Corrective Action Plans

Finding 1173275 (2025-003)

Material Weakness 2025

TX

Student Financial Aid Eligibility

Corrective Action: See above corrective action plan for 2025-002. Contact Persons: Duane Valencia, Assistant Financial Vice President – Student Finance; Jason Kowarsch, Registrar

View Audit 386786

Finding 1173274 (2025-002)

Material Weakness 2025

Southwestern Adventist University

TX

Student Financial Aid Eligibility Special Tests & Provisions

Corrective Action: To prevent future occurrences of PELL and Direct Loans award findings identifying students not enrolled, withdrawn, and over-awarded aid. • Staff Training o Additional training sessions will be conducted for Student Finance staff to enhance understanding of awarding rules and syst...

Corrective Action: To prevent future occurrences of PELL and Direct Loans award findings identifying students not enrolled, withdrawn, and over-awarded aid. • Staff Training o Additional training sessions will be conducted for Student Finance staff to enhance understanding of awarding rules and system functionality. o Training will focus on identifying and correcting over-awarding scenarios before disbursement. • System Monitoring o Regular audits of the Ellucian System will be performed to ensure continued accuracy in aid calculations and refund processing. • Policy Enforcement o A formal policy will be adopted requiring aid disbursement only after census verification. o Exception will be documented and reviewed by the Vice President of Financial Administration. Contact Persons: Duane Valencia, Assistant Financial Vice President – Student Finance; Jason Kowarsch, Registrar Completion Date: To be completed by March 1, 2026

View Audit 386786

Finding 1173272 (2025-001)

Material Weakness 2025

Southwestern Adventist University

TX

Student Financial Aid Special Tests & Provisions Reporting

The 2023-24 Single Audit identified 12 delinquent NSLDS reports for the 2023-24 academic year, with delays ranging from 180 to 459 days. The 2024-25 Single Audit showed improvement, with only 5 of 9 reports filed late for the 2024-25 academic year, and delays reduced to 80-155 days. Corrective Actio...

The 2023-24 Single Audit identified 12 delinquent NSLDS reports for the 2023-24 academic year, with delays ranging from 180 to 459 days. The 2024-25 Single Audit showed improvement, with only 5 of 9 reports filed late for the 2024-25 academic year, and delays reduced to 80-155 days. Corrective Action: To prevent future occurrences of missed NSLDS reporting, the following steps have been implemented: • Cleanup of Past Delinquencies o All outstanding 2024-25 reports have been reviewed and submitted by October 3, 2025. o A reconciliation audit will be conducted to ensure all NSLDS records match institutional data. • Process Improvement o Implemented a centralized calendar with automated reminders for NSLDS reporting deadlines. o Established monthly reconciliation between internal Student Information System and NSLDS data. • Staffing and Training o The registrar is the primary reporting coordinator to the National Student Clearinghouse, with support from both Student Financial Services and ITS. o A standard operating procedure (SOP) has been documented to guide future reporting efforts. • Management Oversight o The Vice President for Academic Administration and ITS must also ensure that all these processes and departments are working to ensure the student data is being reported correctly and on-time. We are confident that these measures will address the issue of failure to report to the NSC and ensure full compliance with NSLDS reporting requirements in the future. Contact Persons: Duane Valencia, Assistant Financial Vice President – Student Finance; Jason Kowarsch, Registrar Completion Date: October 3, 2025

View Audit 386786

Finding 1173250 (2025-001)

Material Weakness 2025

College of Eastern Idaho

ID

Student Financial Aid

Finding 2025-001 Incorrect NSLDS Reporting: The examination disclosed 1 student, out of 25 student files tested, in which NSLDS was not updated within the 60-daytimeframe of their status change. The student graduated on May 9, 2025 but the status change was not certified until September 5, 2025. Cor...

Finding 2025-001 Incorrect NSLDS Reporting: The examination disclosed 1 student, out of 25 student files tested, in which NSLDS was not updated within the 60-daytimeframe of their status change. The student graduated on May 9, 2025 but the status change was not certified until September 5, 2025. Corrective Action Plan The College of Eastern Idaho Financial Aid Office and Registrar Office acknowledges the NSLDS reporting finding. Our corrective action plan will strengthen oversight procedures to ensure all student enrollment status changes are reported accurately and within the required 60-day timeframe. The Registrar's Office will implement a formalized reporting schedule with National Student Clearinghouse (NSC), to address enrollment changes occurring during non-standard reporting periods such as summer terms. In addition, the Registrar's Office will designate and train a second staff member authorized to report enrollment information to NSC as needed to ensure continuity and timely reporting. Person(s) Responsible: Raquel Cuevas, Tiffany Cleverly Timing for Implementation: Immediate 01.01.2026

View Audit 386746

Finding 1173242 (2025-001)

Material Weakness 2025

Roger Williams University

RI

Student Financial Aid Reporting Special Tests & Provisions

Finding – Special Tests and Provisions: Enrollment Reporting – Federal Direct Student Loan Program, Assistance Listing Number 84.268; June 30, 2025 Award Year; U.S. Department of Education Criteria or Specific Requirement Unless it expects to submit its next updated enrollment report to the Secretar...

Finding – Special Tests and Provisions: Enrollment Reporting – Federal Direct Student Loan Program, Assistance Listing Number 84.268; June 30, 2025 Award Year; U.S. Department of Education Criteria or Specific Requirement Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that a loan under title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended (CFR 685.309(b)(2)(i)). Condition Found Three students out of the 16 selected for status change testing had their status change reported to the National Student Loan Data System (“NSLDS”) outside of the maximum 60-day window. Changes were reported 5 days later than the requirement of 60 days. This was not a statistically valid sample. Views of Responsible Officials and Planned Corrective Actions The University concurs with the finding. The University intends to report status changes within the 60-day requirement going forward. Names of Contact Person Responsible for Correction Action: Gloria Arcia, Ed.D., Executive Vice President for Finance and Administration / Chief Financial Officer Anticipated Completion Date: October 2, 2025

View Audit 386736

Finding 1173189 (2025-001)

Material Weakness 2025

Morehead State University

KY

Student Financial Aid

Finding: 2025-001 Finding: The provisions of 34 CFR 668.22 were not followed. Students were not notified of the required communication related to a post-withdrawal disbursement of federal direct loans. Criteria: The University must comply with 34 CFR Section 668.22. Condition: We tested nine officia...

Finding: 2025-001 Finding: The provisions of 34 CFR 668.22 were not followed. Students were not notified of the required communication related to a post-withdrawal disbursement of federal direct loans. Criteria: The University must comply with 34 CFR Section 668.22. Condition: We tested nine official withdrawal samples as part of Return of Title IV Funds testing. Of those nine samples, one student had received a post-withdrawal disbursement of federal subsidized and unsubsidized direct loans. The student did not receive written notification that is required of federal loan post-withdrawal disbursement. Upon further evaluation by the University’s management, there were two additional students who received a post-withdrawal disbursement of federal loans without receiving the required communication. Cause: For the Fall 2024 semester, the University did not have a procedure in place to properly send students or student’s parents the required communication of federal loan post-withdrawal disbursements. Effect: The provisions of 34 CFR 668.22 were not followed and thus the students were not notified of the required communication related to a post-withdrawal disbursement of federal direct loans. Questioned Costs: There were no questioned costs associated with this finding. Recommendation: We recommend that the University update their internal controls related to post-withdrawal disbursements and send required communications prior to making a post-withdrawal disbursement of federal loans. Corrective Actions Taken: We agree with this finding and recommendation. Procedures have been updated to ensure that required written notifications are sent to students or parents in accordance with 34 CFR 668.22 prior to, or in conjunction with, any post-withdrawal disbursement of federal direct loans. Staff have been trained on the revised procedures, and controls are in place to ensure that required communications are sent timely and documented. Management will continue to monitor this process to confirm ongoing compliance. Name of Responsible Person: Dr. Heidi Reid, Assistant Vice President of Enrollment Management Completion Date: November 25, 2025

View Audit 386649

Finding 1173159 (2025-001)

Material Weakness 2025

Lipscomb University

TN

Student Financial Aid Matching / Level of Effort / Earmarking

Finding Summary: When a recipient of Title IV assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must calculate the correct amount of Title IV grant or loan assistance that the student earned based on the ...

Finding Summary: When a recipient of Title IV assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must calculate the correct amount of Title IV grant or loan assistance that the student earned based on the student’s withdrawal date and allocation of Title IV funds and return unearned funds to the Department of Education within 45 days. During the fiscal year 2025 period, one student that withdrew during the Fall term required a return of Title IV funds. However, the funds were not returned to the Department of Education within the required timeframe. Corrective Action Plan: Student Financial Aid management has developed a new master return of Title IV spreadsheet to ensure the return of funds and is routinely monitored by three different members of the Financial Aid Team. Anticipated Completion Date: The procedures will be implemented for the 2025-2026 Financial Aid Year. Responsible Parties: Ron Anderson

View Audit 386574

Finding 1173154 (2025-001)

Material Weakness 2025

University of Northwestern - St. Paul and Subsidiaries

MN

Student Financial Aid Reporting Significant Deficiency

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University review its reporting procedures to ensure that students’ statuses are timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no dis...

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University review its reporting procedures to ensure that students’ statuses are 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: We will update our procedures to make sure we are reporting accurate graduate dates, especially those that differ from the end of standard term date within a timely matter and enrollment effective dates in a timely manner. We have already begun reviewing this and are finding that the incidents found appear to be isolated. Therefore, we are updating procedure to include additional quality control checks to ensure that anomalies are found and resolved within the required timeframe. Name(s) of the contact person(s) responsible for corrective action: Hannah Blahnik Planned completion date for corrective action plan: May 2026

View Audit 386571

Finding 1173139 (2025-001)

Material Weakness 2025

Southern Union State Community College

AL

Student Financial Aid

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 ...

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 timelines 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 September 30, 2025. We obtained the student records and tested compliance with federal regulations for the specific loans and grants. For 1 student selected for NSLDS Reporting testing, the student’s status change was not accurately reported to NSLDS. For the same student, the status change effective date was not accurately reported to NSLDS. Cause - The College’s processes of internal controls for reporting student status changes to NSLDS were not adequate. Effect - Student status changes were not accurately reported to NSLDS. Identification of Repeat Finding - Repeat finding of prior year finding 2024-002. Recommendation - We recommend the College revise its processes for reporting student status changes to NSLDS. The College should implement a process to review, update, and verify student enrollment statuses that appear on the Enrollment Reporting roster files. We also recommend that management implement controls to ensure reported changes are correctly reported to the NSLDS. Views of Responsible Officials - Management agrees with the finding. Errors were caused by a coding error within their reporting system. Upon discovery, the errors were promptly reviewed and corrected subsequent to year-end. The necessary adjustments were made to the enrollment data, and the corrected information was submitted to the appropriate federal and state agencies in compliance with reporting requirements. Corrective Action Plan – A withdrawal process was put in place after this issue was identified as a finding in the prior year’s audit. The Financial Aid Director and Registrar will work closely together and continue to monitor the withdrawal process.

View Audit 386553

Finding 1173044 (2025-001)

Material Weakness 2025

J.f. Drake State Community and Technical College

AL

Student Financial Aid Eligibility Reporting

Management’s Response: Management understands the importance of ensuring information is reported accurately and timely and the requirement to report to the NSLDS the enrollment status of students who receive federal funds. The College will review its policies and procedures to ensure that not only a...

Management’s Response: Management understands the importance of ensuring information is reported accurately and timely and the requirement to report to the NSLDS the enrollment status of students who receive federal funds. The College will review its policies and procedures to ensure that not only are status changes reported to the Clearinghouse, but also that the enrollment changes are reported appropriately from the National Student Clearinghouse to NSLDS. Views of Responsible Officials and Corrective Action: We will reassess controls, review these processes and implement controls, including multiple layers of review, to ensure that timely and accurate enrollment reporting is made. Furthermore, the reporting data was appropriately updated subsequent to the required timeframe. Name of Responsible Person: Jennifer O’Linger, Director of Student Financial Aid Implementation Date: Immediately

View Audit 386504

Finding 1172929 (2025-010)

Material Weakness 2025

Randall University

OK

Student Financial Aid Reporting

FINDING 2025-010– FISAP Accuracy Program Name: Federal Work Study ALN and Program Expenditures: 84.033 ($-0-) Award Number: P033A243421 Federal Award Year: July 1, 2024 to June 30, 2025 Questioned Costs: N/A Condition Found: The University did not award Federal Work Study funds during the 24-25 acad...

FINDING 2025-010– FISAP Accuracy Program Name: Federal Work Study ALN and Program Expenditures: 84.033 ($-0-) Award Number: P033A243421 Federal Award Year: July 1, 2024 to June 30, 2025 Questioned Costs: N/A Condition Found: The University did not award Federal Work Study funds during the 24-25 academic year. However, the FISAP reports that students participating in the Federal Work Study Program earned $26,232. An administrative allowance of $1,312 was also claimed. Total Federal Work Study funds per the FISAP totaled $27,544. Corrective Action Plan: Management will work with the third-party servicer to ensure the figures and amounts reported on the FISAP are accurate. An independent review of the FISAP will be completed by the CFO before the FISAP is filed. Anticipated Completion Date: The University anticipates the corrective action being completed by October 1, 2026. Contact Person: Brad Burnett, Director of Financial Aid 405-912-9000

View Audit 386308

Finding 1172928 (2025-009)

Material Weakness 2025

Randall University

OK

Student Financial Aid

FINDING 2025-009– R2T4 Calculation Program Name: Federal Direct Loan Program Federal Pell Grant Program ALN and Program Expenditures: 84.268 ($866,312) 84.063 ($487,504) Award Number: P268K253315 P063P243315 Federal Award Year: July 1, 2024 to June 30, 2025 Condition Found: R2T4s were not calculated...

FINDING 2025-009– R2T4 Calculation Program Name: Federal Direct Loan Program Federal Pell Grant Program ALN and Program Expenditures: 84.268 ($866,312) 84.063 ($487,504) Award Number: P268K253315 P063P243315 Federal Award Year: July 1, 2024 to June 30, 2025 Condition Found: R2T4s were not calculated during for the award year ending June 30, 2025. During the compliance testing, it was determined that an R2T4 should have been calculated for two of the seventeen students selected for testing. Corrective Action Plan: Management agrees that the R2T4s were not completed. For the first student, the Student Financial Director determined that while the Federal Pell Grant funds were posted to the student’s account, the funds were never requested from the Department of Education. $1,616 was of aid was removed from the student’s account and only $2,081 will be requested from the Department of Education. For the second student, $1,652 of Subsidized Federal Direct Loan funds were returned to the Department of Education in December 2025. Anticipated Completion Date: The University anticipates the corrective action being completed by March 31, 2026. Contact Person: Brad Burnett, Director of Financial Aid 405-912-9000

View Audit 386308

Finding 1172926 (2025-008)

Material Weakness 2025

Randall University

OK

Eligibility Student Financial Aid

FINDING 2025-008 – Pell Grant Calculation Program Name: Federal Pell Grant Program ALN and Program Expenditures: 84.063 ($509,088) Award Number: P063P243315 Federal Award Year: July 1, 2024 to June 30, 2025 Questioned Costs: $1,849 Condition Found: The amount of Pell grant awarded was calculated inc...

FINDING 2025-008 – Pell Grant Calculation Program Name: Federal Pell Grant Program ALN and Program Expenditures: 84.063 ($509,088) Award Number: P063P243315 Federal Award Year: July 1, 2024 to June 30, 2025 Questioned Costs: $1,849 Condition Found: The amount of Pell grant awarded was calculated incorrectly for one of the eleven students who received Pell grant funds in our sample. The student received $1,849 of Federal Pell Grant funds that the student was ineligible to receive. Corrective Action Plan: The Student Financial Aid Director is working with the third-party administrator to the return $1,849 to the Department of Education. The Student Financial Aid Director and third-party administrator will work together to verify a student’s enrollment status before disbursing aid. Anticipated Completion Date: The University anticipates the corrective action being completed by March 31, 2026. Contact Person: Brad Burnett, Director of Financial Aid 405-912-9000

View Audit 386308

Finding 1172925 (2025-007)

Material Weakness 2025

Randall University

OK

Student Financial Aid

FINDING 2025-007 – COD Disbursement Dates Program Name: Federal Pell Grant Program ALN and Program Expenditures: 84.063 ($509,088) Award Number: P063P243315 Federal Award Year: July 1, 2024 to June 30, 2025 Questioned Costs: N/A Condition Found: The Common Origination and Disbursement System (“COD”)...

FINDING 2025-007 – COD Disbursement Dates Program Name: Federal Pell Grant Program ALN and Program Expenditures: 84.063 ($509,088) Award Number: P063P243315 Federal Award Year: July 1, 2024 to June 30, 2025 Questioned Costs: N/A Condition Found: The Common Origination and Disbursement System (“COD”) disbursement date did not agree with the disbursement date on the students’ accounts for one of the seventeen students in our compliance testing sample. Corrective Action Plan: The Student Financial Aid Director correct the date the aid was posted to the student account in December 2025. Procedures will be improved to ensure that the disbursements date per COD and the student account agree. Anticipated Completion Date: The corrective action was completed in December 2025. Contact Person: Brad Burnett, Director of Financial Aid 405-912-9000

View Audit 386308

Finding 1172924 (2025-006)

Material Weakness 2025

Randall University

OK

Eligibility Student Financial Aid Matching / Level of Effort / Earmarking

FINDING 2025-006 – Federal Direct Loan Eligibility Program Name: Federal Direct Student Loan Program ALN and Program Expenditures: 84.268 ($866,312) Award Number: P268K253315 Federal Award Year: July 1, 2024 to June 30, 2025 Questioned Costs: $484, net Condition Found: The amount of subsidized Feder...

FINDING 2025-006 – Federal Direct Loan Eligibility Program Name: Federal Direct Student Loan Program ALN and Program Expenditures: 84.268 ($866,312) Award Number: P268K253315 Federal Award Year: July 1, 2024 to June 30, 2025 Questioned Costs: $484, net Condition Found: The amount of subsidized Federal Direct Loans awarded was incorrect for four of the ten students in our sample that received Federal Direct Loans. In addition, the two of the students was eligible for additional Federal Direct Loan funds. Corrective Action Plan: For the first student, the student was eligible to receive $5,500 of subsidized funds, but only $4,500 was requested. The University gave the student an additional $1,000 of institutional funds to cover the difference in the amount the student was eligible to receive and the amount requested from the Department of Education in December 2025. For the second student, the COD correctly shows the that $5,500 of subsidized aid was disbursed to the student. However, only $4,500 of subsidized loan funds were posted to the student’s account. An institutional scholarship of $1,000 was posted to the student account in December 2025. For the third student, $484 of subsidized loan funds were returned to the Department of Education in December 2025. For the fourth student, the Director of Financial Aid will work with third party administrator to reclassify the subsidized loan funds as unsubsidized loan funds. Anticipated Completion Date: The University anticipates the corrective action being completed by March 31, 2026. Contact Person: Brad Burnett, Director of Financial Aid 405-912-9000

View Audit 386308

Finding 1172923 (2025-005)

Material Weakness 2025

Randall University

OK

Student Financial Aid Matching / Level of Effort / Earmarking

FINDING 2025-005– NSLDS Reporting Program Name: Federal Direct Student Loan Program ALN and Program Expenditures: 84.268 ($866,312) Award Number: P268K253315 Federal Award Year: July 1, 2024 to June 30, 2025 Questioned Costs: N/A Condition Found: During our compliance testing, student enrollment sta...

FINDING 2025-005– NSLDS Reporting Program Name: Federal Direct Student Loan Program ALN and Program Expenditures: 84.268 ($866,312) Award Number: P268K253315 Federal Award Year: July 1, 2024 to June 30, 2025 Questioned Costs: N/A Condition Found: During our compliance testing, student enrollment status changes were reported to the National Student Loan Database System (“NSLDS”) timely for nine of the seventeen students selected for testing. Corrective Action Plan: A new Student Financial Aid Director was hired in July 2025. The Student Financial Aid Director and Registrar will work together to determine and report student enrollment status changes within the required timeframe to NSLDS. Anticipated Completion Date: The University anticipates the corrective action being completed by March 31, 2026. Contact Person: Brad Burnett, Director of Financial Aid 405-912-9000

View Audit 386308

Finding 1172922 (2025-004)

Material Weakness 2025

Randall University

OK

Student Financial Aid

FINDING 2025-004– Reporting/Internal Control Over the SEFA Program Name: Federal Direct Student Loan Program Federal Pell Grant Program Federal Supplemental Educational Opportunity Grant ALN and Program Expenditures: 84.268 ($866,312) 84.063 ($509,088) 84.007 ($ 5,400) Award Number: P268K253315 P063...

FINDING 2025-004– Reporting/Internal Control Over the SEFA Program Name: Federal Direct Student Loan Program Federal Pell Grant Program Federal Supplemental Educational Opportunity Grant ALN and Program Expenditures: 84.268 ($866,312) 84.063 ($509,088) 84.007 ($ 5,400) Award Number: P268K253315 P063P243115 P007A243421 Federal Award Year: July 1, 2024 to June 30, 2025 Questioned Costs: Undetermined Condition Found: The University lacked policies and procedures to reconcile the SEFA data to the financial statements or other supporting documentation. The University was on the HCM2 method of payment and could not provide of the listing by student of the aid requested. During the audit, we were unable to reconcile the Amount Due from the Government on the Financial Statement to the amount due per the financial aid records. In addition, aid was posted to student accounts and never requested from the government for five of the seventeen students in our sample. Corrective Action Plan: The bursar, business office staff, and financial aid staff will work together to review and reconcile Title IV posted to the student accounts to the amounts requested from the Department of Education. When discrepancies are found, the University staff will investigate and determine if the student was eligible for aid and request additional funds as necessary. See the possible effect section for the resolution of the students in this finding. Anticipated Completion Date: The University anticipates the corrective action being completed by June 30, 2026. Contact Person: Brad Burnett, Director of Financial Aid 405-912-9000

View Audit 386308

Finding 1172919 (2025-003)

Material Weakness 2025

Randall University

OK

Student Financial Aid Subrecipient Monitoring Cash Management

84.063 ($509,088) Award Number: P268K253315 P063P243315 Federal Award Year: July 1, 2024 to June 30, 2025 Questioned Costs: N/A Condition Found: The University was placed on the Heightened Cash Monitoring Method 2 (“HCM2”) for disbursing aid in May 2023. In the current fiscal year, a Title IV Credit...

84.063 ($509,088) Award Number: P268K253315 P063P243315 Federal Award Year: July 1, 2024 to June 30, 2025 Questioned Costs: N/A Condition Found: The University was placed on the Heightened Cash Monitoring Method 2 (“HCM2”) for disbursing aid in May 2023. In the current fiscal year, a Title IV Credit Balance was held for more than 14 days for one of the seventeen students in our sample. Corrective Action Plan: There is no longer a credit balance on the account of the student in question. If time allows, the business office will review student accounts to determine if any additional credit balances should be refunded. Procedures should be improved to ensure the University is following the HCM2 regulations. Anticipated Completion Date: The University anticipates the corrective action being completed by March 31, 2026. Contact Person: Brad Burnett, Director of Financial Aid 405-912-9000

View Audit 386308

Finding 1172917 (2025-002)

Material Weakness 2025

Randall University

OK

Student Financial Aid Matching / Level of Effort / Earmarking

FINDING 2025-002 – Exit Interview Program Name: Federal Direct Loan Program ALN and Program Expenditures: 84.268 ($866,312) Award Number: P268K253315 Federal Award Year: July 1, 2024 to June 30, 2025 Questioned Costs: N/A Condition Found: Six of the seventeen federal student financial aid recipients...

FINDING 2025-002 – Exit Interview Program Name: Federal Direct Loan Program ALN and Program Expenditures: 84.268 ($866,312) Award Number: P268K253315 Federal Award Year: July 1, 2024 to June 30, 2025 Questioned Costs: N/A Condition Found: Six of the seventeen federal student financial aid recipients in our sample did not complete or were not sent exit interview instructions to complete within thirty days of the student ceasing to be enrolled in the University at least half-time. Corrective Action Plan: A new Financial Aid Director was hired in July 2025. The Financial Aid Director will review the students in question to determine if exit instructions were sent after the thirty-day time period. If an exit interview has not already been sent, the Financial Aid will mail exit interview instructions to the students’ home address. In addition, the Director of Financial Aid will work with the third-party administrator to determine which entity is responsible for sending exit interview information to students. Anticipated Completion Date: The University anticipates the corrective action being completed by March 31, 2026. Contact Person: Brad Burnett, Director of Financial Aid 405-912-9000

View Audit 386308

Finding 1172912 (2025-001)

Material Weakness 2025

Adler Graduate School

MN

Matching / Level of Effort / Earmarking Student Financial Aid Significant Deficiency § 200.303

Corrective actions were implemented for the Fall 2025 term to ensure all students are notified of Direct Loan disbursements and that sufficient documentation is maintained.

View Audit 386295

Finding 1172866 (2025-001)

Material Weakness 2025

Northwestern College

IA

Student Financial Aid Reporting Significant Deficiency

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the College re-evaluate its procedures and review policies surrounding reporting status changes to NSLDS to put a process in place to ensure the student status changes are being reported timely. Explan...

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the College re-evaluate its procedures and review policies surrounding reporting status changes to NSLDS to put a process in place to ensure the student status changes are being reported timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Early in the 2024-25 fiscal year, the College learned that this finding related to manually reported graduates and withdrawn students. Graduates reported during the automated file submittal process were reported as graduating at end of term, while graduates reported manually were reported as graduating on the College’s actual commencement date (one day different than end of term). The Registrar is now consistent in reporting graduation dates using the end of term for all graduating students. As for the reporting of withdrawals, the Registrar now manually updates the enrollment status and effective dates in NSLDS to ensure accurate and timely reporting. The findings in this audit period occurred prior to the above changes being implemented. Name(s) of the contact person(s) responsible for corrective action: Austin Nyhof, Registrar Planned completion date for corrective action plan: June 30, 2026

View Audit 386256

Finding 1172857 (2025-001)

Material Weakness 2025

Regents of the University of Minnesota

MN

Student Financial Aid Reporting Significant Deficiency

Action taken in response to finding: The Department of Education implementation delays contributed to the untimely reporting. In the event the Department of Education implements future changes, the University will evaluate impacted processes at that time to determine appropriate action. In addition,...

Action taken in response to finding: The Department of Education implementation delays contributed to the untimely reporting. In the event the Department of Education implements future changes, the University will evaluate impacted processes at that time to determine appropriate action. In addition, the Office of Student Finance has evaluated potential process improvements and is actively working with IT support to help automate this financial aid verification process. The University has also increased the frequency of queries within the student records system to identify and update/resolve the records in a timelier manner. Name(s) of the contact person(s) responsible for corrective action: Nate Peterson, Executive Director, Office of Student Finance Planned completion date for corrective action plan: February 2026 If the Department of Education has questions regarding this plan, please call Nate Peterson at 612-624-9442.

View Audit 386232

Finding 1172850 (2025-002)

Material Weakness 2025

California State University

CA

Student Financial Aid Matching / Level of Effort / Earmarking § 200.303

COMPLIANCE REQUIREMENT: Disbursements to or on Behalf of Students Campus: Fullerton, Los Angeles Recommendation: KPMG recommends the University provide proper training on the disbursement notification requirements and apply its existing policies and procedures. Corrective Action Plan: California Sta...

COMPLIANCE REQUIREMENT: Disbursements to or on Behalf of Students Campus: Fullerton, Los Angeles Recommendation: KPMG recommends the University provide proper training on the disbursement notification requirements and apply its existing policies and procedures. Corrective Action Plan: California State University, Fullerton The University concurs with the recommendation. The University will review and enhance its procedures to ensure timely disbursement notification. Estimated Completion Date: March 2026 Contact person: California State University, Fullerton Nick Valdivia Director of Financial Aid nvaldivia@fullerton.edu (657) 278-3064 Justin Chan Associate Director of Accounting Services & Financial Reporting juschan@fullerton.edu (657)278-8371 Corrective Action Plan: California State University, Los Angeles The University concurs with the recommendation. The University will review and enhance its procedures to ensure timely disbursement notification. Estimated Completion Date: June 2026 Contact person: California State University, Los Angeles Linda Lopez Director, Financial Aid and Scholarships (323) 343-3247 llopez148@calstatela.edu

View Audit 386207

Finding 1172848 (2025-001)

Material Weakness 2025

California State University

CA

Student Financial Aid Matching / Level of Effort / Earmarking § 200.303

COMPLIANCE REQUIREMENT: Enrollment Reporting Campuses: Sacramento, Los Angeles Recommendation: KPMG recommends the University provide proper training on the enrollment reporting procedures and apply its existing policies and procedures. Corrective Action Plan: California State University, Sacramento...

COMPLIANCE REQUIREMENT: Enrollment Reporting Campuses: Sacramento, Los Angeles Recommendation: KPMG recommends the University provide proper training on the enrollment reporting procedures and apply its existing policies and procedures. Corrective Action Plan: California State University, Sacramento The University concurs with the recommendation. The University will review and enhance its procedures to ensure timely and accurate reporting to NSLDS. Completion Date: December 2025 Contact person: California State University, Sacramento Tabitha Leeds Senior Director of Accounting Services (916) 278-4679 leeds@csus.edu Corrective Action Plan: California State University, Los Angeles The University concurs with the recommendation. The University will review and enhance its procedures to ensure timely and accurate reporting to NSLDS. Estimated Completion Date: June 2026 Contact person: California State University, Los Angeles Linda Lopez Director, Financial Aid and Scholarships (323) 343-3247 llopez148@calstatela.edu

View Audit 386207

Finding 1172786 (2025-002)

Material Weakness 2025

Mt. San Antonio Community College District

CA

Subrecipient Monitoring Student Financial Aid Significant Deficiency

Views of Responsible Officials and Corrective Action Plan During Fall 2024, the Financial Aid Office experienced the departure of two key senior staff members who were primarily responsible for Return to Title IV (R2T4) processing and the reversal of federal funds. As a result, new staff were tempor...

Views of Responsible Officials and Corrective Action Plan During Fall 2024, the Financial Aid Office experienced the departure of two key senior staff members who were primarily responsible for Return to Title IV (R2T4) processing and the reversal of federal funds. As a result, new staff were temporarily assigned to manage these responsibilities during the transition period, which contributed to delays in returning funds within the required regulatory timeframe. A comprehensive review of all R2T4 calculations completed during the 2024–2025 aid year determined that records processed prior to mid-November 2024 had over awarded funds returned within the applicable 45- and 30-day regulatory timeframes. This timeframe aligns with the period when the responsible staff members announced their retirements. To resolve this matter and prevent recurrence, the District has implemented the following corrective measures. Targeted R2T4 Training: Staff responsible for Return to Title IV (R2T4) processing and disbursement reversals are in the process of completing the National Association of Student Financial Aid Administrators (NASFAA) R2T4 credential training. This certification will ensure staff possess consistent, up-to-date knowledge of federal requirements around the R2T4 process to include the timelines required to return over-awarded funds to the department. Automated Monitoring Report: A recurring monitoring report has been established to identify students with pending Returns of Title IV (R2T4) funds. The report automatically flags cases exceeding 30 days and, for students who withdrew prior to the start of the term, those exceeding 20 days. Department managers will generate and review this report on a weekly basis to ensure timely compliance with federal return requirements. In instances where pending returns are identified as being past the alert threshold, Financial Aid management will promptly coordinate with Fiscal Services to expedite the return of funds and document resolution actions. Cross-Training for Continuity of Operations: Ongoing cross-training has been implemented among Financial Aid staff to ensure sufficient coverage during vacations, extended leaves, or unexpected absences. At least two designated staff members will be fully trained and authorized to perform R2T4 calculations and return processing to prevent delays in compliance during personnel transitions. These measures strengthen accountability, monitoring, and collaboration between the Financial Aid and Fiscal Services departments to ensure full compliance with federal cash management and return regulations.

View Audit 386075

Corrective Action Plans

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