Report 2019-113 All Recommendation Responses

Report 2019-113: The University of California: Qualified Students Face an Inconsistent and Unfair Admissions System That Has Been Improperly Influenced by Relationships and Monetary Donations (Release Date: September 2020)

Recommendation #1 To: University of California

To protect the fairness and integrity of its admissions processes, the Office of the President should establish systemwide protocols for admissions processes by the fall 2021 admissions cycle that prohibit the following:
- Giving authority to any one person to make a final admissions decision.
- Consideration of an applicant's familial or other personal relationships to university staff or faculty in an admissions decision.
- Communication between a campus's development office and its admissions office about applicants and prospective applicants.

Annual Follow-Up Agency Response From September 2023

From November 2022 through January 2023, the Office of the President communicated with the State Auditor's office by phone and email to obtain additional detail on the specific documentation for each campus that the State Auditor found insufficient to fully implement this recommendation. Based on this feedback, we followed up with the campuses to update their policies and procedures to address the State Auditor's concerns.

It is the role and responsibility of the chief admissions officer to make and approve all final admission decisions unless specifically stated. The chief admissions officer is the person held accountable for admission decisions based on the recommendation of others; however, some situations may require protocols, as recommended by the CSA, to have decisions reviewed by more than person. When such procedures exist, they will be followed, but under normal circumstances and in the course of performing the duties of the job, the chief admissions officer has the authority to make final decisions on admissions which supports the use of qualifying policy language prohibiting the authority for any one person to make a final admission decision only "outside established protocol."

California State Auditor's Assessment of Annual Follow-Up Status: Fully Implemented

The University has now provided evidence that the campuses have updated their policies to prohibit consideration of applicant's familial or personal relationships to faculty and staff in admissions decisions. Also, the campuses now all prohibit communication between a campus's development office and admissions office about applicants and prospective applicants. Finally, each campus has a policy prohibiting any one person from making a final admission decision outside established protocol. We reviewed each campus's selection policies and procedures and found that the selection protocols they contain appear to mitigate the risk of the improper influence in admissions decisions that we identified in our report.

Annual Follow-Up Agency Response From October 2022

In March and April 2022, the Office of the President communicated with the State Auditor's office by phone and email to obtain additional detail on the specific documentation for each campus that the State Auditor found insufficient to fully implement this recommendation. Based on this feedback, we followed up with the campuses to update their policies and procedures to address the State Auditor's concerns.

California State Auditor's Assessment of Annual Follow-Up Status: Partially Implemented

This recommendation remains only partially implemented. As we have noted before, the Office of the President has not established a set of systemwide protocols as we recommended, and the campuses have taken different approaches to implementing this recommendation. Based on the documentation that the Office of the President provided, UC Berkeley and UCLA continue to be the only two campuses that have fully implemented this recommendation. The remaining campuses have not adopted sufficient prohibitions in all of the recommended areas. These deficiencies increase the risk of improper influence in admissions decisions.

We will consider this recommendation fully implemented when the Office of the President formally documents prohibitions against these actions and ensures that campuses are consistently addressing these areas.

1-Year Agency Response

The University president required all campuses to implement this recommendation and to document the processes and procedures, via a letter sent in November 2020. All campuses have submitted documentation of local policy and practices, which are under the purview of local governance, that prohibit

a. Giving authority to any one person to make a final admissions decision.

b. Consideration of an applicant's familial or other personal relationships to university staff or faculty in an admissions decision.

c. Communication between a campus's development office and its admissions office about applicants and prospective applicants.

The Office of the President reviewed each campus's submissions to ensure the new processes and procedures addressed the recommendation. Additionally, the Office of the President worked with the campuses to clarify and strengthen local policy language prohibiting communication between development offices and admissions offices.

California State Auditor's Assessment of 1-Year Status: Partially Implemented

This recommendation remains only partially implemented. The Office of the President has not established a set of systemwide protocols as we recommended.

In the absence of systemwide protocols, the Office of the President provided documentation showing each campus's actions to address this recommendation. Unfortunately, the campuses have approached implementation of this recommendation differently than one another and of the nine undergraduate campuses, only Berkeley and UCLA have adopted policies and procedures which fully address all the elements of this recommendation.

Most, but not all campuses, now prohibit communication between the development office and the admissions office about applicants and prospective applicants. The different approaches taken by the campuses reveals an uneven approach across the system to addressing the potential influence of donations on admissions decisions. Further, some campuses still have not prohibited a single individual from making admissions decisions, which increases the risk of improper influence in admissions decisions.

We will consider this recommendation fully implemented when the Office of the President formally documents prohibitions against these actions and ensures campuses are consistently addressing these areas.

6-Month Agency Response

The University president has required all campuses to implement this recommendation and to document the processes and procedures, via a letter sent in November 2020. All campuses have submitted documentation to address processes and procedures for identifying and reporting inappropriate behavior to influence admissions decisions. The Office of the President reviewed each campus's submissions to ensure the new processes and procedures addressed the recommendation.

California State Auditor's Assessment of 6-Month Status: Pending

This recommendation remains pending because the Office of the President has not established a set of systemwide protocols as we recommended.

Further, the Office of the President provided documentation from each campus to substantiate their completion of this recommendation. Berkeley was the only campus of the nine undergraduate campuses that had adopted policies and procedures which fully address all the elements of this recommendation. The campuses sometimes took divergent approaches from one another, emphasizing the value of a single systemwide approach. For example, several campuses only took steps to prohibit communication between development offices and admissions offices beginning three months prior to an application cycle. In contrast, Berkeley's prohibition was absolute and not restricted to a particular period of time.

We will consider this recommendation fully implemented when the Office of the President formally documents prohibitions against these actions.

60-Day Agency Response

The University president has issued a letter to the campus chancellors to implement this recommendation immediately and provide documentation of follow-through no later than January 15, 2021.

California State Auditor's Assessment of 60-Day Status: Pending

The Office of the President provided the letter that the University president issued to campuses. We will consider this recommendation fully implemented when the Office of the President formally documents prohibitions against these actions.

Recommendation #2 To: University of California

To protect the campuses' athletics admissions process from abuse, the Office of the President should require each campus to do the following by the fall 2021 admissions cycle:
- Have at least two reviewers verify the athletic talent of all prospective student athletes before their admittance. At least one of these reviewers should be from a department other than the athletics department. Each campus should develop standards for the level of talent that prospective student athletes for each of its teams must possess and then use those standards to verify the talent.
- Track student athletes' participation in the sport for which they were recruited. If a student does not participate in the sport for longer than one year, the campus should determine the reason why the athlete stopped participating and, if necessary, conduct a review of the circumstances that led to the student's admission to identify signs of inappropriate admissions activity.
- Review donations to athletic programs to determine whether those donations made before or after an athlete's admission may have influenced the athletic department's decision to request the athlete's admission.

Annual Follow-Up Agency Response From January 2024

In its most recent assessment, the State Auditor's Office noted: "Also, all but one campus has provided documentation of processes for independent review of donations to athletics programs made before or after an athlete's admission." The University has now provided this documentation to the State Auditor's Office for the one remaining campus.

California State Auditor's Assessment of Annual Follow-Up Status: Partially Implemented

The University has provided evidence that each campus has policies to track student athletes' participation in the sport for which they were recruited, and conduct reviews of the circumstances that led to the student's admission when athletes do not participate for longer than one year. Additionally, all campuses have provided documentation of processes for independent review of donations to athletics programs made before or after an athlete's admission. However, the University has declined to require all of its campuses to develop standards for the level of athletic talent that prospective student athletes should have to warrant their admission outside of the standard admissions process. Although two campuses have developed those standards, the remaining campuses have not developed or not provided evidence of those standards. As a result, the campuses are less able to validate that a student recommended for admission to participate on an athletic team actually possesses sufficient athletic ability to warrant admission.

Annual Follow-Up Agency Response From September 2023

From November 2022 through January 2023, the Office of the President communicated with the State Auditor's office by phone and email to obtain additional detail on the specific documentation for each campus that the State Auditor found insufficient to fully implement this recommendation. Based on this feedback, we followed up with the campuses to update their policies and procedures to address the State Auditor's concerns.

We believe the standards provided by the campuses are sufficient as documented. Prospective athletes may be scouted for talent based on sport, individual position, or general athletic potential to contribute to a team given the level of athletic competitiveness of the program's conference affiliation (e.g., NCAA Division I, NCAA Division III, NAIA). The standards provided are commensurate with these variables.

California State Auditor's Assessment of Annual Follow-Up Status: Partially Implemented

The University has provided evidence that each campus has policies to track student athletes' participation in the sport for which they were recruited, and conduct reviews of the circumstances that led to the student's admission when athletes do not participate for longer than one year. Also, all but one campus has provided documentation of processes for independent review of donations to athletics programs made before or after an athlete's admission. However, the University has declined to require all of its campuses to develop standards for the level of athletic talent that prospective student athletes should have to warrant their admission outside of the standard admissions process. Although two campuses have developed those standards, the remaining campuses have not developed or not provided evidence of those standards. As a result, the campuses are less able to validate that a student recommended for admission to participate on an athletic team actually possesses sufficient athletic ability to warrant admission.

Annual Follow-Up Agency Response From October 2022

In March and April 2022, the Office of the President communicated with the State Auditor's office by phone and email to obtain additional detail on the specific documentation for each campus that the State Auditor found insufficient to fully implement this recommendation. Based on this feedback, we followed up with the campuses to update their policies and procedures to address the State Auditor's concerns.

California State Auditor's Assessment of Annual Follow-Up Status: Partially Implemented

The status of the University's implementation of this recommendation has not changed substantively since its last update in 2021. Not all of the campuses have developed sport-specific standards for the level of talent that prospective student athletes must demonstrate. Although some campuses provided sport-specific standards, in some cases the standards that campuses developed continue to be vague and nonspecific. Similarly, not all of the campuses have demonstrated that they possess sufficiently independent processes for auditing to ensure that donations did not influence student athlete admissions.

1-Year Agency Response

The University president required all campuses to implement this recommendation and to document the processes and procedures, via a letter sent in November 2020. Local policies and practices are all under the purview of local governance and all campuses have submitted documentation demonstrating a multi-reviewer process, mechanisms for tracking student athlete participation, criteria for assessing talent and an independent donor review process to mitigate fraud and ensure no influence or conflict of interest exists. Additionally, the Office of the President worked with the campuses to clarify and strengthen local policy and procedure language regarding tracking athlete participation in the sport for which they were recruited and investigating when athletes do not participate for at least one year. Each campus also developed protocols to ensure the integrity of the data pulled for donation reviews.

California State Auditor's Assessment of 1-Year Status: Partially Implemented

The campuses have all generally updated their practices to include an independent review of prospective student athletes' athletic qualifications. However, not all of the campuses have developed sport-specific standards for those qualifications, rendering that review less effective. In some cases, the standards that campuses developed are vague and lack specificity when such specificity was possible. For example, instead of establishing a minimum threshold for how quickly a prospective athlete must be able to finish a race, a campus only stated that it would review prospective athletes' times. In another example from another sport, a campus listed that one of its qualifications was that it was looking for prospective athletes that were highly competitive and hungry to learn how to improve and win. These are, no doubt, important soft skills that campuses would desire in their athletes. However, they do not allow for an independent or objective review of whether the athletics admissions process is being used to recruit legitimate athletes or abused to admit students who have no demonstrable athletic talent.

Similarly, not all of the campuses have procedures for investigating the admissions circumstances of student athletes who do not participate in the sport for which they were recruited. Nor do all campuses have sufficiently independent processes for auditing to ensure that donations did not influence student athlete admissions.

6-Month Agency Response

The University president has required all campuses to implement this recommendation and to document the processes and procedures, via a letter sent in November 2020. Campuses have submitted documents that demonstrate a multi-review process, tracking prospective athletes' participation in said sport and pre-admit and post-admit review of program donors. The Office of the President has reviewed each campus's submissions to ensure the new processes and procedures will address the recommendation. All campuses have completed recommendation 2b and seven out of nine campuses have completed 2d. UCOP has assessed gaps in submitted information related to characteristics for defining standards in the level of talent. UCOP has requested additional documentation to confirm the standards or characteristics for verifying talent.

California State Auditor's Assessment of 6-Month Status: Pending

The Office of the President acknowledged in its response that the UC has not fully implemented this recommendation with regard to requiring two reviews of athletic talent and the establishment of standard levels of talent for prospective student athletes.

However, the Office of the President incorrectly asserts that the UC has fully implemented the recommendation as it relates to tracking athlete participation in the sport for which they were recruited and investigating when athletes do not participate for at least one year. The Office of the President provided documentation to support the campuses' implementation of that recommendation, but our review of the documentation showed that the majority of the campuses have not adequately implemented it. For example, in accordance with our recommendation, UC Irvine's athletics policy states that its athletics compliance office will review the circumstances surrounding the admission of all student athletes who do not participate for at least one year to identify possible manipulation of admissions processes. However, several other campuses' policies simply state that they will determine whether the athlete has a valid reason for leaving the team, and do not describe any investigation of the circumstances of their admission. Additionally, the documentation that UCOP provided regarding UC San Diego's athletic policies contained no mention of a review following an athlete's early departure from the team.

We will conclude that this recommendation is implemented when the Office of the President provides sufficient evidence demonstrating that all campuses have implemented this recommendation.

60-Day Agency Response

The University president has issued a letter to the campus chancellors to implement this recommendation immediately and provide documentation of follow-through no later than January 15, 2021.

California State Auditor's Assessment of 60-Day Status: Pending

The Office of the President provided the letter that it sent to the campus chancellors. We will conclude that this recommendation is implemented when the Office of the President formalizes those prohibitions.

Recommendation #3 To: University of California

The Office of the President should immediately require staff involved in making or informing admissions decisions to report all attempts to influence admissions decisions, regardless of source, to their supervisors or to the director of undergraduate admissions.

1-Year Agency Response

The University president required all campuses to implement this recommendation and to document the processes and procedures, via a letter sent in November 2020. The Office of the President reviewed each campus's submissions to ensure the new processes and procedures will address the recommendation. Additionally, the Office of the President worked with the campuses to ensure all responsive policies and procedures are in final form and to clarify and strengthen language regarding potential attempts to influence admissions decisions. All nine campuses have successfully met this recommendation providing procedures and protocols, which are under the purview of local governance, to address attempts of inappropriate influence. Campuses documented this in their Conflict of Interest Policies.

California State Auditor's Assessment of 1-Year Status: Fully Implemented

6-Month Agency Response

The University president has required all campuses to implement this recommendation and to document the processes and procedures, via a letter sent in November 2020. The Office of the President has reviewed each campus's submissions to ensure the new processes and procedures will address the recommendation. All nine campuses have successfully met this recommendation providing procedures and protocols to address inappropriate influence. Campuses document this in their Conflict of Interest Policy.

California State Auditor's Assessment of 6-Month Status: Partially Implemented

We have reviewed the documentation the Office of the President submitted to substantiate the completion of this recommendation, and found that some campuses have not yet adopted policies which adequately implement our recommendation. For example, some documents were labeled as draft policies and others did not make clear that attempts to influence admissions decisions may include activity beyond the use of a gift as a bribe. We will consider this recommendation fully implemented when the Office of the President provides documentation indicating all campuses now require staff involved in making or informing admissions decisions to report all attempts to influence admissions decisions.

60-Day Agency Response

The University president has issued a letter to the campus chancellors to implement this recommendation immediately and provide documentation of follow-through no later than January 15, 2021.

California State Auditor's Assessment of 60-Day Status: Pending

The Office of the President provided the letter it sent to the campus chancellors. We will consider this recommendation fully implemented when the Office of the President adopts a formal requirement to report attempts to inappropriately influence admissions decisions.

Recommendation #4 To: University of California

Beginning with the fall 2021 admissions cycle, the Office of the President should oversee UC Berkeley's admissions process for at least three years. The Office of the President should ensure that all admissions decisions are merit-based and conform to the university's policies on admissions. Further, the Office of the President should facilitate the establishment of a culture of ethical conduct in admissions by providing regular training to admissions and development staff, conducting reviews of admissions decisions, and monitoring the admissions office's communications about applicants to ensure no inappropriate factors influence admissions activities.

1-Year Agency Response

All campuses, including Berkeley, have addressed this issue so that all admissions decisions are merit-based and conform to the university's policies on admissions.

All campuses, including Berkeley have taken steps to improve their processes and policies to strengthen their defenses against the risk of inappropriate activity and are committed to safeguarding the transparency and fairness in their admissions practices. Further, campuses have updated their annual training detailing when and how to report inappropriate activities or conflicts of interest.

UCOP resources are most effectively and efficiently deployed in overseeing admissions from a systemwide vantage point and perspective, in conjunction with the Academic Senate and BOARS.

California State Auditor's Assessment of 1-Year Status: Will Not Implement

UC Berkeley inappropriately admitted more than 50 applicants based on those applicants' connections to donors and University staff. Those admissions occurred despite existing UC Berkeley policy prohibiting the influence of donations on admissions decisions and some other procedural safeguards to prevent improper influence. As we describe in the report, these admissions occurred because UC Berkeley leadership failed to develop a campus culture that supports fair and merit based admissions decisions. Without such a culture, additional trainings and policies, although necessary, are not by themselves sufficient to prevent improper influence in future admissions decisions. It is therefore unfortunate that the University has decided to forego establishing stronger oversight of UC Berkeley admissions until the campus demonstrates that it has developed a culture that promotes fairness in admissions decisions.

6-Month Agency Response

Academic Affairs continues to evaluate the implementation of this recommendation.

California State Auditor's Assessment of 6-Month Status: Pending

60-Day Agency Response

The Office of the President is currently evaluating the implementation of this recommendation.

California State Auditor's Assessment of 60-Day Status: Pending

Recommendation #5 To: University of California

To ensure that the university maintains a fair and consistent admissions process, the Office of the President should require each campus to take the following actions:
- By March 2021, document and implement a selection methodology that describes how it will choose applicants for admission, particularly when the applicants have received similar ratings from application readers. Further, the selection strategy should specify the reasons why a campus may choose an applicant with a low or uncompetitive rating instead of an applicant with a higher rating.
- Develop and implement processes to use when selecting applicants for admission for identifying applicants whom it has selected for admission and who are not eligible for admission to the university, and record their rationale for admitting those applicants despite their ineligibility.

Annual Follow-Up Agency Response From September 2023

The admissions process includes two parts: comprehensive review and selection. Campuses use comprehensive review (or multiple measures of achievement in context) when reviewing applicants for admission. However, the scores generated through this process are not solely determinate in who gets selected for admission. Ultimately, selection decisions are made following the campus's enrollment management strategy, which combines enrollment goals for individual colleges, schools, programs, and/or majors. In addition, as admitted students choose to enroll or not, campuses must adjust their modeling to fill gaps in enrollment using waitlists. Thus, the scores of students admitted to a particular campus can vary depending on an applicant's proposed program/major, demand within specific schools, the depth of the applicant pool, as well as timing of admission. However, all selection decisions abide by the documented systemwide and campus policies.

California State Auditor's Assessment of Annual Follow-Up Status: Partially Implemented

The University has not demonstrated that its campuses have established specific methodologies for how they will choose applicants for admission. Until the campuses do so, they lack an important tool for ensuring accountability and fairness in admissions decisions.

Annual Follow-Up Agency Response From October 2022

The admissions process includes two parts: comprehensive review and selection. Campuses use comprehensive review (or multiple measures of achievement in context) when reviewing applicants for admission. However, the scores generated through this process are not solely determinate in who gets selected for admission. Ultimately, selection decisions are made following the campus's enrollment management strategy, which combines enrollment goals for individual colleges, schools, programs, and/or majors. In addition, as admitted students choose to enroll or not, campuses must adjust their modeling to fill gaps in enrollment using waitlists. Thus, the scores of students admitted to a particular campus can vary depending on an applicant's proposed program/major, demand within specific schools, the depth of the applicant pool, as well as timing of admission. However, all selection decisions abide by the documented systemwide and campus policies.

California State Auditor's Assessment of Annual Follow-Up Status: Partially Implemented

The University has not demonstrated that its campuses have established specific methodologies for how they will choose applicants for admission. Until the campuses do so, they lack an important tool for ensuring accountability and fairness in admissions decisions.

1-Year Agency Response

The University president required all campuses to implement this recommendation and to document the processes and procedures, via a letter sent in November 2020. All campuses have submitted documentation that outlines principles and methodology for choosing applicants, processes for accepting ineligible applicants, and processes for coding admissions by exception. The Office of the President has reviewed each campus's submissions to ensure the new processes and procedures will address the recommendation.

The University believes that the level of specificity provided by the campuses on their selection methodology is appropriate and to disclose the exact details of selection procedures at each campus runs counter to the principles of fairness and equitable access. UC believes greater specificity has the potential to advantage well-resourced families and those in the college consulting business intent on selling their services with claims of "insider" knowledge.

The University is already transparent about its admission selection procedures. The BOARS' Annual Report on Undergraduate Admissions Requirements and Comprehensive Review includes a summary description of campus selection processes in addition to what they have provided in response to the audit recommendation. The release of greater detail on how the university's criteria on comprehensive review are implemented at each campus, either in the generation of a holistic score (for campuses that use it) or in subsequent selection, will hand a significant advantage to those with the resources to take advantage of the information.

California State Auditor's Assessment of 1-Year Status: Pending

The Office of the President misrepresents our recommendation in its response by suggesting that implementing the recommendation would somehow make the details of its selection procedures public. As we describe in the text of the report, we found that both UCLA and UC Berkeley admitted students who, through the campuses' own holistic review processes, the campuses had determined were less qualified for admission than other applicants whom the campuses denied admission. Neither campus was able to explain those admission decisions. Documenting a methodology for selecting students for admission, including the circumstances when lower-rated students will be admitted in place of higher rated students, will lend greater accountability and fairness to the University's admission process, which is why we recommended that the Office of the President require each campus to do so. We did not recommend-and do not recommend-that the campuses make those methodologies public.

6-Month Agency Response

The University president has required all campuses to implement this recommendation and to document the processes and procedures, via a letter sent in November 2020. All campuses have submitted documentation that outlines principles and methodology for choosing applicants, processes for accepting ineligible applicants, and processes for coding admissions by exception. The Office of the President has reviewed each campus's submissions to ensure the new processes and procedures will address the recommendation. Seven out of nine campuses have successfully completed the requirements. There are gaps in criteria and clarity on some of the processes for the remaining two campuses. UCOP has requested additional documentation.

California State Auditor's Assessment of 6-Month Status: Pending

The Office of the President acknowledges that the UC has not fully implemented this recommendation. However, we disagree with its characterization of the progress that the campuses have made in implementing the recommendation. For example, the Office of the President stated that all campuses had outlined principles and methodology for choosing applicants, but when we reviewed the campus documentation that the Office of the President provided to substantiate that statement, we found that several campuses had documented insufficient and vague descriptions of their processes for selecting applicants for admission. Campuses described general characteristics that they consider when evaluating applicants, but did not specifically articulate a priority order for how they would decide which applicants they would admit. Particularly lacking from some statements was a description of how the campus would decide between similarly rated students. Of particular concern was that San Diego's selection methodology was less specific than the methods we reviewed from that campus during our original audit. These vague policies and procedures do not correct the problematic ambiguity that we identified in the campuses' admission processes, and fail to provide needed transparency in admission decisions.

We will consider this recommendation to be fully implemented when the Office of the President provides documentation demonstrating that each campus has documented polices and procedures specifying their methodologies for making admissions decisions as we describe in the recommendation.

60-Day Agency Response

The University president has issued a letter to the campus chancellors to implement this recommendation immediately and provide documentation of follow-through no later than January 15, 2021.

California State Auditor's Assessment of 60-Day Status: Pending

The Office of the President provided the letter it sent to the campus chancellors. We will consider this recommendation fully implemented when the Office of the President adopts a formal requirement that campuses take these actions.

Recommendation #6 To: University of California

To provide assurance that campuses' use of the admission by exception policy is aligned with the policy's purpose, beginning in June 2021, the Office of the President should annually select a random sample of applicants admitted by exception and verify that campuses recorded a rationale for each admission and that each rationale aligns with BOARS's guidance.

Annual Follow-Up Agency Response From October 2022

The Office of the President is unable to independently determine the eligibility status of all applicants. The algorithms in place in the application program provide a preliminary eligibility determination for the majority of applicants, but there are many scenarios in which only a trained reader can identify and resolve issues of eligibility. The Office of the President does not review individual applications. Therefore, the campuses are best equipped to make those determinations.

California State Auditor's Assessment of Annual Follow-Up Status: Fully Implemented

1-Year Agency Response

The Office of the President implemented this recommendation by developing campus guidelines and a selection methodology to randomly sample applicants admitted by exception from fall 2021 and verified that campuses recorded a rationale for each admission and that each rationale aligns with BOARS's guidance. This process will continue on an annual basis.

California State Auditor's Assessment of 1-Year Status: Partially Implemented

The Office of the President provided its report on its audit of admissions by exception, wherein it described that it randomly selected applicants whom the campuses coded for admission, validated that the campuses provided a rationale for those admissions, and confirmed by reviewing the application that the admission by exception aligned with BOARS guidance on permissible reasons for admitting applicants by exception. Although this process can verify that campuses record appropriate rationales when admitting applicants by exception, it reviews only applicants whom the campuses reported were admitted by exception. Because it relies on the campuses reporting, this review process does not ensure that campuses appropriately identify all ineligible students that they admit. To properly verify that campuses identify all ineligible students that they admit and provide a rationale for doing so, the Office of the President must independently determine the actual number of applicants who were ineligible, and verify that the campuses provided appropriate rationales for admitting those applicants.

6-Month Agency Response

Campuses have established practices for Admissions by Exception policy, however UCOP located gaps in training and/or documentation from some of the campuses. UCOP has requested additional materials to verify training protocols and stronger language in the documentation.

Also, the annual random sampling will begin in June 2021, when the Office of the President will review Admission by Exception reported by campuses by selecting a random sample of applicants admitted by exception to verify that campuses recorded a rationale for each admission and that each rationale aligns with BOARS's guidance.

California State Auditor's Assessment of 6-Month Status: Pending

60-Day Agency Response

Beginning in June 2021, the Office of the President will review annually Admission by Exception reported by campuses and annually select a random sample of applicants admitted by exception to verify that campuses recorded a rationale for each admission and that each rationale aligns with BOARS's guidance.

California State Auditor's Assessment of 60-Day Status: Pending

Recommendation #7 To: University of California

To ensure that the university maintains a fair and unbiased admissions process, the Office of the President should require each campus to take the following actions:
- By March 2021, establish acceptable levels of application reader proficiency and maintain training and monitoring programs that ensure that its readers attain and sustain those levels. In addition, it should report annually to BOARS on those efforts and on reader consistency levels, including the frequency with which reader ratings align with campus guidelines for
rating applications.
- Beginning with the academic year 2021-22 admissions cycle, require each campus that does not admit all eligible transfer applicants to ensure that two readers review all transfer
applications.
- Beginning with the academic year 2021-22 admissions cycle, ensure that the second readers cannot see the ratings of first readers for both freshman and transfer applications.

Annual Follow-Up Agency Response From September 2023

From November 2022 through January 2023, the Office of the President communicated with the State Auditor's office by phone and email to obtain additional detail on the specific documentation for each campus that the State Auditor found insufficient to fully implement this recommendation. Based on this feedback, we followed up with the campuses to update their policies and procedures to address the State Auditor's concerns.

Evaluation for transfer admission is a highly technical process that requires professional staff trained to assess coursework for admission to the major at the junior level often from multiple institutions prior to transfer. With constraints on time and staff resources, campuses have implemented quality control measures when second reads are not feasible.

The June 2023 BOARS report includes a section on each campus with information on their reader quality control outcomes.

California State Auditor's Assessment of Annual Follow-Up Status: Partially Implemented

As noted in previous updates, some of the campuses still do not have adequate procedures for ensuring that application reviewers achieve a sufficient level of accuracy when reviewing applications for admission. Some campuses have established accuracy standards and procedures for monitoring the accuracy of readers both during and after initial training. However, other campuses lack robust processes for monitoring application reviewer accuracy throughout the admissions cycle after their initial training has ended. As a result, those campuses lack adequate assurance that their application reviewers are consistent in their review of applications for admission. Additionally, the University has declined to conduct a second review of all transfer applications.

Annual Follow-Up Agency Response From October 2022

In March and April 2022, the Office of the President communicated with the State Auditor's office by phone and email to obtain additional detail on the specific documentation for each campus that the State Auditor found insufficient to fully implement this recommendation. Based on this feedback, we followed up with the campuses to update their policies and procedures to address the State Auditor's concerns.

California State Auditor's Assessment of Annual Follow-Up Status: Partially Implemented

All campuses have now demonstrated that second readers can no longer see the first readers rating of an application. However, some of the campuses still do not have adequate procedures for ensuring that application reviewers achieve a sufficient level of accuracy when reviewing applications for admission. For example, UC Santa Cruz, UC Merced, and UC Davis each have established accuracy standards and procedures for monitoring the accuracy of readers both during and after initial training. However, other campuses lack robust processes for monitoring application reviewer accuracy throughout the admissions cycle after their initial training has ended. As a result, those campuses lack adequate assurance that their application reviewers are consistent in their review of applications for admission.

1-Year Agency Response

Each UC campus that employs application readers has successfully met this recommendation. UCOP worked with the campuses to ensure responsive policies and procedures articulate specific expectations for the proficiency that their readers must maintain and specifically describe processes to monitor their readers to ensure they maintain that level of proficiency. UCOP also collected documentation from the campuses to demonstrate that a second reader cannot view the first reader's score.

Over 20% of transfer applications go through a technical evaluation process where one campus reviews the application for completion of minimum junior transfer admission requirements. Data, including GPA, overall UC-transferable units, and completion of the 7-course pattern, as well as course-by-course evaluations, are then shared with the other campuses to which the student applied. Each campus then conducts its own comprehensive review for selection purposes. This may include identifying major pre-requisites, calculating a major GPA, and reviewing the personal insight questions.

As with any human review process, a small number of errors are expected, and when discovered by a reviewer, they are reported to UCOP as part of this review process. The annual error rate is extremely low and accounts for less than one-tenth of one percent of applications reviewed. Even with these errors, our records indicate that none of these students were unfairly denied admission to UC. Students who did not receive offers of admission were generally not competitive for the campuses and majors to which they applied.

In response to recommendation 7b related to transfer admissions, campuses who do not use an automated (non-human) process or do not have a two reader process are independently conducting an additional quality assurance measure by randomly sampling transfer applications to ensure they have been appropriately evaluated.

California State Auditor's Assessment of 1-Year Status: Pending

6-Month Agency Response

For UC campuses that employ application readers (UCR uses a scoring system), each location has successfully met requirements 7a and 7c, and have provided documentation outlining the reader training on proficiency and standards and how these programs are monitored.

For 7b, eight out of the nine campuses either have a two-reader process in place for transfer students or if a campus doesn't have a 2-reader process and anticipates not admitting all eligible transfers, will develop a random sampling process for a 2nd reader. The random sample is an effective statistical tool that allows campuses to ensure that transfer applications are appropriately evaluated.

California State Auditor's Assessment of 6-Month Status: Pending

Although the Office of the President acknowledges that the UC has not fully implemented the recommendation, it overstates the progress that campuses have made. Half of the campuses have not articulated specific expectations for the proficiency that their readers must maintain throughout the reading process. Additionally, none of the campuses have described with specificity the processes it will use to monitor their readers to ensure they maintain that level of proficiency. For other portions of its response, we cannot substantiate the progress because the Office of the President did not provide sufficient documentation. For example, we cannot validate that each campus's second reader cannot view the first reader's score because the Office of the President did not provide documentation related to this issue for each campus.

Further, the documentation the Office of the President did submit shows it does not plan to require campuses to ensure two reads of each transfer application as we recommended. Rather it plans to allow for a random sampling of applications to be read a second time. This approach does not fully implement the recommendation.

60-Day Agency Response

The University president has issued a letter to the campus chancellors to implement this recommendation immediately and provide documentation of follow-through no later than January 15, 2021.

For 7b, the University offers an alternative implementation as follows due to resource constraints: By the fall 2022 admissions cycle, campuses that anticipate not being able to admit all eligible transfer applicants and do not have a two reader review process must develop a process to have a second read of a random sample of transfer applicants, excluding applicants guaranteed admission.

California State Auditor's Assessment of 60-Day Status: Pending

The Office of the President provided the letter it sent to the campus chancellors. We will consider this recommendation fully implemented when the Office of the President adopts formal requirements that campuses take these actions. Because conducting a second read for only a sample of transfer applicants would not afford all transfer applicants two independent reads, which could affect the fairness of the evaluation of their application, we stand by our recommendation that campuses that do not admit all eligible transfer students conduct two reads of applications from all eligible transfer students.

Recommendation #8 To: University of California

To better ensure that implicit bias in the evaluation of applications does not affect applicants' chances at admission, the Office of the President should remove potentially biasing information from the application information that campuses can access.

1-Year Agency Response

Responses to basic and necessary data fields in the application - e.g. school name or location, personal insight essays, and awards and activities - can be construed as potentially biasing information, but serve as helpful and important admissions context. The removal of this information would be detrimental to UC's ability to enroll students from diverse and/or under-resourced backgrounds and severely damage the University's ability to consider admissions characteristics in context. Certain personal information furthers the effectiveness of UC's Comprehensive Review: Academic accomplishments in light of the applicant's life experiences and special circumstances. Many admissions factors are imperfect but, when used holistically and in context, the deficiencies are minimized and the benefits for achieving admissions policy goals are maximized.

Even if it were desirable to do so, it would be very challenging as a practical matter for UCOP to withhold application information from campuses as data - tied to the fields recommended for removal - are shared across many systems to support essential operations (e.g., financial aid, housing, general communications, etc.).

California State Auditor's Assessment of 1-Year Status: Will Not Implement

The University continues to suggest that all of the potentially biasing information that it shows to application readers is necessary for those readers to perform comprehensive review. That is not correct. As we describe in the report, UC Berkeley, UC San Diego, and UCLA all allow readers to see freshman applicants' names and native languages. UC Berkeley and UC San Diego further allow readers to see applicants' genders, and UC Berkeley and UCLA allow readers to see applicants' birthplaces. None of this information is among the factors that BOARS allows campuses to use to evaluate and select applicants for admission. Thus, providing it to readers is unnecessary for the evaluation process. Although an applicant may disclose potentially biasing information about themselves in other fields, such as the personal essay, the University can still take reasonable steps to reduce the impact of implicit bias by removing unnecessary fields from reader view.

6-Month Agency Response

Academic Affairs continues to evaluate the implementation of this recommendation.

California State Auditor's Assessment of 6-Month Status: Pending

60-Day Agency Response

The Office of the President is currently evaluating the implementation of this recommendation.

California State Auditor's Assessment of 60-Day Status: Pending

Recommendation #9 To: University of California

To ensure that it properly protects all admissions activity against improper influence, the Office of the President should require each campus's undergraduate admissions office to do the following:
- Identify all other campus departments that participate in or provide information that affects admissions decision making.
- Obtain, evaluate, and approve a description of the criteria and processes that these departments use in rating and selecting applicants to recommend for admission.
- Annually obtain a roster from each of these departments of the individuals who will participate in admissions decision making and their roles and ensure that no single individual is responsible for such decisions in any given department.
- Ensure that each individual whom a department includes on the roster it submits has received training on appropriate and inappropriate factors on which to base admissions decisions and has agreed to abide by the campus's conflict-of-interest policies with respect to admissions.

Annual Follow-Up Agency Response From September 2023

From November 2022 through January 2023, the Office of the President communicated with the State Auditor's office by phone and email to obtain additional detail on the specific documentation for each campus that the State Auditor found insufficient to fully implement this recommendation. Based on this feedback, we followed up with the campuses to update their policies and procedures to address the State Auditor's concerns.

California State Auditor's Assessment of Annual Follow-Up Status: Fully Implemented

The University has provided evidence that each campus has adopted policies and procedures for each element of the recommendation.

Annual Follow-Up Agency Response From October 2022

In March and April 2022, the Office of the President communicated with the State Auditor's office by phone and email to obtain additional detail on the specific documentation for each campus that the State Auditor found insufficient to fully implement this recommendation. Based on this feedback, we followed up with the campuses to update their policies and procedures to address the State Auditor's concerns.

California State Auditor's Assessment of Annual Follow-Up Status: Partially Implemented

The Office of the President provided documentation showing that all but one campus has fully implemented this recommendation. UC Riverside has developed processes for staff from academic departments to recommend students for admissions, but that one campus does not yet require all staff who recommend students for admission to adhere to the criteria we outline in the recommendation, such as training on appropriate and inappropriate factors on which to base admissions decisions.

1-Year Agency Response

The University president required all campuses to implement this recommendation and to document the processes and procedures, via a letter sent in November 2020. Campuses have submitted documentation that identifies participants who provide info for admissions decision-making and rosters of those involved in obtaining, evaluating and approving criteria/processes used in decision-making. Campuses also provided training materials on campus admissions policies and protocols. The Office of the President has reviewed each campus's submissions to ensure the new processes, procedures and training includes documentation of the systemwide policies within local policies and addresses the recommendation.

California State Auditor's Assessment of 1-Year Status: Partially Implemented

6-Month Agency Response

The University president has required all campuses to implement this recommendation and to document the processes and procedures, via a letter sent in November 2020. Campuses have submitted documentation that identifies participants who provide info for admissions decision-making and rosters of those involved in obtaining, evaluating and approving criteria/processes used in decision-making. Campuses also provided training materials on campus admissions policies and protocols. However, some campuses only referenced BOARS or UCOP policies. The Office of the President has reviewed each campus's submissions to ensure the new processes and procedures will address the recommendation. UCOP has requested documentation of the systemwide policies within local policies. UCOP is also seeking additional information in some of the training practices where gaps were identified.

California State Auditor's Assessment of 6-Month Status: Pending

The Office of the President indicated that it has made incomplete progress in implementing this recommendation. We requested that the Office of the President share the documentation that substantiated its progress thus far. The Office of the President stated that it had no documentation to share. Therefore, we cannot assess the validity of the statements in the response the Office of the President provided.

60-Day Agency Response

The University president has issued a letter to the campus chancellors to implement this recommendation immediately and provide documentation of follow-through no later than January 15, 2021.

California State Auditor's Assessment of 60-Day Status: Pending

The Office of the President provided the letter it sent to the campus chancellors. We will consider this recommendation fully implemented when the Office of the President adopts a formal requirement that campuses take these actions.

Recommendation #10 To: University of California

To better safeguard the integrity of the university's admissions processes, the Office of the President should, by July 2021, begin conducting regular audits of the admissions processes at each of its undergraduate campuses, ensuring that it reviews each campus at least once every three years. These audits should be conducted by systemwide audit staff and include, but not be limited to, verification of special talents, communication between admissions staff and external parties regarding applicants, and other avenues for inappropriate influence on admissions discussed in this report. The audits should also endeavor to identify inappropriate admissions activity and deficiencies in the admissions process. The Office of the President should make the results of the audits public.

Annual Follow-Up Agency Response From September 2023

The University recognizes admissions as an area of ongoing potential risk and is committed to conducting regular audits of campus admissions processes. In response to one of its own recommendations from the systemwide internal audit of admissions, in fiscal year 2020-21, UC Internal Audit performed retrospective reviews of donations to all nine undergraduate campuses to identify admissions decisions that could have been influenced by these donations. For fiscal years 2021-22 and 2022-23, Internal Audit expanded the scope of its retrospective reviews of donations to include procedures to identify undergraduate admissions decisions that could have been influenced by the applicant's relationship to a member of the Senior Management Group. As part of these audits, the systemwide Office of Ethics, Compliance and Audit Services (ECAS) reviews the analyses performed by the campus internal audit departments to ensure they are performed in accordance with the guidance issued by ECAS. UC Internal Audit will regularly audit campus admissions processes in future years to assess compliance with protocols and to ensure key risks are appropriately addressed.

California State Auditor's Assessment of Annual Follow-Up Status: Partially Implemented

As we have noted before, we will not consider this recommendation to be fully implemented until the Office of the President begins performing independent reviews of the campuses' admissions processes and until the scope of the audit is sufficient to address all of the areas of risk that we describe in the report.

Annual Follow-Up Agency Response From October 2022

The University recognizes admissions as an area of ongoing potential risk and is committed to conducting regular audits of campus admissions processes. In response to one of its own recommendations from the systemwide internal audit of admissions, in fiscal year 2020-21, UC Internal Audit performed retrospective reviews of donations to all nine undergraduate campuses to identify admissions decisions that could have been influenced by these donations. For fiscal year 2021-22, Internal Audit expanded the scope of its retrospective reviews of donations to include procedures to identify undergraduate admissions decisions that could have been influenced by the applicant's relationship to a member of the Senior Management Group. Internal Audit is conducting the same expanded scope audit in fiscal year 2022-23. As part of these audits, the systemwide Office of Ethics, Compliance and Audit Services (ECAS) reviews the analyses performed by the campus internal audit departments to ensure they are performed in accordance with the guidance issued by ECAS. UC Internal Audit will regularly audit campus admissions processes in future years to assess compliance with protocols and to ensure key risks are appropriately addressed.

California State Auditor's Assessment of Annual Follow-Up Status: Partially Implemented

As we have noted before, we will not consider this recommendation to be fully implemented until the Office of the President begins performing independent reviews of the campuses' admissions processes and until the scope of the audit is sufficient to address all of the areas of risk that we describe in the report.

1-Year Agency Response

The University recognizes admissions as an area of ongoing potential risk and is committed to conducting regular audits of campus admissions processes. In response to one of its own recommendations from the systemwide internal audit of admissions, in fiscal year 2020-21, UC Internal Audit performed retrospective reviews of donations to all nine undergraduate campuses to identify admissions decisions that could have been influenced by these donations. For fiscal year 2021-22, Internal Audit is expanding the scope of its retrospective reviews of donations to include procedures to identify undergraduate admissions decisions that could have been influenced by the applicant's relationship to a member of the Senior Management Group. UC Internal Audit will continue the expanded admissions audit activities implemented this past year and will regularly audit campus admissions processes in future years to assess compliance with protocols and to ensure key risks are appropriately addressed.

California State Auditor's Assessment of 1-Year Status: Partially Implemented

As we noted during its six month update, the audit plan that the Office of the President provided indicated that the campuses would conduct these audits themselves. Additionally, even if the campuses expand the scope of the audits to include reviews of relationships to certain staff at the University, the scope of the audit still will not address all of the areas we describe in the recommendation, such as verification of talent. We will not consider this recommendation to be fully implemented until the Office of the President begins performing independent reviews of the campuses' admissions processes, and until the scope of the audit is sufficient to address all of the areas of risk that we describe in the report.

6-Month Agency Response

The University recognizes admissions as an area of ongoing potential risk and is committed to conducting regular audits of campus admissions processes. In response to one of its own recommendations from the systemwide internal audit of admissions, in fiscal year 2020-21, UC Internal Audit initiated retrospective reviews of donations to all nine undergraduate campuses to identify admissions decisions that could have been influenced by these donations. Those reviews are currently in progress. Internal Audit is currently evaluating the scope and approach of admissions audits to be conducted in fiscal year 2021-22.

California State Auditor's Assessment of 6-Month Status: Pending

As the Office of the President indicates, it has not yet completed this recommendation and is still assessing the scope and approach to admissions audits. To that end, we assess this recommendation as pending implementation.

To add clarity to the Office of the President's response: the documentation the Office of the President submitted shows that the retrospective reviews of donations and the potential for influence on admissions decisions are reviews being performed by the campuses' internal audit units. This is the same approach the University used to perform its initial review of admissions processes, which we found had resulted in deficient reviews. As it considers its approach to the admissions audits of the future, the Office of the President must ensure that it performs independent reviews of the campuses' admissions processes.

60-Day Agency Response

The Office of the President is currently evaluating the implementation of this recommendation.

California State Auditor's Assessment of 60-Day Status: Pending

Recommendation #11 To: University of California

To ensure that campuses adequately address deficiencies identified in its own internal audit, the Office of the President should immediately begin to assess whether the campuses have completed the corrective actions they developed in response to systemwide recommendations and should evaluate whether the campuses' actions adequately address the audit's concerns.

1-Year Agency Response

The Office of Ethics, Compliance and Audit Services (ECAS) has completed its independent review and evaluation of the implementation status of all recommendations from the Phase 1 and Phase 2 systemwide internal audits of admissions for all nine campuses. ECAS has verified that all nine campuses have completed the corrective actions they developed in response to systemwide recommendations and that the campuses' actions adequately address the audit's concerns.

California State Auditor's Assessment of 1-Year Status: Fully Implemented

The Office of the President provided the records that it used to track implementation of its recommendations by campuses, which indicates that all campuses provided documentation to the Office of the President demonstrating that they had fully implemented its recommendations. Therefore, we assess this recommendation to be Fully Implemented. However, as we describe in the audit report, the university's internal audit and its recommendations did not address significant aspects of the admissions process that we reviewed during our audit. Furthermore, our recommendations are stronger than those made by the university's internal audit and address serious deficiencies that it did not identify. Left unaddressed, these issues will continue to harm qualified applicants who apply to the university.

6-Month Agency Response

The Office of Ethics, Compliance and Audit Services (ECAS) has independently reviewed and evaluated the implementation status of all recommendations from the Phase 1 and Phase 2 systemwide internal audits of admissions for all nine campuses. For Phase 1, it has confirmed that all of the recommendations have been fully implemented by seven of the nine undergraduate campuses. For Phase 2, it has confirmed that all of the recommendations have been fully implemented by eight of the nine undergraduate campuses. To substantiate full implementation of the recommendations by the remaining campuses, ECAS is working with them to ensure that outstanding questions on the supporting documentation are appropriately addressed.

California State Auditor's Assessment of 6-Month Status: Partially Implemented

We reviewed a selection of the recommendations from the University's internal audits and found that the Office of the President has validated the adoption of policies and procedures in response to its recommendations. We will reassess the progress the Office of the President has made in this area at its next response interval.

60-Day Agency Response

The Office of Ethics, Compliance and Audit Services (ECAS) has initiated a review to independently evaluate the implementation of all recommendations from the two-phased systemwide internal audit of admissions at each undergraduate campus, which have previously been reviewed and validated by the campus internal audit departments per UC's standard protocol. As part of this review, ECAS will inspect evidence provided by the campuses to substantiate fully implementation of the recommendations. ECAS will follow up with the campuses on any deficiencies noted to ensure full implementation of the recommendations.

California State Auditor's Assessment of 60-Day Status: Pending

We will consider this recommendation fully implemented when the Office of the President provides evidence of its review and confirmation that campuses have adequately implemented the internal audit report's corrective actions.

Recommendation #12 To: University of California

To increase the number of high school students who have the opportunity to gain admission to the university through its ELC program, the Office of the President should, beginning in
April 2021, do the following:
- Annually determine which high schools are eligible to participate in ELC but do not. It should annually report to BOARS the number of these high schools and their demographic
characteristics.
- Annually contact eligible high schools that are not participating in ELC to determine their reasons for choosing not to do so. It should assess whether the university can address barriers to participation and, to the extent that it can increase participation, it should take the steps to do so.

1-Year Agency Response

A survey was sent to non-participating and non-responsive schools to collect and evaluate what barriers to participation exist. As a result of the survey responses, UCOP will augment the manner in which information about ELC is routinely shared with high schools and continue to explore ways to streamline the data submission process.

California State Auditor's Assessment of 1-Year Status: Fully Implemented

The Office of the President provided a report summarizing its efforts to address this recommendation, which included performing outreach to eligible schools that do not participate in ELC and conducting a survey to identify the reasons that those schools do not participate. The report further describes the efforts that the Office of the President will take to address the barriers to participation that the schools reported in their surveys; one such effort included annual outreach to nonparticipating schools.

6-Month Agency Response

The annual outreach campaign for ELC participation commenced in February 2021. An invitation to join ELC was sent to nearly 1,000 schools not currently participating in ELC. It should be noted that not all schools are necessarily eligible to participate but information was included on how to determine eligibility, expectations of participating schools, as well as contact information for the program. Schools will have until June 30 to signal their intent to participate.

California State Auditor's Assessment of 6-Month Status: Partially Implemented

Contrary to the Office of the President's response status, there are elements of this recommendation that remain unaddressed. The Office of the President sent a standardized email in February 2021 to almost 1,000 high schools inviting them to join the ELC program. This action does not address our recommendation to:

-Determine the reasons why schools do not participate.

-Assess whether the university can address barriers to participation and take steps to do so.

60-Day Agency Response

The University has submitted its first annual report on schools not-participating in ELC to BOARS on 10/20/2020. This spring, UCOP will survey schools to assess reasons for non-participation in order to determine if it is due to lack of knowledge of ELC, lack of resources or something more. For schools where the reason is the latter, simple outreach and encouragement to join ELC will not help students achieve higher levels of A-G completion and general college readiness. Undergraduate Admissions has initiated engagement with Graduate Undergraduate and Equity Affairs colleagues to explore ways in which UC can leverage SAPEP programs and resources such as the Transcript Evaluation Service to further support college-readiness at non-participating schools as well as develop potential efficiencies in data exchange to facilitate ELC participation. Undergraduate Admissions will report back to BOARS annually on its progress.

California State Auditor's Assessment of 60-Day Status: Partially Implemented

The Office of the President provided its report to BOARS, and the report contained information on the number of schools not participating in ELC as well as the schools' demographics.

The second part of our recommendation is to conduct annual outreach to schools that are eligible for ELC but not participating. The purpose of this recommendation is to encourage more schools to participate to allow students who attend those schools and would otherwise be eligible for guaranteed admission to the University to take advantage of that benefit. This recommendation will be fully implemented when the Office of the President provides evidence that it has conducted outreach to nonparticipating schools and made efforts to increase their participation in the ELC program.

All Recommendations in 2019-113

Agency responses received are posted verbatim.