Corrective Action Plans

Student Financial Aid Cluster – 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: In response to these challenges, the University initiated corrective actions beginning in Summer 2025. 1. Dedicated Technical Resources: We have been assigned dedicated ITS staff members (managed by Dynamic Campus) specifically to the resolution of enrollment and graduation submission and compilation logic. 2. Submission Scheduling: A rigid schedule for monthly enrollment and graduation submissions has been established for both Branch 00 and Branch 76. 3. Staffing: An additional Registrar’s Office staff member has been shifted to assist with the NSC process, specifically focusing on the remediation of error reports. 4. Policy Revision: We have simplified the degree conferral policy to improve the accuracy of graduation reporting. We are also working to align end of term grade submission deadlines to allow for timely end of term processing and degree conferrals. This in turn will aid in more timely submissions especially as it affects graduation reporting. 5. Data Mapping: The Registrar’s Office has collaborated with ITS to audit the specific fields and tables used to generate Clearinghouse reports. This addresses the complexity of reporting on two branches involving multiple term codes. 6. Automation: We have implemented a timely and automated submission schedule. 7. Change Management Protocols: A protocol is being implemented to prevent ITS system upgrades or network maintenance during scheduled reporting windows. 8. Data Reconciliation: We will implement a strict monitoring of Clearinghouse records regarding graduation and withdrawal dates, reconciling them against the Student Information System (SIS) and NSLDS data. That will occur once we can gain NSLDS access for the two staff members. Discrepancies will be corrected immediately. Special attention will be paid to conferral dates since they may not align with the final day of the term or sub-term. 9. Cross-Departmental Alignment: We will continue regular consultations with the Financial Aid Office regarding complex registration changes to ensure consistent interpretation and reporting. 10. Ongoing Training: Staff will continue to utilize training opportunities provided by the Clearinghouse, Banner, and other relevant bodies. Name(s) of the contact person(s) responsible for corrective action: Cheryl Fisk, University Registrar Planned completion date for corrective action plan: March 1, 2026

Enrollment Reporting - Withdrawal Corrective Action Plan Issue Identified: An enrollment reporting error occurred due to a student’s withdrawal date not being transmitted to the National Student Loan Data System (NSLDS). The student submitted a withdrawal form after the last enrollment file for the semester had been reported to the National Student Clearinghouse (NSC). Upon receipt, the withdrawal date was entered retroactively as the final day of the semester. Because the semester had already been reported, the withdrawal was not included until the subsequent first-ofterm enrollment report, resulting in a reporting delay that exceeded the 60-day submission requirement. Corrective Action Taken: The University Registrar consulted with the National Student Clearinghouse to verify the appropriate process for reporting withdrawals received after the final enrollment submission for a term. Based on this guidance, the following corrective measures have been implemented: 1. Manual Reporting of Late Withdrawals: If a withdrawal form is received after the final enrollment file for a term has been submitted, the Registrar’s Office will manually update NSC with the correct withdrawal date. 2. Implementation Date: This procedure became effective at the beginning of the Fall 2025 semester. 3. Ongoing Compliance: The Registrar’s Office will continue to submit timely and accurate enrollment reports to NSLDS, ensuring that all changes to student enrollment status are reported within required federal deadlines. Responsible Office: The Office of the Registrar, under the direct supervision of the University Registrar, is responsible for the implementation, monitoring, and ongoing adherence to this corrective action plan. Enrollment Reporting - Graduation Corrective Action Plan Issue Identified: A reporting error occurred in which a student’s graduation date did not appear in the National Student Loan Data System (NSLDS). The discrepancy was caused by the graduation date being recorded as the commencement date of May 17, 2025, while the official semester end date was May 15, 2025.The final enrollment file was submitted to the National Student Clearinghouse (NSC) on May 15, 2025, prior to the entry of the graduation date, resulting in the omission from the report. Corrective Action Taken: The University Registrar reviewed the reporting procedures and determined that graduation dates must align with the official academic calendar, specifically the last day of class for the semester. To ensure compliance, the following measures have been implemented: 1. Standardization of Graduation Dates: All future graduation dates will be recorded as the official last day of class for the semester, rather than the commencement ceremony date. 2. Adjustment of Final Reporting Timeline: The final enrollment report for each term will not be submitted until all graduation records have been updated in the system to ensure accurate transmission to NSC and NSLDS. 3. Implementation Date: This procedure is effective beginning with the Fall 2025 and Spring 2026 graduation reporting cycle. 4. Ongoing Compliance: The Registrar’s Office will continue to monitor reporting practices to ensure all graduation and enrollment data are transmitted to NSLDS in accordance with federal reporting requirements. Responsible Office: The Office of the Registrar, under the direct supervision of the University Registrar, is responsible for the implementation, oversight, and continued compliance of this corrective action plan. Shannon Bishop Shannon.bishop@converse.edu University Registrar

2025-001 - Student Financial Assistance Cluster - Special Tests and Provisions - NSLDS Enrollment Reporting Condition During testing, it was determined that 3 of the 60 students tested for enrollment status changes had a missing graduation status or a late certification date for a graduation status reflected within their NSLDS reporting. Recommendation We recommend that the College review its control policies to ensure that reporting is completed accurately and timely. Comments on the Finding Management is aware of the oversight and will ensure that there are processes in place for this to be corrected. Actions Taken As of November 2025, there has been a change in personnel within the Registrar's Office. With this new change in staff, the registrar's department will be trained to understand the importance of reporting correct information to the National Student Clearinghouse. They will also set calendar reminders to get the information filed in a timely manner so that students are correctly labeled for the following reporting period. The Registrar's Office will also ensure that there are at least two individuals within the office trained on these processes and importance/adherence to reporting deadlines.

Finding 2025-003: Untimely Enrollment Status Reporting – the Institution did not provide an enrollment update response to National Student Loan Data System (NSLDS) in a timely manner for July 2024. It is recommended the Institution increase controls over enrollment reporting. Comments on Finding and Recommendation(s): During the time, the school was transitioning reporting periods and was reported based on new schedule. This is no longer an issue. Actions Taken or Planned: All student’s enrollment status were verified for the entire year and was found that all statuses reported were correct.

Finding 2025-002: Unpaid Refunds – the auditor tested twenty-two drop students and noted two unpaid refunds. It is recommended that the Institution refund the $5,808 to the Department of Education and increase controls over paying refunds Comments on Finding and Recommendation(s): Happened during transitional phase of banking and employees and should be seen as an one off situation. Actions Taken or Planned: All banking accounts have been reconciled and refunds have been settled. We have secured more qualified accounting representatives to ensure timeliness going forward.

Finding 2025-001: Incorrect Federal Direct Loan Amounts – the auditor tested seventy-one files, sixty-seven of which were Federal Direct Loan recipients, and two students received incorrect loan amounts. It is recommended that the Institution refund $237 to the Department of Education and increase controls over packaging direct loans. There is no action required for the $333 in underawarded subsidized loans, as the student is no longer a current student, so the Institution is unable to reclassify the loans. Comments on Finding and Recommendation(s): This was an oversight on previous FA advisor when prorating loans. Actions Taken or Planned: Employee was removed from role earlier in the year and intense training has been given to the replacement. All debts have been settled with the Department of Education and appropriate student ledgers updated.

Identifying Number: 2025-001 Finding: The Foundation and College did not timely refund a student’s credit balance. Contact person responsible for corrective action: Laura Reagan, Senior Director of Financial Affairs Corrective Actions Taken or Planned: The Student Billing system omitted the student from the original refund list due to an inactive address in the system. The credit balance was identified on a routine review of the student billing aging report and subsequently processed. It was completed outside of the 14 day requirement. A process will be put in place to increase the frequency of the aging review to ensure any missed credit balances will be processed within the required time frame. Anticipated Completion date: June 30th, 2026

Friends University Year Ended June 30, 2025 Corrective Action Plan Finding Reference Number – 2025-001 Criteria or Specific Requirement – Special Tests and Provisions - Return of Title IV Funds (34 CFR section 668.22) (Reference number 2025-001) Recommendation – The University should take appropriate action to ensure information used to support student refund calculations is accurate and ensure proper oversight is performed timely. Views of Responsible Officials and Corrective Action Plan – Management concurs with the findings and recommendation. Responsible personnel will review calculations as they are completed. Individuals Responsible – Amy Stoltzfus, Director, Office of Financial Aid Anticipated Completion Date – Already implemented

Paris Junior College management will ensure that a standardized procedure including internal controls is established and implemented to ensure the R2T4 process is timely and accurate.

2025-001 - Student Financial Aid Cluster - (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Grant (c) Federal Pell Grant Program (d) Federal Direct Loan Program, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2025 Condition Found 4 of the 40 student files (10%) we examined, we noted the students were not properly awarded Direct loans. We consider this condition to be a significant deficiency relating to the Eligibility compliance requirement and is a repeat finding shown in Section IV of this report as prior year finding 2024-004. Statistical sampling was not used in making sample selections. Corrective Action Plan To address this finding, the Student Financial Services (SFS) team has implemented a Quality Assurance process designed to reconcile discrepancies between institutional and federal records: • Quality Assurance selection sets have been created to reconcile student grade level in Jenzabar with the grade level on the ISIR. • These QA queries will be run at multiple control points: o Prior to awarding Direct Loans o Prior to disbursement o At strategic intervals during the term to catch any subsequent changes • Identified discrepancies will be reviewed and corrected before aid is disbursed to ensure compliance with federal eligibility requirements. Responsible Person for Corrective Action Plan Deb Beck Implementation Date of Corrective Action Plan 10/1/2025

2025-002 - Student Financial Aid Cluster - (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Grant (c) Federal Pell Grant Program (d) Federal Direct Loan Program, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2025 Condition Found The Organization did not accurately complete refund calculations for 2 out of 9 students (22.2%) tested that both required post-withdrawal disbursements. For one of these students, the College did not notify the student of the post-withdrawal disbursement of Federal Direct Loans before it was applied to the student’s account. We consider this finding to be a significant deficiency in relation to the Special Tests and Provisions compliance requirement and is a repeat finding shown in Section IV of this report as prior year finding 2024-007. Corrective Action Plan To ensure accuracy and compliance going forward, the Student Financial Services (SFS) team will implement the following corrective actions: • Establish a double-layer review process for all post-withdrawal disbursements. • Each PWD calculation and notification will undergo an initial entry review by the staff member completing the R2T4 and a secondary accuracy check by a separate staff member prior to submission and disbursement. • This layered review is intended to catch and correct data entry errors prior to finalization. Responsible Person for Corrective Action Plan Deb Beck Implementation Date of Corrective Action Plan 10/1/2025

2025-003 - Student Financial Aid Cluster - (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Grant (c) Federal Pell Grant Program (d) Federal Direct Loan Program, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2025 Condition Found In our testing of student files, three out of 40 students (7.5%) had enrollment statuses not timely or accurately reported to NSLDS. We consider this finding to be an instance of noncompliance in relation to the Special Tests and Provisions compliance requirement and is a repeat finding shown in Section IV of this report as prior year finding 2024-008. Corrective Action Plan To address these deficiencies and ensure timely and accurate reporting going forward, the Registrar’s Office has implemented a comprehensive set of actions: • System & Process Review: In early October 2025, a review was conducted of the October NSLDS reporting file due to a Jenzabar bug. That process identified both procedural and software issues impacting data accuracy. • Staff Training: On October 9, 2025, targeted training was provided to the Registrar’s team on the Jenzabar support ticket recommendations and process findings, strengthening staff understanding of reporting requirements and workflows. • Jenzabar Collaboration: The College is actively working with Jenzabar support through the June and September tickets to resolve data discrepancies and implement best practices for future reporting cycles. • Internal Reporting Development: Montreat will create internal reports to identify discrepancies between the “NSC Detail” table and student term tables, enabling proactive error correction before NSLDS submission. • Ongoing Monitoring: This will remain an ongoing process improvement initiative as the team continues to refine validation checks, strengthen internal controls, and leverage Jenzabar system updates to improve accuracy and timeliness. Responsible Person for Corrective Action Plan Kandi Molder Implementation Date of Corrective Action Plan 1/31/2026

2025-003: Student Financial Audit Cluster - Special Tests and Provisions: Disbursements to, or on Behalf of, Students (Significant Deficiency) Corrective Action: The College updated its award notification process, which took effect for the Spring 2025 term. All current and future award notifications now comply with 34 CFR 668.165(a)(1). Including the required information regarding when Title IV funds will be disbursed. Referencing the academic calendar, which clearly identifies the official disbursement dates for the term. To prevent recurrence of this finding, the College has implemented the following permanent measures: • Revised Award Notification Templates: All digital and physical award notification templates have been permanently updated to include dedicated fields for the disbursement date or a direct, clear reference to where the student can find the disbursement schedule. • Enhanced Pre-Release Compliance Review: A mandatory two-step review process has been added to the award notification workflow. This step verifies that all notifications meet the “amount, how, and when” Title IV disclosure requirements before they are sent to students. • Mandatory Staff Training: All Financial Aid staff have received and will receive annual training refreshers on the current federal notification requirements, specifically emphasizing the timing of disbursement disclosure, and the use of the updated, compliant templates. • Ongoing Monitoring and Internal Audits: The College will implement a quarterly internal review process where a sample of student award notifications will be checked for accuracy and full compliance with 34 CFR 668.165(a)(1) to ensure sustained adherence. Anticipated Completion Date: 6/30/2026 Contact Person: Joyce Lubeck-Sonenberg

2025-002: Student Financial Audit Cluster - Reporting (Significant Deficiency) Corrective Action: The College has taken the following actions to implement the required additional control and ensure accurate tuition and fees reporting in the FISAP. • Systemic Data Isolation Control: The College has collaborated with its Institutional Research and Business Office staff to develop and implement a new report or query within the Student Information System (SIS). – This new control will automatically isolate and extract tuition and fees revenue only for students who meet the Section D criteria (regular students enrolled in credit-bearing classes). – This ensures that non-eligible tuition (e.g., non-credit, high school) is systematically excluded from the FISAP input data. • Segregation of Duties and Dual Review: The process for FISAP preparation has been revised to include a required dual-review step: – The Financial Aid Office will prepare the draft FISAP data using the new controlled data isolation report. – The Controller will perform a mandatory secondary verification of the total tuition and fee revenue reported in Part II, Section E, against the specific data extracted by the new systemic report. • Training and Procedure Documentation: Financial Aid and Business Office staff involved in the reporting process have been trained on the updated FISAP instructions and the mandatory use of the new systemic control to calculate Section E tuition and fees. The new control procedure has been documented in the College’s official FISAP preparation manual. Each different entity has the detailed instructions from the FISAP information. Anticipated Completion Date: 9/30/2025 Contact Person: Joyce Lubeck-Sonenberg

2025-004: Student Financial Audit Cluster - Special Tests and Provisions: Enrollment Reporting (Significant Deficiency) Corrective Action: Casper College will implement a multifaceted plan to ensure compliance with enrollment reporting requirements under 34 CFR 690.83, 34 CFR 685.309, and NSLDS guidelines. Key corrective steps include: • Policy Revision: Formally updating institutional policies (Sections 10 and 3.11) to clarify and align the reporting roles of the Registrar and Financial Aid, mandating specific timelines for all status changes, including withdrawals. • Strengthened Internal Controls: Establishing a mandatory dual-verification process for withdrawal effective dates and R2T4 alignment and implementing weekly NSLDS monitoring by Financial Aid and monthly Registrar–Financial Aid reconciliation meetings. • Documentation and Training: Improving documentation standards, including a centralized digital archive, and providing mandatory joint cross-office training on NSLDS rules, SSCR error resolution, and accurate, effective date determination. Anticipated Completion Date: 4/30/2026 Contact Person: Joyce Lubeck-Sonenberg

Management has implemented controls to ensure that all students receiving only failing grades ("all F") at the end of the semester are evaluated for potential R2T4 calculations.

Management has implemented controls to ensure that all students receiving only failing grades ("all F") at the end of the semester are evaluated for potential R2T4 calculations.

Management has implemented controls to ensure that all students receiving only failing grades ("all F") at the end of the semester are evaluated for potential R2T4 calculations.

As of August 2025, management has implemented controls to monitor student enrollment statuses and ensure the timeliness and accuracy of NSLDS reporting.

As of August 2025, management has implemented controls to monitor student enrollment statuses and ensure the timeliness and accuracy of NSLDS reporting.

Planned Corrective Action: Lake Erie College continues to review its operations and explore new partnerships to improve its financial performance. Some examples include: • Expanding marketing efforts to include high school Sophomores and Juniors creating a three-year enrollment funnel for the first time in college history. • Increase net tuition revenue by re-modeling financial aid strategies. • Eliminate academic programs and related faculty personnel for majors with declining enrollment. • Maximize enrollment in the new, market-savvy majors added for fiscal year 2026. • Make a comprehensive 9% cut to the fiscal year 2026 unrestricted operating budget. • Enforcing our residency requirement and meal plan enrollment to meet our budgeted revenue from auxiliaries. • Solicit grants from state, county, and local government agencies for facility projects and scholarship awards. • Continue to increase fundraising projections by engaging new donors and board members. Anticipated Completion Date: The elimination of academic programs and related faculty personnel took place at the end of the Spring 2025 term. The other items will be ongoing throughout the fiscal year. Responsible Contact Person: Jacalyn Kovach, Vice President of Finance

Department of Education Federal Direct Student Loans and Federal Pell Grant Program – Assistance Listing No. 84.268 and 84.063 Recommendation: We recommend that the University continue to enhance its policies and procedures regarding enrollment reporting including additional monitoring over the third-party service provider to ensure that reporting is completed accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management respectfully agrees on all findings and recommendations. Management will engage in business process review and implement redesigns as necessary. Management is committed to ensuring consistent application of policies and procedures so that enrollment reporting and oversight of third-party service providers result in accurate and timely reporting by the third-party service provider. Although the third-party service provider holds a national monopoly on enrollment reporting and other institutions of higher education face similar reporting issues by the third-party service provider, Management believes that review of internal processes over enrollment reporting will mitigate accuracy and timeliness errors made by the third-party service provider. These measures will help ensure compliance with U.S. Department of Education requirements. Name(s) of the contact person(s) responsible for corrective action: Ashlie Pence Planned completion date for corrective action plan: February 28, 2026

Views of Responsible Officials and Planned Corrective Actions Clearinghouse reports are from the college’s student information system (SIS). During FY24, the finding stems from a student’s withdrawal, which was promptly processed and entered in the SIS. However, the system categorized the student as "less than half-time” because the student received a passing grade in a course for which the student was exempted after passing a proficiency test. The SIS did not update the student status to 'withdrawn' until the semester ended, which was more than 60 days after the withdrawal date. To remedy this issue, the college’s Business Office now maintains an online spreadsheet listing withdrawn students outside the SIS that is updated whenever a student withdraws from the college. The list has been shared with the personnel responsible for the Clearinghouse reports and the Financial Aid Coordinator. Personnel will monitor the withdrawal listing and verify that all withdrawn students are accurately categorized in the Clearinghouse report from the SIS before completing the submission. After reviewing the FY25 finding, we discovered that the student attended in the spring 2025 semester but withdrew during the college’s drop/add period. By default, the SIS removes students who withdraw during drop/add from the Clearinghouse report.We have confirmed that Welch is unable to modify data or correct errors in the SIS report submitted to the Clearinghouse.Action Taken/Planned To address these problems, which ultimately stemmed from the limitations of Clearinghouse reporting by the college’s SIS, Welch has taken the following steps: 1. Clearinghouse reporting responsibilities have transitioned to a full-time, onsite employee in the Provost’s Office. 2. When preparing Clearinghouse reports and to help with identifying any errors before submitting the report, the employee will continue to monitor the withdrawn students listing maintained by the college’s Business Office, as outlined in the steps taken with the FY24 finding. 3. Welch plans to engage with its SIS and explain the reporting issues and limitations to determine if the SIS can help the college resolve the reporting limitations with its system. 4. To minimize the possibility of students being omitted from any Clearinghouse report, the employee responsible for the Clearinghouse report will submit an initial report to Clearinghouse on the first day of each term (fall, winter, spring, summer), followed by submitting reports on the mandatory reporting dates, as given by Clearinghouse. 5. The employee responsible for Clearinghouse reporting and the college’s Financial Aid Coordinator will collaborate before and after each Clearinghouse submission, and once the submission data is reported to NSLDS by Clearinghouse, the Financial Aid Coordinator will review all withdrawn students to confirm their NSLDS status is correct. If not, she will manually update the student’s NSLDS status to ensure accuracy. Anticipated Completion Date/Date Completed: November 6, 2025

Special Tests and Provisions: Enrollment Reporting – Federal Direct Student Loan Program, Assistance Listing Number 84.268; June 30, 2025 Award Year; U.S. Department of Education Condition Enrollment information, including the effective date of separation from the institution, must be accurately reported to NSLDS within 30 days whenever attendance changes for a student, unless a roster will be submitted within 60 days. May 2025 graduates were reported to NSLDS outside of the maximum 60-day window. Corrective Actions Ellucian has since released a patch to address the known defect, and it has been successfully deployed by the University. Additionally, the University will continue to monitor subsequent submissions to NSC where errors were initially noted, to ensure status changes have been transmitted by the NSC in a timely manner to NSLDS. Responsible Official: Taylor Horner, University Registrar Completion Date: August 2025

Finding 2025-001: Missing Proof of Loan Exit Counseling – the auditor tested thirty-seven files, of which all were Federal Direct Loan recipients, and proof of loan exit counseling was missing for one student. As the Institution has since provided the missing exit counseling to the student, it is recommended the Institution improve control over exit interviews. Comments on Finding and Recommendation(s): It is agreed that MSP originally missed providing Direct Loan exit counseling for the 1 student found in testing. The student did not graduate or withdraw, but simply did not return for a following semester. This was an oversight in existing procedures as we were not actively looking for this population of students previously. Actions Taken or Planned: MSP immediately revised the monthly enrollment reporting process such that the initial report for each semester now includes queries to look for students who were enrolled in the prior semester, but have not returned. They will be sent Direct Loan exit counseling requirement information and an email with a URL link to complete the process at StudentAid.gov. In addition, in cases that the registrar becomes aware that a student will not return, they will share that information with Financial Aid.