Finding 952136 (2023-002)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2023
Accepted
2024-03-12
Audit: 294773
Organization: Marian University, Inc. (WI)

AI Summary

  • Core Issue: The University's 'Information Security Plan' lacks necessary elements for assessing internally developed applications, as required by federal guidelines.
  • Impacted Requirements: The plan must include safeguards for access controls, data inventory, encryption, multi-factor authentication, and more, as outlined in 16 CFR 314.4(c).
  • Recommended Follow-Up: The University should prioritize finalizing and documenting the policy for internally developed applications to enhance security measures.

Finding Text

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.038, 84.063, 84.268 Federal Award Identification Number and Year: P007A224513-2023; P033A224513-2023; P268K232439-2023; P063P222439-2023; P379T232439-2023 Award Period: March 25, 2022 to August 31, 2028 (84.077, 84.033, 84.063) January 1, 2022 to July 29, 2044 (84.268) January 1, 2022 to September 30, 2043 (84.379) Type of Finding:  Significant Deficiency in Internal Control over Compliance  Other Matters Criteria or specific requirement: Provides for the design and implementation of safeguards to control the risks the institution identifies through its risk assessment (16 CFR 314.4(c)). At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8). The eight minimum safeguards that the written information security program must address are summarized as follows:  Implement and periodically review access controls.  Conduct a periodic inventory of data, noting where it’s collected, stored, or transmitted.  Encrypt customer information on the institution’s system and when it’s in transit.  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. Condition: The University's 'Information Security Plan' does not include the required elements of the assessment of applications developed by the institution as included in the stated criteria. Questioned costs: There are no questioned costs. Context: The University does not have the required element included in the stated criteria. Cause: The University is in process of developing a policy for internally developed applications, but has not completed the policy as of the end of the fiscal year under audit. Effect: There is a risk that the University may not follow the policy for internally developed applications to ensure the security related to the maintenance and transmission of sensitive information. Repeat Finding: No Recommendation: We recommend that the University work to formally document the policy as a part of the University's 'Information Security Plan' as included in the stated criteria. Views of responsible officials: There is no disagreement with the audit finding.

Categories

Subrecipient Monitoring Significant Deficiency Equipment & Real Property Management Internal Control / Segregation of Duties

Other Findings in this Audit

  • 375693 2023-002
    Significant Deficiency
  • 375694 2023-002
    Significant Deficiency
  • 375695 2023-002
    Significant Deficiency
  • 375696 2023-002
    Significant Deficiency
  • 375697 2023-002
    Significant Deficiency
  • 375698 2023-002
    Significant Deficiency
  • 375699 2023-002
    Significant Deficiency
  • 375700 2023-003
    Significant Deficiency
  • 375701 2023-003
    Significant Deficiency
  • 375702 2023-003
    Significant Deficiency
  • 375703 2023-003
    Significant Deficiency
  • 375704 2023-003
    Significant Deficiency
  • 375705 2023-003
    Significant Deficiency
  • 375706 2023-003
    Significant Deficiency
  • 375707 2023-004
    Significant Deficiency
  • 375708 2023-004
    Significant Deficiency
  • 375709 2023-004
    Significant Deficiency
  • 375710 2023-004
    Significant Deficiency
  • 375711 2023-001
    Significant Deficiency
  • 952135 2023-002
    Significant Deficiency
  • 952137 2023-002
    Significant Deficiency
  • 952138 2023-002
    Significant Deficiency
  • 952139 2023-002
    Significant Deficiency
  • 952140 2023-002
    Significant Deficiency
  • 952141 2023-002
    Significant Deficiency
  • 952142 2023-003
    Significant Deficiency
  • 952143 2023-003
    Significant Deficiency
  • 952144 2023-003
    Significant Deficiency
  • 952145 2023-003
    Significant Deficiency
  • 952146 2023-003
    Significant Deficiency
  • 952147 2023-003
    Significant Deficiency
  • 952148 2023-003
    Significant Deficiency
  • 952149 2023-004
    Significant Deficiency
  • 952150 2023-004
    Significant Deficiency
  • 952151 2023-004
    Significant Deficiency
  • 952152 2023-004
    Significant Deficiency
  • 952153 2023-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $2.21M
84.063 Federal Pell Grant Program $1.86M
84.425 Education Stabilization Fund $1.80M
84.038 Federal Perkins Loan Program $763,526
84.047 Trio_upward Bound $268,758
84.042 Trio_student Support Services $254,190
84.007 Federal Supplemental Educational Opportunity Grants $77,527
84.033 Federal Work-Study Program $71,008
84.379 Teacher Education Assistance for College and Higher Education Grants (teach Grants) $5,256