Dr. David J. Spittal, President

Southern Wesleyan University

P.O. Box 1020

907 Wesleyan Dr.

Central, SC 29630-1020

Dear Dr. Spittal:

This **Final Audit Report** (A06-A0024) presents the results of our
Audit of Commissioned Sales and Course Length at Southern Wesleyan
University (University). Our objectives were to determine whether the
University complied with the Higher Education Act's (HEA) prohibition
against the use of incentive payments for recruiting activities and with
the HEA's required minimum number of instructional hours.

**AUDIT RESULTS**

We found that the University was not in compliance with the statutory
prohibition on the use of incentive payments for recruiting based on
success in securing student enrollments when it paid the Institute for
Professional Development (IPD) a percentage of tuition for all students
enrolled in its Adult and Graduate Studies (Adult Studies) programs. As
a result of incentive payments made to IPD, the University is liable for
\$19,451,123 in Title IV funds awarded to students in the Adult Studies
programs who were improperly recruited.

We also found that the University's documentation supporting the actual
number of instructional hours spent in study groups used in the
definition of an academic year for its Adult Studies programs did not
provide the number of instructional hours required to meet the statutory
definition of an academic year. The statutory definition of an academic
year is set forth in 34 C.F.R. § 668.2(b). The regulations in this
section that apply to institutions not using semester, trimester, or
quarter systems are commonly known as the 12-Hour Rule. The 12-Hour Rule
requires the equivalent of at least 360 instructional hours per academic
year. An institution's academic year and the credit hours that a student
is enrolled in are used, in part, to determine the amount of funds a
student is eligible to receive from the Title IV programs. We estimated
that the University over awarded and disbursed Title IV funds totaling
\$4,768,997 on behalf of its Adult Studies students. (This amount is
included in our finding on instructional time.)

We provided a draft of this report to the University. In its response,
the University disagreed with the findings and recommendations. After
reviewing the University's response, we did not change the findings or
recommendations. We have summarized the University's comments after the
applicable recommendations. A copy of the complete response is enclosed
with this report.

**[Finding 1]{.underline} - Institutions Participating in the Title IV
Programs Must Not Provide Payments Based on Success in Securing
Enrollments to Any Person or Entity Engaged in Recruiting**

HEA Sections 487(a) and 487(a)(20) require that:

> In order to be an eligible institution for the purposes of any program
> authorized under this title, an institution . . . shall . . . enter
> into a program participation agreement with the Secretary. The
> agreement shall condition the initial and continuing eligibility of an
> institution to participate in a program upon compliance with the
> following requirements:
>
> ...The institution will not provide any commission, bonus, or other
> incentive payment based directly or indirectly on success in securing
> enrollments or financial aid to any persons or entities engaged in any
> student recruiting or admission activities or in making decisions
> regarding the award of student financial assistance....

The regulations at 34 C.F.R. § 668.14(b)(22) codify the statutory
prohibition on incentive payments based on securing enrollment:

> By entering into this program participation agreement, an institution
> agrees that . . . \[i\]t will not provide, nor contract with any
> entity that provides, any commission, bonus, or other incentive
> payment based directly or indirectly on success in securing
> enrollments or financial aid to any persons or entities engaged in any
> student recruiting or admission activities or in making decisions
> regarding the awarding of student financial assistance.

**IPD Recruited Students and Received Payments Based on Student
Enrollment in the Adult Studies Programs**

The University entered into a contract with IPD that provided for
incentive payments to IPD based on success in securing student
enrollments for its Adult Studies programs. The contract stated that
"IPD is a recruiting service organization assisting Southern Wesleyan
University in recruiting students for the programs." The contract
included the following specific responsibilities for IPD:

-   IPD shall recruit students to enroll in the courses of study in the
    Adult Studies programs.

-   IPD shall provide representatives to recruit students for the Adult
    Studies programs.

-   IPD shall collect, on behalf of Southern Wesleyan University, all
    tuition, application fees, book and material fees, and other fees
    applicable to the programs.

-   IPD shall maintain the official program accounting books and
    records.

IPD remitted book and material fees in full to the University. Tuition
fees were divided between the parties on a weekly basis. During the
period of our audit, in accordance with the contract, the division
ranged from 50 percent to the University and 50 percent to IPD to 70
percent to the University and 30 percent to IPD. The ratios were
student-specific for as long as students maintained continuous
enrollment. For example, revenue for students who enrolled under a 60/40
ratio would still be divided on the basis of that ratio even if the
ratio changed in a subsequent year for incoming students. Refunds were
also paid according to those percentages. In contracting with IPD to
provide recruiting services, the University violated the statutory and
regulatory provisions quoted above by paying IPD a percentage of tuition
for each student IPD recruited.

**The University Violated the HEA by Paying IPD Based on Success in
Securing Enrollments for the Adult Studies Programs Which Resulted in
\$19,451,123 of Improperly Disbursed Title IV Funds**

Because the University did not comply with the HEA and regulations by
paying incentives to IPD based on success in securing student
enrollments for its Adult Studies programs, the University must return
all Title IV funds that were disbursed on behalf of students enrolled in
the Adult Studies programs who were improperly recruited. Because the
University paid incentives for each student enrolled in the Adult
Students programs, all students in the programs were improperly
recruited. Our audit covered the period July 1, 1997, through June 30,
2000. For that period, Title IV funds totaling \$19,451,123 were
disbursed on behalf of students enrolled in the Adult Studies programs,
consisting of \$18,346,658 in Federal Family Education Loan Program
(FFEL), \$1,079,565 in Federal Pell Grant Program (Pell), \$21,400 in
Federal Supplemental Educational Opportunity Grant Program (FSEOG), and
\$3,500 in Federal Perkins Loan Program (Perkins) funds.

**IPD Recruiters Received Salary and Bonuses Based on the Number of
Students Enrolled in the Adult Studies Programs**

Our review of IPD's compensation plans for Fiscal Years (FY) 1997-1999
disclosed that IPD provided incentives to its recruiters through salary
levels that were based on the number of students recruited and enrolled
in the programs. According to the plans, IPD assigned recruiters a
salary within the parameters of performance guidelines (that is,
knowledge of basic policies and procedures, organization and
communication skills, and working relationships). IPD assessed recruiter
performance on a regular basis, comparing it to the established goals
for the fiscal year. The plans stated that IPD would complete formal
evaluations biannually and, after the first six months of employment,
determine salary on an annual basis. The plans showed that the
recruiter's success in enrolling students determined whether IPD
adjusted the salary upward, downward, or kept it the same. In addition,
the FY 1998 and 1999 compensation plans called for the payment of
bonuses to recruiters hired before September 1, 1997, and September 1,
1998, respectively. The bonuses increased as the number of students
increased, and ranged from \$1,344 for recruiting 100 students to
\$29,600 for recruiting over 200 students. The FY 1999 plan indicated
that recruiters hired on or after September 1, 1998, who achieved 100 or
more students enrolled in and starting classes by the end of the fiscal
year, were entitled to a one-time bonus of \$1,500. In contracting with
IPD, the University was not in compliance with 34 C.F.R.

§ 668.14(b)(22) because IPD paid its recruiters incentive compensation
based on success in securing enrollments.

**RECOMMENDATIONS**

We recommend that the Chief Operating Officer for Federal Student Aid
(FSA) require the University to:

1.1 Amend and/or terminate immediately its present contractual
relationship with IPD to eliminate incentive payments based on success
in securing student enrollments.

1.2 Return to lenders \$18,346,658 of FFEL disbursed on behalf of
students enrolled in the Adult Studies programs during the period July
1, 1997, through June 30, 2000, and repay the Department for interest
and special allowance costs incurred on Federally-subsidized loans.

1.3 Return to the Department \$1,079,565 of Pell, \$21,400 of FSEOG, and
\$3,500 of Perkins disbursed to students enrolled in the Adult Studies
programs during the period July 1, 1997, through June 30, 2000.

1.4 Determine the amount of FFEL, Pell, FSEOG, and Perkins funds
improperly disbursed to or on behalf of students since the end of our
audit period and return the funds to the Department and lenders.

**UNIVERSITY'S COMMENTS TO THE DRAFT REPORT**

**AND OIG'S RESPONSE**

The University did not agree with our conclusions and recommendations.
The following is a summary of the University's comments and our response
to the comments. The full text of the University's comments is enclosed.

[University's Comments]{.underline}. **The allocation of revenue under
the IPD contract does not violate the Incentive Compensation Rule.** The
University stated that:

-   The IPD Contract compensates IPD based on the volume of a broad
    range of professional services provided to \[the\] University, many
    of which have variable costs dependant on the number of students
    enrolled in the Adult Studies programs.

-   The Incentive Compensation Rule does not apply to the IPD Contract
    because (1) the Department is without legal authority to use the
    rule as a basis for regulating routine contracts for professional,
    non-enrollment related services; and (2) the rule cannot apply to
    service contracts where the cost of providing services necessarily
    varies depending on the number of students.

-   The Department has published no regulation or other public guidance
    supporting the interpretation of revenue-sharing arrangements
    advanced by the OIG in the Draft Audit Report.

**The IPD Contract compensates IPD based on the volume of a broad range
of professional services provided to the University.** The University
stated that IPD provides the following list of services with respect to
the operation of the Adult Studies programs:

-   Management consultation and training regarding:

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-   Program administration and evaluation;

-   Marketing research and planning;

-   Student accounts management and reporting;

-   Student tracking systems development and implementation;

-   Faculty recruitment and assessment;

-   Ongoing curriculum review and revision;

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-   Learning outcome assessments and academic quality control
    evaluations;

-   Program administration, including office space, on-site contract
    manager, and support administration support staff;

-   Professional development and training activities for the
    University's financial aid staff, student services personnel, and
    Adult Studies faculty;

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-   Feasibility Studies concerning potential expansion of Adult Studies
    programs.

The University stated that OIG implied that IPD only provided recruiting
and tuition collection services and the OIG either overlooked or ignored
other services provided by IPD under the agreement with the University.

[OIG's Response]{.underline}. The OIG did not overlook or ignore the
fact that IPD provided other services to the University under the terms
of the agreement. In the draft audit report, we acknowledged that IPD
provided additional services, such as program accounting. Because it was
not within our scope of audit, we did not determine the extent of
additional services under the agreement that IPD actually provided at
the request of the University and at IPD's cost. We did verify that the
revenue to IPD was generated only by its success in securing enrollments
for the University. This constitutes a statutory violation of providing
a commission, bonus, or other incentive payment based directly or
indirectly on the success in securing enrollments.

While we recognize that IPD logically had to incur expenses to provide
the program accounting services and any additional services that it may
have provided, these expenses are irrelevant in determining whether the
structure of the revenue allocation is a violation of the HEA. No
compensation was to be provided to IPD unless IPD was successful in
recruiting and securing student enrollments. The agreement also included
a minimum enrollment guarantee that, if not achieved, would result in a
reduction of revenue to be allocated to IPD, despite other services that
might have been provided. This further emphasizes that the revenue
stream is completely generated by, and dependent on, student enrollment.

The University does not dispute that the payments made to IPD were based
on a percentage of the tuition and fees paid by students enrolled in the
Adult Studies programs. Likewise, the University does not dispute that
IPD was responsible for recruiting students. Nor does the University
dispute that some portion of the amount paid to IPD was directly related
to IPD's success in securing enrollments for the University's Adult
Studies programs. Our audit report did not focus on what other services
may have been provided by IPD because once IPD became responsible for
recruiting students, even among other activities, and received
compensation from the University based on the number of students
enrolled in the program, the University was in violation of the HEA.

The HEA at § 487(a)(20) states:

The institution will not provide **any** commission, bonus, or other
incentive payment based directly or indirectly on success in securing
enrollments or financial aid to **any persons or entities engaged in any
student recruiting** . . . . \[Emphasis Added\]

Once recruiting was added to the services to be provided under the
contract, compensation based on enrollment was no longer permitted. IPD
had sole responsibility for recruitment and enrollment, and was paid
under the contract only on the basis of its success in securing student
enrollment regardless of what other services it may have been providing.
Whether or not the revenue allocation was intended to provide
compensation for other services is irrelevant because the allocation
violates the law.

[University's Comments]{.underline}. **The Incentive Compensation Rule
does not apply to the IPD Contract because (a) the Department has no
legal authority for using the Incentive Compensation Rule as a basis for
regulating routine contracts for professional, non-enrollment related
services; and (b) the Incentive Compensation Rule cannot apply to
service contracts where the cost of providing services necessarily
varies depending on the number of students.** The University stated that
the Incentive Compensation Rule was intended to prevent schools from
using commissioned salespersons to recruit students, not to regulate
business arrangements. When Congress enacted the statute, and the
Department promulgated the implementing regulation, both emphasized
their intention to halt the use of commissioned salespersons as
recruiters.

[OIG's Response]{.underline}. The HEA does not excuse or permit
incentive payments depending on the type of contractual arrangement that
creates them. Any incentive payment based directly or indirectly on
success in securing enrollment is prohibited. The contract with IPD
included recruiting activities with compensation determined by IPD's
success in securing students for enrollment on a per student basis.

[University's Comments]{.underline}. **The Department has published no
regulation or other public guidance supporting the OIG's interpretation
of the Incentive Compensation Rule to restrict routine revenue sharing
arrangements.** The University stated that the draft report cites no
regulatory guidance, case law, or other published guidance to support
the proposition that the revenue allocation formula violates the
Incentive Compensation Rule. The University did not know, and could not
have known, that the revenue allocation formula would be construed as a
violation of the Incentive Compensation Rule, because no such
pronouncement or interpretation had ever been published and disseminated
to Title IV participating institutions.

[OIG's Response]{.underline}. The HEA prohibition, § 487(a)(20), on
incentive payments is clear.

> The institution will not provide **any** commission, bonus, or other
> incentive payment based directly or indirectly on success in securing
> enrollments or financial aid to **any persons or entities engaged in
> any student recruiting . . ..** \[Emphasis Added\]

The University signed a program participation agreement committing it to
comply with the HEA and regulations. The contract clearly indicated that
IPD was to be an entity engaged in student recruiting on behalf of the
University. The contract also clearly showed that compensation to IPD
was a percentage of the tuition revenue based on IPD's success in
securing student enrollments for the University.

[University's Comments]{.underline}. **The OIG's recommendation --
disallowance of all Title IV funds received by the University for all
Adult Studies enrollees -- is unwarranted and is inconsistent with
applicable law and regulations.** The University stated that no basis
exists to support that a violation of any of the innumerable
requirements of the program participation agreement warrants a wholesale
disallowance of all Title IV funds. In the absence of any OIG statement
of reasons, or other detailed explanation for the extreme sanction, the
University cannot presently submit any comprehensive response to the
draft audit report's recommendations.

[OIG's Response]{.underline}. The University incorrectly characterized
our recommendation for monetary recovery as a sanction. We are not
proposing that the University be fined. We are recommending that the
Department recover funds disbursed in violation of the HEA.

[University's Comments]{.underline}. **Recruiter salaries do not violate
the Incentive Compensation Rule because (1) the Incentive Compensation
Rule does not prohibit salary based on success in securing enrollments;
(2) the legislative history of the Incentive Compensation Rule makes
clear that Congress intended to permit recruiter salaries to be based on
merit; and (3) the Secretary has not published any interpretation of the
Incentive Compensation Rule that would prohibit recruiter salaries based
on merit.** The University stated that IPD's compensation plans based
recruiter salaries on factors or qualities that are not solely related
to success in securing enrollments. It also stated that the prohibition
in §487(a)(20) did not extend to salaries. Even if salaries were
included, the University stated that salaries could be based on merit or
success in securing enrollment as long as enrollment was not the sole
factor.

[OIG's Response]{.underline}. Contrary to the University's
representation, the compensation plan we reviewed did not include
factors other than enrollment to adjust recruiter salaries. According to
the compensation plan, recruiters' salaries were determined annually by
how many students they enrolled in the programs. Annual salaries would
increase, decrease or remain the same in accordance with predetermined
tables that directly tied students enrolled to particular salary
amounts. The salary tables did not include factors other than
enrollment. The requirements of §487(a)(20) cannot be avoided by
labeling improper incentive compensation as salary.

**[Finding 2]{.underline} -- Non-Term Institutions Must Provide a
Minimum of 360 Hours of Instructional Time in an Academic Year**

HEA § 481(a)(2) states that the term "academic year" shall:

> Require a minimum of 30 weeks of instructional time, and, with respect
> to an undergraduate course of study, shall require that during such
> minimum period of instructional time a full-time student is expected
> to complete at least 24 semester or trimester hours or 36 quarter
> hours at an institution that measures program length in credit hours .
> . . .

The regulations at 34 C.F.R. § 668.2(b) clarify what constitutes a week
of instructional time in the definition of an academic year:

> . . . the Secretary considers a week of instructional time to be any
> week in which at least one day of regularly scheduled instruction,
> examinations, or preparation for examinations occurs . . . . For an
> educational program using credit hours but not using a semester,
> trimester, or quarter system, the Secretary considers a week of
> instructional time to be any week in which at least 12 hours of
> regularly scheduled instruction, examinations, or preparation for
> examinations occurs . . . .

These regulations, commonly known as the 12-Hour Rule, require the
equivalent of 360 instructional hours per academic year (12 hours per
week for 30 weeks). Institutions were required to comply with the
12-Hour Rule as of July 1, 1995.

In the preamble to the 12-Hour Rule regulations published on November
29, 1994, the Secretary explained that an institution with a program
that meets less frequently than 12 hours per week would have to meet for
a sufficient number of weeks to result in the required instructional
hours. For example, if an institution decided to establish an academic
year for a program with classes that met for 10 hours per week, the
classes would need to be held for 36 weeks to result in 360 hours.

The University measured its Adult Studies education programs in credit
hours, but did not use a semester, trimester, or quarter system. The
Adult Studies programs consisted of a series of courses for which a
student generally received three credit hours per course. The University
defined its academic year as 45 weeks, during which students could earn
26 credit hours. To comply with the 12-Hour Rule, the University would
need to provide at least eight hours of instruction per week for each
week in its 45-week academic year to equal 360 hours per year.

**The University Did Not Have Management Controls in Place to Ensure
That the Required 360 Hours of Instruction for Each Academic Year Were
Scheduled and Occurred**

Management controls are the policies and procedures adopted and
implemented by an organization to ensure that it meets its goals, which,
as applicable to this situation, are compliance with laws and
regulations. According to the Adult Studies Student Handbook, students
were required to meet in class for four hours per week, and were
expected to meet an additional four hours per week in study groups. The
Adult Studies Student Handbook stated: "\[I\]t is the policy of SWU AGS
administrative staff not to interfere with the make-up or operation of
any study group." The University counted the study group time for
purposes of the 12-Hour Rule. We found that the University did not
establish and implement management controls to ensure that study groups
were regularly scheduled and occurred.

We reviewed the University's policies applicable to the Adult Studies
program classes and study groups. The Adult Studies Handbook provided
that class attendance was mandatory, with a student missing more than 25
percent of the classes receiving no credit for the course. The Adult
Studies Handbook had no such provision for study group participation and
instructors were not required to be present at study group meetings.
According to the Adult Studies Handbook, each study group was required
to create a study group "constitution" to govern the operation of the
group and to "help ensure fairness and equality in the outcomes of group
processing." The constitution was designed to show (1) the time and
place for each group meeting and (2) the students' agreement to comply
with the rules and expectations of the University. University officials
stated that study group constitutions were graded by professors and
returned to the students, and that the constitutions did not become part
of the students' permanent records. Therefore, the constitutions were
unavailable for our review.

Our review of the University's records showed that not all study groups
met for the required number of hours. Each cohort group (class) ranged
in size from 16 to 22 students, and each cohort group had about 4 to 5
study groups, each of which consisted of 3 to 5 students. At the time of
our fieldwork, the University had 79 study groups. We selected a sample
of six classes (two from each of the three years in our audit period),
and then requested study group meeting logs for those classes. The
documentation that we obtained identified 81 courses for those six
classes. At the time of our fieldwork, 10 of the courses had not been
completed. The students in the remaining 71 courses should have met in a
total of at least 1,520 study group sessions. We determined that the
University did not have evidence to support that 54 percent of the
required 6,080 study group hours for the 1,520 study group sessions were
regularly scheduled and occurred.

Based on our review of the University's written policies and procedures,
review of academic records, and interviews with University officials,
the University had no assurance that study groups were scheduled and
occurred to meet the requirements of the 12-Hour Rule.

**Failing to Comply with the 12-Hour Rule Resulted in the University
Over Awarding \$4,768,997 of Title IV Funds to Students Enrolled in the
Adult Studies Programs**

Because the University did not ensure that study group meetings were
scheduled and occurred as required, the meetings do not qualify for
inclusion in the 12-Hour Rule calculation. Consequently, the
University's defined academic year of 45 weeks provided only 180 hours
of the required minimum of 360 hours of instructional time (four hours
of classroom instruction per week for 45 weeks equals 180 hours). In
order to meet the 360-hour requirement, the University's academic year
would need to be 90 weeks in length. By using an academic year of 45
weeks rather than 90 weeks for awarding Title IV funds, the University
disbursed amounts to students that exceeded the maximum amounts for an
academic year allowed under Title IV programs. We estimated that the
University over awarded \$4,768,997 of Title IV funds for Adult Studies
students during the period July 1, 1997, through June 30, 2000. Those
funds consisted of \$4,229,215 in FFEL and \$539,782 in Pell.

> **[FFEL Limits]{.underline}** - 34 C.F.R. § 682.603(d) stipulates that
> an institution may not certify a loan application that would result in
> a borrower exceeding the maximum annual loan amounts specified in 34
> C.F.R. § 682.204. We estimated that \$4,229,215 in FFEL disbursements
> exceeded the annual loan limits.
>
> **[Pell Grant Maximum]{.underline}** - 34 C.F.R. § 690.62(a) specifies
> that the amount of a student's Pell Grant for an academic year is
> based upon schedules published by the Secretary for each award year.
> The payment schedule lists the maximum amount a student could receive
> during a full academic year. We estimated that \$539,782 in Pell Grant
> disbursements exceeded the maximum amount allowed.

Institutions were required to comply with the 12-Hour Rule as of July 1,
1995. Because the University's academic year for its Adult Studies
programs did not meet the requirements of the 12-Hour Rule, the
University improperly disbursed Title IV funds awarded during the audit
period.

**RECOMMENDATION**

We recommend that the Chief Operating Officer for FSA require the
University to:

2.1. Immediately develop an academic year for its undergraduate Adult
Studies programs that satisfies the 12-Hour Rule as a condition for
continued participation in Title IV programs.

The dollars we estimated as over awarded due to violating the statutory
course length requirements are duplicative of the dollars we determined
as over awarded due to violating the statutory prohibition against the
use of incentive payments for recruiting activities. Only those amounts
not recovered in Finding 1 should be recovered by FSA as a result of
Finding 2.

### UNIVERSITY'S COMMENTS TO THE DRAFT REPORT

**AND OIG'S RESPONSE**

The University did not agree with our conclusions and recommendation.
The following is a summary of the University's comments and our response
to the comments. The full text of the University's comments is enclosed.

In summary, the University stated that:

I.  The Adult Studies program complies with the 12-Hour Rule, and the
    University has adequately documented its compliance with the 12-Hour
    Rule.

A. Study group meetings constitute instructional activity.

B.  The University implemented pre-enrollment procedures to ensure
    students' awareness of the study group attendance requirements.

C.  Study group meetings were regularly scheduled and closely monitored
    by the University.

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D.  Study groups are part of an integrated curriculum module, and
    faculty members were aware of which students did not attend the
    study group meetings in any given week.

E.  Additional hours spent by students in preparation for examinations
    are includable under the 12-Hour Rule.

F.  There is no statutory or regulatory basis for the OIG's requirement
    that the University "ensure that study group meetings were taking
    place."

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II. The 12-Hour Rule is widely acknowledged to be unworkable and
    ill-suited for nontraditional programs.

III. The recommended liability is based on erroneous methodology and
     excludes significant amounts of time that can count toward
     compliance with the 12-Hour Rule.

[University's Comments]{.underline}. **The University's Adult Studies
program complies with the 12-Hour Rule and the University has adequately
documented its compliance with the 12-Hour Rule.**

The University stated that the fact that it could document that 46
percent of the study groups occurred demonstrated its diligence in
applying multiple layers of monitoring controls to study groups. It also
questioned why we did not give the University credit for the study
groups it could document in determining the amount of Title IV funds
that were overawarded.

The University stated that the Department has already concluded that
"\[t\] here is no meaningful way to measure 12 hours of instruction" for
nontraditional education programs like those questioned by the draft
audit report. The University implemented various policies and procedures
to ensure the Adult Studies programs provided the requisite amount of
regularly scheduled instruction, examinations, or preparation for
examinations required by the 12-Hour Rule. The University also stated
that the OIG had established a *documentation rule* that exceeded
statutory and regulatory requirements.

[OIG's Response]{.underline}. It is the University's responsibility to
provide each full-time student with 360 hours of regularly scheduled
instruction. It is a simple matter to demonstrate compliance with the
requirement when dealing with classroom instruction because institutions
need to plan for and reserve the space for classes as well as arrange
for and pay an instructor. The University did not schedule space for
study groups or provide an instructor for students at other than the
scheduled classroom time. It is the University's responsibility to
demonstrate compliance with the Title IV regulations. The University
could not provide us with any documentation that the study groups were
regularly scheduled. What the University did provide supported less than
half the required number of additional hours from study groups. This did
not give us sufficient evidence to conclude that the study groups were
regularly scheduled and occurred.

The *Report to Congress on the Distance Education Demonstration
Programs* quoted by the University refers to distance education classes
that allow students to move at their own pace. Students in the Adult
Studies program were required to attend weekly study group meetings,
which the University did not consider as homework. The following excerpt
from the report expands the quotation provided by the University to
include additional clarifying information.

It is difficult if not impossible for distance education programs
offered in nonstandard terms and non-terms to comply with the 12-hour
rule. The regulation would seem to require that full-time distance
education students spend 12 hours per week "receiving" instruction.
There is no meaningful way to measure 12 hours of instruction in a
distance education class. Distance education courses are typically
structured in modules that combine both what \[sic\] an on-site course
might be considered instruction and out-of-class work, so there is no
distinction between instructional time an \[d\] 'homework.' In addition,
when they are given the flexibility to move at their own pace, some
students will take a shorter time to master the material, while others
might take longer.

On August 10, 2000, the Department issued a Notice of Proposed
Rulemaking (NPRM) concerning, among other items, changes to the 12-Hour
Rule. In the NPRM, the Department stated, "\[i\]t was never intended
that homework should count as instructional time in determining whether
a program meets the definition of an academic year, since the 12-hour
rule was designed to quantify the in-class component of an academic
program."

We have not established a documentation rule. An institution
participating in the Title IV, HEA programs is required to establish and
maintain on a current basis records that document the eligibility of its
programs and its administration of the Title IV programs in accordance
with all applicable requirements (34 C.F.R. § 668.24(a)). Our audit
procedures included reviewing any documentation that demonstrated the
University's compliance with the 12-Hour Rule. We did not *require* any
specific documentation as part of our audit. We found that the available
documentation and the University's internal control system did not
support a conclusion that the University complied with the 12-Hour Rule.

[University's Comments]{.underline}. **Study group meetings constitute
instructional activity.** The University stated that study group
meetings fall within the scope of "regularly scheduled instruction,
examinations, or preparation for examinations." The study group meetings
clearly relate to class preparation, and the regulations imply that
activities relating to class preparation qualify as instructional time.

[OIG's Response]{.underline}. We determined that the University did not
establish and implement adequate internal controls to ensure that study
group meetings were actually scheduled and occurred as required by the
University. On August 10, 2000, the Department issued an NPRM
concerning, among other items, changes to the 12-Hour Rule. In the NPRM,
the Department stated, "\[i\]t was never intended that homework should
count as instructional time in determining whether a program meets the
definition of an academic year, since the 12-hour rule was designed to
quantify the in-class component of an academic program."

[University's Comments]{.underline}. **The University implemented
pre-enrollment procedures to ensure students' awareness of the study
group attendance requirements. Study group meetings were regularly
scheduled and closely monitored by the University.** The University
required students to attend study group meetings in order to discuss
course material, prepare graded assignments, and share learning
resources. Each student was expected to contribute to the completion of
all study group assignments, which included oral and written
presentations. The University repeatedly informed students that
attendance in the study groups was mandatory and played a critical role
in the overall education program. The students, in the first week of the
program, completed a "Study Group Constitution" listing the names of all
group members, and stating the day, time, and location of their weekly
study group meeting. Each study group submitted its Constitution to a
faculty member, who reviewed whether the proposed meeting location and
time were conducive to learning.

Several other factors indicate the study group meetings were "regular,"
"scheduled," and under the supervision of University faculty. Specific
tasks were specified in the course module, and all students enrolled in
the course were required to participate in study group activities.
During study group meetings, students completed rigorous team
assignments, often preparing specified projects that were presented
during the next faculty-led workshop. The faculty exerted control over
the study group meetings by reviewing and grading the designated team
assignments and projects.

[OIG's Response]{.underline}. While the University stated that the Study
Group Constitutions listed the day, time, and location of its weekly
study group meetings, it did not provide us with these constitutions
during our fieldwork or with its response. We agree that the course
modules spelled out the requirements for study group assignments as the
University has stated. However, we disagree that a record of graded
assignments supports a conclusion that study group meetings were
regularly scheduled for the required number of hours. On August 10,
2000, the Department issued an NPRM concerning, among other items,
changes to the 12-Hour Rule. In the NPRM, the Department stated, "\[i\]t
was never intended that homework should count as instructional time in
determining whether a program meets the definition of an academic year,
since the 12-hour rule was designed to quantify the in-class component
of an academic program.

[University's Comments]{.underline}. **Study groups are part of an
integrated curriculum module, and faculty members were aware of which
students did not attend the study group meetings in any given week.**
The University contends the OIG's position is that an instructor must be
present at study group meetings in order for study groups to count as
instructional time under the 12-Hour Rule. The 12-Hour Rule expressly
states that time spent in preparation for examinations is included in
the overall calculation of instructional activity. Faculty presence is
not required when students prepare for examinations, nor is it required
for the faculty member to assess whether a student adequately
participated in the weekly meetings because the required work is
reviewed and graded.

[OIG's Response]{.underline}. Our objective was to determine whether the
University complied with the requirements of the 12-Hour Rule. The
University defined its academic year to comply with the 12-Hour Rule,
and this definition required that students attend four hours per week in
study groups. Any time that students spent in preparation for
examinations outside of study groups was not applicable to our review.
Our determination that an instructor was not present at study group
meetings was a result of our review of the University's overall internal
control over study groups. If an instructor had been present at study
group meetings, we would have considered this as evidence of strong
control.

[University's Comments]{.underline}. **Additional hours spent by
students in preparation for examinations is includable under the 12-Hour
Rule.** Some Adult Studies courses utilize traditional examinations, in
addition to study group presentations and other graded activities. The
draft audit report ignores the additional hours spent by students in
those courses preparing for examinations, although the 12-Hour Rule
explicitly permits time spent in preparation for examinations to be
counted towards compliance.

[OIG's Response]{.underline}. The University defined its academic year
as consisting of 8 hours of instruction per week for 45 weeks. This
definition provided the *minimum* 360 hours of instruction as required
by the 12-Hour Rule. University policy required that 4 hours per week be
spent in classroom workshops and 4 hours per week be spent in study
group meetings. Whether or not students spent additional time preparing
for exams is not relevant to the University's definition of an academic
year. On August 10, 2000, the Department issued an NPRM concerning,
among other items, changes to the 12-Hour Rule. The Department stated
that "the only time spent in 'preparation for exams' that could count as
instructional time was the preparation time that some institutions
schedule as study days in lieu of scheduled classes between the end of
formal class work and the beginning of final exams." The Adult Studies
program had no study days scheduled in lieu of scheduled classes.

[University's Comments]{.underline}. **There is no statutory or
regulatory requirement for the OIG's requirements that the University
"ensure that study group meetings were taking place."** The University
stated there is no legal authority for the statement in the draft audit
report that the University must "ensure" that study groups actually
"occurred." All the 12-Hour Rule requires is that study group meetings
were regularly scheduled. The more reasonable interpretation, tracking
actual text of the regulation, is consistent with the amendments to the
12-Hour Rule that took effect July 1, 2001. The revised 12-Hour Rule
requires an institution to provide "\[a\]t least 12 hours of regularly
scheduled instruction or examination" or "\[a\]fter the last scheduled
day of classes for a payment period, at least 12 hours of study for
final examinations." 34 C.F.R.

§ 668.2(b)(2) (2001). The regulation does not require the minimum 12
hours of study, after the last day of classes, to occur under direct
faculty supervision or for the University to somehow document that each
and every student actually studied at least 12 hours during the period
between classes and exams. This revision makes clear that the focus of
the rule, both before and after the regulatory change, is on whether
instructional time is "regularly scheduled" and not on whether an
institution can document that students actually completed 12 hours of
instructional activity in any given week.

[OIG's Response]{.underline}. The University's assertion that there is
no requirement that it ensure the study group meetings actually occurred
is not correct. As a fiduciary, the University must exercise, in
accordance with 34 C.F.R. § 668.82(a), the highest standard of care and
diligence in administering the Title IV programs, including compliance
with the 12-Hour Rule. In addition, the regulations at 34 C.F.R. §
668.24(a)(3) provide that the institution must "establish and maintain
on a current basis . . . program records that document . . .\[i\]ts
administration of the Title IV, HEA programs in accordance with all
applicable requirements." The University must ensure that the study
groups occur in order to confirm the validity of the schedule, the hours
assigned, and the amounts of Title IV disbursed for those meetings. If
the study groups did not meet as supposedly scheduled, then the
University would be disbursing Title IV funds on the basis of
instructional hours that it does not in fact provide.

Contrary to the University's assertion, we are not attempting to
establish a requirement to document every hour of student attendance. We
examined whether the study group meetings occurred in order to
corroborate compliance with the 12-Hour Rule. Evidence of attendance, if
it existed, would help support a conclusion that the study group
meetings were regularly scheduled and that the study group hours
supported the amount of Title IV aid disbursed. We reviewed the student
and faculty handbooks, and we held discussions with University officials
to obtain an understanding of the University's policies and procedures
as they related to its attendance policy. The University's own policy
was that study group attendance was to be monitored. University
officials could not provide us with evidence to show this was actually
done. In the absence of study group attendance reports or some other
effective control selected by the University, we have no basis to
conclude that the University adequately monitored study group meeting
occurrence or compliance with the 12-Hour Rule.

[University's Comments]{.underline}. **The 12-Hour Rule is widely
acknowledged to be unworkable and ill-suited for nontraditional
education programs.** The University stated that the underlying basis
for the 12-Hour Rule and its continued applicability to the Title IV
programs are presently in serious doubt. The HEA requires a minimum of
30 weeks of instructional time; however, the 12-hour per week
requirement was added by regulation and therefore does not have any
statutory basis. The appropriateness of the 12-Hour Rule, and the
immeasurable burden it has created for institutions, has recently come
under increased scrutiny. In addition, the Internet Equity and Education
Act of 2001, adopted by the House of Representatives Committee on
Education and the Workforce, effectively eliminates the 12-Hour Rule.

[OIG's Response]{.underline}. The University was required to comply with
the HEA and the regulations in effect during our audit period. The
12-Hour Rule was a regulatory complement to the statutory definition of
an academic year, and the University acknowledged it was required to
comply with it. As with any other regulation, the University must be
able to document that it is in compliance. Accordingly, the University
must be able to document that its academic year provided 360 hours of
instruction for full-time students.

[University's Comments]{.underline}. **The recommended liability is
based on an erroneous methodology and excludes significant amounts of
time that count toward compliance with the 12-Hour Rule.** The OIG fails
to consider instructional activity includable under the 12-Hour Rule
occurs outside of the classroom and study group meetings. Students'
grades are determined through traditional examinations, graded
individual presentations and papers, graded group projects, or a
combination thereof. No legal authority requires the time spent on these
activities to be monitored or measured under the 12-Hour Rule, but it
must be assumed that students spent additional time preparing for these
examinations and graded activities.

[OIG's Response]{.underline}. The University defined its academic year
as consisting of a minimum of four hours per week in classroom
workshops, and four hours per week in study group meetings. If
individual students spent additional time in preparation for
examinations or homework-type activities, it would not be relevant to
the University's compliance with the 12-Hour Rule. Students were
*required* to spend four hours per week in study *group* meetings. As
previously noted, the Department has stated that "\[i\]t was never
intended that homework should count as instructional time in determining
whether a program meets the definition of an academic year, since the
12-hour rule was designed to quantify the in-class component of an
academic program."

**BACKGROUND**

Founded by The Wesleyan Church in 1906, the University is a liberal arts
institution located in the town of Central, South Carolina. The
University also conducts classes in several other locations within the
State of South Carolina. The Southern Association of Colleges and
Schools (SACS) accredits the institution to offer associate, bachelor's,
and master's degrees. Undergraduate programs are offered in business and
in management. Graduate programs are offered in ministry and in
management. Prior to our audit period, the University founded the
Leadership Education for Adult Professionals (LEAP) program to meet the
needs of adult students. Effective in 1998-1999, it combined the LEAP
program with other programs to form the Adult and Graduate Studies
(Adult Studies) programs.

In March 1986, the University contracted with IPD, a subsidiary of the
Apollo Group, Inc., to help improve its Adult Studies programs. The
University contracted with IPD for marketing, recruiting, and accounting
support, while it provided the curriculum, facilities, and faculty.
During the audit period, the University and IPD shared tuition revenue,
but the University received 100 percent of book, material, computer, and
other miscellaneous fees.

During the period July 1, 1997, through June 30, 2000, the University
participated in the FFEL, Pell, FSEOG, and Perkins programs. The
University's records indicated that, during the period, the University
or lenders disbursed \$19,451,123 on behalf of students in the Adult
Studies programs. That amount specifically consisted of \$18,346,658 in
FFEL, \$1,079,565 in Pell, \$21,400 in FSEOG, and \$3,500 in Perkins.

Title IV of the HEA of 1965, as amended, authorizes these programs, and
they are governed by regulations contained in 34 C.F.R. Parts 676, 682,
and 690, respectively. In addition, these programs are subject to the
provisions contained in the Student Assistance General Provisions
regulations (34 C.F.R. Part 668), and the University must comply with
the Institutional Eligibility regulations (34 C.F.R. Part 600) to
participate in these programs. Regulatory citations in the report are to
the codifications revised as of July 1, 1997, 1998, and 1999.

# 

# OBJECTIVES, Scope, and Methodology

The objectives of the audit were to determine whether the University
complied with the HEA's prohibition against the use of incentive
payments for recruiting activities and with the HEA's required minimum
number of instructional hours. We specifically focused our review on the
University's contract with IPD, the programs of study related to that
contract, and the area of required hours of instruction in an academic
year under the 12-Hour Rule.

To accomplish our objectives, we reviewed the University's policies and
procedures, accounting and bank records, and student financial
assistance records. We reviewed the University's Program Participation
Agreement with the Department, its contract with IPD, and IPD's
compensation plans for its recruiters. In addition, we reviewed Single
Audit reports prepared by the University's Certified Public Accountants
and a program review report prepared by FSA. We also reviewed a report
issued by the University's accrediting agency.

We relied on computer-processed data that the University extracted from
its financial assistance database and on computer-processed data that
IPD extracted from its financial assistance database. We assessed the
reliability of the data by comparing University and IPD records for
total disbursements and also by comparing records from those two sources
for selected student disbursements. We concluded that the data provided
by the University was sufficiently reliable to use in meeting the
audit's objectives.

The audit covered the period July 1, 1997, through June 30, 2000. We
performed on-site fieldwork at the University's main location in
Central, South Carolina during the periods September 12-21, 2000, and
October 18, 2000. We held a field exit conference on October 18, 2000.
On December 4, 2001, we notified the University that we were assessing a
liability for the 12-Hour Rule finding. On December 20, 2001, we
requested additional information from the University. On January 18,
2002, the University informed us that the information was not available.
We issued a draft report to the University on April 18, 2002, and the
University responded to our report on June 17, 2002. We conducted the
audit in accordance with generally accepted government auditing
standards appropriate to the scope of audit described above.

**Methodology Used to Determine the Title IV Funds Improperly Disbursed
for Finding 2**

Students were required to meet in class for four hours per week, and
were expected to meet an additional four hours per week in study groups.
The University counted the study group time for purposes of the 12-Hour
Rule. Therefore, we reviewed the University's records to determine
whether the study groups met for the required number of hours. Each
cohort group (class) ranged in size from 16 to 22 students, and each
cohort group had about 4 to 5 study groups, each of which consisted of 3
to 5 students. At the time of our fieldwork, the University had 79 study
groups. We selected a sample of six classes (two from each of the three
years in our audit period), and then requested study group documentation
(attendance logs) for those classes. The documentation that we obtained
identified 81 courses for those six classes. At the time of our
fieldwork, 10 of the courses had not been completed. The students in the
remaining 71 courses should have met in a total of at least 1,520 study
group sessions. We reviewed a total of 180 study group meeting logs to
determine the amount of recorded study group attendance.

The University's academic year would need to be 90 weeks in length for
it to meet the 360-hour requirement for an academic year. Therefore, the
University could not (1) disburse Title IV funds to students during a
90-week academic period that exceeded the maximum annual amounts for an
academic year allowed under the FFEL and Pell programs and (2) disburse
FFEL funds to students who were enrolled less than half-time during a
90-week academic period.

[FFEL Disbursements in Excess of Annual Limits]{.underline}

We compared the disbursements to the applicable annual loan limit.
Students were not eligible to receive the amounts that exceeded the
limit. For the two groups described below, we estimated \$4,229,215 of
disbursements that exceeded the annual limits.

For the FFEL estimates, we analyzed disbursements for two separate
groups of students identified from the University-provided files. For
students in each group, we analyzed loan period start dates and the loan
disbursements covering a 90-week academic period.

The first group consisted of students who received disbursements for
**loans with loan start dates** in the period July 1, 1997, through June
30, 1998 **[and]{.underline}** disbursements for **loans with loan start
dates** in the period July 1, 1998, through June 30, 1999.

The second group, which excludes students included in the first group,
consisted of students who received disbursements for **loans with loan
start dates** in the period July 1, 1998, through June 30, 1999
**[and]{.underline}** disbursements for **loans with loan start dates**
in the period July 1, 1999, through June 30, 2000.

[Pell Disbursements in Excess of Annual Limits]{.underline}

We identified the Pell funds disbursed to students for our three-year
audit period (July 1, 1997, through June 30, 2000). To determine the
amount of Pell funds that a student may receive in a payment period,
institutions without standard terms multiply the maximum amount shown on
schedules published by the Secretary by a specified fraction. The
numerator of the fraction is the number of credit hours in a payment
period and the denominator is the number of credit hours in an academic
year. Because the University used the credit hours for a 45-week
academic year rather than a 90-week academic year as the denominator,
the Pell awards disbursed were double the amounts that should have been
disbursed. We estimated \$539,782 in Pell disbursements exceeded the
maximum amount allowed.

**Statement on Management Controls**

As part of our review, we gained an understanding of the University's
management control structure, as well as its policies, procedures, and
practices applicable to the scope of the audit. Our purpose was to
assess the level of control risk for determining the nature, extent, and
timing of our substantive tests. We assessed the subject of course
length as a significant control.

Due to inherent limitations, a study and evaluation made for the limited
purpose described above would not necessarily disclose all material
weaknesses in the management controls. However, our assessment disclosed
significant management control weaknesses that adversely affected the
University's ability to administer Title IV programs. Those weaknesses
included incentive-based payments for student enrollment that violated
the statutory prohibition against commissioned sales and inadequate
control over the amount of time spent in instruction that violated the
requirements of the HEA and the regulations. The Audit Results section
of this report fully discusses those weaknesses and their effects.

**ADMINISTRATIVE MATTERS**

If you have any additional comments or information that you believe may
have a bearing on the resolution of this audit, you should send them
directly to the following Department of Education official, who will
consider them before taking final action on the audit:

James Manning, Acting Chief Operating Officer

Federal Student Aid

Regional Office Building, 7^th^ and D Streets, S.W.

ROB Room 4004, Mail Stop 5132

Washington, DC 20202

Office of Management and Budget Circular A-50 directs Federal agencies
to expedite the resolution of audits by initiating timely action on the
findings and recommendations contained therein. Therefore, receipt of
your comments within 30 days would be greatly appreciated.

In accordance with the Freedom of Information Act (5 U.S.C.§552),
reports issued by the Office of Inspector General are available, if
requested, to members of the press and general public to the extent
information contained therein is not subject to exemptions in the Act.

If you have any questions or wish to discuss the contents of this
report, please call Sherri Demmel, Regional Inspector General for Audit,
Dallas, Texas at (214) 880-3031. Please refer to the control number in
all correspondence related to the report.

Sincerely,

Thomas A. Carter

Assistant Inspector General

for Audit Services

Enclosure

**REPORT DISTRIBUTION LIST**

######### CONTROL NO. ED-OIG/A06-A0024

+-----------------------+-----------------------+-----------------------+
| **[A                  | # [ED Action          |                       |
| uditee]{.underline}** | Official]{.underline} |                       |
+-----------------------+-----------------------+-----------------------+
| ##                    | #                     |                       |
+-----------------------+-----------------------+-----------------------+
| # Dr. David           | # Mr. James Manning   |                       |
| J. Spittal, President |                       |                       |
|                       | # Acting Ch           |                       |
| ## Souther            | ief Operating Officer |                       |
| n Wesleyan University |                       |                       |
|                       | ###                   |                       |
| # P. O. Box 1020      | # Federal Student Aid |                       |
|                       |                       |                       |
| Central, SC           |                       |                       |
| 29630-1020            |                       |                       |
+-----------------------+-----------------------+-----------------------+
| #                     | #                     |                       |
+-----------------------+-----------------------+-----------------------+
| # [Other ED Offi      |                       | #                     |
| cials/Staff]{.underli |                       |                       |
| ne} (electronic copy) |                       |                       |
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| ##                    | ##                    |                       |
+-----------------------+-----------------------+-----------------------+
| ##                    | ## Press Secretary    |                       |
| Audit Liaison Officer |                       |                       |
|                       | ## Off                |                       |
| ## Cas                | ice of Public Affairs |                       |
| e Management Division |                       |                       |
|                       |                       |                       |
| #                     |                       |                       |
| # Federal Student Aid |                       |                       |
+-----------------------+-----------------------+-----------------------+
| ##                    | ##                    |                       |
+-----------------------+-----------------------+-----------------------+
| ## C                  | ## Assi               |                       |
| orrespondence Control | stant General Counsel |                       |
|                       |                       |                       |
| ## Offi               | ## Office o           |                       |
| ce of General Counsel | f the General Counsel |                       |
+-----------------------+-----------------------+-----------------------+
| #                     |                       |                       |
+-----------------------+-----------------------+-----------------------+
| #                     | ## Deputy Secretary   |                       |
| # Assistant Secretary |                       |                       |
|                       | ## Office of          |                       |
| ## Offic              |  the Deputy Secretary |                       |
| e of Legislation and  |                       |                       |
|                       |                       |                       |
| ##                    |                       |                       |
| Congressional Affairs |                       |                       |
+-----------------------+-----------------------+-----------------------+
| #                     |                       |                       |
+-----------------------+-----------------------+-----------------------+
| #                     | ## Chief of Staff     |                       |
| # Assistant Secretary |                       |                       |
|                       | ## Of                 |                       |
| ## Office             | fice of the Secretary |                       |
| of Intergovernmental  |                       |                       |
|                       |                       |                       |
| ## an                 |                       |                       |
| d Interagency Affairs |                       |                       |
+-----------------------+-----------------------+-----------------------+
| #######               | #                     |                       |
+-----------------------+-----------------------+-----------------------+
| ## Director           | ## Under Secretary    |                       |
|                       |                       |                       |
| ## Finan              | ## Office o           |                       |
| cial Improvement and  | f the Under Secretary |                       |
|                       |                       |                       |
| ##                    |                       |                       |
| Post Audit Operations |                       |                       |
|                       |                       |                       |
| ## Office of the Ch   |                       |                       |
| ief Financial Officer |                       |                       |
+-----------------------+-----------------------+-----------------------+
|                       | #                     |                       |
+-----------------------+-----------------------+-----------------------+
| ## Post A             | ## Director           |                       |
| udit Group Supervisor |                       |                       |
|                       | ## Off                |                       |
| ## Finan              | ice of Public Affairs |                       |
| cial Improvement and  |                       |                       |
|                       |                       |                       |
| ##                    |                       |                       |
| Post Audit Operations |                       |                       |
|                       |                       |                       |
| ## Office of the Ch   |                       |                       |
| ief Financial Officer |                       |                       |
+-----------------------+-----------------------+-----------------------+
|                       | #                     |                       |
+-----------------------+-----------------------+-----------------------+
| ## Indirect           | ##                    |                       |
| Cost Group Supervisor |                       |                       |
|                       |                       |                       |
| ## Fina               |                       |                       |
| ncial Improvement and |                       |                       |
|                       |                       |                       |
| ##                    |                       |                       |
| Post Audit Operations |                       |                       |
|                       |                       |                       |
| ## Office of the Ch   |                       |                       |
| ief Financial Officer |                       |                       |
+-----------------------+-----------------------+-----------------------+
|                       | #                     |                       |
+-----------------------+-----------------------+-----------------------+
| # [Others]{.underli   |                       |                       |
| ne} (electronic copy) |                       |                       |
|                       |                       |                       |
| Southern Association  |                       |                       |
| of Colleges and       |                       |                       |
| Schools               |                       |                       |
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|                       | #                     |                       |
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