Corrective Action Plans

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University review their current policies and procedures around credit balances and ensure the processes in place are sufficient to ensure student credit balances due to federal funds are refunded within 14 days. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Controller and the Assistant Director of Student Accounts will review credit balances due to federal funds on a weekly basis to determine the balances that need to be refunded. All credit balances that are identified as valid and owed to the student will now be refunded as part of the weekly refund process. Name of the contact person responsible for corrective action: Douglas Wade, Executive Vice President and CFO Warner Pacific University 2219 SE 68th Ave Portland OR 97215 dswade@warnerpacific.edu Office Phone 503-517-1043 Cell Phone 661-706-8379 Planned completion date for corrective action plan: April 30, 2025

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University review its reporting procedures to ensure the 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: WPU will form an internal committee to meet, review the existing procedures and reporting schedule, and update the procedures and reporting schedule as needed to ensure the students’ statuses are accurately and timely reported to NSLDS as required by regulations. The committee will consist of the Registrar, the Senior Associate Registrar, the Director of Student Finance, and representative(s) from the Controller’s Office. The committee will meet as many times as needed in Fall 2025 to fully review the procedures and reporting schedule, including reviewing any audit findings and making sure that the procedures have been properly updated to prevent the identified issue(s) from recurring in the future. Moving forward, the committee will meet at least once per year to review and update the procedures and reporting schedule, and can meet more frequently if needed to respond to individual situations.

Student Financial Assistance Cluster – Assistance Listing No. 84.033 – Federal Work Study Program Recommendation: We recommend that the University establish procedures to ensure that at least 7% of Federal Work Study allocation is used for community service jobs, or successfully receive a waiver as had happened in previous years. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Director of Financial Aid will monitor the progress of establishing partnerships and FWS community service opportunities, as well as review usage of FWS funds in the community service sector. The Director of Financial Aid will provide status updates to, and seek guidance from, the Vice President of Enrollment and Student Success and Engagement at least two times per term to ensure that WPU is on target to reach the federal requirements around the FWS community service rules. At the end of each award year, the University will evaluate student satisfaction in the community service positions and adjust placements accordingly for the upcoming award year.

Finding – Special Tests and Provisions: Enrollment Reporting – Federal Direct Student Loan Program, Assistance Listing Number 84.268; May 31, 2025 Award Year; U.S. Department of Education Criteria or Specific Requirement Enrollment information, including the effective date of separation from the institution, must be accurately reported within 30 days whenever attendance changes for a student, unless a roster will be submitted within 60 days. The changes include reductions or increases in attendance levels, withdrawals, graduations, and approved leaves of absence. It is the institution’s responsibility, as a participant in the Title IV aid programs, to monitor and report these changes to the National Student Loan Data System (“NSLDS”). (NSLDS Enrollment Reporting Guide November 2022, and 34 CFR 685.309(b)) Condition Of the nine students selected for enrollment reporting testing, two students within the sample were reported to NSLDS outside the maximum 60-day window. This was not a statistically valid sample. Views of Responsible Officials and Planned Corrective Actions The College concurs with the finding. The College will continue to remain vigilant in its oversight over timely communication of enrollment reporting detail to NSLDS. In both instances, the data we had sent to the National Student Clearinghouse (NSC) was not received by NSLDS in a timely fashion. We will review our reporting schedule and make the appropriate changes to our reporting timeline to ensure the data we report to the NSC is subsequently received by NSLDS within regulations. Names of Contact Person Responsible for Corrective Action: Anna Lyons, Associate Registrar Anticipated Completion Date: September 1, 2025

Student Financial Assistance Cluster— Assistance Listing Nos. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend the University 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: Student Financial Services is working with the Registrar to update our reporting practices for students with student teaching requirements. The registrar has connected with the Clearinghouse to confirm and utilize a separate file type for this population, which should resolve the reporting date issue. Name of the contact person responsible for corrective action: Catherine Maun Planned completion date for corrective action plan: May 31, 2026

2025‐001 Significant Deficiency: Working During Scheduled Class Time (U.S. Department of Education, Federal Work Study Program, ALN #84.033) Responsible Officials: Christin Mustard, Director of Financial Aid, is responsible for overseeing campus-based funding, and Melissa Tolbert, Financial Aid Office Manager, manages the work study contracts and training with supervisors and students. Kelly Pennington, Payroll and Benefits Supervisor, is responsible for paying work study students. Summary of Finding: During the audit, it was noted that a student appears to have been paid for Federal Work Study hours logged and submitted for time the student was scheduled to be in class without acceptable exemption, which contradicts guidance provided by the 2024-2025 Federal Student Aid Handbook, resulting in an over-payment of $11. Corrective Action Plan: King University has implemented a new mandatory training module for both work study students and supervisors. This training must be completed before a student is cleared to begin working, and this step will be an annual requirement for all new and returning students and supervisors. The training includes key points from the Work Study Handbook and an assessment test that must be passed in order to be cleared for work. Our Work Study Coordinator is completing individual training with all new supervisors as well as refresher training with returning supervisors. Supervisors are informed of their responsibility to verify the accuracy of all timesheets submitted and to ensure that clocked hours do not overlap with scheduled class time. They are required to meet with their work study students in advance to review the policies and expectations outlined in the Work Study Handbook. Both the student and supervisor must sign a document acknowledging that they have read the handbook. Timely communications and reminders will be sent throughout the academic year to supervisors and students as well. As an added safeguard, our IT department has created a report that compares student timesheets to their class schedules to ensure there is no overlap with class time. This report will be run by payroll or financial aid staff prior to each pay cycle to verify compliance. Anticipated Completion Date: King University has returned the overpayment of $11 to the Department via G6 in September 2025.

Student Financial Assistance Cluster – CFDA No. 84.038 Recommendation: We recommend that the College review all retired/assigned Perkins loan files to ensure MPNs are present and properly retained. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The College will review assigned and retired files for the Master Promissory Notes. Name of the contact person responsible for corrective action: Deb Schmidt, Director of Student Accounts Planned completion date for corrective action plan: February 28, 2026

Student Financial Assistance Cluster – CFDA No. 84.063, 84.268 Recommendation: We recommend the College review its reporting procedures to ensure the students’ statuses are accurately reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: No disagreement with the audit finding. Action taken in response to finding: The College will review our reporting procedures to ensure that students’ statuses re reported accurately to NSLDS, as required by regulations. Name of the contact person responsible for corrective action: Bethany Miller, Interim Registrar; Associate Provost & Chief Data Officer. Planned completion date for corrective action plan: December 20, 2025

Finding Reference Number: 2025-001 Return to Title IV Funds Summary of Finding: During the R2T4 calculation, all Title IV funds from the Direct Loan, Federal Pell Grant, Iraq and Afghanistan Service Grant, TEACH Grant, and FSEOG programs that were disbursed or able to be disbursed should have be included in determining the amount of earned Title IV funds. In performing the calculation for one student, the institution failed to include all applicable federal aid resulting in $220 of excess Pell grant funds being retained on the student’s behalf. The excess funds of $220 were returned to the DOE in July 2025. Entity’s Corrective Action Plan: The University recognizes the importance of accuracy when performing R2T4 calculations. In this particular situation, the employee who performed the calculation was new in the role and had not previously had responsibility for R2T4 calculations. The University has reassigned this responsibility and has provided education and training for the staff responsible for R2T4 calculations for 2025-26. In addition, the University is requiring a review of each calculation by another member of the financial aid staff with knowledge and training on how to perform the calculations. Anticipated Completion Date: September 1, 2025 Name and Title of Responsible Person: Gus Morgan, Interim Financial Aid Director and VP for Enrollment Services

Finding Reference Number: 2025-002 Working During Scheduled Class Time Summary of Finding: Students are not permitted to work in Federal Work Study positions during scheduled class times. Exceptions are permitted if an individual class is cancelled, if the instructor has excused the student from attending for a particular day, and if the student is receiving credit for employment in an internship, externship, or community workstudy experience with exemptions being appropriately documented. The University had a few instances in which appropriate documentation for exemptions had not been obtained by the supervisors. The known error is $99 with extrapolation of the error across the population at $3,115. Entity’s Corrective Action Plan: The University understands the federal guidelines and provided reminders to all students and supervisors, via email, that students are not permitted to work during scheduled class times; the reminders were sent at the end of each pay period throughout the 2024-25 year. In August 2025, the University provided a required training session for all work study supervisors and reviewed the importance of compliance with this specific aspect of managing FWS as well as all other federal requirements governing the Federal Work Study Program. Supervisors and students continue to receive bi-monthly reminders of this policy. Supervisors are expected to monitor when their students are working and to know their students’ class schedules. They are expected to request documentation if clock-in times, or any period of their work shift, falls within a scheduled class time. Additionally, for 2025-26, the Human Resource Office is developing a review process to determine that appropriate documentation has been obtained if a student meets one of the eligible exemption criteria. Anticipated Completion Date: November 1, 2025 Name and Title of Responsible Person: Gus Morgan, Interim Financial Aid Director and VP for Enrollment Services and Rebecca Proffitt, Payroll and Student Employment Coordinator

Name of Responsible Individual: Alex Putzer, AVP of Business and Finance Condition: The University had one instance during the year that were identified in which Title IV funds drawn were held in excess of the allowable time frame. Corrective Action Plan: Upon reviewing the situation that led to this error, it was a result of batches from the student accounts system not being posted to the accounting general ledger on a daily basis. To prevent this error from occurring in the future, the Director of Student Accounts will post batches daily going forward. Additionally, the Controller is cross trained on this function and will fill in when needed to post batches. Anticipated Completion Date: September 30, 2025

Name of Responsible Individual: Alex Putzer, AVP of Business and Finance Condition: The University did not return credit balances to students within the required timeframe. Corrective Action Plan: The University experienced significant turnover of staff in the Business Office, particularly in Student Accounts, during summer 2024 through fall 2024. The University recognizes that there needs to be better checks and balances in place to ensure all credit balances triggered by federal aid are properly refunded to students within the 14-day required period. Director of Student Accounts will more frequently post financial aid awards on student accounts, once a week at a minimum. The Business Office will monitor all refunds and process them twice weekly, with two different staff members cross-trained so that a week is never missed. The AVP of Business and Finance will review the status of all credit balances on Student accounts’ on a weekly basis throughout the year to ensure timely reimbursement. This was identified in the prior year audit, but unfortunately not fixed until well into the 2025 fiscal year. Anticipated Completion Date: May 31, 2025

Name of Responsible Individual: Jeni Wyatt, Assistant Provost for Undergraduate Education Condition: The University did not report students' status changes accurately and within the required timeframe. Corrective Action Plan: The University experienced significant turnover of staff in the Registrar’s Office in fiscal year 2024. This turnover unfortunately was the catalyst for untimely student status change submissions to the NSLDS. This was identified previously; however, the situation was not able to be rectified until well into the 2025 fiscal year. The University has hired new permanent staff, including an experienced registrar. This group has been working with the clearinghouse personnel to work out errors, and reporting is now being addressed in a timely manner. Anticipated Completion Date: September 30, 2025

Need Analysis Planned Corrective Action: 1. A revised internal procedure has been implemented, requiring a secondary review of all loan award allocations prior to disbursement to confirm compliance with federal regulations. 2. Staff members responsible for loan origination and packaging have been assigned refresher training on federal loan awarding requirements, with specific emphasis on annual and aggregate loan limits and the prioritization of subsidized eligibility. 3. System-level reports have been created to identify potential discrepancies in loan allocation, which will be reviewed monthly by the Financial Aid Office. Ongoing Monitoring: The Director of Financial Aid will oversee the monitoring process each term to ensure compliance with 34 CFR 685.203, and 34 CFR 685.301 requirements. Any discrepancies identified will be corrected immediately and documented as part of the institution’s internal compliance log. North Greenville University believes these corrective measures address the issue identified and will prevent recurrence of similar errors. Person Responsible for Corrective Action Plan: Cindi Patterson, Director of Financial Aid Anticipated Date of Completion: October 1, 2025

Re: Response to Reference Number 2025-001 Student Financial Aid Cluster View of Responsible Officials: Comments on Finding and Recommendation The University agrees that the Bursar's office did not refund the student credit balances within the 14-day requirement. One was $19.10 and was missed due to human error in filtering refunds under $25. The second was for $800.00 and was refunded 10 days late. Corrective Action Plan for Reference Number 2025-001 Student Financial Aid Cluster The University Controller and CFO provided additional training and guidance to Bursar's office staff regarding the importance of the 14-day refund requirement on September 11 , 2025. An additional verification step has been added to their weekly refund routine : on Fridays, after the weekly refunds have been processed, they will now review the student aging report and investigate credit balances to verify that no one has been missed and that the University remains in compliance. Mid-America Christian University's Controller, Kim Brock, will be responsible for ensuring this corrective action plan is followed as outlined . Kim can be reached at kim.brock@macu.edu or 405-703-8269.

The University has found a critical breakdown in communication between the Ranch Management department and the Registrar’s Office, stemming from informal, ad hoc processes that have not scaled with institutional needs. Specifically, there is no formal mechanism to ensure that updates to student statuses for the ranch management program are consistently reported or verified. To prevent recurrence of this issue, a process is being implemented that all Non-Degree programs will now be required to perform formal degree audits within the student information system. This ensures consistency in processing and aligns with practices currently used for degree-seeking students. Targeted training and communication will be provided to all Non-Degree program administrators to ensure clarity on new expectations, tools, and timelines. The Registrar’s Office will conduct periodic audits of non-degree program records to verify compliance and identify any further process improvements.

It was discovered that for one student a transcription error was made when transcribing the LDA (last date of attendance) from the student’s return of funds worksheet to SFA’s and Registrar’s enrollment tracking document of return of funds students. This student was an unofficial withdrawal at the end of the Fall 2024 semester. The Compliance Officer created a RT24 workflow tracking worksheet to identify enrollment reporting dates and ensure communication between SFA and the Registrar. This includes, but is not limited to, unofficial withdrawals with a LDA, all Fs with a LDA, and Q drops with an LDA. There may be other reasons there will be different enrollment dates, and those are also charted. The Compliance Officer will now run a query from PeopleSoft that pulls return of funds information directly from the PeopleSoft worksheet. This query will be imported into a tracking worksheet to ensure accurate enrollment reporting dates. This new tracking worksheet will remove the need for any additional manual updates to enrollment data tracking and reduce the possibility of future transcription errors.

The University has implemented data checks for program/plan issues as part of our 12th class day reporting/clean-up. Institutional Research will run these with their other data checks. Any records flagged for errors and anomalies will be reviewed and corrected by the Registrar’s Office including any updates to enrollment reporting with the National Student Clearinghouse. The University also implemented targeted training for staff in the Brite Divinity School on accurate plan code assignment and its direct impact on enrollment reporting. The enhanced training and communication protocols will significantly reduce the risk of similar human errors.

Finding 2025-001 - Special Tests and Provisions - Enrollment Reporting (Noncompliance and Significant Deficiency) Identification of the Federal Program - Student Financial Aid Cluster - Assistance Listing Nos. 840007, 84.033, 84.038, 84.063, and 84.268. Criteria - Institutions are required to report enrollment information under the PELL grant and the Direct loan program via the National Student Loan Data System (NSLDS). The administration of the Title IV programs depends heavily on the accurace and timeliness of the enrollment statuses, program information, and effective dates reported to NDLDS. Institutions are responsible for accurate reporting. According to 34 CFR 685.309(2), the University is required to notifly the Department of Education via the NDLDS if a "student has ceased to be enrolled on at least half-time basis for the period for which the loan was intended". Changes to status are required to be reported within 30 days of becoming aware of the status changing, or with the next schedule transmission of statuses if the scheduled transmission is within 60 days. Condition - A sample of 40 student were selected from the population of all students wo Identification of the Federal Program - Student Financial Aid Cluster - Assistance Listing Nos. 84.007, 84.033, 84.038, 84.063, and 84.268. Criteria - Institutions are required to report enrollment information under the Pell grant and the Direct loan program via the National Student Loan Data System (NSLDS). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and verify student enrollment statuses, program information, and effective dates reported to NSLDS. Institutions are responsible for accurate reporting. According to 34 CFR 685.309(2), the University is required to notify the Department of Education via the NSLDS if a “student has ceased to be enrolled on at least a half-time basis for the period for which the loan was intended”. Changes to status are required to be reported within 30 days of becoming aware of the status change, or with the next schedule transmission of statuses if the scheduled transmission is within 60 days. Condition - A sample of 40 students were selected from the population of all students who received federal student financial aid during the year ended May 31, 2025. We obtained the student records and tested compliance with federal regulations for the specific loans and grants. For 5 out of the 40 students selected for Enrollment Reporting testing, the status change was not reported within the 60-day reporting window after the status change was effective. For 9 out of the 40 students selected for Enrollment Reporting testing, the status change was not reported to NSLDS. For 9 out of the 40 students selected for Enrollment Reporting testing, the status change effective date was not accurately reported to NSLDS. For 2 out of the 40 students selected for Enrollment Reporting testing, the status of the student was not accurately reported to NSLDS. ause - The University’s processes of internal controls for reporting student status changes to NSLDS were not adequate. Effect - Student status changes were not reported to NSLDS within the required timeframe. Identification of Repeat Finding - Repeat finding of prior year finding 2024-001. Recommendation - We recommend the University revise its processes for reporting status changes to NSLDS. The University should implement a process to review, update, and verify enrollment statuses that appear on the Enrollment Reporting roster files. We also recommend that management implement controls to ensure reported changes are timely and correctly reported to the NSLDS. Views of Responsible Officials - Management agrees with the finding. Out of the 25 exceptions included in this finding, 8 were properly and timely reported by the University to the third-party service provider. The University has continued to work with its third-party service provider to identify the root cause of the reporting issues. The primary cause stems from varied start dates of academic modules (5-week, 8-week, and 16-week) within a semester. These overlapping start dates often cross the monthly NSLDS upload periods. As students adjust their schedules, changes in the current Student Information System (SIS) may inadvertently override previously reported data. The University’s current SIS has reached the end of its useful life and was not designed to handle the modular academic formats now essential for serving modern student needs. Additionally, the SIS lacks functionality to directly export enrollment data to the third-party service provider resulting in manual intervention and the aggregation of multiple files for upload. This manual process increases the risk for reporting errors. Corrective Action Plan for Finding 2025-001 – In May 2025, the University executed a contract to implement a new and modern Student Information System. This multi-year implementation project is expected to be completed by Fall 2029, with a possibility of early completion by Fall 2028. During the interim period, the University will continue to emphasize data validation and accuracy through staff training and monitoring. To further support the reporting process, the University engaged a former employee on a contractual basis during the fiscal year ended May 31, 2025. This individual brings extensive experience in enrollment reporting to both the National Student Clearinghouse (NSC) and the National Student Loan Data System (NSLDS), providing valuable expertise during this transitional phase.

Single AUdit Report for 2024-2025 Reference/Finding Number 2025-001 Management's Planned Corrective Action Management acknowledges and understands the finding associated with Eligibility. The student's Pell award has already been corrected and accepted by COD. Management is working with IT to automate the enrollment change report to be sent on a weekly basis to validate that all increases in hours have been appropriately updated and processed. This will also become part of our required annual reconciliation process of the Pell grant program. Responsible Official Bridget Moore Director of Student Financial Services Abilene Christian University Estimated Completion Date July 24, 2025

Finding 2025-001 Federal Agency Name: U.S. Department of Education Program Name: Student Financial Assistance Cluster ALN: 84.268 Finding Summary: For a small group of students with very specific circumstances, our software’s enrollment report autopopulated an effective date of enrollment change that did not match the actual effective date. UMHB did not realize that these specific circumstances would require manual processes to identify and correct the enrollment report prior to submission. As a result, four students had incorrect status change effective dates reported to NSLDS. Responsible Individuals: Trent Bridges, Director Data Quality and Institutional Analytics Corrective Action Plan: UMHB plans to implement the following: 1. Review all the coding on system reports used for NSLDS reporting to assess accuracy and completeness of the data based on any changes in business practice and make updates to system reports as necessary. 2. Update internal process to document any required special handling of records based on system limitations. 3. Reassess system report and processes used for NSLDS reporting prior to the beginning of each fall and spring semester. Anticipated Completion Date: Fall 2025

Student Financial Assistance Cluster Assistance Listing Number 84.268 Federal Direct Student Loans, and 84.063 Federal Pell Grant Program U.S. Department of Education Program Year 2024-2025 Criteria or Specific Requirement – Special Tests and Provisions – Enrollment Reporting – 34 CFR Sections 690.83(b)(2) and 685.309 Condition – Student enrollment and program information was not communicated to the National Student Loan Data System (NSLDS) timely or accurately Questioned Costs – N/A Context – A total of 7 out of 40 students tested were noted to have at least 1 error in enrollment or program information reported to NSLDS within the required 60 days. Our sample was not, and was not intended to be, statistically valid. Effect – NSLDS was not notified of student status changes or program information in accordance with compliance requirements. Cause – The University did not have effective internal control processes in place to ensure the accurate collection, review, and reporting of student status changes occurred timely or accurately. The recent turnover in personnel resulted in a lack of oversight as well. Indication as a Repeat Finding – Yes Recommendation – The University should review its internal controls surrounding the enrollment reporting process and ensure internal controls provide for the timely and accurate reporting of student status changes. Views of Responsible Officials and Planned Corrective Actions – Tina Petersen, Registrar, will oversee the two-fold corrective action plan. First, we are immediately reviewing our degree posting policy and dates to create a more effective and standardized process. This policy review will enable us to properly assess any delayed completers and ensure that students are "completed" in our systems and reported to NSLDS in a more timely and accurate manner. Additionally, we are updating our formal, step-by-step written procedure manual for all enrollment reporting processes, with a specific focus on degree conferral and the subsequent reporting to NSLDS. This updated manual will serve as a crucial resource to ensure procedural consistency, especially during personnel changes. Second, we are enhancing our training protocols and internal controls. All staff members involved in the NSLDS reporting process will be required to attend mandatory, recurring training to ensure they are up-to-date on all compliance requirements. We will also implement a more robust system of checks and balances to verify the accuracy of the data before it is submitted to NSLDS. By taking these steps, the University is dedicated to improving its internal controls and fully remediating this finding. The corrective action plan will be implemented by November 1, 2025. Office of Financial Services PO Box 11000 Oklahoma City, OK 73136 405.425.5190 financialservices@oc.edu

Student Financial Assistance Cluster Assistance Listing Number 84.268 Federal Direct Student Loans, and 84.063 Federal Pell Grant Program U.S. Department of Education Program Year 2024-2025 Criteria or Specific Requirement – Disbursements to or on behalf of students, 34 CFR Section 668.164(h)(2) Condition – Students did not receive refunds within the required timeframe Questioned Costs – N/A Context – 7 out of 25 students tested received their credit balance refund more than 14 days after the credit balance was generated. All but 1 of these students received their refund within 16 days of the generation of the credit balance. Our sample was not, and was not intended to be, statistically valid. Effect – Noncompliance with federal regulations requiring timely disbursement of credit balance refunds Cause – Due to the high volume of credit balance refunds being processed, the University encountered operational constraints that prevented all refunds from being generated within the designated 14-day timeframe. Indication as a Repeat Finding – N/A Recommendation – To ensure timely refund of student credit balances, implement a control that flags any refund not processed before the end of the 14-day timeframe for immediate review and escalation. Additionally, establish a monitoring report to track refund timeliness weekly and reinforce accountability for processing within the required timeframe. Views of Responsible Officials and Planned Corrective Actions – Amy Schlup, Director of Student Financial Services, and Carrie Hamilton, Assistant Director of Financial Aid, will oversee the corrective action plan. As part of this process, they will review the daily Student Refund Report to identify and assist the personal financial counselor in expediting student refunds. The Student Financial Services team will also review and retrain on the proper procedures for processing refunds within the required timeframe. The corrective action plan is already in progress and will be fully implemented by October 1, 2025. Office of Financial Services PO Box 11000 Oklahoma City, OK 73136 405.425.5190 financialservices@oc.edu

Corrective Action Plan (CAP for Finding 2025-001) Date: 2 October 2025 Responsible official: Frederick L. Clement, Executive Vice President Management has corrected the finding by taking the following action: First, the institution entered into a professional services agreement with Higher Education Assistance Group to provide a comprehensive business process review of its financial aid operations. The objective of this review is to improve upon the functionality of processes, internal controls, and systems to ensure regulatory compliance and the effectiveness of service deliverables to students receiving financial aid. This review will include updates to policies, procedures, and internal controls for the import and export of electronic records, document tracking and file review, packaging and awarding, satisfactory academic progress, disbursement and reconciliation, withdrawal and Return to Title IV. Workflow and gap analysis will be performed to ensure intraoffice Title IV program compliance and best practices. Second, the institution has entered into a professional services agreement with Higher Education Assistance Group to provide interim staffing and third-party federal student aid processing including, but not limited to, counseling students and families on financial aid options, assisting with the management of Federal Direct Loan and Federal Graduate PLUS Loan programs to include student eligibility, file review, awarding, and origination and disbursement authorization using Populi, COD and other Department of Education software. In addition, Higher Education Assistance Group will provide additional Title IV training for personnel involved in federal student aid processing. With more than 35 years of experience, Higher Education Assistance Group and its team of seasoned consultants, all of whom have worked in federal student aid administration, whether in public/private colleges and universities or for the Department of Education itself, specializes in the compliant administration of Title IV student financial aid programs. The institution will adopt a supplemental internal control to cross-check student eligibility for Direct PLUS loans to ensure that an over-award is not originated and disbursed. Anticipated completion date: November 15, 2025

Auditors noted that for two of the six sampled students, funds were returned to ED more than 45 days after the date the University determined the student had withdrawn. For one selection, a Return of Title IV calculation was performed timely, but an administrative error caused the disbursement to be delayed eight months. For the second selection, the University was notified of withdrawal in early March 2025 and student was included in registrar’s withdrawal listing, but was missed in review by Student Financial Services until late April 2025. Contact Person(s): Vickie Rekov, VP Enrollment Services; Roger Wilson, Associate Director of Financial Aid, SFS; Ryan Porter, CFO and Bernie Rundquist, Controller Explanation and specific reasons for disagreement with the audit finding or that corrective action is not required (if applicable): N/A Corrective action planned: All employees in Student Financial Services and Accounting Office involved in the reporting, distribution, drawdown and return of federal funds have reviewed the criteria under 34 CFR 668.22 The two departments involved will be meeting in the month of September 2025 to review policies and procedures to ensure controls exist and are well documented to ensure funds are returned timely. In-charge personnel will gather training resources to educate those involved in the reporting, disbursement and return of Title IV Funds. Anticipated completion date: October 2025