Identifying Number: Finding No. 2023-002: Special Tests – Enrollment Reporting and Gramm-Leach-Bliley Act
Compliance/Material Weakness
Finding: Instances of noncompliance have been identified around major compliance requirements Enrollment Reporting and Gramm-Bleach-Bliley Act, which are both part of special tests identified in the 2023 Compliance Supplement. ¬
Corrective Actions Taken or Planned:
Responsible Official: Iman Riddick, Registrar, Dean Lane, Chief Information Officer (CIO)
Anticipated Completion Date: 06/30/2024
View of Responsible Individuals:
Management agrees with the assessment and finding. Dean Lane, CIO, will review the annual updates to the Student Financial Assistance Cluster within the OMB Compliance Supplement to ensure the Institute has policies, procedures, and controls in place for all required compliance requirements.
For the noncompliance identified around the Gramm-Leach Bliley Act, the Institute will ensure compliance by establishing a formal written policy that will be created by Dean Lane, CIO, that addresses all required elements for a written information security program listed in the OMB Compliance Supplement. The CFO will review the policy once completed to ensure all required elements within the Compliance Supplement are included.
For the noncompliance identified around the Enrollment Reporting special test, the Institute plans to have the Registrar attend comprehensive trainings around enrollment reporting offered by the National Student
Clearinghouse (NSC) to further educate and enhance their understanding around the enrollment reporting compliance requirement. In addition, the Institute will have each month’s enrollment data submission by the Registrar to the National Student Clearinghouse reviewed by the Director of Financial Aid to verify completeness, accuracy, and timeliness of reporting. This will allow the Institute to correct any inaccurate reporting and verify timely submissions.