Corrective Action Plans

As of the Spring 2025 semester all R2T4 calculations performed will then go through a secondary review by either the Assistant Director of Financial Aid or the Director of Financial Aid. This will ensure that R2T4 calculations have the correct Determination dates and that the correct amounts have been returned In COD for both the Institutional and Student portion owed.

The College has implemented additional controls to ensure that the School Calendar Profile in Common Origination & Disbursement (COD) is entered correctly and verified by a second person. Specifically, guidance has been provided to properly calculate the start and end dates for Scheduled Break Days in excess of five days.

2024-003: National Student Loan Data System Condition: The college did not properly report student enrollment changes for students who received federal student aid to NSLDS. Context: During testing of 60 students, 15 students were enrollment changes submitted past 60 days, 6 students had incorrect effective dates on campus enrollment, 5 were not certified at least every 60 days, 6 had program enrollment effective dates that did not match institutional records, 4 had incorrect program enrollment statuses, and 4 had incorrect program begin dates. Cause: The College did not have proper procedures in place to verify students’ status in NSLDS matched the institutions records in a timely manner. View of responsible official: MACC believes some of the current audit finding may be attributed to the SIS system implemented in November 2022; and these finding occurred before we implemented our Corrective Action Plan, which we have faithfully followed every month. As noted below, our CAP is a process in which we review enrollment records reported to NSLDS and update, if needed. Supporting documentation and verification of the work that has been done this past year can be provided, if needed. As a result of the continued commitment to submit correct data from our system to NSLDS every month, this fall MACC paid more than $12,000 to our software vendor (Jenzabar) for enhancements needed to collect, retain and report enrollment data. • Jenzabar created and installed a custom process to update the NSC status start date and NSC program status start date to the Last Date of Attendance. We began running this custom process with the November 2024 NSC enrollment file. • Jenzabar created and installed a custom process to update program begin dates for students returning to the same program to the original program begin date. We have implemented this as a scheduled process beginning December 2024. We are confident future reviews of our NSLDS enrollment reporting records will reflect greater accuracy. MACC would like to note, although the auditors are noting several students with effective date issues and failure to report students timely, we have evidence of student records being exported from our system every month and recorded in the Program Certification Details within NSLDS, but the data is not found in the Program Enrollment Effective Date area of NSLDS. We acknowledge the data must be in both areas of NSLDS, but we believe there is evidence that we submitted our records as required. We are hopeful the new enhancements will correct this issue. As disclosed in our audit response for 2022-2023, the corrective action plan has been slightly altered, but continues: • The Registrar will review data in J1 and submit enrollment records to NSC each month. • The Registrar will also work with the Director of Administrative Computing to ensure program information and other vital data are reported correctly. • After the enrollment file is accepted by NSC, MACC will review correct enrollment information in NSLDS for all students who have withdrawn from all classes and/or have had an R2T4 calculation, for accuracy. o The Registrar, or designee, will review the data in NSC. o The Director of Financial Aid, or designee, will review the data in NSLDS. • Discrepancies will be addressed between the Registrar and Financial Aid Offices immediately; and will utilize the Director of Administrative Computing to assist with configuration changes and data clean-up. • The records will be maintained in a designated Teams folder. Name(s) of the contact person(s) responsible for corrective action: Amy Hager and Amy See (Registrar). Planned completion date for corrective action plan: We expect the plan will be an ongoing effort to ensure compliance.

2024-002: Eligibility Cause: During our testing, we identified that the College’s internal control policies were not effectively designed to ensure funds are disbursed to eligible students. Context: During inquiries with management, the College identified four students that were awarded and disbursed Pell, SEOG, and Direct Loans, who were subsequently determined to be ineligible for the programs. View of the responsible official: MACC does not agree with this finding. MACC has many measures in place to ensure funds are disbursed to eligible students, including verifying identity when enrolling degree seeking students in classes each semester and reviewing high school completion status with a high school transcript, as well as reviewing ISIRs, and other documentation to determine eligibility for federal student aid. While preparing disbursements for fall 2024, the Financial Aid Office identified some odd entries on some ISIRs, which prompted us to review various patterns in admissions documents. MACC believes the students in question may be cases of stolen identities. However, this is only suspicion at this time because when the students in question enrolled in the summer 2024 semester they provided identification, submitted high school transcripts from valid high schools, completed FAFSAs which resulted with valid ISIRs (in one case the student submitted Verification (V4) documentation), submitted loan data sheets and completed entrance counseling via Zoom. The students in question were referred to the Office of Inspector General at the U. S. Department of Education on 10/15/2024; no follow-up has been received from OIG as of 01/15/2025. MACC has also discussed this case with Kathy Feith, Region 7 Branch Chief, of the U. S. Department of Education, Federal Student Aid. During an interview with an auditor from CLA, MACC disclosed the situation described above to the auditor when questioned about any potential fraud cases. MACC firmly believes all internal control policies were followed to ensure funds were disbursed to eligible students. At the time of disbursement, there was no indication these students were not eligible. As noted above, the OIG has not determined that these are in fact ineligible students; therefore, MACC does not believe it should return funds based on suspicion of ineligibility. As a result of these findings, MACC has added new steps to provide an additional layer of protection, including verifying images of state drivers licenses or other forms of identity, and development of guidelines for staff to follow if they have any suspicion of fraud. Name(s) of the contact person(s) responsible for corrective action: Amy Hager Planned completion date for corrective action plan: We expect the plan will be an ongoing effort to ensure compliance.

2024-001: Return of Federal Funds Context: During our testing of 40 student’s R2T4 calculations, we noted 3 with refunds that were not returned within the 45-day requirement. Cause: The college has not implemented precise controls to ensure timely return of funds related to withdrawals. View of the responsible official: MACC is an attendance taking institution and our regular practice requires review of attendance records two to three times per week. When the Financial Aid Office discovers students have withdrawn from classes, we review and calculate an R2T4 when required – usually within 1-5 days from the date it is discovered. This finding of a “late return” is due to a faculty member dropping a student outside of the dates required by our attendance policy. I would like to note that the R2T4 was performed timely and accurately as soon as the drop was identified. Action taken in response to finding: The issue was reported to the President, Vice Presidents, and Deans; as a result, the faculty were addressed and reminded of the importance to comply with the college’s attendance policy. Name(s) of the contact person(s) responsible for corrective action: Amy Hager Planned completion date for corrective action plan: Our Registrar, Deans, and Vice President for Instruction will provide reminders of our policy with our faculty each semester. In the event that a faculty member does not comply with the attendance policy, their Dean will take disciplinary action.

The San Bernardino Community College District acknowledges and understands the recommendations associated with the Special Tests and Provisions – Enrollment Reporting audit finding. The District has examined the elements detailed by the finding and is committed to implementing appropriate controls to prevent future non-compliance. The District will enhance current internal controls, develop and implement new supporting procedures and institute best practices as part of this corrective action. Actions to be taken include: the improved collaboration between District Support Services, the Financial Aid Office, and the Admission and Records Office to ensure accurate enrollment data reporting. District staff shall report to the Financial Aid Office immediately after each submission is completed to the National Clearinghouse. The Financial Aid Office shall utilize NSLDS reports to ensure all records are submitted and modified in a timely manner. Immediate action has taken place to address this deficiency, and collaborative efforts will continue to ensure compliance in this reporting area by the start of the Spring 2025 semester.

View of Responsible Officials and Corrective Action Plan The District agrees with the finding and will implement procedures that will ensure student enrollment information is updated and accurate on the NSLDS Access website.

Finding – Special Tests and Provisions: Enrollment Reporting – Federal Direct Student Loan Program, Assistance Listing Number 84.268; June 30, 2024 Award Year; U.S. Department of Education Criteria or Specific Requirement Enrollment information, including the effective date of separation from the institution, must be accurately reported within 30 days whenever attendance changes for a student, unless a roster will be submitted within 60 days. The changes include reductions or increases in attendance levels, withdrawals, graduations, and approved leaves-of absence. It is the institution’s responsibility, as a participant in the Title IV aid programs, to monitor and report these changes to the National Student Loan Data System (“NSLDS”). (NSLDS Enrollment Reporting Guide November 2022, and 34 CFR 685.309(b)) Condition Of the fifteen students selected for enrollment reporting testing, two students within the sample were reported to NSLDS outside the maximum 60-day window. This was not a statistically valid sample. Views of Responsible Officials and Planned Corrective Actions The University concurs with the finding. The University will continue to remain vigilant in its oversight over timely communication of enrollment reporting detail to NSLDS. In both instances, the data we had sent to the National Student Clearinghouse (NSC) was not received by NSLDS in a timely fashion. We will review our reporting schedule and make the appropriate changes to our reporting timeline to ensure the data we report to the NSC is subsequently received by NSLDS within regulations. Names of Contact Person Responsible for Correction Action: Frank Mullen, Associate Vice President of Financial Aid Anticipated Completion Date: November 14, 2024

Finding 2024-001 Failure to Meet the Standards for Safeguarding Customer Information Comments on Finding and Recommendation: The management of ICSW concurs with this finding. Actions Taken or Planned: ICSW plans to work closely with its various external, contractual partners for Information Technology and Financial Aid Services around items in the Gramm Leach Bliley Act to build out its policies and further strengthen the safeguarding of customer information. The plan is to have the completed during the fiscal year 2025. Michael Bauman Title: Vice President, Finance & Operations Telephone: (773)943-6503 Email: mbauman@icsw.edu

Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Compliance Requirement: Special tests and Provisions - Enrollment Corrective Action Plan: The Admissions and Records Office is currently responsible for reporting student enrollment to National Student Clearinghouse (NSC). Once enrollment is validated and certified, it is reported directly to the National Student Loan Data System (NSLDS). Grayson College does not report enrollment directly in NSLDS. The OFA requests a copy of the validated and certified NSC enrollment report from the Admissions and Records Office to double check accuracy by performing a random selection of students to confirm they have been reported correctly in NSLDS. If, for some reason, a student’s enrollment is not correct in NSLDS, the OFA contacts NSC to get an understanding as to why it is not reported correctly to NSLDS. This happens after each validated and certified cycle, including all module terms (8-week and mini-mester). The College is investigating how to conduct a batch validation, which will be more robust than the sampling method. GC Financial Aid staff have received additional training and understand the importance of V4 and V5 verification coupled with accurate reporting to the NSLDS. They are committed to making sure these actions as stated occur each semester. Name of Contact Persons: Carolyn Kasdorf - Vice President of Business Services. Stephanie Martin - Director of Financial Aid and Veteran Services Projected Completion Date: 2025

2024-002 Student Financial Assistance Cluster - Assistance Listing No. 84.007; 84.033; 84.063; 84.268 Recommendation: We recommend that the College review policies and procedures related to R2T4 calculations to ensure calculations are performed accurately and federal funds are returned timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The records identified with incorrect R2T4 calculations have been recalculated, reported to COD and funds returned. In order to best ensure policies and procedures for R2T4 calculations, additional staff have been trained to ensure calculations are checked and double checked to ensure compliance. Name(s) of the contact person(s) responsible for corrective action: Katelyn Dawson, Director of Financial Aid, Veteran Services & Student Employment Planned completion date for corrective action plan: All corrections have been submitted as of October 9, 2024. Training of additional staff in progress – to be completed by February 28, 2025.

CORRECTIVE ACTION PLAN: Staff transitions in Financial Aid and the Enrollment Center at the onset of the Fall 2023 term contributed to the later-than-usual submission/certification of First of Term enrollment reporting. Financial Aid and the Enrollment Center experienced staff shortages with resignations and leave. The initial fall enrollment (First of Term) was certified by the Institution and submitted to the National Student Clearinghouse (NSC) on October 18, 2024 within 60 days of the start of the term on August 21, 2023, but the National Student Loan Data Systems (NSLDS) did not receive the submission within the 60-day requirement. Although we anticipate this to be a one-time incident, to prevent any recurrence and ensure enrollment changes are reported to NSLDS within 60 days, Financial Aid provided additional staff training in the Enrollment Submission process, and Early Registration enrollment submissions will be submitted within the first week of classes with the First of Term enrollment submission sent during the third week of classes. Financial Aid also updated the Institution’s NSLDS profile to ensure that records submitted for NSLDS Transfer Monitoring and Financial Aid History are added to the Enrollment Roster submitted to NSC. Financial Aid and the Registrar established an updated policy to ensure that Financial Aid is informed of students who graduate after the graduation process runs each term. After that, the Registrar will report late graduations to the National Student Loan Data System (NSLDS) via the National Student Clearinghouse (NSC). Financial Aid updated the student in question’s graduation status in NSLDS. Person(s) Responsible: Angela Weaver Timing for Implementation: Immediate

CORRECTIVE ACTION PLAN: At Lewis & Clark, the Direct Loan acceptance process switched from affirmative confirmation to passive confirmation to streamline the student loan process for students. For loans accepted via affirmative confirmation, the loan notification must be sent no earlier than 30 days before and no later than 30 days after crediting the student’s account. The student or parent has 14 days from the notification date to request the loan cancellation. For loans accepted via passive confirmation, the loan disbursement notification must be sent no earlier than 30 days before or 7 days after crediting the student’s account. The student or parent then has 30 days from the date of the notification to request cancellation of the loan. Although the new timeline for a student to cancel a loan was reviewed prior to the process change to passive confirmation, Financial Aid neglected to update the notification letter at the time of implementation. The loan notifications now reflect the 30 days for loan cancellation. Cancellation requests of loan funds are processed promptly. Although the timeline to request a cancellation of all or a portion of a loan previously indicated a 14-day deadline, the Financial Aid office accepts most requests beyond the 14 to 30 days. However unlikely, if more than 120 days have elapsed since loan funds were disbursed, loan funds cannot be returned on the borrower’s behalf. In Spring 2024, Financial Aid established a process to send loan notifications in conjunction with weekly financial aid transmittals to ensure compliance with sending loan notifications within 7 days of crediting a student’s account. A Direct Loan transmittal report (TFAR-Transmitted FA Report) is generated through Colleague (ERP Software) weekly throughout each term, and loan notifications are emailed weekly to students whose student loans are credited to their accounts during that weekly process. To prevent Post-withdrawal disbursements of loan funds from updating and transmitting to student accounts before receipt of acceptance of post-withdrawal disbursements (PWD), upon completion of the Return of Federal Funds calculation, Financial Aid will delay updating student accounts until confirmation of acceptance within the established 14-day timeframe; this is a change from the previous practice of updating the student record and then denying the PWD until acceptance of loan funds. Person(s) Responsible: Angela Weaver Timing for Implementation: Immediate

2024-008- Student Financial Aid Cluster- (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans, Assistance Listing No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 - Year Ended June 30, 2024 Condition Found In our testing of student files, six out of 40 students (15%) had enrollment statuses not timely or accurately reported to NSLDS. We consider this finding to be a significant deficiency in relation to the Special Tests and Provisions compliance requirement and is a repeat finding shown in Section IV of this report as prior year finding 2023-002. Corrective Action Plan The Registrar’s Office is updating its process for student location reporting. Further, until accurate graduate reporting can be confirmed, the Registrar’s Office will manually review graduates after conferrals are complete in January, June, and August. Responsible Person for Corrective Action Plan Kandi Molder, Registrar and Executive Director of Student Services Stephanie Connelley, Assistant Director of Records & Registration Implementation Date of Corrective Action Plan Location updates cannot be completed until the Spring term, according to NSC. Graduation reporting will be audited in January, June, and August.

2024-007 - Student Financial Aid Cluster- (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans, Assistance Listing No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 - Year Ended June 30, 2024 Condition Found The College did not accurately complete refund calculations for 1 out of 9 students (11.1%) tested. Additionally, funds were not timely returned and withdrawal dates were not timely determined for three out of nine students (33%) tested. We consider this finding to be a significant deficiency in relation to the Special Tests and Provisions compliance requirement and is a repeat finding shown in Section IV of this report as prior year finding 2023-003. Corrective Action Plan Montreat College is reviewing the faculty record-keeping process and the Registrar's Office’s Last Date of Attendance (LDA) data confirmation. LDAs must be reported accurately and reported in a timely manner. Student Financial Services is developing a two-person process where two staff members review all Return to Title IV funds (R2T4). Responsible Person for Corrective Action Plan Kandi Molder, Registrar and Executive Director of Student Services Deb Beck, Managing Director of Student Financial Services Stephanie Connelly, Assistant Director of Records & Registration Marie Wisner, Associate Dean for Calling & Career Montreat Cabinet Implementation Date of Corrective Action Plan June 30, 2025

2024-006 - Student Financial Aid Cluster- (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Grant (c) Federal Perkins Loan Program (d) Federal Pell Grant Program (e) Federal Direct Loan Program, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.038 (d) 84.063 (e) 84.268 - Year Ended June 30, 2024 Condition Found The College did not report actual loan disbursement dates to the Common Origination and Disbursement (COD) system for 2 of the 40 students in the sample (5%). We consider this condition to be an instance of noncompliance in internal control over compliance relating to the Eligibility compliance requirement and is a repeat finding shown in Section IV of this report as prior year finding 2023-005. Corrective Action Plan Student Financial Services will work with PowerFaids to determine how records are returned to COD for a disbursement date update and ensure reporting is compliant. Responsible Person for Corrective Action Plan Kandi Molder, Registrar and Executive Director of Student Services Deb Beck, Managing Director of Student Financial Services Implementation Date of Corrective Action Plan January 31. 2025

2024-005 - Student Financial Aid Cluster- (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Grant (c) Federal Perkins Loan Program (d) Federal Pell Grant Program (e) Federal Direct Loan Program, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.038 (d) 84.063 (e) 84.268 - Year Ended June 30, 2024 Condition Found During our student file testing, we noted five students out of 40 (12.5%) did not have documentation in their file that exit counseling was sent thirty days after the student withdrew. We consider the missing exit counseling to be a significant deficiency with the Eligibility Compliance Requirement. Corrective Action Plan Student Financial Services will develop a report and process that looks at students with a withdrawal or conferral date in Jenzabar or who have dropped below half time, who have taken Direct Loans and ensure that exit counseling materials are sent. Responsible Person for Corrective Action Plan Kandi Molder, Registrar and Executive Director of Student Services Deb Beck, Managing Director of Student Financial Services Implementation Date of Corrective Action Plan March 31, 2025

2024-004 - Student Financial Aid Cluster – (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Grant (c) Federal Perkins Loan Program (d) Federal Pell Grant Program (e) Federal Direct Student Loans (f) Teacher Education Assistance for College and Higher Education ALN No. (a) 84.007 (b) 84.033 (c) 84.038 (d)84.063 (e) 84.268 - Year Ended June 20, 2024 Condition Found 5 of the 40 student files (12.5%) we examined, we noted the students were not properly awarded Direct loans. Corrective Action Plan Student Financial Services has created a report comparing need-based aid awarded to the student’s need eligibility and an overall aid awarded compared to the Cost of Attendance (COA) budget. We will also work to develop a report that compares FAFSA year in school compared to total credit hours earned. Responsible Person for Corrective Action Plan Kandi Molder, Registrar and Executive Director of Student Services Deb Beck, Managing Director of Student Financial Services Implementation Date of Corrective Action Plan January 31, 2025

2024-003 - Student Financial Aid Cluster – (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher Education Assistance for College and Higher Education ALN No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (t) 84.379 - Year Ended June 20, 2024 Condition Found One of the 40 student files (2.5%) we examined, we noted the students were not properly awarded Pell grants. Corrective Action Plan The Student Financial Services Office will implement a weekly task of reviewing students in a Disbursement Review (DR) status and students with zero credits in a term with an active Period of Enrollment (POE). Responsible Person for Corrective Action Plan Deb Beck, Managing Director of Student Financial Services Implementation Date of Corrective Action Plan December 1, 2024

Corrective Action Plan December 19, 2024 Federal Audit Clearinghouse Northern Tier Career Center respectfully submits the following corrective action plan for the year ended June 30, 2024. Name and address of independent public accounting firm: EFPR Group, CPAs, PLLC Certified Public Accountants 8 Denison Parkway East Corning, NY 14830 Audit period: July 1, 2023 – June 30, 2024 The findings from the June 30, 2024 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAM AUDIT FINDING 2024-001 – Student Financial Aid Cluster – Federal Direct Student Loans and Federal Pell Grant Program - Assistance Listing No. 84.286 and 84.063; Grant Period - For the year ended June 30, 2024 Condition: The School does not have a written information security program containing the required minimum elements including the designation of a qualified individual who is responsible for implementing and monitoring the School’s program. Criteria: The School is required to have a written information security program that includes the required minimum elements including designating a qualified individual who is responsible for implementing and monitoring the School’s program. Cause: The School did not have a written information security program containing the required elements. Effect of Condition: The School was not in compliance with the requirement to have a written information security program that includes the required minimum elements including designating a qualified individual who is responsible for implementing and monitoring the School's program Questioned Costs: None. Recommendation: The School should designate a qualified individual responsible for implementing an monitoring the School's information security program. This individual should put procedures in place to create a written information security program that addresses the required minimum elements required by the Student Financial Aid cluster included in the Gramm-Leach-Bliley Act - Student Information Security. Views of Responsible Officials and Planned Corrective Actions: NTCC is in the process of a First Reading Policy on or before February 20, 2025, and a Second Reading Policy for full approval on or before March 20, 2025. This policy will name the Practical Nursing Coordinator, as the individual responsible for implementing and monitoring the School’s security program. The seven required minimum elements for a financial institution of fewer than 5,000 customers will be in place with this policy. Contact Person Responsible for Corrective Action: Colleen Edsell, Business Administrator. Anticipated Completion Date: The corrective action plan will be completed by March 20, 2025. If the Federal Audit Clearinghouse has questions regarding this plan, please call Colleen Edsell at 570-265-8111. Sincerely yours, Gary Martell, Director

FISAP Reporting Planned Corrective Action: In partnership with our third party servicer, we have contracted there independent review of the 25-26 FISAP report prior to submission to ensure all figures are accurate. We will coordinate with the Department of Education to correct errors related to Pell reporting on the 24-25 FISAP. Person Responsible for Corrective Action Plan: Deborah Rezene, Associate Vice President of Student Financial Services Anticipated Date of Completion: 1/3/2025

Verification Planned Corrective Action: We have contracted a third party servicer to complete and review verification for the current academic year to ensure accuracy and completion. We will establish an a process for periodic audits will be conducted to verify the accuracy of all completed verifications for students flagged. Person Responsible for Corrective Action Plan: Deborah Rezene, Associate Vice President of Student Financial Services Anticipated Date of Completion: 1/3/2025

Untimely and Inaccurate Returns of Title IV Funds (R2T4) and National Student Loan Data System Updates (NSLDS) Planned Corrective Action: We will provide additional training to financial aid staff on Return to Title IV (R2T4) processing from a third party servicer with expertise in processing with our current financial aid management system. We will also collaborate with the Registrar’s Office to implement a system that ensures timely notification of student withdrawals, enabling the financial aid office to process R2T4 returns within the required timeframe. We will establish more robust internal controls to verify that withdrawals are correctly updated in NSLDS, and review staffing needs to ensure adequate resources for processing Title IV aid returns efficiently. Person Responsible for Corrective Action Plan: Deborah Rezene, Associate Vice President of Student Financial Services Anticipated Date of Completion: 1/3/2025

Finding 2024-003 Federal Agency Name: U.S. Department of Education Pass-Through Entity: n/a Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Program Name: Student Financial Assistance (SFA) Cluster Finding Summary: In auditor testing of 60 samples, 1 student was not reported to the COD system within 15 days of disbursement. Corrective Action Plan: The Director of Financial Aid will: • Review and update the disbursement reporting process to ensure timely and accurate reporting to COD and agreement with college records. • Train staff on the new process. • Conduct a second check on COD reports within 14 days for student files with FAFSA-related holds or delays to ensure accuracy. Responsible Individual(s): Christopher Natelborg, Director of Financial Aid Anticipated Completion Date: February 2025.

Finding 2024-002 Federal Agency Name: U.S. Department of Education Pass-Through Entity: n/a Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Program Name: Student Financial Assistance (SFA) Cluster Finding Summary: In auditor testing of 60 samples, 9 students did not receive a timely notification of their award from the College Corrective Action Plan: The Director of Financial Aid will implement procedures to ensure timely notification of financial aid awards: • In August 2024, the Director collaborated with IT to fix a notification system glitch. • IT added a control that sends an email alert to IT, the Director, and tech support if there is a mismatch between student IDs for loan disbursement and notifications sent. This ensures immediate review and resolution of any missed notifications. Responsible Individual(s): Christopher Natelborg, Director of Financial Aid Anticipated Completion Date: February 2025.