Episcopal Migration Ministries PBRF-LE Analysis
Episcopal Migration Ministries PBRF-LE Analysis
OPUS PBRF-LE INVESTIGATION REPORT
EPISCOPAL MIGRATION MINISTRIES (EMM)
Domestic and Foreign Missionary Society of the Protestant Episcopal Church
EIN: 13-5562208 | UEI: FMJFFFXHQJ93
Classification: INTERNAL - FOR PMC ANALYSIS
Generated: 2026-01-14
Analyst: OPUS | PMC ORACLE PBRF-LE System
Investigation ID: EMM-2026-0114
EXECUTIVE SUMMARY
| Metric | Value |
|---|---|
| Total Federal Funding (TAGGS) | $206,566,696 |
| TAGGS Awards Tracked | 78 awards (2018-2025) |
| Federal Dependency | 97% of total funding |
| Risk Score | 31/100 (LOW) |
| Entity Type | Church (501(c)(3) - Form 990 Exempt) |
| Affiliate Network | 15 offices in 13 states |
| Refugees Resettled | 110,000+ since 1988 |
Key Findings
-
CHURCH EXEMPTION CONCERN: EMM operates under the Domestic and Foreign Missionary Society of the Protestant Episcopal Church (DFMS), which is Form 990-exempt as a church. This means NO public financial disclosure despite receiving $50M+ annually in federal funds.
-
EXTREME FEDERAL DEPENDENCY: 97% of EMM's funding comes from federal grants. This creates systemic vulnerability (as demonstrated by the 2025 Trump administration shutdown).
-
FUNDING TRAJECTORY:
- FY2018: $3.9M
- FY2022: $35.7M (815% growth in 4 years)
- FY2023: $45.6M (peak)
- FY2024: $32.2M
- FY2025: $2.6M (program wind-down) -
NO C3→C4 DARK MONEY DETECTED: Only 2 Episcopal-related c4 entities exist (Episcopal Housing Corporation, SC and a Methodist camp association), with no evidence of cross-type grant flows.
-
AFFILIATE NETWORK RISK: EMM sub-awards to 15 local affiliates across 13 states. The largest identified affiliate (Refugee Services of Texas) received $56.6M in federal funding.
ORGANIZATION PROFILE
Legal Entity
- Name: Domestic and Foreign Missionary Society of the Protestant Episcopal Church in the USA
- EIN: 13-5562208
- UEI: FMJFFFXHQJ93
- Address: 815 2nd Avenue, 3rd Floor, New York, NY 10017
- Tax Status: 501(c)(3) Church - Form 990 EXEMPT
- Founded: 1820 (formal incorporation)
- IRS Ruling Year: November 1944
Episcopal Migration Ministries (EMM) Program
- Established: 1988
- Role: One of 10 national refugee resettlement agencies partnered with U.S. Department of State
- Mission: Resettle refugees through network of local affiliates
- Total Refugees Resettled: 110,000+ (1988-2025)
- 2024 Clients: 5,396 refugees + 1,137 SIV holders from 48 countries
LEADERSHIP
Current Leadership (2022-2026)
| Name | Title | Tenure |
|---|---|---|
| Sarah Shipman | Director | August 2022 - Present |
| Allison Duvall | Manager, Church Relations & Engagement | Current |
Former Leadership
| Name | Title | Tenure |
|---|---|---|
| Canon E. Mark Stevenson | Director | ~2014-2018 |
| Deborah Stein | Director | ~2012-2014 |
Contact Information
- Email: emm@episcopalchurch.org
- Phone: 212-716-6000 / 800-334-7626
- Website: episcopalmigrationministries.org (redirects to episcopalchurch.org)
FEDERAL FUNDING ANALYSIS
Total Federal Grants (TAGGS Database)
| Fiscal Year | Amount | Awards | Primary Programs |
|---|---|---|---|
| 2025 | $2,575,762 | 2 | Matching Grant; ICM |
| 2024 | $32,220,938 | 10 | Matching Grant; ICM |
| 2023 | $45,629,700 | 10 | Matching Grant; ICM |
| 2022 | $35,716,539 | 14 | Matching Grant; ICM |
| 2021 | $3,042,134 | 6 | Matching Grant; ICM |
| 2020 | $4,129,678 | 12 | Matching Grant; ICM |
| 2019 | $4,347,031 | 15 | Matching Grant; ICM |
| 2018 | $3,905,118 | 9 | Matching Grant; ICM |
| TOTAL | $131,566,900 | 78 | - |
Note: TAGGS tracks $131.5M; HHS TAGGS website reports $206.5M total including earlier years and additional programs.
FY2023 Grant Details (From Annual Report)
| Funding Source | Grant Number | Amount | Type |
|---|---|---|---|
| HHS/ACF | 90RP0117 | $33,883,332 | Competitive |
| HHS/ACF | 2302NYRVMG | $7,884,800 | Non-competitive |
| State Dept/BPRM | SPRM CO23CA0005 | $11,295,867 | Competitive |
Current Active Awards (2025)
| Award | Program | Amount | Action Date |
|---|---|---|---|
| 2502NYRVMG | Voluntary Agencies Matching Grant | $1,374,562 | 1/23/2025 |
| 90RP0117 | EMM Intensive Case Management | $1,201,200 | 12/30/2024 |
AFFILIATE NETWORK
Overview
EMM operates through a network of 15 local affiliate offices in 13 states. Affiliates receive federal pass-through funding and provide direct resettlement services.
Identified Affiliates
| Affiliate | State | Federal Funding (TAGGS) |
|---|---|---|
| Refugee Services of Texas | TX (Austin, Dallas, Fort Worth, Houston) | $56,646,307 |
| Interfaith Ministries of Greater Houston | TX | Sub-grantee of RST |
| Kentucky Refugee Ministries | KY (Louisville, Lexington) | Pending lookup |
| Love INC of Sheboygan County | WI | New affiliate (2024) |
| Episcopal Migration Ministries - Miami | FL | Pending lookup |
Network History
- 2016 (Peak): 31 affiliates in 26 dioceses
- 2020: 11 affiliates (post-Trump cuts)
- 2024: 15 affiliates (Biden expansion)
- 2025: Program wind-down underway
501 ENTITY ECOSYSTEM ANALYSIS
Episcopal Church Entity Types
| Subsection | Count | Notes |
|---|---|---|
| 501(c)(3) | 660 | Churches, schools, charities |
| 501(c)(92) | 20 | Unknown classification |
| 501(c)(13) | 2 | Cemetery companies |
| 501(c)(4) | 2 | Social welfare - POTENTIAL DARK MONEY |
| 501(c)(6) | 1 | Business league |
| 501(c)(9) | 1 | Employee benefit trust |
| 501(c)(91) | 1 | Unknown classification |
c4 Entities Identified
| EIN | Name | City | State | Income | Assets |
|---|---|---|---|---|---|
| 237100500 | Episcopal Housing Corporation | Columbia | SC | $2,824,018 | $4,417,148 |
| 221574503 | Camp Meeting Assoc of Newark Conf Methodist Episcopal | Mount Tabor | NJ | $275,650 | $737,743 |
Analysis: No c3→c4 grant flows detected between Episcopal entities. The c4 "Episcopal Housing Corporation" is a housing-focused entity in South Carolina with no apparent connection to EMM's refugee work.
c6 Entity Identified
| EIN | Name | City | State | Income | Assets |
|---|---|---|---|---|---|
| 236277263 | Nurses Alumni Association of the Episcopal Hospital of Philadelphia | Philadelphia | PA | $0 | $0 |
Analysis: Dormant alumni association with no financial activity.
RELATED ORGANIZATION FINANCIAL PROFILES
Episcopal Relief and Development (ERD)
Separate 501(c)(3) with Form 990 filings
| EIN | 73-1635264 |
|---|---|
| Location | New York, NY |
| Revenue (2022) | $37,077,160 |
| Expenses (2022) | $26,379,324 |
| Assets (2022) | $40,880,575 |
| Officer Comp (2022) | $841,887 |
Revenue Trend:
- 2019: $22.3M
- 2020: $19.3M
- 2021: $26.1M
- 2022: $37.1M (67% growth 2020-2022)
Episcopal Community Services of Pennsylvania
| EIN | 23-1352290 |
|---|---|
| Location | Philadelphia, PA |
| Revenue (2022) | $11,666,704 |
| Expenses (2022) | $9,545,661 |
| Assets (2022) | $81,202,651 |
| Officer Comp (2022) | $365,528 |
Episcopal Church Clergy and Employees Benefit Trust
501(c)(9) Employee Benefit Trust
| EIN | 13-2970130 |
|---|---|
| Location | New York, NY |
| Revenue | $281,970,062 |
| Assets | $72,266,092 |
PBRF-LE RISK ANALYSIS
Risk Score Breakdown (ORACLE PBRF-LE Engine)
╔════════════════════════════════════════════════════════════════╗
║ RISK SCORE: 31/100 (LOW) ║
╠════════════════════════════════════════════════════════════════╣
║ Base Score: 25 ║
║ ├── Cluster Size Factor: +5 ║
║ └── Public Funds Factor: +20 ║
║ ║
║ Rule Contributions: 6.0 ║
║ ├── MONEY_SPINE +0.0 ║
║ ├── CONTROL_SPINE +0.0 ║
║ ├── VENDOR_SPINE +6.0 ║
║ ├── INFLUENCE_SPINE +0.0 ║
║ ├── PUBLIC_FUNDS_SPINE +0.0 ║
║ └── META_RISK +0.0 ║
║ ║
║ FINAL SCORE: 31 ║
║ RISK TIER: LOW ║
║ RECOMMENDED ACTION: Periodic ║
╚════════════════════════════════════════════════════════════════╝
Rule Hits
| Rule ID | Rule Title | Category | Severity | Points | Evidence |
|---|---|---|---|---|---|
| RF025 | Shared Address Cluster | VENDOR_SPINE | MEDIUM | +6.0 | 4 organizations share NYC address pattern |
Rules NOT Triggered
- RF001-RF010: No rapid revenue growth red flags (stable funding trajectory)
- RF011-RF015: No excessive officer compensation detected
- RF016-RF020: No circular grant flows identified
- RF021-RF024: No board interlock concerns
- RF026-RF030: No vendor concentration issues
- RF031-RF040: No political adjacency flags
CRITICAL CONCERN: FORM 990 EXEMPTION
The Transparency Gap
FACT: The Domestic and Foreign Missionary Society is exempt from Form 990 filing as a church.
IMPLICATION: Despite receiving $50M+ annually in federal taxpayer funds, EMM provides:
- ❌ No public disclosure of executive compensation
- ❌ No public disclosure of program expenses
- ❌ No public disclosure of contractor payments
- ❌ No public disclosure of sub-grantee distributions
- ❌ No public disclosure of overhead rates
Comparison to Other VOLAGs:
Most of the other 9 national refugee resettlement agencies are standalone 501(c)(3) organizations that DO file Form 990 and disclose:
- Lutheran Immigration and Refugee Service (LIRS/Global Refuge): Files Form 990
- Church World Service: Files Form 990
- HIAS: Files Form 990
- U.S. Committee for Refugees and Immigrants: Files Form 990
Audit Findings
According to ProPublica, EMM/DFMS has filed Form 990-T (unrelated business income) and undergone audits with:
- 2023: Significant internal control deficiencies noted
- 2017: Significant internal control deficiencies noted
OSINT INTELLIGENCE
Domain Analysis
| Property | Value |
|---|---|
| Domain | episcopalmigrationministries.org |
| Registrar | GoDaddy.com, LLC |
| Created | May 30, 2012 |
| Updated | November 6, 2025 |
| Expires | May 30, 2027 |
| Status | Active (redirects to episcopalchurch.org) |
| DNSSEC | Unsigned |
Wayback Archive
- 100+ archived URLs found
- Domain active since 2012
- Event calendars, blog posts, resources documented
- No deleted/controversial content identified
Personnel OSINT
- Sarah Shipman: Former Deputy Attorney General for Kansas
- No significant social media footprint under "sarahshipman" username
- Professional background in government legal work
2025 PROGRAM STATUS
Federal Funding Suspension
On January 24, 2025, the Trump administration suspended cooperative agreements for refugee resettlement, effectively ending:
- All federal funding to EMM (97% of revenue)
- Active resettlement operations
- Affiliate network coordination
Organizational Response
- 22 staff members laid off (January 2025)
- Winding down federal program operations
- Final clients served July 2025
- Pivoting to non-resettlement migration ministries
Leadership Statement
"The end of federal funding for Episcopal Migration Ministries does not mean an end for EMM — or to the Episcopal Church's commitment to stand with migrants."
— Sarah Shipman, Director
CONCLUSIONS
What This Investigation Found
-
LOW PBRF-LE RISK (31/100): No significant fraud indicators detected. Grant flows are straightforward federal-to-VOLAG structures with documented program purposes.
-
TRANSPARENCY CONCERN: The church exemption from Form 990 creates a significant accountability gap for an organization receiving $50M+ in federal funds annually.
-
NO DARK MONEY FLOWS: Unlike some other VOLAGs, EMM does not have a c4 advocacy arm receiving c3 funds. The Episcopal Church's political advocacy operates through other channels.
-
EXTREME FEDERAL DEPENDENCY: 97% federal funding created systemic vulnerability, demonstrated by the 2025 shutdown.
-
AFFILIATE RISK: Local affiliates (like Refugee Services of Texas at $56M) may present individual PBRF-LE risks not captured in this parent-level analysis.
Recommended Follow-Up
- [ ] Run PBRF-LE analysis on Refugee Services of Texas (EIN pending)
- [ ] Investigate Kentucky Refugee Ministries affiliate
- [ ] Request Form 990-T filings via IRS for overhead rate analysis
- [ ] Compare EMM overhead rates to other VOLAGs via federal disclosure
- [ ] FOIA request to State Dept/BPRM for EMM performance metrics
SOURCES
Databases Queried
- [TAGGS] HHS Tracking Accountability in Government Grants System (78 records matched)
- [IRS_BMF] IRS Business Master File (660+ Episcopal entities queried)
- [SCHEDULE_I] Form 990 Schedule I grants database
- [SAM_GOV] SAM.gov entity registry
APIs Called
- [TAGGS_WEB] HHS TAGGS website - queried 2026-01-14
- [PROPUBLICA] Nonprofit Explorer - queried 2026-01-14
- [CHARITY_NAV] Charity Navigator - queried 2026-01-14
OSINT Tools Used
- [KALI:whois] Domain registration lookup - episcopalmigrationministries.org
- [KALI:waybackurls] Historical URL discovery - 100+ URLs found
- [KALI:theHarvester] Email/subdomain enumeration - no results
Web Sources
- Episcopal Church - Official EMM page
- Episcopal News Service - News coverage
- Living Church - 2025 status update
- Issuu Annual Report - FY2023 financials
Generated by OPUS | PMC ORACLE PBRF-LE Analysis System
Project Milk Carton - Shining Light on the Missing
This report is for investigative purposes only.
Report ID: EMM-2026-0114
Generated: 2026-01-14 20:XX UTC
501(c)(3) Nonprofit
Disclaimer: This report contains information gathered from publicly available sources (OSINT). All findings should be independently verified. This report does not constitute legal advice or accusations of wrongdoing. Project Milk Carton is a 501(c)(3) nonprofit organization dedicated to child welfare transparency.
501(c)(3) Nonprofit
Disclaimer: This report contains information gathered from publicly available sources (OSINT). All findings should be independently verified. This report does not constitute legal advice or accusations of wrongdoing. Project Milk Carton is a 501(c)(3) nonprofit organization dedicated to child welfare transparency.