Corrective Action Plans

Views of Responsible Officials and Corrective Action Plan The discrepancies noted during the 2024–2025 Financial Aid Audit were found to be attributable to a separate system configuration issue, distinct from the discrepant records identified in the 2023–2024 annual audit, which involved incorrect reporting of effective enrollment status dates. To resolve this matter and prevent recurrence, the District has implemented the following corrective actions: 1. Root-Cause Analysis: Conducted a comprehensive review with IT, Admissions & Records, Financial Aid, and third-party consultants to isolate and correct the specific system errors. 2. Update Systems Settings: Updating systems settings to accurately select records for reporting along with the perspective effective date and accurately report the three-quarter time enrollment level. 3. Manual Verification: Financial Aid staff responsible for Return to Title IV (R2T4) processing will manually review all student enrollment records in NSLDS (approximately 2,400 annually) to ensure accuracy. 4. Ongoing Compliance Monitoring: Established quarterly joint compliance reviews with IT, Admissions and Financial Aid leadership to verify continued accuracy of NSC/NSLDS reporting and to ensure timely detection of anomalies.

Management recognizes that staff had incorrectly interpreted the length of break that would necessitate a change in the refund calculation. Staff are now aware of the correct interpretation of the rule and will use it for all future calculations. Management will also identify a consultant to work with the College’s Director of Financial Aid, Controller and Registrar to review all rules regarding return to title IV calculations so a guide can be created to lessen the chance of incorrect calculations going forward.

Recommendation: We recommend the University review its reporting procedures to ensure that enrollment status change is reported timely to NSLDS as required by regulations. Action taken in response to finding: The University’s enrollment verification process includes reviewing a sample of students whose enrollment status changes were submitted to the National Student Clearinghouse to confirm that NSLDS was updated as expected. This process identified the issue noted in the finding, and it was corrected prior to the audit. To further strengthen controls, the University has implemented additional ad hoc NSLDS reporting to confirm that submitted data is processed after NSC transmission, while continuing the established verification process. Names of the contact persons responsible for corrective action: Shawnn Palmer, Director of Academic Technology and Reporting Planned completion date for corrective action plan: As of January 9, 2026, the student record in the finding has already been corrected. The additional audit report is in draft and will be validated prior to the April reporting. If the Department of Education has questions regarding this plan, please call Joshua Morey, Senior Director of Financial Aid, at (951) 343-4236.

Finding Number: 2025-002 Federal Program: Student Financial Assistance (SFA) Cluster - Various ALN Control Requirement - Return of Title IV Funds Management’s Response The University of Puerto Rico concurs with this finding. Institutional units have identified opportunities for improvement in internal controls related to the timely return of Title IV funds and have implemented, or are in the process of implementing, corrective measures to ensure compliance with the regulatory timeframe of 45 days. The Cayey unit identified that the delay in the return of Title IV funds was related to an unintentional administrative error in the handling and filing of R2T4 documentation, within a context of operational transition and temporary staffing limitations. As a corrective action, the Fiscal Office will strengthen periodic reviews of total withdrawal reports generated in the NEXT system, ensure proper classification and monitoring of R2T4 cases, and provide continuous follow-up until funds are effectively returned within the 45 days regulatory timeframe. As a control mechanism, direct oversight of the R2T4 process by the Finance Director has been established, including recurring reviews of total withdrawal reports and reconciliation of these reports with refund vouchers, in order to ensure that all cases are processed and returned in a timely manner. The Humacao unit acknowledged that the cases identified by the auditors were related to specific circumstances, including system errors, technical limitations, and operational workload associated with the implementation of the shared services model. As a corrective measure, the unit implemented changes to the total withdrawal request form and process to ensure coordinated handling between the Office of Financial Aid and the Fiscal Office, allowing for early identification of cases subject to R2T4. Additionally, the Fiscal Office will review total withdrawal reports generated by the NEXT system on a recurring basis, perform R2T4 calculations timely, and coordinate with the Office of Finance to process returns within the regulatory timeframe. Oversight of the process has been strengthened through the designation of responsible personnel and continuous monitoring of active cases through completion. The Carolina unit identified that delays in the return of Title IV funds were due to discrepancies in attendance reports that were subsequently amended. As a corrective action, the Office of Financial Aid will formally notify the Fiscal Office of any corrections or amendments to attendance reports to ensure that R2T4 cases are identified timely. In addition, the use of “Never Attended” reports has been reinforced at the conclusion of the census period and upon completion of the grade submission period. Once the R2T4 calculation is completed in the COD system and a return is determined, the refund process will be initiated immediately, accompanied by continuous follow-up and the scheduling of key dates to ensure compliance with the 45 days regulatory requirement. The Central Administration Finance Office will conduct a meeting with Finance Directors, Financial Aid Directors, the Office of the Registrar, and Fiscal Directors to discuss this finding and establish a uniform procedure to address the following scenarios: • Students who request a total withdrawal. • Students who stopped attending. • Students who never attended. Additionally, a control mechanism will be implemented through the SharePoint platform, whereby each Fiscal Director will certify that system reviews have been performed for cases approaching the 45 days regulatory deadline. This control will be performed on a bi-weekly basis and will allow for timely monitoring of active cases, ensuring proper compliance with the required return of funds. For cases related to grade-based census determinations, which are processed once faculty submit grades in the system, an additional control mechanism will be established. Specifically, the SharePoint tool will be used for Fiscal Directors to document the academic calendar deadlines for grade submission. Furthermore, Fiscal Directors will schedule Outlook calendar events with these deadlines, including the Director of Financial Aid and the Office of the Registrar, and will establish automated reminders to ensure timely follow-up. These procedures will be documented and incorporated into the internal control manual applicable to the R2T4 process. Responsible Person or Office: Central Administration Finance Office and the finance offices of each of the eleven (11) institutional units. Implementation Timeline: 2026-2027

Recommendation: We recommend the University reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to put a process in place to ensure the student status changes are being reported timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Registrar’s Office has put in place steps to ensure that any exception reports from the Clearinghouse are immediately reviewed and any exceptions are addressed and resubmitted. In addition, the Registrar’s Office has put in place steps to ensure that students are submitted to the Clearinghouse early enough so that they will still be submitted by the Clearinghouse to NSLDS timely, even if there are delays by the Clearinghouse. Name(s) of the contact person(s) responsible for corrective action: Kristin Dvorak, University Registrar; Kevin Moenkhaus, Associate Registrar Planned completion date for corrective action plan: January 2026

Finding 2025-001 Required Disclosures Views of Responsible Officials The University agrees with the auditor’s findings and recommendations. Corrective Action Plan The University has participated in educational opportunities provided by the Department of Education and implemented procedures to ensure timely disclosure. All subsequent updates have been completed. Implementation Date Immediate Individual(s) Responsible Brandon Goen, Controller

Direct Loan Disbursement Notifications Correction Action Planned: For the 2025-2026 academic year, notifications are scheduled in our FAMS system to be sent immediately after student loans are disbursed to the student account. This action started with the Fall 2025 semester. Policy and Procedures have been updated to include the Direct Loan notification statement. This is in Section 10.5, Student & Parent Notifications, on Page 48 of the Financial Aid Policies and Procedures manual. This action has already been completed and in progress as of September 2025. Person Responsible for the Corrective Action: Denise Welch, Director of Financial Aid

OCCIDENTAL COLLEGE CORRECTIVE ACTION PLAN FINDING 2025-001 – Special Tests and Provisions – Enrollment Reporting: Significant Deficiency in Internal Control over Compliance Explanation of Deficiency: A sample of 20 federal aid recipient students was selected fromsystem generated reports of students who graduated, withdrew, or dropped during the 2024-2025 academic year. The enrollment information per the College’s records was compared to the information reported to the National Student Loan Data System (NSLDS) in order to determine if status changes were reported within the required timeframes. All 20 of the students selected as samples were not reported to the NSLDS within the required timeframe. Corrective Action Plan: With the hiring of our Associate Registrar for Systems and Reporting we once again have a staff member specifically responsible for reporting enrollment and degrees to the NSC. That position is backed up by three other staff members who also have access to submit and correct files. This past summer, we adjusted our reporting schedule in a further effort to comply with our reporting requirements. Despite any delays caused by us or by the National Student Clearinghouse, I understand that we are responsible for making sure our data is received and posted according to our obligations. The division of labor that comes with a full staff will allow for data transfers as soon as degrees are posted after the end of a semester. The adjusted timing for enrollment file submissions will also prevent any bottlenecks that might delay our data from being posted. These steps have already been implemented as evidenced by the fact that our degree file for the fall semester just ended was sent before our holiday break. As noted last year, staff have been instructed that the resolution of error files is to be given a high priority. One staff member has priority responsibility for resolving those files backed up by our primary submitter of data to the Clearinghouse. Contact Person Responsible for Corrective Action: James Herr, Occidental College Registrar Anticipated Completion Date: August 1, 2025

Noncompliance with Enrollment Status Change Reporting. Auditor Description of Condition and Effect. Of 18 enrollment status changes tested, we noted 1 change that was not reported to the National Student Loan Data System (NSLDS) within 60 days due to a student being assigned a different coding structure within the College's system which resulted in the student being excluded from the standard status-change reporting process. As a result of university personnel using the incorrect semester start dates. As a result of this condition, the College was temporarily out of compliance with enrollment reporting requirements. Auditor Recommendation. We recommend the College review and update its enrollment reporting processes to ensure that all students-including those with unique or foreign-student coding-are captured in routine status-change monitoring and NSLDS reporting procedures. The College should implement controls to detect nonstandard coding and ensure that all enrollment changes are identified and reported within required federal timelines. Corrective Action. Bay College took swift action after determining some students were being excluded in our enrollment reporting. Our reporting process was excluding students who were noted as being a citizen of a foreign county. We now review these students prior to each reporting cycle to determine if they should be included in the reporting. The Financial Aid team reviews this report to determine if the student is eligible for federal student aid. Students who are eligible are indicated and provided to the Institutional Effectiveness team to include in the enrollment reporting. This process is completed prior to each reporting cycle. For students who were not included in our prior reporting, the Financial Aid team working directly with the Institutional Effectiveness team, determined which should be reported and completed their enrollment reporting directly through NSLDS. Responsible Person. Ruth Carlson, Director of Financial Aid. Anticipated Completion Date. June 30, 2026

Finding: 2025-01 Federal Agency Name: Department of Education Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Award Numbers: P007A242416, P033A242416, R063P242851, P268K252851 Program Name: Student Financial Aid Cluster Finding Summary: In the current fiscal year, the College failed to identify populations whose enrollment status changed and accurately report changes to National Student Clearinghouse and the National Student Loan Data System (NSLDS). This issue was discovered during the annual audit of student financial aid files. Of the565 Title-IV recipients for the affected terms, 37 students (6.5%) have been identified as affected by this issue. Corrective Action: The process has been reviewed and updated to correct this issue. • The Information Technology department has developed an internal script to actively identify and update student enrollment status records whose enrollment statuses have not already changed in the College’s School Information System, which then allows the student files to be identified in National Student Clearinghouse reporting procedures. • A report was created and is checked monthly to screen student accounts for manual review in case script developed does not update student records with new enrollment statuses. This report includes the date of status change for manual auditing of reason for status change in manual review. Responsible Individual: Cameron Brown, Director, Financial Aid Completion Date: August 2025

Views of Responsible Officials and Corrective Action Plan The Campus Business and Financial Aid Offices reviewed the untimely return of Title IV (R2T4) funds and implemented a revised process to ensure compliance. Weekly R2T4 reviews: Financial Aid specialists now review all accounts requiring R2T4 calculations each week. Mid-month reconciliation: Added to the existing end-of-month process to expedite fund returns. Weekly coordination meetings: Financial Aid and Business Services staff review pending cases to ensure all returns meet the 45-day federal deadline. Quarterly compliance checks: Other Financial Aid staff monitor adherence and make recommendations for process improvement. The District will review this process each term and adjust procedures as needed to sustain compliance and efficiency.

Special Tests and Provisions - Enrollment Reporting Auditor Description of Condition and Effect. During our testing we noted that two students out of a testing population of eleven did not have their status change reported timely to NSLDS, one of which also had differences in their program level enrollment and campus level enrollment details. Another student had an incorrect effective date reported to NSLDS. As a result, there is an increased risk that information will not be reported to NSLDS timely and accurately. Auditor Recommendation. We recommend that the College enhance its policies and procedures regarding enrollment reporting to ensure that reporting is completed timely and accurately. Corrective Action. We currently have a 30-day reporting schedule but to prevent these issues from recurring, our institution has implemented the following measures: • Internal control review: We will run a comprehensive review of our enrollment reporting procedures in order to strengthen our internal controls to ensure data accuracy and timeliness. • Increased monitoring: A designated staff member now has direct access to the NSC and NSLDS websites to monitor reporting compliance and track file submissions and error reports. • System review: We have identified the deficiency for unofficial withdrawals. Our SIS platform has a feature that will correct this reporting issue and we will utilize it for future reporting. Our institution is committed to maintaining full compliance with all federal regulations regarding student financial aid and enrollment reporting. We have addressed the root cause of this reporting delay and are confident that our new procedures will ensure accurate and timely submissions to the NSC and NSLDS moving forward. Responsible Person. Michele Traver, Registrar Anticipated Completion Date. Fall 2025

R2T4 Audit: FY25 Corrective Action Plan To address the audit findings, the FCC has initiated the following actions: •Spring 2025, Completed: oRevised Processing Timeline: All R2T4 calculations and returns are now completedwithin 30 days, reserving the final 15 days exclusively for QA. (Responsible Leader:Director of Financial Aid) oCross-Training and Succession Planning:Staff cross-trained; onboarding/offboardingdutiesdocumented to eliminate single points of failure.(Responsible Leader: Director ofFinancial Aid) •September 2025, Underway: oLeadership Communication Protocol:A formal process is beingfinalized to ensurecompliance issues are documentedand escalatedforawareness to the President and theCFO/VP for Administration. Thisprotocol alsoreinforcesa cultureof accountability where compliance concernsare escalated promptly and transparently. (ResponsibleLeader: AVP for Student and Financial SupportServices) •Monthly Monitoring and Reporting:Compliance reviews reported monthlyto the VP for Student Experience and then to the President and the CFO/VPfor Administration for awareness. (Responsible Leader: VP for StudentExperience). oQA Tracking Form: Implemented to document each review and correction for auditverification. (Responsible Leader: Director of Financial Aid) •Fall 2025 – Spring 2026, To Be Planned and Executed: oExternal Program Review: FCC will engage an external consultant agency (TBD) toconduct a comprehensive Financial Aid Office program review in FY26, validatingcompliance, staffing adequacy, and process integrity. (Responsible Leader: AVP forStudent and Financial Support Services) •Timeline, Next Steps, Responsible FCC Leader: oOctober 6, 2025: Submit formal corrective action plan to Auditors (VPSE) oOctober 15, 2025: Receive first compliance review report for AVP to VP reporting toPresident’s Council, as part of enterprise risk management awareness. (AVP/VPSE) oJanuary to April 2026: Conduct external program review of the Financial Aid Office andreport findings to President and the CFO/VP for Administration by June 2026. (AVP) •Expected completion date: June 2026 •Person responsible: Dr. Edmund T. Cabellon, Interim Vice President for Student Experience

AUDIT FINDING Finding 2025-001 NSLDS Status Reporting Error MANAGEMENT'S COMMENTS ON FINDINGS AND RECOMMENDATIONS MANAGEMENT'S We concur with the auditor’s finding and identification of a deficiency in our internal controls. CORRECTIVE ACTION PLAN We will enact stronger controls to ensure that all future enrollment reporting is submitted timely. EMPLOYEE/ DIVISION RESPONSIBLE Financial Aid Director TIMELINE AND ESTIMATED COMPLETION DATE Immediately

Finding 2025-001 Condition The change in student status for 3 of the 60 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 status for 1 of 60 students tested was inaccurately reported to NSLDS. Corrective Action Plan The Registrar completed an analysis of each of the changes in student status that were not reported timely or accurately. The following actions have been implemented to improve processes and to reduce the likelihood of noncompliance. The College has instituted a more stringent Incomplete policy for graduate students that aligns with the mandatory NSLDS reporting deadlines of 30 days for status changes and 60 days for roster file responses. The Registrar's Office has established a manual communication protocol requiring staff members who process student status changes outside regular reporting cycles (mid-semester withdrawals, off-cycle graduations, leaves of absence, late grade changes affecting enrollment status) to immediately notify the designated NSLDS reporting staff member via email or direct communication. All staff members processing degree conferrals have been trained. In addition, standing interdepartmental meetings have been established to improve communications. The NSLDS reporting staff member maintains a simple log to track these notifications and ensure timely submission to NSLDS. Registrar's Office is working directly with their NSC analyst to align the Summer Graduates Only reporting windows and all other NSC reporting deadlines with the 30-day and 60-day NSLDS requirements. Name of Contact Person Responsible for Corrective Action: Elizabeth Brentzel Anticipated Completion Date: Spring 2026

Bethany College and Affiliate Corrective Action Plan For the Year Ended June 30, 2025 Finding 2025‐001 – Significant Deficiency in Internal Control Over Compliance – Return of Title IV Funds Condition Found: Four students who had withdrawn from the institution did not have Title IV funds returned to the Department of Education within 45 days. Corrective Action Plan: The College will review our workflow and make oversight improvements to prevent future delays, including standardizing withdrawal notification and handoff procedures, initiating R2T4 calculations immediately upon withdrawal determination, confirming that required COD adjustments are submitted without delay and establishing internal tracking to monitor return activity against the 45 day requirement. Responsible Official for Corrective Action Plan: Sarah Sherinian, Vice President for Student Success & Operational Excellence/Chief Financial Aid Officer

Finding 2025-003 Federal Agency Name: U.S. Department of Education Program Name: Student Financial Assistance Cluster Federal Financial Assistance Listing: 84.007, 84.033, 84.063, 84.268 Finding Summary: In testing of 60 students, 1 student was identified that was notified of the requirement to return Title IV funds in excess of the amount actually required to be returned. The error was caught by the District, but the student’s account was never corrected to the appropriate amount of the return. Corrective Action Plan: The corrective action for the R2T4 calculation error involved promptly correcting the student's calculation and returning the appropriate funds. To prevent future mistakes, the Director of Financial Aid will review the current R2T4 controls process with staff, which now includes a double review by the Financial Aid Adviser and the Director to catch errors such as typos or miscalculations and to ensure accurate student notifications. After aid adjustments are made, the Director verifies the processed changes for accuracy, and any discovered errors are immediately corrected and documented in the R2T4 file. Responsible Individual(s): Christopher Natelborg Anticipated Completion Date: September 2025

Finding 2025-002 Federal Agency Name: U.S. Department of Education Program Name: Student Financial Assistance Cluster Federal Financial Assistance Listing: 84.007, 84.033, 84.063, 84.268 Finding Summary: In testing of 60 students, 1 student was identified who was not awarded the correct amount of Pell. Corrective Action Plan: The corrective action for the Pell Grant eligibility issue involved promptly adjusting the affected student's Pell Grant to the correct amount, which resulted in an increase and ensured there was no negative impact. To address the root cause, the Director of Financial Aid met with the financial aid team to review the finding and clarified federal regulations on Pell Grant calculations, referencing the 2024-25 FSA Handbook. Importantly, the Director committed to upgrading the internal Pell Grant calculator used by Financial Aid Advisers: this enhancement will add a flagging mechanism that automatically alerts advisers whenever a student's calculated Pell Grant amount falls below the published minimum Pell amount for that award year, thereby ensuring that no student unintentionally receives an ineligible or reduced Pell Grant due to a calculation oversight. Responsible Individual(s): Christopher Natelborg Anticipated Completion Date: January 2026

Finding 2025-001 Federal Agency Name: U.S. Department of Education Program Name: Student Financial Assistance Cluster Federal Financial Assistance Listing: 84.007, 84.033, 84.063, 84.268 Finding Summary: In testing of 60 students, 3 students did not receive a timely notification of their award from the District. Corrective Action Plan: To address missed disbursement notifications, the Financial Aid team identified affected students and sent the required notices, including an official explanation from the Director of Financial Aid. The issue was traced to a system malfunction during the SU24 term, which has since been resolved by implementing a process that alerts IT and the Director if notification counts do not match disbursement records. The notification script has been enhanced to track missing letters over the previous 30 days, and IT has established a weekly audit comparing sent notifications to disbursement records for accuracy. Additionally, coding updates in the CX system now ensure all disbursements are properly captured, regardless of the date entered by Financial Aid, thereby preventing similar oversights in the future. Responsible Individual(s): Christopher Natelborg Anticipated Completion Date: December 2025

Finding – Reporting: Financial Reporting - Student Financial Assistance Cluster, Assistance Listing #84.063 and #84.268, June 30, 2025 Award Year, U.S. Department of Education Criteria or Specific Requirement Institutions submit Direct Loan, Pell Grant, TEACH Grant, and IASG origination records to the COD ("Common Origination and Disbursement") 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. (July 2024 OMB Compliance Supplement pages 5-3-26 and 5-3-27) The date of disbursement determines when a student becomes a federal student aid (FSA) recipient and has the rights and responsibilities of an FSA recipient. A disbursement occurs when the School credits a student’s account or pays a student or parent directly with: • FSA funds received from the Department; or • School funds labeled as FSA funds in advance of receiving actual FSA funds. (Student Financial Aid Handbook, Volume 4, Chapter 2) Condition Found One of the 15 students selected for disbursement reporting had errors in the information that was reported to COD as follows: • The disbursement date reported was different from the actual disbursement date by one day • The cost of attendance that was reported to COD was different by $20 • The incorrect parent was identified as the borrower in the initial submission to COD Views of Responsible Officials and Planned Corrective Actions Staff have been trained on the proper procedures, and a formal policy and procedure has been established and is now referenced by the financial aid team. These procedures cover the correct process for releasing and disbursing federal aid within the Jenzabar JFA system to ensure compliance with federal regulations, including accurate disbursement date reporting in COD. Names of Contact Person Responsible for Correction Action: Renee Jordan, Director of Financial Aid Anticipated Completion Date: October 14, 2025

FISAP Reporting Planned Corrective Action: Deficiency: The backup documentation submitted for the Fiscal Operations Report and Application to Participate (FISAP) did not match the data reported on the FISAP. Institution Response: We acknowledge this discrepancy and agree that the FISAP backup documentation did not fully align with Part II, Sections 7a (Total Undergraduate Students) and 7b (Total Graduate Students) as reported on the submitted FISAP. The current FISAP reflects 43 for Section 7a, whereas the correct figure is 60, and 199 for Section 7b, whereas the correct figure is 202. Root Cause: At the time the report was prepared, the institution was relying on a contracted financial aid professional to provide the data for FISAP reporting. Although this work was performed in good faith, the contracted individual provided incorrect figures, which resulted in minor data discrepancies between the FISAP and the supporting documentation. Corrective Action Taken: Our Institution has ended its contract with the external financial aid services provider. We have transitioned all financial aid and FISAP-related responsibilities in-house and designated a qualified Data Point Administrator / Director of Financial Aid to oversee the preparation of the report. Additionally, there will be multiple financial professionals reviewing future FISAP and backup data. The current year’s FISAP has already been worked on using this updated structure, and all backup documentation has been reviewed for accuracy and confirmed to match the submitted FISAP. Preventive Measures Going Forward: To ensure accuracy and prevent recurrence, the institution has implemented the following procedures: 1. The Director of Financial Aid (Data Point Administrator) will prepare all FISAP data and maintain appropriate source documentation. 2. The Financial Aid Representative will review the completed FISAP and all backup documents to verify accuracy prior to submission. 3. The Financial Controller will receive the full FISAP packet, including backup documentation for an additional review and institutional oversight. 4. All FISAP materials and supporting documents will be stored in the institution’s secure Financial Aid OneDrive folder to ensure accessibility and consistency during audits. These steps have already been implemented for the most recent FISAP cycle and will be followed annually to maintain compliance and data integrity. Person Responsible for Corrective Action Plan: Josh James, CFO Anticipated Date of Completion: 11/24/2025

Student Financial Aid Cluster – Assistance Listing No. 84.063, 84.007, 84.033 Recommendation: Recommend that the College design and implement controls to ensure that all safeguards for identified risks required by the Gramm-Leach-Bliley Act (GLBA) are fully documented and updated as necessary. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Moraine Park Technical College will take or has already taken the following actions to address the audit finding: 1. Updated existing policies and documentation to fully reflect the controls in place to safeguard identified risks under the Gramm-Leach-Bliley Act. 2. Revised and formalized the following documents to ensure they clearly describe current practices and continuous monitoring activities: • Incident Response document • Risk Assessment document • Written Information Security Plan • IT Vulnerability Management Practices document These updates ensure that all existing controls and processes are fully documented, current, and aligned with GLBA requirements. Name(s) of the contact person(s) responsible for corrective action: Larry Plamann, Director of Enterprise Infrastructure Planned completion date for corrective action plan: January 2026

Student Financial Assistance – Assistance Listing No. Various Recommendation: We recommend the University 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: Auditors identified two students for whom enrollment status on the campus level and program level was correctly reported to NSLDS as withdrawal in December 2024; however, both students graduated in March 2025 and that enrollment status was not updated at the campus level or the program level. We have a manual tracking procedure in place for students who complete missing coursework after their last term of enrollment that results in completion of their program. These two students were missed in that process. As a result of this finding, we have reviewed the procedure with the relevant staff and will continue to monitor the process, adding routine spot-checking of this tracking list. Names of the contact persons responsible for corrective action: Gwenn Sherburne, Registrar, and Lynette Wahl, Student Financial Aid Director Planned completion date for corrective action plan: October 31, 2025

Name of the contact person responsible for corrective action planned: Brenda Wendt Controller Cleveland State University 2121 Euclid Avenue Cleveland, OH 44115 Phone: 216.687.3676 Email: b.wendt@csuohio.edu Corrective actions planned: Finding Number: 2025-001 The University did not have adequate controls in place to ensure that credit balances were refunded in a timely manner within the 14-calendar-day requirement. Management has implemented a process to ensure that credit balances are processed within the 14-calendar-day requirement. A workflow hierarchy is in place to ensure adequate staffing and training, preventing processing delays. Any deviations from the normal processing of credit balances will be sent to the relevant department immediately for further action. Anticipated completion date: December 2025

Condition and Criteria: Institutions are required to timely report enrollment information under the Pell Grant and Direct Loan programs via the NSLDS. Institutions must review, update, and certify student enrollment statuses, program information, and effective dates. During our testing of the information submitted to NSLDS, we noted 2 students out of the 40 tested that had errors of status reporting for summer term. Effect: The College is not in compliance with the federal NSLDS reporting requirements described in the OMB Compliance Supplement and required by the Department of Education. Cause: In the College’s software transition to PowerFaids, the system automatically coded all students to full-time status and students that are less than full time had to be adjusted manually. Some students were missed in this manual process. Questioned Costs: None reported Context/Sampling: The College disbursed Federal financial aid to approximately 736 students in the 2024-2025 school year. A non-statistical sample of 40 students was selected for testing. Repeat Finding: No Auditor’s recommendation: The College should implement additional processes to review, update, and verify that student enrollment statuses are reported to NSLDS accurately and timely. Corrective Action to be Taken: Once the issue was identified, students’ statuses were adjusted manually. An automated process has been created to compare student status with the Student Information System (SIS) before the file is sent to NSLDS. Anticipated Completion Date: The status corrections and the new review process was implemented in Fall of 2024. Name and Title of Responsible Person: Angela Rios, Director of Student Financial Aid