Corrective Action Plans

Loras College Corrective Action Plan For the year ended June 30, 2025 February 19, 2026 Finding 2025-001: Significant Deficiency – Incentive Compensation Assistance Listing Number: Various Federal Agency: U.S. Department of Education Condition: One out of five employees selected for testing had a promotion letter that included a salary increase if performance metrics for enrollments were met, with goal numbers for yearover- year increases in applications, admissions, new transfer enrollment and graduate enrollment. This is not in compliance with applicable requirements regarding incentive compensation. Recommendation: The College should establish a policy where employee contracts and compensation are reviewed and approved to ensure compliance with applicable requirements regarding incentive compensation per the regulations at 34 CFR 668.14(b)(22). Corrective Action: Management has reviewed internal processes and procedures and a process has been established whereby all employee contracts and compensation are first reviewed by the Associate VP for Finance/Treasurer and President before they are sent to Human Resources for processing. The Associate VP for Finance/Treasurer has a CPA background. In addition, the President and the HR Director are now well versed in applicable requirements regarding employee compensation. Management believes this process will eliminate a reoccurrence. Renate A. Root Treasurer 1450 Alta Vista St. Dubuque, IA 52001 563-588-7775

Return of Title IV (R2T4) Funds Errors, Reference 2025-002 Audit Finding: Out of a population of 367 students who completely withdrew from courses during the Spring and Fall semesters of the 2025 aid year and received a disbursement during the respective semester(s), 25 were selected for testing. Of those students, three had funds that were returned outside of 45 days from the date the University became aware of the withdrawal. Our sample was not, and was not intended to be, statistically valid. Cause of the Finding: The University did not have appropriate controls in place to ensure timely return of funds, the result of limited staffing within the Financial Aid Office and the absence of a formalized secondary review process. Effect of the Finding: The University failed to return funds timely, and, as such, ED did not have access to funds. Corrective Action Plan: To address the delays identified in the R2T4 funds, the following corrective actions will be taken: 1. Revised Procedures o The University will update its written Return of Title IV procedures to clearly define the identification of official and unofficial withdrawals, required timelines for completing R2T4 calculations, and responsibility for initiating, reviewing, and approving calculations. 2. Training for Staff o Financial Aid staff will receive refresher training on Return of Title IV requirements, including withdrawal determination dates and calculation deadlines. o Training materials will be documented for reference and future onboarding. 3. Secondary Review Process o A secondary review of all R2T4 calculations will now be required prior to posting adjustments and returning funds. o The review will be documented and retained with the student’s financial aid file. 4. Ongoing Monitoring o A withdrawal tracking log will be implemented to monitor the date of withdrawal, the date of R2T4 calculation, and the date funds are returned. o The Senior Director Financial Services and Operations will review the log monthly. 5. Timeline for Implementation o Revised procedures will be updated by the Financial Aid Office staff by June 30, 2026. o Staff training sessions: First session scheduled by June 30, 2026, with periodic refreshers as available. o Secondary review processes and ongoing monitoring will begin immediately. 6. Responsible Parties The Vice President for Enrollment and Student Success, Associate Vice President of Enrollment Management, and the Senior Director Financial Services and Operations will oversee the implementation of the corrective action plan. Responsible party contact information is located at uco.edu.

SEFA Audit Response and Corrective Action Plans NSLDS Reporting Errors, Reference 2025-001 Audit Finding: Out of a population of 3,587 students with status changes during the Spring and Fall semesters of the 2025 aid year, 60 were selected for testing. Of the sixteen students with incorrect enrollment information reported, one had the incorrect CIP year reported, four had the incorrect program begin date reported, one had the incorrect enrollment status reported, four had the incorrect program enrollment effective date reported, and six had two or more items reported incorrectly. Of the nineteen students with enrollment status and/or address changes that were not reported timely, fourteen had enrollment statuses not reported timely and five had address changes not reported timely. Our sample was not, and was not intended to be, statistically valid. Cause of the Finding: The University did not have appropriate controls in place to ensure timely and accurate reporting, primarily due to limited staffing within the Registrar’s Office and the absence of a formal secondary review process. Effect of the Finding: The University reported inaccurate information or failed to report changes within the required time frame and, as such, ED was not provided accurate and timely information. Repeat Finding: This finding is a repeat of 2024-001. Corrective Action Plan: To address the errors identified in the NSLDS reporting, the following corrective actions will be taken: 1. Immediate Review and Correction of Existing Data o Conduct a six-month review of federal student aid records to identify and correct any discrepancies in program dates, borrower statuses, and address changes reported to NSLDS. o Work with the SIS vendor and ED to ensure that all data submissions to NSLDS are accurate and complete. 2. System Integration and Process Improvement o Implement a data validation process that cross-checks loan disbursements and borrower statuses against internal records before submitting to NSLDS. o Enhance the SIS to NSLDS data mapping interface to ensure consistency and accuracy of loan-related information between the two systems. 3. Training for Staff o Provide targeted training for financial aid office staff responsible for NSLDS reporting, emphasizing proper data entry practices, system integration, and error-checking protocols. o Review periodic refresher courses to ensure staff remains up to date on any changes to NSLDS reporting requirements. 4. Ongoing Monitoring and Reconciliation o Establish a routine process to reconcile NSLDS data with internal student aid records monthly, ensuring discrepancies are caught and corrected promptly. o Implement a monthly review of the NSLDS submission to confirm all data is up to date, including loan disbursements, borrower status updates, and any adjustments. 5. Timeline for Implementation o Review and correction of existing NSLDS errors, as needed: Completed by June 30, 2026. o System and integration review: Completed by June 30, 2026. o Staff training sessions: First session scheduled by June 30, 2026, with periodic refreshers as available. o Ongoing monitoring process implementation: Ongoing starting immediately. 6. Responsible Parties The Vice President for Enrollment and Student Success, Associate Vice President of Enrollment Management, and the Registrar will oversee the implementation of the corrective action plan. Responsible party contact information is located at uco.edu.

Audit Finding Response – Disbursement Notifications Not Sent (Award Period 2024–2025) Effect / Impact Students did not receive timely notification of their federal aid disbursements for the 24-25 summer term. While the funds were disbursed accurately and timely, the absence of notifications created a compliance gap with federal notification requirements. Cause The failure to send disbursement notifications occurred as a result of a system implementation during the month of June. The system transition impacted the automated notification process, resulting in notifications not being generated or delivered as expected during one disbursement cycle. Corrective Action The issue was quickly identified and resolved. Notifications are currently being sent to students following disbursement of funds. Additionally, the Financial Aid Department has added verification of disbursement notifications to its Quality Assurance (QA) review process. This additional control ensures confirmation that notifications are generated and sent following each federal aid disbursement cycle. The enhanced QA review is currently in place and will be applied to all future disbursement cycles to prevent recurrence. After each major disbursement day, a Financial Aid Specialist will randomly select disbursement records for review. If an error is identified, the specialist will report the issue to the Financial Aid Functional Analyst and the Director of Financial Aid. Conclusion The issue was isolated to the system implementation period and has been addressed through strengthened QA controls. The Financial Aid Department is committed to ongoing monitoring to ensure continued compliance with federal notification requirements. Samantha Freeman Interim Financial Aid Director Ken Birdsong CFO

Finding Number: 2025-001 – Special Tests and Provisions - Enrollment Reporting Auditor Description of Condition and Effect: In our testing of eighteen students, we noted two students who were reported with inaccurate effective dates. The University's reporting process relies on SAP system data for NSLDS reporting, which did not accurately reflect the student’s actual last date of attendance. Auditor Recommendation: We recommend that the University enhance its policies and procedures regarding enrollment reporting to ensure that reporting is completed accurately. Views of Responsible Officials and Planned Corrective Action: Effective immediately following the Office of Technology system updates, the Registrar’s Office and Student Account Services and University Billing (SASUB) will begin utilizing SAP to store R2T4 dates. These dates will automatically populate the monthly National Student Clearinghouse (NSC) enrollment files, improve reporting accuracy, compliance, and the management of withdrawn students. This centralized platform provides authorized users with streamlined access to view pending returns, associated deadlines, and completion dates for each case. The system enhances tracking accuracy, strengthens accountability, and promotes transparency and communication among university stakeholders. Key personnel and leadership from the Registrar’s Office and SASUB will conduct regular reviews to ensure compliance and operational efficiency. Contact person responsible for corrective action: Keith J. Malkowski, Registrar of Registrar’s Office & Brian C. Bell, Director of Student Account Services and University Billing Anticipated Completion Date: 2/28/2026

Incorrect Loan Disbursement Amount Corrective Action Plan: The Financial Aid Services office, in collaboration with IT, has implemented an exception report. This report is received daily, and designed to identify any students whose subsidized and unsubsidized loan awards may not align with their enrollment status, need, and annual loan limit. The goal is to proactivety identify and correct any discrepancies before disbursement to ensure accuracy. Responsible Person for Correction Action Plan: Marlon Jones Jr., Director of Financial Aid Services Implementation Date of Corrective Action Plan: 9/18/2025

Incorrect Pell Disbursement Corrective Action Plan: The Financial Aid Services office, in collaboration with IT, has implemented an exception report. This report is received, daily, and designed to identify any students whose Pell Grant awards may not align with their enrollment status or need. The goal is to proactively identify and correct discrepancies before disbursement to ensure accuracy. Responsible Person for Corrective Action Plan: Erika Guzman, Associate Di rector of Financial Aid Services Implementation Date of Corrective Action Plan: 6/23/2025

Views of Responsible Officials and Corrective Action Plan Responsible Officials: Associate Dean, Financial Aid & Scholarships, Director of Financial Aid & Scholarships Enhanced data on source reports The Associate Dean of Financial Aid & Scholarships, Director of Financial Aid & Scholarships, and System Specialist worked with the MIS (IT) Department to enhance information provided on the reports used by Financial Aid staff to facilitate identifying student withdrawals and initiating the calculation process. Enhanced report will cut down on the need to manually check student information as the Specialist is processing students. New data elements on the report include course and class section information, start and end week, number of units by course, drop date field and the instructor e-mail. Increase frequency of generating the student withdrawal report. The System Specialist has scheduled on their calendar to run the student withdrawal report every week to ensure that the withdrawals are identified in a timely manner and the calculations and returns are completed within the 45-day window. Redistributed department workload; Specialist focused on withdrawal determination/calculation. The Associate Dean has tasked additional office support to assist the System Specialist in the communication follow up with the impacted students, freeing up the System Specialist’s workload to concentrate fully on the withdrawal determination and calculation completion. Monthly review by Associate Dean to confirm adjustments completed for student withdrawals. The Associate Dean will request a monthly report to review and ensure that the calculations and aid adjustments are completed for each student who has withdrawn. This process update will put in place internal checks and balances over the review of the calculations to ensure financial aid funding is returned in a timely manner. The Associate Dean, or their designee, will sign-off that they have reviewed the report each month and file a copy.

National Student Loan Data System (NSLDS) Recommendation: We recommend reviewing the components of the enrollment roster file to ensure the correct effective date is reported correctly for the "Campus Level" as well as making sure records are being timely reported. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Although the Colleague data is correct, the logic in Colleague used to send the files to the NSC is excluding records when the student is not registered for classes in the month an action such as graduation or withdrawal occurs. In that situation the NSC is inserting default dates onto the record based on the last date of their classes in the prior term. We will continue to manually review and correct issues when needed. Name of the contact person responsible for corrective action: Sean Murphy, Registrar Planned completion date for corrective action plan: Already in place.

Due to varying start dates and end dates to the University’s graduate programs, the University will implement a graduate-only NSLDS reporting process to reduce the risk of late reporting. Reports will be run based on semester completion dates to identify graduate students requiring NSLDS reporting, as these dates may not align with standard reporting deadlines. Undergraduate and graduate students who withdraw will continue to be reported promptly, with increased coordination across the various University campuses to identify withdrawals and allow for proper reporting within U.S. Department of Education requirements. Responsible party: Sigrun Olafsdottir, Vice President of Student Financial Services; (603) 899-4186 Anticipated Completion Date: May 31, 2026

The College’s Vice President for Academic Affairs and Dean of the College concurred with the finding identified. The College has revised its policies and procedures as follows: Historically, Student Affairs coded only those students who took a Leave of Absence during the semester (“L”) or withdrew during the semester (“W”). Student Affairs has created a new code (“N”) to track students who inform the college of their intent to withdraw at the end of a given semester. At the end of each semester, Student Affairs provides the Registrar’s Office with a report of all students who informed the college of their intent to unenroll (“L”, “W”, and “N”). Using the report, the Registrar’s Office confirms that all students have been accurately exited with the appropriate exit date and exit reason prior to submitting the final “end of term” report to the National Student Clearinghouse. This new process was implemented beginning in the Fall 2025 semester. The corrective actions will be implemented by Dr. Kristen M. Amick, Registrar. Dr. Amick’s email address is: amickkm@westminster.edu.

Award periods (AWPD) were set up in summer 2023 for the 24-25 award year. At that time, official semester start and end dates were unknown therefore the expected start date was entered in Colleague. When the semester start and end dates became official in spring 2024, the financial aid office updated AWPD in Colleague, not realizing students whose FAFSAs had already been received and packaged would not be updated with the official start date. Students who were packaged after the AWPD update were correct. Going forward, the financial aid office will ensure that AWPD is updated before packaging any student financial aid.

Northwestern Oklahoma State University agrees with the auditor's findings. The issue is in relation to how the software (Colleague) is currently setup. Northwestern will work on a correction so that moving forward the dates are accurate with the academic year calendar. Northwestern will work to have this done for the next list to be sent to NSLDS.

Views of Responsible Officials and Corrective Action Plan We concur. The District has filed a bug with IT to have this issue addressed and the programming fixed promptly. Corrections have already been made with NSLDS by the campuses.

Views of Responsible Officials and Corrective Action Plan We concur. Management has revised its procedures for R2T4, as well as added additional monthly review to ensure compliance.

Student Financial Aid Cluster – Assistance Listing No. 84.063 Recommendation: We recommend the College review and strengthen its policies and procedures to ensure that all student credit balances resulting from federal funds are refunded within the required 14-day period. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: This finding was from Fall of 2024. During the Fall semester of FY 25, Clarkson College experienced turnover with its financial aid department staff. From Spring 2025 on, the financial aid department now processes financial aid weekly on Monday through Wednesday each week. The student accounts team in turn runs a report for any credit balances on Thursday morning each week. Upon running the report, the student accounts team will then process and issue either a check or ACH payment refund that same day so that at most, there is a eight-day period. In addition, the College enhanced the check payment process so that the checks can be generated, printed, and mailed same-day. Name(s) of the contact person(s) responsible for corrective action: Nathan Wiegand, VP of College Finance/CFO Planned completion date for corrective action plan: Implemented in January, 2025.

Student Financial Aid Cluster – Assistance Listing No. 84.063 Recommendation: We recommend the College establish a process to ensure that all disbursement information is accurately reported to the COD system. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: It was noted in COD that a disbursement date did not match the date recorded in our Anthology system; the discrepancy was by one day. Once identified, the Financial Aid team corrected the error. Unfortunately, the correction was made outside the required 15-day window. All disbursement dates have now been updated, and we have implemented a new process to ensure that all dates in Anthology and COD align. The Financial Aid team is actively monitoring this to ensure that current and future disbursement dates consistently match providing an additional reconciliation of dates. Name(s) of the contact person(s) responsible for corrective action: Dr. Carla Dirkshneider, VP of Enrollment and Retention Planned completion date for corrective action plan: Implemented

Student Financial Aid Cluster – Assistance Listing No. 84.063 Recommendation: We recommend the College implement a review process that compares enrolled credits to Pell awards to ensure all students receive the correct Pell Grant amounts. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: There was one student in Fall 2024 who was under-awarded Pell Grant funds due to an error related to the student’s withdrawal status and the number of credits attempted. The Pell award was manually processed incorrectly based on this enrollment change. Beginning in Spring 2025, the Financial Aid team implemented a new process requiring a formal review of enrollment intensity for all students prior to determining and disbursing Pell Grant funds. This ensures that Pell awards are calculated and adjusted accurately. Additionally, the team now utilizes enrollment and Pell related reports to help identify potential changes in student enrollment and support timely, accurate award reviews. Name(s) of the contact person(s) responsible for corrective action: Dr. Carla Dirkshneider, VP of Enrollment and Retention Planned completion date for corrective action plan: Corrective action was implemented January, 2025.

Student Financial Aid Cluster – Assistance Listing No. Various Recommendation: We recommend the College review the R2T4 requirements and implement procedures to ensure that calculations use the correct number of break days and are completed accurately and within the required timeframes. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: During the review period, two students did not receive their Return to Title IV (R2T4) calculations within the required 45-day timeframe. The delay occurred because the Financial Aid Office did not receive the corresponding change of registration forms from the Registrar’s Office, which is necessary to initiate the R2T4 process. To prevent recurrence, the Financial Aid Office has implemented the following corrective actions: 1. Monitoring Reports: The team now runs a student status change report to independently identify potential R2T4 cases, even if documentation has not yet been forwarded. 2. Improved Communication Workflow: Financial Aid has been added to the Registrar’s change of registration email distribution list to ensure timely notification of withdrawals, drops, and status changes. These measures strengthen internal controls, improve cross departmental communication, and ensure that all future R2T4 calculations are completed within federal timelines. Name(s) of the contact person(s) responsible for corrective action: Dr. Carla Dirkshneider, VP of Enrollment and Retention Planned completion date for corrective action plan: Corrective action was implemented in June 2025.

Student Financial Aid Cluster – Assistance Listing No. Various Recommendation: We recommend the College review and formalize its procedures to ensure that internal controls are in place to identify and correct any inconsistencies throughout the year. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: In the spring of 2025, Clarkson College made the decision to outsource majority of financial aid functions to the Higher Education Assistance Group (HEAG) due to a lack of internal controls. Since hiring HEAG in Spring 2025 to oversee our financial aid functions, Clarkson College has seen many improvements in our internal controls. Reconciliation of Direct Loans and Federal Pell Grant funds is conducted monthly by a designated Financial Aid staff member. Following completion, the reconciliation documentation is forwarded to the College Controller for independent review. Final approval is provided by the Vice President of Enrollment and Advising. A standing monthly meeting is also held between the Financial Aid and Finance teams to review reconciliation activity, address variances, and resolve any items requiring clarification. The Federal Work-Study (FWS) program is monitored and reviewed each pay period to ensure expenditures remain within authorized limits and align with student eligibility. Federal Supplemental Educational Opportunity Grant (FSEOG) and Federal Work-Study (FWS) funds are reviewed and reconciled periodically throughout each semester by a Financial Aid staff member. Upon completion of these reconciliations, supporting documentation is submitted to the College Controller for review and verification of accuracy. These procedures ensure compliance with federal regulations, promote internal control integrity, and provide appropriate oversight of all Title IV funding streams. Name(s) of the contact person(s) responsible for corrective action: Dr. Carla Dirkshneider, VP of Enrollment and Retention Planned completion date for corrective action plan: Corrective action was implemented Spring semester of FY 2025.

Student Financial Aid Cluster – Assistance Listing No. Various Recommendation: We recommend the College review and strengthen its reporting procedures to ensure that student statuses are accurately reported to NSLDS, as required by federal regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Clarkson College completed its implementation of Anthology as a new student information system (SIS) in FY 25. Enrollment reports from the new SIS are used to update the National Student Clearinghouse and thus the NSLDS. The Registrar’s Office is working with our Anthology partner to determine issues with the enrollment dates and statuses. Moving forward, the Registrar’s Office will also do an internal audit of enrollment records between the National Student Clearinghouse, NSLDS, and our internal SIS. Name(s) of the contact person(s) responsible for corrective action: Dr. Carla Dirkshneider, VP of Enrollment and Retention Planned completion date for corrective action plan: Corrective action was implemented in the Spring semester of FY 2025.

The District has reviewed the policies and procedures over the R2T4 calculation and has identified additional controls to prevent miscalculations going forward. The Student Financial Aid Office has begun the implementation of the following corrective action plan to prevent future recurrence: Implement a cross-check with the Common Origination & Disbursement (COD) site R2T4 calculator to supplement the tools within our internal financial system. The COD system automatically calculates dates attended by students, eliminating the manual element of this step in the calculation. Implement a second review to spot check calculations during each semester to ensure accuracy. Require Blue Icon R2T4 training and certification for staff preparing, reviewing, and processing R2T4 calculations. These controls began implementation in November 2025 and are expected to be fully in place by March 2026. New regulations for R2T4 are expected to be released in early 2026. Blue Icon training will be scheduled once the new regulations are released.

Corrective Action Plan

CORRECTIVE ACTION PLAN

Federal Program: Student Financial Aid Cluster