Corrective Action Plans

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

Policy and Procedure on coordination and reconciliation

Pending

Implement draft Policy & Procedures on monthly recs

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

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

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

The discrepancies identified were the result of inconsistencies between internal student records and data transmitted to COD for Direct Loan origination. These errors occurred due to manual data entry and timing differences between updates made in the institution’s student information system (SIS) and those reflected in COD. Financial Aid staff received refresher training on Direct Loan data accuracy, COD reporting requirements, and verification procedures to ensure consistent documentation and communication between systems. Collaboration with IT Office is underway to establish automated data checks between the SIS and COD files to minimize the risk of future mismatches. Implementation of the corrective action plan is expected to be complete by June 30, 2026. Responsible Party Robert Rood Interim Vice President Finance and Administration

This finding was related to staff turnover within the financial aid, student accounts and business offices. The hiring of qualified staff properly trained should avoid this error going forward. Implementation of the corrective action plan is expected to be complete by June 30, 2026. Responsible Party Robert Rood Interim Vice President Finance and Administration

This finding was related to staff turnover within the financial aid, student accounts and business offices. The hiring of qualified staff properly trained should avoid this error going forward. The Perkins program has ended and it is also likely that any personnel involved in the active years left years ago. We are currently working with UAS to reassign our Perkins portfolio back to the U.S. Department of Education. Implementation of the corrective action plan is expected to be complete by June 30, 2026. Responsible Party Robert Rood Interim Vice President Finance and Administration

A discrepancy was identified in the Pell Grant calculation for one student, resulting in an under-award of $250. The error was isolated and corrected; however, the institution was unable to determine the exact cause of the miscalculation at the time of review. The issue appears to have been related to a system-generated calculation variance that was not flagged through existing validation checks in the student information system (SIS). At the time of the finding, there were no automated cross-checks in place to compare scheduled awards against Pell tables for data validation prior to disbursement. The affected student’s Pell Grant award has been reviewed and corrected to reflect the appropriate amount. We are working with IT to develop and implement automated system checks that validate Pell Grant awards. Implementation of the corrective action plan is expected to be complete by June 30, 2026. Responsible Party Robert Rood Interim Vice President Finance and Administration

Finding 2024-004: Failure to Notify Secretary of HCM1 Reporting Events while Participating under the Zone Alternative Comments on Finding and Recommendations: The College agrees with this finding as determined in the examination and states that the College had deficiencies related to the Institution's failure to properly notify the Secretary of a violation of a loan agreement and a failure to make a payment in accordance with its debt obligations,that resulted in a creditor filing suit to recover funds under those obligations. Actions Taken or Planned: The College was unaware of the requirement to notify the Secretary of the concerns with the loans and is taking action to notify the Secretary at the time of generating this document. The College has hired an Accreditation and Compliance Officer to ensure that lack of understanding of requirements does not happen in the future. The College would also like to note the following: the individual referenced in the suit had given verbal, though not written permission to not pay the loan past the due date while she served as the Vice Chair of the Governing Board. Upon removal from the Board due to failure to perform duties the individual filed suit, the suit is being partially argued by the College’s attorney noting the complainant had failed in their duties while on the board and may have engaged with another individual to defraud the College. Additionally while the College is submitting notification currently, there is a Government shutdown that may interfere with the notification process.

Finding 2024-003: Incorrect Refund Calculation Comments on Finding and Recommendations: The College agrees with this finding as determined in the audit and states that the College had deficiencies related to the the return of funds to the Department of Education based on a miscalculation of the last day of attendance. Actions Taken or Planned: The College has returned the funds to the Department of Education and has instituted greater coordination between our departments including but not limited to the Academic Dean, Registrar, Accounting/Bookkeeping, Student Services and Financial Aid to ensure that last dates of attendance are accurately calculated to prevent future occurrences.

FINDING 2024-002: Financial Responsibility Comments on Finding and Recommendation: The College agrees with this finding as determined in the audit and states that the College had a net reduction in student enrollments and had incurred additional expenses as it operated and maintained the rent at two separate locations within Florida. The College incurred additional losses in tuition revenue and services revenue as it restructured how to operate both locations appropriately during 2024 while incurring additional costs as the previous entrenched management was moved out. Additionally the previous board had chosen to continue to push debt into following semesters, impacting each semester's ability to produce a profit. Actions Taken or Planned: The College acted in 2024 and 2025 to increase enrollment through, targeted advertising, bringing on a Director of Marketing and Media relations, examining the curriculum to remove waste and elevate the quality of education, changing the vision and mission statement, in 2025 requesting the Foundation investigate and remove the inactive Governing board who was engaging in practices furthering the school's financial difficulties. This has all led to a steady increase in the student population. Additional changes have been made to the program including recruitment criteria all leading to DRCOM quickly becoming a leader in East Asian medical education. While other colleges are closing DRCOM continues to experience growth. While reporting the Gainesville FL location as no longer offering instruction, but maintaining a clinical facility to allow - 15 - students to complete the requirements of their academic program in 2024 and 2025. The College also removed and replaced the Executive Director and other members of administration that contributed to the financial issues faced by the College.

Condition: Pell Grant disbursement data was not submitted to COD within the 15-day federal requirement due to a system error. Corrective Action: The Financial Aid Office, in collaboration with Bursar, will implement an automated alert system to flag pending COD submissions and conduct reconcilitions twice monthly. Responsible Party: Director of Financial Aid and Bursar Completion Date: January 31, 2026 Monitoring: Monthly COD reporting review with Vice President for Administration & Finance.

United States Department of Education Student Financial Aid Cluster – Assistance Listing No. 84.063 Condition: During our audit procedures, we noted that the 1 student withdrawal did not have a return to Title IV calculation completed timely as the student officially withdrew 8/29/23 and the calculation was not completed until 3/24/25. We also noted that the calculation that was performed did not include documentation of the control process to review and approve the calculations prior to changes being made to the student’s award. Auditors’ Recommendation: We recommend the institution maintain proper documentation in accordance with federal grantor requirements and ensure that the documents are readily available for review upon request, including monitoring of students with triggering events that require a return to Title IV calculation to be completed, reviewed, and approved. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University has implemented a new SIS and Financial Aid processing system. Name(s) of the contact person(s) responsible for corrective action: Qiana Hall, Associate VP of Enrollment Services Planned completion date for corrective action plan: June 30, 2025

United States Department of Education Student Financial Aid Cluster – Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Condition: Under an institution’s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs. Auditors’ Recommendation: We recommend the University engage a third party or perform the risk assessment for the two areas required by the Gramm-Leach-Bliley Act that have not been completed and documented and ensure that there are documented safeguards for identified risks. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University has implemented a new SIS and Financial Aid processing system. The new systems are Jenzebar products and are fully compliant. Name(s) of the contact person(s) responsible for corrective action: Qiana Hall, Associate VP of Enrollment Services Planned completion date for corrective action plan: June 30, 2025

United States Department of Education Student Financial Aid Cluster – Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Condition: Students tested in the Common Origination and Disbursement (COD) reporting were not properly reported based upon University documents, including disbursement dates and applied dates. Auditors’ Recommendation: We recommend that the University strengthen its internal controls to ensure that all disbursement dates are reported to COD accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The previous SIS was subject to frequent interruptions which prevent timely data exchange with COD. Beginning with the 2024-2025 award year a new financial aid processing system was implemented. The new processing system is a more secure environment and hosted by Jenzabar for added compliance assurance. Name(s) of the contact person(s) responsible for corrective action: Qiana Hall, Associate VP of Enrollment Services Planned completion date for corrective action plan: June 30, 2025

United States Department of Education Student Financial Aid Cluster – Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Condition: Student checks related to student refunds of Title IV federal financial aid was outstanding more than 240 days as of June 30, 2024. Auditors’ Recommendation: We recommend that the University review its procedures related to outstanding student refund checks to ensure they are being returned to the Department of Education after 240 days. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University engaged an external consultant in June 2023, hired a new staff accountant in September 2023 and a CFO in November 2023. The University is implementing financial internal controls policies and processes to improve the financial statements preparation and preparation of the schedule of expenditures and federal awards and ensure compliance with the DOE. This includes procedures related to outstanding student refund checks over 240 days. Name(s) of the contact person(s) responsible for corrective action: Denise Johnson, Interim Controller, Bursar Dept. Supervisor Planned completion date for corrective action plan: June 30, 2025

Student Financial Assistance Cluster – Assistance Listing No. 84.033 Recommendation: We recommend the College review its FSEOG awarding procedures and strengthen controls to ensure accurate identification and prioritization of eligible students based on EFC. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: CGCC has reviewed its Federal Supplemental Educational Opportunity Grant (FSEOG) awarding policy and will continue to ensure that FSEOG funds are awarded in accordance with federal guidelines. The discrepancy between the 2023–2024 award year and the current year was due to inaccurate Student Aid Index (SAI) data generated by a previous report. For the current year, the Financial Aid Office has identified and implemented a more accurate reporting tool, which has significantly improved the reliability of the SAI data used in awarding decisions. To further strengthen our internal controls and oversight, a new Financial Aid Director will be joining our team in June 2025. This leadership addition will enhance our ability to maintain compliance and ensure accurate, consistent awarding of FSEOG funds moving forward.. Name(s) of the contact person(s) responsible for corrective action: Sarajane Viemeister Planned completion date for corrective action plan: 6/30/2025

Student Financial Assistance Cluster – Assistance Listing No. 84.268, 84.063, 84.007, 84.033 Recommendation: We recommend the College strengthen its internal controls to ensure timely identification of students not meeting SAP standards. Additionally, the College should work with its system administrator to resolve the SAP calculation issue or implement an alternative method for tracking SAP compliance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: CGCC has completed a thorough review of its Satisfactory Academic Progress (SAP) policy to ensure alignment with the capabilities and limitations of our current system. We remain committed to resolving ongoing system-related issues and are actively keeping the policy and system functionality in sync as improvements are made. The issue regarding SAP not calculating correctly is still in progress. We have been working closely with Anthology to identify and implement long-term solutions. Unfortunately, the necessary fixes require significant time and manual intervention. Despite these challenges, we have made progress: as of Spring 2025, we are now able to accurately identify affected students—something that was not possible during the 2023–2024 award year. Additionally, we are in the process of hiring a Financial Aid Director. This added leadership and support will help us address the remaining issues more efficiently and continue making meaningful progress toward full resolution Name(s) of the contact person(s) responsible for corrective action: Denise Reid-Strachan Planned completion date for corrective action plan: 9/1/2025

Student Financial Assistance Cluster – Assistance Listing No. 84.268, 84.063, 84.007, 84.033 Recommendation: We recommend the College review its current procedures for Title IV funds and implement a control that prevents and detects errors in this process. Additionally, we recommend the College implement a formal review process to ensure the R2T4 calculations being prepared timely and correctly to minimize the likelihood that errors may go undetected and not corrected in a timely manner. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: CGCC is currently undertaking a comprehensive review of its Return to Title IV (R2T4) process. In light of recent staff departures, we are reassessing the applicable regulations and developing a formalized workflow, including clear documentation of our internal controls to support consistent and compliant implementation. Name(s) of the contact person(s) responsible for corrective action: Denise Reid-Strachan Planned completion date for corrective action plan: 9/1/2025

Student Financial Assistance Cluster – Assistance Listing No. 84.268, 84.063, 84.007, 84.033 Recommendation: We recommend the College implement procedures to ensure direct loan, Pell, FSEOG, and FWS reconciliations are reviewed and such review properly documented. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The College has reviewed its policies and procedures and the reconciliation process conducted by Global, its third-party servicer, and has implemented a procedure whereby the Financial Aid Office retrieves the prior month’s completed reconciliation at the beginning of each month. Those records will be reconciled with the finance system records within the SIS in coordination with the Business Office. The College will review the data and make any necessary updates to student records to ensure a complete end-to-end reconciliation between G5/COD, Global, and the College. Name(s) of the contact person(s) responsible for corrective action: Sam Draper & Denise Reid-Strachan Planned completion date for corrective action plan: 6/30/2026

Student Financial Assistance Cluster – Assistance Listing No. 84.268, 84.063, 84.007 Recommendation: We recommend the College review the requirements and implement a control to specifically monitor the outstanding Title IV funded checks and the refunds of disbursements to students throughout the year. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The College has reviewed its policies and procedures in relation to the audit finding and has implemented adjustments to its posting process to ensure more accurate recording of transaction dates that initiate the Title IV credit balance process. In addition, targeted training and coaching have been provided to responsible personnel to reinforce compliance and improve the timeliness of student refunds in accordance with statutory timeframes. Emphasis has been placed on the communication and coordination between the Financial Aid and Business office to ensure that batches are posted in a timely fashion in accordance with the disbursement dates on COD. Additionally, for instances of uncashed refund checks resulting from Title IV credit balances, the Business Office will collaborate with Financial Aid to ensure the return of funds to the appropriate federal programs within 240 days of the date of issuance. Name(s) of the contact person(s) responsible for corrective action: Sam Draper & Denise Reid-Strachan Planned completion date for corrective action plan: 6/30/2026

Student Financial Assistance Cluster – Assistance Listing No. 84.268, 84.063, 84.007, 84.033 Recommendation: We recommend the College review current processes and procedures for NSLDS enrollment reporting and implement an internal control that ensures reporting is both timely and accurate as well as retaining evidence of this control being performed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Enrollment reporting is the responsibility of the Columbia Gorge Community College (CGCC) Registrar. The reporting of enrollment information in a timely manner for the year ended June 30, 2024, was impacted by the implementation of a new Student Information System (SIS) in May 2021. The SIS included significant changes to student recording procedures and a new enrollment reporting process. In response to the Enrollment Reporting Finding for the year ended June 30, 2024, the Registrar continues to work on mitigating any issues that negatively impact enrollment reporting. Our reporting have significantly improved during the 2024-2025 academic year. Name(s) of the contact person(s) responsible for corrective action: Catherine Graham Planned completion date for corrective action plan: 9/30/2025