Corrective Action Plans

Responsible Individual: Tamara Long Vice President for Enrollment and Student Engagement Abilene Christian University Finding 2024-002 Special Tests & Provisions - Bonus & Incentives Related to Enrollment Agency Name: U.S. Deparlment of Education Program Name: Federal Pell Grant, Federal Direct Student Loans, SEOG, Federal Work Study and TEACH Grants August 19, 2024 Finding Summary: Incentive Compensation (34 CFR 668.14(b)(22)(i) Institutions are required, within the Program Participation Agreement (PPA), to acknowledge that they will not provide any commission, bonus, or other incentive payment based on any part, directly or indirectly, upon success in securing enrollments or awards of financial aid. The university documented several bonus payments to individuals related to enrollment strategies and goals. Corrective Action Plan (CAP): Based on the findings of the Special Tests and Provisions for Incentive Compensation as part of (34 CFR668.14(b)(22}(i), the offices of enrollment and financial operations have identified additional review and controls that will be put in place to mitigate future risk of non-compliance. Additional review will be required by a financial operations member for any requests made for enrollment related staff. In addition, a formal tenure bonus structure has already been put in place to ensure that no bonuses or incentives are given based on enrollment goals. Anticipated Completion Date: As the tenured bonus structure has already been activated, the review of bonuses raises, and incentive pay will immediately be required to go through an additional financial review for compliance. The anticipated completion date is July 1, 2024

Responsible Individual: Eric Gumm Registrar and Director of First Year Program and Academic Development Center Abilene Christian University Finding 2024-001 concerning Enrollment Reporting Agency Name: U.S. Department of Education Program Name: Federal Pell Grant, Federal Direct Student Loans August 19, 2024 Finding Summary: Enrollment Reporting (34 CFR 690.93(b)(2); 34 CFR 682.610; 34 CFR 685.309) Institutions are required to report enrollment information. The University's processes did not ensure timely and accurate student status reporting to National Student Loan Data System (NSLDS). Out of the population of 829 students with student attendance changes required to be reported, a sample of 25 students were selected for testing. The University failed to report 3 students who had changes in enrollment status. Of the three students the University failed to report, 2 students had withdrawn from the University. The University reported the incorrect enrollment effective dates for 3 students at the program and campus levels. The University failed to report graduated status for 2 students (students were reported as withdrawn and the University failed to subsequently update the status to graduated). The University reported the incorrect Program Enrollment Effective Date for 1 student. The University did not report a change in enrollment status in a timely manner for 1 student. Corrective Action Plan (CAP): Based on the findings within the Federal and State Financial Assistance Program audit, it was determined that a significant deficiency exists within the review of reporting for student enrollment through the National Student Loan Data System (NSLDS). The office of Student Financial Services has identified the need for regular reconciliation of updates to student enrollment status from the Banner point of record to the NSLDS system. Our plan of action begins with a comprehensive understanding of the roles and responsibilities between the financial aid office and the registrar's office. Once this is well documented, the Office of the Registrar will begin a monthly reconciliation of enrollment reporting for any student status changes that have happened within that month. Anticipated Completion Date: The timeline for this CAP begins with the formal documentation of the enrollment reporting process. This will take place prior to the start of the Fall 2024 semester. The reconciliation of reporting will begin in September 2024 after 12th day of enrollment is confirmed and sent to the Clearinghouse for updates. The anticipated completion date is July 1, 2024

2024-002 Student Financial Aid – 84.268 – Federal Direct Loan Program, 84.063 – Federal Pell Grant Program, 84.007 – Federal Supplemental Educational Opportunity Grant Program, 84.033 – Federal Work-Study Program Recommendation: We recommend the review process for awarding be documented and retained as support for the review and approval process. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Director of Financial Aid will document each change to an award by printing a new award offer and saving to document tracking. As this is the final year in which Lincoln Christian University will have academic operations, we believe this corrective action to be sufficient for the remainder of the year. Name of the contact person responsible for corrective action: Margie Martin, Director of Accounting Planned completion date for corrective action plan: May 31, 2024.

Finding 2024-002 Personnel Responsible for Corrective Action: Cathy Gorrell, Registrar Anticipated Completion Date: September 30, 2024 Corrective Action Plan: The Office of the Registrar recognizes the systematic programming of a pseudo academic program after a pseudo course has been added with a future date after the student’s current program has been inactivated or graduated. This process has been at the request of the Office of Student Accounts for the graduation fee. The Office of the Registrar will work with the Office of Student Accounts to move to the system Graduation Application process rather than the customized and manual process of pseudo courses. Further, the Office of the Registrar has increased its data quality checks on the pseudo programs and courses. In conjunction, this should eliminate the reporting of active programs when the student has graduated.

2023-004 Special Tests (Enrollment Reporting) Federal Agency: Student Financial Assistance Cluster - U.S. Department of Education Program Titles and ALN: Federal Pell Grant Program (ALN 84.063) and Federal Direct Student Loans (ALN 84.268) Federal Grant Numbers: E-P063P130272 (7/1/2022 - 6/30/2023), P268K130272 (7/1/2022 - 6/30/2023) Contact Person: Jean McDonald Rash, AVP Enrollment Services, 848-932-2605 Corrective Action: The University Registrar will send a memorandum to all degree certifying officers at the University reminding them that degree certification must be completed by the appropriate date to be certain all students are included on the file that updates NSLDS with the graduation date. The Chancellor Unit registrars will be asked to send out reminders in the weeks leading up to the required submission date and to track the completion of degree certifications. A process will be developed to allow for the proper reporting of graduation information on the Program-Level Record to NSLDS even when the student remains currently enrolled at the University and is being reported as such on the Campus-Level Record. Anticipated Completion Date: The anticipated completion date for degree certifications is June 2024. The anticipated completion date for dual enrollment reporting statuses is January 2025.

2023-003 Reporting (Financial) Federal Agency: Student Financial Assistance Cluster - U.S. Department of Education Program Titles and ALN: Federal Pell Grant Program (ALN 84.063) and Federal Direct Student Loans (ALN 84.268) Federal Grant Numbers: E-P063P130272 (7/1/2022 - 6/30/2023), P268K130272 (7/1/2022 - 6/30/2023) Contact Person: Jean McDonald Rash, AVP Enrollment Services, 848-932-2605 Corrective Action: OSFP was notified of the error in reporting the correct cost of attendance to the Common Origination and Disbursement (COD) system and the code was changed to prevent the error from reoccurring. The correct cost of attendances are now being reported to COD. A testing plan has been developed that includes confirmation that all system start and end dates align with the University’s published academic calendar. Anticipated Completion Date: Completed

2023-002 Eligibility Federal Agency: Student Financial Assistance Cluster - U.S. Department of Education Program Titles and ALN: Federal Pell Grant Program (ALN 84.063) and Federal Direct Student Loans (ALN 84.268) Federal Grant Numbers: E-P063P130272 (7/1/2022 - 6/30/2023), P268K130272 (7/1/2022 - 6/30/2023) Contact Person: Jean McDonald Rash, AVP Enrollment Services, 848-932-2605 Corrective Action: In order to correct the issue of students being awarded in excess of their cost of attendance, a weekly report has been developed to capture any student whose financial aid, from any source, exceeds the assigned cost of attendance. The Financial Aid Processing team in University Enrollment Services receives and resolves the issues in the report weekly to ensure that students are not awarded in excess of their assigned cost of attendance. In order to correct the issue of the incorrect calculation of the cost of attendance components, a testing plan has been developed that includes manually checking each program cost of attendance prior to signing off for production aid packaging. The script that caused the cost of attendance components to be doubled was corrected prior to the 2023-2024 aid year. Anticipated Completion Date: Completed

2023-001 Eligibility, Reporting (Financial) and Special Tests (Disbursements to or on Behalf of Students) Federal Agency: Student Financial Assistance Cluster - U.S. Department of Education and U.S. Department of Health and Human Services (DHHS), DHHS Health Resources and Services Administration Program Titles and Assistance Listing Numbers (ALN): Federal Supplemental Educational Opportunity Grants (ALN 84.007), Federal Work-Study Program (ALN 84.033), Federal Perkins Loans (ALN 84.038), Federal Pell Grant Program (ALN 84.063), Federal Direct Student Loans (ALN 84.268), Nurse Faculty Loan Program (ALN 93.264) and Scholarships for Health Professions Students from Disadvantaged Backgrounds (ALN 93.925) Federal Grant Numbers: E-P007A132602 (7/1/2022 - 6/30/2023), E-P033A132602 (7/1/2022 - 6/30/2023), E-P038A132602 (7/1/2022 - 6/30/2023), E-P063P130272 (7/1/2022 - 6/30/2023), P268K130272 (7/1/2022 - 6/30/2023), E-01HP28821-02-02, E36HP26092, E36HP25751, E26HP25748, E11HP27284 (7/1/2022 - 6/30/2023), 1T08HP393200100 (7/1/2022 - 6/30/2023), 5 T08HP39320-03-00 (7/1/2022 - 6/30/2023) Contact Person: Ellen Law, AVP OIT Enterprise Application Services, 848-445-5064 Corrective Action: Management has documented and implemented system release management practices for the OSFP system. All system change requests, updates and approvals are being tracked in a project tracking software. A dedicated Oracle Student Financial Planning (OSFP) administrator has been onboarded, to segregate duties within the technical team, with the capability of deploying changes to production. A new access role was implemented which limited some of the permissions, and the majority of the 35 users were moved to this more limited role. A recertification process was developed and the recertification was performed in July 2023. In the future, recertifications will be completed annually. Anticipated Completion Date: Completed

Turnover and vacancies in positions resulting in applications and petitions not being completed within 20 days of receipt. The Domestic Relations Department filled vacant positions through 2023. In response to the prior year finding, the Domestic Relations Department provided semi-annual training to the Intake Unit staff in Case Initiation, record retention, time frame for conversion of applications/petitions to case files and file documentation beginning in November 2023.

Federal Program: Assistance Listing #'s 93.778, Medical Assistance Program, Passed Through Pennsylvania Department of Human Services, Pass-Through Entity Identifying Number: 13-1415MATP- 4-2; 93.658, Foster Care Title IV-E, Passed Through Pennsylvania Department of Human Services, PassThrough Entity Identifying Number: not available; 21.027, COVID-19 - Coronavirus State and Local Fiscal Recovery Funds, U.S. Department of Treasury; 93.558, Temporary Assistance for Needy Families, Passed Through Pennsylvania Department of Labor and Industry, Pass-Through Entity Identifying Number: not available. Criteria: Pursuant to the provisions of the Uniform Guidance, under Section 200.512(a), the County is required to complete and submit its Single Audit and related Data Collection Form within nine months of the end of its fiscal period (September 30) of the following year. Condition/Context The County's Single Audit and reporting package was delayed for the year ended December 31, 2022 beyond the nine-month due date. Effect: The County is not in compliance with certain requirements of the Uniform Guidance, including the Single Audit reporting requirements. Questioned Costs: None. Cause: Reconciliations and reports were not completed on a timely basis, and therefore, the completion and filing of its December 31, 2022 Single Audit and reporting package was not prioritized. Recommendation: We recommend that County management review its staffing and personnel responsibilities to prioritize the completion of its audit responsibilities within the prescribed timeframes. Views of Responsible Officials and Planned Corrective Actions: The County plans to have information ready for the auditors to get 2024 done in a reasonable time frame. This finding will likely carry to 2024 but between staffing and priorities, the County hopes to have cleared by the 2025 audit. Designated Member responsible for Corrective Action Plan: Kayla E. Herman Expected Complete Date: 06/30/2026

Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Foster Care Title IV-E & Stephanie Tubbs Jones Child Welfare Services Program Assistance Listing Numbers: 93.658 & 93.645 Federal Award Identification Number and Year: 21-20016 (2023) & 21-20017 (2023) Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Material Weakness in Internal Control over Compliance and Cash Management Recommendation: We recommend that management ensure that all invoices are based on actual expenses incurred and that there is a review an approval process of invoices before submission. Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding. Aciton take in response to finding: Management has implemented a policy which requires each invoice to be based only on actual expenses incurred for the period and prohibits the use of a straight-line calculation to draw down funds. Invoices are also approved by the CFO prior to submission for reimbursement. Name of contact person responsible for corrective action: Regan Kelly, CEO of NorthEast Treatment Cetners, Inc. (215) 451-7000 Planned completion date for corrective action plan: January 31, 2024

2023-008 - Student Financial Aid Cluster - (a) Federal Supplemental Educational Opportunity Grants (b) Federal Work Study Program (c) Federal Pell Grant Program (d) Federal Direct Student Loans, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2023 Condition: The College incorrectly reported tuition and fees on the Fiscal Operations Report and Application to Participate (FISAP) for the 2021-2022 academic year. We consider this to be an instance of noncompliance of the Reporting compliance requirement and is a repeated finding shown in Section IV of this report as prior year finding 2022-004. Statistical sampling was not used in making sample selections. Corrective Action Plan: The responsible parties listed below will thoroughly review all FISAP reporting requirements and necessary data elements prior to FISAP submission to ensure accuracy. Responsible Party for Corrective Action Plan: Director of Financial Aid and Veteran Affairs, Controller, Vice President of Financial Services Implementation Date for Correction Action Plan: Correction to FISAP will be submitted as soon as the amount of tuition and fees is confirmed by the Controller or Vice President of Financial Services. By September 2025 to accurately report the amount of tuition and fees on the upcoming FISAP reporting cycle due by September 30, 2025.

2023-007 - Student Financial Aid Cluster - (a) Federal Supplemental Educational Opportunity Grants (b) Federal Work Study Program (c) Federal Pell Grant Program (d) Federal Direct Student Loans, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2023 Condition: The College did not report timely or accurately enrollment status changes for twelve of the forty students tested (30%). We consider this condition to be a material weakness for the Special Tests and Provisions compliance requirement and is a repeated finding shown in Section IV of this report as prior year finding 2022-003. Statistical sampling was not used in making sample selections. Corrective Action Plan: Richland Community College adjusted our internal procedures to send enrollment reporting files on a monthly basis instead of a semester basis during the Fall 2022 semester; however, issues still persist. The campus Registrar has routinely worked with the Administrative Information Systems (AIS) Department and the National Student Clearinghouse to identify the issues related to enrollment reporting. The responsible parties listed below will conduct a review of current enrollment reporting workflows to ensure consistent and timely updates. The responsible parties listed below will explore improvements in automation through the utilization of the National Student Clearinghouse and a campus-wise transition to the Jenzabar One platform to assist with timeliness and accuracy of reporting. Due to transition in staffing, the responsible parties listed below will provide targeted training on NSLDS enrollment reporting requirements, including the expectations of timeliness and accuracy. The responsible parties will develop a secondary review to identify missed or delayed updates and take corrective action promptly. Responsible Party for Corrective Action Plan: Director of Financial Aid and Veteran Affairs, Executive Dean of Student Success (until the role of Director of Admission and Registration is filled), Administrative Information Systems (AIS) Implementation Date for Correction Action Plan: As soon as possible since enrollment reporting is completed on a monthly basis.

2023-006 - Student Financial Aid Cluster - (a) Federal Supplemental Educational Opportunity Grants (b) Federal Work Study Program (c) Federal Pell Grant Program (d) Federal Direct Student Loans, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2023 Condition: During our testing of twenty individuals receiving federal work study, we noted one individual (5%) was paid an incorrect pay rate for federal work study hours worked. We consider this condition to be an instance of noncompliance relating to the Activities Allowed or Unallowed compliance requirement and is not a repeat finding. Statistical sampling was not used in making sample selections. Corrective Action Plan: When rates of pay change, and Employee Authorization document is submitted through a series of individuals (Director of Financial Aid, Supervisor, VP, VP of Financial Services, Human Resources & the President) and signed/approved. This document is then received by the Payroll Coordinator. After payroll is completed, the VP of Financial Services thoroughly reviews all payroll items and verifies rate changes have occurred. Responsible Party for Corrective Action Plan: Payroll Coordinator & VP of Financial Services Implementation Date for Correction Action Plan: Implemented January 2023.

Condition Found: In accordance with the loan terms, Peabody Place is required to annually fund a capital asset replacement reserve of $100,000, debt payment reserve in the amount of $111,696, and a resident asset depletion reserve and facility fill reserve each for $50,000. The Organization did not make the required annual deposits into the debt payment reserve, capital asset replacement reserve, resident asset depletion reserve and the facility fill reserve. Individual(s) Responsible for Corrective Action: Lynda P. Goldthwaite, Executive Director and Stacey Matott, Director of Finance Planned Corrective Action: Peabody Place sought a debt work out in 2025 that would allow for deferral of required deposits for six months until January 1, 2026. Anticipated Completion Date: December 31, 2024

Benjie Read CFO and Felecia Read Staff Accountant, will update the policies and procedures for all program reports and the review of each before submission. We will also negotiate with the grantors for appropriate time frams as some of these time frames are impossible for us to meet in an accurate manner. These policies will be done within 90 days of audit completion.

2023-004 - (Noncompliance) Completion of Single Audit Federal Program: Assistance Listing #14.228 Community Development Block Grants/State’s Program and Non-Entitlement Grants in Hawaii, U.S. Department of Housing and Urban Development, Passed Through Pennsylvania Department of Community and Economic Development and Pennsylvania Emergency Management Agency, Pass-Through Entity Identifying Numbers: C000073444, C000075689, C000082264, C000086078, and PEMA-2022-007 Assistance Listing #21.027, COVID-19 - Coronavirus State and Local Fiscal Recovery Funds, U.S. Department of Treasury, Passed Through Pennsylvania Department of Community and Economic Development, Pass-Through Entity Identifying Number: not available Assistance Listing #21.023, COVID-19 Emergency Rental Assistance Program, U.S. Department of Treasury, Passed Through Pennsylvania Department of Human Services, Pass-Through Entity Identifying Number: not available Assistance Listing #93.658, Foster Care - Title IV-E, U.S. Department of Treasury, Passed Through Pennsylvania Department of Human Services, Pass-Through Entity Identifying Number: not available Condition/Context: The County’s December 31, 2022 Single Audit was not completed and submitted within the required time period. Recommendation: We recommend that as the County gets up and running on the new accounting system, the audit be prioritized in future periods. Views of Responsible Officials and Planned Corrective Actions: The County is working with its fee accountant and external auditors to ensure a timely filing of the Single Audit going forward. Individual Responsible: Finance Department Timeline for corrective action: By December 31, 2026

Finding 2023-009 AL No.: 93.658 Program Title: Foster Care – Title IV-E Federal Agency: U.S. Department of Health and Human Services Pass-through Agencies: Wisconsin Department of Children and Families Award Number/Year 3413, 3561, 3681, 3645 / 2023 Condition/Context: There were 13 reports for submission for the County. Three reports were selected for testing. There was no documentation of a review control by someone independent of the preparer for all three reports tested. Our sample was not statistically valid. Management's Response: The finance department staff will work with departmental management and fiscal staff to review current documented and/or undocumented procedures, adopting and/or updating written procedures as necessary to ensure: • All assembled reports (typically prepared by fiscal staff) are reviewed for completeness and accuracy by independent personnel (typically a department head.) • Reports be submitted on a timely basis. • Reconciliation of data on each submitted reports to the financial statements. • Reconciliation of grant period-to-date cumulative data totals to the financial statements. Additionally, the county finance team will assemble and maintain a centralized file for all county grants, requiring grant administrators (fiscal staff or department heads) to report completion dates for mandated report filings. The county finance team will also maintain a centralized data file for all county grant filings and grant documents.

Finding 2023-009 – Completion and Submission of Annual Single Audit - Significant Deficiency/Noncompliance Condition/Context: The County's Single Audit and reporting package was delayed for the year-ended December 31, 2022, as a result of turnover within its Budget and Finance Office, beyond the nine month due date. Corrective Action: The Controller’s office has new procedures in place to help facilitate the year end closing process so the audit can be completed in a timely manner. Responsible for Implementing Corrective Action: Controller’s Office Anticipated Completion Date: We anticipate this to be completed in coordination with the 2026 audit.

Finding No.: 2023-008 Recommendation The College acknowledges the finding and is committed to addressing the gaps identified in enrollment reporting to the National Student Loan Data System (NSLDS). We recognize that accurate and timely reporting at both the Campus Level and Program Level is critical to maintaining compliance with U.S. Department of Education Title IV requirements and ensuring that students’ federal financial aid records are correctly reflected. Response 1. The College will retain the FAO as the lead unit responsible for NSLDS enrollment reporting, in alignment with Title IV compliance functions. However, the College will strengthen interdepartmental collaboration by establishing a formal partnership with the Registrar’s Office, which maintains the official record of enrollment data. 2. A shared workflow and communication protocol between the FAO and Registrar’s Office will be developed to ensure timely, accurate updates of both campus-level and program-level data. The Registrar’s Office will be responsible for updating student enrollment data, which serves as the source data for NSLDS reporting. The FAO will extract and upload these reports via the Enrollment Reporting Roster (ERR) on the NSLDS Professional Access portal. 3. The College will implement internal controls to track and verify changes in student enrollment status, program information, and key data elements. These controls will include but by no means limited to: a. A monthly reconciliation process between SIS data and NSLDS records. b. Use of exception reports to flag and resolve inconsistencies or delays. c. Documentation of all update logs for audit purposes. Periodic reviews will be conducted at least once per term to assess the accuracy and completeness of enrollment reporting. Any discrepancies will be promptly addressed and procedures updated as necessary to prevent recurrence. Relevant staff in both the FAO and Registrar’s Office will receive regular training on NSLDS reporting requirements, including proper use of record types (Campus vs. Program Level), enrollment status codes, and certification timelines. Training will emphasize the implications of noncompliance and best practices for accurate reporting. Training logs will be maintained by both the FAO and Registrar’s Office to support accountability and audit-readiness. Contact: VPEMSS Completion Date: September 30, 2025

Finding 2023-07 - Special Tests and Provisions: Disbursements to or on Behalf of Students Recommendation The College should implement a comprehensive communication strategy to ensure that all students receive clear and timely notifications regarding their Title IV funds. This should include the development of award letter of college financing plans that outline the amount and type of funds, as well as the disbursement schedule. Additionally, the College should establish a monitoring system to ensure that credit balances are disbursed within the required 14-day time frame to maintain compliance with federal records. Response The College acknowledges the finding and has initiated a process to address them. A formal request has been submitted to the SIS program developer for the implementation of a notification feature. The SIS vendor has confirmed development will be completed by July 1, 2025. This feature will ensure that students receive email notifications when they are awarded and reimbursed for any overpayments. Furthermore, we will establish an enhanced level of monitoring to ensure that credit balances are disbursed within the designated 14-day timeframe. Contact: Comptroller Completion Date: September 30, 2025

Finding 2023-06 – Special Tests and Provisions: Gramm-Leach-Bliley Act–Student Information Security Recommendation The College should develop and implement a comprehensive GLBA information security program that includes risk assessments, safeguards, and regular testing and monitoring of the effectiveness of these safeguards. A qualified individual with the necessary expertise and authority to oversee the GLBA information security program should also be designated. Provide training to relevant staff on GLBA requirements and the importance of information security. Conduct periodic reviews and updates of the information security program to ensure ongoing compliance with GLBA requirements. Response The college acknowledges the finding and will strengthen its student information security by implementing the following: 1) Designate a qualified Information Security Officer from within the IT Division or recruit externally if internal capacity is limited. 2) Develop a GLBA compliance program that includes: • Annual risk assessments • Implementation of administrative, technical, and physical safeguards • Staff training on data privacy • Annual testing of the security protocols Contact: Vice President for Institutional Effectiveness & Quality Assurance (VPIEQA) Completion Date: September 30, 2025

Finding No.: 2023-005 Recommendation The College should enhance training programs for staff involved in the verification process to ensure they are fully aware of the requirements and procedures. Establish robust internal controls and review mechanisms to ensure that verification worksheets are completed accurately and consistently with ISIRs. Implement a tracking system to ensure that all required corrections to ISIRs are performed in a timely manner. Response The College acknowledges the audit finding regarding verification errors, including the incorrect application of verification tracking groups, missing documentation, discrepancies between verification worksheets and ISIRs, and failure to make required corrections. In response, the Financial Aid Office (FAO) is committed to strengthening its verification procedures to ensure full compliance with federal regulations and to protect the integrity of Title IV funds. To this end, the College will implement the following corrective actions: 1. Policy and Procedure Enhancement a. The FAO will develop and implement a formal Standard Operating Procedure (SOP) for the verification process, revise and update all existing verification worksheet forms. This SOP will include: • Clear guidelines for identifying and applying the correct verification tracking groups (e.g., V1, V4, V5). • Procedures for resolving discrepancies between verification worksheets and ISIRs prior to award disbursement. • Steps for submitting timely and accurate ISIR corrections, as required. • A documentation checklist to ensure all required verification forms and statements of educational purpose are collected and properly stored. 2. Policy and Procedure Enhancement a. To ensure consistent understanding and application of federal verification rules, FAO staff across all campuses will: • Complete mandatory annual training sessions on verification policies, ISIR review, and regularly read updates on the Federal Student Aid (FSA) Knowledge Center. • Participate in internal refresher workshops focused on hands-on case processing and error prevention. • Complete relevant modules from the Federal Student Aid (FSA) training site, including those on verification tracking groups and identity verification requirements. 3. Verification Quality Control Protocol a. The FAO will implement a structured quality control protocol for verification, including: • A two-person verification review system in which one staff member processes the file and another independently reviews it for accuracy and completeness. • Use of a standardized review checklist to ensure all required documents match the ISIR and that any discrepancies are properly resolved and documented. • A log of all verification actions, including corrections submitted to FAFSA Processing System (FPS) and updates made in the student’s file, to support audit readiness. 4. Oversight and Accountability a. The Director of the Financial Aid Office (FAO) will be responsible for overseeing verification compliance and ensuring corrective actions are implemented effectively. This includes: • Monitoring the accuracy of verification tracking group assignments and documentation across all campuses. • Tracking the completion of required training for all FAO staff. • Conducting quarterly file audits to verify ongoing compliance with federal verification standards. • Reporting findings and corrective actions quarterly to the VPEMSS). Contact: VPEMSS Completion Date - September 30, 2025

Finding No.: 2023-004 Recommendation The College should establish a systematic process for reviewing and updating the origination records prior to submission to COD System. Response The College acknowledges the audit finding regarding the use of outdated cost of attendance (COA) figures and the uniform application of full-time enrollment status in COD origination records for the 2022–2023 academic year. In response, the Financial Aid Office (FAO) is committed to strengthening its policies and procedures to ensure accuracy, compliance, and proper stewardship of the Title IV funds. To this end, the College will implement the following corrective actions: 1. Policy and Procedure Enhancement a. The FAO will develop and implement a formal Standard Operating Procedure (SOP) for COD reporting. This SOP will include: • A COA validation checklist to ensure the correct, current year COA from the approved financial aid handbook is applied. • The college has continuously considered the applicants’ enrollment status (full-time, ¾-time, half-time, or less-than-half-time) when determining the cost of attendance and awards but publishes only one cost of attendance for full time for the purpose of illustration. Hence, the college will start publishing all COA for all enrollment categories in the student financial aid handbook as a published guideline for awarding • A timeline that aligns record origination with student registration/enrollment confirmation to minimize errors and fully utilize the published Pell Recalculation Date (PRD) in the student financial aid handbook b. The SOP will be reviewed annually. 2. Staff Training and Certification a. FAO staff will participate in mandatory annual internal training and refresher workshops on the EDExpress system, COD reporting procedures, and Title IV compliance. The first round of enhanced training will be completed by August 30, 2025]. Staff will also complete Federal Student Aid (FSA) training modules related to COD and verification processes to ensure understanding of federal expectations and system updates. 3. Manual Data Verification Protocol • The Financial Aid Office (FAO) will implement a structured manual data verification protocol to ensure accuracy when transferring information from the Student Information System (SIS) to EDExpress. This protocol will include: Use of pre-submission checklists to verify each student’s cost of attendance (COA), enrollment status, and other required data fields against the official records in the SIS. • Designated FAO staff will perform a two-tiered review process, where one staff member enters data and another independently verifies accuracy prior to COD submission. • Maintenance of record logs for each batch of COD submissions, documenting the review steps taken and any discrepancies corrected before submission. 4. Oversight and Accountability a. The Director of the Financial Aid Office (FAO) will be responsible for monitoring adherence to COD reporting requirements to ensure accuracy and compliance. This includes tracking staff training completion related to EDExpress and Title IV regulations, conducting quarterly internal reviews of origination and disbursement records, and verifying the correct use of current cost of attendance figures and enrollment status classifications. The Director will document findings, implement corrective actions as needed, and provide quarterly progress reports to the Vice President for Enrollment Management and Student Services (VPEMSS). Contact: VPEMSS Completion Date: September 30, 2025

Single Audit Report Submission Federal Agency: Various Federal Program Name: Research and Development Cluster, Education Stabilization Fund, Supplemental Nutritional Assistance Program (SNAP), Federal Supplemental Educational Opportunity Grant Program, Federal Pell Grant Program; Federal Direct Student Loans; Federal Work Study Program, Federal Perkins Loan Program Assistance Listing Number: Various Recommendation: We recommend the University implement and maintain an effective system of internal controls over timely submission of the single audit reporting package. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: As a result of staffing turnover in the Finance area, the University engaged consulting support to assist in readying for financial statementpreparation and the audit of fiscal years ending 6.30.23 and 6.30.24, with oversight from the University management. The University will develop a fiscal year‐end close process that includes submission of the single audit report. Name(s) of the contact person(s) responsible for corrective action: Melissa Hicks, Controller Planned completion date for corrective action plan: December 31, 2025