FAC Explorer

Finding 513229 (2024-006)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2024
Accepted
2024-12-05
Audit: 331167
Organization: Southwestern Oregon Community College (OR)
Auditor: Cliftonlarsonallen LLP

AI Summary

  • Core Issue: The College is not complying with the GLBA Safeguards Rule due to missing procedures.
  • Impacted Requirements: Failure to protect sensitive student financial aid information as mandated by the GLBA.
  • Recommended Follow-Up: Implement necessary policies and procedures to ensure full compliance with GLBA requirements.

Finding Text

Criteria or specific requirement: The Gramm-Leach-Bliley Act (Pub. L. No. 106-102) (GLBA) 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 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)). ED provides additional information about cybersecurity requirements at https://studentprivacy.ed.gov/security. ED also issued an Electronic Announcement on GLBA compliance that can be found at https://fsapartners.ed.gov/knowledge-center/library/electronic-announcements/2023-02-09/updates-gramm-leach-bliley-act-cybersecurity-requirements Condition: We identified that the College fails to meet some of the compliance requirements outlined in the GLBA Safeguards Rule. Questioned costs: None Context: During our testing, we noted the College did not meet one of the required elements outlined in the GLBA safeguards rule. Cause: The College did not have procedures in place to meet the requirements outlined in the GLBA safeguards rule. Effect: The College is not in compliance with the GLBA safeguards rule. Repeat Finding: No Recommendation: We recommend the College implement policies and procedures that meet all requirements outlined in the GLBA safeguards rule. Views of responsible officials: There is no disagreement with the audit finding.

Corrective Action Plan

Student Financial Assistance Cluster – Assistance Listing No. 84.007,84.033,84.063,84.268 Recommendation: We recommend the College maintain an inventory of where information is stored for the entire period under audit. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: An information inventory was conducted mid-year. After this initial inventory, information will be updated as changes occur and reviewed annually for accuracy. Name(s) of the contact person(s) responsible for corrective action: John Taylor Planned completion date for corrective action plan: March 31, 2025

Categories

Student Financial Aid

Other Findings in this Audit

  • 513212 2024-001
    Significant Deficiency
  • 513213 2024-001
    Significant Deficiency
  • 513214 2024-001
    Significant Deficiency
  • 513215 2024-002
    Significant Deficiency
  • 513216 2024-002
    Significant Deficiency
  • 513217 2024-002
    Significant Deficiency
  • 513218 2024-002
    Significant Deficiency
  • 513219 2024-003
    Material Weakness
  • 513220 2024-003
    Material Weakness
  • 513221 2024-003
    Material Weakness
  • 513222 2024-003
    Material Weakness
  • 513223 2024-004
    Material Weakness
  • 513224 2024-004
    Material Weakness
  • 513225 2024-004
    Material Weakness
  • 513226 2024-004
    Material Weakness
  • 513227 2024-005
    Material Weakness
  • 513228 2024-005
    Material Weakness
  • 513230 2024-006
    Significant Deficiency
  • 513231 2024-006
    Significant Deficiency
  • 513232 2024-006
    Significant Deficiency
  • 1089654 2024-001
    Significant Deficiency
  • 1089655 2024-001
    Significant Deficiency
  • 1089656 2024-001
    Significant Deficiency
  • 1089657 2024-002
    Significant Deficiency
  • 1089658 2024-002
    Significant Deficiency
  • 1089659 2024-002
    Significant Deficiency
  • 1089660 2024-002
    Significant Deficiency
  • 1089661 2024-003
    Material Weakness
  • 1089662 2024-003
    Material Weakness
  • 1089663 2024-003
    Material Weakness
  • 1089664 2024-003
    Material Weakness
  • 1089665 2024-004
    Material Weakness
  • 1089666 2024-004
    Material Weakness
  • 1089667 2024-004
    Material Weakness
  • 1089668 2024-004
    Material Weakness
  • 1089669 2024-005
    Material Weakness
  • 1089670 2024-005
    Material Weakness
  • 1089671 2024-006
    Significant Deficiency
  • 1089672 2024-006
    Significant Deficiency
  • 1089673 2024-006
    Significant Deficiency
  • 1089674 2024-006
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.063 Federal Pell Grant Program $2.67M
11.300 Economic Development Administration $1.99M
84.268 Federal Direct Student Loans $1.87M
93.575 Child Care and Development Block Grant $555,420
84.425 Covid-19 Heerf Supplemental Support Under American Rescue Plan (ssarp) Program $380,506
84.042 Trio - Student Support Services $360,535
84.047 Trio - Upward Bound $261,642
17.258 Wioa Adult Program $196,084
84.044 Trio - Educational Talent Search $170,094
93.434 Every Student Succeeds Act/preschool Development Grants $161,392
84.031 Title III - Bolstering Educational Supports and Teaching (best) $134,538
93.596 Child Care Mandatory and Matching Funds of the Child Care and Development Fund $126,073
84.425 Covid-19 Linn-Benton Community College $106,319
84.048 Carl Perkins Vocational Education $99,376
84.007 Federal Supplemental Educational Opportunity Grants $96,918
21.027 Coronavirus State and Local Fiscal Recovery Funds $90,000
17.261 Strengthening Community Colleges Training Grants $78,472
59.037 Small Business Development Centers $66,734
10.527 New Beginnings for Tribal Students $54,842
16.575 Voca Funding Initiatives to Address Or Victim Service Gaps 2nd Release $36,524
84.002 Casas - Statewide Remote Testing Proctor $29,308
84.033 Federal Work-Study Program $22,665
84.048 Nontraditional Perkins Grant $20,000
43.008 Office of Stem Engagement (ostem) $14,577
17.278 Wioa Dislocated Workers Program $3,998
84.002 Wioa Title II Adult Education & Family Literacy $309