Corrective Action Plans

2024-006 - Student Financial Aid Cluster - (a) Federal Supplemental Educational Opportunity Grants (b) Federal Work Study Program (c) Federal Pell Grant Program (d) Federal Direct Student Loans, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2024 Criteria: A school performs internal reconciliation when it compares business office records of funds requested, received, disbursed, and returned to financial aid office records of funds awarded to students. When the school compares its reconciled internal records to the Department’s records of funds received and returned, and of grants or loans originated and disbursed to students at the school, it is performing external reconciliation. A school ensures that the Department’s records reconcile with the school’s records, both at the cumulative and individual student levels, when it performs external reconciliation. (34 CFR 668.166) Condition: The College disbursed funds to students during the appropriate semesters in a timely manner, however, did not draw the federal direct funds down from the Department of Education until September 2024, outside of the award period for the disbursed award year of 2023-2024. We consider this finding an instance of noncompliance and is not a repeated finding. Statistical sampling was not used in making sample selections. Responsible Person: Director of Financial Aid and Veteran Affairs, Controller, Vice President of Financial Services Corrective Action Plan: Between the Census date and Pell disbursement date, the Director of Financial Aid & Veteran Affairs, Controller, and Vice President of Financial Services will verify the amount of Federal dollars to be drawn down using the U.S. Department of Education Common Origination & Disbursement webpage. The draw down will occur prior to the Pell disbursement date. Implementation Date: January/February 2026

2024-005 - Student Financial Aid Cluster - (a) Federal Supplemental Educational Opportunity Grants (b) Federal Work Study Program (c) Federal Pell Grant Program (d) Federal Direct Student Loans, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2024 Criteria: The College must establish and maintain the financial records that reflect each Title IV program transaction on a current basis (34 CFR 668.24). Condition: The College incorrectly reported tuition and fees on the Fiscal Operations Report and Application to Participate (FISAP) for the 2022-2023 academic year. We consider this to be an instance of noncompliance of the Reporting compliance requirement and is a repeated finding shown in Section IV of this report as prior year finding 2023-008. Statistical sampling was not used in making sample selections. Responsible Person: Director of Financial Aid and Veteran Affairs, Controller, Vice President of Financial Services Corrective Action Plan: The responsible parties listed above will thoroughly review all FISAP reporting requirements and necessary data points prior to FISAP submission to ensure accuracy. Implementation Date: Correction to FISAP will be submitted as soon as the amount of tuition and fess is confirmed by the Controller and/or Vice President of Financial Services. By September 2026 to accurately report the amount of tuition and fees on the upcoming FISAP reporting cycle due by the end of September 2026.

2024-004 - Student Financial Aid Cluster - (a) Federal Supplemental Educational Opportunity Grants (b) Federal Work Study Program (c) Federal Pell Grant Program (d) Federal Direct Student Loans, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2024. Criteria: 34 CFR 690.83 (b)(2) which states the institution shall submit “in accordance with deadline dates established by the Secretary, through publication in the Federal Register, other reports and information with Secretary requires and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct.” 34 CFR 685.309(b)(1-2) which states a school shall “upon receipt of a student status confirmation report from the Secretary, complete and return that report to the Secretary within 30 days of receipt; and unless it expects to submit its next student status confirmation report to the Secretary within the next 60 days, notify the Secretary within the next 60 days, notify the Secretary with 30 days if it discovers that a Direct Subsidized, Direct Unsubsidized, or Direct PLUS Loan has been made to or on behalf of student…” Condition: The College did not correctly report enrollment status changes for 15 out of 40 students tested (37.5%). We consider this condition to be a material weakness of the Special Tests and Provisions compliance requirement and is a repeated finding shown in Section IV of this report as prior year finding 2023-007. Statistical sampling was not used in making sampling selections. Responsible Person: Director of Financial Aid and Veteran Affairs, Director of Admission and Registration, and Administrative Information Systems (AIS) Corrective Action Plan: Richland Community College adjusted our internal procedures to send enrollment reporting files on a monthly basis instead of a semester basis during the Fall 2022 semester; however, issues still persist. At the time, the Registrar routinely worked with the Administrative Information Systems (AIS) Department and the National Student Clearinghouse to identify the issues related to enrollment reporting. The responsible parties listed above will conduct a review of current enrollment reporting workflows to ensure consistent and timely updates. The responsible parties listed above will explore improvements in automation through the utilization of the National Student Clearinghouse and a campus-wise transition to the Jenzabar One platform to assist with timeliness and accuracy of reporting. Jenzabar One transition is scheduled to be completed by the end of March 2026. Due to transition in staffing, the responsible parties listed above will provide targeted training on NSLDS enrollment reporting requirements, including the expectations of timeliness and accuracy. The responsible parties will develop a secondary review to identify missed or delayed updates and take corrective action promptly. Implementation Date: As soon as possible since enrollment reporting is completed on a monthly basis.

Finding No. 2024-002 Special Tests: Enrollment Reporting and Gramm-Leach-Bliley Act Compliance / Material Weakness in Internal Controls over Compliance Finding: Instances of noncompliance have been identified around major compliance requirements Enrollment Reporting and Gramm-Leach-Bliley Act, which are both part of special tests identified in the 2024 Compliance Supplement. Additionally, due to a transition in Registrar leadership and concurrent updates to Student Information System (SIS) configurations, a subset of students who had graduated and ceased attendance were incorrectly reported with a “Withdrawn” enrollment status. As part of the institution’s standard enrollment reporting process, student enrollment and graduation data are transmitted monthly from the SIS to the National Student Clearinghouse (NSC). NSC subsequently reports this information to the National Student Loan Data System (NSLDS). Under normal system operations, graduation data should be automatically included with the monthly enrollment transmission and used to determine the correct final enrollment status. However, following the SIS configuration update, the automated linkage between degree conferral data and enrollment status reporting did not function as intended. As a result, certain students with conferred degrees were systemically classified as “Withdrawn” rather than “Graduated” in the enrollment file submitted by the Registrar’s Office. Upon identification of the issue, the Registrar’s Office submitted a help desk ticket to the SIS Helpdesk to document the findings and initiate a technical review of the enrollment reporting configuration. Corrective Actions Taken: A formal help desk ticket was submitted to the SIS Helpdesk to investigate the enrollment status reporting discrepancy. SIS technicians reviewed enrollment reporting configurations and confirmed that graduation data was not being correctly incorporated into the monthly enrollment extract. The Registrar’s Office identified the affected student population and validated degree conferral information against official graduation records. Corrected enrollment statuses have been submitted. Corrective Actions Planned: Concurrently with Fall 2025, SUBSEQUENT OF TERM enrollment report, the Registrar’s Office will submit corrected enrollment records for any additional student to the National Student Clearinghouse (NSC) to ensure that accurate graduation information is transmitted to the National Student Loan Data System (NSLDS). (Due by 01/31/2026) Starting with Fall 2025 graduates, the Registrar’s office will manually update graduation statuses for all identified impacted students to ensure institutional records accurately reflect degree conferral prior to subsequent enrollment reporting cycles. Last, Enrollment reporting procedures will be updated to document revised controls, roles, and review steps, including specific checks related to graduation status accuracy following SIS configuration changes or staffing transitions. Additionally, related to the Gramm-Leach-Bliley Act requirements, IWP acknowledges the repeated finding and has taken immediate steps to ensure full compliance with the Gramm-Leach-Bliley Act requirements outlined in the 2024 Compliance Supplement. Specifically: - Formal Written Information Security Program: A comprehensive written policy is being finalized to address all seven required elements under 16 CFR 314.4(b), including risk assessment, safeguards, and oversight. - Annual Review Process: The CIO will review updates to the Student Financial Aid Cluster within the OMB Compliance Supplement annually to confirm continued compliance. - Policy Approval and Oversight: Once completed, the policy will be reviewed and approved by the EVP to ensure all required elements are included. - Implementation and Training: Staff training will be conducted to ensure awareness and adherence to the security program. - Monitoring and Updates: The Institute will monitor for any changes to federal requirements and update the policy accordingly. The written security program will be completed and implemented by the end of FY2026, with ongoing annual reviews thereafter. Responsibility for oversight rests with the CIO, with final approval by the EVP.

Department of Education Student Financial Aid Cluster – Special Tests and Provisions – NSLDS Recommendation: We recommend that the College continue to enhance its policies and procedures regarding enrollment reporting including additional monitoring over the third-party service provider to ensure that reporting is completed accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Office of the Registrar reports enrollment to NSLDS using the National Student Clearinghouse (NSC). The Office of the Registrar has added a Systems Analyst position, who is now responsible for Clearinghouse submissions, including enrollment reporting and monitoring and resolving errors. As recommended by CLA, the Registrar’s Office is reviewing its process for Clearinghouse submissions with support from our software provider Jenzabar, the National Student Clearinghouse, and the College’s Information Technology Department and Advising Office to ensure that enrollment reporting and error resolution is accurate and timely. Recommended changes to the enrollment reporting were adopted and added to the written procedures. Name(s) of the contact person(s) responsible for corrective action: Rachel Nielson (Registrar Systems Analyst), Nicholas Jobe (Registrar), and Sheia Pleasant (Financial Aid Director). Planned completion date for corrective action plan: Completed December 31, 2024

Planned corrective actions: As a response to concerns about disruptions in processes and the turnover of key staff in several departments, the Enrollment Alliance group that includes director-level staff in Admissions, the Registrar, Financial Aid, Advising, Bursar, and IT began meeting under the facilitation of the VP of Student Affairs on January 7, 2025. This group will continue to work on implementing the proper controls to ensure that the determination of student eligibility for Title IV aid is appropriate and has supporting documentation. Name of Responsible Party: 1. Nancy Benavides,Financial Aid Director 2. Corey Hodge, VP for Student Affairs 3. Joanne Fernandez, Controller 4. Marla Withers, Assistant Controller 5. Sagrario Armenta Jimenez, CFO 6. Dr. Christopher Gilmer, President Anticipated completion date: 6/30/2026

Planned corrective actions: A letter dated August 15,2024 from the Department of Education stated “the liquidation of Heritage University’s Federal Perkins Loan portfolio is complete.” Name of Responsible Party: 1. Nancy Benavides,Financial Aid Director 2. Corey Hodge, VP for Student Affairs 3. 3. Joanne Fernandez, Controller 4. Marla Withers, Assistant Controller 5. Sagrario Armenta Jimenez, CFO 6. Dr. Christopher Gilmer, President Anticipated completion date: 6/30/2025

Planned corrective actions: As a response to concerns about disruptions in processes and the turnover of key staff in several departments, the Enrollment Alliance group that includes director-level staff in Admissions, the Registrar, Financial Aid, Advising, Bursar, and IT began meeting under the facilitation of the VP of Student Affairs on January 7, 2025. This group has helped to guide the Registrar's Office in the development and workflow structure of an electronic withdrawal form that must be routed through several required offices, including Financial Aid, to ensure that processes including R2T4 calculations are completed for each student who withdrawals during the semester. This structure is now in place. Name of Responsible Party: 1. Nancy Benavides,Financial Aid Director 2. J.T. Menard, Registrar 3. Ivan Banks, Interim Provost 4. Corey Hodge, VP for Student Affairs 5. Joanne Fernandez, Controller 6. Marla Withers, Assistant Controller 7. Sagrario Armenta Jimenez, CFO 8. Dr. Christopher Gilmer, President Anticipated completion date: 6/30/2026

As a response to concerns about disruptions in processes and the turnover of key staff in several departments, the Enrollment Alliance group that includes director-level staff in Admissions, the Registrar, Financial Aid, Advising, Bursar, and IT began meeting under the facilitation of the VP of Student Affairs on January 7, 2025. When the registrar office sends their enrollment reporting through the clearing house, financial aid will have a person with access to NSLDS to spot check to ensure enrollment is submitted correctly and in a timely manner. A system will be developed where spot checks will be done monthly on a few random students. Name of Responsible Party: 1. Nancy Benavides,Financial Aid Director 2. J.T. Menard, Registrar 3. Ivan Banks, Interim Provost 4. Corey Hodge, VP for Student Affairs 5. Joanne Fernandez, Controller 6. Marla Withers, Assistant Controller 7. Sagrario Armenta Jimenez, CFO 8. Dr. Christopher Gilmer, President Anticipated completion date: 6/30/2026

The College has already initiated corrective action by hiring entirely new staff in key positions and is committed to fostering a culture of compliance through rigorous procedures and training. 1. Staff Expertise: Financial Aid team members are becoming certified in the enterprise resource program module, specifically related to financial aid, as a first step. 2. SOP Implementation: The core of this plan involves the creation of seven new or updated Standard Operating Procedures (SOPs) (as highlighted above) to standardize compliance activities and reduce reliance on individual employee experience. 3. Proactive Monitoring: We are implementing mandatory monthly and quarterly reconciliation and audit reports to ensure adherence to timelines and documentation requirements, moving from reactive to proactive compliance management. 4. Cross-Training: Training will be conducted across multiple departments (Financial Aid, Business Office, Registrar) to ensure shared understanding and accountability for Title IV compliance. Finding 1: Satisfactory Academic Progress (SAP) Monitoring and Documentation Condition: 11 out of 60 students did not meet SAP, and the College did not provide supporting documentation for successful appeals, resulting in questioned costs of $180,794. (34 CFR 668.34) • SAP Policy Review and Update – The institution is currently reviewing its SAP Policy and will make adjustments where needed to include the appeal processes. The policy will also include a new financial aid SAP committee to review the appeals. • Develop SAP, appeal SOP –New SOP for processing, reviewing, and documenting all SAP appeals, requiring specific documentation of student's successful appeal basis • The institution is currently reviewing all students and is requesting that additional time is granted to ensure a thorough and accurate evaluation. • Expected date of completion: 06/2026 Finding 2: Federal Work-Study (FWS) Timesheet Documentation Condition: 9 out of 10 students for FWS had missing or incomplete timesheets. (34 CFR Part 675) • Implement monthly Timesheet Reconciliation, New SOP requiring the FWS Coordinator to reconcile all timesheets with Payroll records monthly, before payment is released. Any missing/incomplete sheets must be resolved within 48 hours. • FWS Supervisor Training for all FWS supervisors on the new timesheet, proper approval process, and the non-negotiable requirement for complete and timely documentation. Signed supervisor acknowledgment forms required. • Monthly Audit & Report Produce a monthly report of FWS student timesheet completeness/compliance. Report results to the Director of Financial Aid. • Freeze on Disbursements: All pending FWS payroll payments are being held until complete and signed timesheets are submitted. • Expected date of completion: 06/2026 Finding 3: Timely Return of Title IV (R2T4) Funds Condition: 6 out of 10 students tested for withdrawals and R2T4 did not have their Title IV program funds returned within the 45-day requirement. (HEA Section 484B & 34 CFR 668.22) • Establish Formal Withdrawal Date SOP, New SOP defining the official withdrawal date determination process (including school notification vs. last date of attendance), and immediate notification trigger to FA/Business Office. • Implement R2T4 Tracking Log & Checklist, Creation and mandatory use of an R2T4 Log to track the withdrawal date, calculation date, and refund date for every withdrawing student, ensuring adherence to the 45-day deadline. • Funds Returned: All late Title IV returns from the finding have now been processed and documented. • Staff Training: o Financial Aid and Registrar staff received refresher training on R2T4 regulations and deadlines. o Ongoing training scheduled annually and upon policy updates. • Internal R2T4 Processing Policy: o R2T4 calculations must be initiated within 10 business days of withdrawal notification. o Final return of funds must be processed by Day 40 (buffer before 45-day federal limit). • Expected date of completion: 06/2026 Finding 4: Entrance and Exit Counseling Documentation Condition: Entrance and exit counseling documentation was not provided for first-time borrowers, withdrawn students, or graduated students. (34 CFR 685.304) • Automated Verification System: o Financial Aid Office now verifies entrance counseling completion via the StudentAid.gov website prior to disbursing loans. • Exit Counseling Process: o Students flagged for exit counseling are immediately notified via email with instructions and a due date. o Confirmation of completion is pulled from StudentAid.gov or collected as a screenshot/PDF and saved. • Tracking Log: o A centralized loan counseling tracking log has been created to monitor: § Date of enrollment § First disbursement date § Withdrawal/graduation date § Counseling completion dates • Staff Training: o All Financial Aid staff have been trained on the new process for tracking and documenting counseling. o Training includes accessing StudentAid.gov reports and ensuring loan disbursement blocks are in place for non-compliance. • Student Hold Policy: o A registration or transcript hold may be applied for students who fail to complete required exit counseling after multiple reminders. • Expected date of completion: 06/2026

Policy and Procedure on coordination and reconciliation

Pending

Implement draft Policy & Procedures on monthly recs

Finding 2024-008 Repeat Finding 2023-009 ALNo.: Program Title: Federal Agency: Pass-Through Agencies: Award Number/Year 93.658 Foster Care - Title IV-E U.S. Department of Health and Human Services Wisconsin Department of Children and Families 3413,3561,3681,3645/2024 Criteria: The Uniform Guidance and State Single Audit Guidelines require that local entities receiving federal and state awards establish and maintain internal control designed to reasonably ensure compliance with laws, regulations and program compliance requirements. The Uniform Guidance and State Single Audit Guidelines further require auditors to obtain an understanding of the local entity's internal control over federal and state programs. To minimize the risk of errors, internal controls should be in place for all program compliance requirements, including the preparation and submission of monthly reports, which should be reviewed and approved by a responsible party other than the original preparer. Condition/Context: There were 13 reports for submission for the County. Three reports were selected for testing. There was no documentation of a review control by someone independent of the preparer for all three reports tested. Our sample was not statistically valid. Cause: The County did not have procedures in place requiring an independent person to review the reports before submission. Questioned Costs: None noted. Effect: Reports that contain errors could be submitted. Recommendation: We recommend that an employee other than the preparer review all reports before they are submitted to grantors. Corrective Action Planned: Angela Runde and Cody Blindert continued to work on the development of the Grant Manager module of Tyler MUNIS. In 2025 it was reviewed with the Department Heads, Kessa Klaas, CeCe Fink, Lori Reid and Jessica Munson as to their responsibility to review each filing for completeness and accuracy before filing. Cece Fink has designated that one person pull the information and compile the report. The workflow will route the report to Cece Fink for review and then to Patrick Montgomery for final review and approval. Anticipated Completion Date 3/1/2026.

Federal award findings and questioned costs 2024-001. Cluster name: Student Financial Assistance Cluster Assistance Listings numbers and names:84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study Program 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Luisa Ott Anticipated completion date: June 30, 2025 The District agrees with the finding. After reviewing the students in the finding, the District re­processed the Return of Title IV calculation. The students records were updated and resulted in an amount of $109.45 to be returned to the students by offsetting their current balance with the District. The District will fund the reimbursement with institutional funds. During the fiscal year ending June 30, 2024, the District created a supporting automated processes to identify potential Return to Title IV accounts. This new process utilizes the student information system to automatically compute student Return to Title IV calculations. The District will also be implementing new procedures to ensure that the proper amount of scheduled breaks are included and reviewed as a final step before returning the funds.

The Financial Aid and Registrar’s Offices are refining the withdrawal notification and reconciliation process to ensure that both official and unofficial withdrawals are accurately identified and routed for R2T4 calculation within the required timeframe. All identified cases were reviewed, corrected, and documented. The funds totaling $31,830 (Direct Loans) and $3,499 (Pell Grants) have been returned, and student accounts were reconciled accordingly. The Financial Aid Office, in coordination with the Information Technology team, is reviewing the SIS configuration to determine why certain Fall 2024 calculations were one day off, despite correct data entry. Adjustments will be made to eliminate any system-level rounding or timestamp discrepancies that could affect future calculations. Implementation of the corrective action plan is expected to be complete by June 30, 2026. Responsible Party Robert Rood Interim Vice President Finance and Administration

The discrepancies identified were the result of inconsistencies between internal student records and data transmitted to COD for Direct Loan origination. These errors occurred due to manual data entry and timing differences between updates made in the institution’s student information system (SIS) and those reflected in COD. Financial Aid staff received refresher training on Direct Loan data accuracy, COD reporting requirements, and verification procedures to ensure consistent documentation and communication between systems. Collaboration with IT Office is underway to establish automated data checks between the SIS and COD files to minimize the risk of future mismatches. Implementation of the corrective action plan is expected to be complete by June 30, 2026. Responsible Party Robert Rood Interim Vice President Finance and Administration

This finding was related to staff turnover within the financial aid, student accounts and business offices. The hiring of qualified staff properly trained should avoid this error going forward. Implementation of the corrective action plan is expected to be complete by June 30, 2026. Responsible Party Robert Rood Interim Vice President Finance and Administration

This finding was related to staff turnover within the financial aid, student accounts and business offices. The hiring of qualified staff properly trained should avoid this error going forward. The Perkins program has ended and it is also likely that any personnel involved in the active years left years ago. We are currently working with UAS to reassign our Perkins portfolio back to the U.S. Department of Education. Implementation of the corrective action plan is expected to be complete by June 30, 2026. Responsible Party Robert Rood Interim Vice President Finance and Administration

A discrepancy was identified in the Pell Grant calculation for one student, resulting in an under-award of $250. The error was isolated and corrected; however, the institution was unable to determine the exact cause of the miscalculation at the time of review. The issue appears to have been related to a system-generated calculation variance that was not flagged through existing validation checks in the student information system (SIS). At the time of the finding, there were no automated cross-checks in place to compare scheduled awards against Pell tables for data validation prior to disbursement. The affected student’s Pell Grant award has been reviewed and corrected to reflect the appropriate amount. We are working with IT to develop and implement automated system checks that validate Pell Grant awards. Implementation of the corrective action plan is expected to be complete by June 30, 2026. Responsible Party Robert Rood Interim Vice President Finance and Administration

Finding 2024-004: Failure to Notify Secretary of HCM1 Reporting Events while Participating under the Zone Alternative Comments on Finding and Recommendations: The College agrees with this finding as determined in the examination and states that the College had deficiencies related to the Institution's failure to properly notify the Secretary of a violation of a loan agreement and a failure to make a payment in accordance with its debt obligations,that resulted in a creditor filing suit to recover funds under those obligations. Actions Taken or Planned: The College was unaware of the requirement to notify the Secretary of the concerns with the loans and is taking action to notify the Secretary at the time of generating this document. The College has hired an Accreditation and Compliance Officer to ensure that lack of understanding of requirements does not happen in the future. The College would also like to note the following: the individual referenced in the suit had given verbal, though not written permission to not pay the loan past the due date while she served as the Vice Chair of the Governing Board. Upon removal from the Board due to failure to perform duties the individual filed suit, the suit is being partially argued by the College’s attorney noting the complainant had failed in their duties while on the board and may have engaged with another individual to defraud the College. Additionally while the College is submitting notification currently, there is a Government shutdown that may interfere with the notification process.

Finding 2024-003: Incorrect Refund Calculation Comments on Finding and Recommendations: The College agrees with this finding as determined in the audit and states that the College had deficiencies related to the the return of funds to the Department of Education based on a miscalculation of the last day of attendance. Actions Taken or Planned: The College has returned the funds to the Department of Education and has instituted greater coordination between our departments including but not limited to the Academic Dean, Registrar, Accounting/Bookkeeping, Student Services and Financial Aid to ensure that last dates of attendance are accurately calculated to prevent future occurrences.

FINDING 2024-002: Financial Responsibility Comments on Finding and Recommendation: The College agrees with this finding as determined in the audit and states that the College had a net reduction in student enrollments and had incurred additional expenses as it operated and maintained the rent at two separate locations within Florida. The College incurred additional losses in tuition revenue and services revenue as it restructured how to operate both locations appropriately during 2024 while incurring additional costs as the previous entrenched management was moved out. Additionally the previous board had chosen to continue to push debt into following semesters, impacting each semester's ability to produce a profit. Actions Taken or Planned: The College acted in 2024 and 2025 to increase enrollment through, targeted advertising, bringing on a Director of Marketing and Media relations, examining the curriculum to remove waste and elevate the quality of education, changing the vision and mission statement, in 2025 requesting the Foundation investigate and remove the inactive Governing board who was engaging in practices furthering the school's financial difficulties. This has all led to a steady increase in the student population. Additional changes have been made to the program including recruitment criteria all leading to DRCOM quickly becoming a leader in East Asian medical education. While other colleges are closing DRCOM continues to experience growth. While reporting the Gainesville FL location as no longer offering instruction, but maintaining a clinical facility to allow - 15 - students to complete the requirements of their academic program in 2024 and 2025. The College also removed and replaced the Executive Director and other members of administration that contributed to the financial issues faced by the College.

Condition: Pell Grant disbursement data was not submitted to COD within the 15-day federal requirement due to a system error. Corrective Action: The Financial Aid Office, in collaboration with Bursar, will implement an automated alert system to flag pending COD submissions and conduct reconcilitions twice monthly. Responsible Party: Director of Financial Aid and Bursar Completion Date: January 31, 2026 Monitoring: Monthly COD reporting review with Vice President for Administration & Finance.

United States Department of Education Student Financial Aid Cluster – Assistance Listing No. 84.063 Condition: During our audit procedures, we noted that the 1 student withdrawal did not have a return to Title IV calculation completed timely as the student officially withdrew 8/29/23 and the calculation was not completed until 3/24/25. We also noted that the calculation that was performed did not include documentation of the control process to review and approve the calculations prior to changes being made to the student’s award. Auditors’ Recommendation: We recommend the institution maintain proper documentation in accordance with federal grantor requirements and ensure that the documents are readily available for review upon request, including monitoring of students with triggering events that require a return to Title IV calculation to be completed, reviewed, and approved. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University has implemented a new SIS and Financial Aid processing system. Name(s) of the contact person(s) responsible for corrective action: Qiana Hall, Associate VP of Enrollment Services Planned completion date for corrective action plan: June 30, 2025