Audit 392422

Criteria – An institution’s written information security program must address the required minimum seven elements. Condition – During our audit, the College was asked to provide its written information security program related to Gramm-Leach-Bliley required policies. The College confirmed it did not have appropriately updated written policies during the audit period, which is required under the federal student aid program. Cause - There was an oversight by the College. Possible Asserted Effect - The College does not have a written information security program that is in compliance with Gramm-Leach-Bliley. Known Questioned Costs - None Recommendation - The institution should update its written information security plan to include all seven required elements of the Gramm-Leach-Bliley Act. Views of Responsible Officials - Management agrees with the finding. Upon notification by Wipfli, Western has updated written policies/procedures to ensure that the written security program addresses all seven requirements.

Criteria – Per 34 CFR 685.309, schools must complete and return within 30 days the NSLDS Reporting roster file sent by the Department of Education. Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS website. Institutions are responsible for timely reporting, whether they report directly or via a third party servicer. Unless the school expects to complete its next roster within 60 days, the school must notify the lender or the guaranty agency within 30 days, if it discovers that a student who received a loan either did not enroll or ceased to be enrolled on at least a half-time basis. Condition – Our testing disclosed 3 students, out of the 25 students tested, who were not reported to NSLDS or were not reported timely to NSLDS. Cause - There was an oversight by the College. Possible Asserted Effect - The College did not report information accurately or timely to NSLDS. Known Questioned Costs - None Recommendation - The institution should ensure they are reporting all students who received Title IV funding accurately and timely to NSLDS. Views of Responsible Officials – Management agrees with the finding. Upon notification of the situation by Wipfli, Western has identified several new processes to ensure our students are being reported to the NSLDS within the required time frame.