Corrective Action Plans

Management concurs with this finding. The College will adhere to its policies, procedures, processes, and federal guidelines as it relates to calculating and awarding Pell. The College will return any ineligible funds accordingly. Responsible Administrators: Director of Financial Aid & Chief Financial Officer Effective: Immediately and ongoing

Management concurs with this finding. The College will adhere to its policies, procedures, processes, and federal guidelines as it relates to over awarding students. The College will return any ineligible funds accordingly. Responsible Administrators: Director of Financial Aid & Chief Financial Officer Effective: Immediately and ongoing

Management concurs with this finding. The College will review and adhere to its practices, policies, and procedures along with federal guidelines as it relates to students meeting satisfactory academic progress. The College has an SAP appeal committee in place to enforce and abide by the College's policy. The College will return any ineligible funds accordingly. Responsible Administrators: Director of Financial Aid Effective: Immediately and ongoing

Management concurs with this finding. The College will review and adhere to its practices, policies, and procedures along with federal guidelines as it relates to disbursing and administering federal aid. The College will return any ineligible funds accordingly. Responsible Administrators: Director of Financial Aid, Chief Financial Officer & V.P. of Academic Affairs Effective: Immediately and ongoing

Management concurs with this finding. The College will set policies, procedures and practices in place and adhere to ensure that changes in students’ enrollment are reported accurately and timely as defined in the Federal guidelines. Responsible Administrators: Director of Financial Aid & Registrar Effective: Immediately and ongoing

Management concurs with this finding. The College will review and adhere to its practices, policies, and procedures along with federal regulations as it relates to resolving credit balances. The College will resolve credit balances timely and within the 14-day period as defined in the Federal guidelines. Responsible Administrators: Director of Financial Aid & Chief Financial Officer Effective: Immediately and ongoing

Management concurs with this finding. The College will ensure the accuracy of the data that is input into the COD system and the College will work to apply funds appropriately to students' accounts. The College will review and adhere to its practices, policies, and procedures along with federal guidelines as it relates to managing the COD system. Responsible Administrators: Director of Financial Aid & Chief Financial Officer Effective: Immediately and ongoing

Management concurs with this finding. The College will keep accurate attendance and participation records. The College will calculate R2T4s accurately and will return the funds in a timely manner. The College will review and adhere to its practices, policies, and procedures along with federal guidelines as it relates to R2T4 regulations. The College will return any ineligible funds accordingly. Responsible Administrators: Director of Financial Aid & Chief Financial Officer Effective: Immediately and ongoing

Finding No. 2023-001 – Significant Deficiency and Noncompliance: Special Tests and Provisions – Enrollment Reporting Corrective Action The corrective action that will be taken is a graduates only enrollment report will be supplied to the National Student Clearinghouse (NSC) by the Registrar’s Office on a consistent schedule of submission within 60 days of each graduation period. Persons Responsible for Corrective Action The corrective action plan will be completed by Walter Rankin, Vice Provost for Graduate Continuing and Professional Studies and Danielle Quilligan, University Registrar. Completion Date Initial corrective action was completed by Lynn Kohrn, University Registrar and Allison Henderson, Assistant Registrar in October, 2023 with the submission of a graduates only enrollment report to the third-party service provider NSC. A schedule for consistent submissions of a graduates only enrollment report has already been provided to the NSC.

Management’s Response: Briar Cliff will work with Ellucian on a review of the setup and processes that the Registrar’s Office currently follows, and we will work with Ellucian for recommendations on implementing a process/procedure that ensures the Registrar’s Office has been trailed and is in compliance.

Finding 2023-004: Annual Security Report and Campus Crime Awareness Requirements Not Met Comments on Finding and Recommendations: The College agrees with this finding as determined in the audit, and states that the College had failed to provide clear evidence that it had gathered the correct data from the local authorities, however, the College had not confirmed that the document was readily available to all students and prospective students upon the completion of the Annual Security Report on October 3, 2024. Actions Taken or Planned: The College has published the 2024 Annual Security Report on the web page as identified here. Disclosures – Dragon Rises College of Oriental Medicine The 2022 statistics for the Gainesville FL location have been provided to all students, and the College will be completing the required updates for the 2023 statistics and incorporating the findings into an updated Annual Security Report for publications in April of 2025. Name: Dr. Dorian G. Kramer DACM Title: Director Telephone: (941)-289-2456 Email: dkramer@dragonrises.edu

Finding 2023-003: Failure to Meet the Standards for Safeguarding Customer Information Comments on Finding and Recommendations: The College agrees with this finding as determined in the audit and states that the College has complied with the requirement. Actions Taken or Planned: Dragon Rises College of Oriental Medicine has completed the requirements and published the Information Security Program Compliance with Gramm-Leach-Bliley Act (GLBA). The College is committed to the preservation and security of personal data and is dedicated to adhering to regulations pertaining to the safeguarding of personal, sensitive, and other protected data within its purview. Name: Dr. Dorian G. Kramer DACM Title: Director Telephone: (941)-289-2456 Email: dkramer@dragonrises.edu

Finding 2023-002: Financial Responsibility Comments on Finding and Recommendation: The College agrees with this finding as determined in the audit and states that the College had a net reduction in student enrollments and had incurred additional expenses as it operated at two separate locations within Florida. The College incurred additional losses in tuition revenue and services revenue as it restructured how to operate both locations appropriately during 2023. The College had additional interest expense in 2023 during the restructuring of the administration and the facilities of the College. Actions Taken or Planned: The College acted in 2024 to reduce the academic footprint to the facility it owned in Bradenton FL, while reporting the Gainesville FL location as no longer offering instruction, but maintaining a clinical facility to allow students to complete the requirements of their academic program. The College also removed and replaced the Executive Director and other members of administration that contributed to the financial issues faced by the College. Name: Dr. Dorian G. Kramer DACM Title: Director Telephone: (941)-289-2456 Email: dkramer@dragonrises.edu

FINDING 2023-001 NONCOMPLIANCE - REPORT SUBMISSION Program Title/Federal Grantor/ALN: Foster Care Title IV-E U.S. Department of Health and Human Services Assistance Listing Number 93.658 Corrective Action Plan The Organization will file the SF-SAC Single Audit Data Collection Form by the due date or file an extension when needed. Name of the Contact Person Responsible for Corrective Action Brian Gambini, Administrator Anticipated Completion Date September 30, 2025

Given staff & contract staff turnover during the year, required financial aid reporting requirements were late, this will not be an issue moving forward as the University ceased participation in all federal financial aid programs and is expected to fully transition to a scholarship granting organization.

We agree with the recommendation. A full-time staff position "Student Scholarship Accounting & Compliance Officer" is filled and a component of this role is to disburse credit balances within 14 days, should there be a need. However no Federal financial assistance funds were awarded after June 30, 2023 as the University ceased academic operations and degree granting in May 2023 upon completion of spring semester.

Cluster Name: Student Financial Assistance Cluster Assistance listing numbers and names: Northern Arizona University 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study 84.038 Federal Perkins Loan Program—Federal Capital Contributions 84.063 Federal Pell Grant Programs 84.268 Federal Direct Student Loans 84.379 Teacher Education Assistance for College and Higher Education Grants (TEACH Grants) 93.364 Nursing Student Loans 93.925 Scholarships for Health Professions Students from Disadvantaged Backgrounds—Scholarships for Disadvantaged Students (SDS) Agency: Northern Arizona University (NAU) Name of contract person and title: Bradley Miner, NAU Associate Vice President and Comptroller Anticipated Completion Date June 30, 2024 Agency’s Response: Concur The University agrees with this finding and although it relies on the Federal agencies for valid identity verification, the University has already taken significant corrective action to proactively monitor and detect fraudulent student identities. The University has various internal controls, system fraud controls, and integrity measures in place as required or identified as industry best-practice to mitigate and prevent the increasing sophistication of fraudulent activity. In academic year 2023 the University had 282 online students selected for Verification by the Department of Education (ED). The 8 isolated fraud instances were the only identified fraud cases. The University receives valid identity verification checks from the Department of Education (ED) as an input for creating student profiles. Additionally, the University works with administrative agencies and leverages FAFSA checks conducted by Social Security Administration (SSA), Department of Veteran Affairs (VA), Department of Homeland Security (DHS), National Student Loan Data System (NSLDS), Department of Defense (DOD), Department of Justice (DOJ). Financial Aid does not disburse until enrollment verification is complete. 1. The University has reviewed prior fiscal years to determine if additional fraudulently enrolled students received student financial assistance, and if fraudulent loans and awards were awarded. The University conducted an in-depth analysis of multiple qualitative attributes of students receiving financial assistance. This analysis identified high risk students receiving loans and awards. Students in this population were required to complete V4 verification. 2. The University implemented anti-fraud measures as an alternative to automated student Internet Protocol (IP) verification. During the analysis to identify fraudulently enrolled students, the University identified programs at high-risk for fraudulent activity. As a proactive fraudulent activity identification measure, the University will require all students in high-risk programs, with active FAFSAs to submit and complete V4 identity verification. This anti-fraud measure will identify fraudulently enrolled students prior to the disbursement of student financial assistance including loans and awards. 3. The University has put in to place a number of additional verification measures and detective controls to validate online student identities and check for repetitive information and trends. The University is conducting feasibility studies to determine if the suggested guidance for Internet Protocol student verification abides by certain security and privacy standards and policies. Additionally, the University has concern with fraudsters ability to mask Internet Protocols by deploying Virtual Private Networks (VPNs). This renders the advanced protocols ineffective. As a compensating control, the University will begin selecting 5% of online students for V4 verification. Random sampling of online students for identity verification provides enhanced detective measures to combat the risk of identity theft for use in financial aid fraud. Additionally, the University put in place several upfront measures to detect repetitive information and trends to identify potentially fraudulent activity. Detective monitoring reporting identifies duplicate deposit information, redundant student email information, and duplicate student address information. The Department will continue to utilize these successful anti-fraud measures to proactively identify fraudulent student identities. 4. The University will continue its efforts working with law enforcement agencies to recover improper payments for fraudulent claims it paid due to identity theft, to the extent practicable. The University worked with law enforcement agencies to investigate the fraud. At the conclusion of the investigation $138,135 has been repaid. The University will continue to partner with federal, state, and local law enforcement agencies and financial institutions across the country to recover losses and aggressively pursue legal action against perpetrators of fraud.

Assistance listing number and program name: 93.658 Foster Care—Title IV-E 93.658 COVID-19 - Foster Care—Title IV-E Agency: Arizona Department of Child Safety (DCS) Name of contact person and title: Emilio Gonzales, DCS Audit Administrator Anticipated completion date: Fiscal Year 2025 Agency’s Response: Concur The Department will comply with the Federal Funding Accountability and Transparency Act (FFATA) and Federal Uniform Guidance regulations in accordance with the Department’s Grant policies and procedures. As of November 2024, the Department worked with the federal agency to resolve the inability to submit outstanding subaward information prior to January 2024. The FFATA reporting was completed for fiscal years 2024, 2023, 2022 and 2021. The Department will also continue to follow its policies and procedures for reporting subaward actions, as required.

a. Comments on the Findings and Each Recommendation Due the ongoing impact of the COVID 19 pandemic, the Organization and CHR Consulting Services, Inc. (“CHR”), the entity responsible for maintaining the books and records of the Organization, experienced staffing shortages due to retirements and medical leave. In addition, as a result of the ongoing impact of the COVID 19 pandemic, the Organization continued to experience noncompliance with certain debt covenants in 2023 and first half of 2024. In addition, the Organization had several vendor or liabilities, including the Pennsylvania bed tax liability that required resolution prior to the issuance of the audited financial statements. b. Action(s) Taken or Planned on the Finding The Organization and CHR have been able to recruit additional staff and CHR has added additional supervisory personnel to oversee the financial reporting and audit process. In an effort to improve communications with the Grantor, in August 2023, the Organization began providing monthly financial and operational information. In addition, monthly calls were implemented with the representatives of the Grantor, discussing key operational and performance measures. While key issues were identified and discussed with the Grantor, the Grantor has not been able to provide waivers for such noncompliance with covenant requirements. As noted in Note 2 the audited financial statements, the financial performance of the Organization has improved, allowing the Organization to enter into long-term payment plans for the resolution of the key liabilities of the Organization. It is anticipated that the audit for 2024 and related forms will be issued within the allowable time period in the loan agreements.

Finding 2023-004: Internal Control Deficiency Reporting Federal Grantor: United States Department of Health and Human Services Assistance Listing No.: 93.048 Summary of Finding: Evidence of internal controls was not in place throughout the audit period to ensure that reports which are submitted are complete and accurate. The same individual that prepares the SF-425 report, was the same individual who reviewed and submitted the reports. Corrective Action Plan: Internal controls were implemented in October 2023 following the 2022-03 finding, to ensure that once the SF-425 report is completed, someone from the accounting department verifies the funds being reported are correct and appropriate. Documentation will be maintained to support the review process. Responsible Party: Sonja Landry, Executive Director Anticipated Completion Date: Completed October 2023

The University agrees with the finding and acknowledges the finding was also reported in the previous fiscal year. Despite high staff turnover, the Director of the Financial Aid Office and in collaboration with the Controller’s Office the issue is being addressed for any future reporting.

The University concurs with this finding but cannot respond why the student was awarded outside the of procedure and methodology set up for awarding HEERF Funds. The decisions were made by individuals no longer with the University and no documentation was found to determine why the student was awarded outside the policy in place. The Controller’s Office and Financial Aid Office are working together to make sure that in future funds like the HEERF will have documentation attached to secure that we follow procedure and policy and document any exceptions.

The University agrees with the finding. The University has had a significant amount of staff turnover and reorganization in FY 2023 in the financial aid office. The Interim Director of Financial Aid is collaborating with the controller’s office to make sure that the University has internal controls in place over Federal programs to assure that the Pell reporting requirements are executed in compliance with Federal statutes, regulation and terms and conditions of the federal award. The University is investing in making sure that the Financial Aid Office is staffed and create policy and procedure that assure that we improve internal controls on the Pell process.

Management's Response: We concur. View of Responsible Officials and Corrective Action Plan Corrective action plan to ensure enrollment reporting is completed timely and accurately I. The admissions team sends a list of all enrolled students 2. Financial aid will manually enter the student's information into campus IVY 3. Campus IVY updates the student's status in NSLDS every 30 days. 4. If a student withdraws from Community Christian College, financial aid will manually update the student status into campus IVY 5. NSLDS is updated upon completion of the withdrawal This process will ensure that Community Christian College updates enrollment statuses for every student timely

Management's Response: We concur. View of Responsible Officials and Corrective Action Plan The following is the procedure that the College will be implementing to ensure that student withdrawal calculations are performed accurately and returned within 30 days: I. The registrar will send a list to financial aid of all students that have dropped by end of day every Thursday of each week. The list will include date of determination (DOD) and last date of attendance (LOA) of each student b. DOD wiII be within 14 days of student LOA 2. Upon receipt of the list financial aid will complete the following for each student: a. Gather student's current ledger card b. Gather student's current Transcript c. Complete a cover sheet which indicated the current loan period of the student. d. Financial aid will send over items to yd patty processor in order for R2t4 calculation to be completed (Campus IVY) no later than Wednesday of the following week by end of business day. 3. Campus IVY will complete the R2T4 3-5 business days upon receipt and conduct the following: a. If a refund is required- campus IVY will schedule the refund, update student account and send to school. b. School (student accounts) will review the refund, update student account and monies will be placed in the operations account and sent back to GS. c. If a refund is not required based on the R2T4 results, Campus IVY will notate the student account. This corrective action plan will allow Community Christian College to complete the drop process for each student within 30 days from LOA.