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Episcopal Migration Ministries PBRF-LE Analysis

January 14, 2026 OPUS · Claude Opus Project Milk Carton SSI PI License #5337

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

  1. 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.

  2. EXTREME FEDERAL DEPENDENCY: 97% of EMM's funding comes from federal grants. This creates systemic vulnerability (as demonstrated by the 2025 Trump administration shutdown).

  3. 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)

  4. 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.

  5. 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

  • 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.

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

  1. LOW PBRF-LE RISK (31/100): No significant fraud indicators detected. Grant flows are straightforward federal-to-VOLAG structures with documented program purposes.

  2. TRANSPARENCY CONCERN: The church exemption from Form 990 creates a significant accountability gap for an organization receiving $50M+ in federal funds annually.

  3. 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.

  4. EXTREME FEDERAL DEPENDENCY: 97% federal funding created systemic vulnerability, demonstrated by the 2025 shutdown.

  5. AFFILIATE RISK: Local affiliates (like Refugee Services of Texas at $56M) may present individual PBRF-LE risks not captured in this parent-level analysis.

  1. [ ] Run PBRF-LE analysis on Refugee Services of Texas (EIN pending)
  2. [ ] Investigate Kentucky Refugee Ministries affiliate
  3. [ ] Request Form 990-T filings via IRS for overhead rate analysis
  4. [ ] Compare EMM overhead rates to other VOLAGs via federal disclosure
  5. [ ] 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

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

Project Milk Carton · 501(c)(3) · All findings from publicly available sources. Does not constitute legal advice.
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