Untimely Returns of Title IV Funds (R2T4) Material Weakness
DEPARTMENT OF EDUCATION
ALN #: 84.268
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: When students withdrew either officially or unofficially, the University did not always return unearned Title IV aid timely.
Criteria: 34 CFR 668.22
Questioned Costs: $-0-
Context: Out of 25 students tested for accurate and timely R2T4s, 5 students who withdrew during the audit period tested had $5,255 returned late. Four of the late returns were made after the fiscal year and between 160-475 days late. One return was during the fiscal year and 109 days late.
Cause: This was an oversight by the University.
Effect: Returns of Title IV funds were not performed timely.
Identification as repeat finding, if applicable: 2022-002
Recommendation: We recommend a zero-credit report be run at the end of each semester to ensure all unofficial withdrawals are followed up on so that R2T4s are completed timely when required.
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, 84.038, and 84.379 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 updated its written information security program in alignment with the revised regulations; sufficiently documented its security risk assessment and safeguards, including general threats; implemented multi-factor authentication on systems containing personally identifiable information (PII); implemented continuous monitoring, such as penetration testing and vulnerability scanning; implemented sufficient vendor management policies and reviews; implemented an incident response plan; or provided a written, annual report to the board.
Cause: The University has not allocated sufficient resources to address and document compliance with the updated requirements of GLBA.
Effect: The University has not adequately addressed the updated requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: Not applicable.
Recommendation: We recommend the University allocate sufficient resources to address all updated 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, 84.038, and 84.379 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 updated its written information security program in alignment with the revised regulations; sufficiently documented its security risk assessment and safeguards, including general threats; implemented multi-factor authentication on systems containing personally identifiable information (PII); implemented continuous monitoring, such as penetration testing and vulnerability scanning; implemented sufficient vendor management policies and reviews; implemented an incident response plan; or provided a written, annual report to the board.
Cause: The University has not allocated sufficient resources to address and document compliance with the updated requirements of GLBA.
Effect: The University has not adequately addressed the updated requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: Not applicable.
Recommendation: We recommend the University allocate sufficient resources to address all updated 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, 84.038, and 84.379 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 updated its written information security program in alignment with the revised regulations; sufficiently documented its security risk assessment and safeguards, including general threats; implemented multi-factor authentication on systems containing personally identifiable information (PII); implemented continuous monitoring, such as penetration testing and vulnerability scanning; implemented sufficient vendor management policies and reviews; implemented an incident response plan; or provided a written, annual report to the board.
Cause: The University has not allocated sufficient resources to address and document compliance with the updated requirements of GLBA.
Effect: The University has not adequately addressed the updated requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: Not applicable.
Recommendation: We recommend the University allocate sufficient resources to address all updated 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, 84.038, and 84.379 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 updated its written information security program in alignment with the revised regulations; sufficiently documented its security risk assessment and safeguards, including general threats; implemented multi-factor authentication on systems containing personally identifiable information (PII); implemented continuous monitoring, such as penetration testing and vulnerability scanning; implemented sufficient vendor management policies and reviews; implemented an incident response plan; or provided a written, annual report to the board.
Cause: The University has not allocated sufficient resources to address and document compliance with the updated requirements of GLBA.
Effect: The University has not adequately addressed the updated requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: Not applicable.
Recommendation: We recommend the University allocate sufficient resources to address all updated 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, 84.038, and 84.379 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 updated its written information security program in alignment with the revised regulations; sufficiently documented its security risk assessment and safeguards, including general threats; implemented multi-factor authentication on systems containing personally identifiable information (PII); implemented continuous monitoring, such as penetration testing and vulnerability scanning; implemented sufficient vendor management policies and reviews; implemented an incident response plan; or provided a written, annual report to the board.
Cause: The University has not allocated sufficient resources to address and document compliance with the updated requirements of GLBA.
Effect: The University has not adequately addressed the updated requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: Not applicable.
Recommendation: We recommend the University allocate sufficient resources to address all updated 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, 84.038, and 84.379 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 updated its written information security program in alignment with the revised regulations; sufficiently documented its security risk assessment and safeguards, including general threats; implemented multi-factor authentication on systems containing personally identifiable information (PII); implemented continuous monitoring, such as penetration testing and vulnerability scanning; implemented sufficient vendor management policies and reviews; implemented an incident response plan; or provided a written, annual report to the board.
Cause: The University has not allocated sufficient resources to address and document compliance with the updated requirements of GLBA.
Effect: The University has not adequately addressed the updated requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: Not applicable.
Recommendation: We recommend the University allocate sufficient resources to address all updated requirements of GLBA.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Incorrect Pell Calculations DEPARTMENT OF EDUCATION
ALN #: 84.063
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: Pell was not awarded based on enrollment status and Expected Family Contribution (EFC).
Criteria: 34 CFR 690.63(b)
Questioned Costs: $58
Context: Out of 42 students tested, two students were under awarded Pell based on their enrollment level. The total amount of Pell under awards was $1,885. One student was over awarded $58 in Pell due to the incorrect EFC being used.
Cause: The over award of Pell was an oversight by the University. The under awards of Pell were students who changed enrollment status and did not have Pell adjusted accordingly.
Effect: Students not awarded Pell based on eligibility.
Identification as repeat finding, if applicable: 2022-004
Recommendation: We recommend a process be used to adjust the Pell formula used to be paid in alignment with enrollment status.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Untimely Returns of Title IV Funds (R2T4) Material Weakness
DEPARTMENT OF EDUCATION
ALN #: 84.268
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: When students withdrew either officially or unofficially, the University did not always return unearned Title IV aid timely.
Criteria: 34 CFR 668.22
Questioned Costs: $-0-
Context: Out of 25 students tested for accurate and timely R2T4s, 5 students who withdrew during the audit period tested had $5,255 returned late. Four of the late returns were made after the fiscal year and between 160-475 days late. One return was during the fiscal year and 109 days late.
Cause: This was an oversight by the University.
Effect: Returns of Title IV funds were not performed timely.
Identification as repeat finding, if applicable: 2022-002
Recommendation: We recommend a zero-credit report be run at the end of each semester to ensure all unofficial withdrawals are followed up on so that R2T4s are completed timely when required.
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, 84.038, and 84.379 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 updated its written information security program in alignment with the revised regulations; sufficiently documented its security risk assessment and safeguards, including general threats; implemented multi-factor authentication on systems containing personally identifiable information (PII); implemented continuous monitoring, such as penetration testing and vulnerability scanning; implemented sufficient vendor management policies and reviews; implemented an incident response plan; or provided a written, annual report to the board.
Cause: The University has not allocated sufficient resources to address and document compliance with the updated requirements of GLBA.
Effect: The University has not adequately addressed the updated requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: Not applicable.
Recommendation: We recommend the University allocate sufficient resources to address all updated 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, 84.038, and 84.379 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 updated its written information security program in alignment with the revised regulations; sufficiently documented its security risk assessment and safeguards, including general threats; implemented multi-factor authentication on systems containing personally identifiable information (PII); implemented continuous monitoring, such as penetration testing and vulnerability scanning; implemented sufficient vendor management policies and reviews; implemented an incident response plan; or provided a written, annual report to the board.
Cause: The University has not allocated sufficient resources to address and document compliance with the updated requirements of GLBA.
Effect: The University has not adequately addressed the updated requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: Not applicable.
Recommendation: We recommend the University allocate sufficient resources to address all updated 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, 84.038, and 84.379 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 updated its written information security program in alignment with the revised regulations; sufficiently documented its security risk assessment and safeguards, including general threats; implemented multi-factor authentication on systems containing personally identifiable information (PII); implemented continuous monitoring, such as penetration testing and vulnerability scanning; implemented sufficient vendor management policies and reviews; implemented an incident response plan; or provided a written, annual report to the board.
Cause: The University has not allocated sufficient resources to address and document compliance with the updated requirements of GLBA.
Effect: The University has not adequately addressed the updated requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: Not applicable.
Recommendation: We recommend the University allocate sufficient resources to address all updated 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, 84.038, and 84.379 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 updated its written information security program in alignment with the revised regulations; sufficiently documented its security risk assessment and safeguards, including general threats; implemented multi-factor authentication on systems containing personally identifiable information (PII); implemented continuous monitoring, such as penetration testing and vulnerability scanning; implemented sufficient vendor management policies and reviews; implemented an incident response plan; or provided a written, annual report to the board.
Cause: The University has not allocated sufficient resources to address and document compliance with the updated requirements of GLBA.
Effect: The University has not adequately addressed the updated requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: Not applicable.
Recommendation: We recommend the University allocate sufficient resources to address all updated 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, 84.038, and 84.379 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 updated its written information security program in alignment with the revised regulations; sufficiently documented its security risk assessment and safeguards, including general threats; implemented multi-factor authentication on systems containing personally identifiable information (PII); implemented continuous monitoring, such as penetration testing and vulnerability scanning; implemented sufficient vendor management policies and reviews; implemented an incident response plan; or provided a written, annual report to the board.
Cause: The University has not allocated sufficient resources to address and document compliance with the updated requirements of GLBA.
Effect: The University has not adequately addressed the updated requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: Not applicable.
Recommendation: We recommend the University allocate sufficient resources to address all updated 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, 84.038, and 84.379 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 updated its written information security program in alignment with the revised regulations; sufficiently documented its security risk assessment and safeguards, including general threats; implemented multi-factor authentication on systems containing personally identifiable information (PII); implemented continuous monitoring, such as penetration testing and vulnerability scanning; implemented sufficient vendor management policies and reviews; implemented an incident response plan; or provided a written, annual report to the board.
Cause: The University has not allocated sufficient resources to address and document compliance with the updated requirements of GLBA.
Effect: The University has not adequately addressed the updated requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: Not applicable.
Recommendation: We recommend the University allocate sufficient resources to address all updated requirements of GLBA.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Incorrect Pell Calculations DEPARTMENT OF EDUCATION
ALN #: 84.063
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: Pell was not awarded based on enrollment status and Expected Family Contribution (EFC).
Criteria: 34 CFR 690.63(b)
Questioned Costs: $58
Context: Out of 42 students tested, two students were under awarded Pell based on their enrollment level. The total amount of Pell under awards was $1,885. One student was over awarded $58 in Pell due to the incorrect EFC being used.
Cause: The over award of Pell was an oversight by the University. The under awards of Pell were students who changed enrollment status and did not have Pell adjusted accordingly.
Effect: Students not awarded Pell based on eligibility.
Identification as repeat finding, if applicable: 2022-004
Recommendation: We recommend a process be used to adjust the Pell formula used to be paid in alignment with enrollment status.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.