Finding 370096 (2023-005)

Material Weakness
Requirement
P
Questioned Costs
$1
Year
2023
Accepted
2024-02-22

AI Summary

  • Core Issue: WCCC failed to have a compliant information security program for the Gramm-Leach-Bliley Act (GLBA) by the June 9, 2023 deadline.
  • Impacted Requirements: Compliance with GLBA safeguarding standards, specifically the development and maintenance of a comprehensive information security program.
  • Recommended Follow-Up: Ensure ongoing review and integration of GLBA requirements into the finalized information security program and monitor compliance regularly.

Finding Text

Finding 2023-005: Student Financial Assistance Cluster Gramm-Leach-Bliley Act – Student Information Security Federal Agency: Department of Education Program: Student Financial Assistance Cluster Criteria: In accordance 16 CFR Part 314, institutions receiving Student Financial Assistance Cluster funding were required to be in compliance with the revised requirements of the Gramm-Leach-Bliley Act (GLBA) information safeguarding standards by June 9, 2023. Included in these standards is the institution’s requirement to develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts and includes the required elements included in 16 CFR 314.4. Condition: The internal control system to ensure that that the program’s compliance with the requirements of the GLBA was not operating effectively. WCCC is in the process of creating a written information security program that addresses the required minimum elements; however, that written program was not in place prior to June 9, 2023. Cause: Procedures in place to ensure WCCC was in compliance with the requirements of the GLBA were not adequate. Effect: WCCC was not in compliance with the GLBA requirements for Student Financial Aid funds. Repeat Finding: This is not a repeat finding. Questioned costs: Unknown Recommendation: We recommend that WCCC implement a procedure to ensure that all required GLBA requirements are reviewed, and those requirements are included in the written information security program once it is completed. View of Responsible Officials and Planned Corrective Action: WCCC created a written information security program that addresses the required minimum elements. The condition was corrected by implementing the security plan and following the guidelines of the GLBA. The plan was implemented as of 12/1/23. Moving forward we will continue to monitor the requirements of GLBA.

Categories

Questioned Costs Internal Control / Segregation of Duties

Other Findings in this Audit

  • 370088 2023-003
    Material Weakness
  • 370089 2023-004
    Material Weakness
  • 370090 2023-005
    Material Weakness
  • 370091 2023-003
    Material Weakness
  • 370092 2023-004
    Material Weakness
  • 370093 2023-005
    Material Weakness
  • 370094 2023-003
    Material Weakness
  • 370095 2023-004
    Material Weakness
  • 370097 2023-003
    Material Weakness
  • 370098 2023-004
    Material Weakness
  • 370099 2023-005
    Material Weakness
  • 370100 2023-001
    Material Weakness Repeat
  • 370101 2023-002
    Material Weakness
  • 370102 2023-001
    Material Weakness Repeat
  • 370103 2023-002
    Material Weakness
  • 370104 2023-001
    Material Weakness Repeat
  • 370105 2023-002
    Material Weakness
  • 370106 2023-001
    Material Weakness Repeat
  • 370107 2023-002
    Material Weakness
  • 946530 2023-003
    Material Weakness
  • 946531 2023-004
    Material Weakness
  • 946532 2023-005
    Material Weakness
  • 946533 2023-003
    Material Weakness
  • 946534 2023-004
    Material Weakness
  • 946535 2023-005
    Material Weakness
  • 946536 2023-003
    Material Weakness
  • 946537 2023-004
    Material Weakness
  • 946538 2023-005
    Material Weakness
  • 946539 2023-003
    Material Weakness
  • 946540 2023-004
    Material Weakness
  • 946541 2023-005
    Material Weakness
  • 946542 2023-001
    Material Weakness Repeat
  • 946543 2023-002
    Material Weakness
  • 946544 2023-001
    Material Weakness Repeat
  • 946545 2023-002
    Material Weakness
  • 946546 2023-001
    Material Weakness Repeat
  • 946547 2023-002
    Material Weakness
  • 946548 2023-001
    Material Weakness Repeat
  • 946549 2023-002
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $8.41M
84.063 Federal Pell Grant Program $5.36M
84.425 Covid-19 Education Stabilization Fund $427,682
84.048 Career and Technical Education -- Basic Grants to States $391,243
84.042 Trio_student Support Services $313,180
84.007 Federal Supplemental Educational Opportunity Grants $218,500
64.027 Post-9/11 Veterans Educational Assistance $186,058
93.558 Temporary Assistance for Needy Families $94,876
17.235 Senior Community Service Employment Program $66,524
23.011 Appalachian Research, Technical Assistance, and Demonstration Projects $47,604
84.033 Federal Work-Study Program $34,440
93.324 State Health Insurance Assistance Program $33,394
94.002 Retired and Senior Volunteer Program $31,793
12.006 National Defense Education Program $14,675
64.116 Veterans Readiness and Employment $5,392
11.307 Covid-19 Economic Adjustment Assistance $207