Finding 4226 (2023-002)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2023
Accepted
2023-12-13
Audit: 6549
Organization: Centenary College of Louisiana (LA)
Auditor: Forvis LLP

AI Summary

  • Core Issue: The College has not implemented the revised GLBA regulations by the required date, risking sensitive data protection.
  • Impacted Requirements: The College must develop a written information security program that includes at least seven specific elements to comply with GLBA.
  • Recommended Follow-Up: Complete the risk assessment and ensure all required GLBA elements are integrated into the security program, aiming for 80% compliance by FY24 and full compliance by FY25.

Finding Text

Criteria or specific requirement – Special Tests and Provisions – Gramm-Leach-Bliley Act (16 CFR 314) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. 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 (GLBA) because they appear to be significantly engaged in wiring funds to consumers (16 CFR 313.3(k)(2)(vi)). Institutions agree to comply with GLBA in their Program Participation Agreement with ED. Institutions must protect student financial aid information, with particular attention to information provided to institutions by ED or otherwise obtained in support of the administration of the Federal student financial aid programs (16 CFR 314.3; HEA 483(a)(3)(E) and HEA 485B(d)(2)). Condition – The College must have a written information security program that addresses the required minimum seven elements. Questioned costs - $0 Context – The College is in the process of performing a risk assessment that will be used to generate the written information security program. The College has designated their Chief Information Officer as the qualified individual responsible for implementing and monitoring their information security program. They have started addressing the additional six required elements, including reviewing access controls, implementing multi-factor authentication for students, disposing of student information securely, and performing annual penetration testing but they are still in the process of reviewing the log for unauthorized access, implementing multi-factor authentication for staff and faculty with access to student information, implementing policies and procedures to ensure that personnel are able to enact the information security program and encrypting all information on the institution’s system and when it’s in transit. Effect – The College did not implement the revised GLBA regulations by the required date. Cause – The College’s controls did not ensure the revised GLBA regulations were implemented by the required date. Identification of repeat finding, if applicable – N/A Recommendation –The College should complete the risk assessment and implement a written information security program and ensure the additional six required GLBA elements are included in the program. Views of responsible officials and planned corrective actions – The College will continue to make progress of meeting the federal standards related to the GLBA security program. The college expects to at minimum 80% in compliance by the end of FY24 and in full compliance by the end of FY25. The college will prioritize key elements such as reviewing access controls, implementing multi-factor authentication for the campus, disposing of student information securely, performing annual penetration testing, and encrypting all the institution's information.

Categories

Subrecipient Monitoring Special Tests & Provisions Student Financial Aid

Other Findings in this Audit

  • 4220 2023-001
    Significant Deficiency
  • 4221 2023-001
    Significant Deficiency
  • 4222 2023-001
    Significant Deficiency
  • 4223 2023-001
    Significant Deficiency
  • 4224 2023-002
    Significant Deficiency
  • 4225 2023-002
    Significant Deficiency
  • 4227 2023-002
    Significant Deficiency
  • 580662 2023-001
    Significant Deficiency
  • 580663 2023-001
    Significant Deficiency
  • 580664 2023-001
    Significant Deficiency
  • 580665 2023-001
    Significant Deficiency
  • 580666 2023-002
    Significant Deficiency
  • 580667 2023-002
    Significant Deficiency
  • 580668 2023-002
    Significant Deficiency
  • 580669 2023-002
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $3.71M
84.063 Federal Pell Grant Program $1.02M
84.038 Federal Perkins Loan Program $346,506
84.033 Federal Work-Study Program $142,182
84.007 Federal Supplemental Educational Opportunity Grants $59,576
47.074 Biological Sciences $33,124