Finding Text
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, and 84.268
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: July 1, 2023 June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or specific requirement: 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)). The Code of Federal Regulations 2 CFR 200.303 requires the College to establish and maintain effective internal controls over Federal awards.
Condition: During our testing of the College's information technology, we noted the College did not maintain a comprehensive written security program that included the minimum required elements.
Questioned costs: None
Context: Under an institutions 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.
Cause: The College has continued to make progress in updating the College
to become in compliance with all requirements; however, due to capacity and demands on the
information technology individuals, this is still a work in process.
Effect: The student personal information could be vulnerable.
Repeat finding: No
Recommendation: We recommend the College work to update the written security program to ensure
compliance with all of the required elements.
Views of responsible officials: There is no disagreement with the audit finding. While the College's
"written" information security program did not include the minimum requirements, all required
activities were being performed. The College is in the process of updating its written information
security program to achieve compliance with the Gramm-Leach-Bliley Act.