Summit Academy OICHigher Education

2025 – 001: Special Testing - NSLDS Federal Agency: Department of Education Federal Program Title: Student Financial Aid Cluster – Various Assistance Listing Numbers: Various Federal Award Identification Number and Year: Various Pass-Through Agency: N/A Pass-Through Number: N/A Award Period: July 1, 2024, through June 30, 2025 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.309(b), states schools must have some arrangement to report student enrollment data to the National Student Loan Data System (NSLDS) through an enrollment roster file. The school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date as well as program enrollment effective date. Changes to a students' status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. Condition: During our testing, we noted 3 out of the 60 students' enrollment effective report to NSLDS did not match the Academy's records. Questioned costs: None Context: During our testing, it was noted the Academy does not have a process in place to ensure timeliness and accuracy of NSLDS reporting. Cause: The Academy did not have a process in place to ensure the effective dates reported matched the Academy’s records. Effect: The enrollment effective date reported to NSLDS is used to determine when the student’s grace period should begin. By not reporting an incorrect effective date, the grace period begin date for the student will be incorrect. In addition, the Academy did not comply with Department of Education (ED) regulations by reporting student enrollment status changes timely. Repeat finding: Yes - see 2024-002 Recommendation: We recommend the Academy reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to put a process in place to ensure the student status changes are being reported timely. Views of responsible officials: There is no disagreement with the audit finding.

2025 – 002: Internal Controls – Common Origination and Disbursement Reporting Federal Agency: Department of Education Federal Program Title: Student Financial Aid Cluster – Various Assistance Listing Numbers: Various Federal Award Identification Number and Year: Various Pass-Through Agency: N/A Pass-Through Number: N/A Award Period: July 1, 2024, through June 30, 2025 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or specific requirement: The 2 CFR Section 200.303 require that nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal Statues, regulations, and the term and conditions of the federal awards. Condition: During our testing of Common Origination and Disbursement (COD), we noted there was a review process implemented; however, there was no process in place to retain the review being performed as to provide evidence to ensure the controls are being performed effectively. Questioned costs: None Context: During our testing, it was noted the Academy does not have a process in place to ensure controls are being performed effectively. Cause: The Academy did not have a process in place to ensure controls implemented are being performed effectively. Effect: There is no way to determine who was involved in the process should an error be present. Repeat finding: Yes, see 2024-003 Recommendation: We recommend the Academy reevaluate its procedures and review policies surrounding controls implemented for Title IV Aid. Views of responsible officials: There is no disagreement with the audit finding.

2025 – 003: Eligibility - Pell Federal Agency: Department of Education Federal Program Title: Student Financial Aid Cluster – Various Assistance Listing Numbers: Various Federal Award Identification Number and Year: Various Pass-Through Agency: N/A Pass-Through Number: N/A Award Period: July 1, 2024, through June 30, 2025 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or specific requirement: The U.S. Department of Education offers financial aid to students under two programs: 1. Pell Grant program which provides grants to eligible students enrolled in eligible undergraduate programs and certain post-baccalaureate teacher certificate programs and 2. FSEOG program which provides grants to eligible undergraduate students with priority given to Pell recipients who have the lowest expected family contributions. Condition: The Pell Grant Program has maximum and minimum Pell grant awards established by statue and should be awarded based on the student's needs. During our testing, we noted that one of 40 students tested was under awarded Pell funds. Questioned costs: $432 Context: During our testing, it was noted the Academy's internal control process was not able to detect the under awarding of the Pell. Cause: The Academy did not have a process in place to ensure students were awarded Pell properly based on their SAI. Effect: The Academy is not in compliance with Department of Education requirements for awarding Pell. Repeat finding: No Recommendation: We recommend the Academy implement a process to ensure student is being properly awarded based on their SAI and enrollment status. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: Department of Education Federal Program Title: Student Financial Aid Cluster – Various Assistance Listing Numbers: Various Federal Award Identification Number and Year: Various Pass-Through Agency: N/A Pass-Through Number: N/A Award Period: July 1, 2024, through June 30, 2025 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.22(h)(4)(ii) states within 30 days of the date of the institution's determination that the student withdrew, an institution must send a notice to any student who owes a title IV, HEA grant overpayment as a result of the student's withdrawal from the institution in order to recover the overpayment in accordance with paragraph (h)(4)(i) of this section. Additionally, The Code of Federal Regulations, 34 CFR 668.22(f)(2)(i), states that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period. Condition: During our testing of Return of Title IV funds, we noted 3 of the 10 students did not have funds returned to COD within the required 45-day period. Furthermore, we noted 1 of the 10 students tested has used an incorrect percentage attended causing the Academy to incorrectly calculate the return of Title IV funds. Lastly, we noted 1 of the 10 students did not have their return of funds calculated within 45 day period. Questioned costs: $25 Context: During our testing, it was noted the Academy does not have a process in place to ensure timeliness and accuracy of Return of Title IV calculations. Cause: The Academy did not have a process in place to ensure timely return of funds to COD. Additionally, the Academy used the incorrect number of break days thus the students percentage of days attended was miscalculated. Effect: The Academy is not completing accurate R2T4 calculations and following timely return of funds as defined by the regulations. Repeat finding: No Recommendation: We recommend the Academy reevaluate its policies around accurate and timely R2T4 calculations. Views of responsible officials: There is no disagreement with the audit finding.

2025 – 005: Special Testing - Credit Balances Federal Agency: Department of Education Federal Program Title: Student Financial Aid Cluster – Various Assistance Listing Numbers: Various Federal Award Identification Number and Year: Various Pass-Through Agency: N/A Pass-Through Number: N/A Award Period: July 1, 2024, through June 30, 2025 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.164(h)(1), A title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but no later than (i) Fourteen (14) days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or (ii) Fourteen (14) days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period. Condition: During our testing, we noted 3 out of the 5 students tested had credit balances that were not returned to the student or parent within 14 days of the credit balance occurring. Questioned costs: None Context: During our testing, it was noted the Academy does not have a process in place to ensure timeliness of funds being returned to the student based on the regulations set forth by the Department of Education. Cause: The Academy did not have a process in place to ensure the refunds are completed timely. Effect: The Academy is not in compliance with Department of Education requirements that state the credit balance must be returned no later than 14 days. Repeat finding: No Recommendation: We recommend that the Academy implement a process to ensure credit balances are returned timely based on the regulations set forth by the Department of Education. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: Department of Education Federal Program Title: Student Financial Aid Cluster – Various Assistance Listing Numbers: Various Federal Award Identification Number and Year: Various Pass-Through Agency: N/A Pass-Through Number: N/A Award Period: July 1, 2023, through June 30, 2024 Type of Finding: * Significant Deficiency in Internal Control Over Compliance * Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.25(e) states that an institution must notify the Department of Education by way of the ECAR within 10 days of a change in position of an official at the Institution. Condition: During our testing, we noted the Chief Operating Officer and Financial Aid Manager was not reported timely to the Department of Education. Questioned costs: None Context: During our testing, we noted the Chief Operating Officer and Financial Aid Manager had a change in position and it was not updated within 10 days. Cause: There was not a formal process in place to ensure ECAR updates were made timely to ensure the Academy is in compliance with the regulations. Effect: The Academy is not in compliance with Department of Education requirements that state the ECAR must have accurately reported information. Repeat finding: No Recommendation: We recommend the Academy review its reporting procedures surrounding updating the ECAR to ensure reporting is accurate and completed. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: Department of Education Federal Program Title: Student Financial Aid Cluster – Various Assistance Listing Numbers: Various Federal Award Identification Number and Year: Various Pass-Through Agency: N/A Pass-Through Number: N/A Award Period: July 1, 2023, through June 30, 2024 Type of Finding: * Significant Deficiency in Internal Control Over Compliance * Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.309(b), states schools must have some arrangement to report student enrollment data to the National Student Loan Data System (NSLDS) through an enrollment roster file. The school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date as well as program enrollment effective date. Changes to a students’ status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. Condition: During our testing, we noted 15 out of the 40 students’ enrollment effective report to NSLDS did not match the Academy’s records. Furthermore, we noted 22 out of the 40 students did not have their enrollment certified every 60 days. Lastly, we noted 1 out of 40 students change in status was not reported in a timely manner. Questioned costs: None Context: During our testing, it was noted the Academy does not have a process in place to ensure timeliness and accuracy of NSLDS reporting. Cause: The Academy did not have a process in place to ensure the effective dates reported matched the University’s records as well as that these changes were reported timely. Effect: The enrollment effective date reported to NSLDS is used to determine when the student’s grace period should begin. By not reporting an incorrect effective date, the grace period begin date for the student will be incorrect. In addition, the Academy did not comply with Department of Education (ED) regulations by reporting student enrollment status changes timely. Repeat finding: No Recommendation: We recommend the Academy reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to put a process in place to ensure the student status changes are being reported timely. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: Department of Education Federal Program Title: Student Financial Aid Cluster – Various Assistance Listing Numbers: Various Federal Award Identification Number and Year: Various Pass-Through Agency: N/A Pass-Through Number: N/A Award Period: July 1, 2023, through June 30, 2024 Type of Finding: * Significant Deficiency in Internal Control Over Compliance Criteria or specific requirement: The 2 CFR Section 200.303 require that nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal Statues, regulations, and the term and conditions of the federal awards. Condition: During our testing of Common Origination and Disbursement (COD), Return of Title IV Funds (R2T4) and National Student Loan Data System (NSLDS), we noted there was a review process implemented; however, there was no process in place to retain the review being performed as to provide evidence to ensure the controls are being performed effectively. Questioned costs: None Context: During our testing, it was noted the Academy does not have a process in place to ensure controls are being performed effectively. Cause: The Academy did not have a process in place to ensure controls implemented are being performed effectively. Effect: There is no way to determine who was involved in the process should an error be present. Repeat finding: No Recommendation: We recommend the Academy reevaluate its procedures and review policies surrounding controls implemented for Title IV Aid. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: Department of Education Federal Program Title: Student Financial Aid Cluster – Various Assistance Listing Numbers: Various Federal Award Identification Number and Year: Various Pass-Through Agency: N/A Pass-Through Number: N/A Award Period: July 1, 2023, through June 30, 2024 Type of Finding: * Significant Deficiency in Internal Control Over Compliance * Other Matters Criteria or specific requirement: The Gramm-Leach-Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). Institutions are required to develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts. The regulations require the written information security program to include nine elements for institutions with 5,000 or more customers, (16 CFR 314.3(a)). The written information security program (WISP) for institutions with fewer than 5,000 customers must address seven elements (16 CFR 314.3(a) and 16 CFR 314.6). The elements that an institution must address in its written information security program are at 16 CFR 314.4. At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d)). Condition: During our testing, we noted the Academy did not implement multi-factor authentication (MFA) for anyone accessing customer information on the institution’s system during the year under audit. Questioned costs: None Context: Implement MFA is required based on the GLBA requirements that were applicable beginning on June 9, 2023 and was not implemented during the year under audit. Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure compliance. Effect: Student personal information could be vulnerable. Repeat finding: Yes Recommendation: We recommend the Academy implement MFA for individuals that access sensitive information per GLBA requirements. Views of responsible officials: There is no disagreement with the audit finding.

2023 – 001: Gramm-Leach-Bliley Act (GLBA) and Information Security Federal Agency: Department of Education Federal Program Title: Student Financial Aid Cluster – Various Assistance Listing Numbers: Various Federal Award Identification Number and Year: Various Pass-Through Agency: N/A Pass-Through Number: N/A Award Period: July 1, 2022, through June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or specific requirement: The Gramm-Leach-Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). Institutions are required to develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts. The regulations require the written information security program to include nine elements for institutions with 5,000 or more customers, (16 CFR 314.3(a)). The written information security program (WISP) for institutions with fewer than 5,000 customers must address seven elements (16 CFR 314.3(a) and 16 CFR 314.6). The elements that an institution must address in its written information security program are at 16 CFR 314.4. At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d)). Condition: During our testing, we noted several steps missing from the Written Information Security Program (WISP). Questioned costs: None Context: These new GLBA requirements were applicable beginning on June 9, 2023 and there were several elements missing from their WISP. Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure compliance. Effect: Student personal information could be vulnerable. Repeat finding: No Recommendation: We recommend that the Academy review the updated GLBA requirements and ensure their WISP includes all required elements. Views of responsible officials: There is no disagreement with the audit finding.

2022 ? 002: NSLDS Reporting Federal Agency: Department of Education Federal Program Title: Student Financial Aid Cluster ? Various Assistance Listing Numbers: Various Award Period: July 1, 2021, through June 30, 2022 Type of Finding: Significant Deficiency in Internal Control Over Compliance Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.309(b), states schools must have some arrangement to report student enrollment data to NSLDS through an enrollment roster file. The school is required to report changes in the student?s enrollment status, the effective date of the status, and an anticipated completion date. Also, the Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. Condition: During our testing, we noted 4 of the 40 students were not reported of a status change within 30 days. Furthermore, we noted 4 of the 40 students enrollment was not verified every 60 days. Lastly, we noted 3 out of the 4 students effective enrollment date reported to NSLDS on the campus level did not match the program level. Questioned costs: None Context: During our testing, it was noted the Academy did not properly report the change in status within 30 days or certify enrollment every 60 days of the determination. Cause: The Academy did not determine status changes within a timely manner due to extenuating circumstance. Effect: The enrollment effective date reported to NSLDS is used to determine when the student?s grace period should begin. By reporting an incorrect effective date, the grace period begin date for the student will be incorrect. The Academy also did not comply with Department of Education (ED) regulations requiring reporting student enrollment status change to NSLDS within 60 days. Repeat finding: Yes ? 2021-006 Recommendation: We recommend the Academy reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to ensure timely reporting as well as put a process in place to ensure the enrollment effective date reported to NSLDS is aligning with the organization?s last date of attendance. Views of responsible officials: There is no disagreement with the audit finding.

2022 ? 003: COD Reporting Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Numbers: Various Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Criteria or specific requirement: The Department of Education requires the Academy to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system. Condition: During our testing of 40 disbursements, we noted the disbursement date per COD did not match the date disbursed per the student account for 2 disbursements. Questioned costs: None Context: During our testing, it was noted the Academy did not properly follow the process to ensure disbursements are accurately reported to COD. Cause: The Academy did not follow the procedure to meet the requirement that the disbursement date and balance per the student?s account must match the disbursement date and balance in COD. Effect: Disbursements are not reported correctly to COD which can cause funds to be unavailable or drawn down incorrectly. Repeat finding: Yes ? 2021-008 Recommendation: We recommend the Academy evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. Views of responsible officials: There is no disagreement with the audit finding.

2022 ? 004: Reporting Federal Agency: Department of Education Federal Program Title: COVID-19 HEERF Student Aid Portion AND COVID-19 HEERF Institutional Portion Assistance Listing Number: 84.425E and 84.425F Federal Award Identification Number and Year: P425E201204 and P425F201455 Award Period: July 1, 2021, through June 30, 2022 Type of Finding: Significant Deficiency in Internal Control Over Compliance Other Matters Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations and program compliance requirements. The initial reporting for this grant requires the report to be submitted to the Institution?s website within 30 days of the signed Certification Agreement or 30 days after the electronic announcement dated May 6, whichever is later. Institutions were then required to update their websites every 45 days after initial upload. This was changed to quarterly on August 31, 2020. Condition: During our testing of the reporting process, we noted that documentation to support some of the amounts reported for student reports was not retained. Additionally, it was noted there was no documentation of the review/approval process during the first three quarters, and that no support of when the reports were submitted to the website or Emergency Student Funds were retained, preventing us from testing if they were submitted timely. Questioned costs: None Context: A robust tracking system was not employed for all the various reporting requirements including documentation of review and maintenance of records or recorded numbers. Cause: Summit Academy OIC did not have a robust system in place to document and track reporting requirements. Effect: No evidence to support that the reports were completed on time. Repeat finding: Yes ? 2021-001 Recommendation: We recommend the Organization establish a system to track due dates of reports to ensure timely submission and retain documents to support the submission and accuracy of the reports. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: Department of Education Federal Program Title: COVID-19 HEERF Student Aid Portion AND COVID-19 HEERF Institutional Portion Assistance Living Number: 84.425E and 84.425F Award Period: July 1, 2020, through June 30, 2021 Type of Finding: Significant Deficiency in Internal Control Over Compliance Other Matters Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations and program compliance requirements. The initial reporting for this grant requires the report to be submitted to the Institution?s website within 30 days of the signed Certification Agreement or 30 days after the electronic announcement dated May 6, whichever is later. Institutions were then required to update their websites every 45 days after initial upload. This was changed to quarterly on August 31, 2020. Condition: During our testing of the reporting process, we noted that documentation to support some of the amounts reported for student and annual reports was not retained. Additionally, it was noted there was no documentation of the review/approval process and that no support of when the reports were submitted to the website or Emergency Student Funds retained, preventing us from testing if they were submitted timely. Questioned costs: None Context: A robust tracking system was not employed for all the various reporting requirements including documentation of review and maintenance of records or recorded numbers. Cause: Summit Academy OIC did not have a robust system in place to document and track reporting requirements. Effect: No evidence to support that the reports were completed on time. Repeat finding: No Recommendation: We recommend the Organization establish a system to track due dates of reports to ensure timely submission and retain documents to support the submission and accuracy of the reports. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: Department of Education Federal Program Title: COVID-19 HEERF Institutional Portion Assistance Living Number: 84.425F Award Period: July 1, 2020, through June 30, 2021 Type of Finding: Significant Deficiency in Internal Control Over Compliance Other Matters Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. This requirement requires that non-federal entities check new vendors against the suspension and debarment list on SAM.gov and retain documentation of this check. Condition: During our testing of the suspension and debarment process, it noted that no documentation of the SAM.gov checking process was retained to provide evidence it was completed. Questioned costs: None Context: A tracking and documentation system was implemented for the suspension and debarment process. However, the documentation is not retained after the SAM.gov check is performed. Cause: Summit Academy OIC did not have a process to retain evidence that the SAM.gov check was performed. Effect: A vendor could be suspended/debarred after the SAM.gov check was performed but here is no evidence retained to show that as of the time of check the vendor was not debarred/suspended. Repeat finding: No Recommendation: We recommend that the Organization establish a process where when the SAM.gov check is performed, evidence is retained to show that this was completed. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: Department of Education Federal Program Title: COVID-19 HEERF Institutional Portion Assistance Living Number: 84.425F Award Period: July 1, 2020, through June 30, 2021 Type of Finding: Significant Deficiency in Internal Control Over Compliance Other Matters Criteria or specific requirement: Per the Higher Education Emergency Relief Fund (HEERF I, II, and III) Lost Revenue Frequently Asked Questions published March 19, 2021, lost revenue refers to those revenues an institution of higher education (institution) otherwise expected but were reduced or eliminated as a result of the novel coronavirus 2019 (COVID-19) pandemic. Condition: During our testing of lost revenue, it was noted that there were inaccuracies resulting in a lower lost revenue amount than initially calculated by the Organization. Questioned costs: $8,509 Context: The calculation was prepared by two individuals however the errors remained undetected. Cause: Summit Academy OIC did not have a reviewer independent of the preparation process review the calculation. Effect: Inaccurate amounts of federal funds were drawn down. Repeat finding: No Recommendation: We recommend that the Organization have someone independent of the lost revenue calculation process review the calculation for accuracy. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: Department of Education Federal Program Title: COVID-19 HEERF Student Aid Portion Assistance Living Number: 84.425E Award Period: July 1, 2020, through June 30, 2021 Type of Finding: Significant Deficiency in Internal Control Over Compliance Other Matters Criteria or specific requirement: Per approval by the Department of Education, the Organization?s methodology relating to the student portion of the Education Stabilization Fund involves providing assistance to students that go beyond providing disbursements of funds directly to students. The methodology involves the students filling out a form on what items (grocery, gas card, laptop, living stipend) they would like assistance on. The student will then sign off to acknowledge they received the required items. Condition: During our testing of student disbursements, it was noted that 2 of the 60 students tested did not have signatures indicating that they acknowledged and accepted the awards as presented. Questioned costs: $1,560 Context: Documentation of the acceptance was not properly retained. Cause: Summit Academy OIC did not properly retain documentation of student acceptance of the awards. Effect: Funds were drawn from the grant from which there is no evidence retained to provide the expenditure incurred. Repeat finding: No Recommendation: We recommend that the Organization have a system established that ensures documentation required of the student is retained. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: Department of Education Federal Program Title: COVID-19 HEERF Student Aid Portion Assistance Living Number: 84.425E Award Period: July 1, 2020, through June 30, 2021 Type of Finding: Significant Deficiency in Internal Control Over Compliance Other Matters Criteria or specific requirement: Per Frequently Asked Questions about the Emergency Financial Aid Grants to Students under Section 18004 of the Coronavirus Aid, Relief, and Economic Security (CARES) Act put out by the Department of Education, it states that ?The criteria to participate in programs under Section 484 of the [Higher Education Act (HEA)] include but are not limited to the following: U.S. citizenship or eligible noncitizen; a valid Social Security number; registration with Selective Service (if the student is male); and a high school diploma, GED, or completion of high school in an approved homeschool setting.? Condition: During our testing of student disbursements, it was noted that 1 of the 60 students tested self-reported as having a diploma, but the ISIR could not verify the education status of the individual. Questioned costs: $1,050 Context: The Organization took the risk of the liability that self-reported information could be inaccurate and did not have a system in place to correct an error if one was determined. Cause: Summit Academy OIC did not have a system in place to review self-reported information for accuracy. Effect: Inaccurate amounts of federal funds were drawn down. Repeat finding: No Recommendation: We recommend that the Organization have a system established that ensures self-reported information is checked against official verification. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: Department of Education Federal Program Title: Student Financial Aid Cluster ? Various Assistance Living Numbers: 84.063, 84.007, 84.033 Award Period: July 1, 2020, through June 30, 2021 Type of Finding: Significant Deficiency in Internal Control Over Compliance Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.309(b), states schools must have some arrangement to report student enrollment data to NSLDS through an enrollment roster file. The school is required to report changes in the student?s enrollment status, the effective date of the status, and an anticipated completion date. Also, the Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. Condition: During our testing, we noted 15 of the 40 students were not reported of a status change within 30 days. There were also 30 of the 40 students who were not being verified of enrollment every 60 days as required by regulations. Questioned costs: None Context: During our testing, it was noted the College did not properly report the change in status within 30 days or certify enrollment every 60 days of the determination. Cause: The College did not determine status changes within a timely manner due to extenuating circumstance. Effect: The enrollment effective date reported to NSLDS is used to determine when the student?s grace period should begin. By reporting an incorrect effective date, the grace period begin date for the student will be incorrect. The Organization also did not comply with Department of Education (ED) regulations requiring reporting student enrollment status change to NSLDS within 60 days. Repeat finding: No Recommendation: We recommend the Organization reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to ensure timely reporting as well as put a process in place to ensure the enrollment effective date reported to NSLDS is aligning with the organization?s last date of attendance. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Living Numbers: 84.063, 84.007, 84.033 Award Period: July 1, 2020, through June 30, 2021 Type of Finding: Significant Deficiency in Internal Control Over Compliance Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.164(e) states, ?Whenever an institution disburses title IV, HEA program funds by crediting a student?s account and the total amount of all title IV, HEA program funds credited exceeds the amount of tuition and fees, room and board, and other authorized charges the institution assessed the student, the institution must pay the resulting credit balance directly to the student or parent as soon as possible but (1) No later than 14 days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or (2) No later than 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period.? Condition: Through our testing of 40 students whose accounts had a credit balance resulting from federal funds during the year, we noted that one student did not have the credit balance refunded within the 14-day period. Questioned costs: none Context: This student was awarded in November 2021. During this time, the Organization had a turnover in their Financial Aid Department and new Financial Aid Coordinator began working. Due to the transition, the student?s refund was missed. Financial Aid staff normally only have a couple student stipend per year, as most students are enrolled for full time credits and do not end up with credit balances, so it is not something they do on a regular basis. Cause: There was turnover in the Financial Aid Department during the time the refund should have been issued. Effect: The organization did not refund students within 14 days for credit balances that arose from federal funds as required by Department of Education regulations. Repeat finding: No Recommendation: We recommend that the Organization put a process in place to refund student credit balances that arose from federal funds within 14 days. We also recommend that postings to student accounts of institutional charges for each payment period be posted and dated prior to disbursing federal funds to limit the number of refund checks. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Living Numbers: 84.063, 84.007, 84.033 Award Period: July 1, 2020, through June 30, 2021 Type of Finding: Significant Deficiency in Internal Control Over Compliance Other Matters Criteria or specific requirement: The Department of Education requires the Organization to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Condition: During our testing, we noted 2 of the 40 students tested had disbursement dates per COD that did not match the student account. Questioned costs: none Context: During our testing, it was noted the Organization did not properly follow the process to ensure disbursements are accurately reported to COD. Cause: The Organization did not follow the procedure to meet the requirement that the disbursement date and balance per the student?s account must match the disbursement date and balance in COD. Effect: Students interest accrues based on disbursement date reported to COD for Direct Loan disbursements, thus interest calculation could be skewed due to the discrepancy in disbursement dates reported. Repeat finding: No Recommendation: We recommend the Organization evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: Department of Education Federal Program Title: Student Financial Aid Cluster ? Federal Pell Grant Program CFDA Number: 84.063 Award Period: July 1, 2019 through June 30, 2020 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 690.62 states the Pell grant for an academic year is based upon the payment and disbursement scheduled published by the Secretary for each award year. The payment schedules take into account the cost of attendance, the student?s EFC and the enrollment status of the student. Condition: One of 40 students was underawarded Pell grant funds. Questioned costs: $268 Context: An erroneous computation of the student?s eligibility resulted in an underaward of Pell. Cause: Summit Academy OIC 's financial aid software updates regularly. As a result of these updates, packaging and awarding statuses and amounts are sometimes reset, resulting in incorrect calculations of awards. The Pell grant for one term for one student was computed using a less-than-half time enrollment status for two terms, instead of a less-than-half time enrollment status for one term. Effect: One of 40 students was underawarded Pell grant funds. Repeat finding: No Recommendation: We recommend that a review is implemented which compares enrolled credits to Pell award to ensure all Pell funds are awarded at proper amounts. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: Department of Education Federal Program Title: Student Financial Aid Cluster ? Federal Pell Grant Program CFDA Numbers: 84.063, 84.007, 84.033 Award Period: July 1, 2019 through June 30, 2020 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR ? 668.34 defines financial aid probation as the status assigned by an institution to a student who fails to make satisfactory academic progress and who has appealed and has had eligibility for aid reinstated. Condition: Two of 40 students failed to maintain satisfactory academic progress and were not required to appeal to have their eligibility for aid reinstated. Questioned costs: $9,024 Context: Summit Academy OIC evaluates satisfactory academic progress at the end of each payment period and utilizes an academic warning for students who fail to achieve satisfactory academic progress. Summit Academy OIC?s written policy for students on academic warning is to evaluate satisfactory academic progress at the end of the payment period during which the student is on academic warning and terminate the aid eligibility of any students who do not achieve satisfactory academic progress. According to the written policy, such students may then appeal, and if the appeal is approved, will be placed on financial aid probation. However, Summit Academy OIC has not been applying this written policy. Instead, when a student on academic warning fails to achieve satisfactory academic progress and continues enrollment at Summit Academy OIC, the school has been immediately placing such students on academic probation and awarding federal aid without requiring an appeal from the student. Cause: Summit Academy OIC incorrectly applied its written policy to evaluate satisfactory academic progress. Effect: There was federal aid of $9,024 disbursed to students who are not maintaning satisfactory academic progress and were considered ineligible for federal aid. Repeat finding: No Recommendation: We recommend an appeal process for students who have lost their Title IV aid eligibility be implemented by Summit Academy OIC. Views of responsible officials: There is no disagreement with the audit finding.

2019-001 Federal agency: Department of Education Federal program title: Student Financial Aid Cluster CFDA Numbers: 84.063, 84.007, 84.033 Award Period: July 1, 2018 through June 30, 2019 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Section III ? Findings and Questioned Costs ? Major Federal Programs (Continued) Criteria or specific requirement: The Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as ?financial institutions? and subject to the Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi). Condition: Under an institution?s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs. Questioned costs: None Context: During our audit procedures, it was noted that the Organization did not designate an individual to coordinate the information security program; perform a risk assessment that addresses the three areas noted in 16 CFR 314.4 (b) which are (1) Employee training and management; (2) Information systems, including network and software design, as well as information processing, storage, transmission and disposal; and (3) Detecting, preventing and responding to attacks, intrusions, or other systems failures and document safeguards for identified risks. Cause: The organization uses a third party IT service provider for IT related tasks and relied on that service provider to ensure all compliance requirements are met. However, the organization should have an individual designated internally to assure compliance with the requirements of the Gramm-Leach-Bliley Act. The organization did not perform an IT risk assessment tailored specifically to the organization, identify risks or address risks identified as required by the Gramm-Leach-Bliley Act. Effect: The student personal information could be vulnerable. Repeat Finding: No Recommendation: We recommend that the Organization designate an individual to oversee the information security function, engage a third party or perform the risk assessment for the three areas required by the Gramm-Leach-Bliley Act and ensure that there are documented safeguards for identified risks.

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