Finding 2955 (2023-001)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2023
Accepted
2023-11-30
Audit: 4840
Organization: Lincoln Land Community College (IL)

AI Summary

  • Core Issue: The College has significant deficiencies in its internal controls over compliance with the Gramm-Leach-Bliley Act, risking student personal information security.
  • Impacted Requirements: Key compliance areas include access controls, data encryption, security assessments, and monitoring of service providers.
  • Recommended Follow-Up: Designate an individual to oversee information security and implement a comprehensive roadmap to address identified deficiencies.

Finding Text

Section III – Federal Award Findings and Questioned Costs 2023 – 001 Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 (Federal Supplemental Educational Opportunity Grants Program), 84.033 (Federal Work Study Program), 84.063 (Federal Pell Grant Program), 84.268 (Federal Direct Student Loans Program) Federal Award Identification Number and Year: N/A; 2022-2023 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as “financial institutions” and subject to the Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi). Condition: Under an institution’s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs. Questioned costs: None Section III – Federal Award Findings and Questioned Costs (Continued) 2023 – 001 (Continued) Context: During our testing of the College’s information technology, we noted the following items in the College’s written security program did not meet the following compliance requirements: • Implementation and periodic review of access controls • Encryption of customer information on the College’s system and when it is in transit • Evaluating, assessing or testing the security of applications that transmit sensitive information • The anticipation and evaluation of changes to the information system or network • Regular testing or monitoring of established safeguards to ensure effectiveness • The implementation of policies and procedures which ensure personnel can enact the information security program • The monitoring of the College’s information system service providers Cause: The College has continued to make progress in updating the College’s written security program to become compliance with all requirements; however, due to capacity and demands on the information technology individuals, this is still a work in process. Effect: The student personal information could be vulnerable. Repeat finding: No Recommendation: We recommend that the College designate an individual to oversee the information security function and work to update the College’s written security program to ensure compliance with all the standards. Views of responsible officials: Lincoln Land Community College (LLCC) acknowledges and takes seriously the audit findings presented, highlighting areas where compliance requirements were not met. These findings are crucial in ensuring the ongoing enhancement of our Information Security Program. To address these concerns LLCC has proactively taken several measures. In June 2022, the College appointed an IT Security and Assurance Manager, tasked with overseeing the Information Security Program and ensuring compliance with the Gramm-Leach-Bliley Act (GLBA). The Manager has played a pivotal role in developing a comprehensive roadmap to guide the continued evolution of our Information Security Program. This roadmap specifically outlines the steps required to address the identified deficiencies, as detailed in the schedule of findings document received from the CLA. LLCC affirms its agreement with the details provided in the document and has prioritized these findings as top-level concerns in the roadmap. Section III – Federal Award Findings and Questioned Costs (Continued) 2023 – 001 (Continued) Views of responsible officials (Continued) In the upcoming Fiscal Year 2024 (FY24), LLCC commits to diligently implementing the roadmap, with a focused emphasis on the following key areas: 1. Implementation and Periodic Review of Access Controls: The IT Security and Assurance Manager will lead efforts to establish robust access controls and ensure regular reviews to align with compliance requirements. 2. Encryption of Customer Information: Although informal procedures are in place, a comprehensive strategy for encrypting customer information both within the College’s system and during transit will be implemented to safeguard sensitive data. 3. Security Assessment of Applications: Rigorous evaluations, assessments, and testing procedures for applications transmitting sensitive information will be instituted to bolster the overall security posture. 4. Anticipation and Evaluation of System Changes: Proactive measures will be taken to anticipate and evaluate changes to the information system or network, ensuring a proactive stance against potential vulnerabilities, including the development of a formalized change management process. 5. Regular Testing and Monitoring: LLCC is committed to instituting regular testing, monitoring, and assessing protocols for established safeguards to ensure their ongoing effectiveness. 6. Implementation of Policies and Procedures: Policies and procedures will be refined and enforced to guarantee that personnel can effectively enact the information security program. 7. Monitoring Information System Service Providers: Development of a comprehensive approach to monitoring the College’s information system service providers has been initiated and will be established to ensure compliance with security standards. Lincoln Land Community College views this as an opportunity for continuous improvement and remains dedicated to upholding the highest standards of information security. The commitment to addressing these findings is integral to our ongoing efforts to safeguard sensitive information and maintain compliance with regulatory requirements.

Categories

Student Financial Aid Subrecipient Monitoring Significant Deficiency Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Other Findings in this Audit

  • 2952 2023-001
    Significant Deficiency
  • 2953 2023-001
    Significant Deficiency
  • 2954 2023-001
    Significant Deficiency
  • 2956 2023-002
    Significant Deficiency
  • 2957 2023-002
    Significant Deficiency
  • 2958 2023-002
    Significant Deficiency
  • 2959 2023-002
    Significant Deficiency
  • 2960 2023-003
    Significant Deficiency
  • 2961 2023-003
    Significant Deficiency
  • 2962 2023-003
    Significant Deficiency
  • 2963 2023-003
    Significant Deficiency
  • 579394 2023-001
    Significant Deficiency
  • 579395 2023-001
    Significant Deficiency
  • 579396 2023-001
    Significant Deficiency
  • 579397 2023-001
    Significant Deficiency
  • 579398 2023-002
    Significant Deficiency
  • 579399 2023-002
    Significant Deficiency
  • 579400 2023-002
    Significant Deficiency
  • 579401 2023-002
    Significant Deficiency
  • 579402 2023-003
    Significant Deficiency
  • 579403 2023-003
    Significant Deficiency
  • 579404 2023-003
    Significant Deficiency
  • 579405 2023-003
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.063 Federal Pell Grant Program $6.89M
84.268 Federal Direct Student Loans $5.71M
84.048 Career and Technical Education -- Basic Grants to States $437,163
84.002 Adult Education - Basic Grants to States $268,144
93.575 Child Care and Development Block Grant $266,050
84.042 Trio_student Support Services $261,018
84.007 Federal Supplemental Educational Opportunity Grants $175,242
21.027 Coronavirus State and Local Fiscal Recovery Funds $147,725
84.033 Federal Work-Study Program $146,734
84.335 Child Care Access Means Parents in School $90,413
17.268 H-1b Job Training Grants $60,000
17.261 Wia Pilots, Demonstrations, and Research Projects $55,457
10.558 Child and Adult Care Food Program $45,211
81.129 Energy Efficiency and Renewable Energy Technology Deployment, Demonstration and Commercialization $43,701
84.425 Education Stabilization Fund $42,415
20.205 Highway Planning and Construction $33,932
20.235 Commercial Motor Vehicle Operator Training Grants $26,520
11.307 Economic Adjustment Assistance $18,757
84.116 Fund for the Improvement of Postsecondary Education $18,064
20.112 Aviation Maintenance Technical Workforce Grant Program $7,178