Finding 3722 (2023-001)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2023
Accepted
2023-12-08

AI Summary

  • Core Issue: The University failed to include multi-factor authentication and a security program for vendor due diligence in its GLBA policies.
  • Impacted Requirements: This noncompliance affects the University's adherence to the Gramm-Leach-Bliley Act safeguards for protecting nonpublic personal information.
  • Recommended Follow-Up: The University should update its GLBA policy and procedures manual to ensure compliance with all required components.

Finding Text

2023–001 GLBA Risk Assessment Requirements Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Aid Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: P007A234487-2023, P268K242432-2023, P063P222432-2023, P033A224487-2023 Award Period: August 1, 2022 to July 31, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: The Gramm-Leach-Bliley Act (GLBA) provides for the design and implementation of safeguards to control the risks the institution identifies through its risk assessment (16 CFR 314.4(c)). At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8). The eight minimum safeguards that the written information security program must address are summarized as follows: • Implement and periodically review access controls. • Conduct a periodic inventory of data, noting where it’s collected, stored, or transmitted. • Encrypt customer information on the institution’s system and when it’s in transit. • Assess apps developed by the institution • Implement multi-factor authentication for anyone accessing customer information on the institution’s system • Dispose of customer information securely • Anticipate and evaluate changes to the information system or network. • Maintain a log of authorized users’ activity and keep an eye out for unauthorized access. • Provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d)). • Provides for the implementation of policies and procedures to ensure that personnel are able to enact the information security program (16 CFR 314.4(e)(1)). • Addresses how the institution will oversee its information system service providers (16 CFR 314.4(f)). • Provides for the evaluation and adjustment of its information security program in light of the results of the required testing and monitoring; any material changes to its operations or business arrangements; the results of the required risk assessments; or any other circumstances that it knows or has reason to know may have a material impact the institution’s information security program (16 CFR 314.4(g)). Condition: Upon reviewing the GLBA policies and procedures it was noted that University did not include the following required components as required in the stated criteria: • Multi-factor authentication, • Security program including vendor due diligence. Questioned costs: None noted. Context: The noncompliance with the stated criteria was identified in conjunction with our review of the GLBA policies and procedures manual and related supporting documentation. Cause: The University failed to include the multi-factor authentication and the security program including vendor due diligence in its GLBA policy and procedures manual and related supporting documentation. Effect: The University does not comply with certain requirements of the GLBA, as noted in the condition, which governs the treatment of nonpublic personal information about consumers. Repeat Finding: No Recommendation: We recommend that the University consider any modifications to the GLBA policy and procedures manual and related supporting documentation to ensure compliance with the stated criteria. Views of responsible officials: There is no disagreement with the audit finding.

Corrective Action Plan

U.S. Department of Education 2023-001 Student Financial Aid Cluster – Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend that the University consider any modifications to the GLBA policy and procedures manual and related supporting documentation to ensure compliance with the stated criteria. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: As part of the University winding down operations, and no longer providing educational services, University management will consider any modifications to the GLBA policy and procedures manual and related supporting documentation to ensure compliance with the state criteria. Name(s) of the contact person(s) responsible for corrective action: Rachel Nielsen, Vice President of Finance and Administration Planned completion date for corrective action plan: July 31, 2024

Categories

Subrecipient Monitoring Significant Deficiency

Other Findings in this Audit

  • 3723 2023-002
    Material Weakness
  • 3724 2023-001
    Significant Deficiency
  • 3725 2023-002
    Material Weakness
  • 3726 2023-001
    Significant Deficiency
  • 3727 2023-002
    Material Weakness
  • 3728 2023-001
    Significant Deficiency
  • 3729 2023-002
    Material Weakness
  • 3730 2023-001
    Significant Deficiency
  • 3731 2023-002
    Material Weakness
  • 580164 2023-001
    Significant Deficiency
  • 580165 2023-002
    Material Weakness
  • 580166 2023-001
    Significant Deficiency
  • 580167 2023-002
    Material Weakness
  • 580168 2023-001
    Significant Deficiency
  • 580169 2023-002
    Material Weakness
  • 580170 2023-001
    Significant Deficiency
  • 580171 2023-002
    Material Weakness
  • 580172 2023-001
    Significant Deficiency
  • 580173 2023-002
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $5.00M
84.063 Federal Pell Grant Program $1.00M
84.038 Federal Perkins Loan Program $351,749
84.007 Federal Supplemental Educational Opportunity Grants $82,888
84.033 Federal Work-Study Program $26,061
84.334 Gaining Early Awareness and Readiness for Undergraduate Programs $3,000