Finding 1090823 (2024-004)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2024
Accepted
2024-12-16

AI Summary

  • Core Issue: The College lacks a comprehensive written security program to protect student financial aid information as required by the Gramm-Leach-Bliley Act.
  • Impacted Requirements: Compliance with the Gramm-Leach-Bliley Act and 2 CFR 200.303, which mandate effective internal controls over federal awards.
  • Recommended Follow-Up: The College should prioritize updating its written security program to meet all necessary compliance elements.

Finding Text

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, and 84.268 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters 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 College to establish and maintain effective internal controls over Federal awards. Condition: During our testing of the College's information technology, we noted the College did not maintain a comprehensive written security program that included the minimum required elements. Questioned costs: None Context: Under an institutions 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 College has continued to make progress in updating the College 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. Effect: The student personal information could be vulnerable. Repeat finding: No Recommendation: We recommend the College work to update the written security program to ensure compliance with all of the required elements. Views of responsible officials: There is no disagreement with the audit finding. While the College's "written" information security program did not include the minimum requirements, all required activities were being performed. The College is in the process of updating its written information security program to achieve compliance with the Gramm-Leach-Bliley Act.

Categories

Student Financial Aid Significant Deficiency Internal Control / Segregation of Duties

Other Findings in this Audit

  • 514372 2024-001
    Material Weakness
  • 514373 2024-002
    Significant Deficiency
  • 514374 2024-003
    Significant Deficiency
  • 514375 2024-004
    Significant Deficiency
  • 514376 2024-001
    Material Weakness
  • 514377 2024-002
    Significant Deficiency
  • 514378 2024-004
    Significant Deficiency
  • 514379 2024-001
    Material Weakness
  • 514380 2024-002
    Significant Deficiency
  • 514381 2024-004
    Significant Deficiency
  • 514382 2024-001
    Material Weakness
  • 514383 2024-002
    Significant Deficiency
  • 514384 2024-003
    Significant Deficiency
  • 514385 2024-004
    Significant Deficiency
  • 1090814 2024-001
    Material Weakness
  • 1090815 2024-002
    Significant Deficiency
  • 1090816 2024-003
    Significant Deficiency
  • 1090817 2024-004
    Significant Deficiency
  • 1090818 2024-001
    Material Weakness
  • 1090819 2024-002
    Significant Deficiency
  • 1090820 2024-004
    Significant Deficiency
  • 1090821 2024-001
    Material Weakness
  • 1090822 2024-002
    Significant Deficiency
  • 1090824 2024-001
    Material Weakness
  • 1090825 2024-002
    Significant Deficiency
  • 1090826 2024-003
    Significant Deficiency
  • 1090827 2024-004
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.063 Federal Pell Grant Program $3.10M
84.268 Federal Direct Student Loans $347,048
84.042 Trio Student Support Services $343,578
17.259 Wioa Youth Activities $218,795
17.258 Wioa Adult Program $185,982
17.278 Wioa Dislocated Worker Formula Grants $162,845
93.575 Child Care and Development Block Grant $147,255
21.027 Coronavirus State and Local Fiscal Recovery Funds $141,370
84.048 Career and Technical Education -- Basic Grants to States $124,925
84.002 Adult Education - Basic Grants to States $116,895
84.007 Federal Supplemental Educational Opportunity Grants $100,851
84.033 Federal Work-Study Program $61,709
10.558 Child and Adult Care Food Program $29,027
21.019 Coronavirus Relief Fund $2,483