Student Financial Assistance Cluster
U.S. Department of Education ALNs 84.268, 84.063
Federal Direct Student Loans - Award Year 2023
Federal Pell Grant Program - Award Year 2023
Criteria or Specific Requirement – Special Tests & Provisions: Enrollment Reporting (Pell 34 CFR Section 690.83(b)(2); FDL, 34 CFR Section 685.309). Federal regulations state that enrollment information must be reported to the National Student Loan Data System (NSLDS) website within 30 days of whenever attendance changes for students, unless a complete roster will be submitted within 60 days. These changes include reductions or increases in attendance levels, withdrawals, graduations or approved leave of absence. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Additionally, institutions are required to accurately report the student's Campus-Level and Program-Level enrollment data.
Condition – The University did not ensure accurate and timely notification to the NSLDS of student status changes and program-level enrollment data.
Questioned Costs – None noted.
Context – Out of a population of 235 status changes, 36 changes were tested to ensure the University notified the NSLDS of student status changes in a timely manner and used accurate information. Out of these 36 status changes, there were 16 selected where the campus and program-level record information was not in agreement between the NSLDS and the campus level information. Out of these 36 status changes selected for testing, there were 15 instances in which the student's status change was reported after the 60 day requirement. The sample was not, and was not intended to be, a statistically valid sample.
Effect – Notification of student changes was not reported in a timely manner or was reported inaccurately.
Cause – Oversight by management.
Identification as a Repeat Finding – Yes, see prior year findings 2022-002, 2021-001, 2020-002 and 2019-003.
Recommendation – The University should implement monitoring policies and procedures to ensure that notifications are remitted timely and accurately.
Views of Responsible Officials and Planned Corrective Actions – Management has hired a new Director of Institutional Research and provided training and is aware of the federal regulations surrounding enrollment information that must be reported to the NSLDS. Given the complexity of the reporting, management has established additional policies and procedures to address the errors related to enrollment reporting to the NSLDS in a timely and accurate manner.
Student Financial Assistance Cluster
U.S. Department of Education ALNs 84.268, 84.063
Federal Direct Student Loans - Award Year 2023
Federal Pell Grant Program - Award Year 2023
Criteria or Specific Requirement – Special Tests & Provisions: Enrollment Reporting (Pell 34 CFR Section 690.83(b)(2); FDL, 34 CFR Section 685.309). Federal regulations state that enrollment information must be reported to the National Student Loan Data System (NSLDS) website within 30 days of whenever attendance changes for students, unless a complete roster will be submitted within 60 days. These changes include reductions or increases in attendance levels, withdrawals, graduations or approved leave of absence. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Additionally, institutions are required to accurately report the student's Campus-Level and Program-Level enrollment data.
Condition – The University did not ensure accurate and timely notification to the NSLDS of student status changes and program-level enrollment data.
Questioned Costs – None noted.
Context – Out of a population of 235 status changes, 36 changes were tested to ensure the University notified the NSLDS of student status changes in a timely manner and used accurate information. Out of these 36 status changes, there were 16 selected where the campus and program-level record information was not in agreement between the NSLDS and the campus level information. Out of these 36 status changes selected for testing, there were 15 instances in which the student's status change was reported after the 60 day requirement. The sample was not, and was not intended to be, a statistically valid sample.
Effect – Notification of student changes was not reported in a timely manner or was reported inaccurately.
Cause – Oversight by management.
Identification as a Repeat Finding – Yes, see prior year findings 2022-002, 2021-001, 2020-002 and 2019-003.
Recommendation – The University should implement monitoring policies and procedures to ensure that notifications are remitted timely and accurately.
Views of Responsible Officials and Planned Corrective Actions – Management has hired a new Director of Institutional Research and provided training and is aware of the federal regulations surrounding enrollment information that must be reported to the NSLDS. Given the complexity of the reporting, management has established additional policies and procedures to address the errors related to enrollment reporting to the NSLDS in a timely and accurate manner.
Student Financial Assistance Cluster
U.S. Department of Education ALNs 84.268, 84.063
Federal Direct Student Loans - Award Year 2023
Federal Pell Grant Program - Award Year 2023
Criteria or Specific Requirement – Reporting According to 34 CFR 690.83, Dear Colleague Letter Gen 13-13, and Federal Register Volume 84, Number 212, November 1, 2019, an institution must submit Pell and Direct Loan origination records and disbursement records to the Common Origination and Disbursement (COD) in a timely and accurate manner.
Condition – The University did not ensure accurate origination and disbursement reporting to the COD.
Questioned Costs – None noted.
Context – Out of a population of 2,221 students receiving Direct Loan and/or Pell awards during the year, a sample of 40 students were selected for testing. Five errors were noted. There were three instances in which the student's disbursement date was not consistent with the COD, and two instances in which the student's pell award amount was not consistent with the COD. The sample was not, and was not intended to be, a statistically valid sample.
Effect – The University did not report the accurate data (e.g., disbursement dates and amounts) to the COD.
Cause – Lack of reconciliation of student origination records to data provided to the COD.
Identification as a Repeat Finding – Yes, see prior year finding 2022-003
Recommendation – The University should review and update its processes and controls to ensure a formal reconciliation is provided for student origination records to the COD.
Views of Responsible Officials and Planned Corrective Actions – Management has overhauled the underlying processes to include formal monthly reconciliations and additional levels of review. Further, the new process requires that Pell and Direct Loan origination and disbursement records are submitted to the COD by the end of the next business day. The newly implemented reconciliation process validates disbursement dates, amounts and COA in the COD.
Student Financial Assistance Cluster
U.S. Department of Education ALNs 84.268, 84.063
Federal Direct Student Loans - Award Year 2023
Federal Pell Grant Program - Award Year 2023
Criteria or Specific Requirement – Reporting According to 34 CFR 690.83, Dear Colleague Letter Gen 13-13, and Federal Register Volume 84, Number 212, November 1, 2019, an institution must submit Pell and Direct Loan origination records and disbursement records to the Common Origination and Disbursement (COD) in a timely and accurate manner.
Condition – The University did not ensure accurate origination and disbursement reporting to the COD.
Questioned Costs – None noted.
Context – Out of a population of 2,221 students receiving Direct Loan and/or Pell awards during the year, a sample of 40 students were selected for testing. Five errors were noted. There were three instances in which the student's disbursement date was not consistent with the COD, and two instances in which the student's pell award amount was not consistent with the COD. The sample was not, and was not intended to be, a statistically valid sample.
Effect – The University did not report the accurate data (e.g., disbursement dates and amounts) to the COD.
Cause – Lack of reconciliation of student origination records to data provided to the COD.
Identification as a Repeat Finding – Yes, see prior year finding 2022-003
Recommendation – The University should review and update its processes and controls to ensure a formal reconciliation is provided for student origination records to the COD.
Views of Responsible Officials and Planned Corrective Actions – Management has overhauled the underlying processes to include formal monthly reconciliations and additional levels of review. Further, the new process requires that Pell and Direct Loan origination and disbursement records are submitted to the COD by the end of the next business day. The newly implemented reconciliation process validates disbursement dates, amounts and COA in the COD.
Student Financial Assistance Cluster
U.S. Department of Education ALNs 84.268, 84.063, 84.033, 84.379, 84.007
Federal Direct Student Loans - Award Year 2023
Federal Pell Grant Program - Award Year 2023
Federal Work-Study Program - Award Year 2023
Teacher Education Assistance for College and Higher Education Grants - Award Year 2023
Federal Supplemental Educational Opportunities Grant - Award Year 2023
Criteria or Specific Requirement – Special Tests & Provisions: Gramm-Leach-Bliley Act The Gramm-Leach-Bliley Act requires financial institutions to explain their information-sharing to their customers and to safeguard sensitive data. The Federal Trade Commision considers Title IV-eligible institutions that participate in Title IV Educational Assistance Program as "financial institutions" and subject to the Gramm-Leach-Bliley Act because they appear to be significantly engaged in wiring funds to consumers. Under 16 CFR 314, institutions are required to develop, implement and maintain a comprehensive information security program that adresses the implementation of eight minimum safeguards.
Condition – The University does not have a written information security program that addresses the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8), nor the requirements identified in 16 CFR 314.4(d) and (g).
Questioned Costs – None noted.
Context – Through inquirty of management and review of information policies published on the University's website, it was determined the eight requirements were not all included in a comprehensive policy that met the minimum requirements.
Effect – The University was not in compliance with the Gramm-Leach-Bliley Act.
Cause – The University's policy was not finalized.
Identification as a Repeat Finding – Not applicable.
Recommendation – We recommend management takes necessary steps to finalize a written information security policy that complies with the safeguards identified within 16 CFR 314.
Views of Responsible Officials and Planned Corrective Actions – Management agrees with the stated finding and has implemented a corrective action plan.
Student Financial Assistance Cluster
U.S. Department of Education ALNs 84.268, 84.063, 84.033, 84.379, 84.007
Federal Direct Student Loans - Award Year 2023
Federal Pell Grant Program - Award Year 2023
Federal Work-Study Program - Award Year 2023
Teacher Education Assistance for College and Higher Education Grants - Award Year 2023
Federal Supplemental Educational Opportunities Grant - Award Year 2023
Criteria or Specific Requirement – Special Tests & Provisions: Gramm-Leach-Bliley Act The Gramm-Leach-Bliley Act requires financial institutions to explain their information-sharing to their customers and to safeguard sensitive data. The Federal Trade Commision considers Title IV-eligible institutions that participate in Title IV Educational Assistance Program as "financial institutions" and subject to the Gramm-Leach-Bliley Act because they appear to be significantly engaged in wiring funds to consumers. Under 16 CFR 314, institutions are required to develop, implement and maintain a comprehensive information security program that adresses the implementation of eight minimum safeguards.
Condition – The University does not have a written information security program that addresses the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8), nor the requirements identified in 16 CFR 314.4(d) and (g).
Questioned Costs – None noted.
Context – Through inquirty of management and review of information policies published on the University's website, it was determined the eight requirements were not all included in a comprehensive policy that met the minimum requirements.
Effect – The University was not in compliance with the Gramm-Leach-Bliley Act.
Cause – The University's policy was not finalized.
Identification as a Repeat Finding – Not applicable.
Recommendation – We recommend management takes necessary steps to finalize a written information security policy that complies with the safeguards identified within 16 CFR 314.
Views of Responsible Officials and Planned Corrective Actions – Management agrees with the stated finding and has implemented a corrective action plan.
Student Financial Assistance Cluster
U.S. Department of Education ALNs 84.268, 84.063, 84.033, 84.379, 84.007
Federal Direct Student Loans - Award Year 2023
Federal Pell Grant Program - Award Year 2023
Federal Work-Study Program - Award Year 2023
Teacher Education Assistance for College and Higher Education Grants - Award Year 2023
Federal Supplemental Educational Opportunities Grant - Award Year 2023
Criteria or Specific Requirement – Special Tests & Provisions: Gramm-Leach-Bliley Act The Gramm-Leach-Bliley Act requires financial institutions to explain their information-sharing to their customers and to safeguard sensitive data. The Federal Trade Commision considers Title IV-eligible institutions that participate in Title IV Educational Assistance Program as "financial institutions" and subject to the Gramm-Leach-Bliley Act because they appear to be significantly engaged in wiring funds to consumers. Under 16 CFR 314, institutions are required to develop, implement and maintain a comprehensive information security program that adresses the implementation of eight minimum safeguards.
Condition – The University does not have a written information security program that addresses the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8), nor the requirements identified in 16 CFR 314.4(d) and (g).
Questioned Costs – None noted.
Context – Through inquirty of management and review of information policies published on the University's website, it was determined the eight requirements were not all included in a comprehensive policy that met the minimum requirements.
Effect – The University was not in compliance with the Gramm-Leach-Bliley Act.
Cause – The University's policy was not finalized.
Identification as a Repeat Finding – Not applicable.
Recommendation – We recommend management takes necessary steps to finalize a written information security policy that complies with the safeguards identified within 16 CFR 314.
Views of Responsible Officials and Planned Corrective Actions – Management agrees with the stated finding and has implemented a corrective action plan.
Student Financial Assistance Cluster
U.S. Department of Education ALNs 84.268, 84.063, 84.033, 84.379, 84.007
Federal Direct Student Loans - Award Year 2023
Federal Pell Grant Program - Award Year 2023
Federal Work-Study Program - Award Year 2023
Teacher Education Assistance for College and Higher Education Grants - Award Year 2023
Federal Supplemental Educational Opportunities Grant - Award Year 2023
Criteria or Specific Requirement – Special Tests & Provisions: Gramm-Leach-Bliley Act The Gramm-Leach-Bliley Act requires financial institutions to explain their information-sharing to their customers and to safeguard sensitive data. The Federal Trade Commision considers Title IV-eligible institutions that participate in Title IV Educational Assistance Program as "financial institutions" and subject to the Gramm-Leach-Bliley Act because they appear to be significantly engaged in wiring funds to consumers. Under 16 CFR 314, institutions are required to develop, implement and maintain a comprehensive information security program that adresses the implementation of eight minimum safeguards.
Condition – The University does not have a written information security program that addresses the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8), nor the requirements identified in 16 CFR 314.4(d) and (g).
Questioned Costs – None noted.
Context – Through inquirty of management and review of information policies published on the University's website, it was determined the eight requirements were not all included in a comprehensive policy that met the minimum requirements.
Effect – The University was not in compliance with the Gramm-Leach-Bliley Act.
Cause – The University's policy was not finalized.
Identification as a Repeat Finding – Not applicable.
Recommendation – We recommend management takes necessary steps to finalize a written information security policy that complies with the safeguards identified within 16 CFR 314.
Views of Responsible Officials and Planned Corrective Actions – Management agrees with the stated finding and has implemented a corrective action plan.
Student Financial Assistance Cluster
U.S. Department of Education ALNs 84.268, 84.063, 84.033, 84.379, 84.007
Federal Direct Student Loans - Award Year 2023
Federal Pell Grant Program - Award Year 2023
Federal Work-Study Program - Award Year 2023
Teacher Education Assistance for College and Higher Education Grants - Award Year 2023
Federal Supplemental Educational Opportunities Grant - Award Year 2023
Criteria or Specific Requirement – Special Tests & Provisions: Gramm-Leach-Bliley Act The Gramm-Leach-Bliley Act requires financial institutions to explain their information-sharing to their customers and to safeguard sensitive data. The Federal Trade Commision considers Title IV-eligible institutions that participate in Title IV Educational Assistance Program as "financial institutions" and subject to the Gramm-Leach-Bliley Act because they appear to be significantly engaged in wiring funds to consumers. Under 16 CFR 314, institutions are required to develop, implement and maintain a comprehensive information security program that adresses the implementation of eight minimum safeguards.
Condition – The University does not have a written information security program that addresses the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8), nor the requirements identified in 16 CFR 314.4(d) and (g).
Questioned Costs – None noted.
Context – Through inquirty of management and review of information policies published on the University's website, it was determined the eight requirements were not all included in a comprehensive policy that met the minimum requirements.
Effect – The University was not in compliance with the Gramm-Leach-Bliley Act.
Cause – The University's policy was not finalized.
Identification as a Repeat Finding – Not applicable.
Recommendation – We recommend management takes necessary steps to finalize a written information security policy that complies with the safeguards identified within 16 CFR 314.
Views of Responsible Officials and Planned Corrective Actions – Management agrees with the stated finding and has implemented a corrective action plan.
Student Financial Assistance Cluster
U.S. Department of Education ALNs 84.268, 84.063
Federal Direct Student Loans - Award Year 2023
Federal Pell Grant Program - Award Year 2023
Criteria or Specific Requirement – Special Tests & Provisions: Enrollment Reporting (Pell 34 CFR Section 690.83(b)(2); FDL, 34 CFR Section 685.309). Federal regulations state that enrollment information must be reported to the National Student Loan Data System (NSLDS) website within 30 days of whenever attendance changes for students, unless a complete roster will be submitted within 60 days. These changes include reductions or increases in attendance levels, withdrawals, graduations or approved leave of absence. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Additionally, institutions are required to accurately report the student's Campus-Level and Program-Level enrollment data.
Condition – The University did not ensure accurate and timely notification to the NSLDS of student status changes and program-level enrollment data.
Questioned Costs – None noted.
Context – Out of a population of 235 status changes, 36 changes were tested to ensure the University notified the NSLDS of student status changes in a timely manner and used accurate information. Out of these 36 status changes, there were 16 selected where the campus and program-level record information was not in agreement between the NSLDS and the campus level information. Out of these 36 status changes selected for testing, there were 15 instances in which the student's status change was reported after the 60 day requirement. The sample was not, and was not intended to be, a statistically valid sample.
Effect – Notification of student changes was not reported in a timely manner or was reported inaccurately.
Cause – Oversight by management.
Identification as a Repeat Finding – Yes, see prior year findings 2022-002, 2021-001, 2020-002 and 2019-003.
Recommendation – The University should implement monitoring policies and procedures to ensure that notifications are remitted timely and accurately.
Views of Responsible Officials and Planned Corrective Actions – Management has hired a new Director of Institutional Research and provided training and is aware of the federal regulations surrounding enrollment information that must be reported to the NSLDS. Given the complexity of the reporting, management has established additional policies and procedures to address the errors related to enrollment reporting to the NSLDS in a timely and accurate manner.
Student Financial Assistance Cluster
U.S. Department of Education ALNs 84.268, 84.063
Federal Direct Student Loans - Award Year 2023
Federal Pell Grant Program - Award Year 2023
Criteria or Specific Requirement – Special Tests & Provisions: Enrollment Reporting (Pell 34 CFR Section 690.83(b)(2); FDL, 34 CFR Section 685.309). Federal regulations state that enrollment information must be reported to the National Student Loan Data System (NSLDS) website within 30 days of whenever attendance changes for students, unless a complete roster will be submitted within 60 days. These changes include reductions or increases in attendance levels, withdrawals, graduations or approved leave of absence. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Additionally, institutions are required to accurately report the student's Campus-Level and Program-Level enrollment data.
Condition – The University did not ensure accurate and timely notification to the NSLDS of student status changes and program-level enrollment data.
Questioned Costs – None noted.
Context – Out of a population of 235 status changes, 36 changes were tested to ensure the University notified the NSLDS of student status changes in a timely manner and used accurate information. Out of these 36 status changes, there were 16 selected where the campus and program-level record information was not in agreement between the NSLDS and the campus level information. Out of these 36 status changes selected for testing, there were 15 instances in which the student's status change was reported after the 60 day requirement. The sample was not, and was not intended to be, a statistically valid sample.
Effect – Notification of student changes was not reported in a timely manner or was reported inaccurately.
Cause – Oversight by management.
Identification as a Repeat Finding – Yes, see prior year findings 2022-002, 2021-001, 2020-002 and 2019-003.
Recommendation – The University should implement monitoring policies and procedures to ensure that notifications are remitted timely and accurately.
Views of Responsible Officials and Planned Corrective Actions – Management has hired a new Director of Institutional Research and provided training and is aware of the federal regulations surrounding enrollment information that must be reported to the NSLDS. Given the complexity of the reporting, management has established additional policies and procedures to address the errors related to enrollment reporting to the NSLDS in a timely and accurate manner.
Student Financial Assistance Cluster
U.S. Department of Education ALNs 84.268, 84.063
Federal Direct Student Loans - Award Year 2023
Federal Pell Grant Program - Award Year 2023
Criteria or Specific Requirement – Reporting According to 34 CFR 690.83, Dear Colleague Letter Gen 13-13, and Federal Register Volume 84, Number 212, November 1, 2019, an institution must submit Pell and Direct Loan origination records and disbursement records to the Common Origination and Disbursement (COD) in a timely and accurate manner.
Condition – The University did not ensure accurate origination and disbursement reporting to the COD.
Questioned Costs – None noted.
Context – Out of a population of 2,221 students receiving Direct Loan and/or Pell awards during the year, a sample of 40 students were selected for testing. Five errors were noted. There were three instances in which the student's disbursement date was not consistent with the COD, and two instances in which the student's pell award amount was not consistent with the COD. The sample was not, and was not intended to be, a statistically valid sample.
Effect – The University did not report the accurate data (e.g., disbursement dates and amounts) to the COD.
Cause – Lack of reconciliation of student origination records to data provided to the COD.
Identification as a Repeat Finding – Yes, see prior year finding 2022-003
Recommendation – The University should review and update its processes and controls to ensure a formal reconciliation is provided for student origination records to the COD.
Views of Responsible Officials and Planned Corrective Actions – Management has overhauled the underlying processes to include formal monthly reconciliations and additional levels of review. Further, the new process requires that Pell and Direct Loan origination and disbursement records are submitted to the COD by the end of the next business day. The newly implemented reconciliation process validates disbursement dates, amounts and COA in the COD.
Student Financial Assistance Cluster
U.S. Department of Education ALNs 84.268, 84.063
Federal Direct Student Loans - Award Year 2023
Federal Pell Grant Program - Award Year 2023
Criteria or Specific Requirement – Reporting According to 34 CFR 690.83, Dear Colleague Letter Gen 13-13, and Federal Register Volume 84, Number 212, November 1, 2019, an institution must submit Pell and Direct Loan origination records and disbursement records to the Common Origination and Disbursement (COD) in a timely and accurate manner.
Condition – The University did not ensure accurate origination and disbursement reporting to the COD.
Questioned Costs – None noted.
Context – Out of a population of 2,221 students receiving Direct Loan and/or Pell awards during the year, a sample of 40 students were selected for testing. Five errors were noted. There were three instances in which the student's disbursement date was not consistent with the COD, and two instances in which the student's pell award amount was not consistent with the COD. The sample was not, and was not intended to be, a statistically valid sample.
Effect – The University did not report the accurate data (e.g., disbursement dates and amounts) to the COD.
Cause – Lack of reconciliation of student origination records to data provided to the COD.
Identification as a Repeat Finding – Yes, see prior year finding 2022-003
Recommendation – The University should review and update its processes and controls to ensure a formal reconciliation is provided for student origination records to the COD.
Views of Responsible Officials and Planned Corrective Actions – Management has overhauled the underlying processes to include formal monthly reconciliations and additional levels of review. Further, the new process requires that Pell and Direct Loan origination and disbursement records are submitted to the COD by the end of the next business day. The newly implemented reconciliation process validates disbursement dates, amounts and COA in the COD.
Student Financial Assistance Cluster
U.S. Department of Education ALNs 84.268, 84.063, 84.033, 84.379, 84.007
Federal Direct Student Loans - Award Year 2023
Federal Pell Grant Program - Award Year 2023
Federal Work-Study Program - Award Year 2023
Teacher Education Assistance for College and Higher Education Grants - Award Year 2023
Federal Supplemental Educational Opportunities Grant - Award Year 2023
Criteria or Specific Requirement – Special Tests & Provisions: Gramm-Leach-Bliley Act The Gramm-Leach-Bliley Act requires financial institutions to explain their information-sharing to their customers and to safeguard sensitive data. The Federal Trade Commision considers Title IV-eligible institutions that participate in Title IV Educational Assistance Program as "financial institutions" and subject to the Gramm-Leach-Bliley Act because they appear to be significantly engaged in wiring funds to consumers. Under 16 CFR 314, institutions are required to develop, implement and maintain a comprehensive information security program that adresses the implementation of eight minimum safeguards.
Condition – The University does not have a written information security program that addresses the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8), nor the requirements identified in 16 CFR 314.4(d) and (g).
Questioned Costs – None noted.
Context – Through inquirty of management and review of information policies published on the University's website, it was determined the eight requirements were not all included in a comprehensive policy that met the minimum requirements.
Effect – The University was not in compliance with the Gramm-Leach-Bliley Act.
Cause – The University's policy was not finalized.
Identification as a Repeat Finding – Not applicable.
Recommendation – We recommend management takes necessary steps to finalize a written information security policy that complies with the safeguards identified within 16 CFR 314.
Views of Responsible Officials and Planned Corrective Actions – Management agrees with the stated finding and has implemented a corrective action plan.
Student Financial Assistance Cluster
U.S. Department of Education ALNs 84.268, 84.063, 84.033, 84.379, 84.007
Federal Direct Student Loans - Award Year 2023
Federal Pell Grant Program - Award Year 2023
Federal Work-Study Program - Award Year 2023
Teacher Education Assistance for College and Higher Education Grants - Award Year 2023
Federal Supplemental Educational Opportunities Grant - Award Year 2023
Criteria or Specific Requirement – Special Tests & Provisions: Gramm-Leach-Bliley Act The Gramm-Leach-Bliley Act requires financial institutions to explain their information-sharing to their customers and to safeguard sensitive data. The Federal Trade Commision considers Title IV-eligible institutions that participate in Title IV Educational Assistance Program as "financial institutions" and subject to the Gramm-Leach-Bliley Act because they appear to be significantly engaged in wiring funds to consumers. Under 16 CFR 314, institutions are required to develop, implement and maintain a comprehensive information security program that adresses the implementation of eight minimum safeguards.
Condition – The University does not have a written information security program that addresses the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8), nor the requirements identified in 16 CFR 314.4(d) and (g).
Questioned Costs – None noted.
Context – Through inquirty of management and review of information policies published on the University's website, it was determined the eight requirements were not all included in a comprehensive policy that met the minimum requirements.
Effect – The University was not in compliance with the Gramm-Leach-Bliley Act.
Cause – The University's policy was not finalized.
Identification as a Repeat Finding – Not applicable.
Recommendation – We recommend management takes necessary steps to finalize a written information security policy that complies with the safeguards identified within 16 CFR 314.
Views of Responsible Officials and Planned Corrective Actions – Management agrees with the stated finding and has implemented a corrective action plan.
Student Financial Assistance Cluster
U.S. Department of Education ALNs 84.268, 84.063, 84.033, 84.379, 84.007
Federal Direct Student Loans - Award Year 2023
Federal Pell Grant Program - Award Year 2023
Federal Work-Study Program - Award Year 2023
Teacher Education Assistance for College and Higher Education Grants - Award Year 2023
Federal Supplemental Educational Opportunities Grant - Award Year 2023
Criteria or Specific Requirement – Special Tests & Provisions: Gramm-Leach-Bliley Act The Gramm-Leach-Bliley Act requires financial institutions to explain their information-sharing to their customers and to safeguard sensitive data. The Federal Trade Commision considers Title IV-eligible institutions that participate in Title IV Educational Assistance Program as "financial institutions" and subject to the Gramm-Leach-Bliley Act because they appear to be significantly engaged in wiring funds to consumers. Under 16 CFR 314, institutions are required to develop, implement and maintain a comprehensive information security program that adresses the implementation of eight minimum safeguards.
Condition – The University does not have a written information security program that addresses the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8), nor the requirements identified in 16 CFR 314.4(d) and (g).
Questioned Costs – None noted.
Context – Through inquirty of management and review of information policies published on the University's website, it was determined the eight requirements were not all included in a comprehensive policy that met the minimum requirements.
Effect – The University was not in compliance with the Gramm-Leach-Bliley Act.
Cause – The University's policy was not finalized.
Identification as a Repeat Finding – Not applicable.
Recommendation – We recommend management takes necessary steps to finalize a written information security policy that complies with the safeguards identified within 16 CFR 314.
Views of Responsible Officials and Planned Corrective Actions – Management agrees with the stated finding and has implemented a corrective action plan.
Student Financial Assistance Cluster
U.S. Department of Education ALNs 84.268, 84.063, 84.033, 84.379, 84.007
Federal Direct Student Loans - Award Year 2023
Federal Pell Grant Program - Award Year 2023
Federal Work-Study Program - Award Year 2023
Teacher Education Assistance for College and Higher Education Grants - Award Year 2023
Federal Supplemental Educational Opportunities Grant - Award Year 2023
Criteria or Specific Requirement – Special Tests & Provisions: Gramm-Leach-Bliley Act The Gramm-Leach-Bliley Act requires financial institutions to explain their information-sharing to their customers and to safeguard sensitive data. The Federal Trade Commision considers Title IV-eligible institutions that participate in Title IV Educational Assistance Program as "financial institutions" and subject to the Gramm-Leach-Bliley Act because they appear to be significantly engaged in wiring funds to consumers. Under 16 CFR 314, institutions are required to develop, implement and maintain a comprehensive information security program that adresses the implementation of eight minimum safeguards.
Condition – The University does not have a written information security program that addresses the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8), nor the requirements identified in 16 CFR 314.4(d) and (g).
Questioned Costs – None noted.
Context – Through inquirty of management and review of information policies published on the University's website, it was determined the eight requirements were not all included in a comprehensive policy that met the minimum requirements.
Effect – The University was not in compliance with the Gramm-Leach-Bliley Act.
Cause – The University's policy was not finalized.
Identification as a Repeat Finding – Not applicable.
Recommendation – We recommend management takes necessary steps to finalize a written information security policy that complies with the safeguards identified within 16 CFR 314.
Views of Responsible Officials and Planned Corrective Actions – Management agrees with the stated finding and has implemented a corrective action plan.
Student Financial Assistance Cluster
U.S. Department of Education ALNs 84.268, 84.063, 84.033, 84.379, 84.007
Federal Direct Student Loans - Award Year 2023
Federal Pell Grant Program - Award Year 2023
Federal Work-Study Program - Award Year 2023
Teacher Education Assistance for College and Higher Education Grants - Award Year 2023
Federal Supplemental Educational Opportunities Grant - Award Year 2023
Criteria or Specific Requirement – Special Tests & Provisions: Gramm-Leach-Bliley Act The Gramm-Leach-Bliley Act requires financial institutions to explain their information-sharing to their customers and to safeguard sensitive data. The Federal Trade Commision considers Title IV-eligible institutions that participate in Title IV Educational Assistance Program as "financial institutions" and subject to the Gramm-Leach-Bliley Act because they appear to be significantly engaged in wiring funds to consumers. Under 16 CFR 314, institutions are required to develop, implement and maintain a comprehensive information security program that adresses the implementation of eight minimum safeguards.
Condition – The University does not have a written information security program that addresses the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8), nor the requirements identified in 16 CFR 314.4(d) and (g).
Questioned Costs – None noted.
Context – Through inquirty of management and review of information policies published on the University's website, it was determined the eight requirements were not all included in a comprehensive policy that met the minimum requirements.
Effect – The University was not in compliance with the Gramm-Leach-Bliley Act.
Cause – The University's policy was not finalized.
Identification as a Repeat Finding – Not applicable.
Recommendation – We recommend management takes necessary steps to finalize a written information security policy that complies with the safeguards identified within 16 CFR 314.
Views of Responsible Officials and Planned Corrective Actions – Management agrees with the stated finding and has implemented a corrective action plan.