Corrective Action Plans

The College has identified that the dates of enrollment submissions and status changes for the two students identified in the audit were out of compliance (102 days and 69 days). The statuses of both students are correct with NSLDS. Student 1: Student officially withdrew but withdrawal was not processed until the end of the term. Since the withdrawal was not processed in a timely manner, the enollment status and subsequent R2T4 calculation (as noted in finding 2024-002) was delayed. Student 2: Student graduated, and status was updated with NSLDS at 69 days. Due to delayed communication and delayed reporting to NSLDS, CMN will revise institutional policy to clearly define the process and timeline for enrollment status changes. Financial aid staff will seek additional training in enrollment reporting through FSA and/or NSFAA. To further monitor compliance, CMN has already worked with Anthology (student information system) to provide electronic triggers to the financial aid office when a student status changes from active to drop/withdrawal. This electronic, automatic process will provide an additional layer of notification to the financial aid office when a student status change requires further attention.

2024-002 – Special Tests and Provisions - Enrollment Reporting – Material Weakness in Internal Controls over Compliance Student Financial Assistance Cluster Department of Education Federal Assistance Listing Number: 84.063, 84.268 Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans Federal Award Number: P063P230357, P268K230357 Award Year: 2023-24 Criteria: The National Student Loan Data System (NSLDS) is the Department of Education’s (ED) centralized database for students’ enrollment information under the Pell Grant and the Direct Loan and Federal Family Education Loan programs. Uniform guidance requires institutions to have internal controls in place to ensure attendance changes for students are reported to NSLDS within at least 60 days of when the student attendance change occurs. It is the College’s responsibility to update students' enrollment information timely and accurately as outlined in 34 CFR § 685.309. Condition/context: The auditors selected a sample of 34 students out of a population of 1,454 who had received Federal aid and had withdrawn or graduated from the College during the 2023-2024 fiscal year. The auditors compared the withdrawal or graduation date per the College’s records to NSLDS. The auditors noted eight students were not reported to NSLDS within the 60-day requirement. In addition, the auditors identified ten students who graduated but were not reported as graduated to NSLDS. Corrective Action: LCC reports enrollment to the National Student Clearinghouse: in the second, sixth and the tenth week of each standard term. There is an error report that the Clearinghouse returns with discrepancies in enrollment status which we respond to and correct within five business days. Once all errors are resolved and the report is accepted the NSC will post the data and report to NSLDS. Lane is an open access institution and therefore does not have a formal withdrawal policy. Two weeks after the end of each term, Lane sends the enrollment report and the “degree verify” extract to NSC. We are in the process of reviewing our NSC reporting strategies and including additional staff who will be supporting the process. We are reviewing NSC reporting times to ensure that we are reporting often enough to meet the required 60 day timeline for NSLDS. We are considering moving the enrollment and degree verify extract to a 30 day reporting period to meet the 60 day timeline. Phase 1: Issue an off cycle report to the NSC by June 6th, which is our next anticipated enrollment reporting cycle (week ten). We will send both the enrollment report and the “degree verify” extract to catch any updates to graduation information that may have changed since our last end of term report. Phase 2: Review updates to NSC processes that were issued through Banner and Ellucian and revise the “degree verify” process to capture regular graduation or withdrawal updates outside our standard reporting window. Unless it is discovered that the 30 day cycle does not meet the requirements of the reporting cycle, we will update our processes to - at a minimum - report every 30 days or in alignment with the weeks two, six and ten current enrollment report to the NSC. Additionally, the students noted in the finding will be reviewed to address any potential anomalies with reporting and to identify the cause of why these were not updated. This will be another consideration during the assessment for any updates to our reporting cycles. Following spring term, we will report graduated and withdrawn students, as is our current practice and after student degree awarding is complete. Name of Contact Person Responsible for Corrective Action: Dawn Whiting Anticipated Completion Date for the Corrective Action: A review process of 90 days should result in refined practices and an implementation of those practices to meet required reporting. All reporting changes will be finalized and followed by Aug 21, 2025.

The finding from Section III – 2024-006 General Ledger System Condition: The District did not track the federal expenditures within the general ledger system, or if they were, the business office was unaware of the process and was not using the correct expenditures to claim as eligible expenditures. Views of Responsible Officials and Planned Corrective Actions: Southern Fulton School District has hired a Certified Public Accountant (CPA) as the Chief Financial Officer (CFO) as of 4/1/2025 who will be responsible for ensuring that the general ledger system is utilized to track all federal expenditures.

The finding from Section III – 2024-005 Reporting Requirements Condition: The District did not file the Title 1, Title 2, and Title 4 Reconciliation of Cash on Hand Quarterly Reports for March 2024 and June 2024.Additionally, the Final Expenditure Reports for Title 1, Title 2, and Title 4 were not filed by the required date. Views of Responsible Officials and Planned Corrective Actions: Southern Fulton School District has hired a Certified Public Accountant (CPA) as the Chief Financial Officer (CFO) as of 4/1/2025 who will be responsible for ensuring all Title reports are filed timely and by the deadlines.

DEPARTMENT OF TRANSITIONAL ASSISTANCE 2024-026 Temporary Assistance for Needy Families (TANF) - Assistance Listing No. 93.558 Recommendation: We recommend the Department evaluate its procedures and internal controls over Child Support Non-Cooperation to ensure that sanctions are applied timely. Action taken in response to finding: The Department will utilize existing training opportunities, including but not limited to new hire training, monthly supervisor webinars and ad hoc guest training from DOR to address this topic as needed. Further, the Department is working on building out a quality control program on sampling of TAFDC cases in the Quality Management organization. When built out, this program would include a sample review of child support non-cooperative cases to ensure sanctions are applied timely and appropriately. In the interim, ad hoc targeted reviews on this topic will be performed annually at minimum as a compensating control for risk mitigation. Reviews will be performed on a sample basis. Name(s) of the contact person(s) responsible for corrective action: Megan Nicholls, Associate Commissioner of Family and Economic Assistance - Training Lily Kuo, Director of Internal Controls – Ad hoc Targeted Reviews Planned completion date for corrective action plan: September 30, 2025 and forward – Facilitate training March 30, 2026 and forward – Perform ad hoc targeted reviews

Finding 2024-002 - Special Tests and Provisions - Federal Direct Loan Program Student Notification – Significant Deficiency Name of Federal Agency: U.S. Department of Education Federal Program Name: Federal Direct Student Loans Assistance Listing Number: 84.268 Federal Award Identification Number and Year: P268K243382 2024 Name of Pass-through Entity: N/A Planned Corrective Action: The failure to timely send out the required notification of Federal Direct Student Loan Program proceeds credited to one student’s account, as noted in the auditor’s findings, was an administrative oversight. In May 2025, the Institute reviewed and revised its current procedures to ensure that all required notifications are made. Under the revised procedures, an employee independent from the student loan proceed crediting notification process is to review that notifications are sent out within prescribed time frames in accordance with U.S. Department of Education regulations to all students receiving and being credited with Federal Direct Loan Program amounts and that copies of the notifications are maintained in each applicable student’s file.

Finding 2024-001 – Special Tests and Provisions – Exit Counseling – Significant Deficiency Name of Federal Agency: U.S. Department of Education Federal Program Name: Federal Direct Student Loans Assistance Listing Number: 84.268 Federal Award Identification Number and Year: P268K243382 2024 Name of Pass-through Entity: N/A Planned Corrective Action: The failure to document the exit conference of one student borrower in the Federal Direct Loans Program, as noted in the auditor’s findings, was an administrative oversight. In May 2025, the Institute reviewed and revised its current procedures to ensure that all exit conferences are documented. Under the revised procedures, an employee independent from the exit conference process is to review that any student that has not enrolled in a new semester or that is enrolled at less than half time status has received proper exit conferencing and that the exit conferencing has been properly documented.

Finding NO. 2024-0006 – Reporting View of the University of Guam and Correction Action Plan: An agreed upon timeline for generating data will be established for use in the annual FISAP. The Admissions and Records Office will generate the school enrollment for the relevant academic year. The data snapshot will be taken immediately after the end of the summer semester. For the enrollment data for AY24-25, the snapshot will be taken during the first week of September 2025 with a similar timeline for subsequent years. Once that data snapshot is generated, the Office of Information Technology will generate a report of collected tuition and fees corresponding to the snapshot data from Admissions and Records. In testing, this was found to be the most accurate process in generating the required data for the FISAP. Name of Contact Person: Mark Duarte, Director, Financial Aid and Triton One Stop Office Proposed Completion date: Next Reporting Period

Finding NO. 2024-005 Special Tests and Provisions – Enrollment Reporting View of the University of Guam and Corrective Action Plan: The University of Guam has signed a service agreement with the National Student Clearinghouse (NSC) to assist the University with enrollment reporting. The Admissions and Records Office (A&R) will submit an enrollment report to the NSC at least four times per semester. A first of term report, and three other subsequent reports within the semester. This report will be sent to the National Student Loan Database System (NSLDS) in fulfillment of the federal regulations requirement for enrollment reporting. Name of Contact Person: Mark Duarte, Director, Financial Aid and Triton One Stop Office Proposed Completion date: Next Reporting Period

Finding NO. 2024-003 Cash Management View of the University of Guam and Corrective Action Plan: The Financial Aid Office (FAO) will conduct both internal and external monthly reconciliations to ensure the accuracy of financial aid disbursements and compliance with federal regulations. Internally, the FAO and the Business Office will reconcile actual disbursements and adjustments against drawdowns, drawdown adjustments, refunds of cash, and returns weekly or bi-weekly, following each transmittal to the Business Office. Any discrepancies will be documented and resolved promptly. Externally, the FAO will reconcile with the COD system by the 10th of each month, comparing all disbursements, adjustments, and refunds to the balances reported in COD. A copy of the completed monthly reconciliation will be forwarded to Accounts Receivable as official documentation. Name of Contact Person: Mark Duarte, Director, Financial Aid and Triton One Stop Office Proposed Completion date: Ongoing

Finding NO. 2024-002 Special Tests and Provisions – Disbursements to or on Behalf of Students (Credit Balances) View of the University of Guam and Corrective Action Plan: To comply with federal regulations regarding the timely disbursement of Title IV credit balances, the University’s Business Office established a payment log in October 2024 to monitor and document all related transactions. Furthermore, to ensure ongoing compliance, the University will create a Standard Operating Procedure to be distributed among the Business Office staff. Name of Contact Person: Abigail Martin, Comptroller Proposed Completion date: September 30, 2025

Action taken in response to finding: Admissions training manuals have been updated to ensure that the date the student first indicated a desire to withdraw from a course is used as the date of withdrawal rather than the date that the withdrawal was processed in Colleague. Admissions staff members have been trained on the updated procedure for processing student course withdrawals. The Office of Institutional Research has reviewed and updated the procedures used to generate reports sent to National Student Clearinghouse. IR staff members will ensure that the last date of attendance is reported for student course withdrawals. The office of Institutional Research has contacted National Student Clearinghouse for guidance on the enrollment reports needed to ensure that student enrollment is reported to NSLDS accurately and timely. An additional enrollment report will now be sent to National Student Clearinghouse for reporting graduated students. This will ensure that students that have graduated are reported as no longer enrolled within the required reporting timeframe.

Action taken in response to finding: As a result of the 2023 audit, which concluded in May of 2024, adjustments were made to reflect a five day fall break for Fall 2024. R2T4 calculations for Fall 2024 have been reviewed and the use of a five-day break for the term has been verified. The Fall 2025 term has already been built in Colleague to reflect a five day fall break. The Fall 2023 term was built in Colleague by the previous Director of Financial Aid. The current Director of Financial Aid has recognized a five-day break when building the fall terms in Colleague and will continue this practice for future terms. In following our recently updated R2T4 process, all Financial Aid staff members have been trained and are able to perform R2T4 calculations. R2T4 calculations for the 2024-2025 academic year have been performed by Financial Aid staff and have been reviewed for accuracy and approved by the Director of Financial Aid.

Finding #2024-001 – Significant Deficiency and Other Noncompliance. Applicable federal program: U. S. Department of Education, Student Financial Assistance Programs Cluster, Assistance Listing #84.063, Federal Pell Grant Program, Assistance Listing #84.268, Federal Direct Student Loans, Contracts #003556 and G03556, Contract years: 05/05/21 – 12/31/26. Recommendation: Emphasize the importance of accurately reporting enrollment status. Planned corrective action: Management agrees with audit finding #2024-001. The Financial Aid Coordinator is responsible for reporting enrollment status changes, certifying enrollment every 60 days, and responding to NSLDS Roster files within 15 days, all through the NSLDSFAP website. To enhance the accuracy of these enrollment reports, the Institute is implementing a new double-check process. Henceforth, the Financial Aid Coordinator will print all enrollment status changes or enrollment report rosters prior to making any online updates or certifications. These printed reports will then be given to the Director of Operations for verification. Only after this verification will the Financial Aid Coordinator proceed with the necessary changes or certifications on the NSLDSFAP website. All printed reports will be retained by the Financial Aid Coordinator for documentation. Responsible officer: Cody Lopasky, President. Estimated completion date: June 1, 2025.

At the time that the last FISAP was completed, the Financial Aid office was severely understaffed. As a result, an oversight occurred in reporting dependent undergraduate students with Baccalaureate degrees. In thi instance, the correct information was retrieved, however it was reported incorrectly. Staffing in the Financial Aid office has been addressed by hiring an Advisor and Assistant Director. Moving forward, the Assitant Dean will continue to complete the FISAP. However, prior to submission, the application will be reviewed by both Assistant Directors of Financial Aid. Contact person(s) responsible for corrective action: Yvette McGhee, Assistant Dean of Financial Aid. Anticipated completion date: Immediate

2024-004 – Disbursing Funds (Significant Deficiency) Department of Education, SFA Cluster, Special Tests and Provisions Criteria: Except for paying a student under the Federal Work Study program or unless 34 CFR 685.303(d)(4)(i) applies, an institution must disburse during the current payment period the amount of Title IV, HEA program funds that a student enrolled at the institution is eligible to receive for that payment period. (34 CFR 668.164 (b)(1). Condition: From a population of 679 students that received the Pell grant, we tested 24 students and noted that two students did not receive the Pell awards for which they were eligible, and one student received an incorrect Pell award. Cause: Controls to ensure accurate disbursements to students are not functioning properly. Effect: Two students did not receive Pell awards they were eligible for during the payment period and one student received more Pell funds than they were entitled to. Recommendation: We recommend that procedures are put in place to ensure timely and accurate payment of Title VI awards. Action Taken: Shortages in staffing did not allow for double checking student enrollment post census. To correct this situation, we have added an additional counselor. We are working with a consultant to automate manual processes to free up more counselor time. Responsible Party and contact information: Daisy Tabachow, Director of Financial Aid. Expected Date of Correction: Beginning with the summer 2025 trimester and ending at the end of the fiscal year.

2024-003 – Incorrect Calculation of Title IV Refunds (Significant Deficiency) Department of Education, SFA Cluster, Special Tests and Provisions 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)). For a student that ceases attendance at an institution that is not required to take attendance, the student’s withdrawal date is the date that the student provided official notification to the institution, in writing or really, of his or her intent to withdraw (CFR Section 668.22(c)(1)(ii)). Condition: From a population of 130 students that officially or unofficially withdrew during the term, we tested 15 students and noted that four students required refund calculations. From these calculations we noted the following: Spring break of nine days was deducted incorrectly as seven days instead of nine for the three students who withdrew during spring semester. One student’s date of withdrawal was incorrect on the refund calculation. Cause: Controls to ensure proper calculation of Title IV refunds did not function as related to the conditions listed above: The University’s spring break was for the period of February 24, 2024 through March 3, 2024, a nine consecutive calendar day period. However, the University did not include the first two weekend days and calculated the break as seven days instead of nine. Due to this error, the correct number of days for the break was not deducted from the total number of calendar days properly for purposes of calculating refunds. One student’s withdrawal date was entered incorrectly in the R2T4 calculation. Effect: Refunds were calculated incorrectly for three of the four students that required refund calculations resulting in an incorrect amount of funds returned to the student and the Department of Education. Recommendation: We recommend procedures are put in place to ensure accuracy of R2T4 calculations. Action Taken: The Director of Financial Aid as well as the Data Analyst who is responsible for calculating the Return of Title 4 refunds have retaken the training module on calculating R2T4’s and counting days. This process was done manually allowing for marginal errors. Currently we have moved the process to be calculated automatically within our financial aid system which will reduce the margin of errors immensely and dates would be calculated correctly. This too will be affected by the revision of the new attendance policy. Responsible Party and contact information: Valerie Souza, FA Business Systems Analyst and Daisy Tabachow, Director of Financial Aid. Expected Date of Correction: The process has been instituted and has gone into effect immediately.

2024-002 – Return of Title IV Funds (Significant Deficiency) Department of Education, SFA Cluster, Special Tests and Provisions Criteria: Return of Title IV funds are required to be deposited or transferred into the SFA account or electronic fund transfers initiated to the department of Education as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew in accordance with 34 CFR Section 668.173(b). Condition: From a population of 130 students that officially or unofficially withdrew during the term, we tested 15 students and noted that four students required refund calculations. Funds were returned more than 45 days after the date of determination for all students that required refunds. Cause: Controls are not functioning properly to ensure timely return. Effect: Funds were not timely returned to students or the Department of Education as required. Recommendation: We recommend procedures are put in place to ensure R2T4 calculations are performed timely following the University’s date of determination.Action Taken: Due to a significant change/shortage in staff some R2T4’s were not calculated in a timely manner, however we are currently running the report biweekly avoiding delays in the return of Title IV funds. Reminders are placed on calendars. Attendance policy is undergoing a revision to allow for more consistent totals when calculating the number of days. In addition the process has been automated in Financial Aid software so it will no longer be a manual calculation. Responsible Party and contact information: Lynda Swanson, Asst. Director of Financial Aid, Valerie Souza, FA Business Systems Analyst, and Daisy Tabachow, Director of Financial Aid. Expected Date of Correction: Trimester reconciliation-completion date-end of fiscal year.

Improve budget monitoring and reporting accuracy for grant funds. Ensure district records reflect amounts available for expenditure. Effective July 1, 2025, the district will be implementing LINQ, a web-based financial and human resources management system.

Corrective Actions: The Financial Aid Supervisor will check the monthly V4/V5 report to ensure timely submission. However, according to the May 23, 2024, Electronic Announcement (GENERAL-24-63), the V4/V5 reporting deadlines are impacted by 2024-25 FAFSA processing and FAFSA Partner Portal (FPP) functionality delays. Personnel Responsible for Implementation: Ludwig Perez, Financial Aid Manager, Los Angeles Harbor College Marisol Velazquez, Financial Aid Manager, Los Angeles Technical Trade College Vernon Bridges, Financial Aid Manager, Los Angeles Valley College Expected Date of Implementation: When FPP becomes available

Corrective Actions: A. Perform Timely Access Revocation and Strengthen User Access Reviews ‐ The District implemented a new automated solution to terminate SSO and PS SIS access. This was implemented October 2024. ‐ The District’s plan is, upon implementation of the automated solution to deprovision SSO and PS SIS access, our team is planning on performing annual user access for SSO and PS SIS reviews beginning Q1 2025. The District is also implementing Pathlock that will introduce user access reviews. ‐ For SAP access revocation the SAP Team is looking into options to deprovision users and audit user access through internal or third-party tools. The District anticipates selection of the tools by June 30, 2025. Upon implementation of the selected SAP tools the District will perform periodic access reviews for regular users. Personnel responsible for Implementation: Carmen V. Lidz, Vice Chancellor & Chief Information Office Expected Date of Implementation: June 30, 2025 B. Maintain and Review Logs of Users' Activity for both SAP and PS SIS ‐ Upon implementation of Pathlock, the District will perform periodic access reviews for regular users. ‐ Upon implementation of the selected SAP tools, the District will perform periodic access reviews for regular users. Personnel responsible for Implementation: Carmen V. Lidz, Vice Chancellor & Chief Information Office Expected Date of Implementation: June 30, 2025 C. Implement Data-at-Rest encryption for SAP and PS SIS Servers ‐ The District is in the process of upgrading PS SIS PeopleTools after which we will determine the most expedient path to implementing database encryption. The target completion for the PS SIS database encryption is Q3 of 2025 ‐ The District is currently evaluating the feasibility of adding the encryption of the SAP database to the HANA upgrade project. If the District determines that it’s not feasible, we will engage a third party to encrypt the SAP database. The target completion for the SAP database encryption is Q3 of 2025. Personnel responsible for Implementation: Carmen V. Lidz, Vice Chancellor & Chief Information Office Expected Date of Implementation: Q3 of 2025

Corrective Actions: A. Incorrect Calculation of Return of Title IV Funds Los Angeles Harbor College The District’s Central Financial Aid Unit (CFAU) R2T4 Unit centralized the R2T4 process at all nine colleges during the 2023-24 aid year. CFAU is currently processing R2T4 calculations for Los Angeles Harbor College. Personnel Responsible for Implementation: Ludwig Perez, Financial Aid Manager, Los Angeles Harbor College Steve Giorgi, Financial Aid Manager, Central Financial Aid Unit Expected Date of Implementation: Already Implemented B. Distance Education (DE) Courses – Implementation of Formal Process to Determine Accuracy of Student Withdrawal Date – Partial Implementation of Prior Year Corrective Action Plan (CAP) EPIE will share the most recent annual internal audit review with each college team and require each college to develop a corrective action plan. EPIE will submit a request to add a pop-up message to the faculty roster directly tied to completion of the mandatory exclusion roster (census roster), supplemental roster, and active enrollment roster. The pop-up message will continue to be displayed until the faculty member successfully submits their roster. EPIE will work with the distance education (DE) faculty coordinators to create professional development training geared toward using Canvas to determine an online student’s last date of academic engagement and will offer the training annually. Additionally, EPIE will conduct training for administrators on the use of queries to monitor pending rosters. Personnel Responsible for Implementation: Nicole Albo-Lopez, Vice Chancellor, EPIE Expected Date of Implementation: June 30, 2025

Corrective Action: The District’s Educational Programs & Institutional Effectiveness (EPIE) and Information Technology (IT) divisions will analyze the current programming and test cases and develop programming to correct the misalignment of the student status effective date reported to the NSC and student status date in PeopleSoft. EPIE will continue to monitor post-submission errors and warning reports to review the effectiveness of the programming change. Personnel Responsible for Implementation: Maury Pearl, Associate Vice Chancellor Andrew Alvarez, IT Business Analyst Stan Levin, Senior Research Analyst Expected Date of Implementation: March 31, 2025

Audit Firm: RSM US LLP 30 S Wacker Drive, Suite 3300 Chicago, IL 60606 Audit Period: 1/1/2024 – 12/31/2024 Comments on Findings and Recommendations: Finding 2024-002 – Eligibility - Pell Finding: Herzing University did not properly award Pell funding to an eligible student in the Spring 2024 semester. Condition: A student was eligible to receive Pell funding but did not receive Pell funds due to an employee error. For one out of 40 students tested for eligibility, we noted 1 student (2.5%) who was eligible to receive Pell funding but did not receive Pell funds due to an employee error. Action Taken: The identified student withdrew from the University on May 8, 2023. The student’s 2023-24 Pell award was cancelled during the required R2T4 process that was completed on May 23, 2023. The 2023-24 Pell award for the Spring 2024 semester was not manually reinstated upon the student’s return to an Active status on June 28, 2023. The employee who was responsible for updating the student’s financial aid package upon the student’s return to an Active status erroneously neglected to reinstate the 2023-24 Pell award for the Spring 2024 semester. This finding is attributed to human error. In April 2025, Herzing University created an internal compliance checkpoint for Pell awarding. This checkpoint will identify any students with a Pell eligible SAI for the Federal Award year that do not have Pell packaged for the semester. This checkpoint was completed for the Spring 2025 semester on April 7, 2025, and will be completed each semester going forward. Any affected students identified during the completion of this semester-based checkpoint will have their financial aid package revised to include Pell funding for the applicable semester, prior to the end of the semester. Herzing University’s Policy Manual was updated in April 2025 to reflect the addition of the Pell Awarding compliance checkpoint. For the identified student, Herzing University has provided a tuition waiver for the amount of the Pell funds that the student was eligible for and should have received for the Spring 2024 semester. The required corrective action for Finding 2024-002 listed in the SFA audit for the period 1/1/2024 – 12/31/2024 was completed on 5/7/2025. The person responsible for completion of the corrective action was Kevin McShane, Vice President of Financial Aid & Compliance. ____________________________________ _______________________ Kevin McShane Date Vice President of Financial Aid & Compliance Herzing University 275 W. Wisconsin Ave., Ste. 210, Milwaukee, WI 53203 Email Address: kmcshane@herzing.edu

Audit Firm: RSM US LLP 30 S Wacker Drive, Suite 3300 Chicago, IL 60606 Audit Period: 1/1/2024 – 12/31/2024 Comments on Findings and Recommendations: Finding 2024-001 – Eligibility - SEOG Finding: Herzing University did not properly award SEOG funding to an eligible student in the Fall 2024 semester. Condition: A student was eligible to receive SEOG funding but did not receive SEOG funds due to an employee error. For one out of 40 students tested for eligibility, we noted 1 student (2.5%) who was eligible to receive SEOG funding but did not receive SEOG funds due to an employee error. Action Taken: On May 1, 2024, a Financial Aid Advisor manually cancelled the identified student’s 2024-25 SEOG award in Regent (Herzing University’s Financial Aid Management Software), with a notation that the student had an ineligible Student Aid Index (SAI). The student had an SAI of -117 on their 2024-25 ISIR, and in accordance with Herzing University’s FSEOG policy were eligible for 2024-25 SEOG in the Fall 2024 semester. The award was incorrectly manually canceled by the advisor because of human error. In April 2025, Herzing University created an internal compliance checkpoint for FSEOG awarding. This checkpoint will serve as a safety net to identify any students who have a Pell award for the Federal Award year, have an SAI that is FSEOG eligible according to Herzing University’s FSEOG policy, and do not correctly have FSEOG packaged for the semester. Any affected students identified during the completion of this semester-based checkpoint will have their financial aid package reviewed and if necessary revised to include FSEOG funding for the applicable semester, prior to the end of the semester. This checkpoint was completed for the Spring 2025 semester on April 4, 2025, and will be completed each semester going forward. Herzing University’s Policy Manual was updated in April 2025 to reflect the addition of the FSEOG Awarding compliance checkpoint. For the identified student, Herzing University has provided a tuition waiver for the amount of the FSEOG funds that the student was eligible for and should have received for the Fall 2024 semester. The required corrective action for Finding 2024-001 listed in the SFA audit for the period 1/1/2024 – 12/31/2024 was completed on 5/7/2025. The person responsible for completion of the corrective action was Kevin McShane, Vice President of Financial Aid & Compliance. ____________________________________ _______________________ Kevin McShane Date Vice President of Financial Aid & Compliance Herzing University 275 W. Wisconsin Ave., Ste. 210, Milwaukee, WI 53203 Email Address: kmcshane@herzing.edu