Gramm-Leach-Bliley Act (GLBA) Compliance Material Weakness
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, and 84.033, Student Financial Assistance Cluster
Federal Award Identification #: 2023-2024 Award Year
Condition: Life Pacific University did not sufficiently comply with all the updated requirements of GLBA.
Criteria: 16 CFR 314.3, 16 CFR 314.4
Questioned Costs: $0
Context: Life Pacific University has not documented its written information security program, sufficiently documented its security risk assessment and safeguards for all systems, or confirmed and/or implemented multi-factor authentication on all systems containing personally identifiable information (PII). Additionally, Life Pacific University has not implemented a data deletion policy, sufficient vendor management policies and reviews, or implemented an incident response plan.
Cause: Life Pacific University has experienced turnover within the last year and focused on improving the written risk assessment, continuous monitoring capabilities, and the annual report to the board. We commend Life Pacific University for these pieces with significant improvement.
Effect: Life Pacific University has not adequately addressed all the remaining updated requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: 2023-002
Recommendation: We recommend Life Pacific 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 Material Weakness
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, and 84.033, Student Financial Assistance Cluster
Federal Award Identification #: 2023-2024 Award Year
Condition: Life Pacific University did not sufficiently comply with all the updated requirements of GLBA.
Criteria: 16 CFR 314.3, 16 CFR 314.4
Questioned Costs: $0
Context: Life Pacific University has not documented its written information security program, sufficiently documented its security risk assessment and safeguards for all systems, or confirmed and/or implemented multi-factor authentication on all systems containing personally identifiable information (PII). Additionally, Life Pacific University has not implemented a data deletion policy, sufficient vendor management policies and reviews, or implemented an incident response plan.
Cause: Life Pacific University has experienced turnover within the last year and focused on improving the written risk assessment, continuous monitoring capabilities, and the annual report to the board. We commend Life Pacific University for these pieces with significant improvement.
Effect: Life Pacific University has not adequately addressed all the remaining updated requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: 2023-002
Recommendation: We recommend Life Pacific 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 Material Weakness
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, and 84.033, Student Financial Assistance Cluster
Federal Award Identification #: 2023-2024 Award Year
Condition: Life Pacific University did not sufficiently comply with all the updated requirements of GLBA.
Criteria: 16 CFR 314.3, 16 CFR 314.4
Questioned Costs: $0
Context: Life Pacific University has not documented its written information security program, sufficiently documented its security risk assessment and safeguards for all systems, or confirmed and/or implemented multi-factor authentication on all systems containing personally identifiable information (PII). Additionally, Life Pacific University has not implemented a data deletion policy, sufficient vendor management policies and reviews, or implemented an incident response plan.
Cause: Life Pacific University has experienced turnover within the last year and focused on improving the written risk assessment, continuous monitoring capabilities, and the annual report to the board. We commend Life Pacific University for these pieces with significant improvement.
Effect: Life Pacific University has not adequately addressed all the remaining updated requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: 2023-002
Recommendation: We recommend Life Pacific 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 Material Weakness
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, and 84.033, Student Financial Assistance Cluster
Federal Award Identification #: 2023-2024 Award Year
Condition: Life Pacific University did not sufficiently comply with all the updated requirements of GLBA.
Criteria: 16 CFR 314.3, 16 CFR 314.4
Questioned Costs: $0
Context: Life Pacific University has not documented its written information security program, sufficiently documented its security risk assessment and safeguards for all systems, or confirmed and/or implemented multi-factor authentication on all systems containing personally identifiable information (PII). Additionally, Life Pacific University has not implemented a data deletion policy, sufficient vendor management policies and reviews, or implemented an incident response plan.
Cause: Life Pacific University has experienced turnover within the last year and focused on improving the written risk assessment, continuous monitoring capabilities, and the annual report to the board. We commend Life Pacific University for these pieces with significant improvement.
Effect: Life Pacific University has not adequately addressed all the remaining updated requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: 2023-002
Recommendation: We recommend Life Pacific 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.
Inaccurate and Untimely Return of Title IV Funds (R2T4) Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063
Federal Award Identification #: 2023-2024 Award Year
Condition: For students withdrawn in the Spring 2024 semester, Life Pacific University did not always return unearned Title IV aid timely or accurately.
Criteria: 34 CFR 668.22
Questioned Costs: $4,036
Context: Out of 8 students tested, 2 students who withdrew during the Spring 2024 term had R2T4 funds returned late, ranging from 92 to 158 days. The first student had an incorrect R2T4 calculation performed due to federal loans being included in the calculation when the student was ineligible to receive them, resulting in an under return of $1,285 of Pell. The second student did not have an R2T4 performed even though they withdrew during the first module, and Pell was not adjusted to reflect the correct enrollment status. This resulted in an under return of $2,751 of Pell. Another student had a correction to the R2T4 made by Life Pacific University during the Spring term resulting in an additional $159 post-withdrawal disbursement, however this was not paid out until the audit. All of these returns were corrected during the audit.
Cause: Life Pacific University went through unexpected turnover at the beginning of the Spring 2024 term. All issues noted were isolated to this term.
Effect: Returns of Title IV funds were not performed timely or accurately.
Identification as repeat finding, if applicable: Not applicable.
Recommendation: We recommend an individual in financial aid with the appropriate level of experience periodically review R2T4 calculations and returns to help ensure that internal controls over such process can operate effectively and achieve compliance.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Inaccurate and Untimely Return of Title IV Funds (R2T4) Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063
Federal Award Identification #: 2023-2024 Award Year
Condition: For students withdrawn in the Spring 2024 semester, Life Pacific University did not always return unearned Title IV aid timely or accurately.
Criteria: 34 CFR 668.22
Questioned Costs: $4,036
Context: Out of 8 students tested, 2 students who withdrew during the Spring 2024 term had R2T4 funds returned late, ranging from 92 to 158 days. The first student had an incorrect R2T4 calculation performed due to federal loans being included in the calculation when the student was ineligible to receive them, resulting in an under return of $1,285 of Pell. The second student did not have an R2T4 performed even though they withdrew during the first module, and Pell was not adjusted to reflect the correct enrollment status. This resulted in an under return of $2,751 of Pell. Another student had a correction to the R2T4 made by Life Pacific University during the Spring term resulting in an additional $159 post-withdrawal disbursement, however this was not paid out until the audit. All of these returns were corrected during the audit.
Cause: Life Pacific University went through unexpected turnover at the beginning of the Spring 2024 term. All issues noted were isolated to this term.
Effect: Returns of Title IV funds were not performed timely or accurately.
Identification as repeat finding, if applicable: Not applicable.
Recommendation: We recommend an individual in financial aid with the appropriate level of experience periodically review R2T4 calculations and returns to help ensure that internal controls over such process can operate effectively and achieve compliance.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Common Origination and Disbursement (COD) Reporting DEPARTMENT OF EDUCATION
ALN #: 84.268 and 84.063
Federal Award Identification #: 2023-2024 Award Year
Condition: For the Spring 2024 term, the dates that Pell and Federal Direct Loans (FDL) awards were posted to student accounts did not always agree to disbursement records reported to Common Origination and Disbursement (COD).
Criteria: 34CFR 668.164(a)
Questioned Costs: $0
Context: Out of 60 students tested, all students tested that had aid disbursed in the Spring 2024 term had COD loan and Pell disbursement date errors ranging from 4 to 21 days. There were no errors in the amounts reported.
Cause: Due to unexpected turnover in the financial aid office, reconciliations of Life Pacific University records to COD were not being completed regularly. This led to errors between the two systems not being identified in a timely manner.
Effect: Inaccurate FDL reporting can impact a student's interest accumulating period based on the dates of the loan disbursement dates. Inaccurate Pell reporting could allow a student to exceed their lifetime limit.
Identification as repeat finding, if applicable: Not applicable.
Recommendation: We recommend that Life Pacific University implement procedures to reconcile monthly FDL and Pell disbursements to student accounts with disbursements reported to COD.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Common Origination and Disbursement (COD) Reporting DEPARTMENT OF EDUCATION
ALN #: 84.268 and 84.063
Federal Award Identification #: 2023-2024 Award Year
Condition: For the Spring 2024 term, the dates that Pell and Federal Direct Loans (FDL) awards were posted to student accounts did not always agree to disbursement records reported to Common Origination and Disbursement (COD).
Criteria: 34CFR 668.164(a)
Questioned Costs: $0
Context: Out of 60 students tested, all students tested that had aid disbursed in the Spring 2024 term had COD loan and Pell disbursement date errors ranging from 4 to 21 days. There were no errors in the amounts reported.
Cause: Due to unexpected turnover in the financial aid office, reconciliations of Life Pacific University records to COD were not being completed regularly. This led to errors between the two systems not being identified in a timely manner.
Effect: Inaccurate FDL reporting can impact a student's interest accumulating period based on the dates of the loan disbursement dates. Inaccurate Pell reporting could allow a student to exceed their lifetime limit.
Identification as repeat finding, if applicable: Not applicable.
Recommendation: We recommend that Life Pacific University implement procedures to reconcile monthly FDL and Pell disbursements to student accounts with disbursements reported to COD.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance Material Weakness
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, and 84.033, Student Financial Assistance Cluster
Federal Award Identification #: 2023-2024 Award Year
Condition: Life Pacific University did not sufficiently comply with all the updated requirements of GLBA.
Criteria: 16 CFR 314.3, 16 CFR 314.4
Questioned Costs: $0
Context: Life Pacific University has not documented its written information security program, sufficiently documented its security risk assessment and safeguards for all systems, or confirmed and/or implemented multi-factor authentication on all systems containing personally identifiable information (PII). Additionally, Life Pacific University has not implemented a data deletion policy, sufficient vendor management policies and reviews, or implemented an incident response plan.
Cause: Life Pacific University has experienced turnover within the last year and focused on improving the written risk assessment, continuous monitoring capabilities, and the annual report to the board. We commend Life Pacific University for these pieces with significant improvement.
Effect: Life Pacific University has not adequately addressed all the remaining updated requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: 2023-002
Recommendation: We recommend Life Pacific 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 Material Weakness
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, and 84.033, Student Financial Assistance Cluster
Federal Award Identification #: 2023-2024 Award Year
Condition: Life Pacific University did not sufficiently comply with all the updated requirements of GLBA.
Criteria: 16 CFR 314.3, 16 CFR 314.4
Questioned Costs: $0
Context: Life Pacific University has not documented its written information security program, sufficiently documented its security risk assessment and safeguards for all systems, or confirmed and/or implemented multi-factor authentication on all systems containing personally identifiable information (PII). Additionally, Life Pacific University has not implemented a data deletion policy, sufficient vendor management policies and reviews, or implemented an incident response plan.
Cause: Life Pacific University has experienced turnover within the last year and focused on improving the written risk assessment, continuous monitoring capabilities, and the annual report to the board. We commend Life Pacific University for these pieces with significant improvement.
Effect: Life Pacific University has not adequately addressed all the remaining updated requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: 2023-002
Recommendation: We recommend Life Pacific 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 Material Weakness
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, and 84.033, Student Financial Assistance Cluster
Federal Award Identification #: 2023-2024 Award Year
Condition: Life Pacific University did not sufficiently comply with all the updated requirements of GLBA.
Criteria: 16 CFR 314.3, 16 CFR 314.4
Questioned Costs: $0
Context: Life Pacific University has not documented its written information security program, sufficiently documented its security risk assessment and safeguards for all systems, or confirmed and/or implemented multi-factor authentication on all systems containing personally identifiable information (PII). Additionally, Life Pacific University has not implemented a data deletion policy, sufficient vendor management policies and reviews, or implemented an incident response plan.
Cause: Life Pacific University has experienced turnover within the last year and focused on improving the written risk assessment, continuous monitoring capabilities, and the annual report to the board. We commend Life Pacific University for these pieces with significant improvement.
Effect: Life Pacific University has not adequately addressed all the remaining updated requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: 2023-002
Recommendation: We recommend Life Pacific 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 Material Weakness
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, and 84.033, Student Financial Assistance Cluster
Federal Award Identification #: 2023-2024 Award Year
Condition: Life Pacific University did not sufficiently comply with all the updated requirements of GLBA.
Criteria: 16 CFR 314.3, 16 CFR 314.4
Questioned Costs: $0
Context: Life Pacific University has not documented its written information security program, sufficiently documented its security risk assessment and safeguards for all systems, or confirmed and/or implemented multi-factor authentication on all systems containing personally identifiable information (PII). Additionally, Life Pacific University has not implemented a data deletion policy, sufficient vendor management policies and reviews, or implemented an incident response plan.
Cause: Life Pacific University has experienced turnover within the last year and focused on improving the written risk assessment, continuous monitoring capabilities, and the annual report to the board. We commend Life Pacific University for these pieces with significant improvement.
Effect: Life Pacific University has not adequately addressed all the remaining updated requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: 2023-002
Recommendation: We recommend Life Pacific 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.
Inaccurate and Untimely Return of Title IV Funds (R2T4) Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063
Federal Award Identification #: 2023-2024 Award Year
Condition: For students withdrawn in the Spring 2024 semester, Life Pacific University did not always return unearned Title IV aid timely or accurately.
Criteria: 34 CFR 668.22
Questioned Costs: $4,036
Context: Out of 8 students tested, 2 students who withdrew during the Spring 2024 term had R2T4 funds returned late, ranging from 92 to 158 days. The first student had an incorrect R2T4 calculation performed due to federal loans being included in the calculation when the student was ineligible to receive them, resulting in an under return of $1,285 of Pell. The second student did not have an R2T4 performed even though they withdrew during the first module, and Pell was not adjusted to reflect the correct enrollment status. This resulted in an under return of $2,751 of Pell. Another student had a correction to the R2T4 made by Life Pacific University during the Spring term resulting in an additional $159 post-withdrawal disbursement, however this was not paid out until the audit. All of these returns were corrected during the audit.
Cause: Life Pacific University went through unexpected turnover at the beginning of the Spring 2024 term. All issues noted were isolated to this term.
Effect: Returns of Title IV funds were not performed timely or accurately.
Identification as repeat finding, if applicable: Not applicable.
Recommendation: We recommend an individual in financial aid with the appropriate level of experience periodically review R2T4 calculations and returns to help ensure that internal controls over such process can operate effectively and achieve compliance.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Inaccurate and Untimely Return of Title IV Funds (R2T4) Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063
Federal Award Identification #: 2023-2024 Award Year
Condition: For students withdrawn in the Spring 2024 semester, Life Pacific University did not always return unearned Title IV aid timely or accurately.
Criteria: 34 CFR 668.22
Questioned Costs: $4,036
Context: Out of 8 students tested, 2 students who withdrew during the Spring 2024 term had R2T4 funds returned late, ranging from 92 to 158 days. The first student had an incorrect R2T4 calculation performed due to federal loans being included in the calculation when the student was ineligible to receive them, resulting in an under return of $1,285 of Pell. The second student did not have an R2T4 performed even though they withdrew during the first module, and Pell was not adjusted to reflect the correct enrollment status. This resulted in an under return of $2,751 of Pell. Another student had a correction to the R2T4 made by Life Pacific University during the Spring term resulting in an additional $159 post-withdrawal disbursement, however this was not paid out until the audit. All of these returns were corrected during the audit.
Cause: Life Pacific University went through unexpected turnover at the beginning of the Spring 2024 term. All issues noted were isolated to this term.
Effect: Returns of Title IV funds were not performed timely or accurately.
Identification as repeat finding, if applicable: Not applicable.
Recommendation: We recommend an individual in financial aid with the appropriate level of experience periodically review R2T4 calculations and returns to help ensure that internal controls over such process can operate effectively and achieve compliance.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Common Origination and Disbursement (COD) Reporting DEPARTMENT OF EDUCATION
ALN #: 84.268 and 84.063
Federal Award Identification #: 2023-2024 Award Year
Condition: For the Spring 2024 term, the dates that Pell and Federal Direct Loans (FDL) awards were posted to student accounts did not always agree to disbursement records reported to Common Origination and Disbursement (COD).
Criteria: 34CFR 668.164(a)
Questioned Costs: $0
Context: Out of 60 students tested, all students tested that had aid disbursed in the Spring 2024 term had COD loan and Pell disbursement date errors ranging from 4 to 21 days. There were no errors in the amounts reported.
Cause: Due to unexpected turnover in the financial aid office, reconciliations of Life Pacific University records to COD were not being completed regularly. This led to errors between the two systems not being identified in a timely manner.
Effect: Inaccurate FDL reporting can impact a student's interest accumulating period based on the dates of the loan disbursement dates. Inaccurate Pell reporting could allow a student to exceed their lifetime limit.
Identification as repeat finding, if applicable: Not applicable.
Recommendation: We recommend that Life Pacific University implement procedures to reconcile monthly FDL and Pell disbursements to student accounts with disbursements reported to COD.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Common Origination and Disbursement (COD) Reporting DEPARTMENT OF EDUCATION
ALN #: 84.268 and 84.063
Federal Award Identification #: 2023-2024 Award Year
Condition: For the Spring 2024 term, the dates that Pell and Federal Direct Loans (FDL) awards were posted to student accounts did not always agree to disbursement records reported to Common Origination and Disbursement (COD).
Criteria: 34CFR 668.164(a)
Questioned Costs: $0
Context: Out of 60 students tested, all students tested that had aid disbursed in the Spring 2024 term had COD loan and Pell disbursement date errors ranging from 4 to 21 days. There were no errors in the amounts reported.
Cause: Due to unexpected turnover in the financial aid office, reconciliations of Life Pacific University records to COD were not being completed regularly. This led to errors between the two systems not being identified in a timely manner.
Effect: Inaccurate FDL reporting can impact a student's interest accumulating period based on the dates of the loan disbursement dates. Inaccurate Pell reporting could allow a student to exceed their lifetime limit.
Identification as repeat finding, if applicable: Not applicable.
Recommendation: We recommend that Life Pacific University implement procedures to reconcile monthly FDL and Pell disbursements to student accounts with disbursements reported to COD.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.