Corrective Action Plans

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Finding 512852 (2024-001)
Significant Deficiency 2024
Department of Housing and Urban Development Supportive Housing for Persons with Disabilities – Assistance Listing No. 14.181 Recommendation: Submit the $315.75 immediately to the Replacement Reserve Account and train employees involved in the requirements of HUD in regards to timely and accurate ...
Department of Housing and Urban Development Supportive Housing for Persons with Disabilities – Assistance Listing No. 14.181 Recommendation: Submit the $315.75 immediately to the Replacement Reserve Account and train employees involved in the requirements of HUD in regards to timely and accurate Replacement Reserve contributions. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The amount of $315.75 was submitted to the Replacement Reserve via a transfer on September 26, 2024. Training to review the Replacement Reserve funding requirements will be completed. Name(s) of the contact person(s) responsible for corrective action: Thomas Evans, Chief Financial Officer. Planned completion date for corrective action plan: October 31, 2024 If the Department of Housing and Urban Development has questions regarding this plan, please call Thomas Evans at 301-663-8811 X1120.
Supportive Housing for Persons with Disabilities – Assistance Listing No. 14.181 Unauthorized Withdrawal from Replacement Reserve Account Recommendation: Conduct training with all those who are involved with the Project to review HUD requirements for making withdrawals from the Replacement Reserve a...
Supportive Housing for Persons with Disabilities – Assistance Listing No. 14.181 Unauthorized Withdrawal from Replacement Reserve Account Recommendation: Conduct training with all those who are involved with the Project to review HUD requirements for making withdrawals from the Replacement Reserve and create a documentation process for requests and approvals. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: o conduct training to review all HUD requirements regarding the process for withdrawing funds from the Replacement Reserve Account. Name(s) of the contact person(s) responsible for corrective action: Stacy Lawson, Chief Financial Officer, Jacob Schimming, Project Accountant. Planned completion date for corrective action plan: October 31, 2024
Condition: The College did not accurately report the effective date of a students' status changes to the NSLDS or the correct status change to the NSLDS. Planned Corrective Action: Before pulling the enrolled student list for submission to the National Student Clearinghouse (NSC), the Director of F...
Condition: The College did not accurately report the effective date of a students' status changes to the NSLDS or the correct status change to the NSLDS. Planned Corrective Action: Before pulling the enrolled student list for submission to the National Student Clearinghouse (NSC), the Director of Financial Aid will run a debugging process created by the Financial Aid and Information Technology teams to identify any inaccuracies in student enrollment status to be easily identified and corrected. Implementing this debugging process in advance of finalizing the NSC Student Enrollment Report file will ensure all data submitted to NSC is accurate. Contact person responsible for corrective action: Mathew Catanese, Director of Financial Aid Anticipated Completion Date: June 30, 2025
Contact person(s) responsible: Tiffany Tucker, Fiscal Director Corrective Action Planned: All Janus’ Rental Assistance Programming will be consolidated under two experienced Program Directors for whom Rental Assistance administration is a primary program component. Policies and procedures for obta...
Contact person(s) responsible: Tiffany Tucker, Fiscal Director Corrective Action Planned: All Janus’ Rental Assistance Programming will be consolidated under two experienced Program Directors for whom Rental Assistance administration is a primary program component. Policies and procedures for obtaining required documentation have been updated and include a mandatory documentation checklist submitted together with all initial payment requests, and a new policy has been created for the rare circumstances when youth are housed outside our primary service area of Multnomah, Clark or Cowlitz counties requiring Program Director sign off prior to payment. Anticipated Completion Date: November 15, 2024
Federal Agency Name: U.S. Department of Education Program Name: Student Financial Assistance Cluster Federal Financial Assistance Listing #84.007, 84.033, 84.063, 84.268 Compliance Requirement: Reporting – COD Reporting Significant Deficiency in Internal Control Finding Summary: During our tes...
Federal Agency Name: U.S. Department of Education Program Name: Student Financial Assistance Cluster Federal Financial Assistance Listing #84.007, 84.033, 84.063, 84.268 Compliance Requirement: Reporting – COD Reporting Significant Deficiency in Internal Control Finding Summary: During our testing of compliance for COD Reporting, it was noted that there was no documented control over the Student Account Statement (SAS) reconciliation that is performed after loans have been submitted to COD and disbursed. Responsible Individuals: Randy Mashek, Director of Financial Aid Corrective Action Plan: The Financial Aid office will retain documentation of the control over the SAS reconciliation process. Anticipated Completion Date: November 1, 2024.
Finding 2024-001 Federal Agency Name: U.S. Department of Education Program Name: Student Financial Assistance Cluster Federal Financial Assistance Listing #84.007, 84.033, 84.063, 84.268 Compliance Requirement: Special Tests and Provisions – Enrollment Reporting Significant Deficiency in Inter...
Finding 2024-001 Federal Agency Name: U.S. Department of Education Program Name: Student Financial Assistance Cluster Federal Financial Assistance Listing #84.007, 84.033, 84.063, 84.268 Compliance Requirement: Special Tests and Provisions – Enrollment Reporting Significant Deficiency in Internal Control Finding Summary: During testing of compliance for Enrollment Reporting, there was 1 instance out of 60 where the College did not report a student’s change in enrollment status accurately or within the required time frame of 60 days from the effective date of the student’s change in enrollment status. In addition, evidence of the review of this submission was not retained. Responsible Individuals: Karla Winter, Registrar Corrective Action Plan: The Registrar’s office will review clearing house batch errors reports and any students that go from enrolled in a course to auditing a course. In addition, the Registrar’s office will conduct and retain evidence of quality sampling once a semester. Anticipated Completion Date: November 1, 2024.
2024-002: Missing Exit Counseling Documentation - Student Financial Aid Cluster Assistance Listing Number 84.007, 84.033, 84.063, 84.268, Grant Period - Year Ended June 30, 2024 Condition Found During our student file testing, we noted four students out of 40 did not have documentation in their file...
2024-002: Missing Exit Counseling Documentation - Student Financial Aid Cluster Assistance Listing Number 84.007, 84.033, 84.063, 84.268, Grant Period - Year Ended June 30, 2024 Condition Found During our student file testing, we noted four students out of 40 did not have documentation in their file that exit counseling was sent thirty days after the student withdrew. We consider the missing exit counseling to be a Significant Deficiency with the Eligibility Compliance Requirement. This is a repeat finding, see Prior Year Audit Findings 2023-002. Corrective Action Plan LLCC has developed a new reporting method to capture students needing exit counseling. Responsible Person for Corrective Action Plan Alison Mills-Director of Financial Aid Implementation Date of Corrective Action Plan FY25
Finding 512634 (2024-001)
Significant Deficiency 2024
2024-001: Written Internal Control Policies and Federal Grant Award Procedures Finding Condition - The Town did not have written internal controls and Federal grant award policies in place. Corrective Action Plan - An internal control policy and Federal grant award procedures were written and signe...
2024-001: Written Internal Control Policies and Federal Grant Award Procedures Finding Condition - The Town did not have written internal controls and Federal grant award policies in place. Corrective Action Plan - An internal control policy and Federal grant award procedures were written and signed as approved on September 2, 2024.
2024-003 Student Financial Assistance Cluster– Assistance Listing No. 84.063, 84.007, 84.033, 84.268 Recommendation: We recommend that the College review policies and procedures related to R2T4 calculations to ensure calculations are performed correctly and timely. Explanation of disagreement with a...
2024-003 Student Financial Assistance Cluster– Assistance Listing No. 84.063, 84.007, 84.033, 84.268 Recommendation: We recommend that the College review policies and procedures related to R2T4 calculations to ensure calculations are performed correctly and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Registrar will use original contact date from students regarding withdrawal instead of the final approval date. Name(s) of the contact person(s) responsible for corrective action: Ashley Mayfield, Director of Admission & Enrollment; David Fisher, Financial Aid Director Planned completion date for corrective action plan: 09/30/24
2024-002 Student Financial Assistance Cluster– Assistance Listing No. 84.063, 84.007, 84.033, 84.268 Recommendation We recommend that the College implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are repor...
2024-002 Student Financial Assistance Cluster– Assistance Listing No. 84.063, 84.007, 84.033, 84.268 Recommendation We recommend that the College implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely. And we recommend that the College implement formal review procedures to document the review process. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Registrar will prepare the files for the clearing house based on the scheduled receipt of the enrollment roster from NSLDS. Before sending the report to the clearing house the report will be reviewed for accuracy of withdrawal or change in status dates. Name(s) of the contact person(s) responsible for corrective action: Ashley Mayfield, Director of Admission & Enrollment; David Fisher, Financial Aid Director Planned completion date for corrective action plan: 01/01/2025
Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) Planned Corrective Action: With new automation we have more timely notifications when students have been dropped. The Pillar Financial Aid department has updated policies and procedures to monitor the withdrawal process to ...
Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) Planned Corrective Action: With new automation we have more timely notifications when students have been dropped. The Pillar Financial Aid department has updated policies and procedures to monitor the withdrawal process to inform the Registrar’s office, which will ensure the necessary changes to the NSLDS record are made in a timely manner. Person Responsible for Corrective Action Plan: Christine Schroeder, Assistant VP of Enrollment Services Anticipated Date of Completion: Current action
Segregation of Duties (significant deficiency) Year ended June 30, 2024 Auditors’ Recommendation: The Authority should continue to obtain involvement from its Board of Directors in reviewing monthly financial reports and approving expenditures. Grantee Response: The Authority and Executive Director,...
Segregation of Duties (significant deficiency) Year ended June 30, 2024 Auditors’ Recommendation: The Authority should continue to obtain involvement from its Board of Directors in reviewing monthly financial reports and approving expenditures. Grantee Response: The Authority and Executive Director, Wendy Hollabaugh, has tried to maintain as much segregation of duties as physically possible and in instances of not being able to achieve such segregation, has implemented detective procedures as recommended by our external auditors. The Authority believes these procedures will reduce to a relatively low level the risk that errors or irregularities in amounts that would be material in relation to the financial statements may occur and not be detected within a timely period by employees in the normal course of performing their assigned functions. The Authority and Executive Director will continue to review how accounting functions are assigned and consider implementing further detective internal control procedures to help mitigate the risk during the year ending June 30, 2025.
Finding 2024-006 - Corrective Action Plan CHSD - 2023-2024 Audit Findings Finding 2024-006 Special Tests Type: Significant Deficiency in internal control over compliance / Noncompliance Prevailing Wage. Program: COVID 19 - Education Stabilization Fund (ALN 84.425U ESSER III Formula) Condition: As a ...
Finding 2024-006 - Corrective Action Plan CHSD - 2023-2024 Audit Findings Finding 2024-006 Special Tests Type: Significant Deficiency in internal control over compliance / Noncompliance Prevailing Wage. Program: COVID 19 - Education Stabilization Fund (ALN 84.425U ESSER III Formula) Condition: As a result of Management oversight, the District was unable to provide evidence that prevailing wages were paid for the two construction projects charged to the grant. Corrective action to be taken: Grant agreements will be reviewed, approved, and maintained by all applicable shareholders to ensure awarded contracts paid with state or federal funds from the grant has the requisite legal compliance metrics guaranteeing that prevailing wage requirements are included in the contract language and obtain documentation that prevailing wages are paid. Corrective action timeline: The corrective action is effective immediately. District leader responsible for Corrective Action Plan: The Finance Director will be responsible for ensuring compliance with this corrective action. Respectfully submitted, Marc Forrest, Director of Finance
Finding No.: 2024-001 - Significant Deficiency Personnel Responsible for Corrective Action: Teri Gregory, CFO of Good Shepherd Children and Family Services Anticipated Completion Date: March 31, 2025 Corrective Action Plan: Good Shepherd Children and Family Services (GS) will implement a control pro...
Finding No.: 2024-001 - Significant Deficiency Personnel Responsible for Corrective Action: Teri Gregory, CFO of Good Shepherd Children and Family Services Anticipated Completion Date: March 31, 2025 Corrective Action Plan: Good Shepherd Children and Family Services (GS) will implement a control procedure to ensure proper review of monthly financial reimbursement reports for accuracy. An Archdiocese Finance Office accountant will prepare the monthly reports. Reports and supporting documents will be sent to GS's Chief Program Officer and Pregnancy & Parenting Services Program Director. GS management will review and approve the reports before submitting them via email, along with approvals for reimbursement.
2024-003 – Eligibility. Auditor Description of Condition and Effect. In our sample of 40 applications from all students receiving free or reduced cost meals during the year, we noted one instance in which the point of sale (POS) system used by the District classified a student to be free, however,...
2024-003 – Eligibility. Auditor Description of Condition and Effect. In our sample of 40 applications from all students receiving free or reduced cost meals during the year, we noted one instance in which the point of sale (POS) system used by the District classified a student to be free, however, application reviewed by the District indicated ineligible to receive free and reduce meal. The student received free-price meals during the 2024 school year. As a result of this condition, the District granted free lunch to a student that did not meet the eligibility requirements. Auditor Recommendation. The district should perform a review of the POS system to match with the application to ensure only eligible students are provided with free and reduced meal. Responsible Person: Scott Leach, Superintendent and Crystal Lee, Food Service Director.Corrective Action. Management concurs with the finding. The district has already put in multiple checks and procedures for food service. The Point of Sale now has custom reports to help make sure students are in the Point-of-Sale system correctly. The Eligibility listing will be verified multiple times throughout the year. The district has set up weekly meetings with the Food Service Director, Superintendent Administrative Assistant, and the Business Manager. Anticipated Completion Date: June 30, 2025.
Special Programs for the Aging – Title III Part C Nutrition Services – Assistance Listing No. 93.045 Recommendation: We recommend careful review of the Uniform Guidance requirements for subaward contracts in comparison to subaward agreement templates to identify requirements and updates needed. Exp...
Special Programs for the Aging – Title III Part C Nutrition Services – Assistance Listing No. 93.045 Recommendation: We recommend careful review of the Uniform Guidance requirements for subaward contracts in comparison to subaward agreement templates to identify requirements and updates needed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The organization has worked closely with Trellis, the Area Agency on Aging, to review the Uniform Guidance requirements for subaward contracts. Together, they will update the Senior Nutrition Program Purchase of Service Contracts for 2025 to ensure compliance. The updated contracts will now include the required Federal Award Identification Number (FAIN) and the Catalog of Federal Domestic Assistance (CFDA) number for Assisted Living programs. These actions will address the recommendations and ensure alignment with the Uniform Guidance requirements.. Name of the contact person responsible for corrective action: Linda Kirkendall, Associate Director of the organization’s Senior Nutrition Program Planned completion date for corrective action plan: January 1, 2025
Finding 512135 (2024-006)
Significant Deficiency 2024
Student Financial Assistance Cluster- Assistance Listing No. 84.268 Finding: The College did not have documentation that Direct Loan Reconciliation was performed. Context: During our testing we identified the March 2024 Direct Loan Reconciliation was not timely performed and documented. Cause: Due t...
Student Financial Assistance Cluster- Assistance Listing No. 84.268 Finding: The College did not have documentation that Direct Loan Reconciliation was performed. Context: During our testing we identified the March 2024 Direct Loan Reconciliation was not timely performed and documented. Cause: Due to staff turnover, direct loan reconciliation for March 2024 was not performed timely. Recommendation: We recommend the College implement a formal review procedure to document that the direct loan reconciliations are performed on a timely basis each month. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: A formal review process was already in place. The issue came from the turnover in the FA department leading to a loss of access. This will be remediated moving forward with more than one FA staff having reporting access and knowledge of reconciliations. Name(s) of the contact person(s) responsible for corrective action: Tina Ballinger Planned completion date for corrective action plan: 11/01/2024
Finding 512130 (2024-005)
Significant Deficiency 2024
Student Financial Assistance Cluster- Assistance Listing No. 84.063, Finding: The College under-awarded funds for the Pell Grant. Context: During our testing, we identified 2 out of 40 students were awarded and disbursed less Pell funds than should have been awarded based on the 23-24 Pell payment s...
Student Financial Assistance Cluster- Assistance Listing No. 84.063, Finding: The College under-awarded funds for the Pell Grant. Context: During our testing, we identified 2 out of 40 students were awarded and disbursed less Pell funds than should have been awarded based on the 23-24 Pell payment schedule. The Pell payment schedule considers the cost of attendance, the student's Expected Family Contribution and the enrollment status of the student. Cause: Student was initially not disbursed Pell funds due to electronic terms & conditions not being completed. However, when the student completed this requirement in the Spring, Pell was not disbursed for the Fall semester Recommendation: We recommend the College review its current procedures for awarding Title IV funds and implement any changes necessary to ensure federal funds are awarded and disbursed in accordance with federal regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: This is due to a loss of knowledge due to turnover within the FA department. Moving forward, knowledge procedures and knowledge will be disseminated to all FA staff to ensure there are no gaps causing a reoccurring issue. Name(s) of the contact person(s) responsible for corrective action: Tina Ballinger Planned completion date for corrective action plan: 11/01/2024
View Audit 329878 Questioned Costs: $1
Finding 512121 (2024-004)
Significant Deficiency 2024
Student Financial Assistance Cluster- Assistance Listing No. 84.007, 84.038, 84.063, 84.268 Finding: The College did not properly have documentation of exit counseling notification. Context: During our testing of 40 students, we identified 5 students that did not have documentation of exit counselin...
Student Financial Assistance Cluster- Assistance Listing No. 84.007, 84.038, 84.063, 84.268 Finding: The College did not properly have documentation of exit counseling notification. Context: During our testing of 40 students, we identified 5 students that did not have documentation of exit counseling notification. Cause: The College did not have proper procedures in place to ensure that notification of required exit counseling was sent to applicable students. Recommendation: We recommend the College review reporting processes to ensure all students that require exit counseling receive it in a timely manner Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: This is due to a loss of knowledge due to turnover within the FA department. Moving forward, knowledge about loan exit counseling will be disseminated to all FA staff to ensure there are no gaps causing a reoccurring issue. Name(s) of the contact person(s) responsible for corrective action: Tina Ballinger Planned completion date for corrective action plan: 12/15/2024
Finding 512120 (2024-003)
Significant Deficiency 2024
Student Financial Assistance Cluster- Assistance Listing No. 84.007, 84.038, 84.063, 84.268 Finding: The College did not properly notify students when loans were credited to student's ledger account. Context: During our testing of 40 students, we identified that there were 5 students that did not re...
Student Financial Assistance Cluster- Assistance Listing No. 84.007, 84.038, 84.063, 84.268 Finding: The College did not properly notify students when loans were credited to student's ledger account. Context: During our testing of 40 students, we identified that there were 5 students that did not receive the required notification of Direct Loan disbursements Cause: Due to staff turnover, loan notifications were missed being sent out to students. Recommendation: We recommend the College evaluate its procedures around disbursements of loans and ensure that notifications of disbursements are sent and contain all the required elements outlined in the FSA handbook. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: This is due to a loss of knowledge due to turnover within the FA department. Moving forward, knowledge about loan notifications will be disseminated to all FA staff to ensure there are no gaps causing a reoccurring issue. Name(s) of the contact person(s) responsible for corrective action: Tina Ballinger Planned completion date for corrective action plan: 12/15/2024
Finding 512119 (2024-002)
Significant Deficiency 2024
Student Financial Assistance Cluster-Assistance Listing No. 84.007, 84.038, 84.063, 84.268 ...
Student Financial Assistance Cluster-Assistance Listing No. 84.007, 84.038, 84.063, 84.268 Finding: The College did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Context: During our testing of 40 students, we identified 3 students that did not have their Program enrollment reported to NSLDS and 3 students that had Program enrollment effective dates that did not match institutional records. Cause: The College didn't have proper procedures in place to verify students' status in NSLDS matched the institution's records accurately. Recommendation: We recommend the College review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: CSC will put in place procedures that will ensure that submissions are reported accurately. Name(s) of the contact person(s) responsible for corrective action: Tina Ballinger Planned completion date for corrective action plan: 01/01/2025
Finding 512118 (2024-001)
Significant Deficiency 2024
Student Financial Assistance Cluster- Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Finding: The College used the incorrect withdrawal date when calculating Return to Title IV (R2T4) calculations and did not have formal procedures in place to document review of calculations. Context: During ...
Student Financial Assistance Cluster- Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Finding: The College used the incorrect withdrawal date when calculating Return to Title IV (R2T4) calculations and did not have formal procedures in place to document review of calculations. Context: During our testing, we identified 2 out of 15 R2T4 calculations used an incorrect withdrawal date in their calculation. Also, during our testing, we identified 13 instances of no documentation of a formal review of R2T4 calculations. Cause: The College was using the date a withdrawal form was processed, rather than the date the withdrawal process began. Recommendation: We recommend that the College review policies and procedures related to R2T4 calculations to ensure calculations are performed accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Staff will review policies and procedures and make adjustments as needed to ensure that the calculations are accurate. Name(s) of the contact person(s) responsible for corrective action: Tina Ballinger Planned completion date for corrective action plan: 11/01/2024
View Audit 329878 Questioned Costs: $1
Federal Agency Name: Department of Health and Human Services Assistance Listing Number: 93.566 Program Name: Refugee and Entrant Assistance - State Administered Programs Reporting Finding Summary: The FFATA report filed for Huron School District included the incorrect Subaward Obligation/Action Da...
Federal Agency Name: Department of Health and Human Services Assistance Listing Number: 93.566 Program Name: Refugee and Entrant Assistance - State Administered Programs Reporting Finding Summary: The FFATA report filed for Huron School District included the incorrect Subaward Obligation/Action Date within the FFATA Subaward Reporting System. Corrective Action Plan: FFATA reporting requirements were reviewed after the 2023 single audit report was received to ensure management has the correct understanding of reporting terms. The report in question was prepared and filed during July 2023 which was prior to the 2023 single audit report being finalized. FFATA reports filed during April 2024 and May 2024 were properly filed. Responsible Individuals: Nathan Beyer, Emily Lyons Anticipated Completion Date: December 31, 2023
Family Medical Center will have management or assigned staff to review all current sliding fee patients and ensure that the Center has an updated sliding fee application for each. FMC will provide additional training to front desk staff at each site and require them to obtain the proper application ...
Family Medical Center will have management or assigned staff to review all current sliding fee patients and ensure that the Center has an updated sliding fee application for each. FMC will provide additional training to front desk staff at each site and require them to obtain the proper application and documentation. Patient Accounts will review the current application to ensure that the current patients are charged the proper sliding fee scale. Management will develop a training module with Human Resources to have each staff complete in addition to hiring additional staff. This corrective action is expected to be completed by March 31, 2025.
Finding 512059 (2024-003)
Significant Deficiency 2024
2024-003: U.S. Department of Education. Assistance Listing Number: 84.007 (Federal Supplemental Educational Opportunity Grants Program), 84.033 (Federal Work Study Program), 84.063 (Federal Pell Grant Program), 84.268 (Federal Direct Student Loans Program). Criteria or specific requirement: The G...
2024-003: U.S. Department of Education. Assistance Listing Number: 84.007 (Federal Supplemental Educational Opportunity Grants Program), 84.033 (Federal Work Study Program), 84.063 (Federal Pell Grant Program), 84.268 (Federal Direct Student Loans Program). Criteria or specific requirement: The Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as “financial institutions” and subject to the Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi)). The Code of Federal Regulations 2 CFR 200.303 requires the University to establish and maintain effective internal controls over Federal awards. Context: Under an institution’s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, 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 programs. Cause: The University has continued to make progress in updating the University’s written security program to become in compliance with all requirements; however, due to capacity and demands on the information technology individuals, this is still a work in process. Recommendation: We recommend the University work to update the written security program to ensure compliance with all the standards. Views of responsible officials: There is no disagreement with the audit finding.
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