Corrective Action Plans

Management’s Views and Corrective Action Plan For the year ended December 31, 2025 Finding 2025-003 – Non-Compliance with Accurate Student Enrollment Change Submissions to the National Student Loan Data System Grantor: U.S. Department of Education Program: Student Financial Assistance Cluster Assistance Listing#: 84.063, 84.268 Award Title: Federal Pell Grant Program, Federal Direct Student Loan Program Award Years: 7/2024 – 6/2026 Management agrees with the finding and proposes the following corrective action plan: Corrective Action Plan: Incorrectly Reported Graduated Students Our investigation confirmed that the issue is strictly isolated to the Fall 2025 data pull. This was our first production run utilizing a script update from August 2025. Our Jenzabar Student Information System (SIS) vendor has since corrected this degree-conferred logic, and a re-submission of the Fall 2025 data has confirmed 100% accuracy. To ensure ongoing stability, we will perform an accuracy audit of the next data pull on 5/15/26, with a final resolution date of 05/29/26. Completion Date: 5/29/2026 Corrective Action Plan Incorrectly Reported Program Dates Our investigation with our (SIS) vendor revealed the issue stems from legacy business logic. Historically, system “triggers” automatically updated enrollment dates during major changes; however, these were previously removed to resolve record-locking conflicts, leading to the current reporting inconsistencies. To address this, we are moving away from the static enrollment date field in favor of a programmatic fix. The system will now automatically calculate the program begin date: if a student’s major in the current term differs from the previous one, the begin date will be set to the first day of that reporting term. Additionally, mid-semester major changes will not be reported until the subsequent term of enrollment. We will validate this new logic with an initial audit of the 05/27/26 pull, with a final resolution date of 06/30/26. Completion Date 6/30/2026 Lauri Arensmeyer BYU-Idaho Registrar arensmeyerl@byui.edu (208) 496-1010

Management’s Views and Corrective Action Plan For the year ended December 31, 2025 Finding 2025-001 Inaccurate Reporting of Disbursement Records Grantor: U.S. Department of Education Program: Student Financial Assistance Cluster Assistance Listing#: 84.063, 84.268 Award Title: Federal Pell Grant Program, Federal Direct Student Loan Program Award Years: 7/2024 – 6/2026 Management agrees with the finding and proposes the following corrective action plan: Corrective Action Plan: Regent (our financial aid management software provider) is addressing the system error and has determined where the data error occurred. Regent will provide a software fix by August 2026. This will include a script to correct the Pell COA within the system, and a subsequent correction file will be sent to COD for these students with the correct Pell COA. BYUI has developed a monitoring report and will conduct quarterly reviews of all Pell COA data transmitted to COD to ensure ongoing accuracy. Completion Date: August 2026 (estimated) Kenneth Jackson BYU-Idaho Director of Financial Aid jacksonken@byui.edu (208) 496-1610

Management’s Views and Corrective Action Plan For the year ended December 31, 2025 Finding 2025-002 - Failure to Send Financial Aid Notifications to Pell Recipients Grantor: U.S. Department of Education Program: Student Financial Assistance Cluster Assistance Listing#: 84.063 Award Title: Federal Pell Grant Program Award Years: 7/2024 – 6/2026 Management agrees with the finding and has implemented the following corrective action plan: Corrective Action Plan: Regent has an automated process that sends notification letters before aid is released. The Financial Aid Office disabled this process during June 2027, which sends out financial aid award emails to students. This was done while our office was reviewing current awards for accuracy. The automatic process remained inadvertently disabled even after the review was completed. This caused aid to be disbursed before students received notification of their award amounts. In October 2025, we enabled a new communication that is generated at the time of an initial award and again if the award changes. This keeps the automatic process for generating communications in Regent enabled at all times. In addition, staff training has been completed on the requirement to notify students of their financial aid awards before aid is disbursed. Completion Date: October 2025 Kenneth Jackson BYU-Idaho Director of Financial Aid jacksonken@byui.edu (208) 496-1610

Student Financial Aid Cluster – Assistance Listing 84.063 and 84.268 Recommendation: The College should evaluate their procedures and review policies surrounding reporting enrollment effective dates and program enrollment effective dates NSLDS. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Through the review of program reporting and campus reporting, the college will identify the cause for the data error. The college will explore the impact of branch campuses and the potential to shift to a single college reporting model. The following specific steps will be completed. 1. Identify and Analyze the Issues 2. Root Cause Analysis 3. Corrective Measures 4. Automation: Implement automated checks and balances to ensure data integrity before files are processed and sent. Name(s) of the contact person(s) responsible for corrective action: Patricia Munsch, Ph.D. Vice President for Student Affairs Nancy Brewer, College Director for Financial Aid Cheryl Eldredge, College Associate Dean for Registrar and Master Schedule Planned completion date for corrective action plan: December 31, 2026

Student Financial Aid Cluster – Assistance Listing 84.063 and 84.268 Recommendation: The College should review their reporting internal controls and procedures to ensure that they require students' statuses to be reported timely to NSLDS as required by federal regulations. The College should evaluate their procedures and review policies surrounding reporting status changes to NSLDS to ensure the enrollment effective date reported to NSLDS aligns with the College’s last date of attendance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Through the work of a college-wide task force the following actions will be taken in response to the finding. The task force will include representatives from Information Technology, Institutional Research, Financial Aid, Registrar, along with Ellucian consultants. To summarize the steps and details of implementation to the specific areas are as follows: 1. Review Reporting Controls and Procedures 2. Address Error Code 22 3. Review Procedures Surrounding Reporting Status Changes 4. Assure Accuracy in Reporting Enrollment Effective Date Name(s) of the contact person(s) responsible for corrective action: Patricia Munsch, Ph.D. Vice President for Student Affairs Nancy Brewer, College Director for Financial Aid Planned completion date for corrective action plan: December 31, 2026

During fiscal year 2025, differences were identified between amounts reported on the Fiscal Operations Report and Application to Participate (FISAP) and the District’s finalized accounting records due to yearend adjustments recorded after submission of the report. The District recognizes the importance of ensuring reported amounts reconcile fully to underlying accounting records and acknowledges that additional coordination between Business Services and Financial Aid is necessary to strengthen reporting accuracy. To address this finding, the District will undertake the following actions: 1. Develop a formal reconciliation process between the general ledger, student financial aid reporting, and FISAP submissions prior to report filing. 2. Establish documented timelines to ensure year-end accounting adjustments are evaluated and incorporated into federal reporting, when applicable. These actions are intended to improve reporting accuracy, strengthen interdepartmental communication, and ensure compliance with federal reporting requirements under the Student Financial Assistance Cluster.

2025-031 Adoption Assistance 93.659 Recommendation: The Department should enhance its procedures and internal controls to ensure it maintains documentation of participant eligibility and child abuse and neglect registry checks, and that this documentation is readily available for audit. We also recommend the Department enhance the renewal letter to include the reaffirmation of the original subsidy agreement date by the participant. Action taken in response to finding: For the finding related to signed adoption subsidy agreements, the Department has already implemented corrective actions to improve its process of maintaining signed adoption subsidy agreements. We built the capacity to upload electronic documents into iFamilyNet in July 2022, and we now ensure that all prospectively signed agreements are uploaded into the child’s iFamilyNet record. In addition, since July 2023, during the Title IV-E eligibility determination process, the eligibility specialist verifies that the signed adoption subsidy agreement has been uploaded. The Department will also explore the auditor’s recommendation to enhance the renewal letter to include the reaffirmation of the original subsidy agreement date by the participant to see if it is technically feasible. Although the Department was unable to produce a copy of a signed subsidy agreement, the Department has controls to oversee that a subsidy agreement was executed prior to legalization of the adoption through a built-in workflow process in our i-FamilyNet system. For the other 39 sample cases, the dates of the signatures by the Department and the pre-adoptive parents recorded in iFamilyNet matched the signature dates on the copies of the original signed agreements. Hence, the Department asserts the dates entered were accurate. We unfortunately could not produce the document to demonstrate that to the auditors. For the finding relating to out-of-state child welfare checks, the Department has already implemented corrective actions to improve its process of documenting requests of out-of-state child welfare checks. In February 2023, the Department integrated the out-of-state child welfare check into the Background Record Check (BRC) section of the foster home licensing process where it can be documented and included as part of the assessment. The Department also added a value to our “contact purpose” drop down menu within the dictation screen in iFamilyNet to capture structured data that an out-of-state child welfare check was made. Name(s) of the contact person(s) responsible for corrective action: Sharon Silvia, Assistant Commissioner of Permanency COMMONWEALTH OF MASSACHUSETTS CORRECTIVE ACTION PLAN YEAR ENDED JUNE 30, 2025 Planned completion date for corrective action plan: Signed Subsidy Agreements: • July 2022 – capacity to upload electronic documents into iFamilyNet (complete) • July 2023 – eligibility specialist verifies that the signed adoption subsidy agreement has been uploaded (complete) • July 2026 – assess technical feasibility of enhancing the renewal letter Out-of-State Child Welfare Checks: • February 2023 – integrated out-of-state child welfare checks into BRC section and added value to contact purpose drop down (complete)

Audit Finding – Management’s View and Corrective Action Plan Student Financial Assistance Cluster – Various ALNs Reference Number 2025-001 – Special Test – National Student Loan Data System (NSLDS) Reporting Management agrees with the finding. The University’s Enrollment Services teams are thoroughly reviewing the National Student Loan Data System (NSLDS) and National Student Clearinghouse (NSC) reporting requirements and updating the data extract code (Code). The updated Code will be validated with the NSC’s test submission process. Beginning with Spring Term 2026 (April), a modified version of the current Code that addresses the known issues will be used for reporting. The thorough review and Code rewrite will be completed and tested for use with the first reporting for Fall Semester 2026 (September). The University Registrar’s Office will also implement a process to regularly monitor reporting changes issued by the NSLDS and NSC. Responsible party – Kirsten Jensen, Associate Registrar

Student Financial Assistance Cluster – Assistance Listing No. 84.268, 84.063, 84.379 Recommendation: We recommend the College reevaluate its procedures, and review policies surrounding controls implemented for COD reporting. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The College is currently implementing a process in which disbursement dates within the SIS matches all dates within COD’s Award Disbursements Information Disbursement Date. This will be done within the Batch record by utilziing the date the batch was processed as “Funds Deposited” instead of the initial “anticipated” award date. The adjustment will ensure that all dates match as the official date the fund was credited to the student’s account. Review of existing prociedures will be conducted regarding the COD disbursement controls. The importance of accurate documentation and actual disbursement dates within the SIS will be emphasized. All disbursmeent dates will be reviewed and reconcilled by the Director of Financial Aid ensuring timely and accurate reporting. Name(s) of the contact person(s) responsible for corrective action: Walter Thompson Planned completion date for corrective action plan: July 2026

The College is addressing structural deficits in operations and cashflow through expense reductions and market-responsive academic programs to support enrollment growth. Over the past three years, management and the baord of trustees have advanced a coordinated plan centered on enrollemnt and growth, retention, and institutional giving. The College has implemented budget reductions and continues additional strategies to address its structural deficit.

FINDING 2025-010 Names of Responsible Individuals: Associate Director for Compliance, Enrollment Management Associate Director of Loans Systems Analyst, Enrollment Management Assistant Director for Compliance, Financial Aid Loan Coordinator Corrective Action: Beginning with the Fall 2024 semester, Howard University transitioned from using Banner to using Workday as the University’s ERP. As part of the transition to Workday, Howard spent several years configuring Workday to meet the needs of the institution and testing to ensure once the University went “live” during Fall 2024 there would be no configuration issues that affect compliance. It is not possible for Financial Aid to fully test the COD disbursement reporting process prior to "go live" due to the inability to send test disbursement files to COD for reporting purposes. Once Howard disbursed loans and was able to send actual disbursement files to COD, the Enrollment Management Systems Analyst worked to identify and resolve outstanding issues. Initial reporting of disbursements to COD began on August 6, 2025. When the first disbursement file was sent to COD, the EM Systems Analyst identified the file schema sending out disbursements from Workday to COD kept rejecting the entire file. The Systems Analyst worked with the University Workday consultants to resolve the rejections and was able to correct the issue on August 28th. The cause of the rejected files between Workday and COD was an underlying Workday system issue that was corrected an updated released by Workday. There were issues in Workday regarding the school code that were identified which delayed a small cohort of students’ disbursements from being reported to COD. The Howard University enrollment school code is 00144800 and NSC required a “dummy” school code to be used for enrollment reporting of Graduate and Professional students. This “dummy” code was 00144880. A small cohort of students had loans that were rejected due to Workday reporting the 00144880 school code to COD instead of the 00144800 school code. Reconciliation identified the students and once the enrollment code sent to COD was corrected in Workday, the loan was accepted. The cost of attendance variance was a result of unfamiliarity with the Workday system. After a student's aid has been originated and disbursed, Workday will not automatically send the disbursement file back out to COD, which was not an issue Howard encountered when using Ellucian Banner. In Workday, when a student’s cost of attendance changes due to cost of attendance increase or the student’s housing status must be adjusted, there is manual intervention required. Students who have a change to their cost of attendance need to have a flag checked off in the origination record. This will allow the updated cost of attendance to be reported in COD when the next disbursement file is sent to COD. The current process is when a student's cost of attendance is manually adjusted, the flag for the record to be sent to COD is checked off in the origination record. The Associate Director for Compliance has completed internal compliance reviews testing whether disbursements are being sent to COD within 14 days. Thus far, no issues have been found in these reviews. Files are transmitted to COD at least four times per week and rejected disbursements are worked to meet the 14-day disbursement reporting timeline. A compliance review has been initiated to ensure the cost of attendance reported out of Workday matches the cost of attendance in COD. Howard University staff meet daily with Workday consultants from AVAAP to provide feedback and discuss any current issues experienced in Workday. The goal of these meetings is to have a constant flow of information on what is working effectively and what is not working effectively within Workday. This process is documented and staff are trained. Anticipated Completion Date: The underlying Workday system issue resulting in the COD disbursement file being rejected was internally resolved on August 28, 2024. The Fall 2024 update released by Workday in late-September/October 2024 corrected the system from the Workday side. The Systems Analyst receives an error when there is a rejected COD file, and the correction of these files is an ongoing process. Howard staff worked with the University’s Workday consultant to resolve the incorrect school code reported to COD, causing individual students’ disbursements to be rejected. This incorrect school code reported to COD was resolved for the 2025-2026 academic year by changing the configuration of disbursements to ignore any school codes other than 00144800. The Associate Director for Compliance sends a list of rejected loan disbursements to the Financial Aid Loans Team so these rejects can be worked on and resolved in 5-7 business days. The cost of attendance variance was identified in Fall 2025 and the change in the process when a student has a manual cost of attendance increase was implemented at that time as well. The compliance reviews for cost of attendance and COD reporting will take place twice per semester and any issues identified will be resolved to avoid future findings.

FINDING 2025-009 Names of Responsible Individuals: Associate Director for Compliance, Enrollment Management Associate Director of Loans Systems Analyst, Enrollment Management Assistant Director for Compliance, Financial Aid Loan Coordinator Corrective Action: Beginning with the Fall 2024 semester, Howard University transitioned from using Ellucian Banner to Workday as the University’s ERP. As part of the transition to Workday, Howard spent several years configuring Workday to meet the needs of the institution and testing to ensure once the University went “live” in Fall 2024 there would be no configuration issues that affect compliance. Workday was not configured to send out Parent Plus Loans, therefore, Parent Plus notifications were as the result sent out as part of a manual process through the Financial Aid email box. Research into the issue and continued discussions with Workday consultants determined that Parent Plus disbursement notifications definitively cannot be sent out automatically after disbursement in Workday as a result of a flaw in Workday’s configuration capabilities. As a result, “FA CR Parent PLUS Disbursement Notification” report is run weekly out of Workday to identify all Parent Plus Loan disbursements, and a notification is sent to the parent’s email address on file through the Financial Aid Loans team email box. The three disbursement notifications that were not sent out within the 30-day timeline resulted from these Parent PLUS Loans not being shown on the “FA CR Parent PLUS Disbursement Notification” report. These disbursement notifications were originally sent to the student’s email address through Workday instead of being sent to the parent’s email address. While these disbursement notifications were sent timely, a compliance review of disbursement notifications discovered the Workday configuration was sending out some Parent PLUS Loan disbursement notifications to the student’s email address. This left the PLUS disbursement off the “FA CR Parent PLUS Disbursement Notification.” Upon discovery of this configuration error, the Loans Team worked with the University’s Workday consultant to prevent any Parent PLUS Loan disbursement notifications from being sent out through Workday. Bi-semester internal reviews by the Associate Director for Compliance in Enrollment Management are ongoing. The error with Parent PLUS Loan notifications being sent to the wrong individual in Workday was identified in the March 2025 disbursement notification compliance review. An August 2025 review of disbursement notifications for medical students resulted in there being no disbursement notifications found that were sent past the 30-day timeline and they were sent to the correct individuals. A September 2025 review of disbursement notifications was completed and resulted in enhancements to the mail merge template used to manually send out the Parent PLUS Loan disbursement notifications. An updated mail merge template was created, tested and implemented. A November 2025 disbursement notification review was completed to ensure the Parent PLUS notifications went out timely and to the parent’s email address. Anticipated Completion Date: The corrective action taken to prevent the Parent PLUS notifications from going out to the students in Workday was completed in March 2025. Monitoring and reviewing of loan disbursements have been ongoing to ensure the Workday system is correctly identifying and transmitting Direct Loan disbursements for Subsidized, Unsubsidized and Graduate PLUS Loans. Any significant issues are identified, documented and tracked until they are resolved. The Loan Coordinator is responsible for sending out the Parent Plus Loan notifications on a weekly basis and training has been provided to the designated individual who will perform this function in the absence of the Loan Coordinator.

FINDING 2025-008 Names of Responsible Individuals: Manager Systems & Administration (Office of the Bursar) Associate Director for Compliance, Enrollment Management Associate Vice President for Finance and University Bursar Director of Cash Management, Treasury Operations Treasury Specialist Systems Analyst, Enrollment Management Corrective Action: Beginning with the Fall 2024 semester, Howard University transitioned from using Ellucian Banner to Workday as the University’s ERP. The Bursar’s Office was not able to fully test the Title IV refunds process prior to "go live" due to the inability to disburse and create refunds to be sent to the University’s bank, JP Morgan. In August 2024, the Bursar’s Office identified configuration issues with JP Morgan where parents were not associated with students’ IDs and addresses in delivered refund files sent to JP Morgan Chase. These Title IV checks and direct deposits could not be sent to parents until JP Morgan completely migrated to Workday, in September 2024. After this date, there have not been issues with the JP Morgan Chase configuration with Workday. Workday is a date-driven ERP. Meal charges for Spring 2025 were placed on the students’ account, the due date for payment on the referenced meal charges was put in Workday as 12/23/2025 instead of 12/23/2024. This due date is when the charge is factored into the application of payments for the Office of the Bursar. The result was that housing charges were not being applied for the Spring 2025 semester until the error was discovered by the University during reconciliation. These meal charge dates were corrected to 12/23/2024 in March 2025. Internal controls have been created where there is a second level of review of due dates for charges placed on the students’ account. Due dates for charges during a semester are now reviewed by the Bursar and Housing to ensure the application of payments will pick up all charges for a semester. There are also continuing corrective actions being taken to best capture students who were eligible for a Title IV refund and deliver Title IV credit balances to students within the 14-day timeframe, including the use of reports available in Workday. Beginning with Fall 2025 semester, the on-demand “SF Refund Review Report” in Workday is used to identify students that are eligible for a Title IV refund. Howard University staff meet daily with Workday consultants from AVAAP to provide feedback and discuss any current issues experienced in Workday. The goal of these meetings is to have a constant flow of information on what is working effectively and what is not working effectively within Workday. There are also more Howard University staff focused on the Title IV credit balance process and more stages of approval required for the process to be completed. A list of Title IV credit balance refunds is captured from the “SF Refund Review Report,” the settlement run of refunds are reviewed by the refund approver in the Office of the Bursar, then the refund listing goes to the University Bursar for approval. After approval by the University Bursar the listing of students who will receive Title IV refunds by direct deposit and/or check is sent to the Treasury Specialist for approval. Once the Treasury Specialist approves the refunds, the Cash Manager approves the transmittal of this information to JP Morgan, and the funds are then transmitted to JP Morgan for delivery to parents and students. There has also been identification of a backup employee in the Bursar’s Office and Treasury responsible for the Title IV refund process. These backups have been trained so there is no disruption to the workflow, and they are currently running the Title IV credit balance delivery process when there is a workload balance need to do so to ensure timely refunds. Bi-semester internal reviews by the Associate Director for Compliance in Enrollment Management have taken place which complement the additional levels of review put in place by the Bursar. An internal review of 10 Title IV refunds sent to students for Summer 2025 was completed in July 2025. A review of 100 students who received refunds for Summer 2025 and Fall 2025 was completed in August 2025. All the students who received a refund for the Fall 2025 semester had their Title IV credit balance delivered timely. A review of 86 Title IV refunds for Fall 2025 completed in October 2025 showed that 0 students in the sample received their Title IV refund past the 14-day timeline. Anticipated Completion Date: Both issues which created the Title IV credit balance findings for FY25 have been identified and resolved. The issue with JP Morgan’s migration to Workday was identified and resolved during the Fall 2024 semester. The importance of due dates in Workday is now reinforced with a second level of staff members reviewing charge due dates in Workday. Additional steps have also been taken to ensure compliance with the 14-day credit balance delivery timeframe. The identification of the “SF Refund Review” report as the best report to capture Title IV credit balance information was completed in July 2025. The bi-semester reviews of continuing compliance with the 14-day timeline are ongoing and will continue to be used as a tool to identify any potential compliance issues. As of July 2025, there is identification of a backup employee in each office responsible for the Title IV refund process should there be employee turnover.

FINDING 2025-007 Names of Responsible Individuals: Associate Director for Compliance, Enrollment Management AVP for Finance & Bursar Director of Student Billing and Engagement Associate Director for Compliance, Financial Aid Assistant Controller Director of Accounting Corrective Action: Federal Perkins Loan program records are traditionally paper based, as a result, these school records can often be inconsistent. Due to inconsistent data transfer during Howard University’s move from Campus Partners to ECSI (Educational Computer Systems, Inc.) as the Perkins Loan servicer after the 2013-2014 academic year, the University’s Perkins disbursement data did not match the records Howard had from ECSI. In 2022, the University began to work with ECSI on converting the Howard internal records to match ECSI’s records. In mid-April 2026, ECSI notified Howard that the conversion of ECSI Perkins disbursement data to Howard disbursement data was complete. Currently, the adjustments ECSI made to match Howard are being reviewed by the Associate Director for Compliance in Enrollment Management, and feedback will be provided to ECSI. Matching Perkins Loan data between Howard and ECSI will strengthen the data consistency on the FISAP. The consistency of Perkins Loan data between ECSI and Howard University on the FISAP will also assist in strengthening internal controls for determination of the Cash on Hand amount. ECSI works with schools whose general ledger Cash on Hand does not match what is on the FISAP in Part III. It was conveyed by ECSI that it is more important to have awareness of what data does not match and why than to have parity. After the conversion of Perkins data from ECSI has been approved, the Associate Director for Compliance will meet with Director of Accounting to begin the process of reviewing Perkins wind-down procedures and the accounting related. Howard University is in the process of liquidating the Federal Perkins Program. Due to staffing changes, the Director of Student Billing and Engagement, is now responsible for the Federal Perkins Loan liquidation process. The University is working with ECSI and the Department of Education to complete the liquidation. As part of the liquidation process, the Director of Billing and Engagement contacted the Department of Education to determine the remaining steps for Perkins liquidation. 13 Perkins Loans remaining need to be assigned. Howard is in the process of determining if these loans can be assigned to ED or if the school will need to purchase them. Anticipated Completion Date: September 30, 2026, is the target date for the Federal Perkins Loan program to be completely liquidated at Howard University. All but 13 Federal Perkins Loans have been assigned, and the Bursar is working on sending credit balances to Accounts Payable for payment for those Perkins Loans that can be assigned. The conversion of ECSI records to match Howard internal records was completed in April 2026 and final will be completed by May 2026. Once the conversion is approved by Howard, the June 30, 2026 Perkins Annual Report from ECSI will match what Howard has in their Perkins records. This will enable this Perkins Annual Report to be used on the 2027-2028 FISAP due on September 30, 2026.

FINDING 2025-006 Name of Responsible Individual: Associate Provost AVP, Human Resources Senior Director of Payroll Corrective Action: The Offices of Undergraduate Studies, Financial Aid, Human Resources, and Payroll have worked to re-configure our Enterprise Resource Planning system, Workday, to significantly reduce early time approval and minimize incorrect time attribution. We introduced new controls on May 7, 2025, and provided additional training throughout Academic Year 2024-2025. Although we have made much progress, we are still working to minimize FWS program risks. Specifically, we have noticed that retrofitting the staff and faculty hiring system may not be an ideal solution for handling the unique needs of the Federal Work Study program. As such, we are working with our official Workday partner to enact a distinct student hiring portal, that will also leverage Workday. We expect that this portal will be more nimble and better able to address FWS program management and controls. The expected launch date is Fall 2026. Anticipated Completion Date: December 31, 2026

FINDING 2025-005 Names of Responsible Individual: Interim Registrar & AVP for Enrollment Management Associate Director for Compliance, Enrollment Management Associate Registrar for Compliance, Records, and Graduation Services Records Specialist Associate Director for Compliance, Financial Aid Corrective Action: The Enrollment Reporting process is supervised by the University Registrar and the Registrar is responsible for providing enrollment files to Howard University’s third-party servicer, National Student Clearinghouse (NSC), who then submit the enrollment file report to the National Student Loan Database System (NSLDS). Howard moved to Workday Student as the University’s ERP beginning with the Fall 2024 semester and enrollment reporting to NSC was processed solely through Workday with the Fall 2024 semester and enrollment reporting to NSC was processed solely through Workday. As part of the transition to Workday, Howard spent several years configuring Workday to meet the needs of the institution and testing to ensure once the University went “live” there would be no configuration issues that affect compliance. It was not possible for the Registrar’s Office to fully test enrollment reporting prior to "go live" due to students needing to be registered in courses to send a test file to NSC. At the start of the Fall 2024 semester, Howard worked closely with National Student Clearinghouse to troubleshoot issues that could delay the enrollment files transmission in August and September 2024. This setup of the one-time migration between Workday and NSC was not completed timely. The appropriate individuals from the Registrar’s Office, Office of Financial Aid, National Student Clearinghouse are working together to enable ongoing communication and monitoring of reporting requirements. These parties will work together to confirm student enrollment statuses are reported timely and accurately. The transition to Workday Student allowed the University to review each program of study to ensure accuracy when integrating the data from Banner to Workday and certifying the correct program start date and program length are reported to NSLDS. The effective enrollment date reflected in NSLDS for the four students with the incorrect program start date was fed from the University’s prior ERP, Banner, and all program start dates have now been accurately updated in Workday. The implementation of Workday and staffing transitions in the Registrar's Office caused delays in students being cleared for graduation and then to NSC. The issue for Graduate reporting should not recur due to resolved implementation issues with Workday. Monthly enrollment reporting schedules were set up in NSC for the 2025-2026 academic year during Summer 2025. These enrollment reporting schedules will be updated each summer for the upcoming academic year. Graduation files are scheduled to be transmitted on the first of every month to National Student Clearinghouse. This will allow students cleared for graduation to be transmitted monthly and ensure the 60-day reporting timeline will be met. The Office of the Registrar is in constant communication with the representative from NSC when there are questions on reporting student enrollment statuses accurately. Bi-semester reviews by the Associate Director for Compliance will ensure any potential issues in reporting are identified and resolved timely. A review of students reported to NSC for Spring 2025 was completed with a specific focus on students who had a change in enrollment. This review discovered the Workday configuration did not pick up students who dropped courses during the semester in the enrollment file. This configuration issue in Workday has now been corrected. A review of students’ enrollment status for Fall 2025 after the University’s drop/add period showed students in the enrollment reporting file were reported correctly on the Fall 2025 First of Term enrollment file sent to NSC. Anticipated Completion Date: The Workday migration with National Student Clearinghouse was completed in October 2024. The program start dates were accurately set up in Workday during the configuration of each program of study, which occurred prior to “go live” in 2024. Howard University staff meet daily with Workday consultants from AVAAP to provide feedback and discuss any current issues experienced in Workday. Bi-semester compliance reviews of the student’s enrollment status reported to NSC are ongoing and will occur at least once per semester. The monthly reporting schedules were set up for 2025-2026 during Summer 2025 and each summer the monthly reporting schedule will be set up for the upcoming academic year. When the National Student Clearinghouse updated their enrollment file reporting portal in May 2025, the Associate Registrar met with NSC for training on how to use their new portal to upload student enrollment statuses.

Corrective Action Plan FINDING NO. 2025-001 PROGRAM U.S. Department of Education - Student Financial Aid Cluster (ALN 84.268) REQUIREMENT 34 CFR § 668.165(a) CRITERIA OR SPECIFIC REQUIREMENT Under 34 CFR § 668.165(a), institutions are required to notify borrowers in writing ( or electronically) of the anticipated date and amount of each Direct Loan disbursement, as well as the borrower's right to cancel all or a portion of the loan. This notification must be sent within a required time frame of crediting the student's account. CONDITION The College did not provide required notifications to students (or parents, where applicable) regarding the disbursement of Federal Direct Loans for the Spring semester during the award year. RECOMMENDATION The College should implement and document procedures to ensure that all required Direct Loan disbursement notifications are generated and delivered to students (or parents, where applicable) in a timely manner for all payment periods during the award year. VIEW OF RESPONSIBLE OFFICIALS The College concurs with the finding and recommends and presents the following correctiveaction plan to be implemented. PLANNED CORRECTIVE ACTION The College will implement a standardized and automated process within its financial aid system to ensure that disbursement notifications are generated and delivered to all Direct Loan recipients (or parents, where applicable) for each payment period within the required timeframe. Notifications will include the anticipated disbursement date, amount, and the borrower's right to cancel all or a portion of the loan. Additionally, the College will establish documented procedures requiring staff to: • Verify that notifications are generated for each disbursement period • Maintain system-generated records evidencing the date and method of notification • Perform periodic reconciliations between disbursement records and notification logs to ensure completeness The procedures will be incorporated into the Financial Aid Policies and Procedures Manual, and staff will receive training on the updated requirements. RESPONSIBLE PARTY Associate Vice President, Student Aid & Records ANTICIPATED COMPLETION DATE August 31, 2025, with full implementation beginning in the Fall 2025 term Signed Michael Chando, Associate Vice President

Due to challenges related to the implementation and reporting functionality of the Anthology Student system, AGMU temporarily experienced difficulties in identifying enrollment status changes and reporting the changes to NSLDS. Errors and delays related to enrollment reporting were primarily due to AGMU’s delay in identifying withdrawn students (discussed in Finding 2025-2) and identifying the withdrawal date used in the R2T4 calculation so that the date could be reported to NSLDS. AGMU agrees with the auditor’s recommendation that implementing additional processes and controls around enrollment reporting will improve compliance. To resolve this issue and prevent recurrence, AGMU is completing the corrective actions described below. Corrective Action 1: Confirming and reporting withdrawal dates for award years 2023-24 and 2024-25 As part of the withdrawn students file review described in the corrective actions for Finding 2025-2, AGMU is confirming the withdrawal date for students who did not complete the payment period. Once the withdrawal dates have been confirmed (and/or previous withdrawal dates are confirmed), enrollment statuses for impacted students will be updated in NSLDS as appropriate. Corrective Action 2: Monitoring for enrollment status changes To identify enrollment status changes timely, AGMU developed a report (“Customized Enrollment Status Change” report) that identifies students with enrollment status changes, the effective date of enrollment status changes, and potential Title IV adjustments related to enrollment status changes (e.g., Pell Grant recalculations). AGMU generates this report weekly to ensure that any student with an enrollment status change is reviewed, and timely Title IV award revisions are completed, if applicable. Corrective Action 3: Validation of the Enrollment Reporting Roster To validate the accuracy of the Enrollment Reporting Roster, AGMU will be developing a report to identify students with enrollment status changes and the effective date of enrollment status changes. AGMU is determining if it could use the existing report (“Customized Enrollment Status Change” report) for this process. Once AGMU has finalized its process and report, AGMU plans to generate this report monthly to confirm accurate information regarding student enrollment status is being extracted from the Anthology Student system and correctly transmitted to NSLDS via the Enrollment Reporting Roster. Corrective Action 4: Timely identification of ISIR comment codes Although AGMU had policies and procedures related to determining student eligibility, the procedures required revisions due to the Anthology Student implementation. To identify students for whom ISIR comment codes appear after Title IV aid is awarded and/or disbursed (i.e., on a subsequent ISIR), AGMU developed a report (“Customized Ineligible Funds” report) that identifies potentially impacted students, Title IV funds awarded and disbursed, and ISIR comment codes. AGMU generates this report weekly to ensure any student with an ISIR comment code is reviewed and any funds that must be returned are identified timely. Corrective Action 5: Review and revision of policies and procedures related to enrollment reporting. AGMU is in the process of revising its existing policies and procedures related to enrollment reporting to ensure they correctly describe processes in the Anthology system. Corrective Action 6: Ongoing monitoring by and support from system office personnel SUAGM central office financial aid personnel will perform and assist with quality assurance activities related to AGMU’s enrollment reporting such as: 1. Creating reports related to official and unofficial withdrawals to verify that enrollment status changes are identified on a timely basis and accurately reflected in student records in NSLDS. 2. In coordination with the Registrar, creating an enrollment reporting manual. 3. Developing NSLDS enrollment reporting training and requiring that all staff with enrollment reporting responsibilities attend the training. Corrective Action 7: Enrollment reporting file review AGMU is in the process of planning a comprehensive file review of enrollment reporting for the 2023-24 and 2024-25 award years. At this time, AGMU is prioritizing the withdrawn students file review so that unearned funds can be returned to the U.S. Department of Education as soon as possible. Once the withdrawn students file review is completed, AGMU will begin work on the enrollment reporting file review.

Due to challenges related to the implementation and reporting functionality of the Anthology Student system, AGMU temporarily experienced difficulties in identifying students who officially or unofficially withdrew from the payment period. Although the compliance issues identified in this finding are primarily attributable to system implementation challenges, AGMU understands the importance of timely returns to the U.S. Department of Education related to withdrawn students and is engaged in a comprehensive effort to address deficiencies, prevent recurrence, and return any funds due from AGMU as soon as feasible. To resolve this issue and prevent recurrence, AGMU is completing the corrective actions described below. Corrective Action 1: Student eligibility and withdrawn students file review AGMU completed a file review of the 2023-24 and 2024-25 award years to identify students who (1) failed to begin attendance in a course or courses, and/or (2) had ISIR comment codes requiring resolution. As a result of this file review, AGMU has recalculated Title IV awards for impacted students. AGMU has also completed a file review of the 2023-24 and 2024-25 award years to confirm it has identified all students who officially and unofficially withdrew from the payment period. AGMU is now in the process of compiling system data to perform or re-perform R2T4 calculations for these students, as appropriate. Once AGMU has completed the R2T4 file review and confirmed if additional returns are required for the impacted students, AGMU will report the recalculated award amounts to COD and return funds via G5. Corrective Action 2: Development and enhancement of reports to facilitate the identification of withdrawn students and support the R2T4 calculation. AGMU developed new reports and enhanced existing reports that will aid the institution in timely identifying withdrawn students and performing accurate R2T4 calculations, including but not limited to the following reports that AGMU reviews weekly: • A report (“Customized Enrollment Status Change” report) that identifies students with enrollment status changes that may indicate the student ceased attending the payment period and thus a R2T4 is required. • Reports (“AGMU R2T4 Calculation Detail” and “AGMU R2T4 Review by Term” report) that extract data used in the R2T4 calculation from the student information system, such as term dates, module dates, and Title IV disbursements. • A report (“R2T4 Return of Funds” report) that track R2T4s performed in the system for which funds have not yet been returned via COD and potential post-withdrawal disbursements to student and parent borrowers. • A report (“Canvas Last Academic Activity” report) from the learning management system that confirms the student’s last date of academic engagement in an online course to assist in determining the student’s withdrawal date. AGMU uses the above reports jointly with reviewing live student data in the Anthology Student system when performing a R2T4 calculation, returning funds or disbursing or offering a post-withdrawal disbursement to a student or parent borrower. Corrective Action 3: Review and revision of policies and procedures related to student eligibility. AGMU is in the process of revising its existing policies and procedures related to student eligibility determinations to ensure they correctly describe processes in the Anthology system. AGMU is also in the process of revising its existing policies and procedures related to identifying withdrawn students, performing the R2T4 calculation, and returning funds via COD to ensure they correctly describe processes in the Anthology system. Corrective Action 4: Ongoing monitoring by and support from system office personnel SUAGM central office financial aid personnel perform and assist with quality assurance activities related to AGMU’s determination of student eligibility such as: 1. Reporting parameters are reviewed and refined collaboratively by Financial Aid, Registrar, and Information Technology (IT) staff to ensure that custom reports capture accurate, complete, and relevant data. This process includes validating data fields, logic, and calculation criteria used to support enrollment status changes and student eligibility analysis (i.e., the monitoring of ISIR comment codes). 2. Customized reports developed for enrollment status changes and student eligibility analysis are reviewed biweekly to identify changes in enrollment intensity, eligibility indicators, and potential ineligible disbursements. These reports support the timely review of aid adjustments and identification of cases requiring resolutions or returns. 3. Student record samples are selected and discussed at regularly scheduled validation meetings. These meetings include representatives from the Registrar, Financial Aid, Bursar, IT, and Compliance to confirm data accuracy, validate reporting results, and identify any necessary process or reporting adjustments. SUAGM central office financial aid personnel also perform and assist weekly with quality assurance activities related to AGMU’s identification of withdrawn students, performing the R2T4 calculation, and returning funds via COD, such as: 1. Reviewing reports generated by AGMU related to official and unofficial withdrawals, including validation of withdrawal dates, last date of academic activity, and enrollment status changes identified through registrar and financial aid data. 2. Reviewing R2T4 calculations prepared by AGMU to confirm accurate payment period dates and scheduled days for programs offered in modules, earned and unearned aid determinations, and amounts scheduled for return. 3. Monitoring the timely submission of returns through COD, including the review of refund activity reports and confirmation that returns are properly recorded and reconciled. Corrective Action 5: Ongoing training of AGMU personnel on key R2T4 concepts AGMU has mandated additional R2T4 training for personnel who interact with the R2T4 process in the financial aid office, registrar’s office, and bursar’s office. In addition to requiring that personnel attend training organized by SUAGM, AGMU employees have participated in webinars offered by Federal Student Aid, NASFAA, and third-party servicers, accounting firms, and law firms with expertise in R2T4 concepts.

General Background Language During the 2024-2025 award year, Hult’s financial aid department effectively managed Title IV funds. Hult successfully carried out the administrative improvements implemented beginning Summer 2024. These improvements were the result of first, our own internal review of our financial aid operations, and feedback from the prior year’s 2023-2024 award year audit. The mitigating circumstances previously experienced were isolated to the 2023-2024 award year and do not reflect Hult’s ongoing ability to effectively manage Title IV funds. In the 2023-2024 corrective action plan, we noted that our goal was not just to rectify past mistakes but to build a stronger, more resilient foundation moving forward. Over the last year, we have followed through on these corrective actions, including: 1.Continued collaboration with Financial Aid Solutions (FAS) to effectively manage Hult’s core Title IV functions, including awarding, disbursement, and cash management activities, and utilize this resource for timely compliance support of our internal financial aid team 2. Conducted a full review and overhaul of our internal processes, procedures, and Regent system configuration to align with Hult’s business needs and maintain Title IV compliance 3. Maintaining a qualified, in-house financial aid team, with a focus on cross-training and succession planning, to ensure continuity and operational stability 4. Revision of our existing internal controls managed by the financial aid team, and implementing additional internal controls, independently managed by our central finance team, to ensure data accuracy, monitor for discrepancies, and enable prompt resolution of any identified issues Committing dedicated project management resources to identify process gaps, streamline operations, and optimize our use of system tools The successful implementation of these measures represents a deep and sustained investment in the integrity, compliance, and effectiveness of our Title IV operations. With these systems in place, we prevented a recurrence of last year’s findings related to the awarding, disbursement, or management of 2024-2025 Title IV funds. This year’s finding, in our view, was not a new finding, as these instances reflect a corrective action taken as a result of the 2023-2024 audit findings, with the correction happening within this recent audit period. Finding No. 2025-001 Return of Title IV Funds Federal Agency: U.S. Department of Education Assistance Listing Number and Title: 84.268 - Federal Direct Student Loans 84.063 - Federal Pell Grant Program Responsible Individual: Marcus Friberg, VP of Finance Date Action Taken: Fiscal Year 2025 Hult acknowledges that Title IV funds were returned outside the 45-day window in four instances; however, all of which were made as a part of our corrective action plan from the FY2024 audit period. No new instances of returns outside of 45 days occurred with 2024-2025 Title IV funds. Of the four instances noted, three were directly attributable to items identified in the 2023–2024 audit, while the fourth was identified and resolved through our internal reconciliation performed to ensure no additional students were impacted. All returns of 2024-2025 Title IV funds were properly managed and made with the 45-day window. Hult’s collaboration with Financial Aid Solutions (FAS) continues to reinforce our compliance functions, cash management, and provide us with expert support. We implemented a comprehensive set of corrective actions beginning in Summer 2024 which strengthened our internal controls, which include: 1. Extensively redeveloped and tested our Regent infrastructure – in close collaboration with Regent and FAS – to ensure the system operates effectively within Hult’s academic structure, ensures the accuracy of data outputs, and maintains compliance with Title IV regulations 2. Hired a qualified, experienced, in-house financial aid team. We have, and continue, to prioritize cross-training and succession planning to ensure operational continuity 3. Implemented a dual-review process for all Title IV awards, with FAS processing calculations in Regent and Hult staff independently verifying them before disbursing funds 4. Introduced independent, recurring reconciliations of Title IV transactions by Hult’s central finance team, to ensure record accuracy and promptly resolve any issues identified These ongoing efforts have established a more resilient and accountable operational framework. We have demonstrated that with these controls in place, Hult will remain fully compliant with Title IV regulations, as there were no repeat instances of late returns in the 2024–2025 award year.

National Student Loan Data System (NSLDS) Enrollment Reporting Recommendation: We recommend the University review its reporting procedures to ensure the students’ statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The reporting data wasn’t being sent timely to NSLDS, as a result of process and procedural changes at the University. With new personnel in positions and changing processes, management is confident in data feeding NSLDS within the 60 day period after thorough review of the process overall. This includes a remediation effort of IT data feeds to the NSLDS and the compilation of data. As the enrollment data is not sent on a daily/frequent basis, the next reporting cycle (coming month), the process will be investigated and triaged as necessary. Names of the contact persons responsible for corrective action: Josh Perkins, AVP – Finance/Admin; Kevin Klawonn, Director - IT Planned completion date for corrective action plan: 6/1/2026

Common Origination & Disbursement (COD) Reporting Recommendation: We recommend the University establish a process to ensure that all disbursement information is accurately reported to the COD system. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The finding was ultimately caused by a syncing error of a batch job process that sends disbursement data to COD from our legacy (now retired) system that has since been replaced, as of October 2025. This was viewed as a one-off occurrence, not a broader systematic issue. The new system is better configured to accurately report disbursement information accurately. Further, Management has undergone a review of findings, and confirmed batch information is configured to send COD information accurately as of the finding notification date. Names of the contact persons responsible for corrective action: Josh Perkins, AVP – Finance/Admin; Kevin Klawonn, Director - IT Planned completion date for corrective action plan: April 30, 2026

Finding Number 2025-002 Enrollment Reporting ASCC Action Plan - 3 Contact Person(s): Shanell Tilo, Financial Aid Officer, Cr. Emilia Le'i, Dean of Student Services Dr. Letupu Moananu, Vice President of Academics, Community, and Student Affairs Explanation and specific reasons for disagreement with the audit finding or that corrective action is not required (if applicable): No disagreement. Corrective actions taken/planned: The Financial Aid Office ensures strict adherence to NSLDS reporting timelines. Institutionally, enrollment is certified monthly and the school responds within 15 days of the date NSLDS issues a roster file. Any errors identified through the NSLDS are reviewed, corrected and resubmitted within 10 days. To strengthen accuracy, completeness, and compliance, the Financial Aid Office has implemented a dual-review control system; Control #1 - The Processor (Financial Aid Coordinator) is responsible for retrieving the NSLDS Enrollment Roster, performing the initial review, data entry, and status updates. Control #1 cross-checks the roster against the SIS Pell Reconciliation Report (PRER) and ARGOS Enrollment Report. Control#1 identifies and adds students who are currently enrolled and have received Title IV at ASCC or another institution. Upon completion, notifies Control #2 via email for secondary review. Control #2 The Reviewer (Financial Aid Manager) conducts a secondary review to validate accuracy and completeness. Any discrepancies are documented and returned to Control #1 for corrections if necessary. Once data is verified, Control #2 authorizes final processing. Following approval, Control #1 manually reports and adds students via NSLDS website and completes the final sign-off, confirming that all required updates have been reported accurately and timely. A confirmation email is sent documenting the date of submission. A log of all NSLDS submissions is maintained, including submission dates and supporting documentation. The log includes evidence of both the processor and reviewer sign-off to ensure proper documentation and accountability. This tracking was implemented in January 2026 and is now part of the standard operating procedures.

Written procedures will be created on or before May 31, 2026, to ensure the timely return of funds to the Department of Education. Such procedures will include coordination with the Registrar’s office related to this process.

The Financial Aid Office will work closely with the Registrar's office to develop written procedures on or before May 31, 2026, regarding the submission of timely and accurate data regarding student withdrawals.