Wasc Senior College and University Commission

“The draft form 990 was reviewed by audit committee. Once audit committee has approved, the draft form 990 was made available for all commissioners to review before filing. Commissioners had roughly 2 weeks to comment.”

“All officers, directors, and employees, as well as all volunteers who participate as peer reviewers are covered under the policy. Determinations are made by the chair of the commission if it has to do with commissioners and commissioner business, by the president if the chair has a conflict and for other commissioner engagement, and by the executive vice president when it relates to peer reviewers and institutions. If a conflict is determined to exist, that individual is not permitted to participate in the activity. If it is possible to create restrictions related to a conflict, so that the individual can participate, those restrictions will be unique to the occasion. Commission staff are committed to full disclosure and restraint in any institutional consideration or business decision involving a conflict of interest or appearance of conflict. Staff members will absent themselves from deliberations on decisions regarding institutions as to which they have a conflict of interest or appearance of a conflict that warrants recusal.”

“The commission has a bylaws-designated compensation committee. About once every four years the commission contracts with an expert independent organization to conduct a compensation study of all of its employees. During the in-between years, these data are updated for key personnel using the form 990 of similar agencies. The compensation committee specifically establishes that it has reviewed these data and determined that compensation for key employees are appropriate, creating a safe harbor, and these determinations are codified and preserved in minutes. The compensation committee members are, by definition, independent.”

“AVAILABLE UPON REQUEST.”

“The organization makes its governing documents and conflict of interest policy available to the public on the organization's website for the same period of time set forth in sec. 6104(d).”