Finding 384211 (2023-002)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2023
Accepted
2024-03-25
Audit: 297294
Organization: Illinois Wesleyan University (IL)

AI Summary

  • Core Issue: The University has a significant deficiency in its internal controls regarding compliance with the Gramm-Leach-Bliley Act, which requires safeguarding student financial aid information.
  • Impacted Requirements: Key compliance areas lacking include approval of security leadership, encryption controls, security testing standards, multi-factor authentication, and regular security assessments.
  • Recommended Follow-Up: Designate a responsible individual to oversee the information security program and update the security policies to meet all compliance standards.

Finding Text

2023 – 002: Special Tests and Provisions: Gramm-Leach-Bliley Act 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), 84.038 (Federal Perkins Loan Program), 84.063 (Federal Pell Grant Program), 84.268 (Federal Direct Student Loans Program), 93.364 (Nursing Student Loans) Federal Award Identification Number and Year: N/A; 2022-2023 Award Period: August 1, 2022 – July 31, 2023 Pass-Through Agency: N/A Pass-Through Numbers: N/A Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters 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 Context: During our testing of the University’s information technology, we noted the following items in the University’s written security program did not meet the following compliance requirements: • Identify the approval of the appropriate individual leading the information security program • The use of encryption controls in transit on the University's systems • The standards for evaluating, assessing or testing the security of externally developed applications that transmit sensitive information • The use of multi-factor authentication for individuals accessing sensitive information across systems • The processes to perform an annual penetration test and semi-annual vulnerability assessments Cause: The University has continued to make progress in updating the University’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 University designate an individual to oversee the information security function and work to update the University’s written security program to ensure compliance with all the standards. Views of responsible officials: There is no disagreement with the audit finding.

Categories

Student Financial Aid Special Tests & Provisions Significant Deficiency Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Other Findings in this Audit

  • 384203 2023-001
    Significant Deficiency
  • 384204 2023-001
    Significant Deficiency
  • 384205 2023-001
    Significant Deficiency
  • 384206 2023-001
    Significant Deficiency
  • 384207 2023-001
    Significant Deficiency
  • 384208 2023-001
    Significant Deficiency
  • 384209 2023-002
    Significant Deficiency
  • 384210 2023-002
    Significant Deficiency
  • 384212 2023-002
    Significant Deficiency
  • 384213 2023-002
    Significant Deficiency
  • 384214 2023-002
    Significant Deficiency
  • 960645 2023-001
    Significant Deficiency
  • 960646 2023-001
    Significant Deficiency
  • 960647 2023-001
    Significant Deficiency
  • 960648 2023-001
    Significant Deficiency
  • 960649 2023-001
    Significant Deficiency
  • 960650 2023-001
    Significant Deficiency
  • 960651 2023-002
    Significant Deficiency
  • 960652 2023-002
    Significant Deficiency
  • 960653 2023-002
    Significant Deficiency
  • 960654 2023-002
    Significant Deficiency
  • 960655 2023-002
    Significant Deficiency
  • 960656 2023-002
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $10.68M
84.063 Federal Pell Grant Program $1.88M
93.364 Nursing Student Loans $1.86M
84.038 Federal Perkins Loan Program $1.35M
47.076 Education and Human Resources $510,608
84.033 Federal Work-Study Program $290,931
84.007 Federal Supplemental Educational Opportunity Grants $238,000
47.049 Mathematical and Physical Sciences $88,401
59.037 Small Business Development Centers $1,457
47.075 Social, Behavioral, and Economic Sciences $0
84.425 Education Stabilization Fund $0