Corrective Action Plans

Corrective Action Plan 1. Implement Automated Notifications (New and Long-Term Solutions) The institution will establish a two-phase approach to ensure timely and compliant Title IV disbursement notifications. New Process: A weekly report will be generated for Title IV loan disbursements with the corresponding notifications sent to students. Financial aid staff will review the report to confirm that each required notification was issued within the regulatory timeframe. Any missing notifications will be immediately sent and documented. This interim process will remain in effect until full automation is implemented. Long-Term Automated Solution: The student information system will be configured to automatically generate and send Title IV disbursement notifications to students. Each notification will be sent no earlier than 30 days before, and no later than 30 days after, the crediting of Title IV loan funds to the student’s ledger account, as required by 34 CFR §668.165(a)(2). The system will also store a timestamped record of each notification in the student’s electronic file for audit and compliance verification. 2. Develop Written Procedures A formal institutional policy and procedural guide will be developed to define the timing, content, and method of Title IV disbursement notifications. This documentation will explicitly address regulatory requirements under 34 CFR §668.165(a) and outline staff responsibilities for monitoring and documentation. 3. Staff Training Financial Aid staff will receive training on the new automated notification process, including policy updates, system functionality, and documentation requirements. Completion of training will be tracked to ensure all relevant personnel are fully informed and able to implement the new procedures consistently. 4. Periodic Compliance Reviews Quarterly internal audits will be conducted to confirm that required notifications are being issued as scheduled and properly documented in each student’s record. Any discrepancies identified will result in immediate corrective measures and additional staff coaching as needed. Responsible Party Director of Financial Aid Timeline for Completion - New System Implementation: Immediate - Long-Term Solution: Work with software provider and IT for options to implement this process - Policy Documentation & Staff Training: Within 90 days - First Compliance Review: Within 90 days

Management concurs with the auditor's finding. The noncompliance resulted from a communication breakdown between the College and its third-party financial aid processing company, FAME, Inc. When William R. Moore College of Technology (the College) was placed under Heightened Cash Monitoring 1 (HCMl), staff did not immediately notify FAME of the status change. Had FAME been informed, the company would have updated the system configuration to restrict drawdowns until all credit balances were determined and paid. Although this was a communication lapse, the College did follow through on all U.S. Department of Educationdirectives related to financialresponsibility and provisional certification. Specifically, the College obtained and maintained the required Irrevocable Standby Letter of Credit (LOC) each time it was instructed to do so and amended the LOC amount in subsequent years as required by the Department. To correct this issue and ensure full compliance with federal cash-management regulations, the College has implemented the following actions: Notification Protocol and Financial Protection Requirements Before notifying FAME of any change in payment method (placement under or release from HCMl), the College must verify compliance with the Department of Education's Provisional Certification Alternative requirements under 34 C.F.R. § 668.l?S{f). The institution must submit an Irrevocable Standby Letter of Credit (LOC) or cash surety equal to 10% of the most recently completed fiscal year's Title IV funding. The College has complied with this requirement by obtaining and maintaining the LOC as directed and by amending the LOC amount ea'ch time the Department requested an updated financial protection amount. The LOC ensures funds are available to make refunds, provide teach-out facilities, and meet institutional obligations should the College close or terminate classes prematurely. The CFO confirms acceptance of the LOC by the Department before formally notifying FAME of any payment method change (HCMl, HCM2, or release). System Configuration Controls Once notified, FAME has confirmed that the system includes a compliance flag preventing drawdowns prior to disbursement while the College operates under HCMl. This configuration ensures that all Title IV reimbursements occur only after funds have been properly disbursed to students. Staff Training and Awareness Internal financial aid and accounting staff will participate in refresher training with FAME in Spring 2026. The training will cover: Title IV cash-management rules Communication and notification protocols Credit-balance determination and documentation standards Documentation and Oversight A written Title IV Reimbursement Checklist and Approval Workflow has been incorporated into the College's HCMl reimbursement process. The Financial Aid Counselor verifies completion of all disbursement and documentation steps prior to reimbursement. The CFO provides final authorization for each GS drawdown. 5. Monitoring and Continuous Improvement The College conducts quarterly internal reviews of Title IV drawdowns, reconciliations, and reimbursement documentation to confirm ongoing compliance. All findings are shared with FAME to maintain consistent alignment between systems and audit documentation. Anticipated Completion Date: All corrective actions were implemented by October 31, 2025; additional staff training is scheduled for Spring 2026. Status: As of June 30, 2025, the College is no longer operating under Heightened Cash Monitoring 1 (HCMl) and has returned to the standard payment method. However, corrective actions have been implemented; continued monitoring and staff training are in progress. Views of Responsible Official Management agrees with the finding. The noncompliance occurred due to a communication lapse between the College and its third-party processor, FAME, regarding requirements under the Heightened Cash Monitoring 1 (HCMl) payment method. In response, the College has updated its Title IV cash-management policies and procedures to ensure full compliance with federal regulations and the terms of its Provisional Certification Alternative under 34 C.F.R. § 668.175(f). Corrective actions include the submission and amendment of the Irrevocable Standby Letter of Credit, implementation of enhanced notification and verification procedures before alerting FAME of any payment-method changes, and establishment of quarterly internal reviews to confirm ongoing compliance with cash management and financial protection requirements.

Program Name: Federal Direct Student Loan Program AL# and Program Expenditure: 84.268 ($797,519) Award Number: P268K257533 Federal Award Year: July 1, 2024 to June 30, 2025 Questioned Costs: $-0- Condition Found: A Federal Direct Loan exit interview was not completed by, nor were instructions sent to, students on how to complete an exit interview when the students graduated from the College or dropped below a halftime enrollment status. This was applicable for two of the nine students selected for testing that received Federal Direct Loan funds. Corrective Action Plan: Federal Direct Loan exit interview information was sent to one of the students in question in August 2025 and the second student in question in September 2025. Procedures will be improved to ensure Federal Direct Loan exit interviews are completed or information is sent to students when they cease enrollment at the College. Anticipated Completion Date: The corrective action was completed in August 2025 and September 2025. Contact Person: Stephanie Dickerson, Registrar/Financial Aid

Program Name: Federal Direct Student Loan Program AL# and Program Expenditure: 84.268 ($797,519) Award Number: P268K257533 Federal Award Year: July 1, 2024 to June 30, 2025 Questioned Costs: $-0- Condition Found: The incorrect withdrawal date was reported to the National Student Loan Database System (“NSLDS”) for four of the nine students selected for testing that received Federal Direct Student Loans. Corrective Action Plan: Management agrees with the auditors’ finding and their recommendation. The Financial Aid Director updated the enrollment status for the students in question in December 2025. Procedures will be improved to ensure that a student’s enrollment status is updated timely and with the correct date of the change. Anticipated Completion Date: The corrective action was completed in December 2025. Contact Person: Stephanie Dickerson, Registrar/Financial Aid 910-323-5614

Name of Responsible Individual: Matt Cooper, Student Financial Services Corrective Action: To strengthen compliance and ensure the accuracy of student aid eligibility determinations, we will enhance Liberty’s quality control (QC) measures within the federal verification process. Our primary goal is to minimize errors, improve consistency, and ensure all Financial Aid verification activities align with federal regulations and institutional policy. We will begin by implementing a more targeted QC process aimed at validating records of students who submitted subsequent tax documents. We will increase our verification QC selections of this particular population from 35% (current) to 60% (future) to verify data accuracy, documentation completeness, and adherence to ED’s Application and Verification Guide (AVG). Findings from these reviews will be used to identify training needs and process improvements. Staff training will be expanded to focus on federal verification requirements, common error trends, and documentation standards. Refresher trainings will be held with the entire verification processing team, and supplemental individual coaching will be provided on a monthly basis to address any specific issues identified through QC. We will also create reporting to ensure the percentage of reviews mentioned above is maintained by our QC workflow. Regular data analysis will help identify any systemic issues early, allowing for corrective actions to mitigate any compliance issues. By reinforcing staff training, system monitoring, and increased reviews, we will ensure that our federal verification process remains accurate, compliant, and student-centered. Anticipated Completion Date: February 2026

Name of Responsible Individual: Jason Byrd, University Registrar Corrective Action: Liberty University acknowledges that its FY25 single audit identified instances where students’ enrollment reporting was not updated in a timely manner in accordance with U.S. Department of Education (ED) requirements. Liberty has invested significant effort into ensuring its enrollment reporting process is handled compliantly and within alignment with ED’s best practices. Liberty’s Registrar’s Office created a new Director of Clearinghouse Reporting position in May 2024, who is responsible for monitoring Clearinghouse feeds and any associated error reports and works closely with Liberty’s Financial Aid and Information Technology (ADS) offices to ensure enrollment reporting compliance. Liberty has continued the work of developing a more comprehensive quality control (QC) process by reviewing the Clearinghouse Reject report in a timely manner, meeting on a monthly basis with internal stakeholders, and working more closely with Clearinghouse Representatives to identify scenarios where enrollment records are accurately reported to Clearinghouse but never sent on to NSLDS. Liberty University plans to provide Clearinghouse representatives with specific audit cases to identify gaps in enrollment reporting and increase accuracy of individual reviews. Liberty Internal QC Reporting: Liberty University will continue to work quality control and the Clearinghouse Reject report which has enabled the university to be more proactive in its compliance efforts. Additionally, Graduated Dates Prior to Term End, NSLDS MisMatches, NSLDS No Banner SSN, and the NSLDS Record Missing reports will continue to be worked in a timely manner. These reports have been helpful to identify more common/persistent errors/delays and provide an additional layer of quality control checks for Liberty’s enrollment reporting. Accountability Meetings Liberty began holding a series of bi-weekly “Enrollment Reporting Check-In” meetings with key stakeholders from Financial Aid, Registrar, and IT/ADS in February 2024, which are dedicated to discussing current and upcoming enrollment reporting submissions and errors, trends seen with SSCR errors, and brainstorming ways to ensure ongoing compliance. These meetings will continue with a focus on ways to improve reporting logic to prevent errors from occurring. While improvement efforts continue to be underway, Liberty believes these efforts are starting to bear fruit as evidenced by a 99.7% reduction in the number of repeat errors from FY24 to FY25. Finally, Liberty University uses a standard formula for its Program Lengths in order to ensure compliance with other requirements, however certain programs have unique program lengths which may not align with this standard formula for Enrollment Reporting purposes. The Financial Aid Office will work with Registrar and the Provost’s Office, to evaluate any programs which fall outside the standard formula and adjust the published program dates as necessary. Moving forward Liberty will continue to hold monthly meetings with key stakeholders to discuss any enrollment reporting errors and ensure best practices are implemented to ensure ongoing and timely accuracy. The University’s Registrar’s Office will also continue to review the QC reports in an appropriate manner, as well as evaluate the processes for withdrawal/graduated student files. Liberty will continue to review and implement updates as necessary to maintain enrollment reporting compliance and believes these new processes will allow us to be compliant in subsequent years. Anticipated Completion Date: May 2026

Views of Responsible Officials: The Office of the Registrar has continued to struggle with our reporting using the Ellucian product Power Campus. Since Ellucian is sunsetting this product, there have been significant changes in their support due to changes in their staffing. Ellucian employees with more knowledge in NSC reporting have been transferred to their other products, leaving very little knowledge to support our efforts. We are fortunate to work with our current consultant who does seek resources regarding our inability to have a report that works accurately. She has reviewed and rewritten the report. However, according to her support team, they have now admitted that the report will never run correctly using our current version. They have suggested that we upgrade to a different version with corrections but that is impossible currently. With this knowledge, GCU has purchased a new ERP system, Jenzabar, and has begun the implementation process. We are going into Phase 2 of this implementation and expect to go live in Spring 2027. It is our intention to continue to utilize our current Ellucian consultant until that occurs for us to continue to produce the most accurate reporting we can, given these circumstances.

Finding 2025-001: Student Financial Assistance Cluster - Student Eligibility/Special Test and Provisions Federal Agency: U.S. Department of Education Program: Student Financial Assistance Cluster (84.007, 84.033, 84.063, 84.268) Criteria: In accordance with 34 CFR 668.165 (a), before an institution disburses title IV program funds for any award year, the institution must notify a student of the amount of funds that the student or his or her parent can expect to receive under each title IV program and how and when those funds will be disbursed. Additionally, when Direct Loans are being credited to a student's account, the institution must notify the student, or parent, in writing of the date and amount of disbursement, as well as the timing and process by which a parent may cancel the loan. The notification process is often completed by either an award letter or college financing plan. Controls were not in place to ensure College financing plans were emailed to all required students and/or parents that made the required notifications for Title IV program funds or that notifications were sent to students/parents with required communications regarding Direct Loan awards. Condition: The College notifies students of Title IV Funds by emailing a College Financing Plan to the student and/or parent. The College notifies students of Direct Loan awards and information through email notification via its financial aid system. Controls were not in place to ensure College financing plans that made the required notifications for Title IV program funds were emailed to all required students and/or parents or that notifications were sent to students/parents with required communications regarding Direct Loan awards. Cause: The College does not have a system in place to verify that everyone who received Title IV funding received a College Financing Plan or that all students receiving Direct Loans received required communications. Effect: As sampled, the College did not provide notification via a College Financing Plan of Title IV funding to two of its students as required and potentially could have additional students that did not receive proper notification. The College also did not provide notification of Direct Loan Awards to seven of its students, as sampled, as required and potentially could have additional students that did not receive proper notification. Repeat Finding: This is a repeat finding. Questioned costs: None Recommendation: We recommend that the College implement additional procedures to ensure all students receive notification of Title IV funding and Direct Loans as required under 34 CFR 668.165 (a). View of Responsible Officials and Planned Corrective Action: Management agrees, see separate Corrective Action Plan. Corrective Action Plan: To ensure that all students and their parents are adequately informed of the funds they can expect to receive under each Title IV Program, as well as the timing and process for disbursement, the college will implement the following actions. 1.College Financing Plan Notification: The College implemented a new financial aid management system (Jenzabar Financial Aid) during the fall 2025 semester. This new system allowed the college to create processes to notify students, via email, whenever their financial aid package is completed as well as when changes are made to their Title IV financial aid eligibility. These processes are scheduled to run nightly to ensure that notifications are sent in a timely manner without a staff member having to manually send notifications. Each notification directs students to their secure financial aid portal, where they may access the most current version of their College Financing Plan at any time. This ensures continuous access to accurate information regarding awarded aid and anticipated disbursements. 2.Loan Disbursement Notification: With the implementation of Jenzabar Financial Aid during the Fall 2025 semester the college scheduled email notifications to students when a Direct Loan is disbursed to their account. This notification informs them of their right to cancel the loan if desired. The automated process will ensure that timely notifications are sent. 3.Quarterly Review: The Director of Financial Aid and Executive Director of Finance and Financial Aid will conduct a quarterly review to ensure compliance with these procedures and verify that all necessary notifications are being issued as required.

The institution has implemented a new unofficial withdrawals (UW) policy. This policy defines an unofficial withdrawal as a student who stops attending one or more courses without officially withdrawing. An unofficial withdrawal will be assigned to any student who has consecutively ceased attending a course for three weeks and for whom no evidence of attendance is available at the time of reporting within the specified period. If a student stops attending all their courses, Registrar's Office will inactivate the student and issue a report to the Financial Aid office for an R2T4 calculation. This process will occur on the last instructional day before the final exams, as outlined in the academic calendar. According to the policy, Faculty members submit a report of students who have stopped attending (using an official form) and indicate the last date of academic activity for each student reported as UW. These students are not assigned a grade but rather a "UW." Students who complete the course by continuing to attend but fail to meet the academic requirements receive a grade of "F." In addition, effective March 2025, the Academic Deanship has established an institutional policy for submitting grade records (roll books) at the end of each academic term. Since 2024, some faculty members have participated in a pilot project to adopt the Electronic Gradebook (Rollbook). After adjusting the system, the institution will offer training sessions to all faculty members. By the end of the February-May 2025 term,faculty will submit the required documentation to maintain records of the grades assigned to each student.

U.S. Department of Education 2025-001 Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend Austin Community College District re-evaluate their procedures and review policies surrounding reporting status changes to NSLDS to ensure timely and accurate reporting. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: ACC submitted all student graduates’ status changes to the National Student Clearinghouse (NSC) accurately and in a timely manner, however a number of individual records in the transmitted files were not further reported by NSC to NSLDS in a timely manner. ACC is developing internal controls that include follow-up review of all reported records sent from NSC to the NSLDS system, to ensure 100% accurate and timely reporting. The Enrollment and Records Specialist will review and certify all files and submissions, with a second audit verification of records’ status and timely reporting conducted by the Director of Compliance and Operations. Name(s) of the contact person(s) responsible for corrective action: Annisha Morgan, Director of Enrollment and Records Compliance and Operations Planned completion date for corrective action plan: December 19, 2025. If the Department of Education has questions regarding this plan, please call Linda Terry at 512-223-7503.

The University should correct the enrollment status information in NSLDS for the students noted above. In addition, the University should take steps to ensure that its procedures to accurately submit information to NSLDS are strictly followed

Federal Program - Student Financial Aid Cluster, U.S. Department of Education, Program Year 2025 Criteria or Specific Requirement: Special Tests and Provisions - Return of Title IV Funds Condition: The College did not disburse funds required to be returned to the Department of Education within 45 days. (Material Weakness in Internal Control Over Compliance and Other Instance of Noncompliance). Context: During testing for compliance with Special Test and Provisions - Return of Title IV Funds, 1 out of 6 selections resulted in errors. From a population of 51 students, 6 were selected for testing. Error related to the initial return of funds calculation identifying the amount to be returned being completed incorrectly for a graduate student. The error was identified by the College and the additional amount to be returned was processed, however, this occurred more than 45 days after the graduate student withdrew from the College. Effect: The Return of Title IV funds was not completed within the required 45 days. Cause: The Office of Graduate Studies completed the first Return of Title IV Funds (R2T4) process. Once the Office of Student Financial Services began to manage all financial aid processing (including graduate studies), errors in the calculations were discovered and the Office of Student Financial Services submitted the corrected amount to the Department of Education. Unfortunately, the 45 required day window had lapsed. Name of the Responsible Party: Garnet Tipton, Director of Graduate Student Services Heather Buhr, Executive Director of Student Financial Services Corrective Action Planned: All future R2T4 processes will be conducted by the Office of Student Financial Services and reviewed by one additional staff member in the office before submission to the Department of Education within the required 45 days. Graduate Studies will also be implementing a formal withdrawal/dismissal form that will be sent to the Office of Student Financial Services so there will not be a delay in the notification process. Anticipated Completion Date: Will immediately put these processes into practice.

Auditor Description of Condition and Effect. During our cost of attendance recalculation, we noted that for one student, an additional semester in which the student was not taking any classes was included in their calculation. As a result of this condition, the College overstated the student's financial need for the award year. However, no action was required by the College as the corrected cost of attendance still exceeded the student's awards. Auditor Recommendation. We recommend that the College implement a review process to ensure that all manual entries into the cost of attendance system are reviewed and approved by an independent second individual. Auditor Recommendation. We recommend that the College implement a review process to ensure that all manual entries into the cost of attendance system are reviewed and approved by an independent second individual. Corrective Action. Upon discovery of the cost of attendance calculation error, the College went through and determined that this was an isolated incident and had no impact on the amount of aid received by the student. To prevent a similar problem arising in the future, the College will implement a review process to have a second individual review and ensure the cost of attendance is being calculated accurately. Responsible Person. Michelle McNier, Director of Financial Aid. Anticipated Completion Date. June 30, 2026.

Identifying Number: 2025-002 – U.S. Department of Education Student Financial Assistance Cluster – Special Tests and Provisions: Enrollment Reporting Finding: The College failed to accurately and timely report student status changes to NSLDS for 9 students out of 10 students tested Name of Contact Person: Richard Todd, Registrar and Director of Institutional Effectiveness Corrective Action Plan: In April 2025, the University hired a full-time Registrar whose responsibilities include managing enrollment data, updating student status changes, and correcting deficiencies in enrollment reporting. A formal process was implemented to ensure monthly reporting to the National Student Clearinghouse for NSLDS updates, including the generation and review of weekly reports on enrollment changes such as withdrawals, suspensions, and reduced course loads. Louisburg College is currently registered to submit degree verification files at the end of each semester. The Registrar is the single point of contact for all National Student Clearinghouse submissions. The Registrar re-created files for the fall 2024 and spring 2025 semesters. He also updated all graduates from 2019. A submission schedule has been established with the National Student Clearinghouse to assist with timely reports. Anticipated Completion Date: October 1, 2025

Condition: The School District does not properly review students’ institutional Student Information Records (ISIR) to determine that the student is eligible for federal student financial aid. Planned Corrective Action: The School District has implemented a formal review process to ensure all Institutional Student Information Records (ISIRs) are accurately evaluated for student eligibility prior to awarding federal student aid. Staff have been trained on the new procedures, including resolving required data elements and confirming eligibility criteria. The District has also instituted periodic internal checks to ensure consistent and compliant ISIR review practices moving forward. Contact Person Responsible for corrective action: Almir Hodzic Anticipated Completion Date: October 2025

Condition: The School District relies on two-third party vendors to manage key financial aid systems, including student information, eligibility determinations, disbursement calculations, and reporting. During the audit period, the institution did not perform any oversight activities or testing to verify the integrity, accuracy, or compliance of the systems managed by the vendor. There were no documented controls, service-level agreements, or monitoring procedures in place. Planned Corrective Action: The School District will establish formal oversight procedures for all third-party vendors supporting financial aid functions. This will include developing and maintaining service-level agreements, implementing documented monitoring and testing protocols, and conducting periodic reviews to verify system accuracy, data integrity, and federal compliance. Staff will be trained on these updated processes to ensure ongoing accountability. Contact Person Responsible for corrective action: Almir Hodzic Anticipated Completion Date: June 30, 2026

Condition: The School District is eligible to participate in Title IV federal student aid programs; however, it does not conduct an annual review of its institutional eligibility requirements nor maintain documentation supporting such assessments. Planned Corrective Action: The School District will implement an annual review process to verify its institutional eligibility for participation in Title IV programs. Procedures will include maintaining thorough documentation of all eligibility assessments and required approvals. Staff responsible for compliance will be trained on these updated requirements to ensure accurate and timely completion each year. Contact Person Responsible for corrective action: Almir Hodzic Anticipated Completion Date: June 30, 2026

Condition: The institution does not have a process or controls in place for a timely review of program eligibility, ECAR. Planned Corrective Action: The School District will establish a formal process to ensure timely and documented reviews of program eligibility in accordance with federal requirements. Staff will be trained on the new procedures, and the School District will implement internal controls to monitor program eligibility on a regular schedule. These steps will help ensure ongoing compliance and accurate determinations moving forward. Contact Person Responsible for corrective action: Almir Hodzic Anticipated Completion Date: June 30, 2026

Condition: The institution did not reimburse students with credit balances within 14 days of the balance being posted to their student ledger. Planned Corrective Action: The School District will strengthen its procedures to ensure all student credit balances are identified and refunded within the required 14-day timeframe. Staff will receive training on the updated process, and the District will implement regular monitoring to verify timely issuance of refunds going forward. Contact Person Responsible for corrective action: Almir Hodzic Anticipated Completion Date: June 30, 2026

Condition: The institution’s policy maintains that any unchased check must be returned to the State of Colorado after the financial statement year-end to the Great Colorado Payback program and does not include a carve-out for uncashed Title IV aid checks. Planned Corrective Action: The School District will revise its policy to ensure uncashed Title IV aid checks are returned to the U.S. Department of Education in accordance with federal regulations, rather than to the State of Colorado. The updated policy will include a specific carve-out for Title IV funds, and staff will be trained on the revised procedures to ensure accurate handling and timely returns. Contact Person Responsible for corrective action: Lisa Bollers Anticipated Completion Date: June 30, 2026

Condition: The School District does not calculate or process any post-withdrawal disbursements for students that have withdrawn from the institution. Planned Corrective Action: The School District has implemented procedures to ensure post-withdrawal disbursements are calculated and processed in accordance with federal Return of Title IV (R2T4) requirements. Staff have been trained to identify eligible students, complete the required calculations, and issue timely notifications and disbursements. The School District will also conduct periodic reviews to ensure that all post-withdrawal disbursements are consistently met. Contact Person Responsible for corrective action: Almir Hodzic Anticipated Completion Date: October 2025

Condition: The School District did not report the status changes of certain students to the NSLDS in an accurate and timely manner during the fiscal year. Planned Corrective Action: The School District will update its procedures to ensure all student status changes are reported to NSLDS accurately and within required federal timelines. Staff responsible for reporting will be retrained on the updated process and monitoring requirements. The School District will also implement a periodic internal review to verify the timely and accurate submission of information going forward. Contact Person Responsible for corrective action: Almir Hodzic Anticipated Completion Date: June 30, 2026

Condition: The School District did not utilize the cost of attendance when determining the maximum amount of aid a student is eligible to receive. The School District also does not maintain updated cost of attendance calculations for its programs. Planned Corrective Action: The School District will implement procedures to ensure the cost of attendance (COA) is used when determining each student’s maximum eligible aid in accordance with federal requirements. The District will also develop and maintain updated COA calculations for all programs and review them annually. Staff will be trained on these processes to ensure accurate and compliant aid determinations moving forward. Contact Person Responsible for corrective action: Mary Cooper Anticipated Completion Date: June 30, 2026

Condition: The School Districts awarded aid to students using the full-time, three-quarter time, half-time, etc, schedule and improperly recorded students under a credit program versus appropriately recording them under a clock hour program, for which students would have been considered full-time in their enrollment status if they did not attend less than half-time. Planned Corrective Action: The School District has revised its policies to ensure students in clock-hour programs are correctly classified and awarded according to federal requirements. As a result, we are now awarding full aid to all eligible students based on proper enrollment status determinations. Staff have been retrained on the updated procedures to ensure ongoing compliance. Contact Person Responsible for corrective action: Amy Beruan Anticipated Completion Date: November 2025

Finding – 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 Criteria or Specific Requirement Enrollment information, including the effective date of separation from the institution, must be accurately reported within 30 days whenever attendance changes for a student, unless a roster will be submitted within 60 days. The changes include reductions or increases in attendance levels, withdrawals, graduations, and approved leaves of absence. It is the institution’s responsibility, as a participant in the Title IV aid programs, to monitor and report these changes to the National Student Loan Data System (“NSLDS”). (NSLDS Enrollment Reporting Guide November 2022, and 34 CFR 685.309(b)) Condition Of the twelve students selected for enrollment reporting testing, eleven students within the sample were reported to NSLDS outside the maximum 60-day window. This was not a statistically valid sample. Views of Responsible Officials and Planned Corrective Actions The College concurs with the finding. The College will continue to remain vigilant in its oversight over timely communication of enrollment reporting detail to NSLDS. In both instances, the data we had sent to the National Student Clearinghouse (NSC) was not received by NSLDS in a timely fashion. We will review our reporting schedule and make the appropriate changes to our reporting timeline to ensure the data we report to the NSC is subsequently received by NSLDS within regulations. Names of Contact Person Responsible for Corrective Action: Annette MacMullin, Director of Financial Aid Anticipated Completion Date: September 18, 2025