NORTHWEST UNIVERSITY Corrective Action Plan For the Year Ended May 31, 2026 Finding Number 2026-001: Significant deficiency in internal controls over compliance with verification requirements. Significant deficiency in internal controls over compliance with verification requirements: For the two students who received Pell grants of five total students selected for verification testing, verification status was not correctly coded in Common Origination and Disbursement (COD) system. This was the result of an issue in PFAIDS in which verification status code is only reporting for Pell recipients who were selected for verification by the FPS, not for students selected by the school. SFS has reviewed the scope of this issue and determined that these were the only two Pell recipients who were school-selected and verified, and the Verification Status Code for both students has been updated in COD as of 8/11. Contact Person(s): Cynthia Kennedy, Director of SFS; Ryan Porter, CFO; and Bernie Rundquist, Controller Explanation and specific reasons for disagreement with the audit finding or that corrective action is not required (if applicable): N/A Corrective action planned: The compliance issue was the result of a reporting error within the University’s current financial aid management system. Student Financial Services (SFS) is transitioning to a new financial aid management system in October 2026 and has ensured that the verification status flows correctly through COD reporting. The University goes live with the new system for the 2027-2028 award year. For the remainder of the current 2026-2027 reporting cycle, SFS has implemented a regularly scheduled manual review of COD reporting for students who are school-selected for verification to ensure correct reporting. This review will continue through the duration of processing in the current system. Anticipated completion date: October 2026