Corrective Action Plans

Corrective Action Plan 2025-001: We acknowledge the overaward of Direct Subsidized Loans and underaward of Unsubsidized Loans for both students identified in the finding. Based on the guidance in Volume 8, Chapter 3 of the 2024-2025 Federal Student Aid Handbook which states “If you discover that a student received Direct Subsidized Loan funds in excess of financial need after the student is no longer enrolled for the loan period, you are not required to take any action to eliminate the excess subsidized loan amount.” We have not adjusted the student’s loan awards given the identification of the overaward took place after the end of the loan period for each student. As the University has closed after August 15, 2025, no additional actions are considered necessary. Completion Date: August 2025 Contact Person: Ann Spall, Chief Financial Officer

Finding: 2025-001 Federal Agency Name: U.S. Department of Education Assistance Listing Number(s): 84.007, 84.033, 84.038, 84.063, and 84.268. Program Name: Student Financial Assistance Cluster Finding Summary: Under 34 CFR 690.63 and 685.200, institutions must calculate Pell grant and federal direct loan awards based on the student’s eligible enrollment status, cost of attendance, expected family contribution (EFC) or student aid index (SAI), satisfactory academic progress, and other Title IV eligibility requirements. Institutions are required to ensure award amounts are accurate and supported by the documentation in the students’ file. During testing of 60 students, it was found that two students who were not awarded the correct amount of Pell, one student who was not awarded the correct amount of federal direct loans, and two students who received subsidized direct loans however did not meet the requirements to receive the need-based aid. Responsible Individuals: Kella Helyer, Director of Financial Aid Corrective Action Plan: Management agrees with this finding. Banner reports have been modified to ensure that all students who are over gross need and over unmet need are captured in the report for the counseling team to review and update as needed. Anticipated Completion Date: February 16, 2026

Contact Person: Travis Mickey, Registrar Views of Responsible Officials and Planned Corrective Action: There is no disagreement with the audit finding. The College will collaborate with NSC to evaluate the errors in the file transmissions and to develop procedures to minimize further errors in the future. More specifically, the College will review the reporting procedures for withdrawn and graduating students to ensure the correct information is transmitted to NSLDS. Anticipated Completion Date: 6/30/2026

Federal Program: U.S. Department of Education: Student Financial Aid Cluster: Federal Pell Grant Program, Assistance Listing 84.063 Federal Supplemental Educational Opportunity Grants, Assistance Listing 84.007 Direct Loan Student Loans, Assistance Listing 84.268 Criteria: The College must comply with 34 CFR Section 668.22(a). Condition: We tested nine unofficial withdrawals, which included eight students enrolled in modules. For four of these students, the College used the number of days in the module the student withdrew from, instead of using the total amount days the student was enrolled in on the first day of the period or at any time during the period, based on the Title IV rules for modular enrollment. This resulted in the incorrect denominator and inaccurate calculations of earned and unearned aid. For one sample, the student earned sufficient credit hours in the first Fall module to be considered half-time. However the College still performed a return of funds calculation when the student withdrew from the second module even though no return of funds was required based on the Title IV rules for modular enrollment. Upon further analysis, there were 34 student that withdrew from the College during the year that were enrolled in modular programs and 12 of those students had an incorrect return of funds calculation. Cause: The College did not have adequate procedures to ensure that the return of funds calculations for modular students were performed in accordance with federal regulations. In addition, the College’s procedures did not include controls to identify circumstances in which return of funds were not required for modular students, such as when a student has already earned sufficient credit hours before withdrawal. Effect: Incorrect return of funds calculations for modular students led to inaccurate determinations of earned and unearned Title IV aid. Recommendation: We recommend the College implement controls to ensure the number of days used in the return of funds calculation is accurate based on the module-specific rules. We also recommend the College implement a review process to confirm whether a student has completed sufficient coursework to be considered half-time, thereby exempting them from the return of funds requirements, and to provide training to financial aid staff on the return of funds requirements from student enrolled in module programs. Views of responsible officials and planned corrective actions: The Director of Financial Aid will review the student’s enrollment on a module-by module basis at the time of withdrawal to determine the applicable payment period and correct number of days in the period. The Director of Financial Aid will develop a standardized R2T4 checklist for module programs that include identification of all modules within the payment period, confirmation of the student’s start and end dates for each module, and documentation of the total days in the payment period and days completed a the time of withdrawal. To ensure appropriate identification of students who may be exempt from R2T4 requirements due to completion of sufficient coursework, the Director of Financial Aid will establish a formal review process to include the following: 1) Prior to completing an R2T4 calculation, Director of Financial Aid will verify whether the student successfully completed coursework equal to or greater than half-time enrollment, in accordance with federal regulations. 2) This review will include confirmation of: a. Completed credit hours b. Applicable academic records or grades 3) Documentation of the half-time determination will be maintained in the student’s financial aid file to support exemption decisions when applicable The College will enhance training efforts to ensure staff are fully informed of R2T4 requirements specific to module-based enrollment. Training will be conducted annually and incorporated into onboarding for new staff. Completion date: 2/10/2026. Responsible staff: Crystal Benton, Director of Financial Aid.

Federal Program: U.S. Department of Education: Student Financial Aid Cluster: Federal Pell Grant Program, Assistance Listing 84.063 Federal Supplemental Educational Opportunity Grants, Assistance Listing 84.007 Direct Loan Student Loans, Assistance Listing 84.268 Criteria: The College must comply with 34 CFR 668.22(f). Condition: We tested nine official withdrawals, which included four students that officially withdrew in the Spring semester, with two of those who withdrew subsequent to spring break. We noted the incorrect amount of total days in the Spring semester was used in the return of funds calculation for all students who withdrew in the Spring semester. Additionally, the two of the students that official withdrew subsequent to spring break incorrectly had included in the total number of days attended in the semester in their return of funds calculation. Cause: The College does not have procedures in place to properly review days used and attended within the return of funds calculation. Effect: The provisions of 34 CFR Section 668.22 were not followed, thus a total of four students had incorrect return of funds calculations. Recommendation: The College does not have procedures in place to properly review days used and attended within the return of funds calculation. Views of responsible officials and planned corrective actions: The Director of Financial Aid has verified in the Student Aid Handbook to include the weekend after the last day of class to the next full day of instruction (includes Saturday and Sunday). Powerfaids has been updated to include these other days. Before finalizing any returns, the Assistant Director of Financial Aid will review the R2T4. Completion date 2/10/2026. Responsible staff: Crystal Benton, Director of Financial Aid

Finding 2025-001 Federal Program: U.S. Department of Education: Student Financial Aid Cluster: Federal Pell Grant Program, Assistance Listing 84.063 Criteria: The College must comply with 34 CFR 690.83 and 34 Section 685.301(a)(2). Condition: We tested 40 samples for eligibility, and noted that 12 of the samples had reporting errors related to the disbursement dates to Common Origination and Disbursement (COD). 11 of the errors related to Pell disbursements and one related to a disbursement of a direct loan. Cause: The College did not have a procedure in place to properly review COD disbursement amounts and dates to verify all students had the proper reporting in COD. Effect: The provisions of 34 CFR Section 690.83 and 34 Section 685.301(a)(2), were not followed and thus 11 students had incorrect reporting of one day in COD related to Pell disbursements and one student had incorrect reporting of 8 days related to a Direct Loan disbursement. Recommendation: We recommend that the College review all COD disbursements and perform monthly COD reconciliations by student to verify the disbursement date matches the student account. Views of responsible officials and planned corrective actions: The Director of Financial Aid will review and verify the funds that were disbursed to the students’ account match the disbursement dates in COD on the date the transfer batch report is sent to the College’s Business Office by pulling a reconciliation file from COD. The Director of Financial Aid also has in place to pull students who need Pell or Direct Loans to be disbursed by running a report out of CAMS instead of running a selection set in Powerfaids. Monthly reconciliations for both fund types will be completed every 30 days. Completion date: 2/10/2026. Responsible staff: Crystal Benton, Director of Financial Aid

Finding 2025-005 Finding Summary: Under 34 CFR 690.63 and 685.200, institutions must calculate Pell grant and federal direct loan awards based on the student’s eligible enrollment status, cost of attendance, expected family contribution (EFC) or student aid index (SAI), satisfactory academic progress, and other Title IV eligibility requirements. Institutions are required to ensure award amounts are accurate and supported by the documentation in the student’s file. During our testing of 60 students, we found one student who received a subsidized direct loan; however, did not meet the requirements to receive the need-based aid. Corrective Action Plan: The institution is actively working to address this system limitation to prevent future occurrences. Corrective actions include: 1. Collaborating with internal teams and system support to update the configuration so that Cost of Attendance and other adjustments can be made for students receiving student loans only. 2. Implementing additional review procedures to identify and document any instances where system limitations may impact COA calculations. 3. Training relevant staff on the updated process once system changes are in place to ensure consistent and accurate awarding moving forward. Responsible Individual(s): Monze Stark – Dean of Enrollment Services, Jennifer Service – Director of Financial Aid Anticipated Completion Date: 12/31/202525

Finding 2025-004 Finding Summary: 34 CFR 690.83(b)(2) and 34 CFR 685.309 states that Institutions are responsible for timely and accurate reporting of a student’s enrollment status and changes in those enrollment statuses, whether they report directly or via a third-party servicer. When an Institution is made aware of a change in a student’s enrollment status, the Institution has 60 days to update the change in enrollment status via NSLDS. During testing of compliance for Enrollment Reporting, there were 3 instances out of 60 where the College did not report a student’s change in enrollment status accurately or within the required time limit of 60 days from the effective date of the student’s change in enrollment status. Corrective Action Plan: Enrollment reporting has been centralized under a single point of contact, thereby mitigating risk, ensuring consistency, accountability, and regulatory compliance. This structure was formally implemented last summer with the hiring of an Academic Records Compliance Specialist, significantly strengthening oversight and operational controls. Responsible Individual(s): Monze Stark – Dean of Enrollment Services, Noah Briscoe – Assistant Registrar Anticipated Completion Date: 12/31/2025

Finding 2025-003 Finding Summary: 34 CFR 690.83 and the FSA Handbook states that an Institution must report accurate and timely data. During testing of compliance for COD Reporting, there were 6 instances out of 60 where the College did not report a student’s disbursement information to COD accurately. Corrective Action Plan: The institution has taken and has fixed this issue by: • The system is now functioning correctly after addressing the issue with the vendor. • To prevent future issues, a more robust tool has been developed to identify discrepancies promptly should they arise. Responsible Individual(s): Monze Stark – Dean of Enrollment Services, Jennifer Service – Director of Financial Aid Anticipated Completion Date: 12/31/2025

Finding 2025-002 Finding Summary: 34 CFR 668.164(h)(2)(i,ii) states that A title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but no later than—Fourteen (14) days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or Fourteen (14) days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period. During our testing of compliance for HEA Credit balances, there were 5 instances out of 60 where the College did not refund a student’s within the required time frame of 14 days from the first day of class or 14 days after the credit balance was created. Corrective Action Plan: The institution has taken and has fixed this issue by: • Dedicated Staffing: A full-time position has been approved and filled to manage stipend processing, ensuring consistent oversight and timely disbursement. • Process Documentation: Stipend processing procedures have been documented to ensure continuity, accountability, and clarity of responsibilities. • System Review and Planning: The system is up and running as it should have been. • Ongoing Monitoring: Leadership will continue to monitor stipend processing timelines and staffing capacity to ensure compliance and timely student support. Responsible Individual(s): Monze Stark – Dean of Enrollment Services, Bethany Parmer – Assistant Dean of Enrollment Services Anticipated Completion Date: 12/31/2025

Finding 2025-002 - Eligibility - Student Financial Assistance Cluster, ALN 84.268, June 30, 2025 Award Year, U.S. Department of Education Condition Calculation of Benefits: In addition to the requirements and limits, awards must be coordinated among the various programs and with other federal and nonfederal aid (need and non-need-based aid) to ensure that total aid is not awarded in excess of the student’s financial need or cost of attendance (34 CFR 668.42, FWS, and FSEOG, 34 CFR 673.5 and 673.6; Direct Loan, 34 CFR 685.301). The determination of need-based SFA award amounts is based on financial need. Non-need based SFA awards are not limited to financial need but cannot exceed the student’s COA. To determine non-need based SFA awards (unsubsidized aid) one would use the following formula – COA minus OFA. (November 2025 OMB Compliance Supplement pages 5-3-10 and 5-3-11) Out of forty students tested, two students were under-awarded both Subsidized and Unsubsidized loans and one student was under-awarded Subsidized loans. This was not a statistic. Corrective Actions To address the finding, loan certification procedures have been revised to include step-by-step procedures for determining loan eligibility. A standardized template has been created for calculating subsidized and unsubsidized loan amounts, with clear instructions that subsidized loans must be maximized before awarding unsubsidized loans. Comprehensive training on the calculation of loan eligibility has been provided for new staff, including subsidized versus unsubsidized loan rules, and one-on-one coaching is being provided for staff members with knowledge gaps. A quality assurance program that includes a random sample review of loan awards will be performed between the fall and winter semesters to identify errors and ensure that loans are being certified in accordance with applicable rules and limits. Reviews and findings will be documented so that errors can be addressed immediately. Responsible Official: Wendy G. Glass, Director of Student Financial Services Completion Date: December 4, 2025

Finding 2025-001 - Reporting: Financial Reporting - Student Financial Assistance Cluster, ALN 84.268 and 84.063, June 30, 2025 Award Year, U.S. Department of Education Condition Institutions submit Direct Loan, Pell Grant, and TEACH Grant origination records to the Common Origination and Disbursement (“COD”) system. The disbursement record reports the actual disbursement date and the amount of the disbursement. Institutions must report student disbursement data within 15 calendar days after the institution makes the disbursement or becomes aware of the need to make an adjustment to previously reported student disbursement data or expected student disbursement data. (November 2025 OMB Compliance Supplement page 5- 3-24) Three out of forty disbursements tested were reported late to COD, one was 3 days late and two were 23 days late. Corrective Actions To address the finding, procedures have been revised to specifically address COD reporting during school closures, emergency situations, and off-cycle disbursements. As part of this effort, key dates have been noted on a shared calendar for staff to reference to ensure timely reporting under various circumstances. To maintain compliance going forward, staff will perform weekly reviews of all disbursements to ensure timely COD reporting, and monthly audits of COD reporting will be conducted to identify late submissions and address issues promptly. Responsible Official: Wendy G. Glass, Director of Student Financial Services Completion Date: December 4, 2025

Title: Student Financial Assistance Cluster – Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend the College review all R2T4 calculations to confirm accuracy. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We added an additional validation step in our process to confirm that the original charge amounts are accurate. Name(s) of the contact person(s) responsible for corrective action: Danielle Hayden Planned completion date for corrective action plan: October 1, 2025

Title: Student Financial Assistance Cluster – Assistance Listing Nos. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend the College review its reporting procedures to ensure that 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: We identified that the issue is related to transferring data between NSC (where we report enrollment for all students) and NSLDS (where federal aid recipients are monitored). To bridge this gap, we have provided a member of the Registrar’s Office with access to NSLDS to audit the data submitted to NSC and the transfer of information. Additionally, we are conducting research to determine if there are alternative reporting options that may provide greater accuracy. Name(s) of the contact person(s) responsible for corrective action: Theresa Rodriguez Planned completion date for corrective action plan: March 2026

Finding Number: 2025-001 Federal Program: U.S. Department of Education – Student Financial Assistance Cluster Assistance Listing Numbers: 84.063, 84.007, 84.268, 84.033 Compliance Requirement: Special Tests and Provisions – Enrollment Reporting Finding Summary: The College agrees with the audit finding and is committed to strengthening internal controls over enrollment status reporting to ensure continued compliance with federal requirements. During management’s review of the audit results, the Registrar’s Office was unable to reproduce the specific enrollment status reporting errors identified during audit testing and could not definitively determine how the errors occurred. Notwithstanding this, the College recognizes that weaknesses in monitoring and documentation contributed to the inability to detect and prevent the reporting discrepancies in a timely manner. Accordingly, management has developed the following corrective actions. The College will enhance coordination among Registrar’s Office, Financial Aid, and Information Technology to ensure enrollment status changes including graduation, withdrawal, and changes in enrollment status are identified promptly and reported accurately to the National Student Loan Data System (NSLDS) within the required 60-day timeframe in accordance with 34 CFR 690.83(b)(2) and 34 CFR 685.309. For over 20 years, the College of Idaho has been a member of the National Student Clearinghouse (NSCH). One of the many advantages of membership to the NSCH is that the NSCH serves as a conduit to NSLDS and sends reports to the NSLDS for the college. Ellucian Colleague has written a series of reports that result in a .txt file that is uploaded to NSCH who in turn uploads to NSLDS. The College of Idaho submits regular transmissions to NSCH so that the 60-day timeframe is met. Corrective Action Plan: • Process Review and Clarification of Roles The Registrar’s Office will review and formalize procedures related to enrollment status determination and reporting. Roles and responsibilities for identifying enrollment changes, preparing NSLDS files, and submitting updates will be clearly documented to ensure accountability and continuity. • Student Information System Reporting Improvements The College will refine and validate student information system (SIS) reports used for enrollment reporting to ensure accurate capture of enrollment status changes and effective dates. Reports will be reviewed regularly to confirm continued reliability. • Internal Review and Oversight Controls Prior to submission to NSCH, enrollment status reports will be reviewed by the Registrar supervisory personnel to confirm accuracy and completeness. Evidence of review will be retained in accordance with institutional record retention practices. • Established Reporting Timeline A recurring reporting calendar will be implemented to ensure enrollment status updates are submitted within required federal timeframes. Backup personnel will be identified to support continuity during staff absences. • Training and Ongoing Communication Staff involved in enrollment reporting will receive periodic training on federal enrollment reporting requirements and institutional procedures. Regular communication between Enrollment Services and Financial Aid will support timely identification and resolution of discrepancies. Responsible Official(s): Mark Heidrich (Registrar/Associate Vice President for Institutional Effectiveness), in coordination with Stephanie House (Director of Financial Aid) and Imad Sweidan (Chief Information Officer), as appropriate. Anticipated Completion Date: June 30, 2026 Current Status: Corrective action is in progress. Management expects these actions to be fully implemented prior to the next audit period and believes the strengthened controls will prevent recurrence of this finding.

The College will diligently check each financial aid disbursement roster to review and refund any student account credit balances generated from a disbursement. This process is to maintain compliance with this requirement. The College will also create an Infomaker report each week to identify any credit balances that need refunded.

All Registrar staff were re-trained on the proper procedures as they relate to updating enrollment status for students. A double check system was put into place to have two members of the Registrar staff check each student to ensure proper enrollment status accuracy is achieved.

Financial Aid personnel responsible for loan disbursements will review both COD and Pfaid records to ensure they align with the corresponding student account disbursement information. Additionally, the office will conduct monthly COD mismatch reviews to determine whether maintenance files need to be submitted. This process will help ensure continued accuracy and compliance in federal reporting.

Views of responsible officials and planned corrective actions: The University does not agree with the conclusion of this finding. The University determines a student’s withdrawal date based on the student’s official notification or, where applicable, the date of determination when a student ceases attendance without providing official notice. Based on the University’s review of institutional records and applicable regulatory guidance in effect during the audit period, management believes the withdrawal processing methodology applied was reasonable and consistent with institutional procedures and Title IV requirements. For three of the four students identified, the data reported to NSLDS reflected the institution’s determination date rather than the withdrawal date. Management maintains that this approach was the result of interpretation applied to specific withdrawal circumstances and did not materially misrepresent the students’ enrollment status or Title IV outcomes. For the remaining student, management agrees that a clerical data-entry error resulted in an incorrect withdrawal date being reported to NSLDS; however, this instance was isolated and does not represent a systemic control deficiency. While the University does not agree that the instances cited constitute noncompliance, management acknowledges the auditor’s concern regarding consistency in distinguishing withdrawal dates from determination dates for NSLDS reporting purposes. In response, and without conceding noncompliance, the University will enhance its policies, procedures, and internal controls to promote consistent application of regulatory definitions and reduce the risk of future discrepancies.

Finding - Eligibility - Federal Direct Student Loan Program, Assistance Listing Number 84.268 and Federal Pell Grant Program, Assistance Listing Number 84.063: June 30, 2025 Award Year: U.S. Department of Education Criteria or Specific Requirement The amount of a student’s Pell Grant for an academic year is based upon the payment and disbursement schedules published by the Secretary for each award year. (34 CFR 690.62 through 690.66). Direct Loans are determined based on the criteria noted in 34 CFR 685.203(a),(b),(c). Condition Of the 40 students selected for eligibility testing, two students within the sample were incorrectly awarded aid based upon their specific circumstances. This was not a statistically valid sample. Views of Responsible Officials and Planned Corrective Actions The University concurs with the finding. The University will strengthen quality control through improved reporting and staffing to ensure accurate and compliant student aid awards. Names of Contact Persons Responsible for Corrective Action: Anne-Marie Caruso, Associate Vice President, Student Financial Services; Beck Gusler, Director Financial Aid Compliance. Anticipated Completion Date: December, 2025 Summary Schedule of Prior Audit Findings None.

In order to maintain procedures to verify the disbursement dates in the COD System agree to the date funds are credited to the student’s account in the colleges Accounts Receivable subledger to the general ledger, the institute has updated its procedures. The Financial Aid Office will adjust the scheduled disbursement date according to updated procedures when disbursement occurs earlier than the scheduled date to ensure accuracy of reporting data to COD. These are updates to the current Disbursement Policy and Procedures.

Recommendation: We recommend the College review its reporting procedures to ensure the students' statuses are accurately 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 Financial Aid Office updated procedures when citizenship documentation is received for a student previously classified as a noncitizen. The Financial Aid Office will notify the Office of Records and Registration of the student’s status change. Prior to disbursing Title IV aid, the Financial Aid Office will verify with the Office of Records and Registration that the student has been added to required NSLDS reporting. Name(s) of the contact person(s) responsible for corrective action: Tasha Marwitz Planned completion date for corrective action plan: Effective immediately.

Management agrees with the finding. Management at the System Office will work with KVCC and YCCC to implement a process in which all Direct Loan disbursements receive notification within the 30-day window. The timing of this resolution is anticipated to occur in Spring 2026. Richard Rosen, Chief Financial Officer (Interim), is responsible for the corrective action plan.

Management agrees with the finding. Management at the System Office will work with CMCC, YCCC, MCCS IT Shared services and specialists with the Student Information System vendor to implement a process in which all disbursement calculations are checked by the software platform for accuracy. The timing of this resolution is anticipated to occur in 2026. Richard Rosen, Chief Financial Officer (Interim), is responsible for the corrective action plan.

Management agrees with the finding. Management at the System Office will work with EMCC and CMCC management to implement a process which verifies all refund calculations of Title IV funds (R2T4) are reviewed by the appropriate level of management to ensure timely filing to the COD system is occurring. The timing of this resolution is anticipated to occur in Spring 2026. Richard Rosen, Chief Financial Officer (Interim), is responsible for the corrective action plan.