Corrective Action Plans

Management Response We agree with the auditor's comments. The College is actively recruiting to fill critical accounting vacancies. The College is reviewing standard operating procedures for all federal activity to include grants and student aid. Procedures, training, and processes to review the SEFA will be implemented in FY 2026.

Finding 2024-001: UNPAID AND UNTIMELY PAID REFUND- We tested thirteen drop students and noted one unpaid and one untimely paid refund as a result of Return of Title IV funds calculations. Comments on Finding and Recommendation(s): The institution agrees with this finding. It was recommended that the school complete the R2T4 and return the $4,704 in Sub, Unsub, and PLUS funds to the Department of Education. The Pell return, while untimely, was completed prior, therefore no additional action required. Actions Taken or Planned: The $4,704 in Sub, Unsub, and PLUS was returned to the Department of Education on 12/16/24. Withdrawals are processed by the Dean of Academic Success and forwarded to the Registrar and Financial Aid Office for review and action. The Financial Aid Office and Business Office will begin to track withdrawals and follow up with Academic Success and the Registrar when final forms are not shared in a timely manner so that funds can be returned as needed.

Corrective Action Plan: The finding was due an administrative error in the Pell award for this particular student. The College corrected this error and disbursed $492.50 to the student. Timeline for Implementation of Corrective Action Plan By using the incorrect enrollment status, the student was under awarded Federal Pell Grant funds. Contact Person Troy Martin, Director of Student Financial Services

Department of Education NSLDS Enrollment Reporting Student Financial Aid Cluster – Assistance Listing No. 84.268, 84.063, 84.007, 84.033 Auditors’ Recommendation: The University must review their enrollment reporting policies and procedures to ensure accurate reporting. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Point University uses National Student Clearinghouse (NSC) for the enrollment reporting process. The registrar’s office prepares a monthly enrollment change report which is sent to NSC. NSC processes the report and returns a file for any discrepancies and potential errors for the school to fix. The school reviews and makes any necessary updates and submits the report to NSC. NSC updates the enrollment information at NSLDS. For graduated students, the school also submits a degree verification file at the end of each term after graduated status is assigned by the school. This file is separate from the enrollment reporting file. The school inquired as to why the updates were not completed and found that updating enrollment status is not part of NSC’s process for the degree verification files. Moving forward, the registrar will submit a separate enrollment report file along with the degree verification to ensure that graduate status is updated at NSC and NSLDS after the school assigns them. During the 2024-2025 school year, while the school was reviewing FVT/GE reporting that was due in January of 2025, the school was able to review enrollment data that had been reported to NSC for the 2023-24 school year and make corrections to that data. Moving forward, the enrollment data is maintained in the new student information system and updated in real time by the registrar’s office prior to the enrollment reports being sent to NSC. Of the 33 students reviewed for NSLDS enrollment status, five had errors. All five students were graduates whose status errors were related to data migration. All five were corrected during the school’s review of enrollment statuses while reviewing data for the FVT/GE reporting, which was done November 2025 through January 2025. Documentation of corrected enrollment statuses with the dates of the certification corrections is attached as Appendix 2024-002A. Name(s) of the contact person(s) responsible for corrective action: Natalie Brown-Motes, Point University Registrar, natalie.brown@point.edu Planned completion date for corrective action plan: FVT/GE status review is completed. School has process in place moving forward for updating graduated students beginning with Spring 2025 semester.

UCB recognizes its obligation under an institution’s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in supportof the administration of the federal student financial aid programs. The Gramm-Leach-Bliley Act (GLBA) (Pub. L. No. 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as “financial institutions” and subject to the Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi)). To ensure that the University complies with the requirement, during this year that ends at June 30, 2025, University risk assessment addressed the elements required by (16 CFR 314.4). Accordingly, for this year UCB already performed the following: 1. Vulnerability test 2. Penetration test 3. Backup test was performed during year ended June 30, 2025. Anticipated completion date: Immediately.

UCB recognizes its obligation to report enrollment data to the National Student Loan Data System (NSLDS) at least every 60 days. The Registrar's Office reports enrollment data to NSLDS on a monthly basis. To ensure that the University complies with the 60-day requirement, we have established an additional notification procedure. The Financial Aid Office will forward a report of all Title IV student recipients classified as withdrawn to the Registrar's Office, this process consists of a reconciliation of the data. The Registrar's Office will report the enrollment change of these cases to NSLDS within 60 days required. Anticipated completion date: Immediately.

The University afirms its understanding of its obligation to submit disbursement according to 34 CFR Section 668.173 (b) states that an institution returns unearned Title IV, HEA program funds timely if; (1) the institution deposits or transfers the funds into the bank account it maintains under §668.163 no later than forty-five (45) days after the date it determines that the student withdrew; (2) the institution initiates an electronic fund transfer (EFT) no later than forty-five (45) days after the date it determines that the student withdrew; (3) the institution initiates an electronic transaction, no later than forty five (45) days after the date it determines that the student withdrew, that informs a FFEL lender to adjust the borrower's loan account for the amount returned; or (4) the institution issues a check no later than forty-five (45) days after the date it determines that the student withdrew. Due to an information technology systems external cybernetic attack that caused various disruptions in the operations, a delay in returning of funds within the time prescribed by the regulation was caused, even when the institution does everything to perform manually all transaction in order to avoid any noncompliance of the regulation. UCB will reinforce their processes and procedures to satisfy all applicable requirements specified in 668.173 (b) and do a doble verification to make sure every return of funds is made no later than 45 days required by the regulation. Anticipated completion date: Immediately.

Federal Program: Student Financial Assistance Cluster - Federal Direct Student Loan Program Federal Agency: U.S. Department of Education Pass-Through Entity: Not applicable Assistance Listing Number: 84.268 Federal Award Year: June 30, 2024 Criterion: Title IV regulations (34 CFR 685.309b) require that upon receipt of an enrollment report from the Secretary, Institutions must update all information included in the report and return the report to the Secretary; (i) in the manner and format prescribed by the Secretary; and (ii) within the timeframe prescribed by the Secretary. Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an Institution must notify the Secretary within 30 days after the date the Institution discover that: (i) a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the Institution and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or (ii) a student who is enrolled at the Institution and who received a loan under Title IV of the Act has changed his or her permanent address. Condition and Context: For four students out of twenty-five selected for testing, the College did not notify the NSLDS in a timely matter of a change in enrollment status. Cause and Effect: The College failed to follow its procedures for reporting student status changes. The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by schools. If an institution does not review, update, and verify student enrollment statuses, effective dates of the enrollment status, and the anticipated completion dates, then the Title IV student loan records will be inaccurate in NSLDS. Recommendation: The College should implement a process and related to verify with NSLDS that all enrollment status information for all students is updated accurately and timely. Corrective Action Plan The College will continue to work with the NSC Audit Response Team, Office of the Registrar, and Office of Information Technology to resolve the data reporting issues we are currently experiencing. Denise Owens, Student Loan Specialist and Debbie Schreiber, Registrar will work together to provide manual data reporting to NSLDS in an accurate and timely manner. Responsible Persons Scott Allen, Interim Director of Financial Aid Denise Owens, Student Loan Specialist Debbie Schreiber, Registrar Anticipated Completion Date This is an ongoing process and will begin immediately

Identifying Number: 2024-005 – Special Tests – Enrollment Reporting Finding: Student status changes were not reported accurately to NSLDS. The audit team noted that the University does not appear to have a control in place to identify in a timely manner inaccurate information that was provided to the NSLDS by their third party servicer. Corrective Actions Taken or Planned: We agree with the auditors’ findings. NSLDS receives enrollment data from MSMU through the National Student Clearinghouse (NSC). If a student who was previously reported as enrolled is not listed subsequently, NSC will report the student as withdrawn. If MSMU does not update the records on a timely basis, NSC automatically reports to NSLDS that the student has withdrawn, which may not be the case. The errors in the reporting process have been resolved and the appropriate steps are in place to report on a timely basis. Person(s) Responsible for Correction Actions: Boyd Creasman, Provost Anticipated Completion Date: April 30, 2025

Recommendation: We recommend the University review its reporting procedures to ensure that enrollment and program information is accurately reported to NSLDS as required by regulations. Action taken in response to finding: The University has added an additional audit report to be run prior to submission of enrollment reports to Clearinghouse and NSLDS. The report will audit for a change in the reported program begin date between reports when the reported program has not changed. The report inaccurate program begin dates calculated by our Student Information System as a result of a code update sent out by the vendor. 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 March 19, 2025, 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.

Recommendation: We recommend that the University improve the existing procedures and controls to ensure compliance with the aforementioned criteria. Action taken in response to finding: Counselors have completed an intensive R2T4 NASFAA training late April – May 2024. The misunderstanding of the 45-day rule of one of the counselors has been addressed and corrected. Names of the contact persons responsible for corrective action: Joshua Morey, Senior Director of Financial Aid Planned completion date for corrective action plan: As of March 19, 2025, changes and training have already been implemented.

Corrective Action Plan: The Student Support Services program experienced changes in program personnel. This change led to a loss of institutional knowledge, interrupted policy and process enforcement. In many instances documentation wasn’t available due to the transition of key program personnel. During the transition for Student Support Service, we encountered difficulty locating explicit documentation for students who were awarded Grant Aid outside of first- or second-year classification. Section 3518(a) of the CARES Act granted the Department authority to “modify the required and allowable uses of funds” for certain programs authorized by the Higher Education Act of 1965, which included TRIO programs. The flexible extension remained in effect until September 30, 2024. Upward Bound requested a flexibility extension under the CARES Act. Due to a delayed response to the request, the extension request was re-sent for verification. Once received, UB was advised that the Department was no longer accepting new requests. As a result, stipends were processed before receiving the final response. During the Spring of 2024 the University began work to enhance its internal controls, policies and procedures to ensure the appropriate documentation was properly maintained. While there was improvement across all TRIO programs, the issues were not fully remediated by June 30, 2024. The University is committed to ensuring compliance with all federal, institutional, and program regulations. The University continues to enhance its internal controls, policies and procedures to ensure the appropriate documentation to support is maintained. Both the Student Support Services and Upward Bound programs are committed to implementing continuous monitoring of program records to ensure compliance with federal, institutional, and program requirements. The TRIO-SSS program has implemented an online Grant Aid application process for all participants who are eligible for aid; which requires submission of demographic information and a need for support statement. With the expiration of exceptions allowed under the CARES Act, all TRIO programs have converted back to distributing stipends in accordance with current federal regulations. Each program will monitor their respective distributions for accuracy and program compliance. Supporting documentation of statutory and regulatory requirements will be retained in the Policy and Procedures manuals. Anticipated Completion Date: June 30, 2025

Corrective Action Plan: We acknowledge the accuracy of this finding, such that one student’s required return of funds was identified as having been improperly calculated during the R2T4 calculation. The order in which the funds were reduced and returned to the Department was incorrect. Lack of clarity about the enrollment level and activity of the student during the term caused the miscalculated award amounts. A lack of system driven calculation and insufficient knowledge of the proper order of funds (and required student authorization of post-withdrawal disbursement) were also contributing factors that resulted in this finding. The University underwent a re-organization the resulted in the creation of a new division, Strategic Enrollment and Retention Management (“SERM”), effective February 2025. The recent organizational restructuring that placed the Registrar’s Office and the Office of Financial Aid under the new division of Strategic Enrollment and Retention Management is a strategic move to enhance the synchronization of essential data between these departments. This alignment is crucial for accurately determining withdrawal dates and understanding the academic calendar, which are essential components of the R2T4 calculation process. Enhanced inter-departmental communication facilitated by this structure will ensure more accurate and timely data sharing, essential for meeting compliance requirements. The ongoing support from FAS in setting up and optimizing Ellucian Colleague for our specific needs will significantly strengthen our capacity to meet and exceed compliance standards, thus preventing future occurrences of similar issues. Starting June 2025, the Financial Aid Office will engage with FSA Partners and utilize NASFAA study materials to conduct comprehensive training for staff responsible for R2T4 calculations. Continuous education will be emphasized to keep staff updated on regulatory changes and best practices. We will utilize the capabilities of Ellucian Colleague to automate R2T4 calculations. This system will be set up to require authorization for post-withdrawal disbursements and ensure that award reductions are calculated in the correct order. We will introduce a secondary review process for all R2T4 calculations, where a seasoned financial aid counselor will verify the accuracy of the initial calculation and authorization documentation. We will standardize the process for documenting the authorization of post-withdrawal disbursements. Develop a standard communication template within Ellucian Colleague that includes explicit requests for student or parent authorization, ensuring compliance with federal regulations. Anticipated Completion Date: September 30, 2025

Corrective Action Plan: A lack of systematic communication between the Registrar’s Office and the Office of Financial Aid, coupled with an absence of an established process flow or calendar to guide quality assurance activities, led to these discrepancies. The University understands that accurate reporting of student enrollment status is crucial for managing student eligibility for federal financial aid, including loans and grants; however, in these cases, there were several discrepancies. The University underwent a re-organization the resulted in the creation of a new division, Strategic Enrollment and Retention Management (“SERM”), effective February 2025. SERM aims to address the root causes of this finding by fostering enhanced synergy and communication between the Registrar’s Office and the Office of Financial Aid. This structural change aligns both departments under the governance of the Senior Vice President, ensuring cohesive and compliant operational practices. The alignment will facilitate a unified approach to meet federal reporting requirements more effectively and efficiently, thereby enhancing our administrative capability and compliance with critical federal requirements. This proactive governance restructuring is expected to significantly improve our process accuracy and compliance integrity, safeguarding our students' financial interests and maintaining our standing with federal financial aid programs. In addition, the University will establish audit and verification processes that involve conducting an exhaustive audit of current enrollment reporting processes in collaboration with Financial Aid Services (FAS) to identify and amend discrepancies. We will implement comprehensive, quarterly training for all staff involved in enrollment reporting starting August 2025 to ensure adherence to federal regulations. The Registrar’s Office will establish bi-weekly reporting schedules to the National Student Clearinghouse (NSC), including during summer terms, to ensure timely updates in NSLDS. There will also be regular review sessions to evaluate the effectiveness of the new reporting protocols and make necessary adjustments. Anticipated Completion Date: August 31, 2025

Corrective Action Plan: The University acknowledges shortcomings in our institutional processes for managing and communicating the details of Tier One and Tier Two financial arrangements. This has been due to a combination of factors, including outdated website management practices, a lack of clear guidelines on compliance responsibilities for web content, and insufficient inter-departmental communication regarding changes in federal regulations and their implications for our disclosure practices. The University is establishing a continuous feedback loop between Financial Aid, the Business Office, and University Communications and Marketing departments to ensure that our contractual disclosures are not only compliant but also clear and accessible to our stakeholders. Enhanced communication and collaboration across these departments are pivotal for maintaining ongoing compliance and ensuring that all disclosures are managed efficiently and transparently. This proactive approach is aimed at fostering a culture of compliance and transparency throughout the University. The University will improve the accessibility and visibility of contractual disclosures on its website to ensure compliance with federal requirements. The updated URLs will be provided to the Department of Education for publication of the contract in a centralized, accessible database. In addition, in partnership with Financial Aid Services (FAS), the University will conduct comprehensive interdepartmental training sessions by August 2025 for all relevant staff, emphasizing the critical nature of compliance with federal disclosure requirements. Anticipated Completion Date: August 31, 2025

Corrective Action Plan: The University relied on third-party technology to notify students of their disbursements without monitoring if their process was being executed. The failure stemmed from inadequate oversight of the notification process, leading to non-compliance with federal requirements for the timely and accurate notification of loan disbursements. The University partnered with Financial Aid Services (“FAS”) in February 2025 to review the current systems and process, and devise appropriate systems, checks, and balances to address each deficiency in our financial aid processes and personnel. In addition, as part of the University’s transition of its ERP system from Jenzabar to Colleague, Financial Aid will be transition to Ellucian Colleague for financial aid management. University officials are committed to rectifying this deficiency through significant enhancements to our notification processes and technological infrastructure. The systematic integration of notification with the actual disbursement function via Ellucian Colleague represents a robust solution to ensure compliance. By handling this process internally, we ensure greater control, reliability, and compliance with federal regulations. Regular audits of the disbursement and notification process will be implemented to guarantee that our procedures remain in alignment with federal requirements and best practices. This proactive approach ensures that all loan disbursements are properly managed and communicated, safeguarding both our students' financial interests and the university's compliance status. The university has already begun to amend procedures to ensure that all loan disbursements are accompanied by timely and accurate notifications. The Office of Financial Aid will maintain detailed records showing compliance with these notifications. The integration of Ellucian Colleague will automate the notification process. This system ensures that notifications are sent immediately upon disbursement processing, using various modalities such as email, text messages, or direct updates to the student portal. We will enhance our enhance record-keeping through the utilization of Ellucian Colleague by logging all communications sent, ensuring that there is traceable evidence of compliance. This system integration addresses previous dependencies on third-party technologies and brings control of this crucial compliance aspect in-house. Anticipated Completion Date: September 30, 2025

Corrective Action Plan: The verification for one student was improperly conducted, leading to financial aid awards and disbursements based on unverified or incorrectly verified financial data, specifically regarding untaxed IRA distributions and pensions. The verification failure was due to an oversight by the aid administrator who incorrectly verified the untaxed IRA distribution and pension as zero, despite contradictory evidence or a lack of supporting documentation. The University partnered with Financial Aid Services (“FAS”) in February 2025 to review the current systems and process, and devise appropriate systems, checks, and balances to address each deficiency in our financial aid processes and personnel. Resulting from the work of FAS, the verification policies will be thoroughly reviewed, and revised, to ensure comprehensive coverage as mandated by federal regulations. The University will also establish a robust quality control system to regularly review verification practices and compliance, ensuring adherence to updated policies. We will update and maintain a verification checklist that includes all data elements required for verification. This checklist will be used in all verifications, with a secondary review and sign-off by another trained administrator to ensure accuracy and completeness. In addition, we will bolster training for all financial aid staff, utilizing resources from FAS and the National Association of Student Financial Aid Administrators (NASFAA) to deepen understanding and expertise in verification processes. Anticipated Completion Date: September 30, 2025

Corrective Action Plan: The inaccuracies stemmed from insufficient workflow integration among the Office of Financial Aid and the Registrar’ Office. A critical lack of scheduled checks failed to align submission or processing dates. Furthermore, technical issues between Jenzabar and PowerFAIDS systems contributed to erroneous COA budgets. The University partnered with Financial Aid Services (“FAS”) in February 2025 to review the current systems and process, and devise appropriate systems, checks, and balances to address each deficiency in our financial aid processes and personnel. In addition, as part of the University’s transition of its ERP system from Jenzabar to Colleague, Financial Aid will be transition from the use of PowerFaids to Ellucian Colleague for financial aid management. Resulting from the work of FAS, the University will institute a systematic monthly reconciliation process to ensure consistency across all systems (COD, PowerFAIDS, Jenzabar and Colleague). This includes matching COA and disbursement records to ensure accuracy. To optimize workflow, we will establish a comprehensive calendar of disbursement and reporting deadlines, with routine internal audits every 30 days, starting April 2025. This measure will enforce accountability and timeliness in reporting. We will enhance integration between financial systems (Jenzabar and PowerFAIDS) to prevent data mismatches and streamline the reporting process. In addition, we will leverage our partnership with FAS to conduct regular training sessions for staff across the Financial Aid, Registrar, and Finance Offices to ensure everyone is aware of compliance requirements and system functionalities. These training sessions will start May 2025. Anticipated Completion Date: September 30, 2025

Corrective Action Plan: The University did not appropriately review eligibility documentation resulting in over awards. The error arose due to the manual processing of student loans by a single financial counselor without adequate checks, leading to non-compliance with specific fund restrictions related to the student’s year in school and dependency status. A significant contributing factor was the absence of structured, periodic quality assurance reviews. The University partnered with Financial Aid Services (“FAS”) in February 2025 to review the current systems and process, and devise appropriate systems, checks, and balances to address each deficiency in our financial aid processes and personnel. In addition, as part of the University’s transition of its ERP system from Jenzabar to Colleague, Financial Aid will transition from the use of PowerFaids to Ellucian Colleague for financial aid management, which was driven by the need for more robust, systematic controls that can accurately adjust and calculate Cost of Attendance (COA) on a per-student basis. This system change is expected to automate many of the processes that were previously prone to human error, ensuring compliance with regulatory requirements. The University’s Financial Aid counselors will continue to monitor students' credit hours and make necessary adjustments to aid awards, thereby maintaining compliance and addressing any discrepancies proactively. This plan reflects our commitment to upholding the highest standards of financial aid management and ensuring that our processes are transparent, compliant, and responsive to the needs of our students. The University will integrate automated processes in our financial aid packaging to reduce human error. The adoption of the Ellucian Colleague system by JCSU will allow for automatic enforcement of packaging and transmittal rules, tailored to specific funds. Additionally, we will utilize exception reports from Ellucian Colleague to identify and correct discrepancies in real-time. We will establish a routine monitoring system to regularly check the accuracy of financial aid awards against eligibility criteria. Anticipated Completion Date: September 30, 2025

The University recognizes the untimely staff turnover and the impact it has had on University compliance. University leadership has taken steps to ensure immediate and future compliance with the regulations referenced in this finding. The following corrective action plan has been implemented to prevent delays in future reporting. An experienced Institutional Researcher (IR) has been hired for the University, with over 20 years of student enrollment data management and reporting to the National Student Clearinghouse (Clearinghouse). The schedule for reporting student enrollment has been modified to reflect reporting within 30-to-45-day intervals. Reporting at this interval will ensure compliance with the 60-day requirement. Email notifications of enrollment reports due, enrollment reports submitted, correction reports, and report delinquencies from the Clearinghouse are now sent to the IR, the Registrar, and the Provost’s Office. The Provost and the IR meet at least weekly regarding compliance and ongoing reporting for the University.

Corrective Action Plan to Finding 2024‐001: Contact person for corrective action: Melissa Neal, Registrar Correction Action Plan: The University plans to implement the following: During the 2024‐2025 academic year, the Registrar Office will implement the following mechanisms to ensure that all status change records are reported to NLSDS accurately.  Reinforce training of individuals in the compliance and control ownership roles to ensure controls are operating as designed.  Ensure that individuals in compliance and control ownership roles within the Registrar’s office validated that enrollment files submitted were processed in the correct sequence.

Federal Program: U.S. Department of Education - Student Financial Assistance Cluster Federal Perkins Loan Program, 84.038 Federal Supplemental Educational Opportunity Grants, 84.007 Federal Work Study Program, 84.033 Criteria: The College is required to comply with 34 CFR Section 674.19, 34 CFR 675.19 and 34 CFR 676.19. Condition: During our testing of the Fiscal Operations Report and Application to Participate (FISAP), we noted that Part II (Application), Section E, Line 22: total tuition and fees for the award year July 1, 2023 to June 30, 2024 did not agree or reconcile to the statement of activities. Cause: The College did not have controls in place to ensure FISAP reporting was accurate. Effect: The College did not follow federal regulations regarding FISAP reporting accuracy. The provisions of 34 CFR Section 674.19, 34 CFR 675.19 and 34 CFR 676.19 were not followed and thus the total tuition and fees for the award year July 1, 2023 to June 30, 2024 reported on the FISAP were greater than the tuition and fees on the statement of activities by $368,034. Questioned Costs: There are no questioned costs associated with this finding. Recommendation: We recommend that the College implement a control to ensure FISAP reporting is accurate. Corrective Actions Taken or Planned: The College concurs with the finding. A system of controls will be implemented to ensure accurate data is reported on all required reporting. Individual Responsible for Corrective Action: Katie Palmer, Director of Financial Planning Expected Completion Date: August 2025

Federal Program: U.S. Department of Education - Student Financial Assistance Cluster Federal Direct Loan Program, 84.268 Criteria: The College is required to comply with 34 CFR Section 685.304(a)(2). Condition: During our testing of eligibility, we selected 40 samples and noted three instances where the loan disbursement date on the student's leger did not agree to the disbursement date on Common Origination and Disbursement (COD). Cause: The College did not have controls in place to properly review COD disbursement dates to verify all students had proper reporting to COD. Effect: The College did not follow federal regulations regarding reporting to COD. The provisions of 34 CFR Section 685.301(a)(2) were not followed and thus three students loans were improperly reported to COD. Questioned Costs: There are no questioned costs associated with this finding. Recommendation: We recommend that the College review all COD disbursements and perform monthly COD reconciliations by student to verify the disbursement date and amount matches the student ledger. Corrective Action Taken or Planned: The College concurs with the finding. Controls have already been implemented to ensure accurate and timely reporting to COD. Individual Responsible for Corrective Action: Katie Palmer, Director of Financial Planning Expected Completion Date: November 2024

Federal Program: U.S. Department of Education - Student Financial Assistance Cluster Federal Direct Loan Program, 84.268 Criteria: The College is required to comply with 34 CFR Section 685.304(a). Condition: During our testing of eligibility, we selected 40 samples and noted two instances where a student was disbursed a direct loan prior to entrance counseling being completed. Cause: The College did not have controls in place to ensure entrance counseling was completed prior to a loan disbursement. Effect: The College did not follow federal regulations regarding loan disbursements. The provisions of 34 CFR Section 385.304(a) were not followed and thus two students were improperly disbursed a direct loan. Questioned Costs: There are a total of $9,250 of questioned costs associated with this finding. $5,192j related to subsidized loans and $4,058 related to unsubsidized loans. Recommendation: We recommend that the College implement a control to ensure loans are not disbursed to students until entrance counseling has been completed by the student. Corrective Action Taken or Planned: The College agrees with the finding. Controls have already been implemented to ensure that compliance with all federal and state requirements are met before aid is disbursed. Individual Responsible for Corrective Action: Katie Palmer, Director of Financial Planning Expected Completion Date: November 2024

Federal Program: U.S. Department of Education - Student Financial Assistance Cluster Federal Direct Loan Program, 84.268 Criteria: The College is required to comply with 34 CFR Section 685.309(b ). Condition: During our testing of eligibility, official withdraws, and student status changes for graduates, we selected 40, one, and 21 samples, respectively. We noted three instances in eligibility testing, one instance in official withdraws, and one instance in student status change for graduates where a student's status changes were either not reported timely or accurately to the National Student Loan Database System (NSLDS). Cause: The College did not have controls in place to ensure student's classification were being properly reported to the NSLDS. Effect: Student status changes were not reported within the required timeframe under federal regulations. The provisions of 34 CFR Section 685.309(b) were not followed and thus two students were not reported and subsequently not placed into loan repayment status in a timely manner. Questioned Costs: There were no questioned costs associated with this finding. Recommendation: We recommend that the College implement a control to ensure data is being reviewed for accuracy by the appropriate personnel before roster files are submitted to NSLDS. In addition, we recommend that the College submit roster files on a regular basis. Corrective Actions Taken or Planned: The College concurs with the finding. The Registrar's Office will implement a system of reviews and controls that ensure timely and accurate reporting of student status changes to the National Student Loan System (NSLDS). Individual Responsible for Correction Action: Katie Palmer, Director of Financial Planning Expected Completion Date: August 2025