Corrective Action Plans

2025-011 SPECIAL TESTS AND PROVISIONS: GRAMM-LEACH-BLILEY ACT SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE, OTHER MATTERS WEST VIRGINIA STATE UNIVERSITY (WVSU) Assistance Listing Numbers: 84.003/84.007/84.038/84.063/84.268/84.379 WVSU has begun the process of developing a written cybersecurity policy. However, due to the recently fluctuating landscape of cybersecurity, security needs involved, and the number of staff available for the task, WVSU has not yet completed, nor approved any policy beyond the preliminary stages. WVSU is committed to having a written cyber security policy by the end of 2025-2026 which will have been approved by WVSU administration. Further delaying the process was a change in CFO during FY 2026.

2025-012 SPECIAL TESTS AND PROVISIONS: NSLDS REPORTING WEST VIRGINIA UNIVERSITY (WVU), WEST VIRGINIA SCHOOL OF OSTEOPATHIC MEDICINE (WVSOM), SOUTHERN WEST VIRGINIA COMMUNITY AND TECHNICAL COLLEGE (SWVCTC) Assistance Listing Numbers: 84.063/84.268 West Virginia University (WVU) response: The Office of the University Registrar (OUR) will create an “enrollment effective date validation” step in our comparison process. OUR will take the NSC submission file generated by WVU Information Technology Services (ITS) and compare the program effective date and campus enrollment effective date for each student to ensure the dates match. Any dates that do not match will be documented or corrected. West Virginia School of Osteopathic Medicine (WVSOM) response: As of December 2025, WVSOM updated the program enrollment date within the graduation spreadsheet processed out of the Banner system. Going forward, WVSOM registrar will create a calendar reminder to confirm program enrollment on the spreadsheet. The reminder function will be used to ensure this step is not missed in the future. WVSOM registrar will check the report diligently for accuracy. Southern West Virginia Community and Technical College (SWVCTC) response: SWVCTC is consulting with the Clearinghouse to better understand and identify any data elements of concern. SWVCTC is working to resubmit enrollment files and will review each file to ensure the data and processes are correct. An internal review by the CIO and Registrar will be done on each submission for a period of at least six months or until all parties are satisfied with the submissions.

2025-010 CASH MANAGEMENT GLENVILLE STATE UNIVERSITY (GSU), SOUTHERN WEST VIRGINIA COMMUNTY AND TECHNICAL COLLEGE (SWVCTC) Assistance Listing Numbers: 84.063/84.268 Glenville State University (GSU) Response: As of December 2024, the Glenville State University (GSU) Financial Aid Office, in conjunction with the GSU Business and Finance Office, has implemented policies and procedures to perform, at a minimum, monthly Pell Grant and Direct Loan reconciliations, with the appropriate signoffs. The GSU Financial Aid Office reviews and reconciles all Pell Grant and Direct Loan disbursement records at least monthly by comparing Banner records to Common Origination and Disbursement (COD) records. If any do not match, the GSU Financial Aid Office notes this within their documentation and resolves these discrepancies in a timely manner. They are reconciled by the GSU Financial Aid Office, signed off by the reconciling staff member, as well as the Financial Aid Director. Further, the GSU Business and Finance Office Accountant and GSU Financial Controller review and sign-off the reconciled data. The final copy is kept within the GSU Financial Aid Office. 78 Southern West Virginia Community and Technical College (SWVCTC) Response: A Monthly Reconciliation Cover Sheet has been developed. The Financial Aid Counselor will complete the monthly and annual reconciliation for each fund (e.g., Pell Grant, Student Loans). The cover sheet will document the month reconciled, the fund being reconciled, the amount disbursed in Banner, the amount disbursed through COD, any discrepancies with explanations, and the preparer’s signature. The applicable SAS Reconciliation for each fund will be attached to the cover sheet. Upon completion, the reconciliation and cover sheet will be reviewed and approved by the Director of Student Financial Assistance.

The University acknowledges the Pell Grant under award identified during the audit. University officials have developed the following corrective actions to ensure correct calculation of Pell Grant awards in accordance with 34 CFR §690.75. To correct the underlying problem, Financial Aid staff will work directly with Power FAIDS support to identify the specific cause(s) of the miscalculation of Pell Grant awarding. The University will also enhance staff competency through targeted training on the Pell Grant calculation methodology. All training activities will be documented and maintained in office records as part of the University’s compliance documentation. Additionally, the University will develop and revise internal policies and procedures related to Pell Grants to ensure consistency, accuracy, and adherence to federal regulations. These updated procedures will guide staff in the correct application of Pell rules and system processes. Further, to ensure ongoing compliance, the University will implement monitoring and quality‑assurance measures. These measures will include the conduct of monthly internal audits by an internal reviewer within Financial Aid to ensure Pell award accuracy. Monitoring results will be reviewed by the Director of Financial Aid and reported to the Vice President for Enrollment Management for oversight and accountability. Finally, these officials will ensure that the financial aid software used by the University is properly configured and maintained to address and prevent future awarding issues.

Finding number: 2025-001 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster AL #: 84.063 and 84.268 Award year: 2025 Corrective Action Plan: This issue was the result of human error, as established procedures were not followed in which a student withdrawal was not forwarded to the Registrar’s Office, preventing timely reporting to NSLDS. The student’s official withdrawal request was not transmitted by the office responsible for approving student leaves and withdrawals to the Registrar’s Office for processing, resulting in the absence of the required enrollment update in the student information system. In response, the Registrar’s Office has implemented a revised procedure for the handling of late leave requests and will coordinate directly with the Financial Aid Office to ensure accurate updates to the NSLDS. Staff in the Advising Office have been retrained on proper transmission protocols, and both the Registrar’s Office and Advising Office have instituted additional quality control and tracking measures to ensure that all leaves and withdrawals are processed and reported in a timely and compliant manner. Timeline for Implementation of Corrective Action Plan: The corrective action plan was implemented as of October 2025. Contact Person Megan Miller, University Registrar

Common Origination and Disbursement (COD) Reporting Recommendation: We recommend the College evaluate its policies and procedures around reporting to the COD to ensure that information is reported accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to the finding: A PELL reconciliation report will be pulled monthly to check that the disbursement dates/amounts on COD match the disbursement dates/amounts on PowerFAIDS and Bionic. Name of the contact person responsible for corrective action: Shannon Braccili, Associate Director of Financial Aid Planned completion date for corrective action plan: Effective starting August 2025 with the first Fall 2025 PELL disbursement and continuing through the end of the academic year. This procedure will continue to be followed in subsequent academic years.

U.S. Department of Education National Student Loan Data Systems (NSLDS) Enrollment Reporting - Federal Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend the College review its policies and procedures on reporting of enrollment status changes to NSLDS to ensure that all status changes are being reported accurately 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: An investigation that uncovered a National Student Clearinghouse enrollment transmission proofing error related to program-level effective date for graduated students. Name of the contact person responsible for corrective action: James Keane, Registrar Planned Corrective Action Plan: The Registrar's Office will ensure that the program level effective date for graduates is accurate prior to submission. The Registrar will also partner with IITS to ensure that the program-level effective date for graduates is generated in the submission file as expected. Planned completion date for corrective action plan: May 2026, prior to the June 2026 submission date.

Recommendation: The University should review its policies and procedures on determining student's withdrawals and timely communication among departments to ensure timely returns of Title IV funds. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University automated the process of communicating withdrawals between departments a few years ago. Unfortunately, an individual responsible for communicating withdrawals failed to use the system in that instance. When the delay in process was discovered, the offices of Student Support, Registrar, Financial Aid, and Bursar met to review communication and documentation processes. Meetings occurred in Summer 2025 to implement a cohesive process. The corrective action is that dismissals related to student conduct follow the same agreed upon process that hiatus and withdrawal follow. The responsible individual no longer works at the University, and their replacement will be fully trained and using the system in place. Name(s) of the contact person(s) responsible for corrective action: Andrew Moyer Planned completion date for corrective action plan: March 31, 2026

The College agrees with the finding. While many GLBA-required safeguards are operationally in place, documentation and a formal enterprise risk assessment have not been fully completed. The College will engage a qualified third party to perform a comprehensive GLBA-aligned risk assessment using a recognized framework such as NIST. Based on the results, the College will document identified risks, existing safeguards, and remediation plans. Additionally, the College will formalize and update its Written Information Security Program, including policies addressing vendor management, user access controls, data transmission and destruction, change management, and data inventory. Policies will be reviewed and approved through the College’s governance process. Responsible Party: Kyle Brown, Executive Director of Technology, Jamestown Community College, kylebrown@sunyjcc.edu, 716.338.1118 Anticipated Completion Date: August 31, 2026

Recommendation: We recommend the District review its reporting procedures to ensure that enrollment and program information is accurately reported to NSLDS as required by regulations. Action taken in response to finding: During the 2024-2025 audit, two enrollment records were reported late to NSLDS in October 2024. The late reporting occurred prior to the implementation of the corrective action plan developed during the 2023–2024 audit period. The previously identified cause was timing gaps between Clearinghouse file submission and NSLDS processing. Corrective Action Taken: The corrective action plan from the 2023–2024 audit period was fully implemented as of Spring 2025 and has addressed the root cause of the late reporting. Actions implemented include: • Reviewed and documented enrollment reporting timelines from Clearinghouse submission through NSLDS posting. • Established consistent file submission schedules aligned with NSLDS reporting deadlines. • Formalized communication and escalation procedures with the Clearinghouse and NSLDS, including designated points of contact. • Updated internal policies and procedures to reflect revised reporting timelines. • Provided training to staff responsible for enrollment reporting, emphasizing timeliness and compliance requirements. • Implemented monitoring controls to track file submission, acceptance, and processing by NSLDS. The 2023-2024 audit corrective action plan was successfully implemented in Spring 2025. Since implementation, no additional late enrollment reporting instances have occurred. Moving forward, it is expected that enrollment reporting to NSLDS will be timely and compliant with federal requirements, supported by documented procedures and ongoing monitoring controls. Name of the contact person responsible for corrective action: Dr. Kristina Martinez, Acting Dean of Enrollment Services Planned completion date for corrective action plan: June 30, 2026

Recommendation: We recommend the District continue to enhance and consistently apply R2T4 procedures by providing ongoing training to staff responsible for R2T4 calculations and by continuing with additional reviews and quality control measures to ensure accuracy and compliance. Action taken in response to finding: The District acknowledges the importance of compliance with Return to Title IV (R2T4) requirements. The repeat finding cited in the subsequent audit relates to files processed prior to implementation of the corrective action plan. Since implementation, the District has not identified any new R2T4 errors or compliance issues. Action taken in response to finding: 1. Prior-Year File Remediation • Recalculated R2T4 amounts for affected students. • Returned required funds to the U.S. Department of Education. 2. Oversight and Review Controls • Engaged a NASFAA-certified consultant to review all R2T4 calculations during the 2024–2025 aid year. • Implemented secondary internal review of all R2T4 calculations. 3. Training and Staffing Enhancements • Completed department-wide and R2T4-specific training. • R2T4 staff completed NASFAA R2T4 course series. • An additional Accounting Officer position was added to support R2T4 processing and reconciliation with appropriate system access. 4. Process Improvements • Transitioned to the Department of Education’s R2T4 worksheet in COD. • Established formal coordination with Academic Affairs and the Registrar. • Updated R2T4 training and job aids. 5. Ongoing Monitoring • Management performs periodic internal reviews of R2T4 files. • The District continues to evaluate system and reporting enhancements. Conclusion Although the audit included R2T4 files processed prior to corrective action implementation, the District’s actions have been effective. No new R2T4 issues have been identified since implementation, and controls are in place to ensure ongoing compliance. Name of the contact person responsible for corrective action: David Brown, Acting Director of Financial Aid & Basic Needs Planned completion date for corrective action plan: June 30, 2026

Finding Number 2025-001. Enrollment Reporting - The College hired a full-time Registrar in December 2025. Upon onboarding, the Registrar will collaborate with the College’s third-party consultant(s) to conduct a comprehensive review and re-evaluation of the enrollment reporting configuration and associated business processes. This review will ensure alignment with federal reporting requirements and institutional best practices. During this review period, the Registrar and the Financial Aid Office will jointly implement ongoing monitoring procedures to ensure that all students are accurately captured and that enrollment statuses are correctly and timely reported to the National Student Loan Data System (NSLDS). These monitoring controls will remain in place until the enrollment reporting system and processes are fully vetted and validated for compliance. Anticipated Completion Date - February 28, 2026. Responsible Contact Person for Planned Corrective Action: Dominique Colyer, Director of Financial Aid

The Office of Financial Aid has implemented a formal annual review process to determine whether Golden Gate University should request a waiver of the Federal Work-Study (FWS) expenditure requirement for the upcoming waiver period. Each February, the Associate Director of Financial Aid and the Senior Director of Student Financial Services will evaluate projected spending and decide if a waiver is necessary. If a waiver is required, it will be submitted within the designated deadline, which typically falls between March and April each year.

Audit Finding 2025-002 Special Tests and Provisions Enrollment Reporting: Significant Deficiency in Internal Control over Compliance Timely Reporting Errors:  The University was still reporting students from the School of Business and Society and the School of Education under a different branch code (001322-80) in its third-party provider (National Student Clearinghouse), even though that branch code did not exist in the National Student Loan Data System (NSLDS). This was an artifact of a previous academic structure and calendar. With the help of the provider, this branch has been consolidated with the main branch (001322-00) and all programs on the same calendar are now reported simultaneously helping to ensure that all students are recorded.  Upon acceptance of the submitted files to NSLDS, the Registrar’s Office will compare the roster in NSLDS to that of the submitted roster and the current census roster to identify and correct discrepancies either in the student information system or NSLDS. Availability of these types of reports in NSLDS is still being determined. Contact Person Responsible for Corrective Action: Eric Maczka, University Registrar and Director of Institutional Research, eric_maczka@redlands.edu, 909-748-8333 Anticipated Completion Date: March 15, 2026

Audit Finding 2025-001 Special Tests and Provisions Return of Title IV Funding (R2T4): Significant Deficiency in Internal Control over Compliance Student Financial Services has strengthened the current R2T4 calendar set up and calculation review process. An additional administrator in SFS reviews each calendar created in COD to specifically check and document the total number of days in the payment period including scheduled breaks. In addition, University calendars have now been approved for several years in advance so this will prevent late date changes. At the time this student was identified, all students in this program were reviewed for R2T4s and it was confirmed that this is the only student in the program who withdrew and required an R2T4 calculation. The R2T4 was reprocessed with the corrected number of days. The student was contacted about the error in the calculation and informed of their eligibility for an additional $71 in Direct Loan. The student chose not to increase their loan by the additional $71 so no adjustments were made to the student record or to COD. Contact person responsible for Corrective Action: Alisha Aguilar, Associate Vice President of Student Financial Services and Military & Veteran Services alisha_aguilar@redlands.edu, 909-748-8047 Anticipated Completion Date: January 1, 2026

2025-001 – U.S. Department of Education, SFA Cluster, Special Tests and Provisions - Incorrect Return of Title IV (R2T4) Calculations (Significant Deficiency). Condition: From a population of 17 students that officially or unofficially withdrew during the term, we tested four students. All four students required Return of Title IV (R2T4) refund calculations. During our review, we noted that the University excluded only five days from the total number of days in the semester for the Fall 2024 and Spring 2025 breaks. However, each break period included five weekdays plus the surrounding weekend days, resulting in a total of nine days that should have been excluded. The University did not exclude the four weekend days adjacent to the breaks, leading to incorrect total day counts in the R2T4 calculations. Criteria: Under 34 CFR §668.22(f)(2)(i), the total number of calendar days in a payment period includes all days within the period that a student was scheduled to complete, except scheduled breaks of at least five consecutive days, which must be excluded from both the total number of days and the number of days completed. When classes end on a Friday and resume the following Monday after a week‑long break, both weekends (four days) and the five weekdays of the break are excluded from the R2T4 calculation, for a total exclusion of nine days. Cause: Controls to ensure proper calculation of Title IV refunds did not function as related to the condition above. Effect: R2T4 calculations for the students tested who withdrew during the Fall 2024 and Spring 2025 terms were incorrect. As a result, funds were returned in incorrect amounts to both the students and the U.S. Department of Education. Repeat Finding: No. Recommendation: We recommend the University implement and document enhanced procedures to ensure the accurate preparation and review of all Title IV refund calculations, including verification of the correct number of days excluded for scheduled breaks. View of Responsible Officials: The University acknowledges the condition identified. For the Fall 2024 and Spring 2025 terms, the R2T4 calculations excluded only the five instructional weekdays associated with each break and did not exclude the adjacent weekend days. As a result the total number of days in the payment period was overstated, which affected the R2T4 calculations for the students tested. Corrective Action: The University has reviewed the applicable regulatory requirements under 34 CFR§668.22(f)(2)(i) and confirmed that when a scheduled break consists of at least five consecutive days, all calendar days within the break period-including the surrounding weekends when classes end on a Friday and resume the following Monday-must be excluded from the R2T4 calculation. The University has: 1) Recalculated the affected R2T4 determinations for the students identified to ensure the correct number of days is excluded, 2) Returned or recovered any resulting differences in funds, as required, to or from the U.S. Department of Education and the affected students, 3) Updated internal R2T4 calculation procedures and reference materials to explicitly require exclusion of both weekdays and associated weekend days for qualifying scheduled breaks, and 4) Provided additional training to staff responsible for R2T4 calculations to reinforce regulatory requirements and prevent recurrence. Status: Corrective actions have been applied, and revised controls implemented for all future R2T4 calculations to ensure compliance with federal regulations. If the Federal Audit Clearinghouse has questions regarding this plan, please call Amy Brown, Director of Financial Aid at 704-463-3015.

Condition: During testing of the enrollment reporting, we identified the following errors: 􀁸 The change in status was not reported at the program level. 􀁸 The program begin date reported to NSLDS does not match the program begin date per the college’s records. Recommendation: The College should evaluate their procedures and policies related to reporting status changes and program begin dates to NSLDS and enhance as deemed necessary to ensure that accurate information is reported to NSLDS. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We have researched the issue and found that it goes back to the June 2022 purging of the archive file within our student information system in order to get the NSC reports to pull from the system. We no longer purge the archive file, so these issues will only happen on some older records where students return to the college. Name(s) of the contact person(s) responsible for corrective action: Katrina Dumont, Institutional Effectiveness Planned completion date for corrective action plan: We will monitor the Spring 2026 NSC enrollment files to make sure the issue is not getting worse.

Condition: The College did not report certain Pell disbursements within 15 days to COD. Recommendation: We recommend the College ensure that a process is in place to report within 15 days, including a process to respond and report timely when there are student irregularities. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. While we agree with the audit finding, we are not clear as to why the date was recorded by COD outside the disbursement window. Action taken in response to finding: We will maintain automated COD reporting through the Student Information System (SIS) and continuously refine processes based on audit results and regulatory changes. Name(s) of the contact person(s) responsible for corrective action: John Gay Jr. Planned completion date for corrective action plan: Fall 2025

The University will review and update its internal procedures and controls for handling credit balances to ensure that future Title IV credit balances are disbursed to students within the 14 day window.

Finding Number: 2025-003 Federal Assistance Listing Number: 84.007 Federal Supplemental Educational Opportunity Grant, 84.033 Federal Work-Study Program, 84.038 Federal Perkins Loan Program Year Ended: June 30, 2025 Responsible Individual: Steven Dwire, Director of Financial Aid Management’s Response and Corrective Action Plan: Management identified the issue on October 3, 2025 and made the FISAP submission immediately and filed the signature page on October 15, 2025. The issue resulted from staff turnover during the year. Upon discovery, management promptly updated procedures, including adding calendar reminders to avoid such missed occurrences going forward. Additionally, the College has submitted a waiver request with the Department of Education to avoid the return of $441,023 in campus-based aid and to obtain eligibility to receive campus-based aid for the 2026-2027 school year. As of the date of the report, a response to the waiver request from the Department of Education has not been received.

Finding Number: 2025-002 Federal Assistance Listing Number: 84.268 Federal Direct Student Loans Year Ended: June 30, 2025 Responsible Individual: Steven Dwire Director of Financial Aid Management’s Response and Corrective Action Plan: Management identified the issue on September 23, 2025 and exit counseling packages were sent on October 1, 2025. The issue resulted from staff turnover during the year. Upon discovery, management promptly updated procedures, including adding calendar reminders to avoid such missed occurrences going forward.

Finding Number: 2025-001 Federal Assistance Listing Number: 84.268 Federal Direct Student Loans Year Ended: June 30, 2025 Responsible Individual: Christine Banewicz Director of Student Accounts Management’s Response and Corrective Action Plan: Management identified the issue on August 4, 2025 and new letters were emailed on August 8, 2025 and August 12, 2025. To mitigate potential disruptions in the electronic process, the College enhanced its controls to include manual validation of letters.

Corrective Action: The College will implement a revised withdrawal process that shifts outreach and financial aid counseling to occur before a student completes and submits the withdrawal form, rather than after submission. This change is designed to eliminate delays in withdrawal processing and support timely institutional action. Under the current process, outreach to students occurred after the withdrawal form was submitted, which resulted in delays in routing the form to the Records Office for processing. The revised process will require that outreach and financial aid counseling occur before students complete the withdrawal form. Students who indicate they are receiving financial aid will be encouraged to consult with the Financial Aid Office prior to completing the withdrawal form. During this consultation, students will be informed of the financial implications of withdrawing and be made aware of available institutional resources and services that may assist them in remaining enrolled, when appropriate. The revised withdrawal form will allow students to complete and submit it online directly to the Records Office for immediate processing. Eliminating post-submission outreach requirements will remove prior delays and allow the Records Office to promptly process the withdrawal. Receipt of the completed withdrawal form will serve as the institution’s date of determination. Following submission, the Financial Aid Office will complete the Return to Title IV (R2T4) calculation within the required 45-day timeframe and return any required funds. Timely processing of withdrawals will ensure continued compliance with all R2T4 regulatory requirements. Anticipated Completion Date: The College will implement this revised withdrawal process immediately (March 2026). Responsible Party: Breshawn Skinner, Director of Financial Aid, in coordination with the Records Office

Credit Balance Testing Recommendation: CLA recommends that the client re-evaluate their internal controls over credit balance returns in order to establish a more timely process for the identification and disbursement of TIV credit balances. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: Carthage College will update procedures to maintain documentation of student authorizations for credit balances held greater than 14 days. Name(s) of the contact person(s) responsible for corrective action: Vince Ceja, CFO Planned completion date for corrective action plan: June 30, 2026

Name of Responsible Individual: Ransom Prestridge, Registrar; Jennifer Wegman, Assistant Registrar; Kai Howard, Institutional Research; Shane Himes, Director of Financial Aid Corrective Action: The College acknowledges the findings related to the timeliness and accuracy of enrollment reporting to the National Student Loan Data System (NSLDS). The identified exceptions were the result of insufficient administrative oversight and internal controls related to enrollment status reporting at both the campus and program levels. As this is a repeat finding, the College is committed to implementing enhanced and sustainable corrective measures. To address this finding, the College will strengthen internal controls and oversight of enrollment reporting by implementing the following corrective actions: • Establish a documented review and monitoring process to ensure all enrollment status changes, including graduation, withdrawal, attendance level changes, and second majors, are accurately and timely reported to NSLDS at both the campus and program levels. • Implement a standardized tracking and reconciliation process between the Registrar’s Office, the Student Information System, and NSLDS to ensure data consistency and completeness. • Develop and implement written policies and procedures that clearly define roles, responsibilities, timelines, and escalation protocols for enrollment reporting. • Enhance oversight of any third-party servicer, including periodic validation of submitted records to ensure accuracy and timeliness. • Provide comprehensive training to staff responsible for enrollment reporting on federal regulatory requirements and institutional procedures. • Conduct periodic internal quality assurance reviews and monitoring of enrollment reporting to identify and correct discrepancies in a timely manner. • Establish formal communication protocols between the Financial Aid and Registrar’s Offices to ensure timely notification of all enrollment changes. Anticipated Completion Date: May 31, 2026