Finding 965011 (2023-002)

Material Weakness
Requirement
N
Questioned Costs
-
Year
2023
Accepted
2024-03-29

AI Summary

  • Core Issue: The University’s Gramm-Leach-Bliley Act Policy is incomplete and does not meet all requirements outlined in 16 CFR 314.4.
  • Impacted Requirements: The policy lacks necessary administrative, technical, and physical safeguards for protecting sensitive customer information.
  • Recommended Follow-Up: Update the GLBA Policy to comply with regulations and implement effective monitoring controls to ensure proper administration.

Finding Text

2023-002 Material Weakness: Gramm-Leach-Bliley Act (GLBA) (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268) Criteria: In accordance with 16 CFR 314.4, a University shall develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts and contains administrative, technical, and physical safeguards that are appropriate to your size and complexity, the nature and scope of your activities, and the sensitivity of any customer information at issue and must contain all of the elements that are further described in 16 CFR 314.4. Statement of Condition: During the 2023 audit, it was noted that the University’s Gramm-Leach- Bliley Act Policy did not fully address all of the requirements as described by 16 CFR 314.4. In addition, the application of the comprehensive information security program was not effectively administered by the University for the 2023 year. Questioned Costs: Such information is not applicable for this finding since it is nonmonetary in nature. Perspective Information: The 2023 audit included testing of the University’s Gramm-Leach-Bliley Act Policy as outlined in Part 5 of the Compliance Supplement including the application of this program for the year. Cause and Effect: Due to lapses of oversight in multiple departments, the University failed to update their GLBA policy to include the required components in accordance with the Compliance Supplement. Therefore, the policy is considered incomplete and does not provide the appropriate disclosures to consumers. Recommendation: The University should update their Gramm-Leach-Bliley Act Policy to be in accordance with the requirements and put in place effective controls and practices to ensure the policy is monitored in a way to ensure it is administered effectively. View of Responsible Officials: The University has reviewed the Gramm-Leach-Bliley Act Policy and has put in place controls and practices to ensure the policy is monitored and administered effectively moving forward.

Categories

Student Financial Aid Material Weakness Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Other Findings in this Audit

  • 388569 2023-002
    Material Weakness
  • 388570 2023-003
    Significant Deficiency Repeat
  • 388571 2023-004
    Significant Deficiency Repeat
  • 388572 2023-005
    Significant Deficiency
  • 388573 2023-006
    Significant Deficiency
  • 388574 2023-003
    Significant Deficiency Repeat
  • 388575 2023-004
    Significant Deficiency Repeat
  • 388576 2023-005
    Significant Deficiency
  • 388577 2023-006
    Significant Deficiency
  • 388578 2023-004
    Significant Deficiency Repeat
  • 388579 2023-005
    Significant Deficiency
  • 388580 2023-006
    Significant Deficiency
  • 388581 2023-004
    Significant Deficiency Repeat
  • 388582 2023-005
    Significant Deficiency
  • 388583 2023-006
    Significant Deficiency
  • 965012 2023-003
    Significant Deficiency Repeat
  • 965013 2023-004
    Significant Deficiency Repeat
  • 965014 2023-005
    Significant Deficiency
  • 965015 2023-006
    Significant Deficiency
  • 965016 2023-003
    Significant Deficiency Repeat
  • 965017 2023-004
    Significant Deficiency Repeat
  • 965018 2023-005
    Significant Deficiency
  • 965019 2023-006
    Significant Deficiency
  • 965020 2023-004
    Significant Deficiency Repeat
  • 965021 2023-005
    Significant Deficiency
  • 965022 2023-006
    Significant Deficiency
  • 965023 2023-004
    Significant Deficiency Repeat
  • 965024 2023-005
    Significant Deficiency
  • 965025 2023-006
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $657,414
84.063 Federal Pell Grant Program $335,495
84.007 Federal Supplemental Educational Opportunity Grants $16,200
84.033 Federal Work-Study Program $9,945
84.379 Teacher Education Assistance for College and Higher Education Grants (teach Grants) $3,772