EIN: 350867954
UEI: SB3RTA7BQRD6
Audited by: Forvis Mazars, LLP
Oversight agency: 84 [Department of Education]
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Data as of August 28, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on February 26, 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 26, 2026 (5 days ago).
What is a management decision? →FAC accepted this audit on November 26, 2024 — management decision was due May 26, 2025.
Information on the federal program – Department of Education – Federal Pell Grant Program, CFDA 84.063; Federal Direct Loan Program, CFDA 84.268 Criteria or specific requirement – Special Tests and Provisions - When a recipient of Title IV grant or loan assistance withdraws from a University during a payment period or period of enrollment in which the recipient began attendance, the University must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student or on his or her behalf as of the date of the University’s determination that the student withdrew, the difference must be returned to the Title IV programs as outlined in this section and no additional disbursements may be made to the student for the payment period or period of enrollment. (34 CFR Sections 668.22(a)(1)-(3)). Condition – When students withdrew either officially or unofficially, the University did not always return unearned Title IV aid timely. There were also three incorrect calculations of returned funds for students that withdrew during the term. Questioned costs – $1,909 Context – Out of 4 students tested, 2 students who withdrew during the audit period tested had funds returned late. 3 out of the 4 students tested also had inaccurate calculations. These were all corrected as part of the audit process. Effect – Return of Title IV funds were not performed timely. Incorrect amount of unearned Title IV funds returned. Cause – This was an oversight by the University. R2T4 calculations were not reviewed timely and for accuracy due to turnover at the director of financial aid position. Identification as a repeat finding, if applicable – 2023-001 Recommendation – We recommend an individual in financial aid with the appropriate level of experience periodically review R2T4 calculations and returns to help ensure that internal controls over such a process can operate effectively and achieve compliance. We also recommend the University implement controls to track and remind when returns need to be returned once the withdrawal determination has been made. Views of responsible officials and planned corrective actions – Management is in agreement with this finding. Moving forward, for each year, when the academic calendar is released prior to the beginning of the fall semester, The Office of Financial Aid and Scholarships will immediately determine the dates and number of days used for the R2T4 calculations. The individual responsible for preparation of the calculations has signed up for R2T4 training from NASFAA and will also attend PowerFAIDS training related to R2T4. In addition, another employee within the financial aid office is attending R2T4 training to ensure the financial aid office is appropriately cross-trained and to provide an additional layer of review. The Director of Financial aid has implemented a weekly review of R2T4s to ensure funds are returned properly and there are no lapses in timelines.
Show full finding ▾Hide full finding ▴Information on the federal program – Department of Education – Federal Pell Grant Program, CFDA 84.063; Federal Direct Loan Program, CFDA 84.268 Criteria or specific requirement – Special Tests and Provisions - When a recipient of Title IV grant or loan assistance withdraws from a University during a payment period or period of enrollment in which the recipient began attendance, the University must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student or on his or her behalf as of the date of the University’s determination that the student withdrew, the difference must be returned to the Title IV programs as outlined in this section and no additional disbursements may be made to the student for the payment period or period of enrollment. (34 CFR Sections 668.22(a)(1)-(3)). Condition – When students withdrew either officially or unofficially, the University did not always return unearned Title IV aid timely. There were also three incorrect calculations of returned funds for students that withdrew during the term. Questioned costs – $1,909 Context – Out of 4 students tested, 2 students who withdrew during the audit period tested had funds returned late. 3 out of the 4 students tested also had inaccurate calculations. These were all corrected as part of the audit process. Effect – Return of Title IV funds were not performed timely. Incorrect amount of unearned Title IV funds returned. Cause – This was an oversight by the University. R2T4 calculations were not reviewed timely and for accuracy due to turnover at the director of financial aid position. Identification as a repeat finding, if applicable – 2023-001 Recommendation – We recommend an individual in financial aid with the appropriate level of experience periodically review R2T4 calculations and returns to help ensure that internal controls over such a process can operate effectively and achieve compliance. We also recommend the University implement controls to track and remind when returns need to be returned once the withdrawal determination has been made. Views of responsible officials and planned corrective actions – Management is in agreement with this finding. Moving forward, for each year, when the academic calendar is released prior to the beginning of the fall semester, The Office of Financial Aid and Scholarships will immediately determine the dates and number of days used for the R2T4 calculations. The individual responsible for preparation of the calculations has signed up for R2T4 training from NASFAA and will also attend PowerFAIDS training related to R2T4. In addition, another employee within the financial aid office is attending R2T4 training to ensure the financial aid office is appropriately cross-trained and to provide an additional layer of review. The Director of Financial aid has implemented a weekly review of R2T4s to ensure funds are returned properly and there are no lapses in timelines.
Recommendation: We recommend an individual in financial aid with the appropriate level of experience periodically review R2T4 calculations and returns to help ensure that internal controls over such a process can operate effectively and achieve compliance. We also recommend the University implement controls to track and remind when returns need to be returned once the withdrawal determination has been made. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Corrective Action Planned: ● Moving forward, for each year, when the academic calendar is released prior to the beginning of the fall semester, The Office of Financial Aid and Scholarships will immediately determine the dates and number of days used for the R2T4 calculations. ● The Senior Financial Aid Counselor within the Office of Financial Aid and Scholarships, who is responsible for preparing the R2T4 calculations, has enrolled for R2T4 training from NASFAA, which takes place starting on September 3, 2024. The Senior Financial Aid Counselor will also complete a PowerFAIDS training on the R2T4 process within the system. ● The Systems Specialist within the Office of Financial Aid and Scholarships will also be trained on the R2T4 process to provide quality control for the senior financial aid counselor and to ensure we are cross-trained within the Office of Financial Aid. With two individuals working to keep each other accountable, we will be able to avoid similar issues in the future. The Systems Specialist will also complete the NASFAA and PowerFAIDS training. ● All R2T4s will be tracked on a shared file starting in the Fall 2024. The Senior Financial Aid Counselor, Systems Specialist, and Director of Financial Aid will have access to the file for review and quality control. ● The Systems Specialist and Director of Financial Aid will be added to the student withdrawal form workflow through Etrieve. This team of three will all receive a notification when a student withdrawal needs to be processed. ● The Director of Financial Aid will check at least weekly on the shared R2T4 file and will monitor the dates and timelines to ensure calculations are completed within the timeframe allowed. Name of Contact Responsible for Corrective Action: David J. Sarah, Director of Financial Aid, 765.641.4110 Anticipated Completion Date: September 2024
2023-001
Information on the federal program – Department of Education – Federal Direct Loan Program, CFDA 84.268 Criteria or specific requirement – Special Tests - Disbursements – When Direct Loans are being credited to a student’s account, the institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan; and (3) the procedures and time by which the student or parent must notify the institution that he or she wishes to cancel the loan (34 CFR Section 668.165(a)(2)(i-iii)). Condition – Students are provided account statements showing the disbursement amounts and dates (34 CFR Section 668.165(a)(2)(i), however, these disbursement notifications did not contain all information required by 34 CFR Section 668.165(a)(2)(ii-iii). Questioned costs – N/A - Nonmonetary finding Context – Out of 25 students tested, 23 students had direct loan disbursements in which they were not provided a disbursement notification with all information required by 34 CFR Section 668.165(a)(2)(ii-iii). Students were provided account statements showing the disbursement amounts and dates. Effect – Students were not provided with all language required for disbursement notifications Cause – This was an oversight by the University. With the implementation of new software, a disbursement notification was not programmed into the software. Identification as a repeat finding, if applicable – N/A Recommendation – We recommend the Office of Financial Aid utilize their financial aid processing software to implement disbursement notifications which include all information required by (34 CFR Section 668.165(a)(2) to be sent electronically to students once disbursements are posted. Views of responsible officials and planned corrective actions – Management is in agreement with this finding. The Office of Financial Aid and Scholarships drafted a letter using best practices laid out by NAFSAA. The System Specialist, who is responsible for disbursing aid, has created documentation that has been added to the disbursement process. Once disbursement is complete, the System Specialist will run the process in PowerFAIDS that will send the Loan Disbursement Notification via email to students who have received loans. This includes students who have received Federal Direct Subsidized, Unsubsidized, Parent PLUS, Grad PLUS, and private loans.
Show full finding ▾Hide full finding ▴Information on the federal program – Department of Education – Federal Direct Loan Program, CFDA 84.268 Criteria or specific requirement – Special Tests - Disbursements – When Direct Loans are being credited to a student’s account, the institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan; and (3) the procedures and time by which the student or parent must notify the institution that he or she wishes to cancel the loan (34 CFR Section 668.165(a)(2)(i-iii)). Condition – Students are provided account statements showing the disbursement amounts and dates (34 CFR Section 668.165(a)(2)(i), however, these disbursement notifications did not contain all information required by 34 CFR Section 668.165(a)(2)(ii-iii). Questioned costs – N/A - Nonmonetary finding Context – Out of 25 students tested, 23 students had direct loan disbursements in which they were not provided a disbursement notification with all information required by 34 CFR Section 668.165(a)(2)(ii-iii). Students were provided account statements showing the disbursement amounts and dates. Effect – Students were not provided with all language required for disbursement notifications Cause – This was an oversight by the University. With the implementation of new software, a disbursement notification was not programmed into the software. Identification as a repeat finding, if applicable – N/A Recommendation – We recommend the Office of Financial Aid utilize their financial aid processing software to implement disbursement notifications which include all information required by (34 CFR Section 668.165(a)(2) to be sent electronically to students once disbursements are posted. Views of responsible officials and planned corrective actions – Management is in agreement with this finding. The Office of Financial Aid and Scholarships drafted a letter using best practices laid out by NAFSAA. The System Specialist, who is responsible for disbursing aid, has created documentation that has been added to the disbursement process. Once disbursement is complete, the System Specialist will run the process in PowerFAIDS that will send the Loan Disbursement Notification via email to students who have received loans. This includes students who have received Federal Direct Subsidized, Unsubsidized, Parent PLUS, Grad PLUS, and private loans.
Recommendation: We recommend the Office of Financial Aid utilize their financial aid processing software to implement disbursement notifications which include all information required by (34 CFR Section 668.165(a)(2) to be sent electronically to students once disbursements are posted. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Corrective Action Planned: The Office of Financial Aid and Scholarships drafted a letter using best practices laid out by NAFSAA which includes all information required by 34 CFR Section 668.165. The System Specialist, who is responsible for disbursing aid, has created documentation that has been added to the disbursement process. Once a disbursement is complete, the System Specialist will run the process in PowerFAIDS that will send the Loan Disbursement Notification via email to students who have received loans. This includes students who have received Federal Direct Subsidized, Unsubsidized, Parent PLUS, Grad PLUS, and private loans. This process is updated and is now in place. Name of Contact Responsible for Corrective Action: David J. Sarah, Director of Financial Aid, 765.641.4110 Anticipated Completion Date: August 2024
FAC accepted this audit on November 14, 2023 — management decision was due May 14, 2024.
When students withdrew either officially or unofficially, the University did not always return unearned Title IV aid timely. There were also three incorrect calculations of returned funds for students that withdrew during the term. Criteria: 34 CFR 668.22 Questioned Costs: $3,703 Context: Out of 8 students tested, 2 students who withdrew during the audit period tested had funds totaling $14,811 returned late ranging from 39 to 56 days late. 3 out of the 8 students tested also had inaccurate calculations. The University miscalculated the number of days for 1 of the returns and the other 1 return had an inaccurate withdrawal date leading to the miscalculation and 1 did not have a return calculated. The questioned costs are related to the latter 2 students. The University is in the process of correcting all affected students and manually recalculating the students. Because of the error rate, this is classified as a material weakness. Cause: This was an oversight by the University. R2T4 calculations were not reviewed timely and for accuracy due to staffing. 1 of the students was in a distance education program and the University was unable to determine that the student had academic engagement and all Pell funds should have been returned rather than performing an R2T4 calculation. Effect: Return of Title IV funds were not performed timely. Incorrect amount of unearned Title IV funds returned. Identification as repeat finding, if applicable: N/A Recommendation: We recommend an individual in financial aid with the appropriate level of experience periodically review R2T4 calculations and returns to help ensure that internal controls over such a process can operate effectively and achieve compliance. We also recommend the University implement controls to track and remind when returns need to be returned once the withdrawal determination has been made. Views of Responsible Officials and Planned Corrective Action: Management is in agreement with this finding. See attached corrective action plan.
Show full finding ▾Hide full finding ▴Untimely and Inaccurate Return of Title IV Funds (R2T4) Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.063 Pell Grants and 84.268 Federal Direct Loans Federal Award Identification: 2022-2023 Award Year Condition: When students withdrew either officially or unofficially, the University did not always return unearned Title IV aid timely. There were also three incorrect calculations of returned funds for students that withdrew during the term. Criteria: 34 CFR 668.22 Questioned Costs: $3,703 Context: Out of 8 students tested, 2 students who withdrew during the audit period tested had funds totaling $14,811 returned late ranging from 39 to 56 days late. 3 out of the 8 students tested also had inaccurate calculations. The University miscalculated the number of days for 1 of the returns and the other 1 return had an inaccurate withdrawal date leading to the miscalculation and 1 did not have a return calculated. The questioned costs are related to the latter 2 students. The University is in the process of correcting all affected students and manually recalculating the students. Because of the error rate, this is classified as a material weakness. Cause: This was an oversight by the University. R2T4 calculations were not reviewed timely and for accuracy due to staffing. 1 of the students was in a distance education program and the University was unable to determine that the student had academic engagement and all Pell funds should have been returned rather than performing an R2T4 calculation. Effect: Return of Title IV funds were not performed timely. Incorrect amount of unearned Title IV funds returned. Identification as repeat finding, if applicable: N/A Recommendation: We recommend an individual in financial aid with the appropriate level of experience periodically review R2T4 calculations and returns to help ensure that internal controls over such a process can operate effectively and achieve compliance. We also recommend the University implement controls to track and remind when returns need to be returned once the withdrawal determination has been made. Views of Responsible Officials and Planned Corrective Action: Management is in agreement with this finding. See attached corrective action plan.
Untimely and Inaccurate Return of Title IV Funds Planned Corrective Action: FA Solutions (FAS), a third-party vendor, was contracted to assist with compliance and other processing responsibilities that included the processing of all R2T4s for Anderson University. While the staff of the Office of Financial Aid and Scholarships supplied documentation to FAS in a timely manner, FAS processed R2T4 late and, in some cases, inaccurately. When this was discovered by the Office of Financial Aid and Scholarships, all R2T4 and processing responsibilities were brought back under the in-office staff at AU in order to process Return of Title IV funds accurately and in compliance. Anderson University has enrolled our Senior Counselor in a 6-week R2T4 course with the National Association of Student Financial Aid Administrators (NASFAA) where she will pursue credentialing in Return of Title IV Funds with NASFAA as well as R2T4 Specialist designation. Additionally, policies for students who stop attending, and for whom the last day of attendance can not be determined, will be reviewed and revised for clarity and better communication with the Office of Financial Aid and Scholarships. Person Responsible for Corrective Action Plan: David J. Sarah, Director Anticipated Date of Completion: The return of all processing of financial aid was brought back to AU effective 06/20/2023. The R2T4 course taken by our Senior Counselor will be completed 11/06/2023. Final R2T4 adjustments completed 10/20/2023.
3 students out of 28 tested were not properly awarded Pell based on enrollment status and eligibility. Criteria: 34 CFR 690.63(b) Questioned Costs: $1,273 Context: In the eligibility and disbursement testing, out of 28 students tested, 3 students had Pell awarding errors. 1 student was over awarded Pell by $811, 1 student was over awarded Pell by $462, and 1 student was under awarded Pell by $1,645 as Pell was not awarded and disbursed at all though the student was eligible. These were all corrected as part of the audit process. Cause: University oversight and lack of review at the census dates. Effect: Pell was not awarded correctly based on enrollment status. Identification as repeat finding, if applicable: N/A Recommendation: We recommend the University implement procedures and controls to update Pell to be in alignment with enrollment status. Views of Responsible Officials and Planned Corrective Action: Management is in agreement with this finding. See attached corrective action plan.
Show full finding ▾Hide full finding ▴Incorrect Pell Calculations Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.063 Pell Grants Federal Award Identification: 2022-2023 Award Year Condition: 3 students out of 28 tested were not properly awarded Pell based on enrollment status and eligibility. Criteria: 34 CFR 690.63(b) Questioned Costs: $1,273 Context: In the eligibility and disbursement testing, out of 28 students tested, 3 students had Pell awarding errors. 1 student was over awarded Pell by $811, 1 student was over awarded Pell by $462, and 1 student was under awarded Pell by $1,645 as Pell was not awarded and disbursed at all though the student was eligible. These were all corrected as part of the audit process. Cause: University oversight and lack of review at the census dates. Effect: Pell was not awarded correctly based on enrollment status. Identification as repeat finding, if applicable: N/A Recommendation: We recommend the University implement procedures and controls to update Pell to be in alignment with enrollment status. Views of Responsible Officials and Planned Corrective Action: Management is in agreement with this finding. See attached corrective action plan.
Incorrect Pell Calculations Planned Corrective Action: Anderson University will update course withdrawal forms to include documentation from professors of last date of attendance and affirmation of whether or not the student began the course they are dropping. The Office of Financial Aid and Scholarships will receive all completed withdrawal forms to review for changes to academic level and any necessary return of federal aid. Person Responsible for Corrective Action Plan: David J. Sarah, Director Anticipated Date of Completion: N/A
Students were not appropriately awarded subsidized loans based on need. Criteria: 34 CFR 668.42 and 34 CFR 685.301 Questioned Costs: $2,234 Context: Out of 60 students tested, 3 students were not awarded aid appropriately based on need analysis. One student received a subsidized loan exceeding need by $2,234, corrected by returning this over award or getting permission from the student to award as a unsubsidized loan. Two students received subsidized loans exceeding need by $236 and $2,692, respectively, corrected by reallocating the amounts from subsidized to unsubsidized. Cause: The University incorrectly set up endowed scholarships as excluded from estimated financial assistance in their new system. Effect: Students received subsidized federal aid for which they were not eligible and incorrect allocation of subsidized versus unsubsidized which affects the amount and timing of interest the student must repay. Identification as repeat finding, if applicable: N/A Recommendation: We recommend the University ensure that all endowed scholarships are marked as estimated financial assistance and an awarding check is done accurately before disbursement is completed for the student. Views of Responsible Officials and Planned Corrective Action: Management is in agreement with this finding. See attached corrective action plan.
Show full finding ▾Hide full finding ▴Need Analysis DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Direct Loans Federal Award Identification: 2022-2023 Award Year Condition: Students were not appropriately awarded subsidized loans based on need. Criteria: 34 CFR 668.42 and 34 CFR 685.301 Questioned Costs: $2,234 Context: Out of 60 students tested, 3 students were not awarded aid appropriately based on need analysis. One student received a subsidized loan exceeding need by $2,234, corrected by returning this over award or getting permission from the student to award as a unsubsidized loan. Two students received subsidized loans exceeding need by $236 and $2,692, respectively, corrected by reallocating the amounts from subsidized to unsubsidized. Cause: The University incorrectly set up endowed scholarships as excluded from estimated financial assistance in their new system. Effect: Students received subsidized federal aid for which they were not eligible and incorrect allocation of subsidized versus unsubsidized which affects the amount and timing of interest the student must repay. Identification as repeat finding, if applicable: N/A Recommendation: We recommend the University ensure that all endowed scholarships are marked as estimated financial assistance and an awarding check is done accurately before disbursement is completed for the student. Views of Responsible Officials and Planned Corrective Action: Management is in agreement with this finding. See attached corrective action plan.
Need Analysis Planned Corrective Action: PowerFAIDS, a new financial aid processing software, was adopted by the Anderson University Office of Financial Aid this year. It was discovered that PowerFAIDS does not automatically correct the student’s need-based aid when additional aid is added manually after a student has been packaged. The assumption of the Financial Aid Office was that this was automatically adjusting as it had done in the previous system used. The Senior Associate Director reached out to PowerFAIDS to get an understanding of when manual calculations need to be done to a student’s need-based aid. In light of this new information, the Financial Aid Office will adjust their practice going forward. When additional aid is awarded going forward, need based aid will be manually adjusted so that students are not over awarded in need-based aid. Person Responsible for Corrective Action Plan: David J. Sarah, Director Anticipated Date of Completion: Students who were over awarded in Federal Direct Subsidized Loans were corrected on COD effective 08/17/2023.
FAC accepted this audit on November 2, 2022 — management decision was due May 2, 2023.
The University?s underlying documentation of the student grant information did not agree to what was reported in the HEERF annual report for all of the 2021 calendar year and the student quarterly website reporting. Criteria: CRRSAA Section 314(a)(1) and ARP Section 2003(a)(1) Questioned Costs: $-0- Context: During the audit, it was identified that the University did not accurately report the total student grants disbursed for the calendar year ending December 31, 2021. The underlying support was unable to be located with staffing transitions, and the totals from the system as disbursed did not agree to the amounts reported. Additionally, the quarterly reports for student amounts disbursed did not agree to the amounts reported in the system as disbursed to students. The University is in the process of correcting the amounts reports on the website, and the University plans to correct any amounts needed for the HEERF annual reporting in the next reporting cycle. Cause: There was a transition in the financial aid director position after the annual report was submitted prior to the audit process. Effect: The University was not in compliance with the reporting requirements of HEERF, and the Department of Education did not receive accurate information showing the University had expended all student funds. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend the University implement an additional review over the HEERF Annual Reporting to ensure proper information is provided during the report submission. We further recommend the website be updated to reflect information from underlying records on student disbursements. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Higher Education Stabilization Fund Reporting DEPARTMENT OF EDUCATION ALN #: 84.425E Federal Award Identification #: P425E200363 Condition: The University?s underlying documentation of the student grant information did not agree to what was reported in the HEERF annual report for all of the 2021 calendar year and the student quarterly website reporting. Criteria: CRRSAA Section 314(a)(1) and ARP Section 2003(a)(1) Questioned Costs: $-0- Context: During the audit, it was identified that the University did not accurately report the total student grants disbursed for the calendar year ending December 31, 2021. The underlying support was unable to be located with staffing transitions, and the totals from the system as disbursed did not agree to the amounts reported. Additionally, the quarterly reports for student amounts disbursed did not agree to the amounts reported in the system as disbursed to students. The University is in the process of correcting the amounts reports on the website, and the University plans to correct any amounts needed for the HEERF annual reporting in the next reporting cycle. Cause: There was a transition in the financial aid director position after the annual report was submitted prior to the audit process. Effect: The University was not in compliance with the reporting requirements of HEERF, and the Department of Education did not receive accurate information showing the University had expended all student funds. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend the University implement an additional review over the HEERF Annual Reporting to ensure proper information is provided during the report submission. We further recommend the website be updated to reflect information from underlying records on student disbursements. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Higher Education Stabilization Fund Reporting Planned Corrective Action: The planned corrective action plan is bifurcated. First, the University will update its website https://anderson.edu/alums/cares-act/ to correct reported counts for HEERF III Emergency Financial Aid to students for the number of unduplicated recipients notified and approved for grants. Second, Year 2 Higher Education Emergency Relief Fund (HEERF) Annual Performance Report (APR) will be corrected to properly report the count of unduplicated students and related amount of grants directly disbursed to students and amount applied to student accounts. Person Responsible for Corrective Action Plan: Suahil R. Housholder, Assistant VP for Finance and Assistant Treasurer Anticipated Date of Completion: Website update by 11/14/2022 and Year 2 Higher Education Emergency Relief Fund (HEERF) Annual Performance Report (APR) corrected when the Year 3 Higher Education Emergency Relief Fund (HEERF) Annual Performance Report (APR) reporting period is established by the Department of Education in the year 2023.
FAC accepted this audit on October 18, 2021 — management decision was due April 18, 2022.
FAC accepted this audit on October 4, 2020 — management decision was due April 4, 2021.
The University did not sufficiently comply with all the requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $-0- Context: The University has not sufficiently documented its security assessment. Cause: The University has not allocated sufficient resources to address 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. Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management is in agreement with the finding and is in the process of addressing the issue. See attached corrective action plan.
Show full finding ▾Hide full finding ▴2020-001 Gramm-Leach-Bliley-Act (GLBA) Compliance Significant Deficiency DEPARTMENT OF EDUCATION CFDA #: 84.268, 84.063, 84.007, 84.033, 84.038 and 84.379-Student Financial Assistance Cluster Federal Award Identification #: 2019-2020 Financial Aid Year Condition: The University did not sufficiently comply with all the requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $-0- Context: The University has not sufficiently documented its security assessment. Cause: The University has not allocated sufficient resources to address 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. Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management is in agreement with the finding and is in the process of addressing the issue. See attached corrective action plan.
Finding Number: 2020-001 Gramm-Leach-Bliley-Act Compliance (GLBA) Planned Corrective Action: In order to develop, implement, and maintain a written information security program, the University has contracted with a third-party information security consulting firm GreyCastle Security (GCS) to assist the institution in building out its policies, procedures, plans and other documentation. As a key part of this process, initial documentation will include an information security policy, acceptable use policy, and date classification policy and handling procedure. Additionally, a written information security program document is in scope for services to be provided to the institution as part of the contract with GCS. In order to identify and assess the risks to student information, the University has scheduled a risk assessment with GCS for mid-October 2020. This assessment is based on a NIST 800-53 Recommended Security Controls for Federal Information Systems and NIST SP 800-30 Risk Management Guide for IT Systems. These items assist with compliance with GLBA. In order to design and implement an information safeguards program, the results of the Risk Assessment identified above, the University will receive a Summary Findings Report that identifies the top 10 risks identified during the assessment. These risks will be added to a risk register and a Security Road Map development for the University. These will be used to document, track progress, identify owners, and associated activities, and target timeframes for subsequent activities or projects. Activities will include technical projects, documentation production or update, process changes, and overall education and culture change the institution where needed. In order to select the appropriate service providers that are capable of maintaining appropriate safeguards, GCS will work with the University to develop and implement an interim vendor management program. This program will require all new vendors to be reviewed with a pre-engagement form to determine the level of inherent risk of the vendor and the type of security assessment needed. These initial efforts will be focused on the Financial Services-and-Student-Aid-related vendors with plans to expand this to address a larger vendor population once the assessments of these initial vendors are completed. Additional enterprise education will be required for the University population in order to appropriately implement this significant process change. In order to periodically evaluate and update the University security program, the University?s contract with GCS includes a formal update of its risk posture with assessment update project annually if needed, and continual evaluation during standard monthly review of projects with a specific GCS-assigned project manager in addition to the virtual Chief Information Security Officer. Person Responsible for Corrective Action Plan: Michael Tucker, Executive Director of Information Technology Services Anticipated Date of Completion: March 2021
FAC accepted this audit on October 16, 2019 — management decision was due April 16, 2020.
FAC accepted this audit on October 7, 2018 — management decision was due April 7, 2019.
GSA_MIGRATION
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GSA_MIGRATION
FAC accepted this audit on September 28, 2017 — management decision was due March 28, 2018.
FAC accepted this audit on September 28, 2016 — management decision was due March 28, 2017.
GSA_MIGRATION
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GSA_MIGRATION
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