Corrective Action Plans

The errors noted in the finding resulted from a missing step in the reconciliation process. The Registrar’s office relied on an error report from NSC to help identify any issues that might be noted in the student files. The findings noted, reinforced that this process alone was not sufficient to capture all errors. To ensure that these types of errors do not recur, subsequently, the registrar’s office team has initiated an additional monthly reconciliation between the NSLDS and internal student management system. This reconciliation will show any status variance or date mismatches. Any variances noted will be updated in the NSC/NSLDS system. This process was implemented in December 2024 when the issue was found as part of the 2024 audit. The 2025 finding relates to an individual who withdrew from the University prior to December 2024 with the new procedures in place. Responsible party: Sarah Harris, Director, Office of Financial Aid; (802) 485-2679 Anticipated Completion Date: December 2024

Condition: A student added an additional course after the summer term census date, however, the Financial Aid Office did not adjust the student’s corresponding Pell Grant eligibility. As a result, the Pell Grant award was not recalculated to include the additional course. Criteria: The University’s monitoring controls for post-census date enrollment changes were not consistently applied. Although the University’s normal process includes reviewing and adjusting aid when students add/drop classes after the census date, this case was not identified due to human oversight for post-census date schedule changes. Cause: Per 34 CFR 690.80(b)(2)(ii), the University must adjust Federal Pell Grant awards if a student’s enrollment status changes and the change occurs within the University’s established recalculation (census) policies. Additionally, internal University policy states that Pell Grant awards will be adjusted when students add/drop courses after the census date if those courses are applicable toward the student’s degree or certificate requirements and occur within the eligible recalculation period. Effect: Because the student’s enrollment increase was not identified and processed, the student did not receive the full amount of Pell Grant awards they were entitled to. This resulted in a $924 underpayment to the student. Context: This issue was identified during audit testing of Pell Grant awards for the 2024–2025 year. The University reviewed the case and agreed that the student should have received an additional $924. The University believes the error to be an isolated incident rather than a systemic process failure; however, it indicates that post-census monitoring controls may not be fully effective in all cases. Recommendation: The University should establish a formal process to monitor when students add/drop courses after the term census date to ensure financial aid is accurately adjusted and reflected in a timely manner. This process should include periodic reviews or automated reports that identify enrollment changes impacting grant eligibility and additional procedures to verify that corresponding adjustments are made to student accounts. Strengthening this process will help ensure compliance with federal regulations and prevent underpayments or overpayments of student aid. View of Responsible Officials and Planned Corrective Action: The University has recognized the failure to adjust the student's enrollment status and recalculate the Pell Grant award in a timely manner that resulted in an underpayment of $924. To prevent similar issues in the future, the Financial Aid Office will implement a formal process to monitor students who add/drop courses after the census date, including generating reports to flag enrollment changes that impact Pell Grant eligibility and reviewing these cases to ensure adjustments are made promptly.

Criteria Institutions are required to report enrollment information under the Pell grant and the Direct and FFEL loan programs via the NSLDS. The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSDLSFAP) website. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. Title 2 U.S. Code of Federal Regulations Part 200 (2CFR 200) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, section 303(a) states, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statues, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition In testing the Program-Level enrollment reporting data elements as reported to NSLDS, key items to test are: OPEID Number, CIP Code, CIP Year, Credential Level, Published Program Length Measurement, Published Program Length, Program Begin Date, Program Enrollment Status, and Program Enrollment Effective Date. During the performance of our test work, the College identified that 31 of the 409 students who graduated during the year had enrollment statuses that did not agree between campus-level and program-level NSLDS data. Specifically, these 31 students’ enrollment statuses were correctly reported as graduated in the campus-level NSLDS data but were inaccurately reported as withdrawn in the program-level NSLDS data. The exception described above did not result in changes to the amounts awarded or disbursed to students by the College for the current fiscal year. Cause The condition resulted from a gap in the College’s internal control processes. Specifically, the College did not implement a control to ensure that all changes in enrollment information were submitted accurately to NSLDS. Possible Asserted Effect Inaccurate submission of student enrollment status information and related program information affects the determinations that lenders and servicers of students’ loans make related to in-school status, deferments, grace periods, and repayment schedules, as well as the federal government’s payment of interest subsidies. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Identification of Whether the Audit Finding was a Repeat Finding This is not a repeat finding. Recommendation We recommend the College review and enhance its process related to enrollment reporting to ensure that all key data elements are reported accurately to the NSLDS. Views of Responsible Officials Responsible Individual: Joan Romano, Registrar, Enrollment Strategy and Operations Contact Information: jromano2@berklee.edu , 617-747-2475 In response to the condition identified, the College has strengthened its internal controls over enrollment reporting to ensure alignment between campus-level and program-level data submitted to NSLDS. Automated validation control implemented: Crossfield validation added to the student information system to ensure campus and program-level enrollment statuses align prior to NSLDS submission at graduation closure. Graduation records with misaligned statuses will be blocked from transmission, and discrepancies generate exception alerts that must be corrected before file submission. Monthly reconciliation and documented exception tracking established: After each NSLDS submission and graduation file transmission, reconciliation reports will compare campus and program-level data. Any discrepancies identified are resolved through a formal exception tracking process before certifying subsequent submissions. Standard operating procedures will be updated to document these enhancements to enrollment data reporting. Enhanced monitoring and supervisory oversight: Enhanced controls will ensure enrollment data reported to NSLDS is accurate, complete, and compliant preventing future reporting misalignment. The Registrar/Associate Registrar will perform review and sign-off to confirm procedures are consistently followed to remediate the risk of any future findings. Expected Implementation Completed: May 31, 2026 Status of Completion: In Process

Criteria Institutions submit Direct Loan, Pell Grant, TEACH Grant, and IASG origination records and disbursement records to the Common Origination and Disbursement (COD) system. Origination records can be sent well in advance of any disbursements, as early as the institution chooses to submit them for any student the institution reasonably believes will be eligible for a payment. The disbursement record reports the actual disbursement date and the amount of the disbursement. ED processes origination and/or disbursement records and returns acknowledgments to the institution. The acknowledgments identify the processing status of each record: Rejected, Accepted with Corrections, or Accepted. Title 2 U.S. Code of Federal Regulations Part 200 (2CFR 200) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, section 303(a) states, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statues, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition In testing the origination and disbursement data, key items to test on origination records, if applicable, are: Social Security number, award amount, enrollment date, verification status code, transaction number, cost of attendance, and academic calendar. During our test work over the key items on origination records as reported on COD, KPMG identified the following: • 6 of the 40 students selected for test work had incorrect academic start or end dates that did not agree to the College’s records. None of the items that were exceptions described above resulted in the College over awarding students for the current fiscal year. Cause The condition resulted from the College Student Financial Aid Operations Department not reporting updated information to the COD System when changes were made to enrollment dates of the students identified due to the College not having an adequate internal control process. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Identification of Whether the Audit Finding was a Repeat Finding This is not a repeat finding. Recommendation We recommend the College review and enhance its process related to reporting key items to the COD System and update key fields as information may change during the awarding process to ensure that they agree to the College’s records. Views of Responsible Officials Responsible Individual: Russell Romandini, Director of Student Financial Aid Services, Student Financial Services Contact Information: rromandini@berklee.edu , 617-747-2505 Management concurs with the recommendation. Berklee will enhance internal controls over the reporting of key data to the COD system. Designated staff in the Student Financial Aid Operations Department and Office of the Registrar has developed reports and implemented a recurring review process comparing enrollment and academic year dates in PowerFAIDS to Berklee’s registration records. This review will be performed at relevant intervals to be sure data mismatches are resolved by the end of the academic year processing cycle. These intervals occur towards the end of academic year processing (summer semester for campus; spring and summer terms for the online program) as these are the academic periods that generate the most enrollment changes, and with it, academic year date fluctuations. Any differences identified will be updated in PowerFAIDS and COD as necessary and in a timely manner to ensure ongoing data alignment and accuracy between the COD system and institutional records. Supervisory oversight by the Director of Student Aid Operations will include review and sign off to ensure the enhanced procedures are consistently followed by the Operations team to remediate the risk of any future findings. Expected Implementation Completed: May 31, 2026 Status of Completion: In Process

West Hills Community College District and Lemoore College acknowledge the audit finding related to enrollment reporting to the National Student Loan Data System (NSLDS). While no questioned costs were identified, the District recognizes the importance of accurate, timely, and complete enrollment reporting and is committed to strengthening internal controls to ensure full compliance with U.S. Department of Educa on requirements.

The District concurs with the audit finding. The error occurred in the context of courses offered in modules, which are subject to unique federal calculation requirements. To address this finding and strengthen internal controls over R2T4 calculations for modular coursework, Lemoore College will implement the following corrective actions: 1. System-Based Calculation Tool Development Lemoore College will work with the District’s IT department to develop a tool that accurately calculates the percentage of the term completed for students enrolled in courses offered in modules. This tool will be designed to align with applicable federal R2T4 requirements and reduce reliance on manual calculations. 2. Interim Manual Calculation Controls Until the system-based solution is implemented, Lemoore College will implement enhanced review procedures for all R2T4 calculations involving modular coursework, including documented secondary review of the withdrawal date, module dates, and percentage of term completed. 3. Procedure Documentation and Staff Guidance Lemoore College will update internal procedures and provide targeted guidance to Financial Aid staff regarding R2T4 calculations for modular courses, including documentation standards and review expectations. 4. Ongoing Monitoring Supervisory monitoring and periodic spot checks will be conducted to ensure the continued accuracy of R2T4 calculations involving modular coursework.

Management’s Corrective Action Plan: 1. Strengthen Interdepartmental Coordination Aiken Technical College will enhance collaboration between Academic Affairs, the Registrar, and Financial Aid to ensure timely and accurate reporting of Last Dates of Attendance (LDA). This includes: Establishing a standardized communication protocol for timely submission of LDAs following student withdrawals. Ensuring withdrawal data is entered into the student information system promptly to trigger R2T4 processing. 2. Faculty Communication and Compliance To reduce delays and improve reporting accuracy: Faculty will receive term-based reminders regarding the importance of accurate and timely drop/withdrawal reporting. Reminders will reinforce federal compliance expectations and highlight the downstream impact on student financial responsibility and institutional audit outcomes. 3. Policy and Procedure Revision The College will revise its policies and procedures to: Clearly define internal timelines, responsibilities, and handoff points across departments. Increase transparency of each step in the workflow to improve consistency and reduce processing errors. Support a collaborative, student-centered process that aligns with Aiken Technical College’s commitment to regulatory excellence and audit readiness. Responsible Official: Melinda Rodgers, VP Enrollment Mgmt. & Student Affairs Anticipated Implementation Date: Fiscal Year 2026

Student Financial Assistance Cluster – Federal Assistance Listing No. 84.063 Recommendation: We recommend that the College review its procedures to ensure their internal system pulls the correct SAI amounts directly from the student's ISIR when calculating a student’s Pell award. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: To ensure compliance, the College will implement the following corrective actions: 1. System Configuration Review: The Financial Aid Office, in coordination with Powerfaids (College Board), will conduct a comprehensive review of system configuration settings to confirm that SAI values are pulled directly and accurately from the student’s valid ISIR transaction when calculating Pell eligibility when PARM ROLL is run each year. 2. Validation and Testing: The College will perform test file reviews comparing ISIR SAI values to system-calculated Pell awards to confirm accuracy. Any discrepancies identified will be corrected through system reconfiguration or vendor-supported adjustments (as per College Board.) 3. Quality Control Review: A secondary-level review, (i.e., the counselors designated to their individual alphabet cohort) will be implemented during each awarding cycle to confirm that Pell awards align with the student’s valid SAI and enrollment intensity. These corrective actions strengthen internal controls over Pell awarding, ensure SAI data integrity, and mitigate the risk of future calculation discrepancies. Name(s) of the contact person(s) responsible for corrective action: Stephanie Schroeder, Director of Financial Aid Planned completion date for corrective action plan: Immediate action will take place, with the goal of implementing these changes effectively before the start of the new academic year

Student Financial Assistance Cluster – Federal Assistance Listing No. 84.063, 84.268, 84.007, 84.038, 84.033 Recommendation: We recommend the College evaluate its procedures and review policies in overseeing student credit balances to ensure that any credit balances as a result of Title IV aid are returned within the required timeframe. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: In the absence of the Bursar due to short-term disability, the Associate Bursar was not fully trained in processing credit balances within the required timeframe. Since then, under direction of the Bursar, the Associate Bursar has been trained and occasionally processes credit balances to ensure comfortability and accuracy. The College has evaluated and updated its policies and procedures regarding student credit balances to ensure that any credit balances as a result of Title IV aid are returned within the required timeframe. Name(s) of the contact person(s) responsible for corrective action: Julie Lanski, Director Student Financial Services/Bursar Planned completion date for corrective action plan: May 31, 2026

Student Financial Assistance Cluster – Federal Assistance Listing No. 84.063, 84.268, 84.007, 84.038, 84.033 Recommendation: We recommend that the College review its reporting procedures to COD to ensure disbursements are reported timely and accurately to be in compliance with regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: To ensure compliance, the College will implement the following corrective actions: 1. Established Reporting Timeline: All disbursements will be reported to COD within fifteen calendar days of the date of disbursement, in accordance with federal regulations. 2. Secondary-Level Review: We will make it a goal to have another person within the student finance office trained to perform bi-weekly or monthly reviews of COD transmission reports to confirm accuracy and completeness. Evidence of review will be documented and retained. These corrective actions strengthen internal controls, enhance monitoring processes, and ensure disbursements are reported to COD timely and accurately moving forward. Name(s) of the contact person(s) responsible for corrective action: Stephanie Schroeder, Director of Financial Aid Planned completion date for corrective action plan: Immediate action will take place, with the goal of implementing these changes effectively before the start of the new academic year

Student Financial Assistance Cluster – Federal Assistance Listing No. 84.063, 84.268, 84.007, 84.038, 84.033 Recommendation: We recommend the College review its reporting procedures to ensure that key line Items within the Fiscal Operations Report and Application to Participate (FISAP) are reviewed and accurately reported to Department of Education as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Controller will ensure that when reporting revenue on the FISAP that it properly breaks out Graduate tuition separately from all other Tuition. Name(s) of the contact person(s) responsible for corrective action: Lisa Ressman, Controller Planned completion date for corrective action plan: February 17, 2026

Student Financial Assistance Cluster – Federal Assistance Listing No. 84.063, 84.268, 84.007, 84.038, 84.033 Recommendation: The College should review its policies and procedures on determining student's withdrawals, specifically the proper calculation elements and proper rounding were necessary to ensure timely and accurate returns of Title IV funds. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: 1) Break days of 5 consecutive days or more were incorrectly added to PowerFaids during setup. The College has reviewed and updated its policies and procedures to show that both the Director of Financial Aid and the Bursar will review the number of days to be entered into PowerFaids to ensure that prior and post-weekend days are included in the scheduled break when applicable. 2) In manually calculating the Return of Title IV Funds, the adding machine was inadvertently not set to round to three decimal places as required. The Bursar is responsible for calculating Return of Title IV funds and will ensure that any manual calculations are rounded to three decimal places as required. Policies and procedures have been updated to reflect the requirements of this critical step. Name(s) of the contact person(s) responsible for corrective action: Julie Lanski, Director Student Financial Services/Bursar Planned completion date for corrective action plan: May 31, 2026

Student Financial Assistance Cluster – Federal Assistance Listing No. 84.063, 84.268, 84.007, 84.038, 84.033 Recommendation: The College should review its policies and procedures on reviewing enrollment status changes to NSLDS to ensure that all status changes are being reported timely and accurately to be in compliance with regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Registrar will review and strengthen the enrollment report to ensure it pulls all required information according to the needs of the National Student Clearinghouse (NSCL) and the NSLDS. The Registration and Records Office will continue to work with NSCL and NSLDS on specific enrollment scenarios that require different submission update requirements. Name(s) of the contact person(s) responsible for corrective action: Katelyn Letizia, Interim Vice President Institutional Effectiveness and Academic Strategy. Planned completion date for corrective action plan: May 31, 2026

Federal Agency Name: U.S. Department of Education Program Name: Student Financial Assistance Cluster Federal Financial Assistance Listing #: 84.007, 84.033, 84.063, 84.268 Compliance Requirement: Special Tests and Provisions – Return of Title IV Funds Significant deficiency in internal control Finding Summary: One instance was identified where the amount of funds to be returned was not calculated/remitted correctly. Responsible Individuals: Randy Mashek, Financial Aid Director and Dawn Fleming, Assistant Director of Financial Aid Corrective Action Plan: The Financial Aid Office will collaborate with the full Student Services team (Advising, Registrar, Financial Aid, Finance) in order to continue a strong focus on the importance of the Return of Title IV Funds (R2T4) policy and procedures. This focus will improve the process in order to better accurately calculate R2T4s as well as communicate the importance of dates more effectively with students and staff regarding withdrawals and earned aid and the financial impacts of them. Implementation of certain measures has already begun in 2025-26 with the following steps: 1. Return of Title IV Funds (R2T4) calculations in real time as students withdraw from classes throughout the semester. Cross training for the administration staff processing withdrawals was implemented over the past two years. A checks and balances system are now in place to alert the Assistant Director and Director of Financial Aid whenever a complete withdrawal is made. Once the notification is made the Assistant Director reviews, calculates and processes the R2T4. The Director will perform a monthly quality sampling throughout the semester in order to review and test R2T4 calculations for accuracy and document when that happens. This process was in practice as the Assistant Director was being trained by the Director over the past year and now, we will begin to formalize that process as well as document each instance and build it into the workflow starting with the spring 2026 semester. 2. Additionally, ongoing training for R2T4 rules and regulations is completed throughout the year through our state and national associations (NASFAA and IASFAA) by the Assistant Director and Director as well as webinar and training from Federal Student Aid (FSA). From these trainings we will continue to share with Advising and support staff in order to educate and train them on the implications of withdrawals and the importance of earned aid dates, modular classes, class start and end dates, and college breaks that all impact the calculation of days in the R2T4 process and communication. Anticipated Completion Date: Ongoing. Fully functional with the start of 2026-27 year

Federal Agency Name: U.S. Department of Education Program Name: Student Financial Assistance Cluster Federal Financial Assistance Listing #: 84.007, 84.033, 84.063, 84.268 Compliance Requirement: Special Tests and Provisions – Enrollment Reporting Material Weakness in Internal Control Finding Summary: During testing of compliance for Enrollment Reporting, there were 9 instances out of 60 where the College did not report a student’s change in enrollment status accurately or within the required time frame of 60 days from the effective date of the student’s change in enrollment status. Responsible Individuals: Karla Winter, Registrar and Randy Mashek, Financial Aid Director Corrective Action Plan: The Registrar’s Office will collaborate with the Financial Aid Office to provide oversight to the Enrollment Reporting process. Oversight includes timely batch reporting of student enrollment statuses to the National Student Clearinghouse (NSC) for all periods of enrollment, NSC Error Report review and resolution between NICC’s internal Student Information System (Colleague) with the National Student Loan Data System (NSLDS), as well as having documented policies and procedures in place in order to administer, implement and comply with the full scope of Enrollment Reporting on an ongoing basis. The Policies and Procedures will address the previously recommended requirement of the Registrar’s Office to conduct and retain evidence of quality sampling once a semester. Implementation of certain measures has already begun in 2025-26 with the following steps: 1. The Registrar implemented a new reporting schedule with NSC to capture the Winterim semester (which is part of the spring financial aid semester) to accurately reflect the enrollment from that special mini session. This was implemented for the Winterim 2025 session (December 2025-January 2026) and reporting began 1/9/2026. 2. The Financial Aid Office is implementing a new system to review and resolve NSC Error Reports (NSLDS SSCR) beginning with the spring 2026 semester. These reports are provided by the Registrar, and produced by NSC after each enrollment submission. The Financial Aid staff will review Colleague and NSLDS records in order to determine corrective action in the required timeframe and then provide enrollment changes to NSC to have the student’s NSLDS record updated with accurate information. 3. NSC will update NICC’s reporting codes from the current two branches (00 Calmar and 01 Peosta) to a single reporting branch (00) beginning with the fall 2026 semester (2026-27 academic year). This change will align with recent updates over the past few years from two individual school codes (Calmar and Peosta) to just one code with several Federal Student Aid (FSA) systems. These systems include Student Loan origination at the Common Origination & Disbursement Web Site (COD), FSA Partner Connect as well as the Free Application for Federal Student Aid (FAFSA) school codes. The decision to transition from two codes to one in many reporting areas was made in order to reduce student confusion between campuses when completing the FAFSA, reduce reporting inefficiencies and errors, as well as streamline multiple reporting challenges for federal and state aid reporting. The actual process presented many challenges for NICC and FSA and was implemented over the past two years successfully. However, the transition did not include the enrollment reporting side with NSC/NSLDS which has been the source of many of our multiple student record errors. Anticipated Completion Date: Ongoing. Fully functional with the start of 2026-27 year.

FINDING 2025-001 Name of Responsible Individual: Daniel Arndt, Registrar Corrective Action: Management acknowledges the finding regarding the inaccurate reporting of student data elements under the Program-Level record on the NSLDS website. We also acknowledge that this is technically a repeat finding from the prior year; however, the finding identified for one student out of the forty students selected was prior to the implementation of the University’s Corrective Action Plan on January 31, 2025. The University previously addressed this issue and implemented a corrective action plan that included updating our reporting frequency and enhancing our data review processes as follows: Updated Reporting Frequency: As of January 2025, the University now includes the non-compulsory terms, summer 1 and winter sessions, in its reporting. The previous institutional practice did not include reporting program-level data for these terms given that said terms do not involve federal financial aid. This change ensures that all program-level data, regardless of federal financial aid involvement, is accurately reported. Secondary Check Process: Each month, the Compliance Officer reviews a sample of 100 students from NSLDS to verify significant data elements, including program enrollment effective dates. After the initial review, the Compliance Officer summarizes the findings and shares them with the Associate Registrar and Registrar for a secondary review. Any necessary edits are made, followed by a review of an additional 25 students to ensure accuracy. We believe the corrective action steps are critical in ensuring accurate reporting and preventing this issue in the future, and we believe they have been effectively implemented. We believe that the fact that only one of forty students selected was reported incorrectly is an indication that our corrective action plan has been effective. Completion Date: January 31, 2025

Management is responsible for establishing and maintaining effective internal controls over compliance under Uniform Guidance. Personnel Responsible for Corrective Action Plan: Jana Parks, Student Financial Aid Director, and Melissa VanLeiden, Chief Accounting Officer. Anticipated Completion Date: The corrective action plan will be implemented by June 30, 2026. Corrective Action Plan: We have re-established automated enrollment report generation through our SIS, which is now configured to generate enrollment reports for submission to the National Student Clearinghouse (NSC). Before current reports can be submitted, we are required to submit manually created enrollment reports for each missed reporting period from December 2024 through December 2025. Preparation of these reports is currently underway, and we expect to resume submissions on our established enrollment reporting schedule no later than the end of the Spring 2026 semester.

Upper Iowa University Corrective Action Plan For the Year Ended June 30, 2025 Finding 2025-001 Condition: Of the 25 students tested, one student was not reported to NSLDS. There is an issue with the student’s record in NSLDS stemming from information reported by a prior school. The University is reporting information to the National Student Clearinghouse (NSC) servicer but the information is failing to link up to their NSLDS record resulting in her record ultimately not being reported. Corrective Action Plan: Although the University is not able to prevent or resolve rejected records directly when they occur for this reason, we can provide additional information to the Clearinghouse that may allow them to resolve the issue. This sometimes requires requesting that the student provide additional documents and/or submitting information to the Clearinghouse for their review. Rejected records are reviewed by the University after each submission. In addition to this initial review, we have added additional reject tracking in our database. This allows us to better monitor and follow up on records with this issue while we wait for needed information or for the Clearinghouse to review additional information we have submitted. Completion Date: 9/17/2025 Name(s) of Contact Person(s) Responsible for Corrective Action: Jill Austin, CRM Administrator

The records in the student sample that were tested were from the Fall semester 2024. In addition to strengthening controls and staff training, the College completed an internal audit on 4/30/25 of all student accounts to ensure compliance with cash management practices for future federal awards and corrected any findings. As a means of maintaining compliance under the Heightened Cash Monitoring 1 Payment Method (HCM1) as described under 34 C.F.R. § 668.162(d)(1), Keystone first makes disbursements to eligible students and parents and pays any remaining credit balances before it requests or receives funds for the amount of those disbursements from the Department. The College’s practices and internal controls for Title IV, HEA program funds received from the Department reflect the compliance criteria as required.

Finding 2025-002: Eligibility Student Financial Assistance Cluster U.S. Department of Education Award Period: July 1, 2024 – June 30, 2025 Responsible Person: Wilbert Casaine, Executive Director of Student Financial Aid, 609-771-2211 Corrective Action Plan: During the compliance audit for the fiscal year ending June 30, 2025, the College had one student out of a sample of 40 who was selected for the eligibility compliance and control testing that had an incorrect Pell grant award for the Spring 2025 semester. The student was identified as having received the incorrect amount of Pell based on changes in enrollment intensity during the College’s Add/Drop period. The result of this error was that the student was under-awarded the Pell grant. Once the error was discovered, the student’s Pell grant was increased to the correct amount and reported to COD. The College recognizes the importance of reviewing student enrollment intensity changes throughout the disbursement process to ensure it does not result in errors in the calculation and disbursement of aid in accordance with 34 CFR 668.42, 34 CFR 673.5, 34 CFR 673.6, and 34 CFR 685.301. The College has a robust process for confirming enrollment intensity, which includes automated system reviews of student records, as well as manual/in-person award confirmations. In this student’s case, there were multiple course changes in a short span of time during the Spring semester’s Add/Drop period, which required multiple reviews and revisions to the student’s financial aid package. During one of the reviews, a staff member did not accurately increase the student’s Pell grant award when it was flagged by the system as being incorrect. As part of our corrective action, we have implemented additional reporting enhancements to review and confirm accurate awards. The reports are listed below: • The Office of Records and Registration will provide a comprehensive roster of student registration actions immediately following the Add/Drop period, and continuing weekly, until mid-semester, for review. • The Senior Business Analyst in the Financial Aid Office created an enhanced part-time user edit report of Pell students only who are not full-time at the end of the Add/Drop period for review. • The Analyst in the Financial Aid office developed a report to compare student enrollment intensity changes weekly, after the Add/Drop period is over, to identify and correct discrepancies in real time. The aforementioned corrective actions in the Financial Aid Office were fully operational for the Fall 2025 semester. Internal control reviews confirmed that no award errors occurred during the Fall 2025 term, validating the effectiveness of the new reporting and review structure. The College implemented the corrective action on 08/26/2025. Anticipated Completion Date: Completed in August 2025

Finding 2025-001: Special Tests and Provisions – NSLDS Reporting Student Financial Assistance Cluster U.S. Department of Education Award Period: July 1, 2024 – June 30, 2025 Responsible Persons: Heba Jahama, Director of Records and Registration, 609-771-2376, Billy Peitz, Associate Director of Records, Reporting, and Enrollment, 609-771-2333 Corrective Action Plan: For the fiscal year ending June 30, 2025, the College had 1 student out of an initial sample of 40, for which it was noted that the enrollment effective date was reported by the College to the NSLDS inaccurately. The student was noted by the College as having a status of “LOA” (Leave of Absence), but this LOA was not reported to the NSLDS appropriately. Program-Level Enrollment data indicated this student as being withdrawn, but the Campus-Level Enrollment data did not. Additionally, 2 students out of an additional sample of 40 tested were found to have not followed the internal College policy for determining the enrollment effective date, despite internal College records matching those of the NSLDS. Lastly, for 1 out of the additional 40 students, the effective date per internal College records did not match NSLDS. The College recognizes the importance of ensuring accurate enrollment data regarding NSLDS reporting under the Pell Grant and the Direct Loan and FFEL programs via the NSLDS (OMB No. 1845-0035). Institutions must review, update, and certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. After a thorough review of the data errors, it was determined that the root cause was a lack of standardized business processes for LOA and Withdrawal actions. We have since implemented several corrective actions to ensure data integrity and institutional consistency. New procedural documentation has been established to clarify the standard operating procedure for LOAs and Withdrawals. This documentation provides a definitive framework for staff to ensure that term withdrawal dates within PAWS (the system of record) are perfectly aligned with program status updates transmitted to the National Student Clearinghouse (NSC). The updated operating procedures have been shared with all relevant personnel to ensure that staff members are proficient in the new PAWS-to-NSC alignment protocols. In addition, the College has noted that the date of record for student registration must serve as the primary trigger for external reporting. This eliminates inconsistencies between the date a student initiates a withdrawal and the date reported to external agencies. To mitigate the risk of reporting lags, the College has revised its reporting schedule. LOA and Withdrawal updates are now transmitted to the Clearinghouse on a regular, recurring basis, independent of the standard comprehensive enrollment file processing cycle. This ensures that student status changes are reflected in the NSC database timely. The College implemented the corrective action on 12/16/2025. Anticipated Completion Date: Completed in December 2025, with ongoing monitoring

Individual Responsible for Corrective Action: Kenzie Cox, Associate VP of Strategic Enrollment Corrective Action: Southern Virginia University has taken the following steps to resolve the issue: • A new internal check was created to verify that withdrawal dates match the verified withdrawal date before federal aid or institutional charges are updated. • The withdrawal form is being updated to require Financial Aid and Student Accounts signatures, ensuring that all relevant offices receive the information before it is finalized. • Communication procedures between the Registrar, Financial Aid, and Student Accounts have been formalized to ensure that withdrawal information is shared consistently. Southern Virginia University has taken the following preventive actions: • A regular withdrawal review will be completed to confirm accurate dates, status changes, and timely updates across all departments and systems. • The University will maintain and distribute an updated written withdrawal workflow to impacted departments clarifying communication, verification, and documentation requirements for university withdrawals. • Staff in all involved departments will participate in training to reinforce the updated procedures. Anticipated Completion Date: Process started in February 2026; form revisions and process revisions implementation anticipated completion April 30, 2026. Ongoing monitoring thereafter.

Individual Responsible for Corrective Action: Kenzie Cox, Associate VP of Strategic Enrollment Corrective Action: In October 2025, Southern Virginia University transitioned both award letter notifications and loan disbursement notifications to an automated process through the Student Financial Aid Management System. All notifications are now system-generated and automatically logged within each student’s record, ensuring a complete and permanent communication history. The Financial Aid Office will maintain automated notification workflows and conduct an annual review before each aid year to verify that award letter and loan disbursement notifications are generating automatically, and documentation of the notifications is happening correctly. Anticipated Completion Date: October 2025 (process fully implemented).

Individual Responsible for Corrective Action: Kenzie Cox, Associate VP of Strategic Enrollment Corrective Action: To ensure ongoing accuracy in enrollment reporting, Southern Virginia University is strengthening communication and coordination across departments involved in the reporting process. Beginning February 2026, the Financial Aid Office implemented a workflow to review NSC and NSLDS error reports more promptly and resolve discrepancies as they arise. Financial Aid will monitor this process monthly until errors are no longer identified, ensuring timely and accurate reporting going forward. The Registrar's Office will receive training on date reporting requirements and expectations for NSLDS so that they use the correct enrollment change dates. Anticipated Completion Date: Initial corrective actions implemented February 2026. Anticipated completion expected March 2026; ongoing monitoring in place.

Loras College Corrective Action Plan For the year ended June 30, 2025 February 19, 2026 Finding 2025-003: Disbursement Notifications Assistance Listing Number: 84.268 Federal Agency: U.S. Department of Education Condition: For one student in the sample of 25 students tested, the College was unable to provide support that timely notification was provided to the student receiving Direct Loan funds. The communication should include the date and amount of disbursements and the right and process for how to cancel all or a part of the loans. Recommendation: The College should implement a policy/control to ensure that the required notifications are provided to Direct Loan students and documentation is retained. Corrective Action: Management reviewed the process for disbursement notification and has established a process whereby all notifications sent electronically are saved to the College’s cloud based system. In addition, The financial Aid Director will review the disbursement notification process completed by the Financial Aid Counselor at least monthly and not the review on a shared electronic calendar. The review will ensure all required elements are included in the disbursement notification. This procedure will be implemented during the fidcal year ending May 31, 2026. Renate A. Root Treasurer 1450 Alta Vista St. Dubuque, IA 52001 563-588-7775