Corrective Action Plans

Finding 2025-003 – Special Tests and Provisions – Disbursements to or on Behalf of Students Contact Person: Cristen Alicea, Office of Financial Assistance Current status: Resolved Anticipated Completion Date: Completed May 23, 2025 Condition: The University was unable to provide evidence that internal controls were performed in relation to notifications of disbursements, including notification of the amount and type of Title IV funds students are expected to receive, and how and when those disbursements will be made (award letter), and when direct loans are being credited to a student’s account (direct loan notification). 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. There were no instances of non-compliance identified during this audit.

Finding 2025-002 – Special Tests and Provisions – Return of Title IV Funds Contact Person: Cristen Alicea, Office of Financial Assistance Current status: In-Progress Anticipated Completion Date: May 1, 2026 Condition: The University did not provide evidence of an effective review process to ensure the timely calculation and return of Title IV funds to ED. The University did not accurately calculate and return Title IV funds in a timely manner to ED, within 45 days after the date the institution determined that a student withdrew. Identification of repeat finding: Yes – 2024-002, 2023-002 Resolution: The Director of Financial Assistance performed a full review of all withdrawals during 2023-2024, and 2024-2025, to ensure calculations were complete, accurate, and funds returned as required. Documentation will be maintained for review by the auditors and the Department of Education to prove funds were returned correctly, even if not timely. The continuation of this issue was caused by the continued difficulty with recruiting and keeping financial assistance advisors, and the extraordinary disruption caused by the 2024-2025 FAFSA changes. We were unable to fully remediate our staffing issues during the 2024-2025 academic year. We brought on new staff which required extensive training. However, we are now able to spend more time focusing on compliance areas and will be able to fully implement our planned compliance controls during the 2025-2026 aid year. We will not have any returns unprocessed or made outside of 45 days after May 1, 2026. In addition to new staff and training, we will implement a secondary review process for all Return of Title IV transactions whereby an advisor will process the initial calculation and return, and then either the Assistant Director or Director of Financial Assistance will perform a secondary review which evaluates the date of the withdrawal, the date of determination, the eligible disbursed/non-disbursed aid amounts, the returned amounts, and confirms the returned amounts in Banner and COD. This internal review process will be performed upon 100% of Return of Title IV calculations each academic year.

Finding 2025-001 – Special Tests and Provisions – Enrollment Reporting Contact Person: Marisol M. Scheer, Registrar’s Office Cristen Alicea, Office of Financial Assistance Current status: In-progress Anticipated Completion Date: May 31, 2026 Condition: The University did not provide evidence of an effective review process to ensure accurate and timely reporting of student status changes to NSLDS. The University did not report program enrollment effective date or student status to the NSLDS for 1 of 60 students selected for testing. Identification of Repeat Finding: Yes – 2024-001, 2023-001, 2022-001, 2021-001, 2020-001, 2019-002 Resolution: We would again like to reiterate that even though this is considered a repeat finding for enrollment reporting, this particular issue is different than the previous findings. The Registrar's Office has implemented a control whereby a sample of students are reviewed after submission to the National Student Clearinghouse. This student did not appear as part of the sample and was unknown until the audit. We have reviewed all pertinent files for this student and can confirm that all student processing had no errors. In an improvement effort, the Registrar's Office will provide a sample to the Office of Financial Assistance to review for successful data processing. The Registrar's Office has begun researching why the student was not reported but have been able to confirm no procedural errors or delays with the student record that could have caused reporting issues.

Audit Firm: Sikich Audit Period: For the Year Ended May 31, 2025 Criteria: An institution must use the Return to Title IV refund calculation (34 CFR 668.22) A. Comments on Findings and Recommendations Finding 2025-001 Incorrect R2T4 Refund Calculation Condition: Sikich tested twelve drop students and found six incorrect refund calculations. The condition was caused by not including proper break days from the students' Return to Title IV calculations. B. Actions Taken or Planned Finding 2025-001 Incorrect R2T4 Refund Calculation The R2T4 calculation process has been updated to transition into using the built-in R2T4 calculator in the Jenzabar Financial aid software system. This is to ensure that the scheduled break periods are accounted for when calculating the percentage of payment period completed. We have since discountinued using the COD R2T4 calculator. Financial aid staff have been retrained to proper R2T4 procedures including the correct treatment of institutional break days. A secondary review process has been put in place to ensure accuracy of R2T4 calculations prior to submission and processing. Judson University has credited the appropriate amounts to all affected students to resolve the discrepancies identified in this finding. Sarah Taylor Vice President for Business Affairs

Finding 2025-001 Recommendation: It is recommended that management work closely with the NSC and the DoE to ensure that student statuses are reported timely. View of Responsible Officials and Planned Corrective Actions: The late receipt of the ECAR was out of the University’s control due to a known issue with the new system implemented by the DoE for the EApp (Eligibility Application), which created a delay in the updated branch code for Lancaster. Individual Responsible for Corrective Action: Deanna Daly, ddaly@sju.edu and Sarah Taylor, swilli01@sju.edu Anticipated Completion Date for Corrective Action: N/A – no further corrective action is needed from the University at this time.

Saint Mary’s University of Minnesota Corrective Action Plan For the Year Ended May 31, 2025 Finding 2025-003 - Cash Management Condition G5 Drawdown requests were not documented as reviewed and approved by a responsible party separate from the preparer. For 2 of the 7 G5 draws tested, there was no documentation of review or approval by someone other than the preparer. The sample was not a statistically valid sample. Corrective Action Plan Corrective Action Planned: A form will be created to support each G5 draw or refund. Requestor will fill out the form, providing details of the transaction. The form will be reviewed and signed off by the Controller or EVP of Finance. The person performing the transaction in G5 will sign, attached all the appropriate back-up and file in a designated area for future reference. Name(s) of Contact Person(s) Responsible for Corrective Action: Karen Stellpflug, Controller and David Ansell, Assistant Vice President for Finance Anticipated Completion Date: March 31, 2026

Saint Mary's University of Minnesota Corrective Action Plan For the Year Ended May 31, 2025 Finding 2025-001 Criteria: Title IV regulations (34 CFR 668.22) require the University to return the unearned portion of grants or loans to the Title IV program within 45 days after a student withdraws. Additionally, The U.S. Department of Education (ED) requires that an institution must ensure that its administrative procedures for the FSA programs include an adequate system of internal controls or checks and balances to ensure compliance with FSA laws and regulations including the return of Title IV funds. Condition/Context: The federal aid refunds for 1 out of 8 of the students tested was not calculated correctly and subsequently, not returned within 45 days from the withdrawal date. The sample was not statistically valid. Also, the auditor noted that the University did not have evidence or documentation available to support the control/review process for return of Title IV calculations. Cause: The University's review procedures for the return of Title IV funds were not followed and the system was not programmed to ensure the correct withdrawal date was used in the calculation of the return of Title IV funds. Effect: The University was in possession of funds belonging to the federal government longer than allowed and could have incorrect return of Title IV calculations and return incorrect amounts to students and/or the ED. Questioned Costs: Not applicable. Recommendation: The University should adhere to its procedures for refunding awards and implement a more formal documented review process/control to ensure refunds are calculated correctly and timely and any returns are made within the required timeframe. Management Response: The University agrees with this finding. The JFA R2T4 calculation incorrectly populated the wrong date used to perform the calculation, thus causing the error. The error was corrected and the director performs the R2T4 and is working to have a back-up employee trained. Staffing levels will have to be brought up to allow for new financial aid staff to complete this task. Corrective Action Plan Corrective Action Planned: To ensure accuracy, the withdrawal date generated in the JFA calculation will be cross-referenced against the J1 SIS record. Once verified, this date will be documented alongside the R2T4 calculation. This process guarantees that the student's period of attendance is calculated using the correct data. Name(s) of Contact Person(s) Responsible for Corrective Action: Holly Weberg, Director of Financial Aid and new hire designee. Anticipated Completion Date: The director is still fulfilling the R2T4 duties until a new hire candidate is hired and trained.

Saint Mary's University of Minnesota Corrective Action Plan For the Year Ended May 31, 2025 Finding 2025-002 Criteria: Title IV regulations (34 CFR 685.309(b)) require that upon receipt of an enrollment report from the Secretary, institutions must update all information included in the report and return the report to the Secretary: (i) in the manner and format prescribed by the Secretary; and (ii) within the timeframe prescribed by the Secretary. Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the institution discovers that: (i) a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or (ii) a student who is enrolled at the institution and who received a loan under Title IV of the Act has changed his or her permanent address. Condition/Context: The change in student status for 8 of 26 students tested was not reported to the National Student Loan Data System (NSLDS) within 30 days or included in a response to a roster file within 60 days. The student status for 1 of 26 students tested was reported as a withdrawal although the student was on a leave of absence. In addition, for 7 of 26 students tested, the University was unable to provide sufficient support for the status change. The sample was not statistically valid. Cause: The University’s procedures for reporting all students was not designed appropriately in order to allow for timely reporting to the NSLDS. Effect: The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by institutions. If an institution does not review, update and verify student enrollment statuses, effective dates of the enrollment status and the anticipated completion dates, then the Title IV student loan records will be inaccurate. Questioned Costs: Not applicable. Recommendation: The University should revise its procedures to ensure accurate enrollment information is sent to the NSLDS within the required timeframe. Management Response: The University agrees with this finding. The University has been actively taking measures with the new student information system, Jenzabar, and procedures have been standardized across the University. An audit will be preformed to discover the inefficiencies. Corrective Action Plan Corrective Action Planned: The Registrar Office will submit the names of students to the Audit Resource team at NSC so they can research why these students were not reported to NSLDS. As a result of their response, we will meet with the financial aid team to determine the next course of action to audit files. Any changes needed for NSC reporting will be implemented in May 2026 new submission. The University will also work with the system provider to rectify these discrepancies systematically to avoid further conflicts. Name(s) of Contact Person(s) Responsible for Corrective Action: Alison Block, Director of Academic Records and Systems and Holly Weberg, Director of Financial Aid. Anticipated Completion Date: Tentative completion date May 2026.

The University identified certain automated COD communication and reporting rules in the Student Information System (SIS) that were not functioning properly during the 2024-2025 aid year. The breakdown of these automated rules required manual interventions to have all Pell Grant disbursements and R2T4 adjustments reported to COD, in certain cases exceeding the 15-day requirement. The University has re-trained all financial aid staff to ensure the export process to COD is now completed after each R2T4 adjustment calculation. In addition, the financial aid office now has a dedicated employee running this process at minimum twice a week to ensure that all Pell records get successfully captured and reported to COD within the 15 day window.

Student Financial Aid Cluster – Assistance Listing Numbers 84.007, 84.033, 84.038, 84.063, and 84.268 Recommendation: We recommend the University review its reporting procedures to ensure that Key Line Items 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: This finding resulted from inaccuracies introduced through enhancements made to a Workday-delivered report, which ultimately did not produce correct information. Going forward, we will review and validate the Workday report to ensure it aligns with Student Accounts’ reports and accurately reflects tuition and fees for the academic year. Name(s) of the contact person(s) responsible for corrective action: Jacob Witt, AVP of Financial Aid, 703-284-1532 Planned completion date for corrective action plan: June 2026 If the U.S. Department of Education have questions regarding this plan, please contact the individual(s) noted above.

Student Financial Aid Cluster – Assistance Listing Numbers 84.007, 84.033, 84.038, 84.063, and 84.268 Recommendation: We recommend the University review its return of Title IV fund procedures to ensure that calculations are performed with correct inputs as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: This finding was driven by incorrect MSMS program start and end dates configured in the University’s new Student Information System (Workday). When processing Return of Title IV (R2T4) calculations, Workday relies on the program start and end dates stored in the system. Due to these dates being incorrect, the R2T4 process calculated an inaccurate number of days enrolled, which resulted in an incorrect earned percentage of Title IV aid and, consequently, an incorrect amount of aid the student was eligible to retain. To address this issue, the University has implemented internal controls to review and verify the start and end dates of each academic year in Workday prior to the start of each semester. In addition, an internal control has been added to ensure the start and end dates of each academic year are reviewed and validated as part of the Return of Title IV processing. Name(s) of the contact person(s) responsible for corrective action: Jacob Witt, AVP of Financial Aid, 703-284-1532 Courtney Carey, University Registrar, 703-284-1523 Planned completion date for corrective action plan: Completed December 2025.

Student Financial Aid Cluster – Assistance Listing Numbers 84.007, 84.033, 84.038, 84.063, and 84.268 Recommendation: We recommend the University review its reporting procedures to ensure that enrollment and program information is accurately reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The findings were primarily driven by the University’s transition to a new Student Information System (Workday), including the Workday-delivered National Student Clearinghouse (NSC) integrations. These constraints resulted in delays and gaps in enrollment reporting processes, increased processing timelines with the National Student Clearinghouse (NSC), and impacted the timely and accurate transmission of enrollment data to the National Student Loan Data System (NSLDS). In response, Marymount University has developed a formal Standard Operating Procedure (SOP) for National Student Clearinghouse reporting and has begun implementing these procedures during the 2025–2026 academic year. Name(s) of the contact person(s) responsible for corrective action: Courtney Carey, University Registrar, 703-284-1523 Jacob Witt, AVP of Financial Aid, 703-284-1532 Planned completion date for corrective action plan: Completed December 2025.

NSLDS Reporting Recommendation: We recommend the University review its reporting procedures to ensure that students’ statuses are accurately reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: During a typical reporting cycle, all students’ degree information is transmitted to the National Student Clearinghouse (NSC) through a standardized report generated by our Student Information System (Workday). In the instance identified, one student’s graduation status was still pending at the time we submitted degree records for all May 2025 graduates. Once the student’s status was finalized and the degree was officially conferred, we submitted the student’s information manually to the NSC. However, the degree conferral date was reported incorrectly; the actual conferral date was submitted instead of the last day of the student’s final term, which is the required standard. To prevent this issue from recurring, we will discontinue all manual degree submissions to the NSC. Going forward, we will rely exclusively on Workday-generated reports to ensure that all graduation dates are accurate, consistent, and aligned with institutional reporting standards. Name(s) of the contact person(s) responsible for corrective action: James Patton, Assistant Vice President for Academic Affairs and University Registrar Planned completion date for corrective action plan: This change in our data-reporting procedure has already been implemented. The updated process was in place for the most recent degree verification cycle, which was reported to the National Student Clearinghouse on 01-02-2026. If the U.S. Department of Education has questions regarding these plans, please call Dawn Durham at 864-294-2429.

Incorrect Pell Calculations Planned Corrective Action: Management acknowledges the error in calculation. As a result of change in student information software and financial aid software in conjunction with manual processes employed during transition of academic years, timing of review and misinterpretation of Summer Pell regulations, this error was not identified timely. This may have carried over to the subsequent term. Management receives this as opportunity to improve upon processes to ensure higher visibility and oversight to reduce any further risk making certain to align policies with DOE. Person Responsible for Corrective Action Plan: Kristina Elmore, Director of Financial Aid Anticipated Date of Completion: February 2026

U.S. Department of Education Coastal Carolina University respectfully submits the following corrective action plan for the year ended June 30, 2025. Audit Period: July 1, 2024 - June 30, 2025 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS - FINANCIAL STATEMENT AUDIT None noted FINDINGS - FEDERAL AWARD PROGRAMS AUDITS Department of Education 2025-001 National Student Loan Data System (NSLDS) Reporting Recommendation: We recommend the University review and update its policies and procedures to ensure all enrollment status changes are reviewed and submitted in a timely manner in accordance with federal requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Corrective Action Plan: The University reviewed its reporting procedures for enrollment changes occurring after initial term reporting and implemented procedural changes to ensure timely updates. Anticipated Completion Date: Corrective action occurred prior to June 30, 2025. Name of Contact Person Responsible for the Corrective Action Plan: Stacy Wyeth, Registrar

The District has identified the issue and confirmed that enrollment records are now populating with the correct withdrawal dates. Moving forward, we will collaborate with Financial Aid and IT to implement a validation process. As part of this process, a sample of 20 students will be tested each reporting cycle to verify that dates reported to the National Student Clearinghouse (NSC) are accurately reflected in the National Student Loan Data System (NSLDS). To ensure continued compliance, the District will establish a new Enrollment Reporting Workgroup that will meet once per semester, following the submission of the second NSC report. This workgroup will review results of the sample testing, monitor reporting accuracy, and address any discrepancies promptly.

Recommendation: We recommend that the University establish procedures to ensure that FISAP is accurately presented. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: National University (NU) agrees with the importance of ensuring the accuracy of its data reported in the FISAP. The University will take the following steps to resolve the issue. NU identified a knowledge gap for the tuition and fees reporting required on the FISAP. Training will be conducted to review the requirements for reporting tuition and fees at the Undergraduate and Graduate levels, which are fully reconciled to the audited financial statements. In addition to the training, the University has implemented a secondary review of the calculation, which will be completed by the University controller prior to submission. Name(s) of the contact person(s) responsible for corrective action: - Robert Conlon, AVP Financial Aid Compliance - Christina Nowacki, Controller Planned completion date for corrective action plan: December 2025

Recommendation: We recommend that the University establish procedures to ensure that at least 7% of Federal Work Study allocation is used for community service jobs, including a reading tutor, or successfully receive a waiver. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: National University (NU) agrees with the importance of ensuring compliance with FWS community service requirements. The University implemented additional internal controls and policy changes to how it administers the FWS program and completes FISAP reporting to resolve this issue. During NU’s annual FISAP reporting process, it discovered that it had not met its FWS community service obligation. The University submitted a waiver, but it was denied. The University took immediate action to determine the cause of not meeting its FWS community service obligations. Community Partnership Management: National University previously had a partnership with Barrio Logan College Institute (BLCI) located in San Diego, CA. This partnership changed during the pandemic when all schools received a waiver for the community service requirement. In August 2024, Elyse Joiner, Director of Financial Aid Processing, again reached out to BLCI to reestablish a partnership. At that time, National was informed that the previous point of contact was no longer employed with BLCI, but the institute was still interested in partnering with National to meet the community service requirement for Federal Work Study. Ms. Joiner had several communications with BLCI to implement and finalize the setup of the reading and math tutors, with the only outstanding item related to the need for a virtual option. Unfortunately, communication between National University and BLCI ceased in April 2025 when National stopped receiving responses from BLCI to its inquiries. To establish another partnership, Ms. Joiner reached out to United Way of San Diego County to explore the possibility of establishing a reading or math tutor program with them but did not receive a response. Program Administration Change: Federal Work Study funds were budgeted to meet the University’s community service requirement; however, due to unforeseen circumstances and the efforts noted above, the University was unable to meet the 7% community service requirement. The University did have tutors available to the University community, but this did not fulfill the community service requirement. National University has since rectified this for the current aid year. The positions have been posted (R 2025 3051), and the University will have multiple FWS students at the Nest at Spectrum, offering tutoring services to both NU students and the public. The YMCA next to Spectrum will also be informed about the services to promote additional awareness within the local community. Additional opportunities are being actively explored within the Student Disability Services team and the Schools of Law & Public Service and Education. Steps taken to improve transparency and tracking: The University conducted a holistic review of the current FWS policies and procedures and has or will take the following steps: o Comprehensive training for administering the FWS program and Campus-Based Funding programs o Develop and implement an internal control plan that monitors FWS spending activity, allowing for the proactive identification of when the University should reallocate funds between campus-based programs. o Implemented quarterly calibration meetings between FWS/Operations leaders and HR to ensure its FWS program is on track to meet the FWS community service, literacy, and tutoring regulatory requirements. o Explore the expansion of community service relationships and opportunities within the Federal Work Study Program. Name(s) of the contact person(s) responsible for corrective action: - Alan Coddington, AVP Student Financial Services - Elyse Joiner, Director of Operations, Financial Aid Processing and Technical Solutions - Rob Conlon, AVP Financial Aid Compliance Planned completion date for corrective action plan: February 2026

Recommendation: We recommend the University establish and implement a contingency process to ensure enrollment reporting continues during system access disruptions. This process should include monitoring NSC access status and developing alternative procedures to prevent reporting gaps, ensuring that all student statuses are submitted accurately and within the required 60-day timeframe. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: National University agrees with the importance of ensuring accurate and timely enrollment reporting to NSLDS. The University has taken significant steps to improve its internal controls and compliance with enrollment reporting requirements. The University has identified a few items that have resulted in challenges to accurate and timely enrollment reporting during the audit year. National Student Clearing House (NSC) reporting: On October 18, 2024, the institution was notified by NSC that its access to process enrollment reporting on behalf of NU was revoked during July 2024, resulting in a reporting gap. The University took immediate action to restore access to NSC. Access issues were fully resolved on October 23, 2024. Additionally, NU revised its policies and implemented an internal control plan that monitors NSC activity allowing for proactive identification of future service interruptions. All 33 enrollment certification errors occurred during the disconnect noted above. The University believes its current enrollment certification processes are timely, accurate, and compliant. Timing of implemented enrollment reporting changes: During the audit period National University implemented several improvements to refine and enhance the timeliness of its enrollment reporting. NU established stronger alignment across both OPEIDs and adjusted its timelines to ensure consistent and timely submissions. As part of this effort, the University restructured its reporting schedule, so that finalized enrollment report is submitted by the 6th of each month, supporting a successful and expedited monthly transfer from NSC to NSLDS. Since implementing these revised timelines and deadlines, the University has observed significant improvements and consistency in its internal QA audit scores during the audit period (since January 2025). Four of the five late reporting instances occurred before the implementation date of the University’s enrollment reporting changes. The University believes its refined and enhanced process changes demonstrate its commitment to timely, accurate, and compliant enrollment certification processes. One of the five late reporting instances occurred after the implementation date, and that was related to the student’s status change from active, to pending graduate, to graduate, and then withdrawn. The University will evaluate its process for reporting student status changes from pending graduate, graduate, and withdrawal to ensure clear definitions and status flows are in place. The University will create and deliver focused training in this area to stress the importance of accurate enrollment reporting. In addition to the above, the University will continue to take the following steps: • Continued monitoring and refining of processes to maintain timely and accurate reporting. Including, but not limited to its monthly testing of enrollment reporting accuracy to NSLDS conducted by the quality assurance team. • Identification and timely delivery of training for areas of opportunity identified in the monthly reviews to the registrar and data operations teams. • Revise the internal changes and documentation processes to ensure clarity of policy and regulatory guidance in areas of identified risk/confusion during enrollment reporting processing. Name(s) of the contact person(s) responsible for corrective action: - Rob Conlon, AVP Financial Aid Compliance - Sarah Massey, AVP of Operations Student Support and Registrar Operations - Gabrielle Witruke, Associate Director Data Analytics Planned completion date for corrective action plan: November 2025

Recommendation: We recommend the University review the R2T4 requirements and implement adequate procedures to make sure that students that withdrew have a calculation performed. We also recommend the University to evaluate the R2T4 review process to ensure Title IV funds are returned timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University agrees with the importance of ensuring that the return of Title IV funds (R2T4) calculation is performed both timely and accurately. The University has taken significant steps to improve its compliance with R2T4 requirements. These efforts have yielded improved results with the late return error rate decreasing year over year from 13% to 7%. The University will continue to monitor staffing levels and workload to ensure that staffing aligns with timeline requirements. The University’s Processing team will lead focused R2T4 training on topics related to areas of noncompliance. Additional topics will be identified throughout the year as trends are identified in the Quality Assurance Audit process. The following steps will be taken immediately to address finding 2025-001. - The Processing team will continue to conduct subject matter training monthly, prioritized as follows: o Post Withdrawal Disbursements (PWD) identification o Post Withdrawal Disbursement timeline requirements - A new weekly review will be implemented by quality assurance outside of the review completed by R2T4 leadership to test if processing specialists are accurately determining if an R2T4 is required and if a refund is needed for a withdrawn student. Results will be used to coach staff members as needed. The University’s Quality Assurance team will continue to conduct weekly R2T4 reviews to test the R2T4 calculation for accuracy, timeliness of funds returned, and verifying that all internal and external system inputs are completed correctly. Findings from the internal audits will inform ongoing training and remediation steps throughout the year. Name(s) of the contact person(s) responsible for corrective action: - Rob Conlon, AVP Financial Aid Compliance - Alan Coddington, AVP Student Financial Services - John Okel, Director of Operations, Financial Aid Processing Planned completion date for corrective action plan: January 2026

Finding 2025-002; Lehigh acknowledge that in two instances, Title IV credit balances were not refunded within the required 14-day timeframe. The two exceptions identified were isolated in nature and attributable to unique circumstances rather than systemic process failure. In the first instance, the student was enrolled in the summer term and their summer Pell Grant was not processed until October. As a result, the Title IV credit balance was created well after the end of the summer payment period, outside of our typical refund monitoring cycle for that term. In the second instance, the credit balance was identified within the 14-day requirement. However, the student had not enrolled in direct deposit through the eBill system. Lehigh contacted the student to obtain payment instructions. When no banking information was provided to Lehigh, a paper check had to be issued, which extended the disbursement timeline beyond the 14-day period. While these situations were atypical, we recognize the importance of ensuring timely disbursement regardless of individual circumstances. To strengthen controls, we continue to prioritize Title IV credit balance refunds over refunds resulting from institutional aid or other funding sources to ensure compliance with federal timelines. Although we continue our institutional practice of holding refunds until after the 10th day of class to account for schedule adjustments and enrollment changes, we will begin generating and reviewing credit balance reports earlier in the cycle to allow sufficient processing time. We will implement automated reporting to identify credit balances that occur after the end of an academic period. These reports will be sent to a shared bursar office email account rather than an individual staff member. This will ensure visibility and actionability even during staff absences, turnover, or non-workdays. Responsibility for monitoring and processing Title IV credit balances will be formally documented. Multiple staff members will be trained in the procedures to ensure appropriate backup coverage during employee absences, leave, or staffing transitions. Management will periodically review refund timelines to confirm adherence to procedures and verify that credit balances are disbursed within regulatory timeframes. We believe these corrective actions address the audit recommendation and will ensure timely and consistent processing of Title IV credit balance disbursements regardless of staffing availability.Name of contact person: Jennifer Mertz is the Assistant Vice Provost of Financial Services and Director of Financial Aid. Completion date: All of the control strengthening mechanisms and documentation will be complete by June 30, 2026.

Student Financial Assistance Cluster – Assistance Listing No. 84.007, 84.032, 84.033, 84.063 Recommendation: We recommend the University review its policies and procedures related to outstanding Title IV checks to ensure they are being returned to the Department of Education after being outstanding more than 240 days. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: La Salle University AVP/Controller and AVP/Student Financial Service have reviewed the finding related to the escheatment of Title IV student refunds and have implemented a formal step-by-step process and policy to ensure compliance going forward. The updated procedure outlines clear responsibilities, required timelines, and documentation standards for processing unclaimed refunds and escheating funds in accordance with federal and state regulations. Staff have been informed of the new process and will follow the documented policy moving forward. Name(s) of the contact person(s) responsible for corrective action: AVP/Controller, Viviana Yang and AVP/Student Financial Service, Michele McDevitt. Planned completion date for corrective action plan: March 31,2026

Student Financial Assistance Cluster – Assistance Listing No. 84.007, 84.063, 84.268 Recommendation: We recommend the University evaluate its procedures and policies to ensure correct dates are being used in the calculation and that it is reviewed for accuracy. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Selected semester-related values in our Student Information System (BANNER) will be reviewed for compliance with the official, stated values in the school’s academic calendar. Adjusting for Housing-related dates or potential extensions due to possible delays caused by uncontrollable events will not be included. Name(s) of the contact person(s) responsible for corrective action: Gerard Donahue, Registrar Planned completion date for corrective action plan: Corrected as of Summer 2026 (Fall 2025 and Spring 2026 are already in process as of this writing)

Student Financial Assistance Cluster – Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the University evaluate its policies and procedures around reporting student status changes to the NSLDS to ensure that all relevant information is being captured and reported timely in accordance with applicable regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: La Salle contractually relies on the National Student Clearinghouse (NSC) to conduct its enrollment reporting to NSLDS. While there has been closer adherence to the overall transmission schedule established with the NSC, and this covers enrollment reporting for the vast majority of our registered students, such was not always the case in prior semesters, and selected exceptional registration transactions are not directly reported when they actually occur, resulting in delays, until the next regularly scheduled transmission. Going forward, upon encountering these exceptional transactions, we will take steps to ensure reporting of individual enrollments to the NSC within 1-2 business days following the transaction’s occurrence. Name(s) of the contact person(s) responsible for corrective action: Gerard Donahue, Registrar Planned completion date for corrective action plan: Corrected as of Spring 2026 (Fall 2025 is already complete as of this writing)

Student Financial Assistance Cluster – Assistance Listing No. 84.063 Recommendation: We recommend the University evaluate its procedures and review policies in overseeing COD reporting to ensure timely reporting. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: La Salle University has developed a report that enables weekly auditing of the Pell-eligible student population to ensure accurate identification and timely submission for evaluation. This report will be monitored on an ongoing weekly basis to promptly detect and address any errors related to Pell eligibility. Name(s) of the contact person(s) responsible for corrective action: Michele McDevitt, Assistant Vice President for Student Financial Services Planned completion date for corrective action plan: Corrected as of Spring 2026 (Fall 2025 is already complete as of this writing)