Corrective Action Plans

Finding 2025-004 U.S. Department of Education (USDE), Title IV Student Financial Aid Programs – Cost of Attendance Budgets (material weakness): Management’s Response and Corrective Action Plan The College concurs with this finding. We acknowledge that the absence of documented Cost of Attendance (COA) budgets and the resulting inability to verify financial need calculations constitute a significant breakdown in internal controls. The College is committed to immediate remediation to ensure full compliance with Title IV regulations. 1) Corrective Action Plan (CAP) To address the root causes of this finding, the College will implement the following measures: • Establishment of Formal COA Budgets: The Financial Aid Office will immediately develop and document standardized COA budgets for the 2025-2026 academic year. These budgets will account for all required components (tuition, fees, housing, food, books, supplies, transportation, and personal expenses) as required by 34 CFR 668.2. • System Integration: We will update our Student Information System (SIS) to automate the application of these COA budgets to student records, ensuring that "Unmet Need" is calculated electronically and consistently for every applicant. • Formalized Internal Controls: A new Standard Operating Procedure (SOP) manual for Financial Aid Packaging will be authored and implemented by June 1, 2026. This manual will mandate the retention of COA tables used for each award year to provide a clear audit trail. • Enhanced Oversight and Training: The Vice President for Enrollment Management and Student Services will initiate a mandatory training program for all financial aid staff regarding federal packaging requirements. • Internal Quality Assurance (IQA): Beginning April 15, 2026, the College will implement a monthly "Mini-Audit" process where a random sample of 10% of student files is reviewed by a third-party or a non-conflicted administrator to verify COA accuracy before disbursements are finalized. 2) Designated Responsible Party-Director of Financial Aid. 3) Anticipated Completion Date-June 30, 2026

Finding 2025-003 U.S. Department of Education (USDE), Title IV Student Financial Aid Programs – Withdrawals & Return of Title IV Funds (material weakness): The Office of Enrollment Management and Student Services accept the auditor’s findings regarding the administration of Title IV funds and the Return of Title IV (R2T4) calculations. We recognize that the accurate tracking of student withdrawals—particularly unofficial withdrawals—is critical to maintaining federal compliance and institutional integrity. While this was not a repeat finding, we view the "systemic" nature of the observation with the utmost seriousness. The College is committed to rectifying the procedural gaps that led to incorrect calculations and late submissions. To address the Cause identified (inadequate tracking) and mitigate the Effect of potential liabilities, the following measures are being implemented immediately: • Enhanced Tracking for Unofficial Withdrawals: The Registrar’s Office, in coordination with Information Technology (IT), will implement a bi-weekly "Internal Attendance & Participation" audit. This automated report will flag students with zero academic engagement across all registered courses, allowing the Financial Aid office to identify unofficial withdrawals well before the 45-day federal deadline. • Standardization of Calendar Dates: The Director of Financial Aid has revised the R2T4 calculation worksheet to include a "Mandatory Calendar Verification" step. This ensures that the start/end dates and scheduled breaks used in calculations strictly align with the approved institutional academic calendar. • Staff Training and Capacity Building: All Financial Aid staff responsible for R2T4 calculations will undergo mandatory Title IV compliance training. Furthermore, a secondary review process has been established where a senior staff member must sign off on all calculations exceeding $1,000 to ensure accuracy before funds are returned. • Inter-Departmental Communication: A new protocol has been established between the Office of Student Services and the Financial Aid Office to ensure that "Administrative Withdrawals" (e.g., disciplinary or medical) are communicated within 48 hours of the determination date. Anticipated Completion Date: October 31, 2026 The College is dedicated to resolving these discrepancies and ensuring that $13,100 in questioned costs—and all future disbursements—are handled with precision. We believe these enhanced internal controls will prevent a recurrence and satisfy the requirements of the U.S. Department of Education.

Finding 2025-002 U.S. Department of Education (USDE), Title IV Student Financial Aid Programs – Federal Work-Study Program (material weakness): Management’s Response and Corrective Action Plan Tougaloo College acknowledges the findings identified in the audit regarding the Federal Work-Study (FWS) Program for the period ending June 30, 2025. We recognize the gravity of the "material weakness" designation and the systemic nature of the documentation exceptions noted. As the Vice President overseeing these services, I am committed to a rigorous overhaul of our FWS administrative protocols to ensure full compliance with 34 CFR 675.16. To address the root causes of these findings, the College is implementing the following measures immediately: • Mandatory Supervisor Training: All department heads and direct supervisors of FWS students must complete a mandatory compliance seminar. This training emphasizes that no student may be scheduled to work during designated class times and that no wages will be disbursed without a verified, contemporaneous timesheet. • Enhanced Timesheet Verification: We are transitioning to a standardized digital submission process. This system will require: o Verification of the student’s course schedule against hours worked to prevent overlap. o Electronic signatures from both the student and supervisor, timestamped to ensure they are captured prior to payroll processing. • Documentation and Record Retention: The Office of Financial Aid, in coordination with Payroll, will implement a "No Document, No Pay" policy. Documentation for any pay rate changes must now be uploaded and approved by the VP for Enrollment Management and Student Services before being reflected in the Jenzabar system. • Internal Monthly Audits: Starting next month, our internal compliance team will conduct random monthly spot-checks of FWS files (10% of active participants) to ensure all timesheets are present, complete, and accurately reflect hours worked. The College is currently reviewing the identified questioned costs of $10,830.00. We will work closely with the U.S. Department of Education to determine the appropriate restitution or adjustment required for any overpayments resulting from missing documentation. We are dedicated to rectifying these systemic issues and ensuring this does not remain a repeat finding in future audit cycles. Our goal is to maintain the highest level of integrity in our Title IV Student Financial Aid Programs.

Finding 2025-001 U.S. Department of Education (USDE), Title IV Student Financial Aid Programs – Satisfactory Academic Progress (material weakness): Management’s Response and Corrective Action Plan Tougaloo College acknowledges the findings identified in the audit for the fiscal year ending June 30, 2025, regarding Finding 2025-001 (Material Weakness). We recognize the gravity of the systemic issues related to the monitoring of Satisfactory Academic Progress (SAP) and the associated questioned costs of $346,764.00. The College is committed to full compliance with 34 CFR 668.34 and is implementing the following corrective actions to ensure the integrity of our Title IV Student Financial Aid Programs. • Automation and System Integration: The College is transitioning from manual SAP monitoring to an automated tracking system within our Student Information System (SIS). This will ensure that academic standing—specifically GPA and completion rates are calculated systematically at the end of each Spring Semester. • Audit of Appeal Documentation: We are establishing a centralized digital repository for all SAP appeals. Effective immediately, no Title IV funds will be disbursed to students on financial aid probation without a documented, approved appeal and a corresponding academic plan on file. • Staff Training and Accountability: The Office of Financial Aid will undergo mandatory training focused specifically on federal SAP criteria. We have revised our internal "Check and Balance" protocol, requiring a secondary review by the Director of Financial Aid before any student failing SAP is cleared for disbursement. • Annual Policy Review: In alignment with the Auditor’s Recommendation, Tougaloo College will conduct a comprehensive annual evaluation of all students. This evaluation will be reconciled against the Registrar’s records to ensure data consistency. • We have updated our SAP policy to allow us to review at end of each Spring The College has already begun the look-back process to review the eligibility of the 16 students identified in the sample. We anticipate that the new automated monitoring and revised internal controls will be fully operational by the start of the Fall 2026 semester to prevent any further repeat findings.

Name of Responsible Individual: Vice President of Enrollment Management (Dr. Stacey Sowell), University Registrar (Charee Ellison) Corrective Action: The University concurs with this finding. Shaw University acknowledges the finding regarding variances between institutional records and the status reported in NSLDS. For students 1-3 listed for campus enrollment details, the students withdrew then subsequently re-enrolled. The University, to date has had static to confer degrees which do not coincide with the required timeframe of NSLDS reporting. The University will change degree conferral dates to better coincide with timely NSLDS reporting. Management will continue to monitor this process to ensure ongoing compliance. Anticipated Completion Date: May 15, 2026

Name of Responsible Individual: Vice President of Enrollment Management (Dr. Stacey Sowell), Director of Financial Aid (Dr. Ojebe Ifegwu) Corrective Action: The University concurs with the finding and acknowledges the difference between the auditor’s calculations and what was determined as the variance of R2T4. To ensure full compliance with federal Return to Title IV (R2T4) requirements and to strengthen institutional oversight, Shaw University will implement enhanced processes designed to improve accuracy, documentation, and accountability. Each R2T4 calculation will undergo a dual review process in which one Financial Aid team member completes the calculation and a second independently verifies it before any returns are processed. The University will also maintain comprehensive documentation and audit trail for all R2T4 files, including withdrawal documentation, calculation worksheets, COD records, disbursement summaries, and proof of timely returns, stored systematically to support audit readiness and internal review. To reinforce oversight, management will reconcile internal Financial Aid records with the Business Office and COD on a scheduled basis, conduct monthly or biweekly reconciliations for Pell Grants, Direct Loans, and campus-based funds, and review open balances and disbursement records before posting or adjusting aid. Financial Aid staff will continue to receive annual and periodic training on R2T4 regulations, updated federal guidance, and internal process revisions to ensure consistent application of rules. Additionally, management will conduct periodic internal audits of R2T4 files to identify potential issues proactively and respond with timely corrective measures. These strengthened procedures will ensure that future R2T4 calculations are accurate, fully documented, and completed within federally required timeframes, thereby maintaining strong compliance, reinforcing internal controls, and meeting all expectations for federal oversight. Anticipated Completion Date: April 30, 2026

Name of Responsible Individual: Vice President of Enrollment Management (Dr. Stacey Sowell), Director of Financial Aid (Dr. Ojebe Ifegwu) Corrective Action: The University concurs with the findings. Shaw University acknowledges the findings regarding variances between institutional records and the amounts reported on the FISAP, as well as the delay in submitting corrections by the required deadline. The variances were due to insufficient reconciliation between the University’s records and the FISAP prior to submission. In addition, controls were not adequate to ensure that identified discrepancies were corrected within the required timeframe. The University has since completed a full reconciliation of the FISAP, and further corrections will be made. To prevent recurrence, the University has implemented procedures requiring a formal reconciliation of supporting records to the FISAP prior to submission, along with enhanced review and approval controls to ensure accuracy and timely reporting. Management will continue to monitor this process to ensure ongoing compliance. Anticipated Completion Date: April 30, 2026

Name of Responsible Individual: Vice President of Enrollment Management (Dr. Stacey Sowell), Director of Financial Aid (Dr. Ojebe Ifegwu) Corrective Action: The University concurs with the finding and will provide professional justification for the students identified in the audit testing; however, to strengthen internal controls and prevent potential over awards, the Financial Aid Office will enhance cross departmental communication through routine reconciliation meetings and real time reporting of enrollment, housing, scholarship, and waiver changes, implement a double review process in which an assigned counselor and secondary counselor verify aid packages against COA and financial need before disbursement, and provide annual staff training on need analysis, COA construction, Title IV over award regulations (34 CFR 673.5), and proper use of SIS tools to identify conflicts, ensuring stronger compliance and proactive prevention of award discrepancies. Anticipated Completion Date: April 30, 2026

Name of Responsible Individual: Vice President of Financial Operations/CFO (Michelle Lane) Corrective Action: The University concurs with the findings. Shaw University acknowledges that this finding is a repeat condition related to excess cash balances for Pell Grant, Direct Loan, and FSEOG funds not being eliminated within the required seven business days. Management has determined that prior corrective actions were not sufficiently formalized or consistently executed, particularly with respect to reconciliation and monitoring controls. Since that time, the University has strengthened its internal controls over Title IV cash management. A formal monthly reconciliation between G5 drawdowns and the general ledger has been implemented to ensure excess cash balances are identified and resolved timely. In addition, procedures have been revised to limit drawdowns to actual or immediate disbursement needs, and monitoring controls have been established to ensure compliance with the seven-business-day requirement. Management will continue to monitor these processes to ensure ongoing compliance with federal cash management regulations. Anticipated Completion Date: June 30, 2026

Finding Number: 2025-103 The deficiencies resulted from the absence of a comprehensive, system-based control structure capable of: ● Enforcing secure system access protocols, including multi-factor authentication The institution will implement multi-factor authentication (MFA) across all financial aid and student information systems to: ● Protect Title IV data from unauthorized access ● Align with federal information security expectations ● Ensure compliance with institutional cybersecurity policies Anticipated Completion Date: 8/31/2026 Responsible Contact Person: Angela Reese

Finding Number: 2025-102 The deficiencies resulted from the absence of a comprehensive, system-based control structure capable of: ● Generating automated alerts to ensure compliance with federal return-of-funds deadlines To ensure compliance with 34 CFR § 668.22(j): ● The institution will utilize system-generated alerts to track all R2T4 deadlines ● Staff will follow standardized procedures aligned with federal timelines ● Supervisory review will be required prior to final processing of all returns Anticipated Completion Date: 8/31/2026 Responsible Contact Person: Angela Reese

Finding Number: 2025-101 The deficiencies resulted from the absence of a comprehensive, system-based control structure capable of: ● Tracking and documenting R2T4 calculations, including secondary review and approval Tom P. Haney Technical College will implement systemic and procedural corrective actions designed to ensure full compliance with Title IV requirements. The institution will procure and implement the Point-of-Sale (POS) module within the FOCUS School Software system to establish automated internal controls. The system will: ● Require documented review and approval workflows for all R2T4 calculations ● Maintain electronic audit trails for all transactions and approvals ● Provide automated notifications and deadline tracking to ensure timely return of funds ● Generate compliance reports for ongoing monitoring The Financial Aid Office will revise and formalize written policies to include: ● R2T4 calculation, review, and approval procedures ● Timelines for return of funds ● System access and authentication requirements All policies will be maintained in accordance with federal recordkeeping requirements under 34 CFR § 668.24. All financial aid and relevant administrative staff will receive training on: ● R2T4 regulatory requirements ● Use of the FOCUS POS system ● Updated institutional policies and procedures Training will be documented and retained for audit purposes. Anticipated Completion Date: 8/31/2026 Responsible Contact Person: Angela Reese

Management acknowledges the audit finding related to the absence of a formally documented written information security program. While VEEB has implemented certain administrative and technical safeguards to protect sensitive information, these practices have not been consolidated into a single, written information security program as required. Management is committed to addressing this matter and plans to formalize its existing information security practices into a written information security program that is appropriate to the size, complexity, and risk profile of the organization. Management expects to complete the development and implementation of the written program during the upcoming fiscal year. Management believes that this condition does not reflect a failure to safeguard information, but rather a documentation gap that will be remedied through the actions described above.

Management agrees with the finding and has indicated that corrective actions will be implemented to improve monitoring and timeliness of R2T4 returns. Management’s corrective action plan is included in the accompanying schedule.

Management Response 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. Corrective Action The University is currently reviewing all R2T4 calculations for the Spring 2025 withdrawal population to ensure calculations were accurate. Necessary corrections will be processed promptly. The University is implementing procedures to verify that system-configured term dates agree to the officially approved academic calendar. The procedures include a review and signoff process to ensure multiple individuals review the information for accuracy. Contact Person Responsible Name – Justin Pichey Title – Director of Financial Aid Phone – 410-532-5735 Email - jpichey@ndm.edu Anticipated Completion Date – April 30, 2026

Management Response 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. Corrective Action The University reviewed the federal requirements for refunds with applicable members of the Business Office and Financial Aid departments to ensure a thorough understanding of the refund rules. The University enhanced its weekly credit balance review process to require explicit review by the Controller and Director of Financial Aid if uncertainty exists on whether a student is eligible for a refund. This review must be completed within the 14 day period with either the refund issued or the loan removed from the student’s account. Contact Person Responsible Name – Richard Jones Title – Controller Phone – 410-532-5367 Email – rjones13@ndm.edu Anticipated Completion Date – April 30, 2026

Management Response 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. Corrective Action In February 2026, the University updated the entrance counseling loan processing rule parameters within the Colleague financial aid module. From February 2026 forward, the rule parameters would prevent a loan from disbursing if the entrance counseling was not performed. The University reviewed loans processed during the period July 2024 – Feb 2026 to ensure there were no additional loans processed without entrance counseling. Contact Person Responsible Name – Justin Pichey Title – Director of Financial Aid Phone – 410-532-5735 Email - jpichey@ndm.edu Anticipated Completion Date – March 31, 2026

Condition: The change in student status for 1 of the 25 students tested was not reported to the National Student Loan Data Systems (NSLDS) within 30 days or included in a response to a roster file within 60 days. However, these students were ultimately reported to the NSLDS. Corrective Action Planned: The College will implement a secondary review process to ensure that all enrollment updates are through the National Student Clearinghouse within the required timeframe. Name(s) of Contact Person(s) Responsible for Corrective Action Kim Bell, Director of Financial Aid & Compliance Anticipated Completion Date: May 1, 2026

Finding No. 2025-001 – Significant Deficiency and Noncompliance: Reporting Corrective Action The corrective action that will be taken is that Enrollment Information and Status Changes will be reported timely to NSLDS. The following will support this effort: 1. Address Systematic Issues 2. Enhance Staff Training 3. Implement Regular Monitoring and Auditing Persons Responsible for Corrective Action The corrective action plan will be completed by Corry Unis, Vice President for Enrollment Management and Diana Draper, Executive Director of Financial Aid. Anticipated Completion Date: May 31, 2026 The University has already reported 12 of the 21 students to NSLDS. The University will update the enrollment reporting to NSLDS for the remaining 9 students impacted. The University will determine the principal cause of the discrepancy and implement a combination of controls, monitoring, and training to ensure accuracy and timeliness of future reporting.

Finding 2025-001 – Special Tests and Provisions: Enrollment Reporting – Status Change at Program Level Corrective Action Plan I. Overview and Acknowledgment The University acknowledges Finding 2025-001 related to deficiencies in enrollment reporting at the program level under the Pell Grant, Direct Loan, and Federal Family Education Loan (“FFEL”) programs. The University concurs with the finding and recognizes the importance of accurate and timely reporting to the National Student Loan Data System (“NSLDS”) in accordance with federal requirements (OMB No. 1845-0035). The University is committed to strengthening internal controls, enhancing operational procedures, and ensuring full compliance with all enrollment reporting requirements. II. Criteria Institutions participating in federal student aid programs are required to: • Report accurate enrollment information through NSLDS, including enrollment status and program-level data elements. • Ensure that all significant data elements—including enrollment status, program begin date, and enrollment effective date—are accurate as of the reporting date. • Submit enrollment reporting updates at least every 60 days (bi-monthly). • Maintain adequate internal controls to ensure data integrity and compliance with federal regulations. III. Condition The audit identified errors in enrollment reporting for a sample of 25 students, including: • 2 instances of incorrect program enrollment effective date reporting These errors were attributed to administrative oversight and insufficient internal controls governing enrollment reporting processes. IV. Cause Analysis The University has identified the following contributing factors: • Insufficient internal controls and review mechanisms over enrollment status updates • Limited system automation and alert capabilities for tracking status changes • Inadequate staffing resources to manage reporting timelines and data verification • Lack of formalized cross-functional coordination between the Office of the Registrar and reporting entities • Absence of an independent monitoring function to ensure compliance consistency V. Corrective Actions and Implementation Plan The University will implement the following corrective actions to address the identified deficiencies: 1. Establishment of Internal Audit Function • The University will establish a formal Internal Audit function by the start of the next academic year. • This function will have broad authority to oversee compliance, enforce corrective actions, and evaluate internal controls across all relevant departments. • Internal Audit will lead ongoing reviews of enrollment reporting processes and ensure accountability. 2. Process Review and Cross-Functional Collaboration • Internal Audit will coordinate a comprehensive review of enrollment reporting processes involving the Office of the Registrar and the National Student Loan Clearinghouse. • This review will include a structured assessment of strengths, weaknesses, opportunities, and risks (SWOT analysis). • Standard operating procedures (SOPs) will be updated and formally documented. 3. Staffing and Resource Enhancements • The University will enhance staffing within the Office of the Registrar to support enrollment reporting functions. • Additional technological tools and system capabilities will be implemented to provide automated alerts, status tracking, and exception reporting. 4. Implementation of Monitoring and Control Systems • A robust monitoring system will be deployed to: o Track student enrollment status changes in real time o Generate alerts for discrepancies or missing data o Ensure timely submission of required updates to NSLDS • Data validation checkpoints will be integrated prior to submission to ensure accuracy. 5. Strengthening Reporting Protocols • Interim control measures will include the submission of transfer student status reports on a semester basis until full remediation is achieved. • All enrollment updates will undergo a secondary review and certification prior to submission. • A compliance calendar will be implemented to ensure adherence to the 60-day reporting requirement. 6. Training and Accountability Measures • Mandatory training sessions will be conducted for all personnel involved in enrollment reporting. • Training will focus on federal requirements, data accuracy standards, and system utilization. • Performance expectations and accountability metrics will be clearly defined and monitored. VI. Timeline for Implementation • Immediate (0–90 Days): o Initiate staffing enhancements o Implement interim review and validation procedures o Conduct training sessions • Short-Term (90–120 Days): o Deploy monitoring and alert systems o Formalize SOPs and compliance calendar o Begin enhanced reporting protocols • Long-Term (By Start of Next Academic Year): o Fully establish Internal Audit function o Complete comprehensive process review and continuous monitoring framework VII. Monitoring and Ongoing Compliance The Internal Audit function will conduct periodic reviews and report findings for executive leadership. Continuous monitoring will ensure that corrective actions remain effective and that compliance with federal regulations is sustained. VIII. Conclusion Through the implementation of these corrective measures, the University will address the deficiencies identified in Finding 2025-001 and significantly strengthen its internal control environment. These actions will ensure accurate and timely enrollment reporting, uphold the integrity of federal student aid programs, and reinforce the University’s commitment to regulatory compliance and operational excellence. Anticipated Completion Date: September 1, 2026

Finding 2025-001 – Special Tests and Provisions: Enrollment Reporting – Status Change at Program Level Corrective Action Plan I. Overview and Acknowledgment The University acknowledges Finding 2025-001 related to deficiencies in enrollment reporting at the program level under the Pell Grant, Direct Loan, and Federal Family Education Loan (“FFEL”) programs. The University concurs with the finding and recognizes the importance of accurate and timely reporting to the National Student Loan Data System (“NSLDS”) in accordance with federal requirements (OMB No. 1845-0035). The University is committed to strengthening internal controls, enhancing operational procedures, and ensuring full compliance with all enrollment reporting requirements. II. Criteria Institutions participating in federal student aid programs are required to: • Report accurate enrollment information through NSLDS, including enrollment status and program-level data elements. • Ensure that all significant data elements—including enrollment status, program begin date, and enrollment effective date—are accurate as of the reporting date. • Submit enrollment reporting updates at least every 60 days (bi-monthly). • Maintain adequate internal controls to ensure data integrity and compliance with federal regulations. III. Condition The audit identified errors in enrollment reporting for a sample of 25 students, including: • 2 instances of incorrect program enrollment effective date reporting These errors were attributed to administrative oversight and insufficient internal controls governing enrollment reporting processes. IV. Cause Analysis The University has identified the following contributing factors: • Insufficient internal controls and review mechanisms over enrollment status updates • Limited system automation and alert capabilities for tracking status changes • Inadequate staffing resources to manage reporting timelines and data verification • Lack of formalized cross-functional coordination between the Office of the Registrar and reporting entities • Absence of an independent monitoring function to ensure compliance consistency V. Corrective Actions and Implementation Plan The University will implement the following corrective actions to address the identified deficiencies: 1. Establishment of Internal Audit Function • The University will establish a formal Internal Audit function by the start of the next academic year. • This function will have broad authority to oversee compliance, enforce corrective actions, and evaluate internal controls across all relevant departments. • Internal Audit will lead ongoing reviews of enrollment reporting processes and ensure accountability. 2. Process Review and Cross-Functional Collaboration • Internal Audit will coordinate a comprehensive review of enrollment reporting processes involving the Office of the Registrar and the National Student Loan Clearinghouse. • This review will include a structured assessment of strengths, weaknesses, opportunities, and risks (SWOT analysis). • Standard operating procedures (SOPs) will be updated and formally documented. 3. Staffing and Resource Enhancements • The University will enhance staffing within the Office of the Registrar to support enrollment reporting functions. • Additional technological tools and system capabilities will be implemented to provide automated alerts, status tracking, and exception reporting. 4. Implementation of Monitoring and Control Systems • A robust monitoring system will be deployed to: o Track student enrollment status changes in real time o Generate alerts for discrepancies or missing data o Ensure timely submission of required updates to NSLDS • Data validation checkpoints will be integrated prior to submission to ensure accuracy. 5. Strengthening Reporting Protocols • Interim control measures will include the submission of transfer student status reports on a semester basis until full remediation is achieved. • All enrollment updates will undergo a secondary review and certification prior to submission. • A compliance calendar will be implemented to ensure adherence to the 60-day reporting requirement. 6. Training and Accountability Measures • Mandatory training sessions will be conducted for all personnel involved in enrollment reporting. • Training will focus on federal requirements, data accuracy standards, and system utilization. • Performance expectations and accountability metrics will be clearly defined and monitored. VI. Timeline for Implementation • Immediate (0–90 Days): o Initiate staffing enhancements o Implement interim review and validation procedures o Conduct training sessions • Short-Term (90–120 Days): o Deploy monitoring and alert systems o Formalize SOPs and compliance calendar o Begin enhanced reporting protocols • Long-Term (By Start of Next Academic Year): o Fully establish Internal Audit function o Complete comprehensive process review and continuous monitoring framework VII. Monitoring and Ongoing Compliance The Internal Audit function will conduct periodic reviews and report findings for executive leadership. Continuous monitoring will ensure that corrective actions remain effective and that compliance with federal regulations is sustained. VIII. Conclusion Through the implementation of these corrective measures, the University will address the deficiencies identified in Finding 2025-001 and significantly strengthen its internal control environment. These actions will ensure accurate and timely enrollment reporting, uphold the integrity of federal student aid programs, and reinforce the University’s commitment to regulatory compliance and operational excellence. Anticipated Completion Date: September 1, 2026

Explanation of disagreement with audit finding: Prior finding was specific to change to withdrawal status not being timely reported in relation to students who never attended and/or stopped attending. Additional scenarios in this finding, to our knowledge, have not been found in a previous audit. We acknowledge that they fall within the same finding, but the scenarios that fall within the overall finding are not repeats. Action taken in response to finding: WAU acknowledges the importance of effective internal controls in regards to compliance. As a result, the following corrective action steps will be implemented: • Enrollment Date Discrepancies: o The Registrar’s Office will review finding and determine the best course of action to ensure the degree conferral date for a graduate (Effective date per Institutional Record) and the Effective date per NSLDS Campus Record align. After determination of action an SOP will be created. o The Registrar’s Office will create an SOP and add to the withdrawal policy a statement regarding what the effective date will be when students are unofficially withdrawn for not attending and then later submit an official university withdrawal form. o The Registrar’s Office will research the option of continuous enrollment for students who receive a DG and/or Incomplete grade at the end of a term and do not enroll in the next term. Also, the DG and Incomplete policy will be reviewed to determine if the removal of DG and Incomplete deadline needs to be adjusted. • Program Start Date Discrepancies: o The Registrar’s Office will review finding and determine the best course of action to ensure academic program start dates in institutional records align with NSLDS program start dates. After determination of action an SOP will be created. • Missed Enrollment Certification: o See action plan for Enrollment date discrepancies above (bullet 3) • Enrollment Stats discrepancies: o The Registrar will confirm in NSC that all students who graduated but were not enrolled in the term they graduated from are reported as graduated in NSC in a timely manner and work with financial aid to determine the graduation information is recorded timely and accurately in NSLDS as well. After determination of action an SOP will be created. • Inaccurate Institutional Records: o The Registrar’s Office will review finding and determine the best course of action to ensure that students who we send University Withdrawal forms to, upon their request, get withdrawn even if the form is not returned in a timely manner. After determination of action an SOP will be created. Name(s) of the contact person(s) responsible for corrective action: • Team Lead: Registrar (Lynn Zabaleta) • Internal Control Team: Office staff • Senior Management: AVP Enrollment Management (Dirk Whatley) Planned completion date for corrective action plan: June 30, 2026

Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: WAU agrees with the recommendation to update our formal process to identify and maintain an inventory of data, devices, and systems that support or process customer financial aid information. While we currently use the Spiceworks Inventory System to track hardware and software assets and Google Workspace to manage user cloud access and data storage, we acknowledge that a formal, documented inventory process covering all required categories has not yet been fully established. The IT Director has been assigned to develop and document this process within 30 days. We acknowledge this finding and the associated risk arising from the absence of an independent risk assessment. As of March 25, 2026, the University has engaged TeamLogic Cybersecurity to strengthen our managerial, technical, and operational controls and to (1) develop and document a formal, GLBA aligned risk assessment process; (2) conduct annual independent, comprehensive risk assessment of our information systems and data environment; and (3) provide written findings and recommendations. Based on these results, we will implement appropriate safeguards, and institutionalize an annual risk assessment cycle to ensure that risks are consistently identified, assessed, mitigated, and monitored in accordance with GLBA requirements. Name(s) of the contact person(s) responsible for corrective action: Rosalee Pedapudi, IT Director, Information Technology Services Planned completion date for corrective action plan: April 26, 2026

1. Drawdown- Financial Director will authorize drawdown with the AVP of Enrollment reviewing and approving the drawdown. 2. Reconciliation- An SOP will be developed having the Financial Advisor/Pell Grant Officer who manages reconciliation of Pelll, SEOG, and Federal work study. Director financial aid will review and approve reconciliation. For Direct Loans the Direct of Financial aid will prepare the reconciliation to review by the Controller and AVP of Enrollment on a monthly basis. 3. Financial aid Packages- Third party service provider Financial Aid Services (FAS) will complete all financial aid packages with the Director of Financial aid reviewing packaging accuracing by pulling samples of at minimum 25 students for both fall and spring semester. 4. Professional Judgement- An SOP for professional judgment will be created. The Financial aid Director or Pell Grant Officer will prepare the professional judgement. The review and approval to complete by AVP of Enrollment. 5. RT24- Third party service provider (FAS) will prepare RT24 calculations with review and approval by Director of Financial aid and the Associate Vice President of Enrollment. 6. Credit Balances- An SOP will be created to ensure that credit balances are distributed to students within 14 days by verifying enrollment during disbursement. 7. Incentive Compensation – We were unable to verify whether the control to ensure that no incentive compensation is made to employees in the student recruiting and admission, and financial aid departments, is designed and operating effectively. 8. Eligibility – We identified instances in which the Cost of Attendance (COA) used to calculate financial need was inaccurate due to insufficient review and oversight over COA calculations. 9. NSLDS – We noted instances where the University’s records do not match the information shown in the Colleague system, particularly the effective withdrawal dates. Name(s) of the contact person(s) responsible for corrective action: Team Lead: Interim Director of Financial Aid (Alfred Taylor), Director of Student Accounts (Keisha Dublin) ● Internal Control team: Associate Director of Financial Aid (Associate Director of Student Accounts (Arlene Joy Canong), Financial Aid Advisor (Don Lodenquai) ● Senior Management: AVP of Enrollment Management (Dirk Whatley), Controller (Ronald Somervell) ● Financial Aid Services (FAS) Planned Completion Date for Corrective Action Plan: April 26, 2026

Corrective Action Plan Fiscal Year 2025 Finding Number: 2025-001 – Pell Grant Special Tests and Provisions – NSLDS Reporting The District acknowledges the findings related to NSLDS enrollment reporting and has conducted an internal review of processes, systems, and oversight structures contributing to the finding. To ensure compliance with federal reporting requirements, the District will implement the following corrective actions: 1. Enhanced Review Procedures: The District will strengthen internal controls over enrollment reporting by implementing procedures to ensure all enrollment status changes are accurately recorded, reconciled between internal systems and third-party servicer reports, and submitted to NSLDS within required time frames. Additionally, The District is actively restructuring internal systems and workflows within the department to strengthen oversight, improve accuracy, and ensure timely reporting of enrollment status changes. 2. Training: The District recognizes that staff turnover and inconsistent training contributed to the finding. To address this, the District will implement a comprehensive training plan in partnership with the third-party servicer. 3. Monitoring Controls: The District will formally reestablish expectations with its third-party servicer to ensure all contracted services are implemented. Implementation Timeline: • Enhanced review procedures will be implemented immediately. • The District will implement an ongoing comprehensive training plan in partnership with third-party servicer. • Staff will meet with third-party servicer to re-establish expectations and to ensure compliance with federal reporting requirements before fiscal year-end. Responsible Party: Dr. Dywayne B. Hinds, Sr., Area Superintendent, Dr. Jakub Prokop, Director, PTC- Clearwater, and Dr. Jason Shedrick, Director, PTC-St. Petersburg Anticipated Completion Date: June 30, 2026 Dywayne B. Hinds, Sr., Ed.D. Area Superintendent, Area 3