Finding 1143296 (2024-008)

Material Weakness
Requirement
N
Questioned Costs
-
Year
2024
Accepted
2025-06-24
Audit: 359750
Organization: Harris-Stowe State University (MO)
Auditor: Rubinbrown LLP

AI Summary

  • Core Issue: The University’s Information Security Program is not compliant with the FTC Safeguards Rule, exposing it to cybersecurity risks.
  • Impacted Requirements: Key requirements include having a Written Information Security Program (WISP), conducting risk assessments, and implementing access controls and encryption.
  • Recommended Follow-Up: The University should enhance its WISP, complete a comprehensive risk assessment, and formalize current practices to ensure compliance.

Finding Text

Finding 2024-008 - Material Weakness: Special Tests and Provisions - Compliance and Control Finding Student Financial Aid Cluster Federal Agency: U.S. Department of Education Federal Award Number: 84.007, 84.033, 84.063, 84.379 and 84.268 Pass-Through Entity: None Criteria Or Specific Requirement: The Federal Trade Commission (FTC) issued the FTC Safeguards Rule on December 9, 2021, and gave notice to entities that are required to follow the Gramm-Leach-Bliley Act (GLBA) that each entity would be required to be in compliance with the revised requirements no later than June 9, 2023. The FTC Safeguards Rule expanded the requirements for the Written Information Security Program (WISP) required to be established by the University. The requirements for the WISP noted at 16 CFR 314.4 require that the University designate a Qualified Individual responsible for overseeing and implementing the University’s information security program, be based on a risk assessment that identifies reasonably foreseeable internal and external risks and establishes safeguards to address those risks, and requires that the following 8 safeguards be documented: • Implement and periodically review access controls • Conduct a periodic inventory of data, noting where it is collected, stored, or transmitted • Encrypt customer information on the institution’s system and when it’s in transit. • Assess apps developed by the institution • Implement multi-factor authentication for anyone accessing customer information on the institution’s system • Dispose of customer information securely • Anticipate and evaluate changes to the information system or network • Maintain a log of authorized users’ activity and keep an eye out for unauthorized access • In addition, the University is responsible for regularly testing and monitoring the effectiveness of the safeguards it has implemented and establishing how it will complete the monitoring and testing in the WISP. The University is also responsible for documenting in the WISP how it will oversee its information system service providers and shall also provide for the evaluation and adjustment of its information security program in light of the results of the required testing and monitoring; the results of the required risk assessments; any material changes to the University’s operations or business arrangements; or any other circumstances that it knows or has reason to know may have a material impact on the University’s information security program. Condition: The current state of the University’s Information Security Program is not in compliance with the regulatory obligation. Cause: Controls over compliance put in place by management were not operating effectively as it relates to these compliance requirements. Effect: The failure to meet the requirements of the FTC Safeguards Rule could make the University vulnerable to cyber security and student data protection risks. Questioned Costs: Not applicable. Context: We inquired with the University personnel regarding GLBA regulations and noted the following: • There is currently no written information security program in place. • The University has not conducted risk assessments specifically addressing risks related to student data. • Third-party cloud providers, which implement security practices, are utilized to protect student data. These providers encrypt student data when stored on cloud platforms; however, the University does not currently use encryption for local servers or endpoints. Furthermore, there are no established policies regarding encryption. • There are no documented policies governing physical or logical access controls. • Account management practices are informal, with no formal processes or policies in place. • Multi-factor authentication is not required for access to student data, except for email, and no compensating controls have been implemented. • A written data retention policy has not been established. • There is no formal change management process or policy currently in place. • There are no formal policies or requirements for security training for University personnel. Identification As A Repeat Finding: Not applicable. Recommendation: We recommend that the University implement a more robust WISP, conduct a broader risk assessment, and begin documenting the current informally implemented practices in order to ensure appropriate compliance. Views Of Responsible Officials: Harris-Stowe State University acknowledges the audit finding regarding noncompliance with the Gramm-Leach-Bliley Act (GLBA) and the FTC Safeguards Rule. In response, the University has collaborated with Omega Technical Solutions and iLeap Group to execute a comprehensive cybersecurity compliance and modernization initiative. As of the audit period close, over 90% of related deficiencies have been remediated. Specific corrective actions taken or underway include: 1. Written Information Security Program (WISP): A formal WISP has been developed and implemented. It outlines oversight structures, risk management strategies, testing protocols, and required safeguards in alignment with 16 CFR 314.4. 2. Risk Assessment: A comprehensive risk scorecard was created. All Active Directory accounts were reviewed and flagged for deactivation or role reassignment as appropriate. 3. Access and Encryption Controls: Encryption is now deployed across all active endpoints. Logical access control and encryption policies have been adopted and published. Multi-factor authentication (MFA) is enforced for all systems handling student data. 4. Account Management and Role-Based Access: RBAC policies have been established and account provisioning is now formally documented and managed. 5. Retention, Change Management, and Training: A written data retention policy and formal change management procedures are now in place. An onboarding cybersecurity training program has been developed, with full implementation scheduled by August 31, 2025. 6. Legacy Server Risk Mitigation: One legacy Microsoft 2008 server has failed and is decommissioned. The remaining server is isolated, monitored with NIST- and Microsoft Sentinel-aligned tools, and pending full replacement as part of the upcoming infrastructure upgrade. 7. Ongoing Monitoring and Vendor Oversight: TCPM-aligned monitoring practices and vendor oversight protocols are now active and included in the WISP framework. The University’s IT Security SharePoint site houses all related documentation and is structured to support transparency, audit readiness, and continued compliance oversight.

Categories

Subrecipient Monitoring Special Tests & Provisions Material Weakness

Other Findings in this Audit

  • 566850 2024-008
    Material Weakness
  • 566851 2024-008
    Material Weakness
  • 566852 2024-008
    Material Weakness
  • 566853 2024-008
    Material Weakness
  • 566854 2024-008
    Material Weakness
  • 566855 2024-008
    Material Weakness
  • 566856 2024-008
    Material Weakness
  • 566857 2024-006
    Significant Deficiency
  • 566858 2024-006
    Significant Deficiency
  • 566859 2024-006
    Significant Deficiency
  • 566860 2024-006
    Significant Deficiency
  • 566861 2024-006
    Significant Deficiency
  • 566862 2024-005
    Material Weakness
  • 566863 2024-005
    Material Weakness
  • 566864 2024-005
    Material Weakness
  • 566865 2024-007
    Material Weakness
  • 566866 2024-007
    Material Weakness
  • 566867 2024-004
    Material Weakness
  • 566868 2024-004
    Material Weakness
  • 566869 2024-004
    Material Weakness
  • 566870 2024-004
    Material Weakness
  • 1143292 2024-008
    Material Weakness
  • 1143293 2024-008
    Material Weakness
  • 1143294 2024-008
    Material Weakness
  • 1143295 2024-008
    Material Weakness
  • 1143297 2024-008
    Material Weakness
  • 1143298 2024-008
    Material Weakness
  • 1143299 2024-006
    Significant Deficiency
  • 1143300 2024-006
    Significant Deficiency
  • 1143301 2024-006
    Significant Deficiency
  • 1143302 2024-006
    Significant Deficiency
  • 1143303 2024-006
    Significant Deficiency
  • 1143304 2024-005
    Material Weakness
  • 1143305 2024-005
    Material Weakness
  • 1143306 2024-005
    Material Weakness
  • 1143307 2024-007
    Material Weakness
  • 1143308 2024-007
    Material Weakness
  • 1143309 2024-004
    Material Weakness
  • 1143310 2024-004
    Material Weakness
  • 1143311 2024-004
    Material Weakness
  • 1143312 2024-004
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
84.063 Federal Pell Grant Program $5.31M
21.027 Coronavirus State and Local Fiscal Recovery Funds $3.37M
84.425 Education Stabilization Fund $1.39M
84.116 Fund for the Improvement of Postsecondary Education $440,825
84.268 Federal Direct Student Loans $427,127
84.044 Trio Talent Search $343,723
84.047 Trio Upward Bound $279,191
84.042 Trio Student Support Services $274,075
84.031 Higher Education Institutional Aid $209,393
11.307 Economic Adjustment Assistance $181,184
84.033 Federal Work-Study Program $122,317
84.007 Federal Supplemental Educational Opportunity Grants $82,223
47.076 Stem Education (formerly Education and Human Resources) $12,982
10.558 Child and Adult Care Food Program $7,535
84.379 Teacher Education Assistance for College and Higher Education Grants (teach Grants) $3,772