Corrective Action Plans

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend that the College correct there mistake and review the amount of days scheduled in each break for next fiscal year. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The finding was caused by incorrectly calculating the Spring Break dates in the academic calendar. The former Director of Financial Aid accounted for the weekdays of break (M-F=5 days) instead of the required full week plus shouldering weekend dates (9 calendar days) as it should have been entered. This erroneous entry was not noticed or caught in a self-audit process. We have completed a 100% file review of withdrawn students and updated the break calculation to correct the error for this year, and moving forward we will conduct two levels of review when entering calculation parameters to ensure accuracy of break calculation. We have updated the affected students’ R2T4 calculations and sent the fund updates to COD on September 20th. The corrective action taken by the current Director of Financial Aid is to ensure there are two extra reviewers added to each future parameter rollover to make sure all dates are accurate in our processing software, as well as a second review of each completed R2T4. Name of the contact person responsible for corrective action: Margaret Price, Director of Financial Aid Planned completion date for corrective action plan: This new process is already in place for the 2024-2025 academic year.

College Corrective Action Plan: Every 30 days, Ringling College of Art and Design reports updated student enrollment activity, encompassing attendance levels, graduation status, withdrawals, dropouts, and enrollment changes, to the National Student Loan Database System via the National Student Clearinghouse. Regrettably, during the 2023-24 academic year, an unforeseen error from the Clearinghouse resulted in the dissemination of incorrect enrollment statuses for a subset of our students. This oversight was beyond the Registrar's Office's knowledge, leading to an unintended delay in rectifying the reported statuses. We believe this Clearinghouse error was an isolated incident, having never occurred in any preceding academic year. The issue has been effectively resolved and should not recur in the future. Nevertheless, as a proactive measure, commencing with the 2024-25 academic year, the Financial Aid Office will collaborate with the Registrar's Office to review a representative sample of at least 10% of student records transmitted to the Clearinghouse. This review process will serve as an additional safeguard, ensuring the accuracy and timeliness of our reporting requirements. Lee Harrell Director of Financial Aid, Office: 941-359-7532, Cell: 941-928-9413

2024-001: Errors Relating to Return of Title IV Financial Aid - Student Financial Aid Cluster Assistance Listing Number 84.007, 84.033, 84.038, 84.063, 84.268, 84.379, 93.264 Grant Period - Year Ended May 31, 2024 Condition Found During our return of Title IV Fund testing we noted that the University did not calculate or return Title IV for students who ceased attendance correctly for two students out of eleven. The University used the incorrect number of days for the total days in the period of enrollment when calculating the return of Title IV.We consider this to be an instance of non-compliance relating to the Special Tests and ProvisionsCompliance Requirement. Corrective Action Plan Moving forward, the financial aid team will implement internal controls: Marlon Jones, Director of Financial Aid will process the R2T4 using COD instead of Banner. So, Marlon will ensure that the dates for fall break (fall term)/spring break (spring term) are properly utilized within the R2T4 calculations, prior to the start of the terms. After Marlon’s initial process of completing the R2T4 calculation in COD, Erika Guzman, Associate Director, will check the completed R2T4 to ensure precise calculations. This new addition will ensure that two people are determining the accuracy of the R2T4’s, as well as ensuring that the breaks during the terms, are included. Responsible Person for Corrective Action Plan Marlon Jones Jr and Erika Guzman Implementation Date of Corrective Action Plan 9/23/2024

Re: Response to References Number 2024-001 Student Financial Aid Cluster View of Responsible Officials: Comments on Finding and Recommendation The University agrees that the department did not accurately report the dates of two students' tested enrollment status changes. One date was off by two days, and the second one was off by ten days. This was caused by human error when updating the National Student Clearinghouse error report. Corrective Action Plan for References Number 2024-001 Student Financial Aid Cluster: The University Registrar provided additional training to the staff on the proper way to report status changes when a student withdraws to ensure the actual date of the withdrawal request is used instead of the final date of the term. This training occurred on 9.3.24 before the September National Student Clearing House (NSCH) was submitted. The University Registrar will review the error reports with the staff to ensure the dates are entered correctly before submission. Mid-America Christian University’s University Registrar, Stephanie Davidson, will be responsible for ensuring this corrective action plan is followed as outlined. Stephanie can be reached at stephanie.davidson@macu.edu or 405-692-3241

Recommendation: We recommend the College evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Starting in 2025-26 the College is transitioning to a new ERP, a more robust software system, that will correct this issue. However, in the meantime, the financial aid office will not rely on our current software to automatically match COD Disbursement dates with student account posting dates. The financial aid and business offices will communicate to ensure posting to student accounts are done on the same day as aid is disbursed. In addition, the financial aid and business offices will add a new process to compare COD reports with current software reports on a regular basis to look for any discrepancies. Any discrepancies found will be manually corrected on a timely basis. Name(s) of the contact person(s) responsible for corrective action: Eric Anderson, Director of Financial Aid Planned completion date for corrective action plan: June 30, 2025

Recommendation: We recommend the College reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to put a process in place to ensure the student status changes are being reported timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The 2022-23 audit identified similar issues regarding NSLDS enrollment reporting. Following the 2022-23 audit, the College changed the submission dates to the NSC to allow more time for the NSC to timely report to the NSLDS. Upon further research following the 2023-24 audit, the College learned that this finding relates to manually reported graduates and withdrawn students. Graduates reported during the automated file submittal process were reported as graduating at end of term, while graduates reported manually were reported as graduating on the College’s actual commencement date (one day different than end of term). Going forward the Registrar will be consistent in reporting graduation dates using the end of term for all graduating students. As for the reporting of withdrawals, the Registrar will manually update the enrollment status and effective dates in NSLDS to ensure accurate and timely reporting in the 2024-25 fiscal year. Starting in 2025-26 the College is transitioning to a new ERP, a more robust software system, that will correct this issue. Name(s) of the contact person(s) responsible for corrective action: Austin Nyhof, Registrar Planned completion date for corrective action plan: June 30, 2025

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to put a process in place to ensure the enrollment effective date reported to NSLDS on the campus and program level is aligning with the University. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Training on National Student Clearinghouse reporting steps when a non-returning student is processed after the first of term report has been submitted to National Student Clearinghouse. Review process for using end of term date, not Commencement ceremony date as award date. Name(s) of the contact person(s) responsible for corrective action: David L Kumm, Executive VP CFO/COO Planned completion date for corrective action plan: 10/31/2024

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend that the University review the updated GLBA requirements and ensure their WISP includes all required elements and is formally implemented. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The currently-implemented IT procedures were documented in a written information security program (WISP). However, they had not been reviewed and approved during the year of the audit. A penetration test was completed in the Spring of 2024. The penetration testers were unable to gain access to any of the University’s information systems. A risk assessment and vulnerability assessment are scheduled to be completed before April 30, 2025. These actions should correct all significant deficiencies identified in section 2024-001. Name of the contact person responsible for corrective action: Douglas Wade, Executive Vice President and CFO Warner Pacific University 2219 SE 68th Ave Portland OR 97215 dswade@warnerpacific.edu Office Phone 503-517-1043 Cell Phone 661-706-8379 Planned completion date for corrective action plan: April 30, 2025

FINDING 2024-1 UNTIMELY RECONCILIATIONS Comments on Findings and Recommendations The management agent concurs with the auditor’s findings and recommendations. Actions Taken or Planned Management has assigned individuals responsible for performing monthly reconciliations.

COMPLIANCE FINDING 2024-001 Disbursements to or on behalf of Students September 25, 2024 Criteria: Before an institution disburses title IV, HEA program funds for any award year, the institution must notify a student of the amount of funds that the student or his or her parent can expect to receive under each title IV, HEA program, and how and when those funds will be disbursed. If those funds include Direct Loan program funds, the notice must indicate which funds are from subsidized loans, which are from unsubsidized loans, and which are from PLUS loans (34 CRF 668.165(a)(1). Except in the case of a post-withdrawal disbursement made in accordance with § 668.22(a)(5), if an institution credits a student ledger account with Direct Loan, Federal Perkins Loan, or TEACH Grant program funds, the institution must notify the student or parent of (34 CFR 668.165(a)(2)) – (i)The anticipated date and amount of the disbursement; (ii)The student's or parent's right to cancel all or a portion of that loan, loan disbursement, TEACH Grant, or TEACHGrant disbursement and have the loan proceeds or TEACH Grant proceeds returned to the Secretary; and (iii)The procedures and time by which the student or parent must notify the institution that he or she wishes to cancelthe loan, loan disbursement, TEACH Grant, or TEACH Grant disbursement. The institution must provide the notice described in paragraph (a)(2) of this section in writing (34 CFR 668.165(a)(3)) (i)No earlier than 30 days before, and no later than 30 days after, crediting the student's ledger account at theinstitution, if the institution obtains affirmative confirmation from the student under paragraph (a)(6)(i) of this section;or (ii)No earlier than 30 days before, and no later than seven days after, crediting the student's ledger account at theinstitution, if the institution does not obtain affirmative confirmation from the student under paragraph (a)(6)(i) of Effect: Noncompliance with certain requirements under 34 CFR 668.165(a). Corrective Action: The Office of Financial Assistance has established and implemented procedures that ensure students and parents receive the notifications relating to certain federal loans as required under 34 CFR 668.165(a). Specifically, the notifications will be made via electronic mail and include the anticipated date and amount of the disbursement; the recipients' right to cancel the loan or disbursement; and the procedures and time relating to the recipients' notification of cancellation. These notifications will occur within the required time frame resulting from the type of confirmation received from the student. This procedure will adequately address these requirements. Contact Person: Ashley Owens

Correction action University personnel corrected the records in NSLDS and Clearinghouse on July 26, 2024 that were identified in Finding 2024-001. Additionally, university personnel conducted a thorough review of all students to ensure the records in NSLDS properly reflected an accurate enrollment status. The university immediately (August 2024) implemented training for the newly appointed Interim Registrar on the importance of timely and accurate reporting of enrollment status changes and graduation status. This training was conducted in coordination with the Vice President of Student Services, the Director of Financial Aid, the Controller, and the Director of Information Technology. In addition to hands-on training provided by university personnel, online resources were utilized from NSLDS, Clearinghouse, and the United States Department of Education. The policies and procedures for enrollment reporting has been strengthened, and includes the following reporting schedule: a student roster schedule will be submitted every 30 days. The exceptions report will be reviewed immediately and will be corrected within 10 days. Within 15 days of the end of each semester, a list of graduated students will be submitted to NSLDS. Exceptions will be corrected immediately to ensure all records in NSLDS match the student’s record. The university is confident that the finding related to enrollment reporting has been resolved. Enrollment files are being submitted every 30 days. Summer 2024 completers graduated on August 9, 2024. These students were reported through Clearinghouse, exceptions were addressed, and enrollment statuses of “Graduated” show on NSLDS as certified on September 13, 2024. The schedule of enrollment and reporting and graduation reporting will ensure that the statuses will be accurate in NSLDS. Responsible Person Rose Mulkey, Interim Registrar Anticipated completion date Completed as of July 26, 2024.

Special Tests and Provisions – Enrollment Reporting – Significant Deficiency in Internal Controls over Compliance - Federal Assistance Listing Number 84.063, 84.268 Recommendation: The auditors recommend the University further educate and train those involved in the reporting of enrollment status changes to the NSLDS. The auditors also recommend the University review our documented policies and procedures and ensure controls exist and are well documented in order to ensure enrollment data is reported timely and accurately to NSLDS. Action taken: The Director of Financial Aid will continue education on enrollment reporting requirements. The Director and the Registrar will continue to work together on enrollment reporting requirements. The Director of Financial Aid will now report withdrawals due to R2T4, as well as conferrals, to the National Student Loan Data System directly once the University receives notice of either withdrawal or completion of a degree. Weekly, withdrawals for R2T4 are monitored and reported and now SFA will report directly to NSLDS to avoid any lag time in relying on reporting to the Clearinghouse. At the end of each term, after the Registrar has conferred degrees, SFA will also acquire the list of students who have graduated and report their graduation status to NSLDS. Name of Responsible Party: Erin Schaffer Anticipated completion date: 9/30/2024

Gramm-Leach-Bliley Act – Student Information Security – Significant Deficiency in Internal Controls over Compliance – Federal Assistance Listing Number 84.063, 84.268, 84.007, 84.033, 84.379, 84.038 Recommendation: The auditors recommend the University review the compliance requirements and update our written policy to ensure that it addresses all the required elements. Action taken: The CIO, Mary Donahoo, worked in conjunction with prior CFO to create a timeline for implementation for the requirements of GLBA. The Information Technology Services (ITS) department had begun policy development pertaining to the Gramm-Leach- Bliley Act (GLBA) specific elements in 16 CFR 314.4 during fiscal year 2024 but was unable to complete all the required implementations. The ITS department implemented, during fiscal year 2024, improvements to cyber security and minor elements of GLBA, including multifactor authentication. The action plan anticipates completion of all elements of GLBA by the end of the calendar year. Name of Responsible Party: Mary Donahoo Anticipated completion date: 12/31/2024

Condition - Student enrollment reporting was not performed by the Institute after September 2023. Corrective Action Plan - The Financial Aid Officer will continue to pursue ongoing training through FSA, NASFAA and ISAC to ensure that all reporting is done in a timely manner as required by regulations. Contact Person, Title and Phone Number - Chris Scott, President, (815)-772-7218, Ext. 212 Anticipated Completion Date - August 1, 2024

Condition - The Institute had the following changes that have not been updated in the Officials section on their ECAR: • A Board Member was no longer serving the institution as of May 2021. • A Board Member was added to the Board in March 2024. • A Board Member was no longer serving the institution as of May 2024. • A Financial Aid Officer was no longer active at the institution as of September 2023. • A new Financial Aid Officer was active at the institution as of September 2023. Corrective Action Plan - The Institute will review current procedures and adjust accordingly to ensure timely ECAR updates. Contact Person, Title and Phone Number - Chris Scott, President, (815)-772-7218, Ext. 212 Anticipated Completion Date - August 1, 2024

Finding – Special Tests and Provisions: Enrollment Reporting – Federal Direct Student Loans, Assistance Listing Number 84.268; May 31, 2024 Award Year; U.S. Department of Education Condition Of the 17 students selected for enrollment reporting testing, 4 students within the sample were reported to NSLDS outside the maximum 60-day window. This was not a statistically valid sample. View of Responsible Officials and Planned Corrective Actions Effective with the 2023-2024 Academic Catalog year, Dean College implemented a leave of absence policy (LOA) and a medical leave of absence policy (MLOA). These are intended as a temporary interruption of a student’s program of study for a semester. In the case of an MLOA, the reason for the leave is for health reasons (physical, mental or emotional). Extensions of a leave may be granted on a semester-by-semester basis for up to two years. Students on LOA or MLOA must notify the College after the end of their semester’s leave to indicate if they are planning to return in the subsequent semester, if they want to extend their leave by a semester, or if they are withdrawing from the College. As noted in the catalog, from a financial and financial aid perspective, both types of leave (LOA, MLOA) are treated the same as a withdrawal and is reported as such to the National Student Clearinghouse. Medical withdrawals and voluntary withdrawals are reported as withdrawals. Dean College also has a medical withdrawal policy and a voluntary withdrawal policy. These are not temporary interruptions of a student’s studies with an intent to return but are full withdrawals and reported as such. Students who later decide that they do want to return to Dean College must complete the readmission application. In this situation, it appears that the internal code used to record students who were leaving for medical reasons triggered a leave of absence coding to the Clearinghouse, not a withdrawal code as intended by College policy. Dean College reviewed all processes related to leaves of absence, medical leave of absence, and withdrawals, including all coding, to ensure that this does not happen in the future. Coding updates have been implemented, and we will monitor students during the Fall 2024 semester to ensure they are reported appropriately. Responsible Officials: Colleen Crane Expected Completion Date: 8/9/2024

Enrollment Reporting to National Student Loan Data System (NSLDS) Planned Corrective Action: The Registrar’s Office will add additional reporting for the non-standard term to ensure that student enrollment statuses are updated to NSLDS within the 60 day time frame for reporting. An additional check of students that received loans and withdrew officially or unofficially will be done in NSLDS to ensure that dates were entered correctly within the system and transferred over correctly each semester. Person Responsible for Corrective Action Plan: Matthew Adams, Assistant Director of Academic Records and Registrar Anticipated Date of Completion: June 30, 2025

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the College reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to put a process in place to ensure the enrollment effective date reported to NSLDS on the campus level is aligning with the College as well as the status changes are reported timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. The College utilizes a custom report for enrollment reporting to the National Student Clearinghouse (NSC), who then provides data to NSLDS. In recent years the custom report has required additional manual updates. Ellucian, who provides the Colleague system that the Office of the Registrar uses as their system of record, provides quarterly updates to the Colleague code. Each system update results in necessary review and insertion of the custom report into the Colleague process. The College’s Chief Information Officer has approved funding to contract with a NSC Specialist from Ellucian during Fall 2024 to review Grinnell’s enrollment reporting process and to determine what changes should be made within the Colleague system to make the enrollment reporting process less manual. This would improve the accuracy of reporting by eliminating the constant review and manual adjustments the current process requires. Name(s) of the contact person(s) responsible for corrective action: Jason Luedtke, Senior ERP Specialist, Information Technology Services Planned completion date for corrective action plan: Spring 2025.

Criteria or Specific Requirement - Special Tests and Provisions - Enrollment Reporting - 34 CFR Section 690.83(b)(2) and 685.309 Condition - Eight student status changes were not communicated to the NSLDS timely Questioned Costs - N/A Context - Out of the population of 312 students with enrollment status changes requiring reporting to NSLDS, a sample of 25 students was selected for testing. Of those 25 students, 8 student status changes were not reported to NSLDS within the required 60 days. Our sample was not, and was not intended to be, statistically valid. Effect - NSLDS was not notified of student status changes in accordance with compliance requirements Cause - The University did not have effective internal control processes in place to ensure the accurate collection, review and reporting of student status changes occurred timely. Recent turnover in personnel resulted in a lack of oversight as well. Indication as a Repeat Finding - N/A Recommendation - The University should review its internal controls surrounding the enrollment reporting process and ensure internal controls provide for the timely and accurate reporting of student status changes. Views of Responsible Officials and Planned Corrective Actions - Amy Schlup, Director of Student Financial Services, and Rachel Hart, Registrar, will oversee the corrective action plan. New personnel in the Registrar's office have received training for student enrollment reporting and will submit reporting to NSLDS every 30 days in order to stay within the required 60 days. This reporting will take place around the 25th of every month and be completed by the Registrar only. The Associate Registrar and Director of Administrative Computing will retain alternate access in case of emergency. Error reports will be reviewed and resolved within one week ensuring that accurate information is provided to NSLDS well within the required time frame. The corrective action plan has already been completed as of October 9, 2024. Contact information for responsible officials: Office of Financial Services Box 11000 Oklahoma City, OK 73136 405.425.5190 financialservices@oc.edu

Student Financial Assistance Cluster – Assistance Listing No. 84.268 Recommendation: The University should ensure all necessary employees receive proper training, support, and time to follow the University’s policies and federal requirements related to monthly reconciliations. There should be a process to maintain all reconciliations to support these were performed as required monthly. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: In June 2023, the University announced that the 2023-2024 academic year would be the final year of operations due to continued declines in enrollment and operating deficits. On May 11, 2024 the University provided it’s final day of instruction to students and thereby ended its participation in the Title IV Federal Student Aid (FSA) programs. Name(s) of the contact person(s) responsible for corrective action: Lynda Buzzard, Vice President Finance & Administration Planned completion date for corrective action plan: May 11, 2024

Student Financial Assistance Cluster – Assistance Listing No. 84.063, 84.268 Recommendation: The University should review its policies and procedures on reporting of enrollment status changes to NSLDS to ensure that all status changes are being reported accuracy to be in compliance with regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: In June 2023, the University announced that the 2023-2024 academic year would be the final year of operations due to continued declines in enrollment and operating deficits. On May 11, 2024 the University provided it’s final day of instruction to students and thereby ended its participation in the Title IV Federal Student Aid (FSA) programs. Name(s) of the contact person(s) responsible for corrective action: Lynda Buzzard, Vice President Finance & Administration Planned completion date for corrective action plan: May 11, 2024

Student Financial Assistance Cluster – Assistance Listing No. 84.063, 84.007, 84.268, 84.379, 84.033 & 84.033 Recommendation: We recommend the University review all R2T4 calculations to ensure the correct end date and number of scheduled break days are being used for all Title IV aid. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: In June 2023, the University announced that the 2023-2024 academic year would be the final year of operations due to continued declines in enrollment and operating deficits. On May 11, 2024 the University provided it’s final day of instruction to students and thereby ended its participation in the Title IV Federal Student Aid (FSA) programs. Name(s) of the contact person(s) responsible for corrective action: Lynda Buzzard, Vice President Finance & Administration Planned completion date for corrective action plan: May 11, 2024

Student Financial Assistance Cluster – Assistance Listing No. 84.063, 84.007, 84.268, 84.379 & 84.033 Recommendation: We recommend that the University evaluate its procedures and policies around packaging Title IV based on need. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: In June 2023, the University announced that the 2023-2024 academic year would be the final year of operations due to continued declines in enrollment and operating deficits. On May 11, 2024 the University provided it’s final day of instruction to students and thereby ended its participation in the Title IV Federal Student Aid (FSA) programs. Name(s) of the contact person(s) responsible for corrective action: Lynda Buzzard, Vice President Finance & Administration Planned completion date for corrective action plan: May 11, 2024

Enrollment Reporting to NSLDS Planned Corrective Action: The Master’s University will review a sample batch of students sent to NSC to make sure that the batch was successfully processed to NSLDS. Person Responsible for Corrective Action Plan: Kenneth Piester Anticipated Date of Completion: 09/30/2024

Credit Balances Held Beyond Payment Period Planned Corrective Action: The Master’s University has refined its process for returning federal funds. All eligible awards will be disbursed on the first week of class. An additional review of the course load will happen the day following the last day to add or drop a class. Then the student accounts office will run the federal refunds that same day. This should allow the process to be completed within 14 days of disbursement. As students may turn in documents late and disbursements continue in the school year the process should be run biweekly to catch any potential students who are eligible for a federal refund. Person Responsible for Corrective Action Plan: Kenneth Piester Anticipated Date of Completion: 09/30/2024