Corrective Action Plans

Finding Number: 2025-020 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. The reconciliation process will be revised to specify steps to identify clients that are eligible to receive Title IV-E funding and the process to update their IV-E status. The agency could not make the necessary corrections in AASIS when notified of the deficiency due to the expenses being posted in the prior fiscal year. All necessary adjustments will be made on the quarterly report for the period ending on 3/31/26. Anticipated Completion Date: 4/30/26 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

Critical Deadline Controls Implementation of internal tracking alerts to monitor the 45-day regulatory deadline.Tracking calendar for each withdrawn student.Interdepartmental Coordination Review and update of protocols between Academic Departments Registrar, Financial Aid, and Finance.Immediate notification of student withdrawals.Process Standardization Development of detailed procedures for calculation and return of funds.Use of standardized checklists for each R2T4 case.Oversight and Review Weekly review and validation withdrawals, drops of pending R2T4 cases. Monthly reconciliation of withdrawal reports submitted by the Registrar Office.Technical Training Specialized training in R2T4 calculations and federal compliance

Reporting Controls and Monitoring Implementation of a fixed NSLDS reporting calendar.Monthly validation of enrollment status changes (withdrawals, drops, enrollment level changes).Accountability and OversightAssignment of dedicated personnel responsible for Enrollment Reporting.Supervisory review and approval prior to submission of each report.Targeted Training Focused training on NSLDS compliance and federal regulations.Cross-training to reduce dependency on a single staff member Procedural Enhancements Review and update of established process between Academic Departments and the Registrar Office to unsure proper identification of students who have fulfilled graduation requirements.Implementation of reporting checklists to ensure compliance at each cycle.Systems Integration Review and validation of integration between internal systems and NSLDS/Clearinghouse to ensure data accuracy.

Finding 2025-004 - Enrollment Reporting: Untimely Status Update Condition: One student who graduated in December 2024 was not reported within the required 60-day timeframe. Corrective Action Plan: The College will strengthen enrollment reporting controls within Colleague by: • Performing a monthly reconciliation between Registrar records and enrollment reporting files submitted to NSLDS. • Utilizing Colleague reporting tools to identify recent graduates and status changes requiring updates. • Establishing a compliance calendar with system reminders for required reporting deadlines. • Training staff on reporting requirements aligned with the National Student Loan Data System. Responsible Party: Mandy Schnorr, Director of Financial Aid, Cara Moyer, Registrar Anticipated Completion Date: June 30, 2026

The District acknowledges the finding related to the reporting of origination records to the Common Origination and Disbursement (COD) system in accordance with 34 CFR § 668.408(a)(2). The determination is that the discrepancy was the result of a manual data entry error during the preparation and submission of the origination record. The issue was isolated to a single record within the sample reviewed and does not reflect a systemic reporting issue. Upon identification, the District verified the correct cost of attendance information in the student’s file and updated the record in the COD system to ensure it accurately reflects the supporting documentation. The District recognizes the importance of Title IV funding and takes the accuracy of Title IV reporting seriously and has implemented additional internal control procedures to strengthen oversight of origination record submissions, including a secondary review of key data elements, such as cost of attendance, prior to submission of origination records to the COD system and ensuring all required data fields align with the student’s supporting documentation. These corrective actions are intended to ensure that the information reported in the COD system is accurate and consistent with the documentation maintained in student files, thereby maintaining compliance with federal reporting requirements and safeguarding the integrity of Title IV program administration.

2025-002 - The College must provide an original signature on the printed form that must be mailed or hand delivered by the first of October deadline date. (34 CFR 668.24). Condition: The College submitted the FISAP to the Department fourteen days after the requirement due to President being out of the country. We consider this to be an instance of noncompliance in relation to Reporting and is not a repeat finding. Statistical sampling was not used. Responsible Person: Robert Emerson - Director of Financial Aid Corrective Action Plan: The FISAP is available for completion during the months of August and September, with a deadline of October 1st. To avoid potential future schedule issues, the Financial Aid office will target a completion date no later than September 10th. This will ensure our ability to obtain an original signature and mail the application in a timely manner. Implementation Date: 10-22-2025

2025-001 - Sikich tested twenty drop students and found one incorrect refund calculation and one untimely paid refund (10%). We consider this finding to be an instance of non-compliance in relation to Special Tests and Provisions and a repeat of prior year finding 2024-001. Statistical sampling was not used. Responsible Person: Robert Emerson - Director of Financial Aid Corrective Action Plan: Withdrawals are processed by Dean of Academic Success and forwarded to Registrar and Financial Aid Office for review and action. The Financial Aid Office will begin to track and confirm the dates provided for withdrawals, last dates of attendance and disbursement to ensure that funds are returned accurately and in a timely manner. Implementation Date: 10-22-2025

Identifying Number: 2025-001 Finding: For sixteen out of forty students tested who had enrollment changes at the University, the student’s status effective dates at the campus level and program level were not reported to the NSLDS timely. Corrective Actions Taken or Planned: We agree with the finding. The delays in reporting were identified beginning in December 2024 with the hire of a new registrar and since that time we have caught up with reporting requirements are now timely. We have also increased our cross-training efforts in the department, training multiple individuals on NSC reporting procedures, in order to ensure that if turnover were to occur again in the future there are other individuals who can perform the required functions. Person(s) Responsible for Corrective Actions: Katie Soter, Registrar Anticipated Completion Date: Completed

Student Financial Aid Cluster – Assistance Listing 84.007 – Federal Supplemental Educational Opportunity Grants; 84.063 –Federal Pell Grant Program; 84.268 – Federal Direct Loan Program Recommendation: We recommend the University evaluate its monitoring controls over outstanding Title IV refund checks and credit balances to ensure that funds are returned to the Secretary no later than 240 days after the date the University issued the payment and credit balance payments are made within the 14-day requirement. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University will implement a regular review process of all outstanding Title IV payments and monitoring procedures of credit balance payments during the year. Name(s) of the contact person(s) responsible for corrective action: Lenora Stuckmann, Vice President for Finance and Chief Financial Officer Planned completion date for corrective action plan: 06/30/2026. If there are any questions regarding this plan, please call Lenora Stuckmann at 920-565-1027

Gramm-Leach-Bliley Act Recommendation: We recommend that the District update its written information security program to ensure it includes all required elements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Actions planned in response to finding: The District will review and update its written information security program to ensure all required elements are included and fully aligned with applicable state and federal requirements. Updates will be completed and implemented in coordination with the appropriate departments to ensure compliance and ongoing monitoring. Responsible party: Director of Network Operations & Senior Director of Information Services Planned completion date for corrective action plan: April 30, 2026 Plan to monitor completion of corrective action plan: • The Director of Network Operations and Senior Director of Information Services will conduct periodic reviews to verify that updates to the information security program are completed, documented, and implemented as intended. • Progress will be reviewed with relevant departments to ensure ongoing compliance and to address any gaps identified during implementation.

240 Day Outstanding Payments Recommendation: We recommend the District implement a review process for outstanding student payments to ensure any that include Title IV funds are refunded to the U.S. Department of Education within 240 days. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Actions planned in response to finding: The Financial Aid Coordinator will create and maintain a SharePoint spreadsheet to effectively track and monitor outstanding student payments. The Workforce Finance Department will support the setup and ensure the spreadsheet aligns with established financial monitoring practices. Responsible party: Financial Aid Coordinator and Workforce Finance Department Planned completion date for corrective action plan: April 30, 2026 Plan to monitor completion of corrective action plan: The Financial Aid Coordinator and Workforce Finance Department will conduct monthly reviews to ensure the spreadsheet is updated, accurate, and used consistently for monitoring outstanding payments.

Special Tests and Provisions Recommendation: It is recommended that the District strengthen its internal controls over the R2T4 calculation process by implementing a secondary review or quality-assurance check of scheduled clock hours prior to finalizing R2T4 calculations. Staff should receive targeted training on the requirements of 34 CFR § 668.22, particularly regarding the use of scheduled hours in determining earned aid and post-withdrawal disbursement eligibility. Additionally, standardized calculation worksheets or system-generated hour reports should be utilized to reduce reliance on manual entry and minimize the risk of human error. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Actions planned in response to finding: Financial Aid Coordinators from both technical colleges will collaborate to review and audit each other's RT24 calculations to ensure accuracy, accountability, and compliance with regulatory requirements. Responsible party: Financial Aid Coordinator Planned completion date for corrective action plan: April 1, 2026 Plan to monitor completion of corrective action plan: Monthly meetings with the Workforce Finance Department will be held to review RT24 calculations, address discrepancies, and confirm ongoing compliance.

Return to Title IV Recommendation: We recommend that a process is put in place to ensure that all students are notified upon withdrawal they may be required to return federal award funds back to the Department of Education. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Actions planned in response to finding: The District will develop a letter in FOCUS that would automatically generate and notify all students when they are required to return funds to the Department of Education Responsible party: Financial Aid Coordinator, Workforce Finance Department Planned completion date for corrective action plan: April 30, 2026 Plan to monitor completion of corrective action plan: The Financial Aid Coordinator and Workforce Finance Department will conduct monthly reviews to confirm the automated notification process is functioning correctly and that required letters are being sent and documented.

Common Origination & Disbursement Reporting Recommendation: We recommend the District evaluate its procedures and policies around reporting Pell disbursements to COD to ensure that student information is reported accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Actions planned in response to finding: Financial Aid Coordinators will monitor weekly to ensure matching of both systems. Responsible party: Financial Aid Coordinator and Administration Planned completion date for corrective action plan: April 1, 2026 Plan to monitor completion of corrective action plan: • The Financial Aid Coordinator will perform weekly reviews to confirm system alignment. • Administration will conduct quarterly oversight to ensure continued compliance and proper documentation.

Title IV Credit Balances Recommendation: We recommend that the District review its policies and procedures for Title IV credit balances to ensure they are paid in a timely manner. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Actions planned in response to finding: District has already implemented a plan by creating a drawdown process to ensure both the Financial Aid Coordinator and the Workforce Finance Department are in communication with each other. The drawdown process ensures that funds are received by the student in a timely manner (within 14 days) Responsible party: Financial Aid Coordinators, District Workforce Finance Department Planned completion date for corrective action plan: Task is completed Plan to monitor completion of corrective action plan: The Financial Aid Coordinator and Workforce Finance Department will hold monthly meetings to review the drawdown process and confirm continued compliance.

Documentation of Monthly Reconciliation Recommendation: We recommend the District establish policies and procedures to ensure proper documentation of preparation and review of monthly Title IV reconciliations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Actions planned in response to finding: • The District will reconcile the institutional records with Pell funds monthly and maintain documentation and preparation of the reconciliation process • The Financial Aid Coordinator will be responsible for creating a SharePoint drive and maintaining the accuracy of the reconciliation process via SharePoint drive • Create a SharePoint so that when we have employee-related transitions, the newly assigned Financial Aid Coordinator will have access Responsible party: Financial Aid Coordinators and Workforce Finance Department Planned completion date for corrective action plan: April 30, 2026 Plan to monitor completion of corrective action plan: • The Financial Aid Coordinators and Workforce Finance Department will conduct a monthly review to confirm reconciliations are completed, documented, and properly approved. • Any issues identified during monthly reviews will be addressed promptly to ensure ongoing compliance.

The College has implemented a structured NSLDS enrollment reporting control to ensure updates are reported within 60 days to NSLDS, (OMB No. 1845-0035) (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309; Perkins 34 CFR 674.19(f)). The Registrar’s Office, or a representative of, generates a Monthly status-change report, which is reviewed at the Student Affairs Operations meeting. Financial Aid reviews the list for Title IV impacts, and the Director of Financial Aid completes the NSLDS Enrollment Maintenance roster review and certification on a scheduled cadence (at least biweekly; weekly during peak periods). Each submission is documented with (1) the SONIS status-change report, (2) the NSLDS Enrollment Maintenance Report/roster file, and (3) dated evidence of review/approval and submission (email/Teams sign-off plus NSLDS submission history screenshot). Exceptions approaching 45 days are escalated to leadership for same-week certification

U.S. Department of Education Mount Mary University respectfully submits the following corrective action plan for the year ended June 30, 2025. Audit period: July 01, 2024 - June 30, 2025 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FINANCIAL STATEMENT AUDIT Our audit did not disclose any matters required to be reported in accordance with Government Auditing Standards. FINDINGS—FEDERAL AWARD PROGRAMS AUDITS U.S. Department of Education 2025-001 Student Financial Aid Cluster – Assistance Listing No. 84.063 & 84.268 Recommendation: We recommend that the University reviews withdrawals monthly to ensure that the students are reported correctly to NSC and subsequently to NSLDS. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University has submitted and reviewed the four students and have submitted corrections for incorrect statuses and effective dates. Name(s) of the contact person(s) responsible for corrective action: Brian Olson, Vice President of Finance and Administration Planned completion date for corrective action plan: June 30, 2026 *** If the U.S. Department of Education has questions regarding this plan, please call Brian Olson, Vice President of Finance and Administration, at 414-930-3139.

Finding 2025-001 Condition During our audit, 1 out of 3 employees selected for testing received a bonus payment for achieving first year enrollment goals. The College then determined 2 employees received such bonuses and additional testing confirmed a total of 2 out of 27 employees who were involved in the College's admissions/recruiting, financial aid and registrar offices received bonuses based on their contributions towards enrollment performance. These bonuses were paid from internal College funds and not from Title IV funds. Corrective Action Plan Corrective Action Planned: The college implemented a policy on incentive pay citing the restrictions and banning incentive pay for specific job duties. The policy and a standard form for awarding additional compensation have been reviewed and approved by senior leadership and posted to the college’s human resources website. Name(s) of Contact Person(s) Responsible for Corrective Action: Amanda Stahl, Vice President for Finance and Ann Eckert, Assistant Vice President for Human Resources will be responsible for ensuring adherence to the policy and review of any awarding of additional compensation. Anticipated Completion Date: The policy and forms were approved and completed September 30, 2025.

Financial Statement Findings 2025-01 The District’s control procedures over IT systems and data were not sufficient, which increases the risk that the District may not adequately protect those systems and data. Contact: Thomas Thompson, Chief Information Officer Anticipated completion date: June 30, 2026__________________________________________ Corrective Action Plan: The District will prioritize the development and formal documentation of IT policies and procedures addressing logical access controls, system security, and vendor management. These policies will align with recognized industry standards and will include processes to ensure consistent implementation and compliance. a) User access assignment and review b) Timely removal of access c) Enhance verification of assignment through available and to-be-developed reporting tools d) The District will review and enhance formal procedures for evaluating, awarding, and monitoring IT vendor contracts. This will include documenting vendor qualifications, defining security expectations in contracts, and performing periodic reviews to ensure vendors comply with contractual and security requirements. e) Management will implement supervisory review controls to ensure adherence to IT policies and procedures. Federal Award Findings 2025-101 The District did not timely report required student information to the federal agency, risking students not being asked to repay financial assistance. Contact: Sharon Montoya, Director, Financial Aid & Veteran Services Anticipated completion date: June 30, 2026__________________________________________ Corrective Action Plan: The District will implement procedures to ensure all student enrollment status changes are reported to the National Student Loan Data System (NSLDS) within the required 60-day timeframe. This includes establishing a standardized reporting schedule and utilizing system-generated reports to monitor pending status changes. a) Assign monitoring and oversight responsibilities in the Financial Aid department b) Implement ongoing monitoring control within the Financial Aid department c) Monthly inquiring into the Financial Aid department process by Fiscal Control

Credit Balances Held Beyond Payment Period Planned Corrective Action: Ohio Christian University has implemented procedures to ensure that all Title IV credit balances are identified and released to students within 14 days of the credit balance occurring, in compliance with federal regulations. The Financial Aid Office will run weekly credit balance reports following each disbursement to identify any student accounts with a Title IV credit balance. These reports will be reviewed jointly by the Financial Aid and Student Accounts offices to confirm eligibility and authorize timely refunds. As an ongoing quality assurance measure, supervisory review will be conducted monthly to verify compliance with the 14-day requirement, and any exceptions will be documented and addressed immediately. Staff training has been enhanced to reinforce regulatory requirements and internal timelines related to credit balance processing. Person Responsible for Corrective Action Plan: Justin Pichey, Director of Financial Aid & Chelsie Hedrick, Senior Accountant Anticipated Date of Completion: This was implemented starting with the Spring 2026 semester.

Finding 2025-001 Condition The University did not notify the National Student Loan Data System (NSLDS) in a timely manner for four students with status changes. Corrective Action Plan 1. Finding: Incorrect Status Date Reported to NSC/NSLDS for a withdrawn student Corrective Actions: • Root Cause Analysis: A review was conducted to determine why NSC/NSLDS received the incorrect date despite Colleague displaying the correct withdrawal date of 3/20/2025. The analysis confirmed that the Colleague reporting process pulls the date from the course drop/withdrawal field rather than the student status withdrawal date screen. According to system documentation, “SITX determines the enrollment status, enrollment status start date, and the anticipated graduation date for the students included in the extract. If the enrollment status changes during the reporting period since the last census date, the status change date is calculated from schedule changes and hiatus record information.” • Process Improvement: o Staff have been instructed to ensure that all relevant screens reflect the correct status change date prior to reporting. o Documentation is being developed outlining the withdrawal process workflow, including all screens requiring updates. This will promote consistency and serve as a reference for future staff transitions. 2. Finding: Failure to Report Three Graduates to NSLDS Within the 60 Day Requirement Corrective Actions: • Root Cause Analysis: The University Registrar contacted the NSC to investigate the delay. Although the NSC Degree Verify file was submitted within the required timeframe, it was determined that the “G Not Applied” process on the NSC site was not completed promptly by Registrar’s Office staff, resulting in the late NSLDS reporting. • Process Redesign: The University Registrar is working with Gannon IT Services to develop a “Graduates Only” reporting process directly from Colleague. This enhancement will eliminate reliance on the NSC “G Not Applied” step, which has been a recurring compliance challenge. This new process will be implemented no later than July 1, 2026. Until then, the “G Not Applied” list will be processed within 10 days of processing availability (at times the G Not Applied cannot be updated while an Enrollment file submission is pending acceptance). • Proactive Audit Measures: Given the significant staffing transitions and shifts in reporting responsibilities over the past year, an internal audit of the 2025–2026 reporting completed to date is underway, in collaboration with the NSC Audit Department, to determine the full extent of any additional reporting deficiencies that may have carried into the new academic year. 3. As previously stated in the Summary Schedule of Prior Audit Findings for the Year-Ended June 30, 2024 Update, the following corrective actions are being initiated: • Additional staff have been designated to ensure that at least three individuals possess the knowledge and system access required to submit reports and process corrections. • All designated staff are required to complete NSC-provided training to ensure full understanding of reporting requirements and procedures. • Each staff member must submit test reports and review resulting errors using the NSC test submission process, working closely with assigned NSC analysts to demonstrate competency in accurate reporting and effective error resolution. Name(s) of Contact Person(s) Responsible o Barbara Helms, University Registrar – primary responsibility for enrollment reporting submissions, back-up for G reporting o Heidi Thomas, Processing and Data Specialist – assists with enrollment error report cleanup, secondary for enrollment reporting submissions, additional back-up for G reporting o Ashley Dinger, Academic Records and Graduation Specialist – primary responsibility of the G reporting, additional back-up for enrollment reporting. • Although documentation exists from the previous corrective action plan, it has been determined that it is not sufficiently detailed. New documentation is being developed to ensure that any individual responsible for these processes in the future has the necessary tools and guidance to meet all regulatory requirements. Estimated timeline for corrective action to be implemented: April 2026

FINDING 2025-007 Name of Responsible Individual: Brandon Rhone, Systems Administrator Corrective Action: We have revised our award period start and end dates to align or fall within range of our loan period code start and end dates when reporting to COD. This alignment ensures that all reported disbursements meet federal timing requests and reduces the risk of COD rejects or compliance findings. Anticipated Completion Date: March 31, 2026

FINDING 2025-005 Name of Responsible Individual: Chad Wick, Director of Financial Aid Corrective Action: We have implemented a new Quality Assurance Measure for Auditing all students with a C-Flag. The process begins with the FA advisor team. They are responsible for ensuring all documents have been received and all steps have been completed to clear the C-Flag. In Colleague the advisor will then mark the file is ready for audit. Chad Wick, Director, Financial aid or Brandon Rhone, Systems Administrator, will review all documents and steps needed to clear C-Flag and then update the communication code to audited and make any adjustments if needed to the FAFSA. Anticipated Completion Date: Already completed

FINDING 2025-004 Name of Responsible Individual: Chad Wick, Director of Financial Aid, and Brandon Rhone, Systems Administrator Corrective Action: We will implement a second check process after R2T4 has been calculated to ensure the correct dates are being used. Chad Wick, Director, Financial Aid will conduct the initial calculating of R2T4 on a weekly basis. Brandon Rhone, Systems Administrator, will review all calculations prior to processing them in Colleague. Anticipated Completion Date: March 31, 2026