EIN: 570324936
UEI: SXNQC85MLC96
Data as of August 24, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on December 17, 2025. 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 June 17, 2026 (69 days ago).
What is a management decision? →The University did not always report enrollment information to the National Student Loan Data System (NSLDS) in an accurate manner for graduate students. Criteria: 34 CFR 685.309 Questioned Costs: $0 Context: Out of 60 students tested, 5 graduate students had incorrect enrollment statuses reported to NSLDS. 3 doctoral program students were reported as being less than half-time rather than full-time. Even though the students were enrolled and attending full-time, reporting the students as less than half-time triggered the students into repayment for their loans. 2 graduate students were reported as being three-quarter time rather than full-time. Being reported at three-quarter time did not impact the students’ repayment for their loans. These statuses were updated and corrected during the audit. This finding is isolated to the graduate student population. Cause: Transition in financial aid staff. Effect: Inaccurate reporting can impact a student’s loan grace period in school deferment eligibility, beginning loan repayments, appropriate interest charges, etc. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the student financial aid team and registrar work together, potentially including information technology, to ensure that accurate fields are captured from the system for NSLDS enrollment reporting. Additionally, we recommend that the registrar completes spot checks of NSLDS enrollment statuses throughout the year. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴2025-001 Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Direct Student Loan Program Federal Award Identification #: 2024-2025 Financial Aid Year Condition: The University did not always report enrollment information to the National Student Loan Data System (NSLDS) in an accurate manner for graduate students. Criteria: 34 CFR 685.309 Questioned Costs: $0 Context: Out of 60 students tested, 5 graduate students had incorrect enrollment statuses reported to NSLDS. 3 doctoral program students were reported as being less than half-time rather than full-time. Even though the students were enrolled and attending full-time, reporting the students as less than half-time triggered the students into repayment for their loans. 2 graduate students were reported as being three-quarter time rather than full-time. Being reported at three-quarter time did not impact the students’ repayment for their loans. These statuses were updated and corrected during the audit. This finding is isolated to the graduate student population. Cause: Transition in financial aid staff. Effect: Inaccurate reporting can impact a student’s loan grace period in school deferment eligibility, beginning loan repayments, appropriate interest charges, etc. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the student financial aid team and registrar work together, potentially including information technology, to ensure that accurate fields are captured from the system for NSLDS enrollment reporting. Additionally, we recommend that the registrar completes spot checks of NSLDS enrollment statuses throughout the year. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) Planned Corrective Action: Will need to meet with academic records and determine if Doctorate program Dissertation 1-hour course can be coded and reported as full time to NSLDS Person Responsible for Corrective Action Plan: Academic Records / Regina Bolding Harned - Registrar / Allison Sullivan – Director of Financial Aid Anticipated Date of Completion: 12/5/25
FAC accepted this audit on February 4, 2025 — management decision was due August 4, 2025.
The University did not always calculate nontraditional students’ unearned Title IV funds correctly or return funds timely. Criteria: 34 CFR 668.22 Questioned Costs: $184 Context: Out of 9 withdrawals tested, 3 modular unofficial withdrawals had inaccurate R2T4 calculations. Two of those inaccurate R2T4s were also late returns totaling $4,057 ranging 12 to 18 days late. One student did not have the week break between modules excluded from the total days used in the R2T4 calculation ($49 FDL over returned). One student, who was tested for the Fall and Spring semesters, did not have the correct tuition cost included in both the Fall and Spring R2T4 calculations ($184 FDL under returned in the Fall, $210 FDL over returned in the Spring). These were not corrected during the audit. Cause: There was transition in the financial aid office in the middle of the 2023-2024 award year. Effect: Incorrect amounts of unearned Title IV funds were returned and returns were not made timely. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend an individual in financial aid with the appropriate level of experience periodically review modular students’ R2T4 calculations and returns to help ensure that internal controls over such process can operate effectively and achieve compliance. We also recommend the financial aid office run a 0-credit report at the end of each term for modular students to ensure that all unofficial withdrawals requiring returns are returned timely. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Untimely and Inaccurate Returns of Title IV Funds (R2T4) Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063 Federal Award Identification #: 2023-2024 Award Year Condition: The University did not always calculate nontraditional students’ unearned Title IV funds correctly or return funds timely. Criteria: 34 CFR 668.22 Questioned Costs: $184 Context: Out of 9 withdrawals tested, 3 modular unofficial withdrawals had inaccurate R2T4 calculations. Two of those inaccurate R2T4s were also late returns totaling $4,057 ranging 12 to 18 days late. One student did not have the week break between modules excluded from the total days used in the R2T4 calculation ($49 FDL over returned). One student, who was tested for the Fall and Spring semesters, did not have the correct tuition cost included in both the Fall and Spring R2T4 calculations ($184 FDL under returned in the Fall, $210 FDL over returned in the Spring). These were not corrected during the audit. Cause: There was transition in the financial aid office in the middle of the 2023-2024 award year. Effect: Incorrect amounts of unearned Title IV funds were returned and returns were not made timely. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend an individual in financial aid with the appropriate level of experience periodically review modular students’ R2T4 calculations and returns to help ensure that internal controls over such process can operate effectively and achieve compliance. We also recommend the financial aid office run a 0-credit report at the end of each term for modular students to ensure that all unofficial withdrawals requiring returns are returned timely. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Untimely and Inaccurate Returns of Title IV Funds (R2T4) Planned Corrective Action: A review of the student withdrawal process from Registrar notifications to assignment of financial aid reviews and Return of Title IV calculations will be conducted and any needed changes implemented to ensure timely processing. As there are currently only four FA personnel, the Director will continue to process the R2T4 notifications and be held responsible for any late processing. Back-up training for the Associate Director will also be implemented to ensure continuity of coverage in the event the Director is not available to cover this responsibility. Person Responsible for Corrective Action Plan: Thomas Valles, Director of Financial Aid Anticipated Date of Completion: April 30, 2025
Students were not appropriately awarded loans based on need. Criteria: 34 CFR 685.200(a), 34 CFR 685.203 Questioned Costs: $1,237 Context: Out of 60 students tested, 2 students were not awarded aid appropriately based on need analysis. One student who graduated in the Spring term had their loans incorrectly prorated for completing 21 total credit hours out of 24 credit hours for full-time determination; this caused the student to be under awarded $1,563 in FDL. One student was awarded $1,237 in subsidized loans over need. These were not corrected during the audit. Cause: There was transition in the financial aid office in the middle of the 2023-2024 award year. Effect: Students not awarded need based federal aid according to eligibility. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend that the University set up reports in the student information system to periodically check for over or under awarding of need based federal aid. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Need Analysis DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Award Identification #: 2023-2024 Award Year Condition: Students were not appropriately awarded loans based on need. Criteria: 34 CFR 685.200(a), 34 CFR 685.203 Questioned Costs: $1,237 Context: Out of 60 students tested, 2 students were not awarded aid appropriately based on need analysis. One student who graduated in the Spring term had their loans incorrectly prorated for completing 21 total credit hours out of 24 credit hours for full-time determination; this caused the student to be under awarded $1,563 in FDL. One student was awarded $1,237 in subsidized loans over need. These were not corrected during the audit. Cause: There was transition in the financial aid office in the middle of the 2023-2024 award year. Effect: Students not awarded need based federal aid according to eligibility. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend that the University set up reports in the student information system to periodically check for over or under awarding of need based federal aid. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Need Analysis Planned Corrective Action: A process to periodically review over and under awarding of federal need-based aid will be implemented. This will require IT assistance to create and run lists of students in this situation on a weekly basis. Person Responsible for Corrective Action Plan: Thomas Valles, Director of Financial Aid Anticipated Date of Completion: April 30, 2025
FAC accepted this audit on December 8, 2023 — management decision was due June 8, 2024.
The University did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $0 Context: The University has not updated its written information security program in light of regulation changes, sufficiently documented its security risk assessment and safeguards, including general threats, implemented sufficient vendor management policies and reviews, implemented an incident response plan, or provided a written, annual report to the board. Cause: The University has not allocated sufficient resources to address and document compliance with the requirements of GLBA due to turnover in the IT department. Effect: The University has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, and 84.379 - Student Financial Assistance Cluster Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The University did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $0 Context: The University has not updated its written information security program in light of regulation changes, sufficiently documented its security risk assessment and safeguards, including general threats, implemented sufficient vendor management policies and reviews, implemented an incident response plan, or provided a written, annual report to the board. Cause: The University has not allocated sufficient resources to address and document compliance with the requirements of GLBA due to turnover in the IT department. Effect: The University has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance Planned Corrective Action: In order to remediate cited deficiencies and to bring Southern Wesleyan University into compliance with updated regulation changes to the Gramm-Leach-Bliley Act, the Department of Information Technology will update its written information security program. In addition, the department will also sufficiently document its security risk assessment and safeguards. This documentation will include sufficient information on general threats, the implementation of vendor management policies and reviews, and the implementation of an incident response plan. After all the aforementioned documentation has been compiled, the department will provide a report to the Board at the university's fall 2024 Board of Trustee’s meeting, detailing the measures enacted. Person Responsible for Corrective Action Plan: Warren Dennis, Assistant Director of Information Technology Anticipated Date of Completion: 06/01/2024
FAC accepted this audit on December 7, 2020 — management decision was due June 7, 2021.
The University did not sufficiently comply with all requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $0 Context: Risk assessment, appropriate vendor management, and safeguards are not documented. Effect: The University has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Cause: The University has not allocated sufficient resources to address all requirements of GLBA. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA. Views of Responsible Officials: Management agrees with the finding and is in the process of addressing the issue. See corrective action plan.
Show full finding ▾Hide full finding ▴2020-002 Gramm-Leach-Bliley-Act Compliance (GLBA) Significant Deficiency DEPARTMENT OF EDUCATION CFDA #: 84.268, 84.063, 84.007, 84.033, 84.038 and 84.379 Federal Award Identification #: 19/20 Award Year Condition: The University did not sufficiently comply with all requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $0 Context: Risk assessment, appropriate vendor management, and safeguards are not documented. Effect: The University has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Cause: The University has not allocated sufficient resources to address all requirements of GLBA. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA. Views of Responsible Officials: Management agrees with the finding and is in the process of addressing the issue. See corrective action plan.
Finding Number: 2020-002 Gramm-Leach-Bliley-Act Compliance Planned Corrective Action: We will pursue implementation of Capin Crouse?s comments/recommendations. This will require a collaborative effort between IT, Accounting, and Financial Aid. IT has already had a joint call with Capin Crouse. IT to begin a review of the related requirements. Specific areas that will be addressed: - Develop, implement, and maintain a written information security program (scaled to the institution?s size, complexity of its operations, and sensitivity of the information it must protect). - Designate the employee(s) responsible for coordinating the program - Identify and assess the risks to student information - Design and implement an information safeguards program - Select appropriate service providers that are capable of maintaining appropriate safeguards - Periodically evaluate and update their security program. Person Responsible for Corrective Action Plan: Brian Bartlett, Executive Director of Information Technology Anticipated Date of Completion: 6/30/2021
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