Finding 1101050 (2024-002)

Significant Deficiency Repeat Finding
Requirement
N
Questioned Costs
-
Year
2024
Accepted
2025-02-27
Audit: 344056
Organization: Marymount University (VA)

AI Summary

  • Core Issue: The University failed to conduct a required IT risk assessment, leaving student financial aid information potentially vulnerable.
  • Impacted Requirements: This oversight violates the Gramm-Leach-Bliley Act, specifically regarding employee training, information systems, and risk management.
  • Recommended Follow-Up: Engage a third party or conduct an internal risk assessment to address compliance gaps and document safeguards for identified risks.

Finding Text

Criteria or specific requirement: The Gramm-Leach-Bliley Act (Public Law 106-102) requires institutions to explain their informationsharing 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)). Condition: Under an institution’s Program Participation Agreement with the U.S. 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. Questioned costs: None Context: During our audit procedures, it was noted that the University did not perform and document a risk assessment that addresses certain of the elements noted in 16 CFR 314.4 (b) which are (1) employee training and management; (2) information systems, including network and software design, as well as information processing, storage, transmission and disposal; and (3) detecting, preventing and responding to attacks, intrusions, or other systems failures and document safeguards for identified risks. Cause: The University did not perform an IT risk assessment tailored specifically to the University, identify risks or address risks identified as required by the Gramm-Leach-Bliley Act. Effect: The students’ personal information could be vulnerable. Repeat Finding: Yes, finding 2023-002. Recommendation: We recommend that the University engage a third party or perform the risk assessment for the areas required by the Gramm-Leach-Bliley Act and ensure that there are documented safeguards for identified risks. Views of responsible officials: Please refer to the attached corrective action plan.

Categories

Student Financial Aid Subrecipient Monitoring

Other Findings in this Audit

  • 524608 2024-002
    Significant Deficiency Repeat
  • 524609 2024-003
    Significant Deficiency Repeat
  • 524610 2024-002
    Significant Deficiency Repeat
  • 524611 2024-003
    Significant Deficiency Repeat
  • 524612 2024-002
    Significant Deficiency Repeat
  • 524613 2024-003
    Significant Deficiency Repeat
  • 524614 2024-002
    Significant Deficiency Repeat
  • 524615 2024-003
    Significant Deficiency Repeat
  • 524616 2024-004
    Significant Deficiency
  • 524617 2024-004
    Significant Deficiency
  • 524618 2024-004
    Significant Deficiency
  • 524619 2024-004
    Significant Deficiency
  • 524620 2024-004
    Significant Deficiency
  • 524621 2024-004
    Significant Deficiency
  • 524622 2024-004
    Significant Deficiency
  • 524623 2024-004
    Significant Deficiency
  • 524624 2024-004
    Significant Deficiency
  • 524625 2024-004
    Significant Deficiency
  • 524626 2024-002
    Significant Deficiency Repeat
  • 524627 2024-003
    Significant Deficiency Repeat
  • 1101051 2024-003
    Significant Deficiency Repeat
  • 1101052 2024-002
    Significant Deficiency Repeat
  • 1101053 2024-003
    Significant Deficiency Repeat
  • 1101054 2024-002
    Significant Deficiency Repeat
  • 1101055 2024-003
    Significant Deficiency Repeat
  • 1101056 2024-002
    Significant Deficiency Repeat
  • 1101057 2024-003
    Significant Deficiency Repeat
  • 1101058 2024-004
    Significant Deficiency
  • 1101059 2024-004
    Significant Deficiency
  • 1101060 2024-004
    Significant Deficiency
  • 1101061 2024-004
    Significant Deficiency
  • 1101062 2024-004
    Significant Deficiency
  • 1101063 2024-004
    Significant Deficiency
  • 1101064 2024-004
    Significant Deficiency
  • 1101065 2024-004
    Significant Deficiency
  • 1101066 2024-004
    Significant Deficiency
  • 1101067 2024-004
    Significant Deficiency
  • 1101068 2024-002
    Significant Deficiency Repeat
  • 1101069 2024-003
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $36.12M
84.063 Federal Pell Grant Program $3.02M
84.031 Higher Education Institutional Aid $429,524
84.038 Federal Perkins Loan Program_federal Capital Contributions $382,363
93.732 Mental and Behavioral Health Education and Training Grants $300,921
12.905 Cybersecurity Core Curriculum $258,163
84.007 Federal Supplemental Educational Opportunity Grants $217,325
84.033 Federal Work-Study Program $211,296
93.761 Evidence-Based Falls Prevention Programs Financed Solely by Prevention and Public Health Funds (pphf) $204,377
47.076 Stem Education (formerly Education and Human Resources) $98,351
93.846 Arthritis, Musculoskeletal and Skin Diseases Research $84,425
47.084 Nsf Technology, Innovation, and Partnerships $45,398
17.289 Community Project Funding/congressionally Directed Spending $30,169
12.903 Gencyber Grants Program $29,244
47.070 Computer and Information Science and Engineering $6,994