Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, and 84.033 - Student Financial Assistance Cluster
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The University did not sufficiently comply with the updated requirements of GLBA.
Criteria: 16 CFR 314.4
Questioned Costs: $0
Context: The University has not updated the information security program for legislative changes in 2023; sufficiently documented its security risk assessment and safeguards, including encryption, data retention and disposal, and user access reviews; implemented multi-factor authentication on all systems containing personally identifiable information (PII); implemented sufficient vendor management policies and reviews; and provided a written, annual report to the board.
Cause: The University has not allocated sufficient resources to address and document compliance with the updated requirements of GLBA.
Effect: The University has not adequately addressed the updated requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: Not applicable.
Recommendation: We recommend the University allocate sufficient resources to address all updated requirements of GLBA.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, and 84.033 - Student Financial Assistance Cluster
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The University did not sufficiently comply with the updated requirements of GLBA.
Criteria: 16 CFR 314.4
Questioned Costs: $0
Context: The University has not updated the information security program for legislative changes in 2023; sufficiently documented its security risk assessment and safeguards, including encryption, data retention and disposal, and user access reviews; implemented multi-factor authentication on all systems containing personally identifiable information (PII); implemented sufficient vendor management policies and reviews; and provided a written, annual report to the board.
Cause: The University has not allocated sufficient resources to address and document compliance with the updated requirements of GLBA.
Effect: The University has not adequately addressed the updated requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: Not applicable.
Recommendation: We recommend the University allocate sufficient resources to address all updated requirements of GLBA.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, and 84.033 - Student Financial Assistance Cluster
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The University did not sufficiently comply with the updated requirements of GLBA.
Criteria: 16 CFR 314.4
Questioned Costs: $0
Context: The University has not updated the information security program for legislative changes in 2023; sufficiently documented its security risk assessment and safeguards, including encryption, data retention and disposal, and user access reviews; implemented multi-factor authentication on all systems containing personally identifiable information (PII); implemented sufficient vendor management policies and reviews; and provided a written, annual report to the board.
Cause: The University has not allocated sufficient resources to address and document compliance with the updated requirements of GLBA.
Effect: The University has not adequately addressed the updated requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: Not applicable.
Recommendation: We recommend the University allocate sufficient resources to address all updated requirements of GLBA.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, and 84.033 - Student Financial Assistance Cluster
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The University did not sufficiently comply with the updated requirements of GLBA.
Criteria: 16 CFR 314.4
Questioned Costs: $0
Context: The University has not updated the information security program for legislative changes in 2023; sufficiently documented its security risk assessment and safeguards, including encryption, data retention and disposal, and user access reviews; implemented multi-factor authentication on all systems containing personally identifiable information (PII); implemented sufficient vendor management policies and reviews; and provided a written, annual report to the board.
Cause: The University has not allocated sufficient resources to address and document compliance with the updated requirements of GLBA.
Effect: The University has not adequately addressed the updated requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: Not applicable.
Recommendation: We recommend the University allocate sufficient resources to address all updated requirements of GLBA.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Inaccurate and Untimely Returns of Title IV Funds (R2T4) Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063 and 84.007
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: When students withdrew either officially or unofficially, the University did not always return unearned Title IV aid timely and return calculations were not done correctly consistently.
Criteria: 34 CFR 668.22
Questioned Costs: $2,670
Context: Out of 25 students tested, 4 students had $9,067 in late returns of Federal Direct Loans (FDL) ranging from 34 to 300 days late. This was due to a lack of communication between the registrar and financial aid offices that should be triggered by a student’s withdrawal. Two students, who were official withdrawals, had late dates of determination, which caused late returns. One of those students had an incorrect amount initially returned that was then corrected during the audit ($845 FDL). One student did not have a return made due to the initial days completed calculation being incorrect as it did not include one of the student’s modules the student was initially enrolled in resulting in $1,802 FDL to be return. One student had an incorrect calculation which resulted in $23 additional FDL to return. These were corrected during the audit.
Cause: There was a lack of appropriate resources to perform an adequate review of modular withdrawals and a lack of communication between the registrar and financial aid offices.
Effect: Title IV funds were not returned timely.
Identification as repeat finding, if applicable: 2022-001
Recommendation: We recommend that the financial aid office work closely with the registrar office and their third party administrator to ensure that R2T4’s are completed timely when students cease attendance during the term. We also recommend additional staff be allocated to the withdrawal process due to the high population of students (approx. 10%) who withdraw officially or unofficially.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Inaccurate and Untimely Returns of Title IV Funds (R2T4) Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063 and 84.007
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: When students withdrew either officially or unofficially, the University did not always return unearned Title IV aid timely and return calculations were not done correctly consistently.
Criteria: 34 CFR 668.22
Questioned Costs: $2,670
Context: Out of 25 students tested, 4 students had $9,067 in late returns of Federal Direct Loans (FDL) ranging from 34 to 300 days late. This was due to a lack of communication between the registrar and financial aid offices that should be triggered by a student’s withdrawal. Two students, who were official withdrawals, had late dates of determination, which caused late returns. One of those students had an incorrect amount initially returned that was then corrected during the audit ($845 FDL). One student did not have a return made due to the initial days completed calculation being incorrect as it did not include one of the student’s modules the student was initially enrolled in resulting in $1,802 FDL to be return. One student had an incorrect calculation which resulted in $23 additional FDL to return. These were corrected during the audit.
Cause: There was a lack of appropriate resources to perform an adequate review of modular withdrawals and a lack of communication between the registrar and financial aid offices.
Effect: Title IV funds were not returned timely.
Identification as repeat finding, if applicable: 2022-001
Recommendation: We recommend that the financial aid office work closely with the registrar office and their third party administrator to ensure that R2T4’s are completed timely when students cease attendance during the term. We also recommend additional staff be allocated to the withdrawal process due to the high population of students (approx. 10%) who withdraw officially or unofficially.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Inaccurate and Untimely Returns of Title IV Funds (R2T4) Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063 and 84.007
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: When students withdrew either officially or unofficially, the University did not always return unearned Title IV aid timely and return calculations were not done correctly consistently.
Criteria: 34 CFR 668.22
Questioned Costs: $2,670
Context: Out of 25 students tested, 4 students had $9,067 in late returns of Federal Direct Loans (FDL) ranging from 34 to 300 days late. This was due to a lack of communication between the registrar and financial aid offices that should be triggered by a student’s withdrawal. Two students, who were official withdrawals, had late dates of determination, which caused late returns. One of those students had an incorrect amount initially returned that was then corrected during the audit ($845 FDL). One student did not have a return made due to the initial days completed calculation being incorrect as it did not include one of the student’s modules the student was initially enrolled in resulting in $1,802 FDL to be return. One student had an incorrect calculation which resulted in $23 additional FDL to return. These were corrected during the audit.
Cause: There was a lack of appropriate resources to perform an adequate review of modular withdrawals and a lack of communication between the registrar and financial aid offices.
Effect: Title IV funds were not returned timely.
Identification as repeat finding, if applicable: 2022-001
Recommendation: We recommend that the financial aid office work closely with the registrar office and their third party administrator to ensure that R2T4’s are completed timely when students cease attendance during the term. We also recommend additional staff be allocated to the withdrawal process due to the high population of students (approx. 10%) who withdraw officially or unofficially.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, and 84.033 - Student Financial Assistance Cluster
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The University did not sufficiently comply with the updated requirements of GLBA.
Criteria: 16 CFR 314.4
Questioned Costs: $0
Context: The University has not updated the information security program for legislative changes in 2023; sufficiently documented its security risk assessment and safeguards, including encryption, data retention and disposal, and user access reviews; implemented multi-factor authentication on all systems containing personally identifiable information (PII); implemented sufficient vendor management policies and reviews; and provided a written, annual report to the board.
Cause: The University has not allocated sufficient resources to address and document compliance with the updated requirements of GLBA.
Effect: The University has not adequately addressed the updated requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: Not applicable.
Recommendation: We recommend the University allocate sufficient resources to address all updated requirements of GLBA.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, and 84.033 - Student Financial Assistance Cluster
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The University did not sufficiently comply with the updated requirements of GLBA.
Criteria: 16 CFR 314.4
Questioned Costs: $0
Context: The University has not updated the information security program for legislative changes in 2023; sufficiently documented its security risk assessment and safeguards, including encryption, data retention and disposal, and user access reviews; implemented multi-factor authentication on all systems containing personally identifiable information (PII); implemented sufficient vendor management policies and reviews; and provided a written, annual report to the board.
Cause: The University has not allocated sufficient resources to address and document compliance with the updated requirements of GLBA.
Effect: The University has not adequately addressed the updated requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: Not applicable.
Recommendation: We recommend the University allocate sufficient resources to address all updated requirements of GLBA.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, and 84.033 - Student Financial Assistance Cluster
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The University did not sufficiently comply with the updated requirements of GLBA.
Criteria: 16 CFR 314.4
Questioned Costs: $0
Context: The University has not updated the information security program for legislative changes in 2023; sufficiently documented its security risk assessment and safeguards, including encryption, data retention and disposal, and user access reviews; implemented multi-factor authentication on all systems containing personally identifiable information (PII); implemented sufficient vendor management policies and reviews; and provided a written, annual report to the board.
Cause: The University has not allocated sufficient resources to address and document compliance with the updated requirements of GLBA.
Effect: The University has not adequately addressed the updated requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: Not applicable.
Recommendation: We recommend the University allocate sufficient resources to address all updated requirements of GLBA.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, and 84.033 - Student Financial Assistance Cluster
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: The University did not sufficiently comply with the updated requirements of GLBA.
Criteria: 16 CFR 314.4
Questioned Costs: $0
Context: The University has not updated the information security program for legislative changes in 2023; sufficiently documented its security risk assessment and safeguards, including encryption, data retention and disposal, and user access reviews; implemented multi-factor authentication on all systems containing personally identifiable information (PII); implemented sufficient vendor management policies and reviews; and provided a written, annual report to the board.
Cause: The University has not allocated sufficient resources to address and document compliance with the updated requirements of GLBA.
Effect: The University has not adequately addressed the updated requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: Not applicable.
Recommendation: We recommend the University allocate sufficient resources to address all updated requirements of GLBA.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Inaccurate and Untimely Returns of Title IV Funds (R2T4) Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063 and 84.007
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: When students withdrew either officially or unofficially, the University did not always return unearned Title IV aid timely and return calculations were not done correctly consistently.
Criteria: 34 CFR 668.22
Questioned Costs: $2,670
Context: Out of 25 students tested, 4 students had $9,067 in late returns of Federal Direct Loans (FDL) ranging from 34 to 300 days late. This was due to a lack of communication between the registrar and financial aid offices that should be triggered by a student’s withdrawal. Two students, who were official withdrawals, had late dates of determination, which caused late returns. One of those students had an incorrect amount initially returned that was then corrected during the audit ($845 FDL). One student did not have a return made due to the initial days completed calculation being incorrect as it did not include one of the student’s modules the student was initially enrolled in resulting in $1,802 FDL to be return. One student had an incorrect calculation which resulted in $23 additional FDL to return. These were corrected during the audit.
Cause: There was a lack of appropriate resources to perform an adequate review of modular withdrawals and a lack of communication between the registrar and financial aid offices.
Effect: Title IV funds were not returned timely.
Identification as repeat finding, if applicable: 2022-001
Recommendation: We recommend that the financial aid office work closely with the registrar office and their third party administrator to ensure that R2T4’s are completed timely when students cease attendance during the term. We also recommend additional staff be allocated to the withdrawal process due to the high population of students (approx. 10%) who withdraw officially or unofficially.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Inaccurate and Untimely Returns of Title IV Funds (R2T4) Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063 and 84.007
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: When students withdrew either officially or unofficially, the University did not always return unearned Title IV aid timely and return calculations were not done correctly consistently.
Criteria: 34 CFR 668.22
Questioned Costs: $2,670
Context: Out of 25 students tested, 4 students had $9,067 in late returns of Federal Direct Loans (FDL) ranging from 34 to 300 days late. This was due to a lack of communication between the registrar and financial aid offices that should be triggered by a student’s withdrawal. Two students, who were official withdrawals, had late dates of determination, which caused late returns. One of those students had an incorrect amount initially returned that was then corrected during the audit ($845 FDL). One student did not have a return made due to the initial days completed calculation being incorrect as it did not include one of the student’s modules the student was initially enrolled in resulting in $1,802 FDL to be return. One student had an incorrect calculation which resulted in $23 additional FDL to return. These were corrected during the audit.
Cause: There was a lack of appropriate resources to perform an adequate review of modular withdrawals and a lack of communication between the registrar and financial aid offices.
Effect: Title IV funds were not returned timely.
Identification as repeat finding, if applicable: 2022-001
Recommendation: We recommend that the financial aid office work closely with the registrar office and their third party administrator to ensure that R2T4’s are completed timely when students cease attendance during the term. We also recommend additional staff be allocated to the withdrawal process due to the high population of students (approx. 10%) who withdraw officially or unofficially.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Inaccurate and Untimely Returns of Title IV Funds (R2T4) Significant Deficiency
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063 and 84.007
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: When students withdrew either officially or unofficially, the University did not always return unearned Title IV aid timely and return calculations were not done correctly consistently.
Criteria: 34 CFR 668.22
Questioned Costs: $2,670
Context: Out of 25 students tested, 4 students had $9,067 in late returns of Federal Direct Loans (FDL) ranging from 34 to 300 days late. This was due to a lack of communication between the registrar and financial aid offices that should be triggered by a student’s withdrawal. Two students, who were official withdrawals, had late dates of determination, which caused late returns. One of those students had an incorrect amount initially returned that was then corrected during the audit ($845 FDL). One student did not have a return made due to the initial days completed calculation being incorrect as it did not include one of the student’s modules the student was initially enrolled in resulting in $1,802 FDL to be return. One student had an incorrect calculation which resulted in $23 additional FDL to return. These were corrected during the audit.
Cause: There was a lack of appropriate resources to perform an adequate review of modular withdrawals and a lack of communication between the registrar and financial aid offices.
Effect: Title IV funds were not returned timely.
Identification as repeat finding, if applicable: 2022-001
Recommendation: We recommend that the financial aid office work closely with the registrar office and their third party administrator to ensure that R2T4’s are completed timely when students cease attendance during the term. We also recommend additional staff be allocated to the withdrawal process due to the high population of students (approx. 10%) who withdraw officially or unofficially.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.