FAC Explorer

Audit 337905

FY End
2024-06-30
Total Expended
$811,521
Findings
2
Programs
1
Organization: Institute for Clinical Social Work (IL)
Year: 2024 Accepted: 2025-01-14
Auditor: Sikich CPA LLC

Organization Exclusion Status:

Findings

ID Ref Severity Repeat Requirement
519250 2024-001 Material Weakness - N
1095692 2024-001 Material Weakness - N

Programs

ALN Program Spent Major Findings
84.268 Federal Direct Student Loans $811,521 Yes 1

Contacts

Name Title Type
G1CUG245C6K5 Michael Bauman Auditee
7739436500 Ray Krouse Auditor
No contacts on file

Notes to SEFA

Title: FEDERAL LOAN PROGRAM Accounting Policies: The accompanying schedule of expenditures of federal awards is presented on the accrual basis of accounting. The information in this schedule is presented in accordance with the requirements of the Uniform Guidance. De Minimis Rate Used: N Rate Explanation: The Institute for Clinical Social Work has elected not to use the 10% de minimis indirect cost rate allowed under the Uniform Guidance. For the year ended June 30, 2024, The Institute for Clinical Social Work acted as a pass-through agency for Direct Federal Stafford Loans (unsubsidized and PLUS) to students and parents in the amount of $811,521.
Title: OTHER INFORMATION Accounting Policies: The accompanying schedule of expenditures of federal awards is presented on the accrual basis of accounting. The information in this schedule is presented in accordance with the requirements of the Uniform Guidance. De Minimis Rate Used: N Rate Explanation: The Institute for Clinical Social Work has elected not to use the 10% de minimis indirect cost rate allowed under the Uniform Guidance. The Institute for Clinical Social Work did not receive any federal insurance or federal noncash assistance and did not provide any amounts to sub-recipients.

Finding Details

Finding 2024-001
FINDING 2024-001: Failure to Meet the Standards for Safeguarding Customer Information FEDERAL AGENCY: U.S. Department of Education PROGRAM NAME: FEDERAL DIRECT LOAN PROGRAM ALN: 84.268 FEDERAL AWARD YEAR: 2023-2024 Criteria: Institutions shall develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts and contains administrative, technical, and physical safeguards that are appropriate to your size and complexity, the nature and scope of your activities, and the sensitivity of any customer information at issue. The information security program shall include the elements set forth in § 314.4 and shall be reasonably designed to achieve the objectives of this part, as set forth in the objectives of section 501(b) of the Act (16 CFR 314.3(a)). Condition: The Institution failed to implement the new Gramm-Leach-Bliley Act's (GLBA) standards for safeguarding customer information to their student information security policy. We consider this finding to be a material weakness in the Special Tests and Provisions Compliance Requirement. Cause: The condition was caused by the Institution's security officer being unaware of the requirement to establish a policy based off a risk assessment. Question Costs: $0 Recommendation: We recommend the Institution work with their contracted IT department to complete a risk assessment and create a policy using the FTC's 9 elements for GLBA compliance. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan
Finding 2024-001
FINDING 2024-001: Failure to Meet the Standards for Safeguarding Customer Information FEDERAL AGENCY: U.S. Department of Education PROGRAM NAME: FEDERAL DIRECT LOAN PROGRAM ALN: 84.268 FEDERAL AWARD YEAR: 2023-2024 Criteria: Institutions shall develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts and contains administrative, technical, and physical safeguards that are appropriate to your size and complexity, the nature and scope of your activities, and the sensitivity of any customer information at issue. The information security program shall include the elements set forth in § 314.4 and shall be reasonably designed to achieve the objectives of this part, as set forth in the objectives of section 501(b) of the Act (16 CFR 314.3(a)). Condition: The Institution failed to implement the new Gramm-Leach-Bliley Act's (GLBA) standards for safeguarding customer information to their student information security policy. We consider this finding to be a material weakness in the Special Tests and Provisions Compliance Requirement. Cause: The condition was caused by the Institution's security officer being unaware of the requirement to establish a policy based off a risk assessment. Question Costs: $0 Recommendation: We recommend the Institution work with their contracted IT department to complete a risk assessment and create a policy using the FTC's 9 elements for GLBA compliance. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan