Corrective Action Plans

Department of Education – Direct Programs ALN # 84.268, 84.063, 84.007, 84.033 Student Financial Assistance Cluster – Special Tests and Provision – Disbursement on Behalf of Students Finding Summary: Two students were identified who were not awarded the full amount of Pell for which they were qualified. Both students were registered in the summer session. Responsible Individual: Director of Financial Aid Corrective Action Plan: The College will implement a control process to ensure all semesters are properly identified and taken into account when creating a financial aid package for students. An evaluation will be done to ensure that no students who are eligible for Pell are precluded from receiving it. Anticipated Completion Date: Spring 2026

Department of Education – Direct Programs ALN # 84.268, 84.063, 84.007, 84.033 Student Financial Assistance Cluster – Special Tests and Provision – NSLDS Reporting Finding Summary: During review of student statuses on NSLDS, 3 students were noted with a status of “no record found”, and 18 students where the status change was not submitted within the required timeframe established by DOE. Responsible Individuals: Director of Financial Aid and Registrar Corrective Action Plan: The College is coordinating efforts between the Office of Financial Aid and the Registrar’s Office to ensure that timely and accurate reporting of student status is made to NSLDS. Anticipated Completion Date: Spring 2026

Department of Education – Direct Programs ALN # 84.268, 84.063, 84.007, 84.033 Student Financial Assistance Cluster – Special Tests and Provision – Disbursement on Behalf of Students Finding Summary: School is required to provide specific and timely notification when direct loans are being credited to a student’s account. During the review of the direct loans disbursed to students, it was noted that notifications were not sent to students and parents as required. Responsible Individual: Director of Financial Aid Corrective Action Plan: The College is aware of the requirement and the timing of the notification. The College will create a control process to ensure proper notification of loans is sent as required. Anticipated Completion Date: Fall 2025

Department of Education – Direct Programs ALN # 84.268, 84.063, 84.007, 84.033 Student Financial Assistance Cluster – Special Tests and Provision – Disbursement on Behalf of Students Finding Summary: During the review of the calculation of student disbursements, a student was noted whose awards exceed the unmet needs. This over award that was created was in the form of non-Title IV scholarships. Responsible Individual: Director of Financial Aid Corrective Action Plan: The Office of Financial Aid is refining and validating the process for monitoring unmet need and potential over-awarding. The College will put extra effort on ensuring that this situation does not re-occur and ensure that all staff are following the established process to evaluate unmet need. Anticipated Completion Date: Fall 2025

Federal Agency Name: Department of Education – Direct Programs ALN #84.268, 84.063, 84.007, 84.033 Student Financial Assistance Cluster – Special Tests and Provisions – Returns to Title IV Finding Summary: During the review of the return to Title IV funds, there were eleven instances out of thirty in which the Title IV funds to be returned were not calculated and returned if required within the 45-day maximum timeframe allowed. The R2T4 calculations for fall 2024 were not performed until February 2025. Responsible Individual(s): Director of Financial Aid Corrective Action Plan: This finding was due to the turnover of key personnel in the financial aid office during the academic year. Staffing in the office is currently stable and properly trained on regulations and the timing requirements and calculation of Return to Title IV. College is developing and refining a process to review and return Title IV funds in a timely manner. The calculations for subsequent semesters have been made in a timely manner. Anticipated Completion Date: Fall 2025

The independent auditor identified certain concerns as set forth in the SFA Enrollment Reporting Control Deficiency, dated June 30, 2025. All concerns appear to relate to mid-semester withdrawals of students; all will be resolved by the continued implementation of previous corrective action plan (CAP) and the facilitation of the additional plan details set forth herein. As background to these issues, Eastern Wyoming College (EWC) experienced unique circumstances related to the transmission of student information as a result of its status on Heightened Cash Monitoring (HCM2). Simply, the systems in place between the college, the federal government, and a third-party vendor did not communicate accurately, principally due to timing issues of student information and EWC's requests for reimbursement of financial aid. In the previous audit (2023-24), these types of issues were identified and remedied through EWC's corrective action plan. At that time, EWC committed to manually updating the Clearinghouse/NSLDS systems to ensure timely enrollment reporting. This effort was put in motion beginning in October 2024. EWC submits the concerns identified in the latest report were largely being corrected by the previous plan and the resolution of the timing issues due to EWC's move from HCM2 to HCM1 statuses. As part of EWC's continued effort, it is worthwhile to note additional information, issues and resolutions. Enrollment reporting at EWC has been historically managed by the Data Analyst. This singular reporting has allowed data to be reported consistently and efficiently. However, because the analyst does not work in either the Registrar or Financial Aid Offices, the reporting has not been able to adeptly identify and address unusual cases. The current reporting structure requires additional review and oversight. Therefore, as part of corrective actions, the Registrar or designee will manage enrollment statuses for all mid-semester college withdrawals. The Registrar is in the best position see the student's enrollment and to identify the accurate dates. The Registrar will be the final decision maker regarding the reporting of information. In addition, the Financial Aid Office, as part of their R2T4 calculation checklist when an official withdrawal form exists, will ensure that any completed courses from Block A do not impact the student's reported status of withdrawn. The Financial Aid Director, either as part of the initial calculation or the follow-up internal audit, will confirm whether any credits are earned prior to a student's withdrawal. Further, the director will ensure that any withdrawal is separately reported because current, standard reporting may not identify this status change. Delayed reporting as noted in the associated finding, will no longer be an issue now that all systems are aligned following the college's move from HCM2 to HCM1 status. This allows National Student Loan Data System (NSLDS) to be notified of awarded aid, which will then allow the National Student Clearinghouse to effectively report all students, as required. In addition to the systems working as designed, EWC will conduct an internal audit each semester and will review students who withdrew during the term to ensure that all systems were updated correctly, and all offices reported accurate dates. In addition, all offices involved will create a collective Standard Operating Procedure manual related to enrollment reporting in addition to each office's separately documented procedures. Anticipated Completion Date: September 2025 Contact Person: Rebecca McAllister/Xi Feng/Dave Bluemel

2025-002 Significant Deficiency over Activities Allowed and Unallowed and Allowable Costs/Cost Principles The auditors recommend that the County implements a review control over weekly timesheets to ensure the timesheets include all program time coded on the day sheets. NCDHHS policy requires program salaries to be allocated and supported by payroll and attendance records for individuals. There is no disagreement with this audit finding. Annual day sheet training is now required for all staff that submit day sheets. Additionally, all new hires are required to complete day sheet training prior to submitting their first entry. A PowerBI dashboard has been created and released in June 2025 to pull data from both Workday (the County’s system of record) and our daysheet system, ISSI that provides supervisors the ability to show discrepancies between entries in real time. The County will also conduct random reviews monthly. Any discrepancies identified will be provided to staff leadership for support and correction. Additional reviews will be conducted for those staff with identified errors until released by leadership. Semi-annual reports will be provided to HHS Senior Leadership members to show trends and compliance with day sheet and timesheet entries. These reports will be created in December and June of each year. Person responsible for correction action: Leigh Anderson, HHS Business Administrator Completion date: The County has already implemented these changes.

The Director of Financial Aid will review the dates reported to COD at the end of each semester. The current software is set up where manual adjustments to amounts and dates reported to COD are required, the transition to new software should automate part of this process.

Response: According to the student sampling conducted as part of the audit, several withdrawal records were reported incorrectly. The source of the inconsistencies was unknown at the time of notification by the auditors. However, progress had been made since the 2023-24 audit when little to no withdrawal records were being reported correctly. The purpose of this report submitted to NSLDS through NSC, is to notify lenders of students who have dropped below half time status and therefore should be entering their six month grace period prior to loan repayment. All students are included in the withdrawal report, regardless of whether they have a loan with Vernon College or any other institution. It is important to note, internal records are accurate and loan processes are in compliance. Vernon College is pleased to report that recently the Registrar’s Office has discovered the source of the withdrawal reporting errors and has implemented a solution. The source and subsequent solution involve entering certain dates in designated areas in our student information system, Colleague. If errors occur in the future, the Registrar’s Office has developed a backup manual review process to use to ensure reporting will remain consistent and correct. The Registrar’s Office will run an “Enrollment Activity Report” to identify all course withdrawals within a designated time period as outlined by the NSC First of Term and Subsequent Term reports. The reporting official will then audit the Colleague produced NSC report against the Enrollment Activity Report to ensure accuracy and update manually as needed. This will occur prior to submission to the NSC/NSLDS. Moving forward, the manual process will only be used if needed.

This Repeat Finding has been acknowledged. Union has taken several steps towards making the required changes to ensure compliance with our enrollment reporting responsibilities. This includes implementing process improvements related to our National Clearing House (NSC) submissions and reviewing our academic policies related to academic leaves of absence and withdrawals. Timeliness of Enrollment Reporting Rosters: As of January 2024, Union completed the setup and configuration of our enrollment reporting services with NSC as our third-party service provider. The new process is administered by the school Registrar, with back-up responsibilities handled by the Assistant Dean, Director of Financial Aid, and the Vice President of Admissions and Views of Responsible Officials: This Repeat Finding has been acknowledged. Union’s Academic Office is in the late stages of implementing a multi-year action plan to implement the required system, policy, and procedural changes to ensure compliance with all enrollment reporting regulations. As of January 2024, Union completed our migration to the National Clearinghouse (NSC) as our third service provider for enrollment reporting services. We have already experienced a strong positive impact on the timeliness of our enrollment reporting. For example, we have fully addressed the timeliness of our NSLDS Roster response, which is due within 15 days. This year’s testing sample yielded zero (0) errors, demonstrating our ability to successfully address enrollment reporting issues. The steps outlined below will allow us to address the enrollment reporting issue identified in this year’s testing sample. Earlier this academic year, Union revised both our Academic Leave of Absence and Term Withdrawal policies to ensure alignment with our compliance obligations. Due to these changes, Union has already noted a reduction in reporting errors and inconsistencies. The FY25 Single Audit finding is related to the reporting of withdrawal/dismissal actions that took place in summer, a non-required term for students in our programs. Our corrective action will be to: (1) further modify our policies and procedures to specifically address non-required and interim terms; and (2) increase the number of batch enrollment updates to NSC/NSLDS during non-required terms to ensure that all summer withdrawals are communicated within 60 days.

Enforce the organization's R2T4 refund calculation proceedures

All graduate and withdrawn student files will be reviewed on a monthly basis to verify any status changes are reported to NSLDS within regulatory timeframes. Training and professional development will be required for responsible staff to ensure a compliance schedule is developed. Personnel will be evaluated to ensure existing policies, procedures, and processes are followed and supported through corrective action where needed.

When processing unofficial withdrawals through the R2T4 process, an additional step to the withdrawal process has been added. Financial Aid staff will use the NSLDS Enrollment History Update feature to submit the unofficial withdrawal date directly to NSLDS. This ensures that the date has been reported to NSLDS avoiding any potential that the student being reported has missed the regular NSC enrollment reporting rosters.

Condition: For one student, the School District used an incorrect number of days attended in the return to Title IV calculation, resulting in an inaccurate refund amount. Planned Corrective Action: We have conducted on-going training, created R2T4 Quick References, Term Calendar Calculators, R2T4 Decision Trees as well as other tools to assist R2T4 team members. These are supplemental to the body of regulations related to R2T4 found in the Student Aid Handbook. We will also perform and document a sample-based review of R2T4 calculations on a semester by semester basis. Contact person responsible for corrective action: Adrian Robson, Director of Financial Aid Anticipated Completion Date: 11/01/2025

Western Wyoming Community College experienced an unexpected turnover in the Director position and had a consultant from Dynamic Campus and an Interim Director of Financial Aid step in to help assist staff during this time. Due to lack of communication, reporting of a return of Title IV funds for the one student found in the audit did not occur as it normally would. Corrective Action A new Director of Financial Aid has been hired and has worked with the Assistant Director of Financial Aid to train on the process of Return to Title IV and timely reporting. • Each day the total withdrawal list is checked to determine the students who are receiving federal aid and may need to have a Return of Title IV calculation performed. • The students who are determined to require a Return of Title IV calculation are then processed for the Return of Title IV funds. This process is completed by the Assistant Director or Director of Financial Aid. • Once the process is complete and funds have been adjusted appropriately the Assistant Director or Director of Financial immediately run the process to export the files and funds out to the Common Origination and Disbursement (COD). • The next day COD is checked to ensure no reject(s) of the file(s) have occurred. If there are errors/rejects of the file the issue is researched and fixed to be accepted by COD. This process will ensure the timely reporting and return of funds to the Department of Education. Anticipated Completion Date: October 24, 2025 Contact Persons: DeeAnna Archuleta, Director of Financial Aid

Western Wyoming Community College experienced a transition in leadership within the Financial Aid Office, resulting in a change in the Director of Financial Aid position. This transition caused disruptions in communication and process continuity between the Financial Aid, Registrar, and Institutional Effectiveness offices. As a result, inconsistencies were identified in the timing and accuracy of enrollment reporting to the National Student Clearinghouse (NSC) and the National Student Loan Data System (NSLDS). Corrective Action Plan 1. Leadership and Process Realignment a. A new Director of Financial Aid has been appointed and is collaborating with the Institutional Effectiveness Office and the Registrar to define clear processes and timelines for Records & Registration and Financial Aid operations. b. The Director of Financial Aid and Registrar will maintain continuous communication to ensure timely and accurate enrollment reporting and prompt correction of any identified discrepancies. c. The Director of Financial Aid and Registrar will work together to develop a Standard Operating Process (SOP) to ensure if any future attrition occurs in either department that anyone else in those departments will be able to step in and continue processing without interruption ensuring timely and accurate enrollment reporting continues. 2. Implementation of Controls for Third-Party Reporting a. Recognizing the benefits and responsibilities of using the National Student Clearinghouse (NSC) for enrollment reporting, the institution has implemented controls to verify the accuracy of data transmitted through this third-party servicer. b. The Assistant Director (or the Director of Financial Aid in the Assistant Director’s absence) will generate the Summary Return of Funds Report (ROFS) from Colleague each term and provide a copy to the Registrar for enrollment verification and reconciliation. 3. Quarterly Reconciliation and Internal Review a. The Financial Aid Office will conduct a quarterly comparison between Colleague and NSLDS records to ensure consistency of enrollment and status dates. b. Any discrepancies identified will be communicated to the Registrar for prompt resolution. c. Results of the quarterly reviews will be documented and used for internal compliance monitoring and training. 4. Updated End-of-Term Procedure To ensure ongoing accuracy and compliance, the following revised steps will be followed each term: a. The Director or Assistant Director of Financial Aid will run an All F Report after final grades are posted. b. The Director and Assistant Director of Financial Aid will jointly calculate Return to Title IV (R2T4) funds. c. The Return of Funds Report (ROFS) will be provided to the Registrar monthly to verify last date of attendance and withdrawal dates against Colleague records. d. The Registrar will verify subsequent semester enrollments and continuously monitor student enrollment, reporting any changes to Financial Aid leadership. e. The Registrar will submit end-of-term enrollment data to the National Student Clearinghouse as usual, and one week before the next term begins, will submit the end-of-term R2T4 list to prevent overwriting by subsequent semester reporting. 5. Training and Internal Audit Enhancement a. The Financial Aid and Registrar’s Offices will use findings from this audit to develop staff training on identifying and correcting data discrepancies during the quarterly reconciliation process. b. The Director of Financial Aid will review 80% of R2T4 files during each semester for accuracy in reporting and documentation. 6. Graduation Data Accuracy a. The Registrar’s Office utilizes the Update Academic Credentials File (UACF) in Colleague to batch post student degrees and certificates three times per year (end of spring, summer, and fall terms). b. It was determined that the automatic graduation date populates correctly only when students have a single program with no changes. For students with multiple programs or program changes, the graduation date must be entered manually to ensure accuracy. c. The Registrar will oversee the upload of graduates and verification of accurate credential dates, ensuring these dates are correctly reflected in NSC and the Director or Assistant Director of Financial Aid will make sure the dates are correctly reflected in the NSLDS system. d. The Registrar and Director of Financial Aid will conduct joint reviews to verify that all graduation and enrollment data are reported correctly. Anticipated Completion Date: June 30, 2026 Contact Persons: DeeAnna Archuleta, Director of Financial Aid, and Kayla Miller, Registrar

Western Wyoming Community College experienced unexpected turnover in the Director of Financial Aid position, which impacted financial aid reporting and reconciliation processes. Due to access issues with federal systems required for conducting reconciliations and the departure of a consultant who did not retain documentation for completed reconciliations, no reconciliations were available for review for the 2024/2025 Academic Year and 2025 Fiscal Year. Corrective Action Plan 1. Staffing and Training a. A new Director of Financial Aid has been hired and has completed training on the reconciliation process for both Pell Grants and Direct Loans in collaboration with the Assistant Director of Financial Aid. b. Cross-training has been implemented to ensure continuity of operations in the event of future staff turnover. 2. Establishment of Standard Operating Procedures (SOP) a. The Financial Aid Office has worked with the Business/Bursar’s Office to develop and document a Standard Operating Procedure (SOP) governing: • The drawdown of Title IV funds. • The reconciliation process for Pell and Direct Loan programs. b. The SOP outlines responsible parties, required documentation, and timelines for reconciliation and reporting. 3. Monthly Reconciliation Schedule a. A reconciliation schedule has been established requiring completion of Pell and Direct Loan reconciliations by the 15th of each month, or as soon thereafter as federal reports become available. b. Once reconciliations are confirmed as accurate and complete with the Business/Bursar’s Office, drawdowns of funds will occur on or near the 15th of each month, depending on calendar dates and federal system availability. 4. Compliance Alignment a. This process ensures timely and accurate reconciliation of Pell Grant and Direct Loan funding in accordance with 34 CFR 685.300(b)(5) and related federal cash management requirements. Anticipated Completion Date: November 15, 2025 Contact Persons: DeeAnna Archuleta, Director of Financial Aid, Assistant Director of Financial Aid, Business/Bursar’s Office

Western Wyoming Community College experienced an unexpected turnover in the Director position which impacted the timeliness of reporting. Corrective Action A new Director of Financial Aid has been hired and has worked with the Assistant Director of Financial Aid to train on the process of reporting to COD within the 15 day period after disbursing federal aid. • Any available funds are disbursed each Monday throughout the semester, except for when a holiday falls on a Monday. Funds are then disbursed on the next working business day. • The process to export these disbursements to the Department of Education are performed the same day or the following day after the Business office has ran the transmittal process. This process is completed by the Assistant Director or Director of Financial Aid. • Once the process is complete and funds have been exported to the Department of Education through the Common Origination and Disbursement (COD) portal the Assistant Director or Director of Financial will to ensure no reject(s) of the file(s) have occurred. If there are errors/rejects of the file the issue is researched and fixed until accepted by COD. This process will ensure the timely reporting to the Department of Education. Anticipated Completion Date: October 24, 2025 Contact Persons: DeeAnna Archuleta, Director of Financial Aid

Condition During our testing over direct loan disbursement notifications, we found that for twenty out of twenty students tested, City Colleges could not provide evidence that notifications were sent within the required timeframe informing the student, or parent, that a credit will be made to the student’s account for a direct loan disbursement. While City Colleges demonstrated that its system was configured to automatically send notification letters and confirmed that notifications were issued, City Colleges could not provide documentation showing the specific date each notification was sent in relation to the loan disbursement. Cause City Colleges’ system is designed to record the date notifications are sent to students; however, it does not retain a copy of the actual notification content that was transmitted. Corrective Action Taken or Planned City Colleges’ IT team, in collaboration with a consultant, will configure the system to bring all Direct Loan communication letters into the Financial Aid (FA) Status pages. Integrating these letters directly into the FA Status page will ensure they are easily accessible for FA staff. As part of this enhancement, City Colleges will be able to view a timestamp indicating when each communication was sent to the student, as well as view the information required to be communicated by 34 CFR 668.165. Contact Person: Leticia Garcia, District Director of Student Financial Aid Anticipated Completion Date: December 13, 2025

Condition For one out of forty students tested, City Colleges properly recalculated a return of Title IV funds for a student but did not subsequently adjust the student's account to perform the return or notify the student of the adjusted award amount. Cause The lack of return of Title IV funds was an oversight due to human error. Corrective Action Taken or Planned To strengthen internal controls, the District Office assigned an analyst to conduct a review of a random selection of files across all seven colleges scheduled for audit to help identify any discrepancies early and ensure compliance. All R2T4 specialists will receive yearly refresher trainings on R2T4 procedures and controls. Contact Person: Leticia Garcia, District Director of Student Financial Aid Anticipated Completion Date: December 13, 2025

Disbursements to or on Behalf of Students – Credit Balances Corrective Action Plan: We acknowledge and concur with the auditor’s finding. The delay in identifying the credit balance resulted from the manual nature of the account review process. The credit was generated prior to the “go-dark” period associated with the implementation of the new ERP software. During this transition, the system was offline for nearly two weeks, which further contributed to the delay. The refund was issued with the first batch of refunds after the new software became operational. Currently, the refund process within the new ERP system still relies on manual account reviews. At this time, the student information system does not support automated alerts or workflows to assist in identifying Title IV credit balances. In response, the Student Accounts team has conducted a thorough review of the refund process to improve efficiency and ensure compliance with federal regulations regarding the timely disbursement of Title IV credit balance refunds. With support from IT specialists, a new report has been developed to identify Title IV aid posted to student accounts and compare it against allowable charges. This enhancement enables the Student Accounts team to more readily identify credit balances resulting from Title IV aid. Additionally, refunds are now being processed on a weekly basis. These improvements, along with increased monitoring, are expected to significantly reduce the likelihood of future delays in refund processing. Contact Person Responsible for Corrective Action: Carol Summervill, VP for Finance Anticipated Completion Date: Corrective Action was completed as of the date of this report.

Corrective action has been completed. The Institute determined at the start of Academic Year 24-25 that transitioning to a third-party provider of financial aid solutions would be in its best interest. This engagement provides a team of professional financial aid operations and student service specialists, allowing for enhanced loan counseling and processing services, implementing additional checks and balances, and mitigating the potential for errors such as this incident. The error resulting in the finding was actually identified by the third-party provider, following which AFI immediately returned the erroneously awarded federal funds to G5. Individuals responsible for corrective action: Lang Fredrickson, Chief Financial Officer 323.856.8429

2025-001 - Non-Compliance with Timely Student Enrollment Change Submissions to the National Student Loan Data System (NSLDS) Grantor: U.S. Department of Education Cluster Name: Student Financial Assistance Cluster Award Name: Federal Direct Loan Program Award Year: 6/1/2024- 5/31/2025 Award Number: Not applicable Assistance Listing Number: 84.268 Corrective Action Plan The University acknowledges that the graduation reporting date was not adjusted to reflect changes in the academic calendar. This resulted in a compressed timeframe for both the NSC and the University to process and correct student records as needed. To address this, the University will revise its reporting schedule beginning with the Fall 2025 graduation date to ensure that status changes related to graduation are reported promptly. This adjustment will allow the NSC to verify data with the NSLDS and provide the University sufficient time to resolve any discrepancies. Additionally, the University will explore further options to enhance the timeliness of reporting student status changes and will strengthen its reconciliation process to ensure accurate and efficient communication of all status updates. Contact Person: Aida Shadfan, Vice President of Finance and University Controller Aida.shadfan@lmu.edu

Return of Title IV (R2T4) Calculations Planned Corrective Action: SEBTS will take the following steps to address the failure to properly complete R2T4 calculations and returns: We will redefine an FI grade as “Failure due to inactivity” in the Faculty Handbook and Academic Catalog. Students will earn an FI if they fail the class due to lack of attendance or participation. The Provost will remind faculty during the final Faculty Meeting of each academic semester about the FI grade. The Registrar’s Office will send an email to all Faculty and Faculty Support Specialists during the last week of classes to remind faculty about assigning an FI to students who failed the course due to inactivity. The Instructional Design Office will inform Faculty Support Specialists about the FI grade during scheduled training meetings throughout the semester. The Adjunct Faculty Support Specialist will inform adjunct faculty during the final week of classes about the FI grade. The Registrar’s Office has updated Self Service, so faculty must enter the last date of attendance/participation if they enter an FI or F grade. The Registrar’s Office will use this to audit and only request further details from faculty who assign an F and indicate that a student stopped attending/participating before the end of the semester. The Learning Activity Report will be adjusted so Academic Advising can send a check-in email after 2 weeks of inactivity, a warning email after 3 weeks of inactivity, and the professor can assign an FI after 4 weeks of inactivity. Person Responsible for Corrective Action Plan: David Phillips, Director, Student Resources & Financial Aid Anticipated Date of Completion: 12/19/2025

2025-001: Exit Counseling Notification Not Performed Timely Student Financial Aid Cluster Assistance Listing Number 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 not sent exit counseling notification within thirty days after the student withdrew. We consider the exit counseling notification not being performed in a timely manner to be an instance of noncompliance with the Eligibility Compliance Requirement. Corrective Action Plan The College has implemented two new procedures that query data to identify financial aid recipients that have withdrawn from classes. The first query identifies new loan borrowers that have dropped below half-time status and the second query identifies previous loan borrowers that have dropped below half-time status. These queries will be run bi-weekly to identify students that must be sent exit counseling notifications within thirty days of withdrawal. Responsible Person for Corrective Action Plan Jeffrey A. Heap, Sr. Director, Financial Services & Controller Deanna Hogan, Director, Financial Aid Implementation Date of Corrective Action Plan October 3, 2025