Corrective Action Plans

The Institution will track R2T4 timeline with all involved to ensure timely completion; finalize system upgrades and testing so that the correct triggers and timelines are within the system; retain qualified staff for key roles; and implement robust training for all personnel.

The Institution implemented proper training and staff placement; enhanced system processing to avoid delays; and will conduct monthly checks on R2T4 processes.

The Institution had assigned personnel to oversee refund processing; implemented an alert system for deadlines; and will conduct monthly refund audits.

The Institution conducted staff training on documentation requirements; develop checklists and call guides; and regular audits of student files.

The Institution enhanced staff training on award calculations; implement system enhancements for enrollment status monitoring; and quarterly reveiws of Federal Pell Grant files.

The Institution had staff training on R2T4 deadlines; ensure proper information is submitted into the system on time; update system to flag missed deadlines; and conduct monthly audits.

Condition: Of the 40 students selected for Return of Title IV (R2T4) testing, 1 student did not have the appropriate amount returned to the federal agency. Planned Corrective Action: To prevent human error from occurring in the future, the Office of Financial Aid has immediately implemented the following process: When a recipient of Title IV grant or loan assistance withdraws from Eastern Michigan University and a Return of Title IV calculation is performed, a Senior Financial Aid Advisor or member of the Financial Aid Management staff will review all required returns completed to ensure accuracy. This review will occur on a weekly basis. Contact person responsible for corrective action: Jennifer Tremewan, Asst. Director Office of Financial Aid Anticipated Completion Date: December 31, 2024

Condition: Of the 40 students selected for enrollment reporting testing, 5 students did not have their status updated appropriately. Planned Corrective Action: The Office of Financial Aid has implemented a process to communicate and confirm with the office responsible for enrollment reporting to verify that enrollment rosters will not be/have not been sent after a semester has officially ended. Contact person responsible for corrective action: Jennifer Tremewan, Asst. Director Office of Financial Aid Anticipated Completion Date: December 31, 2024

Recommendation The College should continue to work with the accounting department and accounting systems to assist its auditor to catch up its financial reporting and records to allow for the completion of future audits. Corrective Action Unfortunately, due to the untimely completion and release of the June 30, 2023 audit report (released on August 8, 2025 - over two years after the end of the June 30, 2023 fiscal year audit), the College did not have the opportunity to review and begin a timely process of addressing a majority of the audit findings until well after the end of the audit period. While the College is committed to corrective action, the delayed delivery of the June 30, 2023 audit limited the ability to implement corrective measures earlier. The College is working proactively to ensure that these issues are resolved going forward. It is important to note that Southeast New Mexico College was a newly established independent community college, having formally separated from New Mexico State University (NMSU) as of April 2022. During this transition period, many administrative processes, including federal grant compliance procedures, were in the process of being developed, transitioned, and implemented independently from NMSU systems. As a result, certain policies, procedures, and documentation processes were not yet fully established or operational at the time of the audit. To ensure timely future submissions, the following corrective actions have been implemented. Revised Timeline and Calendar Controls: • A compliance calendar has been developed and integrated into the Business Office workflow to monitor federal reporting deadlines, including the DCF due date. This calendar includes reminder notifications at 90, 60 and 30 days before the March deadline. Internal Review Process: • A designated compliance officer or fiscal services staff member has been assigned responsibility for tracking the DCF submission process and coordinating with the external auditors to ensure timely receipt of the final audit. Audit Planning Coordination: • Annual audit planning meetings now include a discussion of reporting deadlines, and the contract with the external audit firm will include a clause requiring delivery of the final audit in a timeframe that supports compliance with federal submission timelines. Training and Awareness: • Relevant staff will have completed training in Uniform Guidance reporting requirements, including DCF submission procedures and deadlines to ensure full understanding of the importance of timely compliance. Due of Completion: August 31, 2025 Responsible Party(ies) Vice President for Business and Finance (or appropriate official), Dean of Business and Finance, Director of Finance, Accounts Receivable Coordinator, Business Office Manager

Recommendation We recommend the College strengthen controls to ensure future FISAP reports are submitted timely. Management Response Corrective Action To ensure timely submission of the Fiscal Operations Report and Application to Participate (FISAP) in future reporting cycles, the College will implement the following corrective measures: 1) Establish a Regulatory Compliance Calendar a. A centralized compliance calendar will be developed and maintained by the Business Office in coordination with Financial Aid. The calendar will include all federal and state reporting deadlines, including the FISAP, with automated reminders set at 90, 60, and 30 days prior to each deadline. 2) Formal Assignment of Responsibility a. The Director of Financial Aid will be designated as the primary responsible party for preparation and submission of the FISAP. A secondary backup (Controller or Business Office designee) will be assigned to ensure continuity and oversight. 3) Written Procedures Update a. The Financial Aid Procedures Manual will be updated to include documented steps, internal timelines, required data sources, reconciliation processes, and final submission verification procedures for FISAP completion. 4) Supervisory Review and Certification a. Prior to submission, the Vice President for Business and Finance will receive written confirmation of completion and submission to ensure executive level oversight. 5) Cross-Training a. Annual cross training between Financial Aid and Business Office staff will be conducted to strengthen institutional knowledge and reduce dependency on a single individual. Implementation Timeline: Compliance calendar implemented within 30 days Written procedures updated within 60 days Cross training completed prior to next FISAP cycle Executive review process effective immediately Monitoring Timely submission will be verified annually and documented as part of the College’s internal controls review process. Due of Completion: July 1, 2026 Responsible Party(ies) Vice President for Business and Finance, Dean of Student Affairs

Finding No.: 2024-07- Special Tests and Provisions: Enrollment Reporting Recommendation The College should develop and implement a formal process for monitoring and updating students' enrollment status in the NSLDS to ensure compliance with reporting requirements. Establish internal controls to track changes in enrollment status and ensure timely updates to the NSLDS. Conduct periodic reviews of the enrollment reporting process to identify and address any inaccuracies or delays. Provide training to relevant staff on the importance of compliance with enrollment reporting requirements and the procedures for accurate and timely updates. Response 1. The College will retain the FAO as the lead unit responsible for NSLDS enrollment reporting, in alignment with Title IV compliance functions. However, the College will strengthen interdepartmental collaboration by establishing a formal partnership with the Registrar’s Office, which maintains the official record of enrollment data. 2. A shared workflow and communication protocol between the FAO and Registrar’s Office will be developed to ensure timely, accurate updates of both campus-level and program-level data. The Registrar’s Office will be responsible for updating student enrollment data, which serves as the source data for NSLDS reporting. The FAO will extract and upload these reports via the Enrollment Reporting Roster (ERR) on the NSLDS Professional Access portal. 3. The College will implement internal controls to track and verify changes in student enrollment status, program information, and key data elements. These controls will include but by no means limited to: a. A monthly reconciliation process between SIS data and NSLDS records. b. Use of exception reports to flag and resolve inconsistencies or delays. c. Documentation of all update logs for audit purposes. Periodic reviews will be conducted at least once per term to assess the accuracy and completeness of enrollment reporting. Any discrepancies will be promptly addressed and procedures updated as necessary to prevent recurrence. Relevant staff in both the FAO and Registrar’s Office will receive regular training on NSLDS reporting requirements, including proper use of record types (Campus vs. Program Level), enrollment status codes, and certification timelines. Training will emphasize the implications of noncompliance and best practices for accurate reporting. Training logs will be maintained by both the FAO and Registrar’s Office to support accountability and audit-readiness. Contact: VPEMSS Completion Date: September 30, 2025

Finding 2024-06 - Special Tests and Provisions: Disbursements to or on Behalf of Students Recommendation The College should implement a comprehensive communication strategy to ensure that all students receive clear and timely notifications regarding their Title IV funds. This should include the development of an award letter of college financing plans that outline the amount and type of funds, as well as the disbursement schedule. Additionally, the College should establish a monitoring system to ensure that credit balances are disbursed within the required 14-day time frame to maintain compliance with federal records. Response The College acknowledges the findings and has initiated a process to address them. A formal request has been submitted to the SIS program developer for the implementation of a notification feature. The SIS vendor has confirmed development will be completed by July 1, 2025. This feature will ensure that students receive email notifications when they are awarded and reimbursed for any overpayments. Furthermore, we will establish an enhanced level of monitoring to ensure that credit balances are disbursed within the designated 14-day timeframe. Contact: Comptroller Completion Date: September 30, 2025

Finding 2024-05 - Special Tests and Provisions: Gramm-Leach-Bliley Act-Student Information Security Recommendation The College should develop and implement a comprehensive GLBA information security program that includes risk assessments, safeguards, and regular testing and monitoring of the effectiveness of these safeguards. A qualified individual with the necessary expertise and authority to oversee the GLBA information security program should also be designated. Provide training to relevant staff on GLBA requirements and the importance of information security. Conduct periodic reviews and updates of the information security program to ensure ongoing compliance with GLBA requirements. Response The college acknowledges the finding and will strengthen its student information security by implementing the following: 1. Designate a qualified Information Security Officer from within the IT Division or recruit externally if internal capacity is limited. 2) Develop a GLBA compliance program that includes: • Annual risk assessments • Implementation of administrative, technical, and physical safeguards • Staff training on data privacy • Annual testing of the security protocols Contact: Vice President for Institutional Effectiveness & Quality Assurance (VPIEQA) Completion Date: September 30, 2025

Finding No.: 2024-04 - Special Test and Provisions: Verification Recommendation The College should enhance training programs for staff involved in the verification process to ensure they are fully aware of the requirements and procedures. Establish robust internal controls and review mechanisms to ensure that verification worksheets are completed accurately and consistently with ISIRs. Implement a tracking system to ensure that all required corrections to ISIRs are performed in a timely manner. Response The College acknowledges the audit finding regarding verification errors, including the incorrect application of verification tracking groups, missing documentation, discrepancies between verification worksheets and ISIRs, and failure to make required corrections. In response, the Financial Aid Office (FAO) is committed to strengthening its verification procedures to ensure full compliance with federal regulations and to protect the integrity of Title IV funds. To this end, the College will implement the following corrective actions: 1. Policy and Procedure Enhancement a. The FAO will develop and implement a formal Standard Operating Procedure (SOP) for the verification process, revise and update all existing verification worksheet forms. This SOP will include: • Clear guidelines for identifying and applying the correct verification tracking groups (e.g.,Vl,V4,V5). • Procedures for resolving discrepancies between verification worksheets and ISIRs prior to award disbursement. • Steps for submitting timely and accurate ISIR corrections, as required. • A documentation checklist to ensure all required verification forms and statements of educational purpose are collected and properly stored. 2. Policy and Procedure Enhancement a. To ensure consistent understanding and application of federal verification rules, FAO staff across all campuses will: • Complete mandatory annual training sessions on verification policies, ISIR review, and regularly read updates on the Federal Student Aid (FSA) Knowledge Center. • Participate in internal refresher workshops focused on hands-on case processing and error prevention. • Complete relevant modules from the Federal Student Aid (FSA) training site, including those on verification tracking groups and identity verification requirements. 3. Verification Quality Control Protocol a. The FAO will implement a structured quality control protocol for verification, including: • A two-person verification review system in which one staff member processes the file and another independently reviews it for accuracy and completeness. • Use of a standardized review checklist to ensure all required documents match the ISIR and that any discrepancies are properly resolved and documented. • A log of all verification actions, including corrections submitted to FAFSA Processing System (FPS) and updates made in the student’s file, to support audit readiness. 4. Oversight and Accountability a. The Director of the Financial Aid Office (FAO) will be responsible for overseeing verification compliance and ensuring corrective actions are implemented effectively. This includes: • Monitoring the accuracy of verification tracking group assignments and documentation across all campuses. • Tracking the completion of required training for all FAO staff. • Conducting quarterly file audits to verify ongoing compliance with federal verification standards. • Reporting findings and corrective actions quarterly to the VPEMSS). Contact: VPEMSS Completion Date - September 30, 2025

Finding No.: 2024-03 - Reporting Recommendation The College should establish a systematic process for reviewing and updating the origination records prior to submission to the COD System. Response The College acknowledges the audit finding regarding the use of outdated cost of attendance (COA) figures and the uniform application of full-time enrollment status in COD origination records for the 2022-2023 academic year. In response, the Financial Aid Office (FAO) is committed to strengthening its policies and procedures to ensure accuracy, compliance, and proper stewardship of the Title IV funds. To this end, the College will implement the following corrective actions: 1. Policy and Procedure Enhancement a. The FAO will develop and implement a formal Standard Operating Procedure (SOP) for COD reporting. This SOP will include: • A COA validation checklist to ensure the correct, current-year COA from the approved financial aid handbook is applied. • The college has continuously considered the applicants’ enrollment status (full-time, %-time, half-time, or less-than-half-time) when determining the cost of attendance and awards but publishes only one cost of attendance for full time for the purpose of illustration. Hence, the college will start publishing all COA for all enrollment categories in the student financial aid handbook as a published guideline for awarding • A timeline that aligns record origination with student registration/enrollment confirmation to minimize errors and fully utilize the published Pell Recalculation Date (PRD) in the student financial aid handbook b. The SOP will be reviewed annually. 2. Staff Training and Certification a. FAO staff will participate in mandatory annual internal training and refresher workshops on the EDExpress system, COD reporting procedures, and Title IV compliance. The first round of enhanced training will be completed by August 30, 2025. Staff will also complete Federal Student Aid (FSA) training modules related to COD and verification processes to ensure understanding of federal expectations and system updates. 3. Manual Data Verification Protocol • The Financial Aid Office (FAO) will implement a structured manual data verification protocol to ensure accuracy when transferring information from the Student Information System (SIS) to EDExpress. This protocol will include: Use of pre- submission checklists to verify each student’s cost of attendance (COA), enrollment status, and other required data fields against the official records in the SIS. • Designated FAO staff will perform a two-tiered review process, where one staff member enters data and another independently verifies accuracy prior to COD submission. • Maintenance of record logs for each batch of COD submissions, documenting the review steps taken and any discrepancies corrected before submission. 4. Oversight and Accountability a. The Director of the Financial Aid Office (FAO) will be responsible for monitoring adherence to COD reporting requirements to ensure accuracy and compliance. This includes tracking staff training completion related to EDExpress and Title IV regulations, conducting quarterly internal reviews of origination and disbursement records, and verifying the correct use of current cost of attendance figures and enrollment status classifications. The Director will document findings, implement corrective actions as needed, and provide quarterly progress reports to the Vice President for Enrollment Management and Student Services (VPEMSS). Contact: VPEMSS Completion Date: September 30, 2025

JFS is in the process of hiring a new Chief Financial Officer (CFO) with pertinent experience for non-profits, governments, and billing. That person will lead the finance team to ensure best accounting and internal control practices are implemented and followed. During 2025, JFS strengthened its governance and internal control environment by implementing a centralized system for tracking all grant-related data in a single, secure location. All grant documentation is now maintained electronically within the organization’s OneDrive system, improving record retention, transparency, and audit readiness. The Finance Department established regular internal finance meetings, in addition to standing leadership meetings, to promote consistent communication, segregation of duties, and oversight across the finance function. Management continues to provide the Finance Committee of the Board with monthly financial reports; supporting ongoing fiscal monitoring and informed decision-making.

We concur with this finding. The County of York has hired a Human Services Director of Finance to assist with improving systems and financial processes within the Human Services (HS) divisions. The HS Executive Director and Director of Finance are recommending engaging an expert Consultant to assist the County’s Children & Youth Fiscal team in getting caught up on internal system timelines, as well as delayed reporting. The Consulting company will also be working to adequately train the Children & Youth Fiscal team for development purposes.

We concur with this finding. Children, Youth and Families will explore ways to better track the State Fiscal Year and County’s Calendar Year side-by-side. The Children & Youth Fiscal team will work with the Director of Finance to implement reconciliation processes and will prioritize timeliness of reporting.

Federal Agency: Various Federal Program Name: Extension Services at 1890 Colleges, Scholarships for Students at 1890 Institutions, Education Stabilization Fund, Federal Supplemental Educational Opportunity Grant Program, Federal Pell Grant Program; Federal Direct Student Loans; Federal Work Study Program; Federal Perkins Loan Program Assistance Listing No.: Various Recommendation: We recommend the University implement and maintain an effective system of internal controls over timely submission of the single audit reporting package. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: As a result of staffing turnover in the Finance area, the University engaged consulting support to assist in readying for financial statement preparation and the audit of fiscal years ending 6.30.23 and 6.30.24, with oversight from the University management. The University has developed a fiscal year-end close process that includes submission of the single audit report. Name(s) of the contact person(s) responsible for corrective action: Melissa Hicks, Controller Planned completion date for corrective action plan: Complete

Federal Agency: US Department of Education Federal Program Name: Federal Perkins Loan Program Assistance Listing No.: 84.038 Recommendation: We recommend reviewing procedures around Perkins Loan Program funds and implementing reconciliations and review to the third-party servicer reports. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The university has implemented policies and procedures regarding reconciliations for Perkins loan services managed by a 3rd party supplier. Name(s) of the contact person(s) responsible for corrective action: Danyel Tolbert, Bursar Planned completion date for corrective action plan: Complete

Federal Agency: US Department of Education Federal Program Name: Federal Perkins Loan Program Assistance Listing No.: 84.038 Recommendation: We recommend reviewing procedures and requirements regarding Perkins third-party service providers to ensure compliance with regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The university has implemented policies and procedures regarding reconciliations for Perkins loan services managed by a 3rd party supplier. Name(s) of the contact person(s) responsible for corrective action: Danyel Tolbert, Bursar Planned completion date for corrective action plan: Complete

Federal Agency: US Department of Education Federal Program Name: Federal Direct Student Loans Assistance Listing No.: 84.268 Recommendation: We recommend management maintain proper recordkeeping and retention of documentation and review of such documentation. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University implemented new procedures related to reconciling drawdown requests and approvals in FY25. The Director of Financial Aid meets monthly with Finance and Grants Accounting to review reconciliations. Finance now submits drawdown requests to the CFO for prior-approval and documentation is maintained in the Accounting department. Name(s) of the contact person(s) responsible for corrective action: Melissa Hicks, Controller Planned completion date for corrective action plan: Complete

Federal Agency: US Department of Education Federal Program Name: Federal Pell Grant Program; Federal Direct Student Loans Assistance Listing No.: 84.063; 84.268 Recommendation: We recommend the University evaluate its procedures and review policies in overseeing submissions to the NSLDS completed by the third-party servicer. Additionally, we recommend the University review its policies and procedures on reporting enrollment information to the NSLDS to ensure that all relevant information is being captured and reporting timely in accordance with applicable regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University will resolve issues within 10 days of receiving notification. Name(s) of the contact person(s) responsible for corrective action: Yolanda Benson, Registrar Planned completion date for corrective action plan: July 1, 2026

Federal Agency: US Department of Education Federal Program Name: Federal Supplemental Educational Opportunity Grant Program, Federal Pell Grant Program; Federal Student Loans; Federal Work Study Program Assistance Listing No.: 84.007; 84.063; 84.268; 84.033 Recommendation: We recommend the calculation logic be reviewed and corrected to align with approved methodology. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: In FY25, the University began utilizing Banner to perform calculations to ensure alignment with federal methodology. The Financial Aid office also began monitoring calculations on a monthly basis. Going forward, the University will verify registrar withdrawal dates are consistent and ensure that academic attendance records are captured correctly. The University will work with faculty to confirm the last date of attendance for unofficial withdrawals. Name(s) of the contact person(s) responsible for corrective action: Dr. Michael Dailey, Provost; Varah Barnett, Director of Financial Aid; and Yolanda Benson, Registrar. Planned completion date for corrective action plan: July 1, 2026

Federal Agency: US Department of Education Federal Program Name: Federal Perkins Loan Program Assistance Listing No.: 84.038 Recommendation: We recommend that the University keep MPNs for loans for three-year retention period. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University will review its files and take steps to ensure that files are complete with respect to MPNs. Name(s) of the contact person(s) responsible for corrective action: Danyel Tolbert, Bursar and Melissa Hicks, Controller Planned completion date for corrective action plan: March 31, 2026