Corrective Action Plan for Fiscal Year Ending December 31, 2025 Institution: ICOHS College OPE ID #: 04265500 Audit Period: January 1 – December 31, 2025 Date of CAP Submission: 09/24/2026 Finding 2025-001 – Reporting (COD Date Disbursed) Programs: Student Financial Assistance Cluster – Federal Direct Loans (84.268), Federal Pell Grant (84.063) Type of finding: Significant deficiency in internal control over compliance; noncompliance Questioned costs: None Cause. Under Heightened Cash Monitoring 1 (HCM1), the College credits Title IV aid to student accounts using institutional funds before requesting reimbursement from the Department of Education. The College interpreted the COD Date Disbursed as the later date associated with COD processing or federal reimbursement rather than the date the funds were credited to the student’s ledger account. The College also lacked a formal reconciliation between the student ledger and COD that would have detected the difference. Corrective Action 1. Immediate change in reporting practice Effective September 28, 2026, the Financial Aid Office will report the COD Date Disbursed as the date Title IV funds are credited to the student’s ledger account, including when institutional funds are used in advance of reimbursement under HCM1. Disbursement records will be reported to COD within the Department’s required timeframe. 2. Updated written disbursement procedure The College will update its written Title IV disbursement procedure to define the disbursement date as the date Title IV funds are credited to the student’s account or paid directly to the student or parent (34 CFR 668.164(a)), and to distinguish anticipated or estimated aid entries from actual disbursements. The procedure will identify who prepares, reviews and approves each step. 3. Staff training Business Office and Financial Aid staff responsible for Title IV disbursements and COD reporting will be trained on the revised procedure, including the treatment of institutional funds used to make Title IV disbursements under HCM1. Attendance will be documented. 4. COD-to-ledger reconciliation for every disbursement cycle For each disbursement cycle, the Financial Aid Office will complete a reconciliation (maintained as the College’s Title IV disbursement tracker) comparing: • Student name and ID • Title IV fund type • Disbursement amount • Student ledger credit date • COD Date Disbursed • COD status (accepted / rejected / pending) Any difference is researched and corrected in COD before the reconciliation is marked complete. The tracker documents each exception, its cause and the correction made. 5. Independent review and sign-off A Business Office staff member who did not prepare the disbursement will review each completed reconciliation and document approval with name and date. Exceptions will be resolved before sign-off. 6. Lookback review of 2025 and 2026 disbursements The Financial Aid Office and Business Office will compare the COD Date Disbursed with the ledger credit date for all Title IV disbursements made from January 1, 2025 through the effective date of the corrected practice. Results will be documented by student and disbursement. 7. Correction of prior records in COD Discrepancies identified in the lookback review will be corrected in COD to reflect the date funds were credited to the student’s account, to the extent permitted by COD and in accordance with Department of Education requirements. Any records that cannot be corrected will be documented with the reason. 8. Monitoring and evidence retention Tim Tandio (Operations & Compliance) will review the reconciliations and tracker monthly and report results to the Executive Director quarterly. Reconciliations, sign-offs, the tracker, lookback results and training records will be retained for audit and program review. Timeline Action Responsible Target completion 1. Report COD Date Disbursed as the ledger credit date Financial Aid Office Effective September 28, 2026 2. Update written Title IV disbursement procedure Financial Aid Office / Business Office; approved by Tim Tandio October 15, 2026 3. Staff training on revised procedure Tim Tandio October 15, 2026 4–5. COD-to-ledger reconciliation and independent review Financial Aid Office (prepare); Business Office (review) First disbursement cycle after September 28, 2026, and every cycle thereafter 6. Lookback review of 2025 and 2026 disbursements Financial Aid Office / Business Office Review complete by November 30, 2026 7. Correct discrepancies in COD Financial Aid Office Submitted by December 31, 2026, to the extent permitted by COD 8. Monitoring and evidence retention Tim Tandio; Executive Director Monthly and quarterly, ongoing Prior Year findings: Finding 2024-001 – Special Tests and Provisions – Enrollment Reporting Status: Corrected Corrective action was implemented to strengthen the College’s enrollment reporting procedures, including monitoring and timely reporting of enrollment status changes to NSLDS. Based on the results of the 2025 audit, no findings related to enrollment reporting were identified. Finding 2024-002 – Special Tests and Provisions – Return of Title IV Funds Status: Corrected Corrective action was implemented to strengthen the monitoring and timely processing of Return of Title IV Funds (R2T4), including additional oversight of the third-party service provider and internal monitoring procedures. Based on the results of the 2025 audit, no findings related to the timely return of Title IV funds were identified.