Corrective Action Plans

The Office of the Registrar will continue to submit enrollment data to the National Student Clearinghouse via the current schedule. The Office of the Registrar will investigate and resolve any errors returned by the National Student Clearinghouse. After the enrollment data is transferred from the NSC to NSLDS the Registrar's office will review the data in NSLDS for any discrepancies including cross-checking graduation files and complete withdrawals. Any inconsistencies will be discussed and timely resolved by the applicable units and officially updated in NSLDS and NSC respectively. The University will keep track of any changes manually made within the NSLDS or NSC database by university representatives, so that the student information system, NSC, and NSLDS records are in-sync.

Management agrees with the auditor’s finding and their recommendation. The School returned $37 of Pell Grant Funds on November 25, 2025. Communication will be improved between the financial aid office and the registrar. Procedures will be improved to ensure that R2T4s are calculated correctly. Anticipated Completion Date: The corrective action was completed on November 25, 2025. Contact Person Valorie Quesenberry, Financial Aid Coordinator 513-763-6659

Finding 2025-001: Instance was identified where a student’s status was not accurately reported. Name of Responsible Individuals: Elizabeth Cox, Registrar & Director of Institutional Research & Ruth Casper, Assistant Vice President of Student Financial Services Corrective Action: The University Financial Aid Office will provide the Registrar with a report of enrolled student social security numbers from the financial aid system prior to the creation of an enrollment file for National Student Clearinghouse reporting. The financial aid file will be used to identify and correct any Social Security number discrepancies. Updates and corrections may include subsequent reporting to the Clearinghouse and/or manual reporting to NSLDS. Anticipated Completion Date: Ongoing

The Downey Adult School (DAS) concurs with the audit finding and to prevent future occurences, the school has purchased a new student database management software system (Campus Café) that articulates with the National Student Loan Data System (NSLDS) in reviewing, updating, verifying, and reporting student enrollment statuses, program information, and effective starting and ending dates that are required to appear on the Enrollment Reporting Roster file, this new process of enrollment and certification eliminated the potential for human errors by obtaining student information data derived directly from the Student Information System (SIS). In addition, DAS continues to work with its SIS, Campus Cafe, to electronically integrate with the Nation Clearing House, specifically with direct transmission of enrollment and certification reporting. The current processes of enrollment and certification reporting will be eliminated and replaced with processes of direct enrollment and certification reporting from the SIS to the National Clearing House, then to NSLDS. The contact person responsible for the implementation of this action plan, to correct State Finding 2025-001, is Ms. Blanca Rochin, Downey Adult School Principal. Implementation Date: August 18, 2025

Management agrees with the auditors’ finding and their recommendation. The NSLDS withdrawal date was updated for one of the students in question before the audit began on July 7, 2025. The withdrawal dates for the remaining four students were updated in August 2025. The student financial office will review withdrawal dates for students who leave during the semester to ensure the dates are not changed to the last date of the semester. Anticipated Completion Date: The corrective action was completed in August 2025. Contact Person Shala LaTorraca, Director of Financial Aid 918-335-6260

Condition The change in student status for 7 of the 7 students tested was not reported to the National Student Loan Data Systems (NSLDS) within 30 days or included in a response to a roster file within 60 days. The sample was not a statistically valid sample but was determined using Chapter 21 - Audit Sampling Considerations of Uniform Guidance Compliance Audits of the Government Auditing Standards and Single Audit Guide. Corrective Action Plan The Ailey School Registrar’s Office has implemented enhanced procedures to ensure that all student status changes are reported to the National Student Loan Data System (NSLDS) within the required timelines. Staff received system training on November 18, 2025 by the Ailey’s School third party processor. and began using the portal immediately to update all future enrollment changes. The Registrar’s Office will follow a formalized reporting schedule to comply with the 60-day submission requirement and will provide confirmation of each update to the Director of Business Operations and the Finance Controller. In parallel, the Finance Office will maintain an independent tracking schedule to verify that all required reports have been submitted. With these new protocols in place, the Ailey School anticipates no findings related to enrollment reporting in FY26. Contact Persons Responsible for Corrective Action: Jennifer Quinones, Director of School Operations Blythe Koster, Registrar Patrick Piras, Coordinator Denise Fox, Finance Controller Anticipated Completion Date: November 18,2025

2025-001 - Student Financial Assistance Cluster - (a) Federal Supplemental Educational Opportunity Grants (b) Federal Work-Study Program (c) Federal Perkins Loan (d) Federal Pell Grant Program (e) Federal Direct Student Loans (f) Teacher Education Assistance for College and Higher Education Grants (TEACH Grants) (a) 84.007 (b) 84.033 (c) 84.038 (d) 84.063 (e) 84.268 (f) 84.379 - Year Ended June 30, 2025 Criteria: 34 CFR 668.162 (d) states: Under the heightened cash monitoring payment method, an institution must credit a student’s ledger account for the amount of Title IV, HEA program funds that the student or parent is eligible to receive, and pay the amount of any credit balance due before the institution submits a request for funds. Condition: We tested 40 students and credit balances were not paid in a timely manner for 8 students (20%). We consider this condition to be a material weakness for the Special Tests and Provisions compliance requirement and is not a repeated finding. Statistical Sampling was not used in making sample selections. Responsible Persons: Andra Butler and Jessica Justice Corrective Action Plan: Management agrees with the finding. Management has already implemented corrective actions to ensure that credit balances caused by federal funds are refunded prior to those federal funds being requested by the University. Financial Aid notifies the Business Office when all postings are complete. The Business Office then runs a disbursement roster and refunds those students with credit balances. Once the refunds have been delivered to the students, the Business Office draws in the funds per the disbursement roster totals. The disbursement roster is retained as support for the drawdown amount Implementation Date: Fall 2025

Corrective Action Plan – Kansas Health Science University Identifying Number: 2025-001 Finding: Excess Cash – Student Financial Aid Applicable Regulation: According to Uniform Grant Guidance (34 CFR 668.166), the Secretary considers excess cash to be any amount of Title IV, HEA program funds, other than Federal Perkins Loan program funds, that an institution does not disburse to students within the required timeframe. Institutions must return any amount of excess cash over the one-percent tolerance and any remaining cash after the seven-day tolerance period. Finding: Kansas Health Science University (KHSU) had one instance of excess cash for the Federal Direct Student Loan program. During cash management testing, excess cash balances ranging from $94,646 to $190,735 were identified for the period March 21, 2025, to April 5, 2025. These balances exceeded the one-percent tolerance of prior year drawdowns and were not returned within the required seven-day period. Summary: KHSU identified one instance of excess cash due to delays in returning unused funds. The issue arose because records transmitted to the Common Origination and Disbursement (COD) system were rejected, which prevented the Cash Funding Ledger (CFL) from accurately reflecting a balance owed through G5/G6. Once the rejected records were identified, the Financial Aid OƯice promptly reconciled and corrected them in COD, enabling the CFL levels to reflect the correct balance and allowing the return of excess cash through G5/G6. Corrective Action Planned or Taken: To prevent recurrence of this issue, the Financial Aid Office will implement a proactive measure: - If a similar technical issue is identified in the future, a temporary refund will be initiated in G5/G6 while reconciliation is underway. Once the actual refund amount is confirmed, the final adjustment will be made accordingly. Contact Person: Michelle Miller, Senior Vice President of Enrollment Management mmiller10@tcsedsystem.edu Anticipated Completion Date: September 30, 2025

Management agrees with the auditors’ finding and their recommendation. The CFO will request a waiver for the 2025-2026 school year. Contact Person: Tasha Young, CFO 816-425-6151

Management agrees with the auditors’ finding and their recommendation. The CFO is working with the TPA to recalculate the R2T4s. The necessary changes detailed in the Possible Asserted Effect section were made in November 2025. Anticipated Completion Date: The corrective action will be completed by November 30, 2025. Contact Person: Tasha Young, CFO 816-425-6151

Management agrees with the auditors’ finding and their recommendation. The CFO has worked with the registrar and other University personnel to file the NSLDS reports. Eventually, the CFO updated enrollment status manually. A report was filed in July 2025. Going forward, the NSLDS enrollment status roster reports will be filed timely. If there is a technology issues, enrollment status changes will be input manually by University personnel. Anticipated Completion Date: The corrective action was completed in July 2025. Contact Person: Tasha Young, CFO 816-425-6151

Corrective Action Planned: The Financial Aid department will distribute an email to the relevant departments upon completion of each financial aid transmittal process, prompting the Information Technology (IT) department to generate direct loan disbursement notifications via email. After emails are distributed, IT will provide Financial Aid with a report of the notifications sent. The Financial Aid Director or Assistant Director will review and compare the data from the IT notifications report to the financial aid disbursement records to ensure accuracy and completeness. Anticipated Completion Date: June 30, 2026 Responsible Person: Tasha Campbell, Director of Financial Aid campbellt68@morainevalley.edu

Corrective Action Planned: Responsibility for reporting has been reassigned to a senior staff member. A secondary review process has been established, requiring managerial verification before submission. Additionally, monthly reconciliations will be conducted to ensure that all status changes are reported accurately and within the required timelines. Timeline: Reassignment of reporting responsibility: Effective immediately. Establishment of secondary review and reconciliation procedures: Within 30 days. Monthly reconciliation review: No later than November 30, 2025. Anticipated Completion Date: June 30, 2026 Responsible Person: Tasha Campbell, Director of Financial Aid campbellt68@morainevalley.edu

2025-001 Inaccurate and Untimely Return of Title IV Funds (R2T4) Planned Corrective Action: The current process for completing the Return of Title IV aid is to have the Title IV counselor review and complete the calculation. Then send it to the Director of Financial aid for final review. We have implemented an internal control as of 09/01/2025, that at the close of every month the Office of Financial Aid verifies with registrar’s office that we have been notified of all withdrawn students to ensure that the process has been completed within the 45 days. The misunderstanding with the 49% exemption has been clearly understood, and proper execution of that rule will be implemented. Person Responsible for Corrective Action Plan: Kenneth Piester, Director of Financial Aid Anticipated Date of Completion: 09/01/2025

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Records & Registration will now submit modified enrollment files as Graduates Only records to ensure accurate and timely graduation status updates. This solution has been confirmed by NSC. Additional staff have been trained on the updated procedures, and new processes are in place to ensure discrepancies and error flags are resolved promptly. Records & Registration and the Financial Aid Office continue to collaborate to identify and address discrepancies that may affect Title IV eligibility. Person(s) Responsible: Assistant Registrar, Director of Financial Aid Timing for Implementation: Immediate

Return of Title IV Fund Calculations Condition/Context: For two of the six students selected in the sample, the amount of the Title IV refund was calculated incorrectly due to using the incorrect number break days for students that withdrew in the Spring term. This results in too much being returned to the U.S Department of Education. Recommendation: The University should modify its procedures for refunding awards to ensure proper data computations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The scheduled break days for the spring semester accidentally failed to include the weekend before the week of Spring Break. The school calendar profile for the Return of Title IV Funds Calculation will now be reviewed by both the Director of Scholarships and Financial Aid and the Assistant Director of Financial Aid before being created in the COD Return of Title IV Funds Tool each term. Contact person: Tom Ochsner, Director of Scholarships and Financial Aid Planned completion date for corrective action plan: August 27, 2025 If the Department of Education has questions regarding this plan, please call Tom Ochsner at (402) 465- 2212.

Enrollment Reporting Condition/Context: For one out of 25 students selected in the sample, the effective date that was reported to NSLDS did not match the date that the student changed status. For a second student, the student's enrollment status was not correctly reported within the 60 day requirement Recommendation: The University should review its procedures to ensure that all effective dates for enrollment status chan•;Jes are updated accurately in NSLDS. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: To prevent future occurrences: • We have implemented an additional verification step in our status update workflow. • We are reviewing how major changes interact with enrollment status updates in Colleague. • We will implement a validation step to ensure that effective dates reflect the original action date when multiple updates occur in close succession. Contact person: Tom Ochsner, Director of Scholarships and Financial Aid Planned completion date for corrective action plan: August 27, 2025 If the Department of Education has questions regarding this plan, please call Tom Ochsner at (402) 465- 2212.

Midland University Corrective Action Plan For the Year Ended May 31, 2025 Finding 2025-002: Significant Deficiency - NSLDS Enrollment Reporting Condition: Of the 25 students tested, two students had incorrect or late information reported. One student's withdrawn date reported in spring 2025 did not agree to the University's documentation to support the date of determination. A second student's status' certification date was reported 71 days after their date of determination. Corrective Action Plan: Beginning in Summer 2025, the new Financial Aid Director and Registrar have been meeting bi-weekly to discuss all aspects of enrollment reporting. This will ensure that both offices are aware of reporting requirements and timelines. Name(s) of Contact Person(s) Responsible for Corrective Action: Jon Dechant, Director of Financial Aid & Joseph Harnisch, CFO Anticipated Completion Date: Finding 2025-002: Completed in July 2025

Midland University Corrective Action Plan For the Year Ended May 31, 2025 Finding 2025-001: Significant Deficiency- Return of Title IV funds (R2T4) Condition: Of the 16 students tested in the sample, one student did not have an R2T4 completed during Summer 2024. Subsequent to the auditor identifying this exception in July 2025 the University completed the calculation and returned the required funds. The auditor reviewed the calculation and student's account statement confirming that corrective action was taken. Corrective Action Plan: Beginning in Summer 2025, the new Financial Aid Director and Registrar have been meeting bi-weekly to discuss all changes of enrollment including withdrawals. This process ensures that all students are reviewed and R2T4's are completed on all students who withdraw from Midland University and have Title IV funding. Name(s) of Contact Person(s) Responsible for Corrective Action: Jon Dechant, Director of Financial Aid & Joseph Harnisch, CFO Anticipated Completion Date: Finding 2025-001: Completed in July 2025

Corrective Actions: The University has implemented the following measures with respect to enrollment reporting (“ER”) to strengthen internal controls and ensure full compliance with federal regulations, University policy, and the requirements of NSLDS: 1. Review of ER Systems and Updates Implemented: The University has contracted with external consultants to assist the University in reviewing and reinforcing its ER systems and processes. This work is ongoing and intended to supplement the prior review of the University’s SIS noted in the Response above, which determined a delay in the chronological processing of reports in NSC due to configuration issues in the SIS contributed to the untimely/inaccurate reporting. As a result, the University updated those parameters within its SIS to ensure accurate configuration in Spring 2025. Through this Finding response and the internal and external reviews initiated by the University, Texas Wesleyan has built upon that prior examination to include an analysis of the specific deficiencies noted by auditors and ensure the same have been cured, as well as to implement any necessary compliance measures to safeguard all future ER. In addition to completing any updates required to student-level data in NSC, the University reviewed each deficiency and corresponding student record to discern the cause of the inaccurate data and made necessary systems and/or procedural changes to cure each. First, the University determined that for two of the students with ER errors, additional processes were necessary to capture students enrolled in compressed terms. In collaboration with external consultants and NSC, the Registrar’s Office is developing new processes to ensure accurate ER for these students. This process development is being overseen by Registrar and Associate Provost with a target date for implementation during the initial Spring 2026 7-week compressed terms beginning on January 12th and March 23rd, respectively, subject to testing being conducted with NSC. Second, with respect to graduation status, the University has reviewed the students noted in this Finding with its external consultants and NSC. To ensure that graduation statuses are timely and accurately reported according to University policy and federal requirements, the University is adopting updated procedures to include reporting “G” or “W” status in accordance with guidance from the NSLDS Enrollment Reporting Guide, Section 4.4.4. These procedural updates are being made by the Registrar, overseen by the Associate Provost, and are expected to be finalized by December 5, 2025 Third, together with IT and external consultants, the Registrar’s Office is continuing its review and testing of parameter settings through a comparison of SIS and NSC data to confirm that parameters are accurately configured for ER. The data for this review has been compiled as of the date of this submission and the Registrar is reviewing the data to prepare a comparative report that will be provided to the Working Group (described in Section 2 below) overseen by the Associate Provost. The Registrar’s comparative report to the Working Group is expected to be delivered on January 20, 2026. Finally, as noted below, to ensure timely and accurate reporting and the reconciliation of error reports, the University has implemented several preventive and detective measures with ongoing monitoring and review measures to ensure its compliance. 2. Preventative Measures and Monitoring: The University has integrated, and continues to integrate, updated detective and preventative controls on ER to safeguard the University’s compliance for future reporting by expanding existing reporting controls through regular monitoring efforts to test and review compliance at each reporting level. These preventative measures, monitoring and reconciliation requirements are being overseen by the Associate Provost and include the establishment of a Working Group with external consultants and service providers, as well as stakeholders from the Provost, Registrar, Information Technology, and Financial Aid offices, that meets frequently to review ER, complete the work described in these Corrective Actions, and to ensure discrepancies are discovered and resolved timely and accurately. The Registrar and the Director of Financial Aid also meet monthly to conduct reconciliations of ER which is then reported to the Provost and Associate Provost. In addition to updating its graduation ER procedures, the University has updated its reporting schedule in NSC to provide additional reporting opportunities during the end of the term to ensure all graduation information is timely reported. Finally, the University has met with NSC to review this Finding and its ER practices generally. As a result of that meeting, the University has received from NSC its “Enrollment Reporting Compliance Best Practices Checklist” which the Registrar has provided to all staff in the Registrar’s Office as a guidance document and reference tool for ER. In addition, the Registrar is conducting an office-wide review of the NSC “Enrollment Reporting Compliance Best Practices Checklist” on December 4th, 2025. 3. Staff and Training: In conjunction with this Finding and the internal and external reviews, the University has and continues to review staffing within the Registrar’s Office to ensure appropriate changes have been made as deemed necessary by management. To ensure compliance and accuracy, beginning December 9, 2025, all personnel in the Registrar’s Office will participate in a weekly “Power-Hour” meeting wherein they will complete ER training through NSC, Federal Student Aid, and other resources. This training will continue in accordance with the 2026 training plan and schedule being developed by the Registrar. The training plan and schedule will be delivered to the Associate Provost by January 1, 2026, and is subject to their review and approval. All training and participation will be documented in a report to the Associate Provost. The University has also engaged external consultants to assist staff in ER to ensure compliance and provide secondary review for the Registrar’s Office as needed. Responsible Official: Dr. Helena Bussell, Associate Provost Estimated Completion Date: April 24, 2026

Corrective Actions: To strengthen internal controls and ensure full compliance with federal regulations, the University has implemented the following measures: 1. Secondary Review Implementation: The University has contracted with an external consultant to serve as a secondary reviewer. In the interim, an internal staff member is receiving comprehensive R2T4 training and will complete the NASFAA Return of Title IV Funds Certification Program in March 2026. Upon completion of the NASFAA Program coursework, the staff member will complete an examination on or before May 31, 2026. Once certification is achieved and the University has full confidence in the internal review process, the secondary review function will transition from the external consultant to an in-house process. 2. Documentation Retention Enhancement: The University has reinforced procedures, including those document retention protocols, by adding this as an additional checklist item on the R2T4 checklist, to ensure that all post-withdrawal disbursement notifications are properly retained in each student’s financial aid record, either electronically or within the designated document management system. The checklist is meant to be a roadmap for the reviewer to ensure each step is completed in the calculation process and that documentation is retained for post-withdrawal disbursement. 3. Staff Training: All financial aid staff involved in the R2T4 process have received updated training on the correct handling of loan returns and post-withdrawal notifications in accordance with 34 CFR 668.22 and current FSA Handbook guidance. Staff involved with R2T4 administration include the Financial Aid Business Analyst and a Financial Aid Advisor. Both team members have completed either official NASFAA or FSA training. The Financial Aid Advisor will be completing the NASFAA Certificate training on R2T4. Additionally, the Assistant Director will also complete the program at the same time, increasing the depth of knowledge for the team around this topic. Responsible Official: Doug Cleary, Director of Financial Aid Estimated Completion Date: May 31, 2026

Attached to this document is a new Summer Pell Policy and Procedures that we developed after the Pell finding was brought to our attention this past summer. A mentor from another private institution that uses Colleague (the same system we use) was recommended to our team to help guide us when awarding summer Pell using the Pell Grant Enrollment Intensity formula. We implemented training on the Enrollment Intensity formula and had various calculation scenarios tested by our new mentor. We then awarded all summer term students who were entitled to the Pell Grant award and disbursed aid to those students by the required deadline. For the future, we will follow the newly developed Summer Pell Policy and Procedures. We will engage with the Registrar's Office to determine and verify when students register, drop and/or change courses for the summer term. In addition, running weekly Informer reports will be another safety net for our office when determining Pell eligibility for summer students. The Financial Aid staff will also immerse themselves in various forms of training available to us on all aspects of processing and awarding aid. We will do this via webinars, TASFAA and NASFAA training opportunities, internal cross-training and various FSA training programs. This year, two members of our team are new to financial aid and the remaining two, including myself, are new to our positions and responsibilities. We feel taking advantage of the plethora of training resources available in our industry will be vital to our growth and success while navigating higher education's rapidly changing regulations. Person ResponsibLe for Corrective Action PLan: Hayley Jordan - Director of Financial Aid Anticipated Date of Completion: Implemented.

The College acknowledges that it did not have a full understanding of the differences between and purpose of the NSC reporting file types “Subsequent of Term,” “End of Term,” and “Degree,” which lead to the incorrect file being submitted at the conclusion of Spring 2025. As a result, NSLDS records for 433 students were not updated in a timely fashion. In order to remediate the NSLDS records, the College worked with the NSC to recall and resubmit all files for period May to September 2025. As of October 2025, all Spring 2025, Summer 2025, and Fall 2025 to-date data reported to the NSLDS properly reflects student statuses. The College will continue to work with the NSC to ensure that “Pre Term”, “Subsequent of Term”, “End of Term,” and “Degree” files are being transmitted in an orderly, timely, and automated manner that minimizes the need for staff intervention. The College will follow NSC’s best practices guidance on data file management. The Planned Corrective Action will be implemented immediately.

Return of Title IV (R2T4) Calculations Planned Corrective Action: OFA will implement a process where an additional person will review R2T4 student records to ensure proper return of funds and calculations. OFA and VPAA will develop a process for instructors and Registrar to identify students that did not begin attendance. Person Responsible for Corrective Action Plan: Stephanie Castillo, Director of Financial Aid Penny Hayes, Vice President of Academic Affairs Anticipated Date of Completion: Spring 2026