Finding 42788 (2022-004)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2022
Accepted
2023-03-29
Audit: 39988
Organization: Chicago State University (IL)

AI Summary

  • Core Issue: The University failed to conduct a required risk assessment for student financial aid information security, risking noncompliance with federal regulations.
  • Impacted Requirements: Compliance with the Gramm-Leach-Bliley Act (GLBA) and Uniform Guidance, which mandate effective internal controls and risk assessments.
  • Recommended Follow-Up: The University should enhance controls to ensure risk assessments are performed and documented for all identified risks related to student information security.

Finding Text

2022-004. FINDING Noncompliance with Special Tests and Provisions ? Student Financial Aid Information Security Federal Agency: U.S. Department of Education Assistance Listing Numbers: 84.007; 84.033; 84.038; 84.063; 84.268; 84.379; 93.925 Program Names: Student Financial Assistance Cluster - Federal Supplemental Educational Opportunity Grants Federal Work-Study Program Federal Perkins Loan Program Federal Pell Grant Program Federal Direct Student Loans Teacher Education Assistance for College and Higher Education Grants Scholarships for Health Professions Students from Disadvantaged Background Program Expenditures: $359,412; $432,302; $1,264,604; $4,213,853; $20,166,174; $26,878; $860,306 Award Numbers: P007A221121; P033A221121; P063P211351; P268K221351; P379T221351 Questioned Costs: None The Chicago State University (University) did not perform risk assessment procedures and document safeguards for each risk identified in relation to student financial aid information. According to the University?s Program Participation Agreement with the Department of Education, the University is required to protect student financial aid information. During our testing, we noted the University had not conducted a risk assessment identifying internal and external risks to the security, confidentiality, and integrity of student information. The Standards for Safeguarding Customer Information, required by the Gramm-Leach-Bliley Act (GLBA) (16 CFR ? 314.4 (b)), require the University to identify reasonable foreseeable internal and external risks to the security, confidentiality, and integrity of student information that could result in the unauthorized disclosure, misuse, alteration, destruction or other compromise of such information, and assess the sufficiency of any safeguards in place to control these risks. At a minimum, such a risk assessment should include consideration of risk in each relevant area of operations, including: 2022-004. FINDING Noncompliance with Special Tests and Provisions ? Student Financial Aid Information Security (Continued) (1) Employee training and management; (2) Information systems, including network and software design, as well as information processing, storage, transmission and disposal; and (3) Detecting, preventing and responding to attacks, intrusions, or other system failures. Additionally, the Uniform Guidance (2 CFR ? 200.303) requires nonfederal entities receiving federal awards to establish and maintain effective internal control designed to reasonably ensure compliance with federal laws, statutes, regulations, and the terms and conditions of the federal award. In addition, the Framework for Improving Critical Infrastructure Cybersecurity published by the National Institute of Standards and Technology (NIST) requires entities to perform a risk assessment and establish a risk mitigation plan to minimize identified risks. University management indicated the issues were due to the vacancy of an Information Technology Security Officer position. Without a risk assessment, the University is at risk of noncompliance with the GLBA. In addition, the University?s systems and information could be vulnerable to attacks or intrusions, and these attacks may not be detected in a timely manner. (Finding Code No. 2022-004) RECOMMENDATION We recommend the University strengthen controls to ensure adequate risk assessment procedures are performed and documentation of safeguards for each risk identified in relation to student information security is maintained. UNIVERSITY RESPONSE The University agrees with the finding and is developing a corrective action plan for implementation.

Categories

Student Financial Aid Matching / Level of Effort / Earmarking Special Tests & Provisions Subrecipient Monitoring

Other Findings in this Audit

  • 42782 2022-004
    Significant Deficiency
  • 42783 2022-004
    Significant Deficiency
  • 42784 2022-004
    Significant Deficiency
  • 42785 2022-004
    Significant Deficiency
  • 42786 2022-003
    Significant Deficiency
  • 42787 2022-003
    Significant Deficiency
  • 42789 2022-005
    Significant Deficiency
  • 42790 2022-005
    Significant Deficiency
  • 42791 2022-004
    Significant Deficiency
  • 42792 2022-004
    Significant Deficiency
  • 42793 2022-006
    Significant Deficiency Repeat
  • 619224 2022-004
    Significant Deficiency
  • 619225 2022-004
    Significant Deficiency
  • 619226 2022-004
    Significant Deficiency
  • 619227 2022-004
    Significant Deficiency
  • 619228 2022-003
    Significant Deficiency
  • 619229 2022-003
    Significant Deficiency
  • 619230 2022-004
    Significant Deficiency
  • 619231 2022-005
    Significant Deficiency
  • 619232 2022-005
    Significant Deficiency
  • 619233 2022-004
    Significant Deficiency
  • 619234 2022-004
    Significant Deficiency
  • 619235 2022-006
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $20.17M
84.063 Federal Pell Grant Program $4.21M
84.038 Federal Perkins Loan Program $1.26M
93.925 Scholarships for Health Professions Students From Disadvantaged Backgrounds $860,306
84.047 Trio_upward Bound $854,993
84.382 Strengthening Minority-Serving Institutions $608,442
84.425 Education Stabilization Fund $526,079
84.033 Federal Work-Study Program $432,302
84.066 Trio_educational Opportunity Centers $428,376
84.007 Federal Supplemental Educational Opportunity Grants $359,412
93.600 Head Start $221,355
84.325 Special Education - Personnel Development to Improve Services and Results for Children with Disabilities $207,342
47.049 Mathematical and Physical Sciences $82,227
93.859 Biomedical Research and Research Training $74,068
47.074 Biological Sciences $37,675
84.031 Higher Education_institutional Aid $35,734
43.008 Office of Stem Engagement $31,059
47.076 Education and Human Resources $27,547
84.379 Teacher Education Assistance for College and Higher Education Grants (teach Grants) $26,878
94.006 Americorps $26,380
45.312 National Leadership Grants $24,509
43.002 Aeronautics $22,157
45.310 Grants to States $18,747
43.008 Education $18,650
93.575 Child Care and Development Block Grant $16,837
84.335 Child Care Access Means Parents in School $12,458
47.070 Computer and Information Science and Engineering $2,482
93.093 Affordable Care Act (aca) Health Profession Opportunity Grants $1,211