Finding 586790 (2023-005)

Material Weakness
Requirement
N
Questioned Costs
-
Year
2023
Accepted
2024-01-26
Audit: 14009
Organization: Clatsop Community College (OR)

AI Summary

  • Core Issue: The College lacks an updated written information security program (WISP) that meets GLBA Safeguards Rule requirements.
  • Impacted Requirements: Compliance with the Gramm-Leach-Bliley Act and Uniform Guidance for internal controls over federal awards.
  • Recommended Follow-Up: Implement necessary IT policies and create an updated WISP to ensure compliance with GLBA.

Finding Text

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Loans 84.007 – Federal Supplemental Educational Opportunity Grants 84.033 – Federal Work Study Program Federal Award Identification Number and Year: P063P210355 - 2023, P268K220355 - 2023, P007A213474 - 2023, P033A213474 - 2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Other Matter. 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)). In addition, per Uniform Guidance 2 CFR 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The College does not have an updated written information security program (WISP) to reflect the current practices that address the required components outlined in the GLBA Safeguards Rule. Questioned Costs: None Context: During our testing, we noted the College has procedures in place for the required elements identified, however, the College does not have an updated WISP that meets the compliance requirements outlined in the GLBA Safeguards Rule. Cause: The College is drafting the necessary IT policies, and they were not in place at the time of testing. Effect: The College is out of compliance with GLBA requirements because they do not have a written information security plan, formal change management policy, and formal vendor management policy in place. Repeat Finding: No. Recommendation: We recommend the College implement IT policies and create an updated WISP to ensure the College is compliant with the GLBA Safeguards Rule. Views of responsible officials: There is no disagreement with the audit finding.

Categories

Student Financial Aid Material Weakness Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 10340 2023-001
    Significant Deficiency Repeat
  • 10341 2023-001
    Significant Deficiency Repeat
  • 10342 2023-002
    Significant Deficiency Repeat
  • 10343 2023-003
    Significant Deficiency
  • 10344 2023-004
    Material Weakness Repeat
  • 10345 2023-004
    Material Weakness Repeat
  • 10346 2023-004
    Material Weakness Repeat
  • 10347 2023-004
    Material Weakness Repeat
  • 10348 2023-005
    Material Weakness
  • 10349 2023-005
    Material Weakness
  • 10350 2023-005
    Material Weakness
  • 10351 2023-005
    Material Weakness
  • 10352 2023-006
    Significant Deficiency
  • 10353 2023-006
    Significant Deficiency
  • 10354 2023-006
    Significant Deficiency
  • 10355 2023-006
    Significant Deficiency
  • 10356 2023-007
    Significant Deficiency
  • 586782 2023-001
    Significant Deficiency Repeat
  • 586783 2023-001
    Significant Deficiency Repeat
  • 586784 2023-002
    Significant Deficiency Repeat
  • 586785 2023-003
    Significant Deficiency
  • 586786 2023-004
    Material Weakness Repeat
  • 586787 2023-004
    Material Weakness Repeat
  • 586788 2023-004
    Material Weakness Repeat
  • 586789 2023-004
    Material Weakness Repeat
  • 586791 2023-005
    Material Weakness
  • 586792 2023-005
    Material Weakness
  • 586793 2023-005
    Material Weakness
  • 586794 2023-006
    Significant Deficiency
  • 586795 2023-006
    Significant Deficiency
  • 586796 2023-006
    Significant Deficiency
  • 586797 2023-006
    Significant Deficiency
  • 586798 2023-007
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.063 Federal Pell Grant Program $979,304
84.047 Trio_upward Bound $376,677
84.048 Career and Technical Education -- Basic Grants to States $373,002
84.044 Trio_talent Search $354,307
84.268 Federal Direct Student Loans $339,260
84.042 Trio_student Support Services $337,611
84.425F Act Institutional Support $244,039
84.425E Cares Act Student Support $233,222
84.002 Adult Education - Basic Grants to States $176,080
84.007 Federal Supplemental Educational Opportunity Grants $100,800
21.027 Coronavirus State and Local Fiscal Recovery Funds $100,145
84.033 Federal Work-Study Program $95,945
84.425M Act Strengthening Institutional Program $95,117
59.037 Small Business Development Centers $52,113