EIN: 351045939
UEI: FC4WY6KFK5E6
Data as of August 24, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 26, 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 September 26, 2024 (697 days ago).
What is a management decision? →The Seminary did document the evaluation of student satisfactory academic progress. Context: Out of a population of 50 students who received aid under the student financial aid cluster, we sampled 10. No documentation of the annual evaluation of satisfactory academic progress was maintained either within or outside of the student management system. None of the sample of 10 were found to not have achieved satisfactory academic progress. Questioned Costs: None Cause: Manual evaluations are being performed in accordance with the Seminary's policy but are not documented within the student management software. Effect: No documentation exists that the annual evaluation was performed. Recommendation: We recommend that management adjust its procedures to document the annual evaluation either within our outside of the student management software. Views of responsible officials and planned corrective actions: Management acknowledges this finding and is working on documentation to remove this deficiency in the future. Satisfactory academic progress is being calculated, but lack of paperwork by the Seminary made this finding necessary. The Seminary financial aid department will work on documenting processes moving forward.
Show full finding ▾Hide full finding ▴MATERIAL WEAKNESS, Document Satisfactory Academic Progress Evaluation, Information on the federal program: U.S. Department of Education, Assistance Listing No. 84.268; Federal Direct Student Loan Program, Criteria: Students awarded financial aid must meet certain eligibility requirements including maintaining satisfactory academic progress. Condition: The Seminary did document the evaluation of student satisfactory academic progress. Context: Out of a population of 50 students who received aid under the student financial aid cluster, we sampled 10. No documentation of the annual evaluation of satisfactory academic progress was maintained either within or outside of the student management system. None of the sample of 10 were found to not have achieved satisfactory academic progress. Questioned Costs: None Cause: Manual evaluations are being performed in accordance with the Seminary's policy but are not documented within the student management software. Effect: No documentation exists that the annual evaluation was performed. Recommendation: We recommend that management adjust its procedures to document the annual evaluation either within our outside of the student management software. Views of responsible officials and planned corrective actions: Management acknowledges this finding and is working on documentation to remove this deficiency in the future. Satisfactory academic progress is being calculated, but lack of paperwork by the Seminary made this finding necessary. The Seminary financial aid department will work on documenting processes moving forward.
Planned Corrective Action: The Director of Financial Aid will document the calculation of Satisfactory Academic Progress. This calculation has occurred each year but the Seminary didn’t keep the documents that proved that the calculation was done and applied to each student. In the future, the Director of Financial Aid will keep detailed records of the calculation on each student and retain the records for audit purposes. Person Responsible for Corrective Action Plan: Sandra Mitchell-Holder – Director of Financial Aid Anticipated Completion Date: June 2024
The Seminary did not have a written program in place by June 9, 2023, the required deadline. Context: The Seminary has an outsourced IT provider which provides services under a service agreement. Questioned Costs: None, Cause: Management was not aware of the documentation requirement. Effect: While the services provided by the IT service provider as well as the Seminary's internal IT department address security concerns and needs within the Seminary, all areas of Gramm-Leach-Bliley might not be addressed. Recommendation: We recommend that management develop the written comprehensive information security program using the standards set by the Gramm-Leach-Bliley Act including designating a qualified individual responsible for overseeing, implementing, and enforcing the program. Views of responsible officials and planned corrective actions: Management acknowledges this finding and is working toward documenting Gramm-Leach-Bliley Act processes and procedures. The Seminary is working on formal process and procedure guides. The Seminary has done work in this area, but without a procedure guide we realize that the documentation is as key as the work that is being done.
Show full finding ▾Hide full finding ▴MATERIAL WEAKNESS, Compliance with Gramm-Leach-Bliley Act, Information on the federal program: U.S. Department of Education, Assistance Listing No. 84.268; Federal Direct Student Loan Program, Criteria: Institutions that participate in Title IV educational assistance programs are subject to the Gramm-Leach-Bliley Act to protect student financial aid information. They are required to develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts and includes certain elements. Condition: The Seminary did not have a written program in place by June 9, 2023, the required deadline. Context: The Seminary has an outsourced IT provider which provides services under a service agreement. Questioned Costs: None, Cause: Management was not aware of the documentation requirement. Effect: While the services provided by the IT service provider as well as the Seminary's internal IT department address security concerns and needs within the Seminary, all areas of Gramm-Leach-Bliley might not be addressed. Recommendation: We recommend that management develop the written comprehensive information security program using the standards set by the Gramm-Leach-Bliley Act including designating a qualified individual responsible for overseeing, implementing, and enforcing the program. Views of responsible officials and planned corrective actions: Management acknowledges this finding and is working toward documenting Gramm-Leach-Bliley Act processes and procedures. The Seminary is working on formal process and procedure guides. The Seminary has done work in this area, but without a procedure guide we realize that the documentation is as key as the work that is being done.
Planned Corrective Action: The Seminary has taken action on many security standards outlined in the Gramm-Leach-Bliley Act. However, the Seminary has not created a written comprehensive information security plan. The Seminary will develop this plan, that will incorporate many of the items that we have already put in place. However, we realize with out a written plan that we are no incompliance with the Act. The Seminary will put the plan in writing. Person Responsible for Corrective Action Plan: Melissa Trayhan – Manager of Information Technology Anticipated Completion Date June 2024
The Seminary did not maintain documentation of accurate cost of attendance used to calculate financial need. Context: Out of a population of 50 students who received aid under the student financial aid cluster, we sampled 10. Within this sample, three of these students were less than full-time. Within their student record, their cost of attendance was noted at the full-time student rate. None of these students received aid in excess of need based on a reduced cost of attendance. Questioned Costs: None Cause: Manual calculations of need are being performed but are not documented within the student management software. Effect: Documentation of cost of attendance within student records is not accurate which could lead to incorrect calculation of need and award of funding. Recommendation: We recommend that management adjust its procedures to document within the student management software the cost of attendance for students who attend less than full-time. Views of responsible officials and planned corrective actions: Management acknowledges this finding and is working on documenting the review of students once they change their status. The calculations are occurring but are not being documented in the system of record.
Show full finding ▾Hide full finding ▴MATERIAL WEAKNESS, Documentation of Cost of Attendance, Information on the federal program: U.S. Department of Education, Assistance Listing No. 84.268; Federal Direct Student Loan Program, Criteria: Students awarded financial aid must meet eligibility requirements including having financial need and total awards that do not exceed that need. Condition: The Seminary did not maintain documentation of accurate cost of attendance used to calculate financial need. Context: Out of a population of 50 students who received aid under the student financial aid cluster, we sampled 10. Within this sample, three of these students were less than full-time. Within their student record, their cost of attendance was noted at the full-time student rate. None of these students received aid in excess of need based on a reduced cost of attendance. Questioned Costs: None Cause: Manual calculations of need are being performed but are not documented within the student management software. Effect: Documentation of cost of attendance within student records is not accurate which could lead to incorrect calculation of need and award of funding. Recommendation: We recommend that management adjust its procedures to document within the student management software the cost of attendance for students who attend less than full-time. Views of responsible officials and planned corrective actions: Management acknowledges this finding and is working on documenting the review of students once they change their status. The calculations are occurring but are not being documented in the system of record.
Planned Corrective Action: The Director of Financial Aid will document the review of students that change academic status (full time vs part time) and determine if any adjustments need to be made to the students Cost of Attendance as a result of the change. The Director of Financial Aid will document this review and note any changes that were made as a result. If no changes are necessary, this will be documented as well Person Responsible for Corrective Action Plan: Sandra Mitchell Holder, Director of Financial Aid Anticipated Completion Date June 2024
FAC accepted this audit on April 17, 2026 — management decision was due October 17, 2026.
One student took a leave of absence during the academic year. The Seminary failed to provide evidence that the student completed the leave of absence form and evidence that the request was approved by the Academic Dean and Program Director, which are both required per the Seminary’s Leave of Absence Policy. Questioned Cost: $-0- Cause: The Seminary did not have a control in place to ensure leave of absence documentation was adequately retained. Effect: Without sufficient documentation, it could not be determined if the student was on an approved leave of absence per the Seminary’s Leave of Absence Policy. It could also not be determined whether the status change reported to NSLDS was done accurately. Recommendation: We recommend that the Seminary establish controls to ensure that documents pertaining to a student’s participation in the Direct Loan Program are adequately retained. Views of responsible officials and planned corrective actions: Management concurs with the above finding. The Registrar will review all leaves of absence to ensure that all paperwork is completed. This occurred during a period of transition within the Registrars Office and collection of paperwork is checked and verified more thoroughly now.
Show full finding ▾Hide full finding ▴Finding 2022-003: Leave of Absence Approval Information on the Federal Program: Federal Direct Student Loan Program (AL Number 84.268) – U.S. Department of Education Criteria or specific requirement: 34 CFR 668.24(e)(2)(ii) – An institution shall keep all records relating to its participation in the Direct Loan Program, including records of any reports or forms, for three years after the end of the award year in which the records are submitted. 34 CFR 668.22(d)(1)(ii) – A leave of absence is an approved leave of absence if the student followed the institution's policy in requesting the leave of absence. Condition: One student took a leave of absence during the academic year. The Seminary failed to provide evidence that the student completed the leave of absence form and evidence that the request was approved by the Academic Dean and Program Director, which are both required per the Seminary’s Leave of Absence Policy. Questioned Cost: $-0- Cause: The Seminary did not have a control in place to ensure leave of absence documentation was adequately retained. Effect: Without sufficient documentation, it could not be determined if the student was on an approved leave of absence per the Seminary’s Leave of Absence Policy. It could also not be determined whether the status change reported to NSLDS was done accurately. Recommendation: We recommend that the Seminary establish controls to ensure that documents pertaining to a student’s participation in the Direct Loan Program are adequately retained. Views of responsible officials and planned corrective actions: Management concurs with the above finding. The Registrar will review all leaves of absence to ensure that all paperwork is completed. This occurred during a period of transition within the Registrars Office and collection of paperwork is checked and verified more thoroughly now.
The Registrar will review all leaves of absence to ensure that all paperwork is completed. This occurred during a period of transition within the Registrars Office and collection of paperwork is checked and verified more thoroughly now.
One student required a return of unearned aid following a withdrawal. The percentage earned was calculated incorrectly because the excluded scheduled break was not determined according to the above guidance. Questioned Cost: $73.66 Cause: The Federal Student Aid Handbook was not followed when the R2T4 calculation was made regarding the excluded scheduled break. Effect: The incorrect determination of the scheduled break resulted in the calculation of a lower percentage earned, and therefore a larger amount of refund due than was necessary. Recommendation: We recommend that the Seminary establish controls to ensure that Federal Student Aid guidance is being appropriately followed in the determination of title IV refunds. Views of responsible officials and planned corrective actions: Management concurs with the above finding. The Financial Aid Director, in conjunction with the Registrar, will review all student withdrawals to ensure that R2T 4 calculations are completed on time. At the midpoint of the semester and other review will be done to ensure that all calculations were completed and on time.
Show full finding ▾Hide full finding ▴Finding 2022-004: Return of Title IV Funds (R2T4) Calculation Information on the Federal Program: Federal Direct Student Loan Program (AL Number 84.268) – U.S. Department of Education Criteria or specific requirement: 34 CFR 668.22(f)(2)(i) – The percentage of title IV grant or loan assistance that has been earned by the student is equal to the percentage of the period of enrollment that the student completed as of the student's withdrawal date. This is determined by dividing the total number of calendar days in the period of enrollment into the number of calendar days completed in that period as of the student's withdrawal date. The total number of calendar days in a period of enrollment includes all days within the period that the student was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a period of enrollment and the number of calendar days completed in that period. Federal Student Aid Handbook Volume 5, Chapter 2 – A scheduled break begins the day after the last classes were held and ends the day before the next classes were held. Condition: One student required a return of unearned aid following a withdrawal. The percentage earned was calculated incorrectly because the excluded scheduled break was not determined according to the above guidance. Questioned Cost: $73.66 Cause: The Federal Student Aid Handbook was not followed when the R2T4 calculation was made regarding the excluded scheduled break. Effect: The incorrect determination of the scheduled break resulted in the calculation of a lower percentage earned, and therefore a larger amount of refund due than was necessary. Recommendation: We recommend that the Seminary establish controls to ensure that Federal Student Aid guidance is being appropriately followed in the determination of title IV refunds. Views of responsible officials and planned corrective actions: Management concurs with the above finding. The Financial Aid Director, in conjunction with the Registrar, will review all student withdrawals to ensure that R2T 4 calculations are completed on time. At the midpoint of the semester and other review will be done to ensure that all calculations were completed and on time.
The Financial Aid Director, in conjunction with the Registrar, will review all student withdrawals to ensure that R2T 4 calculations are completed on time. At the midpoint of the semester and other review will be done to ensure that all calculations were completed and on time.
The Seminary did not have a written information security program in place during the year under audit. Questioned Cost: $0 Cause: Management was not aware of the documentation requirement. Effect: While the services provided by the IT service provider as well as the Seminary's internal IT department address security concerns and needs within the Seminary, all areas of Gramm-Leach- Bliley might not be addressed. Recommendation: We recommend that management develop the written comprehensive information security program using the standards set by the Gramm-Leach-Bliley Act including designating a qualified individual responsible for overseeing, implementing, and enforcing the program. Views of responsible officials and planned corrective actions: Management concurs with the above finding. The Seminary has developed, with the assistance of our outsourced vCIO and vChief Security Officer, a comprehensive security plan which meets the standards required by the Gramm- Leach-Bliley Act.
Show full finding ▾Hide full finding ▴Finding 2022-005: Gramm-Leach-Bliley Act Information on the Federal Program: Federal Direct Student Loan Program (AL Number 84.268) – U.S. Department of Education Criteria or specific requirement: 16 CFR 314 – Institutions that participate in title IV educational assistance programs are subject to the Gramm-Leach-Bliley Act to protect student financial aid information. They are required to (a) designate a qualified individual responsible for overseeing, implementing, and enforcing their information security program, (b) base the information security program on a risk assessment that identifies reasonably foreseeable internal and external risks to customer information, and (c) design and implement safeguards to control the risks identified through risk assessment. Condition: The Seminary did not have a written information security program in place during the year under audit. Questioned Cost: $0 Cause: Management was not aware of the documentation requirement. Effect: While the services provided by the IT service provider as well as the Seminary's internal IT department address security concerns and needs within the Seminary, all areas of Gramm-Leach- Bliley might not be addressed. Recommendation: We recommend that management develop the written comprehensive information security program using the standards set by the Gramm-Leach-Bliley Act including designating a qualified individual responsible for overseeing, implementing, and enforcing the program. Views of responsible officials and planned corrective actions: Management concurs with the above finding. The Seminary has developed, with the assistance of our outsourced vCIO and vChief Security Officer, a comprehensive security plan which meets the standards required by the Gramm- Leach-Bliley Act.
The Seminary has developed, with the assistance of our outsourced vCIO and vChief Security Officer, a comprehensive security plan which meets the standards required by the Gramm- Leach-Bliley Act.
The reporting package for the year ended June 30, 2022 was not submitted by the March 31, 2023 reporting deadline. Questioned Cost: $-0- Cause: The Seminary initially determined federal expenditures were below the Single Audit threshold. Effect: The Seminary is not in compliance with the provisions of 2 CFR Section 200.512(a) for the year ended June 30, 2022. Views of responsible officials and planned corrective actions: The audit report on the financial statements for the year ended June 30, 2022 was issued on April 15, 2026, The Data Collection form and reporting package will be submitted within 5 business days thereafter.
Show full finding ▾Hide full finding ▴Finding 2022-006: Single Audit Submission Deadline Criteria or specific requirement: 2 CFR Section 200.512(a) requires the data collection form and Single Audit reporting package be submitted the earlier of 30 days after the reports are received from the auditors or nine months after the end of the audit period. Condition: The reporting package for the year ended June 30, 2022 was not submitted by the March 31, 2023 reporting deadline. Questioned Cost: $-0- Cause: The Seminary initially determined federal expenditures were below the Single Audit threshold. Effect: The Seminary is not in compliance with the provisions of 2 CFR Section 200.512(a) for the year ended June 30, 2022. Views of responsible officials and planned corrective actions: The audit report on the financial statements for the year ended June 30, 2022 was issued on April 15, 2026, The Data Collection form and reporting package will be submitted within 5 business days thereafter.
The audit report on the financial statements for the year ended June 30, 2022 was issued on April 15, 2026, The Data Collection form and reporting package will be submitted within 5 business days thereafter.
FAC accepted this audit on September 20, 2022 — management decision was due March 20, 2023.
The Seminary did not report quarterly or annual activity accurately or in some cases timely. Context: The Seminary prepared quarterly reports for the quarters ending September 30, 2020, December 31, 2020 and March 31, 2021. However, information included in the reports was not accurate. Aid to Students given during the fiscal year ended June 30, 2021 was $260,041. A total of $355,850 in aid was reported through quarterly reporting, due in part to a cumulative amount being reported for the quarter ended March 31, 2021, rather than quarterly aid. Other costs (not student aid) were not reported as it was not determined which costs would be applied to the grant until after June 30, 2021. Total other costs for the year ended June 30, 2021 were $203,574, but costs totaling $15,628 were the only other costs reported (reported during the quarter ended September 30, 2020). No quarterly report for the period ended June 30, 2021 was completed. Additionally, evidence could not be provided for the date that quarterly reports for December 31, 2020 and March 31, 2021 were posted to the Seminary's website. Questioned Costs: None Cause: Controls surrounding the reporting of grant activity are deficient. Effect: Required reporting was not completed timely or accurately. Recommendation: We recommend that management adjust its procedures and controls surrounding reporting. Procedures should be developed to ensure reports are completed both timely and accurately. Views of responsible officials and planned corrective actions: Management acknowledges this issue and has put steps in place to prevent this from happening in the future. Quarterly reports have been filed and posted to our website. During a turnover in web service providers we were unable to capture dates In which materials were posted to the website. Moving forward we are capturing information to help prove dates of posting and make filings for periods with $0 expenditures.
Show full finding ▾Hide full finding ▴Information on the federal program: U.S. Department of Education, Assistance Listing No. 84.425E, 84.425F, 84.425N; Higher Education Emergency Relief Fund, Material Weakness. Criteria: Reporting under HEERF includes quarterly and annual reporting of both student aid and other costs. Condition: The Seminary did not report quarterly or annual activity accurately or in some cases timely. Context: The Seminary prepared quarterly reports for the quarters ending September 30, 2020, December 31, 2020 and March 31, 2021. However, information included in the reports was not accurate. Aid to Students given during the fiscal year ended June 30, 2021 was $260,041. A total of $355,850 in aid was reported through quarterly reporting, due in part to a cumulative amount being reported for the quarter ended March 31, 2021, rather than quarterly aid. Other costs (not student aid) were not reported as it was not determined which costs would be applied to the grant until after June 30, 2021. Total other costs for the year ended June 30, 2021 were $203,574, but costs totaling $15,628 were the only other costs reported (reported during the quarter ended September 30, 2020). No quarterly report for the period ended June 30, 2021 was completed. Additionally, evidence could not be provided for the date that quarterly reports for December 31, 2020 and March 31, 2021 were posted to the Seminary's website. Questioned Costs: None Cause: Controls surrounding the reporting of grant activity are deficient. Effect: Required reporting was not completed timely or accurately. Recommendation: We recommend that management adjust its procedures and controls surrounding reporting. Procedures should be developed to ensure reports are completed both timely and accurately. Views of responsible officials and planned corrective actions: Management acknowledges this issue and has put steps in place to prevent this from happening in the future. Quarterly reports have been filed and posted to our website. During a turnover in web service providers we were unable to capture dates In which materials were posted to the website. Moving forward we are capturing information to help prove dates of posting and make filings for periods with $0 expenditures.
Finding Number 2021-003 HEERF Reporting Timeliness Planned Corrective Action: The Budget Director will work with our web team in Communications to document the date that information is posted to our website to ensure that reports are posted timely and that the Seminary documents the date in which reports are published. In addition the Budget Director will provide the Vice President for Finance and Operations a detailed reconciliation of the funds each quarter to determine that the proper amounts are being posted to our quarterly reporting. Person Responsible for Corrective Action Plan: Scott Sims ? Budget Director; Stephanie Seeger ? Communications; Ward Logan, Vice President of Finance and Operations Anticipated Completion Date: September 2022
The Seminary did not maintain documentation for the amount of grants awarded to certain students. Context: Total student grants given from the formula grant funds was $228,785. A sample of 13 of these grants were tested with a sum of $25,536. The test identified two grants awarded in the amount of $3,500 without documentation of the final amount granted. One grant in the amount of $2,000 was determined to be underfunded by $342 based on grant criteria and one grant in the amount of $1,500 was funded in accordance with grant criteria, but contained no documentation. Questioned Costs: None Cause: Controls surrounding the documentation of the award of student grants is deemed to be deficient. Effect: Documentation of the determination of grants awarded did not exist for two grants. Recommendation: We recommend that management adjust procedures to include documentation of each student grant awarded and ultimately paid, in accordance with grant criteria. Views of responsible officials and planned corrective actions: Management acknowledges that this occurred. Due to a change in personnel we were unable to determine the rationale for the questioned grants. The Seminary has documented disbursement procedures in subsequent disbursements. The Financial Aid Director, VP of Finance, Finance Director and Dean of the Seminary all approved our latest disbursement rationale.
Show full finding ▾Hide full finding ▴Information on the federal program: U.S. Department of Education, Assistance Listing No. 84.425N; HEERF Fund for the Improvement of Postsecondary Education Criteria: HEERF formula grant funds can be used to defray coronavirus expenses and to provide additional grants to students for any component of the student's cost of attendance. Condition: The Seminary did not maintain documentation for the amount of grants awarded to certain students. Context: Total student grants given from the formula grant funds was $228,785. A sample of 13 of these grants were tested with a sum of $25,536. The test identified two grants awarded in the amount of $3,500 without documentation of the final amount granted. One grant in the amount of $2,000 was determined to be underfunded by $342 based on grant criteria and one grant in the amount of $1,500 was funded in accordance with grant criteria, but contained no documentation. Questioned Costs: None Cause: Controls surrounding the documentation of the award of student grants is deemed to be deficient. Effect: Documentation of the determination of grants awarded did not exist for two grants. Recommendation: We recommend that management adjust procedures to include documentation of each student grant awarded and ultimately paid, in accordance with grant criteria. Views of responsible officials and planned corrective actions: Management acknowledges that this occurred. Due to a change in personnel we were unable to determine the rationale for the questioned grants. The Seminary has documented disbursement procedures in subsequent disbursements. The Financial Aid Director, VP of Finance, Finance Director and Dean of the Seminary all approved our latest disbursement rationale.
Finding Number: 2021-004 HEERF Grant Calculation Planned Corrective Action: The Director of Financial Aid will prepare detailed spreadsheets outlining the grant award requirements and how each award was determined. The initial award criteria will be determined by the Director of Financial Aid and approved by the Dean and the Vice President for Finance and Operations. This award criteria for each student award will be documented to ensure that the funds are given out according to our criteria. Person Responsible for Corrective Action Plan: Sandra Mitchell ? Holder ? Director of Financial Aid; Ward Logan, Vice President of Finance and Operations.
FAC accepted this audit on March 7, 2018 — management decision was due September 7, 2018.
GSA_MIGRATION
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GSA_MIGRATION
GSA_MIGRATION
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GSA_MIGRATION
2016-001
GSA_MIGRATION
Show full finding ▾Hide full finding ▴FAC accepted this audit on March 21, 2017 — management decision was due September 21, 2017.
GSA_MIGRATION
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GSA_MIGRATION
2015-004
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