Corrective Action Plans

2024-003 – Enrollment Reporting (Significant Deficiency) Department of Education, SFA Cluster, Special Tests and Provisions Condition: The College did not report student enrollment data to the National Student Clearinghouse within the minimum required timeframe. Criteria: Based on requirements set forth by 34 CFR Section 685.309(b)(2), the College is responsible for notifying the National Student Loan Data System (NSLDS) to changes to student’s enrollment data within minimum required timeframes. Cause: The College does not have adequate procedures in place to ensure changes in students’ enrollment statuses are identified and reported in a timely manner. Context: From a population of 26 students that withdrew officially and unofficially during a term, we tested 3 students and noted those students’ withdrawals were not reported timely or accurately. Effect: Enrollment data was not reported timely or accurately to the Department of Education thus, the Department could not properly service the student’s loans. The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by institutions. Recommendation: We recommend that a review process be put in place to ensure timely and accurate enrollment reporting to NSLDS and additional training on the reporting requirements as needed. Management Response: Management is working with the Registrar’s Office to determine why there was an issue and provide a process that will eliminate any untimely reporting to Clearinghouse moving forward. If the Federal Audit Clearinghouse has questions regarding this plan, please call Angie Edmondson, CFO, 276-944-6755, aedmonds@emoryhenry.edu

2024-004 – U.S. Department of Education, SFA Cluster, Special Tests and Provisions - Return of Title IV Refunds (Significant Deficiency) Condition: Title IV refunds for the two students tested were calculated incorrectly. Criteria: When the recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV grant or loan assistance that the student earned as of the student’s withdrawal date in accordance with 34 CFR 668.22. The institution must return the lesser of the total amount of unearned Title IV assistance or an amount equal to the total institutional charges incurred by the student for the payment period or period of enrollment multiplied by the percentage of Title IV grant or loan assistance that has not been earned by the student. Cause: Controls are not functioning properly. Effect: The amount returned was incorrect for the two students that required refund calculations. Context: From a population of 60 students that official or unofficially withdrew from a payment period, we tested nine and noted that two students required refund calculations. Repeat Finding from a Prior Year: No Recommendation: We recommend the College put procedures in place for accurate preparation and calculation of Title IV refunds. Management Response: We agree the institution must return the lesser of the total amount of unearned Title IV assistance or an amount equal to the total institutional charges incurred by the student for the payment period or period of enrollment multiplied by the percentage of Title IV grant or loan assistance that has not been earned by the student. This issue arose from a lack of leadership and staff training in the Financial Aid Office over the past several years. As a result, proper procedures for calculating and returning unearned Title IV assistance were not consistently. Currently, staff are undergoing comprehensive training in all areas of Title IV and Higher Education Act (HEA) regulations. In the 2024-2025 academic year, the institution hired a new director of financial aid, who has implemented a system to process withdrawals online through Common Origination and Disbursement (COD) and has been working to maintain necessary documentation for accurate refund calculations. Additionally, an updated policies and procedures manual is being finalized to ensure that all staff members have access to the necessary resources and guidelines for compliance. If the Federal Audit Clearinghouse has questions regarding this plan, please call Danielle Pfaff, Controller at 1-336-316-2140 or dpfaff@guilford.edu.

FY24 interest in the amount of$331.01 was returned to USDHHS PS Program Suppmi Center on 1/30/2025. We are keeping a smaller balance in the Federal Funds bank account to lessen the amount of interest earned on the account. Any amount over $500 at the end of the fiscal year will be returned through the same process as prior years. Responsible Person for Correction Action Plan: Deana Rogers, Vice President of Administration & Finance Implementation Date/or Corrective Action Plan: 01/30/25

Identification and Review • Students clocked in during scheduled class times. Blackburn did not initially educate nor send reminders to students and faculty about students not being able to clock in during class times. • During the 2023-2024 fiscal year, there was a transition in the Dean of Work role. There was not as much oversight of student payroll reports Corrective Actions • The Work Office and Provost Office has increased communication and education about students not being able to work during scheduled class times. Reminders have also been sent out. • The Work Office now has a Dean of Work who is educated about how to run student payroll. Process and Policy Improvements • Starting in the Fall 2024 semester, the Work Office and Provost Office increased awareness and communication regarding students not being allowed to work during scheduled class times. • Student Communication- Student managers communicated with student employees at monthly department meetings and through electronic communication that students are not allowed to clock in during scheduled class times. The exception is when their class is cancelled, and students must send the class cancellation notice (email from Professor or screenshot of Learning Management System announcement) to the Work Office before clocking in during the cancelled class time. Once the cancelled claim information is received, it is added to a spreadsheet maintained jointly by the Provost and Work Office. Professor Communication- The Provost sent an electronic communication to all professors notifying them they must communicate with the Provost and Work Office when they cancel a class. Once the cancelled class information is received, it is added to a spreadsheet maintained jointly by the Provost and Work Office. • Additionally, the Work Office reached out to our time tracking and payroll software vendor to identify a solution to limit students' ability to clock in during scheduled class times. Monitoring and Compliance • The Work Office and Provost Office will dedicate time to educate and remind students and faculty that students are not allowed to work during scheduled class time, and how to report a cancelled class. • The Work Office will dedicate time to double check the student payroll reports before sending them to Human Resources. • The Dean of Work will ensure students are educated in department meetings and through electronic communication that they are not allowed to clock in to work during scheduled class times, and how to report a cancelled class. • The Dean of Work will coordinate with the Provost Office to ensure faculty are educated about students not being able to clock in during scheduled class times, and how to report a class cancellation. • The Dean of Work will randomly select 10 students each payroll to ensure they are not clocking in during their scheduled class times. • The Dean of Work will also ensure that the student payroll is double checked before sending to Human Resources. Reporting and Documentation • Fall 2024 o Student managers educated students during their first department meeting And students also received electronic communication that they could not work during a scheduled class time, and informed them how to report a cancelled class. o The Provost Office sent electronic communication to faculty on the importance of reporting a class cancellation. • Spring 2025 o Student managers educated students during their first department meeting and students also received electronic communication that they could not work during a scheduled class time, and informed them how to report a cancelled class. o The Provost Office sent electronic communication to faculty on the importance of reporting a class cancellation. o The Work Office is facilitating monthly Supervisor trainings. In the February training, supervisors were informed verbally and in writing about students not being able to work during scheduled class times, and what documentation is needed when a class is cancelled. • Fall 2025 o The Work Office will facilitate a Supervisor training before the academic year begins. In the training, we will review policies and procedures with one of them being students not being able to clock in during scheduled class times. Responsible Person for Correction Action Plan: Leslie Johnson, Dean of Work Implementation Date for Corrective Action Plan: 09/03/24

Identification and Review • Conduct an internal audit to identify all students who failed all courses and determine the last date of attendance for each. • Review institutional records (For example, faculty attendance records, Learning Management or participation records) to establish when students stopped engaging academically • Verify whether R2T4 calculations should have been performed Corrective Actions • Process R2T4 calculations for affected students based on their last date of attendance • Return any unearned Title IV funds • Update students file to reflect accurate withdrawal dates and notify them of any financial obligations resulting from the adjustment • If students are still enrolled in future terms, ensure they understand satisfactory academic progress (SAP) implications Process and Policy Improvements • Implement an early alert system to identify students who cease attendance before the end of the term. • Strengthen collaboration between academic departments, the registrar, and the financial aid office to improve withdrawal tracking • Run monthly withdrawal reports to see when students earn all failing grades. Monitoring and Compliance • Conduct regular audits to ensure compliance with R2T4 regulations and timely student withdrawals • Provide staff training on withdrawal procedures and the importance of accurately tracking last dates of attendance. • Establish a set time to review withdrawal policies and ensure adherence to federal regulations. Reporting and Documentation • Maintain detailed records of all identified cases, R2T4 calculations, and funds returned. • Document all policy and procedural updates made to prevent recurrence. • If required, submit a report to the U.S. Department of Education outlining corrective actions taken. Responsible Person for Correction Action Plan: Alexis Brown, Director of Financial Aid Implementation Date for Corrective Action Plan: 2/25/25

Identification and Review • Conduct a comprehensive audit of enrollment records to identify instances of inaccurate or delayed reporting • Verify the accuracy of enrollment statuses (e.g., full-time, half-time, withdrawn, graduated) for all affected students • Determine the root cause of reporting delays or errors, whether due to system malfunctions, manual processing errors, or lack of oversight Corrective Actions • Submit corrected enrollment data to NSLDS for all affected students using our National Student Clearinghouse. • Ensure that all errors identified during the audit are addressed, and follow up to confirm the corrections are reflected in NSLDS. • Notify any impacted students of any changes in their enrollment status and provide necessary support if their loan repayment terms are affected. Process and Policy Improvements • Develop and implement clear policies to ensure accurate and timely submission of enrollment data within the required 30-day reporting window or in accordance with scheduled reporting intervals. • Automate the enrollment reporting process where possible to minimize manual data entry errors. • Establish cross-departmental communication protocols to ensure timely updates on student withdrawals, graduations, and status changes. • Create detailed documentation of reporting procedures for staff training and compliance purposes. Monitoring and Compliance • Implement regular reconciliation checks between our student information system (SIS) and NSLDS to ensure data accuracy • Conduct periodic internal audits to identify discrepancies before external audits occur • Designate staff to oversee enrollment reporting and ensure adherence to federal regulations. Staff Training • Provide comprehensive training for staff responsible for enrollment reporting on NSLDS requirements, deadlines, and best practices • Offer training sessions as regulations change or system updates occur. Reporting and Documentation • Maintain records of all corrected data submissions, audit results, and communications with NSLDS • Document procedural changes and staff training efforts Responsible Person for Correction Action Plan: Dianna Ruyle, Director of Records, Registration and Advising Implementation Date for Corrective Action Plan: Immediately and ongoing

Identification and Review • Identify all students who received incorrect loan amounts (Completed) • Make appropriate adjustments to loan disbursements (Completed) • Notify affected students and provide guidance on next steps (Completed) Policy and Procedure Enhancements • Develop clear, written procedures for verifying loan amounts prior to disbursement • Implement a two-step verification process for loan packaging System Controls • Collaborate with IT to implement automated system checks to flag discrepancies • Enhance reporting tools for regular audits and monitoring Staff Training • Conduct comprehensive training sessions for financial aid staff on federal regulations regarding Direct Loans • Provide ongoing refresher courses and updates as federal policies change Monitoring Continuous Improvement • Establish a quarterly audit process to ensure compliance • Monitor loan discrepancies detected and correct as needed • Conduct regular audits to confirm compliance with federal loan regulations. • Collect feedback from staff on the effectiveness of training Responsible Person for Correction Action Plan: Alexis Brown, Director of Financial Aid Implementation Date for Corrective Action Plan: 03/03/25

Identification and Review • Immediately review and recalculate the subsidized need for the affected students. (Completed) • Identify the sources of aid contributing to the excess amount and whether any adjustments can be made within the same academic year • Adjust the loan amounts as necessary and return any excess funds to the Department of Education. (Completed) • Review packaging procedures to pinpoint the cause of the discrepancy (e.g., late outside scholarships, system errors, or manual adjustments Student Award Adjustments • Reduce or cancel institutional or federal aid (such as loans, Federal Work-Study, or certain grants) in accordance with federal regulations and institutional policies • If the excess aid cannot be adjusted within the same academic year, follow federal guidelines to return any over awarded federal funds through the Common Origination and Disbursement (COD) system • Notify students of any changes to their financial aid package and provide guidance on alternative funding options if needed System Enhancements • Implement system-level edits and warnings in the financial aid software to flag over-awards before disbursement. • Schedule regular audits of loan disbursements to ensure ongoing compliance Policy and Procedure Update • Update the financial aid packaging policy to include stricter controls for verifying subsidized need calculations. • Implement a cross-check system for all financial aid components before loan disbursement • Require timely reporting of external scholarships and third-party payments to prevent adjustments after disbursement Monitoring and Compliance • Conduct training sessions for financial aid staff on loan eligibility calculations. • Conduct periodic reconciliation of student aid packages throughout the academic year to prevent over awards • Provide guidance on using the financial aid management system's tools to avoid over-awards Responsible Person for Correction Action Plan: Alexis Brown, Director of Financial Aid Implementation Date for Corrective Action Plan: 02/25/25

2. Identifying Number: 2024-002: Enrollment Reporting Finding: During the course of our special tests and provisions, we identified 3 students from a sample of 25 where the number of days between the enrollment change and reporting to National Student Loan Data System (NSLDS) was not within the required 60 days. We also identified 3 students from our sample of 25 whose withdrawal date was reported as the day after the withdrawal began and 1 student whose withdrawal date was reported as the end of the semester in which the student was attending. We also identified 2 students from our sample of 25 who were reported as withdrawn instead of graduated. Corrective Action Taken or Planned: Actions Taken The University has already taken corrective action on this finding. The issues raised were addressed in the following ways: number of days between the enrollment change and reporting was not within the required 60 days Graduate File Corrections: We discovered (Fall 2023) an error in the reporting of graduates, despite timely reporting via Degree Verify. Upon this discovery, we met with the National Student Clearinghouse (NSC) to determine the cause of the issue and how to correct it. We learned that students with enrollment in more than one program, or where the program reported did not match the program on record with NSC, were not being properly processed with a G status via the Degree Verify submissions. We were informed that this is common for institutions where students may be enrolled in more than one program at a time. We were advised by NSC to submit a “Graduates only” file, in addition to the Degree Verify file submission. Upon discovering this, we submitted Graduates only files for branches 02, 03, 04, 05, 80, 82, 84, and 97, for all terms for 2020, 2021, 2022, and 2023 beginning in December 2023 and ending in April 2024. We worked through these submissions with NSC, and incorrect withdrawn statuses were corrected to graduated statuses. Antioch’s enrollment reporting process has been updated to include a monthly submission of a graduates only file in addition to degree verify file monthly submission. The University has experienced changes in staffing for personnel involved in enrollment reporting. The person previously in charge of Enrollment Reporting retired on 02/29/24. He was responsible for the enrollment reporting for the majority of this audit period, as well as the prior year. Antioch University hired a new Director of Records Administration with a primary responsibility for NSLDS reporting on 03/28/24. The University has implemented a comprehensive training plan, including improved documentation of procedures, increased clarity regarding the process for the necessity of error resolution, and a review of system processing to help reduce errors in reporting and increase efficiency. The review of current practice and improved procedures was in conjunction with consultants from AACRAO, NSC, Ellucian (the student information system company). Actions Planned The University plans for corrective action on this finding. This includes policy updates for withdrawal processing and implementation of internal audits. Withdraw date was reported as the day after the withdraw began. It has been the practice to process withdrawal requests in this way: When a student withdrawal is submitted, the notification date is considered the last date of active enrollment. The withdraw (W) status begins effective on the following date. This has not been raised as a finding in prior audits. This process will be updated (effective April 1, 2025) to follow 34 CFR 668.22(c). For withdrawal processing effective immediately, this process will be updated to start the withdrawal on the date the student provides official notification, rather than starting on the day following. This means the last date attended and the start of the withdrawal will be the same date. Per the CFR 668.22(c). the student's withdrawal date is—(ii) The date, as determined by the institution, that the student otherwise provided official notification to the institution, in writing or orally, of his or her intent to withdraw; For withdrawal processing effective at the end of the term, the effective date for the ‘W’ status is the final day of the term in which the student was last enrolled. Per the Withdrawal versus Graduation and Effective Dates section of the NSLDS Manual Nov 2022, p.23 - In the case of the student who completes a term and does not return for the next term, leaving the course of study uncompleted, the effective date for the ‘W’ status is the final day of the term in which the student was last enrolled. The policy and process will be updated and training will occur to begin this processing change effective April 1, 2025. Withdraw date was reported as the end of the semester in which the student was attending It has been the practice to process withdrawal requests in this way: When a student requests withdrawal but has completed courses, the grades are updated prior to processing the withdrawal request. The withdrawal is effective on the start date of the next term. This process will be updated (effective April 1, 2025) to follow 34 CFR 668.22(c) and the NSLDS Manual as outlined in the prior bullet point. For students withdrawing immediately from a term in which they’ve already completed one or more courses, the effective date for the ‘W’ status is the date AU is notified. However, they will only be dropped from courses still in progress. Completed courses cannot be withdrawn. The policy and process will be updated and training will occur to begin this processing change effective April 1, 2025. Reported as withdrawn instead of graduated The Grads Only submission did not return student records for 24SPTRI. We will need to review this with Ellucian to determine the issue. Once this is determined, we will re-run the submission for this term to update records. An internal audit process will be implemented to spot check 3-5 records on each submission for enrollment, grads only, or degree verify reporting. In addition, an audit report will be created to review 9 sample records on a quarterly basis from the current list of active students and the last two years of graduated and withdrawn students. The review will select 3 records from each status. An audit log will document these reviews. Person Responsible for Corrective Action: The Registrar and Executive Director of Financial Aid & Scholarships are responsible for executing the corrective action plan. The Executive Director of Financial Aid and Scholarships and the University Registrar will meet on a recurring basis to jointly review enrollment reporting procedures and National Student Loan Data System (NSLDS) reporting timelines. This collaboration ensures that all enrollment data submitted for Title IV purposes is accurate, timely, and aligned with institutional policies and federal regulations. Any discrepancies or issues identified are addressed collaboratively and corrective steps are documented. Anticipated Completion Date: Fiscal year 2025

1. Identifying Number: 2024-001: Title IV Refund and Return of Funds Compliance Issue: A sample review found instances where Title IV refunds were miscalculated and not returned within the required timeframe. Cause: Administrative oversight led to inaccurate and untimely calculation. Effect: The University did not fully comply with FSA Handbook and federal regulations for returning Title IV aid in a timely manner. Corrective Actions Underway 1. Enhanced Quality Assurance Measures Implementation of a new review protocol for Title IV refund calculations, including a secondary verification process before fund returns. Establishment of a biweekly internal audit of refund calculations to identify and resolve errors before submission. 2.Ongoing Compliance Monitoring and Prevention Efforts Establishment of a quarterly compliance review conducted by the Financial Aid leadership team to proactively address potential issues. Development of a standardized documentation process for all Title IV transactions and NSLDS updates to ensure clear audit trails. Creation of staff retraining initiative to reinforce compliance expectations and best practices. Next Steps: Conduct a full compliance assessment at 30, 60, and 90 days to confirm improvement and adjust protocols as needed. Establish a reporting dashboard for real-time tracking of Title IV refunds and enrollment status updates. Formalize a policy review cycle to ensure that all processes remain aligned with the latest federal regulations. These actions are intended to strengthen the University’s compliance posture, mitigate risks, and enhance the accuracy and timeliness of financial aid administration. Please let me know if additional measures or oversight mechanisms should be considered. Person Responsible for Corrective Action:The Executive Director of Financial Aid & Scholarships is responsible for executing the corrective action plan. Anticipated Completion Date: Fiscal year 2025

Corrective Action Plan: The College agrees with this finding. After disbursing aid for the first time in the Fall 2023 semester and sending Pell origination and disbursement records to COD, the College ran the Pell COD Reject Report (PCRR) in Colleague to identify records that COD had rejected. COD identified 8 students whose Pell disbursement was rejected due to citizenship status issues. These files were reviewed and it was identified that a required field in Colleague was not populated correctly to indicate to COD that the citizenship issue had been reviewed by collecting the required documentation from the student. The files were being reviewed and updates were made in Colleague but not within the 15-day window. Procedure notes have been updated and training has occurred to ensure all relevant personnel understand the process and know where to make the appropriate updates in Colleague when reviewing citizenship documents. Status of Correction Action: Completed

The College agrees with this finding. The Registrar’s Office will proactively report withdrawals from the College between academic semesters manually to the National Student Clearinghouse (NSC) in a timely manner to ensure that NSLDS receives those status changes within the required 60-day window. The Registrar will work with IT to create a report to assist in identifying all withdrawals that are processed between terms. Staff will use this report to crosscheck status changes reported to the NSC. The Registrar’s Office will follow up with the Audit Support division of the NSC regarding previous guidance on effective dating of withdrawals. The NSC’s directive to use the day after the final date of a completed term seems to contradict the effective date that the Clearinghouse automatically assigns when a student is not reported for the subsequent term.

Incorrect Pell Calculations Planned Corrective Action: There were two students not awarded for summer school. Both appeared to be graduating in May. Unfortunately, these students did not graduate until August and were then eligible for Pell in the summer. Both students have been awarded. The financial aid office has added summer period of enrollment for all students currently registered for summer classes and will perform a sweep to ensure that additional students are awarded who may register before summer classes begin. Person Responsible for Corrective Action Plan: Karen Benfield, Director of Financial Aid. Anticipated Date of Completion: Implemented 3/24/2025

Verification Planned Corrective Action: Verification was performed for this student based on the documents received at the time. Unfortunately, retrieving these documents was not possible. Prior staff did not move the file to digital file folder and misfiled the documents. As mentioned, due to staff turnover, securing some documents has been difficult. The current process is to scan all documents from students into a secure electronic folder where all financial aid staff can view. Financial Aid counselors perform periodic reviews to ensure documents are on file and retrievable. Financial Aid staff are maintaining hard copy files as a 2nd form of confirmation. Person Responsible for Corrective Action Plan: Karen Benfield, Director of Financial Aid Anticipated Date of Completion: Currently implemented

Inaccurate Return of Title IV Funds (R2T4) Planned Corrective Action: The two students identified had calculations done correctly but the returns were late. These funds have been returned to the Department of Education. The director will coordinate with the registrar to receive a report of zero credits earned at the end of each semester. This review will ensure the Financial Aid Office is returning funds in a timely manner for students that do not officially withdraw. The online administration has a policy in place to alert the financial aid and registrar's office should a student miss more than seven-fourteen days of class. Administration meets on a bi-weekly basis to review official withdrawals and unofficial withdrawals whose date of determination have been noted. Person Responsible for Corrective Action Plan: Karen Benfield, Director of Financial Aid Anticipated Date of Completion: To be implemented at end of spring semester, 2025 (5/7/2025)

Enrollment Reporting to NSLDS Planned Corrective Action: Finalize automation of file configuration, reporting schedule, and transmission process. Person Responsible for Corrective Action Plan: Sid Parrish, Vice President of Institutional Reporting Anticipated Date of Completion: December 31, 2025 While Newberry College successfully transitioned to the JI platform as planned, the automation of enrollment reporting to the National Student Loan Data System (NSLDS) has not yet been fully implemented on the projected timeline. This delay is primarily due to the unexpectedly complex nature of the data table transition required within the new system. The structure and formatting of enrollment data in JI differed significantly from our previous platform, requiring extensive mapping, validation, and customization to ensure accuracy and alignment with NSLDS reporting requirements. That portion of the work is now complete. In addition, the College experienced a change in personnel within the Registrar's Office. While our new Registrar brings significant experience with other student information systems, she required full training on the JI system before assuming full reporting responsibilities. To ensure resolution, the College's Director of Institutional Research is working closely with the Information Technology team and the new Registrar to finalize the automation process. This includes active collaboration with both the National Student Clearinghouse (NSC) and NSLDS to identify, understand, and clear errors that have surfaced in early iterations of the automated enrollment file. These efforts have helped isolate remaining issues and informed adjustments to the file configuration, reporting schedule, and transmission process. We believe this will lead to a fully functional, automated enrollment reporting process by the end of fiscal year 2025. In the interim, the Registrar is manually submitting enrollment files to the NSC to ensure that student status information is communicated to NSLDS in a timely and accurate manner. This manual submission process remains in place and will continue until the automated solution is fully operational.

The College will evaluate their procedures for maintaining original documentation and ensure there is control over maintaining prior documentation over time. The college underwent an internal review of all Perkins promissory notes and plans to purchase back the loan in the event the promissory notes cannot be found. Rani Arsenault in the Business Office will identify missing promissory notes in FY25.

We recommend that the College implement procedures to ensure triggering events are identified and reported to ED in a timely manner. There was confusion as to what needed to be reported due to the fact that one default notice was issued in December 2023 for the FY23 covenant and the bank delayed the amendment knowing that FY24 would be covered by the amendment the same default notice. Reporting of the amendment took place in February of 2025, and a reporting will be made as soon as possible, if it is deemed necessary for FY25. As of right now the College is expeceted to meet its covenants for FY26. VP of Administration and Finance will reach out within 21 days if that is not the case.

Assistance Listings Numbers: 84.007, 84.033, 84.063 & 84.268 Cluster Title: Student Financial Assistance Cluster Program Titles: Federal Supplemental Educational Opportunity Grants, Federal Work-Study Program, Federal Pell Grant Program and Federal Direct Student Loans Federal Agency: U.S. Department of Education Award Year: 2024 Award Number: None Compliance Requirement: Reporting Question Costs: None Total tuition and fees as reported in the FISAP report was $8,787,259 while the district’s underlying accounting records showed $9,133,531 for a difference of $346,272. Total Federal Pell expenditures were reported as $6,259,684 on the FISAP report while the underlying accounting records and schedule of expenditures of federal awards showed $6,298,477 for a difference of $38,793 Joline Pruitt, Vice President Administrative Services & CFO Anticipated Completion Date: September 30, 2025 The District agrees with the reported finding and recommendation. The FISAP report was submitted by September 30, 2024; however, year-end adjustments were recorded in the general ledger resulting in the FISAP report not including the year-end adjustments. For future reporting, the District will ensure the FISAP report is filed by the September 30th due date; however, should adjustments be made subsequent to the FISAP submission, the Business Department will communicate to the financial aid department any adjustments and an amended FISAP report will be filed.

Management Response We agree with the auditor's comments. The College is actively recruiting to fill critical accounting vacancies. The College is reviewing standard operating procedures for all federal activity to include grants and student aid. Procedures, training, and processes to review the SEFA will be implemented in FY 2026.

Finding 2024-001: UNPAID AND UNTIMELY PAID REFUND- We tested thirteen drop students and noted one unpaid and one untimely paid refund as a result of Return of Title IV funds calculations. Comments on Finding and Recommendation(s): The institution agrees with this finding. It was recommended that the school complete the R2T4 and return the $4,704 in Sub, Unsub, and PLUS funds to the Department of Education. The Pell return, while untimely, was completed prior, therefore no additional action required. Actions Taken or Planned: The $4,704 in Sub, Unsub, and PLUS was returned to the Department of Education on 12/16/24. Withdrawals are processed by the Dean of Academic Success and forwarded to the Registrar and Financial Aid Office for review and action. The Financial Aid Office and Business Office will begin to track withdrawals and follow up with Academic Success and the Registrar when final forms are not shared in a timely manner so that funds can be returned as needed.

Corrective Action Plan: The finding was due an administrative error in the Pell award for this particular student. The College corrected this error and disbursed $492.50 to the student. Timeline for Implementation of Corrective Action Plan By using the incorrect enrollment status, the student was under awarded Federal Pell Grant funds. Contact Person Troy Martin, Director of Student Financial Services

Department of Education NSLDS Enrollment Reporting Student Financial Aid Cluster – Assistance Listing No. 84.268, 84.063, 84.007, 84.033 Auditors’ Recommendation: The University must review their enrollment reporting policies and procedures to ensure accurate reporting. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Point University uses National Student Clearinghouse (NSC) for the enrollment reporting process. The registrar’s office prepares a monthly enrollment change report which is sent to NSC. NSC processes the report and returns a file for any discrepancies and potential errors for the school to fix. The school reviews and makes any necessary updates and submits the report to NSC. NSC updates the enrollment information at NSLDS. For graduated students, the school also submits a degree verification file at the end of each term after graduated status is assigned by the school. This file is separate from the enrollment reporting file. The school inquired as to why the updates were not completed and found that updating enrollment status is not part of NSC’s process for the degree verification files. Moving forward, the registrar will submit a separate enrollment report file along with the degree verification to ensure that graduate status is updated at NSC and NSLDS after the school assigns them. During the 2024-2025 school year, while the school was reviewing FVT/GE reporting that was due in January of 2025, the school was able to review enrollment data that had been reported to NSC for the 2023-24 school year and make corrections to that data. Moving forward, the enrollment data is maintained in the new student information system and updated in real time by the registrar’s office prior to the enrollment reports being sent to NSC. Of the 33 students reviewed for NSLDS enrollment status, five had errors. All five students were graduates whose status errors were related to data migration. All five were corrected during the school’s review of enrollment statuses while reviewing data for the FVT/GE reporting, which was done November 2025 through January 2025. Documentation of corrected enrollment statuses with the dates of the certification corrections is attached as Appendix 2024-002A. Name(s) of the contact person(s) responsible for corrective action: Natalie Brown-Motes, Point University Registrar, natalie.brown@point.edu Planned completion date for corrective action plan: FVT/GE status review is completed. School has process in place moving forward for updating graduated students beginning with Spring 2025 semester.

UCB recognizes its obligation under an institution’s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in supportof the administration of the federal student financial aid programs. The Gramm-Leach-Bliley Act (GLBA) (Pub. L. No. 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as “financial institutions” and subject to the Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi)). To ensure that the University complies with the requirement, during this year that ends at June 30, 2025, University risk assessment addressed the elements required by (16 CFR 314.4). Accordingly, for this year UCB already performed the following: 1. Vulnerability test 2. Penetration test 3. Backup test was performed during year ended June 30, 2025. Anticipated completion date: Immediately.

UCB recognizes its obligation to report enrollment data to the National Student Loan Data System (NSLDS) at least every 60 days. The Registrar's Office reports enrollment data to NSLDS on a monthly basis. To ensure that the University complies with the 60-day requirement, we have established an additional notification procedure. The Financial Aid Office will forward a report of all Title IV student recipients classified as withdrawn to the Registrar's Office, this process consists of a reconciliation of the data. The Registrar's Office will report the enrollment change of these cases to NSLDS within 60 days required. Anticipated completion date: Immediately.