Finding 44053 (2022-004)

Significant Deficiency Repeat Finding
Requirement
N
Questioned Costs
-
Year
2022
Accepted
2023-06-14
Audit: 47493
Auditor: Moss Adams LLP

AI Summary

  • Core Issue: The College failed to conduct a required risk assessment for student information security under the Gramm-Leach-Bliley Act, leading to a significant deficiency in internal controls.
  • Impacted Requirements: Compliance with the Gramm-Leach-Bliley Act mandates protections for student financial aid information, specifically in employee training, information systems, and response to security threats.
  • Recommended Follow-Up: Ensure the Chief Information Officer finalizes and maintains the risk assessment documentation, with annual reviews to uphold compliance and address identified action items by October 2023.

Finding Text

FINDING 2022-004 ? Special Tests and Provisions ? Gramm-Leach-Bliley Act ? Student Information Security; Significant Deficiency in Internal Control over Compliance Student Financial Assistance Cluster U.S. Department of Education Assistance Listing Numbers: 84.063, 84.007, 84.033 Federal Program Name: Student Financial Assistance Cluster Award Year: 2021-22 Criteria: 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 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 (16 CFR 313.3(k)(2)(vi). Under an institution?s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department 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 and context: A written risk assessment wasn?t performed that addressed the three required areas noted in 6 CFR 314.4 (b), which are (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 systems failures until September 2022. Questioned costs: None Effect: The College does have limited controls in place surrounding student information security, which limits the effect of non-compliance. Cause: The finding and significant deficiency is due to a prior lack of understanding over the compliance requirement during the first half of the year and delays in implementation due to COVID-19. Repeat finding: Yes, 2021-004 Recommendation: We recommended the College?s designated individual should finalize and complete documentation surrounding the risk assessment that addresses the three required areas noted in 16 CFR 314.4 (b), which are (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 systems failures. This should be in place for the entire fiscal year. Views of responsible officials and planned corrective actions: The College has designated the Chief Information Officer (CIO) and on the following Items were completed in September 2022: a. ASCC Data / Information Security Program b. Risk Assessment that addresses (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 systems failures. The risk assessment identified action items to resolve findings and controls that are put in place in the meantime. Action Items and controls are reviewed and updated monthly. In November 2022, The Federal Student Aid (FSA) Cyber Compliance Team confirmed that ASCC has satisfied the minimum information security requirements under Gramm-Leach-Bliley Act (GLBA) and closed its. The next annual complete Risk Assessment will be completed in August 2023, and ASCC will continue to complete a Risk Assessment annually to stay in compliance with GLBA. Anticipated completion of the corrective action is expected by October 2023.

Corrective Action Plan

Contact Person(s): Grace Tulafono-Asi, Information Officer Sonny Leomiti, Vice President of Administration and Finance Explanation and specific reasons for disagreement with the audit finding or that corrective action is not required (if applicable): No disagreement Corrective actions taken/planned: The College has designated the Chief Information Officer (CIO) and on the following Items were completed in September 2022: a.ASCC Data / Information Security Program b.Risk Assessment that addresses (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 systems failures. The risk assessment identified action items to resolve findings and controls that are put in place in the meantime. Action Items and controls are reviewed and updated monthly. In November 2022, The Federal Student Aid (FSA) Cyber Compliance Team confirmed that ASCC has satisfied the minimum information security requirements under Gramm-Leach-Bliley Act (GLBA) and closed its. The next annual complete Risk Assessment will be completed in August 2023, and ASCC will continue to complete a Risk Assessment annually to stay in compliance with GLBA. Anticipated completion of the corrective action is expected by October 2023.

Categories

Special Tests & Provisions Student Financial Aid Subrecipient Monitoring Significant Deficiency Internal Control / Segregation of Duties

Other Findings in this Audit

  • 44051 2022-005
    Significant Deficiency
  • 44052 2022-003
    Significant Deficiency Repeat
  • 44054 2022-004
    Significant Deficiency Repeat
  • 44055 2022-002
    Significant Deficiency Repeat
  • 44056 2022-002
    Significant Deficiency Repeat
  • 44057 2022-002
    Significant Deficiency Repeat
  • 44058 2022-004
    Significant Deficiency Repeat
  • 620493 2022-005
    Significant Deficiency
  • 620494 2022-003
    Significant Deficiency Repeat
  • 620495 2022-004
    Significant Deficiency Repeat
  • 620496 2022-004
    Significant Deficiency Repeat
  • 620497 2022-002
    Significant Deficiency Repeat
  • 620498 2022-002
    Significant Deficiency Repeat
  • 620499 2022-002
    Significant Deficiency Repeat
  • 620500 2022-004
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
84.063 Federal Pell Grant Program $4.73M
84.425 Education Stabilization Fund $3.29M
15.875 Economic, Social, and Political Development of the Territories $1.69M
10.511 Smith-Lever Funding (various Programs) $1.18M
10.203 Payments to Agricultural Experiment Stations Under the Hatch Act $907,355
10.664 Cooperative Forestry Assistance $384,851
84.027 Special Education_grants to States $311,332
93.048 Special Programs for the Aging_title Iv_and Title Ii_discretionary Projects $268,951
93.632 University Centers for Excellence in Developmental Disabilities Education, Research, and Service $255,407
84.002 Adult Education - Basic Grants to States $207,328
93.107 Area Health Education Centers Point of Service Maintenance and Enhancement Awards $197,023
10.322 Distance Education Grants for Institutions of Higher Education in Insular Areas $151,022
59.037 Small Business Development Centers $139,003
84.007 Federal Supplemental Educational Opportunity Grants $134,519
47.076 Education and Human Resources $131,573
93.612 Native American Programs $114,417
10.308 Resident Instruction Grants for Insular Area Activities $78,908
10.514 Expanded Food and Nutrition Education Program $75,048
84.033 Federal Work-Study Program $48,965
93.310 Trans-Nih Research Support $33,769
15.945 Cooperative Research and Training Programs ? Resources of the National Park System $22,733
10.229 Extension Collaborative on Immunization Teaching & Engagement $21,335
93.569 Community Services Block Grant $16,452
15.630 Coastal Program $12,478
11.473 Office for Coastal Management $10,000
66.716 Research, Development, Monitoring, Public Education, Training, Demonstrations, and Studies $7,568
93.630 Developmental Disabilities Basic Support and Advocacy Grants $6,309
93.791 Money Follows the Person Rebalancing Demonstration $6,062