Corrective Action Plans

Federal Program/ Assistance Listing Number (ALN) 84.268, 84.063, 84.007, 84.033 Finding Reference Number 2024-017 1. Finding Summary The auditor determined that Direct Subsidized Loan funds were originated and disbursed in excess of the student's allowable loan eligibility under federal annual or aggregate loan limits. As a result, the institution could not demonstrate full compliance with federal requirements governing Direct Subsidized Loan origination and disbursement limits. 2. Management's Position Management agrees with the finding. Management Explanation Management agrees with the finding and acknowledges that Direct Subsidized Loan amounts were not consistently adjusted to remain within the student's allowable federal loan eligibility limits prior to disbursement. 3. Root Cause Analysis The root cause of this finding resulted from insufficient supervisory review of loan eligibility calculations and gaps in staff training regarding federal Direct Subsidized Loan limits, which allowed loan amounts to exceed allowable eligibility prior to disbursement. 4. Corrective Action(s) Management has added secondary review, implemented periodic internal monitoring, and conducted targeted staff training tied to updated procedures. Description of Corrective Actions A mandatory supervisory or secondary review has been established to confirm Direct Subsidized Loan eligibility before processing or disbursement. Periodic internal monitoring and quality assurance reviews have been implemented to verify compliance with federal loan limits, and targeted staff training has been conducted to reinforce updated loan eligibility and origination procedures. 5. Risk Mitigation (Required - Even if Disagreeing) These corrective actions reduce the risk of improperly awarding or disbursing Pell Grant funds for summer enrollment by strengthening supervisory oversight, improving staff understanding of summer eligibility requirements, and ensuring eligibility is reviewed and verified prior to disbursement. Ongoing monitoring and quality assurance reviews provide additional safeguards to identify and prevent future noncompliance. 6. Responsible Party • Office/Department: Office of Financial Aid • Title of Responsible Official: Director of Financial Aid • Name (optional): ------------- 7. Implementation Timeline • Corrective action implemented: Yes (No) • If not fully implemented, expected completion date: June 30, 2026 8. Status of Corrective Action (For Prior-Year or Repeat Findings) Fully implemented Partially implemented (Not yet implemented) Evidence of Implementation In progress, evidence is not yet available. 9. Monitoring and Sustainability Supervisory review and periodic internal monitoring will be conducted to ensure Direct Subsidized Loan eligibility before processing or disbursement. Continued staff training, standardized review procedures, and ongoing quality assurance checks will be maintained to support long-term compliance and promptly identify and correct any loan overpayment issues.

Federal Program/ Assistance Listing Number (ALN) 84.268, 84.063, 84.007, 84.033 Finding Reference Number 2024-016 1. Finding Summary The auditor determined that Pell Grant funds were disbursed for summer enrollment without adequate documentation demonstrating that students met all required summer Pell eligibility criteria. As a result, the institution could not demonstrate compliance with federal requirements governing the award and disbursement of additional Pell Grant funds for summer terms. 2. Management's Position Management agrees with the finding. Management Explanation Management agrees with the finding and acknowledges that Pell Grant funds were disbursed for summer enrollment without consistently ensuring and documenting that all federal summer eligibility requirements were met prior to disbursement. 3. Root Cause Analysis The root cause of this finding resulted from insufficient supervisory review of summer Pell eligibility determinations and gaps in staff training regarding federal requirements for awarding and disbursing additional Pell Grant funds for summer enrollment. 4. Corrective Action(s) Management has added secondary review, implemented periodic internal monitoring, and conducted targeted staff training tied to updated procedures. Description of Corrective Actions The institution has added a required supervisory or secondary review to confirm summer Pell eligibility prior to processing or disbursement, implemented periodic internal monitoring and quality assurance reviews to verify ongoing compliance, and conducted targeted staff training aligned with updated summer Pell eligibility procedures. 5. Risk Mitigation (Required - Even if Disagreeing) These corrective actions reduce the risk of improperly awarding or disbursing Pell Grant funds for summer enrollment by strengthening supervisory oversight, improving staff understanding of summer eligibility requirements, and ensuring eligibility is reviewed and verified prior to disbursement. Ongoing monitoring and quality assurance reviews provide additional safeguards to identify and prevent future noncompliance. 6. Responsible Party • Office/Department: Office of Financial Aid • Title of Responsible Official: Director of Financial Aid • Name (optional): 7. Implementation Timeline • Corrective action implemented: Yes (No) • If not fully implemented, expected completion date: June 30, 2026 8. Status of Corrective Action (For Prior-Year or Repeat Findings) Fully implemented Partially implemented (Not yet implemented) Evidence of Implementation In progress, evidence is not yet available. 9. Monitoring and Sustainability Ongoing supervisory review and periodic internal monitoring will be conducted to ensure summer Pell eligibility requirements are consistently met and documented prior to disbursement. Continued staff training, standardized review procedures, and quality assurance checks will be maintained to support long-term compliance and timely identification and correction of any eligibility issues.

Federal Program/ Assistance Listing Number (ALN) 84.268, 84.063, 84.007, 84.033 Finding Reference Number 2024-015 1. Finding Summary The auditor determined that information reflected on student award letters was not always consistent with actual Title IV disbursements. As a result, the institution could not fully demonstrate compliance with federal notification requirements to ensure students and parents received accurate and reliable information regarding Title IV aid awards and disbursements. 2. Management's Position Management agrees with the finding. Management Explanation Management agrees with the finding and acknowledges that discrepancies occurred between information reflected on award letters and actual Title IV disbursements, resulting in inconsistent communication of federal aid information to students and parents. 3. Root Cause Analysis The root cause of this finding resulted from insufficient supervisory or secondary review to ensure award letters were updated prior to processing or disbursement, limited internal monitoring and quality assurance over award communications, and system configuration limitations that affected the timely alignment of award letters with actual Title IV disbursements. 4. Corrective Action(s) Management has added secondary review, implemented periodic internal monitoring, and enhanced system controls within the financial aid software. Description of Corrective Actions A required supervisory or secondary review has been added to confirm award letter accuracy before processing or disbursement, periodic internal monitoring and quality assurance reviews have been implemented to ensure consistency between award letters and Title IV disbursements, and system controls within the financial aid software have been strengthened to improve data alignment and accuracy. 5. Risk Mitigation (Required - Even if Disagreeing) These corrective actions mitigate the risk of discrepancies between award letters and actual Title IV disbursements by strengthening oversight, improving system accuracy, and ensuring timely review and validation of award communications. Ongoing monitoring and quality assurance reviews further reduce the likelihood of inaccurate student notifications and support sustained compliance with federal Title IV disclosure requirements. 6. Responsible Party • Office/Department: Office of Financial Aid • Title of Responsible Official: Director of Financial Aid • Name (optional): ______ 7. Implementation Timeline • Corrective action implemented: Yes (No) • If not fully implemented, expected completion date: June 30, 2026 8. Status of Corrective Action (For Prior-Year or Repeat Findings) Fully implemented Partially implemented (Not yet implemented) Evidence of Implementation In progress, evidence is not yet available. 9. Monitoring and Sustainability The corrective actions will be monitored through ongoing supervisory review and periodic internal quality assurance checks to confirm award letter accuracy before Title IV processing and disbursements. These practices will be sustained through standardized review procedures and continued oversight to ensure long-term compliance and timely correction of any documentation deficiencies.

Federal Program/ Assistance Listing Number (ALN) 84.268, 84.063, 84.007, 84.033 Finding Reference Number 2024-014 1. Finding Summary The auditor determined that the institution did not accurately report recipient counts on the FISAP in accordance with federal reporting requirements. As a result, the institution could not demonstrate compliance with Title IV reporting obligations under its Program Participation Agreement, increasing the risk of inaccurate federal reporting and potential compliance findings. 2. Management's Position Management agrees with the finding. Management Explanation Management agrees with the finding and acknowledges that recipient counts reported on the FISAP were not consistently accurate in accordance with federal reporting requirements. 3. Root Cause Analysis The root cause of this finding resulted from failure to reconcile ISIR income data to the summary totals reported on the FI SAP, use of incorrect or incomplete datasets when preparing recipient counts, and insufficient supervisory review of the FISAP reporting process. 4. Corrective Action(s) Management has added secondary review, implemented periodic internal monitoring, and added system configuration limitations. Description of Corrective Actions The institution has implemented a supervisory or secondary review to validate FISAP data and recipient counts prior to submission, and established periodic internal monitoring and quality assurance reviews to ensure accuracy and completeness of reported information. Additionally, system configuration limitations impacting data extraction and reconciliation have been identified and addressed through revised reporting procedures and compensating manual controls. 5. Risk Mitigation (Required - Even if Disagreeing) These corrective actions mitigate the risk of inaccurate FISAP reporting by strengthening oversight, improving data validation, and establishing compensating controls to address system limitations. Ongoing monitoring and quality assurance reviews further reduce compliance risk and support accurate and reliable federal reporting. 6. Responsible Party • Office/Department: Office of Financial Aid • Title of Responsible Official: Director of Financial Aid • Name (optional): ____________ 7. Implementation Timeline • Corrective action implemented: Yes (No) • If not fully implemented, expected completion date: December 31, 2026 8. Status of Corrective Action (For Prior-Year or Repeat Findings) Fully implemented Partially implemented (Not yet implemented) Evidence of Implementation In progress, evidence is not yet available. 9. Monitoring and Sustainability Supervisory review and periodic internal monitoring will be conducted each reporting cycle to ensure FISAP recipient counts are accurate, complete, and supported by reconciled data. Continued use of quality assurance reviews, documented procedures, and compensating controls for system limitations will support long-term compliance and timely identification and correction of reporting discrepancies.

Federal Program/ Assistance Listing Number (ALN) 84.268, 84.063, 84.007, 84.033 Finding Reference Number 2024-013 1. Finding Summary The auditor determined that the institution did not consistently report accurate and timely student enrollment information to NSLDS in accordance with federal requirements. As a result, the institution could not demonstrate full compliance with enrollment reporting regulations, increasing the risk of incorrect loan status reporting and potential impacts to borrower eligibility and repayment. 2. Management's Position Management agrees with the finding. Management Explanation Management agrees with the finding and acknowledges that student enrollment information was not consistently reported accurately and timely to NSLDS in accordance with federal reporting requirements. 3. Root Cause Analysis The root cause of this finding resulted from inadequate monitoring procedures to ensure timely and accurate updates and reconciliation of enrollment status changes between the Registrar's system and the NSLDS reporting system. 4. Corrective Action(s) Management has added secondary review and implemented periodic internal monitoring. Description of Corrective Actions The institution has implemented a supervisory or secondary review to verify the accuracy and timeliness of enrollment status updates prior to submission to NSLDS. In addition, periodic internal monitoring and quality assurance reviews have been established to ensure ongoing compliance and timely reconciliation of enrollment changes between institutional systems and NSLDS. 5. Risk Mitigation (Required - Even if Disagreeing) These corrective actions reduce the risk of inaccurate or untimely NSLDS reporting by strengthening oversight and ensuring enrollment changes are reviewed and reconciled before submission. Ongoing monitoring and quality assurance reviews further mitigate compliance risk and support sustained adherence to federal enrollment reporting requirements. 6. Responsible Party • Office/Department: Office of the Registrar • Title of Responsible Official: Registrar • Name (optional): ____________ _ 7. Implementation Timeline • Corrective action implemented: Yes (No) • If not fully implemented, expected completion date: June 30, 2026 8. Status of Corrective Action (For Prior-Year or Repeat Findings) Fully implemented Partially implemented (Not yet implemented) Evidence of Implementation In progress, evidence is not yet available. 9. Monitoring and Sustainability Management will conduct ongoing supervisory review and periodic internal monitoring to ensure enrollment status changes are accurately updated and reported to NSLDS in a timely manner. Continued reconciliation between the Registrar's system and NSLDS, along with sustained quality assurance reviews, will support long-term compliance and prompt identification of any reporting discrepancies.

Federal Program/ Assistance Listing Number (ALN) 84.268, 84.063, 84.007, 84.033 Finding Reference Number 2024-012 1. Finding Summary The auditor determined that the institution disbursed Pell Grant funds more than 10 days prior to the first day of classes, in vio]ation of federal Title IV disbursement timing requirements. As a result, the institution could not demonstrate compliance with applicable federal regulations governing the timing of Pell Grant disbursements. 2. Management's Position Management agrees with the finding. Management Explanation Management agrees with the finding and acknowledges that Pell Grant funds were disbursed earlier than permitted under federal Title IV disbursement timing requirements due to a miscalculation of the days. 3. Root Cause Analysis The root cause of this finding resulted from by inaccurate or prematurely scheduled disbursement dates, limited coordination between the Financial Aid and Business Offices on the approved disbursement calendar, and insufficient controls to ensure Pell Grant funds were released in accordance with federal timing requirements. 4. Corrective Action(s) Management will implement a standardized calendar of disbursement dates annually based on the academic calendar. Description of Corrective Actions Management will prepare an annual disbursement calendar based on the academic calendar, which will be reviewed by both the Business Office and Office of Financial Aid to ensure compliance to federal Title IV disbursement timing requirements. 5. Risk Mitigation (Required - Even if Disagreeing) These corrective actions reduce the risk of early federal disbursements by strengthening oversight, implementing a disbursement calendar, and reinforcing staff understanding of federal timing requirements. 6. Responsible Party • Office/Department: Business Office • Title of Responsible Official: Senior Accountant • Name (optional): ___ _________ _ 7. Implementation Timeline • Corrective action implemented: (Yes) No • If not fully implemented, expected completion date: June 30, 2026 8. Status of Corrective Action (For Prior-Year or Repeat Findings) (Fully implemented) Partially implemented Not yet implemented Evidence of Implementation Academic Year 2026-2027 Disbursement Calendar. 9. Monitoring and Sustainability The University will continue to prepare a disbursement calendar annually before any new year disbursements are made.

Federal Program/ Assistance Listing Number (ALN) 84.268, 84.063, 84.007, 84.033 Finding Reference Number 2024-011 1. Finding Summary The auditor determined that the institution did not consistently obtain and document required verification information prior to disbursing Title IV federal student aid for students selected for verification. As a result, the institution could not demonstrate compliance with federal verification requirements, increasing the risk that Title IV funds were disbursed before verification was completed. 2. Management's Position Management agrees with the finding. Management Explanation Management agrees with the finding and acknowledges that required verification documentation was not consistently obtained and documented prior to the disbursement of Title IV federal student aid for students selected for verification. 3. Root Cause Analysis The root cause of this finding resulted from weaknesses in verification monitoring procedures and inadequate review controls, which allowed Title IV aid to be packaged and disbursed prior to the completion and documentation of required verification. 4. Corrective Action(s) Management has implemented standardized checklists and workflows, added secondary review, provided additional training to staff, and implemented periodic internal monitoring. Description of Corrective Actions Management has implemented enhanced verification workflows and system controls to prevent packaging or disbursement of Title IV aid until verification is fully completed. A mandatory supervisory review has been established, and targeted staff training has been conducted to reinforce verification requirements. Periodic internal monitoring and quality assurance reviews will be performed to ensure on going compliance. 5. Risk Mitigation (Required - Even if Disagreeing) The corrective actions mitigate the risk of disbursing Title IV funds prior to verification completion by strengthening verification workflows, system controls, and supervisory review. Targeted staff training and ongoing internal monitoring further reduce the likelihood of premature disbursements and support sustained compliance with federal verification requirements. 6. Responsible Party • Office/Department: Office of Financial Aid • Title of Responsible Official: Director of Financial Aid 7. Implementation Timeline • Corrective action implemented: Yes (No) • If not fully implemented, expected completion date: June 30, 2026 8. Status of Corrective Action (For Prior-Year or Repeat Findings) Fully implemented Partially implemented (Not yet implemented) Evidence of Implementation In progress, evidence is not yet available. 9. Monitoring and Sustainability Management will conduct regular supervisory and periodic internal reviews of verification files to confirm that required documentation is completed prior to Title IV packaging and disbursement. Continued staff training, maintained system controls, and standardized verification procedures will be sustained to ensure long-term compliance and timely identification of any deficiencies.

Federal Program / Assistance Listing Number (ALN) 84.268, 84.063, 84.007, 84.033 Finding Reference Number 2024-010 1. Finding Summary The auditor determined that the institution did not consistently obtain or maintain official transfer transcripts required to document prior academic completion and establish Title IV eligibility in accordance with the Higher Education Act and federal regulations. As a result, the institution could not fully demonstrate compliance with Title IV student eligibility documentation requirements, increasing the risk of awarding federal aid to potentially ineligible students. 2. Management's Position Management agrees with the finding. Management Explanation Management agrees with the finding and acknowledges that official transfer transcripts were not consistently obtained or maintained to adequately document prior academic completion and establish Title IV eligibility in accordance with federal requirements. 3. Root Cause Analysis The root cause of this finding was gaps in staff training related to transfer transcript requirements and insufficient supervisory review to ensure required documentation was obtained and retained prior to the awarding or disbursement of Title IV federal student aid. 4. Corrective Action(s) Management has implemented standardized checklists and workflows, added secondary review, provided additional training to staff, and implemented periodic internal monitoring. Description of Corrective Actions Management has enhanced oversight by implementing additional supervisory review to confirm required transfer transcripts are received and documented before Title IV processing, provided targeted training to address staff knowledge gaps regarding eligibility requirements, and improved documentation practices by centralizing the collection and retention of official transfer transcripts. 5. Risk Mitigation (Required - Even if Disagreeing) The corrective actions reduce the risk of awarding or disbursing Title IV funds to ineligible students by ensuring that high school completion documentation is consistently collected, verified, and retained prior to aid processing. Enhanced supervisory review, centralized documentation practices, strengthened system controls, and ongoing staff training provide multiple layers of oversight to prevent documentation gaps and support sustained compliance with federal eligibility requirements. 6. Responsible Party • Office/Department: Office of Admissions • Title of Responsible Official: Director of Admissions • Name (optional): ________ 7. Implementation Timeline • Corrective action implemented: Yes (No) • If not fully implemented, expected completion date: Action is fully implemented, but will transition to a new automated process at a later date. 8.Status of Corrective Action (For Prior-Year or Repeat Findings) Fully implemented Partially implemented (Not yet implemented) Evidence of Implementation In progress, evidence is not yet available. 9. Monitoring and Sustainability Management will conduct ongoing supervisory and periodic internal reviews of student files to verify that official transfer transcripts are consistently obtained, documented, and retained prior to Title IV awarding or disbursement. Continued staff training, standardized documentation procedures, and strengthened system controls will be maintained to ensure long-term compliance and to promptly identify and correct any deficiencies.

Federal Program/ Assistance Listing Number (ALN) 84.268, 84.063, 84.007, 84.033 Finding Reference Number 2024-009 1. Finding Summary The auditor identified that some students lacked required documentation ofhigh school completion or an allowable alternative in their files yet were awarded Title IV federal student aid. As a result, the institution could not demonstrate compliance with Title IV student eligibility requirements, creating a risk of disbursement to ineligible students. 2. Management's Position Management agrees with the finding. Management Explanation Management agrees with the finding and acknowledges that required documentation of high school completion or an allowable alternative was not consistently maintained in student files prior to the disbursement of Title IV federal student aid. 3. Root Cause Analysis The root cause of this finding was insufficient supervisory review of student eligibility documentation and decentralized documentation practices that resulted in inconsistent collection and retention of required records. 4. Corrective Action(s) Management has implemented standardized checklists and workflows, added secondary review, enhanced system controls, and implemented periodic internal monitoring. Description of Corrective Actions The institution has taken corrective action to strengthen compliance with Title IV student eligibility requirements related to documentation of high school completion. Management has implemented standardized eligibility checklists and documented workflows to ensure required documentation is collected and verified prior to awarding or disbursing federal student aid. A mandatory supervisory or secondary review has been added to confirm eligibility and documentation completeness before processing or disbursement occurs. In addition, system controls within the Student Information System (SIS), financial aid software, and document management systems have been enhanced to require receipt and retention of acceptable high school completion documentation before Title IV funds can be awarded. Targeted staff training has been conducted to reinforce federal eligibility requirements, institutional procedures, and documentation standards. To ensure ongoing compliance, the institution has established periodic internal monitoring and quality assurance reviews of student files to verify documentation accuracy and consistency. These measures are designed to prevent recurrence of the finding and support sustained compliance with federal regulations. 5. Risk Mitigation (Required - Even if Disagreeing) The implemented corrective actions mitigate the risk of awarding or disbursing Title IV funds to ineligible students by ensuring that high school completion documentation is collected, verified, and retained prior to aid processing. Standardized workflows, enhanced system controls, supervisory review, targeted staff training, and ongoing internal monitoring collectively strengthen compliance oversight, reduce documentation errors, and promote consistent adherence to federal student eligibility requirements. 6. Responsible Party • Office/Department: Office of Admissions • Title of Responsible Official: Director of Admissions • Name (optional): _ 7. Implementation Timeline a. Corrective action implemented: Yes (No) b. If not fully implemented, expected completion date: June 30, 2026 8. Status of Corrective Action (For Prior-Year or Repeat Findings) Fully implemented Partially implemented (Not yet implemented) Evidence of Implementation In progress, evidence is not yet available. 9. Monitoring and Sustainability Management will conduct periodic internal reviews and quality assurance checks of student eligibility files to confirm that required high school completion documentation is consistently obtained and maintained prior to Title IV disbursement. Supervisory reviews, ongoing staff training, and continued use of standardized workflows and system controls will be sustained to reinforce compliance, identify issues timely, and ensure long-term adherence to federal Title IV eligibility requirements.

Federal Program/ Assistance Listing Number (ALN) 84.268, 84.063, 84.007, 84.033 Finding Reference Number 2024-008 1. Finding Summary The auditor identified that seven (7) out of sixty (60) sampled students had Title IV-created credit balances that remained on their accounts for more than 14 days without being released to the student or parent. 2. Management's Position Management agrees with the finding. Management Explanation Management agrees with the finding and acknowledges that the identified condition resulted from the system not pulling credit balances per semester. 3. Root Cause Analysis The root cause was the absence of the system not pulling credit balances per semester. Therefore, it is a manual process to verify if the current semester aid creates a refund for current semester charges when a balance from a prior semester is rolling forward. 4. Corrective Action(s) Management has enhanced system controls and implemented periodic internal monitoring. Description of Corrective Actions To address this finding and prevent recurrence, the University is performing weekly reviews of all student accounts that had aid processed during that week. This review is important because all statements are reviewed even if a credit balance is not showing to identify if the aid for the period creates a credit for the semester despite a beginning balance. Further, the University is transitioning to a new accounting system which will identify credit by term. The new system, Colleague, which will automate the process, will be implemented in approximately 18 months. 5. Risk Mitigation (Required - Even if Disagreeing) The institution recognizes the importance of mitigating compliance risk in this area. According!y, the corrective actions described above are designed to timely identify student accounts with a refundable credit balance and future audit findings. 6. Responsible Party a. Office/Department: Business Office b. Title of Responsible Official: Senior Accountant c. Name (optional): 7. Implementation Timeline Manual corrective actions have been implemented and are ongoing as part of standard operating procedures. The automated process is anticipated to be fully in place within 18 months once the University transitions to the Colleague system. • Corrective action implemented: Yes (No) • If not fully implemented, expected completion date: Action is fully implemented, but will transition to a new automated process at a later date. 8.Status of Corrective Action (For Prior-Year or Repeat Findings) (Fully implemented) Partially implemented Not yet implemented Evidence of Implementation An example can be provided for a student with a balance who received a refund for the current semester despite not showing a credit balance. 9. Monitoring and Sustainability The University will continue its manual review process until it can be automated.

Federal Program/ Assistance Listing Number (ALN) 84.268, 84.063, 84.007, 84.033 Finding Reference Number 2024-007 1. Finding Summary The auditor identified inconsistencies in the application of Cost of Attendance (COA) budgets, indicating that COA components were not applied uniformly to students within similar categories and were not consistently supported by documentation. 2. Management's Position Management agrees with the finding. Management Explanation Management agrees with the finding and acknowledges that Cost of Attendance budgets were not applied consistently across similarly situated students. The University recognizes the importance of uniform COA application and adequate documentation to ensure accurate financial aid determinations and compliance with federal regulations and is committed to implementing corrective measures to address this issue. 3. Root Cause Analysis Office of Fiscal Affairs The root cause was the absence of standardized Cost of Attendance budget templates and documented procedures, combined with training gaps and limited supervisory review. These conditions led to inconsistent application of COA components across student categories and insufficient documentation to support the amounts used in financial aid packaging. 4. Corrective Action(s) Management is working to implement standardized workflows and periodic internal monitoring. The University has also enhanced system controls. Description of Corrective Actions To address this finding and prevent recurrence, the University has implemented standardized COA checklists and workflows to ensure consistent application of Cost of Attendance components across similarly situated students. Supervisory review has been added prior to finalizing COA determinations to verify accuracy, consistency, and compliance with federal requirements. In addition, system controls within the student information system and financial aid management software have been enhanced to support standardized COA budgets and reduce the risk of inconsistent manual adjustments. Periodic internal monitoring and quality assurance reviews have been established to assess ongoing compliance, identify variances, and support the long-term sustainability of corrective actions. 5. Risk Mitigation (Required - Even if Disagreeing) The University recognizes the importance of reducing regulatory risk associated with the consistent application of Cost of Attendance budgets. The corrective measures implemented are intended to strengthen consistency, oversight, and system-based controls in COA determinations, thereby minimizing the risk of inaccurate financial aid awards, inconsistent student treatment, and future audit findings. 6. Responsible Party • Office/Department: Office of Financial Aid • Title of Responsible Official: Financial Aid Director • Name ( optional): -------------- 7. Implementation Timeline • Corrective action implemented: Yes (No) • If not fully implemented, expected completion date: June 30, 2026 8. Status of Corrective Action (For Prior-Year or Repeat Findings) Fully implemented Partially implemented (Not yet implemented) Evidence of Implementation In progress, evidence is not yet available. 9. Monitoring and Sustainability The University will maintain ongoing oversight of Cost of Attendance determinations through periodic internal reviews and supervisory verification of COA budgets. System controls, standardized workflows, and quality assurance checks will be routinely evaluated to ensure consistent application across student categories and sustained compliance with federal requirements.

Federal Program/ Assistance Listing Number (ALN) 84.268, 84.063, 84.007, 84.033 Finding Reference Number 2024-006 1. Finding Summary The auditor identified one instance in which the University did not return unearned Title IV funds within the required 45-day time frame following a student's withdrawal, with the return occurring significantly after the institution's date of determination. 2. Management's Position Management agrees with the finding. Management Explanation Management agrees with the finding and concurs that the return of unearned Title IV funds must occur within the required regulatory time frame. The University recognizes the importance of timely Return of Title IV processing and is committed to strengthening internal controls, oversight, and coordination to ensure future compliance. 3. Root Cause Analysis The root cause was the absence of a formal monitoring and tracking process for Return of Title IV (R2T4) obligations, combined with limited supervisory oversight and insufficient coordination between the Office of Financial Aid, the Business Office, and Student Retention. These factors resulted in delayed identification of withdrawals and untimely processing of required Title IV fund returns. 4. Corrective Action( s) Management is working to implement standardized workflows and periodic internal monitoring. Description of Corrective Actions To address this finding and prevent recurrence, the University has centralized oversight of the Return of Title IV (R2T4) process by assigning responsibility to the Director of Financial Aid and implementing a formal tracking and monitoring system to ensure all returns are completed within the required 45-day timeframe. The Director of Financial Aid now collaborates with Student Retention to receive prompt notification of student withdrawals. Once funds are removed from the student account for R2T4, the Business Office returns the funds within 3 days. In addition, supervisory review procedures have been established to verify the accuracy and timeliness of R2T4 calculations and returns, strengthening internal controls and ensuring ongoing compliance with federal regulations. 5. Risk Mitigation (Required - Even if Disagreeing) The University recognizes the importance of proactively managing regulatory risk related to the Return of Title IV process. The corrective actions implemented are intended to improve the timely identification of student withdrawals, strengthen oversight of R2T 4 calculations and returns, and enhance coordination among responsible offices, thereby reducing the risk of delayed returns, regulatory exposure, and future audit findings .. 6. Responsible Party • Office/Department: Office of Financial Aid • Title of Responsible Official: Financial Aid Director • Name (optional): ____________ _ 7. Implementation Timeline • Corrective action implemented: Yes (No) • If not fully implemented, expected completion date: June 30, 2026 8. Status of Corrective Action (For Prior-Year or Repeat Findings) Fully implemented Partially implemented (Not yet implemented) Evidence of Implementation In progress, evidence is not yet available. 9. Monitoring and Sustainability The University will ensure ongoing compliance by conducting routine internal reviews of Return of Title IV activity, including verification of withdrawal notifications, calculation dates, and return confirmations. R2T4 tracking reports and supervisory oversight will be used to monitor timeliness and accuracy, and procedures will be reinforced through continued staff training and management review to support long-term sustainability.

Federal Program / Assistance Listing Number (ALN) 84.268, 84.063, 84.007, 84.033 Finding Reference Number 2024-005 1. Finding Summary The auditor found that the University submitted unreconciled expenditure data on the FISAP for the Federal Pell Grant and Federal Work-Study programs, with reported amounts not aligning to internal records, the general ledger, or federal systems. This condition reflects weaknesses in reconciliation timeliness and oversight and increases the risk of inaccurate federal reporting. 2. Management's Position Management agrees with the finding. Management Explanation Management agrees with the finding and acknowledges the submission of unreconciled expenditure data within the Fiscal Operations Report and Application to Participate (FISAP). Management concurs that all Title IV expenditures must be fully reconciled to internal records,federal systems, and the general ledger prior to year-end federal reporting to ensure accuracy and compliance with federal requirements. 3. Root Cause Analysis The root cause was a combination of insufficient supervisory review and training gaps related to Title IV reconciliation and FISAP reporting requirements. These conditions resulted in delays in completing final reconciliations, inconsistent coordination between the Office of Financial Aid and the Business Office, and the submission of federal reports without documented confirmation that expenditures reconciled to internal records and federal systems. 4. Corrective Action(s) Management is working to implement standardized workflows and periodic internal monitoring. Description of Corrective Actions To address this finding and prevent recurrence, the University has strengthened its reconciliation and reporting processes by implementing mandatory monthly reconciliations for all Title IV programs and requiring completion of a documented year-end reconciliation prior to submission of the FISAP. The Office of Financial Aid now utilizes standardized reconciliation templates and documentation procedures and coordinates closely with the Business Office to ensure reported expenditures reconcile to internal records, the general ledger, and federal systems. In addition, supervisory review has been incorporated into the reconciliation and FISAP preparation process to verify accuracy, resolve discrepancies timely, and ensure federal reporting is complete, accurate, and supported by reconciliation documentation. 5. Risk Mitigation (Required - Even if Disagreeing) The University recognizes the importance of reducing exposure related to federal reporting accuracy and compliance. The corrective actions implemented are intended to strengthen oversight of reconciliation and FISAP reporting, improve coordination between responsible offices, and ensure that reported expenditure data is supported by timely and documented reconciliations, thereby reducing the likelihood of inaccurate reporting or future audit findings. 6. Responsible Party • Office/Department: Office of Financial Aid • Title of Responsible Official: Financial Aid Director • Name (optional): ____________ _ 7. Implementation Timeline 8. Status of Corrective Action (For Prior-Year or Repeat Findings) Fully implemented Partially implemented (Not yet implemented) Evidence of Implementation In progress, evidence is not yet available. 9. Monitoring and Sustainability The University will monitor compliance through ongoing supervisory review of monthly and year-end reconciliation documentation and periodic internal reviews of FISAP preparation processes. Reconciliation procedures and reporting controls will be routinely evaluated and reinforced through staff training and management oversight to support sustained compliance and accurate federal reporting.

Federal Program / Assistance Listing Number (ALN) 84.268, 84.063, 84.007, 84.033 Finding Reference Number 2024-004 1. Finding Summary The auditor found that the University did not complete or document required monthly or year-end reconciliations for several Title IV programs, resulting in unreconciled financial aid records between the Office of Financial Aid, the general ledger, and federal systems. Federal regulations require these reconciliations to ensure the accuracy of disbursements and compliance with Title IV requirements. 2. Management's Position Management agrees with the finding. Management Explanation Management agrees with the finding and acknowledges the failure to perform timely and documented reconciliations of Title IV programs during the audit period. Management concurs with the auditor's assessment that reconciliation is a critical internal control and recognizes the need to strengthen coordination, documentation, and timeliness between the Office of Financial Aid and the Business Office. 3. Root Cause Analysis The root cause was insufficient staff training on Title IV reconciliation and reporting requirements, resulting in inconsistent understanding of regulatory timelines, documentation standards, and cross-department coordination responsibilities. These training gaps limited the effective implementation of required reconciliation and monitoring processes. 4. Corrective Action(s) Management is working to implement standardized workflows and periodic internal monitoring between the Office of Financial Aid and the Business Office. Description of Corrective Actions To address this finding and prevent recurrence, the University has implemented standardized reconciliation procedures aligned with federal requirements. Reconciliation responsibilities have been formally assigned to a designated Financial Aid Counselor, with monthly reconciliations scheduled throughout each month for all Title IV programs. The Office of Financial Aid now utilizes standardized reconciliation checklists and templates, requires documented coordination and data matching with the Business Office and federal systems (COD and GS), and retains all monthly and year-end reconciliation records in accordance with federal record-keeping requirements. In addition, a mandatory year-end reconciliation review is completed prior to FISAP submission to ensure consistency across internal records, the general ledger, and federal reporting systems. 5. Risk Mitigation (Required - Even if Disagreeing) The University acknowledges the need to proactively manage regulatory exposure in this area. The corrective measures implemented are intended to strengthen oversight, promote consistent application of federal requirements, improve the accuracy and timeliness of reconciliation activities, and minimize the likelihood of future reporting issues or audit observations. 6. Responsible Party • Office/Department: Office of Financial Aid • Title of Responsible Official: Financial Aid Director • Name (optional): _ 7. Implementation Timeline • Corrective action implemented: (Yes) No • If not fully implemented, expected completion date: June 30, 2026 8. Status of Corrective Action (For Prior-Year or Repeat Findings) Fully implemented Partially implemented (Not yet implemented) Evidence of Implementation In progress, evidence is not yet available. 9. Monitoring and Sustainability The University will maintain ongoing oversight of reconciliation activities through routine internal reviews and supervisory verification to ensure procedures are consistently followed. Reconciliation processes and documentation practices will be periodically evaluated and updated as needed to support sustained compliance with Title IV requirements and long-term operational effectiveness.

The Institution will track R2T4 timeline with all involved to ensure timely completion; finalize system upgrades and testing so that the correct triggers and timelines are within the system; retain qualified staff for key roles; and implement robust training for all personnel.

The Institution implemented proper training and staff placement; enhanced system processing to avoid delays; and will conduct monthly checks on R2T4 processes.

The Institution had assigned personnel to oversee refund processing; implemented an alert system for deadlines; and will conduct monthly refund audits.

The Institution conducted staff training on documentation requirements; develop checklists and call guides; and regular audits of student files.

The Institution enhanced staff training on award calculations; implement system enhancements for enrollment status monitoring; and quarterly reveiws of Federal Pell Grant files.

The Institution had staff training on R2T4 deadlines; ensure proper information is submitted into the system on time; update system to flag missed deadlines; and conduct monthly audits.

Condition: Of the 40 students selected for Return of Title IV (R2T4) testing, 1 student did not have the appropriate amount returned to the federal agency. Planned Corrective Action: To prevent human error from occurring in the future, the Office of Financial Aid has immediately implemented the following process: When a recipient of Title IV grant or loan assistance withdraws from Eastern Michigan University and a Return of Title IV calculation is performed, a Senior Financial Aid Advisor or member of the Financial Aid Management staff will review all required returns completed to ensure accuracy. This review will occur on a weekly basis. Contact person responsible for corrective action: Jennifer Tremewan, Asst. Director Office of Financial Aid Anticipated Completion Date: December 31, 2024

Condition: Of the 40 students selected for enrollment reporting testing, 5 students did not have their status updated appropriately. Planned Corrective Action: The Office of Financial Aid has implemented a process to communicate and confirm with the office responsible for enrollment reporting to verify that enrollment rosters will not be/have not been sent after a semester has officially ended. Contact person responsible for corrective action: Jennifer Tremewan, Asst. Director Office of Financial Aid Anticipated Completion Date: December 31, 2024

Recommendation The College should continue to work with the accounting department and accounting systems to assist its auditor to catch up its financial reporting and records to allow for the completion of future audits. Corrective Action Unfortunately, due to the untimely completion and release of the June 30, 2023 audit report (released on August 8, 2025 - over two years after the end of the June 30, 2023 fiscal year audit), the College did not have the opportunity to review and begin a timely process of addressing a majority of the audit findings until well after the end of the audit period. While the College is committed to corrective action, the delayed delivery of the June 30, 2023 audit limited the ability to implement corrective measures earlier. The College is working proactively to ensure that these issues are resolved going forward. It is important to note that Southeast New Mexico College was a newly established independent community college, having formally separated from New Mexico State University (NMSU) as of April 2022. During this transition period, many administrative processes, including federal grant compliance procedures, were in the process of being developed, transitioned, and implemented independently from NMSU systems. As a result, certain policies, procedures, and documentation processes were not yet fully established or operational at the time of the audit. To ensure timely future submissions, the following corrective actions have been implemented. Revised Timeline and Calendar Controls: • A compliance calendar has been developed and integrated into the Business Office workflow to monitor federal reporting deadlines, including the DCF due date. This calendar includes reminder notifications at 90, 60 and 30 days before the March deadline. Internal Review Process: • A designated compliance officer or fiscal services staff member has been assigned responsibility for tracking the DCF submission process and coordinating with the external auditors to ensure timely receipt of the final audit. Audit Planning Coordination: • Annual audit planning meetings now include a discussion of reporting deadlines, and the contract with the external audit firm will include a clause requiring delivery of the final audit in a timeframe that supports compliance with federal submission timelines. Training and Awareness: • Relevant staff will have completed training in Uniform Guidance reporting requirements, including DCF submission procedures and deadlines to ensure full understanding of the importance of timely compliance. Due of Completion: August 31, 2025 Responsible Party(ies) Vice President for Business and Finance (or appropriate official), Dean of Business and Finance, Director of Finance, Accounts Receivable Coordinator, Business Office Manager

Recommendation We recommend the College strengthen controls to ensure future FISAP reports are submitted timely. Management Response Corrective Action To ensure timely submission of the Fiscal Operations Report and Application to Participate (FISAP) in future reporting cycles, the College will implement the following corrective measures: 1) Establish a Regulatory Compliance Calendar a. A centralized compliance calendar will be developed and maintained by the Business Office in coordination with Financial Aid. The calendar will include all federal and state reporting deadlines, including the FISAP, with automated reminders set at 90, 60, and 30 days prior to each deadline. 2) Formal Assignment of Responsibility a. The Director of Financial Aid will be designated as the primary responsible party for preparation and submission of the FISAP. A secondary backup (Controller or Business Office designee) will be assigned to ensure continuity and oversight. 3) Written Procedures Update a. The Financial Aid Procedures Manual will be updated to include documented steps, internal timelines, required data sources, reconciliation processes, and final submission verification procedures for FISAP completion. 4) Supervisory Review and Certification a. Prior to submission, the Vice President for Business and Finance will receive written confirmation of completion and submission to ensure executive level oversight. 5) Cross-Training a. Annual cross training between Financial Aid and Business Office staff will be conducted to strengthen institutional knowledge and reduce dependency on a single individual. Implementation Timeline: Compliance calendar implemented within 30 days Written procedures updated within 60 days Cross training completed prior to next FISAP cycle Executive review process effective immediately Monitoring Timely submission will be verified annually and documented as part of the College’s internal controls review process. Due of Completion: July 1, 2026 Responsible Party(ies) Vice President for Business and Finance, Dean of Student Affairs

Finding No.: 2024-07- Special Tests and Provisions: Enrollment Reporting Recommendation The College should develop and implement a formal process for monitoring and updating students' enrollment status in the NSLDS to ensure compliance with reporting requirements. Establish internal controls to track changes in enrollment status and ensure timely updates to the NSLDS. Conduct periodic reviews of the enrollment reporting process to identify and address any inaccuracies or delays. Provide training to relevant staff on the importance of compliance with enrollment reporting requirements and the procedures for accurate and timely updates. Response 1. The College will retain the FAO as the lead unit responsible for NSLDS enrollment reporting, in alignment with Title IV compliance functions. However, the College will strengthen interdepartmental collaboration by establishing a formal partnership with the Registrar’s Office, which maintains the official record of enrollment data. 2. A shared workflow and communication protocol between the FAO and Registrar’s Office will be developed to ensure timely, accurate updates of both campus-level and program-level data. The Registrar’s Office will be responsible for updating student enrollment data, which serves as the source data for NSLDS reporting. The FAO will extract and upload these reports via the Enrollment Reporting Roster (ERR) on the NSLDS Professional Access portal. 3. The College will implement internal controls to track and verify changes in student enrollment status, program information, and key data elements. These controls will include but by no means limited to: a. A monthly reconciliation process between SIS data and NSLDS records. b. Use of exception reports to flag and resolve inconsistencies or delays. c. Documentation of all update logs for audit purposes. Periodic reviews will be conducted at least once per term to assess the accuracy and completeness of enrollment reporting. Any discrepancies will be promptly addressed and procedures updated as necessary to prevent recurrence. Relevant staff in both the FAO and Registrar’s Office will receive regular training on NSLDS reporting requirements, including proper use of record types (Campus vs. Program Level), enrollment status codes, and certification timelines. Training will emphasize the implications of noncompliance and best practices for accurate reporting. Training logs will be maintained by both the FAO and Registrar’s Office to support accountability and audit-readiness. Contact: VPEMSS Completion Date: September 30, 2025