Corrective Action Plans

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Reference Number 2025-02 Return of Title IV Funds (R2T4) Since the 2025 audit, there have been significant improvements in oversight and process management for R2T4 calculations. A leadership transition occurred, and the Associate Director - bringing over 30 years of higher education experience, inc...
Reference Number 2025-02 Return of Title IV Funds (R2T4) Since the 2025 audit, there have been significant improvements in oversight and process management for R2T4 calculations. A leadership transition occurred, and the Associate Director - bringing over 30 years of higher education experience, including prior service as a Financial Aid Director - has assumed responsibility for R2T4 calculations for the 2026-27 academic year. To ensure compliance and accuracy, the Associate Director completed a Department of Education training refresher on R2T4 calculations during Spring 2025. Additionally, the interim Financial Aid Director implemented a structured plan to monitor all student withdrawals and guarantee timely completion of calculations. For Fall 2025, the process has remained on schedule. A two-tier accountability system is in place: the Associate Director manages calculations, and the Director provides immediate support if any delays occur. A comprehensive tracking spreadsheet was developed to record each withdrawal, including the withdrawal date, federal aid status, and the date the R2T4 calculation was completed. This tool ensures real-time monitoring and accuracy. The daily withdrawal report introduced after the 2024 audit continues to be a valuable resource; however, the combination of this report with the new tracking system and dual oversight has proven to be the cornerstone of compliance. All calculations are current, accurate, and completed within required timelines. Based on these improvements, we do not anticipate any findings in the upcoming audit.
Views of Responsible Officials and Planned Corrective Actions – The Registrar and Institutional Researcher will both ensure that any students that have updated their status are updated on a weekly basis. The Institutional Researcher will log into NSLDS to upload the file, and the CFO, Registrar, and...
Views of Responsible Officials and Planned Corrective Actions – The Registrar and Institutional Researcher will both ensure that any students that have updated their status are updated on a weekly basis. The Institutional Researcher will log into NSLDS to upload the file, and the CFO, Registrar, and Institutional Researcher will monitor updates monthly.
Views of Responsible Officials and Planned Corrective Actions – The CFO and the Students Account Manager will add a checklist step to verify the correct inclusion of all scheduled breaks in the R2T4 calculation, will implement a secondary review process to confirm data accuracy before finalizing R2T...
Views of Responsible Officials and Planned Corrective Actions – The CFO and the Students Account Manager will add a checklist step to verify the correct inclusion of all scheduled breaks in the R2T4 calculation, will implement a secondary review process to confirm data accuracy before finalizing R2T4, and will provide training to relevant staff.
Views of Responsible Officials and Planned Corrective Actions – The CFO and Student Accounts Manager has begun the process of uploading the file that specifies disbursement date in the ledger so they match one another.
Views of Responsible Officials and Planned Corrective Actions – The CFO and Student Accounts Manager has begun the process of uploading the file that specifies disbursement date in the ledger so they match one another.
Views of Responsible Officials and Planned Corrective Actions – The CFO and Student Accounts Manager will provide a listing of all students receiving a refund. A grace period of 5 days for students to provide direct deposit information will be established, if after 5 there is still no direct deposit...
Views of Responsible Officials and Planned Corrective Actions – The CFO and Student Accounts Manager will provide a listing of all students receiving a refund. A grace period of 5 days for students to provide direct deposit information will be established, if after 5 there is still no direct deposit information, a check will be issued.
Student Financial Assistance Cluster Assistance Listing No. 84.007, 84.033, 84.063 & 84.268 Recommendation: We recommend the University review credit balance refund processes, including automated processes, to ensure all credit balances are paid timely. Explanation of disagreement with audit finding...
Student Financial Assistance Cluster Assistance Listing No. 84.007, 84.033, 84.063 & 84.268 Recommendation: We recommend the University review credit balance refund processes, including automated processes, to ensure all credit balances are paid timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Revised the daily Title IV credit balance workflows to include credit balances of any amount. Name(s) of the contact person(s) responsible for corrective action: Valerie Marsh, Director of Student Financial Services Planned completion date for corrective action plan: December 1, 2025
Student Financial Assistance Cluster Assistance Listing No. 84.007, 84.033, 84.063 & 84.268 Recommendation: We recommend the University review reporting processes to ensure all students that require exit counseling receive it in a timely manner. Explanation of disagreement with audit finding: There ...
Student Financial Assistance Cluster Assistance Listing No. 84.007, 84.033, 84.063 & 84.268 Recommendation: We recommend the University review reporting processes to ensure all students that require exit counseling receive it in a timely manner. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The workflow FAEXIT_WDR for students who withdrew in the current term or have a late coded CWD was revised from excluding the assignment of exit counseling if exit counseling was assigned in the prior academic term to exclude only if exit counseling already exists in the current term. Name(s) of the contact person(s) responsible for corrective action: Alec Kuzmack, Business Analyst Planned completion date for corrective action plan: November 21, 2025
Corrective Action Plan Related to the Schedule of Findings and Questioned Costs Student Financial Aid University of Hawaiʿi – Maui College Year Ended June 30, 2025 Finding No. 2025-002: Financial Aid Administration – Control Deficiency Federal Agency: U.S. Department of Education CFDA Number and Tit...
Corrective Action Plan Related to the Schedule of Findings and Questioned Costs Student Financial Aid University of Hawaiʿi – Maui College Year Ended June 30, 2025 Finding No. 2025-002: Financial Aid Administration – Control Deficiency Federal Agency: U.S. Department of Education CFDA Number and Title: 84.268 – Federal Direct Student Loans Questioned Costs: $-0- Responsible Individuals: Kulamanu Ishihara, Financial Aid Director, Maui College Date Action Taken: December 2, 2025 Corrective Action Plan for timely notifications for exit counseling- NSLDS reporting. 1. Financial Aid Office Staffing ● The Financial Aid Office has completed recruitment for four full-time positions, including a director to ensure adequate administrative capacity for the financial aid processes. 2. Project Prioritization ● Effective immediately, the Financial Aid Office will prioritize timely notifications and exit counseling to students with loans. 3. Project Documentation ● For any future delays due to unforeseeable circumstances, the financial aid program will provide clear, detailed justifications to ensure compliance with audit expectations. 4. Project Oversight and Monitoring ● The Vice Chancellor of Student Affairs will meet monthly with the Financial Aid Director to ensure deadlines are being met and to and monitor the progress of notifications. Expected Results Implementation of this corrective action plan will result in timely notifications of exit counseling being provided through interactive electronic notifications or by mailing counseling materials to the borrower at the borrower’s last known address within 30 days after learning that the borrower has withdrawn from the institution or failed to complete exit counseling as required.
Corrective Action Plan Related to the Schedule of Findings and Questioned Costs Student Financial Aid University of Hawaiʿi – Maui College Year Ended June 30, 2025 Finding No. 2025-001: Return of Title IV Funds – Control Deficiency Federal Agency: U.S. Department of Education CFDA Number and Title: ...
Corrective Action Plan Related to the Schedule of Findings and Questioned Costs Student Financial Aid University of Hawaiʿi – Maui College Year Ended June 30, 2025 Finding No. 2025-001: Return of Title IV Funds – Control Deficiency Federal Agency: U.S. Department of Education CFDA Number and Title: 84.063 – Federal Pell Grant Questioned Costs: $-0- Responsible Individuals: Kulamanu Ishihara, Financial Aid Director, Maui College Date Action Taken: November 25, 2025 Corrective Action Plan for timely notifications for withdrawal date determination. 1. Financial Aid Office Staffing ● The Financial Aid Office has completed recruitment for four full-time positions, including a director to ensure adequate administrative capacity for the financial aid processes. 2. Project Prioritization ● Effective immediately, the Financial Aid Office will prioritize the timely withdrawal date determination by initiating the new Kuali Build Form with routing capabilities. 3. Project Documentation ● For any future delays due to unforeseeable circumstances, the financial aid program will provide clear, detailed justifications to ensure compliance with audit expectations. 4. Project Oversight and Monitoring ● The Vice Chancellor of Student Affairs will meet monthly with the Financial Aid Director to ensure deadlines are being met and to monitor the progress of notifications. Expected Results Implementation of this corrective action plan will result in a timely determination of the withdrawal date through interactive electronic routing.
2025-001 Significant Deficiency: National Student Loan Data System (NSLDS) Report (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268 and Federal Pell Grant Program, ALN #84.063) (Repeat finding of 2022-001, 2023-003, and 2024-005) Name of Contact Person Casey Reagan, Reg...
2025-001 Significant Deficiency: National Student Loan Data System (NSLDS) Report (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268 and Federal Pell Grant Program, ALN #84.063) (Repeat finding of 2022-001, 2023-003, and 2024-005) Name of Contact Person Casey Reagan, Registrar, and Melissa White, Director of Financial Aid, are responsible for clearinghouse reporting for 2023-24. Corrective Action Planned During the audit, it was noted that the University incorrectly reported student enrollment status for changes in enrollment. The university has identified the issue that is occurring that is causing the enrollment to be reported incorrectly. We are currently working with the IT Department to fix the error that is occurring within the system itself. In the meantime, students who are impacted by the incorrect enrollment status reporting are being manually fixed in the system and then the record is being pulled and reported to clearinghouse. Overall, the university has been working to reduce the number of incorrect enrollment status reportings. This can be seen by the fact that we went from a 45% error rate in 2023-24 to a 20% error rate in 2024-25. Finally, the Registrar’s Office shall be main office reporting clearinghouse data in the future, with financial aid only acting as a secondary reporter should the Registrar’s Office not be available to report. Anticipated Completion Date 08/01/2026
2025-001 Incorrect Direct Loans Disbursement Amount - Student Financial Aid Cluster Assistance Listing #s 84.007, 84.033, 84.063, 84.268, Grant Period - Year Ended June 30, 2025 Condition Found During our student file testing we noted one student out of forty was disbursed the incorrect Direct Loan ...
2025-001 Incorrect Direct Loans Disbursement Amount - Student Financial Aid Cluster Assistance Listing #s 84.007, 84.033, 84.063, 84.268, Grant Period - Year Ended June 30, 2025 Condition Found During our student file testing we noted one student out of forty was disbursed the incorrect Direct Loan amount. Based on the student’s enrollment status and need this student was eligible for $586 in Subsidized Loans and $2,914 in Unsubsidized Loans; however, the College awarded the student $549 in Subsidized loans and $2,951 in Unsubsidized loans which resulted in an under award of $37 in Subsidized Loans and an over award of $37 in Unsubsidized Loans. We consider this error in awarding to be an instance of noncompliance of the Eligibility Compliance Requirement. Corrective Action Plan Waubonsee will ensure to add the loan fees first to ensure sub-loans are calculated correctly. Responsible Person for Corrective Action Plan Mary Greenwood Implementation Date of Corrective Action Plan 12/9/2025
1. Immediate System Correction The clock-to-credit hour conversion file in Banner (GTVSDAX) was reviewed and updated to include all applicable course prefixes, including MAH and PSY. This correction ensured that clock-to-credit hour conversions were calculated accurately for affected technical progr...
1. Immediate System Correction The clock-to-credit hour conversion file in Banner (GTVSDAX) was reviewed and updated to include all applicable course prefixes, including MAH and PSY. This correction ensured that clock-to-credit hour conversions were calculated accurately for affected technical programs. 2. Identification and Review of Impacted Students Financial Aid reviewed all students enrolled in the affected term (202610) and identified those whose federal aid hours had been overstated due to the conversion omission. 3. Correction of Federal Aid Awards Federal aid awards were recalculated for impacted students. The engagement team noted, and the College confirms, that all affected students were enrolled in a current payment period for which funds had not yet been fully drawn, allowing corrections to be made timely. 4. Resolution of Financial Impact Where recalculations resulted in reduced eligibility, institutional need-based funds were applied to affected student accounts to prevent students from incurring balances due to an internal administrative error. This ensured students were not financially penalized for the control deficiency. Preventive Actions and Controls to Avoid Recurrence To address the identified control deficiency and strengthen internal controls over clock-to-credit hour conversions, the College has implemented the following preventive measures: 1. Enhanced Curriculum Oversight The Registrar (Tara Dumas) and Director of Financial Aid (Stacia Richerson) now serve as standing members of the Academic/Curriculum Review Committee. This ensures that Financial Aid and Registrar review all proposed curriculum changes, including: o New courses o New course prefixes o Courses designated as “in degree plan” for technical or clock-hour programs This review occurs prior to course approval and implementation, allowing clock-to-credit hour implications to be addressed in advance. 2. Formal Notification and Review Process Academic Affairs will notify Financial Aid of any curriculum changes that may impact clock-to-credit hour conversions. Financial Aid will review and update Banner conversion tables as needed before federal aid calculations occur. 3. Assigned Responsibility and Monitoring Responsibility for maintaining and reviewing clock-to-credit hour conversion tables has been formally assigned to the Director of Financial Aid (Stacia Richerson). o Conversion tables will be reviewed each semester prior to awarding federal aid. o Discrepancies in ROAENRL will be reviewed promptly to ensure accuracy. 4. Ongoing Compliance Review The College will perform periodic reviews of conversion logic and awarding calculations to ensure continued compliance with federal regulations and internal control standards under 2 CFR 200.303. Conclusion Reid State Technical College has corrected the clock-to-credit hour conversion issue, resolved the related questioned costs, and implemented strengthened internal controls. The addition of the Registrar (Tara Dumas) and Director of Financial Aid (Stacia Richerson) to the Academic/Curriculum Review Committee, combined with formalized review and notification procedures, provides reasonable assurance that clock-to-credit hour conversions will be accurately applied prior to federal aid calculation and disbursement.
Identification Number: 2025‑005 – Satisfactory Academic Progress Finding: One student received Direct Unsubsidized Loan funds despite not meeting maximum timeframe requirements for satisfactory academic progress at the beginning of the Spring 2025 semester. Corrective Action Plan: Management agrees ...
Identification Number: 2025‑005 – Satisfactory Academic Progress Finding: One student received Direct Unsubsidized Loan funds despite not meeting maximum timeframe requirements for satisfactory academic progress at the beginning of the Spring 2025 semester. Corrective Action Plan: Management agrees with the finding. The University will strengthen controls to ensure satisfactory academic progress is fully evaluated and documented prior to the disbursement of Title IV funds. A review checkpoint will be added to verify eligibility before loan disbursements are released. Responsible Officials and Implementation Date: The Director of Student Financial Services will be responsible for this corrective action. Updated review procedures will be implemented by February 16, 2026.
Identification Number: 2025‑004 – Return of Title IV Funds Finding: Incorrect spring break days were used in Return of Title IV calculations for Spring 2025, resulting in inaccurate return amounts and funds not properly returned to the U.S. Department of Education. Corrective Action Plan: Management...
Identification Number: 2025‑004 – Return of Title IV Funds Finding: Incorrect spring break days were used in Return of Title IV calculations for Spring 2025, resulting in inaccurate return amounts and funds not properly returned to the U.S. Department of Education. Corrective Action Plan: Management agrees with the finding. The University will revise Return of Title IV calculation procedures to ensure accurate identification of payment periods, including scheduled breaks. A secondary review of all Return of Title IV calculations will be implemented prior to processing returns to confirm accuracy and compliance with federal regulations. Identified funds due will be returned to the U.S. Department of Education. Responsible Officials and Implementation Date: The Director of Student Financial Services will be responsible for implementing the corrective action, with oversight from the Vice President for Administration and Finance. Revised procedures and secondary review controls will be implemented by February 16, 2026.
Identification Number: 2025‑003 – Enrollment Reporting (Repeat Finding) Finding: The University did not report one student status change timely and reported inaccurate program‑level record data for four students, resulting in inaccurate or untimely enrollment reporting to the U.S. Department of Educ...
Identification Number: 2025‑003 – Enrollment Reporting (Repeat Finding) Finding: The University did not report one student status change timely and reported inaccurate program‑level record data for four students, resulting in inaccurate or untimely enrollment reporting to the U.S. Department of Education. Corrective Action Plan: Management agrees with the finding. The University will enhance controls over enrollment reporting to ensure all student status changes and program‑level data are reviewed for accuracy and reported timely. Additional reconciliation between the Registrar's Office and Student Financial Services will occur before submission to the National Student Clearinghouse and the U.S. Department of Education. Responsible Officials and Implementation Date: The Registrar and Director of Student Financial Services will be responsible. Improved review and reconciliation procedures will be implemented by July 1, 2026, prior to the Fall term.
Identification Number: 2025‑006 – Pell Grant Eligibility Finding: Pell Grant funds were disbursed to five students who were not eiligible, and two students did not receive the full Pell Grant amount for which they were eligible. Corrective Action Plan: Management agrees eith the finding. The Univers...
Identification Number: 2025‑006 – Pell Grant Eligibility Finding: Pell Grant funds were disbursed to five students who were not eiligible, and two students did not receive the full Pell Grant amount for which they were eligible. Corrective Action Plan: Management agrees eith the finding. The University will implement enhanced review controls over Pell Grant eligibility and calculation prior to disbursement. This will include verification of eligibility data and a secondary review of Pell calculations to ensure accuracy and completeness before funds are released. Responsible Officials and Implementation Date: The Director of Student Financial Services will be responsible for implementing this corrective action, with the oversight from the Vice President for Administration and Finance. Enhanced controls will be implemented by February 16, 2026.
Corrective Action Plan 2025-001: The College concurs with the finding and has adjusted its processes and controls beginning with the Fall 2025 semester to ensure that all Title IV funding sources including FSEOG are drawn down in accordance with the Heightened Cash Monitoring requirements. Completio...
Corrective Action Plan 2025-001: The College concurs with the finding and has adjusted its processes and controls beginning with the Fall 2025 semester to ensure that all Title IV funding sources including FSEOG are drawn down in accordance with the Heightened Cash Monitoring requirements. Completion Date: August 2025 Contact Person: Laura Crawley
Upon notification of the reporting error, the institution corrected the enrollment status effective date in both the National Student Clearinghouse (NSC) and NSLDS to reflect the student's actual withdrawal date of November 15, 2024. To prevent future reporting errors, the Registrar's Office will im...
Upon notification of the reporting error, the institution corrected the enrollment status effective date in both the National Student Clearinghouse (NSC) and NSLDS to reflect the student's actual withdrawal date of November 15, 2024. To prevent future reporting errors, the Registrar's Office will implement an additional procedural verification step in the enrollment status reporting process. This step will include a review of effective dates prior to submission to NSC and NSLDS. The Registrar will also ensure appropriate staff training and oversight as process documentation is developed and implemented in the new student information system.
Finding 2025-001 Special Tests and Provisions – Participation of Private School Children Finding Summary: The District failed to conduct timely consultations with private school officials regarding the implementation of the Stronger Connections Grant. Responsible Individuals: Dr. Farrah Gomez, Deput...
Finding 2025-001 Special Tests and Provisions – Participation of Private School Children Finding Summary: The District failed to conduct timely consultations with private school officials regarding the implementation of the Stronger Connections Grant. Responsible Individuals: Dr. Farrah Gomez, Deputy Superintendent of Academics and School Leadership Corrective Action Plan: The District will establish and implement written procedures to ensure annual consultation meetings with private school officials for all grants under the Title IV program. Additionally, the District will consult with TEA to determine next steps regarding the Stronger Connections Grant. Anticipated Completion Date: January 2026
Views of Responsible Officials and Corrective Action Plan The District agrees with the finding and will implement procedures that will ensure Returns of Title IV funds are returned no later than 45 days after that date the College determines the student has withdrew.
Views of Responsible Officials and Corrective Action Plan The District agrees with the finding and will implement procedures that will ensure Returns of Title IV funds are returned no later than 45 days after that date the College determines the student has withdrew.
Corrective Action Plan: To prevent this issue from recurring, we have implemented an additional data validation step during the preparation of the Graduates Only Enrollment Submission. Specifically, we will now cross-check the "last date of attendance" field for all graduating students to ensure tha...
Corrective Action Plan: To prevent this issue from recurring, we have implemented an additional data validation step during the preparation of the Graduates Only Enrollment Submission. Specifically, we will now cross-check the "last date of attendance" field for all graduating students to ensure that it aligns with the official last day of the term, as defined by the academic calendar. In this case, the correct date should have been December 20, 2024; however, the file incorrectly populated the field with December 23, 2024. We are reviewing the logic in the data generation process to identify and correct the source of the discrepancy. Moving forward, the Registrar’s Office will confirm this date field prior to each submission to the Clearinghouse to ensure compliance with NSLDS requirements. Timeline for Implementation of Corrective Action Plan: The corrective action plan was implemented as of October 2025. Contact Person: Caitlin Laurie, Director of Financial Aid Mark Powers, Registrar
Corrective Action Plan: The individual did not have a social security number (“SSN”) on file in Banner. As a result, although the enrollment data was transmitted to the National Student Clearinghouse, the missing SSN went unnoticed until June 2025, when materials were being gathered for the audit. T...
Corrective Action Plan: The individual did not have a social security number (“SSN”) on file in Banner. As a result, although the enrollment data was transmitted to the National Student Clearinghouse, the missing SSN went unnoticed until June 2025, when materials were being gathered for the audit. The Director of Student Financial Aid was able to locate the student’s SSN in PowerFaids and provide it accordingly. We then manually updated the student’s Fall 2024 and Spring 2025 enrollment data in NSLDS to ensure their record was complete. To help prevent this type of issue in the future, both the Registrar and Director of Student Financial Aid have implemented a process that compares missing or potentially incorrect SSNs in Banner against the data in PowerFaids. Timeline for Implementation of Corrective Action Plan: The corrective action plan was implemented as of October 2025. Contact Person: Caitlin Laurie, Director of Financial Aid Mark Powers, Registrar
Corrective Action: See above corrective action plan for 2025-002. Contact Persons: Duane Valencia, Assistant Financial Vice President – Student Finance; Jason Kowarsch, Registrar
Corrective Action: See above corrective action plan for 2025-002. Contact Persons: Duane Valencia, Assistant Financial Vice President – Student Finance; Jason Kowarsch, Registrar
Corrective Action: To prevent future occurrences of PELL and Direct Loans award findings identifying students not enrolled, withdrawn, and over-awarded aid. • Staff Training o Additional training sessions will be conducted for Student Finance staff to enhance understanding of awarding rules and syst...
Corrective Action: To prevent future occurrences of PELL and Direct Loans award findings identifying students not enrolled, withdrawn, and over-awarded aid. • Staff Training o Additional training sessions will be conducted for Student Finance staff to enhance understanding of awarding rules and system functionality. o Training will focus on identifying and correcting over-awarding scenarios before disbursement. • System Monitoring o Regular audits of the Ellucian System will be performed to ensure continued accuracy in aid calculations and refund processing. • Policy Enforcement o A formal policy will be adopted requiring aid disbursement only after census verification. o Exception will be documented and reviewed by the Vice President of Financial Administration. Contact Persons: Duane Valencia, Assistant Financial Vice President – Student Finance; Jason Kowarsch, Registrar Completion Date: To be completed by March 1, 2026
The 2023-24 Single Audit identified 12 delinquent NSLDS reports for the 2023-24 academic year, with delays ranging from 180 to 459 days. The 2024-25 Single Audit showed improvement, with only 5 of 9 reports filed late for the 2024-25 academic year, and delays reduced to 80-155 days. Corrective Actio...
The 2023-24 Single Audit identified 12 delinquent NSLDS reports for the 2023-24 academic year, with delays ranging from 180 to 459 days. The 2024-25 Single Audit showed improvement, with only 5 of 9 reports filed late for the 2024-25 academic year, and delays reduced to 80-155 days. Corrective Action: To prevent future occurrences of missed NSLDS reporting, the following steps have been implemented: • Cleanup of Past Delinquencies o All outstanding 2024-25 reports have been reviewed and submitted by October 3, 2025. o A reconciliation audit will be conducted to ensure all NSLDS records match institutional data. • Process Improvement o Implemented a centralized calendar with automated reminders for NSLDS reporting deadlines. o Established monthly reconciliation between internal Student Information System and NSLDS data. • Staffing and Training o The registrar is the primary reporting coordinator to the National Student Clearinghouse, with support from both Student Financial Services and ITS. o A standard operating procedure (SOP) has been documented to guide future reporting efforts. • Management Oversight o The Vice President for Academic Administration and ITS must also ensure that all these processes and departments are working to ensure the student data is being reported correctly and on-time. We are confident that these measures will address the issue of failure to report to the NSC and ensure full compliance with NSLDS reporting requirements in the future. Contact Persons: Duane Valencia, Assistant Financial Vice President – Student Finance; Jason Kowarsch, Registrar Completion Date: October 3, 2025
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