Corrective Action Plans

2025-002 Federal Program - Student Financial Assistance Cluster -Assistance Listing Nos. 84.063, Federal Pell Grant Program and 84.268 Federal Direct Student Loans U.S. Department of Education Program Year 2024-2025 - Enrollment Reporting Finding Summary: The University is required to report enrollment information to the National Student Loan Data System (NSLDS) when changes occur related to enrollment statuses, program information, and effective dates within a specified time. Recommendation: The University should establish controls designed to facilitate accurate reporting of students' enrollment information to NSLDS within the required time frame. Additionally, the University should enhance controls addressing circumstances in which students unofficially withdraw. Action taken in response to finding: The Office of Registrar implemented a revised end-of-term procedure. Effective immediately, all students who are unofficially withdrawn for the semester- defined as students who have failed all courses or have a combination of official withdrawcJls and fa ilures for all enrolled courses- will have their enrollment status manually updated to withdrawn in the National Student Clearinghouse (NCS) reporting process, which from there is reported to NSLDS. In addition, the Office of Registrar will provide to the Office of Financial Aid a list of these students at the end of each term. This will allow Financial Aid to verify that NSC updates NSLDS accurately and within the required reporting timeframe . To prevent the issue of timely reporting, the Registrar's Office has implemented a reconciliation check to ensure that graduate counts are consistent across both NSC reports and align with internally generated graduate lists prior to submission. Name(s) of the contact person(s) responsible for corrective action: Alaina Abolail Planned completion date for corrective action plan: January 1, 2026

2025-001 Federal Program - Student Financial Assistance Cluster - Assistance Listing Nos. 84.063, Federal Pell Grant Program and 84.268 Federal Direct Student Loans U.S. Department of Education Program Year 2024-2025 - Return of Title IV Funds Finding Summary: The University is responsible for calculating and determining the amount ofTitle IV aid earned by a student when they withdraw from the institution during a payment period and identifying if a post-withdrawal disbursement is applicable. The University is responsible for returning any unearned aid within the required time frame outlined by 34 CFR 668.173(b). Recommendation: The University should establish controls designed to support accurate review of Title IV fund calculation and timely return of funds within the required time frame. Action taken in response to finding: The Office of Financial Aid has established a procedure when the dates are being set for the award year, the term's start date, end date, and consecutive break periods will be submitted to the Provost and Vice President for Academic Affairs for review and approval. A copy of the reviewed and approved dates will be retained within Financial Aid. The Office of Financial Aid also established, internally, an electronic tracking list for Return to Title IV, which will capture post withdrawal offers. Within the list the date of the student's notification is noted, along with the due date of post withdrawal loan acceptance offers. Finally, the Office of Financial Aid established, internally, an electronic tracking list for officially and unofficially withdrawn students. All students reported to the Financial Aid Office as withdrawn are placed on this list to track their progress form initial reporting to Financial Aid, date assigned to the counselor, receipt of R2T4 calculation or date of determination that the calculation is not required in the case of the students not using Title IV awards, reporting date to Common Organization & Disbursement (if applicable), and reporting date of adjustments sent to Bursar Office. Name(s) of the contact person(s) responsible for corrective action: Jason Reavis Planned completion date for corrective action plan: January 1, 2026

2025-002: Student Financial Audit Cluster - Special Tests: Return of T itle IV Funds and NSLDS Reporting Anticipated completion date: done - June 18, 2025 Contact person: Brandi Payne Cervera Corrective actions: The two late aid returns were made under the following circumstances. Student's effective date of the withdrawal was March 25, 2025. However, the withdrawal was not processed in our Colleague system until April 9, 2025. The backdated effective date of the withdrawal in Colleague did not appear on our enrollment activity report that is used to identify complete withdrawals because this report is run weekly using a defined date range. As a result, the student's withdrawal was not identified in a timely manner. The withdrawal was identified by our Assistant Director upon her review of students with all non-passing grades at the end of the semester prior to the audit testing (see existing procedure/internal control below). The return-of-funds was processed as soon as the withdrawal was discovered, but it was out of the 45-day required timeframe. We have implemented a new procedure, as follows. New procedure (backdated withdrawal): The Registrar's Office will immediately notify Financial Aid of any withdrawals received by the Registrar's Office that require a backdated effective date in Colleague to ensure that we are returning funds within the required timeframe. The Financial Aid Director, Assistant Director of Financial Aid, and the Registrar met and developed this new procedure. The procedure was implemented on June 18, 2025. An institution must certify enrollment information to the National Student Loan Data System (NSLDS) every 60 days. Because of the issue with the backdated effective date of the withdrawal described above, the enrollment reporting for this student was made outside of the 60-day reporting window. I request the removal of the NSLDS reporting deficiency since the late processing of the student's withdrawal and return-of-funds was the root cause of the late NSLDS reporting, and there were no other enrollment reporting issues. The second late return was due to human error. After a R2T4 calculation has been performed, there is an "Update Student Aid" button on the ROFC screen in Colleague that must be manually marked "yes" in order for the return of- funds to post to the student's account. This step was missed for one student which caused the late return-of-funds outside of the required 45-day timeframe. New procedure (human error): Assistant Director has put a standing item on her calendar to review RT24's every Wednesday with a notation to check the "Update Student Aid" box in Colleague so that the return will occur. The Assistant Director will also check the list of withdrawals after each weekly aid transmittal to make sure the aid returns have all posted to the student accounts as expected. This procedure was put into place on June 18, 2025. Existing Procedure/Internal Control: We can say with certainty that out of the 165 withdrawals for the 2024/2025 award year, the two students identified in the audit were the only two late returns. The Assistant Director of Financial Aid reviews all students with non-passing grades at the end of each semester to identify unofficial withdrawals and to ensure that all returns were made appropriately and that no R2T4 calculations were missed. Potential issues are identified through this end-of-semester review. This is how the issue with the backdated withdrawal date described above was discovered. She will continue this effective internal control process each semester which will confirm that our new procedures are working as intended.

2025-001 Student Financial Aid Cluster- Reporting Anticipated completion date: Done Contact person: Nola Rocha Corrective actions: The incorrect inclusion of non-credit course data for new programs in the annual FISAP report resulted from a misinterpretation of reporting criteria. This isolated error affected one reporting element within an otherwise accurate submission. The issue was promptly addressed through clarification of FISAP guidance, staff retraining, and updates to procedural documentation and review checklists to ensure non-credit course activity is properly excluded in future reports. While the dollar amount could be viewed as measurable the financial reporting would not result in any financial impact, as the Department of Education allocates Campus-Based Program funds based on institutional requests and does not provide allocations in excess of those requests.

Finding Number: 2025-001 Condition: There was a lack of internal controls in place related to the return of Title IV funds. Planned Corrective Action: The College has implemented procedures to verify that academic dates are entered accurately in Banner and confirmed by personnel other than those responsible for calculating and reviewing returns of Title IV funds. This should ensure the related calculations are complete and accurate, and the funds are returned in a timely manner. Contact person responsible for corrective action: David Cummins, Vice President for Administrative Services and College Treasurer Anticipated Completion Date: December 2025

Management’s View and Corrective Action Plan: This finding has been corrected. In addition, the College has already taken corrective action to prevent this error from occurring again. First, when processing R2T4 calculations for students who populate on the end of term Failure to Pass report, students with a withdrawal date in the first two weeks of a term, will be cross checked with the Registrar’s Office to ensure that the correct LDA is being used for R2T4 calculations. The report will not automatically be assumed as correct. In addition, the Instructional Dean has been notified and informed the faculty of this error and the processes for reporting LDAs have been reiterated. In addition, to the ARGOS report used during the 2024/2025 academic year, the Financial Aid Director is using a more detailed report that is available through the ACCS. The new report and the old report will be cross-checked for accuracy. We will continue to review and modify policies to ensure that R2T4 calculations are correct.

Management’s View and Corrective Action Plan: The College is in the process of correcting this finding for future withdrawals. The College Registrar’s Office reports enrollment, which includes withdrawal’s, every 30 days. However, this finding has to do with the Failure to Pass report and incorrect LDA’s that are reported by the Instructional side of the College and indicating these dates in Banner. There are several places that LDA’s have to be updated and if one is missed it could affect the date that pulls on the Financial Aid Office’s Failure to Pass report. The Financial Aid Director and the College Registrar have already been working to ensure the accuracy of those dates for the Fall 2025 report. In addition, the Instruction Dean has been notified and informed the faculty of this error and the processes for reporting LDAs have been reiterated. The College will continue to improve the accuracy of this process.

2025-002: Late Return of Title [V Financial Aid - Student Financial Aid Cluster - Assistance Listing #s 84.007, 84.033, 84.063, 84.268 - Grant Period - Year Ended June 30, 2025 Condition Found During our Return of Title [V Fund testing, we noted that the College did not calculate or return Title IV Student Financial Aid for two out of twenty-five students tested until after 45 days when the ryan student ceased attendance. We consider the untimely calculation and Return of Title TV Student Financial Aid to be an instance of noncompliance relating to the Special Tests and Provisions Compliance Requirement. This is a repeat finding of prior year Finding 2024-001. Corrective Action Plan To strengthen compliance with R2T4 timelines, the Financial Aid Office has implemented enhanced monitoring and workflow procedures. Responsibility for the weekly review and processing of R2T4 calculations has been reassigned to the Coordinator of Student Loans, ensuring consistent oversight and timely completion of required actions. Meetings are held every Wednesday to address any cases requiring follow-up creating a checkpoint to prevent delays. Responsible Person for Corrective Action Plan Coordinator of Student Loans Executive Director of Financial Aid Implementation Date of Corrective Action Plan 10/01/2025

2025-001 Federal Work Study - Student Financial Aid Cluster Assistance Listing Number 84.007, 84.033, 84.063, 84.268, Grant Period - Year Ended June 30, 2025 Condition Found During our Federal Work Study testing, we selected twenty-five students and noted that one student was paid for hours they did not work and was overpaid $420. The College did not review federal work study hours worked against class hours scheduled and timesheets to ensure the student was not working during a scheduled class and that they were paid for the correct number of hours. We consider this condition to be an instance of non-compliance to the Eligibility compliance requirement. Corrective Action Plan The Financial Aid Department is collaborating with Career Services to implement improved oversight and training for Federal Work-Study. This includes required online training for both student employees and their supervisors, which must be completed prior to hiring any student employees within a department. Additionally, a campus-wide Standard Operating Procedure (SOP) has been developed, along with a Quick Guide for Supervisors of Student Employees, to ensure consistent processes and expectations related to scheduling, timesheet review, and compliance. Responsible Person for Corrective Action Plan Program Manager — Student Employment/Veteran Affairs Director of Career Services and Job Placement Implementation Date of Corrective Action Plan 08/22/2025

Claremont Graduate University Corrective Action Plan For the Fiscal Year Ended June 30, 2025 U.S. Department of Education FINDING 2025-001 – Special Tests and Provisions-Enrollment Reporting: Significant Deficiency in Internal Control over Compliance Condition – During the audit fieldwork, a sample of 20 federal aid recipient students were selected by auditors from system generated reports of students who graduated, reported a physical address change, withdrew, or dropped during the 2024-2025 academic year. The enrollment information and withdrawal, address change, or graduation date per the University’s records was compared to the information reported to the National Student Loan Data System (NSLDS) in order to determine if status changes were reported within the required timeframes. Of the 20 students who had a change in address, graduated, or withdrew, there were four student files with errors. There was one student file that had incorrect enrollment status reported and not reported within the required timeframe. A second student file was reported under the incorrect enrollment status but within the appropriate time requirement. Lastly, two additional student files were not reported within the required timeframe. Explanation of Deficiency On June 20, 2025, the Degree Verify transmission to the National Student Clearinghouse (NSC) failed. Additionally, an error was identified that caused all international student records to be rejected. In order to correct the omission of international students, the monthly transmission was temporarily stopped until the issue could be resolved. This process took longer than anticipated. While degree records were being manually updated in NSC, staff were not aware that the enrollment records also needed to be separately updated. The Degree Verify file had been configured with a flag that should have automatically updated enrollment records upon submission, but this was not recognized at the time. As a result, a sample of student files reviewed contained reporting errors related to incorrect enrollment statuses or reporting delays. These issues would have been avoided if regularly scheduled reports had been submitted to NSC without interruption. Corrective Action Plan To address these deficiencies and prevent recurrence, the following corrective measures have been implemented: 1. Resumption of Scheduled Transmissions – The Office of Information Technology has corrected the Degree Verify file rejection issue. Monthly transmissions of Degree Verify reports will resume beginning September 20, 2025. 2. Enhanced Enrollment Reporting Schedule – Enrollment reporting has been rescheduled to occur every three weeks throughout each term, ensuring that enrollment status changes are reported to NSC and NSLDS within required timeframes. 3. Manual Record Reconciliation – A comprehensive review of late degree conferrals has been completed. All enrollment records have been manually updated in NSC to align with the corresponding degree records. 4. Staff Training and Awareness – The Registrar’s Office staff have been trained on the functional differences between degree reporting and enrollment reporting. Emphasis was placed on the need to verify that enrollment records are updated when degree records are manually corrected. 5. Monitoring and Quality Control – A reconciliation process has been established between the Registrar’s Office and OIT to confirm the successful transmission and acceptance of NSC files. Reports of any rejected records will be reviewed within five business days and promptly corrected. Contact Person Responsible: Vannessa Alvarado, Registrar 909-621-8285 Anticipated/Projected Completion Date: Manual corrections completed on September 3, 2025. Automated processes to projected September 20, 2025.

Finding 2025 – 004 - Special Tests and Provisions- Enrollment Reporting (Significant Deficiency and Noncompliance) Management’s Response: Management concurs with the above finding, and the Fiscal Service Office will implement corrective action before September 2026. Management acknowledges the process gap as indicated and noted in the above findings. The Director of Admissions and Records has stated that students who have a student attribute in Banner of INTL will no longer be excluded from the National Student Clearinghouse enrollment reporting upload so as to prevent any reporting issues due to human error when processing admissions applications.

2025-001: Missing Exit Counseling Documentation Student Financial Aid Cluster Assistance Listing Number 84.007, 84.033, 84.063, 84.268, 84.379 Grant Period – Year Ended June 30, 2025 Condition Found Condition/Context: During our student file testing, we noted two students out of forty 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 an instance of noncompliance with the Eligibility Compliance Requirement. Corrective Action Plan Concordia has created new reporting and updated its Exit Counseling policy to put any students without concurrent semester enrollment, excluding traditional undergraduates who are not required to take summer, into "EXIT". Responsible person for corrective action plan: Kevin Sheridan Implementation Date of Corrective Action Plan: December 11, 2025

2025-002 Significant Deficiency: Working During Scheduled Class Time (U.S. Department of Education - Federal Work Study Program, ALN #84.033) The University noted that multiple students appear to have been paid for Federal Work Study hours logged and submitted for time the student was scheduled to be in class without verification of a reasonable exemption. Management Response Management concurs with the auditor’s finding. Due to incomplete documentation of reasonable exemptions, students were paid Federal Work Study funds for time worked during regularly scheduled class meeting times. Responsible Person(s) Alex Campbell, Director of Financial Aid, and Bobbi Farris, Manager for Student Employment, are the responsible parties for the corrective action. Corrective Action Plan Upon identifying deficiencies related to the lack of documentation for allowable exemptions, the University immediately communicated with all Student Employment Supervisors regarding permitted exemptions and required documentation for students to work during scheduled class times. These requirements and exemptions are reviewed and agreed upon during the annual Student Employment Supervisor Trainings, which occur prior to job postings. Students are notified of the documentation required to be exempt and eligible to work during a scheduled class time during the onboarding process. In collaboration with Information Technology and third-party consultants, the Student Employment Office is enhancing reporting functions to ensure accurate identification of students with conflicting work and class times and to flag any conflicting entries for review and resolution prior to approval. These reports will be reviewed each pay period to ensure accurate documentation is obtained for any conflicting times flagged. While these fields are being implemented, regulations related to working during scheduled class times have been reinforced with both students and supervisors. Beginning with the Spring 2026 term, the University will implement a new policy prohibiting students participating in the Federal Work Study Program from working during scheduled class times, regardless of any met exemptions. All Student Employment Supervisors will be notified of this updated policy by the end of the Fall 2025 term. Training will continue on an annual basis to ensure proper procedures are followed by Student Employment Supervisors and students participating in the Federal Work Study Program. The Director of Financial Aid and Manager for Student Employment will review student time records each pay period to ensure full compliance with these policies. Expected Completion Date This corrective action plan was implemented in September 2025, during the Fall 2025 term. Final implementation will occur at the start of the Spring 2026 term.

2025-001 Significant Deficiency: Awards in Excess of Aggregate Limits (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268) The University awarded and disbursed Federal Direct Loans beyond aggregate limits. Management Response Management concurs with the auditors’ finding. Due to delays and changes in the National Student Loan Data System (NSLDS) post-screening process for the 2024–25 award year, Federal Direct Loans were inadvertently awarded and disbursed to students who had previously exceeded Federal Direct Loan aggregate limits. Responsible Person(s) Alex Campbell, Director of Financial Aid, and Kaitrin Parrett, Assistant Director of Financial Aid, are designated as the individuals responsible for implementing the corrective action. Corrective Action Plan Upon identifying deficiencies in loan aggregate reporting and over-award status, the Financial Aid Office initiated communication with the identified students to inform them of their overaward status and the process for resolving inadvertent overborrowing. In collaboration with software engineers, the Financial Aid Office is developing updated reporting to ensure proper identification of students who are ineligible due to meeting or exceeding aggregate limits set by the U.S. Department of Education. The Financial Aid Office tested and reviewed NSLDS post-screen data and student loan aggregates prior to the disbursement of Fall 2025 Federal Direct Loans to ensure students were not awarded or disbursed aid for which they were ineligible. Reviews of NSLDS post-screen data confirm that the Student Information System (SIS) accurately identifies student aggregate borrowing flags. The Financial Aid Office is also monitoring designated mailboxes to ensure any additional NSLDS post-screen data is reviewed and aggregate limits on student accounts are updated accordingly. All financial aid staff involved in awarding federal loans completed additional training on NSLDS review requirements, aggregate limit monitoring, and reaffirmation procedures prior to Fall 2025 disbursements. Training will continue on a quarterly basis to ensure proper procedures are followed by Financial Aid staff. Compliance reviews will be conducted on a semester basis to ensure that Title IV aid is not awarded to students in excess of their annual or aggregate limits. The Director and Assistant Director of Financial Aid will review aggregate limit reports monthly as part of the University’s internal operational calendar. Expected Completion Date This corrective action plan was implemented in September 2025, prior to Fall 2025 aid disbursements, which began on September 12, 2025.

Individuals Responsible for Corrective Action Plan: •Collections Coordinator •Director of Student Accounts Condition: Life University transitioned from UAS services to ECSI. In the transition of that service provides, documentation that was to be maintained to remain compliant with the Federal Perkins loan program was lost. The university has attempted on numerous occasions to assign the defaulted loans using alternative documentation to verify the debt. All attempts have been denied. The university has now been in practice with the current corrective action plan to address the deficiencies in documentation and reestablish the validity of the debt. Management’s Corrective Action Plan: Life University has implemented and continues to maintain the following corrective measures to ensure ongoing compliance: 1.Borrower Contact and Notification Life University has initiated and continues to conduct proactive outreach to borrowersrequiring an updated or newly established MPN (Master Promissory Note) or equivalentdocumentation. Communication is conducted through multiple channels, including: •Phone •Email 2.Clear Documentation Instructions The University will continue to issue formal notices to affected borrowers outlining therequirement for a new MPN or equivalent documentation. Each notice includes step-by-stepinstructions for completion, a clear explanation of the purpose and importance of the MPN,and information regarding its impact on the borrower’s outstanding loan balance. 3.Reassignment of Collection Rights Upon borrower completion of the required documentation, Life University has coordinatedwith ECSI to reassign the University’s right to collect on any remaining balances. This processcontinues to be applied as additional borrowers complete their documentation. 4.Documentation Review and Verification The University has established and continues to follow a review process to verify that eachnew MPN is complete, accurate, and properly executed. This ensures that borrower consentis valid and that all collection rights are appropriately reassigned. 5.Financial Record Updates Life University has updated and continues to maintain accurate financial records reflectingthe new MPNs and reassigned collection rights. Outstanding amounts, repayment schedules,and related data are verified and recorded to ensure consistency with federal andinstitutional requirements. 6.Ongoing Communication and Monitoring The University continues to monitor borrower compliance and maintain communicationthroughout the process. Regular follow-ups and reminders are sent as needed to ensuretimely completion and documentation integrity. At the conclusion of a 12 month outreach,students who have not verified their debt to come within compliance will be written off. Anticipated Completion Date: ongoing

Individuals Responsible for Corrective Action Plan: •Director of Student Accounts •IT Systems Administrator •CIO •Senior Director of Student Administration and Compliance Cause: The notification for this student was not generated due to timing and process gaps associated with the data security incident that occurred on July 30, 2024. The disbursement posted on Thursday, July 25, one day after the automated report selection window closed. As the team worked to assess the impact of the security incident, this process was not reviewed and this record fell outside of the reporting cycle and was not manually identified for notification. Management’s Corrective Action Plan: Incident Response and Process Impact Assessment: •Develop a standard protocol for identifying and reviewing business processes that may beimpacted during or after a data security event. •Document any suspended or delayed processes during an incident and report to IT andfollow-up. •Conduct a post-incident reconciliation of all financial aid transactions (disbursements,notifications, adjustments) to ensure completeness and compliance. •Collaborate with IT to include critical Student Account processes in the business continuityand recovery plan, ensuring prioritized restoration after any system outage or data event. Anticipated Completion Date: 2/9/2026

Individuals Responsible for Corrective Action Plan: •Dr. Lee Skinkle, VPAA •Elizbeth Geisz, Registrar •Melissa Waters, Senior Director Student Administration and Compliance Condition: The University did not report students’ status changes accurately and within the required timeframe. Management’s Corrective Action Plan: 1.Improved Identification of Withdrawals Per the University’s attendance policy, the Academics team promptly reviews students who haveceased academic activity for 14 consecutive days. Students meeting this criterion are identified androuted to the Registrar’s Office for processing as unofficial withdrawals within the required federaltimeframe. This procedure ensures timely and accurate reporting of enrollment status changes andeliminates the need to backdate information in the SIS, NSC, and NSLDS. 2.Refined Enrollment and Registration Deadlines Enrollment and registration deadlines have been tightened and communicated across alldepartments. Reducing late registration activity minimizes backdated actions that can result ininaccurate program-level and campus-level effective dates in NSC and NSLDS reporting. 3.Review and Adjustment of the Dismissal Timeline The dismissal process timeline is being reviewed and updated to ensure students have sufficienttime to meet enrollment and registration deadlines for subsequent academic periods. This reduceslate or retroactive enrollment-status changes that affect NSLDS timeliness. 4.Enhanced Quality Assurance for Enrollment Reporting Monthly quality checks will be performed on reports related to withdrawals, graduations, programchanges, and registration activity prior to submission to the NSC. These checks will specificallyverify: •Accuracy of program begin dates and program enrollment effective dates, •Accuracy and timeliness of campus-level enrollment status changes, and •Compliance with the 30-day/60-day federal reporting requirement. 5.Monitoring of NSC Transmission and NSLDS Reporting Timelines The University will monitor NSC transmission cycles and verify that all required enrollment changesare submitted in time to meet federal requirements under 34 CFR 685.309. 6.Updated Procedures and Staff Training Revised procedures outlining updated deadlines, reporting expectations, and QC steps will bedocumented and shared with all Enrollment, Registrar, and Deans. Targeted training will beprovided to ensure consistent and accurate implementation of these requirements. Anticipated Completion Date: The University intends to institute these beginning of January of 2026.

Corrective Action Plan December 19, 2025 U.S. DEPARTMENT OF EDUCATION Crowder College respectfully submits the following corrective action plan for the year ended June 30, 2025. Contact information for the individual responsible for the corrective action: Mr. Joseph Brenner, Vice President of Finance Crowder College 601 Laclede Avenue Neosho, MO 64850 (417) 451-3223 Independent public accounting firm: KPM CPAs, PC, 1445 E Republic Rd, Springfield, Missouri 65804 Audit Period: Year Ended June 30, 2025 The finding from the June 30, 2025, audit of the financial statements is below. The findings is numbered with the number assigned in the schedule. FINDING - MAJOR FEDERAL AWARD PROGRAM AUDIT 2025-001 Special Test and Provisions - Return of Title IV Funds Recommendation: We recommend the College implement procedures to strictly comply with the requirements of 34 CFR §668.22 as it relates to calculations of return of Title IV funds. Corrective Action Taken: The College reviewed all accounts affected by this error and identified 15 students whose accounts required adjustments. Upon review, the financial aid representative determined that excess funds were returned when the R2T4 calculations were completed. Financial Aid has since corrected the accounts and requested the additional funds owed. To prevent this issue from recurring, a representative from the Financial Aid Office will be included on the calendar committee. Additionally, Financial Aid Policies and Procedures have been updated to require calendar changes to be promptly updated in PowerFaids to ensure accuracy. Anticipated Completion Date: Fall semester 2025 and ongoing. Sincerely, Joseph Brenner Vice President of Finance

Missouri Western State University will meet the requirements in accordance with 34 CFR Section 685.309 by reviewing the enrollment reporting submitted to NSLDS through the National Student Clearinghouse (NSC) each month and comparing to Missouri Western State University’s student information system to ensure that all dates and information submitted for the month is accurate and timely.

Lack of Administrative Capability Planned Corrective Action: The Office of Financial Aid and Wayland Baptist University agree with this finding. To address the system limitations identified, the University has acquired a new Software-as-a-Service (SaaS) financial aid management system. This system will replace the current platform and is intended to improve automation, reporting accuracy, workflow tracking, and overall compliance with federal and state financial aid requirements. In addition, the Office of Financial Aid is actively reevaluating workload distribution and staff assignments to ensure responsibilities are appropriately aligned with compliance-critical functions. The University is also increasing staffing levels within the Office of Financial Aid to strengthen oversight, reduce processing risk, and ensure timely and accurate completion of compliance and reporting obligations. Collectively, these actions are designed to enhance administrative capacity, strengthen internal controls, and mitigate the risk of future compliance deficiencies. Person Responsible for Corrective Action Plan: Executive Director of Financial Aid, Robert Hamilton, and Assistant Director of Compliance & Reporting, Brooke Tyler Anticipated Date of Completion: June 30, 2026

Inaccurate and Untimely Return of Title IV Funds (R2T4) Planned Corrective Action: The Executive Director of Financial Aid and the Assistant Director of Compliance & Reporting will provide regular in-house R2T4 training specific to WBU for all financial aid staff. All financial aid staff responsible for R2T4 will be required to complete pertinent training provided by FSA and purchased through NASFAA. In addition, financial aid staff responsible for R2T4 have established procedures to ensure the accurate and timely Return of Title IV Funds. To address the system limitations identified, the University has acquired a new Software-as-a-Service (SaaS) financial aid management system. Person Responsible for Corrective Action Plan: Executive Director of Financial Aid, Robert Hamilton, and Assistant Director of Compliance & Reporting, Brooke Tyler, and Assistant Director of Financial Aid, Alyssa Shealor Anticipated Date of Completion: June 30, 2026

Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) Planned Corrective Action: WBU has entered into an agreement with Ellucian to implement Ellucian Student powered by Colleague as the new student information system. WBU will start utilizing this new student information system in April 2026. WBU will utilize the built-in functionality and tools to report to NSLDS at that time which should correct this issue completely. We will continue to work towards compliance with NSLDS reporting requirements through the following action plan: An internal SSRS report for official and unofficial withdrawals which accurately reflects withdrawn students remains available to the WBU offices of Financial Aid and the Registrar for verification as part of the planned corrective action. The custom NSC reporting tool(s) will continue to be updated to make sure the correct combination of fields and corresponding data sources are reported as accurately as possible. WBU will continue to work with NSC to mitigate issues related to data not transferring correctly between NSC and NSLDS. • A field-by-field analysis plus any needed corrections to the queries will be performed. o By default, term "W" withdrawals are reconsidered by the updated tool each time a report is generated for NSC. o Some date fields have been corrected that were previously misunderstood by the custom tool's historical authors. o Post-submission error corrections by registrar staff via NSC's website are spot-checked by Information Technology when requested. o If certain data issues cannot be resolved satisfactorily via NSC alone, then corrective measures via NSLDS directly may be considered. o The PowerCampus 9.1.2 baseline product's NSC reporting tool was determined to be insufficient for timely and accurate reporting to NSC with WBU's current data on several counts. WBU has upgraded the PowerCampus system to version 9.2.3 and will continue to work towards a solution for the baseline reporting tool with the upgraded system.  Some of the recurring data updates needed before running the PC baseline tool, are still being run periodically as a source data benefit for the custom tool. Person Responsible for Corrective Action Plan: Chief Information Officer, Cagan Cummings Anticipated Date of Completion: Ongoing

2025-001 – Special Tests and Provisions - Enrollment Reporting Auditor Description of Condition and Effect. During our testing we noted that one student out of a testing population of twelve did not have their status change reported timely to NSLDS. As a result, there is an increased risk that information will not be reported to NSLDS on a timely basis. Auditor Recommendation. We recommend that the Organization enhance its policies and procedures regarding enrollment reporting to ensure that reporting is completed timely. Corrective Action. The institution concurs with the finding. The error resulted from a manual data entry into the withdrawn students' records. After consulting with our student information systems provider, we were informed about a Wizard that could accurately update the withdrawn date and prevent future reporting issues. The Registrar and IT have rectified the finding. They will implement a monthly review for withdrawn students to ensure the last day attended is reported accurately and on time. Responsible Person. Amy Howarth Anticipated Completion Date. 09 01 2025

Management's Response: We concur. Views of Responsible Officials and Corrective Action Plan Response: The two students identified were underpaid due to locks on their financial aid units for either late-start courses or being on an approved SAP appeal plan. Once locks were removed, PowerFAIDS should have recalculated their aid to reflect their current units, however that did not happen. As a result, the Pell Grant was under-awarded. The students have now been disbursed with their full Pell eligibility. Corrective Action Plan: The transition from a legacy SIS and PowerFAIDS to a single ERP will consolidate financial aid and enrollment data into a single system, eliminating reliance on manual adjustments and reducing the risk of data discrepancies between two systems. Banner allows for automated and real-time recalculations for enrollment changes such as late start courses, reducing the risk of Pell under or over-awarding. Financial aid staff will receive updated training and guidance on the importance of verifying Pell recalculations when manual locks on student financial aid records are needed, for instance in the case of a student on an approved SAP appeal plan.

The following is the Recruitment and Admissions Corrective Action Plan for the single Audit Finding for FY25. Criteria or Specific Requirement: Special Tests and Provisions – NSLDS Reporting, 34 CFR Sections 690.83 (b)(2) and 685.309. Finding Summary: Student enrollment and program information was not communicated to the National Student Loan Data System (NSLDS) timely or accurately. Officials Responsible for Ensuring Corrective Action: Shanna Pope, Registrar Views of Responsible Officials and Planned Corrective Action: Management concurs with the finding and will implement enhanced procedures to ensure internal controls support the timely and accurate reporting of student status, program, and completion information to the National Student Loan Data System (NSLDS). For each National Student Clearinghouse (NSC) file submitted, students with status, program, or completion changes will be systematically identified and flagged for review. Registrar staff will conduct a targeted, sample-based review of these flagged records directly within NSLDS to verify that data transmitted from NSC was received, processed, and reflected accurately. All policies and procedures governing enrollment reporting and the processing of student status, program, and completion changes will be reviewed, revised as necessary, and formally implemented no later than April 1, 2026, to align with this corrective action.