EIN: 161644590
UEI: CJ28UANDGR19
Audited by: CWDL, Certified Public Accountants
Oversight agency: 84 [Department of Education]
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Data as of August 31, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on February 25, 2026. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by August 25, 2026 (7 days ago).
What is a management decision? →FAC accepted this audit on March 28, 2024 — management decision was due September 28, 2024.
FAC accepted this audit on March 19, 2023 — management decision was due September 19, 2023.
FAC accepted this audit on January 11, 2021 — management decision was due July 11, 2021.
FAC accepted this audit on March 26, 2020 — management decision was due September 26, 2020.
FINDING #2019-002 ? GRAMM-LEACH-BLILEY ACT COMPLIANCE Criteria The Gramm-Leach Bliley Act (GLBA) requires districts to have a documented response to the Safeguards Rule. Specifically, this response covers key requirements including: ? Designate an information security officer and related oversight responsibilities for the institution?s security. ? Assess the risks to confidential information, assess the level of mitigating controls in place, and identify action plans to accept or further mitigate remaining risks. ? Implement an information security program, including various technical and physical underlying controls, such as data encryption and secure shredding processes. ? Oversee vendor relationships to ensure confidential data are secured at their locations when applicable and access is controlled when vendors connect to the institution. ? Perform an ongoing evaluation of their program to keep content current with an ever-evolving security environment. Condition We noted that the development of the response is currently underway with anticipated completion and implementation during Fiscal Year 2019-20. Questioned Costs Not applicable Context Compliance with GLBA requirements Effects The intent of the GLBA Safeguards Rule is to enhance security over confidential information. Without a documented response to all applicable requirements, the District is more susceptible to IT vulnerabilities than it would be following full implementation. Cause Steps taken in response to GLBA compliance requirements, new for the 2018-19 year, require extensive administrative efforts to implement. Recommendation The District should continue towards full implementation of its documented response to the GLBA Safeguards Rule in the 2019-20 year. Contact Person: Terry Bartley
Show full finding ▾Hide full finding ▴FINDING #2019-002 ? GRAMM-LEACH-BLILEY ACT COMPLIANCE Criteria The Gramm-Leach Bliley Act (GLBA) requires districts to have a documented response to the Safeguards Rule. Specifically, this response covers key requirements including: ? Designate an information security officer and related oversight responsibilities for the institution?s security. ? Assess the risks to confidential information, assess the level of mitigating controls in place, and identify action plans to accept or further mitigate remaining risks. ? Implement an information security program, including various technical and physical underlying controls, such as data encryption and secure shredding processes. ? Oversee vendor relationships to ensure confidential data are secured at their locations when applicable and access is controlled when vendors connect to the institution. ? Perform an ongoing evaluation of their program to keep content current with an ever-evolving security environment. Condition We noted that the development of the response is currently underway with anticipated completion and implementation during Fiscal Year 2019-20. Questioned Costs Not applicable Context Compliance with GLBA requirements Effects The intent of the GLBA Safeguards Rule is to enhance security over confidential information. Without a documented response to all applicable requirements, the District is more susceptible to IT vulnerabilities than it would be following full implementation. Cause Steps taken in response to GLBA compliance requirements, new for the 2018-19 year, require extensive administrative efforts to implement. Recommendation The District should continue towards full implementation of its documented response to the GLBA Safeguards Rule in the 2019-20 year. Contact Person: Terry Bartley
FINDING #2019-002 ? GRAMM-LEACH-BLILEY ACT COMPLIANCE Finding: The Gramm-Leach Bliley Act (GLBA) requires districts to have a documented response to the Safeguards Rule. Specifically, this response covers key requirements including: ? Designate an information security officer and related oversight responsibilities for the institution?s security. ? Assess the risks to confidential information, assess the level of mitigating controls in place, and identify action plans to accept or further mitigate remaining risks. ? Implement an information security program, including various technical and physical underlying controls, such as data encryption and secure shredding processes. ? Oversee vendor relationships to ensure confidential data are secured at their locations when applicable and access is controlled when vendors connect to the institution. ? Perform an ongoing evaluation of their program to keep content current with an ever-evolving security environment. We noted that the development of the response is currently underway with anticipated completion and implementation during Fiscal Year 2019-20. Recommendation: The District should continue towards full implementation of its documented response to the GLBA safeguards Rule in the 2019-20 year. Management's Response and Corrective Action Plan The District will complete its documented response to the GLBA Safeguards Rule in the 2019-20 year.
FINDING #2019-003 ? DIRECT LOAN QUALITY ASSURANCE SYSTEM Criteria or Specific Requirement 34 CFR 685.300(b)(9) requires schools participating in the Direct Loan program to implement a quality assurance system. Condition We noted that the development of a quality assurance system in compliance with 34 CFR 685.300(b)(9) is currently underway with anticipated completion and implementation during 2019-20. Questioned Costs ? Not applicable Context Compliance with 34 CFR 685.300(b)(9) requirements. Effect Non-compliance with 34 CFR 685.300(b)(9), which requires all participating schools to have a written quality assurance system to ensure that the school is complying with program requirements and meeting program objectives. Cause Clerical oversight. Recommendation The District should continue towards full implementation of its documented response to the Direct Loan quality assurance system in the 2019-20 year. Management's Response and Corrective Action Plan Per auditor conversation with the District, the district if working to develop a direct loan quality assurance system plan. This plan is being developed in tandem with the district?s training manuals, to better encompass the entire direct loan process. Contact Person: Terry Bartley
Show full finding ▾Hide full finding ▴FINDING #2019-003 ? DIRECT LOAN QUALITY ASSURANCE SYSTEM Criteria or Specific Requirement 34 CFR 685.300(b)(9) requires schools participating in the Direct Loan program to implement a quality assurance system. Condition We noted that the development of a quality assurance system in compliance with 34 CFR 685.300(b)(9) is currently underway with anticipated completion and implementation during 2019-20. Questioned Costs ? Not applicable Context Compliance with 34 CFR 685.300(b)(9) requirements. Effect Non-compliance with 34 CFR 685.300(b)(9), which requires all participating schools to have a written quality assurance system to ensure that the school is complying with program requirements and meeting program objectives. Cause Clerical oversight. Recommendation The District should continue towards full implementation of its documented response to the Direct Loan quality assurance system in the 2019-20 year. Management's Response and Corrective Action Plan Per auditor conversation with the District, the district if working to develop a direct loan quality assurance system plan. This plan is being developed in tandem with the district?s training manuals, to better encompass the entire direct loan process. Contact Person: Terry Bartley
FINDING #2019-003 ? DIRECT LOAN QUALITY ASSURANCE SYSTEM Finding: We noted that the development of a quality assurance system in compliance with 34 CFR 685.300(b)(9) is currently underway with anticipated completion and implementation during 2019-20. Recommendation The District should continue towards full implementation of its documented response to the Direct Loan quality assurance system in the 2019-20 year. Management's Response and Corrective Action Plan Per auditor conversation with the District, the district if working to develop a direct loan quality assurance system plan. This plan is being developed in tandem with the district?s training manuals, to better encompass the entire direct loan process.
FAC accepted this audit on January 13, 2019 — management decision was due July 13, 2019.
FAC accepted this audit on February 7, 2018 — management decision was due August 7, 2018.
FAC accepted this audit on February 11, 2018 — management decision was due August 11, 2018.
Data source: This information comes from the Federal Audit Clearinghouse, the official repository of Single Audit data. All data is public domain. Verify this organization's audit history at fac.gov.
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