Corrective Action Plans

NSLDS Enrollment Reporting Student Financial Assistance Cluster – Assistance Listing No. 84.063, 84.033, 84.268, 84.007 Recommendation: We recommend the University review its reporting procedures to ensure that enrollment and program information is accurately reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: A complete review of CIP code usage will be reviewed and ensure that there is alignment across academics, registrar, and financial aid. The last review was done in 2024 but with changes alignment fell out of sync. We are also working with our SIS vendor, Jenzabar, to continue to identify areas where the SIS is out of sync with compliance and how best to e􀆯ectively address them if it is a data issue or an issue with internal SIS logic. We are also actively engaging with the National Student Clearinghouse to identify issues and clean them up proactively. Registrar updated internal processes to ensure enrollment status reporting aligns with NSLDS guidance by using the Date of Determination (DOD), rather than the graduation or term end date, as the exit date for graduates. This approach is consistent with federal guidance and has been implemented. Name(s) of the contact person(s) responsible for corrective action: Robert Boggs, EdD, University Registrar Planned completion date for corrective action plan: 3/6/2026 for the CIP audit; 8/31/2026 for SIS and NSC; internal process changes are complete.

2025-002 Initial Fiscal Year End, 2025 Summary of Finding- During the audit, it was noted the University could not provide support for the last day of attendance to complete the return of Title IV funds for one of the students tested. This lapse in communication between departments led to a variance in the reported last day of attendance, which in turn did not provide a firm last day for calculating return of funding. Name and Title of Responsible Contact Person(s)- Jane Hodgkins, Vice President for Finance Corrective Action Plan Summary- The Finance Department will implement a compliance checklist to be used when a student begins the withdrawal process or when their absence becomes noticed. This checklist will comply with the Federal Student Aid handbook. This procedure will ensure compliance between Academic and Financial Aid Departments. This data path will begin with notification of respective departments and initiation by the Academic Department passing to Financial Aid with parallel communication with the Finance Department for compliance and accuracy of dates and ultimately the return of the accurate amount of Title IV funds. Anticipated Completion Date- Feb 28, 2026

2025-001 Initial Fiscal Year End, 2024 Summary of Finding- During the audit, it was noted that the University did not return the determined unearned Title IV funds for one student within the prescribed timeframe which resulted in non-adherence to the 45-day window. Name and Title of Responsible Contact Person(s)- Jane Hodgkins, Vice President for Finance Corrective Action Plan Summary- The finance department has been building back proper procedures and protocol after experiencing several transitions in key departments. The university will institute a compliance checklist that will ensure adherence to the dates for Title IV funding to be returned. This checklist will have the oversight of the Finance department to ensure that action and calculations are done accurately and in a timely manner adhering to the Financial Aid handbook. Anticipated Completion Date- Feb 28, 2026

Identifying Number: 2025-004 Finding: The Academy did not report student enrollment changes within the timeframe outlined by the Department of Education. Name of Contact Person: Alice Herrick, Director of Fiscal Operations; Ryan French, Director of Financial Aid Corrective Actions Taken or Planned: Root Causes Analysis: Upon internal review, several key factors contributing to this deficiency were identified: a. Clearinghouse Processing Gaps: Enrollment reporting at the Academy is managed through the National Student Clearinghouse (NSC), which transmits enrollment updates to the National Student Loan Data System (NSLDS). A review of discrepancies highlighted cases where: o Student withdrawals were not consistently updated within the mandated timeframe. b. Quality Control Mechanism: o There is currently no established process to cross-check NSC submission data with NSLDS and Student Information System (SIS) records to confirm that all changes were processed correctly. Corrective Measures: To address this deficiency, the Academy will implement the following corrective actions: a. Enhanced Collaboration & Process Review (Owner: FA/IT/Registrar, Deadline: April 30, 2025): o The Financial Aid Office will collaborate with the Registrar’s Office and IT to conduct a thorough review of the NSC reporting process. o IT will analyze report generation to determine if student records that should be included in NSC updates are being omitted due to system logic or timing of data extraction. b. Quality Control Implementation (Owner: FA/IT, Deadline: May 15, 2025): o A monthly QC report will be developed to identify students with the NSLDS status “Z – No Record Found” and verify that their enrollment data has been appropriately updated in NSLDS. o A secondary review of withdrawals, LOAs, and “no-shows” will be completed to confirm their enrollment status changes were transmitted correctly to NSLDS. c. Manual NSLDS Updates for Withdrawals (Owner: FA, Deadline: Immediate): o As a temporary solution, the Financial Aid Office will manually update student enrollment statuses in NSLDS following an R2T4 calculation. o This manual review will act as a safeguard to catch the majority of unreported status changes while a more automated verification process is developed. Future Process Improvements & Next Steps a. Automated Data Integrity Checks (Owner: IT, Deadline: June 30, 2025): o IT will determine whether a custom “NSLDS Status” flag can be implemented in the Academy’s SIS to help identify students whose records do not agree with NSLDS or the NSC report. b. Ongoing Compliance Monitoring (Owner: FA/IT/Registrar, Deadline: July 30, 2025): o Academy staff from the Registrar’s Office, Financial Aid, and IT will meet to discuss and document NSC reporting best practices – Internal Procedures, Operational Workflow, Compliance and QC Measures. o A bi-annual audit of enrollment reporting timeliness will be conducted to ensure continued compliance. Conclusion: Maine Maritime Academy is committed to ensuring compliance with U.S. Department of Education regulations and providing accurate and appropriate financial aid awards to students. The corrective actions outlined in this plan address the deficiencies identified in the Uniform Guidance audit and aim to prevent similar issues in the future. The corrective action above for student enrollment was underway during the fiscal year 2025 period under audit. We appreciate the audit findings and remain dedicated to continuous improvement in our financial aid procedures.

Finding number: 2025-001 Federal agency: U.S. Department of Education Programs: Student Financial Assistance (SFA) Cluster Assistance Listing Number: 84.007, 84.033, 84.268, 84.063 Award year: 2025 Corrective Action Plan The Colleges hired a new Chief Information Security Officer (CISO), who has begun overhauling the information security policies to reflect current practices. The CISO has also created a preliminary draft of a WISP that reflects the Colleges current policies and procedures. This WISP is expected to be completed and implemented during fiscal year 2026, pending board review and approval. Timeline for Implementation of Corrective Action Plan Immediately. Contact Person Sharron Scott, CFO

Student Financial Assistance Cluster – Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Recommendation: We recommend the College implement an internal control that ensures timely and accurate reporting. We also recommend the College implement changes in processes and procedures for NSLDS enrollment reporting and implement an internal control that ensures reporting is both timely and accurate. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: An Ellucian consultant provided us with customized process documentation for our new SIS (Ellucian Colleague) which is saved in a shared drive to ensure consistency in the process. The Interim Dean of Students / Financial Aid Director is currently completing the reporting with our Director of Institutional Research receiving the reports and verifying completeness through National Student Clearinghouse, ensuring that there is an internal control. Name(s) of the contact person(s) responsible for corrective action: Sarah Geleynse & Ian Wilson Planned completion date for corrective action plan: Implemented

Student Financial Assistance Cluster – Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Recommendation: We recommend the College return the funds related to unclaimed Title IV–funded checks that are older than 240 days. In addition, we recommend that the College review applicable requirements and implement effective controls and procedures to monitor outstanding Title IV–funded checks throughout the year to ensure timely compliance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Business Office provides a list monthly of the uncashed financial aid checks to the Financial Aid Office. The Financial Aid Office is contacting the students to remind them to cash their checks. The funds for the uncashed checks are returned to the College after 90 days and then returned to the source of the funding. Name(s) of the contact person(s) responsible for corrective action: Margaret Antilla and Layla Solar. Planned completion date for corrective action plan: Already implemented.

U.S. Department of Education 2025-005: Special Tests and Provisions - NSLDS Enrollment Reporting Student Financial Aid Cluster -Assistance Listing No. 84.063, 84.268 Condition: Enrollment status changes were either not reported to NSLDS within 60 days or did not match the College's records for a portion of the sampled students. Recommendation: The institution should evaluate their procedures and policies related to reporting status changes and effective dates to NSLDS and enhance as deemed necessary to ensure that accurate information is reported to NSLDS. Explanation of disagreement with audit finding : There is no disagreement with the audit finding. The Institution acknowledges that while reporting was completed within a timely manner by HCC, NSC did not update within the time allotted to be compliant. HCC remains committed to continuous improvement and compliance. Action taken in response to finding: As noted in the prior year's response, the College committed to full implementation of corrective actions by June 30, 2026, aligned with the conclusion of the 2025-2026 academic year. The institution is currently and actively working on the corrective action plan previously submitted. Actions underway or in progress include: Formal clarification of interdepartmental roles and responsibilities, establishing the Records, Registration and Veteran's Affairs (RRVA) as the primary enrollment reporting authority, with defined review and compliance support from Financial Aid Services. Enhanced reconciliation and quality control procedures, including routine cross-checks between RRVA and Financial Aid Services records prior to each enrollment reporting submission. Standardized review protocols for program-level enrollment changes, including graduates, withdrawals, and subsequent reenrollments in different academic programs. Ongoing monitoring and documentation of NSC errors and warning reports, with timely resolution and escalation when discrepancies appear to originate outside of the College's student information systems. Targeted training for RRVA and Financial Aid staff on enrollment reporting regulations, NSLDS requirements, and audit-risk mitigation. The College believes these actions, coupled with existing reporting practices, sufficiently address the concerns raised and will further strengthen enrollment reporting accuracy and documentation. Full implementation of the corrective action plan remains on schedule for completion by June 30, 2026, as originally committed. Name(s) of the contact person(s) responsible for corrective action: Detra Hooper, Financial Aid Director and Jessica Peterson, Registrar Planned completion date for corrective action plan: June 30, 2026 If the U.S. Department of Education has questions regarding this plan, please call Detra Hooper, Financial Aid Servies Director at 443-518-4776.

Corrective Action Plan Finding No. 2025-001 – Eligibility (Federal Work Study Program) Federal Program: Student Financial Assistance Cluster – Federal Work Study (ALN 84.033) Federal Agency: U.S. Department of Education Audit Period: July 1, 2024 – June 30, 2025 Finding Summary During testing of student eligibility, auditors identified one instance in which a student’s Cost of Attendance (COA) was increased by $2,810 due to participation in the Federal Work Study (FWS) program. Federal regulations do not permit an institution to increase COA solely to accommodate FWS eligibility. Although the adjustment did not result in the student receiving aid exceeding financial need, the adjustment occurred due to a misunderstanding of guidance related to the FWS program. Corrective Action Plan Management agrees with the finding. To address the finding and ensure compliance with federal regulations governing the Federal Work Study program, the Office of Financial Aid will implement the following corrective actions: 1. Policy Clarification and Documentation The Office of Financial Aid will revise its internal awarding policies and procedures to clearly state that the standard practice of awarding Federal Work Study funds must fit within the student established Cost of Attendance (COA). Additionally, the revised policy will explicitly include flexibility to increase the Cost of Attendance only because of approved Special Circumstance appeals, consistent with federal guidance and institutional professional judgment policies. Federal Student Aid Handbook: Application and Verification Guide: Chapter 5 – Special Cases 2. Award Adjustment Procedures When a student’s aid package exceeds need due to the addition of FWS, staff will take the following steps: • Reduction of loan awards, when applicable, to allow FWS funding to be added within the student’s financial need limits.A Loan Adjustment Form will be required for all downward adjustments to loan awards to ensure documentation and transparency. These procedures will ensure that aid adjustments remain compliant with federal need-analysis requirements. Implementation Timeline • Policy updates and procedural documentation: Within 60 days • Process implementation: Beginning with the 2026-2027 academic year packaging cycle

Corrective Action Plan for Current Year Findings 2025-001 Special Tests & Provisions – Return of Title IV Funds This Corrective Action Plan has been established by the Financial Aid and Registrar’s Offices to resolve findings related to Return of Title IV (R2T4) calculation errors. The goal of this plan is to ensure 100% data integrity through enhanced system logic, multi-tier manual verification, and cross-departmental reconciliation. Identify and Analyze Errors: The institution conducted a root-case analysis of the identified findings and determined the following: R2T4 Transposition Errors: For five (5) student records, the "Date of School’s Determination" (DOD) and the "Date of Withdrawal/Last Date of Engagement" (LDE) were inadvertently switched during manual entry into the COD system. Corrective Standard: The Withdrawal Date must be verified as the actual Last Date of Engagement (LDE), while the Date of Determination must remain the Banner-stamped withdrawal date. Develop and Implement Data Verification Processes: To prevent recurrence, the following "intrusive checks and balances" system has been implemented: Multi-Tier R2T4 Review (Financial Aid) - A four-point verification process is now mandatory for all Pro-rata calculations: a. Preparation: Financial Aid Specialist calculates the return based on Banner data. b. Validation: Financial Aid Coordinator validates the LDE and DOD against the academic record. c. Confirmation: Financial Aid Manager reviews and confirms previous calculations based on LDE and Banner data. d. Final Oversight: The Director of Financial Aid performs the final verification check before and after the data is committed to the Common Origination and Disbursement (COD) system. e. Standardization: All calculations must include employee initials and date within the Pro-rata Calculation Form, based on the 4-point verification process above, to ensure internal record reconciliation. Person(s) Responsible: Christine Genenbacher-Leinbach, Director of Financial Aid Brittany McKeown, Head of Enrollment, Registrar, Financial Aid Services Timing for Implementation: Currently implemented, as well as a retroactive check of prior R2T4 submissions, starting September 1, 2025. New verification tiers are active as of the current term to ensure immediate compliance without further incidents.

2025-001: Late Return of Title IV Financial Aid - Student Financial Aid Cluster - Assistance Listing #s 84.007, 84.033, 84.063- Grant Period - Year Ended June 30, 2025 Condition Found During our Return of Title IV Fund testing, we noted that the College did not calculate or return Title IV Student Financial Aid for two out of twenty-five students tested until after 45 days when the student ceased attendance. We consider the untimely calculation and Return of Title IV Student Financial Aid to be an instance of noncompliance relating to the Special Tests and Provisions Compliance Requirement. This is a repeat finding of prior year finding 2024-001. Corrective Action Plan In the first instance, the Return to Title IV (R2T4) calculation was completed timely; however, the associated disbursement was not processed within the required timeframe. Going forward, Title IV aid disbursements related to R2T4 calculations will be processed manually at the time the calculation is completed. The institution will no longer wait for regularly scheduled system disbursement dates in these circumstances. In the second instance, the student withdrew from the 8-week-1 courses but remained registered for the 8- week-2 courses; therefore, an R2T4 calculation was not initially completed. The student ultimately did not begin attendance in the 8-week-2 courses, and the 45-day timeframe elapsed. To prevent future occurrences, RLC will complete an R2T4 calculation at the time of withdrawal from the 8-week-1 courses and will reverse the calculation if the student subsequently attends the 8-week-2 courses. Responsible Person for Corrective Action Plan - ReAnne May, Director of Financial Aid Implementation Date of Corrective Action Plan - January 16, 2026

Responsible Person(s): Ida Witherspoon, Chief Financial Officer; William Carter, Federal Reporting Manager Corrective Action Planned: Grants now uses a financial system created report to perform a perfunctory audit, matching submission data received from the various Program and Budget staff against each individual upload into the federal system. Vendors are filtered by ALN by each analyst responsible for monitoring the various ALN's that make up the DSS portfolio. Once the lists are cross checked, DSS reaches out again to the sub awarding authority responsible within the agency to ask for additional FFATA information. Estimated Completion Date: 6/30/2026

Finding 2025-002 - Significant Deficiency in Internal Control over Compliance - Student Financial Condition Found: One undergraduate student had aggregate subsidized loans over the aggregate limit. Corrective Action Plan: Previously, Antioch College utilized loan history data from Free Application for Federal Student Aid (FAFSA). FAFSA data was utilized because National Student Loan Data System (NSLDS) loan history data was not always available when Antioch College prepared financial aid award letters. Due to the potential loan history discrepancies between data reported via FAFSA versus NSLDS, at the start of each academic year, Antioch College now uses NSLDS data to update loan history of each student to ensure Antioch College has the correct loan balances for each student. This procedural change was put into effect with the start of the 2025-2026 academic year. Person Responsible for Corrective Action Plan Implementation: Director of Financial Aid

MSU Denver manages enrollment reporting within the Office of the Registrar. We develop a schedule each calendar year and semester with NSC to identify scheduled reporting dates for each term in alignment with critical semester dates (start, end, drop, etc.). In Fiscal Year 2025, there was a technical issue in which we had to work with our ERP vendor, Ellucian, to provide a solution. The Office of the Registrar will strengthen its internal controls to ensure enrollment changes are reported within the required 60-day timeline.

MSU Denver IT Security will update its written information security program to address the necessary requirements of the Gramm-Leach-Bliley Act. The WISP will be reviewed and updated at least once each year, with updates being based on risk assessments, audits, changes to the environment, and any incidents which indicate a need for changes to the WISP. The updated WISP will include existing policies as well as new policies that describe standards for: • Periodic inventory of data • Multi-Factor Authentication, Single Sign-On, and passwords • Assessment of applications developed by the institution • Testing our safeguards The updated WISP will be formally reviewed and approved by the Chief Financial Officer by June 30, 2026.

The Colorado State University and Colorado State University – Pueblo campuses will strengthen their internal controls to ensure enrollment changes are reported within the required 60-day timeline for newly enrolled students. Additionally, the Colorado State University and Colorado State University – Pueblo campuses will improve the documentation provided as part of compliance testing as both students referenced within the finding were unique situations. In both instances referenced, additional context was not provided during compliance testing for both students that was not captured on the provided National Student Loan Data System Campus Enrollment Details webpage that showed the appearance of reporting an enrollment status change outside of the 60-day requirement. For the Colorado State University, the student was reported with an effective date of the beginning of the Fall 2024 Semester but did not complete verification procedures until February 2025 and was then disbursed the Fall 2024 portion of their Pell Grant. For Colorado State University – Pueblo, the student was reported with an effective date of the beginning of the Fall 2024 Semester, but corrections were required on the student’s FAFSA before federal student financial aid could be disbursed. The campuses will improve documentation provided during compliance testing for when these unique situations with enrollment reporting occur.

Subject: Corrective Action Plan for Federal Direct Student Loans Program Compliance The University of the Pacific acknowledges the findings outlined in the audit related to the reporting of student enrollment status to the National Student Loan Data System (NSLDS) for the Federal Direct Student Loans Program (Federal Assistance Listing Number: 84.268) for the award year July 1, 2024 – June 30, 2025. The audit identified a system-level transmittal configuration issue in which campus-level enrollment updates inadvertently overrode certain program-level enrollment status fields within NSLDS reporting. We take our responsibility to comply with the federal regulations under 34 CFR Section 685.309 very seriously and are committed to strengthening our internal controls and system governance processes to ensure accurate, complete, and timely reporting of enrollment changes at both the campus and program levels. Corrective Action Plan: To address the identified deficiency, Finding# 2025-001, related to program-level enrollment status reporting and to strengthen preventive controls over NSLDS submissions, the University has implemented the following measures, effective immediately (February 19, 2026): 1. Root Cause Isolation and System Logic Review: The University identified that a specific NSLDS transmittal file configuration resulted in campuslevel enrollment updates overriding program-level enrollment status fields. In collaboration with Information Technology, the Registrar’s Office has isolated the reporting logic and corrected the configuration to prevent program-level status fields from being overwritten by subsequent campus-level submissions. Documentation of the revised logic has been retained for audit purposes. 2. Full Population Review and Remediation: The University will conduct a comprehensive review of NSLDS records for the affected student population to confirm accuracy of program-level enrollment status. Where discrepancies are identified, corrected submissions will be transmitted promptly to NSLDS. Documentation of the review and any corrections will be maintained to ensure a complete audit trail. 3. Segregation of Campus-Level and Program-Level Reporting Logic: Enrollment reporting procedures have been updated to formally distinguish campus-level and program-level reporting workflows. Any future modifications to enrollment reporting logic will require documented change management review, regression testing, and joint approval from the Registrar’s Office and Information Technology prior to implementation. 4. Targeted Program-Level Monitoring Dashboard: In addition to existing monthly NSC and NSLDS reconciliations, the Registrar’s Office will implement a targeted monthly exception report specifically monitoring program-level enrollment status changes. This report will identify discrepancies between SIS records and transmitted data, including concurrent program records and recent status changes, to ensure ongoing data integrity. 5. Quarterly Compliance Sampling and Oversight: On a quarterly basis, an independent staff member not involved in file preparation will conduct a sampling review of transmitted NSLDS records to verify program-level status accuracy. Results will be documented and reviewed by the Registrar to ensure sustained compliance. 6. SOP Enhancement and Staff Training: The University has updated its Enrollment Reporting Standard Operating Procedures to incorporate explicit review steps for program-level data validation and transmission oversight. Targeted training has been provided to staff responsible for enrollment reporting to reinforce compliance expectations and system configuration awareness. The University remains committed to ensuring accurate and timely reporting of student enrollment data in full compliance with federal regulations. These enhanced preventive and governance controls build upon prior corrective actions and further strengthen the integrity of our Title IV reporting framework. Anticipated Completion Date: 6/30/26 Person Responsible: Michael Snyder, Associate University Registrar

Reference Number: 2025-001 Finding: Other Instance of Noncompliance and Deficiency Status: In-Progress Corrective Action: An instance was found where the R2T4 calculation for one student had a typo of the incorrect date. This was subsequently corrected. We reviewed this student record and concluded that it was a human error made. There is no pattern of incorrect information being used. To avoid future errors, the Assistant Director will meet with the Dean monthly and we will review completed R2T4's during that period. We believe having another pair of eyes to review the work completed will be sufficient to correct any inconsistencies. Person(s) Responsible for Implementing: Lynda McKendree, Dean of Scholarships and Financial Aid and Thuylieu Aligo, Assistant Director of Scholarships and Financial Aid. Implementation Date: 1/27/2026

Finding number: 2025-001 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 Award year: 2025 Corrective Action Plan Contact Person: Sabina Yesman, Director of Financial Aid A PELL Grant was awarded and disbursed for one ineligible student during the 2024-2025 Academic Year at Benjamin Franklin Cummings Institute of Technology (FC Tech). The error resulted from incomplete synchronization between enrollment and financial aid systems during the system transition period. Specifically, enrollment status and census-date verification were not fully integrated into the automated disbursement workflow, allowing aid to disburse before final eligibility confirmation. FC Tech has taken corrective measures and implemented monitoring and system controls to prevent future errors from occurring. Corrective Action Taken  FC Tech reviewed the student’s record and confirmed the ineligibility.  The PELL Grant award was adjusted to $0, and the disbursement was reversed.  The student account was corrected, and all required accounting and G5 drawdown adjustments were completed. The amount of $3,697 was returned on 12/18/2025  The case was documented internally for training purposes. Preventive Measures Implemented (February 2026) To prevent recurrence, FC Tech has implemented the following controls:  Enrollment Verification Prior to Disbursement All PELL-eligible students must be actively enrolled and confirmed in the Student Information System (Jenzabar) prior to disbursement.  Census-Date Verification Through Multiple Systems Enrollment status at census date is now validated through an integrated, multi-system verification process involving the Jenzabar, our Financial Aid System (PowerFAIDS), and Registrarconfirmed Enrollment Reports.  Delayed Disbursement Timeline Federal Aid disbursements are scheduled to occur no earlier than one week after census date to allow sufficient time for enrollment stabilization, drops, corrections and reconciliation  System Edit/Control Automated system edits have been implemented to prevent a PELL disbursement if census-date enrollment status is missing, unconfirmed, or inconsistent across systems.

The district will review expenditures to make sure activities June 30 or prior and July 1 through August 31 are accurately accounted for on the expenditure report that requests this split.

Reports were submitted after the 20th deadline - some within 2-3 days of that 20th date deadline. Moving forward reports will be submitted to Mrs. Forck to submit to ISBE by the 20th of each month.

Corrective Action Plan Thursday, February 12, 2026 Harrisburg Area Community College respectfully submits the following corrective action plan for the year ended June 30, 2025. The findings from the June 30, 2025 audit report dated February 13, 2026 schedule of findings and questioned cost are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Agency: (Federal Agency per Finding): U.S. Department of Education Audit Period: July 1, 2024 – June 30, 2025 Name and Address of independent public accounting firm: Smith Elliott Kearns & Company, LLC, Certified Public Accountants & Consultants, 804 Wayne Avenue, Chambersburg, Pennsylvania 17201 Finding Type: (per Finding) Federal Awards: Material Weakness in Internal Control over Compliance and Noncompliance Internal Control Type: (please choose the type per the finding)  Material Weakness(es) o Significant Deficiencies Audit Finding No.: 2025-001 Federal Program: (per Finding) Student Financial Assistance Cluster Compliance Requirement: (per Finding) Return of Title IV Funds Audit Finding Title/Statement of Condition: (copy from audit findings documentation): The College did not comply with federal requirements related to the timely return of Title IV funds. Specifically, the College failed to return aid for four students who never attended within the 30-day period required under 34 CFR 668.21(b). In addition, the College did not return funds for one student who began attendance but subsequently required a refund within the 45-day timeframe mandated under 34 CFR 668.173(b). Auditor Recommendation: (copy from audit findings documentation) The College should strengthen its internal controls and monitoring procedures to ensure compliance with federal return-of-funds requirements. This should include timely verification that calculated refund amounts match what is actually returned, improved review processes to confirm that students who never attended are identified promptly, and training for relevant staff to ensure consistent understanding and execution of federal aid return requirements. Specific steps to be taken to correct the situation [including a timetable for performance of the CAP] or reason why corrective action is not necessary (including disagreement with the finding). The College has made several enhancements that should prevent future problems with the return of funds. 1) In fall 2025, the College instituted a new process for collecting data for attendance/participation of students. This process includes a data collection approximately one week into the part of term (the “Academic Participation Data Collection) – and before the disbursement of Title IV aid. It also includes follow up with faculty at several intervals throughout the semester to encourage them to withdraw students who have stopped attending. This improved process gives us clearer and more transparent data on attendance/participation so that aid recalculations and returns can be managed in a more timely manner 2) As of January 2025, the College has implemented a process to prevent the disbursement of Title IV (TIV) aid to students who are not enrolled in a future semester or are not considered actively attending. For example, if a student attended the Fall semester but is not enrolled for the Spring semester, Title IV funds cannot be disbursed if the aid was not originated before the student became ineligible. This process applies in both directions, as disbursement includes both paying funds to a student’s account and reversing funds when appropriate. Accordingly, the Previous Semester Fund Request process is designed to ensure that Title IV funds are either paid or reversed in compliance with federal requirements. 3) The Financial Aid team will continue processing returns at the time that an R2T4 occurs to prevent miscommunications and ensure timely completion. 4) The Financial Aid team and Finance teams will collaborate and engage Bank Mobile to improve the processing of stale checks and timed out funds. Anticipated Completion Date: May 1, 2026 Name(s) and Title(s) of contact person(s) responsible for correction action: Tim Barshinger, Associate Vice-president of Student Enrollment Services Juan Cordoba, Financial Aid Director

Views of Responsible Officials and Corrective Action Plan We concur. Management has implemented an IT-led data mapping review of reporting scripts, biweekly error report checks by Financial Aid Director, and increased reporting frequency to every 30 days.

Views of Responsible Officials and Corrective Action Plan We concur. Management has formed an Academic Calendar Committee for pre-year review, as well as implemented automated short-term date detection in SIS and instituted a secondary review process for all R2T4 calculations.

Views of Responsible Officials and Corrective Action Plan We concur. The Financial Aid Office and IT have Implemented a “Just-In-Time” eligibility verification in MyDelta. Additional manual reconciliation before disbursement has also been implemented.