Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, 84.033, and 84.038-Student Financial Assistance Cluster
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The University did not sufficiently comply with the updated requirements of GLBA.
Criteria: 16 CFR 314.3, 16 CFR 314.4
Questioned Costs: $-0-
Context: The University has not fully updated its written information security program and security risk assessment and safeguards, including multi-factor authentication on all systems containing personally identifiable information (PII) in light of the revised regulations. Additionally, the University has not fully implemented continuous monitoring, such as penetration testing and vulnerability scanning, implemented sufficient employee and information security staff training, implemented sufficient vendor management policies and reviews, or provided a written, annual report to the board covering all required areas.
Cause: The University has not allocated sufficient resources to address and document compliance with the requirements of GLBA.
Effect: The University has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: Yes, 2022-002
Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, 84.033, and 84.038-Student Financial Assistance Cluster
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The University did not sufficiently comply with the updated requirements of GLBA.
Criteria: 16 CFR 314.3, 16 CFR 314.4
Questioned Costs: $-0-
Context: The University has not fully updated its written information security program and security risk assessment and safeguards, including multi-factor authentication on all systems containing personally identifiable information (PII) in light of the revised regulations. Additionally, the University has not fully implemented continuous monitoring, such as penetration testing and vulnerability scanning, implemented sufficient employee and information security staff training, implemented sufficient vendor management policies and reviews, or provided a written, annual report to the board covering all required areas.
Cause: The University has not allocated sufficient resources to address and document compliance with the requirements of GLBA.
Effect: The University has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: Yes, 2022-002
Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, 84.033, and 84.038-Student Financial Assistance Cluster
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The University did not sufficiently comply with the updated requirements of GLBA.
Criteria: 16 CFR 314.3, 16 CFR 314.4
Questioned Costs: $-0-
Context: The University has not fully updated its written information security program and security risk assessment and safeguards, including multi-factor authentication on all systems containing personally identifiable information (PII) in light of the revised regulations. Additionally, the University has not fully implemented continuous monitoring, such as penetration testing and vulnerability scanning, implemented sufficient employee and information security staff training, implemented sufficient vendor management policies and reviews, or provided a written, annual report to the board covering all required areas.
Cause: The University has not allocated sufficient resources to address and document compliance with the requirements of GLBA.
Effect: The University has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: Yes, 2022-002
Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, 84.033, and 84.038-Student Financial Assistance Cluster
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The University did not sufficiently comply with the updated requirements of GLBA.
Criteria: 16 CFR 314.3, 16 CFR 314.4
Questioned Costs: $-0-
Context: The University has not fully updated its written information security program and security risk assessment and safeguards, including multi-factor authentication on all systems containing personally identifiable information (PII) in light of the revised regulations. Additionally, the University has not fully implemented continuous monitoring, such as penetration testing and vulnerability scanning, implemented sufficient employee and information security staff training, implemented sufficient vendor management policies and reviews, or provided a written, annual report to the board covering all required areas.
Cause: The University has not allocated sufficient resources to address and document compliance with the requirements of GLBA.
Effect: The University has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: Yes, 2022-002
Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, 84.033, and 84.038-Student Financial Assistance Cluster
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The University did not sufficiently comply with the updated requirements of GLBA.
Criteria: 16 CFR 314.3, 16 CFR 314.4
Questioned Costs: $-0-
Context: The University has not fully updated its written information security program and security risk assessment and safeguards, including multi-factor authentication on all systems containing personally identifiable information (PII) in light of the revised regulations. Additionally, the University has not fully implemented continuous monitoring, such as penetration testing and vulnerability scanning, implemented sufficient employee and information security staff training, implemented sufficient vendor management policies and reviews, or provided a written, annual report to the board covering all required areas.
Cause: The University has not allocated sufficient resources to address and document compliance with the requirements of GLBA.
Effect: The University has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: Yes, 2022-002
Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Enrollment Reporting to National Student Loan Data System (NSLDS) DEPARTMENT OF EDUCATION
ALN #: 84.268 and 84.063
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The University did not report enrollment information to the National Student Loan Data System (NSLDS) in an accurate manner.
Criteria: 34 CFR 690.83(b) and 34 CFR 685.309
Questioned Costs: $-0-
Context: Out of 66 students tested for proper NSLDS enrollment status, 7 students had not been properly reported as graduated to NSLDS.
Cause: The University submitted accurate information to their third-party administrator however the University had not performed periodic checks to ensure that student information was uploaded to NSLDS accurately.
Effect: Inaccurate reporting can impact a student's loan grace period, in school deferment eligibility, beginning loan repayments, appropriate interest charges, etc.
Identification as repeat finding, if applicable: N/A
Recommendation: We recommend the University put a system in place to ensure that enrollment is reported timely and accurately. Additionally, we recommend the University complete spot checks of NSLDS enrollment statuses throughout the year including a graduation spot check after each academic term.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Enrollment Reporting to National Student Loan Data System (NSLDS) DEPARTMENT OF EDUCATION
ALN #: 84.268 and 84.063
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The University did not report enrollment information to the National Student Loan Data System (NSLDS) in an accurate manner.
Criteria: 34 CFR 690.83(b) and 34 CFR 685.309
Questioned Costs: $-0-
Context: Out of 66 students tested for proper NSLDS enrollment status, 7 students had not been properly reported as graduated to NSLDS.
Cause: The University submitted accurate information to their third-party administrator however the University had not performed periodic checks to ensure that student information was uploaded to NSLDS accurately.
Effect: Inaccurate reporting can impact a student's loan grace period, in school deferment eligibility, beginning loan repayments, appropriate interest charges, etc.
Identification as repeat finding, if applicable: N/A
Recommendation: We recommend the University put a system in place to ensure that enrollment is reported timely and accurately. Additionally, we recommend the University complete spot checks of NSLDS enrollment statuses throughout the year including a graduation spot check after each academic term.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, 84.033, and 84.038-Student Financial Assistance Cluster
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The University did not sufficiently comply with the updated requirements of GLBA.
Criteria: 16 CFR 314.3, 16 CFR 314.4
Questioned Costs: $-0-
Context: The University has not fully updated its written information security program and security risk assessment and safeguards, including multi-factor authentication on all systems containing personally identifiable information (PII) in light of the revised regulations. Additionally, the University has not fully implemented continuous monitoring, such as penetration testing and vulnerability scanning, implemented sufficient employee and information security staff training, implemented sufficient vendor management policies and reviews, or provided a written, annual report to the board covering all required areas.
Cause: The University has not allocated sufficient resources to address and document compliance with the requirements of GLBA.
Effect: The University has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: Yes, 2022-002
Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, 84.033, and 84.038-Student Financial Assistance Cluster
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The University did not sufficiently comply with the updated requirements of GLBA.
Criteria: 16 CFR 314.3, 16 CFR 314.4
Questioned Costs: $-0-
Context: The University has not fully updated its written information security program and security risk assessment and safeguards, including multi-factor authentication on all systems containing personally identifiable information (PII) in light of the revised regulations. Additionally, the University has not fully implemented continuous monitoring, such as penetration testing and vulnerability scanning, implemented sufficient employee and information security staff training, implemented sufficient vendor management policies and reviews, or provided a written, annual report to the board covering all required areas.
Cause: The University has not allocated sufficient resources to address and document compliance with the requirements of GLBA.
Effect: The University has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: Yes, 2022-002
Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, 84.033, and 84.038-Student Financial Assistance Cluster
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The University did not sufficiently comply with the updated requirements of GLBA.
Criteria: 16 CFR 314.3, 16 CFR 314.4
Questioned Costs: $-0-
Context: The University has not fully updated its written information security program and security risk assessment and safeguards, including multi-factor authentication on all systems containing personally identifiable information (PII) in light of the revised regulations. Additionally, the University has not fully implemented continuous monitoring, such as penetration testing and vulnerability scanning, implemented sufficient employee and information security staff training, implemented sufficient vendor management policies and reviews, or provided a written, annual report to the board covering all required areas.
Cause: The University has not allocated sufficient resources to address and document compliance with the requirements of GLBA.
Effect: The University has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: Yes, 2022-002
Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, 84.033, and 84.038-Student Financial Assistance Cluster
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The University did not sufficiently comply with the updated requirements of GLBA.
Criteria: 16 CFR 314.3, 16 CFR 314.4
Questioned Costs: $-0-
Context: The University has not fully updated its written information security program and security risk assessment and safeguards, including multi-factor authentication on all systems containing personally identifiable information (PII) in light of the revised regulations. Additionally, the University has not fully implemented continuous monitoring, such as penetration testing and vulnerability scanning, implemented sufficient employee and information security staff training, implemented sufficient vendor management policies and reviews, or provided a written, annual report to the board covering all required areas.
Cause: The University has not allocated sufficient resources to address and document compliance with the requirements of GLBA.
Effect: The University has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: Yes, 2022-002
Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, 84.033, and 84.038-Student Financial Assistance Cluster
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The University did not sufficiently comply with the updated requirements of GLBA.
Criteria: 16 CFR 314.3, 16 CFR 314.4
Questioned Costs: $-0-
Context: The University has not fully updated its written information security program and security risk assessment and safeguards, including multi-factor authentication on all systems containing personally identifiable information (PII) in light of the revised regulations. Additionally, the University has not fully implemented continuous monitoring, such as penetration testing and vulnerability scanning, implemented sufficient employee and information security staff training, implemented sufficient vendor management policies and reviews, or provided a written, annual report to the board covering all required areas.
Cause: The University has not allocated sufficient resources to address and document compliance with the requirements of GLBA.
Effect: The University has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: Yes, 2022-002
Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Enrollment Reporting to National Student Loan Data System (NSLDS) DEPARTMENT OF EDUCATION
ALN #: 84.268 and 84.063
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The University did not report enrollment information to the National Student Loan Data System (NSLDS) in an accurate manner.
Criteria: 34 CFR 690.83(b) and 34 CFR 685.309
Questioned Costs: $-0-
Context: Out of 66 students tested for proper NSLDS enrollment status, 7 students had not been properly reported as graduated to NSLDS.
Cause: The University submitted accurate information to their third-party administrator however the University had not performed periodic checks to ensure that student information was uploaded to NSLDS accurately.
Effect: Inaccurate reporting can impact a student's loan grace period, in school deferment eligibility, beginning loan repayments, appropriate interest charges, etc.
Identification as repeat finding, if applicable: N/A
Recommendation: We recommend the University put a system in place to ensure that enrollment is reported timely and accurately. Additionally, we recommend the University complete spot checks of NSLDS enrollment statuses throughout the year including a graduation spot check after each academic term.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Enrollment Reporting to National Student Loan Data System (NSLDS) DEPARTMENT OF EDUCATION
ALN #: 84.268 and 84.063
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The University did not report enrollment information to the National Student Loan Data System (NSLDS) in an accurate manner.
Criteria: 34 CFR 690.83(b) and 34 CFR 685.309
Questioned Costs: $-0-
Context: Out of 66 students tested for proper NSLDS enrollment status, 7 students had not been properly reported as graduated to NSLDS.
Cause: The University submitted accurate information to their third-party administrator however the University had not performed periodic checks to ensure that student information was uploaded to NSLDS accurately.
Effect: Inaccurate reporting can impact a student's loan grace period, in school deferment eligibility, beginning loan repayments, appropriate interest charges, etc.
Identification as repeat finding, if applicable: N/A
Recommendation: We recommend the University put a system in place to ensure that enrollment is reported timely and accurately. Additionally, we recommend the University complete spot checks of NSLDS enrollment statuses throughout the year including a graduation spot check after each academic term.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.