Corrective Action Plans

Federal Program: U.S. Department of Education Student Financial Assistance Cluster: Federal Direct Student Loans, Federal Assistance Listing 84.268 Criteria: The University is required to comply with 36 CFR 685.309(b). Condition: During our testing of 40 students for NSLDS enrollment, we noted eight students' enrollment effective date was the commencement date instead of the last day of the term. One student's graduation status was not reported to the NSLDS and one student's graduation was not certified to the NSLDS within the 60-day requirement. Cause: The University did not have controls in place to ensure students' classification were being properly reported to the NSLDS or reported in a timely manner. Effect: There were ten student status changes that were either not reported, not reported accurately, or not reported within the required timeframe under federal regulations. The provisions of 34 CFR Section 685.309(b) were not followed and thus, students were subsequently not placed into loan repayment status in a timely manner. Questioned Costs: There were no questioned costs associated with this finding. Recommendation: We recommend that the University implement a control to ensure data is being reviewed for accuracy by the appropriate personnel before roster files are submitted to the NSLDS. In addition, we recommend that the University submit roster files on a regular basis. Corrective Actions Taken or Planned: We agree with this finding and recommendation. The Director of Institutional Research will report the last day of the term for NSLDS reporting. Responsible Parties: Margaret Sidle, Director of Institutional research Completion Date: March 4, 2026

Federal Program: U.S. Department of Education Student Financial Assistance Cluster: Federal Direct Student Loans, Federal Assistance Listing 84.268 Criteria: The University must comply with 34 CFR 668.22(a). Condition: During our testing of six official withdrawals, we noted one instance where the University incorrectly treated a student as withdrawn for Return of Title IV (R2T4) purposes. The student was enrolled in both modules for the Fall term, earned six credit hours in the first module and subsequently withdrew during the second module. The University reported the student as withdrawn to the National Student Loan Data System (NSLDS) and performed a R2T4 calculation using the total days of both modules in the denominator of the R2T4 calculation. However, since the student successfully completed six credit hours in the first module, which exceeds the coursework required for the University's definition of half time enrollment, the student should not have been classified as withdrawn nor had a R2T4 calculation performed. Upon further analysis from management, there were an additional five students that were enrolled in modules, earning half-time enrollment, who were reported as withdrawn to the NSLDS and a R2T4 calculation was erroneously completed for them. Cause: This error occurred due to inadequate internal controls over identifying withdrawal status for students enrolled in module courses, specifically related to assessing whether completed coursework met or exceeded the half-time enrollment threshold prior to performing an R2T4 calculation or reporting them as withdrawn to the NSLDS. Effect: The provisions of 34 CFR 668.22(a) were not followed and thus a total of six students had a R2T4 calculation erroneously performed. Six students were also erroneously reported as withdrawn to the NSLDS. Questioned Costs: There were no questioned costs associated with this finding Recommendation: We recommend that the University strengthen its internal controls related to R2T4 calculations by: (a) implementing a system control to evaluate whether or not completed module coursework meets the half-time threshold before classifying a student as withdrawn, (b) providing additional training to financial aid staff on withdrawal determinations and performing an R2T4 calculation for students enrolled in modules, and (c) performing a supervisory review of all R2T4 calculations related to module students. Corrective Actions Taken or Planned: We agree with this finding and recommendation. After further review of R2T4 rules for module programs, the University of Pikeville will no longer perform R2T4’s on any student that has met the Exemption rules per FSA handbook, Vol 5, Chapter 1, “R2T4 Withdrawal Exemptions”. Responsible Parties: Daniel Donner, Director of Financial Aid Completion Date: March 4, 2026

2025-003 Documentation of Review Recommendation: We recommend the University re-evaluate its procedures and review policies surrounding controls implemented for Title IV Aid. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: 1) The Office of Financial Aid will re-evaluate its current policies and procedures to clearly define internal control objectives and strengthen overall compliance. 2) The Office of Financial Aid has implemented – and will continue to maintain - a dual-review process (second-level review) for Return of Title IV Funds, federal award packaging, and the review of the FISAP report to ensure accuracy and regulatory compliance. 3) The Director and Assistant Director of Financial Aid will continue cross-training staff to promote operational continuity, reinforce internal controls, and maintain clear oversight of key processes. Name(s) of the contact person(s) responsible for corrective action: Vanesa Teran-Martinez, Jennifer Monroy Planned completion date for corrective action plan: June 30, 2026 If the Department of Education has questions regarding this schedule, please call Vanesa Teran-Martinez at 708-209-3338.

2025-002 National Student Loan Data System (NSLDS) Enrollment Reporting Recommendation: We recommend the University review and strengthen its reporting procedures to ensure that student statuses are accurately reported to NSLDS, as required by federal regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: 1) All enrollment reporting was submitted to the National Student Clearinghouse in a timely manner. The delay occurred during the National Student Clearinghouse’s processing and submission to NSLDS. 2) The Office of the Registrar will work with the Office of Financial Aid to learn more about NSLDS compliance requirements and gain a better understanding of their relationship with the National Student Clearinghouse. 3) The Office of the Registrar will work with the National Student Clearinghouse to confirm the submitted reporting schedule for academic year 2026 – 2027 complies with and meets their expectations and will adjust (if needed). 4) The Office of the Registrar will continue to work with the Enrollment Offices to remind them that students who are not enrolled (and not on leave of absence, graduated, and/or deceased) must be marked as withdrawn based on external reporting compliance requirements. 5) The Office of the Registrar continues to work with IT (Banner Team) to improve reporting to capture students who are not enrolled (and not on leave of absence, graduated, and/or deceased) to be marked as withdrawn to comply with the National Student Clearinghouse and NSLDS compliance reporting requirements. Name(s) of the contact person(s) responsible for corrective action: Ingrid Sorensen, Katarzyna Rodriguez Planned completion date for corrective action plan: June 30, 2026

2025-001 Pell Grant Under Award Recommendation: We recommend the University implement a review process that compares enrolled credits to Pell awards to ensure all students receive the correct Pell Grant amounts. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: 1) The Office of Financial Aid will continue to run monthly or bi-monthly enrollment reports for Pell Grant recipients to ensure awards are accurately determined based on enrollment status. 2) Financial Aid Counselors will continue to review the daily and weekly Hour Change Reports for each payment period to ensure Pell Grant awards are adjusted appropriately in response to enrollment status changes. 3) The Director and Assistant Director of Financial Aid will continue providing Banner (student information system) training to staff to ensure Pell Grant amounts are updated accurately within the system. Name(s) of the contact person(s) responsible for corrective action: Vanesa Teran-Martinez, Jennifer Monroy Planned completion date for corrective action plan: June 30, 2026

Finding: 2025-002 – Controls and Noncompliance Over Special Tests and Provisions: Return of Funds Management’s Response South Suburban College acknowledges this finding and has implemented corrective actions to strengthen compliance with established policies and procedures. These actions will ensure that Return of Title IV (R2T4) calculations are performed accurately, using correct term dates, and completed within required timeframes. Action Plan 1. Training The Director of Financial Aid will provide formal training to the Financial Aid Manager on federal Return of Title IV Funds (R2T4) calculation procedures, including the use of accurate term dates. Training of additional personnel will support the internal review process. 2. Control Process South Suburban College has established and will reinforce internal control processes to ensure compliance with federal Return of Title IV (R2T4) requirements. All Return of Title IV Funds R2T4 calculations prepared by the Financial Aid Director or Manager will have second review prior to final submission. This review process will ensure accuracy, timeliness, and compliance with Title IV regulations. Anticipated Date of Completion Note the audit found the error to be remedied as of Spring 2025 and the college continue its efforts. The additional actions noted above demonstrate South Suburban College’s commitment to ensuring Return of Title IV (R2T4) calculations are performed accurately and completed within required timeframes. Name of Contact Person: Yolanda Freemon Director of Financial Aid yfreemon@ssc.edu ext.5845

Finding 2025-001: Controls and Noncompliance Over Reporting - Pell Common Origination and Disbursement; Fiscal Operations Report and Application to Participate Management's Response: The College acknowledges this finding and has implemented the corrective actions outlined below to reinforce established policies and procedures. This will ensure the institution submits disbursement information to the Department of Education’s Common Origination and Disbursement (COD) site within the required 15-day timeframe. Corrective Action Plan: 1. Control Process South Suburban College has established an internal control process to ensure that all records are submitted in a timely manner. The Financial Aid Director and Manager now have access to be promptly notified of updates the Colleague software system. Notifications were previously accessible only to the IT Department. 2. System Upgrade South Suburban College is in the process of transitioning to new software by March 2026. Once the new software is in place, the South Suburban College ‘s IT department may no longer need to update the Colleague system to support the submission of Pell Grant disbursements. The transition to the new system is expected to streamline the process and improve reporting accuracy with automated reminders, updated calendars and other notification mechanisms in the College’s Colleague system to compliment manual. 3. Ongoing Monitoring and Training Regular system audits will continue to be conducted to ensure that personnel are well-informed and that policies are consistently followed. The retaining of documentation to support amounts within the FISAP has been implemented. The Financial Aid Department will also continue to monitor the COD site for compliance and address any discrepancies promptly. Anticipated Date of Completion Note the audit found the error to be remedied as of Spring 2025. However, with these corrective actions, South Suburban College is committed to ensuring that Pell Grant disbursements are reported accurately and submitted in compliance with federal regulations within the specified 15-day window. Name of Contact Person: Yolanda Freemon Director of Financial Aid yfreemon@ssc.edu ext.5845

Corrective Action Taken or Planned: A. Correction of "Day After" Reporting Logic The University previously identified a practice where the withdrawal (W) status was made effective the day following the student's notification. ● Process Update: This process was officially updated in April 2025 to align with the regulation, ensuring the withdrawal start date and the date of official notification are the same. The three findings all occurred prior to the April adjustment. ● Ongoing Diligence: The Registrar’s team is actively monitoring current and future records to ensure this logic is applied consistently going forward. B. Reporting Withdrawal Dates for Late-Term Requests To address students reported as withdrawn on the last day of the term rather than their actual date of request: ● Manual Tracking: For students who request a withdrawal between the official University withdrawal deadline and the end of the term, the Financial Aid Office will create a new process where they track students needing NSC manual corrections and share that information with the RO Team member doing the NSC reporting. ● NSC Overrides: The NSC reporting processor will utilize this information to perform manual date changes for these students, ensuring the reported date reflects the official date of notification rather than the term end date. C. Correlation of Withdrawal Date and Last Date of Attendance (LDA) To address findings where withdrawal dates did not correlate with the LDA: ● Faculty LDA Requirement: Although the University is a non-attendance-taking institution, a new requirement has been implemented for faculty to enter the Last Date of Attendance (LDA) for any student receiving a non-passing grade. ● Reporting Sync: The latest of the reported LDAs will be used by both the Financial Aid office (for calculations) and the NSC processor (for reporting) if a student is withdrawing from the University for the subsequent term and the student received all non-passing grades in the prior term. The Financial Aid office will notify the Registrar’s office if there are students with no passing grades and a LDA prior to the official withdrawal date to update their withdrawal date to match that LDA. ● Verification Workflow: The Registrar’s office will verify withdrawal information with the student, including the notification date, to ensure accuracy before manual NSC corrections are made. D. Internal Audit and Collaborative Controls To prevent recurrence and ensure compliance with federal reporting timelines: ● Collaborative Review: The Registrar and the Executive Director of Financial Aid & Scholarships will meet on a recurring basis to jointly review enrollment reporting procedures and ensure data alignment. ● Spot Checks: An internal audit process has been implemented to spot-check each submission file to verify that enrollment and withdrawal dates are accurate. The shared spreadsheet of manual dates will also be checked to ensure those dates are being changed. ● Petition and Request Review: The Registrar Team will carefully review all petitions and requests to determine which date to use as the original notification. ________________________________________ Person(s) Responsible for Corrective Action: University Registrar and Executive Director of Financial Aid & Scholarships. ________________________________________ Anticipated Completion: June 30, 2026 ________________________________________

Recommendation: Western Connecticut State University should strengthen internal controls to ensure that it submits enrollment status changes to the National Student Loan Data System in accordance with federal regulations. Corrective Action Plan as Reported by Western Connecticut State University: We agree with this finding. The discrepancy was originally identified during the first Gainful Employment / Financial Value Transparency (GE/FVT) submission in 2024, when Clearinghouse program lengths did not match NSLDS data. To ensure accurate reporting, the School Deans reported correct program lengths to the Registrar’s Office who implemented program-specific duration rules in the Program Duration Rules Form (SFACPLR). The corrected program lengths apply to all students with catalog terms beginning Fall 2025 and forward. Per system guidance, existing students will retain the prior six-year duration to prevent retroactive enrollment reporting errors in the Clearinghouse. This corrective action permanently resolves the program length discrepancy for future reporting and ensures compliance with GE/FVT and NSLDS requirements. Anticipated Completion Date: August 14, 2025 Western Connecticut State University Contact Person: Debra Zavatkay, Ed. D., Registrar (203) 837-8229

The University acknowledges the findings related to NSLDS enrollment reporting, including discrepancies involving OPEID reporting, program-level status effective dates, and other enrollment reporting data elements. The University agrees with the recommendation to enhance the precision of the control surrounding the review of enrollment status records, program-level data records, and campus-level data records included in NSLDS reporting submissions. Several corrective actions have already been implemented to address the identified exceptions. Updates have been made within the National Student Clearinghouse (NSC) reporting processes to ensure students are assigned to the appropriate branch codes and that campus-level records reflect the correct OPEID for each reporting entity. In addition, affected student records have been reviewed and updated to ensure program-level status records and effective dates are accurate within the NSC system. Going forward, the Registrar’s Office will monitor enrollment status changes and campus assignments within the NSC reporting process to ensure that status changes, program updates, and campus-level reporting elements are reflected accurately and transmitted in accordance with NSLDS reporting requirements. To further strengthen oversight and prevent recurrence, the Office of Student Financial Aid will implement documented post-submission reconciliation procedures following NSC reporting cycles. These reviews will focus on high-risk enrollment reporting elements, including campus changes, program status changes, and other updates affecting NSLDS reporting, and will validate the accuracy of OPEID assignments and program-level effective dates against institutional records. These enhancements are intended to improve the precision of the University’s existing controls and ensure the accuracy and completeness of future NSLDS enrollment reporting submissions.

2025-006 Federal Pell Grant Program, Federal Direct Student Loans – Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the University evaluate its policies and procedures around reporting student status changes to the NSLDS to ensure that all relevant information is being captured and reported in accordance with applicable regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Rider University concurs with the finding. The Registrar's Office will partner with Financial Aid to regularly correct students who have a mismatched SSN or other NSLDS / NSC information. In cases where students are unable or unwilling to provide Rider with correct SSNs, we will not be able to report their enrollment. This particular student is no longer enrolled at Rider, so no action will be taken in his particular case. Name(s) of the contact person(s) responsible for corrective action: Daniel Pavlick and Jacqueline Watford Planned completion date for corrective action plan: Effective Immediately

2025-005 Federal Pell Grant Program, Federal Direct Student Loans, Federal Supplemental Educational Opportunity Grants – Assistance Listing No. 84.063, 84.268, 84.007 Recommendation: We recommend the University review and strengthen its policies and procedures for completing R2T4 calculations to ensure accurate inputs. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Rider University concurs with this finding. After review the University noted this was an isolated instance of human error. The effective date for the withdrawal was imputed incorrectly as 2/27/2025, however, the correct effective date was 2/17/2025. Rider University will ensure the Financial Aid Administrator completing this task is attentive to eliminate any errors. Name(s) of the contact person(s) responsible for corrective action: Jacqueline Watford Planned completion date for corrective action plan: Effectively Immediately

2025-004 Federal Pell Grant Program, Federal Direct Student Loans, Federal Supplemental Educational Opportunity Grants, Federal Work-Study Program – Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Recommendation: We recommend the University implement policies and monitoring procedures to ensure Title IV credit balances are either refunded to students in a timely manner or supported by documented written authorization. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Rider University concurs with the finding. This was an isolated instance due to prorated tuition charge that was excluded during the Title IV credit balance assessment. The University will work with OIT to ensure the systemic review process is inclusive of all prorated charges. Rider has updated the university’s frequency in their Reporting procedures to ensure this process is completely accurately and timely. Name(s) of the contact person(s) responsible for corrective action: Jacqueline Watford Planned completion date for corrective action plan: Effectively Immediately

2025-003 Federal Pell Grant Program – Assistance Listing No. 84.063 Recommendation: We recommend the University review and enhance its policies and procedures related to COD reporting to ensure all disbursement information is reported accurately and within required timeframes. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Rider University concurs with this finding. The University will implement a bi-weekly Pell Reconciliation process and procedure to ensure timely reporting to COD. Rider has updated the University’s frequency in their reporting procedures to ensure this process is completed accurately and timely. Name(s) of the contact person(s) responsible for corrective action: Jacqueline Watford Planned completion date for corrective action plan: Effectively Immediately

2025-002 Federal Direct Student Loans - Assistance Listing No. 84.268 Recommendation: We recommend the University strengthen its review procedures over student award packages, including a review at the start of each academic year, to ensure Direct Loans are awarded in accordance with grade level and dependency status limits. We also recommend the University review all ISIR codes and resolve any that are necessary. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Rider University concurs with the finding. The University will ensure all student award packages and ISIR codes are reviewed and resolved prior to disbursing any Title IV funding. No additional Unsubsidized Loan will be awarded without a Parent PLUS Loan denial received from COD and on file with the Financial Aid Office. Rider has updated the University’s packaging procedures to ensure this process is implemented. Name(s) of the contact person(s) responsible for corrective action: Jacqueline Watford Planned completion date for corrective action plan: Effective Immediately

ENROLLMENT REPORTING PROCEDURES SHOULD BE STRENGTHENED. STUDENT FINANCIAL AID CLUSTER PROGRAM ALN# 84.268,84.007,84.033, 84.063, and 84.038 (Questioned Costs - None) Views of Responsible Officials and Planned Corrective Actions The university will strengthen coordination between the Registrar, Financial Aid, and the Business Office to ensure that SAP status is evaluated and communicated before financial aid is disbursed. Procedures will be implemented to ensure timely receipt of grade reporting and academic alerts from faculty and Academic Affairs. Financial Aid staff will review SAP eligibility after each academic evaluation period and maintain documentation of SAP determinations. Students who do not meet SAP requirements will be appropriately flagged to ensure financial aid eligibility is addressed prior to disbursement, strengthening compliance with federal financial aid regulations. Date to be implemented: On-going and completed by June 1, 2026. Persons responsible: Vice President of Business & Finance and Office of Financial Aid.

Special Tests and Provisions – Return of Title IV Funds Condition: During the testing of the return of Title IV funds, it was noted that one (1) of eight (8) tested calculation of funds to be returned had no documentation to determine if returns were completed timely as the College did not retain the lists of students associated with drawdowns and/or returns and one (1) of eight (8) tested. Recommendation: Policies and procedures should be written to provide internal control over the documentation used to complete the drawdowns, including returns, from the Department of Education. We recommend the College establish a communication and record retention process that allows for the notification of students withdrawing and a control in place that allows the financial aid department to know that the student financial aid was returned to the Department of Education within the required timeframe. Views of responsible officials and planned corrective action: Areas of focus will be to put in place written policies and procedures for the Financial Aid office, including the area of disbursements that includes additional controls and documentation of such. Our objectives will be that all current and incoming Financial Aid staff will be required to maintain documentation of any drawdowns of funds related to student financial aid. We have put in place a shared an electronic folder with restricted access to provide confidentiality and provide documentation of the shared communication between offices. Documentation of drawdowns and/or returns will be maintained within this folder. Staff will be trained on using the daily generated reports from J1 to watch for students who have withdrawal on their records so that this can be updated and proper calculations done. Measurable targets will be achieved by documenting the records within a shared secure electronic drive between the Financial Aid Office and the Business Office. The Financial Aid Office utilizes system-generated reports to identify student withdrawals on a biweekly basis, or as needed ensuring timely processing of R2T4 calculations. The Business Office processes all returns of funds, and a specific general ledger account has been designated to track R2T4 transactions

Special Tests and Provisions – Payment to Students Condition: During our testing of the financial aid disbursements, it was noted the College is not maintaining records of what students the drawdowns were for, therefore we were unable to determine if the amounts were posted to the student accounts within the required time frame and subsequently were paying out any credit balances created on student accounts. Recommendation: Policies and procedures should be written to provide internal control over the documentation used to complete the drawdowns from the Department of Education. We recommend the College establish a communication and record retention process that allows for the notification of the student financial aid proceeds and a control in place that allows the financial aid department to know the student financial aid was applied to the student’s account timely. Views of responsible officials and planned corrective action: The College has established formal procedures governing the documentation, approval, and processing of financial aid drawdowns from the Department of Education. A segregated and controlled workflow has been implemented through the use of a secure shared electronic folder with restricted access to provide confidentiality and provide documentation of the shared communication between the Financial Aid office who approves the aid, the Business Office who ultimately pulls down from the Department of Education, and with the Cashier who distributes any refunds. The Financial Aid Office prepares and approves disbursement amounts and communicates them via documented reporting; the Business Office reconciles disbursement amounts to individual student accounts prior to drawdown; the CFO initiates drawdowns after documented review and approval; and the Cashier processes student refunds, where applicable. The documentation is being retained and backed up. Measurable targets will be to do this weekly or as batches are prepared for draw-down. This documentation can be found in the secure shared electronic folder, which has already been implemented. Financial aid disbursements are processed on a weekly or batch basis, and funds are applied to student accounts in compliance with federal requirements, generally within three (3) business days of receipt.

Title: Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University evaluate their procedures and review policies surrounding reporting status changes to NSLDS to ensure timely and accurate reporting. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Registrar’s Office and the Financial Aid Office jointly reviewed the processes and data-entry practices related to enrollment reporting to ensure they are applied consistently and accurately. A plan has been implemented to provide ongoing training for employees responsible for managing reporting data. In addition, both offices established clearer communication channels to support timely and accurate updates and agreed to conduct an annual review of these processes to maintain continued alignment. Name(s) of the contact person(s) responsible for corrective action: Stephen Field Planned completion date for corrective action plan: 3/18/2026

Waldorf University was surprised by this finding. In response, several meetings were held, and a clear process was designed to mitigate issues related to uncashed checks. The University accepts the findings and believes the new software will aid in producing accurate reports. Waldorf University is also reorganizing its departmental structure to strengthen oversight and ensure a thorough review of financial reports and account records.

Finding 2025-001 – Enrollment Reporting To address this repeated finding, the following action items have been put into place: 1) The University conducted a reorganization of the student services unit that resulted in a shift of oversight to new personnel. Beginning July 2025, the Office of the Registrar, the unit responsible for enrollment reporting is under the direction of Sonia Gutierrez-Mendoza, Associate Vice Chancellor of Student Services, and Jorge Salas Lizarraga, University Registrar. 2) There were three main NSLDS reporting data errors identified and noted below. For each one, the requirements, source documents, cause of error and corrective action plan are noted. Campus Level Data Errors o Requirements:  NSLDS data elements must include accurate Student Enrollment Status (Full- Time, Three-Quarter Time, Half Time, Less Than Half Time, Withdrawal, Graduation, Leave of Absence) and the Effective Date of student changes. o Source Document/s:  Data source documents are provided through the Banner/Ellucian Campus Level Data delivered reporting. (Requires accurate parameter setup prior to processing). o Cause of error:  Incorrect student data parameters setup/used within Banner/Ellucian Campus Level Data reporting. o Corrective Action Plan:  Correct the Banner/Ellucian reporting parameters to match the NSLDS enrollment data reporting requirements for campus level/student status.  Engage Banner/Ellucian subject matter consultant to advise/provide additional expertise on setup/successful implementation of required campus level data reporting.  Implement controls over the Campus Level Data reporting process to ensure correct data submission to NSLDS. Program Level Data Errors o Requirements:  NSLDS data elements must include accurate Student Enrollment Status (Full-Time, Three-Quarter Time, Half Time, Less Than Half Time, Withdrawal, Graduation, Leave of Absence) and the Effective Date of student changes. o Source Document/s:  Data Source documents are provided through the Banner/Ellucian Program Level Data delivered reporting. (Requires accurate parameter setup prior to processing). o Cause or error:  Incorrect student data parameters setup/used within Banner/Ellucian Program Level Data reporting. o Corrective Action Plan:  Correct the Banner/Ellucian reporting parameters to match the NSLDS enrollment data reporting requirements for program level/student status.  Engage Banner/Ellucian subject matter consultant to advise/provide additional expertise on setup/successful implementation of required program level data reporting.  Implement controls over the Program Level Data reporting process to ensure correct data submission to NSLDS. Timely Reporting Errors O Requirements:  Timely reporting to NSLDS within 60 days of all student enrollment status changes at the campus and program levels. o Source Documents:  Data source documents are provided through the Banner/Ellucian delivered reporting. (Requires accurate parameter setup prior to processing). o Cause of error:  Incorrect reporting student data parameters setup/used to cause student enrollment status changes to be omitted and or skipped. o Corrective Action Plan:  Correct the student data parameters to accurately include all student changes within the Banner/Ellucian report.  Ensure that the student enrollment changes are reported to NSLDS within the 60-day time status requirements.  Engage Banner/Ellucian subject matter consultant to advise/provide additional expertise on setup/successful implementation of the required timely data reporting.  Implement controls over the 60 days timely submission reporting requirement to the NSLDS. 3) The following data from the NSLDS Enrollment Reporting guide will serve as the basis for each revised report: • Student current SSN • OPEID • CIP Code • CIP Year • Credential level • Published Program Length Measurement • Published Program Length • Weeks in Title IV Academic Year • Program Begin Date • Special Program Indicator • Program Enrollment Effective Date Anticipated Completion Date: July 1, 2026 Person Responsible: Jorge Salas Lizarrage, University Registrar

2025-001 - Miscalculation of Reconnect Scholarship Awards. Auditor Description of Condition and Effect. For 3 out of 12 students tested, the incorrect amounts of Michigan Reconnect scholarships were calculated and awarded to students. As a result, the College had a total of 16 students whereby the Michigan Reconnect scholarships awarded during the fiscal year were miscalculated, resulting in $16,101 in under-awarded scholarships and $288 in over-awarded scholarships to students. The College corrected under-awarded scholarships by adjusting student accounts to reflect accurate award amounts and issued refunds to students as applicable on March 18, 2026. The college corrected over-awarded scholarships by adjusting the student accounts and updating the Michigan Student Scholarships Grants ("MiSSG") reporting system to refund MiLEAP on August 6, 2025. Auditor Recommendation. We recommend that the College implement a formal review process for Michigan Reconnect scholarship award calculations, ensuring that each calculation receives a second, independent review to verify its accuracy. Corrective Action. The College recalculated the awards for the students impacted, adjusted their student accounts, notified the students of these corrections and returned $288 in over-awarded scholarships to MiLEAP by updating the MiSSG reporting system. Additionally, the College plans to conduct additional training of stafff on the Michigan Reconnect Expansion program, including the last-dollar calculation methodology, and will implement a review of the calculations by a second individual of all disbursements. Responsible person. Maryann DeCaire, Director of Financial Aid. Anticipated Completion Date. March 31, 2026.

Recommendation We recommend implementing a Program Improvement Plan between the Title IV-E team and Fostering Connections to ensure that adoption cases potentially eligible for extended subsidies are processed promptly upon consideration, with the necessary agreements executed in a timely manner, i.e., before the children in question turn 18. Management Response Corrective Action The Office of Performance and Accountability Director will work with the Adoption and Kinship Unit Supervisor to establish a biannual review of payments to adoptive parents to verify if cases need to be closed. Due Date of Completion: June 30, 2026 Responsible Person(s) Office of Performance and Accountability Director

Recommendation We recommend a Program Improvement Plan with documentation retention and file checklist, training, implementation, and monitoring process. There should be accountability for non compliance with these requirements. Management Response Corrective Action Missing Documentation The CYFD Adoption Subsidy unit will continue to organize its filing system. The Eligibility Manager and Office of Performance and Accountability Director will work with the Adoption and Kinship Unit Supervisor to review and ensure appropriate checklists, training, and processes are in place. In addition, the Eligibility Manager, OPA Director, and Adoption and Kinship Unit will conduct an additional case review to ensure required documentation is present and establish a biannual cadence of self-assessment checks to ensure no missing documentation. Criminal Records Mitigation The agency continues to ensure that workers, supervisors, and managers follow proper procedures for mitigating criminal records checks. The agency addresses this by creating a supervisor checklist to ensure licensure documentation is complete and accurate. The supervisor will conduct an initial placement review; the checklist will include verification by the supervisor of the completed level of care documentation. Supervisors and Managers will address work performance with employees through corrective actions or employment evaluation. Due Date of Completion: June 30, 2026 Responsible Person(s) Office of Performance and Accountability Director

FINDING 2025-009 Name of Responsible Individual: Lisa Simon, CPA, CFO, Terri Helt, Senior Accountant, Tracy Jenkins, Student Account Billing Coordinator, & Dylan J. Nowakowski, Director of Financial Aid Corrective Action: The University acknowledges the FISAP report was filed with incorrect data and not amended in a timely manner. The University has developed a series of internal controls and procedures to ensure that the data provided for the FISAP will be accurate going forward. Wheeling University worked with ECSI regarding Perkins information. With the Perkins program ending, we realized that we needed to move in the direction of closing out Perkins files/information. ECSI has been updated with the Cash on Hand documents that we have from the Department of Education. The University is currently working with ECSI so that we are able to submit Perkins information/files to the Department of Education. Anticipated Completion Date: June 2026