Corrective Action Plans

Bethany College and Affiliate Corrective Action Plan For the Year Ended June 30, 2025 Finding 2025‐001 – Significant Deficiency in Internal Control Over Compliance – Return of Title IV Funds Condition Found: Four students who had withdrawn from the institution did not have Title IV funds returned to the Department of Education within 45 days. Corrective Action Plan: The College will review our workflow and make oversight improvements to prevent future delays, including standardizing withdrawal notification and handoff procedures, initiating R2T4 calculations immediately upon withdrawal determination, confirming that required COD adjustments are submitted without delay and establishing internal tracking to monitor return activity against the 45 day requirement. Responsible Official for Corrective Action Plan: Sarah Sherinian, Vice President for Student Success & Operational Excellence/Chief Financial Aid Officer

Finding 2025-003 Federal Agency Name: U.S. Department of Education Program Name: Student Financial Assistance Cluster Federal Financial Assistance Listing: 84.007, 84.033, 84.063, 84.268 Finding Summary: In testing of 60 students, 1 student was identified that was notified of the requirement to return Title IV funds in excess of the amount actually required to be returned. The error was caught by the District, but the student’s account was never corrected to the appropriate amount of the return. Corrective Action Plan: The corrective action for the R2T4 calculation error involved promptly correcting the student's calculation and returning the appropriate funds. To prevent future mistakes, the Director of Financial Aid will review the current R2T4 controls process with staff, which now includes a double review by the Financial Aid Adviser and the Director to catch errors such as typos or miscalculations and to ensure accurate student notifications. After aid adjustments are made, the Director verifies the processed changes for accuracy, and any discovered errors are immediately corrected and documented in the R2T4 file. Responsible Individual(s): Christopher Natelborg Anticipated Completion Date: September 2025

Finding 2025-002 Federal Agency Name: U.S. Department of Education Program Name: Student Financial Assistance Cluster Federal Financial Assistance Listing: 84.007, 84.033, 84.063, 84.268 Finding Summary: In testing of 60 students, 1 student was identified who was not awarded the correct amount of Pell. Corrective Action Plan: The corrective action for the Pell Grant eligibility issue involved promptly adjusting the affected student's Pell Grant to the correct amount, which resulted in an increase and ensured there was no negative impact. To address the root cause, the Director of Financial Aid met with the financial aid team to review the finding and clarified federal regulations on Pell Grant calculations, referencing the 2024-25 FSA Handbook. Importantly, the Director committed to upgrading the internal Pell Grant calculator used by Financial Aid Advisers: this enhancement will add a flagging mechanism that automatically alerts advisers whenever a student's calculated Pell Grant amount falls below the published minimum Pell amount for that award year, thereby ensuring that no student unintentionally receives an ineligible or reduced Pell Grant due to a calculation oversight. Responsible Individual(s): Christopher Natelborg Anticipated Completion Date: January 2026

Finding 2025-001 Federal Agency Name: U.S. Department of Education Program Name: Student Financial Assistance Cluster Federal Financial Assistance Listing: 84.007, 84.033, 84.063, 84.268 Finding Summary: In testing of 60 students, 3 students did not receive a timely notification of their award from the District. Corrective Action Plan: To address missed disbursement notifications, the Financial Aid team identified affected students and sent the required notices, including an official explanation from the Director of Financial Aid. The issue was traced to a system malfunction during the SU24 term, which has since been resolved by implementing a process that alerts IT and the Director if notification counts do not match disbursement records. The notification script has been enhanced to track missing letters over the previous 30 days, and IT has established a weekly audit comparing sent notifications to disbursement records for accuracy. Additionally, coding updates in the CX system now ensure all disbursements are properly captured, regardless of the date entered by Financial Aid, thereby preventing similar oversights in the future. Responsible Individual(s): Christopher Natelborg Anticipated Completion Date: December 2025

Finding – Reporting: Financial Reporting - Student Financial Assistance Cluster, Assistance Listing #84.063 and #84.268, June 30, 2025 Award Year, U.S. Department of Education Criteria or Specific Requirement Institutions submit Direct Loan, Pell Grant, TEACH Grant, and IASG origination records to the COD ("Common Origination and Disbursement") system. The disbursement record reports the actual disbursement date and the amount of the disbursement. Institutions must report student disbursement data within 15 calendar days after the institution makes the disbursement or becomes aware of the need to make an adjustment to previously reported student disbursement data or expected student disbursement data. (July 2024 OMB Compliance Supplement pages 5-3-26 and 5-3-27) The date of disbursement determines when a student becomes a federal student aid (FSA) recipient and has the rights and responsibilities of an FSA recipient. A disbursement occurs when the School credits a student’s account or pays a student or parent directly with: • FSA funds received from the Department; or • School funds labeled as FSA funds in advance of receiving actual FSA funds. (Student Financial Aid Handbook, Volume 4, Chapter 2) Condition Found One of the 15 students selected for disbursement reporting had errors in the information that was reported to COD as follows: • The disbursement date reported was different from the actual disbursement date by one day • The cost of attendance that was reported to COD was different by $20 • The incorrect parent was identified as the borrower in the initial submission to COD Views of Responsible Officials and Planned Corrective Actions Staff have been trained on the proper procedures, and a formal policy and procedure has been established and is now referenced by the financial aid team. These procedures cover the correct process for releasing and disbursing federal aid within the Jenzabar JFA system to ensure compliance with federal regulations, including accurate disbursement date reporting in COD. Names of Contact Person Responsible for Correction Action: Renee Jordan, Director of Financial Aid Anticipated Completion Date: October 14, 2025

FISAP Reporting Planned Corrective Action: Deficiency: The backup documentation submitted for the Fiscal Operations Report and Application to Participate (FISAP) did not match the data reported on the FISAP. Institution Response: We acknowledge this discrepancy and agree that the FISAP backup documentation did not fully align with Part II, Sections 7a (Total Undergraduate Students) and 7b (Total Graduate Students) as reported on the submitted FISAP. The current FISAP reflects 43 for Section 7a, whereas the correct figure is 60, and 199 for Section 7b, whereas the correct figure is 202. Root Cause: At the time the report was prepared, the institution was relying on a contracted financial aid professional to provide the data for FISAP reporting. Although this work was performed in good faith, the contracted individual provided incorrect figures, which resulted in minor data discrepancies between the FISAP and the supporting documentation. Corrective Action Taken: Our Institution has ended its contract with the external financial aid services provider. We have transitioned all financial aid and FISAP-related responsibilities in-house and designated a qualified Data Point Administrator / Director of Financial Aid to oversee the preparation of the report. Additionally, there will be multiple financial professionals reviewing future FISAP and backup data. The current year’s FISAP has already been worked on using this updated structure, and all backup documentation has been reviewed for accuracy and confirmed to match the submitted FISAP. Preventive Measures Going Forward: To ensure accuracy and prevent recurrence, the institution has implemented the following procedures: 1. The Director of Financial Aid (Data Point Administrator) will prepare all FISAP data and maintain appropriate source documentation. 2. The Financial Aid Representative will review the completed FISAP and all backup documents to verify accuracy prior to submission. 3. The Financial Controller will receive the full FISAP packet, including backup documentation for an additional review and institutional oversight. 4. All FISAP materials and supporting documents will be stored in the institution’s secure Financial Aid OneDrive folder to ensure accessibility and consistency during audits. These steps have already been implemented for the most recent FISAP cycle and will be followed annually to maintain compliance and data integrity. Person Responsible for Corrective Action Plan: Josh James, CFO Anticipated Date of Completion: 11/24/2025

Student Financial Aid Cluster – Assistance Listing No. 84.063, 84.007, 84.033 Recommendation: Recommend that the College design and implement controls to ensure that all safeguards for identified risks required by the Gramm-Leach-Bliley Act (GLBA) are fully documented and updated as necessary. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Moraine Park Technical College will take or has already taken the following actions to address the audit finding: 1. Updated existing policies and documentation to fully reflect the controls in place to safeguard identified risks under the Gramm-Leach-Bliley Act. 2. Revised and formalized the following documents to ensure they clearly describe current practices and continuous monitoring activities: • Incident Response document • Risk Assessment document • Written Information Security Plan • IT Vulnerability Management Practices document These updates ensure that all existing controls and processes are fully documented, current, and aligned with GLBA requirements. Name(s) of the contact person(s) responsible for corrective action: Larry Plamann, Director of Enterprise Infrastructure Planned completion date for corrective action plan: January 2026

Student Financial Assistance – Assistance Listing No. Various Recommendation: We recommend the University review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Auditors identified two students for whom enrollment status on the campus level and program level was correctly reported to NSLDS as withdrawal in December 2024; however, both students graduated in March 2025 and that enrollment status was not updated at the campus level or the program level. We have a manual tracking procedure in place for students who complete missing coursework after their last term of enrollment that results in completion of their program. These two students were missed in that process. As a result of this finding, we have reviewed the procedure with the relevant staff and will continue to monitor the process, adding routine spot-checking of this tracking list. Names of the contact persons responsible for corrective action: Gwenn Sherburne, Registrar, and Lynette Wahl, Student Financial Aid Director Planned completion date for corrective action plan: October 31, 2025

Name of the contact person responsible for corrective action planned: Brenda Wendt Controller Cleveland State University 2121 Euclid Avenue Cleveland, OH 44115 Phone: 216.687.3676 Email: b.wendt@csuohio.edu Corrective actions planned: Finding Number: 2025-001 The University did not have adequate controls in place to ensure that credit balances were refunded in a timely manner within the 14-calendar-day requirement. Management has implemented a process to ensure that credit balances are processed within the 14-calendar-day requirement. A workflow hierarchy is in place to ensure adequate staffing and training, preventing processing delays. Any deviations from the normal processing of credit balances will be sent to the relevant department immediately for further action. Anticipated completion date: December 2025

Condition and Criteria: Institutions are required to timely report enrollment information under the Pell Grant and Direct Loan programs via the NSLDS. Institutions must review, update, and certify student enrollment statuses, program information, and effective dates. During our testing of the information submitted to NSLDS, we noted 2 students out of the 40 tested that had errors of status reporting for summer term. Effect: The College is not in compliance with the federal NSLDS reporting requirements described in the OMB Compliance Supplement and required by the Department of Education. Cause: In the College’s software transition to PowerFaids, the system automatically coded all students to full-time status and students that are less than full time had to be adjusted manually. Some students were missed in this manual process. Questioned Costs: None reported Context/Sampling: The College disbursed Federal financial aid to approximately 736 students in the 2024-2025 school year. A non-statistical sample of 40 students was selected for testing. Repeat Finding: No Auditor’s recommendation: The College should implement additional processes to review, update, and verify that student enrollment statuses are reported to NSLDS accurately and timely. Corrective Action to be Taken: Once the issue was identified, students’ statuses were adjusted manually. An automated process has been created to compare student status with the Student Information System (SIS) before the file is sent to NSLDS. Anticipated Completion Date: The status corrections and the new review process was implemented in Fall of 2024. Name and Title of Responsible Person: Angela Rios, Director of Student Financial Aid

Cash Management Planned Corrective Action: The University agrees with the finding. The University determined that certain federal drawdowns during the audit period were initiated based on authorized amounts rather than confirmed student disbursements, resulting in excess cash on hand beyond allowable timeframes. To address this, the University has reviewed its cash management procedures and strengthened processes to ensure that federal funds are drawn only after student disbursements have been posted to student accounts. The University has reviewed the identified transactions, confirmed that excess funds were fully disbursed or returned as required, and will calculate and remit any applicable interest in accordance with federal regulations. Ongoing monitoring has been implemented to ensure drawdowns are consistently aligned with actual disbursement activity and compliance with cash management requirements is maintained. Person Responsible for Corrective Action Plan: Ken Macur, Interim Chief Financial Officer Anticipated Date of Completion: September 1, 2026

2025-002 Incorrect and Untimely Return of Title IV Funds (R2T4) Calculations Planned Corrective Action: The University agrees mostly with these findings. The University determined that delays in certain Return of Title IV (R2T4) calculations were primarily the result of gaps in the timing and consistency of withdrawal information communicated between offices during the audit period. To address this, the University has strengthened procedures between the Registrar’s Office and the Financial Aid Office to ensure timely identification of official and unofficial withdrawals and prompt initiation of R2T4 calculations. The University has reviewed the affected student accounts and confirmed that Title IV funds were returned appropriately. With respect to the student in the modular program, the Pell Grant adjustment was required because the student had already received Pell Grant funds at another institution during the same award year and was not eligible for the additional amount; this adjustment was not the result of an R2T4 calculation. The University will continue to monitor withdrawal reporting and R2T4 processing to ensure ongoing compliance with federal requirements. Person Responsible for Corrective Action Plan: Adrienne Currington, University Registrar and Shondra Dickson, Director of Financial Aid Anticipated Date of Completion: September 1, 2026

Views of Responsible Officials and Corrective Action Plan The District has reviewed the current R2T4 procedures and taken corrective measures to strengthen internal controls over the Return of Title IV calculations to ensure that funds are returned in a timely manner. 1. Process Review: All Financial Aid staff involved in the R2T4 process have reviewed the Overpayments-R2T4 Policy and Procedure to ensure a full understanding of each step and to continue to comply with federal timelines and documentation requirements. 2. Monitoring and Accountability: The Financial Aid Office will conduct a review of the return of Title IV calculations and ensure that the funds are returned to the ED within 45 days after the institution determines that the student withdrew. 3. Ongoing Evaluation: The Overpayments-R2T4 Policy and Procedure will be reviewed periodically by the Districtwide Financial Aid Directors Workgroup to ensure continued compliance and effectiveness of internal controls.

Views of Responsible Officials and Corrective Action Plan Due to programmatic update requirements mandated by state initiative AB 789, previously reported academic programs required recalculated timeframes. Concurrently, the District undertook a data cleanup initiative to ensure that each student declares only one active program of study, instead of multiple active programs. These adjustments, while essential for compliance and data accuracy, resulted in data discrepancies within the enrollment reporting files. Although the District has been diligently working to resolve these issues, the NSLDS reporting process requires all prior-term errors to be fully resolved before a subsequent term’s file can be submitted. As a result, the time required to correct all identified errors in the prior term caused delays in successful transmission to NSLDS within the required timeframe. The District has completed a comprehensive review to identify the causes of these reporting errors and is implementing an improvement plan with a defined timeline. Specifically, the programming logic used to generate the NSLDS upload file has been rewritten to ensure compliance with updated reporting parameters. Additionally, Admissions and Records offices have established a post-upload review process to conduct spot checks of enrollment data after each NSLDS submission to verify accuracy and prevent future delays. As the District gains more experience with the updated process and completes the backlog of pending submissions, the District is confident that future enrollment reports will be transmitted to NSLDS accurately within the required timeframe.

2025-002: SPECIAL TESTS AND PROVISIONS – GRAMM-LEACH-BLILEY ACT Program: Federal Supplemental Educational Opportunity Grants, Federal Pell Grant Program, Federal Direct Student Loans Cluster Title: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.063, and 84.268 Federal Agency: U.S. Department of Education Type of Finding: Noncompliance (Other Matter), significant deficiency in internal control Compliance Requirement: N. Special Tests and Provisions Questioned Costs: N/A Repeat Finding: No Condition/Context: During our review of the District’s information security policies and procedures, it was noted that the District did not have formally written information security policies and procedures. The District did not have a process to evaluate and maintain a data inventory, ensuring sensitive data is at a higher risk profile and prioritized for security protocols. The District did not limit administrative privileges to dedicated administrator accounts; instead system administrators utilized their administrative accounts for all their job function, rather than just the functions requiring higher levels of access. Criteria: Title IV-eligible institutions are subject to the Gramm-Leach-Bliley Act (the ‘‘Act’’). The Act requires financial institutions to explain their information sharing practices to their customers and to safeguard sensitive data. The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as ‘‘financial institutions’’ and subject to the Act because they appear to be significantly engaged in wiring funds to consumers. Institutions agree to comply with the Act in their Program Participation Agreement with ED. Institutions must protect student financial aid information, with particular attention to information provided to institutions by ED or otherwise obtained in support of the administration of the Federal student financial aid programs. Institutions are required to develop, implement and maintain a written comprehensive information security program. Corrective Action: The District will implement policies and procedures over information technology to properly comply with the provision of the Gramm-Leach-Bliley Act. The District will prepare a security policy that addresses data classifications that ensure sensitive data is protected. In addition, administrator accounts will be restricted. Planned completion date for corrective action plan: For the period ending June 30, 2026. Name of the contact person responsible for corrective action: Edith Perez, Chief Financial Officer

2025-001: REPORTING Program: Federal Supplemental Educational Opportunity Grants, Federal Pell Grant Program, Federal Direct Student Loans Cluster Title: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.063, and 84.268 Federal Agency: U.S. Department of Education Type of Finding: Noncompliance (Other Matter), significant deficiency in internal control Compliance Requirement: L. Reporting Questioned Costs: N/A Repeat Finding: No Condition/Context: Total tuition and fees as reported in the FISAP report was $3,228,909 while the District’s underlying accounting records showed $2,883,823, for a difference of $345,086. Total Federal Pell grant expenditures were reported as $362,929 on the FISAP report while the underlying accounting records and schedule of expenditures of federal awards showed $408,614, for a difference of $45,685. Criteria: The Student Financial Assistance cluster requires that the District submit the Fiscal Operations Report and Application to Participate (FISAP) annually. The amount should agree to the underlying accounting records. Corrective Action: The District will implement procedures to ensure the FISAP revenues and expenditures as posted within the general ledger match with the corresponding application. Planned completion date for corrective action plan: For the period ending June 30, 2026. Name of the contact person responsible for corrective action: Edith Perez, Chief Financial Officer

COMPLIANCE FINDING 2025-002 SFA Cluster: Disbursement to or on Behalf of Students Contact Person: Missy Hughes, Director of Finance Corrective Action Plan: The Business Office is currently seeking an AP/Payroll Manager who will supervise the outstanding check process. The process will be performed and maintained by the Financial Coordinator, Kyle Burnett. 1. Track all Title IV disbursements issued by check, including the issuance date and applicable return deadlines. During monthly bank and check reconciliations, any outstanding check related to Title IV funds will be reviewed by Kyle Burnett, Financial Coordinator. 2. Perform periodic (at least monthly) reviews of outstanding Title IV checks to identify uncashed items approaching the 240-day return requirement. The process of reviewing outstanding Title IV checks will be performed and maintained by the Financial Coordinator, Kyle Burnett. Kyle will review the outstanding checks related to student refunds monthly. 3. Ensure uncashed Title IV checks are returned to the U.S. Department of Education within 240 days of issuance when checks are not cashed or otherwise negotiated. Kyle Burnett, Financial Coordinator, will work with Linda Briggs, Student Account Coordinator and Financial Aid to be sure Title IV checks are returned to the U.S. Department of Education within 240 days of issuance, if still outstanding. 4. Assign clear responsibility for monitoring outstanding checks and returning funds and provide training to staff involved in Title IV disbursement and reconciliation processes. Kyle Burnett, Financial Coordinator, will be trained in Title IV disbursement and reconciliation processes and will work with the Accounts Receivable staff as well as Financial Aid to determine appropriate actions regarding the stale dated check items. 5. Retain documentation evidencing timely monitoring, review, and return of Title IV funds to support compliance and audit review. A SharePoint has been established that is currently maintained by Linda Briggs, Student Account Coordinator and Jeremy Elam, Controller. Kyle Burnett, Financial Coordinator, will be added to this SharePoint. This will be monitored and updated regarding check statuses related to Title IV funds.

MW 2025-001 SFA Cluster: R2T4 Corrective Action Plan Contact Person: Jeff Boyle, Director of Financial Corrective Action Plan: 1. Have at least two staff members enroll and complete the R2T4 training module conducted by NASFAA. Tonja Suttles and Melissa Satterwhite completed the course and passed the credential exam. Suzanne Bonner sat in on a few of the sessions. 2. Make changes to the R2T4 spreadsheet. a. Maintain a separate tab for each calculation group to make tracking and internal reviews easier. Process has been completed and started being used during the 2025 fall semester. b. Add additional columns to the spreadsheet that will provide the necessary data to perform the R2T4 calculation within Colleague and act as a check and balance as the calculation is being performed. There are several columns with calculated data or data coming from a source outside of Colleague. These data values can then be compared to the values Colleague calculates and the two should match. Columns have been added and began being used with the 2025 fall semester. 3. It will be established that one staff member will do the R2T4 calculation and a second staff member will do a spot check of a spot check to ensure the calculation was done properly using the correct data. The number of students checked will depend on the number of students within the calculation groups. The number of students in a group can range from 2 to several hundred. This process was put into practice starting with the 09/17/25 calculation group. Jeff Boyle, Director of Financial Aid, performed all the R2T4 calculations for the 2025 fall term and Tonja Suttles, Assistant Director of Financial Aid, performed 100% review of all the calculations. This will change once we are assured this process is working the way we expect it. 4. The external spreadsheets and charts used for the R2T4 calculation contain a tremendous amount of data elements and are created two years in advance of being used. A process will be established where various staff members within the office will review the data prior to our using it for the R2T4 calculation. This has been implemented as of the 2025 fall semester. All the 2025-2026 terms have been reviewed. A secondary review will be done on each term just prior to the data being used for that term’s R2T4 calculations. The data will be reviewed again at any point we determine the data may not be correct.

Condition: The examination disclosed 11 out of 25 student status change files tested, in which NSLDS was not updated correctly. Eight of the eleven students’ Program Begin Date reported to NSLDS is the same date as the student's most recent effective status date, although the student has been enrolled in the program with the same CIP code with prior statuses such as Full time or Three-Quarter Time. The remaining three students were withdrawn students whose last day of attendance was not reported accurately. The auditor identified noncompliance and a significant deficiency in internal control over compliance related to the administration of Title IV federal financial aid. ________________________________________ Cause: After thorough review, it was discovered that programmatic data manipulation occurred as a result of attempts to circumvent or bypass National Student Clearinghouse enrollment system error messages, by the Information Technology department. This practice developed due to incomplete resolution of underlying system integration issues and insufficient supervisory review of the corrective steps being taken, in the past. Although no evidence of intentional misrepresentation was found, the manipulation of system data reduced the reliability of automated submissions from the Information Technology department. Furthermore, it was discovered that a Jenzabar system defect causing withdrawal dates to be incorrectly reported to the National Student Clearinghouse has occurred. Further review has discovered a default date was entered in the NSLDS system by National Student Clearinghouse, in place of the correct withdrawal date listed in the Jenzabar system. Corrective Action Plan: Action Step Responsible Persons Timeline for Completion Status/Follow-Up Identify and document all programmatic data manipulations performed to address error messages and assess impact on compliance reporting. Kylee Bump, Director of Financial Aid; Brandy Chasteen, Registrar; Raj Siddaraju, CIO November 2025 Complete Work with National Student Clearinghouse to resolve underlying system integration and understand error message issues. Kylee Bump, Director of Financial Aid; Brandy Chasteen, Registrar; Raj Siddaraju, CIO December 2025 Complete Implement formal data correction policy requiring supervisory approval for any system data adjustments. Sarah Gray, CFO & Raj Siddaraju, CIO January 2026 Completed Conduct staff training on proper error resolution procedures and reinforce internal control expectations. Sarah Gray, CFO & Raj Siddaraju, CIO January 2026 Completed Perform quarterly internal reviews of data integrity and system-generated compliance reports. Kylee Bump, Director of Financial Aid; Brandy Chasteen, Registrar; Raj Siddaraju, CIO In Place Ongoing To ensure accuracy moving forward, our Registrar will review a random sampling of our enrollment reporting through the National Student Clearinghouse throughout the semester and after degrees have been confirmed for each semester.

Student Financial Aid Cluster – Assistance Listing No. Various Recommendation: We recommend that the University review their awarding procedures and implement procedures to ensure the Stafford loans are awarded within the annual and aggregate limits. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: At the time the Subsidized Direct Loan was initially awarded, the student was classified as grade level one and was correctly awarded $3,500. Subsequently, the student’s grade level increased; however, the Direct Loan award was not adjusted accordingly. The Office of Financial Aid relies on email notifications to identify students with grade-level changes, and the notification for this student was inadvertently missed. In response to this error, the Office of Financial Aid implemented additional monitoring controls. A report was developed to identify all students with changes in grade level and is now generated and provided weekly by the Office of the Registrar to the Office of Financial Aid. A designated Financial Aid Advisor has been assigned responsibility for reviewing this report and adjusting Direct Loan awards as necessary to ensure accuracy. As an additional preventative measure, the Director of Financial Aid will verify student grade level and corresponding Direct Loan eligibility prior to disbursement. The Office of Financial Aid will also conduct periodic reviews to confirm that Direct Loan awards consistently and accurately align with students’ grade levels.

Student Financial Aid Cluster – Assistance Listing No. Various Recommendation: We recommend that the University implement a formal review process as it relates to withdrawn students to ensure R2T4 calculations are being performed accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The withdrawal dates applied in the Return to Title IV (R2T4) calculations were based on the dates students were administratively withdrawn by the Office of the Registrar. Upon identification of the audit finding, the Office of Financial Aid conducted a comprehensive review of the affected R2T4 calculations and made the necessary corrections. Any balances resulting from these errors were subsequently written off. Additionally, the Director of Financial Aid completed a full file review for the applicable award year to assess the accurate inclusion of scheduled break days. During this review, two additional students were identified whose R2T4 calculations did not include the appropriate number of break days. The calculations for these students were corrected, and the resulting balances were written off. No further errors were identified. As part of the corrective action, the Office of Financial Aid has hired an additional Financial Aid Advisor dedicated to the review and completion of R2T4 calculations. Furthermore, the Director of Financial Aid has implemented a secondary review process for all completed R2T4 calculations to ensure accuracy and compliance. The Office of Financial Aid has also reviewed the Financial Aid Handbook and applicable Code of Federal Regulations (CFR) related to R2T4 calculations to reinforce adherence to regulatory requirements. Name(s) of the contact person(s) responsible for corrective action: Angel Faast and Laura Silva Planned completion date for corrective action plan: 12/17/2025

Student Financial Aid Cluster – Assistance Listing No. Various Recommendation: We recommend the University review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: : In November 2024, the Associate Director of Institutional Research (ADIR) and Associate VP of Institutional Effectiveness (AVPIE) created a tool for scheduling, tracking, and reviewing the status and completion of National Student Clearinghouse submissions. The audit finding occurred before this tool was in place, and since its implementation, late reporting has been reduced, and the corrective action plan has been successful Name(s) of the contact person(s) responsible for corrective action: Jeff Phillips and Eric Tompkins Planned completion date for corrective action plan: November 1, 2024

There is no disagreement with the audit finding. There will be review of the return of funds calculation. Funds have been corrected for the error in calculation. Additional quality checks on the academic calendar have been put into to place to ensure accuracy.

There is no disagreement with the finding. The program length will be corrected for all students. Monitoring of Enrollment reporting is now occurring in partnership of the Registrar’s Office and Financial Aid after each National Clearinghouse Reporting Cycle that the Registrar’s Office performs. In addition after gainful employment reporting we will double check our data outputs to look for unintended consequences and troubleshoot.

Views of Responsible Officials and Planned Corrective Actions -The University’s Office of Student Financial Aid agrees with the recommendation and will enact the following procedure changes: 1. Formal Interdepartmental Oversight • Establish a documented coordination process between the Office of the Registrar (OOR) and the Office of Student Financial Aid (OSFA) to jointly oversee enrollment reporting for Title IV purposes. • Define clear roles and responsibilities for monitoring, review, and escalation of enrollment reporting issues. 2. Transmission Monitoring and Reconciliation • Implement a recurring reconciliation process to verify that enrollment status changes submitted to NSC are successfully transmitted to NSLDS. a. OSFA designee (Associate Director) will review sample populations each reporting cycle to ensure data transfer to NSLDS. • Develop exception process to resolve delayed, rejected, or missing enrollment updates and ensure timely resolution. a. OSFA designee will coordinate with OOR designee (Associate Registrar) to alert of potential issues and work to resolve. 3. Issue Escalation and Resolution Protocol • Establish a formal escalation process with NSC for unresolved transmission issues, including defined timelines for follow-up and resolution. • Maintain documentation of identified issues, corrective actions taken, and final resolution. 4. Ongoing Monitoring • Incorporate enrollment reporting compliance into routine Title IV compliance monitoring activities. • Conduct periodic internal reviews to ensure controls remain effective and reporting continues to meet federal timeliness and accuracy requirements. Implementation of the above listed procedure changes will take place immediately with a completion date no later than June 30, 2026. Responsible Offices and University Officials • Office of the Registrar a. Registrar b. Associate Registrar • Office of Student Financial Aid a. Director of Financial Aid b. Associate Director for Financial Aid Compliance