Corrective Action Plans

Finding Number 2025-001. Enrollment Reporting - The College hired a full-time Registrar in December 2025. Upon onboarding, the Registrar will collaborate with the College’s third-party consultant(s) to conduct a comprehensive review and re-evaluation of the enrollment reporting configuration and associated business processes. This review will ensure alignment with federal reporting requirements and institutional best practices. During this review period, the Registrar and the Financial Aid Office will jointly implement ongoing monitoring procedures to ensure that all students are accurately captured and that enrollment statuses are correctly and timely reported to the National Student Loan Data System (NSLDS). These monitoring controls will remain in place until the enrollment reporting system and processes are fully vetted and validated for compliance. Anticipated Completion Date - February 28, 2026. Responsible Contact Person for Planned Corrective Action: Dominique Colyer, Director of Financial Aid

The Office of Financial Aid has implemented a formal annual review process to determine whether Golden Gate University should request a waiver of the Federal Work-Study (FWS) expenditure requirement for the upcoming waiver period. Each February, the Associate Director of Financial Aid and the Senior Director of Student Financial Services will evaluate projected spending and decide if a waiver is necessary. If a waiver is required, it will be submitted within the designated deadline, which typically falls between March and April each year.

Audit Finding 2025-002 Special Tests and Provisions Enrollment Reporting: Significant Deficiency in Internal Control over Compliance Timely Reporting Errors:  The University was still reporting students from the School of Business and Society and the School of Education under a different branch code (001322-80) in its third-party provider (National Student Clearinghouse), even though that branch code did not exist in the National Student Loan Data System (NSLDS). This was an artifact of a previous academic structure and calendar. With the help of the provider, this branch has been consolidated with the main branch (001322-00) and all programs on the same calendar are now reported simultaneously helping to ensure that all students are recorded.  Upon acceptance of the submitted files to NSLDS, the Registrar’s Office will compare the roster in NSLDS to that of the submitted roster and the current census roster to identify and correct discrepancies either in the student information system or NSLDS. Availability of these types of reports in NSLDS is still being determined. Contact Person Responsible for Corrective Action: Eric Maczka, University Registrar and Director of Institutional Research, eric_maczka@redlands.edu, 909-748-8333 Anticipated Completion Date: March 15, 2026

Audit Finding 2025-001 Special Tests and Provisions Return of Title IV Funding (R2T4): Significant Deficiency in Internal Control over Compliance Student Financial Services has strengthened the current R2T4 calendar set up and calculation review process. An additional administrator in SFS reviews each calendar created in COD to specifically check and document the total number of days in the payment period including scheduled breaks. In addition, University calendars have now been approved for several years in advance so this will prevent late date changes. At the time this student was identified, all students in this program were reviewed for R2T4s and it was confirmed that this is the only student in the program who withdrew and required an R2T4 calculation. The R2T4 was reprocessed with the corrected number of days. The student was contacted about the error in the calculation and informed of their eligibility for an additional $71 in Direct Loan. The student chose not to increase their loan by the additional $71 so no adjustments were made to the student record or to COD. Contact person responsible for Corrective Action: Alisha Aguilar, Associate Vice President of Student Financial Services and Military & Veteran Services alisha_aguilar@redlands.edu, 909-748-8047 Anticipated Completion Date: January 1, 2026

2025-001 – U.S. Department of Education, SFA Cluster, Special Tests and Provisions - Incorrect Return of Title IV (R2T4) Calculations (Significant Deficiency). Condition: From a population of 17 students that officially or unofficially withdrew during the term, we tested four students. All four students required Return of Title IV (R2T4) refund calculations. During our review, we noted that the University excluded only five days from the total number of days in the semester for the Fall 2024 and Spring 2025 breaks. However, each break period included five weekdays plus the surrounding weekend days, resulting in a total of nine days that should have been excluded. The University did not exclude the four weekend days adjacent to the breaks, leading to incorrect total day counts in the R2T4 calculations. Criteria: Under 34 CFR §668.22(f)(2)(i), the total number of calendar days in a payment period includes all days within the period that a student was scheduled to complete, except scheduled breaks of at least five consecutive days, which must be excluded from both the total number of days and the number of days completed. When classes end on a Friday and resume the following Monday after a week‑long break, both weekends (four days) and the five weekdays of the break are excluded from the R2T4 calculation, for a total exclusion of nine days. Cause: Controls to ensure proper calculation of Title IV refunds did not function as related to the condition above. Effect: R2T4 calculations for the students tested who withdrew during the Fall 2024 and Spring 2025 terms were incorrect. As a result, funds were returned in incorrect amounts to both the students and the U.S. Department of Education. Repeat Finding: No. Recommendation: We recommend the University implement and document enhanced procedures to ensure the accurate preparation and review of all Title IV refund calculations, including verification of the correct number of days excluded for scheduled breaks. View of Responsible Officials: The University acknowledges the condition identified. For the Fall 2024 and Spring 2025 terms, the R2T4 calculations excluded only the five instructional weekdays associated with each break and did not exclude the adjacent weekend days. As a result the total number of days in the payment period was overstated, which affected the R2T4 calculations for the students tested. Corrective Action: The University has reviewed the applicable regulatory requirements under 34 CFR§668.22(f)(2)(i) and confirmed that when a scheduled break consists of at least five consecutive days, all calendar days within the break period-including the surrounding weekends when classes end on a Friday and resume the following Monday-must be excluded from the R2T4 calculation. The University has: 1) Recalculated the affected R2T4 determinations for the students identified to ensure the correct number of days is excluded, 2) Returned or recovered any resulting differences in funds, as required, to or from the U.S. Department of Education and the affected students, 3) Updated internal R2T4 calculation procedures and reference materials to explicitly require exclusion of both weekdays and associated weekend days for qualifying scheduled breaks, and 4) Provided additional training to staff responsible for R2T4 calculations to reinforce regulatory requirements and prevent recurrence. Status: Corrective actions have been applied, and revised controls implemented for all future R2T4 calculations to ensure compliance with federal regulations. If the Federal Audit Clearinghouse has questions regarding this plan, please call Amy Brown, Director of Financial Aid at 704-463-3015.

Condition: During testing of the enrollment reporting, we identified the following errors: 􀁸 The change in status was not reported at the program level. 􀁸 The program begin date reported to NSLDS does not match the program begin date per the college’s records. Recommendation: The College should evaluate their procedures and policies related to reporting status changes and program begin 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. Action taken in response to finding: We have researched the issue and found that it goes back to the June 2022 purging of the archive file within our student information system in order to get the NSC reports to pull from the system. We no longer purge the archive file, so these issues will only happen on some older records where students return to the college. Name(s) of the contact person(s) responsible for corrective action: Katrina Dumont, Institutional Effectiveness Planned completion date for corrective action plan: We will monitor the Spring 2026 NSC enrollment files to make sure the issue is not getting worse.

Condition: The College did not report certain Pell disbursements within 15 days to COD. Recommendation: We recommend the College ensure that a process is in place to report within 15 days, including a process to respond and report timely when there are student irregularities. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. While we agree with the audit finding, we are not clear as to why the date was recorded by COD outside the disbursement window. Action taken in response to finding: We will maintain automated COD reporting through the Student Information System (SIS) and continuously refine processes based on audit results and regulatory changes. Name(s) of the contact person(s) responsible for corrective action: John Gay Jr. Planned completion date for corrective action plan: Fall 2025

The University will review and update its internal procedures and controls for handling credit balances to ensure that future Title IV credit balances are disbursed to students within the 14 day window.

Finding Number: 2025-003 Federal Assistance Listing Number: 84.007 Federal Supplemental Educational Opportunity Grant, 84.033 Federal Work-Study Program, 84.038 Federal Perkins Loan Program Year Ended: June 30, 2025 Responsible Individual: Steven Dwire, Director of Financial Aid Management’s Response and Corrective Action Plan: Management identified the issue on October 3, 2025 and made the FISAP submission immediately and filed the signature page on October 15, 2025. The issue resulted from staff turnover during the year. Upon discovery, management promptly updated procedures, including adding calendar reminders to avoid such missed occurrences going forward. Additionally, the College has submitted a waiver request with the Department of Education to avoid the return of $441,023 in campus-based aid and to obtain eligibility to receive campus-based aid for the 2026-2027 school year. As of the date of the report, a response to the waiver request from the Department of Education has not been received.

Finding Number: 2025-002 Federal Assistance Listing Number: 84.268 Federal Direct Student Loans Year Ended: June 30, 2025 Responsible Individual: Steven Dwire Director of Financial Aid Management’s Response and Corrective Action Plan: Management identified the issue on September 23, 2025 and exit counseling packages were sent on October 1, 2025. The issue resulted from staff turnover during the year. Upon discovery, management promptly updated procedures, including adding calendar reminders to avoid such missed occurrences going forward.

Finding Number: 2025-001 Federal Assistance Listing Number: 84.268 Federal Direct Student Loans Year Ended: June 30, 2025 Responsible Individual: Christine Banewicz Director of Student Accounts Management’s Response and Corrective Action Plan: Management identified the issue on August 4, 2025 and new letters were emailed on August 8, 2025 and August 12, 2025. To mitigate potential disruptions in the electronic process, the College enhanced its controls to include manual validation of letters.

Corrective Action: The College will implement a revised withdrawal process that shifts outreach and financial aid counseling to occur before a student completes and submits the withdrawal form, rather than after submission. This change is designed to eliminate delays in withdrawal processing and support timely institutional action. Under the current process, outreach to students occurred after the withdrawal form was submitted, which resulted in delays in routing the form to the Records Office for processing. The revised process will require that outreach and financial aid counseling occur before students complete the withdrawal form. Students who indicate they are receiving financial aid will be encouraged to consult with the Financial Aid Office prior to completing the withdrawal form. During this consultation, students will be informed of the financial implications of withdrawing and be made aware of available institutional resources and services that may assist them in remaining enrolled, when appropriate. The revised withdrawal form will allow students to complete and submit it online directly to the Records Office for immediate processing. Eliminating post-submission outreach requirements will remove prior delays and allow the Records Office to promptly process the withdrawal. Receipt of the completed withdrawal form will serve as the institution’s date of determination. Following submission, the Financial Aid Office will complete the Return to Title IV (R2T4) calculation within the required 45-day timeframe and return any required funds. Timely processing of withdrawals will ensure continued compliance with all R2T4 regulatory requirements. Anticipated Completion Date: The College will implement this revised withdrawal process immediately (March 2026). Responsible Party: Breshawn Skinner, Director of Financial Aid, in coordination with the Records Office

Credit Balance Testing Recommendation: CLA recommends that the client re-evaluate their internal controls over credit balance returns in order to establish a more timely process for the identification and disbursement of TIV credit balances. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: Carthage College will update procedures to maintain documentation of student authorizations for credit balances held greater than 14 days. Name(s) of the contact person(s) responsible for corrective action: Vince Ceja, CFO Planned completion date for corrective action plan: June 30, 2026

Name of Responsible Individual: Ransom Prestridge, Registrar; Jennifer Wegman, Assistant Registrar; Kai Howard, Institutional Research; Shane Himes, Director of Financial Aid Corrective Action: The College acknowledges the findings related to the timeliness and accuracy of enrollment reporting to the National Student Loan Data System (NSLDS). The identified exceptions were the result of insufficient administrative oversight and internal controls related to enrollment status reporting at both the campus and program levels. As this is a repeat finding, the College is committed to implementing enhanced and sustainable corrective measures. To address this finding, the College will strengthen internal controls and oversight of enrollment reporting by implementing the following corrective actions: • Establish a documented review and monitoring process to ensure all enrollment status changes, including graduation, withdrawal, attendance level changes, and second majors, are accurately and timely reported to NSLDS at both the campus and program levels. • Implement a standardized tracking and reconciliation process between the Registrar’s Office, the Student Information System, and NSLDS to ensure data consistency and completeness. • Develop and implement written policies and procedures that clearly define roles, responsibilities, timelines, and escalation protocols for enrollment reporting. • Enhance oversight of any third-party servicer, including periodic validation of submitted records to ensure accuracy and timeliness. • Provide comprehensive training to staff responsible for enrollment reporting on federal regulatory requirements and institutional procedures. • Conduct periodic internal quality assurance reviews and monitoring of enrollment reporting to identify and correct discrepancies in a timely manner. • Establish formal communication protocols between the Financial Aid and Registrar’s Offices to ensure timely notification of all enrollment changes. Anticipated Completion Date: May 31, 2026

Name of Responsible Individual: Shane Himes, Director of Financial Aid Corrective Action: The College acknowledges the exceptions identified related to the timeliness of Return of Title IV (R2T4) calculations and the return of unearned federal funds. The errors were the result of insufficient administrative oversight and internal controls over the withdrawal and R2T4 process. To address this finding, the College will strengthen internal controls and oversight to ensure compliance with federal regulations. The corrective actions include: • Implementing a documented secondary review process for all R2T4 calculations prior to finalization to ensure accuracy and compliance with regulatory requirements. • Enhancing procedures to ensure timely identification of withdrawn students and prompt initiation of the R2T4 calculation process. • Establishing standardized monitoring to ensure all required returns of Title IV funds are processed within the regulatory timeframe. • Developing and implementing a tracking system to monitor withdrawal dates, calculation completion, and return deadlines. • Providing additional training to Financial Aid staff on federal R2T4 regulations and institutional procedures. • Conducting periodic internal quality assurance reviews of R2T4 calculations and returned funds to ensure ongoing compliance. Anticipated Completion Date: May 31, 2026

Name of Responsible Individual: Larry Bomback, Interim CFO / DeMornai Blackwell, Controller Corrective Action: Management acknowledges the instances in which Title IV credit balances were not refunded within the required regulatory timeframe under 34 CFR §668.164(c). Although no questioned costs were identified, the College recognizes the need to strengthen internal controls to ensure full compliance. To address this finding, the College will: • Implement a formal Title IV credit balance monitoring procedure requiring weekly review of student accounts with credit balances • Establish an automated report identifying all Title IV–generated credit balances and tracking the 14-day refund deadline • Strengthen coordination between the Business Office, Financial Aid Office, and Registrar to ensure enrollment status and disbursement timing are properly reflected prior to refund processing • Continued documented supervisory review of credit balance aging reports These corrective measures are designed to ensure timely refunds, improve monitoring controls, and maintain compliance with federal Title IV requirements. Anticipated Completion Date: May 31, 2026

Name of Responsible Individual: Shane Himes, Director of Financial Aid Corrective Action: The College acknowledges the reporting errors identified in certain student origination records submitted to the Common Origination and Disbursement (COD) System, specifically related to cost of attendance and academic end date data elements. To address this finding, the College will enhance internal controls and oversight over federal aid reporting by implementing the following corrective actions: • Establish a documented secondary review process for all origination records prior to submission to COD, with verification of key data elements including cost of attendance, academic start and end dates, enrollment status, and award amounts. • Implement a standardized review checklist to ensure accuracy and completeness of required data fields. • Strengthen reconciliation procedures between the student information system and COD to identify and resolve discrepancies timely. • Conduct periodic internal quality assurance reviews of origination and disbursement records. • Provide additional staff training on federal reporting requirements. Anticipated Completion Date: This process has already been implemented.

Name of Responsible Individual: Larry Bomback, Interim CFO ; Justin Roy, VP of Enrollment ; Irene Langran, VP of Academic Affairs Corrective Action: Management acknowledges the instance in which Title IV funds were held beyond the allowable timeframe under 34 CFR §668.166. Although the amount was within allowable tolerance thresholds and no questioned costs were identified, the College recognizes the need to strengthen internal controls over cash management compliance. To address this finding, the College will: • Implement a formal Title IV drawdown and disbursement monitoring procedure requiring review no later than the third business day following receipt of funds • Establish a standardized reconciliation process between the Business Office, Financial Aid Office, and Registrar to ensure timely identification of: o Students who have withdrawn o Enrollment status changes o Required returns of Title IV (R2T4) calculations • Develop a documented weekly reconciliation of federal drawdowns to disbursements and student account activity • Assign clear responsibility for monitoring excess cash thresholds and ensuring timely return of funds to the U.S. Department of Education when required • Provide cross-functional training to reinforce compliance requirements under federal cash management regulations These measures are intended to ensure timely disbursement of Title IV funds, proper reconciliation of enrollment changes, and full compliance with federal cash management requirements. Anticipated Completion Date: May 31, 2026

Management’s Response: The University has undertaken several initiatives to enhance compliance and accuracy: Management acknowledges the material weakness related to the awarding and disbursement of TEACH Grants and recognizes the importance of ensuring that grant eligibility is verified in accordance with federal regulations prior to disbursement. During fiscal year 2025, an eligibility determination error was identified for one student. Subsequent to year-end, the University returned the related TEACH Grant funds to the U.S. Department of Education through the G5 system. Management has taken corrective actions to strengthen eligibility verification and prevent recurrence. Corrective actions implemented include: • Strengthened Leadership and Oversight: A new Financial Aid Director was hired in March 2025 and has prioritized the development and enforcement of appropriate controls over TEACH Grant awarding and disbursement. • Revised Policies and Procedures: TEACH Grant awarding and disbursement procedures were reviewed and updated to ensure alignment with federal eligibility requirements. • Improved Eligibility Documentation: The TEACH Grant application was enhanced to clearly document all required eligibility criteria and support consistent eligibility determinations. • Secondary Review Controls: A secondary review and approval process has been implemented to ensure that TEACH Grant eligibility is independently verified prior to awarding and disbursement. • Enhanced Tracking and Monitoring: Additional tracking mechanisms were implemented to confirm that eligibility requirements are met and documented before funds are applied to student accounts. • Ongoing Compliance Monitoring: The Financial Aid Office continues to monitor TEACH Grant activity to ensure continued compliance with program requirements. Management believes these actions have significantly strengthened internal controls over TEACH Grant awarding and disbursement. Continued application of these procedures is expected to prevent recurrence and support full compliance in future audit periods. These initiatives demonstrate the University’s commitment to maintaining accurate student enrollment records and ensuring compliance with federal regulations, thereby safeguarding the interests of its students and the institution.

Management’s Response: The University has undertaken several initiatives to enhance compliance and accuracy: Management acknowledges the material weakness related to enrollment reporting for the Federal Direct Student Loan Program and recognizes the importance of timely and accurate reporting to the National Student Loan Data System (NSLDS). During fiscal year 2025, the University experienced challenges related to enrollment reporting accuracy and timeliness. In response, management implemented significant corrective actions to strengthen accountability, improve cross-department coordination, and enhance monitoring controls. Key actions taken during and subsequent to fiscal year 2025 include: • Strengthened Leadership and Accountability: A new Financial Aid Director was hired in March 2025 and has prioritized the resolution of this repeat audit finding. Clear responsibility for enrollment reporting oversight has been established. • Improved Cross-Department Coordination: The Financial Aid Office now works closely with the Registrar’s Office and Information Technology to ensure alignment between institutional enrollment records and federal reporting systems. • System Configuration Review: Enrollment reporting processes and system configurations within the Colleague system were reviewed to ensure that student enrollment statuses and effective dates are captured and reported accurately. • Identification and Correction of Reporting Issues: Management identified discrepancies in enrollment reports generated by Colleague that resulted in inaccurate federal reporting for certain students. Corrective solutions have been identified and implemented to address these issues. Enhanced Monitoring and Review: The Financial Aid Director now performs regular reviews of all withdrawn and graduated students to verify consistency between Colleague, the National Student Clearinghouse, and NSLDS prior to and after submission. • Improved Timeliness of Corrections: Any discrepancies identified are promptly reviewed and corrected in coordination with the Registrar’s Office to ensure compliance with required reporting timeframes. • Policy and Training Enhancements: Policies and procedures related to enrollment reporting are being refined, and additional staff training has been implemented to reinforce compliance requirements and internal controls. Management believes these actions have materially improved the accuracy and timeliness of enrollment reporting. Continued monitoring and application of these controls are expected to result in sustained compliance and resolution of this finding in a future audit period. These initiatives demonstrate the University’s commitment to maintaining accurate student enrollment records and ensuring compliance with federal regulations, thereby safeguarding the interests of its students and the institution.

The University had one R2T4 finding that resulted from a unique situation. The Financial Aid Office will conduct a detailed review of the process and incorporate this specific circumstance into its internal audit procedures. By strengthening internal controls within the R2T4 process and enhancing internal audit protocols, the University will further improve overall compliance in this area and maintain its high standard of regulatory compliance.

The Financial Aid Office will continue to work closely with the Registrar's Office and Information Technology to resolve the NSLDS reporting discrepancies. Based on our preliminary review, the reporting inconsistencies appear to be related to changes in enrollment reporting processes and data feeds associated with the recent Student Information System (SIS) update, implemented in 2025. In partnership with the Registrar's Office, Information Technology, and the Office of Data Analytics (within Information Technology), the University will identify and correct the source of the repeated or inconsistent data submissions to the National Student Clearinghouse. Because enrollment reporting to the Clearinghouse directly impacts data reported to the National Student Loan Data System (NSLDS), resolving these data feed issues is a priority. Additionally, these departments will develop and implement enhanced internal controls to compare institutional enrollment records against NSLDS data to ensure accuracy and timeliness. One of these measures will include a monthly enrollment reporting audit to identify and correct discrepancies proactively. Updates may include but not be limited to timing and frequency of reporting, internal audits monthly during 2026, and expanding written documentation of the process and procedures. The University is committed to strengthening internal processes to ensure compliance with federal enrollment reporting requirements and to prevent recurrence of this issue.

While the District maintained the requisite supporting documentation, limitations arising from the internal record retention policies in place at the time, coupled with the retirement of key personnel, resulted in certain enrollment records not being readily locatable. The District acknowledges that these factors limited the availability of prior-year supporting data. This issue has since been addressed through updated retention practices to ensure that this does not occur going forward. Beginning with the next fiscal year cycle, the District has implemented a documented procedure that specifies the data sources, query parameters, and data pull dates; requires that all supporting extracts and calculations be retained in a centralized, version-controlled folder; and establishes a formal review and approval process to verify that enrollment and low-income counts reconcile to source documentation before submission to ADE. Staff in Federal Programs and Finance have been trained on the new procedure, and an annual internal review has been established to confirm compliance. The Director of Finance and the Director of Federal Programs are responsible for implementing and monitoring this corrective action, which will be completed prior to the next Title I eligibility submission.

Finding 2025-005 – Cash Management Contact Person: Cristen Alicea, Office of Financial Assistance Current status: Resolved Anticipated Completion Date: February 1, 2026 Condition: The University did not provide evidence that the School Account Statements (SAS) from ED were used to reconcile to the University’s financial and business records on a monthly basis during the year ended May 31, 2025. Identification of repeat finding: N/A Resolution: We maintain that we did reconcile to the School Account Statements, as evidenced by the reports that have been run against the SAS statements through the Banner job RLRDLRC. However, we did not maintain the individual monthly evidence of the mismatches identified on those reports, and their resolution. We are maintaining this evidence going forward.

Finding 2025-004 – Special Tests and Provisions – Disbursements to or on Behalf of Students Contact Person: Cristen Alicea, Office of Financial Assistance Ann Margaret Cervantes, Director of Business Office Current status: Resolved Anticipated Completion Date: Completed May 23, 2025 Condition: The University was unable to provide evidence that internal controls over the return of credit balances to students were performed. Additionally, student credit balances were not identified and refunded to students within 14 days after the credit balance occurred. Identification of repeat finding: N/A Resolution: Our Outlook email folders have a limit on storage, despite using non-server folders to extend storage space and length of time. During 2024-2025, these folders reached full capacity and we were unable to send or receive any emails. We were instructed to delete older emails to regain functionality, which unfortunately meant that some of the automated emails that we use for our audit processes had to be deleted. Our Information Technology department was able to provide an online archive folder for Outlook emails that does not fill up, get deleted, or cause us to run out of space. Therefore, all emails proving processing will be available for review during next year’s audit. Please note that this control was in place, and was followed, but we are unable to provide the actual email output. In addition to the automated credit balance reports from ARGOS, the Business Office runs internal reports twice weekly to identify and process any pending credit balances.