Corrective Action Plans

Finding 2025-003: Untimely Enrollment Status Reporting – the Institution did not provide an enrollment update response to National Student Loan Data System (NSLDS) in a timely manner for July 2024. It is recommended the Institution increase controls over enrollment reporting. Comments on Finding and Recommendation(s): During the time, the school was transitioning reporting periods and was reported based on new schedule. This is no longer an issue. Actions Taken or Planned: All student’s enrollment status were verified for the entire year and was found that all statuses reported were correct.

Finding 2025-002: Unpaid Refunds – the auditor tested twenty-two drop students and noted two unpaid refunds. It is recommended that the Institution refund the $5,808 to the Department of Education and increase controls over paying refunds Comments on Finding and Recommendation(s): Happened during transitional phase of banking and employees and should be seen as an one off situation. Actions Taken or Planned: All banking accounts have been reconciled and refunds have been settled. We have secured more qualified accounting representatives to ensure timeliness going forward.

Finding 2025-001: Incorrect Federal Direct Loan Amounts – the auditor tested seventy-one files, sixty-seven of which were Federal Direct Loan recipients, and two students received incorrect loan amounts. It is recommended that the Institution refund $237 to the Department of Education and increase controls over packaging direct loans. There is no action required for the $333 in underawarded subsidized loans, as the student is no longer a current student, so the Institution is unable to reclassify the loans. Comments on Finding and Recommendation(s): This was an oversight on previous FA advisor when prorating loans. Actions Taken or Planned: Employee was removed from role earlier in the year and intense training has been given to the replacement. All debts have been settled with the Department of Education and appropriate student ledgers updated.

Identifying Number: 2025-001 Finding: The Foundation and College did not timely refund a student’s credit balance. Contact person responsible for corrective action: Laura Reagan, Senior Director of Financial Affairs Corrective Actions Taken or Planned: The Student Billing system omitted the student from the original refund list due to an inactive address in the system. The credit balance was identified on a routine review of the student billing aging report and subsequently processed. It was completed outside of the 14 day requirement. A process will be put in place to increase the frequency of the aging review to ensure any missed credit balances will be processed within the required time frame. Anticipated Completion date: June 30th, 2026

Friends University Year Ended June 30, 2025 Corrective Action Plan Finding Reference Number – 2025-001 Criteria or Specific Requirement – Special Tests and Provisions - Return of Title IV Funds (34 CFR section 668.22) (Reference number 2025-001) Recommendation – The University should take appropriate action to ensure information used to support student refund calculations is accurate and ensure proper oversight is performed timely. Views of Responsible Officials and Corrective Action Plan – Management concurs with the findings and recommendation. Responsible personnel will review calculations as they are completed. Individuals Responsible – Amy Stoltzfus, Director, Office of Financial Aid Anticipated Completion Date – Already implemented

Paris Junior College management will ensure that a standardized procedure including internal controls is established and implemented to ensure the R2T4 process is timely and accurate.

2025-001 - Student Financial Aid Cluster - (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Grant (c) Federal Pell Grant Program (d) Federal Direct Loan Program, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2025 Condition Found 4 of the 40 student files (10%) we examined, we noted the students were not properly awarded Direct loans. We consider this condition to be a significant deficiency relating to the Eligibility compliance requirement and is a repeat finding shown in Section IV of this report as prior year finding 2024-004. Statistical sampling was not used in making sample selections. Corrective Action Plan To address this finding, the Student Financial Services (SFS) team has implemented a Quality Assurance process designed to reconcile discrepancies between institutional and federal records: • Quality Assurance selection sets have been created to reconcile student grade level in Jenzabar with the grade level on the ISIR. • These QA queries will be run at multiple control points: o Prior to awarding Direct Loans o Prior to disbursement o At strategic intervals during the term to catch any subsequent changes • Identified discrepancies will be reviewed and corrected before aid is disbursed to ensure compliance with federal eligibility requirements. Responsible Person for Corrective Action Plan Deb Beck Implementation Date of Corrective Action Plan 10/1/2025

2025-002 - Student Financial Aid Cluster - (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Grant (c) Federal Pell Grant Program (d) Federal Direct Loan Program, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2025 Condition Found The Organization did not accurately complete refund calculations for 2 out of 9 students (22.2%) tested that both required post-withdrawal disbursements. For one of these students, the College did not notify the student of the post-withdrawal disbursement of Federal Direct Loans before it was applied to the student’s account. We consider this finding to be a significant deficiency in relation to the Special Tests and Provisions compliance requirement and is a repeat finding shown in Section IV of this report as prior year finding 2024-007. Corrective Action Plan To ensure accuracy and compliance going forward, the Student Financial Services (SFS) team will implement the following corrective actions: • Establish a double-layer review process for all post-withdrawal disbursements. • Each PWD calculation and notification will undergo an initial entry review by the staff member completing the R2T4 and a secondary accuracy check by a separate staff member prior to submission and disbursement. • This layered review is intended to catch and correct data entry errors prior to finalization. Responsible Person for Corrective Action Plan Deb Beck Implementation Date of Corrective Action Plan 10/1/2025

2025-003 - Student Financial Aid Cluster - (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Grant (c) Federal Pell Grant Program (d) Federal Direct Loan Program, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2025 Condition Found In our testing of student files, three out of 40 students (7.5%) had enrollment statuses not timely or accurately reported to NSLDS. We consider this finding to be an instance of noncompliance in relation to the Special Tests and Provisions compliance requirement and is a repeat finding shown in Section IV of this report as prior year finding 2024-008. Corrective Action Plan To address these deficiencies and ensure timely and accurate reporting going forward, the Registrar’s Office has implemented a comprehensive set of actions: • System & Process Review: In early October 2025, a review was conducted of the October NSLDS reporting file due to a Jenzabar bug. That process identified both procedural and software issues impacting data accuracy. • Staff Training: On October 9, 2025, targeted training was provided to the Registrar’s team on the Jenzabar support ticket recommendations and process findings, strengthening staff understanding of reporting requirements and workflows. • Jenzabar Collaboration: The College is actively working with Jenzabar support through the June and September tickets to resolve data discrepancies and implement best practices for future reporting cycles. • Internal Reporting Development: Montreat will create internal reports to identify discrepancies between the “NSC Detail” table and student term tables, enabling proactive error correction before NSLDS submission. • Ongoing Monitoring: This will remain an ongoing process improvement initiative as the team continues to refine validation checks, strengthen internal controls, and leverage Jenzabar system updates to improve accuracy and timeliness. Responsible Person for Corrective Action Plan Kandi Molder Implementation Date of Corrective Action Plan 1/31/2026

2025-003: Student Financial Audit Cluster - Special Tests and Provisions: Disbursements to, or on Behalf of, Students (Significant Deficiency) Corrective Action: The College updated its award notification process, which took effect for the Spring 2025 term. All current and future award notifications now comply with 34 CFR 668.165(a)(1). Including the required information regarding when Title IV funds will be disbursed. Referencing the academic calendar, which clearly identifies the official disbursement dates for the term. To prevent recurrence of this finding, the College has implemented the following permanent measures: • Revised Award Notification Templates: All digital and physical award notification templates have been permanently updated to include dedicated fields for the disbursement date or a direct, clear reference to where the student can find the disbursement schedule. • Enhanced Pre-Release Compliance Review: A mandatory two-step review process has been added to the award notification workflow. This step verifies that all notifications meet the “amount, how, and when” Title IV disclosure requirements before they are sent to students. • Mandatory Staff Training: All Financial Aid staff have received and will receive annual training refreshers on the current federal notification requirements, specifically emphasizing the timing of disbursement disclosure, and the use of the updated, compliant templates. • Ongoing Monitoring and Internal Audits: The College will implement a quarterly internal review process where a sample of student award notifications will be checked for accuracy and full compliance with 34 CFR 668.165(a)(1) to ensure sustained adherence. Anticipated Completion Date: 6/30/2026 Contact Person: Joyce Lubeck-Sonenberg

2025-002: Student Financial Audit Cluster - Reporting (Significant Deficiency) Corrective Action: The College has taken the following actions to implement the required additional control and ensure accurate tuition and fees reporting in the FISAP. • Systemic Data Isolation Control: The College has collaborated with its Institutional Research and Business Office staff to develop and implement a new report or query within the Student Information System (SIS). – This new control will automatically isolate and extract tuition and fees revenue only for students who meet the Section D criteria (regular students enrolled in credit-bearing classes). – This ensures that non-eligible tuition (e.g., non-credit, high school) is systematically excluded from the FISAP input data. • Segregation of Duties and Dual Review: The process for FISAP preparation has been revised to include a required dual-review step: – The Financial Aid Office will prepare the draft FISAP data using the new controlled data isolation report. – The Controller will perform a mandatory secondary verification of the total tuition and fee revenue reported in Part II, Section E, against the specific data extracted by the new systemic report. • Training and Procedure Documentation: Financial Aid and Business Office staff involved in the reporting process have been trained on the updated FISAP instructions and the mandatory use of the new systemic control to calculate Section E tuition and fees. The new control procedure has been documented in the College’s official FISAP preparation manual. Each different entity has the detailed instructions from the FISAP information. Anticipated Completion Date: 9/30/2025 Contact Person: Joyce Lubeck-Sonenberg

2025-004: Student Financial Audit Cluster - Special Tests and Provisions: Enrollment Reporting (Significant Deficiency) Corrective Action: Casper College will implement a multifaceted plan to ensure compliance with enrollment reporting requirements under 34 CFR 690.83, 34 CFR 685.309, and NSLDS guidelines. Key corrective steps include: • Policy Revision: Formally updating institutional policies (Sections 10 and 3.11) to clarify and align the reporting roles of the Registrar and Financial Aid, mandating specific timelines for all status changes, including withdrawals. • Strengthened Internal Controls: Establishing a mandatory dual-verification process for withdrawal effective dates and R2T4 alignment and implementing weekly NSLDS monitoring by Financial Aid and monthly Registrar–Financial Aid reconciliation meetings. • Documentation and Training: Improving documentation standards, including a centralized digital archive, and providing mandatory joint cross-office training on NSLDS rules, SSCR error resolution, and accurate, effective date determination. Anticipated Completion Date: 4/30/2026 Contact Person: Joyce Lubeck-Sonenberg

Management has implemented controls to ensure that all students receiving only failing grades ("all F") at the end of the semester are evaluated for potential R2T4 calculations.

Management has implemented controls to ensure that all students receiving only failing grades ("all F") at the end of the semester are evaluated for potential R2T4 calculations.

Management has implemented controls to ensure that all students receiving only failing grades ("all F") at the end of the semester are evaluated for potential R2T4 calculations.

As of August 2025, management has implemented controls to monitor student enrollment statuses and ensure the timeliness and accuracy of NSLDS reporting.

As of August 2025, management has implemented controls to monitor student enrollment statuses and ensure the timeliness and accuracy of NSLDS reporting.

Planned Corrective Action: Lake Erie College continues to review its operations and explore new partnerships to improve its financial performance. Some examples include: • Expanding marketing efforts to include high school Sophomores and Juniors creating a three-year enrollment funnel for the first time in college history. • Increase net tuition revenue by re-modeling financial aid strategies. • Eliminate academic programs and related faculty personnel for majors with declining enrollment. • Maximize enrollment in the new, market-savvy majors added for fiscal year 2026. • Make a comprehensive 9% cut to the fiscal year 2026 unrestricted operating budget. • Enforcing our residency requirement and meal plan enrollment to meet our budgeted revenue from auxiliaries. • Solicit grants from state, county, and local government agencies for facility projects and scholarship awards. • Continue to increase fundraising projections by engaging new donors and board members. Anticipated Completion Date: The elimination of academic programs and related faculty personnel took place at the end of the Spring 2025 term. The other items will be ongoing throughout the fiscal year. Responsible Contact Person: Jacalyn Kovach, Vice President of Finance

Department of Education Federal Direct Student Loans and Federal Pell Grant Program – Assistance Listing No. 84.268 and 84.063 Recommendation: We recommend that the University continue to enhance its policies and procedures regarding enrollment reporting including additional monitoring over the third-party service provider to ensure that reporting is completed accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management respectfully agrees on all findings and recommendations. Management will engage in business process review and implement redesigns as necessary. Management is committed to ensuring consistent application of policies and procedures so that enrollment reporting and oversight of third-party service providers result in accurate and timely reporting by the third-party service provider. Although the third-party service provider holds a national monopoly on enrollment reporting and other institutions of higher education face similar reporting issues by the third-party service provider, Management believes that review of internal processes over enrollment reporting will mitigate accuracy and timeliness errors made by the third-party service provider. These measures will help ensure compliance with U.S. Department of Education requirements. Name(s) of the contact person(s) responsible for corrective action: Ashlie Pence Planned completion date for corrective action plan: February 28, 2026

Views of Responsible Officials and Planned Corrective Actions Clearinghouse reports are from the college’s student information system (SIS). During FY24, the finding stems from a student’s withdrawal, which was promptly processed and entered in the SIS. However, the system categorized the student as "less than half-time” because the student received a passing grade in a course for which the student was exempted after passing a proficiency test. The SIS did not update the student status to 'withdrawn' until the semester ended, which was more than 60 days after the withdrawal date. To remedy this issue, the college’s Business Office now maintains an online spreadsheet listing withdrawn students outside the SIS that is updated whenever a student withdraws from the college. The list has been shared with the personnel responsible for the Clearinghouse reports and the Financial Aid Coordinator. Personnel will monitor the withdrawal listing and verify that all withdrawn students are accurately categorized in the Clearinghouse report from the SIS before completing the submission. After reviewing the FY25 finding, we discovered that the student attended in the spring 2025 semester but withdrew during the college’s drop/add period. By default, the SIS removes students who withdraw during drop/add from the Clearinghouse report.We have confirmed that Welch is unable to modify data or correct errors in the SIS report submitted to the Clearinghouse.Action Taken/Planned To address these problems, which ultimately stemmed from the limitations of Clearinghouse reporting by the college’s SIS, Welch has taken the following steps: 1. Clearinghouse reporting responsibilities have transitioned to a full-time, onsite employee in the Provost’s Office. 2. When preparing Clearinghouse reports and to help with identifying any errors before submitting the report, the employee will continue to monitor the withdrawn students listing maintained by the college’s Business Office, as outlined in the steps taken with the FY24 finding. 3. Welch plans to engage with its SIS and explain the reporting issues and limitations to determine if the SIS can help the college resolve the reporting limitations with its system. 4. To minimize the possibility of students being omitted from any Clearinghouse report, the employee responsible for the Clearinghouse report will submit an initial report to Clearinghouse on the first day of each term (fall, winter, spring, summer), followed by submitting reports on the mandatory reporting dates, as given by Clearinghouse. 5. The employee responsible for Clearinghouse reporting and the college’s Financial Aid Coordinator will collaborate before and after each Clearinghouse submission, and once the submission data is reported to NSLDS by Clearinghouse, the Financial Aid Coordinator will review all withdrawn students to confirm their NSLDS status is correct. If not, she will manually update the student’s NSLDS status to ensure accuracy. Anticipated Completion Date/Date Completed: November 6, 2025

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 Condition Enrollment information, including the effective date of separation from the institution, must be accurately reported to NSLDS within 30 days whenever attendance changes for a student, unless a roster will be submitted within 60 days. May 2025 graduates were reported to NSLDS outside of the maximum 60-day window. Corrective Actions Ellucian has since released a patch to address the known defect, and it has been successfully deployed by the University. Additionally, the University will continue to monitor subsequent submissions to NSC where errors were initially noted, to ensure status changes have been transmitted by the NSC in a timely manner to NSLDS. Responsible Official: Taylor Horner, University Registrar Completion Date: August 2025

Finding 2025-001: Missing Proof of Loan Exit Counseling – the auditor tested thirty-seven files, of which all were Federal Direct Loan recipients, and proof of loan exit counseling was missing for one student. As the Institution has since provided the missing exit counseling to the student, it is recommended the Institution improve control over exit interviews. Comments on Finding and Recommendation(s): It is agreed that MSP originally missed providing Direct Loan exit counseling for the 1 student found in testing. The student did not graduate or withdraw, but simply did not return for a following semester. This was an oversight in existing procedures as we were not actively looking for this population of students previously. Actions Taken or Planned: MSP immediately revised the monthly enrollment reporting process such that the initial report for each semester now includes queries to look for students who were enrolled in the prior semester, but have not returned. They will be sent Direct Loan exit counseling requirement information and an email with a URL link to complete the process at StudentAid.gov. In addition, in cases that the registrar becomes aware that a student will not return, they will share that information with Financial Aid.

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

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

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