Finding 1115914 (2024-006)

Significant Deficiency Repeat Finding
Requirement
N
Questioned Costs
$1
Year
2024
Accepted
2025-03-28
Audit: 350009
Organization: Urshan College (MO)

AI Summary

  • Core Issue: The College's Written Information Security Program (WISP) does not meet the minimum requirements of the Gramm-Leach-Bliley Act, lacking key elements like secure disposal of customer information.
  • Impacted Requirements: Compliance with federal regulations, specifically 16 CFR 314 regarding information security and 2 CFR 200.303 for internal controls.
  • Recommended Follow-Up: Implement controls for a formal review process of the WISP to ensure compliance and reduce vulnerability to data breaches.

Finding Text

2024-006 8540.13 Department Of Education Student Financial Aid 84.063, 84.268 "P063P218567-2024 P268K228567-2024" N/A N/A 7/1/23 - 6/30/24 Significant Deficiency Did not result in material questioned costs therefore will document as a SD. Finding is neither systemic nor will it lead to 5% questioned cost. N/A "The Gramm-Leach-Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The regulation states that the college must designate a qualified individual responsible for overseeing and implementting your information security program and enforcing your information security program. (16 CFR 314.4(a)). The entity shall have a Written Information Security Program (WISP) that outlines the design and implementation of the risk assessment procedures. (16 CFR 314.4(b)). At a minimum, the institution's written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d)). Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements." "The College has a Written Information Security Program; however, the College did not meet the minimum requirements stated in the Gramm-Leach-Bliley Act. Additionally, we were unable to observe evidence that the WISP was formally reviewed and approved. " N/A "The WISP was missing the element discussing the secure disposal of customer information. Additionally, there was not am observable formal review or authorization. " The college did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements. There is a risk the College’s information and systems could be vulnerable to attacks or intrusions, and these attacks may not be detected in a timely manner. Yes We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements. Management agrees with this finding. See 0100.25

Categories

Questioned Costs Subrecipient Monitoring Reporting Significant Deficiency Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Other Findings in this Audit

  • 539468 2024-004
    Significant Deficiency Repeat
  • 539469 2024-004
    Significant Deficiency Repeat
  • 539470 2024-005
    Material Weakness
  • 539471 2024-005
    Material Weakness
  • 539472 2024-006
    Significant Deficiency Repeat
  • 539473 2024-006
    Significant Deficiency Repeat
  • 539474 2024-007
    Significant Deficiency Repeat
  • 539475 2024-007
    Significant Deficiency Repeat
  • 539476 2024-008
    Significant Deficiency
  • 539477 2024-008
    Significant Deficiency
  • 539478 2024-009
    Significant Deficiency
  • 539479 2024-009
    Significant Deficiency
  • 539480 2024-010
    Significant Deficiency
  • 539481 2024-010
    Significant Deficiency
  • 1115910 2024-004
    Significant Deficiency Repeat
  • 1115911 2024-004
    Significant Deficiency Repeat
  • 1115912 2024-005
    Material Weakness
  • 1115913 2024-005
    Material Weakness
  • 1115915 2024-006
    Significant Deficiency Repeat
  • 1115916 2024-007
    Significant Deficiency Repeat
  • 1115917 2024-007
    Significant Deficiency Repeat
  • 1115918 2024-008
    Significant Deficiency
  • 1115919 2024-008
    Significant Deficiency
  • 1115920 2024-009
    Significant Deficiency
  • 1115921 2024-009
    Significant Deficiency
  • 1115922 2024-010
    Significant Deficiency
  • 1115923 2024-010
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $1.87M
84.063 Federal Pell Grant Program $990,139