CFDA Number: Various – SFA Cluster
Criteria: Per 16 CFR 314.4 (c)(5), the College is required to implement multi-factor authentication for any individual accessing any information system, unless the Qualified Individual has approved in writing the use of reasonably equivalent or more secure access controls. Per the FSA Electronic Announcement GENERAL-23-09, institutions were required to implement this rule by June 9, 2023.
Condition: The College did not fully implement multi-factor authentication by June 9, 2023, which was the effective deadline.
Cause: The College is currently still in the process of implementing multi-factor authentication on the WIReD system.
Effect: The College is not in compliance with the requirement set by the Safeguards Rule under the Gramm-Leach-Bliley Act.
Prevalence: Implementing multi-factor authentication proved to be more complicated and timeconsuming for the student information system WIReD. Multi-factor authentication or equivalent access controls are in place for all other systems containing student information, and all other elements of the Safeguards Rule appear to be in place as required.
Recommendation: The College should implement multi-factor authentication for all systems as soon as possible and reference MFA in the written Information Security Program. The College should also enhance its training and procedures to ensure that any future adjustments to Gramm Leach Bliley Act continue to be met in a timely manner.
Management’s Response and Planned Corrective Action: Management acknowledged that implementation of multi-factor authentication for the WIReD system has taken more time due to the complexity of the systems in place. The multi-factor authentication on the WIReD system was implemented and went into effect on March 26, 2024.
CFDA Number: Various – SFA Cluster
Criteria: Per 16 CFR 314.4 (c)(5), the College is required to implement multi-factor authentication for any individual accessing any information system, unless the Qualified Individual has approved in writing the use of reasonably equivalent or more secure access controls. Per the FSA Electronic Announcement GENERAL-23-09, institutions were required to implement this rule by June 9, 2023.
Condition: The College did not fully implement multi-factor authentication by June 9, 2023, which was the effective deadline.
Cause: The College is currently still in the process of implementing multi-factor authentication on the WIReD system.
Effect: The College is not in compliance with the requirement set by the Safeguards Rule under the Gramm-Leach-Bliley Act.
Prevalence: Implementing multi-factor authentication proved to be more complicated and timeconsuming for the student information system WIReD. Multi-factor authentication or equivalent access controls are in place for all other systems containing student information, and all other elements of the Safeguards Rule appear to be in place as required.
Recommendation: The College should implement multi-factor authentication for all systems as soon as possible and reference MFA in the written Information Security Program. The College should also enhance its training and procedures to ensure that any future adjustments to Gramm Leach Bliley Act continue to be met in a timely manner.
Management’s Response and Planned Corrective Action: Management acknowledged that implementation of multi-factor authentication for the WIReD system has taken more time due to the complexity of the systems in place. The multi-factor authentication on the WIReD system was implemented and went into effect on March 26, 2024.
CFDA Number: Various – SFA Cluster
Criteria: Per 16 CFR 314.4 (c)(5), the College is required to implement multi-factor authentication for any individual accessing any information system, unless the Qualified Individual has approved in writing the use of reasonably equivalent or more secure access controls. Per the FSA Electronic Announcement GENERAL-23-09, institutions were required to implement this rule by June 9, 2023.
Condition: The College did not fully implement multi-factor authentication by June 9, 2023, which was the effective deadline.
Cause: The College is currently still in the process of implementing multi-factor authentication on the WIReD system.
Effect: The College is not in compliance with the requirement set by the Safeguards Rule under the Gramm-Leach-Bliley Act.
Prevalence: Implementing multi-factor authentication proved to be more complicated and timeconsuming for the student information system WIReD. Multi-factor authentication or equivalent access controls are in place for all other systems containing student information, and all other elements of the Safeguards Rule appear to be in place as required.
Recommendation: The College should implement multi-factor authentication for all systems as soon as possible and reference MFA in the written Information Security Program. The College should also enhance its training and procedures to ensure that any future adjustments to Gramm Leach Bliley Act continue to be met in a timely manner.
Management’s Response and Planned Corrective Action: Management acknowledged that implementation of multi-factor authentication for the WIReD system has taken more time due to the complexity of the systems in place. The multi-factor authentication on the WIReD system was implemented and went into effect on March 26, 2024.
CFDA Number: Various – SFA Cluster
Criteria: Per 16 CFR 314.4 (c)(5), the College is required to implement multi-factor authentication for any individual accessing any information system, unless the Qualified Individual has approved in writing the use of reasonably equivalent or more secure access controls. Per the FSA Electronic Announcement GENERAL-23-09, institutions were required to implement this rule by June 9, 2023.
Condition: The College did not fully implement multi-factor authentication by June 9, 2023, which was the effective deadline.
Cause: The College is currently still in the process of implementing multi-factor authentication on the WIReD system.
Effect: The College is not in compliance with the requirement set by the Safeguards Rule under the Gramm-Leach-Bliley Act.
Prevalence: Implementing multi-factor authentication proved to be more complicated and timeconsuming for the student information system WIReD. Multi-factor authentication or equivalent access controls are in place for all other systems containing student information, and all other elements of the Safeguards Rule appear to be in place as required.
Recommendation: The College should implement multi-factor authentication for all systems as soon as possible and reference MFA in the written Information Security Program. The College should also enhance its training and procedures to ensure that any future adjustments to Gramm Leach Bliley Act continue to be met in a timely manner.
Management’s Response and Planned Corrective Action: Management acknowledged that implementation of multi-factor authentication for the WIReD system has taken more time due to the complexity of the systems in place. The multi-factor authentication on the WIReD system was implemented and went into effect on March 26, 2024.
CFDA Number: 84.425 Education Stabilization Fund
Criteria: Student and institutional quarterly portion reporting requirements involve publicly posting completed forms on the institution’s website no later than 10 days after the end of each calendar quarter (September 30, December 31, March 31, and June 30).
Condition: Quarterly reports for the quarters ended March 31, 2023 and June 30, 2023 were not posted to the College’s website within 10 days after the end of each quarter.
Cause: Lean staffing continues to provide challenges to management for timely reporting.
Effect: The College is not in compliance with the federal regulations for HEERF public reporting during 2023.
Prevalence: The College posted the reports for the quarters ended March 31, 2023 and June 30, 2023 to their website after the applicable deadline. The reports for the quarters ended September 30, 2022 and December 31, 2022 were reviewed, submitted and posted on time.
Recommendation: The College should evaluate and enhance its procedures to ensure that reports are posted to the website by the applicable deadlines.
Management’s Response and Planned Corrective Action: Management has enhanced their internal processes for preparing, reviewing, and posting the quarterly reports on time.
CFDA Number: 84.425 Education Stabilization Fund
Criteria: Student and institutional quarterly portion reporting requirements involve publicly posting completed forms on the institution’s website no later than 10 days after the end of each calendar quarter (September 30, December 31, March 31, and June 30).
Condition: Quarterly reports for the quarters ended March 31, 2023 and June 30, 2023 were not posted to the College’s website within 10 days after the end of each quarter.
Cause: Lean staffing continues to provide challenges to management for timely reporting.
Effect: The College is not in compliance with the federal regulations for HEERF public reporting during 2023.
Prevalence: The College posted the reports for the quarters ended March 31, 2023 and June 30, 2023 to their website after the applicable deadline. The reports for the quarters ended September 30, 2022 and December 31, 2022 were reviewed, submitted and posted on time.
Recommendation: The College should evaluate and enhance its procedures to ensure that reports are posted to the website by the applicable deadlines.
Management’s Response and Planned Corrective Action: Management has enhanced their internal processes for preparing, reviewing, and posting the quarterly reports on time.
CFDA Number: 84.425 Education Stabilization Fund
Criteria: Student and institutional quarterly portion reporting requirements involve publicly posting completed forms on the institution’s website no later than 10 days after the end of each calendar quarter (September 30, December 31, March 31, and June 30).
Condition: Quarterly reports for the quarters ended March 31, 2023 and June 30, 2023 were not posted to the College’s website within 10 days after the end of each quarter.
Cause: Lean staffing continues to provide challenges to management for timely reporting.
Effect: The College is not in compliance with the federal regulations for HEERF public reporting during 2023.
Prevalence: The College posted the reports for the quarters ended March 31, 2023 and June 30, 2023 to their website after the applicable deadline. The reports for the quarters ended September 30, 2022 and December 31, 2022 were reviewed, submitted and posted on time.
Recommendation: The College should evaluate and enhance its procedures to ensure that reports are posted to the website by the applicable deadlines.
Management’s Response and Planned Corrective Action: Management has enhanced their internal processes for preparing, reviewing, and posting the quarterly reports on time.
CFDA Number: Various – SFA Cluster
Criteria: Per 16 CFR 314.4 (c)(5), the College is required to implement multi-factor authentication for any individual accessing any information system, unless the Qualified Individual has approved in writing the use of reasonably equivalent or more secure access controls. Per the FSA Electronic Announcement GENERAL-23-09, institutions were required to implement this rule by June 9, 2023.
Condition: The College did not fully implement multi-factor authentication by June 9, 2023, which was the effective deadline.
Cause: The College is currently still in the process of implementing multi-factor authentication on the WIReD system.
Effect: The College is not in compliance with the requirement set by the Safeguards Rule under the Gramm-Leach-Bliley Act.
Prevalence: Implementing multi-factor authentication proved to be more complicated and timeconsuming for the student information system WIReD. Multi-factor authentication or equivalent access controls are in place for all other systems containing student information, and all other elements of the Safeguards Rule appear to be in place as required.
Recommendation: The College should implement multi-factor authentication for all systems as soon as possible and reference MFA in the written Information Security Program. The College should also enhance its training and procedures to ensure that any future adjustments to Gramm Leach Bliley Act continue to be met in a timely manner.
Management’s Response and Planned Corrective Action: Management acknowledged that implementation of multi-factor authentication for the WIReD system has taken more time due to the complexity of the systems in place. The multi-factor authentication on the WIReD system was implemented and went into effect on March 26, 2024.
CFDA Number: Various – SFA Cluster
Criteria: Per 16 CFR 314.4 (c)(5), the College is required to implement multi-factor authentication for any individual accessing any information system, unless the Qualified Individual has approved in writing the use of reasonably equivalent or more secure access controls. Per the FSA Electronic Announcement GENERAL-23-09, institutions were required to implement this rule by June 9, 2023.
Condition: The College did not fully implement multi-factor authentication by June 9, 2023, which was the effective deadline.
Cause: The College is currently still in the process of implementing multi-factor authentication on the WIReD system.
Effect: The College is not in compliance with the requirement set by the Safeguards Rule under the Gramm-Leach-Bliley Act.
Prevalence: Implementing multi-factor authentication proved to be more complicated and timeconsuming for the student information system WIReD. Multi-factor authentication or equivalent access controls are in place for all other systems containing student information, and all other elements of the Safeguards Rule appear to be in place as required.
Recommendation: The College should implement multi-factor authentication for all systems as soon as possible and reference MFA in the written Information Security Program. The College should also enhance its training and procedures to ensure that any future adjustments to Gramm Leach Bliley Act continue to be met in a timely manner.
Management’s Response and Planned Corrective Action: Management acknowledged that implementation of multi-factor authentication for the WIReD system has taken more time due to the complexity of the systems in place. The multi-factor authentication on the WIReD system was implemented and went into effect on March 26, 2024.
CFDA Number: Various – SFA Cluster
Criteria: Per 16 CFR 314.4 (c)(5), the College is required to implement multi-factor authentication for any individual accessing any information system, unless the Qualified Individual has approved in writing the use of reasonably equivalent or more secure access controls. Per the FSA Electronic Announcement GENERAL-23-09, institutions were required to implement this rule by June 9, 2023.
Condition: The College did not fully implement multi-factor authentication by June 9, 2023, which was the effective deadline.
Cause: The College is currently still in the process of implementing multi-factor authentication on the WIReD system.
Effect: The College is not in compliance with the requirement set by the Safeguards Rule under the Gramm-Leach-Bliley Act.
Prevalence: Implementing multi-factor authentication proved to be more complicated and timeconsuming for the student information system WIReD. Multi-factor authentication or equivalent access controls are in place for all other systems containing student information, and all other elements of the Safeguards Rule appear to be in place as required.
Recommendation: The College should implement multi-factor authentication for all systems as soon as possible and reference MFA in the written Information Security Program. The College should also enhance its training and procedures to ensure that any future adjustments to Gramm Leach Bliley Act continue to be met in a timely manner.
Management’s Response and Planned Corrective Action: Management acknowledged that implementation of multi-factor authentication for the WIReD system has taken more time due to the complexity of the systems in place. The multi-factor authentication on the WIReD system was implemented and went into effect on March 26, 2024.
CFDA Number: Various – SFA Cluster
Criteria: Per 16 CFR 314.4 (c)(5), the College is required to implement multi-factor authentication for any individual accessing any information system, unless the Qualified Individual has approved in writing the use of reasonably equivalent or more secure access controls. Per the FSA Electronic Announcement GENERAL-23-09, institutions were required to implement this rule by June 9, 2023.
Condition: The College did not fully implement multi-factor authentication by June 9, 2023, which was the effective deadline.
Cause: The College is currently still in the process of implementing multi-factor authentication on the WIReD system.
Effect: The College is not in compliance with the requirement set by the Safeguards Rule under the Gramm-Leach-Bliley Act.
Prevalence: Implementing multi-factor authentication proved to be more complicated and timeconsuming for the student information system WIReD. Multi-factor authentication or equivalent access controls are in place for all other systems containing student information, and all other elements of the Safeguards Rule appear to be in place as required.
Recommendation: The College should implement multi-factor authentication for all systems as soon as possible and reference MFA in the written Information Security Program. The College should also enhance its training and procedures to ensure that any future adjustments to Gramm Leach Bliley Act continue to be met in a timely manner.
Management’s Response and Planned Corrective Action: Management acknowledged that implementation of multi-factor authentication for the WIReD system has taken more time due to the complexity of the systems in place. The multi-factor authentication on the WIReD system was implemented and went into effect on March 26, 2024.
CFDA Number: 84.425 Education Stabilization Fund
Criteria: Student and institutional quarterly portion reporting requirements involve publicly posting completed forms on the institution’s website no later than 10 days after the end of each calendar quarter (September 30, December 31, March 31, and June 30).
Condition: Quarterly reports for the quarters ended March 31, 2023 and June 30, 2023 were not posted to the College’s website within 10 days after the end of each quarter.
Cause: Lean staffing continues to provide challenges to management for timely reporting.
Effect: The College is not in compliance with the federal regulations for HEERF public reporting during 2023.
Prevalence: The College posted the reports for the quarters ended March 31, 2023 and June 30, 2023 to their website after the applicable deadline. The reports for the quarters ended September 30, 2022 and December 31, 2022 were reviewed, submitted and posted on time.
Recommendation: The College should evaluate and enhance its procedures to ensure that reports are posted to the website by the applicable deadlines.
Management’s Response and Planned Corrective Action: Management has enhanced their internal processes for preparing, reviewing, and posting the quarterly reports on time.
CFDA Number: 84.425 Education Stabilization Fund
Criteria: Student and institutional quarterly portion reporting requirements involve publicly posting completed forms on the institution’s website no later than 10 days after the end of each calendar quarter (September 30, December 31, March 31, and June 30).
Condition: Quarterly reports for the quarters ended March 31, 2023 and June 30, 2023 were not posted to the College’s website within 10 days after the end of each quarter.
Cause: Lean staffing continues to provide challenges to management for timely reporting.
Effect: The College is not in compliance with the federal regulations for HEERF public reporting during 2023.
Prevalence: The College posted the reports for the quarters ended March 31, 2023 and June 30, 2023 to their website after the applicable deadline. The reports for the quarters ended September 30, 2022 and December 31, 2022 were reviewed, submitted and posted on time.
Recommendation: The College should evaluate and enhance its procedures to ensure that reports are posted to the website by the applicable deadlines.
Management’s Response and Planned Corrective Action: Management has enhanced their internal processes for preparing, reviewing, and posting the quarterly reports on time.
CFDA Number: 84.425 Education Stabilization Fund
Criteria: Student and institutional quarterly portion reporting requirements involve publicly posting completed forms on the institution’s website no later than 10 days after the end of each calendar quarter (September 30, December 31, March 31, and June 30).
Condition: Quarterly reports for the quarters ended March 31, 2023 and June 30, 2023 were not posted to the College’s website within 10 days after the end of each quarter.
Cause: Lean staffing continues to provide challenges to management for timely reporting.
Effect: The College is not in compliance with the federal regulations for HEERF public reporting during 2023.
Prevalence: The College posted the reports for the quarters ended March 31, 2023 and June 30, 2023 to their website after the applicable deadline. The reports for the quarters ended September 30, 2022 and December 31, 2022 were reviewed, submitted and posted on time.
Recommendation: The College should evaluate and enhance its procedures to ensure that reports are posted to the website by the applicable deadlines.
Management’s Response and Planned Corrective Action: Management has enhanced their internal processes for preparing, reviewing, and posting the quarterly reports on time.