Finding 588520 (2023-001)

-
Requirement
N
Questioned Costs
-
Year
2023
Accepted
2024-02-07
Audit: 16105
Organization: Park University (MO)
Auditor: Forvis LLP

AI Summary

  • Core Issue: The University lacks a written information security program required by the Gramm-Leach-Bliley Act.
  • Impacted Requirements: The University did not meet the eight minimum safeguards outlined in 16 CFR 314.
  • Recommended Follow-Up: Management should finalize and implement a comprehensive information security policy that includes all required safeguards.

Finding Text

Student Financial Aid Cluster U.S. Department of Education Federal Direct Student loans 84.268, Federal Work-Study Program 84.033, Federal Pell Grant Program 84.063, Federal Supplemental Educational Opportunities Grant 84.007, Teacher Education Assistance for College and Higher Education Grants 84.379 Award Year - Academic year 2022-2023 Criteria or Specific Requirement - The Gramm-Leach-Bliley Act (Pub. L. 106-102) requires financial institutions to explain their information-sharing 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 Program 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)). Under 16 CFR 314, institutions are required to develop, implement and maintain a comprehensive information security program that address the implementation eight minimum safeguards. Condition - The University does not have a written information security program that addresses the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8). Questioned Costs - None noted. Context - Through inquiry of management and review of information policies published on the University's website it was determined the eight requirements were not all included in a comprehensive policy. Effect - The University was not in compliance with the Gramm-Leach-Bliley Act . Cause - The University's policy was not finalized. Identification as a repeat finding, if applicable - Not applicable. Recommendation - We recommend management takes necessary steps to finalize a written information security policy which at minimum has the eight safeguards within 16 CFR 314. View of Responsible Official and Planned Corrective Actions - Management agrees with the stated finding and has implemented a corrective action plan.

Categories

Student Financial Aid Matching / Level of Effort / Earmarking

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $23.70M
84.063 Federal Pell Grant Program $11.44M
84.007 Federal Supplemental Educational Opportunity Grants $471,993
84.033 Federal Work-Study Program $339,456
84.379 Teacher Education Assistance for College and Higher Education Grants (teach Grants) $31,583