U.S. Department of Education
Student Financial Assistance Cluster
Federal Financial Assistance Listing Number(s): 84.063, 84.007, 84.268, 84.033, 84.038, 84.379 Compliance Requirement: Special Tests & Provisions – Enrollment Reporting
Type of Finding: Material Weakness in Internal Control
Criteria: 34 CFR 690.83(b)(2) and 34 CFR 685.309 states that Institutions are responsible for timely and accurate reporting of a student’s enrollment status and changes in those enrollment statuses, whether they report directly or via a third‐party servicer. When an Institution is made aware of a change in a student’s enrollment status, the Institution has 60 days to update the change in enrollment status via NSLDS.
Condition: During our testing of compliance for Enrollment Reporting, there were 16 instances out of 21 where NLSDS did not reflect accurate or timely reporting of a student's change in enrollment status. While records were submitted accurately and timely to the Clearinghouse, those records were not reflected in NSLDS.
Cause: The University pushed through the changes in enrollment status to the Clearinghouse timely and accurately based upon the student’s enrollment status; however, the change in enrollment status was not pushed through all the way to NSLDS resulting in inaccurate and untimely records within NSLDS.
Effect: The student’s change in enrollment status was not accurately reported in NSLDS and/or was not reported timely.
Questioned Costs: None reported.
Context/Sampling: A nonstatistical sample of 21 participants out of 111 students who had a change in enrollment status were selected for testing.
Repeat Finding from Prior Year(s): No
Recommendation: The University should implement controls to ensure that enrollment records for students are being updated every 60 days, and that those records being submitted to NSLDS are accurate.
Views of Responsible Officials: Management agrees with the finding.
U.S. Department of Education
Student Financial Assistance Cluster
Federal Financial Assistance Listing Number(s): 84.063, 84.007, 84.268, 84.033, 84.038, 84.379 Compliance Requirement: Special Tests & Provisions – Enrollment Reporting
Type of Finding: Material Weakness in Internal Control
Criteria: 34 CFR 690.83(b)(2) and 34 CFR 685.309 states that Institutions are responsible for timely and accurate reporting of a student’s enrollment status and changes in those enrollment statuses, whether they report directly or via a third‐party servicer. When an Institution is made aware of a change in a student’s enrollment status, the Institution has 60 days to update the change in enrollment status via NSLDS.
Condition: During our testing of compliance for Enrollment Reporting, there were 16 instances out of 21 where NLSDS did not reflect accurate or timely reporting of a student's change in enrollment status. While records were submitted accurately and timely to the Clearinghouse, those records were not reflected in NSLDS.
Cause: The University pushed through the changes in enrollment status to the Clearinghouse timely and accurately based upon the student’s enrollment status; however, the change in enrollment status was not pushed through all the way to NSLDS resulting in inaccurate and untimely records within NSLDS.
Effect: The student’s change in enrollment status was not accurately reported in NSLDS and/or was not reported timely.
Questioned Costs: None reported.
Context/Sampling: A nonstatistical sample of 21 participants out of 111 students who had a change in enrollment status were selected for testing.
Repeat Finding from Prior Year(s): No
Recommendation: The University should implement controls to ensure that enrollment records for students are being updated every 60 days, and that those records being submitted to NSLDS are accurate.
Views of Responsible Officials: Management agrees with the finding.
U.S. Department of Education
Student Financial Assistance Cluster
Federal Financial Assistance Listing Number(s): 84.063, 84.007, 84.268, 84.033, 84.038, 84.379 Compliance Requirement: Special Tests & Provisions – Enrollment Reporting
Type of Finding: Material Weakness in Internal Control
Criteria: 34 CFR 690.83(b)(2) and 34 CFR 685.309 states that Institutions are responsible for timely and accurate reporting of a student’s enrollment status and changes in those enrollment statuses, whether they report directly or via a third‐party servicer. When an Institution is made aware of a change in a student’s enrollment status, the Institution has 60 days to update the change in enrollment status via NSLDS.
Condition: During our testing of compliance for Enrollment Reporting, there were 16 instances out of 21 where NLSDS did not reflect accurate or timely reporting of a student's change in enrollment status. While records were submitted accurately and timely to the Clearinghouse, those records were not reflected in NSLDS.
Cause: The University pushed through the changes in enrollment status to the Clearinghouse timely and accurately based upon the student’s enrollment status; however, the change in enrollment status was not pushed through all the way to NSLDS resulting in inaccurate and untimely records within NSLDS.
Effect: The student’s change in enrollment status was not accurately reported in NSLDS and/or was not reported timely.
Questioned Costs: None reported.
Context/Sampling: A nonstatistical sample of 21 participants out of 111 students who had a change in enrollment status were selected for testing.
Repeat Finding from Prior Year(s): No
Recommendation: The University should implement controls to ensure that enrollment records for students are being updated every 60 days, and that those records being submitted to NSLDS are accurate.
Views of Responsible Officials: Management agrees with the finding.
U.S. Department of Education
Student Financial Assistance Cluster
Federal Financial Assistance Listing Number(s): 84.063, 84.007, 84.268, 84.033, 84.038, 84.379 Compliance Requirement: Special Tests & Provisions – Enrollment Reporting
Type of Finding: Material Weakness in Internal Control
Criteria: 34 CFR 690.83(b)(2) and 34 CFR 685.309 states that Institutions are responsible for timely and accurate reporting of a student’s enrollment status and changes in those enrollment statuses, whether they report directly or via a third‐party servicer. When an Institution is made aware of a change in a student’s enrollment status, the Institution has 60 days to update the change in enrollment status via NSLDS.
Condition: During our testing of compliance for Enrollment Reporting, there were 16 instances out of 21 where NLSDS did not reflect accurate or timely reporting of a student's change in enrollment status. While records were submitted accurately and timely to the Clearinghouse, those records were not reflected in NSLDS.
Cause: The University pushed through the changes in enrollment status to the Clearinghouse timely and accurately based upon the student’s enrollment status; however, the change in enrollment status was not pushed through all the way to NSLDS resulting in inaccurate and untimely records within NSLDS.
Effect: The student’s change in enrollment status was not accurately reported in NSLDS and/or was not reported timely.
Questioned Costs: None reported.
Context/Sampling: A nonstatistical sample of 21 participants out of 111 students who had a change in enrollment status were selected for testing.
Repeat Finding from Prior Year(s): No
Recommendation: The University should implement controls to ensure that enrollment records for students are being updated every 60 days, and that those records being submitted to NSLDS are accurate.
Views of Responsible Officials: Management agrees with the finding.
U.S. Department of Education
Student Financial Assistance Cluster
Federal Financial Assistance Listing Number(s): 84.063, 84.007, 84.268, 84.033, 84.038, 84.379 Compliance Requirement: Special Tests & Provisions – Enrollment Reporting
Type of Finding: Material Weakness in Internal Control
Criteria: 34 CFR 690.83(b)(2) and 34 CFR 685.309 states that Institutions are responsible for timely and accurate reporting of a student’s enrollment status and changes in those enrollment statuses, whether they report directly or via a third‐party servicer. When an Institution is made aware of a change in a student’s enrollment status, the Institution has 60 days to update the change in enrollment status via NSLDS.
Condition: During our testing of compliance for Enrollment Reporting, there were 16 instances out of 21 where NLSDS did not reflect accurate or timely reporting of a student's change in enrollment status. While records were submitted accurately and timely to the Clearinghouse, those records were not reflected in NSLDS.
Cause: The University pushed through the changes in enrollment status to the Clearinghouse timely and accurately based upon the student’s enrollment status; however, the change in enrollment status was not pushed through all the way to NSLDS resulting in inaccurate and untimely records within NSLDS.
Effect: The student’s change in enrollment status was not accurately reported in NSLDS and/or was not reported timely.
Questioned Costs: None reported.
Context/Sampling: A nonstatistical sample of 21 participants out of 111 students who had a change in enrollment status were selected for testing.
Repeat Finding from Prior Year(s): No
Recommendation: The University should implement controls to ensure that enrollment records for students are being updated every 60 days, and that those records being submitted to NSLDS are accurate.
Views of Responsible Officials: Management agrees with the finding.
U.S. Department of Education
Student Financial Assistance Cluster
Federal Financial Assistance Listing Number(s): 84.063, 84.007, 84.268, 84.033, 84.038, 84.379 Compliance Requirement: Special Tests & Provisions – Enrollment Reporting
Type of Finding: Material Weakness in Internal Control
Criteria: 34 CFR 690.83(b)(2) and 34 CFR 685.309 states that Institutions are responsible for timely and accurate reporting of a student’s enrollment status and changes in those enrollment statuses, whether they report directly or via a third‐party servicer. When an Institution is made aware of a change in a student’s enrollment status, the Institution has 60 days to update the change in enrollment status via NSLDS.
Condition: During our testing of compliance for Enrollment Reporting, there were 16 instances out of 21 where NLSDS did not reflect accurate or timely reporting of a student's change in enrollment status. While records were submitted accurately and timely to the Clearinghouse, those records were not reflected in NSLDS.
Cause: The University pushed through the changes in enrollment status to the Clearinghouse timely and accurately based upon the student’s enrollment status; however, the change in enrollment status was not pushed through all the way to NSLDS resulting in inaccurate and untimely records within NSLDS.
Effect: The student’s change in enrollment status was not accurately reported in NSLDS and/or was not reported timely.
Questioned Costs: None reported.
Context/Sampling: A nonstatistical sample of 21 participants out of 111 students who had a change in enrollment status were selected for testing.
Repeat Finding from Prior Year(s): No
Recommendation: The University should implement controls to ensure that enrollment records for students are being updated every 60 days, and that those records being submitted to NSLDS are accurate.
Views of Responsible Officials: Management agrees with the finding.
U.S. Department of Education
Student Financial Assistance Cluster
Federal Financial Assistance Listing Number(s): 84.063, 84.007, 84.268, 84.033, 84.038, 84.379 Compliance Requirement: Special Tests & Provisions – Gramm‐Leach‐Bliley Act (GLBA) – Student Information Security
Type of Finding: Material Weakness in Internal Control
Criteria: Under 16 CFR Part 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 that the written information security program to include nine elements for institutions with 5,000 or more customers.
Condition: During our testing over GLBA compliance, we noted that the University had not updated their information security program since 2018 and that it was missing aspects of the required nine elements.
Cause: The University has not updated their written information security program since 2018.
Effect: The University did not have a system in place to ensure the required elements under GLBA were included in the comprehensive information security program and that the program was reviewed periodically.
Questioned Costs: None reported.
Context/Sampling: Sampling was not used.
Repeat Finding from Prior Year(s): No
Recommendation: The University should have a system in place to ensure that their comprehensive security program includes the required aspects under GLBA and that they are in documented in writing.
Views of Responsible Officials: Management agrees with the finding.
U.S. Department of Education
Student Financial Assistance Cluster
Federal Financial Assistance Listing Number(s): 84.063, 84.007, 84.268, 84.033, 84.038, 84.379 Compliance Requirement: Special Tests & Provisions – Gramm‐Leach‐Bliley Act (GLBA) – Student Information Security
Type of Finding: Material Weakness in Internal Control
Criteria: Under 16 CFR Part 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 that the written information security program to include nine elements for institutions with 5,000 or more customers.
Condition: During our testing over GLBA compliance, we noted that the University had not updated their information security program since 2018 and that it was missing aspects of the required nine elements.
Cause: The University has not updated their written information security program since 2018.
Effect: The University did not have a system in place to ensure the required elements under GLBA were included in the comprehensive information security program and that the program was reviewed periodically.
Questioned Costs: None reported.
Context/Sampling: Sampling was not used.
Repeat Finding from Prior Year(s): No
Recommendation: The University should have a system in place to ensure that their comprehensive security program includes the required aspects under GLBA and that they are in documented in writing.
Views of Responsible Officials: Management agrees with the finding.
U.S. Department of Education
Student Financial Assistance Cluster
Federal Financial Assistance Listing Number(s): 84.063, 84.007, 84.268, 84.033, 84.038, 84.379 Compliance Requirement: Special Tests & Provisions – Gramm‐Leach‐Bliley Act (GLBA) – Student Information Security
Type of Finding: Material Weakness in Internal Control
Criteria: Under 16 CFR Part 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 that the written information security program to include nine elements for institutions with 5,000 or more customers.
Condition: During our testing over GLBA compliance, we noted that the University had not updated their information security program since 2018 and that it was missing aspects of the required nine elements.
Cause: The University has not updated their written information security program since 2018.
Effect: The University did not have a system in place to ensure the required elements under GLBA were included in the comprehensive information security program and that the program was reviewed periodically.
Questioned Costs: None reported.
Context/Sampling: Sampling was not used.
Repeat Finding from Prior Year(s): No
Recommendation: The University should have a system in place to ensure that their comprehensive security program includes the required aspects under GLBA and that they are in documented in writing.
Views of Responsible Officials: Management agrees with the finding.
U.S. Department of Education
Student Financial Assistance Cluster
Federal Financial Assistance Listing Number(s): 84.063, 84.007, 84.268, 84.033, 84.038, 84.379 Compliance Requirement: Special Tests & Provisions – Gramm‐Leach‐Bliley Act (GLBA) – Student Information Security
Type of Finding: Material Weakness in Internal Control
Criteria: Under 16 CFR Part 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 that the written information security program to include nine elements for institutions with 5,000 or more customers.
Condition: During our testing over GLBA compliance, we noted that the University had not updated their information security program since 2018 and that it was missing aspects of the required nine elements.
Cause: The University has not updated their written information security program since 2018.
Effect: The University did not have a system in place to ensure the required elements under GLBA were included in the comprehensive information security program and that the program was reviewed periodically.
Questioned Costs: None reported.
Context/Sampling: Sampling was not used.
Repeat Finding from Prior Year(s): No
Recommendation: The University should have a system in place to ensure that their comprehensive security program includes the required aspects under GLBA and that they are in documented in writing.
Views of Responsible Officials: Management agrees with the finding.
U.S. Department of Education
Student Financial Assistance Cluster
Federal Financial Assistance Listing Number(s): 84.063, 84.007, 84.268, 84.033, 84.038, 84.379 Compliance Requirement: Special Tests & Provisions – Gramm‐Leach‐Bliley Act (GLBA) – Student Information Security
Type of Finding: Material Weakness in Internal Control
Criteria: Under 16 CFR Part 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 that the written information security program to include nine elements for institutions with 5,000 or more customers.
Condition: During our testing over GLBA compliance, we noted that the University had not updated their information security program since 2018 and that it was missing aspects of the required nine elements.
Cause: The University has not updated their written information security program since 2018.
Effect: The University did not have a system in place to ensure the required elements under GLBA were included in the comprehensive information security program and that the program was reviewed periodically.
Questioned Costs: None reported.
Context/Sampling: Sampling was not used.
Repeat Finding from Prior Year(s): No
Recommendation: The University should have a system in place to ensure that their comprehensive security program includes the required aspects under GLBA and that they are in documented in writing.
Views of Responsible Officials: Management agrees with the finding.
U.S. Department of Education
Student Financial Assistance Cluster
Federal Financial Assistance Listing Number(s): 84.063, 84.007, 84.268, 84.033, 84.038, 84.379 Compliance Requirement: Special Tests & Provisions – Gramm‐Leach‐Bliley Act (GLBA) – Student Information Security
Type of Finding: Material Weakness in Internal Control
Criteria: Under 16 CFR Part 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 that the written information security program to include nine elements for institutions with 5,000 or more customers.
Condition: During our testing over GLBA compliance, we noted that the University had not updated their information security program since 2018 and that it was missing aspects of the required nine elements.
Cause: The University has not updated their written information security program since 2018.
Effect: The University did not have a system in place to ensure the required elements under GLBA were included in the comprehensive information security program and that the program was reviewed periodically.
Questioned Costs: None reported.
Context/Sampling: Sampling was not used.
Repeat Finding from Prior Year(s): No
Recommendation: The University should have a system in place to ensure that their comprehensive security program includes the required aspects under GLBA and that they are in documented in writing.
Views of Responsible Officials: Management agrees with the finding.
U.S. Department of Education
Student Financial Assistance Cluster
Federal Financial Assistance Listing Number(s): 84.063, 84.007, 84.268, 84.033, 84.038, 84.379 Compliance Requirement: Special Tests & Provisions – Enrollment Reporting
Type of Finding: Material Weakness in Internal Control
Criteria: 34 CFR 690.83(b)(2) and 34 CFR 685.309 states that Institutions are responsible for timely and accurate reporting of a student’s enrollment status and changes in those enrollment statuses, whether they report directly or via a third‐party servicer. When an Institution is made aware of a change in a student’s enrollment status, the Institution has 60 days to update the change in enrollment status via NSLDS.
Condition: During our testing of compliance for Enrollment Reporting, there were 16 instances out of 21 where NLSDS did not reflect accurate or timely reporting of a student's change in enrollment status. While records were submitted accurately and timely to the Clearinghouse, those records were not reflected in NSLDS.
Cause: The University pushed through the changes in enrollment status to the Clearinghouse timely and accurately based upon the student’s enrollment status; however, the change in enrollment status was not pushed through all the way to NSLDS resulting in inaccurate and untimely records within NSLDS.
Effect: The student’s change in enrollment status was not accurately reported in NSLDS and/or was not reported timely.
Questioned Costs: None reported.
Context/Sampling: A nonstatistical sample of 21 participants out of 111 students who had a change in enrollment status were selected for testing.
Repeat Finding from Prior Year(s): No
Recommendation: The University should implement controls to ensure that enrollment records for students are being updated every 60 days, and that those records being submitted to NSLDS are accurate.
Views of Responsible Officials: Management agrees with the finding.
U.S. Department of Education
Student Financial Assistance Cluster
Federal Financial Assistance Listing Number(s): 84.063, 84.007, 84.268, 84.033, 84.038, 84.379 Compliance Requirement: Special Tests & Provisions – Enrollment Reporting
Type of Finding: Material Weakness in Internal Control
Criteria: 34 CFR 690.83(b)(2) and 34 CFR 685.309 states that Institutions are responsible for timely and accurate reporting of a student’s enrollment status and changes in those enrollment statuses, whether they report directly or via a third‐party servicer. When an Institution is made aware of a change in a student’s enrollment status, the Institution has 60 days to update the change in enrollment status via NSLDS.
Condition: During our testing of compliance for Enrollment Reporting, there were 16 instances out of 21 where NLSDS did not reflect accurate or timely reporting of a student's change in enrollment status. While records were submitted accurately and timely to the Clearinghouse, those records were not reflected in NSLDS.
Cause: The University pushed through the changes in enrollment status to the Clearinghouse timely and accurately based upon the student’s enrollment status; however, the change in enrollment status was not pushed through all the way to NSLDS resulting in inaccurate and untimely records within NSLDS.
Effect: The student’s change in enrollment status was not accurately reported in NSLDS and/or was not reported timely.
Questioned Costs: None reported.
Context/Sampling: A nonstatistical sample of 21 participants out of 111 students who had a change in enrollment status were selected for testing.
Repeat Finding from Prior Year(s): No
Recommendation: The University should implement controls to ensure that enrollment records for students are being updated every 60 days, and that those records being submitted to NSLDS are accurate.
Views of Responsible Officials: Management agrees with the finding.
U.S. Department of Education
Student Financial Assistance Cluster
Federal Financial Assistance Listing Number(s): 84.063, 84.007, 84.268, 84.033, 84.038, 84.379 Compliance Requirement: Special Tests & Provisions – Enrollment Reporting
Type of Finding: Material Weakness in Internal Control
Criteria: 34 CFR 690.83(b)(2) and 34 CFR 685.309 states that Institutions are responsible for timely and accurate reporting of a student’s enrollment status and changes in those enrollment statuses, whether they report directly or via a third‐party servicer. When an Institution is made aware of a change in a student’s enrollment status, the Institution has 60 days to update the change in enrollment status via NSLDS.
Condition: During our testing of compliance for Enrollment Reporting, there were 16 instances out of 21 where NLSDS did not reflect accurate or timely reporting of a student's change in enrollment status. While records were submitted accurately and timely to the Clearinghouse, those records were not reflected in NSLDS.
Cause: The University pushed through the changes in enrollment status to the Clearinghouse timely and accurately based upon the student’s enrollment status; however, the change in enrollment status was not pushed through all the way to NSLDS resulting in inaccurate and untimely records within NSLDS.
Effect: The student’s change in enrollment status was not accurately reported in NSLDS and/or was not reported timely.
Questioned Costs: None reported.
Context/Sampling: A nonstatistical sample of 21 participants out of 111 students who had a change in enrollment status were selected for testing.
Repeat Finding from Prior Year(s): No
Recommendation: The University should implement controls to ensure that enrollment records for students are being updated every 60 days, and that those records being submitted to NSLDS are accurate.
Views of Responsible Officials: Management agrees with the finding.
U.S. Department of Education
Student Financial Assistance Cluster
Federal Financial Assistance Listing Number(s): 84.063, 84.007, 84.268, 84.033, 84.038, 84.379 Compliance Requirement: Special Tests & Provisions – Enrollment Reporting
Type of Finding: Material Weakness in Internal Control
Criteria: 34 CFR 690.83(b)(2) and 34 CFR 685.309 states that Institutions are responsible for timely and accurate reporting of a student’s enrollment status and changes in those enrollment statuses, whether they report directly or via a third‐party servicer. When an Institution is made aware of a change in a student’s enrollment status, the Institution has 60 days to update the change in enrollment status via NSLDS.
Condition: During our testing of compliance for Enrollment Reporting, there were 16 instances out of 21 where NLSDS did not reflect accurate or timely reporting of a student's change in enrollment status. While records were submitted accurately and timely to the Clearinghouse, those records were not reflected in NSLDS.
Cause: The University pushed through the changes in enrollment status to the Clearinghouse timely and accurately based upon the student’s enrollment status; however, the change in enrollment status was not pushed through all the way to NSLDS resulting in inaccurate and untimely records within NSLDS.
Effect: The student’s change in enrollment status was not accurately reported in NSLDS and/or was not reported timely.
Questioned Costs: None reported.
Context/Sampling: A nonstatistical sample of 21 participants out of 111 students who had a change in enrollment status were selected for testing.
Repeat Finding from Prior Year(s): No
Recommendation: The University should implement controls to ensure that enrollment records for students are being updated every 60 days, and that those records being submitted to NSLDS are accurate.
Views of Responsible Officials: Management agrees with the finding.
U.S. Department of Education
Student Financial Assistance Cluster
Federal Financial Assistance Listing Number(s): 84.063, 84.007, 84.268, 84.033, 84.038, 84.379 Compliance Requirement: Special Tests & Provisions – Enrollment Reporting
Type of Finding: Material Weakness in Internal Control
Criteria: 34 CFR 690.83(b)(2) and 34 CFR 685.309 states that Institutions are responsible for timely and accurate reporting of a student’s enrollment status and changes in those enrollment statuses, whether they report directly or via a third‐party servicer. When an Institution is made aware of a change in a student’s enrollment status, the Institution has 60 days to update the change in enrollment status via NSLDS.
Condition: During our testing of compliance for Enrollment Reporting, there were 16 instances out of 21 where NLSDS did not reflect accurate or timely reporting of a student's change in enrollment status. While records were submitted accurately and timely to the Clearinghouse, those records were not reflected in NSLDS.
Cause: The University pushed through the changes in enrollment status to the Clearinghouse timely and accurately based upon the student’s enrollment status; however, the change in enrollment status was not pushed through all the way to NSLDS resulting in inaccurate and untimely records within NSLDS.
Effect: The student’s change in enrollment status was not accurately reported in NSLDS and/or was not reported timely.
Questioned Costs: None reported.
Context/Sampling: A nonstatistical sample of 21 participants out of 111 students who had a change in enrollment status were selected for testing.
Repeat Finding from Prior Year(s): No
Recommendation: The University should implement controls to ensure that enrollment records for students are being updated every 60 days, and that those records being submitted to NSLDS are accurate.
Views of Responsible Officials: Management agrees with the finding.
U.S. Department of Education
Student Financial Assistance Cluster
Federal Financial Assistance Listing Number(s): 84.063, 84.007, 84.268, 84.033, 84.038, 84.379 Compliance Requirement: Special Tests & Provisions – Enrollment Reporting
Type of Finding: Material Weakness in Internal Control
Criteria: 34 CFR 690.83(b)(2) and 34 CFR 685.309 states that Institutions are responsible for timely and accurate reporting of a student’s enrollment status and changes in those enrollment statuses, whether they report directly or via a third‐party servicer. When an Institution is made aware of a change in a student’s enrollment status, the Institution has 60 days to update the change in enrollment status via NSLDS.
Condition: During our testing of compliance for Enrollment Reporting, there were 16 instances out of 21 where NLSDS did not reflect accurate or timely reporting of a student's change in enrollment status. While records were submitted accurately and timely to the Clearinghouse, those records were not reflected in NSLDS.
Cause: The University pushed through the changes in enrollment status to the Clearinghouse timely and accurately based upon the student’s enrollment status; however, the change in enrollment status was not pushed through all the way to NSLDS resulting in inaccurate and untimely records within NSLDS.
Effect: The student’s change in enrollment status was not accurately reported in NSLDS and/or was not reported timely.
Questioned Costs: None reported.
Context/Sampling: A nonstatistical sample of 21 participants out of 111 students who had a change in enrollment status were selected for testing.
Repeat Finding from Prior Year(s): No
Recommendation: The University should implement controls to ensure that enrollment records for students are being updated every 60 days, and that those records being submitted to NSLDS are accurate.
Views of Responsible Officials: Management agrees with the finding.
U.S. Department of Education
Student Financial Assistance Cluster
Federal Financial Assistance Listing Number(s): 84.063, 84.007, 84.268, 84.033, 84.038, 84.379 Compliance Requirement: Special Tests & Provisions – Gramm‐Leach‐Bliley Act (GLBA) – Student Information Security
Type of Finding: Material Weakness in Internal Control
Criteria: Under 16 CFR Part 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 that the written information security program to include nine elements for institutions with 5,000 or more customers.
Condition: During our testing over GLBA compliance, we noted that the University had not updated their information security program since 2018 and that it was missing aspects of the required nine elements.
Cause: The University has not updated their written information security program since 2018.
Effect: The University did not have a system in place to ensure the required elements under GLBA were included in the comprehensive information security program and that the program was reviewed periodically.
Questioned Costs: None reported.
Context/Sampling: Sampling was not used.
Repeat Finding from Prior Year(s): No
Recommendation: The University should have a system in place to ensure that their comprehensive security program includes the required aspects under GLBA and that they are in documented in writing.
Views of Responsible Officials: Management agrees with the finding.
U.S. Department of Education
Student Financial Assistance Cluster
Federal Financial Assistance Listing Number(s): 84.063, 84.007, 84.268, 84.033, 84.038, 84.379 Compliance Requirement: Special Tests & Provisions – Gramm‐Leach‐Bliley Act (GLBA) – Student Information Security
Type of Finding: Material Weakness in Internal Control
Criteria: Under 16 CFR Part 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 that the written information security program to include nine elements for institutions with 5,000 or more customers.
Condition: During our testing over GLBA compliance, we noted that the University had not updated their information security program since 2018 and that it was missing aspects of the required nine elements.
Cause: The University has not updated their written information security program since 2018.
Effect: The University did not have a system in place to ensure the required elements under GLBA were included in the comprehensive information security program and that the program was reviewed periodically.
Questioned Costs: None reported.
Context/Sampling: Sampling was not used.
Repeat Finding from Prior Year(s): No
Recommendation: The University should have a system in place to ensure that their comprehensive security program includes the required aspects under GLBA and that they are in documented in writing.
Views of Responsible Officials: Management agrees with the finding.
U.S. Department of Education
Student Financial Assistance Cluster
Federal Financial Assistance Listing Number(s): 84.063, 84.007, 84.268, 84.033, 84.038, 84.379 Compliance Requirement: Special Tests & Provisions – Gramm‐Leach‐Bliley Act (GLBA) – Student Information Security
Type of Finding: Material Weakness in Internal Control
Criteria: Under 16 CFR Part 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 that the written information security program to include nine elements for institutions with 5,000 or more customers.
Condition: During our testing over GLBA compliance, we noted that the University had not updated their information security program since 2018 and that it was missing aspects of the required nine elements.
Cause: The University has not updated their written information security program since 2018.
Effect: The University did not have a system in place to ensure the required elements under GLBA were included in the comprehensive information security program and that the program was reviewed periodically.
Questioned Costs: None reported.
Context/Sampling: Sampling was not used.
Repeat Finding from Prior Year(s): No
Recommendation: The University should have a system in place to ensure that their comprehensive security program includes the required aspects under GLBA and that they are in documented in writing.
Views of Responsible Officials: Management agrees with the finding.
U.S. Department of Education
Student Financial Assistance Cluster
Federal Financial Assistance Listing Number(s): 84.063, 84.007, 84.268, 84.033, 84.038, 84.379 Compliance Requirement: Special Tests & Provisions – Gramm‐Leach‐Bliley Act (GLBA) – Student Information Security
Type of Finding: Material Weakness in Internal Control
Criteria: Under 16 CFR Part 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 that the written information security program to include nine elements for institutions with 5,000 or more customers.
Condition: During our testing over GLBA compliance, we noted that the University had not updated their information security program since 2018 and that it was missing aspects of the required nine elements.
Cause: The University has not updated their written information security program since 2018.
Effect: The University did not have a system in place to ensure the required elements under GLBA were included in the comprehensive information security program and that the program was reviewed periodically.
Questioned Costs: None reported.
Context/Sampling: Sampling was not used.
Repeat Finding from Prior Year(s): No
Recommendation: The University should have a system in place to ensure that their comprehensive security program includes the required aspects under GLBA and that they are in documented in writing.
Views of Responsible Officials: Management agrees with the finding.
U.S. Department of Education
Student Financial Assistance Cluster
Federal Financial Assistance Listing Number(s): 84.063, 84.007, 84.268, 84.033, 84.038, 84.379 Compliance Requirement: Special Tests & Provisions – Gramm‐Leach‐Bliley Act (GLBA) – Student Information Security
Type of Finding: Material Weakness in Internal Control
Criteria: Under 16 CFR Part 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 that the written information security program to include nine elements for institutions with 5,000 or more customers.
Condition: During our testing over GLBA compliance, we noted that the University had not updated their information security program since 2018 and that it was missing aspects of the required nine elements.
Cause: The University has not updated their written information security program since 2018.
Effect: The University did not have a system in place to ensure the required elements under GLBA were included in the comprehensive information security program and that the program was reviewed periodically.
Questioned Costs: None reported.
Context/Sampling: Sampling was not used.
Repeat Finding from Prior Year(s): No
Recommendation: The University should have a system in place to ensure that their comprehensive security program includes the required aspects under GLBA and that they are in documented in writing.
Views of Responsible Officials: Management agrees with the finding.
U.S. Department of Education
Student Financial Assistance Cluster
Federal Financial Assistance Listing Number(s): 84.063, 84.007, 84.268, 84.033, 84.038, 84.379 Compliance Requirement: Special Tests & Provisions – Gramm‐Leach‐Bliley Act (GLBA) – Student Information Security
Type of Finding: Material Weakness in Internal Control
Criteria: Under 16 CFR Part 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 that the written information security program to include nine elements for institutions with 5,000 or more customers.
Condition: During our testing over GLBA compliance, we noted that the University had not updated their information security program since 2018 and that it was missing aspects of the required nine elements.
Cause: The University has not updated their written information security program since 2018.
Effect: The University did not have a system in place to ensure the required elements under GLBA were included in the comprehensive information security program and that the program was reviewed periodically.
Questioned Costs: None reported.
Context/Sampling: Sampling was not used.
Repeat Finding from Prior Year(s): No
Recommendation: The University should have a system in place to ensure that their comprehensive security program includes the required aspects under GLBA and that they are in documented in writing.
Views of Responsible Officials: Management agrees with the finding.