Finding 377347 (2023-002)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2023
Accepted
2024-03-14
Audit: 295133
Organization: Edgewood College, Inc. (WI)

AI Summary

  • Core Issue: The College lacked documented controls to ensure compliance with GLBA Safeguards by the June 9, 2023 deadline.
  • Impacted Requirements: Compliance with the revised information security program standards under 16 CFR Part 314 is essential for safeguarding student data.
  • Recommended Follow-Up: The College should review and document its information security program to confirm compliance with Uniform Guidance and GLBA requirements.

Finding Text

Agencies: U.S Department of Education Federal Assistance Listing Number: 84.038, 84.063, 84.007, 84.033, 84.268, and 84.379 Programs: Student financial assistance cluster Criteria: The College is required to have documented internal controls in place to monitor compliance over special tests in accordance with the Uniform Guidance. On December 9, 2021, the Federal Trade Commission issued final regulations for 16 Code of Federal Regulations Part 314 to implement the Gramm-Leach-Bliley Act (GLBA) information safeguarding standards that institutions must implement. These regulations significantly modified the requirements that institutions must meet under GLBA. The regulations established minimum standards that institutions must meet. The FTC stated that it “believes many of the requirements set forth in the Final Rule are so fundamental to any information security program that the information security programs of many financial institutions will already include them if those programs are in compliance with the current Safeguards Rule.” Institutions are required to be in compliance with the revised requirements no later June 9, 2023. Institutions are required to develop, implement and maintain a comprehensive information security program that is written in one or more readily accessible parts. Condition: The College did not have documented controls in place reviewing that the comprehensive information security program was in compliance with the Safeguards Rule and was prepared and in place by June 9, 2023. The College did meet the compliance requirements. Questioned Costs: The amount of questioned costs could not be determined. Context: The College is required to have documented controls in place to ensure the College has completed information security program available on or before June 9, 2023. Management could not provide documentation that a review occurred. Cause: The College did not have proper documented controls in place to ensure that the College was compliant with GLBA Safeguards requirements in the timeframe specified by 16 CFR Part 314. Effect: The ability to adequately safeguard student electronic data may be compromised if the College does not have controls in place to ensure that a timely-prepared information security program to define the various ways in which data is protected is completed. Recommendation: We recommend the College review their policies and procedures in place ensure that the information security program review is documented to support the College’s compliance under the Uniform Guidance. Management Response: Management agrees and has implemented necessary procedures/controls to ensure the College is in compliance with enrollment requirements.

Categories

Internal Control / Segregation of Duties Special Tests & Provisions

Other Findings in this Audit

  • 377339 2023-001
    Material Weakness
  • 377340 2023-001
    Material Weakness
  • 377341 2023-001
    Material Weakness
  • 377342 2023-001
    Material Weakness
  • 377343 2023-001
    Material Weakness
  • 377344 2023-001
    Material Weakness
  • 377345 2023-002
    Significant Deficiency
  • 377346 2023-002
    Significant Deficiency
  • 377348 2023-002
    Significant Deficiency
  • 377349 2023-002
    Significant Deficiency
  • 377350 2023-002
    Significant Deficiency
  • 953781 2023-001
    Material Weakness
  • 953782 2023-001
    Material Weakness
  • 953783 2023-001
    Material Weakness
  • 953784 2023-001
    Material Weakness
  • 953785 2023-001
    Material Weakness
  • 953786 2023-001
    Material Weakness
  • 953787 2023-002
    Significant Deficiency
  • 953788 2023-002
    Significant Deficiency
  • 953789 2023-002
    Significant Deficiency
  • 953790 2023-002
    Significant Deficiency
  • 953791 2023-002
    Significant Deficiency
  • 953792 2023-002
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $10.64M
84.063 Federal Pell Grant Program $1.32M
84.038 Federal Perkins Loan Program $547,665
84.033 Federal Work-Study Program $157,011
84.007 Federal Supplemental Educational Opportunity Grants $98,715
84.379 Teacher Education Assistance for College and Higher Education Grants (teach Grants) $36,835