Corrective Action Plans

Dear Mr. Waguespack: Thank you for the opportunity to offer the University's response to the referenced finding. FINDING: Inadequate Internal Controls and Noncompliance with Cash Management Requirements RESPONSE: Southern University - Baton Rouge (SUBR) concurs with the above noted finding. Management concurs with the finding and the recommendation to strengthen its procedures over the drawing of Title IV funds to ensure timely compliance with federal cash management requirements. This finding resulted from an instance of requesting Title IV funds in total without specificity of Direct Loans or Pell Grants. To address this matter, the following corrective actions have been implemented: 1. The Financial Aid Director has instituted a process whereby the authorized draws for both Pell and Direct Loans are requested separately to assure that a clear distinction is made between the type of Student Aid being requested. This change was effective October 2023. 2. The University has moved to requesting Title IV funds only once per month to assure there is no duplicative request made. This change was effective July 1, 2024. Both of these changes will ensure better control of and elimination of the risk of such occurring. This corrective has been implemented fully. This will remain an ongoing process subject to continuous review and refinement to ensure institutional compliance. The individuals responsible for overseeing these corrective actions are: • Dr. Anthony Jackson, Interim Vice Chancellor for Enrollment Management • Taishieka Davis, Director of Financial Aid We appreciate the opportunity to address this matter and will continue our efforts to strengthen our compliance processes. Should you require any further information, please do not hesitate to contact us. If you have any questions or require additional information, please contact Mrs. Desiree Honore Thomas at 225-771-3571.

Dear Mr. Waguespack: Thank you for the opportunity to offer the University's response to the referenced finding. FINDING: Control Weaknesses over and Noncompliance with Return of Title IV Funds RESPONSE: Southern University - Baton Rouge (SUBR) concurs with the above noted finding. Management concurs with the finding and the recommendation to ensure alignment between our academic calendars and financial aid policies to maintain compliance with federal regulations. To address this matter, the following corrective actions are being implemented: 1. Alignment of Academic Calendars - The Office of the Registrar is working in collaboration with the Division of Academic Affairs to establish a clear mechanism for aligning academic calendars with financial aid calculations. This effort will ensure that the mid-point and 60% completion date are identified using calendar days rather than instructional days, eliminating discrepancies between the financial aid calendar and the academic calendar published in the student information system (Banner 9). 2. Faculty Training and Acknowledgment - To reinforce the importance of accurate attendance reporting and grading, the Office of the Registrar and the Division of Academic Affairs will develop a structured training document for faculty each term. Faculty members will be required to review and sign an acknowledgment form detailing their responsibilities related to attendance tracking and grade submission in the Banner 9 system. 3. Enhancements to the Withdrawal Process - The Official Withdrawal Form will be updated to require documented evidence of a student's written request to withdraw. Additionally, administrative withdrawal and drop policies will be revised to define a specific timeframe for submission, ensuring timely processing and compliance. The anticipated completion date for full implementation of these corrective actions is February 28, 2025; however, this will remain an ongoing process subject to continuous review and refinement to ensure institutional compliance. The individuals responsible for overseeing these corrective actions are: • Dr. Luria Young, Vice Chancellor for Academic Affairs • Dr. Anthony Jackson, Interim Vice Chancellor for Enrollment Management • Dr. Scott Wicker, Associate Vice Chancellor for Accountability and Accreditation • Taishieka Davis, Director of Financial Aid • Johlana Turner, Interim Registrar We appreciate the opportunity to address this matter and will continue our efforts to strengthen our compliance processes. Should you require any further information, please do not hesitate to contact us. If you have any questions or require additional information, please contact Mrs. Desiree Honore Thomas at 225-771-3571.

Dear Mr. Waguespack: Thank you for the opportunity to offer the University’s response to the referenced finding. FINDING: Control Weaknesses over and noncompliance with Enrollment Reporting RESPONSE: Southern University - Baton Rouge (SUBR) concurs with the above noted finding. Management concurs with this finding. Southern University and A&M College, especially the Office of Financial Aid, and the Office of the Registrar, are committed to ensuring full compliance with federal regulations and improving their reporting processes. Management fixed the file structure with the assistance of an external consultant. Management has also begun a comprehensive review of the current enrollment reporting procedures to identify and address gaps in compliance with federal regulations. New internal controls are being established to verify the accuracy and timeliness of enrollment reporting, including additional data validation checks before submission to NSLDS. The University has engaged an external consultant to assist with assessment and are exploring system upgrades to streamline and automate the submission processes to prevent recurring issues associated with manual operations outside of Banner 9. We acknowledge the auditor's recommendations to strengthen our policies, procedures, and practices for modifying enrollment statuses and tracking these changes promptly. Training sessions will be provided to all enrollment staff, including registrar, to reinforce compliance requirements and reporting deadlines for Federal Pell Grant and Federal Direct Student Loan recipients. Managers will be assigned to monitor and audit enrollment data accuracy and submission timeliness continuously. Regular internal audits will be conducted to ensure ongoing compliance with periodic reports submitted to senior management for review. Management anticipate all corrective actions and implementation to be completed over the next several months, with quarterly progress updates provided to relevant stakeholders. Management is committed to taking the necessary steps to strengthen enrollment reporting procedures and ensure compliance with federal regulations to support students and maintain SUBR's reputation for regulatory compliance. The Vice Chancellor of Enrollment Management Anthony Jackson and Associate Vice Chancellor of Accountability and Accreditation Scott Wicker be responsible for implementing and monitoring corrective actions. If you have any questions or require additional information, please contact Mrs. Desiree Honore Thomas, Associate Vice President at 225-771-3571.

Dear Mr. Waguespack: LSUS takes very seriously the security of student information. Finding: Noncompliance with Gramm-Leach-Bliley Act Regarding Student Information Security Management Response: Management concurs with the finding. The University will develop, implement, and maintain an information security program to ensure the security and confidentiality of student information and to protect against any anticipated threats or hazards to the security or integrity of such information. Responsible Personnel: Scott Hardwick, Associate Vice Chancellor of Information Technology & CIO. Implementation Date: December 1, 2025

Dear Mr. Waguespack: LSUS takes very seriously our responsibility of returning Title IV Funds in the required time frame. LSUS is proud of the fact that during the time frame of September 2014 to May 2024, the university disbursed more than $445.5 million to students or families. A report of outstanding checks was being generated by the Department of Accounting Services on an ad hoc basis and sent to the Department of Financial Aid. However, there was a misunderstanding about which department was following up. Therefore, each department thought the other department was following up on the outstanding checks. Finding: Failure to Return Title IV Funds in Required Time Frames Management Response: Management concurs with the finding. The University will develop and implement an updated process to return all Title IV funds that are not received by a student or parent to the USDOE within the required timeframes. Responsible Personnel: Veronica Crabtree, Associate Vice Chancellor of Financer & Executive Director of Accounting Services and Lisa Pickering, Executive Director of Financial Aid. Implementation Date: March 31, 2025

Finding 2024‐005 Student Financial Assistance Cluster ALN: 84.268 Finding: The College did not submit the required monthly reconciliation for the direct loan program Corrective Action Plan: To address the issue of not submitting the required monthly reconciliation for the Direct Loan Program, the Financial Aid office has implemented a process to ensure Direct Loan reconciliation is completed monthly. An outlook calendar reminder entry will serve as a reminder to begin the reconciliation process on the 15th of each month. The Senior Financial Aid Counselor requests a YTD SAS report from COD, which contains loan data from the central processor, the report is delivered to our electronic mailbox within 24 hours. The Senior Financial Aid Counselor runs a second report from the SIS System to generate YTD loan disbursement information. The files are reformatted and compared by the Senior Financial Aid Counselor. Any discrepancies are reviewed and resolved in the appropriate system (COD or SIS), dependent on the discrepancy. The Senior Counselor notifies the Senior Manager of Financial Aid that the comparison and updates are complete. The Senior Manager of Financial Aid then reviews delta from the compared data and verifies that corrections are made in the correct system. The Senior Manager ensures that resolved amount is within the COD delta found on the summary page in COD and a screenshot is maintained in the reconciliation file. Senior Manager marks “Sr Manager Reviewed” column on the loan reconciliation spreadsheet with a date of review as evidence. The completed reconciliation is maintained in the Financial Aid Shared Directory. Person Responsible: Scott Moore, Senior Manager, Financial Aid, Baylor College of Medicine Expected Completion: April 2024

Title: Student Financial Assistance Cluster – Assistance Listing Nos. 84.038, 84.268, 84.033, 84.007, 84.063 Recommendation: We recommend that the Corporation review each element of GLBA to ensure compliance with all necessary requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The College will update its Written Information Security Program to include a description of the use of a data inventory that includes how we identify and manage data, personnel, devices and facilities. Some of these items can be found in the other documents submitted but we will merge them into our WISP. Multi-factor authentication is in use for individuals accessing sensitive information but that also was not clearly identified in the WISP and will be added. To ensure GLBA compliance going forward, the College has contracted FRSecure to develop a risk assessment and roadmap which will do system scan for issues, an assessor will interview staff including IT, HR, Finance Leaders and others to learn more about the currentstate of overall security program. Compliance with GLBA will be part of their review. Finally,FRSecure will issue an assessment ‘Roadmap Plan’ for the department to review andpending results, implement as feasible.

Title: Student Financial Assistance Cluster – Assistance Listing Nos. 84.038, 84.268, 84.033, 84.007, 84.063 Recommendation: We recommend the Corporation review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: While this is classified as a repeat finding as it involves enrollment reporting, it is a different type of issue than prior year, which involved withdrawal date reporting. The College will implement a process to ensure that the beginning term date matches the enrollment record. The College will make sure that the campus enrollment date will not be affected by change of major date going forward and will make sure that correct dates are coming across and being correctly populated from the Admissions Department. Name of the contact person responsible for corrective action: Jeff Younge, Director of Financial Aid Planned completion date for corrective action plan: Fiscal Year 2025

Corrective Action The corrective action that will be taken is that Pell Grant disbursements will be reported timely to COD. The following will support this effort: 1. Address Systematic Issues 2. Enhance Staff Training 3. Implement Regular Monitoring and Auditing Persons Responsible for Corrective Action The corrective action plan will be completed by Corry Unis, Vice President for Enrollment Management and Diana Draper, Executive Director of Financial Aid. Completion Date Initial corrective action was taken by Diana Draper, Financial Aid Director, in March 2024 when the student disbursements were reports to COD. Additional corrective actions included systematic controls, additional training, and greater internal monitoring and auditing have been put in place.

Finding During testing it was identified that for one (1) of thirty (30) students selected for test work, one (1) of the ten (10) required verification elements, specifically the parents’ education credits, was not accurately reflected within the student’s SAR and was not submitted for correction by the institution. Endicott College Responsible Contact Maria Morelli, Director of Financial Aid Corrective Action Plan Anticipated Completion Date March 2025

2024-001: Special Tests and Provisions – Student Financial Assistance Cluster Management’s view and corrective action plan Management concurs with the audit findings related to the disbursement of loan funds, verification of financial aid applications and return of Title IV funds. These findings are directly attributed to the challenge of maintaining staffing levels. The Student Financial Aid Office became fully staffed in March 2025. Management will implement enhanced controls and training are required within the Student Financial Aid office. Additionally, management concurs with the following audit findings pertaining to noncompliance with enrollment reporting requirements for 20 of the 25 sampled. Management will implement enhanced controls and additional dedicated resources are required within the Registrar’s Office in order to monitor and assure compliance with regulatory requirements. Additionally, efforts will be employed to monitor and confirm the timely and accurate submission of information from the National Student Clearinghouse to the NSLDS. Furthermore, the procedural and training enhancements of the Financial Aid and Registrar’s Offices, as well as their resource plans, will be reviewed and approved by the Office of Internal Audit. Implementation date: September 2025 Raelynn Cooter, PhD Vice Provost for Academic Infrastructure and Effectiveness.

We concur with this finding. Last year the school implemented a significant upgrade to its student information system, Banner. The transition to Banner SaaS was difficult and resulted in significant breakdowns in operations that are slowly recovering, and efforts are underway to implement modifications to ensure smooth operations. This, along with omissions on our part resulted in noncompliance with the reporting requirements. We will going forward, institute timely submissions to meet the requirements, while we continue to work with our vendors in fixing the software issues that produce the required reports.

We concur with the audit finding regarding the need to ensure disbursement reporting is completed within the required 15-day threshold. As stated, of the 40 disbursements selected for testing, one disbursement was reported late. The instance noted was an isolated case that occurred during the institution's transition to a new system platform. We recognize the importance of timely reporting to maintain compliance with federal regulations. Corrective Action: The Office of Student Financial Services has reinforced existing procedures to ensure that all disbursement data—specifically the disbursement date and amount—is accurately reviewed, recorded, and reported within 15 calendar days of the disbursement being made. This process is effective immediately. Additional Monitoring Measures: 1. A designated financial aid team member will conduct weekly reviews of all disbursement records to verify timely reporting. 2. A monthly reconciliation report will be generated to confirm that all disbursements made during the month have been reported within the required timeframe. 3. The Executive Director of Financial Aid will review the monthly reconciliation reports and certify compliance. 4. Calendar alerts have been implemented to prompt staff of upcoming reporting deadlines. Training and Accountability: 1. Staff responsible for disbursement reporting have been trained on the new system process for this federal requirement, which includes ongoing discussion with the Ellucian team as we continue to navigate Banner SaaS. 2. Ongoing monitoring and periodic internal audits will be conducted to ensure sustained compliance. The corrective action plan has been fully implemented and is currently in effect. We are committed to maintaining compliance with all federal regulations governing financial aid disbursements.

The Controller will ensure he signs the monthly schedule on all future bank reconciliations that he reviews. The controller will sign all bank reconciliations starting March 2024.

To ensure compliance with the 60-day enrollment update requirement, the Registrar's Office staff will manually enter any withdrawals and leaves of absence into the National Student Clearinghouse (NSC) website upon processing them in Coileague. Using the Student Look Up tool on the NSC website, they will update the student's status along with the status start date. Additionally, the confirmation email from the NSC, which verifies that the enrollment update has been processed, will be saved in the student's record.

Federal Perkins Loan Program, ALN 84.038; Grant period—Year ended June 30, 2024 Condition: There was lack of documentation related to notices for loans paid off for eight out of ten students tested. Criteria: According to §674.19(e)(4)(iii), after the loan obligation is satisfied, the institution shall return the original or a true and exact copy of the note marked "paid in full" to the borrower, or otherwise notify the borrower in writing that the loan is paid in full, and retain a copy for the prescribed period. Cause: The College was unable to locate the communication sent to certain students of loan payoff as a result of staff turnover. Effect: Certain documentation for notification of loan satisfaction could not be provided. Context: During the compliance audit testing of ALN 84.038, it was determined that documentation to confirm delivery of loan satisfaction notices could not be provided for certain students selected for testing. Recommendation: We recommend all required documentation be backed up to support compliance with certain requirements. View of Responsible Officials and Planned Corrective Action: The College is currently working within the financial aid department to make sure the College has support for all communications.

The following was noted during the audit of Federal programs in accordance with UMB Uniform Guidance. Management proposes the following Corrective Action Plan: Finding 2024-001: Notification of Title IV loan disbursements and the borrower’s right to cancel all or part of the loan was not provided appropriately. Management’s View The University agrees with this finding. Two separate issues contributed to the finding. Vanderbilt identified both issues internally and implemented immediate measures to mitigate the impact to students ensuring all notifications are properly delivered prospectively. First, human error, primarily due to incomplete documentation and a new staff member running the process, caused the issue of some loan notifications not being sent. However, the University implemented quality control steps in July of 2024 to resolve the issue. These steps included providing additional training to the staff member, correcting the documentation, and updating the scheduled run control of the process to correctly identify all students with any federal loan disbursement. In addition, the University implemented a quality control process creating a daily report, generated from multiple PeopleSoft queries, that identifies any students who have a federal loan either initially or subsequently disbursed who are missing the required notifications. Second, a data merge issue combined with larger than usual volumes of students receiving loan disbursements caused a processing error resulting in blank information on loan notifications. The initial run in the spring semester included a larger than usual number of students with loan disbursements who shared the same start date, whereas in comparison fall start dates generally are more varied. The University identified this issue in January through manual reviews and manually sent subsequent notifications to affected students. Corrective Action Plan As a corrective measure, Vanderbilt took the following actions to address the identified issues: 1. Reviewed and updated documentation related to the Peoplesoft notification process to ensure completeness and accuracy. 2. Provided additional staff training to the personnel responsible for running the notifications process within Peoplesoft. 3. Created a quality review process to review a daily report from Peoplesoft that identifies any student with a federal loan disbursement that is missing required notifications. 4. Updated queries related to communication generation to run more efficiently. 5. Modified the communication generation process to run nightly instead of weekly to ensure data limits are appropriate to allow the process to run completely and accurately. 6. Created a quality review process to review a weekly report from PeopleSoft to timely identify any missing information in student notifications. Vanderbilt fully implemented the steps above by September 2024. For follow-up questions and information, please contact Brent Tener, Assistant Provost and Executive Director of Student Financial Aid and Scholarships at Vanderbilt University.

Finding 2024-002: Incomplete Verification Tested sixty-three files and an application selected for verification did not match supporting documentation for one student. Comments on Finding and Recommendation(s): The Institute agrees with the finding and Auditor's recommendation. Actions Taken or Planned: The school has implemented an internal check and balance to ensure that all files have the documentation required. The school has also partnered with a third-party servicer that will also be auditing the documentation needed to complete verification of student files.

Finding 2024-001: Incorrect Pell Grants Tested sixty-three files, fifty-four of which were Pell Grant recipients, and four students received Pell grants in excess of their allowed amounts and two students did not receive the full amount of their allowed Pell grants. Comments on Finding and Recommendation(s): The Institute agrees with the finding and Auditor's recommendation. Actions Taken or Planned: The school has revised our method of requesting aid and the enrollment status of each student will be verified individually prior to requesting Pell. We have also removed FA administrator (effective 12/2023) and third-party servicer from their role (effective 4/2024). We will be refunding $2,910 to the Department of Education and crediting $1,053 to the affected student accounts.

2024-003 Student Financial Assistance Cluster Federal Supplemental Educational Opportunity Grants – Assistance Listing No. 84.007 Federal Work-Study Program – Assistance Listing No. 84.033 Federal Pell Grant Program – Assistance Listing No. 84.063 Federal Direct Loans – Assistance Listing No. 84.268 Teacher Education Assistance for College and Higher Education Grants– Assistance Listing No. 84.379 Recommendation: We recommend that the Student Financial Aid department work to ensure disbursements are reported to COD within 15 days of the disbursement date and that disbursements date reported in COD matches the disbursement date to the student. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The McKendree University Financial Aid Office has an automated daily process for notifying COD of all federal aid disbursements after a disbursement is made to a student’s account. This process also includes a step for checking the COD website for any rejected files to confirm that students were correctly reported within a day of loan and TEACH grant disbursements occurring, well within the 15-day required notification time frame. Name(s) of the contact person(s) responsible for corrective action: Patrick Michael, Director of Financial Aid Planned completion date for corrective action plan: June 30, 2025

The College will be forgiving the outstanding balance for all students that the original Perkins loan promissory note was unable to be located, eliminating the requirement to have the promissory note on file.

Corrective Action Plan Year-end June 30, 2024 The following finding was noted during the audit of Federal programs in accordance with 2 CFR 200. Management of Syracuse University agrees with the finding and proposes the following Corrective Action Plan. Finding Number 2024-001: Enrollment Reporting Corrective Action Plan: The University has identified a remediation plan in response to the finding, including the following: 1. Immediate Mitigations (within 90 Days): a. The Office of the Registrar and Office of Financial Aid and Scholarship programs will formalize a quarterly check-in meeting with multiple levels of stakeholders to ensure that our enrollment reporting process is complying and to address any new concerns that may arise. These check-in meetings have been scheduled and begin on March 26, 2025. 2. Long-Term Mitigations (within 12 months) a. The Office of the Registrar will work with Information Technology Services colleagues to implement a Graduates Only Enrollment file for multi-career students to increase the quantity of records that can be automatically processed. This work will be made productional by February 1, 2026 i. This will reduce our error rate and decrease the volume of records requiring manual review, allowing for more focused attention on the most complicated scenarios. Responsible individuals: Michele B Sipley, Executive Director of Financial Aid Kelly Campbell, University Registrar

Finding 2024-001 Federal Agency: Department of Education Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.268 Federal Award Year: Funding periods between July 1, 2023 through June 30, 2024 Compliance Requirement: Eligibility Finding Type: Noncompliance and Significant Deficiency The School of Dental Medicine did not have a report to identify students with a federal loan aggregate related issue. The Office of Admissions and Financial Aid had a report for students in the undergraduate and graduate careers (excluding the Dental Medicine professional Primary Academic Program). The Office of Admissions and Financial Aid added the School of Dental Medicine staff as a recipient on this report to assist them in identifying students with an ISIR code indicating students that are approaching or have already exceeded the Federal Direct Loan aggregate limits for review. Since September 2024, the School of Dental Medicine has been receiving and reviewing the Aggregate Overpay Checklist report. Name of the contact person: Michelle Jackson Completion date: Already completed, September 2024

The correc􀆟ve ac􀆟on plan is as follows: Anna L. Stovall, with the assistance of the Registrar’s office, will review the status of graduated students during the first two weeks in June 2025, to ensure their effec􀆟ve graduate date is accurately reported. Further, those students who have informed Davidson College that they are on a leave of absence will also be reviewed in the coming weeks. It is an􀆟cipated that these ac􀆟vi􀆟es will be completed not later than June 30, 2025. These ac􀆟ons are in response to audit finding 2024-001.

Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: SOU acknowledges at the time of the audit; management could not ascertain whether the contract with BankMobile was uploaded to the Department of Education Contract portal as there is no repository or database available to schools. This submission was completed on March 17, 2025 and documentation was retained to support the submission. Name(s) of the contact person(s) responsible for corrective action: Daniel M. Tramuta, Interim Director of Financial Aid Planned completion date for corrective action plan: March 2025