Corrective Action Plans

Finding: 2025-001: Special Tests and Provisions – Eligibility – Significant Deficiency in Internal Control over Compliance Corrective Action Plan – The University conducted a review of affected students and identified 19 additional students with enrollment intensity that was incorrectly calculated. The University has returned a total of $2,448 to the Pell Grant program and has written off the corresponding balances on the affected students’ ledgers. In January 2025, the University fully implemented a new, integrated Student Information and Financial Aid System that automates enrollment intensity calculations based on real-time data from the Registrar’s Office. This eliminates manual entry and ensures Pell Grant disbursements are automatically and accurately calculated. There is no option to manually change the Pell enrollment intensity or award amount in the new system. The Financial Aid staff involved in Pell packaging and processing have been retrained on enrollment intensity calculations and system functionality. Contact Person Responsible for Corrective Action: Sally Mickelson, Director of Financial Aid Completion Date: November 13,2025

Management is formalizing written enrollment reporting procedures to ensure timely and accurate reporting to NSLDS. Until implementation of a new student information system, enrollment reporting will continue to be performed manually, with monthly supervisory review and documentation of submissions. Automation of enrollment reporting is expected upon implementation of the new SIS.

Management has implemented formal monthly reconciliation procedures between the Financial Aid Office, Registrar, and Accounting Department to ensure the accuracy of the FISAP data. Reconciliations include review of enrollment status, aid disbursements, and supporting documentation, with documented supervisory review and retention of reconciliation evidence.

Management has implemented additional review procedures over Pell Grant calculations, including documented manual recalculations and supervisory approval prior to disbursement. These controls will remain in place until Pell calculations are automated through the planned SIS implementation.

Finding 2025-004 Name of Responsible Individual: Cinnamon Bradley, Assoc Dean Student Affairs Corrective Action: The Registrar prepares the program calendars with input from the programs on an annual basis. MSM has a diversity of programs with different start and end dates. We understand that this needs to be accurately reflected in our calendars and in the Banner system or other enrollment platform. Academic calendars will be reviewed by the Registrar and program staff on an annual basis. Any changes to the academic calendars will need to be communicated to all members of the team. Updated calendars will be posted annually on the website and in the student handbook. After the Registrar’s Office confirms the academic start date and academic end date, Student Fiscal Affairs will continue to input this information in our Student Information System Banner to allow accuracy in our student records sent to the Department of Education Common Origination and Disbursement. If there is a change in the academic start dates and/or academic end dates, the Registrar’s Office will notify Student Fiscal Affairs, Admissions, and Student Accounts to allow for updates within the institution. Anticipated Completion Date: March 1, 2026

Finding 2025-001 Name of Responsible Individual: Cinnamon Bradley, Assoc Dean Student Affairs Corrective Action: Due in part to frequent turnover in the Registrar's Office, there have been reporting errors in Clearinghouse which have been reflected in NSLDS. In addition to changes in personnel, the Office of the Dean will provide joint oversight with the Office of Student Affairs on matters impacting regulatory requirements. Specifically, there will be a monthly review of the NSLDS database on the second Monday of each month with a regular tracking system. The Registrar, Associate Dean of Students and Dean’s Office representative will provide quarterly “audits” to the Dean on accuracy of data and reporting compliance. Annual NSLDS training, appropriate to the role, will be provided for all team members in the Registrar's Office and others as appropriate. Anticipated Completion Date: March 31, 2026

Finding No. 2025-001 Corrective Action Plan: The University concurs with this finding. The Financial Aid office is in the process of tightening its policies and procedures to identify all students subject to the required exit counseling, with the goal of delivering said counseling within the prescribed 30-day window. Responsible Official: Dane Fuhrman, CFO Anticipated Completion Date: June 2026

Finding 2025-001: Special Tests and Provisions: Enrollment Reporting Context/Condition: Of the 40 students selected for enrollment reporting testing, one (1) student graduation was reported to NSLDS outside the maximum 60-day window. Recommendation: The auditor recommended that the College review and update internal controls to ensure student enrollment status in the National Student Loan Data System (NSLDS) is updated in a timely manner to ensure compliance with Federal requirements. Persons Responsible for Corrective Action: Registrar Liz Force Planned Corrective Action: The Registrar will update NSLDS reporting processes and controls to include detection controls to ensure all student graduations, including those occurring outside the traditional reporting window, are accurately and timely reported to the NSLDS within the maximum 60-day window. Anticipated Completion Date: December 31, 2025

Develop a Strategic Plan of Action ensuring data accuracy and timely transmission of Enrollment Status Reports & Degree Verification Reports to the National Student Clearinghouse for further submission to NSLDS. The plan will establish a structured, repeatable process to:  Validate the accuracy of student enrollment and degree data prior to NSCH submission.  Ensure timely transmission of Enrollment Status Reports (ESRs) and Degree Verification Reports (DVRs).  Strengthen internal controls, documentation, and audit readiness with system-generated audit reports and dual review.  Improve communication among Registrar, IT, Institutional Research, and Financial Aid. Susan W. Gibson, University Registrar James Stotts, Associate VP Financial Aid Tansha Gillins, Principal Analyst June 30, 2026 Due to BANNER SaaS system upgrade in progress, this action will be completed by June 30, 2026, to allow for report writing in the new reporting tool postimplementation Immediate action: To ensure timely reporting to National Student Clearinghouse and NSLDS, reports will be generated bi-weekly. ISE scheduler will be used to extract baseline data from BANNER for uploading the Enrollment Status Report to National Student Clearing biweekly with off-cycle adjustments as needed. Initial errors will be identified and corrected using a dual-review process before uploading the report to NSCH. Martha Henderson, Associate Registrar Tansha Gillins, Principal Analyst On-going activity Beginning March 30, 2026 The Degree Verification Report will be generated monthly to ensure that graduation status is reported within the timeframe required by NSLDS. Graduation lists will be forwarded to the Office of Financial Aid for dual review and validation to confirm the accuracy of the data and the timeliness of certification to NSLDS. Martha Henderson, Associate Registrar Palmira Wakhisi, Financial Aid On-going activity Beginning May 20, 2026

Finding Summary During the recent Federal and State Single Audit report, completed by WIPFLI, it was identified that the institution did not accurately report Last Date of Attendance (LDA) information to the National Student Loan Data System (NSLDS) for the unofficial withdrawal population. Specifically, adjusted end dates were not being properly communicated to the National Student Clearinghouse (NSC), which is responsible for enrollment reporting to NSLDS. As a result, students’ withdrawal dates were not accurately reflected. Issue Identified Upon notification of the finding, the Financial Aid and Registration & Records offices met to review existing procedures. It was determined that when grades of “F” were assigned, the LDA was updated in our ERP. Since internal systems had the updated last day of attendance, R2T4 calculations were done correctly. However, an enrollment file was not resubmitted to NSC to reflect the revised LDA for enrollment reporting to NSLDS. Corrective Action Taken The institution has implemented the following corrective measures to assure updated Reporting to NSC: o Once the correct LDA is confirmed by the Financial Aid Office the Registrar’s Office updates the student record in the student information system. o The updated LDA is reported to the National Student Clearinghouse (NSC), which in turn updates NSLDS. Internal Controls Implemented To prevent recurrence, the following controls are now in place:  Written procedures have been updated to clearly define: o Roles and responsibilities of Financial Aid and Registrar staff o Timeline for reporting updates to NSC  Staff training was conducted with both departments to ensure understanding of federal reporting requirements. Implementation Date The revised process was implemented immediately upon identification of the issue and is fully operational. Fall 2025 unofficial withdrawals were accurately updated to NSC on 1/15/26. Persons Responsible: Jennifer Anderegg, Dean of Strategic Enrollment Kim Yoder, Director of Financial Aid Jess Schwartz, Registrar

Finding 2025-006 - U.S. Department of Education (USDE, Title IV Student Financial Aid Programs (significant deficiency): Information on the federal program: Federal Direct Student Loans, FAL No. 84.268, June 30, 2025; Federal Pell Grant Program, FAL No. 84. 063, June 30, 2025; Federal Supplemental Educational Opportunity Grant, FAL No. 84.007, June 30, 2025; Federal Work-Study Program, FAL No. 84.033, June 30, 2025. Condition - During review of enrollment reporting procedures, we noted that one (1) student record requested for testing was not provided, and two (2) sampled student records were not updated to reflect current enrollment status changes in NSLDS. As a result, the College could not demonstrate that enrollment reporting was complete, accurate, or timely for the students tested. Views of Responsible Officials –The College accepts the recommendation. The Institution has reviewed the finding and acknowledges that one student record was not submitted for review. The Institution has provided the NSLDS enrollment verification for that student. For the remaining two students, enrollment reporting was not updated within the required 30-day timeframe. The Institution has since updated their enrollment statuses in NSLDS and has provided updated records for review. The Institution respectfully requests that the finding be formally updated, if applicable, upon the auditor’s review and acceptance of all submitted NSLDS enrollment documentation. In response, the institution has updated its processes and procedures regarding student enrollment reporting with NSLDS, by ensuring accurate enrollments status matches the student transcript. Along with continuing to update within the 30 days established timeframe within NSLDS. Responsible Officials -The Registrar, the Financial Aid Office under the direction of the Vice President of Student Affairs, and Business Office under the direction of the Vice President for Business and Finance plans to have the finding resolved by its next fiscal year end audit (between July – October 2026). The College is aware of the need to review and mitigate compliance risks in this area and will use the described corrective action plan to reduce those risks and eliminate the potential for future audit findings.

Finding 2025-005 - U.S. Department of Education (USDE, Title IV Student Financial Aid Programs (significant deficiency): Information on the federal program: Federal Direct Student Loans, FAL No. 84.268, June 30, 2025; Federal Pell Grant Program, FAL No. 84. 063, June 30, 2025; Federal Supplemental Educational Opportunity Grant, FAL No. 84.007, June 30, 2025; Federal Work-Study Program, FAL No. 84.033, June 30, 2025. Condition - Testing of student withdrawals revealed that for three (3) students, Title IV funds identified as unearned through the Return of Title IV (R2T4) process were not returned to the U.S. Department of Education within the required timeframe. The returns were made between 209 and 349 days after the College’s date of determination (DOD), which is well beyond the 45-day requirement established by federal regulations. Views of Responsible Officials – The College accepts the recommendation. The Institution has reviewed the finding and acknowledges that one student record was not submitted for review. The Institution has provided the NSLDS enrollment verification for that student. For the remaining two students, enrollment reporting was not updated within the required 30-day timeframe. The Institution has since updated their enrollment statuses in NSLDS and has provided updated records for review. The Institution respectfully requests that the finding be formally updated, if applicable, upon the auditor’s review and acceptance of all submitted NSLDS enrollment documentation. In response, the institution has updated its processes and procedures regarding student enrollment reporting with NSLDS, by ensuring accurate enrollments status matches the student transcript. Along with continuing to update within the 30 days established timeframe within NSLDS. Responsible Officials -The Registrar, the Financial Aid Office under the direction of the Vice President of Student Affairs, and Business Office under the direction of the Vice President for Business and Finance plan to have the finding resolved by its next fiscal year end audit (between July – October 2026). The College is aware of the need to review and mitigate compliance risks in this area and will use the described corrective action plan to reduce those risks and eliminate the potential for future audit findings.

Finding 2025-004- U.S. Department of Education (USDE, Title IV Student Financial Aid Programs (significant deficiency): Information on the federal program: Federal Direct Student Loans, FAL No. 84.268, June 30, 2025; Federal Pell Grant Program, FAL No. 84. 063, June 30, 2025; Federal Supplemental Educational Opportunity Grant, FAL No. 84.007, June 30, 2025; Federal Work-Study Program, FAL No. 84.033, June 30, 2025. Failure to Provide Student-Level Documentation to Support FISAP Reporting (significant deficiency) Condition - The College did not provide the requested student-level records (ISIRs) to substantiate the number of eligible applicants reported on the FISAP submitted to the U.S. Department of Education. As a result, we were unable to verify the accuracy and completeness of the eligible applicant data reported for the applicable award year. Views of Responsible Officials - The College accepts the recommendation. The institution acknowledges that this request was initially overlooked during the audit review. The requested sample testing of ISIRs has now been completed, and a total of 34 ISIR records have been provided and uploaded to the shared file for the auditor’s review. The institution respectfully requests a formal update to this finding (if applicable), once all submitted ISIR documents have been reviewed and deemed acceptable by the auditor Responsible Officials - The Financial Aid Office under the direction of the Vice President of Student Affairs plans (to have the finding resolved by its next fiscal year end audit (between July – October 2026). The College is aware of the need to review and mitigate compliance risks in this area and will use the described corrective action plan to reduce those risks and eliminate the potential for future audit findings.

Finding 2025-003 - U.S. Department of Education (USDE, Title IV Student Financial Aid Programs (significant deficiency): Information on the federal program: Federal Direct Student Loans, FAL No. 84.268, June 30, 2025; Federal Pell Grant Program, FAL No. 84. 063, June 30, 2025; Federal Supplemental Educational Opportunity Grant, FAL No. 84.007, June 30, 2025; Federal Work-Study Program, FAL No. 84.033, June 30, 2025. Condition – During testing of student account activity, we identified that nine (9) out of sixty (60) sampled students had Title IV -created credit balances that remained on their accounts for more than 14 days without being released to the student or parent. Views of Responsible Officials - The College accepts the recommendation. The institution has reviewed the audit finding and acknowledges that student refunds were not consistently issued within the required 14-day timeframe due to students’ incomplete admissions requirements. The institution recognizes this as a compliance deficiency and has implemented revised processes and internal controls to ensure timely and compliant issuance of student refunds going forward. Effective immediately, the Registrar’s Office provides a weekly roster of students with incomplete admission requirements to the Financial Aid Office and the Business Office prior to the release of federal student aid. These offices meet weekly to review the roster, ensure timely communication, and document all actions taken. This control ensures that federal student aid is not disbursed when admissions requirements have not been met and prevents the creation of improper student credit balances. Under the revised refund process, the Business Office staff identify student credit balances and prepare refund requests. These requests are reviewed by the Registrar’s Office to reconfirm when admission requirements have been met and by the Financial Aid Office to confirm that federal student aid has been properly originated and disbursed through the Common Origination and Disbursement (COD) system. If it is determined that a student’s admissions requirements are incomplete and a refund has been created, the Business Office notifies the Financial Aid Office to cancel all applicable federal student aid and return the funds to the U.S. Department of Education through COD. When a student’s admissions requirements have been met, then the Business Office completes the refund process by transmitting the approved refund file to the institution’s third-party refund vendor and submitting funds for release to students. These revised procedures strengthen oversight, improve interdepartmental coordination, and ensure compliance with federal refund timelines. College administrators for each department (Vice President for Student Affairs and Vice President for Business and Finance) will be responsible for informing staff of changes in campus operations that may have an impact on their ability to process refunds. Responsible Officials - The Registrar, the Financial Aid Office under the direction of the Vice President of Student Affairs, and Business Office under the direction of the Vice President for Business and Finance plan to have the finding resolved by its next fiscal year end audit (between July – October 2026). The College is aware of the need to review and mitigate compliance risks in this area and will use the described corrective action plan to reduce those risks and eliminate the potential for future audit findings.

Finding 2025-002 - U.S. Department of Education (USDE, Title IV Student Financial Aid Programs (significant deficiency): Information on the federal program: Federal Direct Student Loans, FAL No. 84.268, June 30, 2025; Federal Pell Grant Program, FAL No. 84. 063, June 30, 2025; Federal Supplemental Educational Opportunity Grant, FAL No. 84.007, June 30, 2025; Federal Work-Study Program, FAL No. 84.033, June 30, 2025. Condition - Based on documentation provided for the 2024–2025 award year, the College disbursed Title IV funds to a student whose ISIR contained Comment Code 325, indicating that the student’s unaccompanied homeless youth status required resolution prior to awarding and disbursing aid. The College did not provide documentation from an authorized entity, nor evidence of a documented Financial Aid Administrator case-by-case determination, to support the student’s independent status. As a result, the student’s dependency status remained unresolved at the time Title IV funds were disbursed. Views of Responsible Officials – The College accepts the recommendation Although a recommendation was noted, the Financial Aid Management System (FAMS) was not programmed as expected for the 2024– 2025 FAFSA application year. The issue was anticipated to be addressed by the third-party vendor through system updates; however, because of the programming oversight, no system flag was generated to request self-supporting documentation or validation of a student’s homelessness or risk of homelessness. In addition, the Department of Education’s FAFSA application did not generate a comment code requiring further action on the student’s record. The Institution has since worked with its third-party vendor to correct the programming oversight to ensure that required documentation is requested for students who indicate homelessness or risk of homelessness. Additionally, at the direction of the FAMS vendor, the Financial Aid Office implemented an internal edit to ensure a system flag alerts staff when documentation is required to resolve such cases. With these corrections, the conditions that caused the error have been addressed. Responsible Officials -The Financial Aid Office under the direction of the Vice President of Student Affairs plans to have the finding resolved by its next fiscal year end audit (between July – October 2026).To ensure ongoing compliance, the Financial Aid Office will monitor student records for appropriate flags and required documentation. The College is aware of the need to review and mitigate compliance risks in this area and will use the described corrective action plan to reduce those risks and eliminate the potential for future audit findings.

Finding 2025-001 - U.S. Department of Education (USDE, Title IV Student Financial Aid Programs (significant deficiency): Information on the federal program: Federal Direct Student Loans, FAL No. 84.268, June 30, 2025; Federal Pell Grant Program, FAL No. 84. 063, June 30, 2025; Federal Supplemental Educational Opportunity Grant, FAL No. 84.007, June 30, 2025; Federal Work-Study Program, FAL No. 84.033, June 30, 2025. Condition– It was noted that the College did not perform the required reconciliations between: a. The Student Financial Aid (SFA) Office records, b. The Business Office/General Ledger (SEFA), and c. The Common Origination and Disbursement (COD) System. In additional, unreconciled figures from the College’s internal records were used in preparing and submitting the Fiscal Operations Report and Application to Participate (FISAP) submitted to the U.S. Department of Education for the most recent award year. As a result, the College could not demonstrate that Title IV activity reported to ED was accurate or fully supported. Subsequent to the identification of this exception, management provided additional documentation intended to support reconciliation activities; however, the documentation did not demonstrate that reconciliations were performed timely or as part of established internal control procedures during the period under audit. Views of Responsible Officials - The College accepts the recommendation. Beginning with future monthly Title IV reconciliations, the Institution will complete all required reconciliations no later than five (5) days after the COD reconciliation reports are made available. The Financial Aid Office will provide the reports to the Business Office for reconciliation. Following reconciliation by the Business Office, the reports will be returned to the Financial Aid Office when resolution of discrepancies is required. Once discrepancies are resolved, the Financial Aid Office will submit the updated reports back to the Business Office, and the resolution will be documented. If no resolution is required, the reports will be retained for the applicable month. All monthly reconciliations will be maintained and made available for review during the yearend audit by the Business Office Responsible Officials- The Financial Aid Office under the direction of the Vice President of Student Affairs plans to have the finding resolved by its next fiscal year end audit (between July – October 2026). The College is aware of the need to review and mitigate compliance risks in this area and will use the described corrective action plan to reduce those risks and eliminate the potential for future audit findings.

Student Financial Assistance Cluster Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: As a corrective action, the unit has strengthened internal controls by implementing a dual-review process for all submissions. Following Nikki Stork’s promotion to assistant registrar, submissions are now reviewed by two qualified staff members prior to final approval, providing appropriate segregation of duties and an added level of oversight. Although the specific cause of the incorrect date entry could not be conclusively identified, this enhanced review process mitigates the risk of similar errors and supports continued compliance with federal program requirements. Name(s) of the contact person(s) responsible for corrective action: Erin Moore Planned completion date for corrective action plan: January 30, 2026

2025-003 - Student Financial Aid Cluster - (a) Federal Supplemental Educational Opportunity Grants (b) Federal Work Study Program (c) Federal Perkins Loan Program - Federal Capital Contributions (d) Federal Pell Grant Program (e) Federal Direct Student Loans (f) Teacher Education Assistance for College and Higher Education (TEACH), Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.038 (d) 84.063 (e) 84.268 (f) 84.379 - Year Ended June 30, 2025 Condition: We tested forty files and enrollment statuses were incorrectly reported to the National Student Loan Data System (NSLDS) for three students (7.5%). We consider this to be an instance of noncompliance relating to Special Tests and Provisions compliance requirement and is not a repeat finding. Statistical sampling was not used in making sample selections. Management Response: We agree with this finding. Corrective Action Plan: Review of new academic programs that allow graduate courses for undergraduate credit will be complete to ensure that enrollment is reported correctly. This specific case was for our MSAT program. The students involved were in their transition year from undergrad to grad. Graduate courses were not coded to report as undergrad towards full time status. Responsible Person: Registrar Implementation Date: January 2026

2025-002 - Student Financial Aid Cluster - (a) Federal Supplemental Educational Opportunity Grants (b) Federal Work Study Program (c) Federal Perkins Loan Program - Federal Capital Contributions (d) Federal Pell Grant Program (e) Federal Direct Student Loans (f) Teacher Education Assistance for College and Higher Education (TEACH), Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.038 (d) 84.063 (e) 84.268 (f) 84.379 - Year Ended June 30, 2025 Condition: The University did not accurately complete refund calculations for official withdrawals. In review of the Fall 2024 official calculations the number of days in the break was not calculated correctly, resulting in the incorrect number of days in the calculation. The Title IV amounts for all withdrawn students were incorrectly calculated and returned for 5 out of the population of 5 (100%) Fall official withdrawal calculations. However, the No Passing Grade Sample for Fall unofficial withdrawals total number of days was calculated correctly. A sample of Spring official withdrawal calculations identified 2 calculation errors however the total days were calculated correctly. We noted 2 out of 4 (50%) Spring students tested in the Return of Title IV sample had incorrect calculations. Additionally, a sample of No Passing Grades students for unofficial withdrawals noted 2 out of 9 (22%) students tested did not have refund calculations completed timely. We consider this finding to be a material weakness in relation to Special Tests and Provisions and a repeat of prior year finding 2024-001. Statistical sampling was not used. Management Response: We agree with this finding. Corrective Action Plan: This error was caused in a staff interpretation of a Saturday course being offered for one program. However, Saturday's are not on the academic calendar as a class day prior to the Thanksgiving break. Due to staff turnover, this was a change made in calculations in January 2025 that does not count that Saturday as a course day in regards to the length of Thanksgiving break. The change in days per semester calculation is now in line wiht the academic calendar posted by the institution. Responsible Person: Financial Aid Director/Registrar Implementation Date: January 2025

2025-001 - Student Financial Aid Cluster - (a) Federal Supplemental Educational Opportunity Grants (b) Federal Work Study Program (c) Federal Perkins Loan Program - Federal Capital Contributions (d) Federal Pell Grant Program (e) Federal Direct Student Loans (f) Teacher Education Assistance for College and Higher Education (TEACH), Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.038 (d) 84.063 (e) 84.268 (f) 84.379 - Year Ended June 30, 2025 Condition: During our testing of forty individuals receiving federal work study, we noted four individuals (10%) working during scheduled class hours. We consider this condition to be an instance of noncompliance relating to Activities Allowed or Unallowed compliance requirement and is not a repeat finding. Statistical sampling was not used in making sample selections. Management Response: We accept this finding. Corrective Action Plan: Additional planning is ongoing to correct timecards to not allow students to clock work hours during their scheduled classes. Additional training will also be provided to timecard approval staff for departments with student workers receiving Federal Work Study. Responsible Person: Student Employment/Financial Aid Implementation Date: January 2026

Finding 2025-002 Student Status Changes Condition The College did not notify the National Student Loan Data System (NSLDS) with an accurate effective date for 9 students with status changes in our sample of 25 students. Additionally, the College did not notify the NSLDS in a timely manner for 1 student with status changes in our sample of 25 students. The sample was not a statistically valid sample. Corrective Action Plan All records for the students identified in the audit have been manually corrected in the NSC and NSLDS systems to match their actual graduation or last date of attendance. A comprehensive review was completed for all students graduating in June 2025. We are working with NSC to verify the changes we made to our reporting will resolve the issue. Name(s) of Contact Person(s) Responsible for Corrective Action: Mark Badarraco, Executive Director of Enrollment Services and Information Systems Thomas Camillo, Registrar Anticipated Completion Date: 6/30/26 Polices & Procedures update was completed during FY26 Software training for existing staff will continue through FY26

Finding 2025-001 Disbursement Notification Condition 25 students in a sample of 25 were not given notifications that met the required criteria. Students were notified of awards throughout the academic year, but notifications did not meet the required criteria. Additionally, the required information on the timing and procedures for canceling loans was made available to students on the College’s website and financial aid office. The sample was not a statistically valid sample. Corrective Action Plan Corrective Action Planned: Upon identification a permanent, automated daily notification process has been successfully developed, tested, and implemented. Name(s) of Contact Person(s) Responsible for Corrective Action: Mark Badarraco, Executive Director of Enrollment Services and Information Systems Kyle Armstrong, Director of Financial Aid Anticipated Completion Date: 11/14/25 Polices & Procedures update was completed during FY26 Software training for existing staff will continue through FY26

Finding 2025-001 N. Special Tests and Provisions – N6. NSLDS Reporting Identification of the federal program: Federal Grantor: United States Department of Education Federal Cluster: Student Financial Assistance (SFA) Cluster Assistance Listing Nos.: 84.063, Federal Pell Grant Program, and 84.268, Federal Direct Student Loans Award Period of Performance: July 1, 2024–June 30, 2025 Condition: Internal controls over the review and approval of the enrollment report sent to the third-party servicer, National Student Clearinghouse (NSC), were not adequately designed or operating effectively as follows: • A record count reconciliation between the enrollment report submitted to the NSC and the number of files received by the NSC, and documentation over how any rejected records were addressed, is not performed as part of the internal control. • Details of the validation of student information included in the enrollment report for accuracy prior to being sent to the NSC were not retained by Mercy Health. • Details of the NSC error report and corrections made were not retained by Mercy Health. Views of Responsible Officials and Planned Corrective Actions: 1. Corrective Action: Record Count Reconciliation & Rejected Records • Implement a mandatory, documented reconciliation process for every submission. 2. Corrective Action: Pre-Submission Validation Documentation • Formalize the validation process and retain evidence of accuracy checks. 3. Corrective Action: Retention of NSC Error Reports & Corrections • Establish a procedure for downloading and retaining error reports. By implementing these actions, Southeast Missouri Hospital College of Nursing & Health Sciences will ensure compliance with federal regulations regarding the accuracy and timeliness of student enrollment reporting to the NSC and NSLDS. Responsible Party: Steve Ritter, Registrar and/or Deanna Sells, Business Officer Date of Completion: Phased implementation began in January 2026 and our action plan will be fully implemented as of the March 2026 enrollment reporting process.

Views of Responsible Officials: The College acknowledges the audit finding that Return of Title IV (R2T4) calculations were not accurately completed for nine of the sixty students sampled, and that Title IV funds were not returned timely for fifteen of the sixty students sampled. During the audit period, R2T4 tracking and oversight processes were in transition, which resulted in insufficient monitoring of calculation accuracy and timeliness. In addition, for several end-of-term cases involving unofficial withdrawals, the institution could not initiate R2T4 calculation until final grades were posted and an unofficial withdrawal determination was made based on non-passing (F) grades, in accordance with federal regulations governing unofficial withdrawals. The Fall 2024 semester ended on December 21st. The college was closed for the winter break and reopened January 2, 2025. Therefore, the Date of Determination (DOD) was not two days after the end of the semester but in January with the earliest available processing date being January 2, 2025. Corrective Action: The College has implemented enhanced internal controls to ensure compliance with Return of Title IV (R2T4) requirements. Responsibility for monitoring R2T4 calculations and timeliness has been assigned to the Director of Financial Aid and Compliance. A R2T4 tracking log has been established and is reviewed on a weekly basis to ensure that all official withdrawals are identified and processed within the required regulatory timeframe. For unofficial withdrawals, R2T4 calculations are initiated after the end of term once final grades are posted and an unofficial withdrawal date of determination (DOD) is made based on non-passing (F) grades, consistent with federal regulations. End-of-term R2T4 reviews for the fall semester are conducted upon return from winter break after the New Year to ensure complete and accurate academic records are available. Internal staff have received additional training on R2T4 regulatory requirements, timelines, and documentation standards. To ensure operational continuity, a senior specialist has been trained to manage R2T4 processing in the Director's absence. These corrective actions will strengthen internal controls and ensure accurate and timely processing of R2T4 calculations.

Views of Responsible Officials: After consultation with the College’s Information Technology department, management determined that the file was processed and submitted on time. However, the NSLDS discrepancy resulted from a data processing issue during the March 2025 enrollment status download. Specifically, while the NSLDS file was being generated, staff from another office were simultaneously accessing the same student records. These concurrent activities caused the affected students’ enrollment statuses to default to data from a prior download, resulting in incorrect reporting for the two records of the sixty examined. Corrective action: The College has revised its NSLDS data reporting process to prevent a recurrence of concurrent access. A static, saved population list is now used to generate NSLDS enrollment status downloads, eliminating conflicts caused by concurrent system access. This change ensures that enrollment status data is not impacted and remains consistent at the time of submission. Management believes this corrective action adequately addresses the identified issue, strengthens controls, mitigate this issue for future status change reports, and allows for accurate submission within the required 60-day timeframe.