Finding 2365 (2020-004)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2021
Accepted
2023-11-26
Audit: 4064
Organization: Concordia College (NY)

AI Summary

  • Core Issue: The College lacked a policy for student information security, raising concerns about compliance with the Gramm-Leach Bliley Act.
  • Impacted Requirements: Sensitive student data may be at risk due to inadequate security measures during the College's closure.
  • Recommended Follow-Up: Establish a comprehensive information security policy and conduct a review to ensure compliance with relevant regulations.

Finding Text

2020-004 Special Test - Gramm-Leach Bliley Act FALN Number: 84.268 / 84.063 / 84.007 / 84.379 Program or Cluster Name: Federal Direct Student Loans / Federal Pell Grant Program / Federal Work-Study Program / Federal Supplemental Educational Opportunity Grants / Teacher Education Assistance for College and Higher Education (Student Financial Assistance Cluster) Agency: U.S. Department of Education Condition: We noted that the College did not have a policy to address student information security. Status: Due to the closure of the College, various software systems were shutdown with little consideration being given to information security and the storage of sensitive student data. Management was more concerned with recording of financial transactions and winding down operations of the College. We are unable to verify if the College is in compliance with the Program Participation Agreement and the Gramm-Leach Bliley Act. As such, the correction of the finding could not be verified. See current year finding 2021-002.

Corrective Action Plan

Management’s Response: Concordia College ceased academic operations in August 2021 and is in the process of winding down its operations and completing its remaining compliance requirements. Subsequent to the announcement of the closure of the College and following the ceasing of academic operations, virtually all employees left their employ with the College )including key Information technology personnel). The significant turnover in personnel, transition to outside consultants, and preparing proper teach out and transition plans for remaining students was a much larger focus than compliance requirements, which led to additional time lapsing between the prior year when findings were discovered to the current report being sent out.

Categories

Student Financial Aid Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 2362 2021-002
    Material Weakness
  • 2363 2020-002
    Material Weakness
  • 2364 2020-003
    Significant Deficiency
  • 2366 2020-005
    Material Weakness
  • 2367 2020-006
    Significant Deficiency
  • 2368 2020-007
    Significant Deficiency Repeat
  • 2369 2020-008
    Material Weakness Repeat
  • 2370 2020-009
    Significant Deficiency
  • 2371 2020-010
    Material Weakness
  • 2372 2020-011
    Material Weakness
  • 2373 2020-012
    Material Weakness
  • 2374 2020-013
    Material Weakness
  • 578804 2021-002
    Material Weakness
  • 578805 2020-002
    Material Weakness
  • 578806 2020-003
    Significant Deficiency
  • 578807 2020-004
    Material Weakness Repeat
  • 578808 2020-005
    Material Weakness
  • 578809 2020-006
    Significant Deficiency
  • 578810 2020-007
    Significant Deficiency Repeat
  • 578811 2020-008
    Material Weakness Repeat
  • 578812 2020-009
    Significant Deficiency
  • 578813 2020-010
    Material Weakness
  • 578814 2020-011
    Material Weakness
  • 578815 2020-012
    Material Weakness
  • 578816 2020-013
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $7.06M
84.063 Federal Pell Grant Program $1.52M
84.007 Federal Supplemental Educational Opportunity Grants $40,768
84.379 Teacher Education Assistance for College and Higher Education Grants (teach Grants) $33,031