Corrective Action Plans

Documentation of Monthly Reconciliation Recommendation: We recommend the District establish policies and procedures to ensure proper documentation of preparation and review of monthly Title IV reconciliations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Actions planned in response to finding: • The District will reconcile the institutional records with Pell funds monthly and maintain documentation and preparation of the reconciliation process • The Financial Aid Coordinator will be responsible for creating a SharePoint drive and maintaining the accuracy of the reconciliation process via SharePoint drive • Create a SharePoint so that when we have employee-related transitions, the newly assigned Financial Aid Coordinator will have access Responsible party: Financial Aid Coordinators and Workforce Finance Department Planned completion date for corrective action plan: April 30, 2026 Plan to monitor completion of corrective action plan: • The Financial Aid Coordinators and Workforce Finance Department will conduct a monthly review to confirm reconciliations are completed, documented, and properly approved. • Any issues identified during monthly reviews will be addressed promptly to ensure ongoing compliance.

The College has implemented a structured NSLDS enrollment reporting control to ensure updates are reported within 60 days to NSLDS, (OMB No. 1845-0035) (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309; Perkins 34 CFR 674.19(f)). The Registrar’s Office, or a representative of, generates a Monthly status-change report, which is reviewed at the Student Affairs Operations meeting. Financial Aid reviews the list for Title IV impacts, and the Director of Financial Aid completes the NSLDS Enrollment Maintenance roster review and certification on a scheduled cadence (at least biweekly; weekly during peak periods). Each submission is documented with (1) the SONIS status-change report, (2) the NSLDS Enrollment Maintenance Report/roster file, and (3) dated evidence of review/approval and submission (email/Teams sign-off plus NSLDS submission history screenshot). Exceptions approaching 45 days are escalated to leadership for same-week certification

U.S. Department of Education Mount Mary University respectfully submits the following corrective action plan for the year ended June 30, 2025. Audit period: July 01, 2024 - June 30, 2025 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FINANCIAL STATEMENT AUDIT Our audit did not disclose any matters required to be reported in accordance with Government Auditing Standards. FINDINGS—FEDERAL AWARD PROGRAMS AUDITS U.S. Department of Education 2025-001 Student Financial Aid Cluster – Assistance Listing No. 84.063 & 84.268 Recommendation: We recommend that the University reviews withdrawals monthly to ensure that the students are reported correctly to NSC and subsequently to NSLDS. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University has submitted and reviewed the four students and have submitted corrections for incorrect statuses and effective dates. Name(s) of the contact person(s) responsible for corrective action: Brian Olson, Vice President of Finance and Administration Planned completion date for corrective action plan: June 30, 2026 *** If the U.S. Department of Education has questions regarding this plan, please call Brian Olson, Vice President of Finance and Administration, at 414-930-3139.

Finding 2025-001 Condition During our audit, 1 out of 3 employees selected for testing received a bonus payment for achieving first year enrollment goals. The College then determined 2 employees received such bonuses and additional testing confirmed a total of 2 out of 27 employees who were involved in the College's admissions/recruiting, financial aid and registrar offices received bonuses based on their contributions towards enrollment performance. These bonuses were paid from internal College funds and not from Title IV funds. Corrective Action Plan Corrective Action Planned: The college implemented a policy on incentive pay citing the restrictions and banning incentive pay for specific job duties. The policy and a standard form for awarding additional compensation have been reviewed and approved by senior leadership and posted to the college’s human resources website. Name(s) of Contact Person(s) Responsible for Corrective Action: Amanda Stahl, Vice President for Finance and Ann Eckert, Assistant Vice President for Human Resources will be responsible for ensuring adherence to the policy and review of any awarding of additional compensation. Anticipated Completion Date: The policy and forms were approved and completed September 30, 2025.

Financial Statement Findings 2025-01 The District’s control procedures over IT systems and data were not sufficient, which increases the risk that the District may not adequately protect those systems and data. Contact: Thomas Thompson, Chief Information Officer Anticipated completion date: June 30, 2026__________________________________________ Corrective Action Plan: The District will prioritize the development and formal documentation of IT policies and procedures addressing logical access controls, system security, and vendor management. These policies will align with recognized industry standards and will include processes to ensure consistent implementation and compliance. a) User access assignment and review b) Timely removal of access c) Enhance verification of assignment through available and to-be-developed reporting tools d) The District will review and enhance formal procedures for evaluating, awarding, and monitoring IT vendor contracts. This will include documenting vendor qualifications, defining security expectations in contracts, and performing periodic reviews to ensure vendors comply with contractual and security requirements. e) Management will implement supervisory review controls to ensure adherence to IT policies and procedures. Federal Award Findings 2025-101 The District did not timely report required student information to the federal agency, risking students not being asked to repay financial assistance. Contact: Sharon Montoya, Director, Financial Aid & Veteran Services Anticipated completion date: June 30, 2026__________________________________________ Corrective Action Plan: The District will implement procedures to ensure all student enrollment status changes are reported to the National Student Loan Data System (NSLDS) within the required 60-day timeframe. This includes establishing a standardized reporting schedule and utilizing system-generated reports to monitor pending status changes. a) Assign monitoring and oversight responsibilities in the Financial Aid department b) Implement ongoing monitoring control within the Financial Aid department c) Monthly inquiring into the Financial Aid department process by Fiscal Control

Credit Balances Held Beyond Payment Period Planned Corrective Action: Ohio Christian University has implemented procedures to ensure that all Title IV credit balances are identified and released to students within 14 days of the credit balance occurring, in compliance with federal regulations. The Financial Aid Office will run weekly credit balance reports following each disbursement to identify any student accounts with a Title IV credit balance. These reports will be reviewed jointly by the Financial Aid and Student Accounts offices to confirm eligibility and authorize timely refunds. As an ongoing quality assurance measure, supervisory review will be conducted monthly to verify compliance with the 14-day requirement, and any exceptions will be documented and addressed immediately. Staff training has been enhanced to reinforce regulatory requirements and internal timelines related to credit balance processing. Person Responsible for Corrective Action Plan: Justin Pichey, Director of Financial Aid & Chelsie Hedrick, Senior Accountant Anticipated Date of Completion: This was implemented starting with the Spring 2026 semester.

Finding 2025-001 Condition The University did not notify the National Student Loan Data System (NSLDS) in a timely manner for four students with status changes. Corrective Action Plan 1. Finding: Incorrect Status Date Reported to NSC/NSLDS for a withdrawn student Corrective Actions: • Root Cause Analysis: A review was conducted to determine why NSC/NSLDS received the incorrect date despite Colleague displaying the correct withdrawal date of 3/20/2025. The analysis confirmed that the Colleague reporting process pulls the date from the course drop/withdrawal field rather than the student status withdrawal date screen. According to system documentation, “SITX determines the enrollment status, enrollment status start date, and the anticipated graduation date for the students included in the extract. If the enrollment status changes during the reporting period since the last census date, the status change date is calculated from schedule changes and hiatus record information.” • Process Improvement: o Staff have been instructed to ensure that all relevant screens reflect the correct status change date prior to reporting. o Documentation is being developed outlining the withdrawal process workflow, including all screens requiring updates. This will promote consistency and serve as a reference for future staff transitions. 2. Finding: Failure to Report Three Graduates to NSLDS Within the 60 Day Requirement Corrective Actions: • Root Cause Analysis: The University Registrar contacted the NSC to investigate the delay. Although the NSC Degree Verify file was submitted within the required timeframe, it was determined that the “G Not Applied” process on the NSC site was not completed promptly by Registrar’s Office staff, resulting in the late NSLDS reporting. • Process Redesign: The University Registrar is working with Gannon IT Services to develop a “Graduates Only” reporting process directly from Colleague. This enhancement will eliminate reliance on the NSC “G Not Applied” step, which has been a recurring compliance challenge. This new process will be implemented no later than July 1, 2026. Until then, the “G Not Applied” list will be processed within 10 days of processing availability (at times the G Not Applied cannot be updated while an Enrollment file submission is pending acceptance). • Proactive Audit Measures: Given the significant staffing transitions and shifts in reporting responsibilities over the past year, an internal audit of the 2025–2026 reporting completed to date is underway, in collaboration with the NSC Audit Department, to determine the full extent of any additional reporting deficiencies that may have carried into the new academic year. 3. As previously stated in the Summary Schedule of Prior Audit Findings for the Year-Ended June 30, 2024 Update, the following corrective actions are being initiated: • Additional staff have been designated to ensure that at least three individuals possess the knowledge and system access required to submit reports and process corrections. • All designated staff are required to complete NSC-provided training to ensure full understanding of reporting requirements and procedures. • Each staff member must submit test reports and review resulting errors using the NSC test submission process, working closely with assigned NSC analysts to demonstrate competency in accurate reporting and effective error resolution. Name(s) of Contact Person(s) Responsible o Barbara Helms, University Registrar – primary responsibility for enrollment reporting submissions, back-up for G reporting o Heidi Thomas, Processing and Data Specialist – assists with enrollment error report cleanup, secondary for enrollment reporting submissions, additional back-up for G reporting o Ashley Dinger, Academic Records and Graduation Specialist – primary responsibility of the G reporting, additional back-up for enrollment reporting. • Although documentation exists from the previous corrective action plan, it has been determined that it is not sufficiently detailed. New documentation is being developed to ensure that any individual responsible for these processes in the future has the necessary tools and guidance to meet all regulatory requirements. Estimated timeline for corrective action to be implemented: April 2026

FINDING 2025-007 Name of Responsible Individual: Brandon Rhone, Systems Administrator Corrective Action: We have revised our award period start and end dates to align or fall within range of our loan period code start and end dates when reporting to COD. This alignment ensures that all reported disbursements meet federal timing requests and reduces the risk of COD rejects or compliance findings. Anticipated Completion Date: March 31, 2026

FINDING 2025-005 Name of Responsible Individual: Chad Wick, Director of Financial Aid Corrective Action: We have implemented a new Quality Assurance Measure for Auditing all students with a C-Flag. The process begins with the FA advisor team. They are responsible for ensuring all documents have been received and all steps have been completed to clear the C-Flag. In Colleague the advisor will then mark the file is ready for audit. Chad Wick, Director, Financial aid or Brandon Rhone, Systems Administrator, will review all documents and steps needed to clear C-Flag and then update the communication code to audited and make any adjustments if needed to the FAFSA. Anticipated Completion Date: Already completed

FINDING 2025-004 Name of Responsible Individual: Chad Wick, Director of Financial Aid, and Brandon Rhone, Systems Administrator Corrective Action: We will implement a second check process after R2T4 has been calculated to ensure the correct dates are being used. Chad Wick, Director, Financial Aid will conduct the initial calculating of R2T4 on a weekly basis. Brandon Rhone, Systems Administrator, will review all calculations prior to processing them in Colleague. Anticipated Completion Date: March 31, 2026

FINDING 2025-003 Name of Responsible Individual: Brandon Rhone, Systems Administrator Corrective Action: We implemented a process which assigns communications management codes based on transmittal activity of each federal direct loan. On the same day a loan is disbursed, our system applies the appropriate code to the student record. These codes are then automatically selected for the correct loan disbursement notification to be sent either to the student or parent based on the federal loan type. Anticipated Completion Date: Already completed

FINDING 2025-002 Name of Responsible Individual: Chad Wick, Director of Financial Aid Corrective Action: We have implemented a new Quality Assurance Measure for Auditing all students selected for verification. The process begins with the FA advisor team. They are responsible for ensuring all documents have been received and verification has been completed. In Colleague the advisor will then mark the file is ready for audit. Chad Wick, Director, Financial aid or Brandon Rhone, Systems Administrator, will review all documents and verification steps and then update the verification status to verified and the communication code to audited. Anticipated Completion Date: Already completed

FINDING 2025-001 Name of Responsible Individual: Mary Beth Schiller-Schwenke, Chief Financial Officer and Controller Corrective Action: The Federal Pell Grant Program instances resulted from reversals of student awards. The Business Office routinely monitors the general ledger for award transactions, however, reversals of student aid awarded late in the academic term can be missed. The Financial Aid Office will be responsible for notifying the Business Office when they initiate award reversals that necessitate a refund. The Business Office has updated procedures so that the related general ledger accounts are reviewed no less than once per week for the full year. In addition to ongoing monitoring of the related general ledger accounts, the Business Office will also create automated reporting to notify staff of the pending account balances. Anticipated Completion Date: April 30, 2026

2025-008 Federal Direct Student Loans – Assistance Listing No. 84.268 Federal Pell Grant Program – Assistance Listing No. 84.063 Recommendation: We recommend that the University should implement formal review procedures to document that the Cash Management reconciliation and drawdown reviews are being performed to correct errors in a timely manner and to minimize the likelihood of errors going undetected. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University performs cash management reconciliation and drawdown reviews; however, formal documentation of these reviews has not been consistently maintained. To address this, the University is implementing formal review procedures that include documented evidence of reconciliation and drawdown review activities. As part of this process, reconciliations and drawdowns prepared by FA Solutions will be reviewed by the Financial Aid Office for accuracy and completeness prior to submission and reporting. These procedures will be formalized within a standardized SOP, which will outline review timelines, responsibilities, and required documentation to ensure errors are identified and resolved in a timely manner and to reduce the risk of discrepancies going undetected. Name(s) of the contact person(s) responsible for corrective action: Levi Powell, Director of Financial Aid Planned completion date for corrective action plan: 4/30/2026

2025-006 Federal Direct Student Loans – Assistance Listing No. 84.268 Federal Pell Grant Program – Assistance Listing No. 84.063 Recommendation: We recommend the University review its current procedures for awarding Title IV funds and implement any changes necessary to ensure federal funds are awarded and disbursed in accordance with federal regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University has conducted a review of its procedures for awarding Title IV funds, with particular attention to the awarding of Summer Pell. Through this review, we identified that Summer Pell was not awarded to eligible students during the applicable period, due in part to a misunderstanding of awarding requirements during a transition in third-party processing support. Urshan has since partnered with FA Solutions to strengthen oversight and ensure alignment with federal awarding requirements. Updated procedures have been implemented to ensure all eligible students are properly evaluated for Title IV aid, including Summer Pell, across all applicable terms. Name(s) of the contact person(s) responsible for corrective action: Levi Powell, Director of Financial Aid Planned completion date for corrective action plan: 8/31/2026

2025-004 Federal Direct Student Loans – Assistance Listing No. 84.268 Federal Pell Grant Program – Assistance Listing No. 84.063 Recommendation: We recommend that the University review policies and procedures related to R2T4 calculations to ensure calculations are performed accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Urshan has partnered with FA Solutions, an experienced third-party processor. Through this partnership, we have strengthened our processes and implemented additional checks and balances to ensure that R2T4 determinations are identified, calculated, and processed in a timely and compliant manner. Name(s) of the contact person(s) responsible for corrective action: Levi Powell, Director of Financial Aid Planned completion date for corrective action plan: 3/31/2026

U.S. Department of Education 2025-003 Federal Direct Student Loans – Assistance Listing No. 84.268 Federal Pell Grant Program – Assistance Listing No. 84.063 Recommendation: We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Urshan is currently in the onboarding process to partner with the National Student Clearinghouse, which will improve the timeliness and accuracy of our enrollment reporting to NSLDS. In addition, we are developing and implementing a standardized SOP that establishes defined reporting schedules (at least every 60 days), clearly outlines roles and responsibilities, and includes reconciliation procedures to ensure data accuracy. Name(s) of the contact person(s) responsible for corrective action: Levi Powell, Director of Financial Aid Planned completion date for corrective action plan: 7/31/2026

Condition: Management's review of the enrollment reporting did not detect that 2 student's change status was reported to NSLDS with incorrect information. Corrective Action Planned: The offices of Academic Advising and the Registrar will follow the procedure and process on student withdrawals and student dismissals and inform the Senior Data Specialist and the Office of Financial Aid to ensure the date of withdrawal or date of dismissal is accurately and consistently recorded according to Alverno policy and to the National Student Loan Data System (NSLDS). Name(s) of Contact Person(s) Responsible for Corrective Action: Kate Tisch, Director -Academic Advising, Jillian Smith, Registrar, Denise Sanders, Senior Data Specialist and Naomi Coe, Director of Financial Aid. Anticipated Completion Date: This corrective action has been established and review of student changes of status are reviewed and reported on timely basis and accurately immediately.

Finding: 2025-001 CFDA #: 84.063 and 84.268 Recommendation: We recommend the College monitor and evaluate the schedule reporting dates to the NSLDS and confirm or modify existing policies, procedures, or processes from timely identification to ensure that status changes can be communicated to the NSLDS within the regulatory timeframes. Explanation of disagreement with audit finding: There is no disagreement with the audit finding Corrective Action Plan: 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. Name of Contact Responsible for Corrective Action: Joy Hirdler, Vice President of Financial Administration, Chief Financial Officer, 707-965-6699 Anticipated Completion Date: March 31, 2026

Student Financial Assistance Cluster– Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend that the College review policies and procedures related to R2T4 calculations to ensure calculations are performed accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: One of the findings was a clerical math error. CSC is moving R2T4 Calculations into COD to ensure proper calculations and reporting. The second finding was a date of determination discrepancy. CSC FA and Registrar to review how the last date of academic activity is determined and reported in Banner. The Financial Aid Director to review the R2T4 Process and create an SOP. Name(s) of the contact person(s) responsible for corrective action: Current Financial Aid Director: Tara Torres OR Current Assistant Financial Aid Director: Tina Ballinger Planned completion date for corrective action plan: 06/30/2026

Student Financial Assistance Cluster– Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend the College review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: CSC utilizes National Student Clearinghouse (NSC) for NSLDS Reporting. The Registrar’s office is responsible for Enrollment Reporting. The four students with Reporting discrepancies are correctional students that do not have access to electronic forms. This population of students must submit paper requests and have them physically routed to the Registrar’s office for processing. The Enrollment and Reporting dates were in line; the discrepancy lies in the Program Enrollment date. The Registrar is researching if the student changed programs after their Enrollment dates. For the Enrollment Reporting date discrepancy outside the 60-day requirement, we reported the correct date to NSC. The Registrar has put in a ticket with NSC to see why they reported the Enrollment Date late. Name(s) of the contact person(s) responsible for corrective action: Current Registrar: Tosha Stout and Current Financial Aid Director: Tara Torres Planned completion date for corrective action plan: 6/30/26

Student Financial Assistance Cluster– Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend the College review its current procedures for awarding Title IV funds and implement any changes necessary to ensure federal funds are awarded and disbursed in accordance with federal regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The audit finding was a result of a student enrolling in summer coursework, and their awards were not recalculated. CSC is creating a documented Standard Operating Procedure (SOP) on how to package awards prior to each term to prevent under awarding and a Financial Aid Processing Calendar to ensure awarding occurs each term. Name(s) of the contact person(s) responsible for corrective action: Current Financial Aid Director: Tara Torres OR Current Assistant Financial Aid Director: Tina Ballinger Planned completion date for corrective action plan: 06/30/2026

Student Financial Assistance Cluster– Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend the College evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The late reporting was the result of a known FAFSA issue that began occurring with the 24/25 FAFSA Simplification and continues with the 25/26 FAFSA. The exception occurred when the student was not presented with the HS Completion Status question on the application. Students must self-certify they have a HS Diploma or Equivalent to be eligible for Federal Student Aid. CSC exported the origination to COD. COD approved the award, but CSC was unable to post the award to the student’s account because the HS Completion Status was blank. As soon as the student corrected her FAFSA, CSC posted the award and reported it to COD. The CSC FA office now receives a report with missing HS Completion Status each day and deletes federal awards until the issue is resolved preventing late COD Reporting. Name(s) of the contact person(s) responsible for corrective action: Current Financial Aid Director: Tara Torres OR Current Assistant Financial Aid Director: Tina Ballinger Planned completion date for corrective action plan: Completed

Student Financial Assistance Cluster– Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend the College review current processes for calculating and tracking the students employed in community service activities for its Federal Work Study funds to meet the minimum 7% requirement. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: CSC is in a rural area that does not afford many community service opportunities and usually files the FWS Community Service Waiver. Personnel changes caused CSC to miss the 24/25 filing deadline. CSC received the 25/26 Waiver on 06/05/2025. The 26/27 Wavier was requested 01/15/2026. CSC is creating a documented Standard Operating Procedure (SOP) on how to request the waiver and creating a Financial Aid Processing Calendar to ensure the deadline is met each year. Name(s) of the contact person(s) responsible for corrective action: Current Financial Aid Director: Tara Torres OR Current Assistant Financial Aid Director: Tina Ballinger Planned completion date for corrective action plan: 06/30/2026

Finding Number: 2025-003 Condition: The College did not perform an accurate calculation to determine the amount of funds to return of Title IV funds for 2 students. Planned Corrective Action: Accuracy in performing the required Return to Title IV Funds function is of significant importance to Lake Michigan College. Currently, a second individual performs an independent review of a sample of calculations. Although we find these two scenarios to be isolated in nature, we will increase our quality control sample review. We are also investigating how we might automate more of the process in order to help reduce any manual error. The two situations noted have been corrected. Contact person responsible for corrective action: Ben Burton, Director of Financial Aid Anticipated Completion Date: 03/15/2026