EIN: 840421879
UEI: JEHQPT7GTLE7
Data as of August 23, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on November 11, 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 May 11, 2025 (470 days ago).
What is a management decision? →There were 2 late returns of funds for students that withdrew during the term and 1 additional late return of funds for a student that did not attend the term. Criteria: 34 CFR 668.22 Questioned Costs: $0 Context: 2 of 7 withdrawals tested had returns that were 109 and 259 days late totaling $622 and $668, respectively. 1 out of 7 had a late return of 128 days for $4,750 due to a delayed determination of non-attendance. These errors were discovered and corrected during the audit. After these errors were discovered, the Seminary completed a full file review of all 16 withdrawals to ensure accurate and timely R2T4 calculations noting no additional errors. Cause: The Seminary had staff turnover in the registrar’s office which caused miscommunication between the registrar and financial aid office as well as inaccurate system reports. Because of the inaccurate system reports, the student who didn’t attend wasn’t identified. Additionally, because of the reporting problem, the original returns for students that formally withdrew were based on an inaccurate last day of attendance used in the R2T4 calculation and the late return was due to the correction of the original returns. Effect: Federal funding was returned late. Identification as repeat finding, if applicable: N/A Recommendation: We recommend that the Seminary review all dates provided by Campus Nexus reports to verify correct last day of attendance is used in R2T4 calculations. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Untimely Returns of Title IV Funds (R2T4) Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Award Identification #: 2023-2024 Award Year Condition: There were 2 late returns of funds for students that withdrew during the term and 1 additional late return of funds for a student that did not attend the term. Criteria: 34 CFR 668.22 Questioned Costs: $0 Context: 2 of 7 withdrawals tested had returns that were 109 and 259 days late totaling $622 and $668, respectively. 1 out of 7 had a late return of 128 days for $4,750 due to a delayed determination of non-attendance. These errors were discovered and corrected during the audit. After these errors were discovered, the Seminary completed a full file review of all 16 withdrawals to ensure accurate and timely R2T4 calculations noting no additional errors. Cause: The Seminary had staff turnover in the registrar’s office which caused miscommunication between the registrar and financial aid office as well as inaccurate system reports. Because of the inaccurate system reports, the student who didn’t attend wasn’t identified. Additionally, because of the reporting problem, the original returns for students that formally withdrew were based on an inaccurate last day of attendance used in the R2T4 calculation and the late return was due to the correction of the original returns. Effect: Federal funding was returned late. Identification as repeat finding, if applicable: N/A Recommendation: We recommend that the Seminary review all dates provided by Campus Nexus reports to verify correct last day of attendance is used in R2T4 calculations. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Untimely Returns of Title IV Funds (R2T4) Planned Corrective Action: Exception found during audit on several student returns of their Title IV aid. This was due to multiple factors. Campus Nexus, our SIS system, reported dates for LDA that did not line up with the drop date indicated by the professors on withdrawal/drop forms. A major shift in management of the Registrar’s office also occurred this year that left gaps in information. Our Student Life department that tracks start activity for a term did not translate data to our department for students with loans since they do not track loan borrowing in their system. During audit allstudents were reviewed, in addition to selections to ensure that LDAs were accurate for any R2T4s. As of the Fall 2024 term we will still run our Campus Nexus reports but will be reviewing all dates against withdrawal/drop forms for LDA listed by the professor. The Registrar’s office has a new staff that we are working closely with to ensure accurate data. We also are working directly with Student Life to review inactivity lists the first and second week of classes and are tracking students with loans. Any student with a loan without activity within the first week of classes, we will be returning funding. If they start activity in the second week and maintain activity prior to being dropped at the third week, we can reinstate their loans at their request. Person Responsible for Corrective Action Plan: Gina K Kelbert, Director of Financial Aid Anticipated Date of Completion: Effective since beginning of Fall term 2024.
FAC accepted this audit on November 20, 2023 — management decision was due May 20, 2024.
The Seminary did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.4 Questioned Costs: $0 Context: The Seminary has not implemented multi-factor authentication on all systems containing personally identifiable information (PII) or had the qualified individual approve in writing the exception. Additionally, the written, annual report to the board does not include all the required areas based on the updated regulations. Cause: The Seminary has limited resources and has allocated certain staff time and dollars as available to address and document compliance with the requirements of GLBA. Effect: The Seminary has a couple of gaps to adequately address the updated 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 commend the Seminary for the work completed on GLBA. We recommend the Seminary allocate sufficient resources to address the remaining 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 DEPARTMENT OF EDUCATION ALN #: 84.268 and 84.033 - Student Financial Assistance Cluster Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The Seminary did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.4 Questioned Costs: $0 Context: The Seminary has not implemented multi-factor authentication on all systems containing personally identifiable information (PII) or had the qualified individual approve in writing the exception. Additionally, the written, annual report to the board does not include all the required areas based on the updated regulations. Cause: The Seminary has limited resources and has allocated certain staff time and dollars as available to address and document compliance with the requirements of GLBA. Effect: The Seminary has a couple of gaps to adequately address the updated 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 commend the Seminary for the work completed on GLBA. We recommend the Seminary allocate sufficient resources to address the remaining 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: The school’s student information system vendor did not offer multi-factor authentication (MFA) capability during or prior to the year under audit. This capability has just become available for their software as of October 2023. The school has requested access to this capability from the vendor and will be coordinating implementation of MFA as soon as possible. The written annual report will be modified to include all required areas based on updated regulations. Person Responsible for Corrective Action Plan: Debra Kellar, VP of Finance and Campus Operations Anticipated Date of Completion: March 31, 2024
FAC accepted this audit on December 9, 2020 — management decision was due June 9, 2021.
Enrollment status was not always updated correctly and timely to the National Student Loan Data Service (NSLDS) Criteria: 34 CFR 685.309(b) Questioned Costs: $-0- Context: NSLDS reporting was not updated for the fall term for 26 of the 51 students tested, even though the Seminary reported the information accurately and timely to the National Student Clearinghouse (NSC) who failed to processes the reporting with NSLDS. These 26 students all returned in spring and were reported correctly in that term so there was no impact on deferral. Additionally, there were 4 students out of 51 students tested were not reported correctly to NSLDS. 2 students who withdrew in the spring term were not reported as withdrawn in NSLDS. 2 students who withdrew did not have the correct effective dates reported. These 4 students were corrected as part of the audit process. Effect: Inaccurate reporting of enrollment status and effective dates can impact a student?s grace period, in school deferment eligibility, beginning of loan repayment, appropriate interest charges, etc. Cause: While the Seminary submitted NSLDS information to NSC in a timely manner, the data was not uploaded accurately by the NSC. The Seminary didn?t have a process in place to monitor if NSC processed the enrollment reporting submissions. Other reporting errors were attributable to the Seminary, not NSC. Identification as repeat finding, if applicable: yes, 2019-001, 2018-002, and 2017-01 Recommendation: We recommend spot checks be performed after each submission to NCS to ensure that NSLDS has been properly updated after NSC processes reporting, or when changes to enrollment status happen. We also recommend that for students who withdraw officially or unofficially have their NSLDS status updated as part of the R2T4 process and that there be a secondary review to ensure timely and accurate reporting to NSLDS. Views of Responsible Official and Corrective Action Plan: Management agrees with the finding and is in process of addressing the issue. See corrective action plan.
Show full finding ▾Hide full finding ▴2020-001 NSLDS Reporting Material Weakness DEPARTMENT OF EDUCATION CFDA #: 84.268 Federal Award Identification #: 2019-2020 Financial Aid Year Condition: Enrollment status was not always updated correctly and timely to the National Student Loan Data Service (NSLDS) Criteria: 34 CFR 685.309(b) Questioned Costs: $-0- Context: NSLDS reporting was not updated for the fall term for 26 of the 51 students tested, even though the Seminary reported the information accurately and timely to the National Student Clearinghouse (NSC) who failed to processes the reporting with NSLDS. These 26 students all returned in spring and were reported correctly in that term so there was no impact on deferral. Additionally, there were 4 students out of 51 students tested were not reported correctly to NSLDS. 2 students who withdrew in the spring term were not reported as withdrawn in NSLDS. 2 students who withdrew did not have the correct effective dates reported. These 4 students were corrected as part of the audit process. Effect: Inaccurate reporting of enrollment status and effective dates can impact a student?s grace period, in school deferment eligibility, beginning of loan repayment, appropriate interest charges, etc. Cause: While the Seminary submitted NSLDS information to NSC in a timely manner, the data was not uploaded accurately by the NSC. The Seminary didn?t have a process in place to monitor if NSC processed the enrollment reporting submissions. Other reporting errors were attributable to the Seminary, not NSC. Identification as repeat finding, if applicable: yes, 2019-001, 2018-002, and 2017-01 Recommendation: We recommend spot checks be performed after each submission to NCS to ensure that NSLDS has been properly updated after NSC processes reporting, or when changes to enrollment status happen. We also recommend that for students who withdraw officially or unofficially have their NSLDS status updated as part of the R2T4 process and that there be a secondary review to ensure timely and accurate reporting to NSLDS. Views of Responsible Official and Corrective Action Plan: Management agrees with the finding and is in process of addressing the issue. See corrective action plan.
Finding Number: 2020-001 NSLDS Reporting Planned Corrective Action: During audit it was found that even though the Financial Aid office correctly reported all enrollment to the National Student Clearinghouse, the enrollment was not transferred correctly to NSLDS by our third party servicer for a handful of our students. Action Plan: Our Financial Aid office is spot checking all students for our Fall 2020 enrollment file and will do this for every file submitted to ensure that data is being reported correctly. We are also working with the audit team with the National Student Clearinghouse. We have informed them of the students who were not reported correctly and they are looking into the issue for us so this can be resolved and not occur again in the future. If it is determined that the third party servicer cannot ensure correct transfer of data to the NSLDS, the Seminary will report directly or through another third party servicer. Person Responsible for Corrective Action Plan: Gina Kelbert Anticipated Date of Completion: Fall spot check completed Oct 1 2020. Audit resolution with NSC expected by November 1, 2020
2019-001
Federal regulations require that a student who has federal aid but no passing grades be reviewed to determine if the student stopped attending and a return of Title IV aid is due back to the Department of Education. This review is to be completed 30 days after the end of a term. In testing compliance with this regulation, it was determined that the Seminary was not completing this review. As part of the audit process, the Seminary determined that 2 students in the fall did not complete the term and the Seminary needed to return the unearned federal direct loans back to the Department of Education. The Seminary also determined that a student registered for the fall term and had federal loans disbursed, actually never began attendance and therefore was ineligible for any loans. The full amount of these loans were returned. Criteria: 34CFR 668.21(b) and 34CFR 668.22 (c) Questioned Costs: $13,528 Context: Out of 7 students tested for potential unofficial withdraws, 3 students had unearned federal direct loans returned late. $3,386 for the 2 students who didn?t complete the fall term was returned in July 2020, 215 days late. For the student who didn?t begin attendance in the fall term, the Seminary incorrectly completed an R2T4 and returned $1,015 in July 2020 but the entire $10,142 should have been returned. Returns for the spring term were timely. Effect: The Title IV funds were not returned timely. Cause: The Seminary didn?t monitor students with federal aid and no passing grades for unofficial withdraws until the audit process. For the student who never began attendance in the fall term, the professor had inappropriately reported an F grade and when the Seminary asked for a date of last attendance, the professor then indicated that the student never started the term. Identification as repeat finding, if applicable: not applicable Recommendation: We recommend the Seminary put procedures in place to monitor for potential unofficial withdraws after each term to ensure timely return of unearned Title IV funds when required. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding and is in process of addressing the issue. See corrective action plan.
Show full finding ▾Hide full finding ▴2020-002 Failure to Monitor for Students with Federal Aid Who Unofficially Withdraw or Don?t Begin Attendance Significant Deficiency DEPARTMENT OF EDUCATION CFDA #: 84.268 Federal Award Identification #: 2019-2020 Financial Aid Year Condition: Federal regulations require that a student who has federal aid but no passing grades be reviewed to determine if the student stopped attending and a return of Title IV aid is due back to the Department of Education. This review is to be completed 30 days after the end of a term. In testing compliance with this regulation, it was determined that the Seminary was not completing this review. As part of the audit process, the Seminary determined that 2 students in the fall did not complete the term and the Seminary needed to return the unearned federal direct loans back to the Department of Education. The Seminary also determined that a student registered for the fall term and had federal loans disbursed, actually never began attendance and therefore was ineligible for any loans. The full amount of these loans were returned. Criteria: 34CFR 668.21(b) and 34CFR 668.22 (c) Questioned Costs: $13,528 Context: Out of 7 students tested for potential unofficial withdraws, 3 students had unearned federal direct loans returned late. $3,386 for the 2 students who didn?t complete the fall term was returned in July 2020, 215 days late. For the student who didn?t begin attendance in the fall term, the Seminary incorrectly completed an R2T4 and returned $1,015 in July 2020 but the entire $10,142 should have been returned. Returns for the spring term were timely. Effect: The Title IV funds were not returned timely. Cause: The Seminary didn?t monitor students with federal aid and no passing grades for unofficial withdraws until the audit process. For the student who never began attendance in the fall term, the professor had inappropriately reported an F grade and when the Seminary asked for a date of last attendance, the professor then indicated that the student never started the term. Identification as repeat finding, if applicable: not applicable Recommendation: We recommend the Seminary put procedures in place to monitor for potential unofficial withdraws after each term to ensure timely return of unearned Title IV funds when required. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding and is in process of addressing the issue. See corrective action plan.
Finding Number: 2020-002 Failure to Monitor for Students with Federal Aid Who Unofficially Withdrew or Don?t Begin Attendance Planned Corrective Action: This finding was documented because review for students with no passing grades had not been timely completed. Upon belated review at the time of the audit, correct funds were returned for several students who had unofficially withdrawn. However, for one student with an ?F? grade, the professor confirmed that, in fact, the student never attended class. Funds returned for this student were mis-calculated since there had been no attendance. Action plan: Recalculation of the R2T4 has been done for the student that never attended the fall 2019 term and the funds have been returned. The Seminary will institute regular review of student records for unofficial withdrawal no later than 30 days after the end of each semester. Additionally, the Seminary will institute training of faculty in the proper reporting of students who do not attend or who stop participating in class mid-semester. Person(s) Responsible for Corrective Action Plan: Gina Kelbert and Debra Kellar Anticipated Date of Completion: January 1, 2021
FAC accepted this audit on October 20, 2019 — management decision was due April 20, 2020.
Enrollment status was not always updated correctly to the National Student Loan Data Service (NSLDS). Criteria: 34 CFR 685.309(b) Questioned Costs: $-0- Context: NSLDS reporting was inaccurate for 9 students out of the 53 tested. There were two separate reasons that caused the NSLDS status to be inaccurate. Out of the 9 exceptions, 7 of them affected repayment status. Three of the exceptions related to students who attended at least half time in the fall semester but were not reported as attending. These three were correctly reported in the spring semester as attending. The remaining 4 exceptions were all unofficial withdrawals. Two students were reported as withdrawn but as of an incorrect date. Two students were not reported as withdrawn, and one of those two had not had a return of Title IV funds completed until the audit. All students were corrected or were in the process of being corrected during the audit process. Effect: Inaccurate reporting of enrollment status and effective dates can impact a student?s grace period, in school deferment eligibility, beginning loan repayment, appropriate interest charges, etc. Cause: The previous financial aid director had been addressing the prior year NSLDS issues, and it appears that some of the fall 2018 reporting was not included in those adjustments. The unofficial withdrawals were not reviewed for using the last date of attendance and ensuring the student was reported as withdrawn. Identification as repeat finding, if applicable: yes, 2018-002 and 2017-001 Recommendation: We recommend the Seminary review the setup for each enrollment status submission to ensure the correct term is being reported. We further recommend the Seminary adjust its practices related to unofficial withdrawals to ensure timely information can be used to update NSLDS appropriately. Views of Responsible Officials: Management is in agreement with the finding and is in the process of addressing the issue. See attached corrective action plan.
Show full finding ▾Hide full finding ▴2019-001 NSLDS Reporting Material Weakness DEPARTMENT OF EDUCATION CFDA #: 84.268 Federal Award Identification #: 2018-2019 Financial Aid Year Condition: Enrollment status was not always updated correctly to the National Student Loan Data Service (NSLDS). Criteria: 34 CFR 685.309(b) Questioned Costs: $-0- Context: NSLDS reporting was inaccurate for 9 students out of the 53 tested. There were two separate reasons that caused the NSLDS status to be inaccurate. Out of the 9 exceptions, 7 of them affected repayment status. Three of the exceptions related to students who attended at least half time in the fall semester but were not reported as attending. These three were correctly reported in the spring semester as attending. The remaining 4 exceptions were all unofficial withdrawals. Two students were reported as withdrawn but as of an incorrect date. Two students were not reported as withdrawn, and one of those two had not had a return of Title IV funds completed until the audit. All students were corrected or were in the process of being corrected during the audit process. Effect: Inaccurate reporting of enrollment status and effective dates can impact a student?s grace period, in school deferment eligibility, beginning loan repayment, appropriate interest charges, etc. Cause: The previous financial aid director had been addressing the prior year NSLDS issues, and it appears that some of the fall 2018 reporting was not included in those adjustments. The unofficial withdrawals were not reviewed for using the last date of attendance and ensuring the student was reported as withdrawn. Identification as repeat finding, if applicable: yes, 2018-002 and 2017-001 Recommendation: We recommend the Seminary review the setup for each enrollment status submission to ensure the correct term is being reported. We further recommend the Seminary adjust its practices related to unofficial withdrawals to ensure timely information can be used to update NSLDS appropriately. Views of Responsible Officials: Management is in agreement with the finding and is in the process of addressing the issue. See attached corrective action plan.
Finding Number: 2019-001 NSLDS Reporting Planned Corrective Action: NSLDS reporting enrollment not accurate either due to staff reporting issue or NSC reporting issue. Corrected all incorrect files directly in NSLDS. Will institute spot check during future reporting. This will include reviewing rejected files and a selection of students from each submission. Person Responsible for Corrective Action Plan: Gina Kelbert Anticipated Date of Completion: Completed September 9th
2018-002
One student did not have a return form completed until the audit. Criteria: 34 CFR 668.22 Questioned Costs: $932 Context: Of the 16 unofficial withdrawals that were tested for proper R2T4 returns, one of the return calculations was not completed until the audit process. This was due to a miscommunication between a professor and the financial aid director. The professor had indicated the student had earned the F, but upon further review, the professor had applied the student?s percentage of completed coursework to total coursework and provided the F grade. During the audit process, the professor indicated that the student had stopped attending class. This student was corrected during the audit process using the last date of attendance provided by the professor. Effect: The amount was returned late to the DOE. Cause: There was an incorrect assumption used that the earned F indicated the student had attended the entire course. Identification as repeat finding, if applicable: not applicable Recommendation: We recommend the Seminary specifically ask for last dates of attendance on any unofficial withdrawals and perform a return calculation if applicable. Views of Responsible Officials: Management is in agreement with the finding and is in the process of addressing the issue. See attached corrective action plan.
Show full finding ▾Hide full finding ▴2019-002 Missed R2T4 Calculation FEDERAL AGENCY CFDA #: 84.268 Federal Award Identification #: 2018-2019 Financial Aid Year Condition: One student did not have a return form completed until the audit. Criteria: 34 CFR 668.22 Questioned Costs: $932 Context: Of the 16 unofficial withdrawals that were tested for proper R2T4 returns, one of the return calculations was not completed until the audit process. This was due to a miscommunication between a professor and the financial aid director. The professor had indicated the student had earned the F, but upon further review, the professor had applied the student?s percentage of completed coursework to total coursework and provided the F grade. During the audit process, the professor indicated that the student had stopped attending class. This student was corrected during the audit process using the last date of attendance provided by the professor. Effect: The amount was returned late to the DOE. Cause: There was an incorrect assumption used that the earned F indicated the student had attended the entire course. Identification as repeat finding, if applicable: not applicable Recommendation: We recommend the Seminary specifically ask for last dates of attendance on any unofficial withdrawals and perform a return calculation if applicable. Views of Responsible Officials: Management is in agreement with the finding and is in the process of addressing the issue. See attached corrective action plan.
Finding Number: 2019-002 Missed R2T4 Calculation Planned Corrective Action: This missed R2T4 was corrected during the audit process. Strict communication guidelines will be followed with feedback from professors. If no exact withdrawal date can be determined between professor and financial aid office then the last date of activity will be used. Person Responsible for Corrective Action Plan: Gina Kelbert Anticipated Date of Completion: Completed July 19th
FAC accepted this audit on October 17, 2018 — management decision was due April 17, 2019.
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2017-001
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2017-002
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Show full finding ▾Hide full finding ▴FAC accepted this audit on November 5, 2017 — management decision was due May 5, 2018.
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