FAC Explorer

Finding 1191822 (2025-004)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-03-30
Audit: 395639
Organization: Lincoln University (MO)
Auditor: FORVIS MAZARS LLP

AI Summary

  • Core Issue: The University lacks a complete written information security program as required by the Gramm-Leach-Bliley Act.
  • Impacted Requirements: The program must include all 14 elements outlined in 16 CFR Part 314, which were due for compliance by June 9, 2023.
  • Recommended Follow-Up: Revise the written information security program to meet the current requirements of 16 CFR Part 314.

Finding Text

Student Financial Assistance Cluster Federal Pell Grant Program, ALN 84.063 Federal Direct Student Loans, ALN 84.268 U.S. Department of Education Program Year 2024 - 2025 Criteria or specific requirement - Special Tests: Gramm-Leach-Bliley Act - Student Information Security 16 CFR 314.4(c)(1) - (8), 16 CFR 314.4(e) Condition - The University does not have a written information security program that addresses all required elements of the Gramm-Leach-Bliley Act . Cause - The University did not update its written information security program by June 9, 2023 for the revised requirements of 16 CFR Part 314. Effect or potential effect - The University's written information security program does not address all required written statement elements of the Gramm-Leach-Bliley Act . Questioned costs - None Context - On December 9, 2021, the Federal Trade Commission issued final regulations for 16 CFR Part 314 to implement the Gramm-Leach-Bliley Act information safeguarding standards that institutions must implement. The regulations established minimum standards that institutions must meet. Institutions were required to be in compliance with the revised requirements no later than June 9, 2023. The University's written information security program contained one out of the 14 elements required by the revised Gramm- Leach-Bliley Act regulations. Identification as a repeat finding - N/A Recommendation - The University should revise its written information security program to be compliant with the current requirements of 16 CFR Part 314.

Corrective Action Plan

The University concurs with the finding that the University does not have a written information security program that addresses all required elements of the Gramm-Leach-Bliley Act . While the University processes defined to address GLBA are in place, the Information Security Policy does not specifically address Gramm-Leach-Bliley Act (GLBA) security criteria. It is now understood that the defined processes that address and support GLBA security criteria need to be put into a format that is published for access by the Lincoln community. Lincoln has started the process to create and publish the written information security program that addresses all required elements of GLBA. The corrective measures above are designed to ensure full compliance with all required elements of the GLBA.

Categories

No categories assigned yet.

Other Findings in this Audit

  • 1191815 2025-001
    Material Weakness Repeat
  • 1191816 2025-001
    Material Weakness Repeat
  • 1191817 2025-002
    Material Weakness Repeat
  • 1191818 2025-002
    Material Weakness Repeat
  • 1191819 2025-003
    Material Weakness Repeat
  • 1191820 2025-003
    Material Weakness Repeat
  • 1191821 2025-004
    Material Weakness Repeat
  • 1191823 2025-005
    Material Weakness Repeat
  • 1191824 2025-005
    Material Weakness Repeat
  • 1191825 2025-006
    Material Weakness Repeat
  • 1191826 2025-006
    Material Weakness Repeat
  • 1191827 2025-007
    Material Weakness Repeat
  • 1191828 2025-007
    Material Weakness Repeat
  • 1191829 2025-007
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $7.47M
84.268 FEDERAL DIRECT STUDENT LOANS $6.87M
84.063 FEDERAL PELL GRANT PROGRAM $5.83M
10.512 EXTENSION SERVICES AT 1890 COLLEGES AND TUSKEGEE UNIVERSITY, WEST VIRGINIA STATE COLLEGE, AND CENTRAL STATE UNIVERSITY $4.45M
10.205 PAYMENTS TO 1890 LAND-GRANT COLLEGES AND TUSKEGEE UNIVERSITY $4.35M
84.031 HIGHER EDUCATION INSTITUTIONAL AID $3.86M
10.237 FROM LEARNING TO LEADING: CULTIVATING THE NEXT GENERATION OF DIVERSE FOOD AND AGRICULTURE PROFESSIONALS $1.28M
84.002 ADULT EDUCATION - BASIC GRANTS TO STATES $594,410
11.028 CONNECTING MINORITY COMMUNITIES PILOT PROGRAM $498,995
10.912 ENVIRONMENTAL QUALITY INCENTIVES PROGRAM $311,699
10.937 PARTNERSHIPS FOR CLIMATE-SMART COMMODITIES $269,479
84.033 FEDERAL WORK-STUDY PROGRAM $193,676
10.303 INTEGRATED PROGRAMS $149,968
10.307 ORGANIC AGRICULTURE RESEARCH AND EXTENSION INITIATIVE $116,513
10.443 OUTREACH AND ASSISTANCE FOR SOCIALLY DISADVANTAGED AND VETERAN FARMERS AND RANCHERS $111,343
10.514 EXPANDED FOOD AND NUTRITION EDUCATION PROGRAM $108,264
81.049 OFFICE OF SCIENCE FINANCIAL ASSISTANCE PROGRAM $103,350
93.569 COMMUNITY SERVICES BLOCK GRANT $97,000
10.310 AGRICULTURE AND FOOD RESEARCH INITIATIVE (AFRI) $90,038
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $86,815
47.070 COMPUTER AND INFORMATION SCIENCE AND ENGINEERING $84,327
12.431 BASIC SCIENTIFIC RESEARCH $83,340
66.436 SURVEYS, STUDIES, INVESTIGATIONS, DEMONSTRATIONS, AND TRAINING GRANTS AND COOPERATIVE AGREEMENTS - SECTION 104(B)(3) OF THE CLEAN WATER ACT $72,818
10.935 URBAN AGRICULTURE AND INNOVATIVE PRODUCTION $70,537
81.087 RENEWABLE ENERGY RESEARCH AND DEVELOPMENT $67,746
10.202 COOPERATIVE FORESTRY RESEARCH $64,765
10.210 HIGHER EDUCATION NATIONAL NEEDS GRADUATE FELLOWSHIP GRANTS $57,128
16.525 GRANTS TO REDUCE DOMESTIC VIOLENCE, DATING VIOLENCE, SEXUAL ASSAULT, AND STALKING ON CAMPUS $51,248
10.186 REGIONAL FOOD BUSINESS CENTERS $31,776
10.523 CENTERS OF EXCELLENCE AT 1890 INSTITUTIONS $30,974
47.076 STEM EDUCATION (FORMERLY EDUCATION AND HUMAN RESOURCES) $28,712
59.037 SMALL BUSINESS DEVELOPMENT CENTERS $27,609
10.025 PLANT AND ANIMAL DISEASE, PEST CONTROL, AND ANIMAL CARE $26,638
10.971 URBAN AGRICULTURE AND URBAN COUNTY COMMITTEE OUTREACH, TECHNICAL ASSISTANCE, AND EDUCATION $25,936
10.520 AGRICULTURE RISK MANAGEMENT EDUCATION PARTNERSHIPS COMPETITIVE GRANTS PROGRAM $24,138
10.229 EXTENSION COLLABORATIVE ON IMMUNIZATION TEACHING & ENGAGEMENT $22,016
47.074 BIOLOGICAL SCIENCES $21,426
10.311 BEGINNING FARMER AND RANCHER DEVELOPMENT PROGRAM $21,320
10.309 SPECIALTY CROP RESEARCH INITIATIVE $18,950
10.147 OUTREACH EDUCATION AND TECHNICAL ASSISTANCE $18,220
12.630 BASIC, APPLIED, AND ADVANCED RESEARCH IN SCIENCE AND ENGINEERING $16,658
47.049 MATHEMATICAL AND PHYSICAL SCIENCES $10,311
10.515 RENEWABLE RESOURCES EXTENSION ACT $9,887
10.170 SPECIALTY CROP BLOCK GRANT PROGRAM - FARM BILL $8,748
10.215 SUSTAINABLE AGRICULTURE RESEARCH AND EDUCATION $7,000
84.379 TEACHER EDUCATION ASSISTANCE FOR COLLEGE AND HIGHER EDUCATION GRANTS (TEACH GRANTS) $5,772
84.425 EDUCATION STABILIZATION FUND $5,680
10.500 COOPERATIVE EXTENSION SERVICE $5,663
10.216 1890 INSTITUTION CAPACITY BUILDING GRANTS $5,600
10.328 FOOD SAFETY OUTREACH PROGRAM $5,556
47.084 NSF TECHNOLOGY, INNOVATION, AND PARTNERSHIPS $5,244
10.727 INFLATION REDUCTION ACT URBAN & COMMUNITY FORESTRY PROGRAM $3,830
47.041 ENGINEERING $2,849
43.008 OFFICE OF STEM ENGAGEMENT (OSTEM) $24
10.524 SCHOLARSHIPS FOR STUDENTS AT 1890 INSTITUTIONS $-1,675