Finding Text
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Aid Cluster
Assistance Listing Number: 84.063, 84.268, 84.007, 84.033
Federal Award Identification Number: P063P233052, P063P223052, P268K243052, P268K233052, P007A231754, P007A221754, P033A231754
Award Period: July 1, 2023 – June 30, 2024
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or specific requirement:
Internal Control – Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non- Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller
General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Compliance – 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). Institutions are required to develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts. The regulations require the written information security program to include nine elements for institutions with 5,000 or more customers, (16 CFR 314.3(a)). The elements that an institution must address in its written information security program are at 16 CFR 314.4.
Condition: Certain elements of the College’s information security program were not maintained in written form.
Questioned Costs: None
Context: The College’s written information security program did not cover the following requirements as of the required deadline in June 2024:
- Assess apps developed by the institution
- Implement multi-factor authentication for anyone accessing customer information on
the institution’s system
- Dispose of customer information securely
- Anticipate and evaluate changes to the information system or network.
- Maintain a log of authorized users’ activity and keep an eye out for unauthorized
access.
- Provides for the institution to regularly test or otherwise monitor the effectiveness of the
safeguards it has implemented (16 CFR 314.4(d)).
- Provides for the implementation of policies and procedures to ensure that personnel are able to enact the information security program (16 CFR 314.4(e)(1)).
- Provides for the evaluation and adjustment of its information security program in light of
the results of the required testing and monitoring; any material changes to its
operations or business arrangements; the results of the required risk assessments; or
any other circumstances that it knows or has reason to know may have a material
impact the institution’s information security program (16 CFR 314.4(g)).
Cause: These deficiencies were primarily due to insufficient resources and oversight dedicated to the development and maintenance of the written information security program.
Effect: Information security management may not be optimized and responses delayed without the written plan.
Repeat Finding: No
Recommendation: We recommend the College ensure its written information security program addresses the required minimum elements as outlined in 16 CFR 314.4.
Views of responsible officials: There is no disagreement with the audit finding.