Corrective Action Plans

Finding Number: 2025-102 The deficiencies resulted from the absence of a comprehensive, system-based control structure capable of: ● Generating automated alerts to ensure compliance with federal return-of-funds deadlines To ensure compliance with 34 CFR § 668.22(j): ● The institution will utilize system-generated alerts to track all R2T4 deadlines ● Staff will follow standardized procedures aligned with federal timelines ● Supervisory review will be required prior to final processing of all returns Anticipated Completion Date: 8/31/2026 Responsible Contact Person: Angela Reese

Finding Number: 2025-101 The deficiencies resulted from the absence of a comprehensive, system-based control structure capable of: ● Tracking and documenting R2T4 calculations, including secondary review and approval Tom P. Haney Technical College will implement systemic and procedural corrective actions designed to ensure full compliance with Title IV requirements. The institution will procure and implement the Point-of-Sale (POS) module within the FOCUS School Software system to establish automated internal controls. The system will: ● Require documented review and approval workflows for all R2T4 calculations ● Maintain electronic audit trails for all transactions and approvals ● Provide automated notifications and deadline tracking to ensure timely return of funds ● Generate compliance reports for ongoing monitoring The Financial Aid Office will revise and formalize written policies to include: ● R2T4 calculation, review, and approval procedures ● Timelines for return of funds ● System access and authentication requirements All policies will be maintained in accordance with federal recordkeeping requirements under 34 CFR § 668.24. All financial aid and relevant administrative staff will receive training on: ● R2T4 regulatory requirements ● Use of the FOCUS POS system ● Updated institutional policies and procedures Training will be documented and retained for audit purposes. Anticipated Completion Date: 8/31/2026 Responsible Contact Person: Angela Reese

Management acknowledges the audit finding related to the absence of a formally documented written information security program. While VEEB has implemented certain administrative and technical safeguards to protect sensitive information, these practices have not been consolidated into a single, written information security program as required. Management is committed to addressing this matter and plans to formalize its existing information security practices into a written information security program that is appropriate to the size, complexity, and risk profile of the organization. Management expects to complete the development and implementation of the written program during the upcoming fiscal year. Management believes that this condition does not reflect a failure to safeguard information, but rather a documentation gap that will be remedied through the actions described above.

Management agrees with the finding and has indicated that corrective actions will be implemented to improve monitoring and timeliness of R2T4 returns. Management’s corrective action plan is included in the accompanying schedule.

Management Response The University concurs with this finding. Management has initiated a review of all relevant institutional academic calendars to ensure that the correct payment period start and end dates are accurately configured within the Colleague system. The Spring 2025 withdrawal population is being reviewed to determine whether additional R2T4 recalculations and returns of Title IV funds are required. Necessary corrections will be processed promptly. Going forward, the University will implement procedures to verify that system-configured term dates agree to the officially approved academic calendar prior to each academic term to ensure compliance with federal R2T4 requirements. Corrective Action The University is currently reviewing all R2T4 calculations for the Spring 2025 withdrawal population to ensure calculations were accurate. Necessary corrections will be processed promptly. The University is implementing procedures to verify that system-configured term dates agree to the officially approved academic calendar. The procedures include a review and signoff process to ensure multiple individuals review the information for accuracy. Contact Person Responsible Name – Justin Pichey Title – Director of Financial Aid Phone – 410-532-5735 Email - jpichey@ndm.edu Anticipated Completion Date – April 30, 2026

Management Response The University concurs with this finding. Management has reviewed its processes for monitoring and issuing Title IV credit balance refunds and has implemented procedures to ensure refunds are processed within the required 14-day timeframe. The Financial Aid and Student Accounts offices will review credit balance reports on a regular basis to identify students eligible for refunds and confirm timely disbursement. In addition, staff have been reminded of federal requirements related to credit balance refunds. Management will monitor this process periodically to ensure ongoing compliance. Corrective Action The University reviewed the federal requirements for refunds with applicable members of the Business Office and Financial Aid departments to ensure a thorough understanding of the refund rules. The University enhanced its weekly credit balance review process to require explicit review by the Controller and Director of Financial Aid if uncertainty exists on whether a student is eligible for a refund. This review must be completed within the 14 day period with either the refund issued or the loan removed from the student’s account. Contact Person Responsible Name – Richard Jones Title – Controller Phone – 410-532-5367 Email – rjones13@ndm.edu Anticipated Completion Date – April 30, 2026

Management Response The University concurs with this finding and has implemented corrective actions to prevent recurrence. The entrance counseling loan processing rule parameters within the Colleague financial aid module have been updated to prevent loan authorization and disbursement if entrance counseling has not been received and posted to the student's loan record. The system update was implemented in February 2026. In addition, the University reviewed loans processed during the affected period to confirm no additional instances of noncompliance occurred. Financial aid staff have been reminded of federal entrance counseling requirements, and management will periodically monitor system controls to ensure continued compliance. Corrective Action In February 2026, the University updated the entrance counseling loan processing rule parameters within the Colleague financial aid module. From February 2026 forward, the rule parameters would prevent a loan from disbursing if the entrance counseling was not performed. The University reviewed loans processed during the period July 2024 – Feb 2026 to ensure there were no additional loans processed without entrance counseling. Contact Person Responsible Name – Justin Pichey Title – Director of Financial Aid Phone – 410-532-5735 Email - jpichey@ndm.edu Anticipated Completion Date – March 31, 2026

Condition: The change in student status for 1 of the 25 students tested was not reported to the National Student Loan Data Systems (NSLDS) within 30 days or included in a response to a roster file within 60 days. However, these students were ultimately reported to the NSLDS. Corrective Action Planned: The College will implement a secondary review process to ensure that all enrollment updates are through the National Student Clearinghouse within the required timeframe. Name(s) of Contact Person(s) Responsible for Corrective Action Kim Bell, Director of Financial Aid & Compliance Anticipated Completion Date: May 1, 2026

Finding No. 2025-001 – Significant Deficiency and Noncompliance: Reporting Corrective Action The corrective action that will be taken is that Enrollment Information and Status Changes will be reported timely to NSLDS. The following will support this effort: 1. Address Systematic Issues 2. Enhance Staff Training 3. Implement Regular Monitoring and Auditing Persons Responsible for Corrective Action The corrective action plan will be completed by Corry Unis, Vice President for Enrollment Management and Diana Draper, Executive Director of Financial Aid. Anticipated Completion Date: May 31, 2026 The University has already reported 12 of the 21 students to NSLDS. The University will update the enrollment reporting to NSLDS for the remaining 9 students impacted. The University will determine the principal cause of the discrepancy and implement a combination of controls, monitoring, and training to ensure accuracy and timeliness of future reporting.

Finding 2025-001 – Special Tests and Provisions: Enrollment Reporting – Status Change at Program Level Corrective Action Plan I. Overview and Acknowledgment The University acknowledges Finding 2025-001 related to deficiencies in enrollment reporting at the program level under the Pell Grant, Direct Loan, and Federal Family Education Loan (“FFEL”) programs. The University concurs with the finding and recognizes the importance of accurate and timely reporting to the National Student Loan Data System (“NSLDS”) in accordance with federal requirements (OMB No. 1845-0035). The University is committed to strengthening internal controls, enhancing operational procedures, and ensuring full compliance with all enrollment reporting requirements. II. Criteria Institutions participating in federal student aid programs are required to: • Report accurate enrollment information through NSLDS, including enrollment status and program-level data elements. • Ensure that all significant data elements—including enrollment status, program begin date, and enrollment effective date—are accurate as of the reporting date. • Submit enrollment reporting updates at least every 60 days (bi-monthly). • Maintain adequate internal controls to ensure data integrity and compliance with federal regulations. III. Condition The audit identified errors in enrollment reporting for a sample of 25 students, including: • 2 instances of incorrect program enrollment effective date reporting These errors were attributed to administrative oversight and insufficient internal controls governing enrollment reporting processes. IV. Cause Analysis The University has identified the following contributing factors: • Insufficient internal controls and review mechanisms over enrollment status updates • Limited system automation and alert capabilities for tracking status changes • Inadequate staffing resources to manage reporting timelines and data verification • Lack of formalized cross-functional coordination between the Office of the Registrar and reporting entities • Absence of an independent monitoring function to ensure compliance consistency V. Corrective Actions and Implementation Plan The University will implement the following corrective actions to address the identified deficiencies: 1. Establishment of Internal Audit Function • The University will establish a formal Internal Audit function by the start of the next academic year. • This function will have broad authority to oversee compliance, enforce corrective actions, and evaluate internal controls across all relevant departments. • Internal Audit will lead ongoing reviews of enrollment reporting processes and ensure accountability. 2. Process Review and Cross-Functional Collaboration • Internal Audit will coordinate a comprehensive review of enrollment reporting processes involving the Office of the Registrar and the National Student Loan Clearinghouse. • This review will include a structured assessment of strengths, weaknesses, opportunities, and risks (SWOT analysis). • Standard operating procedures (SOPs) will be updated and formally documented. 3. Staffing and Resource Enhancements • The University will enhance staffing within the Office of the Registrar to support enrollment reporting functions. • Additional technological tools and system capabilities will be implemented to provide automated alerts, status tracking, and exception reporting. 4. Implementation of Monitoring and Control Systems • A robust monitoring system will be deployed to: o Track student enrollment status changes in real time o Generate alerts for discrepancies or missing data o Ensure timely submission of required updates to NSLDS • Data validation checkpoints will be integrated prior to submission to ensure accuracy. 5. Strengthening Reporting Protocols • Interim control measures will include the submission of transfer student status reports on a semester basis until full remediation is achieved. • All enrollment updates will undergo a secondary review and certification prior to submission. • A compliance calendar will be implemented to ensure adherence to the 60-day reporting requirement. 6. Training and Accountability Measures • Mandatory training sessions will be conducted for all personnel involved in enrollment reporting. • Training will focus on federal requirements, data accuracy standards, and system utilization. • Performance expectations and accountability metrics will be clearly defined and monitored. VI. Timeline for Implementation • Immediate (0–90 Days): o Initiate staffing enhancements o Implement interim review and validation procedures o Conduct training sessions • Short-Term (90–120 Days): o Deploy monitoring and alert systems o Formalize SOPs and compliance calendar o Begin enhanced reporting protocols • Long-Term (By Start of Next Academic Year): o Fully establish Internal Audit function o Complete comprehensive process review and continuous monitoring framework VII. Monitoring and Ongoing Compliance The Internal Audit function will conduct periodic reviews and report findings for executive leadership. Continuous monitoring will ensure that corrective actions remain effective and that compliance with federal regulations is sustained. VIII. Conclusion Through the implementation of these corrective measures, the University will address the deficiencies identified in Finding 2025-001 and significantly strengthen its internal control environment. These actions will ensure accurate and timely enrollment reporting, uphold the integrity of federal student aid programs, and reinforce the University’s commitment to regulatory compliance and operational excellence. Anticipated Completion Date: September 1, 2026

Finding 2025-001 – Special Tests and Provisions: Enrollment Reporting – Status Change at Program Level Corrective Action Plan I. Overview and Acknowledgment The University acknowledges Finding 2025-001 related to deficiencies in enrollment reporting at the program level under the Pell Grant, Direct Loan, and Federal Family Education Loan (“FFEL”) programs. The University concurs with the finding and recognizes the importance of accurate and timely reporting to the National Student Loan Data System (“NSLDS”) in accordance with federal requirements (OMB No. 1845-0035). The University is committed to strengthening internal controls, enhancing operational procedures, and ensuring full compliance with all enrollment reporting requirements. II. Criteria Institutions participating in federal student aid programs are required to: • Report accurate enrollment information through NSLDS, including enrollment status and program-level data elements. • Ensure that all significant data elements—including enrollment status, program begin date, and enrollment effective date—are accurate as of the reporting date. • Submit enrollment reporting updates at least every 60 days (bi-monthly). • Maintain adequate internal controls to ensure data integrity and compliance with federal regulations. III. Condition The audit identified errors in enrollment reporting for a sample of 25 students, including: • 2 instances of incorrect program enrollment effective date reporting These errors were attributed to administrative oversight and insufficient internal controls governing enrollment reporting processes. IV. Cause Analysis The University has identified the following contributing factors: • Insufficient internal controls and review mechanisms over enrollment status updates • Limited system automation and alert capabilities for tracking status changes • Inadequate staffing resources to manage reporting timelines and data verification • Lack of formalized cross-functional coordination between the Office of the Registrar and reporting entities • Absence of an independent monitoring function to ensure compliance consistency V. Corrective Actions and Implementation Plan The University will implement the following corrective actions to address the identified deficiencies: 1. Establishment of Internal Audit Function • The University will establish a formal Internal Audit function by the start of the next academic year. • This function will have broad authority to oversee compliance, enforce corrective actions, and evaluate internal controls across all relevant departments. • Internal Audit will lead ongoing reviews of enrollment reporting processes and ensure accountability. 2. Process Review and Cross-Functional Collaboration • Internal Audit will coordinate a comprehensive review of enrollment reporting processes involving the Office of the Registrar and the National Student Loan Clearinghouse. • This review will include a structured assessment of strengths, weaknesses, opportunities, and risks (SWOT analysis). • Standard operating procedures (SOPs) will be updated and formally documented. 3. Staffing and Resource Enhancements • The University will enhance staffing within the Office of the Registrar to support enrollment reporting functions. • Additional technological tools and system capabilities will be implemented to provide automated alerts, status tracking, and exception reporting. 4. Implementation of Monitoring and Control Systems • A robust monitoring system will be deployed to: o Track student enrollment status changes in real time o Generate alerts for discrepancies or missing data o Ensure timely submission of required updates to NSLDS • Data validation checkpoints will be integrated prior to submission to ensure accuracy. 5. Strengthening Reporting Protocols • Interim control measures will include the submission of transfer student status reports on a semester basis until full remediation is achieved. • All enrollment updates will undergo a secondary review and certification prior to submission. • A compliance calendar will be implemented to ensure adherence to the 60-day reporting requirement. 6. Training and Accountability Measures • Mandatory training sessions will be conducted for all personnel involved in enrollment reporting. • Training will focus on federal requirements, data accuracy standards, and system utilization. • Performance expectations and accountability metrics will be clearly defined and monitored. VI. Timeline for Implementation • Immediate (0–90 Days): o Initiate staffing enhancements o Implement interim review and validation procedures o Conduct training sessions • Short-Term (90–120 Days): o Deploy monitoring and alert systems o Formalize SOPs and compliance calendar o Begin enhanced reporting protocols • Long-Term (By Start of Next Academic Year): o Fully establish Internal Audit function o Complete comprehensive process review and continuous monitoring framework VII. Monitoring and Ongoing Compliance The Internal Audit function will conduct periodic reviews and report findings for executive leadership. Continuous monitoring will ensure that corrective actions remain effective and that compliance with federal regulations is sustained. VIII. Conclusion Through the implementation of these corrective measures, the University will address the deficiencies identified in Finding 2025-001 and significantly strengthen its internal control environment. These actions will ensure accurate and timely enrollment reporting, uphold the integrity of federal student aid programs, and reinforce the University’s commitment to regulatory compliance and operational excellence. Anticipated Completion Date: September 1, 2026

Explanation of disagreement with audit finding: Prior finding was specific to change to withdrawal status not being timely reported in relation to students who never attended and/or stopped attending. Additional scenarios in this finding, to our knowledge, have not been found in a previous audit. We acknowledge that they fall within the same finding, but the scenarios that fall within the overall finding are not repeats. Action taken in response to finding: WAU acknowledges the importance of effective internal controls in regards to compliance. As a result, the following corrective action steps will be implemented: • Enrollment Date Discrepancies: o The Registrar’s Office will review finding and determine the best course of action to ensure the degree conferral date for a graduate (Effective date per Institutional Record) and the Effective date per NSLDS Campus Record align. After determination of action an SOP will be created. o The Registrar’s Office will create an SOP and add to the withdrawal policy a statement regarding what the effective date will be when students are unofficially withdrawn for not attending and then later submit an official university withdrawal form. o The Registrar’s Office will research the option of continuous enrollment for students who receive a DG and/or Incomplete grade at the end of a term and do not enroll in the next term. Also, the DG and Incomplete policy will be reviewed to determine if the removal of DG and Incomplete deadline needs to be adjusted. • Program Start Date Discrepancies: o The Registrar’s Office will review finding and determine the best course of action to ensure academic program start dates in institutional records align with NSLDS program start dates. After determination of action an SOP will be created. • Missed Enrollment Certification: o See action plan for Enrollment date discrepancies above (bullet 3) • Enrollment Stats discrepancies: o The Registrar will confirm in NSC that all students who graduated but were not enrolled in the term they graduated from are reported as graduated in NSC in a timely manner and work with financial aid to determine the graduation information is recorded timely and accurately in NSLDS as well. After determination of action an SOP will be created. • Inaccurate Institutional Records: o The Registrar’s Office will review finding and determine the best course of action to ensure that students who we send University Withdrawal forms to, upon their request, get withdrawn even if the form is not returned in a timely manner. After determination of action an SOP will be created. Name(s) of the contact person(s) responsible for corrective action: • Team Lead: Registrar (Lynn Zabaleta) • Internal Control Team: Office staff • Senior Management: AVP Enrollment Management (Dirk Whatley) Planned completion date for corrective action plan: June 30, 2026

Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: WAU agrees with the recommendation to update our formal process to identify and maintain an inventory of data, devices, and systems that support or process customer financial aid information. While we currently use the Spiceworks Inventory System to track hardware and software assets and Google Workspace to manage user cloud access and data storage, we acknowledge that a formal, documented inventory process covering all required categories has not yet been fully established. The IT Director has been assigned to develop and document this process within 30 days. We acknowledge this finding and the associated risk arising from the absence of an independent risk assessment. As of March 25, 2026, the University has engaged TeamLogic Cybersecurity to strengthen our managerial, technical, and operational controls and to (1) develop and document a formal, GLBA aligned risk assessment process; (2) conduct annual independent, comprehensive risk assessment of our information systems and data environment; and (3) provide written findings and recommendations. Based on these results, we will implement appropriate safeguards, and institutionalize an annual risk assessment cycle to ensure that risks are consistently identified, assessed, mitigated, and monitored in accordance with GLBA requirements. Name(s) of the contact person(s) responsible for corrective action: Rosalee Pedapudi, IT Director, Information Technology Services Planned completion date for corrective action plan: April 26, 2026

1. Drawdown- Financial Director will authorize drawdown with the AVP of Enrollment reviewing and approving the drawdown. 2. Reconciliation- An SOP will be developed having the Financial Advisor/Pell Grant Officer who manages reconciliation of Pelll, SEOG, and Federal work study. Director financial aid will review and approve reconciliation. For Direct Loans the Direct of Financial aid will prepare the reconciliation to review by the Controller and AVP of Enrollment on a monthly basis. 3. Financial aid Packages- Third party service provider Financial Aid Services (FAS) will complete all financial aid packages with the Director of Financial aid reviewing packaging accuracing by pulling samples of at minimum 25 students for both fall and spring semester. 4. Professional Judgement- An SOP for professional judgment will be created. The Financial aid Director or Pell Grant Officer will prepare the professional judgement. The review and approval to complete by AVP of Enrollment. 5. RT24- Third party service provider (FAS) will prepare RT24 calculations with review and approval by Director of Financial aid and the Associate Vice President of Enrollment. 6. Credit Balances- An SOP will be created to ensure that credit balances are distributed to students within 14 days by verifying enrollment during disbursement. 7. Incentive Compensation – We were unable to verify whether the control to ensure that no incentive compensation is made to employees in the student recruiting and admission, and financial aid departments, is designed and operating effectively. 8. Eligibility – We identified instances in which the Cost of Attendance (COA) used to calculate financial need was inaccurate due to insufficient review and oversight over COA calculations. 9. NSLDS – We noted instances where the University’s records do not match the information shown in the Colleague system, particularly the effective withdrawal dates. Name(s) of the contact person(s) responsible for corrective action: Team Lead: Interim Director of Financial Aid (Alfred Taylor), Director of Student Accounts (Keisha Dublin) ● Internal Control team: Associate Director of Financial Aid (Associate Director of Student Accounts (Arlene Joy Canong), Financial Aid Advisor (Don Lodenquai) ● Senior Management: AVP of Enrollment Management (Dirk Whatley), Controller (Ronald Somervell) ● Financial Aid Services (FAS) Planned Completion Date for Corrective Action Plan: April 26, 2026

Corrective Action Plan Fiscal Year 2025 Finding Number: 2025-001 – Pell Grant Special Tests and Provisions – NSLDS Reporting The District acknowledges the findings related to NSLDS enrollment reporting and has conducted an internal review of processes, systems, and oversight structures contributing to the finding. To ensure compliance with federal reporting requirements, the District will implement the following corrective actions: 1. Enhanced Review Procedures: The District will strengthen internal controls over enrollment reporting by implementing procedures to ensure all enrollment status changes are accurately recorded, reconciled between internal systems and third-party servicer reports, and submitted to NSLDS within required time frames. Additionally, The District is actively restructuring internal systems and workflows within the department to strengthen oversight, improve accuracy, and ensure timely reporting of enrollment status changes. 2. Training: The District recognizes that staff turnover and inconsistent training contributed to the finding. To address this, the District will implement a comprehensive training plan in partnership with the third-party servicer. 3. Monitoring Controls: The District will formally reestablish expectations with its third-party servicer to ensure all contracted services are implemented. Implementation Timeline: • Enhanced review procedures will be implemented immediately. • The District will implement an ongoing comprehensive training plan in partnership with third-party servicer. • Staff will meet with third-party servicer to re-establish expectations and to ensure compliance with federal reporting requirements before fiscal year-end. Responsible Party: Dr. Dywayne B. Hinds, Sr., Area Superintendent, Dr. Jakub Prokop, Director, PTC- Clearwater, and Dr. Jason Shedrick, Director, PTC-St. Petersburg Anticipated Completion Date: June 30, 2026 Dywayne B. Hinds, Sr., Ed.D. Area Superintendent, Area 3

2025-001 Eligibility, Reporting (Financial) and Special Tests (Disbursements to or on Behalf of Students) Federal Agency: Student Financial Assistance Cluster - U.S. Department of Education and U.S. Department of Health and Human Services (DHHS), DHHS Health Resources and Services Administration Program Titles and Assistance Listing Numbers (ALN): Federal Supplemental Educational Opportunity Grants (ALN 84.007), Federal Work-Study Program (ALN 84.033), Federal Perkins Loans (ALN 84.038), Federal Pell Grant Program (ALN 84.063), Federal Direct Student Loans (ALN 84.268), Nurse Faculty Loan Program (ALN 93.264), Health Professions Student Loans, Including Primary Care Loans and Loans for Disadvantaged Students (ALN 93.342), Nursing Student Loans (ALN 93.364), Scholarships for Health Professions Students from Disadvantaged Backgrounds (ALN 93.925) Federal Grant Numbers: E P007A252602 (7/1/2024 – 6/30/2025), E P033A252602 (7/1/2024 – 6/30/2025), E P038A132602 (7/1/2024 – 6/30/2025), E P063P250272 (7/1/2024 – 6/30/2025), P268K260272 (7/1/2024 – 6/30/2025), E-01HP28821-02-02, E-01HP31830-01-00,(7/1/2024 – 6/30/2025), E4CHP42498-01-00 (7/1/2024 – 6/30/2025), E26HP25750, E36HP25751, E11HP27284, E36HP26092, E36HP25751, E26HP25748 (7/1/2024 – 6/30/2025) Contact Person: Robert Fahy, AVP of University Enrollment Services, 848-932-2603 Corrective Action: Since the audit period, the University has strengthened governance and oversight over OSFP by formalizing access controls and reinforcing monitoring practices. Management has established and documented OSFP system roles and responsibilities. A review of user access was performed to ensure alignment with job responsibilities, and users holding multiple or incompatible roles were corrected. In addition, the University implemented an audit log to track user provisioning and deprovisioning activity, providing documented evidence of access changes and removals. The University has also enhanced its change management process to ensure that all updates to OSFP follow the documented change management procedures. These measures collectively strengthen logical access and change management controls and support effective internal control over system operations. Management will continue to monitor the effectiveness of these controls. Anticipated Completion Date: Completed

Student Financial Assistance Cluster Federal Direct Loans - Assistance Listing No. 84.268 Recommendation: We recommend the University evaluate controls around monitoring return of Title IV funds to determine changes, either on the electronic processes or review processes that should be made to properly capture return of Title IV funds on a timely basis. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Planned corrective action: Currently, the return of Title IV calculations are done manually and a second person within Financial Aid reviews the calculation. The University is working on a training engagement for the Financial Aid office which will explore the ability to perform the return of Title IV calculations within the ERP system. A second person would continue to review the calculation. Name(s) of the contact person(s) responsible for corrective action: Patrick Michael, Director of Financial Aid If the United States Department of Education has questions regarding this plan, please call Shari Keffer, Vice President for Administration & Finance at 618-537-6838.

Student Financial Assistance Cluster Federal Pell Grant Program - Assistance Listing No. 84.063 Federal Direct Loans - Assistance Listing No. 84.268 Recommendation: We recommend the University evaluate controls around monitoring enrollment reporting to determine changes, either on the electronic processes or review processes, that should be made to properly capture enrollment status changes on a timely basis and to properly monitor its third-party service provider for timely reporting as necessary. Planned corrective action: Processes will be reviewed and updated to ensure submissions are being reported timely and accurately Name(s) of the contact person(s) responsible for corrective action: Patrick Michael, Director of Financial Aid If the United States Department of Education has questions regarding this plan, please call Shari Keffer, Vice President for Administration & Finance at 618-537-6838.

Views of Responsible Officials: SCC’s implementation of Student First on August 10, 2026, will help rectify the enrollment reporting issues.

The Enrollment Division at The Cooper Union has seen recent turnover in leadership and personnel coinciding with the 2024-2025 data submission cycle. A new Vice President for Enrollment, Troy Cogburn, joined the community in October 2024 and the College experienced continued transition and turnover. In May 2025, an Assistant Registrar was hired, and Troy stepped in as Interim Registrar, while also overseeing a search to fill the position permanently, which did not come to fruition until a new Senior Registrar was hired/started working for The Cooper Union during the first week of January 2026. Moving forward, the new Senior Registrar, Bryan Cracchiolo, has resumed responsibilities for timely enrollment and graduation reporting through the National Clearinghouse. Additionally, Bryan is working in closer collaboration with the Offices of Institutional Effectiveness and Research, to ensure accurate processing of all institutional data. Furthermore, the Vice President and Senior Registrar, as an interim step, are teaming with campus executive leadership to revisit a long-held, multi-step conferral confirmation practice which has contributed to certain delays in the processing of student enrollment records. Their goal is to implement an expedited review process by the Spring of 2026 that will lead to the timely submission of student enrollment changes to the NSLDS.

Recommendation: We recommend the College evaluate its policies and procedures around reporting student status changes to NSLDS to ensure that all relevant information is being captured and reported timely in accordance with applicable regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: Internal Control Enhancement: The Registrar will update the department’s internal control procedures to include a scheduled monitoring process to ensure that all enrollment status changes are reviewed and reported to NSLDS within 60 days. The procedure will also include a verification step to document when a student qualifies under the limited exception policy, ensuring appropriate justification is maintained for any enrollment updates reported outside the 60-day timeframe. Periodic reconciliation between the Student Information System and NSLDS reporting records will be conducted to confirm that all enrollment changes are transmitted within the required reporting period. Name(s) of the contact person(s) responsible for corrective action: Carrie Santaw, Bursar Planned completion date for corrective action plan: April 1, 2026

Recommendation: We recommend the College evaluate its procedures around packaging and awarding students to ensure loan eligibility is reassessed prior to disbursement. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: 􀁸 The College determined that this issue resulted from the absence of a consistent process to identify and reassess students whose transfer credits were added or revised after initial financial aid packaging, potentially affecting grade level classification and Direct Loan eligibility. 􀁸 To correct this, the College will revise its packaging procedures to require a mandatory review of Direct Loan eligibility whenever transfer credits are added or updated. The Financial Aid Office will work in coordination with the IT Department and the Registrar’s Office to develop automated reports or system alerts that flag students with transfer credit changes occurring after packaging. These reports will be reviewed regularly, and any impacted student records will be reassessed and updated as necessary prior to disbursement. 􀁸 In addition, the College will strengthen oversight by implementing monitoring controls such as requirements. These measures are intended to prevent future instances of under-awarding and to enhance internal controls within the financial aid packaging and awarding process. Name(s) of the contact person(s) responsible for corrective action: Stephanie Liebowitz, Director of Financial Aid Planned completion date for corrective action plan: April 15, 2026 – Procedures will be in place for the awards cycle of the incoming 2026-2027 class.

Recommendation: We recommend the College evaluate its procedures and review policies in overseeing student credit balances to ensure that any credit balances as a result of Title IV aid are returned within the required timeframe. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: The institution will conduct a comprehensive policy review related to student accounts and financial aid disbursements. The Student Accounts team will receive retraining, including additional Financial Aid–specific training focused on federal guidelines and compliance requirements. Cross training will be implemented within the Student Accounts team to prevent delays and ensure continuity of operations when staff are on leave. Ongoing communication protocols will also be reinforced between Student Accounts and the outsourced financial aid staffing team (Financial Aid Services (FAS)) regarding disbursement timing to promote coordination and timeliness. Name(s) of the contact person(s) responsible for corrective action: Scott Crawford, Director of Accounting and Melissa Ogelvie, Bursar Planned complet ion date for corrective action plan: July 1, 2027 – While we anticipate improvement in these processes throughout the training process, completion of these corrective actions will be complete by this date. This timeline accounts for the identification, scheduling, and completion of appropriate training opportunities, including potential external training or professional development programs that may require advance enrollment and availability.

The institution has reinforced its R2T4 internal training program and continues to monitor withdrawals to detect and proceed promptly with any deviation to the application of the regulations for this purpose.To prevent recurrence and ensure full compliance with Federal Student Aid regulations, our institution has initiated the following actions:Report Modification: We have formally requested the modification of two specific monitoring reports (class status audit report/selected letter grade report). These enhancements will ensure that all students are correctly flagged for R2T4 (Return to Title IV) calculations. We will continue exploring reports and configurations in our system (SIS) that will serve as tools to perform these verifications more efficiently.Staff Training: The Bursars teams are undergoing training sessions focused on identifying "hidden" withdrawals and mastering the updated reporting tools.Increased Monitoring Frequency: We have transitioned to every two weeks monitoring of student enrollment status with weekly detailed evaluation of courses identified as withdrawals. This ensures that any "unofficial withdrawals" or "drop-outs" are captured within the required regulatory window.We take our fiduciary responsibility regarding Title IV funds very seriously. We are confident that the integration of more frequent reviews and the refinement of our reporting software will eliminate the gap that led to this finding.

Finding Number: 2025-022 ALN Number(s) and Program Title(s): 93.658 – Title IV-E Foster Care Views of Responsible Officials and Planned Corrective Action: DHS concurs with this finding. DCFS will conduct a review to determine if additional controls are needed to ensure that foster homes complete all required checks. All improper Title IV-E payments will be returned on the next CB-496 quarterly report. Anticipated Completion Date: 4/30/2026 Contact Person: Name: Tiffany Wright Title: Director, Division of Children and Family Services Agency: Department of Human Services Address: 700 Main Street City, State, Zip: Little Rock, AR 72201 Phone Number: 501-396-6477 Email Address: Tiffany.Wright@dhs.arkansas.gov