Finding 1101235 (2024-003)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2024
Accepted
2025-02-27
Audit: 344180
Organization: University of Dubuque (IA)
Auditor: Rsm US LLP

AI Summary

  • Core Issue: The University failed to implement its information security policy on time, lacking essential components for safeguarding student information.
  • Impacted Requirements: Non-compliance with 2 CFR 200.303(a) and 16 CFR Part 314, including risk assessment, safeguard implementation, and oversight responsibilities.
  • Recommended Follow-Up: Ensure timely completion of the information security program and establish necessary policies and procedures to protect student data effectively.

Finding Text

U.S. Department of Education Student Financial Assistance Programs Cluster Gramm-Leach Bliley Act – Student Information Security (84.007, 84.268, 84.038, 84.063, 84.378) Federal Award Year: 2023-2024 Finding: The University created and implemented a comprehensive information security policy, but did not have it done in a timely manner. Criteria: 2 CFR 200.303(a) requires that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in Standards for Internal Control in the Federal Government issued by the Comptroller General of the United States or the Internal Control Integrated Framework, issued by the Committee of Sponsoring Organizations of the Treadway Commission. The Program Participation Agreement (PPA) with the U.S. Department of Education requires the institution to comply with the Standards for Safeguarding Customer Information as described in 16 CFR Part 314 which includes the development of a comprehensive written security program that includes the following parts: 16 CFR 314.4(a) requires institutions to designate a qualified individual responsible for overseeing and implementing the institution’s information security program and enforcing the information security program. 16 CFR 314.4(b) requires institutions to provide for the information security program to be based on a risk assessment that identifies reasonably foreseeable internal and external risks to the security, confidentiality and integrity of customer information (as the term customer information applies to the institution) that could result in the unauthorized disclosure, misuse, alteration, destruction or other compromise of such information, and assesses the sufficiency of any safeguards in place to control these risks. 16 CFR 314.4(c) requires institutions to provide for the design and implementation of safeguards to control the risks the institution provides through its risk assessment. 16 CFR 314.4(d) requires institutions to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented 16 CFR 314.4(e) requires institutions to develop policies and procedures to ensure that personnel are able to enact the information security program. 16 CFR 314.4(f) requires institutions to develop policies and procedures to oversee its information system service providers. Condition: The institution’s written information security program was not done in a timely manner to include the following elements required by regulation as agreed to in the PPA: The written information security program does not designate an individual responsible for overseeing and implementing the institution’s information security program or enforcing the information security program. The institution has performed a risk assessment utilizing internal resources but has not based the information security program on the results of this assessment, nor has the institution included all required elements of internal and external risks to the security, confidentiality or integrity of customer information. The institution’s risk assessment is missing an inventory of IT systems that process and store customer information and the compliance with information security elements related to multifactor authentication, access control, change management, logging and alerting and encryption. The institution has not identified, designed or implemented safeguards for all of the risks identified in the risk assessment. The safeguards do not include the identification of security events or detection and response capabilities to support incident response. The institution has not been able to test safeguards because safeguards have not been designed or implemented in response to the risk assessment. The institution has not developed written policies and procedures to ensure that personnel are able to enact the information security program. There is a lack of evidence of leadership being required to report to the board or an appropriate supervisory council to ensure those charged with governance are informed on the current state of the information security program. The institution has not developed policies and procedures to oversee information service providers. Cause: The institution did not create and implement a comprehensive information security policy in a timely manner. Effect: The institution did not create and implement a comprehensive information security policy in a timely manner. The absence of internal controls and policies and procedures could result in the unauthorized disclosure, misuse, alteration, destruction or other compromise of student account information. Questioned costs: None. Context: Under an institution’s PPA with the U.S. Department of Education, schools must protect student financial aid information, with particular attention to information provided to institutions by the U.S. Department of Education or otherwise obtained in support of the administration of federal student financial aid programs. Repeat finding: This is not a repeat finding. Recommendation: We recommend that the University completes these requirements in a timely manner in the future. Views of responsible officials: Management agrees with this finding. See corrective action plan.

Categories

Subrecipient Monitoring Equipment & Real Property Management Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Other Findings in this Audit

  • 524789 2024-001
    Significant Deficiency Repeat
  • 524790 2024-002
    Significant Deficiency
  • 524791 2024-003
    Significant Deficiency
  • 524792 2024-003
    Significant Deficiency
  • 524793 2024-003
    Significant Deficiency
  • 524794 2024-003
    Significant Deficiency
  • 524795 2024-003
    Significant Deficiency
  • 524796 2024-003
    Significant Deficiency
  • 1101231 2024-001
    Significant Deficiency Repeat
  • 1101232 2024-002
    Significant Deficiency
  • 1101233 2024-003
    Significant Deficiency
  • 1101234 2024-003
    Significant Deficiency
  • 1101236 2024-003
    Significant Deficiency
  • 1101237 2024-003
    Significant Deficiency
  • 1101238 2024-003
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $14.84M
84.063 Federal Pell Grant Program $3.09M
84.038 Federal Perkins Loan Program $2.51M
84.042 Trio Student Support Services $263,491
84.007 Federal Supplemental Educational Opportunity Grants $177,288
84.033 Federal Work-Study Program $172,965
84.379 Teacher Education Assistance for College and Higher Education Grants (teach Grants) $41,015