Corrective Action Plans

Although there was a procedure in place for timely reporting of withdrawals, an employee retirement caused the lapse in reporting. As a safeguard in the future, we have updated the documents procedures to indicate that all documents will be sent digitally to the registrar’s office, rather than a combination of paper delivery and/or email. By only email delivery, a trail can be followed to ensure both offices have received notification that the withdrawal process and its completion. As an additional safeguard, a regular review between all offices that manage student withdrawals will be conducted to ensure student cases have been completed timely. The email communication plan was put into place on February 13th, the monthly review will begin with the Month of March 2025.

MANAGEMENT’S VIEWS AND CORRECTIVE ACTION PLAN For the year ended December 31, 2024 Finding 2024-001 - Non-Compliance with Accurate Student Enrollment Change Submissions to the National Student Loan Data System (Significant Deficiency) Grantor: U.S. Department of Education Program: Student Financial Assistance Cluster Assistance Listing #: 84.268, 84.063 Award Titles: Federal Direct Student Loan Program, Federal Pell Grant Program Award Years: 7/2023 – 6/2025 Management agrees with the finding and proposes the following corrective action plan: Corrective Action Plan: Due to non-compliance with timely and accurate student enrollment change submissions to the National Student Loan Data System (NSLDS), Brigham Young University – Hawaii (BYUH) Management proposes the following corrective action plan to mitigate reporting errors. The Registrar’s Office, in coordination with BYUH’s Enterprise Information Systems team, will review and enhance the processes used to extract student data from PeopleSoft and transmit it to the National Student Clearinghouse (NSC) and NSLDS. This includes: -Reviewing all relevant PeopleSoft updates and ensuring that corresponding changes are reflected in the data transmitted to NSLDS. -Testing and validating the reporting processes within PeopleSoft to confirm data accuracy and completeness. -Verifying that the correct data is being transmitted to NSLDS. -Testing the student data within NSLDS to ensure its integrity. -Documenting the entire process for future reference and ongoing quality assurance. In addition, the Registrar’s office has already added additional resources to run all reporting processes. The Registrar’s office has also reached out to Ensign College to learn about their reporting process. The University is considering contacting the PeopleSoft reporting specialist that Ensign used, although that decision will be made at a later date, and if necessary. These actions will enable the Registrar’s Office to more effectively review credit load determinations and accurately establish program begin dates for students. Daryl Whitford, Registrar, will remain responsible for enrollment reporting at BYUH. She will oversee the implementation of the revised process, provide training to all relevant staff members, and lead the development and implementation of a control mechanism to ensurefuture compliance with NSLDS reporting requirements within PeopleSoft. Timing: Daryl Whitford, Registrar, will be responsible for overseeing that all items noted in the corrective action plan will be implemented by September 1, 2025. Signed and Acknowledged Daryl Whitford, BYUH Registrar

Management Views and Corrective Action Plan Year Ending December 31, 2024 Finding 2024-002 – Non-Compliance with Financial Need Requirements for Subsidized Direct Loans Grantor: U.S. Department of Education Program: Student Financial Assistance Cluster Assistance Listing#: 84.268 Award Titles: Federal Direct Student Loan Program Award Years: 7/2023 – 6/2026 Management agrees with the finding and proposes the following corrective action plan: Corrective Action Plan The incomplete installation of a student information system (PeopleSoft) update resulted in certain EFCs not prorating correctly. The incomplete system update that created this issue has been corrected. Moving forward, all PeopleSoft updates will be reviewed upon completion by Jesus Garcia, PeopleSoft project manager, to ensure all steps have been finalized as expected. Additionally, with the implementation of the 2024–25 FAFSA Simplification Act, prorated EFCs are no longer applicable. As such, this issue will not recur in future processing cycles. Timing The incomplete PeopleSoft update was corrected in March 2024. PeopleSoft updates are done every quarter and will be reviewed upon completion by Jesus Garcia. Because the 2024-25 FAFSA Simplification Act eliminated the use of prorated EFCs in this process there will be no further action taken. Sincerely, S. Christopher Reitz Director of Financial Services and Controller creitz@ensign.edu 801-524-8109

Management Views and Corrective Action Plan Year Ending December 31, 2024 Finding 2024-001 – Enrollment Reporting Grantor: U.S. Department of Education Program: Student Financial Assistance Cluster Assistance Listing#: 84.268, 84.063 Award Titles: Federal Direct Student Loan Program, Federal Pell Grant Program Award Years: 7/2023 – 6/2026 Management agrees with the finding and proposes the following corrective action plan: Corrective Action Plan Campus Status Matt Smith, College Registrar, will work with Tom Cote, NSC Enrollment Reporting Consultant, to adjust the enrollment report produced by PeopleSoft. With this change, PeopleSoft will report a student's campus-level enrollment as withdrawn when they withdraw in the middle of a semester instead of leaving them as less than half-time. Program Status Matt Smith, College Registrar, and Riley Niemand, Director of Financial Aid, will use the NSLDS Enrollment Error Report to reconcile what is being reported from NSC to NSLDS to ensure it is accurate. Timing Campus Status Matt Smith is currently working with Tom Cote to make these changes and work will be completed by the end of May 2025. Program Status Matt Smith and Riley Niemand will have this reconciliation implemented by the end of June 2025. Sincerely, S. Christopher Reitz Director of Financial Services and Controller creitz@ensign.edu 801-524-8109

Finding #2: Untimely Return of Title IV Funds (R2T4) Criteria: Under 34 CFR 668.22(j), institutions must return unearned Title IV funds no later than 45 days from the date the institution determines that a student has withdrawn. Condition: Six R2T4s were submitted late. While four were linked to third-party service platform transitions, two delays were related to students experiencing hardship (homelessness and mental health emergencies) and internal documentation gaps. Effect: Noncompliance with R2T4 deadlines may result in program findings, increased liabilities, and recurring audit scrutiny if unresolved. Corrective Actions for R2T4: 6. R2T4 Tracker Implementation o Action: Launch a live R2T4 tracker in Campus Café, flagged by withdrawal status and showing days remaining until the 45-day deadline. o Due Date: May 15, 2025 o Lead: Registrar, Business Office, Financial Aid Lead 7. Case Ownership Assignment Protocol o Action: Assign R2T4 responsibility to ECM and Business Office, written timelines and escalation criteria. o Due Date: May 15, 2025 o Lead: Executive Director 8. R2T4 Checklist & Escalation Framework o Action: Finalize a standardized checklist for all R2T4 cases including withdrawal date, calculation verification, fund return confirmation, and dual review. o Due Date: May 15, 2025 o Lead: Operations Manager 9. Quarterly R2T4 Audit o Action: Conduct quarterly compliance audits on all R2T4 files and include findings in compliance reports. o Due Date: First audit by June 30, 2025 o Lead: Compliance Officer 10. Emergency Circumstance Protocol o Action: Document a formal protocol for handling R2T4 cases with student hardship that allows internal escalation, verification, and documentation of exception handling. o Due Date: July 1, 2025 o Lead: Executive Director Monitoring Plan: Compliance will provide a quarterly report on R2T4 timeliness to the Executive Director. Any case that nears 35 days will be auto escalated for executive intervention.

Finding #1: Delayed or Incomplete Enrollment Reporting Criteria: Per 34 CFR 685.309(b), institutions must report student enrollment status changes (withdrawals, graduations, leaves of absence) within 30 days of determination or every 60 days using a consistent reporting schedule. Condition: Enrollment changes for several students were not reported to NSLDS within the required timelines. Delays resulted from third-party servicer (ECM) processing issues, gaps in cross-verification, and lack of internal triggers for mid-enrollment aid recipients. Effect: Untimely reporting may result in incorrect loan repayment statuses for borrowers and may trigger additional oversight by the Department of Education. Corrective Actions for Enrollment Reporting: 1. Shared Operational Calendar with Alerts o Action: Expand the institutional calendar to include enrollment reporting cycles with automated alerts 15 and 5 days before reporting deadlines. o Due Date: May 15, 2025 o Lead: Registrar 2. Internal Monthly Cross-Verification Audit o Action: Reconcile Campus Café enrollment records with ECM NSLDS batch confirmations monthly to catch and correct discrepancies. o Due Date: Begins May 2025, ongoing o Lead: Compliance Officer 3. Enhanced Title IV Status Tracking o Action: Update batch tracker template to log when students begin receiving Title IV aid after initial enrollment, with clear notation requirements. o Due Date: May 15, 2025, Ongoing o Lead: Registrar 4. Targeted Staff Training o Action: Deliver internal training on accurate Title IV status coding and enrollment reporting procedures to Registrar and Business Office teams. o Due Date: May 15, 2025 o Lead: Executive Director & Registrar 5. Bi-Monthly Enrollment Reporting Review o Action: Conduct a compliance review every 8 weeks to assess reporting timeliness and documentation quality. o Due Date: Begins May 2025 o Lead: Compliance Officer Monitoring Plan: Compliance team will issue bi-monthly reports to the Executive Director summarizing reporting performance and identifying risk patterns.

2024-002 Student Financial Aid Cluster – Assistance Listing 84.063 and 84.268 Recommendation: The College should evaluate their procedures and review policies surrounding reporting enrollment effective dates and program enrollment effective dates NSLDS. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Through the review of program reporting and campus reporting, the college will identify the cause for the data error. The college will explore the impact of branch campuses and the potential to shift to a single college reporting model. The following specific steps will be completed. 1. Identify and Analyze the Issues 2. Root Cause Analysis 3. Corrective Measures 4. Automation: Implement automated checks and balances to ensure data integrity before files are processed and sent. Name(s) of the contact person(s) responsible for corrective action: Patricia Munsch, Ph.D. Vice President for Student Affairs Nancy Brewer, College Director for Financial Aid Cheryl Eldredge, College Associate Dean for Registrar and Master Schedule Planned completion date for corrective action plan: December 31, 2026

2024-001 Student Financial Aid Cluster – Assistance Listing 84.063 and 84.268 Recommendation: The College should review their reporting internal controls and procedures to ensure that they require students' statuses to be reported timely to NSLDS as required by federal regulations. The College should evaluate their procedures and review policies surrounding reporting status changes to NSLDS to ensure the enrollment effective date reported to NSLDS aligns with the College’s last date of attendance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Through the work of a college-wide task force the following actions will be taken in response to the finding. The task force will include representatives from Information Technology, Institutional Research, Financial Aid, Registrar, along with Ellucian consultants. To summarize the steps and details of implementation to the specific areas are as follows: 1. Review Reporting Controls and Procedures 2. Address Error Code 22 3. Review Procedures Surrounding Reporting Status Changes 4. Assure Accuracy in Reporting Enrollment Effective Date Name(s) of the contact person(s) responsible for corrective action: Patricia Munsch, Ph.D. Vice President for Student Affairs Nancy Brewer, College Director for Financial Aid Planned completion date for corrective action plan: December 31, 2026

2024-003 Student Financial Aid Cluster – Assistance Listing 84.063, 84.268, 84.007, and 84.033 Recommendation: We recommend reviewing and implementing GLBA guidelines in order to explain the College’s information-sharing practices to their customers and to safeguard sensitive data, including student financial information. We also recommend designating a qualified individual responsible for implementing and monitoring the institution’s information security program. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The College is working toward documenting its policy and procedures with the proper oversight and its continual monitoring of all GLBA guidelines and the sensitive student data therein. While the College has been in the practice of safeguarding all its sensitive student data and adhering to all the GLBA guidelines. It has not been properly documented. The qualified designated individual responsible for the implementation and continued monitoring is Jason Fried, College Director of Service Delivery and IT Compliance. Name(s) of the contact person(s) responsible for corrective action: Sara E. Gorton, CPA, Vice President for Business and Financial Affairs Holmer A. Avellan, CPA, CFE, Controller Jaime Hahn, Senior Auditor Stephen Clark, College Administrative Director of Infrastructure Services Jason Fried, College Director of Service Delivery and IT Compliance Planned completion date for corrective action plan: August 31, 2025 If the Department of Education has questions regarding this plan, please call: Sara Gorton, CPA, VP of Finance and Business Affairs 631-451-4223

The error identified stemmed from a lack of independent review caused by staffing turnover and unfilled positions within the Student Financial Aid Department during the year ended June 30, 2024. While the refund for one student was returned, we acknowledge that it was not processed within the required timeframe. To address this issue and ensure compliance moving forward, the University has prioritized filling vacant positions within the Student Financial Aid Department. Additionally, the University has implemented a procedure requiring an independent review of all R2T4 calculations. A designated reviewer will 400 Magnolia Street – Orangeburg, SC 29115 A University of the United Methodist Church verify computations and ensure compliance with federal requirements prior to the return or disbursement of funds.

Management Response: Management concurs with the finding and will reconcile the College’s disbursement records with the federal COD system and correct all errors on a monthly basis.

Management Response: Going forward, all students who withdraw from the College will be forwarded to the financial aid team to review whether a student is still eligible for the full funding of the specific semester in question or whether funding needs to be returned based on the withdrawal date. If it is deemed that funds need to be returned, the Bursar will provide the financial aid team with a copy of the student charges for that period and the Registrar will provide proof of the withdrawal date and the financial aid team will determine the amount of funding that needs to be returned. Financial aid will then complete the return through the student's account and notify the Controller and VP of Finance and Administration to process the return to G5.

Management Response: The College concurs with the finding and is in the process of implementing a policy when satisfactory academic progress is run, students will be notified via mail or email of their academic standing. Students who are suspended will have an opportunity to appeal their suspension. If the appeal of suspension is approved, students will meet with their academic advisor to be placed on an academic plan. The academic plan must be signed by both the student and advisor. The academic plan must be submitted to the Office of Financial Aid via the teams. A financial aid hold will be placed on the student's account until the signed academic plan is received. Once received, the Office of Financial Aid will remove the hold so the student can be awarded.

Management Response: The College acknowledges and concurs with the finding. The College is in the process of implementing changes to the student information systems and related process to accommodate both the internal enrollment polices and required reporting statuses, and enhances monitoring processes to ensure the integrity and punctuality of data reported to the NSLDS.

CORRECTIVE ACTION PLAN A. Comments on Findings and Recommendations: We agree with the finding and recommendation. B. Actions Taken or Planned: Upon review, the institution has found this to be an isolated incident due to human error. Additional refresher training has been performed to reinforce understanding of processes.

Finding 2024-002 – Student Financial Aid Cluster, Assistance Listing # 84.063 and 84.268 Limestone University utilizes Jenzabar software to extract and report enrollment data to the National Student Clearinghouse (NSC). However, in some instances, the data reported was incorrect. Since the occurrence of this issue, the University hired a new Registrar in August 2024. After reviewing the findings, the Registrar implemented the use of the NSC Edit Student Data Records window, in addition to the NSC Edit Registration Transactions window. This change allows a special status on the NSC Edit Student Data Records window to override the status on the Registration Transactions window, providing more precise monitoring of withdrawal dates and ensuring the accuracy and timeliness of the data reported to NSC. To ensure ongoing accuracy, the Registrar now reports enrollment status changes to NSC on a monthly basis. Additionally, the University reviewed the students identified in the findings, along with other students who had the same status (withdrawn) and made adjustments as necessary to ensure that all student data was accurately reported.

Finding 2024-002 – The Organization’s current documented procurement policy does not contain all the required elements identified within the Uniform Guidance. 2024-002 Recommendation: The Organization should adopt a formal procurement policy that complies with 2 CFR 200, Sections 200.318 through 200.327. Action Taken: Management agrees with the finding and will review the requirements under the Uniform Guidance relating to procurement and establish a formal policy and related procedures to comply with those requirements. Expected Date of Completion: June 30, 2025

Finding 2024-001 – Salaries and wages of employees charged or allocated to the major program were not supported by formal records that accurately reflect the work performed. During our testing of four payroll transactions, we noted three timesheets had no approval and the Organization recorded amounts based on budgeted estimates rather than actual amounts for all four payroll transaction tested. For those payroll transactions tested, two transactions were overcharged by $563 and two were undercharged by $527 resulting in a net overcharge to the grant of $36. The sample was not intended to be, and was not, a statistically valid sample. 2024-001 Recommendation: We recommend the Organization implement a process and related controls related to review and approval of payroll expenditures for allowability in accordance with the terms of the grant award and federal regulations. Payroll amounts charged to the grant should be based on actual time and effort reported by the employee working on the grant and related documentation maintained by the Organization to support those amounts. The Organization should implement a review process over recording time and effort for payroll transactions, for proper classification and allowability. Action Taken: Management agrees with the finding and has taken corrective action by formally adopting controls which will track the employee’s actual time spent. These controls were placed in service during the year ended June 30, 2024, but were not in place for the entire year. Date of Completion: February 16, 2024

Corrective Action Plan Year Ended June 30, 2024 Finding 2024-002: Reporting: Pell Grant Disbursement Data Condition Found: In the auditors’ testing over reporting of Pell Grant disbursement data for the year, they identified a total of twenty-three late submissions of the forty samples reviewed. Recommendation: The auditors recommend the University enhance our internal control over compliance with the federal regulations related to reporting of Pell Grant disbursement data. The University should maintain an appropriate level of staffing to properly perform timely reporting of Pell Grant disbursement information to the COD system. The University should also align the internal control process of reporting Pell Grant disbursement data regardless of semester to eliminate manual errors. University of Delaware Corrective Action Plan: The University agrees with the finding. These late reporting stemmed from two issues. The fall and spring delays were related to errors in the reporting file, which caused the disbursements to fail in processing through the COD via the electronic batch process. The Student Financial Services team identified these errors during their reconciliation process, generally completed weekly. However, during part of the last academic year, this schedule was not consistently followed due to staffing issues. In addition to the fall and spring delays, there were delays in reporting summer Pell disbursements. This delay was directly related to correcting the University’s self-identified issue with the awarding and disbursement of funds during the Winter term related to Finding 2024-001. The University has corrected the processing of Pell during the winter term which will eliminate the sequencing issue. Additionally, the University has implemented electronic batch processing to COD for the summer term and addressed staffing issues to ensure that the reconciliation process continues on a weekly basis. Completion Date: November 1, 2024 Contact Person: Amanda Steele-Middleton, Assistant Vice President for Enrollment Management

Corrective Action Plan Year Ended June 30, 2024 Finding 2024-001: Disbursements: Pell Grant Condition Found: The University utilizes a standard term calendar and therefore should calculate federal student aid under Formula 1 (Volume 7, Chapter 1). Under Formula 1, institutions generally calculate a student’s Scheduled Award and splits such award evenly between the fall and spring semesters. The University offers a winter intersession, but did not combine the winter intersession with the fall or spring semester as prescribed by the Federal Student Aid Handbook when calculating federal student aid awards under Formula 1. Instead, the University used Formula 3 to calculate Pell Grant awards and treated the winter intersession as a separate term and awarded Pell Grants to students for the Winter 2024 intersession. In 2024, the University identified that such approach did not align with applicable Title IV regulations and Department guidance. By using Formula 3 to calculate Pell Grant awards, the University exceeded the students’ standard Scheduled Award. The total amount of over-awarded Pell Grants for the 2023-2024 academic period was $698,000. Recommendation: The auditors recommend the University enhance our internal control over compliance with the federal regulations related to disbursement of Pell Grant awards. The University should enhance how we receive, and process external information to ensure the University is properly awarding federal student aid in accordance with Title IV regulations and Department guidance. Additionally, a control should be designed and implemented for the review of such information. University of Delaware Corrective Action Plan: The University agrees with the finding. The University identified this issue as a result of an extensive review of processes, procedures and internal controls within Student Financial Services with the assistance of both external consultants and outside counsel. Through the University’s research, it was determined that this issue began in 2018 with the reintroduction of Year-Round Pell. The over-awarded amount resulted from the misinterpretation of the regulations and associated guidance and use of the incorrect formula. The University self-identified the issue with the Department of Education and is working towards resolution. The questioned costs of $698,000 related to fiscal year 2024 were refunded to the government through COD system as of September 30, 2024. The University is working with the Department of Education to open prior periods to finalize the repayment of an additional $1.9 million which is expected to be completed by June 30, 2025. The University has implemented internal controls which include the use of the Peoplesoft delivered tools to ensure that Pell is awarded using Formula 1 in accordance with Title IV regulations and Department guidance. The information related to winter intersession aid has been updated to specifically address winter Pell and ensure that it meets required regulations for attaching an intersession to a standard term when using Formula 1 for calculating Pell grant eligibility. Additionally, the University has implemented a weekly reconciliation and over-award reports to monitor for compliance. Completion Date: Return of $698,000 Questioned Costs: September 30, 2024 Implementation of Weekly Reconciliations: November 1, 2024 Return of Additional $1,900,000: Anticipated June 30, 2025 Contact Person: Amanda Steele-Middleton, Assistant Vice President for Enrollment Management

Condition During our testing, the College was unable to provide evidence of these Direct Loan reconciliations being performed monthly. Corrective Action(s): Community Christian College will include cash management for Direct Loans into our reconciliation process: Monthly meetings will be held each month between the Financial Aid Department and the Accounting Department. Monthly reconciliation will begin May 2025.

Condition During our testing over the NSLDS reporting requirements, the following deficiencies were noted: 3 of 50 program reporting details did not agree with enrollment details from the enrollment records per the College. 24 of 40 students did not have campus reporting completed within the required timeframe. Corrective Action(s): Community Christian College has established the following procedure to ensure timely reporting to NSLDS on behalf of our students. The implementation of bi-weekly Change in Status meetings to identify enrollment updates on the campus level will assist us in updating student statuses in CCC’s student information system. Community Christian College will implement a bi-weekly reconciliation process where discrepancies will be flagged, investigated, and corrected during that time. CCC will do a mass reconciliation immediately and begin the bi-weekly reconciliation process in June 2025. Additional measures: The Director of Financial Aid will conduct mandatory NSLDS reporting training for all relevant staff, including how to identify and correct discrepancies and if seen fit, assign a designated enrollment reporting coordinator to work closely with our 3rd party servicer to ensure accurate and timely reporting.

Condition During our testing over the return of credit balances, the following deficiencies were noted: 􀁸 8 instances where credit balances were not refunded in the required time frame. 􀁸 11 instances where refunds were due to students, but none were posted in the ledger. 􀁸 7 instances where the balances refunded to students could not be recalculated. Corrective Action(s): Community Christian College has established the following procedure to ensure the timely return of credit balances: The college will revise and formalize the institutions credit balance refund policy to align with federal regulations. The college will implement a centralized tracking log to include fields for credit balance creation date, refund due date, refund issue date, and reconciliation status. The reconciliation process for unresolved credit balances/refunds will begin April 21, 2025 and should be completed by April 25, 2025. CCC will begin developing a tracking process to have in place for next start in June 2025. Additional measures: Community Christian College has established a bi-weekly reconciliation process to take place between the Accounting Department and the Financial Aid Department; this internal audit will ensure the credit balances aligns with federal regulations. Furthermore, the Director of Financial aid will conduct trainings will all parties of both departments.

Condition The College did not retain supporting evidence utilized for reporting certain critical information within the FISAP including: 􀁸 Total number of students 􀁸 Total tuition and fees 􀁸 Information on eligible applicants Corrective Action(s): Community Christian College will establish a pre-submission review process where the Director of Financial aid will verify that all data reported in the FISAP is accompanied by appropriate supporting evidence: The college will use reports made available by our 3rd Party Servicer to report accurate data each FISAP submission year. This process will begin for the 26-27 Award year.

Condition During our procedures over Return to Title IV requirements, the following deficiencies were noted: 􀁸 7 of 13 Return to Title IV calculations were performed outside of the allowable time frame. 􀁸 1 of 13 withdrawn students did not have a Return to Title IV calculation performed. 􀁸 2 of 6 instances where funds were returned beyond the required time frame. Corrective Action(s): Community Christian College has established the following procedure to ensure timely and compliant processing of Return to Title IV (R2T4) calculations: The College will conduct bi-weekly Change in Status meetings to proactively monitor and identify any enrollment changes within the active student population. This process enables the timely identification of students who have recently withdrawn or are pending withdrawal. By doing so, the institution is able to initiate the R2T4 process promptly and ensure its completion within the federally mandated 30-day timeframe, thereby maintaining compliance and upholding institutional accountability. The bi-weekly Change in Status meetings will begin May 2025 and will continue as such, with adjustments made as needed. Additional measures: Community Christian College’s Registrar will notify respective parties of any enrollment changes; this ensures no changes go unnoticed between biweekly meetings.