Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268 and 84.063
Federal Award Identification #: 2023-2024 Award Year
Condition: The University did not report enrollment information to the National Student Loan Data System (NSLDS) in a timely and accurate manner for all withdrawn students.
Criteria: 34 CFR 690.83(b) and 34 CFR 685.309
Questioned Costs: $0
Context: Out of 91 students tested, 8 students were not properly reported to NSLDS. All of these students either withdrew between semesters or during a semester. The students have not yet been corrected.
Cause: The system tracks the data needed for enrollment reporting, but somehow with the third-party servicer, these were not properly reported to NSLDS.
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: Yes, 2023-003, 2022-003, 2021-005, 2020-002, and 2019-001.
Recommendation: We recommend the University work with the third-party to determine why the data is not transferring correctly to NSLDS. We further recommend the University complete spot checks of enrollment statuses to NSLDS, particularly for those students who withdrew.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268 and 84.063
Federal Award Identification #: 2023-2024 Award Year
Condition: The University did not report enrollment information to the National Student Loan Data System (NSLDS) in a timely and accurate manner for all withdrawn students.
Criteria: 34 CFR 690.83(b) and 34 CFR 685.309
Questioned Costs: $0
Context: Out of 91 students tested, 8 students were not properly reported to NSLDS. All of these students either withdrew between semesters or during a semester. The students have not yet been corrected.
Cause: The system tracks the data needed for enrollment reporting, but somehow with the third-party servicer, these were not properly reported to NSLDS.
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: Yes, 2023-003, 2022-003, 2021-005, 2020-002, and 2019-001.
Recommendation: We recommend the University work with the third-party to determine why the data is not transferring correctly to NSLDS. We further recommend the University complete spot checks of enrollment statuses to NSLDS, particularly for those students who withdrew.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Return of Title IV (R2T4) Calculations
Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063
Federal Award Identification #: 2023-2024 Award Year
Condition: There were two incorrect calculations of returned funds for students that withdrew during the term.
Criteria: 34 CFR 668.22
Questioned Costs: $0
Context: Out of 37 students, 2 students who withdrew had incorrect calculations. One student was not offered a post-withdrawal disbursement (PWD) of Pell when they attended less than half time in the spring, and one student had an incorrect last date of attendance used in the calculation. These students were not yet corrected during the audit process.
Cause: These were oversights by the University.
Effect: Incorrect amounts of federal funding were returned. One PWD of Pell was $76 less than the student was eligible for and a Pell PWD of $152 was not paid to one student.
Identification as repeat finding, if applicable: Yes, 2023-002, 2022-002, 2021-004, and 2020-003.
Recommendation: We recommend the University continue to provide additional training for counselors performing R2T4 calculations.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Return of Title IV (R2T4) Calculations
Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063
Federal Award Identification #: 2023-2024 Award Year
Condition: There were two incorrect calculations of returned funds for students that withdrew during the term.
Criteria: 34 CFR 668.22
Questioned Costs: $0
Context: Out of 37 students, 2 students who withdrew had incorrect calculations. One student was not offered a post-withdrawal disbursement (PWD) of Pell when they attended less than half time in the spring, and one student had an incorrect last date of attendance used in the calculation. These students were not yet corrected during the audit process.
Cause: These were oversights by the University.
Effect: Incorrect amounts of federal funding were returned. One PWD of Pell was $76 less than the student was eligible for and a Pell PWD of $152 was not paid to one student.
Identification as repeat finding, if applicable: Yes, 2023-002, 2022-002, 2021-004, and 2020-003.
Recommendation: We recommend the University continue to provide additional training for counselors performing R2T4 calculations.
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 #: 2023-2024 Award Year
Condition: Two students out of 60 were not properly awarded Pell based on enrollment status.
Criteria: 34 CFR 690.63(b)
Questioned Costs: $925
Context: One student was inadvertently awarded and paid Pell for one more class than they attended as they started in 11 hours instead of 12 resulting in an overaward of $925. This was corrected during the audit. One student was half time in summer and was not picked up to be paid Pell for the summer term, resulting in an underaward of $1,849. This student was corrected during the audit.
Cause: These were oversights in the cleanup reports run.
Effect: There was an incorrect amount of Pell paid to these two students.
Identification as repeat finding, if applicable: Yes, 2023-005 and 2022-005.
Recommendation: We recommend a process be used to adjust Pell 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.
Gramm-Leach-Bliley Act (GLBA) Compliance DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, and 84.379 - Student Financial Assistance Cluster
Federal Award Identification #: 2023-2024 Award 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 implemented multi-factor authentication on all systems containing personally identifiable information (PII) or documented an exception and has not updated it policy related to data deletion or documented an exception.
Cause: The University was not able to fully address all prior year items with transition at the University in order to address and document compliance with the updated 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, 2023-004
Recommendation: We recommend the University allocate sufficient resources to address all updated requirements of GLBA. We commend the University for the work completed on GLBA in the past year.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, and 84.379 - Student Financial Assistance Cluster
Federal Award Identification #: 2023-2024 Award 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 implemented multi-factor authentication on all systems containing personally identifiable information (PII) or documented an exception and has not updated it policy related to data deletion or documented an exception.
Cause: The University was not able to fully address all prior year items with transition at the University in order to address and document compliance with the updated 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, 2023-004
Recommendation: We recommend the University allocate sufficient resources to address all updated requirements of GLBA. We commend the University for the work completed on GLBA in the past year.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, and 84.379 - Student Financial Assistance Cluster
Federal Award Identification #: 2023-2024 Award 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 implemented multi-factor authentication on all systems containing personally identifiable information (PII) or documented an exception and has not updated it policy related to data deletion or documented an exception.
Cause: The University was not able to fully address all prior year items with transition at the University in order to address and document compliance with the updated 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, 2023-004
Recommendation: We recommend the University allocate sufficient resources to address all updated requirements of GLBA. We commend the University for the work completed on GLBA in the past year.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, and 84.379 - Student Financial Assistance Cluster
Federal Award Identification #: 2023-2024 Award 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 implemented multi-factor authentication on all systems containing personally identifiable information (PII) or documented an exception and has not updated it policy related to data deletion or documented an exception.
Cause: The University was not able to fully address all prior year items with transition at the University in order to address and document compliance with the updated 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, 2023-004
Recommendation: We recommend the University allocate sufficient resources to address all updated requirements of GLBA. We commend the University for the work completed on GLBA in the past year.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, and 84.379 - Student Financial Assistance Cluster
Federal Award Identification #: 2023-2024 Award 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 implemented multi-factor authentication on all systems containing personally identifiable information (PII) or documented an exception and has not updated it policy related to data deletion or documented an exception.
Cause: The University was not able to fully address all prior year items with transition at the University in order to address and document compliance with the updated 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, 2023-004
Recommendation: We recommend the University allocate sufficient resources to address all updated requirements of GLBA. We commend the University for the work completed on GLBA in the past year.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, and 84.379 - Student Financial Assistance Cluster
Federal Award Identification #: 2023-2024 Award 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 implemented multi-factor authentication on all systems containing personally identifiable information (PII) or documented an exception and has not updated it policy related to data deletion or documented an exception.
Cause: The University was not able to fully address all prior year items with transition at the University in order to address and document compliance with the updated 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, 2023-004
Recommendation: We recommend the University allocate sufficient resources to address all updated requirements of GLBA. We commend the University for the work completed on GLBA in the past year.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Documentation of Reconciliations
DEPARTMENT OF EDUCATION
ALN #: 84.268 and 84.063
Federal Award Identification #: 2023-2024 Award Year
Condition: Reconciliations were not available to review on a student-by-student basis year to date.
Criteria: 34 CFR 668 Subpart L
Questioned Costs: $0
Context: Reconciliations are required to be maintained on a monthly basis including year to date information for FDL and Pell. These reconciliations have been done on screen with each batch disbursement and in aggregate but not at the student-by-student detail year to date. Because the University has a large enrollment, student by student manual reconciliations are not time effective.
Cause: The University’s system does not currently allow importing of student files from Common Origination and Disbursement (COD) to complete the reconciliations in a time effective manner.
Effect: The documentation for reconciliations is not available year to date.
Identification as repeat finding, if applicable: Not applicable.
Recommendation: We recommend the University explore options to make the year-to-date reconciliations and documentation of student Pell and Direct Loans more efficient.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Documentation of Reconciliations
DEPARTMENT OF EDUCATION
ALN #: 84.268 and 84.063
Federal Award Identification #: 2023-2024 Award Year
Condition: Reconciliations were not available to review on a student-by-student basis year to date.
Criteria: 34 CFR 668 Subpart L
Questioned Costs: $0
Context: Reconciliations are required to be maintained on a monthly basis including year to date information for FDL and Pell. These reconciliations have been done on screen with each batch disbursement and in aggregate but not at the student-by-student detail year to date. Because the University has a large enrollment, student by student manual reconciliations are not time effective.
Cause: The University’s system does not currently allow importing of student files from Common Origination and Disbursement (COD) to complete the reconciliations in a time effective manner.
Effect: The documentation for reconciliations is not available year to date.
Identification as repeat finding, if applicable: Not applicable.
Recommendation: We recommend the University explore options to make the year-to-date reconciliations and documentation of student Pell and Direct Loans more efficient.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268 and 84.063
Federal Award Identification #: 2023-2024 Award Year
Condition: The University did not report enrollment information to the National Student Loan Data System (NSLDS) in a timely and accurate manner for all withdrawn students.
Criteria: 34 CFR 690.83(b) and 34 CFR 685.309
Questioned Costs: $0
Context: Out of 91 students tested, 8 students were not properly reported to NSLDS. All of these students either withdrew between semesters or during a semester. The students have not yet been corrected.
Cause: The system tracks the data needed for enrollment reporting, but somehow with the third-party servicer, these were not properly reported to NSLDS.
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: Yes, 2023-003, 2022-003, 2021-005, 2020-002, and 2019-001.
Recommendation: We recommend the University work with the third-party to determine why the data is not transferring correctly to NSLDS. We further recommend the University complete spot checks of enrollment statuses to NSLDS, particularly for those students who withdrew.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268 and 84.063
Federal Award Identification #: 2023-2024 Award Year
Condition: The University did not report enrollment information to the National Student Loan Data System (NSLDS) in a timely and accurate manner for all withdrawn students.
Criteria: 34 CFR 690.83(b) and 34 CFR 685.309
Questioned Costs: $0
Context: Out of 91 students tested, 8 students were not properly reported to NSLDS. All of these students either withdrew between semesters or during a semester. The students have not yet been corrected.
Cause: The system tracks the data needed for enrollment reporting, but somehow with the third-party servicer, these were not properly reported to NSLDS.
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: Yes, 2023-003, 2022-003, 2021-005, 2020-002, and 2019-001.
Recommendation: We recommend the University work with the third-party to determine why the data is not transferring correctly to NSLDS. We further recommend the University complete spot checks of enrollment statuses to NSLDS, particularly for those students who withdrew.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Return of Title IV (R2T4) Calculations
Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063
Federal Award Identification #: 2023-2024 Award Year
Condition: There were two incorrect calculations of returned funds for students that withdrew during the term.
Criteria: 34 CFR 668.22
Questioned Costs: $0
Context: Out of 37 students, 2 students who withdrew had incorrect calculations. One student was not offered a post-withdrawal disbursement (PWD) of Pell when they attended less than half time in the spring, and one student had an incorrect last date of attendance used in the calculation. These students were not yet corrected during the audit process.
Cause: These were oversights by the University.
Effect: Incorrect amounts of federal funding were returned. One PWD of Pell was $76 less than the student was eligible for and a Pell PWD of $152 was not paid to one student.
Identification as repeat finding, if applicable: Yes, 2023-002, 2022-002, 2021-004, and 2020-003.
Recommendation: We recommend the University continue to provide additional training for counselors performing R2T4 calculations.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Return of Title IV (R2T4) Calculations
Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063
Federal Award Identification #: 2023-2024 Award Year
Condition: There were two incorrect calculations of returned funds for students that withdrew during the term.
Criteria: 34 CFR 668.22
Questioned Costs: $0
Context: Out of 37 students, 2 students who withdrew had incorrect calculations. One student was not offered a post-withdrawal disbursement (PWD) of Pell when they attended less than half time in the spring, and one student had an incorrect last date of attendance used in the calculation. These students were not yet corrected during the audit process.
Cause: These were oversights by the University.
Effect: Incorrect amounts of federal funding were returned. One PWD of Pell was $76 less than the student was eligible for and a Pell PWD of $152 was not paid to one student.
Identification as repeat finding, if applicable: Yes, 2023-002, 2022-002, 2021-004, and 2020-003.
Recommendation: We recommend the University continue to provide additional training for counselors performing R2T4 calculations.
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 #: 2023-2024 Award Year
Condition: Two students out of 60 were not properly awarded Pell based on enrollment status.
Criteria: 34 CFR 690.63(b)
Questioned Costs: $925
Context: One student was inadvertently awarded and paid Pell for one more class than they attended as they started in 11 hours instead of 12 resulting in an overaward of $925. This was corrected during the audit. One student was half time in summer and was not picked up to be paid Pell for the summer term, resulting in an underaward of $1,849. This student was corrected during the audit.
Cause: These were oversights in the cleanup reports run.
Effect: There was an incorrect amount of Pell paid to these two students.
Identification as repeat finding, if applicable: Yes, 2023-005 and 2022-005.
Recommendation: We recommend a process be used to adjust Pell 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.
Gramm-Leach-Bliley Act (GLBA) Compliance DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, and 84.379 - Student Financial Assistance Cluster
Federal Award Identification #: 2023-2024 Award 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 implemented multi-factor authentication on all systems containing personally identifiable information (PII) or documented an exception and has not updated it policy related to data deletion or documented an exception.
Cause: The University was not able to fully address all prior year items with transition at the University in order to address and document compliance with the updated 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, 2023-004
Recommendation: We recommend the University allocate sufficient resources to address all updated requirements of GLBA. We commend the University for the work completed on GLBA in the past year.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, and 84.379 - Student Financial Assistance Cluster
Federal Award Identification #: 2023-2024 Award 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 implemented multi-factor authentication on all systems containing personally identifiable information (PII) or documented an exception and has not updated it policy related to data deletion or documented an exception.
Cause: The University was not able to fully address all prior year items with transition at the University in order to address and document compliance with the updated 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, 2023-004
Recommendation: We recommend the University allocate sufficient resources to address all updated requirements of GLBA. We commend the University for the work completed on GLBA in the past year.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, and 84.379 - Student Financial Assistance Cluster
Federal Award Identification #: 2023-2024 Award 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 implemented multi-factor authentication on all systems containing personally identifiable information (PII) or documented an exception and has not updated it policy related to data deletion or documented an exception.
Cause: The University was not able to fully address all prior year items with transition at the University in order to address and document compliance with the updated 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, 2023-004
Recommendation: We recommend the University allocate sufficient resources to address all updated requirements of GLBA. We commend the University for the work completed on GLBA in the past year.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, and 84.379 - Student Financial Assistance Cluster
Federal Award Identification #: 2023-2024 Award 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 implemented multi-factor authentication on all systems containing personally identifiable information (PII) or documented an exception and has not updated it policy related to data deletion or documented an exception.
Cause: The University was not able to fully address all prior year items with transition at the University in order to address and document compliance with the updated 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, 2023-004
Recommendation: We recommend the University allocate sufficient resources to address all updated requirements of GLBA. We commend the University for the work completed on GLBA in the past year.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, and 84.379 - Student Financial Assistance Cluster
Federal Award Identification #: 2023-2024 Award 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 implemented multi-factor authentication on all systems containing personally identifiable information (PII) or documented an exception and has not updated it policy related to data deletion or documented an exception.
Cause: The University was not able to fully address all prior year items with transition at the University in order to address and document compliance with the updated 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, 2023-004
Recommendation: We recommend the University allocate sufficient resources to address all updated requirements of GLBA. We commend the University for the work completed on GLBA in the past year.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, and 84.379 - Student Financial Assistance Cluster
Federal Award Identification #: 2023-2024 Award 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 implemented multi-factor authentication on all systems containing personally identifiable information (PII) or documented an exception and has not updated it policy related to data deletion or documented an exception.
Cause: The University was not able to fully address all prior year items with transition at the University in order to address and document compliance with the updated 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, 2023-004
Recommendation: We recommend the University allocate sufficient resources to address all updated requirements of GLBA. We commend the University for the work completed on GLBA in the past year.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Documentation of Reconciliations
DEPARTMENT OF EDUCATION
ALN #: 84.268 and 84.063
Federal Award Identification #: 2023-2024 Award Year
Condition: Reconciliations were not available to review on a student-by-student basis year to date.
Criteria: 34 CFR 668 Subpart L
Questioned Costs: $0
Context: Reconciliations are required to be maintained on a monthly basis including year to date information for FDL and Pell. These reconciliations have been done on screen with each batch disbursement and in aggregate but not at the student-by-student detail year to date. Because the University has a large enrollment, student by student manual reconciliations are not time effective.
Cause: The University’s system does not currently allow importing of student files from Common Origination and Disbursement (COD) to complete the reconciliations in a time effective manner.
Effect: The documentation for reconciliations is not available year to date.
Identification as repeat finding, if applicable: Not applicable.
Recommendation: We recommend the University explore options to make the year-to-date reconciliations and documentation of student Pell and Direct Loans more efficient.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Documentation of Reconciliations
DEPARTMENT OF EDUCATION
ALN #: 84.268 and 84.063
Federal Award Identification #: 2023-2024 Award Year
Condition: Reconciliations were not available to review on a student-by-student basis year to date.
Criteria: 34 CFR 668 Subpart L
Questioned Costs: $0
Context: Reconciliations are required to be maintained on a monthly basis including year to date information for FDL and Pell. These reconciliations have been done on screen with each batch disbursement and in aggregate but not at the student-by-student detail year to date. Because the University has a large enrollment, student by student manual reconciliations are not time effective.
Cause: The University’s system does not currently allow importing of student files from Common Origination and Disbursement (COD) to complete the reconciliations in a time effective manner.
Effect: The documentation for reconciliations is not available year to date.
Identification as repeat finding, if applicable: Not applicable.
Recommendation: We recommend the University explore options to make the year-to-date reconciliations and documentation of student Pell and Direct Loans more efficient.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.