Finding 384359 (2023-002)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2023
Accepted
2024-03-25
Audit: 297474
Organization: Eastern University (PA)
Auditor: Capincrouse LLP

AI Summary

  • Core Issue: The University is not fully complying with the updated requirements of the Gramm-Leach-Bliley Act (GLBA).
  • Impacted Requirements: Key areas include the written information security program, risk assessments, multi-factor authentication, vendor management, and incident response plans.
  • Recommended Follow-Up: Allocate necessary resources to meet GLBA requirements and implement corrective actions as agreed by management.

Finding Text

Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, and 84.379 Student Financial Assistance Cluster Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The University did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $-0- Context: The University has not updated its written information security program in alignment with the revised regulations; sufficiently documented its security risk assessment and safeguards, including general threats; implemented multi-factor authentication on systems containing personally identifiable information (PII); implemented continuous monitoring, such as penetration testing and vulnerability scanning; implemented sufficient vendor management policies and reviews; implemented an incident response plan; or provided a written, annual report to the board. Cause: The University has not allocated sufficient resources to address and document compliance with the updated requirements of GLBA. Effect: The University has not adequately addressed the updated requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the University allocate sufficient resources to address all updated requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Corrective Action Plan

Gramm-Leach-Bliley Act (GLBA) Compliance Planned Corrective Action: The University concurs with the audit finding of partial compliance and recognizes the need to fully comply with GLBA regulations. The University has updated its written risk assessment. The University is working on improving safeguards, improving continuous monitoring provided from a vendor, implementing procedures for staff training which will be required for all employees, implementing procedures for assessing service providers, documenting an incident response plan, and completing a written annual status report to the board. Person Responsible for Corrective Action Plan: Eric McCloy, CIO Anticipated Date of Completion: April 30, 2024. Board report will be June 30, 2024.

Categories

Subrecipient Monitoring Significant Deficiency

Other Findings in this Audit

  • 384358 2023-001
    Material Weakness Repeat
  • 384360 2023-002
    Significant Deficiency
  • 384361 2023-002
    Significant Deficiency
  • 384362 2023-002
    Significant Deficiency
  • 384363 2023-002
    Significant Deficiency
  • 384364 2023-002
    Significant Deficiency
  • 384365 2023-003
    - Repeat
  • 960800 2023-001
    Material Weakness Repeat
  • 960801 2023-002
    Significant Deficiency
  • 960802 2023-002
    Significant Deficiency
  • 960803 2023-002
    Significant Deficiency
  • 960804 2023-002
    Significant Deficiency
  • 960805 2023-002
    Significant Deficiency
  • 960806 2023-002
    Significant Deficiency
  • 960807 2023-003
    - Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $29.60M
84.063 Federal Pell Grant Program $3.16M
84.038 Federal Perkins Loan Program $369,563
84.031 Higher Education Institutional Aid - Developing Hispanic Serving Institutions $330,121
84.033 Federal Work-Study Program $246,466
84.007 Federal Supplemental Educational Opportunity Grants $233,430
84.184 Safe and Drug-Free Schools and Communities_national Programs $204,632
84.425 Covid-19 Education Stabilization Fund Heerf - Institutional Portion $90,928
84.425 Covid-19 Education Stabilization Fund Heerf - Minority Serving Institutions $55,383
84.379 Teacher Education Assistance for College and Higher Education Grants (teach Grants) $26,874
84.335 Child Care Access Means Parents in School $11,421