Corrective Action Plans

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 Cause: Within the University's student information system, PowerCampus, the degree verifier report was not cross referenced with the graduation report. This student was on the degree verifier report but did not appear on graduation report, which is the report that is sent to the National Student Clearinghouse ("NSC") who then transmits information to NSLDS on behalf of the University. Condition: One student was excluded from the report used for the Clearinghouse as a graduated student. As they did not appear on the report twice, the Clearinghouse changed their status to withdrawn. The School then became aware of the change and the graduated status was transmitted to the clearinghouse on 2/7/25 and not received by NSLDS until 7/24/25. Criteria: The 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)) Corrective Action Plan to be Taken: After each graduation period the Registrar’s Office will compare the Degree Verify file against the Graduation Enrollment file as both files are uploaded to the National Student Clearinghouse. The Degree Verify file is generated and uploaded after the Graduation Enrollment file; this process of report comparison will allow us to capture any student not reported in the Graduation Enrollment file. Thereby ensuring all graduating students are reported correctly to the National Student Clearinghouse. We’ll begin this process, on October 3, 2025 with the August 2025 graduates as they were just reported to the National Student Clearinghouse this past month. Sincerely, Linda M. Arce Registrar

Personnel turnover within the Office of the Registrar (July 2023) and the AVP for Academic Affairs (June 2024) led to procedural gaps during these transitions. Some of the proccesses and procedures suffered from a lack of transitional clarity. The Office of the Registrar is responsible for updating the STVMAJR screen in Banner which is a manual process. To rectify this, we have created a streamlined process for updates to the curriculum workflow to ensure precise alignment between Banner and CIP codes. This includes a new monthly meeting between the Registrar, Associate Registrar and AVP to review all curriculum updates, modifications, and new programs to prevent future errors. Issues with the Fall 2024 degree file delayed First of Term processing for Spring 2025. A defect introducted by an Ellucian update affected the degree file output and was resolved by updating the Banner page STVACAT (specifically the NSC Credential Level Translation column). This issue is not expected to recur. Spring 2025 First of Term processing was also delayed due to the manual creation of approximately 200 Social Security Numbers for newly admitted international students following the SLATE implementation and Admissions staffing turnover. This process has since been automated through an update to an Argos generator, eliminating the need for manual SSN creation. In addition, the National Student Clearinghouse transmission schedules were updated to allow additional processing time between files and to avoid submissions during the winter break. Specifically, transmissions for Fall Subsequent of Term were moved from January 1 to January 11, Fall Graduates Only (WS) from January 4 to January 18, and the Fall Degree file from January 14 to January 25.

Corrective Action/Management Response: Ensuring that Adoption records are maintained accurately with all documented requirements. Changing Practice to include putting documents into the document management system (Traverse) in order to have a copy of required documents in the event originals are lost, or documents are damaged due to flooding (which is what occurred in the basement where documents were housed). Cases that are more than 10 years old are typically going to be more difficult to locate needed items, due to records being maintained differently at that time and requirements were different in what the Department was required to maintain in an Adoption file. Proposed Completion Date: June 30, 2026 checking monthly to ensure paper files are scanned into Traverse.

Reference Number 2025-02 Return of Title IV Funds (R2T4) Since the 2025 audit, there have been significant improvements in oversight and process management for R2T4 calculations. A leadership transition occurred, and the Associate Director - bringing over 30 years of higher education experience, including prior service as a Financial Aid Director - has assumed responsibility for R2T4 calculations for the 2026-27 academic year. To ensure compliance and accuracy, the Associate Director completed a Department of Education training refresher on R2T4 calculations during Spring 2025. Additionally, the interim Financial Aid Director implemented a structured plan to monitor all student withdrawals and guarantee timely completion of calculations. For Fall 2025, the process has remained on schedule. A two-tier accountability system is in place: the Associate Director manages calculations, and the Director provides immediate support if any delays occur. A comprehensive tracking spreadsheet was developed to record each withdrawal, including the withdrawal date, federal aid status, and the date the R2T4 calculation was completed. This tool ensures real-time monitoring and accuracy. The daily withdrawal report introduced after the 2024 audit continues to be a valuable resource; however, the combination of this report with the new tracking system and dual oversight has proven to be the cornerstone of compliance. All calculations are current, accurate, and completed within required timelines. Based on these improvements, we do not anticipate any findings in the upcoming audit.

Views of Responsible Officials and Planned Corrective Actions – The Registrar and Institutional Researcher will both ensure that any students that have updated their status are updated on a weekly basis. The Institutional Researcher will log into NSLDS to upload the file, and the CFO, Registrar, and Institutional Researcher will monitor updates monthly.

Views of Responsible Officials and Planned Corrective Actions – The CFO and the Students Account Manager will add a checklist step to verify the correct inclusion of all scheduled breaks in the R2T4 calculation, will implement a secondary review process to confirm data accuracy before finalizing R2T4, and will provide training to relevant staff.

Views of Responsible Officials and Planned Corrective Actions – The CFO and Student Accounts Manager has begun the process of uploading the file that specifies disbursement date in the ledger so they match one another.

Views of Responsible Officials and Planned Corrective Actions – The CFO and Student Accounts Manager will provide a listing of all students receiving a refund. A grace period of 5 days for students to provide direct deposit information will be established, if after 5 there is still no direct deposit information, a check will be issued.

Student Financial Assistance Cluster Assistance Listing No. 84.007, 84.033, 84.063 & 84.268 Recommendation: We recommend the University review credit balance refund processes, including automated processes, to ensure all credit balances are paid timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Revised the daily Title IV credit balance workflows to include credit balances of any amount. Name(s) of the contact person(s) responsible for corrective action: Valerie Marsh, Director of Student Financial Services Planned completion date for corrective action plan: December 1, 2025

Student Financial Assistance Cluster Assistance Listing No. 84.007, 84.033, 84.063 & 84.268 Recommendation: We recommend the University review reporting processes to ensure all students that require exit counseling receive it in a timely manner. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The workflow FAEXIT_WDR for students who withdrew in the current term or have a late coded CWD was revised from excluding the assignment of exit counseling if exit counseling was assigned in the prior academic term to exclude only if exit counseling already exists in the current term. Name(s) of the contact person(s) responsible for corrective action: Alec Kuzmack, Business Analyst Planned completion date for corrective action plan: November 21, 2025

Corrective Action Plan Related to the Schedule of Findings and Questioned Costs Student Financial Aid University of Hawaiʿi – Maui College Year Ended June 30, 2025 Finding No. 2025-002: Financial Aid Administration – Control Deficiency Federal Agency: U.S. Department of Education CFDA Number and Title: 84.268 – Federal Direct Student Loans Questioned Costs: $-0- Responsible Individuals: Kulamanu Ishihara, Financial Aid Director, Maui College Date Action Taken: December 2, 2025 Corrective Action Plan for timely notifications for exit counseling- NSLDS reporting. 1. Financial Aid Office Staffing ● The Financial Aid Office has completed recruitment for four full-time positions, including a director to ensure adequate administrative capacity for the financial aid processes. 2. Project Prioritization ● Effective immediately, the Financial Aid Office will prioritize timely notifications and exit counseling to students with loans. 3. Project Documentation ● For any future delays due to unforeseeable circumstances, the financial aid program will provide clear, detailed justifications to ensure compliance with audit expectations. 4. Project Oversight and Monitoring ● The Vice Chancellor of Student Affairs will meet monthly with the Financial Aid Director to ensure deadlines are being met and to and monitor the progress of notifications. Expected Results Implementation of this corrective action plan will result in timely notifications of exit counseling being provided through interactive electronic notifications or by mailing counseling materials to the borrower at the borrower’s last known address within 30 days after learning that the borrower has withdrawn from the institution or failed to complete exit counseling as required.

Corrective Action Plan Related to the Schedule of Findings and Questioned Costs Student Financial Aid University of Hawaiʿi – Maui College Year Ended June 30, 2025 Finding No. 2025-001: Return of Title IV Funds – Control Deficiency Federal Agency: U.S. Department of Education CFDA Number and Title: 84.063 – Federal Pell Grant Questioned Costs: $-0- Responsible Individuals: Kulamanu Ishihara, Financial Aid Director, Maui College Date Action Taken: November 25, 2025 Corrective Action Plan for timely notifications for withdrawal date determination. 1. Financial Aid Office Staffing ● The Financial Aid Office has completed recruitment for four full-time positions, including a director to ensure adequate administrative capacity for the financial aid processes. 2. Project Prioritization ● Effective immediately, the Financial Aid Office will prioritize the timely withdrawal date determination by initiating the new Kuali Build Form with routing capabilities. 3. Project Documentation ● For any future delays due to unforeseeable circumstances, the financial aid program will provide clear, detailed justifications to ensure compliance with audit expectations. 4. Project Oversight and Monitoring ● The Vice Chancellor of Student Affairs will meet monthly with the Financial Aid Director to ensure deadlines are being met and to monitor the progress of notifications. Expected Results Implementation of this corrective action plan will result in a timely determination of the withdrawal date through interactive electronic routing.

2025-001 Significant Deficiency: National Student Loan Data System (NSLDS) Report (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268 and Federal Pell Grant Program, ALN #84.063) (Repeat finding of 2022-001, 2023-003, and 2024-005) Name of Contact Person Casey Reagan, Registrar, and Melissa White, Director of Financial Aid, are responsible for clearinghouse reporting for 2023-24. Corrective Action Planned During the audit, it was noted that the University incorrectly reported student enrollment status for changes in enrollment. The university has identified the issue that is occurring that is causing the enrollment to be reported incorrectly. We are currently working with the IT Department to fix the error that is occurring within the system itself. In the meantime, students who are impacted by the incorrect enrollment status reporting are being manually fixed in the system and then the record is being pulled and reported to clearinghouse. Overall, the university has been working to reduce the number of incorrect enrollment status reportings. This can be seen by the fact that we went from a 45% error rate in 2023-24 to a 20% error rate in 2024-25. Finally, the Registrar’s Office shall be main office reporting clearinghouse data in the future, with financial aid only acting as a secondary reporter should the Registrar’s Office not be available to report. Anticipated Completion Date 08/01/2026

2025-001 Incorrect Direct Loans Disbursement Amount - Student Financial Aid Cluster Assistance Listing #s 84.007, 84.033, 84.063, 84.268, Grant Period - Year Ended June 30, 2025 Condition Found During our student file testing we noted one student out of forty was disbursed the incorrect Direct Loan amount. Based on the student’s enrollment status and need this student was eligible for $586 in Subsidized Loans and $2,914 in Unsubsidized Loans; however, the College awarded the student $549 in Subsidized loans and $2,951 in Unsubsidized loans which resulted in an under award of $37 in Subsidized Loans and an over award of $37 in Unsubsidized Loans. We consider this error in awarding to be an instance of noncompliance of the Eligibility Compliance Requirement. Corrective Action Plan Waubonsee will ensure to add the loan fees first to ensure sub-loans are calculated correctly. Responsible Person for Corrective Action Plan Mary Greenwood Implementation Date of Corrective Action Plan 12/9/2025

1. Immediate System Correction The clock-to-credit hour conversion file in Banner (GTVSDAX) was reviewed and updated to include all applicable course prefixes, including MAH and PSY. This correction ensured that clock-to-credit hour conversions were calculated accurately for affected technical programs. 2. Identification and Review of Impacted Students Financial Aid reviewed all students enrolled in the affected term (202610) and identified those whose federal aid hours had been overstated due to the conversion omission. 3. Correction of Federal Aid Awards Federal aid awards were recalculated for impacted students. The engagement team noted, and the College confirms, that all affected students were enrolled in a current payment period for which funds had not yet been fully drawn, allowing corrections to be made timely. 4. Resolution of Financial Impact Where recalculations resulted in reduced eligibility, institutional need-based funds were applied to affected student accounts to prevent students from incurring balances due to an internal administrative error. This ensured students were not financially penalized for the control deficiency. Preventive Actions and Controls to Avoid Recurrence To address the identified control deficiency and strengthen internal controls over clock-to-credit hour conversions, the College has implemented the following preventive measures: 1. Enhanced Curriculum Oversight The Registrar (Tara Dumas) and Director of Financial Aid (Stacia Richerson) now serve as standing members of the Academic/Curriculum Review Committee. This ensures that Financial Aid and Registrar review all proposed curriculum changes, including: o New courses o New course prefixes o Courses designated as “in degree plan” for technical or clock-hour programs This review occurs prior to course approval and implementation, allowing clock-to-credit hour implications to be addressed in advance. 2. Formal Notification and Review Process Academic Affairs will notify Financial Aid of any curriculum changes that may impact clock-to-credit hour conversions. Financial Aid will review and update Banner conversion tables as needed before federal aid calculations occur. 3. Assigned Responsibility and Monitoring Responsibility for maintaining and reviewing clock-to-credit hour conversion tables has been formally assigned to the Director of Financial Aid (Stacia Richerson). o Conversion tables will be reviewed each semester prior to awarding federal aid. o Discrepancies in ROAENRL will be reviewed promptly to ensure accuracy. 4. Ongoing Compliance Review The College will perform periodic reviews of conversion logic and awarding calculations to ensure continued compliance with federal regulations and internal control standards under 2 CFR 200.303. Conclusion Reid State Technical College has corrected the clock-to-credit hour conversion issue, resolved the related questioned costs, and implemented strengthened internal controls. The addition of the Registrar (Tara Dumas) and Director of Financial Aid (Stacia Richerson) to the Academic/Curriculum Review Committee, combined with formalized review and notification procedures, provides reasonable assurance that clock-to-credit hour conversions will be accurately applied prior to federal aid calculation and disbursement.

Identification Number: 2025‑005 – Satisfactory Academic Progress Finding: One student received Direct Unsubsidized Loan funds despite not meeting maximum timeframe requirements for satisfactory academic progress at the beginning of the Spring 2025 semester. Corrective Action Plan: Management agrees with the finding. The University will strengthen controls to ensure satisfactory academic progress is fully evaluated and documented prior to the disbursement of Title IV funds. A review checkpoint will be added to verify eligibility before loan disbursements are released. Responsible Officials and Implementation Date: The Director of Student Financial Services will be responsible for this corrective action. Updated review procedures will be implemented by February 16, 2026.

Identification Number: 2025‑004 – Return of Title IV Funds Finding: Incorrect spring break days were used in Return of Title IV calculations for Spring 2025, resulting in inaccurate return amounts and funds not properly returned to the U.S. Department of Education. Corrective Action Plan: Management agrees with the finding. The University will revise Return of Title IV calculation procedures to ensure accurate identification of payment periods, including scheduled breaks. A secondary review of all Return of Title IV calculations will be implemented prior to processing returns to confirm accuracy and compliance with federal regulations. Identified funds due will be returned to the U.S. Department of Education. Responsible Officials and Implementation Date: The Director of Student Financial Services will be responsible for implementing the corrective action, with oversight from the Vice President for Administration and Finance. Revised procedures and secondary review controls will be implemented by February 16, 2026.

Identification Number: 2025‑003 – Enrollment Reporting (Repeat Finding) Finding: The University did not report one student status change timely and reported inaccurate program‑level record data for four students, resulting in inaccurate or untimely enrollment reporting to the U.S. Department of Education. Corrective Action Plan: Management agrees with the finding. The University will enhance controls over enrollment reporting to ensure all student status changes and program‑level data are reviewed for accuracy and reported timely. Additional reconciliation between the Registrar's Office and Student Financial Services will occur before submission to the National Student Clearinghouse and the U.S. Department of Education. Responsible Officials and Implementation Date: The Registrar and Director of Student Financial Services will be responsible. Improved review and reconciliation procedures will be implemented by July 1, 2026, prior to the Fall term.

Identification Number: 2025‑006 – Pell Grant Eligibility Finding: Pell Grant funds were disbursed to five students who were not eiligible, and two students did not receive the full Pell Grant amount for which they were eligible. Corrective Action Plan: Management agrees eith the finding. The University will implement enhanced review controls over Pell Grant eligibility and calculation prior to disbursement. This will include verification of eligibility data and a secondary review of Pell calculations to ensure accuracy and completeness before funds are released. Responsible Officials and Implementation Date: The Director of Student Financial Services will be responsible for implementing this corrective action, with the oversight from the Vice President for Administration and Finance. Enhanced controls will be implemented by February 16, 2026.

Corrective Action Plan 2025-001: The College concurs with the finding and has adjusted its processes and controls beginning with the Fall 2025 semester to ensure that all Title IV funding sources including FSEOG are drawn down in accordance with the Heightened Cash Monitoring requirements. Completion Date: August 2025 Contact Person: Laura Crawley

Upon notification of the reporting error, the institution corrected the enrollment status effective date in both the National Student Clearinghouse (NSC) and NSLDS to reflect the student's actual withdrawal date of November 15, 2024. To prevent future reporting errors, the Registrar's Office will implement an additional procedural verification step in the enrollment status reporting process. This step will include a review of effective dates prior to submission to NSC and NSLDS. The Registrar will also ensure appropriate staff training and oversight as process documentation is developed and implemented in the new student information system.

Finding 2025-001 Special Tests and Provisions – Participation of Private School Children Finding Summary: The District failed to conduct timely consultations with private school officials regarding the implementation of the Stronger Connections Grant. Responsible Individuals: Dr. Farrah Gomez, Deputy Superintendent of Academics and School Leadership Corrective Action Plan: The District will establish and implement written procedures to ensure annual consultation meetings with private school officials for all grants under the Title IV program. Additionally, the District will consult with TEA to determine next steps regarding the Stronger Connections Grant. Anticipated Completion Date: January 2026

Views of Responsible Officials and Corrective Action Plan The District agrees with the finding and will implement procedures that will ensure Returns of Title IV funds are returned no later than 45 days after that date the College determines the student has withdrew.

Corrective Action Plan: To prevent this issue from recurring, we have implemented an additional data validation step during the preparation of the Graduates Only Enrollment Submission. Specifically, we will now cross-check the "last date of attendance" field for all graduating students to ensure that it aligns with the official last day of the term, as defined by the academic calendar. In this case, the correct date should have been December 20, 2024; however, the file incorrectly populated the field with December 23, 2024. We are reviewing the logic in the data generation process to identify and correct the source of the discrepancy. Moving forward, the Registrar’s Office will confirm this date field prior to each submission to the Clearinghouse to ensure compliance with NSLDS requirements. Timeline for Implementation of Corrective Action Plan: The corrective action plan was implemented as of October 2025. Contact Person: Caitlin Laurie, Director of Financial Aid Mark Powers, Registrar

Corrective Action Plan: The individual did not have a social security number (“SSN”) on file in Banner. As a result, although the enrollment data was transmitted to the National Student Clearinghouse, the missing SSN went unnoticed until June 2025, when materials were being gathered for the audit. The Director of Student Financial Aid was able to locate the student’s SSN in PowerFaids and provide it accordingly. We then manually updated the student’s Fall 2024 and Spring 2025 enrollment data in NSLDS to ensure their record was complete. To help prevent this type of issue in the future, both the Registrar and Director of Student Financial Aid have implemented a process that compares missing or potentially incorrect SSNs in Banner against the data in PowerFaids. Timeline for Implementation of Corrective Action Plan: The corrective action plan was implemented as of October 2025. Contact Person: Caitlin Laurie, Director of Financial Aid Mark Powers, Registrar