Audit 399050

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.

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.

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.

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.