EIN: 611014882
UEI: E1KJM4T54MK6
Data as of August 25, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on February 22, 2024. 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 22, 2024 (734 days ago).
What is a management decision? →The University did not update student status change and enrollment effective date timely. Context: The enrollment effective date reported to the National Student Loan Database System (NSLDS) for one of the forty sampled students from the University was incorrect. Questioned costs: None Cause: The University did not timely or properly report student status change to NSLDS through their third-party servicer, National Student Clearinghouse (NSC). Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Repeat finding: No Recommendation: CLA recommends that the University work with their third-party servicer and implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS are reported timely. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Show full finding ▾Hide full finding ▴2023 – 002 Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.063, 84.268, 84.379, 84.033 Federal Award Identification Number: P007A221612 - 2023, P063P221506 - 2023, P268K231506 - 2023, P379T231506 - 2023, P033A221612 - 2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: Compliance, Other Matter Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure enrollment reporting is completed properly. Condition: The University did not update student status change and enrollment effective date timely. Context: The enrollment effective date reported to the National Student Loan Database System (NSLDS) for one of the forty sampled students from the University was incorrect. Questioned costs: None Cause: The University did not timely or properly report student status change to NSLDS through their third-party servicer, National Student Clearinghouse (NSC). Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Repeat finding: No Recommendation: CLA recommends that the University work with their third-party servicer and implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS are reported timely. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
FINDINGS—FEDERAL AWARD PROGRAMS AUDITS SIGNIFICANT DEFICIENCY U.S. Department of Education 2023-002 Student Financial Assistance Cluster: Assistance Listing No. 84.007, 84.063, 84.268, 84.379, 84.033 UNIVERSITY OF LOUISVILLE CORRECTIVE ACTION PLAN YEAR ENDED JUNE 30, 2023 Recommendation: We recommend that the University work with their third-party servicer and implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS are reported timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The original guidance for missing or incorrect social security number from the Clearinghouse was to reach out to the student and obtain proof of the social security number or enter the student into the system without a social security number. The student was entered without using a social security number and this issue was not resolved. The University’s Registrar’s Office has inquired about this issue and have since been provided updated guidance on how to rectify the occurrence of such. The new guidance provided has already been implemented by the Registrar’s Office. The new guidance from the National Student Clearinghouse allows for a student’s information to be entered with the social security number supplied when registering and add enrollment information. Going forward, this missing information will not preclude a student from being reported. Name(s) of the contact person(s) responsible for corrective action: Chris Goodman Planned completion date for corrective action plan: Implemented 09/28/2023 If the U.S. Department of Education has questions regarding this plan, please call Beverly Santamouris at (502) 852-6272.
FAC accepted this audit on March 27, 2022 — management decision was due September 27, 2022.
During our testing, we noted 10 of 20 students where the student was not reported to NSLDS in a timely manner.Questioned Costs: None Context: In connection to prior year audit finding (2020-001), the University implemented their corrective action plan to correct the effective date of enrollment status changes related to withdrawals on June 1, 2021. Due to the corrective plan implemented, the corrected change in enrollment status dates were not received within the required timeframe for R2T4s. The auditors noted that corrective action was properly implemented to correct the deficiency moving forward.Cause: The University implemented their corrective action plan related to prior year audit finding (2020-001). The completion date of the corrective plan related to prior year audit finding (2020-001) wasJune 1, 2021. Due to the timing of the corrective action taken, the corrected students were not reported within the 60-day required timeframe.Effect: The NSLDS system is not updated with the student information which can cause over awarding should the student transfer to another institution and the students may not properly enter the repayment period.Repeat Finding: Yes; 2020-001Recommendation: Corrective action was taken during fiscal year 2021. No further recommendation is needed.Views of responsible officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴2021 ? 002 NSLDS Enrollment ReportingFederal agency: U.S. Department of EducationFederal program title: Student Financial Aid ClusterFederal Assistance listing Numbers: 84.007, 84.033, 84.038, 84.063, 84.268, 84.379Award Period: July 1, 2020 to June 30, 2021Type of Finding:? Other mattersCriteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.309(b), states schools must have some arrangement to report student enrollment data to the National Student Loan Data System (NSLDS) through an enrollment roster file. The school is required to report changes in the student?s enrollment status, the effective date of the status, and an anticipated completion date. The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level as well as the program begin date. In addition, at a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that NSLDS sends a Roster file to the school or its third-party servicer. The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date.Condition: During our testing, we noted 10 of 20 students where the student was not reported to NSLDS in a timely manner.Questioned Costs: None Context: In connection to prior year audit finding (2020-001), the University implemented their corrective action plan to correct the effective date of enrollment status changes related to withdrawals on June 1, 2021. Due to the corrective plan implemented, the corrected change in enrollment status dates were not received within the required timeframe for R2T4s. The auditors noted that corrective action was properly implemented to correct the deficiency moving forward.Cause: The University implemented their corrective action plan related to prior year audit finding (2020-001). The completion date of the corrective plan related to prior year audit finding (2020-001) wasJune 1, 2021. Due to the timing of the corrective action taken, the corrected students were not reported within the 60-day required timeframe.Effect: The NSLDS system is not updated with the student information which can cause over awarding should the student transfer to another institution and the students may not properly enter the repayment period.Repeat Finding: Yes; 2020-001Recommendation: Corrective action was taken during fiscal year 2021. No further recommendation is needed.Views of responsible officials: There is no disagreement with the audit finding.
Recommendation: Corrective action was taken in fiscal year 2021. No further recommendation is needed.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: Corrective action in response to audit finding 2020-001 was completed on June 1, 2021. The University continues to follow the action plan presented as a result of this finding from the 2020 audit.Name(s) of the contact person(s) responsible for corrective action: Angie BlackPlanned completion date for corrective action plan: June 1, 2021
2020-001
During our testing, we noted one of forty expenditures tested which was inaccurately charged to the federal grant.Questioned Costs: $50,910Context: During our testing, it was noted that one expenditure was inaccurately charged to the federal grant.Cause: The University's controls in place to ensure expenditures are accurate and allowable are not operating effectively and failed to detect a clerical error in one expenditure inaccurately charged to the grant.Effect: The auditor noted one instance of noncompliance with the provisions of allowable costs. The internal controls in place are not operating effectively and provide further opportunities for noncompliance.Repeat Finding: NoRecommendation: We recommend the University design controls to ensure an adequate review process is in place to review costs charged to federal awards are accurate.Views of responsible officials: Controls over expenditures and allowable cost are in place to ensure allowable cost are appropriately charged to grants. The error identified was an allowable cost that was mis-keyed when being allocated to the grant, causing an over charge. The University?s established controls over reallocating cost to grants includes review of the entries and supporting documents. This error was an isolated incident as mistakes are usually caught in the review process. The incident has been communicated to the individuals responsible for the review to ensure due care is exercised in cost allocation review.
Show full finding ▾Hide full finding ▴2021 ? 003 Allowable CostsFederal agency: U.S. Department of EducationFederal program title: Governors Emergency Education Relief FundFederal Assistance listing Number: 84.425CAward Period: July 1, 2020 to June 30, 2021Type of Finding:? Significant Deficiency in Internal Control over Compliance? Other MattersCriteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of Allowable Costs. Costs must be determined in accordance with accounting principles generally accepted in the United States of America (GAAP).Condition: During our testing, we noted one of forty expenditures tested which was inaccurately charged to the federal grant.Questioned Costs: $50,910Context: During our testing, it was noted that one expenditure was inaccurately charged to the federal grant.Cause: The University's controls in place to ensure expenditures are accurate and allowable are not operating effectively and failed to detect a clerical error in one expenditure inaccurately charged to the grant.Effect: The auditor noted one instance of noncompliance with the provisions of allowable costs. The internal controls in place are not operating effectively and provide further opportunities for noncompliance.Repeat Finding: NoRecommendation: We recommend the University design controls to ensure an adequate review process is in place to review costs charged to federal awards are accurate.Views of responsible officials: Controls over expenditures and allowable cost are in place to ensure allowable cost are appropriately charged to grants. The error identified was an allowable cost that was mis-keyed when being allocated to the grant, causing an over charge. The University?s established controls over reallocating cost to grants includes review of the entries and supporting documents. This error was an isolated incident as mistakes are usually caught in the review process. The incident has been communicated to the individuals responsible for the review to ensure due care is exercised in cost allocation review.
Recommendation: We recommend the University design controls to ensure an adequate review process is in place to review costs charged to federal awards are accurate.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: Controls over expenditures and allowable cost are in place to ensure allowable cost are appropriately charged to grants. The error identified was an allowable cost that was mis-keyed when being allocated to the grant, causing an over charge. The University?s established controls over reallocating cost to grants includes review of the entries and supporting documents. This error was an isolated incident as mistakes are usually caught in the review process. The incident has been communicated to the individuals responsible for the review to ensure due care is exercised in cost allocation review.Name(s) of the contact person(s) responsible for corrective action: Beverly SantamourisPlanned completion date for corrective action plan: November 2021
FAC accepted this audit on April 25, 2021 — management decision was due October 25, 2021.
During our testing, we noted 32 of 40 students were reported to NSLDS with an incorrectenrollment effective date.Questioned Costs: NoneContext: During our testing, it was noted the University did not report the correct enrollment effectivedate for 32 withdrawn students. These students enrollment effective date reported was not back dated totheir last date of attendance.Cause: The University did not have a process in place to ensure the effective date reported to NSLDSmatches the effective date of the student?s last date of attendance.Effect: The enrollment effective date reported to NSLDS is used to determine when the student?s graceperiod should begin. By not reporting an incorrect effective date, the grace period begin date for thestudent will be incorrect.Repeat Finding: NoRecommendation: We recommend the University puts a process in place ensure the enrollmenteffective date reported to NSLDS is aligning with the University?s last date of attendance.Views of responsible officials: There is no disagreement with the audit finding. While there is nodisagreement with the finding, it is unclear that NSLDS Reporting must be maintained such that the datesare exactly the same as those used for R2T4 processing.
Show full finding ▾Hide full finding ▴2020 ? 001 Enrollment Reporting ? Incorrect Enrollment DateFederal agency: U.S. Department of EducationFederal program title: Student Financial Aid ClusterCFDA Numbers: 84.007, 84.033, 84.038, 84.063, 84.268, 84.379Award Period: July 1, 2019 to June 30, 2020Type of Finding:? Significant Deficiency in Internal Control over Compliance? Other mattersCriteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.309(b), states schoolsmust have some arrangement to report student enrollment data to the National Student Loan DataSystem (NSLDS) through an enrollment roster file. The school is required to report changes in thestudent?s enrollment status, the effective date of the status, and an anticipated completion date.Condition: During our testing, we noted 32 of 40 students were reported to NSLDS with an incorrectenrollment effective date.Questioned Costs: NoneContext: During our testing, it was noted the University did not report the correct enrollment effectivedate for 32 withdrawn students. These students enrollment effective date reported was not back dated totheir last date of attendance.Cause: The University did not have a process in place to ensure the effective date reported to NSLDSmatches the effective date of the student?s last date of attendance.Effect: The enrollment effective date reported to NSLDS is used to determine when the student?s graceperiod should begin. By not reporting an incorrect effective date, the grace period begin date for thestudent will be incorrect.Repeat Finding: NoRecommendation: We recommend the University puts a process in place ensure the enrollmenteffective date reported to NSLDS is aligning with the University?s last date of attendance.Views of responsible officials: There is no disagreement with the audit finding. While there is nodisagreement with the finding, it is unclear that NSLDS Reporting must be maintained such that the datesare exactly the same as those used for R2T4 processing.
Recommendation: We recommend the University puts a process in place ensure the enrollment effective date reported to NSLDS is aligning with the University?s last date of attendance.Explanation of disagreement with audit finding: There is no disagreement with the audit finding. While there is no disagreement with the finding, it is unclear that NSLDS Reporting must be maintained such that the dates are exactly the same as those used for R2T4 processing. These are the situations where the enrollment dates differ. Further explanation below for `Actions taken?.Action taken in response to finding: We will review our process and continue to refine procedures so there is as much consistency as possible.Based on the `NSLDS Enrollment Reporting Guide November 2020? that ?the Department defers to a school?s policy regarding the establishment of effective dates?, as a school not required to take attendance, to ensure consistent and fair enrollment reporting for all students regardless of their current Title IV eligibility, the official withdraw date (the date the student officially withdrew from all of his/hers coursework for the term) is what is reported to NSLDS as the effective date of withdraw. The withdrawal date is known for all students who officially withdraw; therefore, it has been identified as the date that can consistently be reported for all students.For current Title IV aid recipients who withdraw from all coursework, since we may always use the last date of attendance at an academically related activity as a student?s withdrawal date when determining the amount of overpayment received, if it is determined a student?s last date of attendance at an academically related activity precedes the student?s withdraw date, the earlier date is used to determine the earned and unearned portions of Title IV aid.Since the last date of attendance at an academically related activity is not sought for students who are not currently Title IV aid recipients (since no overpayment has been received), the official withdrawal date is reported to NSLDS for all students. However, to ensure the most accurate calculation of overpayment, the date of attendance at an academically related activity is used for the return calculation if it proceeds the official withdrawal date. Therefore, to ensure consistent and fair enrollment reporting, and at the same time ensuring the most accurate calculations of potential overpayments, the following is our withdraw date policy:Withdraw date used by the institution for reporting purposes?the official date the student withdrew from the universityWithdraw date used for R2T4 calculation purposes?if the student?s last date of participation in an academically related activity is less-than the official withdraw date, the last date of participation of an academically related activity is used for R2T4 calculation purposes only.Name of the contact person responsible for corrective action: Angie BlackPlanned completion date for corrective action plan: August 1, 2021
FAC accepted this audit on November 3, 2019 — management decision was due May 3, 2020.
Students who entered repayment during the fall semester of 2018 did not receive exit counseling communications within the 30-day timeframe required. Cause: University management has indicated that staff turnover in the Bursar?s office contributed to the noncompliance. Effect: Exit counseling communications with students entering Perkins repayment were not conducted timely. Repeat Finding: Yes Recommendation: We recommend that the Bursar?s office implement internal control improvements in order to ensure compliance with this requirement. Separation dates must be updated in a timely manner to allow for communication to occur with the students within 30 days. Views of Responsible Officials: The University has identified the management of student loans as an area of development. The correction implemented was the assignment of an individual in the Bursar?s office the responsibilities of loan monitoring, including ensuring exit counseling materials are provided to students in the appropriate manner and time frame. The University will continue to monitor student loan activities and the resources available to perform these functions to address the timeliness of supplying materials to students.
Show full finding ▾Hide full finding ▴FINDING 2019-004 ? Perkins Exit Counseling (Significant Deficiency/No Questioned Costs) Federal Program: CFDA No. 84.038 Department of Education Federal Perkins Loan Program Award Period: July 1, 2018 to June 30, 2019 Criteria: 34 CFR 674.42(b) - Exit counseling - An institution must ensure that exit counseling is conducted with each borrower either in person, by audiovisual presentation, or by interactive electronic means. The institution must ensure that exit counseling is conducted shortly before the borrower ceases at least half?time study at the institution. As an alternative, in the case of a student enrolled in a correspondence program or a study-abroad program that the institution approves for credit, the borrower may be provided with written counseling material by mail within 30 days after the borrower completes the program. If a borrower withdraws from the institution without the institution?s prior knowledge or fails to complete an exit counseling session as required, the institution must ensure that exit counseling is provided through either interactive electronic means or by mailing counseling materials to the borrower at the borrower?s last known address within 30 days after learning that the borrower has withdrawn from the institution or failed to complete exit counseling as required. Condition: Students who entered repayment during the fall semester of 2018 did not receive exit counseling communications within the 30-day timeframe required. Cause: University management has indicated that staff turnover in the Bursar?s office contributed to the noncompliance. Effect: Exit counseling communications with students entering Perkins repayment were not conducted timely. Repeat Finding: Yes Recommendation: We recommend that the Bursar?s office implement internal control improvements in order to ensure compliance with this requirement. Separation dates must be updated in a timely manner to allow for communication to occur with the students within 30 days. Views of Responsible Officials: The University has identified the management of student loans as an area of development. The correction implemented was the assignment of an individual in the Bursar?s office the responsibilities of loan monitoring, including ensuring exit counseling materials are provided to students in the appropriate manner and time frame. The University will continue to monitor student loan activities and the resources available to perform these functions to address the timeliness of supplying materials to students.
2019-004 Federal Perkins Loan Program ? CFDA No. 84.038 Recommendation: We recommend that the Bursar's office implement internal control improvements in order to ensure compliance with this requirement. Separation dates must be updated in a timely manner to allow for communication to occur with the students within 30 days. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University has identified the management of student loans as an area of development. The correction implemented was the assignment of an individual in the Bursar?s office the responsibilities of loan monitoring, including ensuring exit counseling materials are provided to students in the appropriate manner and time frame. The University will continue to monitor student loan activities and the resources available to perform these functions to address the timeliness of supplying materials to students. Name(s) of the contact person(s) responsible for corrective action: Carrie McCubbins, Bursar Planned completion date for corrective action plan: June 30, 2020
2018-003
During the year, several student status changes were not properly reported to National Student Loan Data Systems (NSLDS) within the 30 day timeframe. Cause: University management has indicated that enrollment status changes were sent to National Student Clearinghouse (NSC) within the 30 day timeframe, but due to delays at NSC, changes were not properly reported to NSLDS within the required timeframe. Effect: Student enrollment status changes were not received by NSLDS within the 30 day timeframe required. Repeat Finding: No Recommendation: We recommend that the Bursar?s office and the Financial Aid office review dates scheduled to submit student enrollment data and work with NCS to ensure that changes are properly reported within the 30 day timeframe required. Views of Responsible Officials: In all instances reviewed during the audit, the University submitted files to NSC within the 30 day requirement. The files were not accepted by NSC and forwarded to NSLDS in a timely manner that resulted in the files being late. The issue resides with the time taken by NCS to accept the files. The University will continue to submit files within the accepted time frame. The University will also work with NSC to ensure the process to accept the files falls within the accepted time frame.
Show full finding ▾Hide full finding ▴FINDING 2019-005 ? Enrollment Reporting ? Untimely Student Status Reporting (Significant Deficiency/No Questioned Costs) Federal Program: Student Financial Aid Cluster Award Period: July 1, 2018 to June 30, 2019 Criteria: 34 CFR 685.309 (b) - Enrollment Reporting - Unless it expects to submit its next student status confirmation report to the Secretary within the next 60 days, notify the Secretary within 30 days if it discovers that a Direct Subsidized, Direct Unsubsidized, or Direct PLUS Loan has been made to or on behalf of a student who?(i) Enrolled at that school but has ceased to be enrolled on at least a halftime basis; (ii) Has been accepted for enrollment at that school but failed to enroll on at least a half-time basis for the period for which the loan was intended; or (iii) Has changed his or her permanent address. Condition: During the year, several student status changes were not properly reported to National Student Loan Data Systems (NSLDS) within the 30 day timeframe. Cause: University management has indicated that enrollment status changes were sent to National Student Clearinghouse (NSC) within the 30 day timeframe, but due to delays at NSC, changes were not properly reported to NSLDS within the required timeframe. Effect: Student enrollment status changes were not received by NSLDS within the 30 day timeframe required. Repeat Finding: No Recommendation: We recommend that the Bursar?s office and the Financial Aid office review dates scheduled to submit student enrollment data and work with NCS to ensure that changes are properly reported within the 30 day timeframe required. Views of Responsible Officials: In all instances reviewed during the audit, the University submitted files to NSC within the 30 day requirement. The files were not accepted by NSC and forwarded to NSLDS in a timely manner that resulted in the files being late. The issue resides with the time taken by NCS to accept the files. The University will continue to submit files within the accepted time frame. The University will also work with NSC to ensure the process to accept the files falls within the accepted time frame.
2019-005 Student Financial Aid Cluster ? CFDA No. 84.007, 84.033, 84.038, 84.063, 84.268, 84.379 Recommendation: We recommend that the Bursar?s office and the Financial Aid office review dates scheduled to submit student enrollment data and work with National Student Loan Clearinghouse (NSC) to ensure that changes are properly reported within the 30 day timeframe required. Explanation of disagreement with audit finding: In all instances reviewed during the audit, the University submitted files to NSC within the 30 day requirement. The files were not accepted by NSC and forwarded to the National Student Loan Data System for Students (NSLDS) in a timely manner that resulted in the files being late. The issue resides with the time taken by NCS to accept the files. Action taken in response to finding: The University will continue to submit files within the accepted time frame. The University will also work with NSC to ensure the process to accept the files falls within the accepted time frame. Name(s) of the contact person(s) responsible for corrective action: Director, Student Financial Aid Planned completion date for corrective action plan: June 30, 2020
During the year, several student error records were not corrected and returned to NSLDS within 10 day timeframe required Cause: University management has indicated that error record corrections were sent to NSC within the 10 day timeframe, but due to delays at NSC, changes were not properly reported to NSLDS within the required timeframe. Effect: Error records were not corrected and received by NSLDS within the 10 day timeframe required. Repeat Finding: No Recommendation: We recommend that the Bursar?s office and the Financial Aid office work with NCS to ensure that error record corrections are properly reported to NSLDS within the 10 day timeframe required. Views of Responsible Officials: In all instances reviewed during the audit, the University submitted files to NSC within the 10 day requirement. The files were not accepted by NSC and forwarded to NSLDS in a timely manner that resulted in the files being late. The issue resides with the time taken by NSC to accept the files. The University will continue to submit files within the accepted time frame. The University will also work with NSC to ensure the process to accept the files falls within the accepted time frame.
Show full finding ▾Hide full finding ▴FINDING 2019-006 ? Enrollment Reporting - Untimely Error Correction (Significant Deficiency/No Questioned Costs) Federal Program: Student Financial Aid Cluster Award Period: July 1, 2018 to June 30, 2019 Criteria: NSLDS processes the file and returns an Acknowledgement/Error File that contains a count of accepted records and any error records. Error records must be corrected and returned within 10 days of the receipt of the Acknowledgement/Error File. The file is returned as an Error Correction file. Condition: During the year, several student error records were not corrected and returned to NSLDS within 10 day timeframe required Cause: University management has indicated that error record corrections were sent to NSC within the 10 day timeframe, but due to delays at NSC, changes were not properly reported to NSLDS within the required timeframe. Effect: Error records were not corrected and received by NSLDS within the 10 day timeframe required. Repeat Finding: No Recommendation: We recommend that the Bursar?s office and the Financial Aid office work with NCS to ensure that error record corrections are properly reported to NSLDS within the 10 day timeframe required. Views of Responsible Officials: In all instances reviewed during the audit, the University submitted files to NSC within the 10 day requirement. The files were not accepted by NSC and forwarded to NSLDS in a timely manner that resulted in the files being late. The issue resides with the time taken by NSC to accept the files. The University will continue to submit files within the accepted time frame. The University will also work with NSC to ensure the process to accept the files falls within the accepted time frame.
2019-006 Student Financial Aid Cluster ? CFDA No. 84.007, 84.033, 84.038, 84.063, 84.268, 84.379 Recommendation: We recommend that the Bursar?s office and the Financial Aid office work with NSC to ensure that error record corrections are properly reported to NSLDS within the 10 day timeframe required. Explanation of disagreement with audit finding: In all instances reviewed during the audit, the University submitted files to NSC within the 10 day requirement. The files were not accepted by NSC and forwarded to NSLDS in a timely manner that resulted in the files being late. The issue resides with the time taken by NSC to accept the files. Action taken in response to finding: The University will continue to submit files within the accepted time frame. The University will also work with NSC to ensure the process to accept the files falls within the accepted time frame. Name(s) of the contact person(s) responsible for corrective action: Director, Student Financial Aid Planned completion date for corrective action plan: June 30, 2020
Under an institution?s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs. During our audit procedures, it was noted that the College/University did not designate an individual to coordinate the information security program; perform a risk assessment that addresses the three areas noted in 16 CFR 314.4 (b) which are (1) Employee training and management; (2) Information systems, including network and software design, as well as information processing, storage, transmission and disposal; and (3) Detecting, preventing and responding to attacks, intrusions, or other systems failures and document safeguards for identified risks. Cause: The University uses a third party IT service provider for IT related tasks and relied on that service provider to ensure all compliance requirements are met. However, the organization should have an individual designated internally to assure compliance with the requirements of the Gramm-Leach-Bliley Act. The organization did not perform an IT risk assessment tailored specifically to the organization, identify risks or address risks identified as required by the Gramm-Leach-Bliley Act. The compliance requirements related to the Gramm-Leach-Bliley Act was an addition made to the 2019 Compliance Supplement specifically relating to the Student Financial Aid Cluster. The Federal Trade Commission now considers Title IV-eligible institutions that participate in the Title IV Educational Assistance Programs as ?financial institutions? and subject to the Gramm-Leach-Bliley Act. Effect: The student personal information could be vulnerable. Repeat Finding: No Recommendation: We recommend that the University designate an individual to oversee the information security function, engage a third party or perform the risk assessment for the three areas required by the Gramm-Leach-Bliley Act and ensure that there are documented safeguards for identified risks. Views of Responsible Officials: The University will evaluate the current Information Technology security atmosphere under the guidance requirements of GLBA and establish oversight of the information security activities pertaining to student accounts and student financial aid. The responsibility for oversight and monitoring will reside with the appropriate manager familiar with the information technology policies and procedures.
Show full finding ▾Hide full finding ▴FINDING 2019-007 ? Gramm-Leach-Bliley Act ? Student Information Security (Significant Deficiency/No Questioned Costs) Federal Program: Student Financial Aid Cluster Award Period: July 1, 2018 to June 30, 2019 Criteria: The Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as ?financial institutions? and subject to the Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi). Condition: Under an institution?s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs. During our audit procedures, it was noted that the College/University did not designate an individual to coordinate the information security program; perform a risk assessment that addresses the three areas noted in 16 CFR 314.4 (b) which are (1) Employee training and management; (2) Information systems, including network and software design, as well as information processing, storage, transmission and disposal; and (3) Detecting, preventing and responding to attacks, intrusions, or other systems failures and document safeguards for identified risks. Cause: The University uses a third party IT service provider for IT related tasks and relied on that service provider to ensure all compliance requirements are met. However, the organization should have an individual designated internally to assure compliance with the requirements of the Gramm-Leach-Bliley Act. The organization did not perform an IT risk assessment tailored specifically to the organization, identify risks or address risks identified as required by the Gramm-Leach-Bliley Act. The compliance requirements related to the Gramm-Leach-Bliley Act was an addition made to the 2019 Compliance Supplement specifically relating to the Student Financial Aid Cluster. The Federal Trade Commission now considers Title IV-eligible institutions that participate in the Title IV Educational Assistance Programs as ?financial institutions? and subject to the Gramm-Leach-Bliley Act. Effect: The student personal information could be vulnerable. Repeat Finding: No Recommendation: We recommend that the University designate an individual to oversee the information security function, engage a third party or perform the risk assessment for the three areas required by the Gramm-Leach-Bliley Act and ensure that there are documented safeguards for identified risks. Views of Responsible Officials: The University will evaluate the current Information Technology security atmosphere under the guidance requirements of GLBA and establish oversight of the information security activities pertaining to student accounts and student financial aid. The responsibility for oversight and monitoring will reside with the appropriate manager familiar with the information technology policies and procedures.
2019-007 Student Financial Aid Cluster ? CFDA No. 84.007, 84.033, 84.038, 84.063, 84.268, 84.379 Recommendation: We recommend that the University designate an individual to oversee the information security function, engage a third party or perform the risk assessment for the three areas required by the Gramm-Leach-Bliley Act (GLBA) and ensure that there are documented safeguards for identified risks. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University will evaluate the current Information Technology security atmosphere under the guidance requirements of GLBA and establish oversight of the information security activities pertaining to student accounts and student financial aid. The responsibility for oversight and monitoring will reside with the appropriate manager familiar with the information technology policies and procedures. Name(s) of the contact person(s) responsible for corrective action: Walter Newell, Controller Planned completion date for corrective action plan: June 30, 2020
FAC accepted this audit on November 13, 2018 — management decision was due May 13, 2019.
GSA_MIGRATION
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GSA_MIGRATION
2017-001
FAC accepted this audit on November 28, 2017 — management decision was due May 28, 2018.
GSA_MIGRATION
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GSA_MIGRATION
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