William E.

Scheu

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August 7,2012

REPORT TO THE BOARD OF TRUSTEES OF FLORIDA STATE COLLEGE AT JACKSONVILLE ABOUT INSTITUTIONAL ISSUES RAISED BY THE FINDINGS OF THE AUDITOR GENERAL CONCERNING PELL GRANT APPEALS

On January 12, 2012, David Martin, the Auditor General of the State of Florida (the "Auditor General"), acting on behalf of the U.S. Department of Education ("DOE"), delivered to Dr. Steven R. Wallace, President of Florida State College at Jacksonville ("FSCJ" or the "College"), his preliminary and tentative findings and recommendations (the "Audit Report"), concerning processes and decisions made by FSCJ about financial aid for the academic year 2010-11, specifically those concerning the award of Pell Grants and student appeals of grant eligibility denials. On February 7, 2012, President Wallace and Steven Bowers, FSCJ Vice President for Administrative Services, discussed the Audit Report with FSCJ Trustees ("Trustees"), at a noticed "Post Board Meeting". In March, 2012, FSCJ Director of Financial Aid Michelle Bowles, filed with the Auditor General the College's response to the Audit Report and estimated a corrective action date of June 30, 2012. That date was subsequently extended to September 15, 2012. The FSCJ Board considered the implications of the Audit Report at its meetings on April 3, May 1, and June 5, 2012. On June 5, 2012, FSCJ announced the engagement of William E. Scheu to examine the institutional practices of the College related to the findings contained in the Audit Report. Mr. Scheu was not engaged to review particular Pell Grant awards and appeals, but to examine institutional history and practices, and to make recommendations for the future. At the June 5, 2012, FSCJ Board meeting, Mr. Bowers announced that DOE had extended its review of the FSCJ Pell Grant program to the 2011-12 academic year, but the College did not include the 2011-12 year in the scope of Mr. Scheu's work. Background Information The Federal Pell Grant program provides needs-based grants to low income undergraduate students. There are also limited circumstances (such as teacher certification programs) in which post-graduate students may be awarded Pell Grants. As implied by the name, a Pell Grant is a grant, not a loan, and does not have to be repaid by the student recipient. For the 2010-11 academic year, the maximum Pell Grant award was $5,550.00.

August 7, 2012 Page 2 A student seeking a Pell Grant files an application for student aid ("Free Application for Student Aid", or "FAFSA") with DOE, which considers the eligibility of the student under federal law. 34 C.F.R. §668.32 sets forth the regulatory requirements for student eligibility, which include among other "non-economic" standards, whether a student satisfies certain citizenship and residency requirements, whether the student satisfies Selective Service registration requirements, whether the student has a correct social security number, whether the student is enrolled in an eligible institution, whether the student is incarcerated, and whether the student has a baccalaureate or first professional degree. In addition to the "non-economic" standards, DOE evaluates the FAFSA pursuant to an "economic" eligibility formula, the fundamental elements of which are the student's income (and assets if the student is independent), the student's parents' income and assets (if the student is dependent), the family's household size, and the number of family members (excluding parents) who are attending postsecondary institutions. The application is not filed under oath, but there are warnings about perjury if the information furnished by the student is found to be intentionally untrue. When the DOE completes its evaluation of the FAFSA, it electronically sends to FSCJ an Institutional Student Information Record ("ISIR") , in which the DOE advises the institution as to whether the student is eligible, based on the information submitted by the student. A Student Aid Report ("SAR") is simultaneously furnished electronically to the student so that the student can keep track of his/her status. In addition, DOE requires FSCJ to verify 30% of the ISIRlFAFSA's, selected randomly by DOE, and any other ISIRlFAFSA's which are otherwise flagged by DOE. On occasion DOE has required FSCJ to verify up to 50% of the ISIRlFAFSA's sent to it. FSCJ's Office of Financial Aid handles the verifications, and a student keeps track of his or her status using "Connections", which is a College electronic communication system. DOE's verification notification may include verification of some or all of both "economic" and "non-economic" eligibility requirements. The verification task often requires FSC] staff to evaluate tax returns and other complex information that has been furnished by the student. DOE refuses to do the verifications itself and imposes that burden on FSCJ and other educational institutions that use federal student financial aid programs. It is a very staff-intensive effort. At FSCJ, there are only four Financial Aid Processors and a supervising Financial Aid Program Coordinator involved in verifications, which include not only Pel1 Grant awards, but other types of federal financial aid. While the verification process is proceeding, or, if no verification is required, upon the student being deemed "qualified" by DOE in the ISIR, a determination is made under the supervision of the College's Office of Financial Aid as to whether the student is making "satisfactory academic progress" for retention of financial aid. This determination is made pursuant to policies established by FSCJ pursuant to applicable federal regulations. Under the federal regulations in effect for the 2010-11 academic year (34 C.F.R. §§668.16(e), 668.32 and 668.34), which were revised beginning with the 2011-12 academic year (and not discussed herein), an institution's policy for determining "satisfactory academic progress" for financial aid must be acceptable to DOE. A policy will be considered acceptable if, among other things not pertinent to this Report, the policy contains both qualitative and quantitative standards.

August 7,2012 Page 3 The qualitative standard is that a student must maintain a 2.0 cumulative grade point average if a 4.0 grading system is used, which is the case at FSCl The quantitative standard is two-fold. First, the student must have completed at least 67% of the classes the student started, on a cumulative basis (the "67% Rule"). This is to avoid the situation where a student seemingly may be maintaining a 2.0 grade point average, but only by dropping courses in which he or she is doing poorly. Second, a student must finish his or her program of study within a maximum time frame, which is 150% of the published length of the academic program of study (the "150% Rule"). For example, if the published length of an academic program is 120 credit hours, the maximum period in that program for which the student is eligible for a Pell Grant is 180 hours (120 x 1.50). At FSCJ there are two types of "satisfactory academic progress". The first is an academic determination "to clearly communicate the College's minimum expectations of academic progress", which is the standard by which the College determines a student's satisfaction of the College's "Standards of Academic Progress", which is identified as "SOAP". The SOAP policy warns, "Please note that these standards are not the same as those applicable to financial aid." The second type of "satisfactory academic progress" is a determination made by the College's Office of Financial Aid for financial aid eligibility, which is known as "SAP". The process of determining SAP is known as being "SAPPED". It is the "SAP" determination with which this Report is concerned, not the "SOAP". The SOAP vs. SAP distinction is unfortunate in that these are slightly different standards and there may be confusion in the minds of students as to which applies to financial aid. During the 2010-11 academic year and previous years, FSCJ evaluated SAP on an annual basis. When federal regulations changed in late 2010, to be effective July 1, 2011, the College changed its SAP evaluation schedule to require SAP evaluations each academic term rather than annually, effective for the academic year beginning July 1,2011. Even if the verification of information on the ISIRIF AFSA is positive and a student is deemed to have satisfied the basic eligibility thresholds, the student is not cleared for financial aid until the student passes SAP If the SAP determination results in a finding that a student is not making satisfactory academic progress, the student has a right to appeal under 34 C.F.R. §668.16 (e)(5), which, as it existed in 2010-11, required that an institution must provide specific procedures under which a student may appeal the negative SAP determination. The 2010-11 regulations are confusing as to the right of appeal for the quantitative standard (See 34 C.F.R. §668.34(c), which seems to limit appeals to the qualitative standard.) Under that regulation, on an appeal, the institution may find that the student is making satisfactory academic progress only if the student failed to attain the cumulative grade point requirement because of: (1) the death of the relative of the student, (2) an injury or illness of the student, or (3) other special circumstances. However, in practice and in the explanatory materials published by DOE, a student's right to appeal has been recognized for failure to satisfy either the qualitative (grade point average) or quantitative standards (67% Rule and 150% Rule).

August 7,2012 Page 4 The FSCJ 2010-2011 Catalog described the appeal process adopted by FSCJ as follows: Students whose aid is cancelled may appeal this decision only if there are extenuating circumstances (medical or personal problems). To appeal, the student must complete and return the appeal form to the home campus enrollment/financial aid office. All supporting documentation must be attached or the appeal form will not be accepted. After reviewing the written appeal and all documentation, the campus dean will notify the student in Connections (students will be required to log on to their student accounts in Connections for notification). All aid remains cancelled until the student receives notification the appeal was approved for the next period of enrollment. The dean reserves the right to limit the student's enrollment to less than full-time. (Emphasis added) That process was established as policy by the FSCJ Board on April 26, 2005, as Administrative Procedure Manual ("APM") Policy Number 10-0606, Rule 6Hx7 -10.6. In the section entitled "Appeals", the policy provided: Students who lose their financial aid may appeal if extenuating circumstances caused the loss of aid. To appeal, the student must complete and return the appeal fonn to the home campus Enrollment Services/Financial Aid Office. The appeal form must be submitted with all supporting documentation attached. Incomplete appeals will not be accepted After reviewing the written appeal and all documentation, the Campus Dean of Student Success will notify the student in writing. All aid will remain cancelled until the student receives written notification that the appeal was approved for the next period of enrollment. The Dean reserves the right to limit the student's enrollment to less than full time. (Emphasis added) Surprisingly, the minutes of a FSCJ Financial Aid Strategies meeting held on January 10, 2011, state, "While discussing SAP, Mr. Bowers informed the committee that there is no APM for SAP but there should be." Moreover, Michele Bowles, the Director of Financial Aid, recalls that at that time she, too, was unaware of the existence of the 2005 APM. She advised that a College policy manual is ordinarily used by College officials, but she conceded that the manual is difficult to access and, once accessed, difficult to find specific policies. Mr. Bowers, on the other hand, felt that his reference to there being no APM referred to any APM dealing with procedures, not appeal standards. He was aware of the 2005 APM, and felt that the minutes of the January 10, meeting were inaccurate. Nevertheless, the uncertainty as late as January, 2011, as to whether there was a SAP APM reflects confusion about the appeal process among senior administrative leaders, much less the persons on the campus level who were responsible for implementing that policy. Mrs. Bowles also indicated that the Administrative Procedure

August 7,2012 Page 5 Manual, in which the APM's are lodged, is not particularly accessible or useful, even for policies unrelated to fmancial aid. The January, 2011, Financial Aid Strategies Committee meeting was one of several committee meetings dealing with student debt and financial aid procedures following the employment of Michele Bowles as Director of Financial Aid. In a May, 2012, Executive Sunnnary he prepared for President Wallace, Vice President Bowers indicated that Mrs. Bowles began her work in early 2010, and that she quickly realized that there were problems in the College's financial aid program, including high student debt and "weak procedures for student loans and approval of Satisfactory Academic Progress appeals". According to Mr. Bowers, her suggestions for changes "was the first indication we had a problem with staff approval of financial aid appeals." Mr. Bowers did acknowledge prior awareness among senior administrators that there were problems in both student loan policies and SAP procedures, and for that reason the job description for the position of Director of Financial Aid was strengthened, including giving the position more authority. Mrs. Bowles was employed pursuant to the new job description. During the last quarter of the 2009-10 academic year (winter-spring 2010), Mrs. Bowles began working diligently to change the policies. She held a meeting on June 29, 2010, in which loan issues and SAP appeal procedures were discussed. It is unclear who was present at that meeting, but a listing of "required attendees" included all of the Deans of Student Success. During the beginning of the 2010-11 academic year, Mr. Bowers and Mrs. Bowles became convinced that a senior level committee would be necessary to deal with student debt and financial aid issues, including the College's policies for both student loans and SAP. A Financial Aid Strategies Committee was created and its first meeting was held on October 4, 2010. It is not clear from a summary of the meeting who the attendees were. According to that summary, subjects discussed included the impact of increased volume on the financial aid office, verification procedures, loan volume, communications, and, near the end of the meeting, the SAP appeal process. The summary reflects that committee agreed that "the SAP appeal procedures need to be more strictly enforced," and that students "should only be approved if they meet extenuating circumstances". It was decided that a more in-depth discussion should take place at the next meeting of the committee. The committee held its next meeting on October 11, 2010. According to the minutes, attendees were Steven Bowers, Dr. Tracey Pierce, Sherry David, Michele Bowles, Bill Davis, Audrey Jackson, Katie Meyer-Griffith, Dr. Denis Wright and RJ. Hausman. The meeting minutes reflect that in the SAP appeal discussion, there was consensus that the policy was too flexible and needed to be strengthened, that there was no consistency between campuses, and that the SAP appeal procedures needed to be revised. Mr. Bowers observed that statistics revealed a 75% appeal approval rate, which was, in his opinion, too high. The committee also discussed running SAP more than once a year and the centralization of SAP appeals, and then decided that these suggestions needed further discussion. At its next meeting, on October 18, 2010, the committee decided that due to volumes and limited resources, SAP appeals would continue to be handled by the campuses and not

August 7, 2012 Page 6 centralized. The committee also tabled the proposal to permit appeals more than once a year until expected new DOE regulations were released. The committee discussed imaging issues, student loans, the phone tree and SAP. Automation of the SAP process was also discussed. Revised SAP guidelines, which included a definition of "extenuating circumstances", were circulated for consideration. The committee felt that the guidelines should be accepted as written, but did not approve their implementation at that time. According to the minutes, attendees were Steve Bowers, Dr. Tracey Pierce, Sherry David, Michele Bowles, Bill Davis, Audrey Jackson, Katie Myers-Griffith, Dr. Denis Wright, Melanie Clark, Dr. Peter Biegel, Amy Perkins and BJ. Hausman. The committee held its next meeting on November 1, 2010. According to the minutes, attendees were Steven Bowers, Dr. Tracey Pierce, Sherry David, Michele Bowles, Audrey Jackson, Katie Meyer-Griffith, Dr. Denis Wright, Melanie Clark, Dr. Peter Biegel, Amy Perkins and BJ. Hausman. The committee reconsidered the guidelines as they applied to the 150% Rule. BJ. Hausman indicated that North Campus staff felt that the proposed guidelines (modification of the 150% Rule only for extenuating circumstances) would penalize students at North Campus who were entering the nursing program because of their need to take prerequisite courses prior to entering the nursing curriculum. It was agreed that Mrs. Hausman would bring case studies to the next meeting. Mrs. Bowles was tasked with bringing revised SAP guidelines, as they enunciated the 150% Rule. Differences in SAP and SOAP calculations were also discussed, as were imaging issues and the prospect of increasing the amount of courses for students to teach them more about financial aid. The committee held its next meeting on November 8, 2010, at which it continued its discussion of the 150% Rule. The minutes state, "Committee members also questioned whether advisors are familiar enough with financial aid regulations to properly advise students on decisions that may impact their eligibility for financial aid." Questions were also posed about the College's policy regarding students returning to school after an absence of five years or more. Mrs. Bowles discussed the new federal regulations that would go into effect on July 1, 2011, permitting SAP more than once a year, and allowing probationary periods. The minutes state that attendees were Steven Bowers, Dr. Tracy Pierce, Sherry David, Michele Bowles, Bill Davis, Audrey Jackson, Katie Meyer-Griffith, Dr. Denis Wright, Dr. Peter Biegel, Amy Perkins and RJ. Hausman. The committee's next meeting was November 15,2010. The only SAP issues discussed were those concerning imaging and the mechanics for the initial filing of appeals. The discussion centered on students dropping off appeal forms and documents rather than waiting in line for them to be checked in, and students being counseled or advised regarding any of their concerns or complaints. Attendees at the meeting were Peter Biegel, Steven Bowers, Dr. Tracey Pierce, Sherry David, Michele Bowles, Bill Davis, Audrey Jackson, Kate Meyer-Griffith, Dr. Denis Wright and RJ. Hausman. The committee next met on January 10, 2011. Attendees were Steve Bowers, Michele Bowles, Dr. Peter Biegel, Melanie Clark, Audrey Jackson, Amy Perkins and Dr. Tracy Pierce. Among the matters discussed were recent regulatory changes for year round Pell eligibility requirements, student debt and SAP. This was the meeting at which Mr. Bowers indicated that

August 7, 2012 Page 7 there was no APM for SAP. Mrs. Bowles was asked to work on an APM and bring it to the next meeting. The SAP appeal process for students not enrolled for five years or more was also discussed, and it was agreed that the procedures would be updated to clarify what documentation would be required in such cases. The committee also discussed other documentation issues. The next meeting of the committee was held on January 24, 2011, at which a draft SAP APM and a draft SAP Appeal APM were considered, along with other issues related to SAP. The committee approved the SAP APM as proposed, but decided to have Mrs. Bowles further revise the proposed SAP Appeal APM and resubmit it to the committee. These APM's were intended to apply to the 2011-12 academic year, under the new federal regulations, not to the 2010-11 academic year. Attendees at this meeting were Dr. Peter Biegel, Steve Bowers, Michele Bowles, Audrey Jackson, Amy Perkins, Dr. Tracey Pierce, Sherry David and Bill Davis. At its next meeting, held on January 31, 2011, the revised SAP Appeal APM was approved by the committee, and there were comments about automating appeals, limitation of hours, codes for the "Financier" and "Connections" computer programs. It was also suggested that the proposed APM be sent to the College's legal advisors for review. The revision of SAP failure notices were also discussed. Again, it should be noted that the APM was intended for use in the next academic year. Attendees at the January 3 I, meeting were Steve Bowers, Michele Bowles, Audrey Jackson, Amy Perkins, Dr. Tracy Pierce, Sherry David, Dr. Denis Wright, Katie Meyer-Griffith, Melanie Clark and Bill Davis. The final meeting of the committee was held on February 14, 2011. Attendees were Dr. Peter Biegel, Dr. Tracey Pierce, Katie Meyer-Griffith, Melanie Clark, Dr. Denis Wright, Bill Davis, B.J. Hausman, Audrey Jackson and Amy Perkins. At that meeting the final SAP Appeal APM was distributed, and the committee felt that it should be tied to a FSCJ Board of Trustees rule. Other subjects were discussed, including the issue of scanning/imaging of documents by students. While another meeting of the committee was scheduled, it is believed that the February 14 meeting was its last. It is interesting that an Executive Summary of the new DOE regulations that were to become effective July 1, 2011, which was distributed at the meeting, intimated that there were problems nationwide with the integrity of the Pell Grant program and reasons to change the regulations to assure proper use of taxpayer funds: The rapid growth of enrollment, debt load, and student default rates of postsecondary institutions in recent years prompted the US Department of Education (ED) to embark on an I8-month negotiation with the higher education community to develop new regulations. During the negotiations, ED worked with stakeholders to develop a set of proposals with a goal of strengthening the integrity of the federal student aid program and ensuring that taxpayer funds are used appropriately. On March 9-10, President Wallace and the College cabinet met for a retreat, and a major topic was the discussion and approval of both the SAP and SAP Appeal APM's. On April 5, 2011, the FSCJ Board adopted the new SAP and SAP appeal policies, (APM 10-0606, amending Rule 6Hx7-10.6), which had been slightly revised from those approved by the Financial Aid

August 7, 2012 Page 8 Strategies Committee, and in some respects consolidated, before being presented to and approved by the Board. The new policies were significantly strengthened. Thereafter SAP appeals were to be handled on a semester by semester basis, not annually, which would permit the College to include a probationary period in the appeal process. The new policies were to apply to the 2011-12 year, not the 2010-11 year. The work of the Financial Aid Strategies Committee shows that senior FSCJ administrative leaders, notably Vice President for Administrative Services Steven Bowers and Director of Financial Aid Michele Bowles, and the Deans, had identified problems in the financial aid area and were trying to solve those problems in an orderly fashion. They should be given credit for these efforts, all of which occurred in the late fall and early winter of 20 10-11, a year prior to the College's receipt of the Audit Report in January, 2012. However, those efforts were future-oriented and did not change the culture or reduce the confusion concerning SAP standards for appeals in the 2010-11 academic year. It should also be noted that FSCJ was not alone in its application of the requirements of the Pell Grant program. On December 14, 2010, a newspaper published an article describing Pell Grant "blunders" by State College of Florida, in Bradenton. That college was required to return substantial Pell Grant dollars to DOE because of its poor appeal procedures. By the time of the publication of the article, FSCJ administrators were already engaged in identifying and correcting problems in the College's administration of the Pell Grant program, but, according to an email timeline summary prepared by Mr. Bowers for the FSCJ Trustees, the article was an alert to Mr. Bowers and other FSCJ administrators of the possible scale of the problem that FSCJ might be facing. The Pell Grant program itself has been criticized by The Wall Street Journal, which opined on June 18,2012, in an editorial entitled, "Pell Grants Flunk Out", that "the federal Pell Grant program is starting to look like a runaway train". All this is to say that while it has encouraged a large increase in the national student census, the Pell Grant program is very complex, difficult to administer, and, in many respects, out of control. Media outlets and others who are not intimately familiar with and proficient in the complexities of the Pell Grant program should be slow to cast stones at those charged with administering it. Background Organizational Description FSCJ is a diverse and multifaceted organization. Much of the operation of the College is devolved to individual campuses, although there are centralized administrative services such as human resources, technology, governmental relations and legal resources. FSCJ operates four separate campuses, an "Open Campus" and five centers. Each campus has a President and, among other deans, a Dean of Student Success. Deerwood Center, with approximately 10,000 students, is not technically a "campus", but it has an executive director. Presidents have wide authority for the operation of their campuses, but usually are not involved in financial aid decisions or appeals. The Office of Department, headed by Michele Bowles, began served in that capacity Financial Aid is lodged under the central Administrative Services Vice President Steven Bowers. The current Director of Financial Aid, her work at FSCJ in early 2010. The prior Director, Joel Friedman, had for many years. As noted above, and as will be seen, Mrs. Bowles,

August 7, 2012 Page 9 shortly after her arrival, noted several weaknesses in the financial aid system at the College, but implementation of her recommended changes was delayed until the 2011-12 academic year because of the necessary process of reviewing new federal regulatory requirements and developing a consensus for change. Most of the work concerning SAP appeals was done at the campus level under the supervision of the Deans of Student Success. In 2010-11, the Deans (and in the case of Deerwood Center, the Executive Director) were charged with overseeing fmanciaI aid appeals even though their overall responsibilities included 29 other significant areas of responsibility. While the Director of Financial Aid had what amounted to advisory authority, she had no "chain of command" authority which would leave her as the ultimate decision maker. This decentralized system had been in place for many years prior to the employment of Mrs. Bowles as Director of Financial Aid. The prior director, Joel Friedman, was instrumental in establishing and implementing the procedures that formed the culture for processing the financial aid appeals that were the subject of the Audit Report. The SAP appeal failures were a direct result of the lax SAP culture inspired by Mr. Friedman. Financial aid appeals were a minimal part of the duties of the Deans and the Deerwood Center Executive Director. The summary of the 29 specific duties in the Dean of Student Success position description described the areas of responsibility as: faculty and staff supervision, evaluation, planning, and leading initiatives; budgeting; problem solving for faculty and students; registration and related student services. Supervises and manages specified programs and services. Employees in this position are responsible for the campus coordination student (g£) activities or programs. The Deans were part of a culture of "what can we do to keep the student enrolled?", rather than determining whether the student was complying with federal student financial aid requirements. The College administration has begun to change that culture through its efforts to change SAP and SAP appeal policies for 2011-12 and subsequent years, and through its withdrawal of SAP appeal approval authority from North, Kent and South campuses, and Deerwood Center. SAP appeals from students enrolled at those campuses are now handled by the Director of Financial Aid. Only the Deans of Student Success for the Downtown Campus and the Open Campus retain SAP appeal approval authority. The specific organization of each campus, insofar as financial aid is concerned, is as follows: North Campus President Dean of Student Success Campus Enrollment Leader Student Success Advisor

Barbara Darby BJ. Hausman Terence Wright Sharon Hoose

August 7, 2012 Page 10 South Campus President Dean of Student Success Campus Enrollment Leader Deerwood Center Executive Director Deerwood Associate Dean of Student Success *did not become Associate Dean until Spring, 2012, but participated in the meetings of the Financial Aid Strategies Committee in Fall 2010-11 Deerwood Enrollment Services Coordinator Kent Campus President Dean of Student Success Campus Enrollment Leader Student Success Advisor Downtown Campus President "did not arrive until January, 2011 Dean of Student Success "Melanie Clark served as Interim Dean part of 20 I 0-11 year Mrs. Perkins arrived as Dean mid-2010-1I Campus Enrollment Leader Advisor III Open Campus President Associate Dean of Student Success

Denis Wright Billy Davis Jennifer Doster Patty Adeeb Audrey Jackson"

Gloria Graham

Maggie Cabral-Maly Sherry David Pamela Walker Jacquelyn Bostick

Christal Albrecht* Amy Perkins*

Curlene Wims Sara Friedman

Jana Kooi Melanie Clark

FCSJ ordinarily processed SAP appeals during the months of June, Ju1y and August of each year. As stated above, appeals were neither filed nor reviewed centrally, but rather processed by each separate campus and at Deerwood Center. There was no central coordination or control of the appeal process, and the Deans and other reviewers at each campus were directed to use their "professional judgment" in making decisions about the appeals. The appeal procedure was that a student would file an appeal at the campus at which the student was enrolled. In the appeal form the student would articulate what the reasons were for his or her failure to make SAP. While the catalog and the policy required supporting documentation to be attached, sometimes it was, but sometimes not. A Student Success Advisor or other advisor would help the student fill out the form. The form would then be reviewed by a Campus Enrollment Leader or Enrollment Services Coordinator, who would make a

August 7,2012 Page 11 recommendation to the Dean of Student Success at that campus (or to the Executive Director, in the case of Deerwood Center), who would review the form and the recommendation, and then make a decision as to whether to overrule the initial SAP determination. The campus Presidents had little if any involvement in the SAP appeal process. All of the Deans of Student Success were interviewed and to a person indicated that historically, not just in the 2010-11 year, there was little central oversight or coordination, very little, if any, effective training, and serious technological deficiencies. The Deans indicated that in using their "professional judgment", the Deans and their Enrollment Services Coordinators relied on practices which were common among the campuses. Those common practices included: a. circumstances ("POS"), and considered for Students with no documented extenuating could take 4 hours in their program of study demonstrate success, and their appeals would be positive action.

b. If a student is performing well academically and can graduate within 2 terms, the appeal could be approved. c. It is acceptable to approve appeals involving the "150% Rule" up to 200% at the campus level. Those appeals exceeding 200% required the approval of both the Dean of Student Success and the Director of Financial Aid. d. If a student returned to school after 5-10 years absence, an appeal could be approved for one semester without any documentation (note the "approval" language, implying that the grant is being "approved" not that an appeal is being taken and sustained. These common practices utilized by the Deans and others in the appeal process bear little relationship to the actual policies that had been adopted by the Board in 2005. Better training would have insured that the correct policies were being implemented and applied consistently throughout the College. . Vice President Bowers believes that those in senior positions had a responsibility to make sure that they knew about and implemented the correct policies. He also feels that the Deans or their designees participated in the analysis of the financial aid issues facing FSCJ begirming with Mrs. Bowles' June 29, 2010, meeting and continuing with the Financial Aid Strategies Committee meetings in fall and winter, 2010-11. He believes that those meetings were equivalent to trainings and should have focused the attention of the Deans on the need for stricter SAP appeal review procedures. On the other hand, the College's Vice President for Human Resources observed that the Financial Aid Strategies Committee meetings were not "trainings". She did consider them to have been valuable professional development for those involved.

August 7,2012 Page 12 It is important to note that three of the participants in the Financial Aid Strategies Committee meetings were staff persons involved with marketing or enrollment, not financial aid. Dr. Tracey Pierce was Vice President for Student Development & Community Education; Katie Meyer-Griffith was responsible for the Welcome Center; and Dr. Peter Biegel was the College's Registrar and dealt with admissions. One participant, Dr. Denis Wright, was a campus President and was not involved in SAP or SAP appeals. The Deans of Student Success did not attend all the meetings, and the Executive Director of Deerwood Center, Patty Adeeb, did not participate. The financial aid policies discussed by the Financial Aid Strategies Committee and the recommendations it made, were intended to be implemented in the 2011-12 year. The committee was not focused on correcting or establishing new policies or procedures for the then-current 2010-11 year, about which there continued to be a great deal of confusion. Also, there were organizational tensions between the central financial aid office and the campuses, The attempts by the Director of Financial Aid to assert more authority in the appeal process conflicted with the desire of the Deans of Student Success to retain control. An example of this is the disapproval of the proposal for centralization of the SAP appeal process at the committee's October 11,2010, meeting. In an interview, Vice President Bowers observed that confusion in organizational design was a "fundamental flaw" in the financial aid process. Conclusions and Recommendations With the foregoing background in mind, the following conclusions and recommendations are submitted: 1. History and Culture. For the last decade, if not longer, the implementation of the SAP appeal process has been organized on a decentralized basis. The previous Director of Financial Aid, Joel Friedman, structured a campus-centered process. The appeal process was the responsibility of the Dean of Student Success at each campus. All of the Deans and Presidents interviewed explained that it was a truly laissez faire process, in large part left up to the Deans to handle as best they could. No Dean could remember any training program about appeals, financial aid standards or federal regulations, going back to 2001, which is consistent with the recollection of My. Bowers that there was no training going back to 1998 (although there apparently was a training on June 18, 2007). The first formal training program of any note that dealt with SAP appeals probably occurred in June, 2010, and the appeal process was only a portion of the meeting agenda. The Deans believed that their instructions were to use their "best professional judgment" in considering SAP appeals. The only SAP training program cited by the Deans as being effective and "high quality" was a training event held in March, 2012, after the Audit Report had been issued. Even then, the Deans were critical that some persons who were involved in appeals were not invited to that training, and that there was little follow-up or testing done to assure that attendees actually understood what they were supposed to have learned at the training. The job description for the position of Dean of Student Success has 29 general areas of responsibility assigned to the position, and financial aid is only a minor task. The Deans are responsible for the overall success of students: encouraging them, disciplining them and advocating for them. The Deans' psyche, even "call" (in vocational or theological terms) is to

August 7,2012 Page 13 help students stay in school, not hold them accountable for compliance with federal regulations. It is problematic that the ones charged with enforcing compliance are the very ones who are supposed to do their very best to keep students in school. One is reminded of the recent incentive monitoring analysis completed by a Mayoral Task Force to evaluate how the Jacksonville Economic Development Commission tracked and monitored its economic development incentive grants. Instead of having an "underwriting" person responsible for monitoring grant compliance, the "sales" people were put in charge of monitoring. Consequently there was little monitoring and little knowledge of whether grantees were complying with the conditions ofthe economic development incentives. In the same way, at FSCJ, the "sales" people (the Deans) were put in charge of enforcing the financial aid regulations. Not only did they have little knowledge about the actual standards and policies (other than "common practices"), they were encouraged to keep students in school, not cause them to depart. As one Dean put it, "We were so generous handing out candy from our candy store; now they have a lot of cavities." Candy indeed .... Such a system did not and could not work. When that was coupled with little training or central administrative oversight, and poor communications, a system and culture resulted which made the appeal process an individual decision process, not one that was consistent throughout the institution. Recommendation 1: The financial aid culture and mindset at FSCJ should be changed so that both staff persons and students can appreciate that financial aid is not an entitlement, but an act of generosity, for which students are accountable. This change starts with the Board, which must consider and adopt policies that establish strict standards for grant eligibility. Those policies must be written in understandable, clear language, and contain procedures that can be easily implemented and fully communicated to staff and students in direct ways. The policies must be reinforced through serious training, training exercises, and follow-up. A direct line of authority should be articulated. While some of the previous policies have changed, the current ones are somewhat ponderous and still difficult to understand. The Board should revisit the SAP and SAP appeal policies it adopted in April, 2011, to make sure they are clear and easily understood. Appropriate staff and students should be included in the reconsideration of the policies. 2. Organization and Accountability. The FSCJ organizational structure for handling financial aid appeals is scattered to the various campuses. While it is true that the Director of Financial Aid is responsible for the process, in actuality she effectively had only an advisory or training role in the 2010-11 appeal process. Campus Deans of Student Success are responsible for financial aid decisions affecting students at their respective campuses. Yet because of their larger responsibilities, limited knowledge, historically, of the rules, and little training of the persons involved in the SAP appeal decision-making process, there has not been a clear and uniform practice throughout the College. Deans of Student Success have many other responsibilities and should not be responsible for financial aid compliance. It is unfortunate that the Financial Strategies Committee, at its meeting on October 11, 2010, decided that SAP appeals would continue to be handled on a decentralized basis at individual campuses. Recommendation 2. The financial aid appeal process should be removed from individual campuses and centralized under the direct supervision of the Director of Financial Aid, who

August 7, 2012 Page 14 should be accountable for its proper implementation. Additional staff should be employed for this purpose. All Deans of Student Success, all campus Presidents, the Director of Financial Aid and the Vice President for Administrative Services unanimously agree with this recommendation for decentralization. It should be noted that the responsibility for SAP appeals has temporarily been removed from North, South and Kent campuses, and from Deerwood Center. This should be made permanent and extended to all other campuses. 3. Appeal Process. SAP appeals have been treated as applications, not appeals. An appeal of a negative financial aid determination is just that: an appeal. It is not a de novo application. Consequently, the burden of sustaining an appeal should be placed on the student; and understandable, uniform appeal procedures should be promulgated. As many Deans and Presidents stated, part of college is learning that life is not free, that each person, to be successful, must learn to carry out certain responsibilities. The basic responsibility for complying with financial aid policies and regulations should lie with students, both as a policy matter and, in the words of the Deans, as a learning tool. In addition, the new form for initiating an appeal remains somewhat complicated and confusing and should not form the basis upon which a student should be required to articulate an appeaL Recommendation 3. The form of "notice of appeal" should be reconsidered and simplified as part of the policy reconsiderations set forth in Recommendation 1. By way of example, one can imagine a procedure that a student would have 45 days from the date of a SAP determination of non-compliance within which to file a notice of appeal with the Director of Financial Aid, not with the individual campuses. Such an appeal policy would provide that the notice of appeal must contain (i) the basis upon which the appeal is made (ie. extenuating circumstances related to one or more qualitative standards), (ii) a narrative signed by the student explaining what the extenuating circumstances are, and (iii) third party documentation supporting the claimed extenuating circumstance. The burden should be placed on the student to overrule an initial SAP determination. An appeal should be automatically rejected if the notice of appeal is incomplete for lack of documentation or other information. The breach of the 150% Rule should not be appealable except for computational errors. In addition, documentation should only be required for the particular, current failure, not those that happened in the distant past. For example, if a student falls below the 67% Rule during the semester ended May, 2012, the extenuating circumstance should apply only to that semester and any supporting documentation should apply only to those circumstances, not those in prior semesters. It is the "tripping" incident that is relevant, not circumstances in the distant past. In other words, a student should not be able to justify his or her failing the 67% Rule by citing a death in the family two years earlier. The appeal process should also include a training component for students, which training should be a condition for filing a notice of appeal. For example, if a student decides to appeal, he or she should be required to attend a mandatory class on appeal requirements. The classes should be scheduled to be held within 15 days after the financial aid denial, leaving 30 days for the student to gather the necessary documentation and file the notice of appeaL Trainers could be welltrained Student Success Advisors acting under the Deans at each campus, but who would themselves be trained by an informed trainer from the Office of Financial Aid. Campus-led

August 7, 2012 Page 15 student training is consistent with the role of Deans to help and advise students, while the actual appellate review is handled centrally by disinterested central reviewers. 4. Training. One interviewee observed that the training culture at FSCJ is not one of compliance. While there is training on the academic side, there is little emphasis on training of staff persons (whether in the financial aid department or others). Formal and consistent training about compliance with financial aid policies and procedures has been slim, or virtually nonexistent. Vice President Bowers conceded that he has no memory of and that there are no records of any SAP training held between February, 1998, and Mrs. Bowles' June 29, 2010, meeting (although, as stated above, apparently there was a training on June 18, 2007). The Deans remember no training prior to 2011 about the SAP process or appeal procedures, other than the June 29, 2010, training; and the only training affirmed by the Deans as reasonably thorough was the one conducted in March, 2012, which occurred after the Audit Report had been published. A review by the College's Vice President of Human Resources of the records of the Academy for Professional Development ("AFPD") for 2010-11 and 2011-12 identify some courses related to financial aid being offered, but they dealt with financial aid basics, the "Connections" and "Financier" technology systems and fmancial aid yearly updates. It is unclear whether any of those trainings included SAP or SAP appeals, but the presumption is that they did not, given their titles. Recommendation 4. The training regimen for staff should be strengthened substantially. A culture should be cultivated which keeps employees knowledgeable and up-to-date about their job 'responsibilities, and, in the case of financial aid appeals, the training should be with a view toward compliance with applicable regulations, not maintaining the student census. A person responsible for training should be employed under a suitable job description and with appropriate authority. All persons involved in financial aid determinations and appeals should be trained thoroughly, both those who will be helping students apply for financial aid and those who will be training students on their appeal responsibilities. Training should include the requirements of particular financial aid programs. Training should utilize case method pedagogy and real life role-play examples. .It should be geared to particular subjects and not lumped in with more generic training. It should include all those with a "need to know". The training should include follow-up assessments and testing to make sure that attendees do indeed understand FSC],s policies and procedures. Training should be repeated at least annually. Financial aid training should also be provided to students when they first apply for fmancial aid, and should be repeated for the appellate process in the case of SAP appeals, as noted above. 5. Staffing Levels. The student census at FSCJ has grown exponentially over the last few years. In the financial aid area, staffing levels have not significantly increased, and current staff is unable to keep up with the demand. This is true in both the central financial aid administrative area and on the campuses, and was true in the 2010-11 academic year. As Vice President Bowers stated in an Executive Summary he prepared for the FSCJ Board (May, 2012 revision): The College enrollment grew dramatically (+35% or 6,000 full time equivalent students) and federal financial aid grants grew

August 7, 2012 Page 16

+ 185% in the years 2007-2011 and very few campus staff

even faster ($33 million in 2007-8 to $94 million in 2010-11, or

personnel were added in these years due to State budget problems. The volume crunch on financial staff was a contributing factor in the SAP appeal problem. This was particularly acute during the financial aid appeal process because appeals were handled on an annual basis, resulting in extremely high volumes of appeals for staff to handle within narrow time constraints. In addition, during the last several years, state funding of public higher education has been reduced substantially (from 75% to 50% in aggregate support, according to President Wallace in remarks to the FSCJ Trustees at their June 5, 2012, meeting). State funding reductions seriously impacted the College's staffing and hence the SAP appeal process. Even if the appeal process is centralized, staffing levels must be augmented to be sufficient for the task. The current staffmg of the Office of Financial Aid is 32 persons, including the Director. Of those, one person, a "Funds Manager-Pell", is responsible for reports to DOE; five persons, including a supervisor, are responsible for verifications; and one person is responsible for "packaging" the submittal of verifications to the FSCJ Information Technology department. It appears that the Director may be the only person currently doing SAP training. The persons responsible for DOE verifications must be experts in reading and understanding tax returns, financial statements and other documents submitted by students to verify their ISIRIF AFSA' s. They must have more than just "check the box" skills. Insufficient staffing has also contributed to communications issues with both students and campus personnel. Recommendation 5. Staffing structures and levels in FSCTs Office of Financial Aid should be analyzed and improved. It may be very difficult to augment staffing levels given state funding reductions, but the College administration should endeavor to do so. An accountable structure should be put in place, and a sufficient number of employees should be employed to insure that the important tasks of the office can be properly performed, including appeals. Further, the required qualifications and experience levels of financial aid employees should be evaluated and promulgated as part of new job descriptions. They should not be entry-level positions. 6. Technology. As noted above, there has been a huge increase in enrollment at FSCJ, and one way to keep up with it is through the application of effective technology resources. It is apparent from interviews of the Deans and Presidents that the technological apparatus serving FSCJ's financial aid sector is not sufficient. The programs utilized are not the most current, and the inputting to and updating of the programs is not efficient or timely. Some Deans observed that even if updates are made, changes are not always timely communicated to staff and students. There often is no testing of upgrades with stakeholders prior to systemic introduction to determine if the upgrades will perform as expected. Information has been inconsistent as depicted from screen to screen in different programs. The technological shortcomings have caused confusion and frustration among both students and staff, as for example, the proper calculation of the 67% Rule and the 150% Rule.

August 7,2012 Page 17 One Dean recalled that June, 2010, was "a public relations disaster for FSCJ" in terms of the communication of financial aid decisions to students and staff. The failures of the computer program seriously impacted the ability of students to know what their financial aid status was; and the Deans, who were the face of the institution as it related to students, were embarrassed and unable to respond with appropriate knowledge and authority. Another Dean lamented that there have been imaging/filing issues in which documents may have been submitted by students, but improperly filed or imaged so that they were not effective parts of the students' electronic files. Imaging issues were among the subjects discussed at meetings of the Financial Aid Strategies Committee held in fall, 2010. Some Deans observed that electronic tools, such as automatic calculation programs for the qualitative and quantitative standards, are utilized in other colleges and universities and would be helpful at FSCJ. One noted that the University of Florida's financial aid and appeal system is all-electronic. Recommendation 6. The technological systems and programs being used in the College's financial aid sector should be reviewed by competent persons to determine if they are adequate and effective, much less state-of-the-art. The use of standardized financial aid packages should be considered. Staffing levels and qualifications in the College's Information Technology department should also be reviewed for their sufficiency. These reviews would probably best be carried out by third party consultants who are experienced in such matters. The consultants should work with a group/committee consisting not only of Information Technology personnel, but also end users such as the Director of Financial Aid, Deans of Student Success, and even students themselves. Updates and new programs should be tested with cohorts of users before being introduced to the system at large, so that unanticipated "bugs" can be resolved. 7. Communication. Communication issues have arisen in two maj or areas. First, the communication of changes in technology have been delayed, late or incorrect, as discussed above. Second, in the scheduling and holding of training events, more thought could be given to assuring attendance at training events by specific teams or supervisors (those who "need to know") for particular training events. Notices of the events have not always been furnished to persons who would need the particular trainings. There have been few follow-up communications to test if the trainings which were held were adequate, helpful and understood. Recommendation 7. More insightful planning and scheduling of training events should be utilized by persons responsible for training. They should review organizational charts and job descriptions to determine who should be present at particular trainings, and before finalizing the attendee list, supervisors should be consulted to determine if any other persons should be included. Persons furnishing notice of meetings and trainings should make sure that the email addresses, etc., of participants are accurate. Finally, the question as to whether the "Connections" system is a suitable means of communication for financial aid status and SAP appeals should be considered. 8. Recovery of Student Debts Created by Appeal Denials. As a result ofthe findings by the Auditor General, FSCJ was obligated under the Pell Grant regulations to return substantial sums to DOE, but those amounts are not owed to the federal government by the students and are

August 7, 2012 Page 18 not subject to recovery by the federal government from the students. However, a Florida statute does require the College's Board of Trustees to "exert every effort to collect all delinquent accounts". F.S. §1010.03. A legal issue arises as to whether the improperly granted Pell funds became "delinquent accounts", thus imposing on the College the obligation under F.S. §1010.03 to seek reimbursement from the students. Because the statute does not define "delinquent", it will be given its plain and ordinary meaning. School Board of Palm Beach County v. Survivors Charter Schools, Inc., 3 So.3d 1220, 1233 (Fla. 2009). It has been defined elsewhere as failing to do what is required; overdue in payment; and failing to do what is required by law or obligation. Corum v. Fifth Third Bancorp, 2003 WL 21672828 (W.D.Ky.) quoting Webster's II New Riverside University Dictionary 359 (1994); see Gladysz v. King, 658 N.E.2d 309, 312 (1995)("[A]s applied to a debt or claim, 'delinquent' means simply 'due and unpaid at the time appointed by law or fixed by contract;' ... ), quoting Black's Law Dictionary (5 ed. 1979). The 2010-11 FSCJ catalog provides: If financial aid is reduced, terminated or otherwise insufficient to pay charges, student is (sic) responsible for payment of charges from their (sic) own resources. In addition, financial aid award letters to students provided that by acceptance of the award, the student agreed to certain attached "Financial Aid Terms and Conditions", which, in bold, setoff language, stated: "If you receive aid you are not entitled to, it will be your responsibility to repay those funds". Therefore, while there is no promissory note or other instrument creating a specific debt or amount for the repayment of the Pell grants for which students were ineligible, the combination of the catalog policy and the acceptance by students of financial aid in response to the offer made by the letters incorporating the highlighted condition, created a contract and hence an account that becomes "delinquent" if the student refuses to pay the amount owed. Under F.S. §101O.03, the College's Board of Trustees is obligated to "exert every effort to collect all delinquent accounts", and the administration should therefore seek to recover the improperly disbursed Pell funds. At its April 3, 2012, meeting, the FSCJ Board, by vote of 8-1, adopted a motion to amend the Student Debt Repayment Plan, as expressed in Board Rule 6Hx7-4.22, as recommended by President Wallace, to include a statement "authorizing the College to use the maximum amount of time to repay the debt permissible by law". Recommendation 8. The amendment to the Student Debt Repayment Plan as set forth above should be refined to be more specific in terms of its expectations of the time in which repayment can be made, so that it provides an ascertainable standard by which the College can "exert every effort" to collect the delinquent accounts. Collection efforts may involve litigation in which

August 7, 2012 Page 19 students will have an opportunity to raise defenses. If the FSCJ Board intends to comply with F.S. §1010.03, it should not give extra ammunition to defaulting students in the form of an implication that the College has waived or intends to waive or excuse the repayment of any delinquent account. 9. Treatment of Certain Employees whose Employment Status is On Hold. At the FSCJ Board meeting held on June 5, 2012, a motion was adopted to approve interim rather than annual appointments for 12 persons who were involved in the review of student financial appeals for the 2010-2011 year. Ordinarily the annual appointments for these persons would have been renewed along with other annual appointment renewals. However, because of the examination of the appeal process, the decision on these appointments was deferred until a clear understanding of what had occurred could be presented to and understood by the Board. Recommendation 9. It is recommended that the FSCJ Board find that the Pell Grant deficiencies were the result of institutional and organizational history, culture, structures and practices, inadequate staffing and training and insufficient use of technology, and was not the fault of individual persons. The persons who are subject to the Board's June 5, 2012, interim appointment resolution should be approved by the Board for annual reappointment, absent findings of specific egregious misconduct or dereliction of duty. Trustees should note that at the June 5,2012, FSCJ Board meeting, President Wallace stated that there had been "no evidence of misconduct or personal gain" by any of the SAP appeal decision-makers. In making this recommendation the undersigned acknowledges and appreciates that the Vice President for Administrative Services feels that these employees were senior administrators who had a responsibility to "seek out and find out what is right", and that, given the efforts of the Financial Aid Strategies Committee to strengthen the policy in the fall and winter of 2010-11, they should have known and enforced the rules. Nevertheless, as stated above, the Financial Aid Strategies Committee was not primarily focused on SAP appeals, which was reflected by the makeup of the participants. The efforts in the fall and winter of 2010-11 were not directed toward the current year, but were to apply to subsequent years. The Vice President for Human Resources did not consider them to be "trainings". Committee members included non-financial aid staff, and the Deans who attended varied somewhat from meeting to meeting. The errors in the SAP appeal process were caused by long-standing institutional customs and practices. It would be wrong to punish individual professional employees by effectively secondguessing them as arm-chair quarterbacks after the fact, unless there were, in individual cases, gross misfeasance or malfeasance. That is not to diminish the recommendations for change described above, which should be adopted, implemented and enforced. The Board, however, should look forward, not backward, in dealing with its employees. Final Observations This review has suggested to devolved structures may have impacted that in July, 2012, the FSCJ Board experienced educational management the undersigned that FSCJ's governance policies and SAP and SAP appeal policies and procedures. It is noted voted to engage MGT of America, Inc. ("MGT"), an consulting firm, to advise it on a number of matters,

August 7, 2012 Page 20 including "Executive leadership and strategic management structure, College-wide and component unit organizational structure, and Effectiveness of the leadership in identified organizational structures". The FSCJ Board is encouraged to assure itself that MGT's review includes governance and structural concerns related to financial aid. It is clear to the undersigned that FSCJ has the capacity of adequately administering its financial aid programs, as particularly shown by the work of the Director of Financial Aid, the Vice President for Administrative Services and those involved in the Financial Aids Strategies Committee. It is important to reiterate that problems in the financial aid program were first identified by the College's senior administrative staff, specifically Mrs. Bowles and Mr. Bowers. Their efforts for change were begun long before the Audit Report. Indeed, the new SAP processes that were developed over the course of fall-winter 2010-11 were recommended to the Administration in February, 2011, and approved by the FSCJ Board of Trustees at its April 5, 2011, meeting. This was almost a year before the College received the Audit Report. The administration's decision to remove the authority to review SAP appeals from the North, South and Kent campuses, and from Deerwood Center, and to transfer that authority to the Director of Financial Aid, reflects the capacity and ability of the College administration to deal with these issues promptly. These actions show the inherent strength and capability of the administrative leadership of the College. Those leaders, like administrators at many other colleges, were playing "catchup" to deal with ambiguous DOE financial aid protocols, huge increases in enrollment caused by the rapid expansion of the Pell Grant program, and substantial decreases in state funding support for public higher education. It has been both an honor and an education to have researched and prepared this Report. Every person interviewed expressed a deep love for Florida State College at Jacksonville, and each desires it to thrive and succeed. Persons employed by FSCJ feel a real "call" to serve students, the College and the community. Each person interviewed expressed the hope that FSCJ's financial aid system and structures can be improved, with the result that students formed by Florida State College at Jacksonville will become productive workers, servant leaders and responsible citizens of our community and nation. Thank you for the opportunity to present these observations and recommendations. Respectfully submitted,

~~

William E. Scheu

1678186 _1.DOC

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