Corrective Action Plans

Views of Responsible Officials and Planned Corrective Actions – University personnel reviewed the four instances identified for untimely NSLDS reporting and determined that neither case resulted from a failed or rejected submission to the National Student Clearinghouse (NSC) or NSLDS. Rather, the timing difference resulted from the enrollment status effective date used for NSC reporting, which did not align with the reporting roster submission cycle. The University reports enrollment information to NSLDS through the National Student Clearinghouse on a regular monthly basis and confirmed through review of NSC acknowledgment and error reports that no transmission errors occurred. To reduce the risk of similar timing differences in the future, the University is working on process improvements in coordination with Banner support, including ensuring backdated drops and withdrawals are processed prior to initial NSC transmissions each term, reviewing the timing of enrollment reporting submissions to improve data capture, strengthening procedures for monitoring post-census backdated status changes, continuing timely review of NSC error reports, reviewing enrollment status calculations for nonstandard coursework, and implementing pre-submission validation procedures to confirm all required status calculation and extract processes have been completed prior to NSC file transmission.

Timely Exit Counseling Notification Finding: The University did not have adequate procedures or review controls to ensure that reports used to identify students requiring exit counseling notifications included all students who withdrew or otherwise ceased to be enrolled at least half-time. As a result, four students did not receive timely notifications regarding exit counseling. Corrective Actions Taken or Planned: FNU will update its exit counseling procedures to ensure that all students who withdraw or otherwise cease to be enrolled at least half-time are identified and timely notified of the exit counseling requirement. Additionally, FNU will implement controls to validate the completeness of reports used for this purpose and establish backup procedures and review controls when key personnel are unavailable. Estimated Completion Date: September 30, 2026. Responsible Personnel: Kaleena Burnett, Director of Financial Aid

Enrollment Reporting Finding: The enrollment statuses in the National Student Loan Data System for students who took a Regular Academic Hiatus were incorrect during the time of their hiatus. Corrective Actions Taken or Planned: FNU changed its reported enrollment status for all students on a regular Academic Hiatus (AH) from “Enrolled” to “Leave of Absence (LOA)” in the National Student Clearinghouse (NSC). Note that both status types indicate an enrolled status per NSC. Also, FNU revised internal procedures to ensure that students on a regular AH were coded properly in the Student Learning Management System with a status that aligned with enrollment reporting requirements for a temporary interruption in study. In September 2025, key personnel at FNU completed comprehensive training with NSC regarding reporting timelines and to set up an automated reporting feed from FNU’s Student Learning Management System. FNU repeated the training again in January 2026 to ensure new staff were educated in the process and provide a consistent understanding of the updated procedures. As a result of these actions, FNU demonstrated improved consistency in reporting and timeliness. In addition to these steps, it was determined during 2026 that students submitting late notice to withdraw require a manual update in NSC. The automated data feed does not retroactively capture changes. Training is underway to ensure the offices of Registration and Financial Aid are aware of the file feed limitation and implement a process to update students with approved exceptions to late withdraw. Estimated Completion Date: August 31, 2026. Responsible Personnel: Jessalyn Cornett, Director of Academic Records & Registrar

Finding 2026-001 Personnel Responsible for Corrective Action: Deborah Vinnola, Registrar Anticipated Completion Date: September 30, 2027 Corrective Action Plan: The Office of the Registrar has put into place a more detailed corrective action plan regarding the finding of delayed enrollment and non-enrollment reporting to NSLDS through NSC. The Office of the Registrar has adjusted the Degree Verify submission from every 45 days to every 30 days to NSC to ensure graduation dates are reported in a more timely fashion for NSLDS within the required 60 days for financial aid. Starting Summer 2026, the Office of the Registrar has begun inactivating academic programs for students who have not had registration activity within the last two to three academic years to ensure that they are not reported as enrolled to NSC/NSLDS. NSC Enrollment Reporting will continue to be submitted every 30 days and the Office of the Registrar has worked to review the reporting criteria using terms and not semesters to better report active enrollment in current courses. The Ellucian Graduation Application form and process is in the final stages of testing which will eliminate completely the need to add a pseudo course with a future date after the student’s current program has been inactivated or graduated. The Office of the Registrar will be more proactive with the colleges for identifying students who have not graduated within the six year (undergraduate), four year (graduate) and certificate time frames by working with the appropriate dean’s offices. This should eliminate those students who have completed their coursework; close to completing their coursework but were never reviewed by their advisor/program for graduation. Since Regis uses the end date of the last course completed, the Office of the Registrar will work with advising units to review the lists to increase a better reporting of degree completion.

Corrective Action Plan Management will ensure that we apply the correct indirect cost rate to future agreements. New management is in place at TPFC who understand the indirect cost rate. Timeline for Implementation of Corrective Action Plan July 1, 2025 Contact Person Johanna Dunleavy, CFO

11. 2025-011 – Special Tests and Provisions - Verification – Material Weakness in Internal Controls over Compliance and Instance of Noncompliance Recommendation: The auditors recommend the University implement the proper controls to ensure that verification of students is completed accurately and according to the applicable guidance. Planned corrective actions: Heritage University agrees with the recommendation and is strengthening its processes and internal controls surrounding student verification. As part of the University's broader efforts to build capacity within the Financial Aid department, management is reviewing existing verification procedures to ensure requirements are clearly documented, consistently applied, and aligned with applicable federal guidance. The University is establishing clearer ownership of verification responsibilities, defined timelines and checkpoints for completion, and appropriate review procedures to ensure required documentation is obtained and reviewed before verification is considered complete and aid is disbursed. Management will also continue to strengthen staff training and supervisory review and will periodically review procedures as federal requirements change. These efforts are intended to provide greater consistency, accountability, and oversight while ensuring verification requirements are completed accurately and timely. Name of Responsible Party: Nancy Benavidez, Sagrario Armenta Jimenez Anticipated completion date: Most of the clean-up will happen during Fiscal Year 2026-2027. But this will always remain a project for continuous improvement.

10. 2025-010 – Reporting – Material Weakness in Internal Controls over Compliance and Instance of Noncompliance Recommendation: The auditors recommend the University implement the proper controls to ensure that disbursements are accurately applied to student accounts and reported to COD accurately and timely. Planned corrective actions: Heritage University agrees with the recommendation and is strengthening its controls over the disbursement and reporting of Title IV funds. Management is reviewing the processes between Financial Aid and Student Accounts to ensure disbursements are accurately applied to student accounts and reported to COD completely, accurately, and within required timeframes. As part of this work, the University is establishing clearer ownership, defined timelines, and documented checkpoints for reviewing and reconciling disbursement activity between the financial aid system, student accounts, and COD. Responsibilities will be assigned for identifying and resolving discrepancies and ensuring required corrections are completed timely. The University will also incorporate documented review and reconciliation procedures into its Financial Aid processes and continue to evaluate staffing, training, system access, and workload to ensure employees have the capacity and resources necessary to consistently perform these compliance responsibilities. Name of Responsible Party: Nancy Benavidez, Sagrario Armenta Jimenez Anticipated completion date: Most of the clean-up will happen during Fiscal Year 2026-2027. But this will always remain a project for continuous improvement.

6. 2025-006 – Eligibility – Material Weakness in Internal Controls over Compliance and Material Noncompliance Recommendation: The auditors recommend the University implement the proper controls to ensure the determination of student eligibility for Title IV aid is appropriate and supported. Planned corrective actions: Heritage University agrees with the recommendation and is strengthening its processes and internal controls surrounding the determination and documentation of student eligibility for Title IV aid. As part of the University's ongoing efforts to build capacity within the Financial Aid department, management is reviewing existing eligibility procedures to clearly define responsibilities, required documentation, and appropriate review checkpoints. The University will establish processes to ensure eligibility requirements are consistently evaluated, adequately supported, and documented prior to the disbursement of Title IV funds. Management will also continue to evaluate staff training, system access, workload, and supervisory review to ensure employees responsible for determining and reviewing eligibility have the knowledge, resources, and capacity necessary to consistently perform these responsibilities. These efforts will be incorporated into documented Financial Aid procedures and periodically reviewed to ensure the controls are operating as intended. Name of Responsible Party: Nancy Benavidez, Sagrario Armenta Jimenez Anticipated completion date: Most of the clean-up will happen during Fiscal Year 2026-2027. But this will always remain a project for continuous improvement.

5. 2025-005 – Special Tests and Provisions – Return of Title IV Funds (R2T4) – Material Weakness in Internal Controls over Compliance and Material Noncompliance Recommendation: The auditors recommend the University review their policies and procedures to ensure all withdrawals, including unofficial withdrawals where the student does not give formal notification can be identified and accurately evaluated. They also recommend a control be put in place to ensure the calculations and return of funds are performed accurately and timely. Planned corrective actions: Heritage University agrees with the recommendation and is reviewing its withdrawal and Return of Title IV (R2T4) processes to strengthen both the timely identification of student withdrawals and the accurate and timely completion of required calculations and return of funds. The University is reviewing the processes and communication between Financial Aid, the Registrar, Academic Affairs, and other appropriate departments to ensure both official and unofficial withdrawals are identified timely and the information necessary to evaluate a student's withdrawal date is appropriately documented and communicated. Within Financial Aid, responsibilities and timelines will be clearly assigned for reviewing withdrawal information, completing required R2T4 calculations, and returning funds within applicable deadlines. The University will also establish documented review checkpoints to verify that calculations are accurate, required documentation is maintained, and returns are completed timely. As part of its broader efforts to build capacity within Financial Aid, management will continue to evaluate staffing, training, system access, and internal procedures to ensure these compliance responsibilities have clear ownership and appropriate oversight. Name of Responsible Party: Nancy Benavidez, Sagrario Armenta Jimenez Anticipated completion date: Most of the clean-up will happen during Fiscal Year 2026-2027. But this will always remain a project for continuous improvement.

3. 2025-003 – Special Tests and Provisions – Enrollment Reporting – Material Weakness in Internal Controls over Compliance and Instance of Noncompliance Recommendation: – The auditors recommend the University follow and enhance existing policies to ensure all student changes in status are identified timely and submitted accurately within the required time frame. They also recommend the University establish a formal internal monitoring control whereby a designated individual with NSLDS access, on a sample basis, spot checks the status updates on NSLDS so to internally audit the National Student Clearinghouse submissions. Planned corrective actions: Heritage University agrees with the recommendation and is strengthening its enrollment reporting and monitoring processes. The University is focused on building capacity within the Financial Aid department, clearly assigning responsibility for enrollment reporting activities, and establishing specific timelines and checkpoints to ensure required status changes are identified, reviewed, and submitted within required timeframes. The University is also reviewing the coordination and flow of information between Financial Aid, the Registrar, and other departments involved in student status changes to ensure responsibilities and handoffs are clearly understood. As part of the enhanced monitoring process, designated staff with appropriate NSLDS access will perform periodic spot checks of student enrollment status information to verify that National Student Clearinghouse submissions are accurately reflected in NSLDS. These reviews will be documented, and identified discrepancies will be researched and corrected timely. The Enrollment Alliance group continues to meet on a daily basis. Some of the areas of improvement that have been identified in this group are around system development. We are currently working with IT to explore the options available to support our staff and our processes through our software. Management will continue to evaluate staffing, training, access, and procedures to ensure the department has the capacity and accountability necessary to consistently complete these required compliance activities. Name of Responsible Party: Nancy Benavides, Sagrario Armenta Jimenez Anticipated completion date: Heritage University anticipates implementing the enhanced enrollment reporting procedures and formal NSLDS monitoring controls during Fiscal Year 2026–2027. Once implemented, the monitoring and reconciliation process will continue as an ongoing internal compliance control.

Federal Program / Assistance Listing Number (ALN) 84.268, 84.063, 84.007, 84.033 Finding Reference Number 2025-019 1. Finding Summary The auditor determined that the institution did not properly notify students and employees of the required annual security report. As a result, the institution could not demonstrate compliance with federal requirements governing campus security policies and crime statistics. 2. Management's Position Management agrees with the finding. Management Explanation Management agrees with the finding and acknowledges that while the information is posted to the institution's website, a campus-wide notification was not sent out in accordance with federal requirements. 3. Root Cause Analysis The exception was caused by insufficient procedures for distributing the data, along with the lack of formal sign-off one the completed action. 4. Corrective Action(s) Management will implement a formal management sign-off on the notification of the required annual security report, which will include maintaining documentation of the notification submission. The next required annual security report is due October 1, 2026. Description of Corrective Actions The institution has added a required supervisory review to verify timely notification is given to students and employees to ensure ongoing compliance and consistent documentation of annual campus safety and fire security disclosure requirements. 5. Risk Mitigation (Required - Even if Disagreeing) These corrective actions will mitigate the risk of noncompliance with annual campus safety and fire security disclosure requirements and ensure students and employees have adequate information. 6. Responsible Party • Office/Department: Office of Financial Aid • Title of Responsible Official: Director of Financial Aid • Name (optional): ____________ _ 7. Implementation Timeline • Corrective action implemented: D Yes ~ No • If not fully implemented, expected completion date: October 1, 2026 8. Status of Corrective Action (For Prior-Year or Repeat Findings) D Fully implemented D Partially implemented D Not yet implemented Evidence of Implementation In progress, evidence is not yet available. 9. Monitoring and Sustainability The corrective actions will be monitored through ongoing supervisory review to confinn required documentation is obtained and information is shared. These practices will be sustained through standardized review procedures and continued oversight to ensure long-term compliance.

Federal Program / Assistance Listing Number (ALN) 84.268, 84.063, 84.007, 84.033 Finding Reference Number 2025-018 1. Finding Summary The auditor determined that the institution did not consistently obtain or maintain documentation confirming that required Direct Loan entrance and exit counseling was completed for applicable borrowers. As a result, the institution could not demonstrate compliance with federal Direct Loan counseling and Title IV record retention requirements. 2. Management's Position Management agrees with the finding. Management Explanation Management agrees with the finding and acknowledges that documentation of required Direct Loan entrance and exit counseling was not consistently obtained or maintained in student files in accordance with federal requirements. 3. Root Cause Analysis The root cause of this finding resulted from the absence of a formal process to verify completion of entrance and exit counseling, failure to reconcile COD counseling completion reports with student records, and insufficient internal controls to prevent loan disbursement or separation processing without required counseling documentation. 4. Corrective Action(s) Management has implemented standardized checklists and workflows, added secondary review, provided additional training to staff, and implemented periodic internal monitoring. Description of Corrective Actions The institution has implemented standardized checklists and workflows to ensure required Direct Loan entrance and exit counseling is completed and documented. A supervisory or secondary review has been added prior to loan processing or student separation, and periodic internal monitoring and quality assurance reviews have been established to verify ongoing compliance with federal counseling and documentation requirements. Implementing the revised process has been delayed due to personnel changes. Additionally, the University has contracted with Blue Icon Advisors, a National Association of Student Financial Aid Administrators' financial aid consulting service, to review the review process and assist with implementation. Finally, the University is investing in a new cloud-based Enterprise Resource Planning (ERP) software designed for higher education institutions, Ellucian Colleague, which should automate notifications and account flags for missing documents. 5. Risk Mitigation (Required - Even if Disagreeing) These corrective actions mitigate the risk of disbursing Direct Loan funds or processing student separations without required counseling by strengthening documentation verification, supervisory oversight, and file review processes. Ongoing monitoring and quality assurance reviews further reduce compliance risk and support sustained adherence to federal Direct Loan counseling requirements. 6. Responsible Party • Office/Department: Office of Financial Aid • Title of Responsible Official: Director of Financial Aid • Name (optional): ____________ _ 7. Implementation Timeline • Corrective action implemented: D Yes 1:8:Nl o • If not fully implemented, expected completion date: June 30, 2027 8. Status of Corrective Action (For Prior-Year or Repeat Findings) D Fully implemented D Partially implemented 1:8:Nl ot yet implemented Evidence of Implementation In progress, evidence is not yet available. 9. Monitoring and Sustainability Supervisory review and periodic internal monitoring will be conducted to ensure loan counseling is obtained timely. Continued staff training, standardized workflows, and quality assurance reviews will be sustained to support long-term compliance and promptly identify and address any documentation deficiencies.

Federal Program / Assistance Listing Number (ALN) 84.268, 84.063, 84.007, 84.033. Finding Reference Number 2025-017 1. Finding Summary The auditor identified one (1) of sixty (60) students selected for student eligibility testing who was not awarded the full amount of Federal Pell Grant funds for which the student was eligible. As a result, the institution could not demonstrate compliance with Title IV eligibility requirements, creating a risk that Federal Pell Grants funds could be awarded in an incorrect amount. 2. Management's Position Management agrees with the finding. Management Explanation Management agrees with the finding and acknowledges that the university should strengthen its procedures for reviewing student hours to ensure Federal Pell Grant funds are awarded in correct amount. 3. Root Cause Analysis The root cause of this finding resulted from an isolated oversight in the enrollment intensity review process and management will work to provide additional training to staff for review procedures. 4. Corrective Action(s) Management will provide additional training to staff. Description of Corrective Actions Management will provide additional training for staff in the Office of Financial Aid. Additionally, management will review the exception and award any Title IV aid determined to be underawarded. The University is also investing in a new cloud-based Enterprise Resource Planning (ERP) software designed for higher education institutions, Ellucian Colleague, which should automate the enrollment intensity and awarding process. 5. Risk Mitigation (Required - Even if Disagreeing) These corrective actions mitigate the risk of aid being awarded incorrected based on enrollment intensity by strengthening and automating review procedures and ensuring staff are adequately trained to complete and document the review. 6. Responsible Party • Office/Department: Office of Financial Aid • Title of Responsible Official: Director of Financial Aid • Name (optional): ____________ _ 7. Implementation Timeline • Corrective action implemented: D Yes IZI No • If not fully implemented, expected completion date: June 30, 2027 8. Status of Corrective Action (For Prior-Year or Repeat Findings) D Fully implemented D Partially implemented D Not yet implemented Evidence of Implementation In progress, evidence is not yet available. 9. Monitoring and Sustainability Continued staff training and immediate correction of any isolated exceptions including awarding/returning Title IV aid, if applicable.

Federal Program / Assistance Listing Number (ALN) 84.268, 84.063, 84.007, 84.033 Finding Reference Number 2025-016 1. Finding Summary The auditor identified one (1) of sixty ( 60) students selected for student eligibility testing who received Federal Direct Loans in excess of the student's applicable aggregate loan limit. As a result, the institution could not demonstrate compliance with Title IV eligibility requirements, creating a risk that Direct Loans could be originated and disbursed in excess oflimits. 2. Management's Position Management agrees with the finding. Management Explanation Management agrees with the finding and acknowledges that the university should strengthen its procedures for reviewing student loan history prior to awarding and disbursing Federal Direct Loans. 3. Root Cause Analysis The root cause of this finding resulted from an isolated oversight in the student loan history review process and management will work to provide additional training to staff for review procedures. 4. Corrective Action(s) Management will provide additional training to staff. Description of Corrective Actions Management will provide additional training for staff in the Office of Financial Aid. Additionally, management will review the exception and return any Title IV aid determined to be improperly disbursed. 5. Risk Mitigation (Required - Even if Disagreeing) These corrective actions mitigate the risk of aid being awarded in excess of applicable aggregate loan limits by strengthening loan history review procedures and ensuring staff are adequately trained to complete and document the review. 6. Responsible Party • Office/Department: Office of Financial Aid • Title of Responsible Official: Director of Financial Aid • Name (optional): ____________ _ 7. Implementation Timeline • Corrective action implemented: D Yes ~ No • If not fully implemented, expected completion date: September 30, 2026 8. Status of Corrective Action (For Prior-Year or Repeat Findings) D Fully implemented D Partially implemented D Not yet implemented Evidence of Implementation In progress, evidence is not yet available. 9. Monitoring and Sustainability Continued staff training and immediate correction of any isolated exceptions including the return of Title IV aid, if applicable.

Federal Program / Assistance Listing Number (ALN) 84.268, 84.063, 84.007, 84.033 Finding Reference Number 2025-015 1. Finding Summary The auditor identified one (1) of sixty (60) students selected for student eligibility testing whose ISIR maintained did not reflect the appropriate dependency model. As a result, the institution could not demonstrate compliance with Title IV eligibility requirements, creating a risk that aid could be awarded based on incomplete or unsupported eligibility information. 2. Management's Position Management agrees with the finding. Management Explanation Management agrees with the finding and acknowledges that the university should strengthen its procedures for reviewing ISIR transactions prior to awarding and disbursing Title IV aid. 3. Root Cause Analysis The root cause of this finding resulted from an isolated oversight in the ISIR review process and management will work to provide additional training to staff for ISIR review procedures. 4. Corrective Action(s) Management will provide additional training to staff. Description of Corrective Actions Management will provide additional training for staff in the Office of Financial Aid. Additionally, management will review the exception and return any Title IV aid determined to be improperly disbursed. 5. Risk Mitigation (Required - Even if Disagreeing) These corrective actions mitigate the risk of aid being awarded based on incomplete or unsupported eligibility information by strengthening ISIR review procedures and ensuring staff are adequately trained to complete ISIR reviews. 6. Responsible Party • Office/Department: Office of Financial Aid • Title of Responsible Official: Director of Financial Aid • Name (optional): ------------- 7. Implementation Timeline • Corrective action implemented: D Yes IZI No • If not fully implemented, expected completion date: September 30, 2026 8. Status of Corrective Action (For Prior-Year or Repeat Findings) D Fully implemented D Partially implemented D Not yet implemented Evidence of Implementation In progress, evidence is not yet available. 9. Monitoring and Sustainability Continued staff training and immediate correction of any isolated exceptions including the return of Title IV aid, if applicable.

Federal Program / Assistance Listing Number (ALN) 84.268, 84.063, 84.007, 84.033 Finding Reference Number 2025-014 1. Finding Summary The auditor determined that the institution did not accurately report recipient counts for students receiving Pell Grants on the FISAP in accordance with federal reporting requirements. As a result, the institution could not demonstrate compliance with Title IV reporting obligations under its Program Participation Agreement, increasing the risk of inaccurate federal reporting and potential compliance findings. 2. Management's Position Management agrees with the finding. Management Explanation Management agrees with the finding and acknowledges that recipient counts reported on the FISAP were not consistently accurate in accordance with federal reporting requirements. 3. Root Cause Analysis The root cause of this finding resulted from failure to reconcile ISIR income data to the summary totals reported on the FISAP, use of incorrect or incomplete datasets when preparing recipient counts, and insufficient supervisory review of the FIS AP reporting process. 4. Corrective Action(s) Management has added secondary review, implemented periodic internal monitoring, and added system configuration limitations. Description of Corrective Actions The institution has implemented a supervisory or secondary review to validate FISAP data and recipient counts prior to submission, and established periodic internal monitoring and quality assurance reviews to ensure accuracy and completeness of reported information. Additionally, system configuration limitations impacting data extraction and reconciliation have been identified and addressed through revised reporting procedures and compensating manual controls. The next FISAP submission is due October 1, 2026. 5. Risk Mitigation (Required - Even if Disagreeing) These corrective actions mitigate the risk of inaccurate FISAP reporting by strengthening oversight, improving data validation, and establishing compensating controls to address system limitations. Ongoing monitoring and quality assurance reviews further reduce compliance risk and support accurate and reliable federal reporting. 6. Responsible Party • Office/Department: Office of Financial Aid • Title of Responsible Official: Director of Financial Aid • Name (optional): ____________ _ 7. Implementation Timeline • Corrective action implemented: D Yes 18N1 o • If not fully implemented, expected completion date: December 31, 2026 8. Status of Corrective Action (For Prior-Year or Repeat Findings) D Fully implemented D Partially implemented 181N ot yet implemented Evidence of Implementation In progress, evidence is not yet available. 9. Monitoring and Sustainability Supervisory review and periodic internal monitoring will be conducted each reporting cycle to ensure FISAP recipient counts are accurate, complete, and supported by reconciled data. Continued use of quality assurance reviews, documented procedures, and compensating controls for system limitations will support long-term compliance and timely identification and correction of reporting discrepancies.

Federal Program/ Assistance Listing Number (ALN) 84.268, 84.063, 84.007, 84.033 Finding Reference Number 2025-013 1. Finding Summary The auditor determined that the institution did not consistently report accurate and timely student enrollment information to NSLDS in accordance with federal requirements. As a result, the institution could not demonstrate full compliance with enrollment reporting regulations, increasing the risk of incorrect loan status reporting and potential impacts to borrower eligibility and repayment. 2. Management's Position Management agrees with the finding. Management Explanation Management agrees with the finding and acknowledges that student enrollment information was not consistently reported accurately and timely to NSLDS in accordance with federal reporting requirements. 3. Root Cause Analysis The root cause of this finding resulted from inadequate monitoring procedures to ensure timely and accurate updates and reconciliation of enrollment status changes between the Registrar's system and the NSLDS reporting system. 4. Corrective Action( s) Management has added secondary review and implemented periodic internal monitoring. Description of Corrective Actions The institution has implemented a supervisory or secondary review to verify the accuracy and timeliness of enrollment status updates prior to submission to NSLDS. In addition, periodic internal monitoring and quality assurance reviews have been established to ensure ongoing compliance and timely reconciliation of enrollment changes between institutional systems and NSLDS. 5. Risk Mitigation (Required - Even if Disagreeing) These corrective actions reduce the risk of inaccurate or untimely NSLDS reporting by strengthening oversight and ensuring enrollment changes are reviewed and reconciled before submission. Ongoing monitoring and quality assurance reviews further mitigate compliance risk and support sustained adherence to federal enrollment reporting requirements. 6. Responsible Party • Office/Department: Office of the Registrar • Title of Responsible Official: Registrar • Name (optional): ____________ _ 7. Implementation Timeline • Corrective action implemented: ~ Yes D No • If not fully implemented, expected completion date: 8. Status of Corrective Action (For Prior-Year or Repeat Findings) ~ Fully implemented D Partially implemented D Not yet implemented Evidence of Implementation Evidence of submissions post April 2026. 9. Monitoring and Sustainability Management will conduct ongoing supervisory review and periodic internal monitoring to ensure enrollment status changes are accurately updated and reported to NSLDS in a timely manner. Continued reconciliation between the Registrar's system and NSLDS, along with sustained quality assurance reviews, will support long-term compliance and prompt identification of any reporting discrepancies.

Federal Program/ Assistance Listing Number (ALN) 84.268, 84.063, 84.007, 84.033 Finding Reference Number 2025-012 1. Finding Summary The auditor determined that the institution disbursed Pell Grant funds more than 10 days prior to the first day of classes, in violation of federal Title IV disbursement timing requirements. As a result, the institution could not demonstrate compliance with applicable federal regulations governing the timing of Pell Grant disbursements. 2. Management's Position Management agrees with the finding. Management Explanation Management agrees with the finding and acknowledges that Pell Grant funds were disbursed earlier than permitted under federal Title IV disbursement timing requirements due to a miscalculation of the days. 3. Root Cause Analysis The root cause of this finding resulted from by inaccurate or prematurely scheduled disbursement dates, limited coordination between the Financial Aid and Business Offices on the approved disbursement calendar, and insufficient controls to ensure Pell Grant funds were released in accordance with federal timing requirements. 4. Corrective Action(s) Management will implement a standardized calendar of disbursement dates annually based on the academic calendar. Description of Corrective Actions Management will prepare an annual disbursement calendar based on the academic calendar, which will be reviewed by both the Business Office and Office of Financial Aid to ensure compliance to federal Title IV disbursement timing requirements. 5. Risk Mitigation (Required - Even if Disagreeing) These corrective actions reduce the risk of early federal disbursements by strengthening oversight, implementing a disbursement calendar, and reinforcing staff understanding of federal timing requirements. 6. Responsible Party • Office/Department: Business Office • Title of Responsible Official: Senior Accountant • Name (optional): ____________ _ 7. Implementation Timeline • Corrective action implemented: ~ Yes D No • If not fully implemented, expected completion date: 8. Status of Corrective Action (For Prior-Year or Repeat Findings) ~ Fully implemented D Partially implemented D Not yet implemented Evidence of Implementation Academic Year 2026-2027 Disbursement Calendar. 9. Monitoring and Sustainability The University will continue to prepare a disbursement calendar annually before any new year disbursements are made. 900

Federal Program/ Assistance Listing Number (ALN) 84.268, 84.063, 84.007, 84.033 Finding Reference Number 2025-011 1. Finding Summary The auditor determined that the institution did not consistently obtain and document required verification information prior to disbursing Title IV federal student aid for students selected for verification. As a result, the institution could not demonstrate compliance with federal verification requirements, increasing the risk that Title IV funds were disbursed before verification was completed. 2. Management's Position Management agrees with the finding. Management Explanation Management agrees with the finding and acknowledges that required verification documentation was not consistently obtained and documented prior to the disbursement of Title IV federal student aid for students selected for verification. 3. Root Cause Analysis The root cause of this finding resulted from weaknesses in verification monitoring procedures and inadequate review controls, which allowed Title IV aid to be packaged and disbursed prior to the completion and documentation of required verification. 4. Corrective Action(s) Management has implemented standardized checklists and workflows, added secondary review, provided additional training to staff, and implemented periodic internal monitoring. Description of Corrective Actions Management has implemented enhanced verification workflows and system controls to prevent packaging or disbursement of Title IV aid until verification is fully completed. A mandatory supervisory review has been established, and targeted staff training has been conducted to reinforce verification requirements. Periodic internal monitoring and quality assurance reviews will be performed to ensure ongoing compliance. 5. Risk Mitigation (Required - Even if Disagreeing) The corrective actions mitigate the risk of disbursing Title IV funds prior to verification completion by strengthening verification workflows, system controls, and supervisory review. Targeted staff training and ongoing internal monitoring further reduce the likelihood of premature disbursements and support sustained compliance with federal verification requirements. 6. Responsible Party • Office/Department: Office of Financial Aid • Title of Responsible Official: Director of Financial Aid • Name (optional): ____________ _ 7. Implementation Timeline • Corrective action implemented: ~ Yes D No • If not fully implemented, expected completion date: 8. Status of Corrective Action (For Prior-Year or Repeat Findings) ~ Fully implemented D Partially implemented D Not yet implemented Evidence of Implementation Evidence of verifications completed in May through July 2026. 9. Monitoring and Sustainability Management will conduct regular supervisory and periodic internal reviews of verification files to confirm that required documentation is completed prior to Title IV packaging and disbursement. Continued staff training, maintained system controls, and standardized verification procedures will be sustained to ensure long-term compliance and timely identification of any deficiencies.

Federal Program/ Assistance Listing Number (ALN) 84.268, 84.063, 84.007, 84.033 Finding Reference Number 2025-010 1. Finding Summary The auditor identified that one (1) out of sixty (60) sampled students lacked required docwnentation of high school completion or an allowable alternative in their files, yet were awarded Title IV federal student aid. As a result, the institution could not demonstrate compliance with Title IV student eligibility requirements, creating a risk of disbursement to ineligible students. 2. Management's Position Management agrees with the finding. Management Explanation Management agrees with the finding and acknowledges that required documentation of high school completion or an allowable alternative was not consistently maintained in student files prior to the disbursement of Title IV federal student aid. 3. Root Cause Analysis The root cause of this finding was insufficient supervisory review of student eligibility documentation and decentralized documentation practices that resulted in inconsistent collection and retention of required records. 4. Corrective Action( s) Management has implemented standardized checklists and workflows, added secondary review, enhanced system controls, and implemented periodic internal monitoring. Description of Corrective Actions The institution has taken corrective action to strengthen compliance with Title IV student eligibility requirements related to documentation of high school completion. Management has implemented standardized eligibility checklists and documented workflows to ensure required documentation is collected and verified prior to awarding or disbursing federal student aid. A mandatory supervisory or secondary review has been added to confirm eligibility and documentation completeness before processing or disbursement occurs. In addition, system controls within the Student Information System (SIS), financial aid software, and document management systems have been enhanced to require receipt and retention of acceptable high school completion documentation before Title IV funds can be awarded. Targeted staff training has been conducted to reinforce federal eligibility requirements, institutional procedures, and documentation standards. To ensure ongoing compliance, the institution has established periodic internal monitoring and quality assurance reviews of student files to verify documentation accuracy and consistency. These measures are designed to prevent recurrence of the finding and support sustained compliance with federal regulations. 5. Risk Mitigation (Required - Even if Disagreeing) The implemented corrective actions mitigate the risk of awarding or disbursing Title IV funds to ineligible students by ensuring that high school completion documentation is collected, verified, and retained prior to aid processing. Standardized workflows, enhanced system controls, supervisory review, targeted staff training, and ongoing internal monitoring collectively strengthen compliance oversight, reduce documentation errors, and promote consistent adherence to federal student eligibility requirements. 6. Responsible Party • Office/Department: Office of Admissions • Title of Responsible Official: Director of Admissions • Name (optional): ____________ _ 7. Implementation Timeline • Corrective action implemented: 181Y es D No • If not fully implemented, expected completion date: 8. Status of Corrective Action (For Prior-Year or Repeat Findings) 181F ully implemented D Partially implemented D Not yet implemented Evidence of Implementation Evidence of high school completion for students. 9. Monitoring and Sustainability Management will conduct periodic internal reviews and quality assurance checks of student eligibility files to confirm that required high school completion documentation is consistently obtained and maintained prior to Title IV disbursement. Supervisory reviews, ongoing staff training, and continued use of standardized workflows and system controls will be sustained to reinforce compliance, identify issues timely, and ensure long-term adherence to federal Title IV eligibility requirements.

Federal Program / Assistance Listing Number (ALN) 84.268, 84.063, 84.007, 84.033. Finding Reference Number 2025-009 1. Finding Summary The auditor identified that five (5) out of sixty (60) sampled students had Title IV-created credit balances that remained on their accounts for more than 14 days without being released to the student or parent. 2. Management's Position Management agrees with the finding. Management Explanation Management agrees with the finding and acknowledges that the identified condition resulted from the system not pulling credit balances per semester. 3. Root Cause Analysis The root cause was the absence of the system not pulling credit balances per semester. Therefore, it is a manual process to verify if the current semester aid creates a refund for current semester charges when a balance from a prior semester is rolling forward. 4. Corrective Action(s) Management has enhanced system controls and implemented periodic internal monitoring. Description of Corrective Actions To address this finding and prevent recurrence, the University is performing weekly reviews of all student accounts that had aid processed during that week. This review is important because all statements are reviewed even if a credit balance is not showing to identify if the aid for the period creates a credit for the semester despite a beginning balance. Further, the University is transitioning to a new accounting system which will identify credit by term. The new system, Colleague, which will automate the process, will be implemented in approximately 18 months. 5. Risk Mitigation (Required - Even if Disagreeing) The institution recognizes the importance of mitigating compliance risk in this area. Accordingly, the corrective actions described above are designed to timely identify student accounts with a refundable credit balance and future audit findings. 6. Responsible Party • Office/Department: Business Office • Title of Responsible Official: Senior Accountant • Name (optional): ____________ _ 7. Implementation Timeline Manual corrective actions have been implemented and are ongoing as part of standard operating procedures. The automated process is anticipated to be fully in place within 18 months once the University transitions to the Colleague system. • Corrective action implemented: IZI Yes D No • If not fully implemented, expected completion date: Action is fully implemented, but will transition to a new automated process at a later date. 8. Status of Corrective Action (For Prior-Year or Repeat Findings) IZI Fully implemented D Partially implemented D Not yet implemented Evidence of Implementation An example can be provided for a student with a balance who received a refund for the current semester despite not showing a credit balance. 9. Monitoring and Sustainability The University will continue its manual review process until it can be automated.

Federal Program / Assistance Listing Number (ALN) 84.268, 84.063, 84.007, 84.033 Finding Reference Number 2025-008 1. Finding Summary The auditor identified three (3) instances in which the University did not return unearned Title IV funds within the required 45-day timeframe following a student's withdrawal, with the return occurring significantly after the institution's date of determination and one (1) instance in which proper supporting documentation was not maintained. 2. Management's Position Management agrees with the finding. Management Explanation Management agrees with the finding and concurs that the return of unearned Title IV funds must occur within the required regulatory timeframe. The University recognizes the importance of timely Return of Title IV processing and is committed to strengthening internal controls, oversight, and coordination to ensure future compliance. "3. Root Cause Analysis The root cause was the absence of a formal monitoring and tracking process for Return of Title IV (R2T4) obligations, combined with limited supervisory oversight and insufficient coordination between the Office of Financial Aid, the Business Office, and Student Retention. These factors resulted in delayed identification of withdrawals and untimely processing ofrequired Title IV fund returns. 4. Corrective Action(s) Management is working to implement standardized workflows and periodic internal monitoring. Description of Corrective Actions To address this finding and prevent recurrence, the University has centralized oversight of the Return of Title IV (R2T4) process by assigning responsibility to the Director of Financial Aid and implementing a formal tracking and monitoring system to ensure all returns are completed within the required 45-day timeframe. The Director of Financial Aid now collaborates with Student Retention to receive prompt notification of student withdrawals. Once funds are removed from the student account for R2T4, the Business Office returns the funds within 3 days. In addition, supervisory review procedures have been established to verify the accuracy and timeliness ofR2T4 calculations and returns, strengthening internal controls and ensuring ongoing compliance with federal regulations. Implementing the revised process has been delayed due to personnel changes. Additionally, the University has contracted with Blue Icon Advisors, a National Association of Student Financial Aid Administrators' financial aid consulting service, to review the R2T4 process and assist with implementation. 5. Risk Mitigation (Required - Even if Disagreeing) The University recognizes the importance of proactively managing regulatory risk related to the Return of Title IV process. The corrective actions implemented are intended to improve the timely identification of student withdrawals, strengthen oversight ofR2T4 calculations and returns, and enhance coordination among responsible offices, thereby reducing the risk of delayed returns, regulatory exposure, and future audit findings. 6. Responsible Party • Office/Department: Office of Financial Aid • Title of Responsible Official: Financial Aid Director • Name (optional): ____________ _ 7. Implementation Timeline • Corrective action implemented: D Yes ~ No • If not fully implemented, expected completion date: December 31, 2026 8. Status of Corrective Action (For Prior-Year or Repeat Findings) D Fully implemented D Partially implemented ~ Not yet implemented Evidence of Implementation In progress, evidence is not yet available. 9. Monitoring and Sustainability The University will ensure ongoing compliance by conducting routine internal reviews of Return of Title IV activity, including verification of withdrawal notifications, calculation dates, and return confirmations. R2T4 tracking reports and supervisory oversight will be used to monitor timeliness and accuracy, and procedures will be reinforced through continued staff training and management review to support long-term sustainability.

Federal Program/ Assistance Listing Number (ALN) 84.268, 84.063, 84.007, 84.033 Finding Reference Number 2025-007 1. Finding Summary The auditor found that the University submitted unreconciled expenditure data on the FISAP for the Federal Pell Grant, Federal Work-Study, and Supplemental Educational Opportunity Grant programs, with reported amounts not aligning to internal records, the general ledger, or federal systems. This condition reflects weaknesses in reconciliation timeliness and oversight and increases the risk of inaccurate federal reporting. 2. Management's Position Management agrees with the finding. Management Explanation Management agrees with the finding and acknowledges the submission of unreconciled expenditure data within the Fiscal Operations Report and Application to Participate (FISAP). Management concurs that all Title IV expenditures must be fully reconciled to internal records, federal systems, and the general ledger prior to year-end federal reporting to ensure accuracy and compliance with federal requirements. 3. Root Cause Analysis Office of Fiscal Affairs The root cause was a combination of insufficient supervisory review and training gaps related to Title IV reconciliation and FISAP reporting requirements. These conditions resulted in delays in completing final reconciliations, inconsistent coordination between the Office of Financial Aid and the Business Office, and the submission of federal reports without documented confirmation that expenditures reconciled to internal records and federal systems. 4. Corrective Action(s) Management is working to implement standardized workflows and periodic internal monitoring. Description of Corrective Actions To address this finding and prevent recurrence, the University has strengthened its reconciliation and reporting processes by implementing mandatory monthly reconciliations for all Title IV programs and requiring completion of a documented year-end reconciliation prior to submission of the FISAP. The Office of Financial Aid now utilizes standardized reconciliation templates and documentation procedures and coordinates closely with the Business Office to ensure reported expenditures reconcile to internal records, the general ledger, and federal systems. In addition, supervisory review has been incorporated into the reconciliation and FISAP preparation process to verify accuracy, resolve discrepancies timely, and ensure federal reporting is complete, accurate, and supported by reconciliation documentation. The next FISAP submission is due October 1, 2026. 5. Risk Mitigation (Required - Even if Disagreeing) The University recognizes the importance of reducing exposure related to federal reporting accuracy and compliance. The corrective actions implemented are intended to strengthen oversight of reconciliation and FISAP reporting, improve coordination between responsible offices, and ensure that reported expenditure data is supported by timely and documented reconciliations, thereby reducing the likelihood of inaccurate reporting or future audit findings. 6. Responsible Party • Office/Department: Office of Financial Aid • Title of Responsible Official: Financial Aid Director • Name (optional): ____________ _. 7. Implementation Timeline • Corrective action implemented: D Yes C8l No • If not fully implemented, expected completion date: October 1, 2026 8. Status of Corrective Action (For Prior-Year or Repeat Findings) D Fully implemented D Partially implemented x Not yet implemented Evidence of Implementation In progress, evidence is not yet available. 9. Monitoring and Sustainability The University will monitor compliance through ongoing supervisory review of monthly and yearend reconciliation documentation and periodic internal reviews of FISAP preparation processes. Reconciliation procedures and reporting controls will be routinely evaluated and reinforced through staff training and management oversight to support sustained compliance and accurate federal reporting.

Federal Program/ Assistance Listing Number (ALN) 84.268, 84.063, 84.007, 84.033 Finding Reference Number 2025-006 1. Finding Summary The auditor found that the University did not complete or document required monthly or year-end reconciliations for several Title IV programs, resulting in unreconciled financial aid records between the Office of Financial Aid, the general ledger, and federal systems. Federal regulations require these reconciliations to ensure the accuracy of disbursements and compliance with Title IV requirements. 2. Management's Position Management agrees with the finding. Management Explanation Management agrees with the finding and acknowledges the failure to perform timely and documented reconciliations of Title IV programs during the audit period. Management concurs with the auditor's assessment that reconciliation is a critical internal control and recognizes the need to strengthen coordination, documentation, and timeliness between the Office of Financial Aid and the Business Office. 3. Root Cause Analysis The root cause was insufficient staff training on Title IV reconciliation and reporting requirements, resulting in inconsistent understanding of regulatory timelines, documentation standards, and cross-department coordination responsibilities. These training gaps limited the effective implementation of required reconciliation and monitoring processes. 4. Corrective Action(s) Management is working to implement standardized workflows and periodic internal monitoring between the Office of Financial Aid and the Business Office. Description of Corrective Actions To address this finding and prevent recurrence, the University has implemented standardized reconciliation procedures aligned with federal requirements. Reconciliation responsibilities have been formally assigned to a designated Financial Aid Counselor, with monthly reconciliations scheduled throughout each month for all Title IV programs. The Office of Financial Aid now utilizes standardized reconciliation checklists and templates, requires documented coordination and data matching with the Business Office and federal systems (COD and GS), and retains all monthly and year-end reconciliation records in accordance with federal record-keeping requirements. In addition, a mandatory year-end reconciliation review is completed prior to FISAP submission to ensure consistency across internal records, the general ledger, and federal reporting systems. The University is slightly behind on monthly reconciliations, but is working to complete July 2026 and August 2026 reconcilations and to revise the progress to shorten the time required to complete reconciliations. 5. Risk Mitigation (Required - Even if Disagreeing) The University acknowledges the need to proactively manage regulatory exposure in this area. The corrective measures implemented are intended to strengthen oversight, promote consistent application of federal requirements, improve the accuracy and timeliness of reconciliation activities, and minimize the likelihood of future reporting issues or audit observations. 6. Responsible Party • Office/Department: Office of Financial Aid • Title of Responsible Official: Financial Aid Director •Name (optional): 7. Implementation Timeline • Corrective action implemented: ~ Yes D No • If not fully implemented, expected completion date: December 31, 2026 8. Status of Corrective Action (For Prior-Year or Repeat Findings) D Fully implemented ~ Partially implemented D Not yet implemented Evidence of Implementation Monthly reconciliations and close-outs of prior year aid periods. 9. Monitoring and Sustainability The University will maintain ongoing oversight of reconciliation activities through routine internal reviews and supervisory verification to ensure procedures are consistently followed. Reconciliation processes and documentation practices will be periodically evaluated and updated as needed to support sustained compliance with Title IV requirements and long-term operational effectiveness.

Finding 2025-12 Special Tests and Provisions: Title IV Credit Balance Disbursements – Noncompliance and Significant Deficiency in Internal Control Over Compliance; Planned Corrective Action Plan: APU will enhance monitoring of Title IV credit balances to ensure balances are identified, reviewed, and disbursed within the required 14-day period. Student account and financial aid personnel will establish a recurring review of outstanding credit balances, document follow-up and resolution, and escalate unresolved balances before the federal deadline.; Anticipated Completion Date: July 1, 2027