Corrective Action Plans

Name of Responsible Individual: Shane Himes, Director of Financial Aid Corrective Action: The College acknowledges the exceptions identified related to the timeliness of Return of Title IV (R2T4) calculations and the return of unearned federal funds. The errors were the result of insufficient administrative oversight and internal controls over the withdrawal and R2T4 process. To address this finding, the College will strengthen internal controls and oversight to ensure compliance with federal regulations. The corrective actions include: • Implementing a documented secondary review process for all R2T4 calculations prior to finalization to ensure accuracy and compliance with regulatory requirements. • Enhancing procedures to ensure timely identification of withdrawn students and prompt initiation of the R2T4 calculation process. • Establishing standardized monitoring to ensure all required returns of Title IV funds are processed within the regulatory timeframe. • Developing and implementing a tracking system to monitor withdrawal dates, calculation completion, and return deadlines. • Providing additional training to Financial Aid staff on federal R2T4 regulations and institutional procedures. • Conducting periodic internal quality assurance reviews of R2T4 calculations and returned funds to ensure ongoing compliance. Anticipated Completion Date: May 31, 2026

Name of Responsible Individual: Larry Bomback, Interim CFO / DeMornai Blackwell, Controller Corrective Action: Management acknowledges the instances in which Title IV credit balances were not refunded within the required regulatory timeframe under 34 CFR §668.164(c). Although no questioned costs were identified, the College recognizes the need to strengthen internal controls to ensure full compliance. To address this finding, the College will: • Implement a formal Title IV credit balance monitoring procedure requiring weekly review of student accounts with credit balances • Establish an automated report identifying all Title IV–generated credit balances and tracking the 14-day refund deadline • Strengthen coordination between the Business Office, Financial Aid Office, and Registrar to ensure enrollment status and disbursement timing are properly reflected prior to refund processing • Continued documented supervisory review of credit balance aging reports These corrective measures are designed to ensure timely refunds, improve monitoring controls, and maintain compliance with federal Title IV requirements. Anticipated Completion Date: May 31, 2026

Name of Responsible Individual: Shane Himes, Director of Financial Aid Corrective Action: The College acknowledges the reporting errors identified in certain student origination records submitted to the Common Origination and Disbursement (COD) System, specifically related to cost of attendance and academic end date data elements. To address this finding, the College will enhance internal controls and oversight over federal aid reporting by implementing the following corrective actions: • Establish a documented secondary review process for all origination records prior to submission to COD, with verification of key data elements including cost of attendance, academic start and end dates, enrollment status, and award amounts. • Implement a standardized review checklist to ensure accuracy and completeness of required data fields. • Strengthen reconciliation procedures between the student information system and COD to identify and resolve discrepancies timely. • Conduct periodic internal quality assurance reviews of origination and disbursement records. • Provide additional staff training on federal reporting requirements. Anticipated Completion Date: This process has already been implemented.

Name of Responsible Individual: Larry Bomback, Interim CFO ; Justin Roy, VP of Enrollment ; Irene Langran, VP of Academic Affairs Corrective Action: Management acknowledges the instance in which Title IV funds were held beyond the allowable timeframe under 34 CFR §668.166. Although the amount was within allowable tolerance thresholds and no questioned costs were identified, the College recognizes the need to strengthen internal controls over cash management compliance. To address this finding, the College will: • Implement a formal Title IV drawdown and disbursement monitoring procedure requiring review no later than the third business day following receipt of funds • Establish a standardized reconciliation process between the Business Office, Financial Aid Office, and Registrar to ensure timely identification of: o Students who have withdrawn o Enrollment status changes o Required returns of Title IV (R2T4) calculations • Develop a documented weekly reconciliation of federal drawdowns to disbursements and student account activity • Assign clear responsibility for monitoring excess cash thresholds and ensuring timely return of funds to the U.S. Department of Education when required • Provide cross-functional training to reinforce compliance requirements under federal cash management regulations These measures are intended to ensure timely disbursement of Title IV funds, proper reconciliation of enrollment changes, and full compliance with federal cash management requirements. Anticipated Completion Date: May 31, 2026

Management’s Response: The University has undertaken several initiatives to enhance compliance and accuracy: Management acknowledges the material weakness related to the awarding and disbursement of TEACH Grants and recognizes the importance of ensuring that grant eligibility is verified in accordance with federal regulations prior to disbursement. During fiscal year 2025, an eligibility determination error was identified for one student. Subsequent to year-end, the University returned the related TEACH Grant funds to the U.S. Department of Education through the G5 system. Management has taken corrective actions to strengthen eligibility verification and prevent recurrence. Corrective actions implemented include: • Strengthened Leadership and Oversight: A new Financial Aid Director was hired in March 2025 and has prioritized the development and enforcement of appropriate controls over TEACH Grant awarding and disbursement. • Revised Policies and Procedures: TEACH Grant awarding and disbursement procedures were reviewed and updated to ensure alignment with federal eligibility requirements. • Improved Eligibility Documentation: The TEACH Grant application was enhanced to clearly document all required eligibility criteria and support consistent eligibility determinations. • Secondary Review Controls: A secondary review and approval process has been implemented to ensure that TEACH Grant eligibility is independently verified prior to awarding and disbursement. • Enhanced Tracking and Monitoring: Additional tracking mechanisms were implemented to confirm that eligibility requirements are met and documented before funds are applied to student accounts. • Ongoing Compliance Monitoring: The Financial Aid Office continues to monitor TEACH Grant activity to ensure continued compliance with program requirements. Management believes these actions have significantly strengthened internal controls over TEACH Grant awarding and disbursement. Continued application of these procedures is expected to prevent recurrence and support full compliance in future audit periods. These initiatives demonstrate the University’s commitment to maintaining accurate student enrollment records and ensuring compliance with federal regulations, thereby safeguarding the interests of its students and the institution.

Management’s Response: The University has undertaken several initiatives to enhance compliance and accuracy: Management acknowledges the material weakness related to enrollment reporting for the Federal Direct Student Loan Program and recognizes the importance of timely and accurate reporting to the National Student Loan Data System (NSLDS). During fiscal year 2025, the University experienced challenges related to enrollment reporting accuracy and timeliness. In response, management implemented significant corrective actions to strengthen accountability, improve cross-department coordination, and enhance monitoring controls. Key actions taken during and subsequent to fiscal year 2025 include: • Strengthened Leadership and Accountability: A new Financial Aid Director was hired in March 2025 and has prioritized the resolution of this repeat audit finding. Clear responsibility for enrollment reporting oversight has been established. • Improved Cross-Department Coordination: The Financial Aid Office now works closely with the Registrar’s Office and Information Technology to ensure alignment between institutional enrollment records and federal reporting systems. • System Configuration Review: Enrollment reporting processes and system configurations within the Colleague system were reviewed to ensure that student enrollment statuses and effective dates are captured and reported accurately. • Identification and Correction of Reporting Issues: Management identified discrepancies in enrollment reports generated by Colleague that resulted in inaccurate federal reporting for certain students. Corrective solutions have been identified and implemented to address these issues. Enhanced Monitoring and Review: The Financial Aid Director now performs regular reviews of all withdrawn and graduated students to verify consistency between Colleague, the National Student Clearinghouse, and NSLDS prior to and after submission. • Improved Timeliness of Corrections: Any discrepancies identified are promptly reviewed and corrected in coordination with the Registrar’s Office to ensure compliance with required reporting timeframes. • Policy and Training Enhancements: Policies and procedures related to enrollment reporting are being refined, and additional staff training has been implemented to reinforce compliance requirements and internal controls. Management believes these actions have materially improved the accuracy and timeliness of enrollment reporting. Continued monitoring and application of these controls are expected to result in sustained compliance and resolution of this finding in a future audit period. These initiatives demonstrate the University’s commitment to maintaining accurate student enrollment records and ensuring compliance with federal regulations, thereby safeguarding the interests of its students and the institution.

The University had one R2T4 finding that resulted from a unique situation. The Financial Aid Office will conduct a detailed review of the process and incorporate this specific circumstance into its internal audit procedures. By strengthening internal controls within the R2T4 process and enhancing internal audit protocols, the University will further improve overall compliance in this area and maintain its high standard of regulatory compliance.

The Financial Aid Office will continue to work closely with the Registrar's Office and Information Technology to resolve the NSLDS reporting discrepancies. Based on our preliminary review, the reporting inconsistencies appear to be related to changes in enrollment reporting processes and data feeds associated with the recent Student Information System (SIS) update, implemented in 2025. In partnership with the Registrar's Office, Information Technology, and the Office of Data Analytics (within Information Technology), the University will identify and correct the source of the repeated or inconsistent data submissions to the National Student Clearinghouse. Because enrollment reporting to the Clearinghouse directly impacts data reported to the National Student Loan Data System (NSLDS), resolving these data feed issues is a priority. Additionally, these departments will develop and implement enhanced internal controls to compare institutional enrollment records against NSLDS data to ensure accuracy and timeliness. One of these measures will include a monthly enrollment reporting audit to identify and correct discrepancies proactively. Updates may include but not be limited to timing and frequency of reporting, internal audits monthly during 2026, and expanding written documentation of the process and procedures. The University is committed to strengthening internal processes to ensure compliance with federal enrollment reporting requirements and to prevent recurrence of this issue.

While the District maintained the requisite supporting documentation, limitations arising from the internal record retention policies in place at the time, coupled with the retirement of key personnel, resulted in certain enrollment records not being readily locatable. The District acknowledges that these factors limited the availability of prior-year supporting data. This issue has since been addressed through updated retention practices to ensure that this does not occur going forward. Beginning with the next fiscal year cycle, the District has implemented a documented procedure that specifies the data sources, query parameters, and data pull dates; requires that all supporting extracts and calculations be retained in a centralized, version-controlled folder; and establishes a formal review and approval process to verify that enrollment and low-income counts reconcile to source documentation before submission to ADE. Staff in Federal Programs and Finance have been trained on the new procedure, and an annual internal review has been established to confirm compliance. The Director of Finance and the Director of Federal Programs are responsible for implementing and monitoring this corrective action, which will be completed prior to the next Title I eligibility submission.

Finding 2025-005 – Cash Management Contact Person: Cristen Alicea, Office of Financial Assistance Current status: Resolved Anticipated Completion Date: February 1, 2026 Condition: The University did not provide evidence that the School Account Statements (SAS) from ED were used to reconcile to the University’s financial and business records on a monthly basis during the year ended May 31, 2025. Identification of repeat finding: N/A Resolution: We maintain that we did reconcile to the School Account Statements, as evidenced by the reports that have been run against the SAS statements through the Banner job RLRDLRC. However, we did not maintain the individual monthly evidence of the mismatches identified on those reports, and their resolution. We are maintaining this evidence going forward.

Finding 2025-004 – Special Tests and Provisions – Disbursements to or on Behalf of Students Contact Person: Cristen Alicea, Office of Financial Assistance Ann Margaret Cervantes, Director of Business Office Current status: Resolved Anticipated Completion Date: Completed May 23, 2025 Condition: The University was unable to provide evidence that internal controls over the return of credit balances to students were performed. Additionally, student credit balances were not identified and refunded to students within 14 days after the credit balance occurred. Identification of repeat finding: N/A Resolution: Our Outlook email folders have a limit on storage, despite using non-server folders to extend storage space and length of time. During 2024-2025, these folders reached full capacity and we were unable to send or receive any emails. We were instructed to delete older emails to regain functionality, which unfortunately meant that some of the automated emails that we use for our audit processes had to be deleted. Our Information Technology department was able to provide an online archive folder for Outlook emails that does not fill up, get deleted, or cause us to run out of space. Therefore, all emails proving processing will be available for review during next year’s audit. Please note that this control was in place, and was followed, but we are unable to provide the actual email output. In addition to the automated credit balance reports from ARGOS, the Business Office runs internal reports twice weekly to identify and process any pending credit balances.

Finding 2025-003 – Special Tests and Provisions – Disbursements to or on Behalf of Students Contact Person: Cristen Alicea, Office of Financial Assistance Current status: Resolved Anticipated Completion Date: Completed May 23, 2025 Condition: The University was unable to provide evidence that internal controls were performed in relation to notifications of disbursements, including notification of the amount and type of Title IV funds students are expected to receive, and how and when those disbursements will be made (award letter), and when direct loans are being credited to a student’s account (direct loan notification). Identification of repeat finding: N/A Resolution: Our Outlook email folders have a limit on storage, despite using non-server folders to extend storage space and length of time. During 2024-2025, these folders reached full capacity and we were unable to send or receive any emails. We were instructed to delete older emails to regain functionality, which unfortunately meant that some of the automated emails that we use for our audit processes had to be deleted. Our Information Technology department was able to provide an online archive folder for Outlook emails that does not fill up, get deleted, or cause us to run out of space. Therefore, all emails proving processing will be available for review during next year’s audit. Please note that this control was in place, and was followed, but we are unable to provide the actual email output. There were no instances of non-compliance identified during this audit.

Finding 2025-002 – Special Tests and Provisions – Return of Title IV Funds Contact Person: Cristen Alicea, Office of Financial Assistance Current status: In-Progress Anticipated Completion Date: May 1, 2026 Condition: The University did not provide evidence of an effective review process to ensure the timely calculation and return of Title IV funds to ED. The University did not accurately calculate and return Title IV funds in a timely manner to ED, within 45 days after the date the institution determined that a student withdrew. Identification of repeat finding: Yes – 2024-002, 2023-002 Resolution: The Director of Financial Assistance performed a full review of all withdrawals during 2023-2024, and 2024-2025, to ensure calculations were complete, accurate, and funds returned as required. Documentation will be maintained for review by the auditors and the Department of Education to prove funds were returned correctly, even if not timely. The continuation of this issue was caused by the continued difficulty with recruiting and keeping financial assistance advisors, and the extraordinary disruption caused by the 2024-2025 FAFSA changes. We were unable to fully remediate our staffing issues during the 2024-2025 academic year. We brought on new staff which required extensive training. However, we are now able to spend more time focusing on compliance areas and will be able to fully implement our planned compliance controls during the 2025-2026 aid year. We will not have any returns unprocessed or made outside of 45 days after May 1, 2026. In addition to new staff and training, we will implement a secondary review process for all Return of Title IV transactions whereby an advisor will process the initial calculation and return, and then either the Assistant Director or Director of Financial Assistance will perform a secondary review which evaluates the date of the withdrawal, the date of determination, the eligible disbursed/non-disbursed aid amounts, the returned amounts, and confirms the returned amounts in Banner and COD. This internal review process will be performed upon 100% of Return of Title IV calculations each academic year.

Finding 2025-001 – Special Tests and Provisions – Enrollment Reporting Contact Person: Marisol M. Scheer, Registrar’s Office Cristen Alicea, Office of Financial Assistance Current status: In-progress Anticipated Completion Date: May 31, 2026 Condition: The University did not provide evidence of an effective review process to ensure accurate and timely reporting of student status changes to NSLDS. The University did not report program enrollment effective date or student status to the NSLDS for 1 of 60 students selected for testing. Identification of Repeat Finding: Yes – 2024-001, 2023-001, 2022-001, 2021-001, 2020-001, 2019-002 Resolution: We would again like to reiterate that even though this is considered a repeat finding for enrollment reporting, this particular issue is different than the previous findings. The Registrar's Office has implemented a control whereby a sample of students are reviewed after submission to the National Student Clearinghouse. This student did not appear as part of the sample and was unknown until the audit. We have reviewed all pertinent files for this student and can confirm that all student processing had no errors. In an improvement effort, the Registrar's Office will provide a sample to the Office of Financial Assistance to review for successful data processing. The Registrar's Office has begun researching why the student was not reported but have been able to confirm no procedural errors or delays with the student record that could have caused reporting issues.

Audit Firm: Sikich Audit Period: For the Year Ended May 31, 2025 Criteria: An institution must use the Return to Title IV refund calculation (34 CFR 668.22) A. Comments on Findings and Recommendations Finding 2025-001 Incorrect R2T4 Refund Calculation Condition: Sikich tested twelve drop students and found six incorrect refund calculations. The condition was caused by not including proper break days from the students' Return to Title IV calculations. B. Actions Taken or Planned Finding 2025-001 Incorrect R2T4 Refund Calculation The R2T4 calculation process has been updated to transition into using the built-in R2T4 calculator in the Jenzabar Financial aid software system. This is to ensure that the scheduled break periods are accounted for when calculating the percentage of payment period completed. We have since discountinued using the COD R2T4 calculator. Financial aid staff have been retrained to proper R2T4 procedures including the correct treatment of institutional break days. A secondary review process has been put in place to ensure accuracy of R2T4 calculations prior to submission and processing. Judson University has credited the appropriate amounts to all affected students to resolve the discrepancies identified in this finding. Sarah Taylor Vice President for Business Affairs

Finding 2025-001 Recommendation: It is recommended that management work closely with the NSC and the DoE to ensure that student statuses are reported timely. View of Responsible Officials and Planned Corrective Actions: The late receipt of the ECAR was out of the University’s control due to a known issue with the new system implemented by the DoE for the EApp (Eligibility Application), which created a delay in the updated branch code for Lancaster. Individual Responsible for Corrective Action: Deanna Daly, ddaly@sju.edu and Sarah Taylor, swilli01@sju.edu Anticipated Completion Date for Corrective Action: N/A – no further corrective action is needed from the University at this time.

Saint Mary’s University of Minnesota Corrective Action Plan For the Year Ended May 31, 2025 Finding 2025-003 - Cash Management Condition G5 Drawdown requests were not documented as reviewed and approved by a responsible party separate from the preparer. For 2 of the 7 G5 draws tested, there was no documentation of review or approval by someone other than the preparer. The sample was not a statistically valid sample. Corrective Action Plan Corrective Action Planned: A form will be created to support each G5 draw or refund. Requestor will fill out the form, providing details of the transaction. The form will be reviewed and signed off by the Controller or EVP of Finance. The person performing the transaction in G5 will sign, attached all the appropriate back-up and file in a designated area for future reference. Name(s) of Contact Person(s) Responsible for Corrective Action: Karen Stellpflug, Controller and David Ansell, Assistant Vice President for Finance Anticipated Completion Date: March 31, 2026

Saint Mary's University of Minnesota Corrective Action Plan For the Year Ended May 31, 2025 Finding 2025-001 Criteria: Title IV regulations (34 CFR 668.22) require the University to return the unearned portion of grants or loans to the Title IV program within 45 days after a student withdraws. Additionally, The U.S. Department of Education (ED) requires that an institution must ensure that its administrative procedures for the FSA programs include an adequate system of internal controls or checks and balances to ensure compliance with FSA laws and regulations including the return of Title IV funds. Condition/Context: The federal aid refunds for 1 out of 8 of the students tested was not calculated correctly and subsequently, not returned within 45 days from the withdrawal date. The sample was not statistically valid. Also, the auditor noted that the University did not have evidence or documentation available to support the control/review process for return of Title IV calculations. Cause: The University's review procedures for the return of Title IV funds were not followed and the system was not programmed to ensure the correct withdrawal date was used in the calculation of the return of Title IV funds. Effect: The University was in possession of funds belonging to the federal government longer than allowed and could have incorrect return of Title IV calculations and return incorrect amounts to students and/or the ED. Questioned Costs: Not applicable. Recommendation: The University should adhere to its procedures for refunding awards and implement a more formal documented review process/control to ensure refunds are calculated correctly and timely and any returns are made within the required timeframe. Management Response: The University agrees with this finding. The JFA R2T4 calculation incorrectly populated the wrong date used to perform the calculation, thus causing the error. The error was corrected and the director performs the R2T4 and is working to have a back-up employee trained. Staffing levels will have to be brought up to allow for new financial aid staff to complete this task. Corrective Action Plan Corrective Action Planned: To ensure accuracy, the withdrawal date generated in the JFA calculation will be cross-referenced against the J1 SIS record. Once verified, this date will be documented alongside the R2T4 calculation. This process guarantees that the student's period of attendance is calculated using the correct data. Name(s) of Contact Person(s) Responsible for Corrective Action: Holly Weberg, Director of Financial Aid and new hire designee. Anticipated Completion Date: The director is still fulfilling the R2T4 duties until a new hire candidate is hired and trained.

Saint Mary's University of Minnesota Corrective Action Plan For the Year Ended May 31, 2025 Finding 2025-002 Criteria: Title IV regulations (34 CFR 685.309(b)) require that upon receipt of an enrollment report from the Secretary, institutions must update all information included in the report and return the report to the Secretary: (i) in the manner and format prescribed by the Secretary; and (ii) within the timeframe prescribed by the Secretary. Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the institution discovers that: (i) a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or (ii) a student who is enrolled at the institution and who received a loan under Title IV of the Act has changed his or her permanent address. Condition/Context: The change in student status for 8 of 26 students tested was not reported to the National Student Loan Data System (NSLDS) within 30 days or included in a response to a roster file within 60 days. The student status for 1 of 26 students tested was reported as a withdrawal although the student was on a leave of absence. In addition, for 7 of 26 students tested, the University was unable to provide sufficient support for the status change. The sample was not statistically valid. Cause: The University’s procedures for reporting all students was not designed appropriately in order to allow for timely reporting to the NSLDS. Effect: The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by institutions. If an institution does not review, update and verify student enrollment statuses, effective dates of the enrollment status and the anticipated completion dates, then the Title IV student loan records will be inaccurate. Questioned Costs: Not applicable. Recommendation: The University should revise its procedures to ensure accurate enrollment information is sent to the NSLDS within the required timeframe. Management Response: The University agrees with this finding. The University has been actively taking measures with the new student information system, Jenzabar, and procedures have been standardized across the University. An audit will be preformed to discover the inefficiencies. Corrective Action Plan Corrective Action Planned: The Registrar Office will submit the names of students to the Audit Resource team at NSC so they can research why these students were not reported to NSLDS. As a result of their response, we will meet with the financial aid team to determine the next course of action to audit files. Any changes needed for NSC reporting will be implemented in May 2026 new submission. The University will also work with the system provider to rectify these discrepancies systematically to avoid further conflicts. Name(s) of Contact Person(s) Responsible for Corrective Action: Alison Block, Director of Academic Records and Systems and Holly Weberg, Director of Financial Aid. Anticipated Completion Date: Tentative completion date May 2026.

The University identified certain automated COD communication and reporting rules in the Student Information System (SIS) that were not functioning properly during the 2024-2025 aid year. The breakdown of these automated rules required manual interventions to have all Pell Grant disbursements and R2T4 adjustments reported to COD, in certain cases exceeding the 15-day requirement. The University has re-trained all financial aid staff to ensure the export process to COD is now completed after each R2T4 adjustment calculation. In addition, the financial aid office now has a dedicated employee running this process at minimum twice a week to ensure that all Pell records get successfully captured and reported to COD within the 15 day window.

Student Financial Aid Cluster – Assistance Listing Numbers 84.007, 84.033, 84.038, 84.063, and 84.268 Recommendation: We recommend the University review its reporting procedures to ensure that Key Line Items are reviewed and accurately reported to Department of Education as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: This finding resulted from inaccuracies introduced through enhancements made to a Workday-delivered report, which ultimately did not produce correct information. Going forward, we will review and validate the Workday report to ensure it aligns with Student Accounts’ reports and accurately reflects tuition and fees for the academic year. Name(s) of the contact person(s) responsible for corrective action: Jacob Witt, AVP of Financial Aid, 703-284-1532 Planned completion date for corrective action plan: June 2026 If the U.S. Department of Education have questions regarding this plan, please contact the individual(s) noted above.

Student Financial Aid Cluster – Assistance Listing Numbers 84.007, 84.033, 84.038, 84.063, and 84.268 Recommendation: We recommend the University review its return of Title IV fund procedures to ensure that calculations are performed with correct inputs as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: This finding was driven by incorrect MSMS program start and end dates configured in the University’s new Student Information System (Workday). When processing Return of Title IV (R2T4) calculations, Workday relies on the program start and end dates stored in the system. Due to these dates being incorrect, the R2T4 process calculated an inaccurate number of days enrolled, which resulted in an incorrect earned percentage of Title IV aid and, consequently, an incorrect amount of aid the student was eligible to retain. To address this issue, the University has implemented internal controls to review and verify the start and end dates of each academic year in Workday prior to the start of each semester. In addition, an internal control has been added to ensure the start and end dates of each academic year are reviewed and validated as part of the Return of Title IV processing. Name(s) of the contact person(s) responsible for corrective action: Jacob Witt, AVP of Financial Aid, 703-284-1532 Courtney Carey, University Registrar, 703-284-1523 Planned completion date for corrective action plan: Completed December 2025.

Student Financial Aid Cluster – Assistance Listing Numbers 84.007, 84.033, 84.038, 84.063, and 84.268 Recommendation: We recommend the University review its reporting procedures to ensure that enrollment and program information is accurately 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: The findings were primarily driven by the University’s transition to a new Student Information System (Workday), including the Workday-delivered National Student Clearinghouse (NSC) integrations. These constraints resulted in delays and gaps in enrollment reporting processes, increased processing timelines with the National Student Clearinghouse (NSC), and impacted the timely and accurate transmission of enrollment data to the National Student Loan Data System (NSLDS). In response, Marymount University has developed a formal Standard Operating Procedure (SOP) for National Student Clearinghouse reporting and has begun implementing these procedures during the 2025–2026 academic year. Name(s) of the contact person(s) responsible for corrective action: Courtney Carey, University Registrar, 703-284-1523 Jacob Witt, AVP of Financial Aid, 703-284-1532 Planned completion date for corrective action plan: Completed December 2025.

NSLDS Reporting Recommendation: We recommend the University review its reporting procedures to ensure that students’ statuses are accurately 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: During a typical reporting cycle, all students’ degree information is transmitted to the National Student Clearinghouse (NSC) through a standardized report generated by our Student Information System (Workday). In the instance identified, one student’s graduation status was still pending at the time we submitted degree records for all May 2025 graduates. Once the student’s status was finalized and the degree was officially conferred, we submitted the student’s information manually to the NSC. However, the degree conferral date was reported incorrectly; the actual conferral date was submitted instead of the last day of the student’s final term, which is the required standard. To prevent this issue from recurring, we will discontinue all manual degree submissions to the NSC. Going forward, we will rely exclusively on Workday-generated reports to ensure that all graduation dates are accurate, consistent, and aligned with institutional reporting standards. Name(s) of the contact person(s) responsible for corrective action: James Patton, Assistant Vice President for Academic Affairs and University Registrar Planned completion date for corrective action plan: This change in our data-reporting procedure has already been implemented. The updated process was in place for the most recent degree verification cycle, which was reported to the National Student Clearinghouse on 01-02-2026. If the U.S. Department of Education has questions regarding these plans, please call Dawn Durham at 864-294-2429.

Incorrect Pell Calculations Planned Corrective Action: Management acknowledges the error in calculation. As a result of change in student information software and financial aid software in conjunction with manual processes employed during transition of academic years, timing of review and misinterpretation of Summer Pell regulations, this error was not identified timely. This may have carried over to the subsequent term. Management receives this as opportunity to improve upon processes to ensure higher visibility and oversight to reduce any further risk making certain to align policies with DOE. Person Responsible for Corrective Action Plan: Kristina Elmore, Director of Financial Aid Anticipated Date of Completion: February 2026