Corrective Action Plans

The University has found a critical breakdown in communication between the Ranch Management department and the Registrar’s Office, stemming from informal, ad hoc processes that have not scaled with institutional needs. Specifically, there is no formal mechanism to ensure that updates to student statuses for the ranch management program are consistently reported or verified. To prevent recurrence of this issue, a process is being implemented that all Non-Degree programs will now be required to perform formal degree audits within the student information system. This ensures consistency in processing and aligns with practices currently used for degree-seeking students. Targeted training and communication will be provided to all Non-Degree program administrators to ensure clarity on new expectations, tools, and timelines. The Registrar’s Office will conduct periodic audits of non-degree program records to verify compliance and identify any further process improvements.

It was discovered that for one student a transcription error was made when transcribing the LDA (last date of attendance) from the student’s return of funds worksheet to SFA’s and Registrar’s enrollment tracking document of return of funds students. This student was an unofficial withdrawal at the end of the Fall 2024 semester. The Compliance Officer created a RT24 workflow tracking worksheet to identify enrollment reporting dates and ensure communication between SFA and the Registrar. This includes, but is not limited to, unofficial withdrawals with a LDA, all Fs with a LDA, and Q drops with an LDA. There may be other reasons there will be different enrollment dates, and those are also charted. The Compliance Officer will now run a query from PeopleSoft that pulls return of funds information directly from the PeopleSoft worksheet. This query will be imported into a tracking worksheet to ensure accurate enrollment reporting dates. This new tracking worksheet will remove the need for any additional manual updates to enrollment data tracking and reduce the possibility of future transcription errors.

The University has implemented data checks for program/plan issues as part of our 12th class day reporting/clean-up. Institutional Research will run these with their other data checks. Any records flagged for errors and anomalies will be reviewed and corrected by the Registrar’s Office including any updates to enrollment reporting with the National Student Clearinghouse. The University also implemented targeted training for staff in the Brite Divinity School on accurate plan code assignment and its direct impact on enrollment reporting. The enhanced training and communication protocols will significantly reduce the risk of similar human errors.

Finding 2025-001 - Special Tests and Provisions - Enrollment Reporting (Noncompliance and Significant Deficiency) Identification of the Federal Program - Student Financial Aid Cluster - Assistance Listing Nos. 840007, 84.033, 84.038, 84.063, and 84.268. Criteria - Institutions are required to report enrollment information under the PELL grant and the Direct loan program via the National Student Loan Data System (NSLDS). The administration of the Title IV programs depends heavily on the accurace and timeliness of the enrollment statuses, program information, and effective dates reported to NDLDS. Institutions are responsible for accurate reporting. According to 34 CFR 685.309(2), the University is required to notifly the Department of Education via the NDLDS if a "student has ceased to be enrolled on at least half-time basis for the period for which the loan was intended". Changes to status are required to be reported within 30 days of becoming aware of the status changing, or with the next schedule transmission of statuses if the scheduled transmission is within 60 days. Condition - A sample of 40 student were selected from the population of all students wo Identification of the Federal Program - Student Financial Aid Cluster - Assistance Listing Nos. 84.007, 84.033, 84.038, 84.063, and 84.268. Criteria - Institutions are required to report enrollment information under the Pell grant and the Direct loan program via the National Student Loan Data System (NSLDS). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and verify student enrollment statuses, program information, and effective dates reported to NSLDS. Institutions are responsible for accurate reporting. According to 34 CFR 685.309(2), the University is required to notify the Department of Education via the NSLDS if a “student has ceased to be enrolled on at least a half-time basis for the period for which the loan was intended”. Changes to status are required to be reported within 30 days of becoming aware of the status change, or with the next schedule transmission of statuses if the scheduled transmission is within 60 days. Condition - A sample of 40 students were selected from the population of all students who received federal student financial aid during the year ended May 31, 2025. We obtained the student records and tested compliance with federal regulations for the specific loans and grants. For 5 out of the 40 students selected for Enrollment Reporting testing, the status change was not reported within the 60-day reporting window after the status change was effective. For 9 out of the 40 students selected for Enrollment Reporting testing, the status change was not reported to NSLDS. For 9 out of the 40 students selected for Enrollment Reporting testing, the status change effective date was not accurately reported to NSLDS. For 2 out of the 40 students selected for Enrollment Reporting testing, the status of the student was not accurately reported to NSLDS. ause - The University’s processes of internal controls for reporting student status changes to NSLDS were not adequate. Effect - Student status changes were not reported to NSLDS within the required timeframe. Identification of Repeat Finding - Repeat finding of prior year finding 2024-001. Recommendation - We recommend the University revise its processes for reporting status changes to NSLDS. The University should implement a process to review, update, and verify enrollment statuses that appear on the Enrollment Reporting roster files. We also recommend that management implement controls to ensure reported changes are timely and correctly reported to the NSLDS. Views of Responsible Officials - Management agrees with the finding. Out of the 25 exceptions included in this finding, 8 were properly and timely reported by the University to the third-party service provider. The University has continued to work with its third-party service provider to identify the root cause of the reporting issues. The primary cause stems from varied start dates of academic modules (5-week, 8-week, and 16-week) within a semester. These overlapping start dates often cross the monthly NSLDS upload periods. As students adjust their schedules, changes in the current Student Information System (SIS) may inadvertently override previously reported data. The University’s current SIS has reached the end of its useful life and was not designed to handle the modular academic formats now essential for serving modern student needs. Additionally, the SIS lacks functionality to directly export enrollment data to the third-party service provider resulting in manual intervention and the aggregation of multiple files for upload. This manual process increases the risk for reporting errors. Corrective Action Plan for Finding 2025-001 – In May 2025, the University executed a contract to implement a new and modern Student Information System. This multi-year implementation project is expected to be completed by Fall 2029, with a possibility of early completion by Fall 2028. During the interim period, the University will continue to emphasize data validation and accuracy through staff training and monitoring. To further support the reporting process, the University engaged a former employee on a contractual basis during the fiscal year ended May 31, 2025. This individual brings extensive experience in enrollment reporting to both the National Student Clearinghouse (NSC) and the National Student Loan Data System (NSLDS), providing valuable expertise during this transitional phase.

Single AUdit Report for 2024-2025 Reference/Finding Number 2025-001 Management's Planned Corrective Action Management acknowledges and understands the finding associated with Eligibility. The student's Pell award has already been corrected and accepted by COD. Management is working with IT to automate the enrollment change report to be sent on a weekly basis to validate that all increases in hours have been appropriately updated and processed. This will also become part of our required annual reconciliation process of the Pell grant program. Responsible Official Bridget Moore Director of Student Financial Services Abilene Christian University Estimated Completion Date July 24, 2025

Finding 2025-001 Federal Agency Name: U.S. Department of Education Program Name: Student Financial Assistance Cluster ALN: 84.268 Finding Summary: For a small group of students with very specific circumstances, our software’s enrollment report autopopulated an effective date of enrollment change that did not match the actual effective date. UMHB did not realize that these specific circumstances would require manual processes to identify and correct the enrollment report prior to submission. As a result, four students had incorrect status change effective dates reported to NSLDS. Responsible Individuals: Trent Bridges, Director Data Quality and Institutional Analytics Corrective Action Plan: UMHB plans to implement the following: 1. Review all the coding on system reports used for NSLDS reporting to assess accuracy and completeness of the data based on any changes in business practice and make updates to system reports as necessary. 2. Update internal process to document any required special handling of records based on system limitations. 3. Reassess system report and processes used for NSLDS reporting prior to the beginning of each fall and spring semester. Anticipated Completion Date: Fall 2025

Student Financial Assistance Cluster Assistance Listing Number 84.268 Federal Direct Student Loans, and 84.063 Federal Pell Grant Program U.S. Department of Education Program Year 2024-2025 Criteria or Specific Requirement – Special Tests and Provisions – Enrollment Reporting – 34 CFR Sections 690.83(b)(2) and 685.309 Condition – Student enrollment and program information was not communicated to the National Student Loan Data System (NSLDS) timely or accurately Questioned Costs – N/A Context – A total of 7 out of 40 students tested were noted to have at least 1 error in enrollment or program information reported to NSLDS within the required 60 days. Our sample was not, and was not intended to be, statistically valid. Effect – NSLDS was not notified of student status changes or program information in accordance with compliance requirements. Cause – The University did not have effective internal control processes in place to ensure the accurate collection, review, and reporting of student status changes occurred timely or accurately. The recent turnover in personnel resulted in a lack of oversight as well. Indication as a Repeat Finding – Yes Recommendation – The University should review its internal controls surrounding the enrollment reporting process and ensure internal controls provide for the timely and accurate reporting of student status changes. Views of Responsible Officials and Planned Corrective Actions – Tina Petersen, Registrar, will oversee the two-fold corrective action plan. First, we are immediately reviewing our degree posting policy and dates to create a more effective and standardized process. This policy review will enable us to properly assess any delayed completers and ensure that students are "completed" in our systems and reported to NSLDS in a more timely and accurate manner. Additionally, we are updating our formal, step-by-step written procedure manual for all enrollment reporting processes, with a specific focus on degree conferral and the subsequent reporting to NSLDS. This updated manual will serve as a crucial resource to ensure procedural consistency, especially during personnel changes. Second, we are enhancing our training protocols and internal controls. All staff members involved in the NSLDS reporting process will be required to attend mandatory, recurring training to ensure they are up-to-date on all compliance requirements. We will also implement a more robust system of checks and balances to verify the accuracy of the data before it is submitted to NSLDS. By taking these steps, the University is dedicated to improving its internal controls and fully remediating this finding. The corrective action plan will be implemented by November 1, 2025. Office of Financial Services PO Box 11000 Oklahoma City, OK 73136 405.425.5190 financialservices@oc.edu

Student Financial Assistance Cluster Assistance Listing Number 84.268 Federal Direct Student Loans, and 84.063 Federal Pell Grant Program U.S. Department of Education Program Year 2024-2025 Criteria or Specific Requirement – Disbursements to or on behalf of students, 34 CFR Section 668.164(h)(2) Condition – Students did not receive refunds within the required timeframe Questioned Costs – N/A Context – 7 out of 25 students tested received their credit balance refund more than 14 days after the credit balance was generated. All but 1 of these students received their refund within 16 days of the generation of the credit balance. Our sample was not, and was not intended to be, statistically valid. Effect – Noncompliance with federal regulations requiring timely disbursement of credit balance refunds Cause – Due to the high volume of credit balance refunds being processed, the University encountered operational constraints that prevented all refunds from being generated within the designated 14-day timeframe. Indication as a Repeat Finding – N/A Recommendation – To ensure timely refund of student credit balances, implement a control that flags any refund not processed before the end of the 14-day timeframe for immediate review and escalation. Additionally, establish a monitoring report to track refund timeliness weekly and reinforce accountability for processing within the required timeframe. Views of Responsible Officials and Planned Corrective Actions – Amy Schlup, Director of Student Financial Services, and Carrie Hamilton, Assistant Director of Financial Aid, will oversee the corrective action plan. As part of this process, they will review the daily Student Refund Report to identify and assist the personal financial counselor in expediting student refunds. The Student Financial Services team will also review and retrain on the proper procedures for processing refunds within the required timeframe. The corrective action plan is already in progress and will be fully implemented by October 1, 2025. Office of Financial Services PO Box 11000 Oklahoma City, OK 73136 405.425.5190 financialservices@oc.edu

Corrective Action Plan (CAP for Finding 2025-001) Date: 2 October 2025 Responsible official: Frederick L. Clement, Executive Vice President Management has corrected the finding by taking the following action: First, the institution entered into a professional services agreement with Higher Education Assistance Group to provide a comprehensive business process review of its financial aid operations. The objective of this review is to improve upon the functionality of processes, internal controls, and systems to ensure regulatory compliance and the effectiveness of service deliverables to students receiving financial aid. This review will include updates to policies, procedures, and internal controls for the import and export of electronic records, document tracking and file review, packaging and awarding, satisfactory academic progress, disbursement and reconciliation, withdrawal and Return to Title IV. Workflow and gap analysis will be performed to ensure intraoffice Title IV program compliance and best practices. Second, the institution has entered into a professional services agreement with Higher Education Assistance Group to provide interim staffing and third-party federal student aid processing including, but not limited to, counseling students and families on financial aid options, assisting with the management of Federal Direct Loan and Federal Graduate PLUS Loan programs to include student eligibility, file review, awarding, and origination and disbursement authorization using Populi, COD and other Department of Education software. In addition, Higher Education Assistance Group will provide additional Title IV training for personnel involved in federal student aid processing. With more than 35 years of experience, Higher Education Assistance Group and its team of seasoned consultants, all of whom have worked in federal student aid administration, whether in public/private colleges and universities or for the Department of Education itself, specializes in the compliant administration of Title IV student financial aid programs. The institution will adopt a supplemental internal control to cross-check student eligibility for Direct PLUS loans to ensure that an over-award is not originated and disbursed. Anticipated completion date: November 15, 2025

Auditors noted that for two of the six sampled students, funds were returned to ED more than 45 days after the date the University determined the student had withdrawn. For one selection, a Return of Title IV calculation was performed timely, but an administrative error caused the disbursement to be delayed eight months. For the second selection, the University was notified of withdrawal in early March 2025 and student was included in registrar’s withdrawal listing, but was missed in review by Student Financial Services until late April 2025. Contact Person(s): Vickie Rekov, VP Enrollment Services; Roger Wilson, Associate Director of Financial Aid, SFS; Ryan Porter, CFO and Bernie Rundquist, Controller Explanation and specific reasons for disagreement with the audit finding or that corrective action is not required (if applicable): N/A Corrective action planned: All employees in Student Financial Services and Accounting Office involved in the reporting, distribution, drawdown and return of federal funds have reviewed the criteria under 34 CFR 668.22 The two departments involved will be meeting in the month of September 2025 to review policies and procedures to ensure controls exist and are well documented to ensure funds are returned timely. In-charge personnel will gather training resources to educate those involved in the reporting, disbursement and return of Title IV Funds. Anticipated completion date: October 2025

The Office of the University Registrar and the Office of the Law Registrar have reviewed current policies and procedures related to the reporting of status changes in NSLDS. The Office of the Law Registrar will report status changes to National Student Clearinghouse no later than 30 days after degree conferral but no later than June 30. In additional they will follow up with NSC three business days after submission to verify that the file was received and processed correctly. The Law School does not confer degrees year-round. Based on the ABA accreditation and program plan, Fowler School of Law has three conferral dates: January 31, June 10, and September 1. Most students are conferred on June 10. The Office of the University Registrar will report enrollment status changes to the National Student Clearinghouse every 30 days. Unlike the Law school, the University Registrar’s office confers degree year-round. The registrar’s office is scheduled to submit a Degree Verify file every two weeks to the clearinghouse and will review students in submited degree file for accuracy in our reporting.

Federal and State Financial Assistance Programs Year Ended May 31, 2025 CORRECTIVE ACTION PLAN Audit Finding Reference: 2025-001 Planned Corrective Action: The University conducted a full review of the population of cancellations for the fiscal year ending May 31, 2025, comprising of 53 students. The review identified seven instances of late reporting, all of which were previously corrected through the University’s monthly disbursement reconciliation processes, but beyond the 15 calendar day reporting requirement. Each of the identified instances resulted from a system defect which caused canceled BBAY Direct Loans reduced to zero (“0”) to receive an automatic null attendance cost. Due to the automatic null value, the record was excluded from the financial aid management system to COD record extraction process. The University has created a report to identify instances where the attendance cost value is null. When identified, action will be taken to populate the attendance cost to zero and allow extraction. The records will be subsequently verified to confirm extraction for submission to COD and reports will be reviewed weekly by the supervisor. The University will continue to review and implement additional controls to ensure disbursement records are submitted to COD within 15 calendar days. To ensure enhanced oversight and monitoring controls are effective to maintain compliance and timely reporting to COD, management will incorporate this review into their routine Assurance validation processes for students from the identified population. These remediation efforts and risk management strategies will continue to be reviewed and implemented throughout fiscal year 2026. The University continues to update controls as needed to ensure compliance with an estimated completion date of May 31, 2026. Contact Person: Suzanne Weems Controller Baylor University Phone: (254) 710-3731

FINDING 2025‐002 – Special Tests and Provisions – Return of Title IV (R2T4) Funds Significant Deficiency in Return of Title IV Funds Processing Recommendation: The University should enhance its monitoring and review procedures to ensure that all unofficial withdrawals are identified and reported within the federally required timeframe. Strengthening this process will support the timeliness of federal compliance. Response: There is no disagreement with this audit finding. Action taken in response to finding: Some of the corrective actions noted in our response to finding 2025-001 also apply here. For example, quality assurance reports to identify students who withdraw from all classes in a part of term and the upcoming joint training and process mapping session with Student Financial Services and the Registrar’s Office will strengthen understanding of how enrollment status updates drive downstream compliance, including R2T4 processing. These steps will also ensure exceptions are addressed consistently and that communication channels between offices are clear. To address immediate gaps specific to R2T4 compliance, the Registrar’s Office has enhanced training regarding R2T4 compliance requirements related to recording withdrawals and enrollment changes in a timely, accurate and consistent manner. Additional quality checks are being implemented to confirm that withdrawal dates and status changes are entered accurately into the student information system so that R2T4 calculations are completed within federal timeframes. Together, these interventions are designed to ensure the timeliness and accuracy of R2T4 processing and compliance with federal requirements. We expect to have these corrective actions completed by September 12, 2025. Contact Person(s): Sarah Everitt, Dean of Student Financial Services; Maxwell Kwenda, University Registrar & Director of Institutional Research

FINDING 2025‐001 – Special Tests and Provisions – Enrollment Reporting Significant Deficiency in Internal Control over Compliance Recommendation: The University should implement a reconciliation between the system of record and the reporting system to ensure all student changes (enrollment status and address changes) are reported on a timely basis. Response: There is no disagreement with this audit finding. Action taken in response to finding: Gonzaga has already taken action and implemented quality assurance reports and monitoring to ensure all student changes (enrollment status and address changes) are reported timely. Additionally, to strengthen compliance going forward, Student Financial Services and the Registrar’s Office are partnering to conduct a joint annual training and process mapping session for key personnel. This session will provide an overview of enrollment reporting requirements, outline the steps needed when exceptions to normal policies occur, and evaluate processes to improve understanding of how decisions affect both upstream and downstream functions. The session will also focus on building a shared understanding of reporting processes, identifying gaps in procedures and knowledge, and establishing communication channels so that exceptions are addressed timely, consistently and appropriately. These actions are designed to enhance internal controls and ensure compliance of timely reporting between the system of record and the reporting system, and we expect to complete this training by September 12, 2025. Contact Person(s): Sarah Everitt, Dean of Student Financial Services; Maxwell Kwenda, University Registrar & Director of Institutional Research

Views of Responsible Officials and Planned Corrective Actions – To address the identified issues related to student withdrawal processing and Return to Title IV (R2T4) calculations, the University will implement the following steps: 1. Process Review and Collaboration: A joint meeting will be held with key personnel from Academic Records and Financial Aid to review current withdrawal procedures, including the use of drop and exit forms. Emphasis will be placed on ensuring that appropriate withdrawal codes are consistently applied to support accurate and automated R2T4 processing. The goal is to establish a unified and clearly documented process that meets the operational needs of both departments. 2. Systematic Scheduling and Monitoring: Withdrawal-related tasks, including the running of BANNER return reports and other custom reports developed by the IT team, will be scheduled at regular intervals to ensure timely identification and processing of student withdrawals. These tasks will be integrated into departmental calendars, with scheduled dates already entered for the Fall 2025 and Spring 2026 semesters. 3. Ongoing Oversight and Communication: A communication protocol will be developed to ensure that all relevant documentation, including drop forms, is consistently shared between departments. This will help prevent delays in processing and ensure compliance with federal financial aid regulations.

Views of Responsible Officials and Planned Corrective Actions – The National Student Clearinghouse (NSC) Graduation and Enrollment Change Status’ submission calendar will be updated to reflect the necessary reporting timeline. The report will be completed after verification of graduation requirements and credentialing are completed by the Academic Record’s Department. Additional training will be provided to all members within the department to ensure timely submissions.

Finding 2025-001 Personnel Responsible for Corrective Action: Deborah Vinnola, Registrar Anticipated Completion Date: September 30, 2025 Corrective Action Plan: The Office of the Registrar has put into place a more detailed corrective action plan regarding the finding of delayed enrollment and non-enrollment reporting to NSLDS through NSC. The Office of the Registrar has adjusted the Degree Verify submission from every 45 days to every 30 days to NSC to ensure graduation dates are reported in a more timely fashion for NSLDS within the required 60 days for financial aid. Starting Summer 2025, the Office of the Registrar has begun inactivating academic programs for students who have not had registration activity within the last two to three academic years to ensure that they are not reported as enrolled to NSC/NSLDS. NSC Enrollment Reporting will continue to be submitted every 30 days and the Office of the Registrar has worked to review the reporting criteria using terms and not semesters to better report active enrollment in current courses. The Ellucian Graduation Application form and process is in the final stages of testing which will eliminate completely the need to add a pseudo course with a future date after the student’s current program has been inactivated or graduated. The Office of the Registrar will be more proactive with the colleges for identifying students who have not graduated within the six year (undergraduate), four year (graduate) and certificate time frames by working with the appropriate dean’s offices. This should eliminate those students who have completed their coursework; close to completing their coursework but were never reviewed by their advisor/program for graduation. Since Regis uses the end date of the last course completed, the Office of the Registrar will work with advising units to review the lists to increase a better reporting of degree completion.

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the College review its reporting procedures to ensure the students’ statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The student that was incorrectly coded as FWS funds, the funds were immediately reclassified as institutional aid. Since Cornish, did not draw down all FWS funding, it did not impact the G5 drawdown and no needs needed to be returned. Going forward, a higher-level review will be conducted for students with high SAI and low need to ensure that no need-based funds, if not eligible, are in the packaging. This review, will take place after the initial counselor review, but before a student can begin working in the FWS program. This third check will ensure that these types of files are again reviewed in a timely manner and no over awards will happen in the future. Name(s) of the contact person(s) responsible for corrective action: Sara Drummond Planned completion date for corrective action plan: June 16th, 2025

The College has already initiated corrective action by hiring entirely new staff in key positions and is committed to fostering a culture of compliance through rigorous procedures and training. 1. Staff Expertise: Financial Aid team members are becoming certified in the enterprise resource program module, specifically related to financial aid, as a first step. 2. SOP Implementation: The core of this plan involves the creation of seven new or updated Standard Operating Procedures (SOPs) (as highlighted above) to standardize compliance activities and reduce reliance on individual employee experience. 3. Proactive Monitoring: We are implementing mandatory monthly and quarterly reconciliation and audit reports to ensure adherence to timelines and documentation requirements, moving from reactive to proactive compliance management. 4. Cross-Training: Training will be conducted across multiple departments (Financial Aid, Business Office, Registrar) to ensure shared understanding and accountability for Title IV compliance. Finding 1: Satisfactory Academic Progress (SAP) Monitoring and Documentation Condition: 11 out of 60 students did not meet SAP, and the College did not provide supporting documentation for successful appeals, resulting in questioned costs of $180,794. (34 CFR 668.34) • SAP Policy Review and Update – The institution is currently reviewing its SAP Policy and will make adjustments where needed to include the appeal processes. The policy will also include a new financial aid SAP committee to review the appeals. • Develop SAP, appeal SOP –New SOP for processing, reviewing, and documenting all SAP appeals, requiring specific documentation of student's successful appeal basis • The institution is currently reviewing all students and is requesting that additional time is granted to ensure a thorough and accurate evaluation. • Expected date of completion: 06/2026 Finding 2: Federal Work-Study (FWS) Timesheet Documentation Condition: 9 out of 10 students for FWS had missing or incomplete timesheets. (34 CFR Part 675) • Implement monthly Timesheet Reconciliation, New SOP requiring the FWS Coordinator to reconcile all timesheets with Payroll records monthly, before payment is released. Any missing/incomplete sheets must be resolved within 48 hours. • FWS Supervisor Training for all FWS supervisors on the new timesheet, proper approval process, and the non-negotiable requirement for complete and timely documentation. Signed supervisor acknowledgment forms required. • Monthly Audit & Report Produce a monthly report of FWS student timesheet completeness/compliance. Report results to the Director of Financial Aid. • Freeze on Disbursements: All pending FWS payroll payments are being held until complete and signed timesheets are submitted. • Expected date of completion: 06/2026 Finding 3: Timely Return of Title IV (R2T4) Funds Condition: 6 out of 10 students tested for withdrawals and R2T4 did not have their Title IV program funds returned within the 45-day requirement. (HEA Section 484B & 34 CFR 668.22) • Establish Formal Withdrawal Date SOP, New SOP defining the official withdrawal date determination process (including school notification vs. last date of attendance), and immediate notification trigger to FA/Business Office. • Implement R2T4 Tracking Log & Checklist, Creation and mandatory use of an R2T4 Log to track the withdrawal date, calculation date, and refund date for every withdrawing student, ensuring adherence to the 45-day deadline. • Funds Returned: All late Title IV returns from the finding have now been processed and documented. • Staff Training: o Financial Aid and Registrar staff received refresher training on R2T4 regulations and deadlines. o Ongoing training scheduled annually and upon policy updates. • Internal R2T4 Processing Policy: o R2T4 calculations must be initiated within 10 business days of withdrawal notification. o Final return of funds must be processed by Day 40 (buffer before 45-day federal limit). • Expected date of completion: 06/2026 Finding 4: Entrance and Exit Counseling Documentation Condition: Entrance and exit counseling documentation was not provided for first-time borrowers, withdrawn students, or graduated students. (34 CFR 685.304) • Automated Verification System: o Financial Aid Office now verifies entrance counseling completion via the StudentAid.gov website prior to disbursing loans. • Exit Counseling Process: o Students flagged for exit counseling are immediately notified via email with instructions and a due date. o Confirmation of completion is pulled from StudentAid.gov or collected as a screenshot/PDF and saved. • Tracking Log: o A centralized loan counseling tracking log has been created to monitor: § Date of enrollment § First disbursement date § Withdrawal/graduation date § Counseling completion dates • Staff Training: o All Financial Aid staff have been trained on the new process for tracking and documenting counseling. o Training includes accessing StudentAid.gov reports and ensuring loan disbursement blocks are in place for non-compliance. • Student Hold Policy: o A registration or transcript hold may be applied for students who fail to complete required exit counseling after multiple reminders. • Expected date of completion: 06/2026

Policy and Procedure on coordination and reconciliation

Pending

Implement draft Policy & Procedures on monthly recs

Finding 2024-008 Repeat Finding 2023-009 ALNo.: Program Title: Federal Agency: Pass-Through Agencies: Award Number/Year 93.658 Foster Care - Title IV-E U.S. Department of Health and Human Services Wisconsin Department of Children and Families 3413,3561,3681,3645/2024 Criteria: The Uniform Guidance and State Single Audit Guidelines require that local entities receiving federal and state awards establish and maintain internal control designed to reasonably ensure compliance with laws, regulations and program compliance requirements. The Uniform Guidance and State Single Audit Guidelines further require auditors to obtain an understanding of the local entity's internal control over federal and state programs. To minimize the risk of errors, internal controls should be in place for all program compliance requirements, including the preparation and submission of monthly reports, which should be reviewed and approved by a responsible party other than the original preparer. Condition/Context: There were 13 reports for submission for the County. Three reports were selected for testing. There was no documentation of a review control by someone independent of the preparer for all three reports tested. Our sample was not statistically valid. Cause: The County did not have procedures in place requiring an independent person to review the reports before submission. Questioned Costs: None noted. Effect: Reports that contain errors could be submitted. Recommendation: We recommend that an employee other than the preparer review all reports before they are submitted to grantors. Corrective Action Planned: Angela Runde and Cody Blindert continued to work on the development of the Grant Manager module of Tyler MUNIS. In 2025 it was reviewed with the Department Heads, Kessa Klaas, CeCe Fink, Lori Reid and Jessica Munson as to their responsibility to review each filing for completeness and accuracy before filing. Cece Fink has designated that one person pull the information and compile the report. The workflow will route the report to Cece Fink for review and then to Patrick Montgomery for final review and approval. Anticipated Completion Date 3/1/2026.

Federal award findings and questioned costs 2024-001. Cluster name: Student Financial Assistance Cluster Assistance Listings numbers and names:84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study Program 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Luisa Ott Anticipated completion date: June 30, 2025 The District agrees with the finding. After reviewing the students in the finding, the District re­processed the Return of Title IV calculation. The students records were updated and resulted in an amount of $109.45 to be returned to the students by offsetting their current balance with the District. The District will fund the reimbursement with institutional funds. During the fiscal year ending June 30, 2024, the District created a supporting automated processes to identify potential Return to Title IV accounts. This new process utilizes the student information system to automatically compute student Return to Title IV calculations. The District will also be implementing new procedures to ensure that the proper amount of scheduled breaks are included and reviewed as a final step before returning the funds.

The Financial Aid and Registrar’s Offices are refining the withdrawal notification and reconciliation process to ensure that both official and unofficial withdrawals are accurately identified and routed for R2T4 calculation within the required timeframe. All identified cases were reviewed, corrected, and documented. The funds totaling $31,830 (Direct Loans) and $3,499 (Pell Grants) have been returned, and student accounts were reconciled accordingly. The Financial Aid Office, in coordination with the Information Technology team, is reviewing the SIS configuration to determine why certain Fall 2024 calculations were one day off, despite correct data entry. Adjustments will be made to eliminate any system-level rounding or timestamp discrepancies that could affect future calculations. Implementation of the corrective action plan is expected to be complete by June 30, 2026. Responsible Party Robert Rood Interim Vice President Finance and Administration