Finding 384360 (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.

Categories

Subrecipient Monitoring Significant Deficiency

Other Findings in this Audit

  • 384358 2023-001
    Material Weakness Repeat
  • 384359 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