Finding 960664 (2023-002)

Significant Deficiency Repeat Finding
Requirement
N
Questioned Costs
-
Year
2023
Accepted
2024-03-25
Audit: 297334
Organization: Hannibal-Lagrange University (MO)
Auditor: Capincrouse LLP

AI Summary

  • Core Issue: The University is not fully compliant with the updated requirements of the Gramm-Leach-Bliley Act (GLBA), risking student information security.
  • Impacted Requirements: Key areas include the written information security program, multi-factor authentication, continuous monitoring, and employee training.
  • Recommended Follow-Up: Allocate necessary resources to meet GLBA requirements and implement corrective actions as agreed by management.

Finding Text

Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, and 84.038-Student Financial Assistance Cluster Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The University did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $-0- Context: The University has not fully updated its written information security program and security risk assessment and safeguards, including multi-factor authentication on all systems containing personally identifiable information (PII) in light of the revised regulations. Additionally, the University has not fully implemented continuous monitoring, such as penetration testing and vulnerability scanning, implemented sufficient employee and information security staff training, implemented sufficient vendor management policies and reviews, or provided a written, annual report to the board covering all required areas. Cause: The University has not allocated sufficient resources to address and document compliance with the requirements of GLBA. Effect: The University has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: Yes, 2022-002 Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Categories

Subrecipient Monitoring Significant Deficiency

Other Findings in this Audit

  • 384221 2023-002
    Significant Deficiency Repeat
  • 384222 2023-002
    Significant Deficiency Repeat
  • 384223 2023-002
    Significant Deficiency Repeat
  • 384224 2023-002
    Significant Deficiency Repeat
  • 384225 2023-002
    Significant Deficiency Repeat
  • 384226 2023-003
    -
  • 384227 2023-003
    -
  • 960663 2023-002
    Significant Deficiency Repeat
  • 960665 2023-002
    Significant Deficiency Repeat
  • 960666 2023-002
    Significant Deficiency Repeat
  • 960667 2023-002
    Significant Deficiency Repeat
  • 960668 2023-003
    -
  • 960669 2023-003
    -

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $2.02M
84.063 Federal Pell Grant Program $713,286
84.038 Federal Perkins Loan Program $172,308
84.425 Covid-19 Education Stabilization Fund Heerf-Student Aid Portion $67,314
84.007 Federal Supplemental Educational Opportunity Grants $48,695
84.033 Federal Work-Study Program $36,608