Finding 519617 (2024-003)

- Repeat Finding
Requirement
N
Questioned Costs
-
Year
2024
Accepted
2025-01-17
Audit: 338706
Organization: Cleary University (MI)
Auditor: Capincrouse LLP

AI Summary

  • Core Issue: The University is not fully compliant with the GLBA requirements, specifically in vendor management policies.
  • Impacted Requirements: Compliance with 16 CFR 314.4 is incomplete, risking student information security.
  • Recommended Follow-Up: Allocate resources to finalize vendor management policies to achieve full GLBA compliance.

Finding Text

Gramm-Leach-Bliley Act (GLBA) Compliance DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, and 84.033 Student Financial Assistance Cluster Federal Award Identification #: 2023-2024 Award Year Condition: The University did not sufficiently comply with all the requirements of GLBA. Criteria: 16 CFR 314.4 Questioned Costs: $0 Context: The University has made progress from the prior year on GLBA compliance. The University has one remaining area left to implement relating to sufficient vendor management policies and reviews. Cause: The University has prioritized resources to address and document compliance with multi-factor authentication and risk assessment evaluation before implementing the vendor management requirements of GLBA. Effect: The University has not adequately addressed all the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: Yes, 2023-003 Recommendation: We recommend the University allocate sufficient resources to address all remaining requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Categories

Subrecipient Monitoring

Other Findings in this Audit

  • 519609 2024-001
    Material Weakness Repeat
  • 519610 2024-001
    Material Weakness Repeat
  • 519611 2024-001
    Material Weakness Repeat
  • 519612 2024-002
    Significant Deficiency
  • 519613 2024-002
    Significant Deficiency
  • 519614 2024-003
    - Repeat
  • 519615 2024-003
    - Repeat
  • 519616 2024-003
    - Repeat
  • 1096051 2024-001
    Material Weakness Repeat
  • 1096052 2024-001
    Material Weakness Repeat
  • 1096053 2024-001
    Material Weakness Repeat
  • 1096054 2024-002
    Significant Deficiency
  • 1096055 2024-002
    Significant Deficiency
  • 1096056 2024-003
    - Repeat
  • 1096057 2024-003
    - Repeat
  • 1096058 2024-003
    - Repeat
  • 1096059 2024-003
    - Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $5.49M
84.063 Federal Pell Grant Program $1.49M
84.007 Federal Supplemental Educational Opportunity Grants $74,929
84.033 Federal Work-Study Program $26,250