Corrective Action Plans

Student Financial Assistance Cluster – Federal Assistance Listing No. 84.063, 84.268, 84.007, 84.038, 84.033 Recommendation: The College should review its policies and procedures on determining student's withdrawals, specifically the proper calculation elements and proper rounding were necessary to ensure timely and accurate returns of Title IV funds. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: 1) Break days of 5 consecutive days or more were incorrectly added to PowerFaids during setup. The College has reviewed and updated its policies and procedures to show that both the Director of Financial Aid and the Bursar will review the number of days to be entered into PowerFaids to ensure that prior and post-weekend days are included in the scheduled break when applicable. 2) In manually calculating the Return of Title IV Funds, the adding machine was inadvertently not set to round to three decimal places as required. The Bursar is responsible for calculating Return of Title IV funds and will ensure that any manual calculations are rounded to three decimal places as required. Policies and procedures have been updated to reflect the requirements of this critical step. Name(s) of the contact person(s) responsible for corrective action: Julie Lanski, Director Student Financial Services/Bursar Planned completion date for corrective action plan: May 31, 2026

Student Financial Assistance Cluster – Federal Assistance Listing No. 84.063, 84.268, 84.007, 84.038, 84.033 Recommendation: The College should review its policies and procedures on reviewing enrollment status changes to NSLDS to ensure that all status changes are being reported timely and accurately to be in compliance with regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Registrar will review and strengthen the enrollment report to ensure it pulls all required information according to the needs of the National Student Clearinghouse (NSCL) and the NSLDS. The Registration and Records Office will continue to work with NSCL and NSLDS on specific enrollment scenarios that require different submission update requirements. Name(s) of the contact person(s) responsible for corrective action: Katelyn Letizia, Interim Vice President Institutional Effectiveness and Academic Strategy. Planned completion date for corrective action plan: May 31, 2026

Federal Agency Name: U.S. Department of Education Program Name: Student Financial Assistance Cluster Federal Financial Assistance Listing #: 84.007, 84.033, 84.063, 84.268 Compliance Requirement: Special Tests and Provisions – Return of Title IV Funds Significant deficiency in internal control Finding Summary: One instance was identified where the amount of funds to be returned was not calculated/remitted correctly. Responsible Individuals: Randy Mashek, Financial Aid Director and Dawn Fleming, Assistant Director of Financial Aid Corrective Action Plan: The Financial Aid Office will collaborate with the full Student Services team (Advising, Registrar, Financial Aid, Finance) in order to continue a strong focus on the importance of the Return of Title IV Funds (R2T4) policy and procedures. This focus will improve the process in order to better accurately calculate R2T4s as well as communicate the importance of dates more effectively with students and staff regarding withdrawals and earned aid and the financial impacts of them. Implementation of certain measures has already begun in 2025-26 with the following steps: 1. Return of Title IV Funds (R2T4) calculations in real time as students withdraw from classes throughout the semester. Cross training for the administration staff processing withdrawals was implemented over the past two years. A checks and balances system are now in place to alert the Assistant Director and Director of Financial Aid whenever a complete withdrawal is made. Once the notification is made the Assistant Director reviews, calculates and processes the R2T4. The Director will perform a monthly quality sampling throughout the semester in order to review and test R2T4 calculations for accuracy and document when that happens. This process was in practice as the Assistant Director was being trained by the Director over the past year and now, we will begin to formalize that process as well as document each instance and build it into the workflow starting with the spring 2026 semester. 2. Additionally, ongoing training for R2T4 rules and regulations is completed throughout the year through our state and national associations (NASFAA and IASFAA) by the Assistant Director and Director as well as webinar and training from Federal Student Aid (FSA). From these trainings we will continue to share with Advising and support staff in order to educate and train them on the implications of withdrawals and the importance of earned aid dates, modular classes, class start and end dates, and college breaks that all impact the calculation of days in the R2T4 process and communication. Anticipated Completion Date: Ongoing. Fully functional with the start of 2026-27 year

Federal Agency Name: U.S. Department of Education Program Name: Student Financial Assistance Cluster Federal Financial Assistance Listing #: 84.007, 84.033, 84.063, 84.268 Compliance Requirement: Special Tests and Provisions – Enrollment Reporting Material Weakness in Internal Control Finding Summary: During testing of compliance for Enrollment Reporting, there were 9 instances out of 60 where the College did not report a student’s change in enrollment status accurately or within the required time frame of 60 days from the effective date of the student’s change in enrollment status. Responsible Individuals: Karla Winter, Registrar and Randy Mashek, Financial Aid Director Corrective Action Plan: The Registrar’s Office will collaborate with the Financial Aid Office to provide oversight to the Enrollment Reporting process. Oversight includes timely batch reporting of student enrollment statuses to the National Student Clearinghouse (NSC) for all periods of enrollment, NSC Error Report review and resolution between NICC’s internal Student Information System (Colleague) with the National Student Loan Data System (NSLDS), as well as having documented policies and procedures in place in order to administer, implement and comply with the full scope of Enrollment Reporting on an ongoing basis. The Policies and Procedures will address the previously recommended requirement of the Registrar’s Office to conduct and retain evidence of quality sampling once a semester. Implementation of certain measures has already begun in 2025-26 with the following steps: 1. The Registrar implemented a new reporting schedule with NSC to capture the Winterim semester (which is part of the spring financial aid semester) to accurately reflect the enrollment from that special mini session. This was implemented for the Winterim 2025 session (December 2025-January 2026) and reporting began 1/9/2026. 2. The Financial Aid Office is implementing a new system to review and resolve NSC Error Reports (NSLDS SSCR) beginning with the spring 2026 semester. These reports are provided by the Registrar, and produced by NSC after each enrollment submission. The Financial Aid staff will review Colleague and NSLDS records in order to determine corrective action in the required timeframe and then provide enrollment changes to NSC to have the student’s NSLDS record updated with accurate information. 3. NSC will update NICC’s reporting codes from the current two branches (00 Calmar and 01 Peosta) to a single reporting branch (00) beginning with the fall 2026 semester (2026-27 academic year). This change will align with recent updates over the past few years from two individual school codes (Calmar and Peosta) to just one code with several Federal Student Aid (FSA) systems. These systems include Student Loan origination at the Common Origination & Disbursement Web Site (COD), FSA Partner Connect as well as the Free Application for Federal Student Aid (FAFSA) school codes. The decision to transition from two codes to one in many reporting areas was made in order to reduce student confusion between campuses when completing the FAFSA, reduce reporting inefficiencies and errors, as well as streamline multiple reporting challenges for federal and state aid reporting. The actual process presented many challenges for NICC and FSA and was implemented over the past two years successfully. However, the transition did not include the enrollment reporting side with NSC/NSLDS which has been the source of many of our multiple student record errors. Anticipated Completion Date: Ongoing. Fully functional with the start of 2026-27 year.

FINDING 2025-001 Name of Responsible Individual: Daniel Arndt, Registrar Corrective Action: Management acknowledges the finding regarding the inaccurate reporting of student data elements under the Program-Level record on the NSLDS website. We also acknowledge that this is technically a repeat finding from the prior year; however, the finding identified for one student out of the forty students selected was prior to the implementation of the University’s Corrective Action Plan on January 31, 2025. The University previously addressed this issue and implemented a corrective action plan that included updating our reporting frequency and enhancing our data review processes as follows: Updated Reporting Frequency: As of January 2025, the University now includes the non-compulsory terms, summer 1 and winter sessions, in its reporting. The previous institutional practice did not include reporting program-level data for these terms given that said terms do not involve federal financial aid. This change ensures that all program-level data, regardless of federal financial aid involvement, is accurately reported. Secondary Check Process: Each month, the Compliance Officer reviews a sample of 100 students from NSLDS to verify significant data elements, including program enrollment effective dates. After the initial review, the Compliance Officer summarizes the findings and shares them with the Associate Registrar and Registrar for a secondary review. Any necessary edits are made, followed by a review of an additional 25 students to ensure accuracy. We believe the corrective action steps are critical in ensuring accurate reporting and preventing this issue in the future, and we believe they have been effectively implemented. We believe that the fact that only one of forty students selected was reported incorrectly is an indication that our corrective action plan has been effective. Completion Date: January 31, 2025

Management is responsible for establishing and maintaining effective internal controls over compliance under Uniform Guidance. Personnel Responsible for Corrective Action Plan: Jana Parks, Student Financial Aid Director, and Melissa VanLeiden, Chief Accounting Officer. Anticipated Completion Date: The corrective action plan will be implemented by June 30, 2026. Corrective Action Plan: We have re-established automated enrollment report generation through our SIS, which is now configured to generate enrollment reports for submission to the National Student Clearinghouse (NSC). Before current reports can be submitted, we are required to submit manually created enrollment reports for each missed reporting period from December 2024 through December 2025. Preparation of these reports is currently underway, and we expect to resume submissions on our established enrollment reporting schedule no later than the end of the Spring 2026 semester.

Upper Iowa University Corrective Action Plan For the Year Ended June 30, 2025 Finding 2025-001 Condition: Of the 25 students tested, one student was not reported to NSLDS. There is an issue with the student’s record in NSLDS stemming from information reported by a prior school. The University is reporting information to the National Student Clearinghouse (NSC) servicer but the information is failing to link up to their NSLDS record resulting in her record ultimately not being reported. Corrective Action Plan: Although the University is not able to prevent or resolve rejected records directly when they occur for this reason, we can provide additional information to the Clearinghouse that may allow them to resolve the issue. This sometimes requires requesting that the student provide additional documents and/or submitting information to the Clearinghouse for their review. Rejected records are reviewed by the University after each submission. In addition to this initial review, we have added additional reject tracking in our database. This allows us to better monitor and follow up on records with this issue while we wait for needed information or for the Clearinghouse to review additional information we have submitted. Completion Date: 9/17/2025 Name(s) of Contact Person(s) Responsible for Corrective Action: Jill Austin, CRM Administrator

The records in the student sample that were tested were from the Fall semester 2024. In addition to strengthening controls and staff training, the College completed an internal audit on 4/30/25 of all student accounts to ensure compliance with cash management practices for future federal awards and corrected any findings. As a means of maintaining compliance under the Heightened Cash Monitoring 1 Payment Method (HCM1) as described under 34 C.F.R. § 668.162(d)(1), Keystone first makes disbursements to eligible students and parents and pays any remaining credit balances before it requests or receives funds for the amount of those disbursements from the Department. The College’s practices and internal controls for Title IV, HEA program funds received from the Department reflect the compliance criteria as required.

Finding 2025-002: Eligibility Student Financial Assistance Cluster U.S. Department of Education Award Period: July 1, 2024 – June 30, 2025 Responsible Person: Wilbert Casaine, Executive Director of Student Financial Aid, 609-771-2211 Corrective Action Plan: During the compliance audit for the fiscal year ending June 30, 2025, the College had one student out of a sample of 40 who was selected for the eligibility compliance and control testing that had an incorrect Pell grant award for the Spring 2025 semester. The student was identified as having received the incorrect amount of Pell based on changes in enrollment intensity during the College’s Add/Drop period. The result of this error was that the student was under-awarded the Pell grant. Once the error was discovered, the student’s Pell grant was increased to the correct amount and reported to COD. The College recognizes the importance of reviewing student enrollment intensity changes throughout the disbursement process to ensure it does not result in errors in the calculation and disbursement of aid in accordance with 34 CFR 668.42, 34 CFR 673.5, 34 CFR 673.6, and 34 CFR 685.301. The College has a robust process for confirming enrollment intensity, which includes automated system reviews of student records, as well as manual/in-person award confirmations. In this student’s case, there were multiple course changes in a short span of time during the Spring semester’s Add/Drop period, which required multiple reviews and revisions to the student’s financial aid package. During one of the reviews, a staff member did not accurately increase the student’s Pell grant award when it was flagged by the system as being incorrect. As part of our corrective action, we have implemented additional reporting enhancements to review and confirm accurate awards. The reports are listed below: • The Office of Records and Registration will provide a comprehensive roster of student registration actions immediately following the Add/Drop period, and continuing weekly, until mid-semester, for review. • The Senior Business Analyst in the Financial Aid Office created an enhanced part-time user edit report of Pell students only who are not full-time at the end of the Add/Drop period for review. • The Analyst in the Financial Aid office developed a report to compare student enrollment intensity changes weekly, after the Add/Drop period is over, to identify and correct discrepancies in real time. The aforementioned corrective actions in the Financial Aid Office were fully operational for the Fall 2025 semester. Internal control reviews confirmed that no award errors occurred during the Fall 2025 term, validating the effectiveness of the new reporting and review structure. The College implemented the corrective action on 08/26/2025. Anticipated Completion Date: Completed in August 2025

Finding 2025-001: Special Tests and Provisions – NSLDS Reporting Student Financial Assistance Cluster U.S. Department of Education Award Period: July 1, 2024 – June 30, 2025 Responsible Persons: Heba Jahama, Director of Records and Registration, 609-771-2376, Billy Peitz, Associate Director of Records, Reporting, and Enrollment, 609-771-2333 Corrective Action Plan: For the fiscal year ending June 30, 2025, the College had 1 student out of an initial sample of 40, for which it was noted that the enrollment effective date was reported by the College to the NSLDS inaccurately. The student was noted by the College as having a status of “LOA” (Leave of Absence), but this LOA was not reported to the NSLDS appropriately. Program-Level Enrollment data indicated this student as being withdrawn, but the Campus-Level Enrollment data did not. Additionally, 2 students out of an additional sample of 40 tested were found to have not followed the internal College policy for determining the enrollment effective date, despite internal College records matching those of the NSLDS. Lastly, for 1 out of the additional 40 students, the effective date per internal College records did not match NSLDS. The College recognizes the importance of ensuring accurate enrollment data regarding NSLDS reporting under the Pell Grant and the Direct Loan and FFEL programs via the NSLDS (OMB No. 1845-0035). Institutions must review, update, and certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. After a thorough review of the data errors, it was determined that the root cause was a lack of standardized business processes for LOA and Withdrawal actions. We have since implemented several corrective actions to ensure data integrity and institutional consistency. New procedural documentation has been established to clarify the standard operating procedure for LOAs and Withdrawals. This documentation provides a definitive framework for staff to ensure that term withdrawal dates within PAWS (the system of record) are perfectly aligned with program status updates transmitted to the National Student Clearinghouse (NSC). The updated operating procedures have been shared with all relevant personnel to ensure that staff members are proficient in the new PAWS-to-NSC alignment protocols. In addition, the College has noted that the date of record for student registration must serve as the primary trigger for external reporting. This eliminates inconsistencies between the date a student initiates a withdrawal and the date reported to external agencies. To mitigate the risk of reporting lags, the College has revised its reporting schedule. LOA and Withdrawal updates are now transmitted to the Clearinghouse on a regular, recurring basis, independent of the standard comprehensive enrollment file processing cycle. This ensures that student status changes are reflected in the NSC database timely. The College implemented the corrective action on 12/16/2025. Anticipated Completion Date: Completed in December 2025, with ongoing monitoring

Individual Responsible for Corrective Action: Kenzie Cox, Associate VP of Strategic Enrollment Corrective Action: Southern Virginia University has taken the following steps to resolve the issue: • A new internal check was created to verify that withdrawal dates match the verified withdrawal date before federal aid or institutional charges are updated. • The withdrawal form is being updated to require Financial Aid and Student Accounts signatures, ensuring that all relevant offices receive the information before it is finalized. • Communication procedures between the Registrar, Financial Aid, and Student Accounts have been formalized to ensure that withdrawal information is shared consistently. Southern Virginia University has taken the following preventive actions: • A regular withdrawal review will be completed to confirm accurate dates, status changes, and timely updates across all departments and systems. • The University will maintain and distribute an updated written withdrawal workflow to impacted departments clarifying communication, verification, and documentation requirements for university withdrawals. • Staff in all involved departments will participate in training to reinforce the updated procedures. Anticipated Completion Date: Process started in February 2026; form revisions and process revisions implementation anticipated completion April 30, 2026. Ongoing monitoring thereafter.

Individual Responsible for Corrective Action: Kenzie Cox, Associate VP of Strategic Enrollment Corrective Action: In October 2025, Southern Virginia University transitioned both award letter notifications and loan disbursement notifications to an automated process through the Student Financial Aid Management System. All notifications are now system-generated and automatically logged within each student’s record, ensuring a complete and permanent communication history. The Financial Aid Office will maintain automated notification workflows and conduct an annual review before each aid year to verify that award letter and loan disbursement notifications are generating automatically, and documentation of the notifications is happening correctly. Anticipated Completion Date: October 2025 (process fully implemented).

Individual Responsible for Corrective Action: Kenzie Cox, Associate VP of Strategic Enrollment Corrective Action: To ensure ongoing accuracy in enrollment reporting, Southern Virginia University is strengthening communication and coordination across departments involved in the reporting process. Beginning February 2026, the Financial Aid Office implemented a workflow to review NSC and NSLDS error reports more promptly and resolve discrepancies as they arise. Financial Aid will monitor this process monthly until errors are no longer identified, ensuring timely and accurate reporting going forward. The Registrar's Office will receive training on date reporting requirements and expectations for NSLDS so that they use the correct enrollment change dates. Anticipated Completion Date: Initial corrective actions implemented February 2026. Anticipated completion expected March 2026; ongoing monitoring in place.

Loras College Corrective Action Plan For the year ended June 30, 2025 February 19, 2026 Finding 2025-003: Disbursement Notifications Assistance Listing Number: 84.268 Federal Agency: U.S. Department of Education Condition: For one student in the sample of 25 students tested, the College was unable to provide support that timely notification was provided to the student receiving Direct Loan funds. The communication should include the date and amount of disbursements and the right and process for how to cancel all or a part of the loans. Recommendation: The College should implement a policy/control to ensure that the required notifications are provided to Direct Loan students and documentation is retained. Corrective Action: Management reviewed the process for disbursement notification and has established a process whereby all notifications sent electronically are saved to the College’s cloud based system. In addition, The financial Aid Director will review the disbursement notification process completed by the Financial Aid Counselor at least monthly and not the review on a shared electronic calendar. The review will ensure all required elements are included in the disbursement notification. This procedure will be implemented during the fidcal year ending May 31, 2026. Renate A. Root Treasurer 1450 Alta Vista St. Dubuque, IA 52001 563-588-7775

Loras College Corrective Action Plan For the year ended June 30, 2025 February 19, 2026 Finding 2025-001: Significant Deficiency – Incentive Compensation Assistance Listing Number: Various Federal Agency: U.S. Department of Education Condition: One out of five employees selected for testing had a promotion letter that included a salary increase if performance metrics for enrollments were met, with goal numbers for yearover- year increases in applications, admissions, new transfer enrollment and graduate enrollment. This is not in compliance with applicable requirements regarding incentive compensation. Recommendation: The College should establish a policy where employee contracts and compensation are reviewed and approved to ensure compliance with applicable requirements regarding incentive compensation per the regulations at 34 CFR 668.14(b)(22). Corrective Action: Management has reviewed internal processes and procedures and a process has been established whereby all employee contracts and compensation are first reviewed by the Associate VP for Finance/Treasurer and President before they are sent to Human Resources for processing. The Associate VP for Finance/Treasurer has a CPA background. In addition, the President and the HR Director are now well versed in applicable requirements regarding employee compensation. Management believes this process will eliminate a reoccurrence. Renate A. Root Treasurer 1450 Alta Vista St. Dubuque, IA 52001 563-588-7775

Return of Title IV (R2T4) Funds Errors, Reference 2025-002 Audit Finding: Out of a population of 367 students who completely withdrew from courses during the Spring and Fall semesters of the 2025 aid year and received a disbursement during the respective semester(s), 25 were selected for testing. Of those students, three had funds that were returned outside of 45 days from the date the University became aware of the withdrawal. Our sample was not, and was not intended to be, statistically valid. Cause of the Finding: The University did not have appropriate controls in place to ensure timely return of funds, the result of limited staffing within the Financial Aid Office and the absence of a formalized secondary review process. Effect of the Finding: The University failed to return funds timely, and, as such, ED did not have access to funds. Corrective Action Plan: To address the delays identified in the R2T4 funds, the following corrective actions will be taken: 1. Revised Procedures o The University will update its written Return of Title IV procedures to clearly define the identification of official and unofficial withdrawals, required timelines for completing R2T4 calculations, and responsibility for initiating, reviewing, and approving calculations. 2. Training for Staff o Financial Aid staff will receive refresher training on Return of Title IV requirements, including withdrawal determination dates and calculation deadlines. o Training materials will be documented for reference and future onboarding. 3. Secondary Review Process o A secondary review of all R2T4 calculations will now be required prior to posting adjustments and returning funds. o The review will be documented and retained with the student’s financial aid file. 4. Ongoing Monitoring o A withdrawal tracking log will be implemented to monitor the date of withdrawal, the date of R2T4 calculation, and the date funds are returned. o The Senior Director Financial Services and Operations will review the log monthly. 5. Timeline for Implementation o Revised procedures will be updated by the Financial Aid Office staff by June 30, 2026. o Staff training sessions: First session scheduled by June 30, 2026, with periodic refreshers as available. o Secondary review processes and ongoing monitoring will begin immediately. 6. Responsible Parties The Vice President for Enrollment and Student Success, Associate Vice President of Enrollment Management, and the Senior Director Financial Services and Operations will oversee the implementation of the corrective action plan. Responsible party contact information is located at uco.edu.

SEFA Audit Response and Corrective Action Plans NSLDS Reporting Errors, Reference 2025-001 Audit Finding: Out of a population of 3,587 students with status changes during the Spring and Fall semesters of the 2025 aid year, 60 were selected for testing. Of the sixteen students with incorrect enrollment information reported, one had the incorrect CIP year reported, four had the incorrect program begin date reported, one had the incorrect enrollment status reported, four had the incorrect program enrollment effective date reported, and six had two or more items reported incorrectly. Of the nineteen students with enrollment status and/or address changes that were not reported timely, fourteen had enrollment statuses not reported timely and five had address changes not reported timely. Our sample was not, and was not intended to be, statistically valid. Cause of the Finding: The University did not have appropriate controls in place to ensure timely and accurate reporting, primarily due to limited staffing within the Registrar’s Office and the absence of a formal secondary review process. Effect of the Finding: The University reported inaccurate information or failed to report changes within the required time frame and, as such, ED was not provided accurate and timely information. Repeat Finding: This finding is a repeat of 2024-001. Corrective Action Plan: To address the errors identified in the NSLDS reporting, the following corrective actions will be taken: 1. Immediate Review and Correction of Existing Data o Conduct a six-month review of federal student aid records to identify and correct any discrepancies in program dates, borrower statuses, and address changes reported to NSLDS. o Work with the SIS vendor and ED to ensure that all data submissions to NSLDS are accurate and complete. 2. System Integration and Process Improvement o Implement a data validation process that cross-checks loan disbursements and borrower statuses against internal records before submitting to NSLDS. o Enhance the SIS to NSLDS data mapping interface to ensure consistency and accuracy of loan-related information between the two systems. 3. Training for Staff o Provide targeted training for financial aid office staff responsible for NSLDS reporting, emphasizing proper data entry practices, system integration, and error-checking protocols. o Review periodic refresher courses to ensure staff remains up to date on any changes to NSLDS reporting requirements. 4. Ongoing Monitoring and Reconciliation o Establish a routine process to reconcile NSLDS data with internal student aid records monthly, ensuring discrepancies are caught and corrected promptly. o Implement a monthly review of the NSLDS submission to confirm all data is up to date, including loan disbursements, borrower status updates, and any adjustments. 5. Timeline for Implementation o Review and correction of existing NSLDS errors, as needed: Completed by June 30, 2026. o System and integration review: Completed by June 30, 2026. o Staff training sessions: First session scheduled by June 30, 2026, with periodic refreshers as available. o Ongoing monitoring process implementation: Ongoing starting immediately. 6. Responsible Parties The Vice President for Enrollment and Student Success, Associate Vice President of Enrollment Management, and the Registrar will oversee the implementation of the corrective action plan. Responsible party contact information is located at uco.edu.

Audit Finding Response – Disbursement Notifications Not Sent (Award Period 2024–2025) Effect / Impact Students did not receive timely notification of their federal aid disbursements for the 24-25 summer term. While the funds were disbursed accurately and timely, the absence of notifications created a compliance gap with federal notification requirements. Cause The failure to send disbursement notifications occurred as a result of a system implementation during the month of June. The system transition impacted the automated notification process, resulting in notifications not being generated or delivered as expected during one disbursement cycle. Corrective Action The issue was quickly identified and resolved. Notifications are currently being sent to students following disbursement of funds. Additionally, the Financial Aid Department has added verification of disbursement notifications to its Quality Assurance (QA) review process. This additional control ensures confirmation that notifications are generated and sent following each federal aid disbursement cycle. The enhanced QA review is currently in place and will be applied to all future disbursement cycles to prevent recurrence. After each major disbursement day, a Financial Aid Specialist will randomly select disbursement records for review. If an error is identified, the specialist will report the issue to the Financial Aid Functional Analyst and the Director of Financial Aid. Conclusion The issue was isolated to the system implementation period and has been addressed through strengthened QA controls. The Financial Aid Department is committed to ongoing monitoring to ensure continued compliance with federal notification requirements. Samantha Freeman Interim Financial Aid Director Ken Birdsong CFO

Finding Number: 2025-001 – Special Tests and Provisions - Enrollment Reporting Auditor Description of Condition and Effect: In our testing of eighteen students, we noted two students who were reported with inaccurate effective dates. The University's reporting process relies on SAP system data for NSLDS reporting, which did not accurately reflect the student’s actual last date of attendance. Auditor Recommendation: We recommend that the University enhance its policies and procedures regarding enrollment reporting to ensure that reporting is completed accurately. Views of Responsible Officials and Planned Corrective Action: Effective immediately following the Office of Technology system updates, the Registrar’s Office and Student Account Services and University Billing (SASUB) will begin utilizing SAP to store R2T4 dates. These dates will automatically populate the monthly National Student Clearinghouse (NSC) enrollment files, improve reporting accuracy, compliance, and the management of withdrawn students. This centralized platform provides authorized users with streamlined access to view pending returns, associated deadlines, and completion dates for each case. The system enhances tracking accuracy, strengthens accountability, and promotes transparency and communication among university stakeholders. Key personnel and leadership from the Registrar’s Office and SASUB will conduct regular reviews to ensure compliance and operational efficiency. Contact person responsible for corrective action: Keith J. Malkowski, Registrar of Registrar’s Office & Brian C. Bell, Director of Student Account Services and University Billing Anticipated Completion Date: 2/28/2026

Incorrect Loan Disbursement Amount Corrective Action Plan: The Financial Aid Services office, in collaboration with IT, has implemented an exception report. This report is received daily, and designed to identify any students whose subsidized and unsubsidized loan awards may not align with their enrollment status, need, and annual loan limit. The goal is to proactivety identify and correct any discrepancies before disbursement to ensure accuracy. Responsible Person for Correction Action Plan: Marlon Jones Jr., Director of Financial Aid Services Implementation Date of Corrective Action Plan: 9/18/2025

Incorrect Pell Disbursement Corrective Action Plan: The Financial Aid Services office, in collaboration with IT, has implemented an exception report. This report is received, daily, and designed to identify any students whose Pell Grant awards may not align with their enrollment status or need. The goal is to proactively identify and correct discrepancies before disbursement to ensure accuracy. Responsible Person for Corrective Action Plan: Erika Guzman, Associate Di rector of Financial Aid Services Implementation Date of Corrective Action Plan: 6/23/2025

Views of Responsible Officials and Corrective Action Plan Responsible Officials: Associate Dean, Financial Aid & Scholarships, Director of Financial Aid & Scholarships Enhanced data on source reports The Associate Dean of Financial Aid & Scholarships, Director of Financial Aid & Scholarships, and System Specialist worked with the MIS (IT) Department to enhance information provided on the reports used by Financial Aid staff to facilitate identifying student withdrawals and initiating the calculation process. Enhanced report will cut down on the need to manually check student information as the Specialist is processing students. New data elements on the report include course and class section information, start and end week, number of units by course, drop date field and the instructor e-mail. Increase frequency of generating the student withdrawal report. The System Specialist has scheduled on their calendar to run the student withdrawal report every week to ensure that the withdrawals are identified in a timely manner and the calculations and returns are completed within the 45-day window. Redistributed department workload; Specialist focused on withdrawal determination/calculation. The Associate Dean has tasked additional office support to assist the System Specialist in the communication follow up with the impacted students, freeing up the System Specialist’s workload to concentrate fully on the withdrawal determination and calculation completion. Monthly review by Associate Dean to confirm adjustments completed for student withdrawals. The Associate Dean will request a monthly report to review and ensure that the calculations and aid adjustments are completed for each student who has withdrawn. This process update will put in place internal checks and balances over the review of the calculations to ensure financial aid funding is returned in a timely manner. The Associate Dean, or their designee, will sign-off that they have reviewed the report each month and file a copy.

National Student Loan Data System (NSLDS) Recommendation: We recommend reviewing the components of the enrollment roster file to ensure the correct effective date is reported correctly for the "Campus Level" as well as making sure records are being timely reported. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Although the Colleague data is correct, the logic in Colleague used to send the files to the NSC is excluding records when the student is not registered for classes in the month an action such as graduation or withdrawal occurs. In that situation the NSC is inserting default dates onto the record based on the last date of their classes in the prior term. We will continue to manually review and correct issues when needed. Name of the contact person responsible for corrective action: Sean Murphy, Registrar Planned completion date for corrective action plan: Already in place.

Due to varying start dates and end dates to the University’s graduate programs, the University will implement a graduate-only NSLDS reporting process to reduce the risk of late reporting. Reports will be run based on semester completion dates to identify graduate students requiring NSLDS reporting, as these dates may not align with standard reporting deadlines. Undergraduate and graduate students who withdraw will continue to be reported promptly, with increased coordination across the various University campuses to identify withdrawals and allow for proper reporting within U.S. Department of Education requirements. Responsible party: Sigrun Olafsdottir, Vice President of Student Financial Services; (603) 899-4186 Anticipated Completion Date: May 31, 2026

The College’s Vice President for Academic Affairs and Dean of the College concurred with the finding identified. The College has revised its policies and procedures as follows: Historically, Student Affairs coded only those students who took a Leave of Absence during the semester (“L”) or withdrew during the semester (“W”). Student Affairs has created a new code (“N”) to track students who inform the college of their intent to withdraw at the end of a given semester. At the end of each semester, Student Affairs provides the Registrar’s Office with a report of all students who informed the college of their intent to unenroll (“L”, “W”, and “N”). Using the report, the Registrar’s Office confirms that all students have been accurately exited with the appropriate exit date and exit reason prior to submitting the final “end of term” report to the National Student Clearinghouse. This new process was implemented beginning in the Fall 2025 semester. The corrective actions will be implemented by Dr. Kristen M. Amick, Registrar. Dr. Amick’s email address is: amickkm@westminster.edu.