Finding 381080 (2023-003)

Material Weakness
Requirement
P
Questioned Costs
$1
Year
2023
Accepted
2024-03-19
Audit: 295826

AI Summary

  • Core Issue: The College failed to comply with the Gramm-Leach-Bliley Act (GLBA) by not having a designated Qualified Individual or a comprehensive information security program by the June 9, 2023 deadline.
  • Impacted Requirements: The College did not meet the GLBA safeguarding standards, specifically the requirement to develop and maintain a written information security program that includes all necessary elements.
  • Recommended Follow-Up: Designate a Qualified Individual to oversee GLBA compliance and create a written information security program that addresses all required elements.

Finding Text

Finding 2023-003: Student Financial Assistance Cluster Gramm-Leach-Bliley Act – Student Information Security Federal Agency: U.S. Department of Education Program: Student Financial Assistance Cluster (84.007, 84.033, 84.063, 84.268) 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 the program’s compliance with the requirements of the GLBA was not operating effectively. The College did not designate a Qualified Individual responsible for a written information security program, nor did it create such a program that addresses the six required minimum elements prior to June 9, 2023. Cause: Procedures were not in place to ensure the College was in compliance with the requirements of the GLBA. Effect: The College 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 the College designate a Qualified Individual responsible for implementing and monitoring all GLBA requirements, and ensure that the written information security program addressing all required minimum elements is created and implemented. View of Responsible Officials and Planned Corrective Action: Management agrees, see separate Corrective Action Plan.

Categories

Questioned Costs Subrecipient Monitoring Internal Control / Segregation of Duties

Other Findings in this Audit

  • 381078 2023-003
    Material Weakness
  • 381079 2023-003
    Material Weakness
  • 381081 2023-003
    Material Weakness
  • 957520 2023-003
    Material Weakness
  • 957521 2023-003
    Material Weakness
  • 957522 2023-003
    Material Weakness
  • 957523 2023-003
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $3.03M
84.063 Federal Pell Grant Program $1.89M
11.307 Covid-19 Economic Adjustment Assistance $324,152
84.048 Career and Technical Education -- Basic Grants to States $263,666
10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program $155,335
64.028 Post-9/11 Veterans Educational Assistance $150,222
84.425 Covid-19 Education Stabilization Fund $72,573
84.007 Federal Supplemental Educational Opportunity Grants $46,005
17.245 Trade Adjustment Assistance $36,514
93.558 Temporary Assistance for Needy Families $10,381
84.033 Federal Work-Study Program $9,090