Finding No. 2025-001 – Reporting – Compliance and Internal Control (Significant Deficiency) Corrective Action Plan: The discrepancies identified during the current audit were determined to be timing-related issues associated with the transition and implementation of revised disbursement reporting and reconciliation procedures in order to address a similar compliance finding that was identified in the 2024 Single Audit. These discrepancies occurred while updated controls and monitoring processes were being fully integrated into daily operations. During the prior audit conducted on April 6, 2025, auditors identified discrepancies between institutional disbursement dates and the dates reflected in the Common Origination and Disbursement (COD) system for the 2023-2024 award year. Immediately upon identification of the issue in the 2024 Single Audit, the institution implemented corrective measures to ensure that institutional disbursement dates matched Common Origination and Disbursement (COD) reporting. Since May 2025, the following corrective actions have already been fully implemented: 1. Revised and strengthened reconciliation procedures between the Student Information System and COD to ensure accurate disbursement date reporting. 2. Implemented secondary review controls prior to transmitting disbursement records to COD. 3. Established ongoing internal monitoring and periodic reconciliation reviews to identify and resolve discrepancies promptly. 4. Conducted additional staff training regarding Title IV disbursement reporting requirements and COD reconciliation procedures. 5. Assigned designated personnel responsibility for continuous oversight and verification of disbursement date accuracy. 6. Corrected disbursement reporting processes to ensure institutional records align with COD reporting requirements moving forward. Anticipated Completion Date: Since May 2025, the institution has taken all necessary measures to address and correct the identified issues on a prospective basis. All corrective actions outlined above are currently in place and operational. The institution continues to monitor disbursement reporting and reconciliation processes to ensure ongoing compliance with federal Title IV regulations and accurate reporting to COD. Person(s) Responsible for Corrective Action: Beatriz Novoa-Cruz Associate Vice President of Enrollment 718-429-6600 ext. 114