Audit 50889

FY End
2022-06-30
Total Expended
$14.79M
Findings
36
Programs
11
Organization: Holy Names University (CA)
Year: 2022 Accepted: 2023-07-17

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
42752 2022-001 - Yes N
42753 2022-002 - - N
42754 2022-001 - Yes N
42755 2022-002 - - N
52212 2022-001 - Yes N
52213 2022-002 - - N
52214 2022-001 - Yes N
52215 2022-002 - - N
52216 2022-001 - Yes N
52217 2022-002 - - N
52218 2022-001 - Yes N
52219 2022-002 - - N
52220 2022-001 - Yes N
52221 2022-002 - - N
52222 2022-001 - Yes N
52223 2022-002 - - N
52224 2022-001 - Yes N
52225 2022-002 - - N
619194 2022-001 - Yes N
619195 2022-002 - - N
619196 2022-001 - Yes N
619197 2022-002 - - N
628654 2022-001 - Yes N
628655 2022-002 - - N
628656 2022-001 - Yes N
628657 2022-002 - - N
628658 2022-001 - Yes N
628659 2022-002 - - N
628660 2022-001 - Yes N
628661 2022-002 - - N
628662 2022-001 - Yes N
628663 2022-002 - - N
628664 2022-001 - Yes N
628665 2022-002 - - N
628666 2022-001 - Yes N
628667 2022-002 - - N

Contacts

Name Title Type
FVJMAY9HM3A5 James Barajas Auditee
5104361220 Susan Malone Auditor
No contacts on file

Notes to SEFA

Title: Loan/loan guarantee outstanding balances Accounting Policies: Summary of Significant Accounting Policies:Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. De Minimis Rate Used: N Rate Explanation: Indirect Costs:Although the U.S. Department of Education provides an Administrative Cost Allowance as a component of the Student Financial Aid programs, there is no indirect cost rate allowed as a part of these programs listed on the accompanying Schedule of Expenditures of Federal Awards. The Strengthening Institutions Program and Upward Bound Program for Disadvantaged Students are covered by approved indirect costs rates of 8%. The University has elected to not use the 10% de minimis indirect cost rate. The outstanding balance at June 30, 2022, of the Perkins Loans was $98,177.
Title: Basis of Presentation Accounting Policies: Summary of Significant Accounting Policies:Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. De Minimis Rate Used: N Rate Explanation: Indirect Costs:Although the U.S. Department of Education provides an Administrative Cost Allowance as a component of the Student Financial Aid programs, there is no indirect cost rate allowed as a part of these programs listed on the accompanying Schedule of Expenditures of Federal Awards. The Strengthening Institutions Program and Upward Bound Program for Disadvantaged Students are covered by approved indirect costs rates of 8%. The University has elected to not use the 10% de minimis indirect cost rate. The accompanying Schedule of Expenditures of Federal Awards (the Schedule) includes the federal grant activity of Holy Names University (the University) under programs of the federal government for the year ended June 30, 2022. The information in this Schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (Uniform Guidance). Because the Schedule presents only a selected portion of the operations of the University, it is not intended to and does not present the financial position, changes in net assets or cash flows of the University.

Finding Details

2022 ? 001 Financial Responsibility Ratio (Student Financial Aid Cluster ? All programs) Criteria According to 34 CFR 668. 171(b)(1), an institution is considered to be financially responsible if the institution?s Equity, Primary Reserve, and Net Income ratios yield a composite score of at least 1.5. Condition The University?s composite score as of June 30, 2022 was below 1.5. Cause Noncompliance was caused by the University?s financial condition. Effect The University is not considered to be financially responsible. Questioned Cost There is no questioned cost related to this finding. Context During review of the University?s financial responsibility ratio calculation, we noted that it?s composite score as of June 30, 2022 was below 1.5. Identification as a Repeat Finding This finding is a repeat of finding 2021-001 and 2020-001 in the immediately prior two audits. Recommendation We recommend the University take appropriate steps to improve its financial condition to be compliant. Views of Responsible Officials We agree with the recommendation.
2022 ? 002 Gramm-Leach-Bliley Act (Student Financial Aid Cluster ? All programs) Criteria Under the University?s Program Participation Agreement and the Gramm-Leach-Bliley Act (GLBA), schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid. According to 16 CFR 314.4(b), a school must identify reasonably foreseeable internal and external risks to the security, confidentiality, and integrity of customer information that could result in the unauthorized disclosure, misuse, alteration, destruction, or other compromise of such information, and assess the sufficiency of any safeguards in place to control these risks. At a minimum, such a risk assessment should include consideration of risks in each relevant area of your operations, including: 1. Employee training and management; 2. Information systems, including network and software design, as well as information processing, storage, transmission, and disposal; and 3. Detecting, preventing, and responding to attacks, intrusions, or other systems failures. Condition Although the University has documented various IT policies around access, they are not comprehensive enough to cover the Gramm-Leach-Bliley Act requirements around the process of identifying the internal and external risks to data security. Cause The University has not conducted a formal risk assessment since January 2021. Effect Student information may be at risk of unauthorized disclosure, misuse, alteration, destruction, or other compromise of such information. Questioned Costs There were no questioned costs related to this finding. Context During our review of the University?s Information Technology system, we noted through inquiry that a formal risk assessment of the University?s documented safeguards had not been performed since January 2021. Recommendation We recommend that the University re-engage the outside resource to independently perform and develop a formal risk assessment, along with recommendations for remediation of any open items and/or deficiencies. Views of Responsible Officials We agree with the recommendation.
2022 ? 001 Financial Responsibility Ratio (Student Financial Aid Cluster ? All programs) Criteria According to 34 CFR 668. 171(b)(1), an institution is considered to be financially responsible if the institution?s Equity, Primary Reserve, and Net Income ratios yield a composite score of at least 1.5. Condition The University?s composite score as of June 30, 2022 was below 1.5. Cause Noncompliance was caused by the University?s financial condition. Effect The University is not considered to be financially responsible. Questioned Cost There is no questioned cost related to this finding. Context During review of the University?s financial responsibility ratio calculation, we noted that it?s composite score as of June 30, 2022 was below 1.5. Identification as a Repeat Finding This finding is a repeat of finding 2021-001 and 2020-001 in the immediately prior two audits. Recommendation We recommend the University take appropriate steps to improve its financial condition to be compliant. Views of Responsible Officials We agree with the recommendation.
2022 ? 002 Gramm-Leach-Bliley Act (Student Financial Aid Cluster ? All programs) Criteria Under the University?s Program Participation Agreement and the Gramm-Leach-Bliley Act (GLBA), schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid. According to 16 CFR 314.4(b), a school must identify reasonably foreseeable internal and external risks to the security, confidentiality, and integrity of customer information that could result in the unauthorized disclosure, misuse, alteration, destruction, or other compromise of such information, and assess the sufficiency of any safeguards in place to control these risks. At a minimum, such a risk assessment should include consideration of risks in each relevant area of your operations, including: 1. Employee training and management; 2. Information systems, including network and software design, as well as information processing, storage, transmission, and disposal; and 3. Detecting, preventing, and responding to attacks, intrusions, or other systems failures. Condition Although the University has documented various IT policies around access, they are not comprehensive enough to cover the Gramm-Leach-Bliley Act requirements around the process of identifying the internal and external risks to data security. Cause The University has not conducted a formal risk assessment since January 2021. Effect Student information may be at risk of unauthorized disclosure, misuse, alteration, destruction, or other compromise of such information. Questioned Costs There were no questioned costs related to this finding. Context During our review of the University?s Information Technology system, we noted through inquiry that a formal risk assessment of the University?s documented safeguards had not been performed since January 2021. Recommendation We recommend that the University re-engage the outside resource to independently perform and develop a formal risk assessment, along with recommendations for remediation of any open items and/or deficiencies. Views of Responsible Officials We agree with the recommendation.
2022 ? 001 Financial Responsibility Ratio (Student Financial Aid Cluster ? All programs) Criteria According to 34 CFR 668. 171(b)(1), an institution is considered to be financially responsible if the institution?s Equity, Primary Reserve, and Net Income ratios yield a composite score of at least 1.5. Condition The University?s composite score as of June 30, 2022 was below 1.5. Cause Noncompliance was caused by the University?s financial condition. Effect The University is not considered to be financially responsible. Questioned Cost There is no questioned cost related to this finding. Context During review of the University?s financial responsibility ratio calculation, we noted that it?s composite score as of June 30, 2022 was below 1.5. Identification as a Repeat Finding This finding is a repeat of finding 2021-001 and 2020-001 in the immediately prior two audits. Recommendation We recommend the University take appropriate steps to improve its financial condition to be compliant. Views of Responsible Officials We agree with the recommendation.
2022 ? 002 Gramm-Leach-Bliley Act (Student Financial Aid Cluster ? All programs) Criteria Under the University?s Program Participation Agreement and the Gramm-Leach-Bliley Act (GLBA), schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid. According to 16 CFR 314.4(b), a school must identify reasonably foreseeable internal and external risks to the security, confidentiality, and integrity of customer information that could result in the unauthorized disclosure, misuse, alteration, destruction, or other compromise of such information, and assess the sufficiency of any safeguards in place to control these risks. At a minimum, such a risk assessment should include consideration of risks in each relevant area of your operations, including: 1. Employee training and management; 2. Information systems, including network and software design, as well as information processing, storage, transmission, and disposal; and 3. Detecting, preventing, and responding to attacks, intrusions, or other systems failures. Condition Although the University has documented various IT policies around access, they are not comprehensive enough to cover the Gramm-Leach-Bliley Act requirements around the process of identifying the internal and external risks to data security. Cause The University has not conducted a formal risk assessment since January 2021. Effect Student information may be at risk of unauthorized disclosure, misuse, alteration, destruction, or other compromise of such information. Questioned Costs There were no questioned costs related to this finding. Context During our review of the University?s Information Technology system, we noted through inquiry that a formal risk assessment of the University?s documented safeguards had not been performed since January 2021. Recommendation We recommend that the University re-engage the outside resource to independently perform and develop a formal risk assessment, along with recommendations for remediation of any open items and/or deficiencies. Views of Responsible Officials We agree with the recommendation.
2022 ? 001 Financial Responsibility Ratio (Student Financial Aid Cluster ? All programs) Criteria According to 34 CFR 668. 171(b)(1), an institution is considered to be financially responsible if the institution?s Equity, Primary Reserve, and Net Income ratios yield a composite score of at least 1.5. Condition The University?s composite score as of June 30, 2022 was below 1.5. Cause Noncompliance was caused by the University?s financial condition. Effect The University is not considered to be financially responsible. Questioned Cost There is no questioned cost related to this finding. Context During review of the University?s financial responsibility ratio calculation, we noted that it?s composite score as of June 30, 2022 was below 1.5. Identification as a Repeat Finding This finding is a repeat of finding 2021-001 and 2020-001 in the immediately prior two audits. Recommendation We recommend the University take appropriate steps to improve its financial condition to be compliant. Views of Responsible Officials We agree with the recommendation.
2022 ? 002 Gramm-Leach-Bliley Act (Student Financial Aid Cluster ? All programs) Criteria Under the University?s Program Participation Agreement and the Gramm-Leach-Bliley Act (GLBA), schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid. According to 16 CFR 314.4(b), a school must identify reasonably foreseeable internal and external risks to the security, confidentiality, and integrity of customer information that could result in the unauthorized disclosure, misuse, alteration, destruction, or other compromise of such information, and assess the sufficiency of any safeguards in place to control these risks. At a minimum, such a risk assessment should include consideration of risks in each relevant area of your operations, including: 1. Employee training and management; 2. Information systems, including network and software design, as well as information processing, storage, transmission, and disposal; and 3. Detecting, preventing, and responding to attacks, intrusions, or other systems failures. Condition Although the University has documented various IT policies around access, they are not comprehensive enough to cover the Gramm-Leach-Bliley Act requirements around the process of identifying the internal and external risks to data security. Cause The University has not conducted a formal risk assessment since January 2021. Effect Student information may be at risk of unauthorized disclosure, misuse, alteration, destruction, or other compromise of such information. Questioned Costs There were no questioned costs related to this finding. Context During our review of the University?s Information Technology system, we noted through inquiry that a formal risk assessment of the University?s documented safeguards had not been performed since January 2021. Recommendation We recommend that the University re-engage the outside resource to independently perform and develop a formal risk assessment, along with recommendations for remediation of any open items and/or deficiencies. Views of Responsible Officials We agree with the recommendation.
2022 ? 001 Financial Responsibility Ratio (Student Financial Aid Cluster ? All programs) Criteria According to 34 CFR 668. 171(b)(1), an institution is considered to be financially responsible if the institution?s Equity, Primary Reserve, and Net Income ratios yield a composite score of at least 1.5. Condition The University?s composite score as of June 30, 2022 was below 1.5. Cause Noncompliance was caused by the University?s financial condition. Effect The University is not considered to be financially responsible. Questioned Cost There is no questioned cost related to this finding. Context During review of the University?s financial responsibility ratio calculation, we noted that it?s composite score as of June 30, 2022 was below 1.5. Identification as a Repeat Finding This finding is a repeat of finding 2021-001 and 2020-001 in the immediately prior two audits. Recommendation We recommend the University take appropriate steps to improve its financial condition to be compliant. Views of Responsible Officials We agree with the recommendation.
2022 ? 002 Gramm-Leach-Bliley Act (Student Financial Aid Cluster ? All programs) Criteria Under the University?s Program Participation Agreement and the Gramm-Leach-Bliley Act (GLBA), schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid. According to 16 CFR 314.4(b), a school must identify reasonably foreseeable internal and external risks to the security, confidentiality, and integrity of customer information that could result in the unauthorized disclosure, misuse, alteration, destruction, or other compromise of such information, and assess the sufficiency of any safeguards in place to control these risks. At a minimum, such a risk assessment should include consideration of risks in each relevant area of your operations, including: 1. Employee training and management; 2. Information systems, including network and software design, as well as information processing, storage, transmission, and disposal; and 3. Detecting, preventing, and responding to attacks, intrusions, or other systems failures. Condition Although the University has documented various IT policies around access, they are not comprehensive enough to cover the Gramm-Leach-Bliley Act requirements around the process of identifying the internal and external risks to data security. Cause The University has not conducted a formal risk assessment since January 2021. Effect Student information may be at risk of unauthorized disclosure, misuse, alteration, destruction, or other compromise of such information. Questioned Costs There were no questioned costs related to this finding. Context During our review of the University?s Information Technology system, we noted through inquiry that a formal risk assessment of the University?s documented safeguards had not been performed since January 2021. Recommendation We recommend that the University re-engage the outside resource to independently perform and develop a formal risk assessment, along with recommendations for remediation of any open items and/or deficiencies. Views of Responsible Officials We agree with the recommendation.
2022 ? 001 Financial Responsibility Ratio (Student Financial Aid Cluster ? All programs) Criteria According to 34 CFR 668. 171(b)(1), an institution is considered to be financially responsible if the institution?s Equity, Primary Reserve, and Net Income ratios yield a composite score of at least 1.5. Condition The University?s composite score as of June 30, 2022 was below 1.5. Cause Noncompliance was caused by the University?s financial condition. Effect The University is not considered to be financially responsible. Questioned Cost There is no questioned cost related to this finding. Context During review of the University?s financial responsibility ratio calculation, we noted that it?s composite score as of June 30, 2022 was below 1.5. Identification as a Repeat Finding This finding is a repeat of finding 2021-001 and 2020-001 in the immediately prior two audits. Recommendation We recommend the University take appropriate steps to improve its financial condition to be compliant. Views of Responsible Officials We agree with the recommendation.
2022 ? 002 Gramm-Leach-Bliley Act (Student Financial Aid Cluster ? All programs) Criteria Under the University?s Program Participation Agreement and the Gramm-Leach-Bliley Act (GLBA), schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid. According to 16 CFR 314.4(b), a school must identify reasonably foreseeable internal and external risks to the security, confidentiality, and integrity of customer information that could result in the unauthorized disclosure, misuse, alteration, destruction, or other compromise of such information, and assess the sufficiency of any safeguards in place to control these risks. At a minimum, such a risk assessment should include consideration of risks in each relevant area of your operations, including: 1. Employee training and management; 2. Information systems, including network and software design, as well as information processing, storage, transmission, and disposal; and 3. Detecting, preventing, and responding to attacks, intrusions, or other systems failures. Condition Although the University has documented various IT policies around access, they are not comprehensive enough to cover the Gramm-Leach-Bliley Act requirements around the process of identifying the internal and external risks to data security. Cause The University has not conducted a formal risk assessment since January 2021. Effect Student information may be at risk of unauthorized disclosure, misuse, alteration, destruction, or other compromise of such information. Questioned Costs There were no questioned costs related to this finding. Context During our review of the University?s Information Technology system, we noted through inquiry that a formal risk assessment of the University?s documented safeguards had not been performed since January 2021. Recommendation We recommend that the University re-engage the outside resource to independently perform and develop a formal risk assessment, along with recommendations for remediation of any open items and/or deficiencies. Views of Responsible Officials We agree with the recommendation.
2022 ? 001 Financial Responsibility Ratio (Student Financial Aid Cluster ? All programs) Criteria According to 34 CFR 668. 171(b)(1), an institution is considered to be financially responsible if the institution?s Equity, Primary Reserve, and Net Income ratios yield a composite score of at least 1.5. Condition The University?s composite score as of June 30, 2022 was below 1.5. Cause Noncompliance was caused by the University?s financial condition. Effect The University is not considered to be financially responsible. Questioned Cost There is no questioned cost related to this finding. Context During review of the University?s financial responsibility ratio calculation, we noted that it?s composite score as of June 30, 2022 was below 1.5. Identification as a Repeat Finding This finding is a repeat of finding 2021-001 and 2020-001 in the immediately prior two audits. Recommendation We recommend the University take appropriate steps to improve its financial condition to be compliant. Views of Responsible Officials We agree with the recommendation.
2022 ? 002 Gramm-Leach-Bliley Act (Student Financial Aid Cluster ? All programs) Criteria Under the University?s Program Participation Agreement and the Gramm-Leach-Bliley Act (GLBA), schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid. According to 16 CFR 314.4(b), a school must identify reasonably foreseeable internal and external risks to the security, confidentiality, and integrity of customer information that could result in the unauthorized disclosure, misuse, alteration, destruction, or other compromise of such information, and assess the sufficiency of any safeguards in place to control these risks. At a minimum, such a risk assessment should include consideration of risks in each relevant area of your operations, including: 1. Employee training and management; 2. Information systems, including network and software design, as well as information processing, storage, transmission, and disposal; and 3. Detecting, preventing, and responding to attacks, intrusions, or other systems failures. Condition Although the University has documented various IT policies around access, they are not comprehensive enough to cover the Gramm-Leach-Bliley Act requirements around the process of identifying the internal and external risks to data security. Cause The University has not conducted a formal risk assessment since January 2021. Effect Student information may be at risk of unauthorized disclosure, misuse, alteration, destruction, or other compromise of such information. Questioned Costs There were no questioned costs related to this finding. Context During our review of the University?s Information Technology system, we noted through inquiry that a formal risk assessment of the University?s documented safeguards had not been performed since January 2021. Recommendation We recommend that the University re-engage the outside resource to independently perform and develop a formal risk assessment, along with recommendations for remediation of any open items and/or deficiencies. Views of Responsible Officials We agree with the recommendation.
2022 ? 001 Financial Responsibility Ratio (Student Financial Aid Cluster ? All programs) Criteria According to 34 CFR 668. 171(b)(1), an institution is considered to be financially responsible if the institution?s Equity, Primary Reserve, and Net Income ratios yield a composite score of at least 1.5. Condition The University?s composite score as of June 30, 2022 was below 1.5. Cause Noncompliance was caused by the University?s financial condition. Effect The University is not considered to be financially responsible. Questioned Cost There is no questioned cost related to this finding. Context During review of the University?s financial responsibility ratio calculation, we noted that it?s composite score as of June 30, 2022 was below 1.5. Identification as a Repeat Finding This finding is a repeat of finding 2021-001 and 2020-001 in the immediately prior two audits. Recommendation We recommend the University take appropriate steps to improve its financial condition to be compliant. Views of Responsible Officials We agree with the recommendation.
2022 ? 002 Gramm-Leach-Bliley Act (Student Financial Aid Cluster ? All programs) Criteria Under the University?s Program Participation Agreement and the Gramm-Leach-Bliley Act (GLBA), schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid. According to 16 CFR 314.4(b), a school must identify reasonably foreseeable internal and external risks to the security, confidentiality, and integrity of customer information that could result in the unauthorized disclosure, misuse, alteration, destruction, or other compromise of such information, and assess the sufficiency of any safeguards in place to control these risks. At a minimum, such a risk assessment should include consideration of risks in each relevant area of your operations, including: 1. Employee training and management; 2. Information systems, including network and software design, as well as information processing, storage, transmission, and disposal; and 3. Detecting, preventing, and responding to attacks, intrusions, or other systems failures. Condition Although the University has documented various IT policies around access, they are not comprehensive enough to cover the Gramm-Leach-Bliley Act requirements around the process of identifying the internal and external risks to data security. Cause The University has not conducted a formal risk assessment since January 2021. Effect Student information may be at risk of unauthorized disclosure, misuse, alteration, destruction, or other compromise of such information. Questioned Costs There were no questioned costs related to this finding. Context During our review of the University?s Information Technology system, we noted through inquiry that a formal risk assessment of the University?s documented safeguards had not been performed since January 2021. Recommendation We recommend that the University re-engage the outside resource to independently perform and develop a formal risk assessment, along with recommendations for remediation of any open items and/or deficiencies. Views of Responsible Officials We agree with the recommendation.
2022 ? 001 Financial Responsibility Ratio (Student Financial Aid Cluster ? All programs) Criteria According to 34 CFR 668. 171(b)(1), an institution is considered to be financially responsible if the institution?s Equity, Primary Reserve, and Net Income ratios yield a composite score of at least 1.5. Condition The University?s composite score as of June 30, 2022 was below 1.5. Cause Noncompliance was caused by the University?s financial condition. Effect The University is not considered to be financially responsible. Questioned Cost There is no questioned cost related to this finding. Context During review of the University?s financial responsibility ratio calculation, we noted that it?s composite score as of June 30, 2022 was below 1.5. Identification as a Repeat Finding This finding is a repeat of finding 2021-001 and 2020-001 in the immediately prior two audits. Recommendation We recommend the University take appropriate steps to improve its financial condition to be compliant. Views of Responsible Officials We agree with the recommendation.
2022 ? 002 Gramm-Leach-Bliley Act (Student Financial Aid Cluster ? All programs) Criteria Under the University?s Program Participation Agreement and the Gramm-Leach-Bliley Act (GLBA), schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid. According to 16 CFR 314.4(b), a school must identify reasonably foreseeable internal and external risks to the security, confidentiality, and integrity of customer information that could result in the unauthorized disclosure, misuse, alteration, destruction, or other compromise of such information, and assess the sufficiency of any safeguards in place to control these risks. At a minimum, such a risk assessment should include consideration of risks in each relevant area of your operations, including: 1. Employee training and management; 2. Information systems, including network and software design, as well as information processing, storage, transmission, and disposal; and 3. Detecting, preventing, and responding to attacks, intrusions, or other systems failures. Condition Although the University has documented various IT policies around access, they are not comprehensive enough to cover the Gramm-Leach-Bliley Act requirements around the process of identifying the internal and external risks to data security. Cause The University has not conducted a formal risk assessment since January 2021. Effect Student information may be at risk of unauthorized disclosure, misuse, alteration, destruction, or other compromise of such information. Questioned Costs There were no questioned costs related to this finding. Context During our review of the University?s Information Technology system, we noted through inquiry that a formal risk assessment of the University?s documented safeguards had not been performed since January 2021. Recommendation We recommend that the University re-engage the outside resource to independently perform and develop a formal risk assessment, along with recommendations for remediation of any open items and/or deficiencies. Views of Responsible Officials We agree with the recommendation.
2022 ? 001 Financial Responsibility Ratio (Student Financial Aid Cluster ? All programs) Criteria According to 34 CFR 668. 171(b)(1), an institution is considered to be financially responsible if the institution?s Equity, Primary Reserve, and Net Income ratios yield a composite score of at least 1.5. Condition The University?s composite score as of June 30, 2022 was below 1.5. Cause Noncompliance was caused by the University?s financial condition. Effect The University is not considered to be financially responsible. Questioned Cost There is no questioned cost related to this finding. Context During review of the University?s financial responsibility ratio calculation, we noted that it?s composite score as of June 30, 2022 was below 1.5. Identification as a Repeat Finding This finding is a repeat of finding 2021-001 and 2020-001 in the immediately prior two audits. Recommendation We recommend the University take appropriate steps to improve its financial condition to be compliant. Views of Responsible Officials We agree with the recommendation.
2022 ? 002 Gramm-Leach-Bliley Act (Student Financial Aid Cluster ? All programs) Criteria Under the University?s Program Participation Agreement and the Gramm-Leach-Bliley Act (GLBA), schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid. According to 16 CFR 314.4(b), a school must identify reasonably foreseeable internal and external risks to the security, confidentiality, and integrity of customer information that could result in the unauthorized disclosure, misuse, alteration, destruction, or other compromise of such information, and assess the sufficiency of any safeguards in place to control these risks. At a minimum, such a risk assessment should include consideration of risks in each relevant area of your operations, including: 1. Employee training and management; 2. Information systems, including network and software design, as well as information processing, storage, transmission, and disposal; and 3. Detecting, preventing, and responding to attacks, intrusions, or other systems failures. Condition Although the University has documented various IT policies around access, they are not comprehensive enough to cover the Gramm-Leach-Bliley Act requirements around the process of identifying the internal and external risks to data security. Cause The University has not conducted a formal risk assessment since January 2021. Effect Student information may be at risk of unauthorized disclosure, misuse, alteration, destruction, or other compromise of such information. Questioned Costs There were no questioned costs related to this finding. Context During our review of the University?s Information Technology system, we noted through inquiry that a formal risk assessment of the University?s documented safeguards had not been performed since January 2021. Recommendation We recommend that the University re-engage the outside resource to independently perform and develop a formal risk assessment, along with recommendations for remediation of any open items and/or deficiencies. Views of Responsible Officials We agree with the recommendation.
2022 ? 001 Financial Responsibility Ratio (Student Financial Aid Cluster ? All programs) Criteria According to 34 CFR 668. 171(b)(1), an institution is considered to be financially responsible if the institution?s Equity, Primary Reserve, and Net Income ratios yield a composite score of at least 1.5. Condition The University?s composite score as of June 30, 2022 was below 1.5. Cause Noncompliance was caused by the University?s financial condition. Effect The University is not considered to be financially responsible. Questioned Cost There is no questioned cost related to this finding. Context During review of the University?s financial responsibility ratio calculation, we noted that it?s composite score as of June 30, 2022 was below 1.5. Identification as a Repeat Finding This finding is a repeat of finding 2021-001 and 2020-001 in the immediately prior two audits. Recommendation We recommend the University take appropriate steps to improve its financial condition to be compliant. Views of Responsible Officials We agree with the recommendation.
2022 ? 002 Gramm-Leach-Bliley Act (Student Financial Aid Cluster ? All programs) Criteria Under the University?s Program Participation Agreement and the Gramm-Leach-Bliley Act (GLBA), schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid. According to 16 CFR 314.4(b), a school must identify reasonably foreseeable internal and external risks to the security, confidentiality, and integrity of customer information that could result in the unauthorized disclosure, misuse, alteration, destruction, or other compromise of such information, and assess the sufficiency of any safeguards in place to control these risks. At a minimum, such a risk assessment should include consideration of risks in each relevant area of your operations, including: 1. Employee training and management; 2. Information systems, including network and software design, as well as information processing, storage, transmission, and disposal; and 3. Detecting, preventing, and responding to attacks, intrusions, or other systems failures. Condition Although the University has documented various IT policies around access, they are not comprehensive enough to cover the Gramm-Leach-Bliley Act requirements around the process of identifying the internal and external risks to data security. Cause The University has not conducted a formal risk assessment since January 2021. Effect Student information may be at risk of unauthorized disclosure, misuse, alteration, destruction, or other compromise of such information. Questioned Costs There were no questioned costs related to this finding. Context During our review of the University?s Information Technology system, we noted through inquiry that a formal risk assessment of the University?s documented safeguards had not been performed since January 2021. Recommendation We recommend that the University re-engage the outside resource to independently perform and develop a formal risk assessment, along with recommendations for remediation of any open items and/or deficiencies. Views of Responsible Officials We agree with the recommendation.
2022 ? 001 Financial Responsibility Ratio (Student Financial Aid Cluster ? All programs) Criteria According to 34 CFR 668. 171(b)(1), an institution is considered to be financially responsible if the institution?s Equity, Primary Reserve, and Net Income ratios yield a composite score of at least 1.5. Condition The University?s composite score as of June 30, 2022 was below 1.5. Cause Noncompliance was caused by the University?s financial condition. Effect The University is not considered to be financially responsible. Questioned Cost There is no questioned cost related to this finding. Context During review of the University?s financial responsibility ratio calculation, we noted that it?s composite score as of June 30, 2022 was below 1.5. Identification as a Repeat Finding This finding is a repeat of finding 2021-001 and 2020-001 in the immediately prior two audits. Recommendation We recommend the University take appropriate steps to improve its financial condition to be compliant. Views of Responsible Officials We agree with the recommendation.
2022 ? 002 Gramm-Leach-Bliley Act (Student Financial Aid Cluster ? All programs) Criteria Under the University?s Program Participation Agreement and the Gramm-Leach-Bliley Act (GLBA), schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid. According to 16 CFR 314.4(b), a school must identify reasonably foreseeable internal and external risks to the security, confidentiality, and integrity of customer information that could result in the unauthorized disclosure, misuse, alteration, destruction, or other compromise of such information, and assess the sufficiency of any safeguards in place to control these risks. At a minimum, such a risk assessment should include consideration of risks in each relevant area of your operations, including: 1. Employee training and management; 2. Information systems, including network and software design, as well as information processing, storage, transmission, and disposal; and 3. Detecting, preventing, and responding to attacks, intrusions, or other systems failures. Condition Although the University has documented various IT policies around access, they are not comprehensive enough to cover the Gramm-Leach-Bliley Act requirements around the process of identifying the internal and external risks to data security. Cause The University has not conducted a formal risk assessment since January 2021. Effect Student information may be at risk of unauthorized disclosure, misuse, alteration, destruction, or other compromise of such information. Questioned Costs There were no questioned costs related to this finding. Context During our review of the University?s Information Technology system, we noted through inquiry that a formal risk assessment of the University?s documented safeguards had not been performed since January 2021. Recommendation We recommend that the University re-engage the outside resource to independently perform and develop a formal risk assessment, along with recommendations for remediation of any open items and/or deficiencies. Views of Responsible Officials We agree with the recommendation.
2022 ? 001 Financial Responsibility Ratio (Student Financial Aid Cluster ? All programs) Criteria According to 34 CFR 668. 171(b)(1), an institution is considered to be financially responsible if the institution?s Equity, Primary Reserve, and Net Income ratios yield a composite score of at least 1.5. Condition The University?s composite score as of June 30, 2022 was below 1.5. Cause Noncompliance was caused by the University?s financial condition. Effect The University is not considered to be financially responsible. Questioned Cost There is no questioned cost related to this finding. Context During review of the University?s financial responsibility ratio calculation, we noted that it?s composite score as of June 30, 2022 was below 1.5. Identification as a Repeat Finding This finding is a repeat of finding 2021-001 and 2020-001 in the immediately prior two audits. Recommendation We recommend the University take appropriate steps to improve its financial condition to be compliant. Views of Responsible Officials We agree with the recommendation.
2022 ? 002 Gramm-Leach-Bliley Act (Student Financial Aid Cluster ? All programs) Criteria Under the University?s Program Participation Agreement and the Gramm-Leach-Bliley Act (GLBA), schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid. According to 16 CFR 314.4(b), a school must identify reasonably foreseeable internal and external risks to the security, confidentiality, and integrity of customer information that could result in the unauthorized disclosure, misuse, alteration, destruction, or other compromise of such information, and assess the sufficiency of any safeguards in place to control these risks. At a minimum, such a risk assessment should include consideration of risks in each relevant area of your operations, including: 1. Employee training and management; 2. Information systems, including network and software design, as well as information processing, storage, transmission, and disposal; and 3. Detecting, preventing, and responding to attacks, intrusions, or other systems failures. Condition Although the University has documented various IT policies around access, they are not comprehensive enough to cover the Gramm-Leach-Bliley Act requirements around the process of identifying the internal and external risks to data security. Cause The University has not conducted a formal risk assessment since January 2021. Effect Student information may be at risk of unauthorized disclosure, misuse, alteration, destruction, or other compromise of such information. Questioned Costs There were no questioned costs related to this finding. Context During our review of the University?s Information Technology system, we noted through inquiry that a formal risk assessment of the University?s documented safeguards had not been performed since January 2021. Recommendation We recommend that the University re-engage the outside resource to independently perform and develop a formal risk assessment, along with recommendations for remediation of any open items and/or deficiencies. Views of Responsible Officials We agree with the recommendation.
2022 ? 001 Financial Responsibility Ratio (Student Financial Aid Cluster ? All programs) Criteria According to 34 CFR 668. 171(b)(1), an institution is considered to be financially responsible if the institution?s Equity, Primary Reserve, and Net Income ratios yield a composite score of at least 1.5. Condition The University?s composite score as of June 30, 2022 was below 1.5. Cause Noncompliance was caused by the University?s financial condition. Effect The University is not considered to be financially responsible. Questioned Cost There is no questioned cost related to this finding. Context During review of the University?s financial responsibility ratio calculation, we noted that it?s composite score as of June 30, 2022 was below 1.5. Identification as a Repeat Finding This finding is a repeat of finding 2021-001 and 2020-001 in the immediately prior two audits. Recommendation We recommend the University take appropriate steps to improve its financial condition to be compliant. Views of Responsible Officials We agree with the recommendation.
2022 ? 002 Gramm-Leach-Bliley Act (Student Financial Aid Cluster ? All programs) Criteria Under the University?s Program Participation Agreement and the Gramm-Leach-Bliley Act (GLBA), schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid. According to 16 CFR 314.4(b), a school must identify reasonably foreseeable internal and external risks to the security, confidentiality, and integrity of customer information that could result in the unauthorized disclosure, misuse, alteration, destruction, or other compromise of such information, and assess the sufficiency of any safeguards in place to control these risks. At a minimum, such a risk assessment should include consideration of risks in each relevant area of your operations, including: 1. Employee training and management; 2. Information systems, including network and software design, as well as information processing, storage, transmission, and disposal; and 3. Detecting, preventing, and responding to attacks, intrusions, or other systems failures. Condition Although the University has documented various IT policies around access, they are not comprehensive enough to cover the Gramm-Leach-Bliley Act requirements around the process of identifying the internal and external risks to data security. Cause The University has not conducted a formal risk assessment since January 2021. Effect Student information may be at risk of unauthorized disclosure, misuse, alteration, destruction, or other compromise of such information. Questioned Costs There were no questioned costs related to this finding. Context During our review of the University?s Information Technology system, we noted through inquiry that a formal risk assessment of the University?s documented safeguards had not been performed since January 2021. Recommendation We recommend that the University re-engage the outside resource to independently perform and develop a formal risk assessment, along with recommendations for remediation of any open items and/or deficiencies. Views of Responsible Officials We agree with the recommendation.
2022 ? 001 Financial Responsibility Ratio (Student Financial Aid Cluster ? All programs) Criteria According to 34 CFR 668. 171(b)(1), an institution is considered to be financially responsible if the institution?s Equity, Primary Reserve, and Net Income ratios yield a composite score of at least 1.5. Condition The University?s composite score as of June 30, 2022 was below 1.5. Cause Noncompliance was caused by the University?s financial condition. Effect The University is not considered to be financially responsible. Questioned Cost There is no questioned cost related to this finding. Context During review of the University?s financial responsibility ratio calculation, we noted that it?s composite score as of June 30, 2022 was below 1.5. Identification as a Repeat Finding This finding is a repeat of finding 2021-001 and 2020-001 in the immediately prior two audits. Recommendation We recommend the University take appropriate steps to improve its financial condition to be compliant. Views of Responsible Officials We agree with the recommendation.
2022 ? 002 Gramm-Leach-Bliley Act (Student Financial Aid Cluster ? All programs) Criteria Under the University?s Program Participation Agreement and the Gramm-Leach-Bliley Act (GLBA), schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid. According to 16 CFR 314.4(b), a school must identify reasonably foreseeable internal and external risks to the security, confidentiality, and integrity of customer information that could result in the unauthorized disclosure, misuse, alteration, destruction, or other compromise of such information, and assess the sufficiency of any safeguards in place to control these risks. At a minimum, such a risk assessment should include consideration of risks in each relevant area of your operations, including: 1. Employee training and management; 2. Information systems, including network and software design, as well as information processing, storage, transmission, and disposal; and 3. Detecting, preventing, and responding to attacks, intrusions, or other systems failures. Condition Although the University has documented various IT policies around access, they are not comprehensive enough to cover the Gramm-Leach-Bliley Act requirements around the process of identifying the internal and external risks to data security. Cause The University has not conducted a formal risk assessment since January 2021. Effect Student information may be at risk of unauthorized disclosure, misuse, alteration, destruction, or other compromise of such information. Questioned Costs There were no questioned costs related to this finding. Context During our review of the University?s Information Technology system, we noted through inquiry that a formal risk assessment of the University?s documented safeguards had not been performed since January 2021. Recommendation We recommend that the University re-engage the outside resource to independently perform and develop a formal risk assessment, along with recommendations for remediation of any open items and/or deficiencies. Views of Responsible Officials We agree with the recommendation.
2022 ? 001 Financial Responsibility Ratio (Student Financial Aid Cluster ? All programs) Criteria According to 34 CFR 668. 171(b)(1), an institution is considered to be financially responsible if the institution?s Equity, Primary Reserve, and Net Income ratios yield a composite score of at least 1.5. Condition The University?s composite score as of June 30, 2022 was below 1.5. Cause Noncompliance was caused by the University?s financial condition. Effect The University is not considered to be financially responsible. Questioned Cost There is no questioned cost related to this finding. Context During review of the University?s financial responsibility ratio calculation, we noted that it?s composite score as of June 30, 2022 was below 1.5. Identification as a Repeat Finding This finding is a repeat of finding 2021-001 and 2020-001 in the immediately prior two audits. Recommendation We recommend the University take appropriate steps to improve its financial condition to be compliant. Views of Responsible Officials We agree with the recommendation.
2022 ? 002 Gramm-Leach-Bliley Act (Student Financial Aid Cluster ? All programs) Criteria Under the University?s Program Participation Agreement and the Gramm-Leach-Bliley Act (GLBA), schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid. According to 16 CFR 314.4(b), a school must identify reasonably foreseeable internal and external risks to the security, confidentiality, and integrity of customer information that could result in the unauthorized disclosure, misuse, alteration, destruction, or other compromise of such information, and assess the sufficiency of any safeguards in place to control these risks. At a minimum, such a risk assessment should include consideration of risks in each relevant area of your operations, including: 1. Employee training and management; 2. Information systems, including network and software design, as well as information processing, storage, transmission, and disposal; and 3. Detecting, preventing, and responding to attacks, intrusions, or other systems failures. Condition Although the University has documented various IT policies around access, they are not comprehensive enough to cover the Gramm-Leach-Bliley Act requirements around the process of identifying the internal and external risks to data security. Cause The University has not conducted a formal risk assessment since January 2021. Effect Student information may be at risk of unauthorized disclosure, misuse, alteration, destruction, or other compromise of such information. Questioned Costs There were no questioned costs related to this finding. Context During our review of the University?s Information Technology system, we noted through inquiry that a formal risk assessment of the University?s documented safeguards had not been performed since January 2021. Recommendation We recommend that the University re-engage the outside resource to independently perform and develop a formal risk assessment, along with recommendations for remediation of any open items and/or deficiencies. Views of Responsible Officials We agree with the recommendation.
2022 ? 001 Financial Responsibility Ratio (Student Financial Aid Cluster ? All programs) Criteria According to 34 CFR 668. 171(b)(1), an institution is considered to be financially responsible if the institution?s Equity, Primary Reserve, and Net Income ratios yield a composite score of at least 1.5. Condition The University?s composite score as of June 30, 2022 was below 1.5. Cause Noncompliance was caused by the University?s financial condition. Effect The University is not considered to be financially responsible. Questioned Cost There is no questioned cost related to this finding. Context During review of the University?s financial responsibility ratio calculation, we noted that it?s composite score as of June 30, 2022 was below 1.5. Identification as a Repeat Finding This finding is a repeat of finding 2021-001 and 2020-001 in the immediately prior two audits. Recommendation We recommend the University take appropriate steps to improve its financial condition to be compliant. Views of Responsible Officials We agree with the recommendation.
2022 ? 002 Gramm-Leach-Bliley Act (Student Financial Aid Cluster ? All programs) Criteria Under the University?s Program Participation Agreement and the Gramm-Leach-Bliley Act (GLBA), schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid. According to 16 CFR 314.4(b), a school must identify reasonably foreseeable internal and external risks to the security, confidentiality, and integrity of customer information that could result in the unauthorized disclosure, misuse, alteration, destruction, or other compromise of such information, and assess the sufficiency of any safeguards in place to control these risks. At a minimum, such a risk assessment should include consideration of risks in each relevant area of your operations, including: 1. Employee training and management; 2. Information systems, including network and software design, as well as information processing, storage, transmission, and disposal; and 3. Detecting, preventing, and responding to attacks, intrusions, or other systems failures. Condition Although the University has documented various IT policies around access, they are not comprehensive enough to cover the Gramm-Leach-Bliley Act requirements around the process of identifying the internal and external risks to data security. Cause The University has not conducted a formal risk assessment since January 2021. Effect Student information may be at risk of unauthorized disclosure, misuse, alteration, destruction, or other compromise of such information. Questioned Costs There were no questioned costs related to this finding. Context During our review of the University?s Information Technology system, we noted through inquiry that a formal risk assessment of the University?s documented safeguards had not been performed since January 2021. Recommendation We recommend that the University re-engage the outside resource to independently perform and develop a formal risk assessment, along with recommendations for remediation of any open items and/or deficiencies. Views of Responsible Officials We agree with the recommendation.
2022 ? 001 Financial Responsibility Ratio (Student Financial Aid Cluster ? All programs) Criteria According to 34 CFR 668. 171(b)(1), an institution is considered to be financially responsible if the institution?s Equity, Primary Reserve, and Net Income ratios yield a composite score of at least 1.5. Condition The University?s composite score as of June 30, 2022 was below 1.5. Cause Noncompliance was caused by the University?s financial condition. Effect The University is not considered to be financially responsible. Questioned Cost There is no questioned cost related to this finding. Context During review of the University?s financial responsibility ratio calculation, we noted that it?s composite score as of June 30, 2022 was below 1.5. Identification as a Repeat Finding This finding is a repeat of finding 2021-001 and 2020-001 in the immediately prior two audits. Recommendation We recommend the University take appropriate steps to improve its financial condition to be compliant. Views of Responsible Officials We agree with the recommendation.
2022 ? 002 Gramm-Leach-Bliley Act (Student Financial Aid Cluster ? All programs) Criteria Under the University?s Program Participation Agreement and the Gramm-Leach-Bliley Act (GLBA), schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid. According to 16 CFR 314.4(b), a school must identify reasonably foreseeable internal and external risks to the security, confidentiality, and integrity of customer information that could result in the unauthorized disclosure, misuse, alteration, destruction, or other compromise of such information, and assess the sufficiency of any safeguards in place to control these risks. At a minimum, such a risk assessment should include consideration of risks in each relevant area of your operations, including: 1. Employee training and management; 2. Information systems, including network and software design, as well as information processing, storage, transmission, and disposal; and 3. Detecting, preventing, and responding to attacks, intrusions, or other systems failures. Condition Although the University has documented various IT policies around access, they are not comprehensive enough to cover the Gramm-Leach-Bliley Act requirements around the process of identifying the internal and external risks to data security. Cause The University has not conducted a formal risk assessment since January 2021. Effect Student information may be at risk of unauthorized disclosure, misuse, alteration, destruction, or other compromise of such information. Questioned Costs There were no questioned costs related to this finding. Context During our review of the University?s Information Technology system, we noted through inquiry that a formal risk assessment of the University?s documented safeguards had not been performed since January 2021. Recommendation We recommend that the University re-engage the outside resource to independently perform and develop a formal risk assessment, along with recommendations for remediation of any open items and/or deficiencies. Views of Responsible Officials We agree with the recommendation.