (Federal Assistance Listing Number: 84.268) for the award year July 1, 2024 – June 30, 2025. The audit identified a system-level transmittal configuration issue in which campus-level enrollment updates inadvertently overrode certain program-level enrollment status fields within NSLDS reporting. We take our responsibility to comply with the federal regulations under 34 CFR Section 685.309 very seriously and are committed to strengthening our internal controls and system governance processes to ensure accurate, complete, and timely reporting of enrollment changes at both the campus and program levels. Corrective Action Plan: To address the identified deficiency, Finding# 2025-001, related to program-level enrollment status reporting and to strengthen preventive controls over NSLDS submissions, the University has implemented the following measures, effective immediately (February 19, 2026): 1. Root Cause Isolation and System Logic Review: The University identified that a specific NSLDS transmittal file configuration resulted in campuslevel enrollment updates overriding program-level enrollment status fields. In collaboration with Information Technology, the Registrar’s Office has isolated the reporting logic and corrected the configuration to prevent program-level status fields from being overwritten by subsequent campus-level submissions. Documentation of the revised logic has been retained for audit purposes. 2. Full Population Review and Remediation: The University will conduct a comprehensive review of NSLDS records for the affected student population to confirm accuracy of program-level enrollment status. Where discrepancies are identified, corrected submissions will be transmitted promptly to NSLDS. Documentation of the review and any corrections will be maintained to ensure a complete audit trail. 3. Segregation of Campus-Level and Program-Level Reporting Logic: Enrollment reporting procedures have been updated to formally distinguish campus-level and program-level reporting workflows. Any future modifications to enrollment reporting logic will require documented change management review, regression testing, and joint approval from the Registrar’s Office and Information Technology prior to implementation. 4. Targeted Program-Level Monitoring Dashboard: In addition to existing monthly NSC and NSLDS reconciliations, the Registrar’s Office will implement a targeted monthly exception report specifically monitoring program-level enrollment status changes. This report will identify discrepancies between SIS records and transmitted data, including concurrent program records and recent status changes, to ensure ongoing data integrity. 5. Quarterly Compliance Sampling and Oversight: On a quarterly basis, an independent staff member not involved in file preparation will conduct a sampling review of transmitted NSLDS records to verify program-level status accuracy. Results will be documented and reviewed by the Registrar to ensure sustained compliance. 6. SOP Enhancement and Staff Training: The University has updated its Enrollment Reporting Standard Operating Procedures to incorporate explicit review steps for program-level data validation and transmission oversight. Targeted training has been provided to staff responsible for enrollment reporting to reinforce compliance expectations and system configuration awareness. The University remains committed to ensuring accurate and timely reporting of student enrollment data in full compliance with federal regulations. These enhanced preventive and governance controls build upon prior corrective actions and further strengthen the integrity of our Title IV reporting framework. Anticipated Completion Date: 6/30/26 Person Responsible: Michael Snyder, Associate University Registrar

Reference Number: 2025-001 Finding: Other Instance of Noncompliance and Deficiency Status: In-Progress Corrective Action: An instance was found where the R2T4 calculation for one student had a typo of the incorrect date. This was subsequently corrected. We reviewed this student record and concluded that it was a human error made. There is no pattern of incorrect information being used. To avoid future errors, the Assistant Director will meet with the Dean monthly and we will review completed R2T4's during that period. We believe having another pair of eyes to review the work completed will be sufficient to correct any inconsistencies. Person(s) Responsible for Implementing: Lynda McKendree, Dean of Scholarships and Financial Aid and Thuylieu Aligo, Assistant Director of Scholarships and Financial Aid. Implementation Date: 1/27/2026

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 Contact Person: Sabina Yesman, Director of Financial Aid A PELL Grant was awarded and disbursed for one ineligible student during the 2024-2025 Academic Year at Benjamin Franklin Cummings Institute of Technology (FC Tech). The error resulted from incomplete synchronization between enrollment and financial aid systems during the system transition period. Specifically, enrollment status and census-date verification were not fully integrated into the automated disbursement workflow, allowing aid to disburse before final eligibility confirmation. FC Tech has taken corrective measures and implemented monitoring and system controls to prevent future errors from occurring. Corrective Action Taken  FC Tech reviewed the student’s record and confirmed the ineligibility.  The PELL Grant award was adjusted to $0, and the disbursement was reversed.  The student account was corrected, and all required accounting and G5 drawdown adjustments were completed. The amount of $3,697 was returned on 12/18/2025  The case was documented internally for training purposes. Preventive Measures Implemented (February 2026) To prevent recurrence, FC Tech has implemented the following controls:  Enrollment Verification Prior to Disbursement All PELL-eligible students must be actively enrolled and confirmed in the Student Information System (Jenzabar) prior to disbursement.  Census-Date Verification Through Multiple Systems Enrollment status at census date is now validated through an integrated, multi-system verification process involving the Jenzabar, our Financial Aid System (PowerFAIDS), and Registrarconfirmed Enrollment Reports.  Delayed Disbursement Timeline Federal Aid disbursements are scheduled to occur no earlier than one week after census date to allow sufficient time for enrollment stabilization, drops, corrections and reconciliation  System Edit/Control Automated system edits have been implemented to prevent a PELL disbursement if census-date enrollment status is missing, unconfirmed, or inconsistent across systems.

The district will review expenditures to make sure activities June 30 or prior and July 1 through August 31 are accurately accounted for on the expenditure report that requests this split.

Reports were submitted after the 20th deadline - some within 2-3 days of that 20th date deadline. Moving forward reports will be submitted to Mrs. Forck to submit to ISBE by the 20th of each month.

Corrective Action Plan Thursday, February 12, 2026 Harrisburg Area Community College respectfully submits the following corrective action plan for the year ended June 30, 2025. The findings from the June 30, 2025 audit report dated February 13, 2026 schedule of findings and questioned cost are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Agency: (Federal Agency per Finding): U.S. Department of Education Audit Period: July 1, 2024 – June 30, 2025 Name and Address of independent public accounting firm: Smith Elliott Kearns & Company, LLC, Certified Public Accountants & Consultants, 804 Wayne Avenue, Chambersburg, Pennsylvania 17201 Finding Type: (per Finding) Federal Awards: Material Weakness in Internal Control over Compliance and Noncompliance Internal Control Type: (please choose the type per the finding)  Material Weakness(es) o Significant Deficiencies Audit Finding No.: 2025-001 Federal Program: (per Finding) Student Financial Assistance Cluster Compliance Requirement: (per Finding) Return of Title IV Funds Audit Finding Title/Statement of Condition: (copy from audit findings documentation): The College did not comply with federal requirements related to the timely return of Title IV funds. Specifically, the College failed to return aid for four students who never attended within the 30-day period required under 34 CFR 668.21(b). In addition, the College did not return funds for one student who began attendance but subsequently required a refund within the 45-day timeframe mandated under 34 CFR 668.173(b). Auditor Recommendation: (copy from audit findings documentation) The College should strengthen its internal controls and monitoring procedures to ensure compliance with federal return-of-funds requirements. This should include timely verification that calculated refund amounts match what is actually returned, improved review processes to confirm that students who never attended are identified promptly, and training for relevant staff to ensure consistent understanding and execution of federal aid return requirements. Specific steps to be taken to correct the situation [including a timetable for performance of the CAP] or reason why corrective action is not necessary (including disagreement with the finding). The College has made several enhancements that should prevent future problems with the return of funds. 1) In fall 2025, the College instituted a new process for collecting data for attendance/participation of students. This process includes a data collection approximately one week into the part of term (the “Academic Participation Data Collection) – and before the disbursement of Title IV aid. It also includes follow up with faculty at several intervals throughout the semester to encourage them to withdraw students who have stopped attending. This improved process gives us clearer and more transparent data on attendance/participation so that aid recalculations and returns can be managed in a more timely manner 2) As of January 2025, the College has implemented a process to prevent the disbursement of Title IV (TIV) aid to students who are not enrolled in a future semester or are not considered actively attending. For example, if a student attended the Fall semester but is not enrolled for the Spring semester, Title IV funds cannot be disbursed if the aid was not originated before the student became ineligible. This process applies in both directions, as disbursement includes both paying funds to a student’s account and reversing funds when appropriate. Accordingly, the Previous Semester Fund Request process is designed to ensure that Title IV funds are either paid or reversed in compliance with federal requirements. 3) The Financial Aid team will continue processing returns at the time that an R2T4 occurs to prevent miscommunications and ensure timely completion. 4) The Financial Aid team and Finance teams will collaborate and engage Bank Mobile to improve the processing of stale checks and timed out funds. Anticipated Completion Date: May 1, 2026 Name(s) and Title(s) of contact person(s) responsible for correction action: Tim Barshinger, Associate Vice-president of Student Enrollment Services Juan Cordoba, Financial Aid Director

Views of Responsible Officials and Corrective Action Plan We concur. Management has implemented an IT-led data mapping review of reporting scripts, biweekly error report checks by Financial Aid Director, and increased reporting frequency to every 30 days.

Views of Responsible Officials and Corrective Action Plan We concur. Management has formed an Academic Calendar Committee for pre-year review, as well as implemented automated short-term date detection in SIS and instituted a secondary review process for all R2T4 calculations.

Views of Responsible Officials and Corrective Action Plan We concur. The Financial Aid Office and IT have Implemented a “Just-In-Time” eligibility verification in MyDelta. Additional manual reconciliation before disbursement has also been implemented.

Student Financial Aid Cluster: Federal Supplemental Educational Opportunity Grant – Assistance Listing No. 84.007 Federal Work Study Program – Assistance Listing No. 84.033 Federal Perkins Loan Program– Assistance Listing No. 84.038 Federal Pell Grant Program – Assistance Listing No. 84.063 Federal Direct Student Loans – Assistance Listing No. 84.268 Teacher Education Assistance for College and Higher Education Grants– Assistance Listing No. 84.379 Nursing Student Loans – Assistance Listing No. 93.364 Recommendation: We recommend that the College work with their third-party servicer and implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS are reported accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: During the short time the Financial Aid Office has had direct oversight of this process, we have substantially reduced the number of incidents. Enrollment Reporting is a top priority. Like our colleagues at other Idaho institutions, we are striving to eliminate all issues with enrollment reporting. Enrollment reports will continue to be submitted monthly. The data is reviewed at various intervals during the process by Registrar and Financial Aid staff, and the reviews are documented. Corrections and updates are provided and submitted as required. Procedures have been updated to reflect all changes and validations. Additional focus will be on the reports that overlap semesters. Timelines will be reviewed and adjusted as determined necessary Name(s) of the contact person(s) responsible for corrective action: Laura Hughes, Soo Lee Bruce-Smith, Travis Osburn, Kim Tuschhoff, and John Bender Planned completion date for corrective action plan: Immediate Implementation

Pennsylvania College of Art & Design Management’s Corrective Action Plan 6/30/25 Finding: Tuition revenue reported on the FISAP did not agree to the final audited general ledger due to timing of preparation and lack of documented reconciliation. Management Response and Corrective Action Plan: Management concurs with the finding. During the fiscal year, the Director of Financial Aid prepared the FISAP using tuition data obtained from the Bursar’s office in early September in order to meet the October 1 filing deadline. At that time, not all year-end adjusting journal entries had been recorded by the Controller, and a formal reconciliation of the FISAP tuition amount to the final general ledger had not been performed. To remediate this issue and strengthen internal controls over federal reporting, the College has implemented the following corrective actions: Formal Reconciliation Requirement Effective immediately, all financial data reported on the FISAP will be reconciled to the final general ledger balances after year-end adjusting entries are posted. Defined Roles and Review Process The Director of Financial Aid will prepare the FISAP using tuition revenue from the Controller-approved general ledger. The Controller will prepare and document a reconciliation between: FISAP tuition revenue General ledger tuition revenue The Chief Financial Officer will review and sign off on the reconciliation prior to FISAP submission. Responsible Officials: Controller (reconciliation), Director of Financial Aid (FISAP preparation), CFO (final review) Implementation Date: Effective for the June 30, 2026 reporting cycle.

Finding 2025-002: Enrollment Reporting Condition: The change in student status for 1 of the 25 students tested was not reported to the National Student Loan Data Systems (NSLDS) within 30 days or included in a response to a roster file within 60 days. However, this student was ultimately reported to the NSLDS. The sample was not a statistically valid sample but was determined using Chapter 21 - Audit Sampling Considerations of Uniform Guidance Compliance Audits of the Government Auditing Standards and Single Audit Guide Corrective Action Plan: The College will closely review submissions to the National Clearing House to alleviate duplicate submissions that override previously submitted data. The College is committed to complete and accurate enrollment data submissions to the National Student Clearinghouse and ultimately to the National Student Loan Data System. Responsible Persons: Kim Peters, Director of Financial Aid and Debbie Schreiber, Registrar Anticipated Completion Date: Immediately

Brooklyn Law School Single Audit Corrective Action Plan For the Year Ending June 30, 2025 Section III - Federal Awards Findings and Questioned Costs Finding 2025-001: Significant Deficiency - NSLDS Enrollment Reporting Criteria: Title IV regulations (34 CFR 685.309(b)) require that upon receipt of an enrollment report from the Secretary of the Department of Education (Secretary), institutions must update all information included in the report and return the report to the Secretary: (I) in the manner and format prescribed by the Secretary; and (ii) within the timeframe prescribed by the Secretary. Unless the institution expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the institution discovers that: (i) a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the student has ceased to be enrolled on at least a halftime basis or failed to enroll on at least a half-time basis for the period for which the loan was intended or (ii) a student who is enrolled at the institution and who received a loan under Title IV of the Act has changed his or her permanent address. Condition: The Law School did not notify the National Student Loan Data System (NSLDS) in a timely manner for 23 students with status changes in our sample of 25 students. For 2 out of 25 students selected in the sample, the effective date that was reported to the NSLDS did not match the date that the student changed status. The sample was not a statistically valid sample. Questioned Costs: There are no questioned costs associated with this finding. Cause: The Law School's controls surrounding the reporting of students’ statuses and status effective dates to the NSLDS did not appropriately ensure the information was submitted accurately or timely. Effect: The accuracy of the Title IV student loan records depends heavily on the accuracy of the enrollment information reported by schools. If an institution does not review, update, and verify student enrollment statuses, effective dates of the enrollment status, and the anticipated completion dates, then the Title IV student loan records will be inaccurate. Recommendation: We recommend that the Law School review its procedures for student status changes and NSLDS notifications to ensure there are follow-up and review procedures being performed for all students with status changes at the Law School to ensure accurate and timely reporting. Management Response: Management agrees with the finding, The Director of Financial Aid and the Registrar will implement procedures and controls in fiscal 2026 to ensure accurate and timely updating of the enrollment reports to NSLDS. Anticipated Completion Date: June 30, 2026 Responsible Person: John K. Zhang, Vice President for Finance and Board Treasurer (718)-780-7503 - john.zhang@brooklaw.edu

Finding 2025-001 The College concurs with the audit finding that students who withdrew at the conclusion of the fall 2024 semester were not reported to the National Student Loan Data System (NSLDS) within the required 60-day reporting timeframe. This occurred as a result of two primary factors: (1) the enrollment reporting schedule with the National Student Clearinghouse was outdated, and (2) the 60-day reporting requirement was not clearly defined within Allegheny’s internal processes. Allegheny recognizes the importance of timely and accurate reporting of students’ enrollment status to NSLDS. Enrollment rosters and updated enrollment statuses are regularly reported to NSLDS to ensure that changes affecting loan repayment obligations and in-school deferment eligibility are accurately reflected within the Department of Education’s records. The College is committed to strengthening its procedures to ensure continued compliance with federal reporting requirements. The College will continue to adhere to NSLDS reporting processes and required timelines. Through enhanced collaboration among the Financial Aid, Registrar’s, and Provost’s Offices, Allegheny will fully align and formalize enrollment reporting procedures. The College will review, verify, and update reporting schedules to ensure accuracy and compliance with applicable requirements. Specifically, the College will annually review its enrollment reporting schedule with the National Student Clearinghouse to ensure that enrollment data is transmitted to the National Student Loan Data System (NSLDS) at least once every 60 calendar days, in accordance with federal reporting requirements. For students who notify the College of their intent to leave at the upcoming conclusion of a semester, the College will report the student as enrolled on the final enrollment report for that term and will then manually update the student's enrollment status to withdrawn within a few days of the report’s submission, rather than waiting for the next scheduled enrollment transmission, to ensure timely and accurate reporting. Allegheny College will implement quarterly review of processes established to ensure compliance. This proactive approach will ensure ongoing compliance with federal regulations. In addition, Allegheny College is developing a secondary review process for each enrollment report submission to identify students with recent or pending enrollment status changes. This review will serve as a quality control check to ensure that students whose enrollment status has changed since the prior reporting period are accurately identified and updated, thereby strengthening oversight and ensuring timely and compliant reporting to NSLDS.

Background During the audit, it was identified that the University did not report all required program-level record elements to the National Student Loan Data System (NSLDS). Cause The root cause of the issue was a gap in our data entry and reporting processes: • Prior to January 1 2025, majors and program-level data for domestic students were entered by the domestic enrollment team. With the transition of responsibilities to the Registrar’s Office, controls were fully aligned to ensure program-level elements were consistently captured and transmitted. Corrective Action Plan The University has taken and will continue to take the following corrective actions: 1. Process Realignment o Responsibility for capturing and validating program-level record elements has been formally assigned to the Registrar’s Office. 2. System Enhancements o Validation reports have been developed to flag missing or inconsistent program-level data prior to NSLDS submission. 3. Follow-Up Monitoring o Quarterly monitoring ensures proactive identification and correction of any missing program-level enrollment data prior to submitting data to NSLDS. Conclusion The University is committed to ensuring full compliance with NSLDS enrollment reporting requirements. We believe the corrective measures outlined above will prevent recurrence of incomplete program-level reporting and strengthen the reliability of our enrollment submissions. Sincerely, Christopher Bryan CFO

Corrective Action Plan: To address the deficiencies identified in Finding 2025-008, the University has implemented and continues to strengthen a Registrar-led corrective action framework focused on improving the accuracy, timeliness, and oversight of Campus-Level and Program-Level enrollment reporting to the National Student Loan Data System (NSLDS). Primary Control Enhancements. The University has engaged Strata Information Group (SIG) to support validation and configuration of enrollment reporting functionality within Ellucian Colleague. This engagement assists the Registrar’s Office in ensuring that enrollment status changes, credential completions, and program-level data are transmitted accurately through established reporting processes. Responsibility for enrollment reporting remains with the Office of the Registrar, with SIG serving in a technical advisory capacity. The Office of the Registrar will establish a structured enrollment reporting cadence, including submission of enrollment files on a bimonthly basis. This reporting schedule will ensure timely identification and reporting of enrollment status changes in compliance with federal requirements and reduce reliance on ad hoc or event-driven reporting. Supporting Controls and Training. To further strengthen upstream data integrity, the Registrar’s Office will implement enrollment governance controls, including restricting late graduation applications and limiting major declarations to designated academic periods. These controls reduce late-cycle data changes that previously contributed to reporting inconsistencies. Monitoring and Quality Assurance. The Office of the Registrar has institutionalized a formal quality assurance calendar requiring enrollment reporting reviews at least twice per semester. These reviews validate the accuracy and timeliness of Campus-Level and Program-Level enrollment data reported to the National Student Clearinghouse (NSC) and, by extension, NSLDS. As part of this monitoring framework, the Registrar’s Office will conduct periodic sampling of reported enrollment records to confirm compliance with reporting timelines and verify the effectiveness of enrollment reporting controls. Sustained Oversight. Any discrepancies identified through quality assurance reviews will be documented, corrected, and evaluated to inform process refinement and prevent recurrence. To support reconciliation and data validation, the Registrar’s Office will meet monthly with the Office of Data Analytics to compare enrollment data within Ellucian Colleague to downstream reporting outputs. Anticipated Completion Date: June 2026

Corrective Action Plan: To address the deficiencies identified in Finding 2025-006, The Offices of Student Accounts and Financial Aid offices (“the Offices”) will improve coordination and communication regarding the timing of fund transfers and refund disbursements. The Offices have established a schedule to begin the refund process 10 calendar days of the credit balance creation date to ensure compliance with the 14-day federal requirement. A written processing calendar has been established to track key deadlines and responsibilities. These actions establish preventive controls to ensure all Title IV credit balances are refunded within the federally required timeframe and to prevent recurrence. Ongoing monitoring of this process will ensure the University issues Title IV refunds within 14 days of the credit balance being applied to the student’s account. Anticipated Completion Date: December 2026

Corrective Action Plan: To address the deficiencies identified in Finding 2025-005, the University has implemented and continues to strengthen a comprehensive corrective action framework focused on automating Return of Title IV (R2T4) processing, clarifying cross-functional responsibilities, enforcing withdrawal data integrity, and institutionalizing quality assurance and supervisory oversight. Primary Control Enhancements. Ellucian Colleague has been configured to automate R2T4 calculations and prevent post-withdrawal disbursements without documented authorization, supported by system-generated audit trails. Supporting Controls and Training. Controls governing withdrawal determination have been strengthened, including required reporting of last date of attendance as a part of grade submission and faculty training to support accurate withdrawal data. This requirement strengthens the integrity of withdrawal data, supports accurate determination of official and unofficial withdrawal dates, and ensures that R2T4 calculations are based on verified enrollment activity. The University has clarified and formalized cross-functional responsibilities related to withdrawal determination and R2T4 processing. Controls now ensure structured communication between academic units, the Office of the Registrar, and the Office of Financial Aid, with defined ownership for initiating, calculating, reviewing, and completing R2T4 determinations. Monitoring and Quality Assurance. To ensure accuracy and timeliness, the University has implemented a secondary review process for all R2T4 calculations. Initial calculations completed in Ellucian Colleague are independently validated using the Return of Title IV calculation tools within the Common Origination and Disbursement (COD) system. This secondary calculation serves as a quality control measure prior to final processing and fund return. In addition, R2T4 activity is subject to periodic quality assurance reviews, including monitoring of calculation timeliness, authorization documentation, and fund return deadlines. Sustained Oversight. Any discrepancies identified by QA reviews are documented, corrected, and reviewed to inform process improvements and staff training. Supervisory oversight is in place to ensure compliance with federal timelines and calculation requirements. Anticipated Completion Date: August 2026

Corrective Action Plan: To address the deficiencies identified in Finding 2025-004, the University has implemented and continues to enhance corrective actions focused on automating loan disbursement notifications, standardizing notification content and timing, strengthening documentation and audit trails, and institutionalizing quality assurance oversight to ensure sustained compliance with federal notification requirements. Primary Control Enhancements. Loan disbursement notifications to the student for Subsidized, Unsubsidized, and Graduate PLUS Loans are now system-generated through Ellucian Colleague, providing automated delivery and a documented audit trail. Notifications are issued upon disbursement processing and delivered through system-supported modalities, including electronic communication and student portal updates. Ellucian Colleague retains a system-generated audit trail documenting the timing and content of each notification, strengthening the University’s ability to demonstrate compliance with federal requirements. This system-based approach eliminates reliance on third-party notification tools previously used and brings direct control of notification sequencing, content, and documentation within the University’s financial aid infrastructure. Supporting Controls and Training. The University has revised the Parent PLUS Loan notification process to ensure that required disbursement information—including the date, amount, and type of loan—is provided directly within the notification communication. While Parent PLUS notifications currently require initiation through a controlled manual process, procedures have been amended to ensure timely issuance, content accuracy, and supervisory oversight during this interim period. The University is actively working with the Ellucian Colleague implementation team to further automate Parent PLUS Loan disbursement notifications and eliminate manual triggering. Until full automation is achieved, documented procedures and quality assurance reviews will serve as compensating controls to ensure compliance with notification timing and content requirements. Monitoring and Quality Assurance. The University established and maintains a formal quality assurance framework to monitor loan disbursement notifications. A quality assurance calendar requires reviews at least twice per semester to confirm that notifications are issued within required regulatory timeframes, include all required elements, and are sent to the appropriate recipient (student or parent). As part of ongoing monitoring, the University has conducted multiple quality assurance reviews of loan disbursement notifications. These reviews have demonstrated improved compliance with notification timing and content requirements while also identifying isolated system sequencing issues that were promptly addressed through configuration updates and enhanced scheduling controls within Ellucian Colleague. Sustained Oversight. Any discrepancies identified through quality assurance reviews are documented, corrected, and evaluated to inform process refinement, system configuration, and staff training. Anticipated Completion Date: September 2026

Corrective Action Plan: To address the deficiency identified in Finding 2025-003, the University has implemented and is continuing to formalize corrective actions focused on strengthening award notification sequencing, automating required communications, and ensuring a verifiable audit trail prior to the disbursement of Title IV funds. Primary Control Enhancements. With the assistance of Financial Aid Services (FAS), Ellucian Colleague has been configured to automate award notification generation upon completion of student packaging, creating a system-generated audit trail that documents notification timing relative to disbursement. This automation ensures that award notifications are issued prior to disbursement activity and creates a system-generated audit trail documenting the timing and issuance of the notification. Supporting Controls and Training. Financial Aid staff receive ongoing system and compliance training to reinforce proper sequencing of notifications and disbursements. Monitoring and Quality Assurance. Routine quality assurance reviews confirm that award notifications are issued and documented prior to disbursement, with exceptions documented and corrected. Sustained Oversight. Any exceptions identified will be reviewed, documented, and corrected to ensure sustained compliance. Anticipated Completion Date: June 2026

Corrective Action Plan: To address the deficiencies identified in Finding 2025-002, the University has implemented and is continuing to formalize a comprehensive corrective action strategy focused on strengthening disbursement scheduling, improving system integration, institutionalizing reconciliation and quality assurance processes, and enhancing cross-functional oversight of COD reporting. Primary Control Enhancements. A standardized disbursement and reporting calendar has been established, and system integration between Ellucian Colleague and Jenzabar has been strengthened to improve consistency of cost-of-attendance and disbursement data transmitted to COD. For the 2025–2026 academic year, the Office of Financial Aid and the Office of Student Accounts are disbursing Title IV aid on the second and fourth Tuesday of each month. This schedule has been jointly approved and will continue to be followed by both departments to ensure consistency between disbursement activity and COD reporting. Supporting Controls and Training. Staff participate in targeted training related to COD reporting and cash management through NASFAA and FSA to reinforce knowledge of reporting timelines and requirements. Monitoring and Quality Assurance. A formal financial aid compliance calendar has been developed and institutionalized, outlining required quality assurance (QA) reviews by month, identifying responsible departments, and requiring documented supervisory sign-off. Reviews of COD reporting timelines are conducted twice per semester, and any discrepancies identified are documented, reviewed, and resolved in a timely manner. A systematic monthly reconciliation process has been instituted and is maintained involving the Office of Financial Aid, the Office of Student Accounts, and Budgets & Grants Accounting to ensure consistency across internal systems and COD reporting. Sustained Oversight. Any discrepancies identified through reconciliation are documented, communicated to relevant departments, and resolved, with formal supervisory sign-off required from the Assistant Director of Financial Aid and the Director of Budgets & Grants Accounting. In addition, Financial Aid maintains standing bi-weekly coordination meetings with Student Accounts and Business Office staff to support ongoing alignment related to Title IV disbursement activity and COD reporting timelines. Anticipated Completion Date: June 2026

Corrective Action Plan: To address the deficiencies identified in Finding 2025-001, the University has undertaken and continues to implement a comprehensive corrective action strategy focused on strengthening financial aid systems, standardizing processes, enhancing staff capacity, and institutionalizing quality assurance and oversight mechanisms. Primary Control Enhancements. The University transitioned from PowerFAIDS to Ellucian Colleague as the system of record for financial aid awarding, enabling automated enforcement of packaging, eligibility, and fund-specific awarding rules. System configuration enhancements now support accurate cost of attendance calculations, enforcement of loan limits, and eligibility sequencing based on updated ISIR data, reducing reliance on manual intervention. Supporting Controls and Training. To support the implementation and stabilization of these controls, the University partnered with Financial Aid Services (FAS) in February 2025 to conduct a comprehensive review of financial aid systems, processes, and internal controls. Through this partnership, FAS has provided experienced Colleague specialists to support annual system setup, troubleshooting, validation of awarding rules, and targeted staff training. In addition, Financial Aid staff participate in ongoing professional development through the National Association of Student Financial Aid Administrators (NASFAA) and Federal Student Aid (FSA) to ensure continued proficiency and regulatory awareness. Monitoring and Quality Assurance. A formal quality assurance framework has been institutionalized, requiring eligibility and award accuracy reviews at least twice per semester. Reviews validate FSEOG prioritization by Student Aid Index (SAI), resolution of ISIR comment codes prior to disbursement, compliance with annual and lifetime loan limits, and alignment between cost-of-attendance values maintained in Ellucian Colleague and those reported to COD. Since the implementation of enhanced system controls and QA procedures, the University has conducted multiple eligibility and award accuracy reviews across Title IV programs, including Direct Loans, Pell Grants, and cost-ofattendance reconciliation. These reviews have demonstrated improved accuracy and control effectiveness, while also identifying isolated issues that were addressed through system updates or corrective adjustments. Sustained Oversight. Results of quality assurance reviews are documented, corrected, and analyzed to inform system configuration, staff training, and supervisory oversight. These controls ensure that improvements supported through the FAS partnership are institutionalized within university operations and sustained beyond the initial remediation period. Anticipated Completion Date: June 2026

2025-004 REPORTING – CASH MANAGEMENT IMPROVEMENT ACT WEST VIRGINIA STATE TREASURER’S OFFICE (WVSTO) Assistance Listing Numbers: 10.551/10.561/10.555/17.225/20.205/84.010/84.027/84.425/93.558/93.568/ 93.575/93.658/93.659/93.767/93.778/97.036 For the Annual Report filing deadline, December 31, 2025, WVSTO staff experienced multiple extenuating circumstances including training of newer staff members, medical treatments, illness, and the sudden unexpected passing of a close family member. Realizing that these circumstances would interfere with the timely submission of the Annual Report, an extension was requested on December 30, 2025, with the Bureau of the Fiscal Service and was granted through Friday, January 9, 2026. Regrettably, the extenuating circumstances were not fully resolved by that date, and the report was ultimately submitted on January 14, 2026. The WVSTO remained focused on completing the Report but overlooked the need to request an additional extension. WVSTO staff subsequently met with Angela Smith, Director of the Bureau of the Fiscal Service and staff members Mary Bailey and Christopher Bush from the Revenue Collections Management Team. Director Smith confirmed there will be no penalties assessed due to the late filing. Additionally, WVSTO Banking Services staff will review the internal timeline of CMIA activities and procedures to ensure that future reporting is complete and submitted in a timely manner.