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Finding 2023-001 To whom it may concern, UNIVERSITY of INDIANAPOLIS,,, UNIVERSITY OF INDIANAPOLIS'S RESPONSE TO AUDIT FINDING February 15, 2024 Management acknowledges the error in the Federal Work Study calculation. A refund was processed to the GS site on February 15th , 2024, in the amount of $90...
Finding 2023-001 To whom it may concern, UNIVERSITY of INDIANAPOLIS,,, UNIVERSITY OF INDIANAPOLIS'S RESPONSE TO AUDIT FINDING February 15, 2024 Management acknowledges the error in the Federal Work Study calculation. A refund was processed to the GS site on February 15th , 2024, in the amount of $90,184. Management further notes that it has removed the waiver from its calculation files. This corrective action will be monitored by the University's Controller and will be fully implemented during the 2023-2024 fiscal year. Jodi Purtee, AVP & Controller
View Audit 295435 Questioned Costs: $1
Corrective Action Plan for Current Year Findings June 30, 2023 Finding 2023-001: Reporting – Special Reporting Student Financial Assistance Cluster U.S Department of Education Award Period: July 1, 2022 – June 30, 2023 Responsible Person: Wilbert Casaine, Executive Director of Student Financial Aid,...
Corrective Action Plan for Current Year Findings June 30, 2023 Finding 2023-001: Reporting – Special Reporting Student Financial Assistance Cluster U.S Department of Education Award Period: July 1, 2022 – June 30, 2023 Responsible Person: Wilbert Casaine, Executive Director of Student Financial Aid, 609-771-2211 Corrective Action Plan: For the fiscal year ending June 30, 2023, the supporting documentation for the FISAP did not tie to the report that was submitted through COD. The two sections reported zero (0) students were erroneously skipped, thus no data was entered, even though the support document had students listed there, for the following lines in Part II, Section F: Line 29 Column C per the FISAP noted 0 students, and 8 students in the underlying support. Line 29 Column E, per the FISAP noted 0, and 16 students in the underlying support. One section where 12 students were reported but the support document had 11 was due to the excel support spreadsheet formula error that counted an additional column causing data entry error for the following line: Line 34, Column E, per the FISAP, noted 12 students, and 11 in the underlying support. After the original FISAP submission, the data errors were discovered. The FISAP was reopened and the data was corrected. In completing the annual FISAP, the College will conduct a more thorough multi-level review of entries and support documents before submitting the report to the DOE. The College implemented the corrective action on October 18, 2023 retroactive to July 1, 2023 and was able to resubmit the FISAP. The College implemented the corrective action on October 18, 2023 retroactive to July 1, 2023. Anticipated Completion Date: Completed
Finding 380499 (2023-001)
Significant Deficiency 2023
The Office of the Registrar has identified the errors in the National Student Clearinghouse reporting. They have worked internally with our IT department to pinpoint the errors resulting in delays in submission to the National Student Loan Database Systems (NSLDS) via the National Clearinghouse. The...
The Office of the Registrar has identified the errors in the National Student Clearinghouse reporting. They have worked internally with our IT department to pinpoint the errors resulting in delays in submission to the National Student Loan Database Systems (NSLDS) via the National Clearinghouse. The Office of the Registrar is presently completing data review and clean-up. Once this is completed The Office of the Registrar will submit overdue files to the National Clearinghouse in conjunction with the Senior Director of Information Technology to ensure all technical requirements are met. These updates and alignments should bring late reporting to zero. The goal is to have no findings in 2025. Name of Contact Person Responsible for Corrective Action: Debbie Blake, Registrar and Emily Perl, Associate Vice President for Student Success. Anticipated Completion Date: 06/01/2024
II. FEDERAL FINDINGS AND QUESTIONED COSTS 2023-001 Special Tests and Provisions Management's Response: We concur. View of Responsible Officials and Corrective Action Plan The District reviewed past practices and implemented revised procedures to ensure accurate student enrollment information is...
II. FEDERAL FINDINGS AND QUESTIONED COSTS 2023-001 Special Tests and Provisions Management's Response: We concur. View of Responsible Officials and Corrective Action Plan The District reviewed past practices and implemented revised procedures to ensure accurate student enrollment information is reported to the National Student Loan Data System. Additionally, the District consulted with the National Student Clearinghouse and prior semesters’ enrollment information was revised and resubmitted. Name of responsible individual: John Cooney Implementation Date: October 26, 2023
Finding Number: 2023-003 Condition: The notifications related to the direct loan borrowers did not include information on the right to cancel or instructions on how to cancel the loans. Planned Corrective Action: Missing notifications to students was a result of a coding error in the automated proce...
Finding Number: 2023-003 Condition: The notifications related to the direct loan borrowers did not include information on the right to cancel or instructions on how to cancel the loans. Planned Corrective Action: Missing notifications to students was a result of a coding error in the automated process that was resolved on September 5, 2023. Notifications to parents didn’t begin until the Summer 2023, with an automated procedure being implemented in the Fall 2023 semester. Contact person responsible for corrective action: Kent McGowan, Assistant Director, Office of Financial Aid Anticipated Completion Date: 01/01/2024
Finding Number: 2023-002 Condition: The University used inaccurate or incomplete data in the return of Title IV calculations. Planned Corrective Action: The failure to return funds in a timely fashion is primarily a result of university withdrawal policy not aligning with the timelines required by t...
Finding Number: 2023-002 Condition: The University used inaccurate or incomplete data in the return of Title IV calculations. Planned Corrective Action: The failure to return funds in a timely fashion is primarily a result of university withdrawal policy not aligning with the timelines required by the regulations. To that end, the university is revising its policies and procedures, specifically as they relate to “medical withdrawals” and for programs where attendance is required. As of June 2023, the University now has reports that identify all the affected students in a timely fashion. Additional resources have been allocated to assure that there is consistency and timeliness in the review of enrollment data specifically as it relates to determining attendance in dropped courses, and students who rescind their intent to withdraw, or enroll in or attend subsequent modules. Contact person responsible for corrective action: Steve Shablin - University Registrar, Matthew Lyth - Financial Aid Officer Anticipated Completion Date: 05/10/2024
View Audit 295211 Questioned Costs: $1
Finding Number: 2023-001 Condition: The University did not report the status changes of certain students to the NSLDS in an accurate and timely manner during the fiscal year. Planned Corrective Action: The University is submitting the data to NSLDS via the Clearinghouse in the required timeline. Cer...
Finding Number: 2023-001 Condition: The University did not report the status changes of certain students to the NSLDS in an accurate and timely manner during the fiscal year. Planned Corrective Action: The University is submitting the data to NSLDS via the Clearinghouse in the required timeline. Certain status changes took place after the standard reporting cycle and were not picked up in this process. New processes have been established to identify and report these status changes to NSLDS that take place after the standard reporting cycle. Contact person responsible for corrective action: Becky Keogh, Senior Associate Registrar Anticipated Completion Date: 05/10/2024
Corrective Action Plan For the Year Ended May 31, 2023 Finding 2023-001 Assistance Listing Number(s), Federal Agency and Program Name: 84.063, 84.007, 84.033, and 84.268; United States Department of Education (DOE), Student financial assistance cluster. Finding Type: Noncompliance and material weakn...
Corrective Action Plan For the Year Ended May 31, 2023 Finding 2023-001 Assistance Listing Number(s), Federal Agency and Program Name: 84.063, 84.007, 84.033, and 84.268; United States Department of Education (DOE), Student financial assistance cluster. Finding Type: Noncompliance and material weakness in internal control over compliance relating to special tests. Criteria: The Institute is responsible for designing, implementing, and maintaining internal control over compliance for special tests and provisions and for accurately and timely reporting significant data elements under the Campus- Level and Program-Level records within the National Student Loan Data System (NSLDS) that DOE considers high risk. Statement of Condition: Management implemented controls that specifically addressed the circumstances surrounding prior year finding 2022-001. Management's review of the enrollment reporting did not detect other errors on certain student data elements or timely reporting. Certain student records within the NSLDS were identified with inaccurate data elements and not timely reported. Questioned Costs: Questioned costs could not be determined. Context: 10 students were identified with inaccurate data elements and not timely reported out of a total of 25 students tested. Cause: The Institute’s internal control over compliance did not detect and correct the errors. The preparer incorrectly input the student's effective date and status into NSLDS resulting in inaccuracies in significant Campus- Level and Program-Level enrollment data elements that DOE considers high risk. Effect: The Institute incorrectly reported certain Campus-Level and Program-Level records in NSLDS which is information that DOE considers high risk and the Institute’s internal controls over compliance did not detect and correct the errors. Recommendation: We recommend management review policies and procedures surrounding enrollment reporting submissions to ensure the accuracy of data elements reported to DOE. A review performed by an appropriate individual separate from the preparer prior to the submission of the enrollment reports to NSLDS may improve the accuracy of enrollment reporting. Status: Completed February 2024 Corrective Action: Management agrees with the finding. Through internal investigation, it was determined that there was a procedural issue with the manual entry of two date fields which both need to be the same when submitted to National Student Clearinghouse (NSC). Human error during these manual checks caused one data field to be correct, and the other incorrect. This error has been fixed so that both fields will always be the same and accurate. We have also updated our enrollment reporting procedures to have the registrar log into NSLDS monthly to confirm that the prior month NSC status changes are properly recorded in NSLDS. Contact Jean Weimer Registrar 414-847-3272 jeanweimer@miad.edu Submitted Feb 23, 2024
Finding: Management's review of the enrollment reporting did not detect errors on certain student data elements. Certain student records within the NSLDS were identified with inaccurate data elements. The College is responsible for designing, implementing, and maintaining internal control over compl...
Finding: Management's review of the enrollment reporting did not detect errors on certain student data elements. Certain student records within the NSLDS were identified with inaccurate data elements. The College is responsible for designing, implementing, and maintaining internal control over compliance for special tests and provisions and for accurately reporting significant data elements under the Campus-Level and Program-Level records within the National Student Loan Data System (NSLDS) that the Department of Education (ED) considers high risk. The College's internal control over compliance for special tests are not operating effectively. The preparer did not update the student's status into NSLDS resulting in inaccuracies in significant Campus-Level and Program-Level enrollment date elements that ED considers high risk. Additionally, student with status changes were incorrectly reported as withdrawn but upon review of internal documentation, those same students graduated. We recommend management review and enhance its review policies and procedures surrounding enrollment reporting submissions to ensure the accuracy of data elements reported to ED. A review performed by an appropriate individual separate from the prepared prior to the submission of the enrollment reports to NSLDS may improve the accuracy of enrollment reporting. We also recommend management review all students reported to NSLDS to verify they are accurately reported. Corrective Action: Management agrees and has implemented necessary procedures/controls to ensure the College is in compliance with enrollment requirements.
Finding number: 2023-002 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Clusters AL #’s: 84.268 Award year: 2023 Corrective Action Plan: The College will be looking at making some business process changes to review files submitted to ...
Finding number: 2023-002 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Clusters AL #’s: 84.268 Award year: 2023 Corrective Action Plan: The College will be looking at making some business process changes to review files submitted to NSC(National Student Clearing House) and NSLDS (National Student Loan Data Service) on a monthly basis and perform monthly reconciliation between responsible offices to ensure students are accurately reported to ED/NSLDS. This new implementation will allow the College/Office to better verify each student’s enrollment status visibility of reporting issues in the future. Timeline for Implementation of Corrective Action Plan: This new procedure was implemented starting with the Fall 2023 semester and beyond. Contact Person Alex Jean-Jacques Director of Financial Aid of Operations
Condition: The College did not have a control in place to ensure all returns of Title IV refunds were reviewed. As a result, certain student Title IV refund calculations were not correctly calculated and returned.. Planned Corrective Action: • GRCC updated its R2T4 procedure document to highlight t...
Condition: The College did not have a control in place to ensure all returns of Title IV refunds were reviewed. As a result, certain student Title IV refund calculations were not correctly calculated and returned.. Planned Corrective Action: • GRCC updated its R2T4 procedure document to highlight the steps needed to be taken so that bookstore charges are handled correctly in the R2T4 calculation. • GRCC provided updated training to the current employees who handle the R2T4 process. • GRCC reviewed all of the R2T4s in which students had bookstore charges. The results were as follows: oTotal number of students: -Fall -- 103 students reviewed; 61 corrections made -Winter -- 83 students reviewed; 5 corrections made o Total amount of adjustments: -Fall = $13,372 -Winter = $1,362 • GRCC reviewed all unofficial withdrawals during fiscal year 2023 adn matched them with R2T4's where required. Once correction was made for $558. This is the same error noted in teh finding. • During the 2023-2024 year (fiscal year 2024), GRCC is performing a 100% review of the R2T4s that have bookstore charges. While performing the review of the bookstore charges, we are reviewing the entire R2T4, not only whether bookstore charges are correctly included. By doing so, we can ensure that the entire process is performed accurately. • Additionally, GRCC will be conducting R2T4 training each semester by way of ensuring that staff who perform the calculations understand the process and the specific steps needed to complete the calculations. Contact person responsible for corrective action: David DeBoer, Executive Director of Financial Aid Anticipated Completion Date: 12/02/2023
View Audit 295065 Questioned Costs: $1
Finding 2023-001- Enrollment Reporting Recommendation: It is recommended that the University review policies and procedures in place to resolve reporting issues in a timely manner to facilitate compliance with Title IV regulations. Action Taken: Each error was corrected within the system. Going forw...
Finding 2023-001- Enrollment Reporting Recommendation: It is recommended that the University review policies and procedures in place to resolve reporting issues in a timely manner to facilitate compliance with Title IV regulations. Action Taken: Each error was corrected within the system. Going forward, the reports submitted to NSLDS will be closely reviewed to ensure effective dates for student changes are appropriately reported. In addition, the registrar has updated their process notes which are used each time they pull the report. Responsible Individual for Corrective Action: Registrar - Joanna Raudenbush Anticipated Completion Date: December 31, 2023
2023-001: Student Financial Aid Cluster - Return to Title V Recommendation: We recommend that the Colleges improve the existing procedures and controls to ensure compliance with the aforementioned criteria. We also recommend an additional level of review is added in the process to ensure completed R...
2023-001: Student Financial Aid Cluster - Return to Title V Recommendation: We recommend that the Colleges improve the existing procedures and controls to ensure compliance with the aforementioned criteria. We also recommend an additional level of review is added in the process to ensure completed Return to Title IV calculations are properly completed. Action taken in response to finding: The Financial Aid office is implementing the following steps to ensure all Return to Title IV calculations are properly completed: To improve our process, a Return of Funds Calculation report is in place to assist with monitoring the return of unearned aid the Department of Education within 45 days of determination. An additional staff member has been assigned to the Return of Title IV program. We now have two staff members processing Return to Title IV calculations and each will be required to complete R2T4 training on an annual basis. The first staff member is assigned with the review of Return to Title IV calculations, while the second will conduct a secondary review for any miscalculation or data entry error. Thus, each Return to Title IV calculation will be checked by two staff members for accuracy. We will have an additional staff member help with the return of funds to COD to meet the 45-day rule; this will be on the accounting side. Our final step includes management review of Return to Title IV calculations. These added redundancy review will confirm Return to Title IV calculations are accurate. Our Return to Title IV procedures have been updated to reflect these changes. Name of the contact person responsible for corrective action: Chau Dao, Director of Financial Aid & Basic Needs Planned completion date for corrective action plan: June 2024
FISAP Reporting Planned Corrective Action: Corban will work collaboratively with the Department of Education to investigate FISAP reporting and resolve any inconsistencies appropriately. Additionally, independent of the individual who prepares the FISAP, Corban will appoint a knowledgeable individua...
FISAP Reporting Planned Corrective Action: Corban will work collaboratively with the Department of Education to investigate FISAP reporting and resolve any inconsistencies appropriately. Additionally, independent of the individual who prepares the FISAP, Corban will appoint a knowledgeable individual to review the completed FISAP for quality assurance (QA). These actions will ensure a diversity of accountability and prevent reoccurrence. Person Responsible for Corrective Action Plan: Jordan Lindsey, Associate Vice President for Enrollment Management and Marketing Anticipated Date of Completion: April 30, 2024
Inaccurate Return of Title IV Funds (R2T4) Planned Corrective Action: Corban has appointed an experienced individual in Financial Aid to periodically review modular students’ R2T4 calculations, review returns, and conduct training. These important actions will ensure the preservation of perishable k...
Inaccurate Return of Title IV Funds (R2T4) Planned Corrective Action: Corban has appointed an experienced individual in Financial Aid to periodically review modular students’ R2T4 calculations, review returns, and conduct training. These important actions will ensure the preservation of perishable knowledge, while also promoting the acquisition of knowledge of new developments within the sector. Person Responsible for Corrective Action Plan: Jordan Lindsey, Associate Vice President for Enrollment Management and Marketing Anticipated Date of Completion: April 30, 2024
The Downey Adult School concurs with the finding and to prevent future occurrences, the school purchased a new student database management software system (Campus Café) that was implemented on August 1, 2023. The school also partnered with National Student Clearinghouse (NSCH). NSCH articulates with...
The Downey Adult School concurs with the finding and to prevent future occurrences, the school purchased a new student database management software system (Campus Café) that was implemented on August 1, 2023. The school also partnered with National Student Clearinghouse (NSCH). NSCH articulates with the new student database management software system (Campus Café). The new student database management software system together with National Student Clearinghouse will help to prevent human errors and omissions from occurring when reporting National Student Loan Data System (NSLDS) data. While the district purchased the new system in November of 2022, the school did not begin using the new system(s) until August of 2023 because the switch had to be implemented at the beginning of the fiscal year. Implementation is a several month process and all DAS employees have been receiving extensive training (ongoing) to be proficient and comfortable with the new system(s). We have ongoing weekly training for all DAS staff as we continue to fully implement the new student database management software system.
Corrective actions: In September 2023, EWC Financial Aid implemented a permanent fix utilizing the Colleague Process Handler, which automates disbursement notifications. The automated disbursement process is set to run weekly and ensures time sensitive acknowledgement to aid recipients. Completion d...
Corrective actions: In September 2023, EWC Financial Aid implemented a permanent fix utilizing the Colleague Process Handler, which automates disbursement notifications. The automated disbursement process is set to run weekly and ensures time sensitive acknowledgement to aid recipients. Completion date: September 2023 Contact person: Director of Financial Aid - Rebecca McAllister
Corrective actions: EWC Financial Aid actively addressed the issue of awards not showing in the Common Origination and Disbursement (COD) system. EWC has implemented a new process utilizing the Colleague Transfer Monitoring system to ensure NSLDS accepts the NSC enrollment information. In the event ...
Corrective actions: EWC Financial Aid actively addressed the issue of awards not showing in the Common Origination and Disbursement (COD) system. EWC has implemented a new process utilizing the Colleague Transfer Monitoring system to ensure NSLDS accepts the NSC enrollment information. In the event that EWC’s HCM2 status prevents automatic reporting, EWC Financial Aid will update NSLDS monthly. Completion date: October 2023 Contact person: Financial Aid Director - Rebecca McAllister ________ Student with reported program length: EWC has set internal controls to ensure the proper settings within Colleague are selected, including setting years as a default instead of months. EWC Financial Aid and EWC Academic Services will review and evaluate each program and ensure that the proper default is selected to ensure accurate program reporting. Anticipated completion date: December 2023 Contact people: Financial Aid Director - Rebecca McAllister and Admin. Specialist - Lynn Wamboldt _________ Students with a program date from Colleague that did not match NSLDS: The Colleague student-information system will be updated to define the parameter of start date as the first day of each semester. This software patch will ensure Colleague matches the reporting parameters utilized by NSLDS. Anticipated completion date: January 2024 Contact people: Data Analyst - Xi Feng and CIO -Tyler Vasko
Corrective Action Plan: The College has previously established detailed policies and procedures to process and to accurately report status changes timely via the National Student Clearinghouse (NSC) to NSLDS. The reporting of the Initial Submission along with the Subsequent Submissions occurs approx...
Corrective Action Plan: The College has previously established detailed policies and procedures to process and to accurately report status changes timely via the National Student Clearinghouse (NSC) to NSLDS. The reporting of the Initial Submission along with the Subsequent Submissions occurs approximately 5 business days prior to the month for which the report is due. This then ensures that NSC has the opportunity to transmit the data to NSLDS within 14 days of the 1st of the month. Submission of additional rosters would not change anything as NSC only submits once per month to NSLDS. The College will continue to submit on time to NSC and will continue to monitor when NSC transmits to NSLDS. Further, the College will implement an audit process that will sample NSLDS status and compare those sampled to college records and to records submitted to NSC at least once prior to end of term. Timeline for Implementation of Corrective Action Plan: The corrective action plan was implemented as of October 2023. Contact Person Todd Wonders, Associate Director of Financial Aid Allison Wrobel, Registrar
The school has re-allocated funds from UNSUB to SUB to accommodate the SUB award that had been initiated before the student graduated (see Exhibit 3.1). In the effort to prevent this kind of error arising from quirky and unusual transfer credit scenarios, the institution's financial aid office and o...
The school has re-allocated funds from UNSUB to SUB to accommodate the SUB award that had been initiated before the student graduated (see Exhibit 3.1). In the effort to prevent this kind of error arising from quirky and unusual transfer credit scenarios, the institution's financial aid office and our servicer now track transfer credits for all students on a shared document. Any late transfer credits that come in for a student are added to the tracker so that all parties are made aware of any re-packaging need that may arise.
View Audit 294799 Questioned Costs: $1
This issue has already been addressed and remedied. The institution has updated procedures to send automatic email Exit notification to the student at any change of status, other than from full-time to half-time. This email notification is recorded in the student's activity feed, and a screen shot o...
This issue has already been addressed and remedied. The institution has updated procedures to send automatic email Exit notification to the student at any change of status, other than from full-time to half-time. This email notification is recorded in the student's activity feed, and a screen shot of the activity feed noting the date the exit notification was sent will be placed in the student's financial aid file.
Management's Response: We concur. View of Responsible Officials and Corrective Action Plan. Return of Funds - The Campus Business Office and the Financial Aid Office met to review the untimely return of funds. We determined and immediately implemented a restructured process where the R2T4 speciali...
Management's Response: We concur. View of Responsible Officials and Corrective Action Plan. Return of Funds - The Campus Business Office and the Financial Aid Office met to review the untimely return of funds. We determined and immediately implemented a restructured process where the R2T4 specialist in financial aid will review student accounts that require R2T4 calculations on a weekly basis. The students will be posted to the shared database between Financial Aid and the Business Office. The dedicated weekly time will expedite the calculation process. The Business Office, as part of the updated process will continue to treat the R2T4 award adjustments as a priority. In addition to the existing process of end of month reconciliation and return of funds, a mid-month returning of funds was added and implemented. The dedicated weekly timeline to calculate, as well as the added mid-month return of funds, will ensure that we meet the required return of funds within the 45-day window. The offices will meet to review this updated process and make any additional changes should they be necessary to maintain compliance. Calculations - To ensure compliance with calculations processed timely, we will relieve the R2T4 specialist of other responsibilities so he can dedicate 100% of his time to calculate within the required timeframe. In addition, there will be additional staff assisting with calculations because the institution closes for a 10- day period which impacts the 30-day timeframe. This will ensure that all calculations are done. Implementation Date: 11/15/2023
Recommendation: We recommend that the University review its processes and internal controls to includes a review of all manual adjustment made within NSLDS. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The err...
Recommendation: We recommend that the University review its processes and internal controls to includes a review of all manual adjustment made within NSLDS. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The error was made while making manual corrections to prior year posting. The University formally document a policy and procedure that will require the review all manual edits made to NSLDS. Name(s) of the contact person(s) responsible for corrective action: Mark Quistorf and Registrar’s office. Planned completion date for corrective action plan: March 31, 2024
Recommendation: We recommend the College review and strengthen its procedures for notifying students of their Direct Loan disbursements within the required time frame and that documentation of the letters sent is maintained. Explanation of disagreement with audit finding: There is no disagreement w...
Recommendation: We recommend the College review and strengthen its procedures for notifying students of their Direct Loan disbursements within the required time frame and that documentation of the letters sent is maintained. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Bursar desk manual has been updated to include information regarding the notice required Direct Loan disbursements. Additionally, statements have been updated to include appropriate messaging when loads are disburses. The statements are sent at the time the disbursements are made. Name(s) of the contact person(s) responsible for corrective action: Michele Peterson Planned completion date for corrective action plan: 12/31/23
Condition: The University has not designated a Qualified Individual responsible for implementing and monitoring the University's information security program, nor does the University have a written information security program that addresses the six required minimum elements as required by the Gramm...
Condition: The University has not designated a Qualified Individual responsible for implementing and monitoring the University's information security program, nor does the University have a written information security program that addresses the six required minimum elements as required by the Gramm‐Leach Bliley Act (GLBA). Corrective Action: At the time that we replied to the question, our former Qualified Individual responsible for implementing and monitoring the Institution's information security program had left the organization a month previously. Upon reflecting on the significance of this position, I have elevated this role to a higher priority in the organization and named Darrin Burns, Director of ERP and IT, as Fielding’s Qualified Individual. In collaboration with Darrin and CIO Solutions, our MSP, we will draft the written information security program using the cybersecurity assessment results and recommendations as a starting point. In addition, we will ensure that the final document will include all six required minimum elements per Title IV regulations (16 CFR 314). Person Responsible For Corrective Action: Darrin Burns, Director of IT and ERP Anticipated Completion Date: December 31, 2024
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