Asbury Theological Seminary respectfully submits the following corrective action plan for the year ended June 30, 2022. Name and address of independent public accounting firm: Blue & Company, LLC; 250 West Main Street, Suite 2900; Lexington, Kentucky 40507. The finding from the schedule of findings and questioned costs for the year ended June 30, 2022 is discussed below. The finding is numbered consistently with the numbers assigned in the schedule. 2022-001 Finding: Asbury Theological Seminary (ATS) failed to collect entrance counseling on a student before Title IV funds were disbursed to the institutional student account. Summary: The Seminary did not have a control in place to ensure timely completion of the entrance counseling. Institution Response: ATS uses an import tool through ED Connect to identify students who have completed entrance counseling. When the import is received, the financial aid staff manually enters the information into the Student Information System (Nexus) for each individual student. The student record in Nexus is then checked prior to the first Title IV loan disbursement for the student. The Department of Education introduced a new counseling item, Financial Awareness Counseling. While available, this form was imported and treated in the same manner as the other counseling forms (entrance/exit). Financial Awareness Counseling was completed for the student noted in the exception. The staff member reviewing the record mistakenly released loans, confusing the Financial Awareness Counseling as entrance counseling. ATS agrees with the audit finding. With the Department of Education terminating Financial Awareness Counseling, this helps avoid confusing the two documents. To prevent disbursing future Title IV loan funds to student accounts without the proper entrance counseling on file, a new process has been implemented. The Associate Director of Financial Aid, Mariah Shumate, will now cross check each new disbursement record prior to requesting funds from the Department of Education. Estimated Completion Date: September 22, 2022; Responsible manager: Mariah Shumate, Associate Director of Financial Aid