Corrective Action Plans

Finding 2025-001 Condition Significant Deficiency – Disbursement/Refund of Credit Balances - Title IV regulations (34 CFR 668.164(h)(1) require that Title IV credit balances on student accounts be paid directly to the student as soon as possible but no later than 14 days after the credit balance occurred. A student or parent may authorize the Institution to hold the credit balance to be applied to specified other nontuition fees, room and board charges as noted in the regulations at (34 CFR 668.165(b)). The credit balance generated in the accounts of 2 out of 25 students tested was not timely refunded to them based on the outlined criteria, leading to late refunds to those students (neither of which completed a voluntary hold authorization). The sample was not a statistically valid sample. The College's payment process cycle is not set up to process refunds as soon as possible, which caused delays in refunds being made to students, resulting in a violation of the 14-day maximum policy. Corrective Action Plan Corrective Action Planned: The College acknowledges the untimely disbursement of Title IV credit balance refunds. We concur that, for 2 of the 25 student accounts reviewed, Title IV credit balances were not refunded within the 14-day period required under 34 CFR 668.164(h)(1). We further acknowledge that no valid student or parent authorization to hold these credit balances was on file, and therefore the refunds should have been issued promptly. The College completed an internal review and determined that the delays resulted from the structure of the existing payment processing cycle. Although the College’s processes emphasize careful reconciliation and verification of student account activity, the timing of our refund cycle was not aligned with the regulatory requirement. To remediate this deficiency and ensure full compliance going forward, the College is implementing the following corrective action: Revision of Federal Funds Disbursement Policies: The College is revising its policy governing the drawdown and disbursement of federal funds to align the timing of Title IV activity with the academic add/drop period. This change will ensure greater predictability of credit balance creation and enhance monitoring capabilities. The College is committed to strengthening its internal controls to ensure sustained compliance with all Title IV cash management regulations. Name(s) of Contact Person(s) Responsible for Corrective Action: Pat Tyler, Bursar and Destiny Guerrero, Director of Financial Aid. Anticipated Completion Date: May 2026 – next semester starting date

Personnel Responsible for Corrective Action: Dr. Tom Stuart, Associate Vice President of Student Financial Services Anticipated Completion Date: April 14, 2026 Corrective Action Plan: The corrective action plan includes the following: 1) With assistance from the NSC, the College established a second branch for EMBA reporting and submitted an out-of-cycle update for all EMBA students in the 2024-2025 population. Moving forward an EMBA enrollment report will be submitted at the start of each monthly term. 2) With regard to program length corrections we have confirmed program-level records in SIS reflect accurate published program lengths and units as well as updated the enrollment reporting parameters used for NSC. We will continue to monitor to ensure that the changes to the reporting parameters correct the program length errors.

Student Financial Aid Corrective Action Plan Institution Name: Southwestern University Audit/Review Period: FY 2024-2025 Date of Plan: Feb 4, 2026 Finding: 2025-001 Effect: The University did not report withdraw changes to the NSLDS timely. Recommendation: The University should put in place a process to timely capture student status changes so that they can be reported to the NSLDS. Management Response: The University concurs with this finding. University Corrective Action Plan: Every 30 days, the University reports updated student enrollment activity, encompassing attendance levels, graduation status, withdrawals, dropouts, and enrollment changes, to the National Student Loan Database System via the National Student Clearinghouse. Regrettably, during the 2024-25 academic year, an unforeseen error from the Clearinghouse resulted in the dissemination of incorrect enrollment statuses for a subset of our students. This oversight was beyond the Registrar's Office's knowledge, leading to an unintended delay in rectifying the reported statuses. We believe this Clearinghouse error was an isolated incident, having never occurred in any preceding academic year. The issue has been effectively resolved and should not recur in the future. Nevertheless, as a proactive measure, commencing with the 2025-26 academic year, the Financial Aid Office will collaborate with the Registrar's Office to review a representative sample of at least 10% of student records transmitted to the Clearinghouse. This review process will serve as an additional safeguard, ensuring the accuracy and timeliness of our reporting requirements.

February 18, 2026 2025 - 001 Federal Program - Student Financial Assistance Cluster - Asstance Listing Nos. 84.063, Federal Pell Grant Program and 84.268 Federal Direct Student Loans U.S. Department of Education Program Year 2024 - 2025 - Enrollment Reporting Summary of Findings: A student record graduation status was not reported correctly. The student was flagged by the Clearinghouse as not having a graduation status applied after the spring degree file submission, but that error was not resolved by the registrar. The failure to resolve this issue was due to staffing issues within the Office of the Registrar. Additionally, another student's withdrawal status was not reported correctly. This student submitted a complete withdrawal form prior to the end of the 2025 spring semester effective for the 2025 fall semester and had their program closed in the school's SIS after the spring semester ended. Students who separate from the university in between regular semesters, and who don't have enrollment in the non-standard summer term, need to be reported as withdrawn individually. Their status change will not be picked up by our normal enrollment process. Recommendations: Staffing issues may be problematic again in the future. Cross-training and adequate staffing is necessary to make sure enrollment reporting is finished in a timely manner. A change to how summer enrollment reporting is handled is necessary to ensure student status changes are reported correctly. Action taken in response to findings: The university has eliminated the hourly graduation specialist position and moved the resposibility for submitting and resolving errors on the degree file to the Associate Registrar. The registrar has also created an enrollment and degree reporting checklist to ensure the process of submitting and resolving errors is completed. The university is changing how it handles complete withdrawals. The Registrar's Office will be responsible for closing out student programs and processing the complete withdrawal form starting this spring. Derrick Weddle University Registrar

Student Financial Aid Cluster – Assistance Listing No.: Various Recommendation: We recommend the University evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Outdated Banner jobs have been updated. After review, the 3PELL disbursement on 08/28/2024 was not caused by human intervention. The early disbursement occurred because Automic ran during that period using the outdated RPEDISB job, which can, in rare cases, trigger a disbursement without a COD Document ID. The Pell grant did not officially originate in COD until 09/12/2024, so the disbursement technically occurred earlier than expected. This was due to the legacy process still running in Automic despite Ellucian phasing out RPEDISB. Name of the contact person responsible for corrective action: This change was made by our former IT Department, prior to contracting with our current IT Managed Services partner, Collegis Education. Going forward, any similar technical issues would fall under the leadership of our new CIO, Debra Lang. Planned completion date for corrective action plan: September 2024 If the United States Department of Education has questions regarding this schedule, please call LaNita Robinson at 651-690-7795.

Student Financial Aid Cluster – Assistance Listing No.: Various Recommendation: We recommend the University review its reporting procedures to ensure the students’ statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We continue to have system-related issues, for example, the NSC FTP didn't accept our October report, so it was late and it took a long time for us to figure out what had happened. Also, the wrong dates were sent in fall. Our system sent summer dates during the fall semester. Student Affairs staff are now contacting students who have withdrawn in the semester to encourage them to complete a “Leave of Absence” (LOA) request if they think they will not be returning in the subsequent semester. Students have the ability to make their decision at any time. Once we are notified of an LOA, we are updating our system and sending that information to NSLDS. Name of the contact person responsible for corrective action: Kerri Vickers, Registrar. Planned completion date for corrective action plan: On-going.

Identifying Number: 2025-003 Finding: Graham Leach Bliley Act – Student Information Security The College’s written information security program did not include the following elements required by regulation as agreed to in the PPA: • The College has performed a risk assessment utilizing internal resources but has not fully integrated the information security program on the results of this assessment, nor has the College included all required elements of internal and external risks to the security, confidentiality or integrity of customer information. The College’s risk assessment is in the process of implementing an inventory of IT systems that process and store customer information and the compliance with information security elements related to multifactor authentication, access control, change management, logging and alerting and encryption. • The College has not identified, designed or implemented safeguards for all of the risks identified in the risk assessment. The safeguards do not include the identification of security events the detection and response capabilities to support incident response is still being developed. • The College has not been able to test safeguards because safeguards have not been fully designed or implemented in response to the risk assessment. • The College has not developed written policies and procedures to ensure that personnel are able to enact the information security program. There is a lack of evidence of leadership being required to report to the board or an appropriate supervisory council to ensure those charged with governance are informed on the current state of the information security program. Corrective Actions Taken or Planned: 1. Integration of Risk Assessment Results • Corrective Actions Taken or Planned: Complete a new risk assessment for our new information systems and fully integrate the results including safeguards into the College’s information security program. • Person Responsible: James Stevens, Chief Information Officer, jstevens@knox.edu • Anticipated Completion Date: June 30, 2026 2. Provide Training for Written Policies and Procedures • Corrective Actions Taken or Planned: Distribute written policies and procedures to ensure personnel can enact the information security program. Provide training to all relevant staff. • Person Responsible: James Stevens, Chief Information Officer, jstevens@knox.edu • Anticipated Completion Date: June 30, 2026 3. Testing of Safeguards • Corrective Actions Taken or Planned: Conduct regular testing of implemented safeguards to ensure effectiveness. Document results and make improvements as needed. • Person Responsible: James Stevens, Chief Information Officer, jstevens@knox.edu • Anticipated Completion Date: June 30, 2026 4. Comprehensive Inventory of IT Systems • Corrective Actions Taken or Planned: Update and maintain our inventory of all IT systems that process and store customer information. Ensure compliance with multifactor authentication, access control, change management, logging, alerting, and encryption requirements. • Person Responsible: James Stevens, Chief Information Officer, jstevens@knox.edu • Anticipated Completion Date: June 30, 2026 5. Governance and Reporting • Corrective Actions Taken or Planned: Establish a formal process requiring leadership to report on the state of the information security program to the Board of Trustees and include in our security policies. • Person Responsible: James Stevens, Chief Information Officer, jstevens@knox.edu • Anticipated Completion Date: 6/30/2026 6. GLBA Policy Enhancement • Corrective Actions Taken or Planned: Review and revise the information security policy to ensure all GLBA-required elements are included, referencing current regulatory guidance. • Person Responsible: James Stevens, Chief Information Officer, jstevens@knox.edu • Anticipated Completion Date: 6/30/2026

Identifying Number: 2025-002 Finding: Disbursements to or on Behalf of Students (Credit Balances) The College did not pay the Title IV credit balances to the students directly within the required timeline noted above. Out of the 40 students tested, we noted 2 students (5%) whose credit balances were not paid directly to the students within the required timeframe noted above. The incorrect timing did not have an effect on the total award given to students (timing only). The College did not have formally documented controls related to the process associated with disbursements to or on behalf of students (credit balances), which is required under Uniform Grant Guidance. Corrective Actions Taken or Planned: Knox College has implemented the following corrective measures to ensure compliance with federal credit balance requirements: 1. Automated Monitoring: A system-generated report (Aging Report) of all student credit balances is now produced twice per week from the Jenzabar J1 student information system. 2. Formal Workflow: The AVP of Student Financial Services (SFS) will review the Student Accounts Aging Report. Student Financial Services Advisors will review each of their student accounts that have a credit balance within 24 hours. If the student has a credit balance and has receive Title IV aid during the academic year, the advisor will review if the credit balance is derived by Title IV. A standardized credit balance processing schedule has been established, ensuring that credit balances are reviewed and released within 14 days of disbursement. Role Clarification: Responsibilities are now clearly defined: • SFS confirms refund eligibility. • Business Office processes refunds through Bill.com and posts to the student account. Staff Training: Relevant staff received training on: • Title IV credit balance requirements • Handling of student/parent authorizations • Timely return of unclaimed funds Documentation Controls: All credit balance disbursement and return transactions are documented and retained as part of the official audit record. Person Responsible: Leigh Brinson, Assistant Vice President of Student Financial Services, ltbrinson@knox.edu Anticipated Completion Date: November 10, 2025

Identifying Number: 2025-001 Finding: Error in Reporting for National Student Loan Data System (NSLDS) The College did not properly report the student enrollment change for students who received federal student aid to the NSLDS. The College did not timely report three students’ Program-Level or Campus-Level enrollment status change to NSLDS. Out of the 25 students tested, we noted 3 students (12%) whose status change at the Program-Level and Campus-Level was not timely reported to NSLDS. The College did not have adequate controls related to the process of enrollment reporting, which is required under Uniform Grant Guidance. Corrective Actions Taken or Planned: Knox College will add a third report submission to the end of the term. This will ensure that we report any students that made end of term withdrawals within the time window we are required to report. Any students who withdraw between terms will be captured in the first report submitted after our two week census. Person Responsible: Patrick Hathaway, Registrar, phathaway@knox.edu Anticipated Completion Date: December 31, 2025

Finding 2025-003: Late Student Status Change Reporting Federal Agency: U.S. Department of Education Program: Student Financial Assistance Cluster Criteria: 34 CFR 668.32 requires that an organization reports student status changes within 60 days of graduation, withdrawal, or other roster status changes. Condition: The change in status for 4 of 40 students tested was not reported to the National Student Loan Data System (NSLDS) within 60 days of the change. Cause: Staffing changes during the year impacting the College’s internal control structure resulted in an administrative delay in reporting the changes to NSLDS. Effect: The effect of the condition described above was that the College was not in compliance with NSLDS reporting requirements. Repeat Finding: This is not a repeat finding. Questioned costs: There are no known questioned costs to report. Recommendation: We recommend that the College ensures sufficient staffing is available to report NSLDS requirements timely. View of Responsible Officials and Planned Corrective Action Corrective Action Plan: There is no disagreement with this audit finding. During the fall of 2024 the Registrar’s Office was downsized. This resulted in the delayed processing of the error report following the 10.25.2024 report. This resolution required contacting NSC for assistance in clearing two of the errors, which increased the processing time. Moving forward, the Registrar’s Office will continue to report to NSC on the predetermined schedule, process errors timely, and additionally, a quality control check will be implemented for the Financial Aid Office to compare NSLDS records following the NSC transmissions. Name(s) of the contact person(s) responsible for corrective action: Dr. Melissa Wisniewski, Dean of Enrollment Services at 717-391-7234. Planned completion date for corrective action plan: February 2026 If the Department of Education has questions regarding this plan, please call the Vice President of Finance and Administration, Mr. George Longridge at 717-391-6947.

Finding 2025-002: Student Financial Aid Cluster – Allowable Costs and Allowable Activities and Eligibility Federal Agency: U.S. Department of Education Program: Student Financial Assistance Cluster Criteria: The College is required to have controls in place to ensure students receive the proper amount of student financial assistance they are entitled to based on financial need. Condition: Our financial aid sample of 40 items tested yielded 31 students who received Direct Loan Funding. Of the 31 students who received Direct loan funding, we noted 1 instance where the student received the incorrect amount of Unsubsidized funding. Based on the students Student Aid Index, the student should have received $1,750 in Unsubsidized funding; however, they received $2,227 in Unsubsidized Direct Loan funding, resulting in an overpayment of Direct Loan funding of $477. Cause: The controls in place did not detect that the student had incorrectly been awarded assistance based on more than 30 credits when they actually had 25 credits. The additional 5 credits needed for the amount of the award were not earned until the following semester. Effect: Internal controls related to student financial assistance were not operating properly. Repeat Finding: This is not a repeat finding. Questioned costs: $477 Recommendation: We recommend Thaddeus develop systems that would detect credits posted but not earned to ensure proper student assistance is awarded. View of Responsible Officials and Planned Corrective Action: Management agrees. See separate Corrective Action Plan. Corrective Action Plan: There is no disagreement with the audit finding. After reviewing the policy for Grade-Level Advancement for Direct Loan Consideration, it was determined that the student referenced in the funding did not meet the qualifications needed to be considered a sophomore level student for the Fall 2024 semester. The student became eligible for the increased loan amount in the Spring 2025 semester. The $500 that was incorrectly awarded to the student for the Fall 2024 semester has been corrected and reallocated to Spring 2025. The Office of Financial Aid has created a procedure to check student loan amounts during fall and spring semester to ensure accuracy. Additionally, an Assistant Director of Financial Aid was hired in February 2025 to strengthen financial aid administration within the department. Name(s) of the contact person(s) responsible for corrective action: Melissa Wisniewski, Dean of Enrollment Services at 717-391-7234. Planned completion date for corrective action plan: January 2026. If the Department of Education has questions regarding this plan, please call the Vice President of Finance and Administration, George Longridge at 717-391-6947.

Finding 2025-001 Condition Management implemented controls that specifically addressed some of the circumstances surrounding prior year finding 2024-001. Management's review of the enrollment reporting did not timely report certain student Campus-Level and Program-Level data elements. Student records within the NSLDS was identified with non-timely Campus-Level and Program-Level data elements. Corrective Action Plan Corrective Action Planned: Management agrees with the finding. To resolve this issue, when a student formally withdraws or is academically dismissed in summer, the student information will be manually added to the next National Student Clearinghouse (NSC) upload file, submitted once a month, and marked as “Withdrawn” with an effective status date of the withdrawn date of determination. This complies with NSC processes detailed here: https://help.studentclearinghouse.org/compliancecentral/knowledge-base/enrollment-reporting-for-summer-and-other-non-required-terms/. Name of Contact Person Responsible for Corrective Action: Mark Fetherston, Vice President for Enrollment Management Anticipated Completion Date: Process and procedures will be updated in February 2026, with first implementation in May 2026 (as part of the Summer 2026 submission process).

Audit Period: June 30, 2025 The findings from the June 30, 2025 Schedule of Findings and Questioned Costs (the “Schedule”) are discussed below. The findings are numbered consistently with the number assigned in the Schedule. FINDINGS AND QUESTIONS COSTS – MAJOR FEDERAL AWARD PROGRAM AUDIT 2025-002 – U.S. Department of Education, SFA Cluster, Special Tests and Provisions - Return of Title IV Refunds (Significant Deficiency) Condition: From a population of 74 students that officially or unofficially withdrew during the term, we tested nine students and noted that four students required refund calculations. From the fall 2024 semester calculations we noted that the College did not deduct Thanksgiving break of nine days, November 23, 2024 through December 1, 2024, from the total days in the semester. Criteria: The total number of calendar days in a payment period or period of enrollment includes all days within the period that a student was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period (34 CFR Section 668.22(f)(2)(i)). Cause: Controls to ensure proper calculation of Title IV refunds did not function as related to the condition above. Effect: Calculations were incorrect for the three students tested that officially or unofficially withdrew during the fall 2024 term resulting in an incorrect amount of funds returned to the student and the Department of Education. Repeat Finding from a Prior Year: No Recommendation: We recommend the College implement procedures for accurate preparation and calculation of Title IV refunds. Management Response: The college is in agreement with the recommendation to implement procedures for accurate preparation and calculation of Title IV funds. If the Federal Audit Clearinghouse has questions regarding this plan, please call Danielle Pfaff, Controller, at 1-336-316-2140 or dpfaff@guilford.edu

The Office of Financial Aid is currently strengthening the Return to Title IV (R2T4) process by formalizing written procedures and integrating industry best practices. As part of this effort, we are implementing a quality control system whereby a second team member reviews each file to ensure the accuracy of calculations, the completion of necessary pullbacks or billings, and timely communication with students. Additionally, we are enhancing our Title IV reconciliation process to serve as an added layer of oversight, verifying that award data in our student information system (Banner) aligns with records in the Common Origination and Disbursement (COD) system.

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

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

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

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

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

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

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

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

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

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

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