Corrective Action Plans

Condition The Federal Pell Grant for one student out of 27 sampled was calculated incorrectly, and the student received excess aid. Corrective Action Plan La Roche University concurs with the finding. The Office of Financial Aid has implemented enhanced controls to ensure accurate Federal Pell Grant calculations in accordance with Title IV regulations and U.S. Department of Education Pell Grant payment and disbursement guidance. Immediate Correction of Identified Error The affected student’s Pell Grant award was recalculated using the correct Scheduled Pell amount and enrollment intensity. The overaward was resolved in accordance with federal overpayment and reconciliation requirements, and the Common Origination and Disbursement (COD) system was updated accordingly. Pell Calculation Verification Control A mandatory secondary review process has been implemented for all Pell-eligible students prior to disbursement to prevent future occurrences noted in this finding. This control collectively mitigates the risk of recurrence and strengthen institutional compliance with federal eligibility and disbursement requirements. Name(s) of Contact Person(s) Responsible for Corrective Action • Lawrence Britton, Executive Director of Financial Aid • Ron Elmore, Associate Director of Financial Aid Anticipated Completion Date All corrective actions were implemented as of February 9, 2026.

Condition The federal aid disbursed resulted in a credit balance for one of the 25 students tested were not returned within 14 days of the date the credit balance occurred. Corrective Action Plan La Roche University concurs with the finding. The University’s procedures did not allow for timely payment of the funds to the student due to holidays that occurred. The Office of Student Accounts has implemented enhanced controls to ensure that credit balances are reviewed and issued refunds in a timely manner. Name(s) of Contact Person(s) Responsible for Corrective Action • Frank Corona, Controller • Dayna Tinkey, Director of Student Accounts Anticipated Completion Date All corrective actions were implemented as of February 12, 2026.

Condition The University did not notify the National Student Loan Data System (NSLDS) in a timely manner for 1 student with status changes in the sample of 25 students selected. Corrective Action Plan La Roche University concurs with the finding. The Office of the Registrar has implemented a new standard operating procedure regarding the reporting of students who have notified us of their withdrawal from the University at the end of spring term/early summer. Identified Error: La Roche University reports enrollment through the National Student Clearinghouse (NSC), which then reports to NSLDS. Because summer is not a mandatory reporting period, if a student is not enrolled they are not coded as withdrawn until they do not return in the fall; only on the first of fall enrollment report would they be coded as withdrawn. This does not meet the reporting timeline to NSLDS if we know a student is not planning to return. This only presents as an issue with the length of time between the end of spring and start of fall term; this is not an issue between the end of fall and start of spring term. New Procedure: If a student submits a Withdrawal form at the end of spring term through the first week of August, we must manually report them as withdrawn in NSC, as we know their intention to not return. Any forms submitted beginning in mid to late August will be picked up on the first of fall enrollment report as withdrawn and still fall within the reporting timeline. Name(s) of Contact Person(s) Responsible for Corrective Action • Katie Elverson, Registrar Anticipated Completion Date Implementation begins in May 2026 and will continue being implemented in all summers going forward.

Management Response: The University agrees with the finding. The identified issue was isolated and only impacted fall graduates. This issue was fully addressed when the university filed its fall 2025 enrollment reporting. The university has conducted an internal audit to identify students that were reported incorrectly and has manually updated files to ensure dates were properly reflected. At current state, internal monitoring and manual edits are made if discrepancies appear. The university has been in contact with PeopleSoft software related to the issue. Should the software issue not be resolved, the university plans to continue with manual edits to ensure proper reporting. Contact Person: Stacy Ramsey, University Registrar srramse@ilstu.edu Completion Date: December 2025

Uniform Guidance Corrective Action Plan Year ended June 30, 2025 Federal Finding #2025-002 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)) Quinnipiac University agrees with the finding. An enrollment roster of students that graduated during the 2024-2025 academic year was reported to NSLDS outside the maximum 60-day window. As a result of this finding, Management implemented steps on January 5th, 2026, within the Registrar’s production calendar to run a graduate report along with monthly enrollment reports so that changes in enrollment status are reported on a timely basis. In addition, the Registrar’s office has adjusted the transmission with the National Student Clearinghouse to receive reminders of when file transmissions are coming due. If the Office of Management and Budget have questions regarding this plan, please reach out to Amy Terry, University Registrar, who is responsible for ensuring this corrective action plan is implemented, at 203-582-3933.

Uniform Guidance Corrective Action Plan Year ended June 30, 2025 Federal Finding #2025-001 Direct Loans are determined based on the criteria noted in 34 CFR 685.203(a),(b),(c). Students should be allocated the appropriate potion of subsidized loan funds before being awarded unsubsidized loan funds. Quinnipiac University agrees with the finding. In one instance, a student was under-awarded Subsidized Direct Loans. The student was awarded the appropriate annual amount of direct loans, however received only unsubsidized direct loans. The student should have been allocated a portion of subsidized loan funds before being awarded all unsubsidized loan funds. In another instance, a student was under-awarded Subsidized Direct Loans. Based on their demonstrated financial need, the student should have received additional subsidized loan funds before being awarded unsubsidized loan funds. As a result of this finding, Management implemented an exception report on December 9th, 2025, that will identify students who were awarded less than their maximum subsidized eligibility but have remaining need eligibility. This report will be run at least monthly to identify those students and will allow for their loans to be revised on a timely basis. In addition, the University is in the process of a software modernization project and while working with software consultants, the University plans to review all processes in accordance with best practice recommendations so that they are designed to meet current regulations. If the Office of Management and Budget have questions regarding this plan, please reach out to Kelly Osorio, University Director of Financial Aid, who is responsible for ensuring this corrective action plan is implemented, at 203-582-7446.

Federal Operations Report and Application to Participate (FISAP) –Assistance Listing No. 84.007, 84.033, 84.038 Recommendation: The University should review its policies and procedures on reviewing underlying FISAP data prior to submission to be in compliance with regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Widener University is committed to ensuring the accuracy and integrity of all data reported in the annual FISAP. To support this commitment, additional data-validation measures and internal review procedures will be implemented. These enhancements will help ensure that all information is thoroughly verified and approved prior to final submission by the Director of Financial Aid Services. Name(s) of the contact person(s) responsible for the corrective action: Colleen Shinkle, Director of Financial Aid Services Planned completion date for corrective action plan: February 2026

Upon Notification of the situation by Wipfli, Western had identified several new processes to assure our students are being reported to NSLDS within the 60-day period. 1. Resolved: Western worked with Ellucian Services to review and update our savedlist for National Student Clearinghouse reporting. We discovered the savedlist excluded a subset of student, which prevented their enrollment from being updated correctly. The savedlist is now updated. 2. Update our Admissions Policy (E0200) and Procedure (E0200p9(1)) to direct students on how to officially withdraw from the College. This will help us identify students who do not plan to return to the College. We will create a report of students who officially withdraw from the College and update their status on National Student Clearinghouse website in a timely manner. 3. Identify a process to update the enrollment status for students who receive an extenuating drop for courses. We will develop a report to monitor and update on the National Student Clearinghouse website. 4. Identify a process to update the enrollment status for students who unofficially withdraw from a session 1 course which impacts their enrollment status. We will develop a report to monitor and update the National Student Clearinghouse website. Person Responsible: Lyndsey Thomas, Registrar Projected Completion Date: June 1, 2026

Westminster College Corrective Action Plan (CAP) Federal Program: SFA Cluster, Finding 2025-002: Policies and Procedures Related to Withdrawals (significant deficiency) In accordance with 34 CFR 668-22 Treatment of Title IV Funds When a Student Withdrawals, Westminster College has implemented the following Corrective Action Plan: Name of Contact Person: Dr. Annette Roberts, Assistant Dean of Institutional Research and Registrar Specific Corrective Action: Management has developed written policies and procedures to document the steps put in place to ensure that changes in student status are reported in a timely manner. A critical excerpt from that language is included below: After receiving post-notification from EIPC, the Registrar contacts faculty to confirm the student’s last date of attendance. Using this information, the Registrar determines the withdrawal date, exit date, and records these in Jenzabar. The Registrar then notifies Financial Aid, the Business Office, Institutional Research, Residence Life, Advancement, and IT/Help Desk. Institutional Research subsequently pulls the data from Jenzabar and cross references it with the notifications from these offices, once verified. Institutional Research submits the finalized data to the National Student Clearinghouse. Anticipated Completion Date: The Corrective Action Plan

Finding 2025-002 Reporting Department’s Response: Management agrees with this finding. Corrective Action: This issue arose during the onboarding of students admitted through a teach-out arrangement with a closing institution. Because these students entered under program structures that differed from NUNM’s standard enrollment models, some of the information initially received did not align with NUNM’s financial aid packaging assumptions. In two cases, cost of attendance calculations reflected full-time status when the program design required three-quarter-time treatment. While the situation was limited to a small number of students within a unique population, management recognizes that our internal coordination processes did not sufficiently account for the complexity of the teach-out transition. In particular, clearer confirmation of enrollment status and program structure should have occurred before aid was packaged and originated. Management is strengthening procedures for any future teach-out, transfer, or non-standard admissions cohorts to ensure accurate and compliant packaging from the outset. Going forward, NUNM will implement the following controls: • A standardized handoff process from Admissions to Financial Aid for special populations that documents program structure, term length, and expected enrollment level prior to packaging. • A secondary review requirement for initial aid awards for new program types or cohorts before loans are originated. • Regular cross-functional checkpoints between Admissions and Financial Aid during the setup of non-standard programs. Management views this experience as an opportunity to improve coordination and compliance during periods of institutional transition and is committed to maintaining strong controls over Title IV packaging and cost of attendance calculations. Contact: Jerry Bores Anticipated Completion Date: Immediately

A. Incorrect Calculation of Return of Title IV Funds The District’s Central Financial Aid Unit will collaborate with the Office of Information Technology (OIT) to utilize the last date of academically related activity (also known as the last date of participation) as the withdrawal date for R2T4 (Return to Title IV) calculation purposes. Personnel Responsible for Implementation: Steve Giorgi Position of Responsible Personnel: District Financial Aid Systems Manager Expected Date of Implementation: Fall 2026 B. Distance Education (DE) Courses – Implementation of Formal Process to Determine Accuracy of Student Withdrawal Date – Partial Implementation of Prior Year Corrective Action Plan (CAP) The District’s Educational Program & Institutional Effectiveness office (EPIE) will continue to provide updated guidance and resources to enable faculty to identify academic participation in online classes and to accurately determine the last date of academically related activity. For distance education courses, the process will consistently translate instructor-documented last dates of academic participation, as captured on instructor exclusion rosters, into the withdrawal dates recorded in SIS for R2T4 calculation purposes. Personnel Responsible for Implementation: Mily Kudo Position of Responsible Personnel: Associate Vice Chancellor, Educational Programs and Institutional Effectiveness Expected Date of Implementation: Fall 2026

The District’s Educational Programs & Institutional Effectiveness (EPIE) and Information Technology (IT) divisions will continue reviewing the current programming, analyzing test cases, and studying the more complex system changes required to address the misalignment between the student status effective date reported to the NSC and the date recorded in the PeopleSoft enrollment reporting system. Because the necessary programming updates are more intricate than initially anticipated, additional analysis and testing will be needed before implementing a long-term solution. EPIE will continue to monitor post-submission errors and warning reports to assess the effectiveness of the programming changes. Personnel Responsible for Implementation: Mily Kudo, Andrew Alvarez, Stan Levin Position of Responsible Personnel: Associate Vice Chancellor, IT Business Analyst, Research Analyst Expected Date of Implementation: March 2026

Special Tests & Provisions – Gramm-Leach-Bliley Act – Student Information Security Responses UNLV agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; UNLV Office of Information Technology (OIT) notes that all safeguards noted within the finding are in place and operating effectively. The action necessary relates to an update within the written information security program. This corrective action was taken immediately at the beginning of the current fiscal year, with the updated UNLV written information security program effective July 2025. ● How compliance and performance will be measured and documented for future audit, management and performance review. The UNLV Chief Information Security Officer will review the written information security program at least annually, to occur by the end of each fiscal year, to ensure documentation matches the control environment in practice. Additionally, UNLV engages a third party to perform a robust review of the overall GLBA environment to ensure the institution is appropriately addressing risk areas (most recently in FY25). ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The GLBA regulation requires designation of a Qualified Individual within the organization who is responsible for overseeing and implementing the Information Security Program. At UNLV, this is the Chief Information Security Officer and this individual is the responsible party to exercise oversight and accountability in this area. Official Contact: Rhett R. Vertrees, Assistant Chief Financial Officer 2601 Enterprise Road, Reno NV 89512-1666 Phone: (775)784-3409, Fax: (775)784-1127 Email: rvertrees@nshe.nevada.edu

Special Tests & Provisions – Enrollment Reporting Responses CSN – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; CSN is implementing additional validation steps in the monthly learinghouse report submission process to ensure all required information is accurate and complete. In addition, a monthly quality control review will be conducted on submitted data. Ongoing professional development will also be provided through scheduled monthly and annual trainings, as well as on an ad hoc basis as needed. ● How compliance and performance will be measured and documented for future audit, management and performance review. Under the direction of the Assistant Registrar, the Program Officer II responsible for processing enrollment reporting submissions will distribute error report data. The Assistant Registrar will also conduct a monthly validation by reviewing a random sample of files on the Clearinghouse website to ensure accurate submissions. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. CSN Registrar will be responsible. NSU – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; NSU has reviewed the finding and continues to monitor measures that have been put in place to ensure compliance. Also, some additional procedures have been identified and others further refined. All processes will be fully in place within the next 30 to 45 days. o Continue bi-weekly enrollment reporting schedule to the National Student Clearinghouse (NSC). o Maintain bi-weekly calendar reminders to ensure timely submission of enrollment updates, supplementing NSC notifications. o Establish end-of-term calendar reminders to ensure prompt reporting of graduated statuses. o Continue coordination with NSC to identify students included in submitted enrollment reports whose statuses were not updated. o Review NSC response and reject files following each submission to identify discrepancies. Address any identified discrepancies promptly, even if students do not appear in the reject file. Confirm that updated enrollment statuses are reflected within the National Student Loan Data System (NSLDS). o Maintain documentation of submission dates and communications with NSC. ● How compliance and performance will be measured and documented for future audit, management and performance review. To ensure compliance and strengthened performance in reporting changes in student enrollment status, Nevada State University (NSU) will continue and enhance the following tracking, monitoring, and documentation measures: o NSU will conduct documented monthly reconciliations of enrollment status reports to verify the accuracy, completeness, and timeliness of submissions to the National Student Clearinghouse (NSC). These reviews will include confirmation of submission dates, validation of reported status changes, and resolution of any identified discrepancies prior to the next reporting cycle. o Detailed logs of all enrollment status submissions and NSC notifications will be maintained and centrally retained. Documentation will include timestamps, submission confirmations, reconciliation records, exception reports, and evidence of follow-up actions to ensure a clear and complete audit trail. o Periodic internal compliance reviews will be conducted to assess adherence to the bi-weekly and end-of-term reporting schedule. Review results will be formally documented and provided to management to support oversight and continuous process improvement. o Key performance indicators (KPIs) will continue to be tracked and formally reviewed on a quarterly basis. These KPIs will include:  Percentage of reports submitted within required timelines  Accuracy rate of enrollment status updates  Timeliness of discrepancy resolution o Any discrepancies identified during monthly reconciliations or internal reviews will be addressed promptly, with documented corrective actions, assigned responsible parties, and established resolution timelines. o NSU will compile an annual compliance summary outlining monitoring activities, audit results, corrective actions implemented, and overall performance metrics. This report will be maintained for executive oversight and future audit and management review. o Beginning in March 2026, these measures outlined above will be formally documented and maintained to ensure ongoing compliance. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The Student Information and Scheduling Systems Analyst is primarily responsible for ensuring accurate and timely enrollment status reporting. A new Registrar assumed the role at the start of FY2026 and has begun overseeing compliance with established internal controls, including bi-weekly and end-of-term reporting requirements. Official Contact: Rhett R. Vertrees, Assistant Chief Financial Officer 2601 Enterprise Road, Reno NV 89512-1666 Phone: (775)784-3409, Fax: (775)784-1127 Email: rvertrees@nshe.nevada.edu

Special Tests & Provisions – Return of Title IV (R2T4) Responses CSN – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; CSN added additional resources to the R2T4 program by hiring a Senior Specialist to ensure R2T4 queries are frequently run, and accounts are reviewed on a weekly basis. CSN also contracted the services of a PeopleSoft consultant to assess, streamline, and automate R2T4 queries. Additionally, R2T4 staff, PeopleSoft Consultant and third-party vendor meet on an ongoing basis and implement necessary changes to meet compliance requirements. CSN is also providing professional development opportunities to staff through our trade organizations. ● How compliance and performance will be measured and documented for future audit, management and performance review. Under the direction of the Assistant Director, the newly hired Senior Specialist position runs queries and assigns identified files to staff twice a week to ensure accounts are reviewed within the federally mandated timeframe. CSN also continues to train staff on the processing of R2T4 and schedule regular team meetings to ensure updates and changes are communicated in real time and R2T4 procedures are applied accurately and consistently. CSN continues to perform quality control through the review of processed R2T4 files. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. CSN Director of Financial Aid will be responsible. Official Contact: Rhett R. Vertrees, Assistant Chief Financial Officer 2601 Enterprise Road, Reno NV 89512-1666 Phone: (775)784-3409, Fax: (775)784-1127 Email: rvertrees@nshe.nevada.edu

Eligibility Responses UNR – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; The Financial Aid Office has implemented a daily query to check for awards not matching the academic program and level. The query is run by the data team and then again by the Compliance team to mitigate improper awarding due to manual changes. ● How compliance and performance will be measured and documented for future audit, management and performance review. This revised process ensures that any mismatched program awards are resolved without negatively impacting students and resolution occurs within established time frames. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The Assistant Director for Compliance and Processing, Program Manager of Federal Funding, and the Interim Financial Aid Director. Official Contact: Rhett R. Vertrees, Assistant Chief Financial Officer 2601 Enterprise Road, Reno NV 89512-1666 Phone: (775)784-3409, Fax: (775)784-1127 Email: rvertrees@nshe.nevada.edu

Cash Management Responses UNR – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; The Financial Aid Office has implemented enhanced reconciliation and cash management procedures designed to strengthen internal controls and mitigate future risk. The monthly reconciliation process has been revised to ensure that each reconciliation clearly documents all outstanding items, including timing differences and variances. ● How compliance and performance will be measured and documented for future audit, management and performance review. Under the revised process, the Assistant Director for Compliance and Processing ensures drawdowns are supported by detailed reconciliation schedules, discrepancies are formally identified and tracked, and resolution occurs within established timeframes. The updated procedures have been fully implemented and are operating as designed. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The Assistant Director for Compliance and Processing and the Interim Financial Aid Director. Official Contact: Rhett R. Vertrees, Assistant Chief Financial Officer 2601 Enterprise Road, Reno NV 89512-1666 Phone: (775)784-3409, Fax: (775)784-1127 Email: rvertrees@nshe.nevada.edu

Finding 2025-005 Errors in Verification Reporting Condition: Northern Illinois University (University) did not properly code the verification status in the Common Origination and Disbursement (COD) System for students who were disbursed Pell Grant funds and later selected for verification and the internal controls in place did not prevent and detect the exceptions. Corrective Action Plan: University has taken the following corrective actions that will eliminate all material exceptions: 1) University procedures have been updated to ensure verification status updates are properly transmitted to the Common Origination and Disbursement (COD) system upon completion of verification. Relevant staff have been trained on the revised procedures. 2) University has implemented a process to periodically review records and confirm that verification statuses are accurately reflected in COD. All affected student records have been reviewed and corrected. It has been confirmed in the National Student Loan Data System (NSLDS) that none of the mis-reported statuses resulted in an overpayment. Individual(s) Responsible for Corrective Action: Registration and Records Staff Anticipated Completion Date: June 30, 2026

Finding 2025-003 Errors in Reporting for NSLDS Condition: Northern Illinois University (University) did not properly report enrollment changes for certain students who received federal student aid to the National Student Loan Data System (NSLDS) and the internal controls in place did not prevent and detect errors. Corrective Action Plan: University has taken the following corrective actions that will eliminate all material exceptions: 1. The University will review and strengthen its current enrollment reporting procedures to ensure Program-Level updates are completed consistently, particularly in cases involving unofficial withdrawals. 2. The University will develop a batch reporting process for unofficial withdrawals to facilitate accurate enrollment reporting at both the program and campus level. Additional verification steps will be implemented prior to submission to confirm that both campus-level and program-level enrollment statuses are properly updated. 3. The University will also reinforce staff training related to NSLDS reporting requirements and enhance supervisory review procedures to reduce the risk of similar errors occurring in the future. Individual(s) Responsible for Corrective Action: Registration and Records Staff Anticipated Completion Date: June 30, 2026

Incorrect Term Dates Used in R2T4 Calculations Auditor Description of Condition and Effect. During testing of Return to Title IV ("R2T4") calculations for students who withdrew during the academic year, we noted 1 of 2 student calculations tested had an incorrect term start date when determining the percentage of the payment period completed. We further noted that the University used an incorrect term start date for all R2T4 calculations performed for the Fall 2024 semester. Specifically, the start date used in the calculation did not agree to the official academic calendar approved for the applicable term. As a result of this condition, the University performed R2T4 calculations that included inaccurate percentages of the payment periods completed, which lead to the improper calculation of Title IV funds earned and unearned. Auditor Recommendation. We recommend that the University implement a control requiring reconciliation of term dates used in R2T4 calculations to the officially approved academic calendar prior to processing withdrawals. Additionally, management should review R2T4 calculations completed during the affected period to determine whether recalculations and any necessary adjustments or returns are required. Corrective Action. The University will establish formal procedures to review the term dates used in R2T4 calculations to the officially approved academic calendar prior to processing withdrawals. Responsible Person. Anne Van, Director of Financial Aid Anticipated Completion Date. June 30, 2026

Non-Compliance with Servicer to Deliver Title IV Credit Balances Auditor Description of Condition and Effect. The University does not have a formal Banking Services Agreement with its financial institution. In addition, the University has not posted the agreement online, lacks documentation of the required biennial review, has not reported the arrangement to Federal Student Aid, and does not maintain adequate internal controls over the Tier Two Arrangement. Failure to comply with federal regulations increases the risk of regulatory sanctions, reputational harm, and potential financial penalties. Auditor Recommendation. We recommend the University execute a formal Banking Services Agreement with the financial institution, publish the agreement on its website, document and perform biennial reviews, report the arrangement to Federal Student Aid, and implement appropriate internal controls to ensure ongoing compliance. Corrective Action. The University will create a formal Banking Services Agreement with the Financial Institution, publish the agreement on its website, document and perform biennial reviews, report the arrangement to Federal Student Aid, and implement appropriate internal controls. Responsible Person. Yah-Sheba Jenkins, Controller Anticipated Completion Date. June 30, 2026

March 11, 2026 The University acknowledges the finding and the recommendation from Baker Tilly regarding improving procedures. Finding: 2025-001 – Special Tests and Provisions – Return of Title IV Funding (R2T4) and Enrollment Reporting: Significant Deficiency in Internal Control over Compliance Improved Process of Protocol This finding stemmed from 4 (four) departments at the University: College of Science and Health, College of Nursing, Office of the Registrar and Office of Financial Aid. As such, each department’s corrective action plan is listed below. College of Science and Health (COSH) To address this finding, the office of the COSH Dean has implemented a formal attendance-monitoring and escalation process to improve internal controls and ensure timely intervention. The updated process clearly defines responsibilities for faculty, program coordinators, and program leadership. Program Coordinators will review attendance records regularly: before the add/drop deadline, prior to the last day of the withdrawal period, and biweekly afterward to identify students who are not attending or exhibiting patterns of repeated absence. The process also outlines escalation procedures and timelines for student outreach, documentation of communication efforts, and reporting to the Registrar when administrative actions are needed. These procedures help ensure that non-attendance is identified promptly and that appropriate enrollment status adjustments are made in line with institutional policies. The Office of the Dean will oversee compliance with these procedures by conducting regular reviews of attendance records, documenting outreach efforts, and verifying notifications from the Registrar. This corrective measure enhances oversight, promotes prompt intervention for atrisk students, and ensures consistent enforcement of institutional policies on attendance and enrollment status. The action plan will be implemented on March 13th, 2026, and reviewed every semester for quality improvement. *See Corrective Action Plan for included table* Contact Person Responsible for Corrective Action: Dr. Monica G. Ferini, Dean, COSH Anticipated Completion Date: March 13th, 2026 College of Nursing (CON) To address this finding, the office of the CON Dean has implemented the following corrective action plan as follows: • Faculty: consistent check of attendance • Program Coordinator (PC): to run reports before add and drop date to track student activity status, if not active, Program Director (PD) will send notification to Registrar to request to process "drop" from the course • Program Coordinators (PC): Run attendance data tracking every 2 weeks • If student is identified missing >2 classes: PC will notify Faculty then faculty reach out to student (within 2-3d) • If student does not respond to faculty or continues to miss class: Faculty to notify PD (within 3-5d) • If student does not respond to PD or continues to miss class: PD to notify registrar of "withdraw" or dismissal (within 3d) Contact Person Responsible for Corrective Action: Dr. Sheryl Antido, Associate Dean, CON Anticipated Completion Date: March 23rd, 2026 Office of the Registrar Upon receipt of the university administrative or withdrawal form from the college or student, the form is processed in PowerCampus by the Office of the Registrar within five business days. Once the student’s status has been updated from "Enrolled" to "Withdrawn" or "Dismissed," an email notification is sent to the Office of Financial Aid, Student Finance, and the respective academic program. Upon receipt of the notification from the Office of the Registrar that a student’s status has been updated to “Withdrawn” or “Dismissed,” an email notification is sent to the Office of Financial Aid, Student Finance, and the respective academic program as confirmation that the student enrollment status has been updated. Contact Person Responsible for Corrective Action: Raquel Munoz, Registrar Anticipated Completion Date: Current Workflow in Place Office of Financial Aid Upon notification from the Office of the Registrar, The Office of Financial Aid will review the student’s record to determine whether a Return of Title IV (R2T4) calculation is required. If applicable, the Office of Financial Aid will complete the R2T4 calculation and process the return of Title IV funds within the required federal timeframe in accordance with 34 CFR 668.22, ensuring that funds are returned no later than 45 days from the date the institution determines the student withdrew. The Office of Financial Aid maintains an internal tracking process to monitor students who withdraw and to ensure timely completion of R2T4 calculations and reporting requirements. We remain committed to this process and will continue to provide ongoing training throughout the year to ensure compliance and to keep academic departments informed of the procedures. Contact Person Responsible for Corrective Action: Henry Espinoza, Director of Financial Aid Anticipated Completion Date: Current Workflow in Place

The University experienced a mid-year leadership transition in the Registrar’s Office when the prior Registrar resigned, requiring a search for a new Registrar. At the time of the transition, the former Registrar was responsible for both routine office operations and oversight of enrollment reporting to the National Clearinghouse and NSLDS. During this period, incorrect data entries occurred. Corrective action has been initiated under the leadership of the newly appointed Registrar, who is conducting a comprehensive review of existing processes and internal controls within the office. This review includes evaluating data entry procedures and oversight practices to ensure greater accuracy and consistency. In addition, as part of the integration with Sentara College of Allied Health, the University is adding staff positions in both the Registrar’s Office and Financial Aid. The new staff members will allow for improved systems and process oversight and reduce operational strain on the Registrar’s Office. These corrective actions and staffing enhancements are expected to strengthen internal controls and prevent similar issues in the future.

Federal Pell Grant Program; Federal Stafford Loans Program; Federal Parents’ Loans Program for Undergraduate Students; Federal Graduated Plus Loan – Assistance Listing No. 84.063; 84.268 Recommendation: We recommend the University evaluate its procedures for sending enrollment information to the NSLDS, especially around graduated enrollment information. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University has updated its policies and procedures for NSLDS submissions via their third-party servicer to ensure relevant information is being captured and reported timely in accordance with applicable regulations. Name(s) of the contact person(s) responsible for corrective action: Kamla Singh-Ramoutar, University Registrar, (201) 761-6051 Planned completion date for corrective action plan: Completed

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