Finding 389328 (2023-002)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2023
Accepted
2024-03-29
Audit: 300314
Organization: Chatham University (PA)

AI Summary

  • Core Issue: The University failed to comply with the Gramm-Leach-Bliley Act regarding oversight of information system service providers.
  • Impacted Requirements: The lack of a vendor management review process violates 16 CFR 314.4(f), which mandates oversight policies.
  • Recommended Follow-Up: Implement policies for regular vendor management reviews to enhance oversight of information system service providers.

Finding Text

Federal Program Information: Student Financial Assistance Cluster (ALN: Various), U.S. Department of Education. 2022-2023 Federal Award Year. 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 audit finding was based on 16 CFR 314.4(f), which requires that the University have a policy that addresses how the institution will oversee its information system service providers. Condition: The University does was not able to demonstrate its compliance with 16 CFR 314.4(f). Cause: The University does not currently have a vendor management review process in place. Effect or potential effect: Without consideration for oversight of its information system service providers, the University’s information system security program may not adequately address the risks that these service providers, and their systems, have on the University’s environment. Questioned Costs: None noted. Context: We were unable to verify that the University has a vendor management review process in place. Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that policies and procedures be put in place to ensure that regular vendor management reviews on information system service providers are conducted in an appropriate manner. Views of Responsible Officials: Management concurs with this finding. See management’s corrective action plan document.

Categories

Internal Control / Segregation of Duties

Other Findings in this Audit

  • 389325 2023-002
    Significant Deficiency
  • 389326 2023-002
    Significant Deficiency
  • 389327 2023-002
    Significant Deficiency
  • 965767 2023-002
    Significant Deficiency
  • 965768 2023-002
    Significant Deficiency
  • 965769 2023-002
    Significant Deficiency
  • 965770 2023-002
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $29.11M
84.063 Federal Pell Grant Program $1.54M
93.732 Mental and Behavioral Health Education and Training Grants $575,210
10.175 Farmers Market and Local Food Promotion Program (b) $256,283
59.043 Women's Business Ownership Assistance $197,024
93.778 Medical Assistance Program $169,991
84.033 Federal Work-Study Program $156,943
47.074 Biological Sciences $152,802
84.007 Federal Supplemental Educational Opportunity Grants $48,000
93.243 Substance Abuse and Mental Health Services_projects of Regional and National Significance $38,411
47.075 Social, Behavioral, and Economic Sciences $21,527