Corrective Action Plans

Student Financial Assistance Cluster – 84.063 Recommendation: We recommend that a review is implemented which compares enrolled credits to Pell award to ensure all Pell funds are awarded at proper amounts. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Upon notification of the finding, a query was developed and a review performed to identify potentially impacted records in advance of the 2025-2026 academic year. The University has also added review mechanisms to its semester-based enrollment adjustment and repackaging process designed to identify Enrollment Intensity (EI) coding changes, either by batch or manual processes. These review mechanisms allowed for the increased monitoring and correction of potentially incorrect EI coding that would ultimately increase the likelihood of an incorrect Pell Grant amount. A formal bi-weekly query and review process has recently been implemented that compares the student’s total enrollment for a term with the coded EI, confirming accuracy of the EI percentage. The query process also checks that the posted Pell award is the correct amount based on the EI percentage. Name(s) of the contact person(s) responsible for corrective action: Connie Smith, Executive Director of Student Financial Services Planned completion date for corrective action plan: March 2026

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University review its reporting procedures to ensure that students’ statuses are accurately and timely reported to National Student Loan Data System (NSLDS) within the appropriate timeframe as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: A weekly query process was implemented to identify continuing, degree-seeking students with cancellations or term withdrawals. This process allows us to identify this population of students and accurately report status changes to National Student Clearinghouse (NSC) within a week, ensuring plenty of time for information to be sent from NSC to NSLDS. Name(s) of the contact person(s) responsible for corrective action: Jack Campbell, Registrar, University of Maine and Saman Lesinski, Senior Associate Registrar, University of Southern Maine Planned completion date for corrective action plan: University of Maine – August 2025, University of Southern Maine – March 2026

Finding 2025-001 Condition During our audit, for 1 out of 25 students selected for testing, the College did not report to the National Student Clearninghouse (NSC) and the National Student Loan Data System (NSLDS) within 30 days or included in a response to a roster file within 60 days. However, the student was ultimately reported to the NSC and NSLDS. Corrective Action Plan The graduation status of the student was not reported to NSC and NSLDS in a timely manner. The student qualified as a May 2025 graduate. However, at the point in time at which May graduates were reported to NSC, the final transcripts for the off-campus credits the student used to complete his degree had not yet been received. As a result, his degree was not conferred in the student information system until after the degree upload was sent to NSC. Then, by human error, once the student’s transcripts were received, his graduation status was not manually reported to NSC until after the 60-day reporting period had passed. To prevent this situation from arising in the future, we have changed the way we track students whose degree conferrals are entered into the SIS after the date on which the graduates upload has been sent to NSC. This process change will highlight those students whose conferrals must be manually reported to NSC because they were not included in the initial upload of graduates sent to NSC. We will also require students sending transcripts for credits taken off campus to have those transcripts received by our office within 30 days of the conferral date. If transcripts containing credits necessary for graduation are received more than 30 days after the conferral date, the student’s degree conferral will be pushed back to the next available degree conferral data. Name of Contact Person Responsible for Corrective Action: Michael Reig, Registrar Completion Date: December 1, 2025

Student Financial Assistance Cluster – Assistance Listing Numbers 84.007, 84.033, 84.038, 84.063, 84.268 Recommendation: We recommend the University review its reporting procedures to ensure that students’ statuses are timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Plymouth State University: The registrar’s office will be examining how these situations came about. Given that our records pulled from Banner are correct and were sent to NSC as per reporting compliance requirements, we believe that there are issues with the NSC side of the current reporting process. We will connect with the NSC audit team with the expectation that there will be a noticeable fix – one that can be used in the future to preempt findings. Additionally, teams at USNH will explore two items: 1) Review of how the NSC template is set up and working in PSU-Banner, and provide assistance in correcting any portions of the process that are out of line. 2) Investigate downloading PSU data from NSLDS to compare with the data pulled from PSU-Banner so potential mismatches on statuses can be caught in real time. Keene State College: KSC Registrar, which is responsible for reporting enrollment statuses to NSLDS, confirmed with NSC the record was sent in a time manner to NSC. The records for unknown reasons were not processed by NSC until a later date. The Registrar has been made aware this is a repeat finding and additional training will be provided, along with a review of the procedures. Name(s) of the contact person(s) responsible for corrective action: Tonya LaBrosse, Registrar, Plymouth State College Cathy Mullins, Director of Financial Aid and Scholarships, Keene State College Planned completion date for corrective action plan: July 1, 2026

Student Financial Assistance Cluster – Assistance Listing Numbers 84.007, 84.033, 84.038, 84.063, 84.268 Recommendation: We recommend that the College put a process in place to refund student credit balances that arose from federal funds within 14 days. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: This repeat finding was partially due to the implementation of Workday, the adjustments of aid to individual student records, and a shortage of staff. We have hired an additional staff member and trained additional staff to help with federal refunds during the demanding time of the term. Name(s) of the contact person(s) responsible for corrective action: Cathy Mullins, Director of Financial Aid and Scholarships. Keene State College Planned completion date for corrective action plan: July 1, 2026

CORRECTIVE ACTION PLAN YEAR ENDED JUNE 30, 2025 Finding No. 2025-001 – Return of Title IV Funds Finding: During the audit, for the 2 students selected for testing of Title IV disbursements, the institution improperly calculated the number of days used in the Return of Title IV Funds (R2T4) calculation for the Fall 2024 semester, resulting in an incorrect percentage of Title IV aid earned. Consequently, the amount of Title IV aid refunded was not calculated in accordance with federal requirements. Corrective Action Taken or Planned: Senior management at NEC takes Title IV requirements seriously. Moving forward, the institution review its academic calendar and will strengthen controls over R2T4 calculations to ensure that the number of calendar days used in determining earned Title IV aid is calculated accurately and in accordance with federal requirements. Responsible Person: Rebecca Barry-Wolff, Director of Student Financial Planning Update: The corrective actions noted are all in place for fiscal year 2026.

Bluefield University does include required disbursement information, including the right to cancel Title IV funds, in financial aid award letters, Master Promissory Notes, and entrance counseling. However, effective January 1, 2026, the University implemented a policy in the financial aid office requiring use of the PowerFAIDS system-generated disbursement notice at the time of each type of disbursement: direct loan, plus loan, and alternative loan. This auto-generated notice is an email to the student clearly noting the student’s right to cancel all or a portion of that specific loan disbursement, referencing the timeline and process by which a student may exercise this cancellation right.

Effective February 1, 2026, Bluefield University’s top management set forth the expectation of the University Registrar/Veteran Certifying Official that she ultimately is responsible for routine enrollment reporting and withdrawal reporting in accordance with NSLDS requirements. The University has drafted a process to support this task, designating a Compliance Reporting Officer within the Registrar’s Office to be responsible for reporting enrollment and withdrawal data to the NSC. This responsibility is included in the job description and performance evaluation metrics for this position. The documented process notes that the University has implemented a tracking sheet to use for monitoring the University’s progress on bringing current enrollment reporting for previous semesters and identifying dates going forward that align with federal enrollment reporting deadlines. Further, the process includes a secondary review by the Director of Financial Aid or designee to verify submission of required enrollment reporting through NSC acknowledgement reports. The University also has engaged an external consultant to help address prior reporting gaps and accelerate reporting and reconciliation efforts, with the goal of achieving full operational compliance and current reporting by June 30, 2026.

National Student Loan Database System (NSLDS) Enrollment Reporting Recommendation: We recommend the College reevaluate their procedures and review policies surrounding reporting status changes to NSLDS to ensure timely and accurate reporting. Explanation of disagreement with audit finding: There is no disagreement with the auditfinding. Action taken in response to finding: The Registrar will re-evaluate policies, procedures and training materials to ensure timely and accurate reporting. Name(s) of the contact person(s) responsible for corrective action: Michele Peterson Planned completion date for corrective action plan: 03/31/26 If

Finding 2025-001 – Inaccurate NSLDS Reporting Corrective Action Plan: Now that this protocol has been identified, our NSC coordinator has been manually updating the enrollment statuses for this population of students, changing their indicators from “W” to “G” as required. Contact Person(s): Jennifer Seyer, University Registrar Office Anticipated Completion Date: We identified all students who met this specific scenario, ran the necessary reports, and manually updated their enrollment statuses accordingly within the NSC. All updates were completed in February 2026.

2025-002 – U.S. Department of Education, SFA Cluster, Special Tests and Provisions - Untimely Return of Title IV Refunds (Significant Deficiency) Condition: From a population of 40 students that unofficially withdrew during the academic year, we tested four students and noted that all four students required refund calculations. R2T4 calculations were not prepared for three of the four students. Criteria: For a student who withdrawals, without providing notification, from a school that is not required to take attendance, the school must determine the withdrawal date no later than 30 days after the end of the earlier of (1) the payment period or the period of enrollment (as applicable), (2) the academic year, or (3) the student’s educational program. An institution must return the amount of Title IV funds for which it is responsible as soon as possible but no later than 45 days after the date of the institution’s determination that the student withdrew (34 CFR Section 668.22(a)(6)(j)(1)). Cause: Controls to ensure timely preparation of Title IV refunds did not function as related to the condition above. Effect: R2T4 calculations were not prepared for three students tested that unofficially withdrew resulting in untimely return of funds to the Department of Education. Repeat Finding from a Prior Year: No Recommendation: We recommend the University review and update its procedures to ensure timely preparation of Title IV refunds for students that unofficial withdrawal. View of Responsible Officials: Lander University acknowledges the finding related to the untimely return of Title IV funds and recognizes the seriousness of this compliance matter. The University has conducted a comprehensive review of its processes related to the identification of unofficial withdrawals and the timely completion of Return of Title IV (R2T4) calculations. The review determined that the prior process relied on a single point of control within the Financial Aid Office to identify unofficial withdrawals and initiate R2T4 calculations. During the period under review, that control did not function as intended, resulting in certain students not being identified in a timely manner and required R2T4 calculations not being completed within regulatory timeframes. In response, the University has redesigned the control environment governing unofficial withdrawal identification and R2T4 processing to introduce multiple, independent points of review and verification, and to formalize cross-office responsibilities. Under the revised process, faculty are required, pursuant to institutional grading policy, to document the student’s last date of academically related activity when assigning grades indicative of non-participation. At the conclusion of each academic term, the Registrar’s Office performs a structured review of students receiving grades associated with non-attendance to identify those who may have unofficially withdrawn from all coursework. The Registrar reviews the documented information for completeness and consistency and records the verified last date of attendance or participation in the student information system. The verified information is then provided to the Financial Aid Office, which completes the required R2T4 calculation within established timelines. The process now includes multiple levels of review, including supervisory and director-level oversight within Financial Aid, to ensure calculations are completed accurately and timely. Relevant information is also communicated to Student Accounts and the Registrar to ensure appropriate billing, notification, and enrollment reporting. These revised procedures have been implemented and are designed to eliminate reliance on a single control, strengthen accountability across offices, and ensure timely identification of unofficial withdrawals and prompt return of Title IV funds. Through these corrective actions, the University has strengthened its internal controls and is committed to maintaining full compliance with federal Title IV requirements. Joseph T. Greenthal Vice President for Finance and Administration Lander University

The Tennessee State University (TSU) Management concurs. The management of and the compliance with Title IV programs accountability is jointly owned by the Registrar’s Office and the Financial Aid Office, and as such requires commingled remediation. The Tennessee State University (TSU) has made significant improvements by automating the potential return calculation for students with less than 60% of the semester complete and documenting the procedures for these instances. However, these findings reflect there is more to do related to the validation of the input data (i.e., dates) to ensure output accuracy (i.e., the calculation) as well as the coordination between the two offices to initiate action when a student withdrawal occurs. The Tennessee State University has identified this step as particularly critical and pervasive to our compliance. As stated in the response to Finding 2, the Financial Aid Office now receives an automated file of the students who have withdrawn that day. This report serves as a notice to review and update students’ enrollment statuses. The additional procedure helps to ensure accurate dates are being captured timely. Additionally, our comprehensive corrective action, referred to in Finding 1, to rebuild our application of payment sequencing will allow the automation of the returns once calculated. In addition to the process improvements, we continue to create a higher standard of operating effectiveness to ensure all critical policies and procedures are being executed properly without exception.

The Tennessee State University (TSU) Management concurs. The management of and the compliance with Title IV programs accountability is jointly owned by the Admissions & Records Office and the Financial Aid Office, and as such require commingled remediation. While the TSU management has made significant improvements in the activities in the separate areas, including hiring additional staff, updating process documents, and re-emphasizing the process during staff meetings, these findings reflect there is more to do related to the connectivity activities and procedures of the Offices to ensure both accurate and timely reporting of students’ enrollment statuses. We have identified this is particularly critical in the compliance procedures that require sequential actions by different departments. Starting in the Fall 2025 semester, the Financial Aid Office receives an automated file of the students who have withdrawn that day. This report serves as a notice to review and update students’ enrollment statuses. The additional procedure helps to ensure accurate dates are being captured timely. In addition to the process improvements, we continue to create a higher standard of operating effectiveness to ensure all critical policies and procedures are being executed properly without exception.

The Tennessee State University (TSU) Management concurs. The Refund Timeliness and Disbursement Notification Accountabilities are owned by the Bursar’s Office and the Financial Aid Office, respectively, and as such have required separate remediation. While we have made significant improvements, including updating process documents, increasing external staffing support, and internal training, the University’s “last dollar” scholarship approach creates more complexity that we continue to address. Post fiscal-end June 30, 2025, the Tennessee State University (TSU) updated the text scripts to ensure all required information is included, as well as activated non-term specific automated notifications. These updates were put into place for the Fall 2025 semester and are expected to provide additional safeguards from these errors going forward. Additionally, the TSU comprehensive corrective action is to rebuild our application of payment sequencing, including creating new detail codes with accurate parameters for all awards. This will allow our Banner system to properly automate refunds without the manual initiation and interventions currently required. We expect this project to be completed by the Fall 2026 semester.

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the College review its reporting procedures to ensure the students’ statuses are timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Dunwoody’s Registrar’s Office has adjusted our reporting scheduling process to accommodate for additional time to work through our third-party vendor (NSC) customer service if there is a processing error. Our Registrar’s Office is attending all training provided by NSC on enrollment reporting and the Director of Financial Aid is attending NSLDS trainings provided by Federal Student Aid and NASFAA. In addition, we have scheduled monthly regular meetings between the Registrar and the Director of Financial Aid to collaborate and proactively address any concerns with NSLDS reporting in advance of deadlines. Name of the contact person responsible for corrective action: Jaz Hofbauer, Registrar Planned completion date for corrective action plan: This process is in place for the 2025-2026 academic year.

View of Responsible Officials The University concurs with this finding. Management has initiated a review of all relevant institutional academic calendars to ensure that the correct payment period start and end dates are accurately configured within the Colleague system. The Spring 2025 withdrawal population is being reviewed to determine whether additional R2T4 recalculations and returns of Title IV funds are required. Necessary corrections will be processed promptly. Going forward, the University will implement procedures to verify that system-configured term dates agree to the officially approved academic calendar prior to each academic term to ensure compliance with federal R2T4 requirements.

View of Responsible Officials The University concurs with this finding. Management has reviewed its processes for monitoring and issuing Title IV credit balance refunds and has implemented procedures to ensure refunds are processed within the required 14-day timeframe. The Financial Aid and Student Accounts offices will review credit balance reports on a regular basis to identify students eligible for refunds and confirm timely disbursement. In addition, staff have been reminded of federal requirements related to credit balance refunds. Management will monitor this process periodically to ensure ongoing compliance.

View of Responsible Officials The University concurs with this finding and has implemented corrective actions to prevent recurrence. The entrance counseling loan processing rule parameters within the Colleague financial aid module have been updated to prevent loan authorization and disbursement if entrance counseling has not been received and posted to the student's loan record. The system update was implemented in February 2026. In addition, the University reviewed loans processed during the affected period to confirm no additional instances of noncompliance occurred. Financial aid staff have been reminded of federal entrance counseling requirements, and management will periodically monitor system controls to ensure continued compliance.

Management agrees with the finding and plans to implement practices to ensure compliance with all federal requirements.

Management recognizes the importance of complying with all federal requirements and agrees with the finding. In this case, out of the one student who was sampled, the student was reported late to the National Student Loan Data System (NSLDS). This late reporting was due to human error in processing the status change internally late and therefore missing the next automated upload to NSLDS. Measures will be put in place to ensure all changes are processed timely.

2025-002 Student Financial Assistance Cluster – Federal Assistance Listing Nos. 84.063, and 84.268 – Enrollment Reporting Recommendation: We recommend the University evaluate its procedures and review policies in overseeing submissions to the NSLDS completed by the third-party servicer. Additionally, we recommend the University review its policies and procedures on reporting enrollment information to the NSLDS to ensure that all relevant information is captured and reported timely in accordance with applicable regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Registrar’s office has diligently been working to resolve enrollment reporting concerns with internal IT assistance and the Audit Resource Center with the National Student Clearinghouse. In February 2025, a request was sent to the National Student Clearinghouse representative who referred us to the audit resource center regarding students being submitted to the National Student Clearinghouse and not bridging over to NSLDS. We are still working through these issues as some students who were manually submitted on the same day in the National Student Clearinghouse successfully bridged over to NSLDS while others did not. Additionally, we have continued to work with the National Student Clearinghouse, including Mr. Patrick Ciardullo and his team, to work on other enrollment file errors. With our internal IT team, we have also advanced, created and strengthened the enrollment file report process to alleviate any potential issues while pulling the file for submission monthly. This has included integrating a purge process to remove students no longer registered, updating graduation data including expected graduation date, and updating time statuses in batch mode. We have also created and used numerous popsels to assist in aligning the student data with the enrollment file requirements, which has also assisted in double checking that all reported information is accurate. This has significantly cut the number of errors returned from the National Student Clearinghouse by approximately 90%. Due to this, we can review and address any discrepancies in a more timely and efficient manner. The recommendation was to continue with our updated process and manually check a group of students to ensure they bridged over to the NSLDS since there are no uniform or explainable causes outside of technical abnormality. We continue to work on outliers, such as the errors presented during the audit. Documentation was presented and shared during the review process that confirmed the findings are indeed software/technical outliers and ones already being worked on by the Delaware State University and National Student Clearinghouse teams. Name(s) of the contact person(s) responsible for corrective action: Registrar, Dr. Genita Mangum Planned completion date for corrective action plan: October 2026

Finding number: 2025-002 Federal agency: U.S. Department of Education Programs: Federal Direct Student Loans Assistance listing #: 84.268 Award year: 2025 Corrective Action Plan: College Unbound is expanding capacity, hiring in both the Financial Aid and Accounting departments. We are also hiring a new CFO in the Summer of 2026. With this increased capacity, we will have backups for each process and institute a series of double checks in order to ensure accuracy. Timeline for Implementation of Corrective Action Plan: August 15, 2026 Contact Person: Mark Hartonchik, Interim CFO

Finding number: 2025-003 Federal agency: U.S. Department of Education Programs: Federal Direct Student Loans Assistance listing #: 84.268 Award year: 2025 Corrective Action Plan: College Unbound is expanding capacity, hiring in both the Financial Aid and Accounting departments. We are also hiring a new CFO in the Summer of 2026. With this increased capacity, we will have backups for each process and institute a series of double checks in order to ensure accuracy. Timeline for Implementation of Corrective Action Plan: August 15, 2026 Contact Person: Mark Hartonchik, Interim CFO

Finding number: 2025-004 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance listing #: 84.063 and 84.268 Award year: 2025 Corrective Action Plan: College Unbound is expanding capacity, hiring in both the Financial Aid and Accounting departments. We are also hiring a new CFO in the Summer of 2026. With this increased capacity, we will have backups for each process and institute a series of double checks in order to ensure accuracy. Timeline for Implementation of Corrective Action Plan: August 15, 2026 Contact Person: Mark Hartonchik, Interim CFO

Corrective Action Plan: Because several issues related to compliance requirements surrounding enrollment status changes were identified in this process, we have developed a unified reporting tracking system to ensure the Registrar, the Office of Student Financial Assistance, and the Office of Fiscal Affairs all have visibility into the requirements when students leave the institution. This report will show all students identified by the registrar as having withdrawn, the date of determination, and the deadlines for NSLDS reporting, Exit Counseling, and R2T4 actions if necessary. This report will be visible to all three offices, and will identify when Title IV friends must be returned, automate the identification of the due dates for the return of Title IV funds, and timestamp the completion of the return of the funds, ensuring each action is taken within the required timeframe. It will improve oversight of this process as the status of the return of these funds will be visible to several staff members across several functions. Further, the Financial Aid office will identify an additional staff member to grant access to this report to assist the Director in ensuring Title IV funds are returned within the required timeframe moving forward. Timeline for Implementation of Corrective Action Plan: This report is currently under construction and will be fully implemented by Apr 1 2026.