Corrective Action Plans

FINDING 2025-005– NSLDS Reporting Program Name: Federal Direct Student Loan Program ALN and Program Expenditures: 84.268 ($866,312) Award Number: P268K253315 Federal Award Year: July 1, 2024 to June 30, 2025 Questioned Costs: N/A Condition Found: During our compliance testing, student enrollment status changes were reported to the National Student Loan Database System (“NSLDS”) timely for nine of the seventeen students selected for testing. Corrective Action Plan: A new Student Financial Aid Director was hired in July 2025. The Student Financial Aid Director and Registrar will work together to determine and report student enrollment status changes within the required timeframe to NSLDS. Anticipated Completion Date: The University anticipates the corrective action being completed by March 31, 2026. Contact Person: Brad Burnett, Director of Financial Aid 405-912-9000

FINDING 2025-004– Reporting/Internal Control Over the SEFA Program Name: Federal Direct Student Loan Program Federal Pell Grant Program Federal Supplemental Educational Opportunity Grant ALN and Program Expenditures: 84.268 ($866,312) 84.063 ($509,088) 84.007 ($ 5,400) Award Number: P268K253315 P063P243115 P007A243421 Federal Award Year: July 1, 2024 to June 30, 2025 Questioned Costs: Undetermined Condition Found: The University lacked policies and procedures to reconcile the SEFA data to the financial statements or other supporting documentation. The University was on the HCM2 method of payment and could not provide of the listing by student of the aid requested. During the audit, we were unable to reconcile the Amount Due from the Government on the Financial Statement to the amount due per the financial aid records. In addition, aid was posted to student accounts and never requested from the government for five of the seventeen students in our sample. Corrective Action Plan: The bursar, business office staff, and financial aid staff will work together to review and reconcile Title IV posted to the student accounts to the amounts requested from the Department of Education. When discrepancies are found, the University staff will investigate and determine if the student was eligible for aid and request additional funds as necessary. See the possible effect section for the resolution of the students in this finding. Anticipated Completion Date: The University anticipates the corrective action being completed by June 30, 2026. Contact Person: Brad Burnett, Director of Financial Aid 405-912-9000

84.063 ($509,088) Award Number: P268K253315 P063P243315 Federal Award Year: July 1, 2024 to June 30, 2025 Questioned Costs: N/A Condition Found: The University was placed on the Heightened Cash Monitoring Method 2 (“HCM2”) for disbursing aid in May 2023. In the current fiscal year, a Title IV Credit Balance was held for more than 14 days for one of the seventeen students in our sample. Corrective Action Plan: There is no longer a credit balance on the account of the student in question. If time allows, the business office will review student accounts to determine if any additional credit balances should be refunded. Procedures should be improved to ensure the University is following the HCM2 regulations. Anticipated Completion Date: The University anticipates the corrective action being completed by March 31, 2026. Contact Person: Brad Burnett, Director of Financial Aid 405-912-9000

FINDING 2025-002 – Exit Interview Program Name: Federal Direct Loan Program ALN and Program Expenditures: 84.268 ($866,312) Award Number: P268K253315 Federal Award Year: July 1, 2024 to June 30, 2025 Questioned Costs: N/A Condition Found: Six of the seventeen federal student financial aid recipients in our sample did not complete or were not sent exit interview instructions to complete within thirty days of the student ceasing to be enrolled in the University at least half-time. Corrective Action Plan: A new Financial Aid Director was hired in July 2025. The Financial Aid Director will review the students in question to determine if exit instructions were sent after the thirty-day time period. If an exit interview has not already been sent, the Financial Aid will mail exit interview instructions to the students’ home address. In addition, the Director of Financial Aid will work with the third-party administrator to determine which entity is responsible for sending exit interview information to students. Anticipated Completion Date: The University anticipates the corrective action being completed by March 31, 2026. Contact Person: Brad Burnett, Director of Financial Aid 405-912-9000

Corrective actions were implemented for the Fall 2025 term to ensure all students are notified of Direct Loan disbursements and that sufficient documentation is maintained.

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the College re-evaluate 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: Early in the 2024-25 fiscal year, the College learned that this finding related 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). The Registrar is now consistent in reporting graduation dates using the end of term for all graduating students. As for the reporting of withdrawals, the Registrar now manually updates the enrollment status and effective dates in NSLDS to ensure accurate and timely reporting. The findings in this audit period occurred prior to the above changes being implemented. Name(s) of the contact person(s) responsible for corrective action: Austin Nyhof, Registrar Planned completion date for corrective action plan: June 30, 2026

Action taken in response to finding: The Department of Education implementation delays contributed to the untimely reporting. In the event the Department of Education implements future changes, the University will evaluate impacted processes at that time to determine appropriate action. In addition, the Office of Student Finance has evaluated potential process improvements and is actively working with IT support to help automate this financial aid verification process. The University has also increased the frequency of queries within the student records system to identify and update/resolve the records in a timelier manner. Name(s) of the contact person(s) responsible for corrective action: Nate Peterson, Executive Director, Office of Student Finance Planned completion date for corrective action plan: February 2026 If the Department of Education has questions regarding this plan, please call Nate Peterson at 612-624-9442.

COMPLIANCE REQUIREMENT: Disbursements to or on Behalf of Students Campus: Fullerton, Los Angeles Recommendation: KPMG recommends the University provide proper training on the disbursement notification requirements and apply its existing policies and procedures. Corrective Action Plan: California State University, Fullerton The University concurs with the recommendation. The University will review and enhance its procedures to ensure timely disbursement notification. Estimated Completion Date: March 2026 Contact person: California State University, Fullerton Nick Valdivia Director of Financial Aid nvaldivia@fullerton.edu (657) 278-3064 Justin Chan Associate Director of Accounting Services & Financial Reporting juschan@fullerton.edu (657)278-8371 Corrective Action Plan: California State University, Los Angeles The University concurs with the recommendation. The University will review and enhance its procedures to ensure timely disbursement notification. Estimated Completion Date: June 2026 Contact person: California State University, Los Angeles Linda Lopez Director, Financial Aid and Scholarships (323) 343-3247 llopez148@calstatela.edu

COMPLIANCE REQUIREMENT: Enrollment Reporting Campuses: Sacramento, Los Angeles Recommendation: KPMG recommends the University provide proper training on the enrollment reporting procedures and apply its existing policies and procedures. Corrective Action Plan: California State University, Sacramento The University concurs with the recommendation. The University will review and enhance its procedures to ensure timely and accurate reporting to NSLDS. Completion Date: December 2025 Contact person: California State University, Sacramento Tabitha Leeds Senior Director of Accounting Services (916) 278-4679 leeds@csus.edu Corrective Action Plan: California State University, Los Angeles The University concurs with the recommendation. The University will review and enhance its procedures to ensure timely and accurate reporting to NSLDS. Estimated Completion Date: June 2026 Contact person: California State University, Los Angeles Linda Lopez Director, Financial Aid and Scholarships (323) 343-3247 llopez148@calstatela.edu

Views of Responsible Officials and Corrective Action Plan During Fall 2024, the Financial Aid Office experienced the departure of two key senior staff members who were primarily responsible for Return to Title IV (R2T4) processing and the reversal of federal funds. As a result, new staff were temporarily assigned to manage these responsibilities during the transition period, which contributed to delays in returning funds within the required regulatory timeframe. A comprehensive review of all R2T4 calculations completed during the 2024–2025 aid year determined that records processed prior to mid-November 2024 had over awarded funds returned within the applicable 45- and 30-day regulatory timeframes. This timeframe aligns with the period when the responsible staff members announced their retirements. To resolve this matter and prevent recurrence, the District has implemented the following corrective measures. Targeted R2T4 Training: Staff responsible for Return to Title IV (R2T4) processing and disbursement reversals are in the process of completing the National Association of Student Financial Aid Administrators (NASFAA) R2T4 credential training. This certification will ensure staff possess consistent, up-to-date knowledge of federal requirements around the R2T4 process to include the timelines required to return over-awarded funds to the department. Automated Monitoring Report: A recurring monitoring report has been established to identify students with pending Returns of Title IV (R2T4) funds. The report automatically flags cases exceeding 30 days and, for students who withdrew prior to the start of the term, those exceeding 20 days. Department managers will generate and review this report on a weekly basis to ensure timely compliance with federal return requirements. In instances where pending returns are identified as being past the alert threshold, Financial Aid management will promptly coordinate with Fiscal Services to expedite the return of funds and document resolution actions. Cross-Training for Continuity of Operations: Ongoing cross-training has been implemented among Financial Aid staff to ensure sufficient coverage during vacations, extended leaves, or unexpected absences. At least two designated staff members will be fully trained and authorized to perform R2T4 calculations and return processing to prevent delays in compliance during personnel transitions. These measures strengthen accountability, monitoring, and collaboration between the Financial Aid and Fiscal Services departments to ensure full compliance with federal cash management and return regulations.

Views of Responsible Officials and Corrective Action Plan The discrepancies noted during the 2024–2025 Financial Aid Audit were found to be attributable to a separate system configuration issue, distinct from the discrepant records identified in the 2023–2024 annual audit, which involved incorrect reporting of effective enrollment status dates. To resolve this matter and prevent recurrence, the District has implemented the following corrective actions: 1. Root-Cause Analysis: Conducted a comprehensive review with IT, Admissions & Records, Financial Aid, and third-party consultants to isolate and correct the specific system errors. 2. Update Systems Settings: Updating systems settings to accurately select records for reporting along with the perspective effective date and accurately report the three-quarter time enrollment level. 3. Manual Verification: Financial Aid staff responsible for Return to Title IV (R2T4) processing will manually review all student enrollment records in NSLDS (approximately 2,400 annually) to ensure accuracy. 4. Ongoing Compliance Monitoring: Established quarterly joint compliance reviews with IT, Admissions and Financial Aid leadership to verify continued accuracy of NSC/NSLDS reporting and to ensure timely detection of anomalies.

Management recognizes that staff had incorrectly interpreted the length of break that would necessitate a change in the refund calculation. Staff are now aware of the correct interpretation of the rule and will use it for all future calculations. Management will also identify a consultant to work with the College’s Director of Financial Aid, Controller and Registrar to review all rules regarding return to title IV calculations so a guide can be created to lessen the chance of incorrect calculations going forward.

Recommendation: We recommend the University review its reporting procedures to ensure that enrollment status change is reported timely to NSLDS as required by regulations. Action taken in response to finding: The University’s enrollment verification process includes reviewing a sample of students whose enrollment status changes were submitted to the National Student Clearinghouse to confirm that NSLDS was updated as expected. This process identified the issue noted in the finding, and it was corrected prior to the audit. To further strengthen controls, the University has implemented additional ad hoc NSLDS reporting to confirm that submitted data is processed after NSC transmission, while continuing the established verification process. Names of the contact persons responsible for corrective action: Shawnn Palmer, Director of Academic Technology and Reporting Planned completion date for corrective action plan: As of January 9, 2026, the student record in the finding has already been corrected. The additional audit report is in draft and will be validated prior to the April reporting. If the Department of Education has questions regarding this plan, please call Joshua Morey, Senior Director of Financial Aid, at (951) 343-4236.

Finding Number: 2025-002 Federal Program: Student Financial Assistance (SFA) Cluster - Various ALN Control Requirement - Return of Title IV Funds Management’s Response The University of Puerto Rico concurs with this finding. Institutional units have identified opportunities for improvement in internal controls related to the timely return of Title IV funds and have implemented, or are in the process of implementing, corrective measures to ensure compliance with the regulatory timeframe of 45 days. The Cayey unit identified that the delay in the return of Title IV funds was related to an unintentional administrative error in the handling and filing of R2T4 documentation, within a context of operational transition and temporary staffing limitations. As a corrective action, the Fiscal Office will strengthen periodic reviews of total withdrawal reports generated in the NEXT system, ensure proper classification and monitoring of R2T4 cases, and provide continuous follow-up until funds are effectively returned within the 45 days regulatory timeframe. As a control mechanism, direct oversight of the R2T4 process by the Finance Director has been established, including recurring reviews of total withdrawal reports and reconciliation of these reports with refund vouchers, in order to ensure that all cases are processed and returned in a timely manner. The Humacao unit acknowledged that the cases identified by the auditors were related to specific circumstances, including system errors, technical limitations, and operational workload associated with the implementation of the shared services model. As a corrective measure, the unit implemented changes to the total withdrawal request form and process to ensure coordinated handling between the Office of Financial Aid and the Fiscal Office, allowing for early identification of cases subject to R2T4. Additionally, the Fiscal Office will review total withdrawal reports generated by the NEXT system on a recurring basis, perform R2T4 calculations timely, and coordinate with the Office of Finance to process returns within the regulatory timeframe. Oversight of the process has been strengthened through the designation of responsible personnel and continuous monitoring of active cases through completion. The Carolina unit identified that delays in the return of Title IV funds were due to discrepancies in attendance reports that were subsequently amended. As a corrective action, the Office of Financial Aid will formally notify the Fiscal Office of any corrections or amendments to attendance reports to ensure that R2T4 cases are identified timely. In addition, the use of “Never Attended” reports has been reinforced at the conclusion of the census period and upon completion of the grade submission period. Once the R2T4 calculation is completed in the COD system and a return is determined, the refund process will be initiated immediately, accompanied by continuous follow-up and the scheduling of key dates to ensure compliance with the 45 days regulatory requirement. The Central Administration Finance Office will conduct a meeting with Finance Directors, Financial Aid Directors, the Office of the Registrar, and Fiscal Directors to discuss this finding and establish a uniform procedure to address the following scenarios: • Students who request a total withdrawal. • Students who stopped attending. • Students who never attended. Additionally, a control mechanism will be implemented through the SharePoint platform, whereby each Fiscal Director will certify that system reviews have been performed for cases approaching the 45 days regulatory deadline. This control will be performed on a bi-weekly basis and will allow for timely monitoring of active cases, ensuring proper compliance with the required return of funds. For cases related to grade-based census determinations, which are processed once faculty submit grades in the system, an additional control mechanism will be established. Specifically, the SharePoint tool will be used for Fiscal Directors to document the academic calendar deadlines for grade submission. Furthermore, Fiscal Directors will schedule Outlook calendar events with these deadlines, including the Director of Financial Aid and the Office of the Registrar, and will establish automated reminders to ensure timely follow-up. These procedures will be documented and incorporated into the internal control manual applicable to the R2T4 process. Responsible Person or Office: Central Administration Finance Office and the finance offices of each of the eleven (11) institutional units. Implementation Timeline: 2026-2027

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 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 Registrar’s Office has put in place steps to ensure that any exception reports from the Clearinghouse are immediately reviewed and any exceptions are addressed and resubmitted. In addition, the Registrar’s Office has put in place steps to ensure that students are submitted to the Clearinghouse early enough so that they will still be submitted by the Clearinghouse to NSLDS timely, even if there are delays by the Clearinghouse. Name(s) of the contact person(s) responsible for corrective action: Kristin Dvorak, University Registrar; Kevin Moenkhaus, Associate Registrar Planned completion date for corrective action plan: January 2026

Finding 2025-001 Required Disclosures Views of Responsible Officials The University agrees with the auditor’s findings and recommendations. Corrective Action Plan The University has participated in educational opportunities provided by the Department of Education and implemented procedures to ensure timely disclosure. All subsequent updates have been completed. Implementation Date Immediate Individual(s) Responsible Brandon Goen, Controller

Direct Loan Disbursement Notifications Correction Action Planned: For the 2025-2026 academic year, notifications are scheduled in our FAMS system to be sent immediately after student loans are disbursed to the student account. This action started with the Fall 2025 semester. Policy and Procedures have been updated to include the Direct Loan notification statement. This is in Section 10.5, Student & Parent Notifications, on Page 48 of the Financial Aid Policies and Procedures manual. This action has already been completed and in progress as of September 2025. Person Responsible for the Corrective Action: Denise Welch, Director of Financial Aid

OCCIDENTAL COLLEGE CORRECTIVE ACTION PLAN FINDING 2025-001 – Special Tests and Provisions – Enrollment Reporting: Significant Deficiency in Internal Control over Compliance Explanation of Deficiency: A sample of 20 federal aid recipient students was selected fromsystem generated reports of students who graduated, withdrew, or dropped during the 2024-2025 academic year. The enrollment information per the College’s records was compared to the information reported to the National Student Loan Data System (NSLDS) in order to determine if status changes were reported within the required timeframes. All 20 of the students selected as samples were not reported to the NSLDS within the required timeframe. Corrective Action Plan: With the hiring of our Associate Registrar for Systems and Reporting we once again have a staff member specifically responsible for reporting enrollment and degrees to the NSC. That position is backed up by three other staff members who also have access to submit and correct files. This past summer, we adjusted our reporting schedule in a further effort to comply with our reporting requirements. Despite any delays caused by us or by the National Student Clearinghouse, I understand that we are responsible for making sure our data is received and posted according to our obligations. The division of labor that comes with a full staff will allow for data transfers as soon as degrees are posted after the end of a semester. The adjusted timing for enrollment file submissions will also prevent any bottlenecks that might delay our data from being posted. These steps have already been implemented as evidenced by the fact that our degree file for the fall semester just ended was sent before our holiday break. As noted last year, staff have been instructed that the resolution of error files is to be given a high priority. One staff member has priority responsibility for resolving those files backed up by our primary submitter of data to the Clearinghouse. Contact Person Responsible for Corrective Action: James Herr, Occidental College Registrar Anticipated Completion Date: August 1, 2025

Noncompliance with Enrollment Status Change Reporting. Auditor Description of Condition and Effect. Of 18 enrollment status changes tested, we noted 1 change that was not reported to the National Student Loan Data System (NSLDS) within 60 days due to a student being assigned a different coding structure within the College's system which resulted in the student being excluded from the standard status-change reporting process. As a result of university personnel using the incorrect semester start dates. As a result of this condition, the College was temporarily out of compliance with enrollment reporting requirements. Auditor Recommendation. We recommend the College review and update its enrollment reporting processes to ensure that all students-including those with unique or foreign-student coding-are captured in routine status-change monitoring and NSLDS reporting procedures. The College should implement controls to detect nonstandard coding and ensure that all enrollment changes are identified and reported within required federal timelines. Corrective Action. Bay College took swift action after determining some students were being excluded in our enrollment reporting. Our reporting process was excluding students who were noted as being a citizen of a foreign county. We now review these students prior to each reporting cycle to determine if they should be included in the reporting. The Financial Aid team reviews this report to determine if the student is eligible for federal student aid. Students who are eligible are indicated and provided to the Institutional Effectiveness team to include in the enrollment reporting. This process is completed prior to each reporting cycle. For students who were not included in our prior reporting, the Financial Aid team working directly with the Institutional Effectiveness team, determined which should be reported and completed their enrollment reporting directly through NSLDS. Responsible Person. Ruth Carlson, Director of Financial Aid. Anticipated Completion Date. June 30, 2026

Finding: 2025-01 Federal Agency Name: Department of Education Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Award Numbers: P007A242416, P033A242416, R063P242851, P268K252851 Program Name: Student Financial Aid Cluster Finding Summary: In the current fiscal year, the College failed to identify populations whose enrollment status changed and accurately report changes to National Student Clearinghouse and the National Student Loan Data System (NSLDS). This issue was discovered during the annual audit of student financial aid files. Of the565 Title-IV recipients for the affected terms, 37 students (6.5%) have been identified as affected by this issue. Corrective Action: The process has been reviewed and updated to correct this issue. • The Information Technology department has developed an internal script to actively identify and update student enrollment status records whose enrollment statuses have not already changed in the College’s School Information System, which then allows the student files to be identified in National Student Clearinghouse reporting procedures. • A report was created and is checked monthly to screen student accounts for manual review in case script developed does not update student records with new enrollment statuses. This report includes the date of status change for manual auditing of reason for status change in manual review. Responsible Individual: Cameron Brown, Director, Financial Aid Completion Date: August 2025

Views of Responsible Officials and Corrective Action Plan The Campus Business and Financial Aid Offices reviewed the untimely return of Title IV (R2T4) funds and implemented a revised process to ensure compliance. Weekly R2T4 reviews: Financial Aid specialists now review all accounts requiring R2T4 calculations each week. Mid-month reconciliation: Added to the existing end-of-month process to expedite fund returns. Weekly coordination meetings: Financial Aid and Business Services staff review pending cases to ensure all returns meet the 45-day federal deadline. Quarterly compliance checks: Other Financial Aid staff monitor adherence and make recommendations for process improvement. The District will review this process each term and adjust procedures as needed to sustain compliance and efficiency.

Special Tests and Provisions - Enrollment Reporting Auditor Description of Condition and Effect. During our testing we noted that two students out of a testing population of eleven did not have their status change reported timely to NSLDS, one of which also had differences in their program level enrollment and campus level enrollment details. Another student had an incorrect effective date reported to NSLDS. As a result, there is an increased risk that information will not be reported to NSLDS timely and accurately. Auditor Recommendation. We recommend that the College enhance its policies and procedures regarding enrollment reporting to ensure that reporting is completed timely and accurately. Corrective Action. We currently have a 30-day reporting schedule but to prevent these issues from recurring, our institution has implemented the following measures: • Internal control review: We will run a comprehensive review of our enrollment reporting procedures in order to strengthen our internal controls to ensure data accuracy and timeliness. • Increased monitoring: A designated staff member now has direct access to the NSC and NSLDS websites to monitor reporting compliance and track file submissions and error reports. • System review: We have identified the deficiency for unofficial withdrawals. Our SIS platform has a feature that will correct this reporting issue and we will utilize it for future reporting. Our institution is committed to maintaining full compliance with all federal regulations regarding student financial aid and enrollment reporting. We have addressed the root cause of this reporting delay and are confident that our new procedures will ensure accurate and timely submissions to the NSC and NSLDS moving forward. Responsible Person. Michele Traver, Registrar Anticipated Completion Date. Fall 2025

R2T4 Audit: FY25 Corrective Action Plan To address the audit findings, the FCC has initiated the following actions: •Spring 2025, Completed: oRevised Processing Timeline: All R2T4 calculations and returns are now completedwithin 30 days, reserving the final 15 days exclusively for QA. (Responsible Leader:Director of Financial Aid) oCross-Training and Succession Planning:Staff cross-trained; onboarding/offboardingdutiesdocumented to eliminate single points of failure.(Responsible Leader: Director ofFinancial Aid) •September 2025, Underway: oLeadership Communication Protocol:A formal process is beingfinalized to ensurecompliance issues are documentedand escalatedforawareness to the President and theCFO/VP for Administration. Thisprotocol alsoreinforcesa cultureof accountability where compliance concernsare escalated promptly and transparently. (ResponsibleLeader: AVP for Student and Financial SupportServices) •Monthly Monitoring and Reporting:Compliance reviews reported monthlyto the VP for Student Experience and then to the President and the CFO/VPfor Administration for awareness. (Responsible Leader: VP for StudentExperience). oQA Tracking Form: Implemented to document each review and correction for auditverification. (Responsible Leader: Director of Financial Aid) •Fall 2025 – Spring 2026, To Be Planned and Executed: oExternal Program Review: FCC will engage an external consultant agency (TBD) toconduct a comprehensive Financial Aid Office program review in FY26, validatingcompliance, staffing adequacy, and process integrity. (Responsible Leader: AVP forStudent and Financial Support Services) •Timeline, Next Steps, Responsible FCC Leader: oOctober 6, 2025: Submit formal corrective action plan to Auditors (VPSE) oOctober 15, 2025: Receive first compliance review report for AVP to VP reporting toPresident’s Council, as part of enterprise risk management awareness. (AVP/VPSE) oJanuary to April 2026: Conduct external program review of the Financial Aid Office andreport findings to President and the CFO/VP for Administration by June 2026. (AVP) •Expected completion date: June 2026 •Person responsible: Dr. Edmund T. Cabellon, Interim Vice President for Student Experience

AUDIT FINDING Finding 2025-001 NSLDS Status Reporting Error MANAGEMENT'S COMMENTS ON FINDINGS AND RECOMMENDATIONS MANAGEMENT'S We concur with the auditor’s finding and identification of a deficiency in our internal controls. CORRECTIVE ACTION PLAN We will enact stronger controls to ensure that all future enrollment reporting is submitted timely. EMPLOYEE/ DIVISION RESPONSIBLE Financial Aid Director TIMELINE AND ESTIMATED COMPLETION DATE Immediately

Finding 2025-001 Condition The change in student status for 3 of the 60 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. The status for 1 of 60 students tested was inaccurately reported to NSLDS. Corrective Action Plan The Registrar completed an analysis of each of the changes in student status that were not reported timely or accurately. The following actions have been implemented to improve processes and to reduce the likelihood of noncompliance. The College has instituted a more stringent Incomplete policy for graduate students that aligns with the mandatory NSLDS reporting deadlines of 30 days for status changes and 60 days for roster file responses. The Registrar's Office has established a manual communication protocol requiring staff members who process student status changes outside regular reporting cycles (mid-semester withdrawals, off-cycle graduations, leaves of absence, late grade changes affecting enrollment status) to immediately notify the designated NSLDS reporting staff member via email or direct communication. All staff members processing degree conferrals have been trained. In addition, standing interdepartmental meetings have been established to improve communications. The NSLDS reporting staff member maintains a simple log to track these notifications and ensure timely submission to NSLDS. Registrar's Office is working directly with their NSC analyst to align the Summer Graduates Only reporting windows and all other NSC reporting deadlines with the 30-day and 60-day NSLDS requirements. Name of Contact Person Responsible for Corrective Action: Elizabeth Brentzel Anticipated Completion Date: Spring 2026