Corrective Action Plans

Finding 2025-11 Special Tests and Provisions: NSLDS Reporting – Noncompliance and Significant Deficiency in Internal Control Over Compliance; Planned Corrective Action Plan: APU will strengthen procedures for identifying and reporting enrollment status changes, including degree conferrals occurring outside the normal graduation cycle. Appropriate personnel will periodically review enrollment and graduation activity to identify changes requiring submission to the National Student Clearinghouse and NSLDS, and documentation of the review and reporting will be retained.; Anticipated Completion Date: July 1, 2027

Cluster name: Student Financial Assistance Cluster Assistance Listings numbers and names: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study Program 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Terrance Quest Anticipated completion date: June 30, 2027 The District concurs with the findings and recommendations. The District recognizes the importance of submitting complete and accurate Fiscal Operations Report and Application to Participate (FISAP) information to the U.S. Department of Education and maintaining appropriate internal controls over the preparation, review, and submission of federally required reports. The Financial Aid Office is implementing new processes to ensure that the FISAP report is submitted accurately. The District is working with the Department of Education to correct the FISAP that covers the Award Year July 1, 2024 through June 30, 2025. The corrective actions are expected to be implemented in FY2026-2027 and include: 1. Detailed written procedures that govern the preparation and submission of the FISAP report and provide guidance for all parties involved in the FISAP reporting process. 2. Implementation of standardized data sourcing and collection to reduce errors. 3. Independent secondary review and approval to confirm that the report has been prepared in accordance with the new procedures and has appropriate supporting documentation. 4. Internal annual compliance review following the FISAP submission to ensure that all procedures were followed properly and evaluate the current process for any additional improvements.

Cluster name: Student Financial Assistance Cluster Assistance Listings numbers and names: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study Program 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Terrance Quest Anticipated completion date: June 30, 2027 The District concurs with the findings and recommendations. The District recognizes the importance of ensuring Student Financial Assistance credit balances are disbursed to students or parent timely. Since the error took place in October 2024, the District has implemented a new report to properly notate all credit balance in the system. This report is monitored and reviewed regularly to ensure that all student credit balances are paid back within the required 14-day time frame.

Cluster name: Student Financial Assistance Cluster Assistance Listings numbers and names: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study Program 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Terrance Quest Anticipated completion date: June 30, 2027 The District concurs with the findings and recommendations. The District recognizes the importance of ensuring that enrollment statuses and status changes for the Pell and Direct Loan programs are reported timely to the National Student Loan Data System (NSLDS). In Fall 2024, the National Student Clearinghouse changed the processing for enrollment for nonrequired terms. This change affected the logic for the enrollment status start dates at the campus and program levels. To remain in compliance and proactively address the data sources changes, the District updated report queries. However, this update resulted in unanticipated errors with the report. The District has since reevaluated and updated the reporting logic to reflect the errors outlined in the audit and will continue to monitor reporting to ensure that compliance is maintained

Cluster name: Student Financial Assistance Cluster Assistance Listings numbers and names: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study Program 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Terrance Quest Anticipated completion date: June 30, 2027 The District concurs with the findings and recommendations. The District recognizes the importance of ensuring that Return of Title IV Funds (R2T4) calculations are completed accurately and timely, that all applicable institutional charges are included in the calculations, and that required institutional and student returns and notifications are completed within the federally established timeframes. The District has taken corrective action regarding the specific students identified during the audit and has returned the applicable funds to the U.S. Department of Education. In addition, the Financial Aid Office is implementing enhanced procedures and system controls designed to address the underlying causes of the finding and strengthen ongoing compliance with federal R2T4 requirements. The updated procedures are expected to be implemented in FY2026-2027 and include: 1. Additional withdrawal monitoring and tracking added to the Return of Title IV (R2T4) reporting. 2. Secondary independent review of the calculation prior to the notification that is sent to students. 3. Implementation of internal automation system connected to the student information system to improve accuracy and reduce the risk of errors in the R2T4 calculation. 4. Tracking and monitoring student notifications and returns to meet required deadlines. 5. Ongoing monitoring of R2T4 activities to evaluate new procedures alignment with compliance requirements.

Finding 2025-005: Fiscal Operations Report and Application to Participate (FISAP) Reporting | Name of Contact Person: Jared Smith, Dean of Student Affairs and Enrollment Management & Amy Brown, Director of Financial Aid | Corrective Action Plan: Carolinas College is implementing PowerFAIDS as its new student financial aid management system, with deployment anticipated in August 2027. The new platform is expected to enhance reporting capabilities and address limitations within the current Jenzabar Financial Aid system related to reporting, disbursement verification, and record retention. Until implementation is complete, management will maintain supplemental documentation, including manual records and supporting screenshots, to support the accuracy and completeness of financial aid reporting and related compliance requirements. Additionally, management will perform periodic reviews of reporting outputs to help ensure key reporting information is retained and available for monitoring and audit purposes. | Proposed Completion Date: Management expects interim remediation through enhanced manual documentation and monitoring procedures by December 31, 2026. Following the implementation of PowerFAIDS in August of 2027, a full remediation is expected to be completed by December 31, 2027. Due to the academic-year operating cycle, the College is unable to transition financial aid systems during the middle of an active award year, making a phased implementation approach necessary.

Finding 2025-004: Gramm-Leach-Bliley Act (GLBA) – Student Information Security Controls | Name of Contact Person: Jared Smith, Dean of Student Affairs and Enrollment Management & Amy Brown, Director of Financial Aid | Corrective Action Plan: Atrium Health CMHA management has remediated this finding through the implementation of multifactor authentication (MFA) controls for the Student Information System (SIS) in February 2026. Following implementation, the SIS successfully underwent internal security review procedures in 2026, confirming that the required controls were operating as designed. Management will continue to monitor these controls as part of its ongoing information security and compliance program. | Proposed Completion Date: Completed February 2026.

Finding 2025-003: Notification of Disbursements to or on Behalf of Students | Name of Contact Person: Jared Smith, Dean of Student Affairs and Enrollment Management & Amy Brown, Director of Financial Aid | Corrective Action Plan: Atrium Health CMHA management will work with the current financial aid system vendor to identify options for retaining and retrieving disbursement notification letters and related documentation. Management will also implement supplemental procedures, as necessary, to support the retention and accessibility of these records. As a long-term solution, the College plans to transition to the PowerFAIDS financial aid management system, which is expected to provide enhanced document retention and retrieval capabilities and address the deficiencies identified in this finding. | Proposed Completion Date: Management expects to implement interim remediation measures within the current system by December 31, 2026. Following the implementation of PowerFAIDS in August of 2027, a full remediation is expected to be completed by December 31, 2027. Due to the academic-year operating cycle, the College is unable to transition financial aid systems during the middle of an active award year, making a phased implementation approach necessary.

Finding 2025-002: SFA Review and Approval of Internal Controls over Cash Management, Eligibility, Enrollment Reporting | Name of Contact Person: Jared Smith, Dean of Student Affairs and Enrollment Management & Amy Brown, Director of Financial Aid | Corrective Action Plan: Atrium Health CMHA management will strengthen oversight of Student Financial Assistance compliance by improving internal controls over Student Financial Aid (SFA) systems, National Student Clearinghouse reporting, and National Student Loan Data System (NSLDS) processes. Designated personnel will be assigned accountability for each area to ensure key controls are performed consistently and monitored appropriately. In addition, management will develop and implement written standard operating procedures (SOPs) to support compliance with cash management, eligibility, and enrollment reporting requirements. | Proposed Completion Date: Management expects to complete the development and implementation of the SOPs and formal assignment of control responsibilities by December 31, 2026.

Finding 2025-001: Internal controls within the Student Financial Assistance (SFA) IT Systems | Name of Contact Person: Jared Smith, Dean of Student Affairs and Enrollment Management & Amy Brown, Director of Financial Aid | Corrective Action Plan: Carolinas College is implementing PowerFAIDS as its new student financial aid management system, with deployment anticipated in August 2027. The new platform is expected to address limitations in the current Jenzabar Financial Aid system related to reporting capabilities, disbursement verification, and record retention. Until implementation is complete, management will utilize supplemental manual procedures, including maintaining supporting documentation and screenshots, to ensure adequate documentation of eligibility determinations, reporting, and disbursement activities. | Proposed Completion Date: Management expects interim remediation through enhanced manual recordkeeping procedures by December 31, 2026. Following the implementation of PowerFAIDS in August of 2027, a full remediation is expected to be completed by December 31, 2027. Due to the academic-year operating cycle, the College is unable to transition financial aid systems during the middle of an active award year, making a phased implementation approach necessary.

The Children Service Department will seek legal advice on the implementation of a policy that meets the requirements set for in 2 CFR 200.302(b)(7) for determining the allowability of costs in accordance with Subpart E-Cost Principles.

Cambria County has continued with the following actions which include: maintaining a list of reporting due dates for all fiscal and administrative staff; engagement of external consultants and temporary fiscal staff to support reporting functions if there is staff departure; retain and support existing County staff to maintain institutional knowledge until a dedicated competent Fiscal Officer who is invested in child welfare and county government employment is identified. The department will continue to ensure audit components are included for submissions. The department maintained and will continue communication with oversight entities to ensure transparency regarding reporting timelines, submission delays, fiscal status and corrective actions taken to uphold integrity. These delays were not due to negligence, but rather a strategic and collaborative effort to ensure accuracy and completeness of all required documentation. The department prioritized the integrity of submissions to meet federal audit standards and reimbursement eligibility. These submissions were completed to ensure compliance and to position the CYS department for improved timeliness in the 2025 audit year. The department prioritized accuracy and completeness, ensuring required audit components were included. Please note: Reviewing the audit findings and reporting processes from FY2024 & FY2025 demonstrates a significant improvement in the department’s fiscal operations and compliance efforts as well as to ensure federal audit standard. The accounting team has shown a strong commitment to improving the accuracy, timeliness, and quality of fiscal reporting. Through increased oversight, enhanced monitoring of reporting deadlines, and ongoing collaboration with administrative staff, the department has strengthened its internal controls and reporting practices.

Cambria County has continued with the following actions which include: maintaining a list of reporting due dates for all fiscal and administrative staff; engagement of external consultants and temporary fiscal staff to support reporting functions if there is staff departure; retain and support existing County staff to maintain institutional knowledge until a dedicated competent Fiscal Officer who is invested in child welfare and county government employment is identified. The department will continue to ensure audit components are included for submissions. The department maintained and will continue communication with oversight entities to ensure transparency regarding reporting timelines, submission delays, fiscal status and corrective actions taken to uphold integrity. These delays were not due to negligence, but rather a strategic and collaborative effort to ensure accuracy and completeness of all required documentation. The department prioritized the integrity of submissions to meet federal audit standards and reimbursement eligibility. These submissions were completed to ensure compliance and to position the CYS department for improved timeliness in the 2025 audit year. The department prioritized accuracy and completeness, ensuring required audit components were included. Please note: Reviewing the audit findings and reporting processes from FY 2024 & FY 2025 demonstrates a significant improvement in the department's fiscal operations and compliance efforts as well as to ensure federal audit standard. The accounting team has shown a strong commitment to improving the accuracy, timeliness, and quality of fiscal reporting. Through increased oversight, enhanced monitoring of reporting deadlines, and ongoing collaboration with administrative staff, the department has strengthened its internal controls and reporting practices.

Finding 2025-001: CFDA #93.658 Foster Care, Title IV-E CFDA #93.659 Adoption Assistance Corrective Action: Management intends to implement procedures to improve document retention, electronic record storage, supervisory review, and overall monitoring controls for the Foster Care and Adoption Assistance programs. Contact: Randy Lozier, County Treasurer Anticipated Completion Date: By December 31, 2026

Cambria County has continued with the following actions which include: maintaining a list of reporting due dates for all fiscal and administrative staff; engagement of external consultants and temporary fiscal staff to support reporting functions if there is staff departure; retain and support existing County staff to maintain institutional knowledge until a dedicated competent Fiscal Officer who is invested in child welfare and county government employment is identified. The department will continue to ensure audit components are included for submissions. The department maintained and will continue communication with oversight entities to ensure transparency regarding reporting timelines, submission delays, fiscal status and corrective actions taken to uphold integrity. These delays were not due to negligence, but rather a strategic and collaborative effort to ensure accuracy and completeness of all required documentation. The department prioritized the integrity of submissions to meet federal audit standards and reimbursement eligibility. These submissions were completed to ensure compliance and to position the CYS department for improved timeliness in the 2025 audit year. The department prioritized accuracy and completeness, ensuring required audit components were included. Please note: Reviewing the audit findings and reporting processes from FY2024 & FY2025 demonstrates a significant improvement in the department’s fiscal operations and compliance efforts as well as to ensure federal audit standard. The accounting team has shown a strong commitment to improving the accuracy, timeliness, and quality of fiscal reporting. Through increased oversight, enhanced monitoring of reporting deadlines, and ongoing collaboration with administrative staff, the department has strengthened its internal controls and reporting practices.

Cambria County has continued with the following actions which include: maintaining a list of reporting due dates for all fiscal and administrative staff; engagement of external consultants and temporary fiscal staff to support reporting functions if there is staff departure; retain and support existing County staff to maintain institutional knowledge until a dedicated competent Fiscal Officer who is invested in child welfare and county government employment is identified. The department will continue to ensure audit components are included for submissions. The department maintained and will continue communication with oversight entities to ensure transparency regarding reporting timelines, submission delays, fiscal status and corrective actions taken to uphold integrity. These delays were not due to negligence, but rather a strategic and collaborative effort to ensure accuracy and completeness of all required documentation. The department prioritized the integrity of submissions to meet federal audit standards and reimbursement eligibility. These submissions were completed to ensure compliance and to position the CYS department for improved timeliness in the 2025 audit year. The department prioritized accuracy and completeness, ensuring required audit components were included. Please note: Reviewing the audit findings and reporting processes from FY 2024 & FY 2025 demonstrates a significant improvement in the department's fiscal operations and compliance efforts as well as to ensure federal audit standard. The accounting team has shown a strong commitment to improving the accuracy, timeliness, and quality of fiscal reporting. Through increased oversight, enhanced monitoring of reporting deadlines, and ongoing collaboration with administrative staff, the department has strengthened its internal controls and reporting practices.

In response to the deficiencies noted in the audit findings referenced above, management has established a comprehensive framework of inter-departmental controls, routine reconciliations, and independent quality assurance testing. To ensure the absolute accuracy and alignment of records, Financial Aid (FA) and Student Accounts (SA) personnel conduct mandatory monthly reconciliation meetings. During this collaborative process, both departments verify that all federal aid disbursements are properly recorded on the student’s ledger with the correct transactional dates, ensuring perfect alignment with records in the COD system. Supplementing this process, the Financial Aid Office performs independent monthly random spot checks of disbursements directly within the COD system to verify that record dates mirror the actual transaction dates on the student accounts ledger. During these same spot checks, FA personnel validate core academic parameters by cross-referencing student enrollment dates and loan period dates against the official institutional academic calendar, while simultaneously reviewing Cost of Attendance (COA) figures to ensure strict adherence to each student's official award letter. To maintain compliance and reporting during non-standard operational shifts, the Financial Aid Office collaborates immediately with Global Financial Services, our third-party servicer, to update federal records in a timely manner whenever academic dates are modified later than normal. Furthermore, to strengthen institutional data integrity and eliminate enrollment reporting gaps, the Financial Aid Office and the Office of the Registrar participated in joint training sessions focused on National Student Clearinghouse (NSC) and NSLDS reporting mechanics to optimize data transmissions between platforms. As an ongoing monitoring control, the Financial Aid Office now executes an independent monthly random sampling of student records directly from NSLDS. This routine sampling allows management to verify that enrollment statuses are being transmitted accurately and seamlessly from the Clearinghouse to NSLDS

The College will implement enhanced controls to ensure that Title IV credit balances are identified, monitored, and refunded within the required 14 day timeframe. The Student Financial Services team will establish a formal credit balance monitoring process. A designated staff member will review student accounts on a routine basis to identify accounts with credit balances and document the date each credit balance was created. A centralized tracking mechanism will be maintained to identify the required refund deadline and document the date the refund was processed. To provide additional oversight, the following controls will be implemented: • Student accounts with credit balances will be reviewed at least twice weekly. • Each identified credit balance will be recorded on a Credit Balance Monitoring Log that includes the student, date the credit balance occurred, amount, required refund date, actual refund date, and responsible staff member. • Accounts approaching the 14 day deadline will be escalated to Student Financial Services leadership for immediate review and resolution. • The Director of Financial Aid and appropriate Student Accounts staff will conduct a monthly reconciliation and supervisory review to verify that required refunds were completed timely. • Documentation supporting the review and reconciliation process will be retained as evidence that the control was performed. • Staff responsible for financial aid disbursements, student accounts, and credit balance refunds will receive annual training on Title IV credit balance requirements and the College’s internal control procedures. • The Dean of Student Success will conduct periodic management reviews during the first year of implementation to verify that the controls are operating as designed and address any identified exceptions.Because this is a repeat finding from the prior audit year, the College will also review the underlying workflow and Student Information System configuration to determine whether additional automated reporting or alerts can be implemented to reduce reliance on manual identification of credit balances.

The Registrar’s Office maintains primary responsibility for submitting student enrollment statuses to the National Student Clearinghouse (NSC) and providing timely status updates (graduations, withdrawals, and Leaves of Absence [LOA]) to the Financial Aid Office. To ensure the accuracy and integrity of these transmissions, the following controls and ongoing systemic corrections have been established: • Pre-Submission Validation Control: The Registrar has implemented a mandatory data validation process. Whenever a student is processed as a withdrawal or placed on an LOA, the corresponding Clearinghouse data extract is reviewed prior to transmission. This control verifies that the student’s enrollment status and effective date are entirely accurate before final submission to the NSC.Ad-Hoc Adjustments: Any enrollment status changes that occur outside of the standard, scheduled reporting cycle are updated directly in the NSC secure portal on an ad-hoc basis to prevent reporting lags. • Systemic Technical Resolution: The Registrar’s Office has identified a technical issue within the Student Information System (SIS) data extraction logic that leaves the program-level status blank for students on LOA. The Registrar’s Office is actively collaborating with the SIS vendor and our Academic Data Warehouse Administrator to isolate the root cause and modify the extraction script. This vendor resolution is currently ongoing, and final implementation to correct the extract data mapping is underway. Additionally, The Financial Aid Office is responsible for downstream validation, ensuring that enrollment statuses and effective dates match across internal systems and federal databases, including the Common Origination and Disbursement (COD) system and the National Student Loan Data System (NSLDS). To satisfy the federal 60-day notification requirement, the Financial Aid Office executes the following quality assurance framework: • Reconciliation Sampling: Routine validation samples are compiled using the Student Status Confirmation Report (SSCR) from the NSC alongside internal status change notifications provided by the Registrar. • Proactive Review Timeline: Sample testing is conducted precisely 30 days post-notice of graduation or separation from the college. This 30-day window provides a compliance buffer, allowing the Financial Aid team to identify, research, and correct any reporting discrepancies well before the federally mandated 60-day NSLDS reporting deadline.

Corrective Action Plan for Fiscal Year Ending December 31, 2025 Institution: ICOHS College OPE ID #: 04265500 Audit Period: January 1 – December 31, 2025 Date of CAP Submission: 09/24/2026 Finding 2025-001 – Reporting (COD Date Disbursed) Programs: Student Financial Assistance Cluster – Federal Direct Loans (84.268), Federal Pell Grant (84.063) Type of finding: Significant deficiency in internal control over compliance; noncompliance Questioned costs: None Cause. Under Heightened Cash Monitoring 1 (HCM1), the College credits Title IV aid to student accounts using institutional funds before requesting reimbursement from the Department of Education. The College interpreted the COD Date Disbursed as the later date associated with COD processing or federal reimbursement rather than the date the funds were credited to the student’s ledger account. The College also lacked a formal reconciliation between the student ledger and COD that would have detected the difference. Corrective Action 1. Immediate change in reporting practice Effective September 28, 2026, the Financial Aid Office will report the COD Date Disbursed as the date Title IV funds are credited to the student’s ledger account, including when institutional funds are used in advance of reimbursement under HCM1. Disbursement records will be reported to COD within the Department’s required timeframe. 2. Updated written disbursement procedure The College will update its written Title IV disbursement procedure to define the disbursement date as the date Title IV funds are credited to the student’s account or paid directly to the student or parent (34 CFR 668.164(a)), and to distinguish anticipated or estimated aid entries from actual disbursements. The procedure will identify who prepares, reviews and approves each step. 3. Staff training Business Office and Financial Aid staff responsible for Title IV disbursements and COD reporting will be trained on the revised procedure, including the treatment of institutional funds used to make Title IV disbursements under HCM1. Attendance will be documented. 4. COD-to-ledger reconciliation for every disbursement cycle For each disbursement cycle, the Financial Aid Office will complete a reconciliation (maintained as the College’s Title IV disbursement tracker) comparing: • Student name and ID • Title IV fund type • Disbursement amount • Student ledger credit date • COD Date Disbursed • COD status (accepted / rejected / pending) Any difference is researched and corrected in COD before the reconciliation is marked complete. The tracker documents each exception, its cause and the correction made. 5. Independent review and sign-off A Business Office staff member who did not prepare the disbursement will review each completed reconciliation and document approval with name and date. Exceptions will be resolved before sign-off. 6. Lookback review of 2025 and 2026 disbursements The Financial Aid Office and Business Office will compare the COD Date Disbursed with the ledger credit date for all Title IV disbursements made from January 1, 2025 through the effective date of the corrected practice. Results will be documented by student and disbursement. 7. Correction of prior records in COD Discrepancies identified in the lookback review will be corrected in COD to reflect the date funds were credited to the student’s account, to the extent permitted by COD and in accordance with Department of Education requirements. Any records that cannot be corrected will be documented with the reason. 8. Monitoring and evidence retention Tim Tandio (Operations & Compliance) will review the reconciliations and tracker monthly and report results to the Executive Director quarterly. Reconciliations, sign-offs, the tracker, lookback results and training records will be retained for audit and program review. Timeline Action Responsible Target completion 1. Report COD Date Disbursed as the ledger credit date Financial Aid Office Effective September 28, 2026 2. Update written Title IV disbursement procedure Financial Aid Office / Business Office; approved by Tim Tandio October 15, 2026 3. Staff training on revised procedure Tim Tandio October 15, 2026 4–5. COD-to-ledger reconciliation and independent review Financial Aid Office (prepare); Business Office (review) First disbursement cycle after September 28, 2026, and every cycle thereafter 6. Lookback review of 2025 and 2026 disbursements Financial Aid Office / Business Office Review complete by November 30, 2026 7. Correct discrepancies in COD Financial Aid Office Submitted by December 31, 2026, to the extent permitted by COD 8. Monitoring and evidence retention Tim Tandio; Executive Director Monthly and quarterly, ongoing Prior Year findings: Finding 2024-001 – Special Tests and Provisions – Enrollment Reporting Status: Corrected Corrective action was implemented to strengthen the College’s enrollment reporting procedures, including monitoring and timely reporting of enrollment status changes to NSLDS. Based on the results of the 2025 audit, no findings related to enrollment reporting were identified. Finding 2024-002 – Special Tests and Provisions – Return of Title IV Funds Status: Corrected Corrective action was implemented to strengthen the monitoring and timely processing of Return of Title IV Funds (R2T4), including additional oversight of the third-party service provider and internal monitoring procedures. Based on the results of the 2025 audit, no findings related to the timely return of Title IV funds were identified.

Finding 2025-003: Late Refunds- Student Financial Assistance Cluster - Federal Direct Student Loans -ALN # 84.268 - Year Ended December 31, 2025 Criteria: The Department of Education requires that all refunds be made within 45 days of a student’s withdrawal (34 CFR 668.22, 685.306). Condition: Sikich tested four drop students in our sample and noted two late refunds. This finding is considered to be a material weakness and an instance of noncompliance. This finding was not a repeat finding. Recommendation: We recommend the College increase controls over monitoring drop students and paying refunds. Responsible Person: Dr. Jessica Fritz, Bridgette McGuire, Denise Land, DJ Kramer, Derrick Phillips Corrective Action Plan: DRCOM has implemented increased controls over the R2T4 process through increased and timely communication between various departments involved in the drop process and LOA’s. These departments are the Academic Dean, Registrar, Financial Aid, IT, and Student Accounts Implementation Date: 08/01/2026

Finding 2025-002: Financial Responsibility - Student Financial Assistance Cluster - Federal Direct Student Loans - ALN # 84.268 - Year Ended December 31, 2025 Criteria: An accredited school that participates in Federal programs authorized by Title IV of the Higher Education Act of 1965 is required to demonstrate minimum standards of financial responsibility set forth by the U.S. Department of Education (DOE). Condition: The College did not meet the minimum Composite Score set forth by the U.S. Department of Education for the year ended December 31, 2025. We consider this finding to be a material weakness and an instance of noncompliance. This finding is repeated and was reported in the prior year as Finding 2024-002. Recommendation: The College needs to monitor its financial responsibility ratios throughout the year. Responsible Person: Dorian G. Kramer, DJ Kramer, Jennifer Hogan Corrective Action Plan: The college continues to monitor its financial responsibility ratios through the aforementioned financial accountability plans. As well, DRCOM has continued to improve its financial soundness through 2026 through multiple approaches, including a professional third-party assessment and plan implementation for increasing admissions, restructuring of debt, donor recruitment, hiring of a new clinic manager to increase income in the student clinic, and exploring other revenue streams for the college Implementation Date: Overall plan has been in place since 08/2024, with a reassessment of all strategies at the beginning of each semester.

Following the NSC security breach and incorrect institution linking, the College worked with NSC to restore the correct connection, which was resolved in November 2023. The Registrar redeveloped reporting queries and resumed accurate submissions in June 2024. Enhanced processes now allow files to be reviewed, corrected, and finalized within approximately one week, and all reporting was brought current by the end of 2025.

Student Financial Aid Cluster – Special Tests and Provisions – NSLDS Recommendation: We recommend that the College continue to enhance its policies and procedures regarding enrollment reporting including additional monitoring over the third-party service provider to ensure that reporting is completed accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Office of the Registrar reports enrollment to NSLDS using the National Student Clearinghouse (NSC). The Office of the Registrar has added a Systems Analyst position, who is now responsible for Clearinghouse submissions, including enrollment reporting and monitoring and resolving errors. As recommended by CLA, the Registrar’s Office is reviewing its process for Clearinghouse submissions with support from our software provider Jenzabar, the National Student Clearinghouse, and the College’s Information Technology Department and Advising Office to ensure that enrollment reporting and error resolution is accurate and timely. Recommended changes to the enrollment reporting were adopted and added to the written procedures. The College reviewed the instances identified in the audit and determined that they resulted from one enrollment file submitted to the National Student Clearinghouse (NSC) that was rejected. At the time, the FTP submission method did not provide the submitting employee with a readily visible processing status, and the rejection notice was sent to a former institutional contact. The College has transitioned to the NSC's Data Upload tool, which displays the processing status of submitted enrollment files. Following each submission, the Registrar Systems Analyst now verifies that the file was successfully processed and addresses any rejection or processing error promptly. Name(s) of the contact person(s) responsible for corrective action: Rachel Nielson (Registrar Systems Analyst), Nicholas Jobe (Registrar), and Sheia Pleasant (Financial Aid Director). Planned completion date for corrective action plan: February 11, 2026 If the U.S. Department of Education, State of Florida or Florida Department of Education have questions regarding these plans, please call Sheia Pleasant at (904) 819-6435

Student Financial Aid Cluster – Special Tests and Provisions – Credit Balance Recommendation: We recommend that the College reviews its internal control processes for improvements and to detect potential non-compliance issues related to timeliness. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Student refund payments will be prioritized for processing at the first payment date following notification of the credit balance. To ensure continuity of operations during employee absences, leave, and staffing transitions, the College has established authorization for multiple individuals to review and approve refund payments. Additionally, the College has enhanced its refund monitoring procedures. Following each refund batch submission, the Student Accounts Office will monitor and verify that EFT transactions and/or paper checks have been successfully processed and completed within the required 14-day timeframe. The College expects these enhancements to promote the timely and consistent processing of credit balance refunds and to reduce the risk of future delays resulting from staffing availability or processing issues. Name(s) of the contact person(s) responsible for corrective action: Brittney Percival (Director of Students Account) and Theresa Lincoln (Controller) Planned completion date for corrective action plan: Ongoing and effective immediately.