Princeton Theological Seminary

To: PKF O’Connor Davies LLP, U.S. Department of Education From: Princeton Theological Seminary Jean Hall, Vice President for Finance & CEO Date: March XX, 2025 Subject: Princeton Theological Seminary - Corrective Action Plan for the Year Ending June 30, 2024 2024-001 Special Tests and Provisions – Enrollment Reporting Federal Assistance Listing Number: 84.268, 84.038, and 84.033 Name of Program or Cluster: Student Financial Aid Cluster Agency: U.S. Department of Education Criteria: Princeton Theological Seminary (the “Seminary”) is required to update students’ statuses on the National Student Loans Data System (“NSLDS”) website if they graduate, withdraw or have an increase/decrease in attendance level during the year within 60 days of the date the Seminary becomes aware of the change in enrollment status. Condition: The Seminary did not submit an accurate status change notification to the NSLDS website for two out of eleven students sampled from a total population of 110 students who graduated, withdrew or had an increase/decrease in attendance level during the year. Cause: Management oversight. Effect: Noncompliance with OMB federal grant compliance requirements. Questioned Costs: None. Repeat Finding: Yes. Recommendation: The Seminary should properly follow its policies and procedures over enrollment reporting to ensure that all status changes are submitted to the NSLDS website accurately and within the required timeframe. Views of Responsible Officials: Princeton Theological Seminary’s management acknowledges these two errors and agrees with the requirement to update students’ enrollment status changes as they occur and in a timely manner. The Seminary’s policy mandates reporting every thirty (30) days, and in these two occurrences, that did not happen. We will review all current student files to ensure compliance. Our Corrective Action Plan to prevent further errors includes implementing a monitoring and verification process of the reporting through the National Student Clearinghouse to the National Student Loan Data System (NSLDS). Further, our Registrar’s office will be required to promptly review and resolve any discrepancies noted in the NSLDS or National Student Clearinghouse error reporting.

July 13, 2022 Princeton Theological Seminary submits the following corrective action plan for the year ended June 30, 2022. Audit period: July 1, 2021 to June 30, 2022 The finding from the schedule of finds and questioned costs are discussed below. Finding 2021-001 Federal Agency: Department of Education Federal Program Title: Coronavirus Aid, Relief and Economic Security Act ? Higher Education Emergency Relief Fund ? Institutional Portion Assistance Listing Number: 84.425F ? Institutional Portion Award Period: July 1, 2020 to June 30, 2021 Type of Finding: Significant Deficiency in Internal Control Over Compliance Criteria or Specific Requirement: The Cares Act 18004(e) and the CRRSAA 314(e) requires an institution receiving funds under the HEERF grant to submit timely quarterly reports to the Department of Education as well as publicly post to the institution?s website. The quarterly reporting forms must be conspicuously posted on the institution?s primary website on the same page the reports of the institution's activities as to the emergency financial aid grants to students made with funds from the institution's allocation under Section 18004(a)(1) of the CARES Act (Student Aid Portion) are posted. A new separate form must be posted covering each quarterly reporting period (September 30, December 31, March 31, June 30). The institution must post this quarterly report form no later than 10 days after the end of each calendar quarter (October 10, January 10, April 10, July 10) apart from the first report, which was due October 30, 2020. Condition: During our testing of the quarterly reports for the institutional portion of the HEERF grants, we noted that the Seminary was unable to provide the documentation for the timely submission of the quarterly reports for three of four quarterly reports and support that the three of four quarterly reports were uploaded to the institution?s website within the required 10-day timeframe. There was one of four quarterly reports timely submitted and uploaded to the website, however the report included inaccurate information and was to be revised by the Seminary. Questioned Costs: None. Context: During our testing of the quarterly reports for the institutional portion of the HEERF grants, we noted that the Seminary could not produce the documentation for the quarterly reports submitted and support that the reports were publicly posted on their website within the required 10 days of the calendar quarter. The Seminary also did not revise the report that was submitted and publicly posted as it included inaccurate information. Cause: The Seminary did not have the proper controls and processes in place to identify and track the reporting requirements regarding the HEERF grants. Effect: Failure to support or file the required reports timely may result in the loss of funding. Repeat Finding: No. Recommendation: We recommend that the Seminary enhance its procedures, controls and review policies around CARES Act and CRRSAA reporting requirements regarding the HEERF grant. The missing quarterly reports should be submitted and posted to their website immediately in order to satisfy the required compliance requirements. Also, the Seminary should revise the quarterly report previously submitted and posted with updated information. Action planned/taken in response to finding: Princeton Theological Seminary?s corrective plan with regard to Finding 2021-001 will involve the following steps in order to ensure full compliance with governmental regulations: 1. As quarterly reporting is now required to be in compliance with regulations, a working group will meet either in person, or virtually ten days prior to the end of each fiscal quarter. (March 20, June 20, September 20, December 20). At this meeting, the working group will go over the spending for that quarter, and ensure the necessary report is completed. a. The working group will consist of the Director of Financial Aid, and two members of the Business Office. 2. The Office of Communications will be informed that there will be a regular need for quarterly updates to the CARES/HEERF section of our website. Once the report is completed at the meeting detailed in item number 1 above, the report will be forwarded immediately to the Office of Communication for posting. 3. The working group will communicate with each other 3 days before the posting deadline for each quarter (April 7, July 7, October 7, January 7) via email to ensure the report is posted, and sent via email to the Department of Education. 4. All of the above-mentioned dates will be sent via Microsoft Outlook to the parties mentioned above and to the VP for Finance to ensure that these dates are reserved, and that proper oversight is done. Names of the contact persons responsible for the corrective action: Director of Institutional Advancement, Mike Livio and Deputy to the CFO/Controller, Rachele Sylvan Planned completion date for corrective action plan: June 30, 2022 Regards, Rachele Sylvan Cc: K. Gabbard E. Cheng