Corrective Action Plans

Finding Number: 2025-001 Federal Program: U.S. Department of Education – Student Financial Assistance Cluster Assistance Listing Numbers: 84.063, 84.007, 84.268, 84.033 Compliance Requirement: Special Tests and Provisions – Enrollment Reporting Finding Summary: The College agrees with the audit finding and is committed to strengthening internal controls over enrollment status reporting to ensure continued compliance with federal requirements. During management’s review of the audit results, the Registrar’s Office was unable to reproduce the specific enrollment status reporting errors identified during audit testing and could not definitively determine how the errors occurred. Notwithstanding this, the College recognizes that weaknesses in monitoring and documentation contributed to the inability to detect and prevent the reporting discrepancies in a timely manner. Accordingly, management has developed the following corrective actions. The College will enhance coordination among Registrar’s Office, Financial Aid, and Information Technology to ensure enrollment status changes including graduation, withdrawal, and changes in enrollment status are identified promptly and reported accurately to the National Student Loan Data System (NSLDS) within the required 60-day timeframe in accordance with 34 CFR 690.83(b)(2) and 34 CFR 685.309. For over 20 years, the College of Idaho has been a member of the National Student Clearinghouse (NSCH). One of the many advantages of membership to the NSCH is that the NSCH serves as a conduit to NSLDS and sends reports to the NSLDS for the college. Ellucian Colleague has written a series of reports that result in a .txt file that is uploaded to NSCH who in turn uploads to NSLDS. The College of Idaho submits regular transmissions to NSCH so that the 60-day timeframe is met. Corrective Action Plan: • Process Review and Clarification of Roles The Registrar’s Office will review and formalize procedures related to enrollment status determination and reporting. Roles and responsibilities for identifying enrollment changes, preparing NSLDS files, and submitting updates will be clearly documented to ensure accountability and continuity. • Student Information System Reporting Improvements The College will refine and validate student information system (SIS) reports used for enrollment reporting to ensure accurate capture of enrollment status changes and effective dates. Reports will be reviewed regularly to confirm continued reliability. • Internal Review and Oversight Controls Prior to submission to NSCH, enrollment status reports will be reviewed by the Registrar supervisory personnel to confirm accuracy and completeness. Evidence of review will be retained in accordance with institutional record retention practices. • Established Reporting Timeline A recurring reporting calendar will be implemented to ensure enrollment status updates are submitted within required federal timeframes. Backup personnel will be identified to support continuity during staff absences. • Training and Ongoing Communication Staff involved in enrollment reporting will receive periodic training on federal enrollment reporting requirements and institutional procedures. Regular communication between Enrollment Services and Financial Aid will support timely identification and resolution of discrepancies. Responsible Official(s): Mark Heidrich (Registrar/Associate Vice President for Institutional Effectiveness), in coordination with Stephanie House (Director of Financial Aid) and Imad Sweidan (Chief Information Officer), as appropriate. Anticipated Completion Date: June 30, 2026 Current Status: Corrective action is in progress. Management expects these actions to be fully implemented prior to the next audit period and believes the strengthened controls will prevent recurrence of this finding.

The College will diligently check each financial aid disbursement roster to review and refund any student account credit balances generated from a disbursement. This process is to maintain compliance with this requirement. The College will also create an Infomaker report each week to identify any credit balances that need refunded.

All Registrar staff were re-trained on the proper procedures as they relate to updating enrollment status for students. A double check system was put into place to have two members of the Registrar staff check each student to ensure proper enrollment status accuracy is achieved.

Financial Aid personnel responsible for loan disbursements will review both COD and Pfaid records to ensure they align with the corresponding student account disbursement information. Additionally, the office will conduct monthly COD mismatch reviews to determine whether maintenance files need to be submitted. This process will help ensure continued accuracy and compliance in federal reporting.

Views of responsible officials and planned corrective actions: The University does not agree with the conclusion of this finding. The University determines a student’s withdrawal date based on the student’s official notification or, where applicable, the date of determination when a student ceases attendance without providing official notice. Based on the University’s review of institutional records and applicable regulatory guidance in effect during the audit period, management believes the withdrawal processing methodology applied was reasonable and consistent with institutional procedures and Title IV requirements. For three of the four students identified, the data reported to NSLDS reflected the institution’s determination date rather than the withdrawal date. Management maintains that this approach was the result of interpretation applied to specific withdrawal circumstances and did not materially misrepresent the students’ enrollment status or Title IV outcomes. For the remaining student, management agrees that a clerical data-entry error resulted in an incorrect withdrawal date being reported to NSLDS; however, this instance was isolated and does not represent a systemic control deficiency. While the University does not agree that the instances cited constitute noncompliance, management acknowledges the auditor’s concern regarding consistency in distinguishing withdrawal dates from determination dates for NSLDS reporting purposes. In response, and without conceding noncompliance, the University will enhance its policies, procedures, and internal controls to promote consistent application of regulatory definitions and reduce the risk of future discrepancies.

Finding - Eligibility - Federal Direct Student Loan Program, Assistance Listing Number 84.268 and Federal Pell Grant Program, Assistance Listing Number 84.063: June 30, 2025 Award Year: U.S. Department of Education Criteria or Specific Requirement The amount of a student’s Pell Grant for an academic year is based upon the payment and disbursement schedules published by the Secretary for each award year. (34 CFR 690.62 through 690.66). Direct Loans are determined based on the criteria noted in 34 CFR 685.203(a),(b),(c). Condition Of the 40 students selected for eligibility testing, two students within the sample were incorrectly awarded aid based upon their specific circumstances. This was not a statistically valid sample. Views of Responsible Officials and Planned Corrective Actions The University concurs with the finding. The University will strengthen quality control through improved reporting and staffing to ensure accurate and compliant student aid awards. Names of Contact Persons Responsible for Corrective Action: Anne-Marie Caruso, Associate Vice President, Student Financial Services; Beck Gusler, Director Financial Aid Compliance. Anticipated Completion Date: December, 2025 Summary Schedule of Prior Audit Findings None.

In order to maintain procedures to verify the disbursement dates in the COD System agree to the date funds are credited to the student’s account in the colleges Accounts Receivable subledger to the general ledger, the institute has updated its procedures. The Financial Aid Office will adjust the scheduled disbursement date according to updated procedures when disbursement occurs earlier than the scheduled date to ensure accuracy of reporting data to COD. These are updates to the current Disbursement Policy and Procedures.

Recommendation: We recommend the College review its reporting procedures to ensure the students' statuses are accurately reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Financial Aid Office updated procedures when citizenship documentation is received for a student previously classified as a noncitizen. The Financial Aid Office will notify the Office of Records and Registration of the student’s status change. Prior to disbursing Title IV aid, the Financial Aid Office will verify with the Office of Records and Registration that the student has been added to required NSLDS reporting. Name(s) of the contact person(s) responsible for corrective action: Tasha Marwitz Planned completion date for corrective action plan: Effective immediately.

Management agrees with the finding. Management at the System Office will work with KVCC and YCCC to implement a process in which all Direct Loan disbursements receive notification within the 30-day window. The timing of this resolution is anticipated to occur in Spring 2026. Richard Rosen, Chief Financial Officer (Interim), is responsible for the corrective action plan.

Management agrees with the finding. Management at the System Office will work with CMCC, YCCC, MCCS IT Shared services and specialists with the Student Information System vendor to implement a process in which all disbursement calculations are checked by the software platform for accuracy. The timing of this resolution is anticipated to occur in 2026. Richard Rosen, Chief Financial Officer (Interim), is responsible for the corrective action plan.

Management agrees with the finding. Management at the System Office will work with EMCC and CMCC management to implement a process which verifies all refund calculations of Title IV funds (R2T4) are reviewed by the appropriate level of management to ensure timely filing to the COD system is occurring. The timing of this resolution is anticipated to occur in Spring 2026. Richard Rosen, Chief Financial Officer (Interim), is responsible for the corrective action plan.

Finding – Special Tests and Provisions: Enrollment Reporting – Federal Direct Student Loan Program, Assistance Listing Number 84.268; June 30, 2025 Award Year; U.S. Department of Education Cause: Within the University's student information system, PowerCampus, the degree verifier report was not cross referenced with the graduation report. This student was on the degree verifier report but did not appear on graduation report, which is the report that is sent to the National Student Clearinghouse ("NSC") who then transmits information to NSLDS on behalf of the University. Condition: One student was excluded from the report used for the Clearinghouse as a graduated student. As they did not appear on the report twice, the Clearinghouse changed their status to withdrawn. The School then became aware of the change and the graduated status was transmitted to the clearinghouse on 2/7/25 and not received by NSLDS until 7/24/25. Criteria: The Enrollment information, including the effective date of separation from the institution, must be accurately reported within 30 days whenever attendance changes for a student, unless a roster will be submitted within 60 days. The changes include reductions or increases in attendance levels, withdrawals, graduations, and approved leaves of absence. It is the institution’s responsibility, as a participant in the Title IV aid programs, to monitor and report these changes to the National Student Loan Data System (“NSLDS”). (NSLDS Enrollment Reporting Guide November 2022, and 34 CFR 685.309(b)) Corrective Action Plan to be Taken: After each graduation period the Registrar’s Office will compare the Degree Verify file against the Graduation Enrollment file as both files are uploaded to the National Student Clearinghouse. The Degree Verify file is generated and uploaded after the Graduation Enrollment file; this process of report comparison will allow us to capture any student not reported in the Graduation Enrollment file. Thereby ensuring all graduating students are reported correctly to the National Student Clearinghouse. We’ll begin this process, on October 3, 2025 with the August 2025 graduates as they were just reported to the National Student Clearinghouse this past month. Sincerely, Linda M. Arce Registrar

Personnel turnover within the Office of the Registrar (July 2023) and the AVP for Academic Affairs (June 2024) led to procedural gaps during these transitions. Some of the proccesses and procedures suffered from a lack of transitional clarity. The Office of the Registrar is responsible for updating the STVMAJR screen in Banner which is a manual process. To rectify this, we have created a streamlined process for updates to the curriculum workflow to ensure precise alignment between Banner and CIP codes. This includes a new monthly meeting between the Registrar, Associate Registrar and AVP to review all curriculum updates, modifications, and new programs to prevent future errors. Issues with the Fall 2024 degree file delayed First of Term processing for Spring 2025. A defect introducted by an Ellucian update affected the degree file output and was resolved by updating the Banner page STVACAT (specifically the NSC Credential Level Translation column). This issue is not expected to recur. Spring 2025 First of Term processing was also delayed due to the manual creation of approximately 200 Social Security Numbers for newly admitted international students following the SLATE implementation and Admissions staffing turnover. This process has since been automated through an update to an Argos generator, eliminating the need for manual SSN creation. In addition, the National Student Clearinghouse transmission schedules were updated to allow additional processing time between files and to avoid submissions during the winter break. Specifically, transmissions for Fall Subsequent of Term were moved from January 1 to January 11, Fall Graduates Only (WS) from January 4 to January 18, and the Fall Degree file from January 14 to January 25.

Corrective Action/Management Response: Ensuring that Adoption records are maintained accurately with all documented requirements. Changing Practice to include putting documents into the document management system (Traverse) in order to have a copy of required documents in the event originals are lost, or documents are damaged due to flooding (which is what occurred in the basement where documents were housed). Cases that are more than 10 years old are typically going to be more difficult to locate needed items, due to records being maintained differently at that time and requirements were different in what the Department was required to maintain in an Adoption file. Proposed Completion Date: June 30, 2026 checking monthly to ensure paper files are scanned into Traverse.

Reference Number 2025-02 Return of Title IV Funds (R2T4) Since the 2025 audit, there have been significant improvements in oversight and process management for R2T4 calculations. A leadership transition occurred, and the Associate Director - bringing over 30 years of higher education experience, including prior service as a Financial Aid Director - has assumed responsibility for R2T4 calculations for the 2026-27 academic year. To ensure compliance and accuracy, the Associate Director completed a Department of Education training refresher on R2T4 calculations during Spring 2025. Additionally, the interim Financial Aid Director implemented a structured plan to monitor all student withdrawals and guarantee timely completion of calculations. For Fall 2025, the process has remained on schedule. A two-tier accountability system is in place: the Associate Director manages calculations, and the Director provides immediate support if any delays occur. A comprehensive tracking spreadsheet was developed to record each withdrawal, including the withdrawal date, federal aid status, and the date the R2T4 calculation was completed. This tool ensures real-time monitoring and accuracy. The daily withdrawal report introduced after the 2024 audit continues to be a valuable resource; however, the combination of this report with the new tracking system and dual oversight has proven to be the cornerstone of compliance. All calculations are current, accurate, and completed within required timelines. Based on these improvements, we do not anticipate any findings in the upcoming audit.

Views of Responsible Officials and Planned Corrective Actions – The Registrar and Institutional Researcher will both ensure that any students that have updated their status are updated on a weekly basis. The Institutional Researcher will log into NSLDS to upload the file, and the CFO, Registrar, and Institutional Researcher will monitor updates monthly.

Views of Responsible Officials and Planned Corrective Actions – The CFO and the Students Account Manager will add a checklist step to verify the correct inclusion of all scheduled breaks in the R2T4 calculation, will implement a secondary review process to confirm data accuracy before finalizing R2T4, and will provide training to relevant staff.

Views of Responsible Officials and Planned Corrective Actions – The CFO and Student Accounts Manager has begun the process of uploading the file that specifies disbursement date in the ledger so they match one another.

Views of Responsible Officials and Planned Corrective Actions – The CFO and Student Accounts Manager will provide a listing of all students receiving a refund. A grace period of 5 days for students to provide direct deposit information will be established, if after 5 there is still no direct deposit information, a check will be issued.

Student Financial Assistance Cluster Assistance Listing No. 84.007, 84.033, 84.063 & 84.268 Recommendation: We recommend the University review credit balance refund processes, including automated processes, to ensure all credit balances are paid timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Revised the daily Title IV credit balance workflows to include credit balances of any amount. Name(s) of the contact person(s) responsible for corrective action: Valerie Marsh, Director of Student Financial Services Planned completion date for corrective action plan: December 1, 2025

Student Financial Assistance Cluster Assistance Listing No. 84.007, 84.033, 84.063 & 84.268 Recommendation: We recommend the University review reporting processes to ensure all students that require exit counseling receive it in a timely manner. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The workflow FAEXIT_WDR for students who withdrew in the current term or have a late coded CWD was revised from excluding the assignment of exit counseling if exit counseling was assigned in the prior academic term to exclude only if exit counseling already exists in the current term. Name(s) of the contact person(s) responsible for corrective action: Alec Kuzmack, Business Analyst Planned completion date for corrective action plan: November 21, 2025

Corrective Action Plan Related to the Schedule of Findings and Questioned Costs Student Financial Aid University of Hawaiʿi – Maui College Year Ended June 30, 2025 Finding No. 2025-002: Financial Aid Administration – Control Deficiency Federal Agency: U.S. Department of Education CFDA Number and Title: 84.268 – Federal Direct Student Loans Questioned Costs: $-0- Responsible Individuals: Kulamanu Ishihara, Financial Aid Director, Maui College Date Action Taken: December 2, 2025 Corrective Action Plan for timely notifications for exit counseling- NSLDS reporting. 1. Financial Aid Office Staffing ● The Financial Aid Office has completed recruitment for four full-time positions, including a director to ensure adequate administrative capacity for the financial aid processes. 2. Project Prioritization ● Effective immediately, the Financial Aid Office will prioritize timely notifications and exit counseling to students with loans. 3. Project Documentation ● For any future delays due to unforeseeable circumstances, the financial aid program will provide clear, detailed justifications to ensure compliance with audit expectations. 4. Project Oversight and Monitoring ● The Vice Chancellor of Student Affairs will meet monthly with the Financial Aid Director to ensure deadlines are being met and to and monitor the progress of notifications. Expected Results Implementation of this corrective action plan will result in timely notifications of exit counseling being provided through interactive electronic notifications or by mailing counseling materials to the borrower at the borrower’s last known address within 30 days after learning that the borrower has withdrawn from the institution or failed to complete exit counseling as required.

Corrective Action Plan Related to the Schedule of Findings and Questioned Costs Student Financial Aid University of Hawaiʿi – Maui College Year Ended June 30, 2025 Finding No. 2025-001: Return of Title IV Funds – Control Deficiency Federal Agency: U.S. Department of Education CFDA Number and Title: 84.063 – Federal Pell Grant Questioned Costs: $-0- Responsible Individuals: Kulamanu Ishihara, Financial Aid Director, Maui College Date Action Taken: November 25, 2025 Corrective Action Plan for timely notifications for withdrawal date determination. 1. Financial Aid Office Staffing ● The Financial Aid Office has completed recruitment for four full-time positions, including a director to ensure adequate administrative capacity for the financial aid processes. 2. Project Prioritization ● Effective immediately, the Financial Aid Office will prioritize the timely withdrawal date determination by initiating the new Kuali Build Form with routing capabilities. 3. Project Documentation ● For any future delays due to unforeseeable circumstances, the financial aid program will provide clear, detailed justifications to ensure compliance with audit expectations. 4. Project Oversight and Monitoring ● The Vice Chancellor of Student Affairs will meet monthly with the Financial Aid Director to ensure deadlines are being met and to monitor the progress of notifications. Expected Results Implementation of this corrective action plan will result in a timely determination of the withdrawal date through interactive electronic routing.

2025-001 Significant Deficiency: National Student Loan Data System (NSLDS) Report (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268 and Federal Pell Grant Program, ALN #84.063) (Repeat finding of 2022-001, 2023-003, and 2024-005) Name of Contact Person Casey Reagan, Registrar, and Melissa White, Director of Financial Aid, are responsible for clearinghouse reporting for 2023-24. Corrective Action Planned During the audit, it was noted that the University incorrectly reported student enrollment status for changes in enrollment. The university has identified the issue that is occurring that is causing the enrollment to be reported incorrectly. We are currently working with the IT Department to fix the error that is occurring within the system itself. In the meantime, students who are impacted by the incorrect enrollment status reporting are being manually fixed in the system and then the record is being pulled and reported to clearinghouse. Overall, the university has been working to reduce the number of incorrect enrollment status reportings. This can be seen by the fact that we went from a 45% error rate in 2023-24 to a 20% error rate in 2024-25. Finally, the Registrar’s Office shall be main office reporting clearinghouse data in the future, with financial aid only acting as a secondary reporter should the Registrar’s Office not be available to report. Anticipated Completion Date 08/01/2026

2025-001 Incorrect Direct Loans Disbursement Amount - Student Financial Aid Cluster Assistance Listing #s 84.007, 84.033, 84.063, 84.268, Grant Period - Year Ended June 30, 2025 Condition Found During our student file testing we noted one student out of forty was disbursed the incorrect Direct Loan amount. Based on the student’s enrollment status and need this student was eligible for $586 in Subsidized Loans and $2,914 in Unsubsidized Loans; however, the College awarded the student $549 in Subsidized loans and $2,951 in Unsubsidized loans which resulted in an under award of $37 in Subsidized Loans and an over award of $37 in Unsubsidized Loans. We consider this error in awarding to be an instance of noncompliance of the Eligibility Compliance Requirement. Corrective Action Plan Waubonsee will ensure to add the loan fees first to ensure sub-loans are calculated correctly. Responsible Person for Corrective Action Plan Mary Greenwood Implementation Date of Corrective Action Plan 12/9/2025