Finding 1180747 (2025-001)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-03-17
Audit: 392422
Auditor: WIPFLI LLP

AI Summary

  • Core Issue: The College lacked an updated written information security program as required by the Gramm-Leach-Bliley Act.
  • Impacted Requirements: The program must include all seven required elements to comply with federal student aid regulations.
  • Recommended Follow-Up: The College should ensure its written information security plan is updated to meet all seven elements and maintain compliance.

Finding Text

Criteria – An institution’s written information security program must address the required minimum seven elements. Condition – During our audit, the College was asked to provide its written information security program related to Gramm-Leach-Bliley required policies. The College confirmed it did not have appropriately updated written policies during the audit period, which is required under the federal student aid program. Cause - There was an oversight by the College. Possible Asserted Effect - The College does not have a written information security program that is in compliance with Gramm-Leach-Bliley. Known Questioned Costs - None Recommendation - The institution should update its written information security plan to include all seven required elements of the Gramm-Leach-Bliley Act. Views of Responsible Officials - Management agrees with the finding. Upon notification by Wipfli, Western has updated written policies/procedures to ensure that the written security program addresses all seven requirements.

Corrective Action Plan

Issue identified: An Institution's written information security program must address the required minimum seven requirements of the Gramm-Leach Bliley Act. Program Affected: Student Financial Assistance Cluster Corrective Action: - Upon notification of the finding by Wipfli, Western is updating written policy/procedures to ensure that our written security program addresses all seven requirements of the Gramm-Leach Bliley policies. -We are running our penetration tests each quarter to ensure that we are maintaining security as needed in education at Western. -The internal testing and quarterly tests results we will be running will be performed during the last month of each quarter for review upon request. Person Responsible: Primary - Joan Pierce, CIO, Secondary - Michael Caretta, IT Director

Categories

Internal Control / Segregation of Duties

Other Findings in this Audit

  • 1180744 2025-001
    Material Weakness Repeat
  • 1180745 2025-001
    Material Weakness Repeat
  • 1180746 2025-001
    Material Weakness Repeat
  • 1180748 2025-002
    Material Weakness Repeat
  • 1180749 2025-002
    Material Weakness Repeat
  • 1180750 2025-002
    Material Weakness Repeat
  • 1180751 2025-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.063 FEDERAL PELL GRANT PROGRAM $7.95M
84.268 FEDERAL DIRECT STUDENT LOANS $7.50M
17.261 WIA PILOTS, DEMONSTRATIONS, AND RESEARCH PROJECTS $530,938
84.031 HIGHER EDUCATION_INSTITUTIONAL AID $424,730
84.126 REHABILITATION SERVICES_VOCATIONAL REHABILITATION GRANTS TO STATES $262,642
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $147,934
15.114 INDIAN EDUCATION_HIGHER EDUCATION GRANT PROGRAM $143,743
84.116 FUND FOR THE IMPROVEMENT OF POSTSECONDARY EDUCATION $136,298
84.033 FEDERAL WORK-STUDY PROGRAM $126,830
84.335 CHILD CARE ACCESS MEANS PARENTS IN SCHOOL $122,274
84.048 CAREER AND TECHNICAL EDUCATION -- BASIC GRANTS TO STATES $110,656
84.002 ADULT EDUCATION - BASIC GRANTS TO STATES $75,000
64.111 VETARANS REPORTING FEE $3,728
97.044 ASSISTANCE TO FIREFIGHTERS GRANT $-4,159