Corrective Action Plans

Finding 1205819 (2025-003)

Material Weakness 2025

LA

Student Financial Aid Subrecipient Monitoring Eligibility

Annual and Aggregate Loan Limits The University acknowledges the finding regarding the awarding of unsubsidized loan funds in excess of annual limits without adequate supporting documentation. We recognize that federal regulations require either a valid PLUS denial or fully documented professional j...

Annual and Aggregate Loan Limits The University acknowledges the finding regarding the awarding of unsubsidized loan funds in excess of annual limits without adequate supporting documentation. We recognize that federal regulations require either a valid PLUS denial or fully documented professional judgment to support additional unsubsidized eligibility. Corrective Actions 1. Strengthened Documentation Requirements: Effective immediately, financial aid staff will maintain complete professional judgment documentation, including the rationale, supporting evidence, and approval, in the student’s file before any additional unsubsidized loan is awarded. 2. Verification Controls: A mandatory checklist has been implemented to ensure that a PLUS denial or documented professional judgment is obtained and reviewed prior to disbursement of any loan amount exceeding standard limits. 3. Staff Training: The Office of Financial Aid will conduct targeted training to reinforce Title IV loan limit rules and proper documentation standards. 4. Ongoing Monitoring: Supervisory review will be performed on all professional judgment decisions and on any loan increases exceeding the standard $2,000 annual limit. The University believes these corrective measures will address the root cause of the finding and ensure full compliance with federal loan regulations going forward.

View Audit 397569

Finding 1205818 (2025-002)

Material Weakness 2025

Dillard University

LA

Subrecipient Monitoring Student Financial Aid Reporting

Student Status Confirmation Report The University acknowledges the finding regarding the timeliness of providing required reports to support audit testing of student enrollment status. We recognize the importance of accurate and timely reporting to the student status confirmation process and regret ...

Student Status Confirmation Report The University acknowledges the finding regarding the timeliness of providing required reports to support audit testing of student enrollment status. We recognize the importance of accurate and timely reporting to the student status confirmation process and regret that the requested documentation was not supplied within the audit timeframe. Corrective Actions Taken / Planned 1. Process Redesign and Timeliness Controls The University has implemented revised internal procedures to ensure that all requested enrollment reports are generated promptly. This includes establishing defined timelines for responding to audit requests and assigning responsibility to specific staff members to track and manage reporting obligations. 2. System and Reporting Enhancements We are reviewing and updating our reporting workflow within our student information system to strengthen data retrieval capabilities and reduce delays in report generation. Additional user training will be provided to ensure staff can efficiently extract the required information. 3. Improved Communication With the Guaranty Agency The University will review past enrollment status submissions and implement additional checks to ensure that future enrollment reporting to the guaranty agency is complete, accurate, and timely. A 45-day reconciliation process has been added to verify that all required status updates have been transmitted. 4. Ongoing Monitoring The University has established ongoing oversight to ensure consistent compliance with reporting requirements. Internal reviews will be performed periodically to confirm that corrective actions remain effective. Management Conclusion We believe these measures will address the root causes identified in the finding and will ensure the timely delivery of required information for future audits. The University is committed to maintaining full compliance with federal and state reporting standards.

View Audit 397569

Finding 1205770 (2025-004)

Material Weakness 2025

Hampton University

VA

Student Financial Aid Special Tests & Provisions

Corrective Action: The University agrees with the findings. Management will perform a review of Title IV refunds to ensure credit balances are refunded to students within the required 14-day timeframe. In addition, management will review the existing system of controls related to the timely refund o...

Corrective Action: The University agrees with the findings. Management will perform a review of Title IV refunds to ensure credit balances are refunded to students within the required 14-day timeframe. In addition, management will review the existing system of controls related to the timely refund of credit balances. Further, management will reinforce control ownership and provide targeted training to individuals responsible for compliance. The actions will help to ensure that appropriate controls are in place and responsibilities are clearly defined, and instances of noncompliance are mitigated to support controls. Contact Person: Terry Nixon, Assistant Comptroller, Student Business Services Anticipated Completion Date: June 15, 2026

View Audit 397505

Finding 1205768 (2025-002)

Material Weakness 2025

Hampton University

VA

Student Financial Aid

Corrective Action : The U niversity agrees with the find ings. We will update our interna l review repoti so that we wi ll meet the enrollment status changes withi n the 60 day period. . The Program Level is updated by the SHRDEGV report and is al ready submitted in a timely manner. The time status ...

Corrective Action : The U niversity agrees with the find ings. We will update our interna l review repoti so that we wi ll meet the enrollment status changes withi n the 60 day period. . The Program Level is updated by the SHRDEGV report and is al ready submitted in a timely manner. The time status issues were addressed and updated during the Fall 2025 term merge project. We will work with IT to enhance the information included in the Comprehensive Graduation Report (CRT) to ensure complete, accurate and timely repmiing.Contact Person: Regina Cotter, University Registrar Anticipated Completion Date: June 15, 2026

View Audit 397505

Finding 1205764 (2025-001)

Material Weakness 2025

Richmont Graduate University

TN

Student Financial Aid Reporting Material Weakness

Richmont Graduate University has updated their policy for the Registrar to communicate to the Financial Aid Office AND the Administration Office when a student as fallen below half-time or has withdrawn/dropped all their coursework for the semester. The Registrar has updated the Add/Drop/Withdrawn f...

Richmont Graduate University has updated their policy for the Registrar to communicate to the Financial Aid Office AND the Administration Office when a student as fallen below half-time or has withdrawn/dropped all their coursework for the semester. The Registrar has updated the Add/Drop/Withdrawn form that requires her to sign that she has communicated to both offices. Hear is the updated for: Add/Drop/Withdrawn Form

View Audit 397502

Finding 1205711 (2025-007)

Material Weakness 2025

Paine College

GA

Student Financial Aid Internal Control / Segregation of Duties

Uniform Guidance Financial and Compliance Audit-June 30, 2025, Ending Fiscal Year Paine College has developed a structured corrective action plan to address findings (2025- 001, 2025-002, 2025-003, 2025-004, and 2025-005) identified in the Uniform Guidance Financial and Compliance Audit. The institu...

Uniform Guidance Financial and Compliance Audit-June 30, 2025, Ending Fiscal Year Paine College has developed a structured corrective action plan to address findings (2025- 001, 2025-002, 2025-003, 2025-004, and 2025-005) identified in the Uniform Guidance Financial and Compliance Audit. The institution is prioritizing the strengthening of internal controls, the improvement of financial oversight, and the enhancement of compliance monitoring to ensure responsible stewardship offederal funds and long-term institutional stability. The corrective action outlines each audit finding and the steps the College is taking to resolve the identified concerns.

View Audit 397416

Finding 1205707 (2025-006)

Material Weakness 2025

Paine College

GA

Student Financial Aid Internal Control / Segregation of Duties Subrecipient Monitoring

Uniform Guidance Financial and Compliance Audit-June 30, 2025, Ending Fiscal Year Paine College has developed a structured corrective action plan to address findings (2025- 001, 2025-002, 2025-003, 2025-004, and 2025-005) identified in the Uniform Guidance Financial and Compliance Audit. The institu...

Uniform Guidance Financial and Compliance Audit-June 30, 2025, Ending Fiscal Year Paine College has developed a structured corrective action plan to address findings (2025- 001, 2025-002, 2025-003, 2025-004, and 2025-005) identified in the Uniform Guidance Financial and Compliance Audit. The institution is prioritizing the strengthening of internal controls, the improvement of financial oversight, and the enhancement of compliance monitoring to ensure responsible stewardship offederal funds and long-term institutional stability. The corrective action outlines each audit finding and the steps the College is taking to resolve the identified concerns.

View Audit 397416

Finding 1205703 (2025-005)

Material Weakness 2025

Paine College

GA

Student Financial Aid Subrecipient Monitoring Eligibility

Uniform Guidance Financial and Compliance Audit-June 30, 2025, Ending Fiscal Year Paine College has developed a structured corrective action plan to address findings (2025- 001, 2025-002, 2025-003, 2025-004, and 2025-005) identified in the Uniform Guidance Financial and Compliance Audit. The institu...

Uniform Guidance Financial and Compliance Audit-June 30, 2025, Ending Fiscal Year Paine College has developed a structured corrective action plan to address findings (2025- 001, 2025-002, 2025-003, 2025-004, and 2025-005) identified in the Uniform Guidance Financial and Compliance Audit. The institution is prioritizing the strengthening of internal controls, the improvement of financial oversight, and the enhancement of compliance monitoring to ensure responsible stewardship offederal funds and long-term institutional stability. The corrective action outlines each audit finding and the steps the College is taking to resolve the identified concerns. Corrective Action 2025-005: Administrative and Fiscal Affairs 1235 Fifteenth Street, Augusta, GA 30901 Implement the Return to Title IV monitoring system, weekly credit balance tracking, counseling verification procedures, and strengthen coordination between Financial Aid, Registrar, and Business Office Target resolution: Spring-Summer 2026

View Audit 397416

Finding 1205695 (2025-002)

Material Weakness 2025

Miles College

AL

Student Financial Aid Cash Management Allowable Costs / Cost Principles § 200.305

Finding 2025-002 - U.S. Department of Education (USO}, Title IV Student Financial Aid Programs (significant deficiency): Information on the federal program - Federal Pell Grant Program, FAL No. 84.063, June 30,2025; Federal Work-Study Program, FAL No. 84.033, June 30, 2025; Federal Supplemental Oppo...

Finding 2025-002 - U.S. Department of Education (USO}, Title IV Student Financial Aid Programs (significant deficiency): Information on the federal program - Federal Pell Grant Program, FAL No. 84.063, June 30,2025; Federal Work-Study Program, FAL No. 84.033, June 30, 2025; Federal Supplemental Opportunity Grant Program, FAL No. 84.007, June 30, 2025; Federal Direct Student Loan Program, FAL No. 84.268, June 30, 2025; Teachers Education Assistance for College(TEACH),FAL No. 84.379, June 30, 2025. Under 2 CFR 200.305 and the U.S. Department of Education's cash management requirements at 34 CFR 668.162, institutions must draw down Title IV funds only for expenditures 1. Corrective Action Description The College now requires all drawdowns to include supporting documentation of the funds requested from GS, along with sign-offs on preparation and approval. Supporting documents are stored securely on the College's accounting drive for easy access. 2. Person Responsible and Department Diana Knighton Senior Vice President, Finance and Business Administration Miles College 5500 Myron Massey Boulevard Fairfield, AL 3506 (205) 929-1442 dknighton@miles.edu a. Implementation Timeline This procedure took effect as of July 31, 2025. b. Planned Preventive Measures Following the policy and procedures to support all drawdowns with proper documentation. c. Disagreement with the Finding None

View Audit 397405

Finding 1205691 (2025-001)

Material Weakness 2025

Miles College

AL

Student Financial Aid Matching / Level of Effort / Earmarking Subrecipient Monitoring

Finding 2025 - 001 - U.S. Department of Education (USD), Title IV Student Financial Aid Programs (material weakness): Information on the federal program - (Federal Award Identification): - Federal Pell Grant Program, FAL No. 84.063, June 30, 2025; Federal Supplemental Opportunity Grant Program, FAL ...

Finding 2025 - 001 - U.S. Department of Education (USD), Title IV Student Financial Aid Programs (material weakness): Information on the federal program - (Federal Award Identification): - Federal Pell Grant Program, FAL No. 84.063, June 30, 2025; Federal Supplemental Opportunity Grant Program, FAL No. 84.007, June 30, 2025; Federal Work-Study Program, FAL No. 84.033, June 30, 2025; Federal Direct Student Loan Program, FAL No. 84.268, June 30, 2025; Federal Teacher Education Assistance for College (TEACH), FAL No. 84.379, June 30, 2025. Institutions must determine a student's financial need by subtracting the expected family contribution and estimated financial assistance from the cost of attendance. 34 CFR 668.2 and 34 CFR 637.S(a). 1. Corrective Action Description The College has engaged a financial aid consultant to support the development of cost-of-attendance budgets and ensure they align with industry best practices, thereby making improvements to the College's financial aid operating system. After evaluating the auditors' sample of forty students, the College confirmed that no instances of over/under awarding occurred. There were clarifications and changes made to the initial cost of attendance budgets provided to the auditors that led to the questioned cost. The College will implement ongoing monitoring each semester to further enhance operational efficiency and effectiveness. The cost of attendance budgets has been uploaded into the College's financial aid system to prevent the recurrence of this issue for the current and future years. a. Responsible Person and Department Diana Knighton Senior Vice President, Finance and Business Administration Miles College 5500 Myron Massey Boulevard Fairfield, AL 3506 (205) 929-1442 dknighton@miles.edu b. Implementation Timeline January 18, 2026, for the spring semester c. Planned Preventive Measures The College hired a financial aid consultant to assist the financial aid Director with best practices and to make modifications to the ERP system to provide better operating efficiency and effectiveness. d. Disagreement with the Finding None

View Audit 397405

Finding 1205680 (2025-001)

Material Weakness 2025

East-West University

IL

Student Financial Aid Eligibility Matching / Level of Effort / Earmarking

2025-001: Incorrect Direct Loans Disbursement Amount - Student Financial Aid Cluster Assistance Listing Number 84.007, 84.033, 84.038, 84.063, 84.268, Grant Period - Year Ended August 31, 2025 Condition Found During our student file testing we noted two students out of forty were disbursed the incor...

2025-001: Incorrect Direct Loans Disbursement Amount - Student Financial Aid Cluster Assistance Listing Number 84.007, 84.033, 84.038, 84.063, 84.268, Grant Period - Year Ended August 31, 2025 Condition Found During our student file testing we noted two students out of forty were disbursed the incorrect Direct Loan amount. Based on the student’s enrollment status and need, the University over awarded the students by $1,229. We consider this error in awarding to be an instance of noncompliance of the Eligibility Compliance Requirement. Corrective Action Plan Financial Aid office will make sure the correct amount is awarded based on the student enrollment status and need of the student. EWU will make the proper adjustments to the Direct Subsidized Loan to reflect the correct amount for the two students. Responsible Person for Corrective Action Plan Director of Financial Aid Cesar Campos Implementation Date of Corrective Action Plan March 06, 2026

View Audit 397395

Finding 1205644 (2025-008)

Material Weakness 2025

Tougaloo College

MS

Student Financial Aid

"U.S. Department of Education (ED), Student Financial Assistance Programs - NSLDS Enrollment (material weakness): Management Response and Corrective Action Plan The Office of the Vice President for Enrollment Management and Student Services concur with this finding. Responsible officials acknowledge...

"U.S. Department of Education (ED), Student Financial Assistance Programs - NSLDS Enrollment (material weakness): Management Response and Corrective Action Plan The Office of the Vice President for Enrollment Management and Student Services concur with this finding. Responsible officials acknowledge the seriousness of this finding and recognize that timely and accurate NSLDS enrollment reporting is critical to the integrity of Title IV programs and the proper administration of student loan repayment obligations. The institution is committed to maintaining compliance with all federal student aid requirements and agrees that this issue represents a control weakness that required immediate attention. While the error affected a limited number of students, officials understand the potential systemic implications and have taken corrective measures accordingly. Responsible officials will continue to monitor enrollment reporting through periodic reconciliations and management oversight to ensure all enrollment status changes—including withdrawals—are reported accurately and within the prescribed regulatory timeframe. Management believes the corrective actions implemented will prevent recurrence of this issue and demonstrate the institution’s commitment to compliance and accountability. "

View Audit 397293

Finding 1205643 (2025-007)

Material Weakness 2025

Tougaloo College

MS

Student Financial Aid

Finding 2025-007 U.S. Department of Education (USDE), Title IV Student Financial Aid Programs – Policy & Procedures Manual (material weakness): Management Response and Corrective Action Plan The Office of the Vice President for Enrollment Management and Student Services concur with this finding. We ...

Finding 2025-007 U.S. Department of Education (USDE), Title IV Student Financial Aid Programs – Policy & Procedures Manual (material weakness): Management Response and Corrective Action Plan The Office of the Vice President for Enrollment Management and Student Services concur with this finding. We recognize that the maintenance of a current and comprehensive Policy & Procedures Manual is a fundamental requirement under 34 CFR 668.16 and 34 CFR 668.34 to ensure the consistent and accurate administration of Title IV federal student aid. While the institution maintained operational compliance with Department of Education regulations throughout the audit period, we acknowledge that the formal documentation had not been updated since the 2018-2019 academic year. To address this finding and mitigate any risk of systemic processing errors, the Student Financial Aid Office has completed a comprehensive revision of the Financial Aid Policy & Procedures Manual. • Completion Status: The manual has been fully updated to reflect the 2024-2026 academic cycles. • Scope: The updated manual incorporates current federal regulations for all major programs, including the Federal Pell Grant, FSEOG, Federal Work-Study, Federal Direct Student Loans, and TEACH Grant programs. • Compliance: The new documentation aligns with the latest Federal Student Aid Handbook guidance and ensures that all institutional policies meet current USDE requirements. To ensure this remains a "one-time" finding rather than a recurring issue, the Financial Aid Director has implemented an Annual Review Protocol. Beginning in June each year, the manual will undergo a formal review and update cycle to coincide with the release of the new award year’s federal guidelines.

View Audit 397293

Finding 1205642 (2025-006)

Material Weakness 2025

Tougaloo College

MS

Student Financial Aid Internal Control / Segregation of Duties

Finding 2025-006 U.S. Department of Education (USDE), Title IV Student Financial Aid Programs – Federal Work-Study Community Service (material weakness): Management Response and Corrective Action Plan Tougaloo College acknowledges the auditor’s finding regarding the 7% Federal Work-Study (FWS) commu...

Finding 2025-006 U.S. Department of Education (USDE), Title IV Student Financial Aid Programs – Federal Work-Study Community Service (material weakness): Management Response and Corrective Action Plan Tougaloo College acknowledges the auditor’s finding regarding the 7% Federal Work-Study (FWS) community service expenditure requirement under 34 CFR 675.18. While the College has a storied history of community engagement, we recognize that the administrative tracking and placement of students into qualifying FWS community service positions for the 2024-25 academic year did not meet federal mandates. Management accepts the recommendation to strengthen internal controls and is committed to ensuring that our Student Financial Aid Office has the oversight necessary to maintain compliance and protect our participation in Title IV programs. Corrective Action Plan (CAP): • Expanded Community Partnerships: The Office of Enrollment Management and Student Services will immediately re-establish and formalize Memorandums of Understanding (MOUs) with local non-profit organizations and governmental agencies in the Jackson, MS metropolitan area. These partnerships will prioritize literacy and mathematics tutoring (consistent with the FWS "America Reads/America Counts" initiatives) and social service support. • Enhanced Internal Monitoring: The Director of Student Financial Aid will implement a monthly FWS Allocation Tracker. This internal control will monitor FWS expenditures specifically for community service to ensure the 7% threshold is reached well before the end of the academic year. • Administrative Oversight: The Vice President for Enrollment Management and Student Services will conduct a formal quarterly review of these trackers. This ensures that any shortfall in community service placements is identified early enough to initiate a Community Service Waiver request to the U.S. Department of Education, should unique circumstances arise. • Student Awareness Campaign: We will integrate community service FWS opportunities into our student orientation and "Federal Work-Study Fair" to ensure students are aware of these high-impact service opportunities. Completion Date: August 15, 2026

View Audit 397293

Finding 1205641 (2025-005)

Material Weakness 2025

Tougaloo College

MS

Student Financial Aid

Finding 2025-005 U.S. Department of Education (USDE), Title IV Student Financial Aid Programs – Fiscal Operations Report and Application to Participate (FISAP) (material weakness): Management Response and Corrective Action Plan The Office of Enrollment Management and Student Services acknowledge the...

Finding 2025-005 U.S. Department of Education (USDE), Title IV Student Financial Aid Programs – Fiscal Operations Report and Application to Participate (FISAP) (material weakness): Management Response and Corrective Action Plan The Office of Enrollment Management and Student Services acknowledge the auditor’s finding regarding the discrepancies in the Fiscal Operations Report and Application to Participate (FISAP) for the 2024-25 award year. We recognize the criticality of maintaining accurate records to support federal funding eligibility and are committed to resolving the underlying systemic issues identified. The College concurs with the finding. It was determined that the inaccuracies in Part 2, Section F (Information on Eligible Aid Applicants) resulted from a lack of synchronization between the latest federal reporting requirements and the institution’s current software version. Specifically, the manual compilation of data was used in lieu of automated Jenzabar reports due to a pending system update. To ensure future compliance and the accuracy of all Title IV reporting, the following actions have been initiated: • System Synchronization & Updates: The Information Technology (IT) Department, in coordination with the Office of Financial Aid, has established a priority schedule for all Jenzabar FA/SIS system updates. A mandatory "Systems Readiness" review will now occur 60 days prior to the FISAP submission deadline to ensure all regulatory patches are installed. • Standardization of Reporting Procedures: Management has mandated that all future FISAP data must be pulled directly from the Jenzabar system modules. Manual entries will only be permitted as a secondary verification measure to ensure data integrity against system-generated reports. • Inter-Departmental Oversight: A new "FISAP Task Force" comprising representatives from Financial Aid, IT, and Business/Finance has been formed. This group will perform a preliminary review of the FISAP data 30 days before submission to verify that the system-generated data aligns with institutional records and federal criteria (34 CFR 675.19 and 34 CFR 676.19). • Technical Assistance Engagement: The College is currently coordinating with the U.S. Department of Education to facilitate an On-site Title IV Technical Assistance & Support (OTA) visit. This visit will include a specific focus on optimizing our SIS reporting capabilities for campus-based program funds. 4) Implementation Timeline • System Update Completion: Immediate (April 2026) • Standard Operating Procedure (SOP) Revision: May 15, 2026 • On-site Technical Assistance Visit: Expected April/May 2026

View Audit 397293

Finding 1205640 (2025-004)

Material Weakness 2025

Tougaloo College

MS

Student Financial Aid Internal Control / Segregation of Duties

Finding 2025-004 U.S. Department of Education (USDE), Title IV Student Financial Aid Programs – Cost of Attendance Budgets (material weakness): Management’s Response and Corrective Action Plan The College concurs with this finding. We acknowledge that the absence of documented Cost of Attendance (CO...

Finding 2025-004 U.S. Department of Education (USDE), Title IV Student Financial Aid Programs – Cost of Attendance Budgets (material weakness): Management’s Response and Corrective Action Plan The College concurs with this finding. We acknowledge that the absence of documented Cost of Attendance (COA) budgets and the resulting inability to verify financial need calculations constitute a significant breakdown in internal controls. The College is committed to immediate remediation to ensure full compliance with Title IV regulations. 1) Corrective Action Plan (CAP) To address the root causes of this finding, the College will implement the following measures: • Establishment of Formal COA Budgets: The Financial Aid Office will immediately develop and document standardized COA budgets for the 2025-2026 academic year. These budgets will account for all required components (tuition, fees, housing, food, books, supplies, transportation, and personal expenses) as required by 34 CFR 668.2. • System Integration: We will update our Student Information System (SIS) to automate the application of these COA budgets to student records, ensuring that "Unmet Need" is calculated electronically and consistently for every applicant. • Formalized Internal Controls: A new Standard Operating Procedure (SOP) manual for Financial Aid Packaging will be authored and implemented by June 1, 2026. This manual will mandate the retention of COA tables used for each award year to provide a clear audit trail. • Enhanced Oversight and Training: The Vice President for Enrollment Management and Student Services will initiate a mandatory training program for all financial aid staff regarding federal packaging requirements. • Internal Quality Assurance (IQA): Beginning April 15, 2026, the College will implement a monthly "Mini-Audit" process where a random sample of 10% of student files is reviewed by a third-party or a non-conflicted administrator to verify COA accuracy before disbursements are finalized. 2) Designated Responsible Party-Director of Financial Aid. 3) Anticipated Completion Date-June 30, 2026

View Audit 397293

Finding 1205639 (2025-003)

Material Weakness 2025

Tougaloo College

MS

Student Financial Aid

Finding 2025-003 U.S. Department of Education (USDE), Title IV Student Financial Aid Programs – Withdrawals & Return of Title IV Funds (material weakness): The Office of Enrollment Management and Student Services accept the auditor’s findings regarding the administration of Title IV funds and the Re...

Finding 2025-003 U.S. Department of Education (USDE), Title IV Student Financial Aid Programs – Withdrawals & Return of Title IV Funds (material weakness): The Office of Enrollment Management and Student Services accept the auditor’s findings regarding the administration of Title IV funds and the Return of Title IV (R2T4) calculations. We recognize that the accurate tracking of student withdrawals—particularly unofficial withdrawals—is critical to maintaining federal compliance and institutional integrity. While this was not a repeat finding, we view the "systemic" nature of the observation with the utmost seriousness. The College is committed to rectifying the procedural gaps that led to incorrect calculations and late submissions. To address the Cause identified (inadequate tracking) and mitigate the Effect of potential liabilities, the following measures are being implemented immediately: • Enhanced Tracking for Unofficial Withdrawals: The Registrar’s Office, in coordination with Information Technology (IT), will implement a bi-weekly "Internal Attendance & Participation" audit. This automated report will flag students with zero academic engagement across all registered courses, allowing the Financial Aid office to identify unofficial withdrawals well before the 45-day federal deadline. • Standardization of Calendar Dates: The Director of Financial Aid has revised the R2T4 calculation worksheet to include a "Mandatory Calendar Verification" step. This ensures that the start/end dates and scheduled breaks used in calculations strictly align with the approved institutional academic calendar. • Staff Training and Capacity Building: All Financial Aid staff responsible for R2T4 calculations will undergo mandatory Title IV compliance training. Furthermore, a secondary review process has been established where a senior staff member must sign off on all calculations exceeding $1,000 to ensure accuracy before funds are returned. • Inter-Departmental Communication: A new protocol has been established between the Office of Student Services and the Financial Aid Office to ensure that "Administrative Withdrawals" (e.g., disciplinary or medical) are communicated within 48 hours of the determination date. Anticipated Completion Date: October 31, 2026 The College is dedicated to resolving these discrepancies and ensuring that $13,100 in questioned costs—and all future disbursements—are handled with precision. We believe these enhanced internal controls will prevent a recurrence and satisfy the requirements of the U.S. Department of Education.

View Audit 397293

Finding 1205638 (2025-002)

Material Weakness 2025

Tougaloo College

MS

Student Financial Aid HUD Housing Programs Material Weakness

Finding 2025-002 U.S. Department of Education (USDE), Title IV Student Financial Aid Programs – Federal Work-Study Program (material weakness): Management’s Response and Corrective Action Plan Tougaloo College acknowledges the findings identified in the audit regarding the Federal Work-Study (FWS) P...

Finding 2025-002 U.S. Department of Education (USDE), Title IV Student Financial Aid Programs – Federal Work-Study Program (material weakness): Management’s Response and Corrective Action Plan Tougaloo College acknowledges the findings identified in the audit regarding the Federal Work-Study (FWS) Program for the period ending June 30, 2025. We recognize the gravity of the "material weakness" designation and the systemic nature of the documentation exceptions noted. As the Vice President overseeing these services, I am committed to a rigorous overhaul of our FWS administrative protocols to ensure full compliance with 34 CFR 675.16. To address the root causes of these findings, the College is implementing the following measures immediately: • Mandatory Supervisor Training: All department heads and direct supervisors of FWS students must complete a mandatory compliance seminar. This training emphasizes that no student may be scheduled to work during designated class times and that no wages will be disbursed without a verified, contemporaneous timesheet. • Enhanced Timesheet Verification: We are transitioning to a standardized digital submission process. This system will require: o Verification of the student’s course schedule against hours worked to prevent overlap. o Electronic signatures from both the student and supervisor, timestamped to ensure they are captured prior to payroll processing. • Documentation and Record Retention: The Office of Financial Aid, in coordination with Payroll, will implement a "No Document, No Pay" policy. Documentation for any pay rate changes must now be uploaded and approved by the VP for Enrollment Management and Student Services before being reflected in the Jenzabar system. • Internal Monthly Audits: Starting next month, our internal compliance team will conduct random monthly spot-checks of FWS files (10% of active participants) to ensure all timesheets are present, complete, and accurately reflect hours worked. The College is currently reviewing the identified questioned costs of $10,830.00. We will work closely with the U.S. Department of Education to determine the appropriate restitution or adjustment required for any overpayments resulting from missing documentation. We are dedicated to rectifying these systemic issues and ensuring this does not remain a repeat finding in future audit cycles. Our goal is to maintain the highest level of integrity in our Title IV Student Financial Aid Programs.

View Audit 397293

Finding 1205637 (2025-001)

Material Weakness 2025

Tougaloo College

MS

Student Financial Aid Eligibility Internal Control / Segregation of Duties

Finding 2025-001 U.S. Department of Education (USDE), Title IV Student Financial Aid Programs – Satisfactory Academic Progress (material weakness): Management’s Response and Corrective Action Plan Tougaloo College acknowledges the findings identified in the audit for the fiscal year ending June 30, ...

Finding 2025-001 U.S. Department of Education (USDE), Title IV Student Financial Aid Programs – Satisfactory Academic Progress (material weakness): Management’s Response and Corrective Action Plan Tougaloo College acknowledges the findings identified in the audit for the fiscal year ending June 30, 2025, regarding Finding 2025-001 (Material Weakness). We recognize the gravity of the systemic issues related to the monitoring of Satisfactory Academic Progress (SAP) and the associated questioned costs of $346,764.00. The College is committed to full compliance with 34 CFR 668.34 and is implementing the following corrective actions to ensure the integrity of our Title IV Student Financial Aid Programs. • Automation and System Integration: The College is transitioning from manual SAP monitoring to an automated tracking system within our Student Information System (SIS). This will ensure that academic standing—specifically GPA and completion rates are calculated systematically at the end of each Spring Semester. • Audit of Appeal Documentation: We are establishing a centralized digital repository for all SAP appeals. Effective immediately, no Title IV funds will be disbursed to students on financial aid probation without a documented, approved appeal and a corresponding academic plan on file. • Staff Training and Accountability: The Office of Financial Aid will undergo mandatory training focused specifically on federal SAP criteria. We have revised our internal "Check and Balance" protocol, requiring a secondary review by the Director of Financial Aid before any student failing SAP is cleared for disbursement. • Annual Policy Review: In alignment with the Auditor’s Recommendation, Tougaloo College will conduct a comprehensive annual evaluation of all students. This evaluation will be reconciled against the Registrar’s records to ensure data consistency. • We have updated our SAP policy to allow us to review at end of each Spring The College has already begun the look-back process to review the eligibility of the 16 students identified in the sample. We anticipate that the new automated monitoring and revised internal controls will be fully operational by the start of the Fall 2026 semester to prevent any further repeat findings.

View Audit 397293

Finding 1205562 (2025-005)

Material Weakness 2025

The Shaw University, Inc.

NC

Student Financial Aid Internal Control / Segregation of Duties Special Tests & Provisions

Name of Responsible Individual: Vice President of Enrollment Management (Dr. Stacey Sowell), University Registrar (Charee Ellison) Corrective Action: The University concurs with this finding. Shaw University acknowledges the finding regarding variances between institutional records and the status re...

Name of Responsible Individual: Vice President of Enrollment Management (Dr. Stacey Sowell), University Registrar (Charee Ellison) Corrective Action: The University concurs with this finding. Shaw University acknowledges the finding regarding variances between institutional records and the status reported in NSLDS. For students 1-3 listed for campus enrollment details, the students withdrew then subsequently re-enrolled. The University, to date has had static to confer degrees which do not coincide with the required timeframe of NSLDS reporting. The University will change degree conferral dates to better coincide with timely NSLDS reporting. Management will continue to monitor this process to ensure ongoing compliance. Anticipated Completion Date: May 15, 2026

View Audit 397245

Finding 1205560 (2025-004)

Material Weakness 2025

The Shaw University, Inc.

NC

Student Financial Aid

Name of Responsible Individual: Vice President of Enrollment Management (Dr. Stacey Sowell), Director of Financial Aid (Dr. Ojebe Ifegwu) Corrective Action: The University concurs with the finding and acknowledges the difference between the auditor’s calculations and what was determined as the varia...

Name of Responsible Individual: Vice President of Enrollment Management (Dr. Stacey Sowell), Director of Financial Aid (Dr. Ojebe Ifegwu) Corrective Action: The University concurs with the finding and acknowledges the difference between the auditor’s calculations and what was determined as the variance of R2T4. To ensure full compliance with federal Return to Title IV (R2T4) requirements and to strengthen institutional oversight, Shaw University will implement enhanced processes designed to improve accuracy, documentation, and accountability. Each R2T4 calculation will undergo a dual review process in which one Financial Aid team member completes the calculation and a second independently verifies it before any returns are processed. The University will also maintain comprehensive documentation and audit trail for all R2T4 files, including withdrawal documentation, calculation worksheets, COD records, disbursement summaries, and proof of timely returns, stored systematically to support audit readiness and internal review. To reinforce oversight, management will reconcile internal Financial Aid records with the Business Office and COD on a scheduled basis, conduct monthly or biweekly reconciliations for Pell Grants, Direct Loans, and campus-based funds, and review open balances and disbursement records before posting or adjusting aid. Financial Aid staff will continue to receive annual and periodic training on R2T4 regulations, updated federal guidance, and internal process revisions to ensure consistent application of rules. Additionally, management will conduct periodic internal audits of R2T4 files to identify potential issues proactively and respond with timely corrective measures. These strengthened procedures will ensure that future R2T4 calculations are accurate, fully documented, and completed within federally required timeframes, thereby maintaining strong compliance, reinforcing internal controls, and meeting all expectations for federal oversight. Anticipated Completion Date: April 30, 2026

View Audit 397245

Finding 1205557 (2025-003)

Material Weakness 2025

The Shaw University, Inc.

NC

Student Financial Aid Internal Control / Segregation of Duties Reporting

Name of Responsible Individual: Vice President of Enrollment Management (Dr. Stacey Sowell), Director of Financial Aid (Dr. Ojebe Ifegwu) Corrective Action: The University concurs with the findings. Shaw University acknowledges the findings regarding variances between institutional records and the a...

Name of Responsible Individual: Vice President of Enrollment Management (Dr. Stacey Sowell), Director of Financial Aid (Dr. Ojebe Ifegwu) Corrective Action: The University concurs with the findings. Shaw University acknowledges the findings regarding variances between institutional records and the amounts reported on the FISAP, as well as the delay in submitting corrections by the required deadline. The variances were due to insufficient reconciliation between the University’s records and the FISAP prior to submission. In addition, controls were not adequate to ensure that identified discrepancies were corrected within the required timeframe. The University has since completed a full reconciliation of the FISAP, and further corrections will be made. To prevent recurrence, the University has implemented procedures requiring a formal reconciliation of supporting records to the FISAP prior to submission, along with enhanced review and approval controls to ensure accuracy and timely reporting. Management will continue to monitor this process to ensure ongoing compliance. Anticipated Completion Date: April 30, 2026

View Audit 397245

Finding 1205553 (2025-002)

Material Weakness 2025

The Shaw University, Inc.

NC

Student Financial Aid Matching / Level of Effort / Earmarking

Name of Responsible Individual: Vice President of Enrollment Management (Dr. Stacey Sowell), Director of Financial Aid (Dr. Ojebe Ifegwu) Corrective Action: The University concurs with the finding and will provide professional justification for the students identified in the audit testing; however, ...

Name of Responsible Individual: Vice President of Enrollment Management (Dr. Stacey Sowell), Director of Financial Aid (Dr. Ojebe Ifegwu) Corrective Action: The University concurs with the finding and will provide professional justification for the students identified in the audit testing; however, to strengthen internal controls and prevent potential over awards, the Financial Aid Office will enhance cross departmental communication through routine reconciliation meetings and real time reporting of enrollment, housing, scholarship, and waiver changes, implement a double review process in which an assigned counselor and secondary counselor verify aid packages against COA and financial need before disbursement, and provide annual staff training on need analysis, COA construction, Title IV over award regulations (34 CFR 673.5), and proper use of SIS tools to identify conflicts, ensuring stronger compliance and proactive prevention of award discrepancies. Anticipated Completion Date: April 30, 2026

View Audit 397245

Finding 1205549 (2025-001)

Material Weakness 2025

The Shaw University, Inc.

NC

Cash Management Student Financial Aid Internal Control / Segregation of Duties

Name of Responsible Individual: Vice President of Financial Operations/CFO (Michelle Lane) Corrective Action: The University concurs with the findings. Shaw University acknowledges that this finding is a repeat condition related to excess cash balances for Pell Grant, Direct Loan, and FSEOG funds no...

Name of Responsible Individual: Vice President of Financial Operations/CFO (Michelle Lane) Corrective Action: The University concurs with the findings. Shaw University acknowledges that this finding is a repeat condition related to excess cash balances for Pell Grant, Direct Loan, and FSEOG funds not being eliminated within the required seven business days. Management has determined that prior corrective actions were not sufficiently formalized or consistently executed, particularly with respect to reconciliation and monitoring controls. Since that time, the University has strengthened its internal controls over Title IV cash management. A formal monthly reconciliation between G5 drawdowns and the general ledger has been implemented to ensure excess cash balances are identified and resolved timely. In addition, procedures have been revised to limit drawdowns to actual or immediate disbursement needs, and monitoring controls have been established to ensure compliance with the seven-business-day requirement. Management will continue to monitor these processes to ensure ongoing compliance with federal cash management regulations. Anticipated Completion Date: June 30, 2026

View Audit 397245

Finding 1205544 (2025-103)

Material Weakness 2025

Bay County District School Board

FL

Special Tests & Provisions Student Financial Aid Material Weakness § 200.303

Finding Number: 2025-103 The deficiencies resulted from the absence of a comprehensive, system-based control structure capable of: ● Enforcing secure system access protocols, including multi-factor authentication The institution will implement multi-factor authentication (MFA) across all financial a...

Finding Number: 2025-103 The deficiencies resulted from the absence of a comprehensive, system-based control structure capable of: ● Enforcing secure system access protocols, including multi-factor authentication The institution will implement multi-factor authentication (MFA) across all financial aid and student information systems to: ● Protect Title IV data from unauthorized access ● Align with federal information security expectations ● Ensure compliance with institutional cybersecurity policies Anticipated Completion Date: 8/31/2026 Responsible Contact Person: Angela Reese

View Audit 397241

Corrective Action Plans

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