Corrective Action Plans

Responsible Official’s Response and Corrective Action Planned: We agree with the finding and recommendations.  All monies owed, will be paid back to the department.  Thomas University is actively searching for a qualified individual to fill the role of Director of Financial Aid, and interview is being held with a high potential candidate on Friday June 25, 2026.  Thomas University will revise and document Return of Title IV Funds procedure to ensure calculations are completed in accordance with 34 CFR 668.22 requirements.  Establish standardized processes for determining withdrawal dates, enrollment status, and earned versus unearned Title IV aid.  A secondary review process requiring a qualified financial aid administrator to review and approve all calculations before funds are returned or adjustments are processed.  Increase coordination between Financial Aid office, Registrar Office, and Business office to endure timely communication of attendance and withdrawal information.  Staff will be required to participate in periodic federal compliance training and regulatory update sessions. Planned Implementation Date of Corrective Action: December 31, 2026. Person Responsible for Corrective Action: Kurt Stringfellow, President

Finding 2025-005 - Untimely Release of Title IV Credit Balances (Significant Deficiency): Condition - During testing of student account activity, we identified that fourteen (14) out of sixty (60) sampled students had Title IV created credit balances that remained on their accounts for more than 14 days without being released to the student or parent. All refunds were eventually released to the students. Corrertive Action Plan The College experienced significant staff turnover within the business office. In addition, the College is undergoing conversion to a new Enterprise Resource Planning (ERP) system which affected its ability to complete some functions within a timely manner. A new bursar was hired in May 2026. Timely processing of student refunds was emphasized during her training. Going forward, student refunds will be released within 14 days after credit balances are reflected on student accounts." Completion Date - September 30, 2026 Responsible Party - Chief Financial Officer

Identification: 10.766 United States Department of Agriculture (USDA), Community Facilities Loans and Grants; Noncompliance Finding; Special Tests and Provisions Corrective Action Plan: The Medical Center will take the necessary steps outlined in the bond indenture and retain a financial consultant to review operations and make recommendations to restore the days cash on hand ratio above the minimum requirement. Anticipated completion date: The Medical Center has engaged a financial consultant and will work with the consultant during 2026 to improve operations.

Federal Agency: U.S. Department of Education Federal Program: Student Financial Assistance Cluster Assistance Listing Number: Various Federal Award Numbers: Various Finding No.: 2025-004 Corrective Action Plan: The identified conditions relate to students who experienced a change in status code within the Union College system specifically related to graduation and withdrawal dates. A report that includes status code changes will be reconciled with student status changes transmitted by the National Student Clearinghouse (NSC) to the National Student Loan Database System (NSLDS), and any necessary corrections will be made in the appropriate time frame. Timeline for Implementation of Corrective Action Plan: The corrective action plan was implemented at the end of the Spring 2026 term.

2025-001 Student Financial Assistance Cluster – Assistance Listing No. 84.SFA Condition: The College did not report information to NSLDS in a timely manner, enrollment was not being certified every 60 days, and information being reported was inaccurate. Recommendation: Management should review and update internal control processes over NSLDS reporting. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The college’s financial aid team has scheduled time for NSLDS reporting until the National Student Clearinghouse reporting has been confirmed by the Department of Education. Name(s) of the contact person(s) responsible for corrective action: Wendy Davis Planned completion date for corrective action plan: 06/26/2026

During the 2025 audit, the auditors discovered that a secondary review of eligibility determinations did not occur in a timely manner. The lack of internal control opened the possibility that an individual was incorrectly determined to be eligible to receive benefits and this error would not have been identified or corrected in a timely manner. Federal Regulations establish requirements for internal control over compliance with Federal program requirements. 2 CFR Section 200.303 requires non-Federal entities to establish and maintain effective internal control over Federal awards that provides reasonable assurance the entity is managing the award in compliance with Federal statutes, regulations, and the terms and conditions of the award. These requirements include the design, implementation, and operation of control activities to ensure compliance with applicable compliance requirements, including eligibility. As eligibility is a key compliance requirement identified in the OMB Compliance Supplement, the County is required to implement a review process and system of internal controls that allows management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, errors or noncompliance in eligibility determinations on a timely basis. The Department of Human Services (DHS) has implemented a monthly review process to audit a random sample of the IV-E cases. The review includes verification of timely and accurate determinations, client information, supporting documentation, and system entries, with results documented and approved by the reviewer. DHS Division leadership will monitor compliance to ensure the reviews are conducted each month. DHS believes this additional review procedure will provide the needed internal controls over IV-E determination.

Tyler Luce, Executive Vice President & CFO, respectfully submits the following corrective action plan for the year ended September 30, 2025. Name and address of independent public accounting firm: Maner Costerisan, P.C. 2425 E. Grand River Ave, Ste 1 Lansing, MI 48912 Audit period: October 1, 2024 – September 30, 2025 The findings from the September 30, 2025 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Finding 2025-001 Recommendation: The entity should design and implement stronger internal controls over project funds, including enhanced segregation of duties, documented procurement procedures, conflict-of-interest monitoring, and periodic independent review of project expenditures to ensure compliance with Uniform Guidance. Management Comments: We agree with the facts and circumstances of this finding. Management has taken corrective action in response to this finding. The employees involved are no longer employed in connection with the project, and the matter was reported to the HUD Office of Inspector General. Management has reviewed and strengthened the project's controls over conflict-of-interest monitoring and enforcement of existing time-clock policies. In addition, we have and will continue to perform independent reviews of project expenditures to ensure compliance with Uniform Guidance.

The College acknowledges the finding and agrees that required notifications to students must be provided prior to the disbursement of Title IV funds. The condition resulted from the absence of formal procedures and controls to ensure timely notification and documented review. The College is in the process of implementing enhanced controls over student notification procedures. Formal policies and procedures will be established to ensure that notifications are generated and delivered prior to disbursement, including defined timing, content, and documentation requirements. The College will engage third-party consultants and implement system enhancements to improve the timing and sequencing of notifications and disbursements. In addition, the College will implement monitoring procedures, including tracking of notification and disbursement dates and documented supervisory review, to ensure compliance with timing requirements and timely identification and resolution of exceptions. Accounting, independent of the Office of Financial Aid, will perform a final review to verify that notifications are issued prior to disbursement and that established procedures are consistently followed. Implementation of these procedures began in April 2026 and was not in place for the full fiscal year. Fiscal year 2026 represents a transition period during which controls are being implemented and refined. Full implementation is expected for the 2026–2027 award year. These actions are intended to ensure that required notifications are provided timely and in accordance with federal requirements, and to prevent recurrence

The College acknowledges the finding and agrees that verification procedures must include documented evidence of completion and supervisory review. The condition resulted from the absence of formal procedures and lack of retained documentation evidencing completion and review of verification activities. The College is in the process of implementing enhanced controls over verification procedures. Formal policies and procedures will be established to define responsibilities, documentation requirements, and supervisory review expectations. Each verification file will require documented evidence of completion and review, including electronic sign-off or system-based approval. In addition, the College will implement quality control measures, including systematic validations and periodic supervisory reviews, with documentation retained to evidence the scope and results of such reviews. Implementation of these procedures began in April 2026 and was not in place for the full fiscal year. Fiscal year 2026 represents a transition period during which controls are being implemented and refined. Full implementation is expected for the 2026–2027 award year. These actions are intended to ensure that verification procedures are consistently applied, properly documented, and subject to appropriate review, and to prevent recurrence.

The College acknowledges the finding and agrees that Return of Title IV Funds (R2T4) calculations and related return activity must be accurately calculated, properly documented, and fully traceable. The condition resulted from the absence of formal procedures, lack of documented supervisory review, and insufficient documentation and reconciliation of student-level return activity. The College is in the process of implementing enhanced controls over the R2T4 process. A monthly structured workflow has been established whereby the Office of Financial Aid prepares and provides a detailed listing of students subject to R2T4 calculations, including institutional return amounts. Accounting independently reviews and verifies the calculated return amounts and processes the return through the federal system, with documented review and approval. The College has eliminated undocumented manual netting adjustments and requires that all R2T4 returns be recorded as distinct transactions supported by a standardized documentation package, including studentlevel calculations, withdrawal determination dates, and institutional return amounts. All activity is maintained in a centralized electronic repository to ensure a complete audit trail. In addition, the College is formalizing written procedures to define roles and responsibilities, establish documentation standards, and require documented supervisory review and approval. Periodic reconciliations will be performed to ensure that student-level return amounts agree to system activity and federal cash activity. Implementation of these procedures began in April 2026 and was not in place for the full fiscal year. Fiscal year 2026 represents a transition period during which controls are being implemented and refined. Full implementation is expected for the 2026–2027 award year. These actions are intended to ensure that R2T4 calculations and returns are accurate, properly documented, fully traceable, and compliant with federal requirements, and to prevent recurrence.

The College acknowledges the finding and agrees that reporting to the Common Origination and Disbursement (COD) system must be accurate, complete, and submitted within required timeframes. The condition resulted from the absence of formal procedures and controls to validate key data elements and monitor reporting timeliness. The College is in the process of implementing enhanced controls over COD reporting. The Office of Financial Aid will develop and formalize written procedures governing the reconciliation of awarding and disbursement activity with COD reporting, including defined responsibilities, documentation standards, and review requirements. The College will also engage third-party consultants to review current processes and assist with system enhancements. System configuration and process improvements will be implemented to support the automation of award and disbursement reporting through PeopleSoft. The Office of Financial Aid will implement quality control measures, including systematic validations and documented supervisory review, to ensure accuracy, consistency, and compliance in COD reporting. Implementation of these procedures began in April 2026 and was not in place for the full fiscal year. Fiscal year 2026 represents a transition period during which controls are being implemented and refined. Full implementation is expected for the 2026–2027 award year. These actions are intended to ensure that COD reporting is accurate, timely, and properly controlled, and to prevent recurrence.

The College acknowledges the finding and agrees that Cost of Attendance and Satisfactory Academic Progress determinations must be calculated, documented, and reviewed in accordance with federal requirements. The condition resulted from reliance on manual processes, lack of retained supporting documentation, and absence of independent review and approval. The College is in the process of implementing enhanced controls over COA and SAP determinations. Formal policies and procedures will be established to define methodologies, documentation requirements, and responsibilities for preparation and review. The College will work with Information Technology and third-party consultants to enhance system configuration and develop automated processes to support calculation and retention of COA and SAP determinations within a controlled environment. In addition, the College will implement quality control measures, including a COA review committee, systematic validations and documented supervisory review, and will retain sufficient supporting documentation to allow for independent recalculation and verification of eligibility determinations. Implementation of these procedures began in April 2026 and was not in place for the full fiscal year. Fiscal year 2026 represents a transition period during which controls are being implemented and refined. Full implementation is expected for the 2026–2027 award year. These actions are intended to ensure that eligibility determinations are accurate, properly supported, and compliant with federal requirements, and to prevent recurrence.

The College acknowledges the finding and agrees that formal cash management controls are required to ensure that Title IV funds are drawn only for immediate cash needs and are properly supported and documented. The condition resulted from the absence of documented procedures and inconsistent execution of draw preparation, review, approval, and reconciliation processes. The College is in the process of implementing enhanced controls over cash management. Formal written procedures are being established to govern draw calculations, timing, approvals, supporting documentation, reconciliation requirements, and identification and return of excess cash. A standardized draw file will be maintained for each draw, including supporting student-level disbursement detail, reconciliation to eligible expenditures, and documented supervisory approval. The College will also perform and document monthly reconciliations between student disbursement records and federal cash activity. Cash balances will be monitored to ensure funds are drawn only for immediate needs and that excess cash is identified and returned, as necessary. Implementation of these procedures began in April 2026 and was not in place for the full fiscal year. Fiscal year 2026 represents a transition period during which controls are being implemented and refined. Full implementation is expected for the 2026–2027 award year. These actions are intended to ensure that draw amounts are accurate, properly supported, and compliant with federal requirements, and to prevent recurrence.

Cash Management Drawdowns from G5 Planned Corrective Action: Management acknowledges the audit finding regarding the inability to provide documentation demonstrating that Federal Direct Loan and Pell Grant funds were disbursed to students within the required timeframe following drawdown. While the College performed end-of-term reconciliations between student accounts and G5 to ensure no excess cash was maintained, documentation supporting timely disbursement at the student level was not consistently retained. Under the leadership of the Assistant Vice President (AVP) for Financial Aid and the AVP for Finance, the College has implemented a revised operating procedure to track cash management drawdowns on a student-by-student basis. A shared tracking workbook is now used by both offices to coordinate drawdowns and monitor the timing of disbursements. This enhanced process provides improved documentation and oversight to ensure compliance with federal requirements, including the timely disbursement of funds. Person Responsible for Corrective Action Plan: Missy Perry, AVP for Financial Aid, Landee Buzhardt, Director of Student Accounts, and Carrie Morris, AVP for Finance Anticipated Date of Completion: Completed.

Need Analysis Planned Corrective Action: Management acknowledges the audit finding related to errors in need analysis, including instances of over-awarded Federal Direct Loans and under-awarded Pell Grants. These errors were the result of deficiencies in oversight and review processes within the Financial Aid Office during the audit period. The identified discrepancies have been corrected. To address this issue, the College has implemented significant changes within the Financial Aid Office, including elevating leadership to the Assistant Vice President (AVP) level and hiring experienced, qualified staff. These changes strengthen both technical expertise and supervisory capacity. Additionally, the College has enhanced review procedures related to awarding, including increased oversight of need analysis calculations and enrollment verification prior to disbursement. These measures are intended to improve accuracy and ensure compliance with Title IV requirements. Management believes these corrective actions have addressed the root causes of the finding and will continue to monitor awarding processes to ensure ongoing compliance. Person Responsible for Corrective Action Plan: Missy Perry, AVP for Financial Aid Anticipated Date of Completion: June 30, 2026

Inaccurate Return of Title IV Funds (R2T4) Planned Corrective Action: Management acknowledges the audit finding regarding an inaccurate Return of Title IV (R2T4) calculation. In the instance identified, an incorrect number of days was used for a student enrolled in a modular course, resulting in an over-return of $332 in Federal Direct Loans and $419 in Pell Grant funds. The College has addressed this issue through a comprehensive restructuring of the Financial Aid Office. Leadership of the office has been elevated from a director-level position to an Assistant Vice President (AVP) role, and the office has been restaffed with experienced and qualified personnel. In addition, the College has reinforced training and review procedures related to R2T4 calculations, including increased supervisory oversight to ensure accuracy, particularly for students enrolled in modular coursework. Ongoing monitoring will be performed to ensure continued compliance. Person Responsible for Corrective Action Plan: Missy Perry, AVP for Financial Aid Anticipated Date of Completion: June 30, 2026

Enrollment Reporting to NSLDS Planned Corrective Action: Management acknowledges the audit finding regarding untimely and inaccurate reporting of enrollment information to the National Student Loan Data System (NSLDS). The issue was primarily due to a lack of awareness regarding discrepancies between reporting through the National Student Clearinghouse to the NSLDS, as well as complications following the College’s recent upgrade to Jenzabar One (J1). After the upgrade, certain internal reports did not function as expected, and resolving these reporting issues required additional time and coordination between the Director of Institutional Research (IR) and the Registrar. The Director of IR has continued to work in coordination with the Registrar and the Assistant Vice President (AVP) for Financial Aid to ensure accurate and timely reporting to both NSLDS and the Clearinghouse. The Director of IR now provides biweekly status reports to the Vice President for Administration to support ongoing oversight and accountability. Person Responsible for Corrective Action Plan: Kristy Parker, Registrar Anticipated Date of Completion: June 30, 2026

Corrective Action Plan (CAP): The College has reviewed the Federal Pell Grant calculation identified in this finding and confirmed that the student's award was calculated incorrectly, resulting in an under-award, due to staff error in applying the enrollment intensity calculation under the rules in effect for the 2024-25 award year. The College has recalculated the student's award using the correct enrollment intensity methodology, and the additional Pell Grant funds owed to the student (616.00) have been disbursed. Financial Aid staff are committed to maintaining current knowledge of federal regulatory changes affecting Title IV award calculations. To support this, staff will continue to participate in NASFAA training and U.S. Department of Education webinars addressing Pell Grant calculation methodology and other regulatory updates on an ongoing basis, including specific training addressing changes to enrollment intensity calculations.

Corrective Action Plan (CAP): The College has reviewed the student identified in this finding and confirmed that the student had been placed on financial aid suspension during a previous term due to exceeding the 150% maximum timeframe for program completion, but the suspension status was not reflected when the student's enrollment was subsequently evaluated, resulting in the student receiving Title IV aid for which they were not eligible during the period under audit. The College has identified that this occurred in connection with how the student's enrollment was recorded across programs within Anthology, the College's student information system, and is continuing to investigate the precise cause of the system behavior that allowed the student's Satisfacto1y Academic Progress (SAP)/150% status to not carry forward or recalculate appropriately. The aid improperly disbursed to this student has been identified, and repayment has been completed.

Corrective Action Plan (CAP): The College operates under a just- in-time (JIT) cash management model for Title IV funds, in which the disbursement date reported to COD and the date funds are credited to the student's ledger are intended to occur on the same day. Under this model, the CMN draws down Pell grant funds in conjunction with disbursing those funds to the student, rather than disbursing from institutional funds in advance of drawdown. This approach is designed to ensure the College does not hold excess cash on hand, consistent with cash management requirements under 34 CFR 668.164. The College has reviewed the six disbursements identified in this finding and confirmed that, in each instance, the COD submission was processed on schedule, but the corresponding batch process that credits funds to the student ledger ran four days later than intended, resulting in a misalignment between the reported disbursement date and the actual date the student was credited. The College has reviewed the timing and sequencing of COD submissions and ledger transactions with the Bursar's office and the Financial Aid office to ensure both are scheduled and performed on the same day. The existing weekly reconciliation process between Financial Aid and the Bursar's office will be expanded to include a verification that the disbursement date on the ledger matches the COD disbursement date. The College notes that this finding reflects a single disbursement- timing discrepancy across the sample, a reduction in both scope and recurrence compared to findings identified in prior audit periods, and reflects continued improvement in the College's cash management and COD reporting controls.

Corrective Action Plan (CAP): The College has identified that the dates of Return of Title IV Calculations and amounts (in one case) were out of compliance. The return calculations for both students identified through this audit have been completed and corrected to reflect the correct return amounts, if appropriate. Student 1: Student initiated an official withdrawal on October 5, 2024, and the withdrawal was processed on that date. A notification of student status was not received in the financial aid office in order to trigger an R2T4 calculation. This student's calculation was performed at the end of the fall 2024 term with the end of term processing, resulting in 89 days passing from notification to completion of R2T4. This instance resulted in an automatic trigger being built into the student information system, which sends an email to the financial aid office for each student when their status changes from active to withdrawal. Student 2: Student initiated an official withdrawal on February 13, 2025, and the withdrawal was processed on that date. The R2T4 calculation was not performed on this student until the end of spring 2025 term processing, resulting in 96 days passing from notification to completion of R2T4. Due to delayed calculations on these students, CMN will continue to work with financial aid staff and the registrar's office to streamline communication on withdrawals and students who complete the term with all F/NP grades, as indicated in CMN policy. CMN has already worked with Anthology (student information system) to provide electronic triggers to the financial aid office when a student status changes from active to drop/withdrawal. Additionally, Enrollment Management notifies all faculty by email at the beginning of the term and again prior to final grades being submitted that electronic notification must be sent by the faculty to financial aid in order to alert the financial aid office of the date of last academic engagement for students who earn an For NP grade. For the current audit period, the Director of Enrollment Management and the Financial Aid Coordinator work together to review a final grade report for all students and identify those who need R2T4 calculations based on that review. Both the director and coordinator sign the working documents to indicate that it has been reviewed by both parties. We will continue with this process and will refine as necessary, but we anticipate that this will resolve the issue of calculations not having been performed on students with all F/NP grades at the end of the term.

Corrective Action Plan (CAP): The College has identified that the dates of enrollment submissions and status changes for the two students identified in the audit were out of compliance (92 days and 66 days). The statuses of both students are correct with NSLDS. Student 1: Student earned all F grades during the fall 2024 trimester. The student's status was changed to withdrawal in the internal student information system on January 17, 2025. This change was not communicated to NSLDS until the March 2025 enrollment report, due to issues with the February 2025 enrollment report. Student 2: Student was a non-returner in the spring 2025 trimester. The student's status was changed to withdrawal in the internal student information system on January 21, 2025. This change was not communicated to NSLDS until the March 2025 enrollment report, due to issues with the February 2025 enrollment report. The College acknowledges this repeat finding and recognizes that, although the gap was narrowed days beyond tolerance, the prior corrective action plan did not fully resolve the underlying cause of late NSLDS reporting. The previous plan relied primarily on manual identification and status-change processes within the student information system, which remained vulnerable to human error and processing delays. To address this gap, the college will implement a secondary review checkpoint that flags students with status changes in the student information system to ensure timely transmission to NSLDS. To prevent additional recurrences, the College has implemented a monthly reconciliation procedure between the Registrar's Office and the Financial Aid Office, replacing the prior plan's reliance on manual status-chang communication alone. Each month, the Registrar's Office provides a student status change report to the Financial Aid Office. The Financial Aid Office then reconciles each status change against the institution's NSLDS submission history to confirm timely and accurate reporting. This added verification step, paired with documented recordkeeping of each reconciliation cycle, directly addresses the root cause of the repeat finding by introducing a cross-office check that does not depend solely on a single manual status update being correctly carried through to NSLDS reporting.

Finding 2025-003: Special Tests and Provisions: NSLDS Reporting Recommendation: The College should develop and implement a formal process for monitoring and updating students' enrollment status in the NSLDS to ensure compliance with reporting requirements. Establish internal controls to track changes in enrollment status and ensure timely updates to the NSLDS. Conduct periodic reviews of the enrollment reporting process to identify and address any inaccuracies or delays. Provide training to relevant staff on the importance of compliance with enrollment reporting requirements and the procedures for accurate and timely updates. Response: The College concurs with Finding 2025-003 and the auditors’ recommendation. To address this finding, the College has implemented the following actions. Corrective Action Responsible Party Target Date Status Execute formal written agreement between FAO and OARR defining data ownership for each NSLDS record type, update timelines, escalation procedures, and monthly reconciliation responsibilities. Agreement reviewed annually. FAO Director/Registrar/VPEMSS 30 days Draft in progress Implement NSLDS Reporting Calendar aligned to the academic calendar, distributed to FAO, Registrar, and VPEMSS. Built-in reminders at 30, 14, and 7 days before each deadline. FAO Director 30 days Being initiated Implement monthly SIS-to-NSLDS reconciliation. The Financial Aid Office (FAO) will reconcile Student Information System (SIS) data against the NSLDS roster, and any discrepancies will be resolved within five (5) business days. Exception reports will be reviewed and certified monthly by VPEMSS. The monthly reconciliation process will be completed before certification by the VPEMSS, and all identified reporting discrepancies will either be corrected or formally documented with an action plan before certification. FAO Director/Registrar 30 days First cycle underway Coordinate with OARR to verify and maintain accurate CIP codes and credential level data for all active programs at start of each academic year. FAO Director/Registrar 60 days In progress Recruit and fill vacant FAO positions to restore NSLDS processing and monitoring capacity. FAO Director/VPEMSS/HRO 90 days In progress Incorporate NSLDS reporting compliance into annual Title IV self-assessment each August. FAO Director/VPEMSS August 2026 Scheduled Primary Responsible Office: Director, Financial Aid Office Oversight Office: Vice President for Enrollment Management and Student Services Overall CAP Completion Target: Within 90 days of the final audit report issuance; NSLDS record updates within 15 days

Finding 2025-002: Special Tests and Provisions: Verification Recommendation: The College should enhance training programs for staff involved in the verification process to ensure they are fully aware of the requirements and procedures. Establish robust internal controls and review mechanisms to ensure that verification worksheets are completed accurately and consistently with ISIRs. Implement a tracking system to ensure that all required corrections to ISIRs are performed in a timely manner. Response: The College concurs with Finding 2025-002 and the auditors’ recommendation. To address this finding, the College has implemented the following actions. Action Responsible Party Target Date Status Reinstate mandatory two-tiered verification file review. No student file in any Verification Tracking Group may be finalized or disbursed without independent review and sign-off by the second FAO staff member. Review logs maintained and submitted monthly to FAO Director. FAO Director/VPEMSS 30 days In progress Implement ISIR Correction Tracking Log. Log captures: date discrepancy identified, date submitted to CPS, CPS confirmation number, and date corrected transaction received. FAO Director reviews weekly. This control directly addresses the gap that led to missed corrections in AY 2024-2025. FAO Director/Student Services Specialist IV 45 days In development Establish mid-year ISIR correction deadline. An internal institutional deadline – set 60 days before the award year closes – will be established to ensure all pending ISIR corrections are submitted before the CPS window closes. FAO Director responsible for tracking FAO Director 30 days Policy and procedure being drafted Mandatory annual FSA verification training for all FAO staff, covering tracking group identification, ISIR-worksheet cross-matching, CPS correction procedures, and the importance of submitting corrections before year-end closure. FAO Director 60 days Scheduled Conduct monthly internal file audits of verified student files. Results reported in writing to the VPEMSS. Shift from quarterly to monthly frequency to ensure errors are caught well before the award year closes. FAO Director 30 days First cycle initiated Revise and redistribute Verification SOP to all FAO staff across all campuses with mandatory sign-off. SOP to include explicit section on ISIR correction deadlines relative to award year closes. FAO Director 30 days In progress Recruit and fill three vacant FAO positions to restore full review capacity FAO Director/VPEMSS/HRO 90 days Recruitment initiated Primary Responsible Office: Director, Financial Aid Office Oversight Office: Vice President for Enrollment Management and Student Services Overall CAP Completion Target: Within 90 days of the final audit issuance

Finding 2025-001: Eligibility Recommendation: We recommend that management establish and implement formal policies and procedures for the administration of the FSEOG program, including clear guidance on the minimum and maximum award limits in accordance with federal regulations. Management should also provide adequate training to Financial Aid Office personnel on applicable federal requirements, perform supervisory reviews of award calculations prior to disbursement, and conduct periodic monitoring to ensure ongoing compliance with established limits. Response: The College acknowledges the findings resulting from the initial year of the Federal Supplemental Educational Opportunity Grant (FSEOG) program's implementation. The College recognizes that the finding resulted from deficiencies in newly implemented award procedures during the first year of the FSEOG program. In light of this, we wish to provide context regarding the situation and the corrective actions undertaken to address the issue. The seven students identified in this finding were awarded FSEOG funds that reflected their significant financial need and the institution's commitment to enabling students to cover both direct and indirect enrollment costs. An internal review conducted by the Financial Aid Office revealed that these awards inadvertently exceeded the $4,000 annual maximum established by program regulations. Following this internal review, prompt corrective measures were enacted, culminating in the issuance of a formal memorandum to the Comptroller in October of FY26. This memorandum directed adjustments to the affected students’ FSEOG awards to ensure compliance with the prescribed annual maximum. This internal monitoring process underscores the College’s proactive commitment to program integrity and fiscal accountability. Furthermore, the unexpended funds were returned to the U.S. Department of Education during FY26. The College remains dedicated to the proper administration of the FSEOG program and has reinforced its internal review procedures. This includes conducting more frequent audits of award ceilings during active disbursement periods to prevent similar errors in future award years. To address the finding, the College will implement the following actions: 1. Establishment of Formal Policy and Standard Operating Procedures (SOPs): Within 30 days, the College will adopt and implement a dedicated section within the Financial Aid Policy and Procedures Manual specifically for the FSEOG program. This document will delineate federal award limitations, selection criteria based on exceptional financial need groupings, and compliance parameters in accordance with 34 CFR 676.20. 2. Staff Training and Competency Review: Prior to the next award cycle, the College will conduct a mandatory training workshop for all counselors and processing staff within the Financial Aid Office. This training will emphasize the identification of the FSEOG-eligible student population, the applicable selection criteria, and the importance of cross-referencing final award packages. 3. Monitoring and Long-Term Quality Control: The College will implement a mandatory two-tiered verification process. Prior to any FSEOG batch disbursement being sent to the Office of the Comptroller for final payment execution, a senior financial aid officer or director must review and authorize a compliance checklist. This checklist will confirm that there are no boundary violations, and any batch disbursement package containing an amount below $100 or exceeding $4,000 per academic year will be flagged for review. Quarterly compliance reviews will be documented and retained as part of the College's internal control records to verify continued compliance with FSEOG award requirements and to provide supporting documentation for future audits. Primary Responsible Office: Director, Financial Aid Office Oversight Office: Vice President for Enrollment Management and Student Services Overall CAP Completion Target: Addressed in Dec 2026