Corrective Action Plans

Finding 2024-002: Common Origination and Disbursement (COD) Reporting Cluster Name: Student Financial Assistance Federal Awarding Agency: Department of Education Award Name: Federal Pell Grant Program, Federal Direct Loans Award Number: Various Award Year: 10/1/2023-9/30/2024 Assistance Listing Title: Federal Pell Grant Program, Federal Direct Student Loans Assistance Listing Number: 84.063, 84.268 Pass-Through Entities: Not applicable As described in finding 2024-002, 1 of the 25 selections was not reported to the COD system within 15 calendar days of the disbursement to the student. The noted disbursement was reported 5 calendar days late. Caltech confirmed it had additional instances of late reporting beyond the audit selection. To address this finding, Caltech created a Disbursement Checklist to ensure that all steps in the process are followed, including generating common record files of disbursement information and transmitting those files to COD the same day as the funds are disbursed to the student accounts. The checklist was created in May 2025. Malina Chang, Director, Financial Aid Office, is responsible for this corrective action plan. Caltech also performs Pell monthly reconciliations to capture discrepancies between internal information and that which is reported by COD. Any discrepancies are investigated via this monthly reconciliation process, and errors are corrected. In addition, Caltech requests Pell funds from the Department of Education on a quarterly basis (quarterly EDCAPS draws), significantly reducing the risk of the Institute needing to return funds.

Finding 2024-001: E-Sign Act Cluster Name: Student Financial Assistance Federal Awarding Agency: Department of Education Award Name: Federal Supplemental Educational Opportunity Grant, Federal Work Study Program, Federal Pell Grant Program, Federal Perkins Loan, Federal Direct Loans Award Number: Various Award Year: 10/1/2023-9/30/2024 Assistance Listing Title: Federal Supplemental Educational Opportunity Grants, Federal Work-Study Program, Federal Pell Grant Program, Federal Perkins Loan Program, Federal Direct Student Loans Assistance Listing Number: 84.007, 84.033, 84.063, 84.038, 84.268 Pass-Through Entities: Not applicable As described in finding 2024-001, in examining 25 student records, a statement prompting voluntarily consent to participate in electronic transactions was not included in the list of terms and conditions. To address this finding, in March 2025, Caltech revised the Financial Aid Terms and Conditions, found under the student portal, which students must agree to before accepting their financial aid, to include language about voluntarily consenting to participate in electronic transactions. Malina Chang, Director, Financial Aid Office, is responsible for this corrective action plan.

2024-002 • Material Weakness in Internal Control over Compliance Condition: During our eligibility assessment, we examined 40 files from Community Umbrella Agency 3 (CUA) foster care children to ensure they contained required documents by the City of Philadelphia and Pennsylvania's Department of Human Services (DHS). Our review found missing documents, time gaps between submissions, or untimely paperwork, including the following: (a) 29 CUA Safety Assessments, (b) 30 CUA Safety Plans, (c) 7 CUA PA Model Risk Assessments, (d) 3 CUA Documented Client Visits (Structure Case Notes), (e) FAST Family Advocacy Forms, (f) 17 Life Skills Assessment/ Biopsychosocial Evaluation/ IEP or Ages & Stages Questionnaire (ASQ), (g) 11 School Aged Report Cards, (h) 6 CUA Authorization to Release Information, (i) 9 CUA Immunizations, (j) 3 DHS Court Order Sheets, (k) 14 Child’s Photo, (l) 10 Initial CUA Single Case Plan, (m) 7 Monthly Updates to CUA Single Case Plan, (n) 17 Initial CUA Case Service Conference Summary Report, and (o) 16 Six Month Ongoing CUA Services Conference Summary Report. Furthermore, each child's file needed to contain specific documents from the DHS, which had to be supplied by the department or shown evidence of request by the CUA. Missing documents consisted of: (a) 34 DHS Service Authorization Forms, (b) 21 DHS CUA Provider Referral Forms, and (c) 30 DHS CUA In-Home Services Referral Forms. Recommendation: We recommend that management continue to develop policies and procedures in order to properly include all pertinent documentation within each client file as required by the City of Philadelphia, Department of Human Services. In addition, we recommend that program leadership and/or quality control department performs periodic audits of the client files to ensure all required documentation is included. Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. FINDINGS – FEDERAL AWARD PROGRAM AUDITS (CONTINUED) Action taken in response to finding: 1. Hiring of Chief Compliance Officer to oversee Concilio Quality Assurance and Compliance process 2. Staffing of Quality Assurance department 3. Monthly review of client files for accuracy and completeness 4. Additional training of staff to review audit findings and implement corrective action Name of the contact person responsible for corrective action: Albert Essilfie, Chief Financial Officer albert.essilfie@elconcilio.net (215) 627-3100 Planned completion date for corrective action plan: June 30, 2025

Management’s Response: The University has undertaken several initiatives to enhance compliance and accuracy: (1) Collaboration with External Financial Aid Experts a. In 2025, the University engaged an external financial aid contractor to optimize system usage within its database, ensuring more accurate and timely reporting. (2) Appointment of a New Financial Aid Director a. A new Financial Aid Director has been hired, commencing their role on March 1, 2025. This leadership is expected to prioritize and address the issues identified in the audit finding. (3) Process Enhancement and Staff Training a. A comprehensive assessment of current enrollment reporting procedures has been conducted to identify and rectify gaps. b. Staff members in the Registrar’s Office have undergone targeted training to ensure accurate and timely updates to the National Student Loan Data System (NSLDS). (4) Policy and Procedure Development a. New policies and procedures have been established to verify that correct effective dates and status changes are reported to NSLDS within the required timeframes. b. Regular audits and reviews are now in place to ensure ongoing compliance and to promptly address any discrepancies. These initiatives demonstrate the University’s commitment to maintaining accurate student enrollment records and ensuring compliance with federal regulations, thereby safeguarding the interests of its students and the institution.

1. Strengthening Timely Submission of Enrollment Reporting Rosters  The Institution will implement a structured tracking system to monitor all incoming enrollment roster files and ensure timely response within the required 15-day period.  A compliance calendar with automated reminders will be established to notify financial aid staff of upcoming roster submission deadlines and the 10-day correction requirement. 2. Designating Accountability & Oversight  A dedicated staff member within the financial aid office will be assigned sole responsibility for monitoring, reviewing, and submitting NSLDS enrollment rosters.  A dual-verification process will be introduced, where a second staff member will confirm that roster files are submitted on time and corrections are made within the 10-day resubmission window. 3. Enhancing Training & Compliance Awareness  Financial aid personnel will undergo training on NSLDS enrollment reporting procedures, including: a) The importance of timely enrollment certification and reporting compliance. b) How to efficiently process and submit enrollment roster files via SAIG and the NSLDS website. c) Best practices for reviewing, correcting, and resubmitting enrollment records within the required 10-day correction window.  Staff will participate in annual refresher training to stay updated on any regulatory changes and process improvements. 4. Internal Audits & Process Improvements  The Institution will conduct quarterly internal audits of NSLDS enrollment reporting to ensure compliance with submission timelines.  A compliance checklist will be developed to ensure that each roster file is reviewed, corrected, and resubmitted within the 10-day requirement.  A monthly reconciliation process will be introduced to cross-check institutional records against NSLDS enrollment reporting to identify and correct discrepancies proactively. Personnel Responsible for Implementation: Danielle Skinner Position of Responsible Personnel: President Expected Date of Implementation: Immediate

1. Corrections to NSLDS Program-Level and Campus-Level Data Reporting: The Institution has conducted a full review of its NSLDS records and is correcting all program-level data discrepancies, including the published program length for the Machine Tool Technology/Machinist program. We are updating the "Weeks in Title IV Academic Year" field to ensure that NSLDS correctly calculates program length. A dedicated NSLDS Compliance Checklist will be implemented to ensure that all program-level and campus-level data is aligned with institutional records before submission. 2. Strengthening Accuracy in Campus-Level Enrollment Reporting: A mandatory second-level review process will be implemented for all graduation and withdrawal status updates to prevent misreported enrollment dates or statuses. NSLDS data will be cross-checked monthly against the Institution’s internal student records to proactively detect and correct any discrepancies. 3. Improving Timeliness in Certification of Enrollment Status: The Institution will implement a structured 60-day certification schedule to ensure that all enrollment changes are reported to NSLDS within federal timeframes. A compliance tracking system will be introduced to flag students requiring enrollment status updates, allowing for proactive monitoring and timely submission 4. Staff Training and Process Improvement: The Institution will train financial aid and student records personnel on NSLDS reporting standards, including: a) Accurate program length calculations and Title IV academic year reporting. b) Timely certification of enrollment changes to remain within the 60-day requirement. c) Common reporting errors and best practices for NSLDS data management. Annual refresher training sessions will be held to ensure staff remain up to date on NSLDS reporting regulations and procedural improvements. 5. Internal Compliance Monitoring & Quality Assurance: A quarterly audit of NSLDS reporting will be conducted by a designated compliance officer to identify and correct discrepancies before regulatory deadlines. The Institution will establish internal controls and reporting checklists to ensure consistency, accuracy, and compliance with federal requirements. Personnel Responsible for Implementation: Danielle Skinner Position of Responsible Personnel: President Expected Date of Implementation: Immediate

To ensure full compliance with Title IV R2T4 requirements, the Institution is implementing the following corrective actions: 1. Process Improvements for Accurate R2T4 Calculations  The Institution will implement a dual-verification review process to ensure all R2T4 calculations are accurate before funds are returned.  A dedicated compliance review team member will oversee the manual entry of student withdrawal dates and enrollment period calculations to prevent miscalculations.  The Institution will utilize automated tools within Jenzabar Financial Aid (our Student Management System) to improve accuracy in calculating earned vs. unearned Title IV aid.  A preliminary audit of student accounts will be conducted before R2T4 calculations are finalized to catch errors before submission. 2. Strengthening Internal Controls & Timely Fund Returns  A tracking system will be implemented to flag all students requiring R2T4 processing, ensuring that returns are initiated and completed within the required 45-day period.  The Institution will conduct weekly internal reconciliation reviews of withdrawal records to verify compliance with notification and return due date requirements.  The financial aid office and student accounts team will coordinate weekly reconciliation meetings to monitor all outstanding Title IV returns. 3. Enhanced Staff Training on R2T4 Compliance  Specialized training will be provided to financial aid personnel on: a) Accurate calculation methodologies for R2T4, including proper determination of payment period percentage completion. b) Compliance with 34 CFR 668.22 and 668.173(b) regarding timely notification and return of unearned funds. c) Utilizing internal checklists and reconciliation tools to prevent future miscalculations or delays.  Staff will undergo mandatory annual compliance refresher training to stay current with federal regulations and best practices. 4. Strengthening Documentation & Compliance Monitoring  The Institution will implement a comprehensive R2T4 compliance checklist to ensure: a) All Title IV returns are properly calculated and reviewed. b) The correct withdrawal dates and enrollment period lengths are recorded. c) All funds are returned within the regulatory 45-day window.  A quarterly audit of all R2T4 transactions will be conducted by a designated compliance officer to assess and report on adherence to federal requirements. Personnel Responsible for Implementation: Danielle Skinner Position of Responsible Personnel: President Expected Date of Implementation: Immediate

To ensure full compliance with Title IV regulations, the Institution is implementing the followingcorrective actions: 1. Enhanced Monitoring & Timely Processing of Credit Balances: The Institution will implement a weekly review process to identify and track all student accounts with credit balances. This will ensure that any resulting credit balance is disbursed within the required 14-day timeframe. A dedicated staff member will be assigned to monitor and track credit balances to prevent delays. 2. Strengthening Internal Controls & Oversight: A Title IV Compliance Checklist will be developed to ensure that every step in the credit balance disbursement process is completed on time. Dualreview procedures will be implemented, requiring an additional financial aid staff member to verify that all credit balances are disbursed within the required timeframe 3. Student Authorization Procedures: The Institution will update its financial aid policies to include voluntary credit balance authorization forms for students who wish to allow the Institution to retain excess funds beyond the required period. All students receiving Title IV funds will be provided with the option to complete and submit an authorization form at the time of enrollment 4. Staff Training & Compliance Awareness: Financial aid and student accounts personnel will undergo annual training on Title IV credit balance requirements, disbursement procedures, and compliance deadlines. Staff will be trained on the importance of proactive monitoring and timely disbursements to prevent future delays. Personnel Responsible for Implementation: Danielle Skinner Position of Responsible Personnel: President Expected Date of Implementation: Immediate

University awarded Subsidized Federal Direct Loans to one student in excess of their Subsidized Federal Direct Loan eligibility, and therefore did not comply with all requirements associated with excess loan proceeds. Corrective Actions Taken or Planned: This finding is considered an isolated occurrence and is not indicative of Roosevelt University’s standard administrative practices or institutional policies. The University has taken the following corrective actions to address the issue and prevent recurrence Student Account Adjustment: A reallocation of $2,900 from the Federal Direct Subsidized Loan to the Federal Direct Unsubsidized Loan was completed to correct the student’s account. All necessary updates were submitted to the U.S. Department of Education on May 16, 2025. Root Cause Analysis and System Improvements: The University will conduct a thorough root cause analysis to determine the underlying factors that led to the overaward. This analysis will be completed within 30 days. Preventative Measure and On-going Monitoring: Based upon the outcome of the root cause analysis, Roosevelt will implement appropriate system controls and develop an on-going monitoring plan to prevent similar issues in the future. These preventative measures will be established within 45 days. Roosevelt University remains committed to maintaining compliance with federal regulations and to continuously strengthening its internal controls to ensure accurate administration of Title IV funds. Anticipated Completion Date: July 15, 2025 Contact Person: Michelle Hayes, Senior Director, Financial Aid and Compliance // Michelle Stipp, Associate Vice President, Enrollment Management

Finding 2024-002 – Special Tests and Provisions – Enrollment Reporting Name of contact person responsible for corrective action: Tara Kent tara.kent@wagner.edu 718-390-3121 Corrective action: The College has made great strides in working through its historical data to correct and update students’ program begin dates. There has been significant improvement in the accuracy of this data being reported to the NSLDS, and we expect final completion of this manual process during the College’s next fiscal year. The College also recognizes the importance of reporting all enrollment changes timely to the NSLDS. In order to address the cause of the late enrollment reporting finding, the College has now implemented a process of reporting to the National Student Clearinghouse every 45 days, to ensure that the 60-day timeframe required by the ED is always met. Proposed Completion Date: August 2026 (Item 1) and August 2025 (Item 2)

– Enrollment Reporting Cluster: Student Financial Assistance Sponsoring Agency: Department of Education Award Name: Pell Grant Program and Federal Direct Student Loans Award Number: Various Assistance Listing Title: Federal Pell Grant Program and Federal Direct Student Loans Assistance Listing Number: 84.033 and 84.268 Award Year: 2023-2024 Pass-through entity: Not applicable Stanford agrees with this finding and will be taking proactive steps to ensure that similar issues do not arise in the future. For the issue affecting 6 out of 25 students, whose status change effective dates did not match their program level information, the Academic Records and Compliance Officer will work closely with systems staff to perform tests to identify a cause and ensure accuracy between the enrollment file extract and records themselves. Expected completion by December 31, 2025. For the issue affecting 2 out of 25 students, whose graduated status was not accurately reflected in their enrollment history, the Academic Records and Compliance Officer is leading a system enhancement currently in progress to replace the ‘G from DV’ file to a ‘Grads Only’ file to report degrees, which is expected to be completed by December 31, 2025. The new and improved file type will ensure the third-party servicer applies graduated statuses for students enrolled in multiple programs. Until the system enhancement is completed, the Academic Records and Compliance Officer will begin carefully reviewing ‘G Not Applied’ error files for manual correction after degrees are reported at the end of each quarter.

Verification status code within the Common Origination and Disbursement System Cluster: Student Financial Assistance Sponsoring Agency: Department of Education Award Name: Pell Grant Program Award Number: Various Assistance Listing Title: Federal Pell Grant Program Assistance Listing Number: 84.033 Award Year: 2023-2024 Pass-through entity: Not applicable Stanford agrees with this finding and will take steps to prevent these types of errors from happening in the future. Specifically regarding the case of the applicant for whom verification was not completed until after federal aid funds had been disbursed, the Director of Compliance and Technology in the Central Financial Aid Office has adjusted the existing report of verification selections to include students from the three professional schools, as of January 01, 2025, and will work closely with the financial aid offices of each professional school to ensure that selected applicants are verified prior to disbursement of federal aid funds. This communication will be ongoing and occur quarterly at a minimum. Regarding the issue of verification status codes not being updated correctly, the Central Financial Aid office has made two enhancements to our procedures in an effort to avoid future errors: • First, the Director of Compliance and Technology will emphasize to aid application reviewers the importance of correctly setting the verification field values in the PeopleSoft system as part of annual training, which occurs at the beginning of each academic year cycle typically in November, and when new team members arrive. The status of these values will be monitored throughout the year using a database query beginning May 01, 2025 and ongoing on a monthly basis. • Second, the Assistant Director of Technology will regularly request and review a report from the federal Common Origination & Disbursement (COD) system that shows the verification status codes for all selected applicants, to ensure that the codes in the COD system accurately reflect the verification status of aid recipients on a monthly basis beginning on May 01, 2025. We will also double-check the values in all COD records as part of the year-end reconciliation process at the end of each award year, typically in September.Verification status code within the Common Origination and Disbursement System Cluster: Student Financial Assistance Sponsoring Agency: Department of Education Award Name: Pell Grant Program Award Number: Various Assistance Listing Title: Federal Pell Grant Program Assistance Listing Number: 84.033 Award Year: 2023-2024 Pass-through entity: Not applicable Stanford agrees with this finding and will take steps to prevent these types of errors from happening in the future. Specifically regarding the case of the applicant for whom verification was not completed until after federal aid funds had been disbursed, the Director of Compliance and Technology in the Central Financial Aid Office has adjusted the existing report of verification selections to include students from the three professional schools, as of January 01, 2025, and will work closely with the financial aid offices of each professional school to ensure that selected applicants are verified prior to disbursement of federal aid funds. This communication will be ongoing and occur quarterly at a minimum. Regarding the issue of verification status codes not being updated correctly, the Central Financial Aid office has made two enhancements to our procedures in an effort to avoid future errors: • First, the Director of Compliance and Technology will emphasize to aid application reviewers the importance of correctly setting the verification field values in the PeopleSoft system as part of annual training, which occurs at the beginning of each academic year cycle typically in November, and when new team members arrive. The status of these values will be monitored throughout the year using a database query beginning May 01, 2025 and ongoing on a monthly basis. • Second, the Assistant Director of Technology will regularly request and review a report from the federal Common Origination & Disbursement (COD) system that shows the verification status codes for all selected applicants, to ensure that the codes in the COD system accurately reflect the verification status of aid recipients on a monthly basis beginning on May 01, 2025. We will also double-check the values in all COD records as part of the year-end reconciliation process at the end of each award year, typically in September.

Corrective Action Plan: The identified conditions relate to students who experienced a change in status code within the Union College system. This report will be reconciled with student status changes transmitted by the National Student Clearinghouse (NSC) to the National Student Loan Database System (NSLDS), and any necessary corrections will be made immediately. Timeline for Implementation of Corrective Action Plan: These corrective actions are being implemented in Spring 2025.

2024-002 Special Tests (Enrollment Reporting) Student Financial Assistance Cluster: U.S. Department of Education Federal Direct Student Loans (ALN 84.268) Federal Grant Numbers and Years: P268K240460 (9/1/2023-8/31/2024) Finding Type: Significant Deficiency and Noncompliance Responsible personnel: Christopher Nieves, Registrar, ctn2114@tc.columbia.edu, 212 678-4056 Corrective Action Plan: The College identified that the periodic degree record submission process to the Clearinghouse was not fully and accurately updating a student’s status at NSLDS from the prior status to Graduated. These students were not included on the Clearinghouse standard error resolution reports for review and timely correction by the College and therefore, the student status change(s) will also reflect a late certification. The Office of the Registrar consulted with the Clearinghouse which identified a universal limitation with the DegreeVerify service. Despite the College’s accurate and timely submission of degree conferral data, the process did not apply a Graduated enrollment status for students awarded multiple and similar level degrees and/or for students who have multiple enrollment records for more than one academic program. To address this issue, and with the Clearinghouse’s guidance, a manual correction process for the student population was implemented and is available through a separate section on their dashboard. Designated staff in the Registrar’s Office initiated enrollment history corrections through this process. As DegreeVerify reporting is conducted on a monthly basis by the College, manual corrections will also be processed monthly aligning with the submission schedule. Any necessary corrections will be completed directly following the Clearinghouse’s confirmation that the latest report has posted to the dashboard. This will ensure that all graduation statuses will be accurately and timely reflected and consistent across the College’s records and Campus and Program-Level records in NSLDS going forward. Additionally, while graduated status was not timely applied for these students, withdrawal status records were reported and available within the allowable grace period resulting in proper timing for entering federal loan repayment status.

2024-001 Reporting (Financial) Student Financial Assistance Cluster: U.S. Department of Education Federal Direct Student Loans (ALN 84.268) Federal Grant Numbers and Years: P268K240460, (9/1/2023-8/31/2024) Finding Type: Material Weakness and Noncompliance Responsible personnel: Alyssa Timko, Director of Financial Aid, act2156@tc.columbia.edu, 212 678-3654 Corrective Action Plan: In September 2023, the College identified a technical issue with the manual reporting process for student loan disbursements to COD and determined the existing solution was only partially functioning at that time. While some loan activity was timely and properly reported to COD, other student disbursement transactions were stalled and reported after the 15-calendar day requirement. At that time, the College’s ERP, Banner, job submission process for disbursement reporting to COD was manually initiated by the Office of Financial Aid. The resulting reports were then uploaded through the DOE’s EDconnect, a Windows based software application, using WinSCP file transfer (the same process was used for return files from COD). After an evaluation, it was determined that a new solution and process was required to ensure proper, complete and timely reporting under the regulations. The reporting process was redesigned in October 2023 as part of a plan to automate loan origination and now functions through Automic, a workload automation software. Instead of manually generated files and upload / receipt through EDconnect, student loan disbursement records are now automated to/from COD using TDClient, which is a command software for sending and receiving student aid related information through the DOE’s Student Aid Internet Gateway (SAIG). The new process regularly transfers loan disbursement data to COD. However, the College also determined that a prescheduled pause in the Automic loan origination process at the end of the fiscal year 2024 academic year (in August 2024), which was established in accordance with the regulations, also inadvertently paused loan disbursement reporting and resulted in late submissions. The Office of Financial Aid has also remedied this issue by adding non-standard reporting days to the standard calendar. Along with more frequent and recurring reconciliations of Banner to COD loan disbursement data and ensuring the continuation of disbursement reporting after loan originations are paused at the end the academic year, the College does not anticipate any further late reporting matters and expects all future disbursement data to be reported within 15 calendar days.

Point Park University submits the following corrective action plan for the year ended August 31, 2024. Finding 2024-001 - Enrollment Reporting Management Response: Management concurs with the finding Views of Responsible Officials and Corrective Action Plan: Point Park University uses the National Student Clearinghouse (NSC) to transmit enrollment information to the National Student Loan Data System (NSLDS). The University determined that students reported with incorrect status’s, students reported late, and students not reported; were due to incorrect formatting on an internally generated system report causing the status information to be incorrect. In addition, a final review of the information submitted to the NSC and the NSLDS did not take place. The following procedures have been implemented to ensure accurate reporting in the future. The internally generated report submitted to the NSC was modified to properly include all students enrolled and to correct all formatting errors which affected the student enrollment status. Once the report is submitted to the NSC, the Registrar will verify the total required enrolled students agrees with the total number of students received by the NSC. The Registrar will then correct any errors the NSC reports back to Point Park before submission to the NSLDS. After every submission, the Registrar performs a sample audit from Point Park’s system information and compares it to both the final information submitted to both the NSC and the NSLDS to make any final necessary corrections. The audit procedure is verified by management. Anticipated Completion Date: April 15, 2025 Name of Responsible Person: George Santucci, Director of Financial Aid

CORRECTIVE ACTION PLAN: Staff transitions in Financial Aid and the Enrollment Center at the onset of the Fall 2023 term contributed to the later-than-usual submission/certification of First of Term enrollment reporting. Financial Aid and the Enrollment Center experienced staff shortages with resignations and leave. The initial fall enrollment (First of Term) was certified by the Institution and submitted to the National Student Clearinghouse (NSC) on October 18, 2024 within 60 days of the start of the term on August 21, 2023, but the National Student Loan Data Systems (NSLDS) did not receive the submission within the 60-day requirement. Although we anticipate this to be a one-time incident, to prevent any recurrence and ensure enrollment changes are reported to NSLDS within 60 days, Financial Aid provided additional staff training in the Enrollment Submission process, and Early Registration enrollment submissions will be submitted within the first week of classes with the First of Term enrollment submission sent during the third week of classes. Financial Aid also updated the Institution’s NSLDS profile to ensure that records submitted for NSLDS Transfer Monitoring and Financial Aid History are added to the Enrollment Roster submitted to NSC. Financial Aid and the Registrar established an updated policy to ensure that Financial Aid is informed of students who graduate after the graduation process runs each term. After that, the Registrar will report late graduations to the National Student Loan Data System (NSLDS) via the National Student Clearinghouse (NSC). Financial Aid updated the student in question’s graduation status in NSLDS. Person(s) Responsible: Angela Weaver Timing for Implementation: Immediate

CORRECTIVE ACTION PLAN: At Lewis & Clark, the Direct Loan acceptance process switched from affirmative confirmation to passive confirmation to streamline the student loan process for students. For loans accepted via affirmative confirmation, the loan notification must be sent no earlier than 30 days before and no later than 30 days after crediting the student’s account. The student or parent has 14 days from the notification date to request the loan cancellation. For loans accepted via passive confirmation, the loan disbursement notification must be sent no earlier than 30 days before or 7 days after crediting the student’s account. The student or parent then has 30 days from the date of the notification to request cancellation of the loan. Although the new timeline for a student to cancel a loan was reviewed prior to the process change to passive confirmation, Financial Aid neglected to update the notification letter at the time of implementation. The loan notifications now reflect the 30 days for loan cancellation. Cancellation requests of loan funds are processed promptly. Although the timeline to request a cancellation of all or a portion of a loan previously indicated a 14-day deadline, the Financial Aid office accepts most requests beyond the 14 to 30 days. However unlikely, if more than 120 days have elapsed since loan funds were disbursed, loan funds cannot be returned on the borrower’s behalf. In Spring 2024, Financial Aid established a process to send loan notifications in conjunction with weekly financial aid transmittals to ensure compliance with sending loan notifications within 7 days of crediting a student’s account. A Direct Loan transmittal report (TFAR-Transmitted FA Report) is generated through Colleague (ERP Software) weekly throughout each term, and loan notifications are emailed weekly to students whose student loans are credited to their accounts during that weekly process. To prevent Post-withdrawal disbursements of loan funds from updating and transmitting to student accounts before receipt of acceptance of post-withdrawal disbursements (PWD), upon completion of the Return of Federal Funds calculation, Financial Aid will delay updating student accounts until confirmation of acceptance within the established 14-day timeframe; this is a change from the previous practice of updating the student record and then denying the PWD until acceptance of loan funds. Person(s) Responsible: Angela Weaver Timing for Implementation: Immediate

Corrective Action Plan Emory University Office of Financial Aid Prepared by John Leach, Assoc Ve Prov/Dir, Univ Fin Aid, Office of Financial Aid Federal Program: Federal Direct Student Loans (ALN 84.268} CFR 200.303/685.300(b)(S0) Federal Award Year: September 1, 2023 to August 31, 2024 Federal Agency: U.S. Department of Education Finding 2024-001: Cash Management The reconciliation between ED's records (School Account Statements) and the school's financial and business records were prepared timely throughout the year; however, the differences identified in the reconciliation were not accounted for and no review or segregation of duties was documented as part of that process. Management Response and Corrective Action Plan: The finding was primarily caused by an unforeseen staff shortage. This led to one person being the preparer and reviewer with no segregation of duties. Although the differences were identified, they were not documented on the reconciliation form. To resolve this finding, the Office of Financial Aid {OFA) has hired new employees and implemented a new process. The Financial Operations Team is now fully staffed with two senior accountants and one senior director. As part of our ongoing efforts to strengthen internal controls and ensure the integrity of our processes, we have implemented a segregation of duties framework. This approach will help us clearly define roles and responsibilities, ensuring that critical tasks are divided among different individuals. By doing so, we will meet compliance requirements, reduce errors, and promote accountability within our office. One senior accountant will prepare the monthly reconciliation by the 10th of the following month. The senior director will review the monthly reconciliation by the 15th of the following month. In the absence of the initial preparer/reviewer, the executive director of OFA will take on the reviewer role. We understand that proper documentation is crucial for clarity, tracking, and future troubleshooting. The differences/discrepancies that are identified in the reconciliation process will be accounted for through proper documentation on the reconciliation form, which will be reviewed/investigated by a second reviewer. The Financial Operations Team within the OFA will continue to create timely and accurate monthly Federal Direct Student Loan reconciliations that compare OPUS (Emory), General Ledger (Emory), Student Account Statement-SAS (U.S. Department of Education), and GS (U.S. Department of Education). Anticipated Completion Date The corrective action plan was implemented for FY 24-25 (September 1, 2024). Responsible Department: Office of Financial Aid John B. Leach, Associate Vice Provost for Enrollment and University Financial Aid Suite 300 Boisfeuillet Jones Center 200 Dowman Drive Atlanta, Georgia 30322

Although there was a procedure in place for timely reporting of withdrawals, an employee retirement caused the lapse in reporting. As a safeguard in the future, we have updated the documents procedures to indicate that all documents will be sent digitally to the registrar’s office, rather than a combination of paper delivery and/or email. By only email delivery, a trail can be followed to ensure both offices have received notification that the withdrawal process and its completion. As an additional safeguard, a regular review between all offices that manage student withdrawals will be conducted to ensure student cases have been completed timely. The email communication plan was put into place on February 13th, the monthly review will begin with the Month of March 2025.

MANAGEMENT’S VIEWS AND CORRECTIVE ACTION PLAN For the year ended December 31, 2024 Finding 2024-001 - Non-Compliance with Accurate Student Enrollment Change Submissions to the National Student Loan Data System (Significant Deficiency) Grantor: U.S. Department of Education Program: Student Financial Assistance Cluster Assistance Listing #: 84.268, 84.063 Award Titles: Federal Direct Student Loan Program, Federal Pell Grant Program Award Years: 7/2023 – 6/2025 Management agrees with the finding and proposes the following corrective action plan: Corrective Action Plan: Due to non-compliance with timely and accurate student enrollment change submissions to the National Student Loan Data System (NSLDS), Brigham Young University – Hawaii (BYUH) Management proposes the following corrective action plan to mitigate reporting errors. The Registrar’s Office, in coordination with BYUH’s Enterprise Information Systems team, will review and enhance the processes used to extract student data from PeopleSoft and transmit it to the National Student Clearinghouse (NSC) and NSLDS. This includes: -Reviewing all relevant PeopleSoft updates and ensuring that corresponding changes are reflected in the data transmitted to NSLDS. -Testing and validating the reporting processes within PeopleSoft to confirm data accuracy and completeness. -Verifying that the correct data is being transmitted to NSLDS. -Testing the student data within NSLDS to ensure its integrity. -Documenting the entire process for future reference and ongoing quality assurance. In addition, the Registrar’s office has already added additional resources to run all reporting processes. The Registrar’s office has also reached out to Ensign College to learn about their reporting process. The University is considering contacting the PeopleSoft reporting specialist that Ensign used, although that decision will be made at a later date, and if necessary. These actions will enable the Registrar’s Office to more effectively review credit load determinations and accurately establish program begin dates for students. Daryl Whitford, Registrar, will remain responsible for enrollment reporting at BYUH. She will oversee the implementation of the revised process, provide training to all relevant staff members, and lead the development and implementation of a control mechanism to ensurefuture compliance with NSLDS reporting requirements within PeopleSoft. Timing: Daryl Whitford, Registrar, will be responsible for overseeing that all items noted in the corrective action plan will be implemented by September 1, 2025. Signed and Acknowledged Daryl Whitford, BYUH Registrar

Management Views and Corrective Action Plan Year Ending December 31, 2024 Finding 2024-002 – Non-Compliance with Financial Need Requirements for Subsidized Direct Loans Grantor: U.S. Department of Education Program: Student Financial Assistance Cluster Assistance Listing#: 84.268 Award Titles: Federal Direct Student Loan Program Award Years: 7/2023 – 6/2026 Management agrees with the finding and proposes the following corrective action plan: Corrective Action Plan The incomplete installation of a student information system (PeopleSoft) update resulted in certain EFCs not prorating correctly. The incomplete system update that created this issue has been corrected. Moving forward, all PeopleSoft updates will be reviewed upon completion by Jesus Garcia, PeopleSoft project manager, to ensure all steps have been finalized as expected. Additionally, with the implementation of the 2024–25 FAFSA Simplification Act, prorated EFCs are no longer applicable. As such, this issue will not recur in future processing cycles. Timing The incomplete PeopleSoft update was corrected in March 2024. PeopleSoft updates are done every quarter and will be reviewed upon completion by Jesus Garcia. Because the 2024-25 FAFSA Simplification Act eliminated the use of prorated EFCs in this process there will be no further action taken. Sincerely, S. Christopher Reitz Director of Financial Services and Controller creitz@ensign.edu 801-524-8109

Management Views and Corrective Action Plan Year Ending December 31, 2024 Finding 2024-001 – Enrollment Reporting Grantor: U.S. Department of Education Program: Student Financial Assistance Cluster Assistance Listing#: 84.268, 84.063 Award Titles: Federal Direct Student Loan Program, Federal Pell Grant Program Award Years: 7/2023 – 6/2026 Management agrees with the finding and proposes the following corrective action plan: Corrective Action Plan Campus Status Matt Smith, College Registrar, will work with Tom Cote, NSC Enrollment Reporting Consultant, to adjust the enrollment report produced by PeopleSoft. With this change, PeopleSoft will report a student's campus-level enrollment as withdrawn when they withdraw in the middle of a semester instead of leaving them as less than half-time. Program Status Matt Smith, College Registrar, and Riley Niemand, Director of Financial Aid, will use the NSLDS Enrollment Error Report to reconcile what is being reported from NSC to NSLDS to ensure it is accurate. Timing Campus Status Matt Smith is currently working with Tom Cote to make these changes and work will be completed by the end of May 2025. Program Status Matt Smith and Riley Niemand will have this reconciliation implemented by the end of June 2025. Sincerely, S. Christopher Reitz Director of Financial Services and Controller creitz@ensign.edu 801-524-8109

Finding #2: Untimely Return of Title IV Funds (R2T4) Criteria: Under 34 CFR 668.22(j), institutions must return unearned Title IV funds no later than 45 days from the date the institution determines that a student has withdrawn. Condition: Six R2T4s were submitted late. While four were linked to third-party service platform transitions, two delays were related to students experiencing hardship (homelessness and mental health emergencies) and internal documentation gaps. Effect: Noncompliance with R2T4 deadlines may result in program findings, increased liabilities, and recurring audit scrutiny if unresolved. Corrective Actions for R2T4: 6. R2T4 Tracker Implementation o Action: Launch a live R2T4 tracker in Campus Café, flagged by withdrawal status and showing days remaining until the 45-day deadline. o Due Date: May 15, 2025 o Lead: Registrar, Business Office, Financial Aid Lead 7. Case Ownership Assignment Protocol o Action: Assign R2T4 responsibility to ECM and Business Office, written timelines and escalation criteria. o Due Date: May 15, 2025 o Lead: Executive Director 8. R2T4 Checklist & Escalation Framework o Action: Finalize a standardized checklist for all R2T4 cases including withdrawal date, calculation verification, fund return confirmation, and dual review. o Due Date: May 15, 2025 o Lead: Operations Manager 9. Quarterly R2T4 Audit o Action: Conduct quarterly compliance audits on all R2T4 files and include findings in compliance reports. o Due Date: First audit by June 30, 2025 o Lead: Compliance Officer 10. Emergency Circumstance Protocol o Action: Document a formal protocol for handling R2T4 cases with student hardship that allows internal escalation, verification, and documentation of exception handling. o Due Date: July 1, 2025 o Lead: Executive Director Monitoring Plan: Compliance will provide a quarterly report on R2T4 timeliness to the Executive Director. Any case that nears 35 days will be auto escalated for executive intervention.

Finding #1: Delayed or Incomplete Enrollment Reporting Criteria: Per 34 CFR 685.309(b), institutions must report student enrollment status changes (withdrawals, graduations, leaves of absence) within 30 days of determination or every 60 days using a consistent reporting schedule. Condition: Enrollment changes for several students were not reported to NSLDS within the required timelines. Delays resulted from third-party servicer (ECM) processing issues, gaps in cross-verification, and lack of internal triggers for mid-enrollment aid recipients. Effect: Untimely reporting may result in incorrect loan repayment statuses for borrowers and may trigger additional oversight by the Department of Education. Corrective Actions for Enrollment Reporting: 1. Shared Operational Calendar with Alerts o Action: Expand the institutional calendar to include enrollment reporting cycles with automated alerts 15 and 5 days before reporting deadlines. o Due Date: May 15, 2025 o Lead: Registrar 2. Internal Monthly Cross-Verification Audit o Action: Reconcile Campus Café enrollment records with ECM NSLDS batch confirmations monthly to catch and correct discrepancies. o Due Date: Begins May 2025, ongoing o Lead: Compliance Officer 3. Enhanced Title IV Status Tracking o Action: Update batch tracker template to log when students begin receiving Title IV aid after initial enrollment, with clear notation requirements. o Due Date: May 15, 2025, Ongoing o Lead: Registrar 4. Targeted Staff Training o Action: Deliver internal training on accurate Title IV status coding and enrollment reporting procedures to Registrar and Business Office teams. o Due Date: May 15, 2025 o Lead: Executive Director & Registrar 5. Bi-Monthly Enrollment Reporting Review o Action: Conduct a compliance review every 8 weeks to assess reporting timeliness and documentation quality. o Due Date: Begins May 2025 o Lead: Compliance Officer Monitoring Plan: Compliance team will issue bi-monthly reports to the Executive Director summarizing reporting performance and identifying risk patterns.