Finding 965831 (2023-008)

Significant Deficiency Repeat Finding
Requirement
N
Questioned Costs
-
Year
2023
Accepted
2024-03-29
Audit: 300370
Organization: Urshan College (MO)

AI Summary

  • Core Issue: The College's Written Information Security Program does not meet the minimum requirements of the Gramm-Leach-Bliley Act, and a qualified individual has not been designated to oversee it.
  • Impacted Requirements: Compliance with the Gramm-Leach-Bliley Act and 2 CFR 200.303 regarding internal controls and information security.
  • Recommended Follow-Up: Implement controls for a thorough review process to ensure compliance with all reporting and security requirements.

Finding Text

2023-008 Special Tests and Provisions Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing No. 84.063, 84.268 Federal Award Identification Number and Year: P063P218567-2023, P268K228567-2023 Award Periods: July 1, 2022 through June 30, 2023 Type of Finding: - Significant Deficiency in Internal Control Over Compliance - Other Matters Criteria or specific requirement: The Gramm-Leach-Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The regulation states that the college must designate a qualified individual responsible for overseeing and implementing your information security program and enforcing your information security program. (16 CFR 314.4(a)). The entity shall have a Written Information Security Program (WISP) that outlines the design and implementation of the risk assessment procedures. (16 CFR 314.4(b)). 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) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d)). Per 2 CFR 200.303, nonfederal 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 has now created a Written Information Security Program; however, the College did not meet the minimum requirements stated in the Gramm-Leach-Bliley Act. Additionally, the College did not designate a qualified individual responsible for overseeing and implementing the information and security program. Questioned Costs: None Context: The College now has a Written Information Security Program; however, the College did not meet the minimum requirements stated in the Gramm-Leach-Bliley Act. Additionally, the College did not designate a qualified individual responsible for overseeing and implementing the information and security program. Cause: The College did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements. Effect: There is a risk the College’s information and systems could be vulnerable to attacks or intrusions, and these attacks may not be detected in a timely manner. Repeat findings: 2022-007 Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements. Views of Responsible Officials: There is no disagreement with the audit finding.

Categories

Special Tests & Provisions Subrecipient Monitoring Reporting Significant Deficiency Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Other Findings in this Audit

  • 389382 2023-004
    Significant Deficiency Repeat
  • 389383 2023-005
    Significant Deficiency
  • 389384 2023-005
    Significant Deficiency
  • 389385 2023-006
    Significant Deficiency Repeat
  • 389386 2023-006
    Significant Deficiency Repeat
  • 389387 2023-007
    Significant Deficiency Repeat
  • 389388 2023-007
    Significant Deficiency Repeat
  • 389389 2023-008
    Significant Deficiency Repeat
  • 389390 2023-008
    Significant Deficiency Repeat
  • 965824 2023-004
    Significant Deficiency Repeat
  • 965825 2023-005
    Significant Deficiency
  • 965826 2023-005
    Significant Deficiency
  • 965827 2023-006
    Significant Deficiency Repeat
  • 965828 2023-006
    Significant Deficiency Repeat
  • 965829 2023-007
    Significant Deficiency Repeat
  • 965830 2023-007
    Significant Deficiency Repeat
  • 965832 2023-008
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $1.45M
84.063 Federal Pell Grant Program $816,917