2024-04-23T19:04:24-05:00 2023-06-30 366055558 GRANT THORNTON LLP 1000 WILSON BLVD SUITE 1500 ARLINGTON VA 22209 990 2022-07-01 231627436 PEIRCE COLLEGE PEIR 2156709128 1608 WALNUT STREET SUITE 1900 PHILADELPHIA PA 19103 ELIZABETH KRAPP VP, FINANCE/ADMIN & TREASURER 2156709128 2024-04-23 1 ELIZABETH KRAPP XXX-XX-XXXX 0 MARY TORRETTA P00847851 7038477500 2 AAL1 IAL1 2022 2023-04-26 12:10:37Z X DR MARY ELLEN CARO 1608 WALNUT STREET SUITE 1900 PHILADELPHIA PA 19103 18314841 0 X WWW.PEIRCE.EDU X 1963 PA SEE SCHEDULE O 13 13 177 14 0 0 8244953 4997951 11908138 10666776 1511430 1299733 390019 224954 22054540 17189414 6473230 5050478 0 0 10864226 10555799 0 0 329658 5052966 5404376 22390422 21010653 -335882 -3821239 35094756 38047512 3933006 9579068 31161750 28468444 X SEE SCHEDULE O 0 0 17657612 5050478 10666776 SEE SCHEDULE O 17657612 1 1 0 1 0 0 0 0 0 1 1 0 0 1 1 1 1 0 1 0 0 0 0 0 0 0 0 0 1 1 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 1 1038 0 1 177 1 0 0 0 0 0 0 0 0 0 0 0 0 X 13 13 0 0 0 0 0 0 0 1 1 0 0 1 1 1 1 1 1 1 1 0 PA X ELIZABETH KRAPP 2156709128 1420 PINE STREET PHILADELPHIA PA 19102 TONI PERGOLIN CHAIR 1.00 0.00 X 0 0 0 DAVID SILVERMAN BOARD MEMBER 1.00 0.00 X 0 0 0 SCOTT D SMITH BOARD MEMBER 1.00 0.00 X 0 0 0 LISA S WALKER BOARD MEMBER 1.00 0.00 X 0 0 0 RENEE B YANCEY BOARD MEMBER 1.00 0.00 X 0 0 0 SHEILA IRELAND BOARD MEMBER 1.00 0.00 X 0 0 0 KEITH DAVISTON BOARD MEMBER 1.00 0.00 X 0 0 0 STEVEN SCOTT BRADLY BOARD MEMBER 1.00 0.00 X 0 0 0 ROBERT GRASSO BOARD MEMBER 1.00 0.00 X 0 0 0 TOM KARINSHAK BOARD MEMBER 1.00 0.00 X 0 0 0 TOM MCLAUGHLIN VICE CHAIR 1.00 0.00 X 0 0 0 SHARMAIN MATLOCK-TURNER BOARD MEMBER 1.00 0.00 X 0 0 0 JOSHUA W RICHARDS BOARD MEMBER 1.00 0.00 X 0 0 0 MARCOS R LOPEZ BOARD MEMBER (THRU 7/22) 1.00 0.00 X 0 0 0 DR MARY ELLEN CARO PRESIDENT AND CEO 40.00 0.00 X 757307 0 31558 ELIZABETH M KRAPP VP FINANCE/ADMIN & TREASURER 40.00 0.00 X 252215 0 22519 AMANDA HILL SR DIR MARKETING & INTERIM SECRETARY 40.00 0.00 X 96409 0 16210 TARA MCBRIDE EXEC ASST TO PRESIDENT & SECRETARY 40.00 0.00 X 90020 0 16599 JOSEPH GUZZARDO VP MARKETING/COMMUNICATIONS 40.00 0.00 X 233955 0 30202 BRAD HODGE VP ENROLL/STUDENT SERVICES 40.00 0.00 X 174654 0 20211 DR RITA TOLIVER-ROBERTS PROVOST & VP ACADEMIC AFFAIRS 40.00 0.00 X 245082 0 42657 CARRIE ROBINSON AVP HUMAN RESOURCES/CHIEF DEI OFFICER 40.00 0.00 X 153507 0 36764 ADRIAN ZAPPALA DEAN OF GRADUATE STUDIES 40.00 0.00 X 145707 0 38212 JAMES BURNS CHIEF INFORMATION OFFICER 40.00 0.00 X 144306 0 30786 DEBRA SCHRAMMEL ASSISTANT VP, INSTITUTIONAL ASSESSMENT 40.00 0.00 X 143056 0 20283 STEPHANIE DONOVAN PROF & FACULTY CHAIR, BUSINESS 40.00 0.00 X 141489 0 29735 2577707 0 335736 16 0 1 0 DCW MEDIA 895 MARCONI AVE RONKONKOMA NY 11779 ADVERTISING 822000 CAPTURE LLC 2303 RIVER ROADSUITE 201 LOUISVILLE KY 40206 LEAD MANAGEMENT 205763 GRANT THORNTON LLP 33960 TREASURY CENTER CHICAGO IL 60694 AUDIT/TAX 138002 SALESFORCEORG 50 FREMONT STSUITE 300 SAN FRANCISCO CA 94105 SOFTWARE 125562 JENZABAR 101 HUNTINGTON AVE BOSTON MA 02199 LICENSES 121714 5 4632027 365924 4997951 TUITION AND FEES 611310 10666776 10666776 10666776 633395 633395 1791765 1125427 666338 666338 666338 NON-CREDIT FEES 900099 112688 112688 ALL OTHER 900099 112266 112266 224954 17189414 10666776 0 1524687 5050478 5050478 1580746 1123553 435670 21523 6827979 5912642 879613 35724 388034 310610 61422 16002 1199377 885087 267171 47119 559663 482758 74130 2775 89745 89745 142601 142601 65000 65000 51683 51683 1089095 802182 228065 58848 843260 843260 176829 168624 8118 87 946296 857345 60563 28388 522421 473314 33435 15672 16595 15920 5 670 23778 22400 1278 100 230903 230903 634619 574964 40616 19039 177360 177360 AR PROVISION FOR LOSS 230260 230260 ALL OTHER 146264 54168 8528 83568 MEALS AND BANQUETS 17667 15307 2217 143 21010653 17657612 3023383 329658 555925 322308 4622 2071 802111 537696 675145 776327 0 0 0 0 376671 462205 24931650 17178515 8131845 7753135 24489021 24786058 59416 61860 0 0 0 3345852 35094756 38047512 1033094 745750 170815 173551 2479097 2335764 250000 3500000 0 2824003 3933006 9579068 X 27489205 24848866 3672545 3619578 31161750 28468444 35094756 38047512 -3821239 1127933 0 X 0 1 X 1 1 1 X RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED 0 0 0 0 0 0 1 65000 0 0 65000 0 PART II-B, LINE 1G ATTENDED MEETINGS WITH MEMBERS OF THE PENNSYLVANIA HOUSE AND SENATE IN ORDER TO EDUCATE MEMBERS ON PEIRCE COLLEGE AND TO DISCUSS THE IMPACT OF THE COLLEGE ON THE SURROUNDING REGION. THE GOAL OF THESE MEETINGS WAS TO RAISE THE PROFILE OF PEIRCE COLLEGE AND SEEK PARTNERSHIPS WITH THE COMMONWEALTH OF PENNSYLVANIA. 3395823 1237 336925 113140 23401 7079 3590365 4086797 3065 -561974 104573 21727 5765 3395823 3309000 3462 900309 100702 21012 4260 4086797 3271824 4090 151809 94934 19835 3954 3309000 3175705 5848 203515 90566 18783 3895 3271824 0.18080 0.16280 0.65640 1 0 27670 27670 19140506 13275052 5865454 139955 13995 125960 5623519 3889468 1734051 0 7753135 LEASE RIGHT OF USE ASSET 2697252 OTHER RECEIVABLE 648600 3345852 LEASE RIGHT OF USE LIABILITY 2824003 2824003 X 13572515 1127933 -1858610 -730677 14303192 51683 2834539 2886222 17189414 16265821 -2834539 -2834539 19100360 51683 1858610 1910293 21010653 PART V, LINE 4: INTENDED USE OF ENDOWMENT FUNDS: THE COLLEGE'S ENDOWMENT CONSISTS OF DONOR-RESTRICTED AND BOARD DESIGNATED FUNDS TO BE HELD IN PERPETUITY, WITH INCOME BEING USED FOR SCHOLARSHIPS, OPERATING EXPENSES, AND FACULTY AWARDS. PART X, LINE 2: AS OF JUNE 30, 2023 AND 2022, MANAGEMENT DETERMINED THAT THE COLLEGE HAS NO MATERIAL UNCERTAIN TAX POSITIONS THAT WOULD REQUIRE RECOGNITION OR DISCLOSURE IN ITS FINANCIAL STATEMENTS. PART XI, LINE 2D - OTHER ADJUSTMENTS: RECLASS OF SCHOLARSHIPS -1,858,610. PART XI, LINE 4B - OTHER ADJUSTMENTS: RECLASS OF PELL/PHEAA 2,834,539. PART XII, LINE 2D - OTHER ADJUSTMENTS: RECLASS OF PELL/PHEAA -2,834,539. PART XII, LINE 4B - OTHER ADJUSTMENTS: RECLASS OF SCHOLARSHIPS 1,858,610. 1 1 1 1 1 1 1 0 0 0 0 0 0 0 0 1 0 1 SCHEDULE E, PART I, LINE 6 GOVERNMENT ASSISTANCE: PEIRCE COLLEGE RECEIVED ASSISTANCE FROM THE U.S. DEPARTMENT OF EDUCATION FOR THE FOLLOWING PROGRAMS: FEDERAL PELL GRANT, FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANT, FEDERAL WORK STUDY, STRENGTHENING MINORITY SERVING INSTITUTIONS (PBI COMPETITIVE), HIGHER EDUCATION - INSTITUTIONAL AID (PBI FORMULA), AND CAREER & TECHNICAL EDUCATION GRANT. PEIRCE COLLEGE ALSO RECEIVED A PENNSYLVANIA HIGHER EDUCATION ASSISTANCE AGENCY GRANTS FOR STUDENTS AND AN INSTITUTIONAL ASSISTANCE GRANT. SCHEDULE E, PART I, LINE 3 PEIRCE COLLEGE IS AN EQUAL OPPORTUNITY INSTITUTION. THE COLLEGE IS COMMITTED TO ENSURING EQUAL OPPORTUNITY IN ALL EMPLOYMENT DECISIONS, POLICIES AND PRACTICES, AND IN CONNECTION WITH ALL EDUCATIONAL PROGRAMS AND ACTIVITIES, INCLUDING BUT NOT LIMITED TO RECRUITMENT, ADMISSIONS, ACCESS TO PROGRAMS AND COURSE OFFERINGS, COUNSELING, FINANCIAL AID AND SCHOLARSHIPS, EMPLOYMENT, USE OF FACILITIES, AND COLLEGE-SPONSORED EXTRACURRICULAR ACTIVITIES. THE COLLEGE WILL NOT ENGAGE IN OR TOLERATE UNLAWFUL DESCRIMINATION, HARASSMENT, OR RETALIATION ON THE BASIS OF RACE, GENDER, ETHNICITY, RELIGION, A RELIGIOUS GROUP'S ACTUAL OR PERCEIVED SHARED ANCESTRY OR ETHNIC CHARACTERISTICS, AGE, NATIONAL ORIGIN, COLOR, DISABILITY, MARITAL STATUS, FAMILIAL STATUS, VETERAN STATUS, ANCESTRY, GENETIC CHARACTERISTICS, PREGNANCY, CHILDBIRTH, OR MEDICAL CONIDTIONS RELATED TO PREGNANCY OR CHILDBIRTH, CREED, CITIZENSHIP, SEXUAL ORIENTATION, GENDER IDENTITY OR EXPRESSION, MILITARY STATUS OR ANY OTHER PROTECTED CLASSIFICATIONS IN ITS EMPLOYMENT, ADMISSIONS PROGRAMS AND ACTIVITIES AS REQUIRED BY TITLE IX OF THE EDUCATIONAL AMENDMENTS OF 1972, THE AMERICANS WITH DISABILITY ACT OF 1990, SECTION 504 OF THE REHABILIATION ACT OF 1973, TITLE VII OF THE CIVIL RIGHTS ACT OF 1964, THE AGE DISCRIMINATION ACT OF 1975, AND OTHER APPLICABLE STATUTES AND COLLEGE POLICIES. THE COLLEGE'S POLICY ON EQUAL OPPORTUNITY SUPPORTS AND IS CONSISTENT WITH THE COLLEGE'S COMMITMENT TO DIVERSITY, EQUITY, INCLUSION AND BELONGING. 1 FEDERAL PELL GRANT 612 1939339 SCHOLARSHIPS 982 1858610 PHEAA STATE GRANT 297 895200 FELLOWSHIPS 217 357329 SCHEDULE I, PART I, LINE 2 PROCEDURE FOR MONITORING USE OF GRANT FUNDS INSIDE U.S.: ALL FINANCIAL AID GRANTS ARE USED FOR THE INTENDED PURPOSE WHICH IS TO PROVIDE AID TO STUDENTS WITH FINANCIAL NEED TO COVER THE STUDENTS' COST OF ATTENDANCE. THESE GRANTS INCLUDE FEDERAL PELL GRANTS, FEDERAL SEOG GRANTS, AND STATE PHEAA GRANTS. THE COLLEGE ALSO PROVIDES INSTITUIONAL AND DONOR RESTRICTED GRANTS TO ELIGIBLE STUDENTS. THE GRANTS ARE AWARDED AND POSTED TO THE ELIGIBLE STUDENTS' ACCOUNTS BY THE FINANCIAL AID OFFICE. THESE ACCOUNTS ARE RECONCILED BY THE ACCOUNTING DEPARTMENT AND THE FINANCIAL AID OFFICE ON A MONTHLY BASIS. THE FINANCIAL AID OFFICE COMPLIES WITH THE U.S. DEPARTMENT OF EDUCATION GUIDELINES AS WELL AS ANY DONOR RESTRICTIONS. THE FINANCIAL AID OFFICE REPORTS STUDENT GRANT AWARDS TO THE U.S. DEPARTMENT OF EDUCATION AND PHEAA THROUGHOUT THE YEAR AND ALSO SUBMITS THE REQUIRED ANNUAL FISAP REPORT TO THE U.S. DEPARTMENT OF EDUCATION. ANNUALLY THE COLLEGES' EXTERNAL INDEPENDENT AUDITOR ISSUES THE FINANCIAL STATEMENT AND REPORT OF INDEPENDENT CERTIFIED PUBLIC ACCOUNTANTS AS REQUIRED BY TITLE 2 U.S. CODE OF FEDERAL REGULATIONS PART 200, UNIFORM ADMINISTRATIVE REQUREMENTS, COST PRINCIPLES, AND AUDIT REQUIREMENTS FOR FEDERAL AWARDS AND GOVERNMENT AUDITING STANDARDS. X X X X 0 0 0 0 0 0 0 1 0 DR MARY ELLEN CARO PRESIDENT AND CEO 366354 0 383135 0 7818 0 18300 0 13258 0 788865 0 0 0 DR RITA TOLIVER-ROBERTS PROVOST & VP ACADEMIC AFFAIRS 194370 0 50000 0 712 0 12102 0 30555 0 287739 0 0 0 ELIZABETH M KRAPP VP FINANCE/ADMIN & TREASURER 200180 0 50000 0 2035 0 12045 0 10474 0 274734 0 0 0 JOSEPH GUZZARDO VP MARKETING/COMMUNICATIONS 183301 0 50000 0 654 0 11256 0 18946 0 264157 0 0 0 BRAD HODGE VP ENROLL/STUDENT SERVICES 174267 0 0 0 387 0 10487 0 9724 0 194865 0 0 0 CARRIE ROBINSON AVP HUMAN RESOURCES/CHIEF DEI OFFICE 152972 0 0 0 535 0 9594 0 27170 0 190271 0 0 0 ADRIAN ZAPPALA DEAN OF GRADUATE STUDIES 145426 0 0 0 281 0 8156 0 30056 0 183919 0 0 0 JAMES BURNS CHIEF INFORMATION OFFICER 142896 0 0 0 1410 0 8816 0 21970 0 175092 0 0 0 STEPHANIE DONOVAN PROF & FACULTY CHAIR, BUSINESS 141196 0 0 0 293 0 8426 0 21309 0 171224 0 0 0 DEBRA SCHRAMMEL ASSISTANT VP, INSTITUTIONAL ASSESSME 140419 0 0 0 2637 0 8559 0 11724 0 163339 0 0 0 PART I, LINE 7 NON-FIXED PAYMENTS: THE CHIEF EXECUTIVE OFFICER OF THE COLLEGE PARTICIPATES IN A BOARD OF TRUSTEES APPROVED EXECUTIVE COMPENSATION PROGRAM WHICH INCLUDES AN INCENTIVE COMPENSATION PLAN. THE ANNUAL AMOUNT IS CAPPED AT A PERCENTAGE OF SALARY. THE PLAN IS BASED ON THE ACHIEVEMENT OF CERTAIN INSTITUTIONAL GOALS. THE PLAN IS APPROVED BY THE EXECUTIVE COMMITTEE, WHICH REVIEWS AND APPROVES THE ANNUAL AWARD BASED ON THE PERFORMANCE ACHIEVED ON THE AGREED UPON GOALS. FORM 990, PART I, LINE 1 DESCRIPTION OF ORGANIZATION MISSION: PEIRCE COLLEGE IS A PRIVATE ACCREDITED INSTITUTION OFFERING CERTIFICATES/ASSOCIATE/BACHELOR/MASTER DEGREES IN CAREER ORIENTED PROGRAMS GEARED TOWARDS ADULT LEARNERS. FORM 990, PART III, LINE 1 ORGANIZATION'S MISSION: PEIRCE COLLEGE EMPOWERS ADULT LEARNERS TO IMPROVE THEIR LIVES BY ACHIEVING CAREER GOALS THROUGH ACADEMIC OFFERINGS ALIGNED WITH EVOLVING WORKFORCE NEEDS. FORM 990, PART III, LINE 4A PROGRAM SERVICE: FOUNDED IN 1865, PEIRCE COLLEGE IS A PRIVATE INSTITUTION PROVIDING PRACTICAL LEADING-EDGE CURRICULA TO PRIMARILY WORKING ADULT LEARNERS. THE COLLEGE AWARDS MASTER, BACHELOR, AND ASSOCIATE DEGREES AS WELL AS CERTIFICATES IN BUSINESS, HEALTH CARE, INFORMATION TECHNOLOGY, LIBERAL STUDIES AND LEGAL STUDIES. PEIRCE COLLEGE IS ACCREDITED BY THE MIDDLE STATES COMMISSION ON HIGHER EDUCATION.THE BACHELOR OF SCIENCE, ASSOCIATE OF SCIENCE AND THE CERTIFICATE OF PROFICIENCY IN PARALEGAL STUDIES ARE RECOGNIZED AND APPROVED BY THE AMERICAN BAR ASSOCIATION (ABA). THE ACCREDITATION COUNCIL FOR BUSINESS SCHOOLS AND PROGRAMS (ACBSP) ACCREDITS PEIRCE COLLEGE'S BACHELOR, ASSOCIATE AND CERTIFICATES OF PROFICIENCY IN BUSINESS ADMINISTRATION AND ACCOUNTING. FORM 990, PART VI, SECTION B, LINE 11B THE FORM 990 WAS PREPARED BY A NATIONALLY RENOWNED ACCOUNTING FIRM IN CONJUNCTION WITH THE ORGANIZATION'S FINANCE DEPARTMENT. THE FORM IS THEN SUBMITTED TO THE AUDIT, RISK & COMPLIANCE COMMITTEE OF THE BOARD FOR APPROVAL. A COPY OF THE DRAFT 990 IS THEN CIRCULATED TO THE FULL BOARD OF TRUSTEES FOR DISCUSSION AND COMMENT PRIOR TO FILING WITH THE INTERNAL REVENUE SERVICE. FORM 990, PART VI, SECTION B, LINE 12C CONFLICT OF INTEREST POLICY MONITORING & ENFORCEMENT: ANNUALLY THE COLLEGE REQUIRES EACH EMPLOYEE, INCLUDING THE PRESIDENT/CEO AND OTHER KEY EMPLOYEES, TO COMPLETE AND SIGN A CONFLICT OF INTEREST QUESTIONNAIRE TO DETERMINE IF THE EMPLOYEE HAS A RELATIONSHIP, FINANCIAL INTEREST OR BUSINESS AFFILIATION THAT COULD RESULT IN A CONFLICT OF INTEREST. EMPLOYEES ARE REQUIRED TO UPDATE THEIR DISCLOSURE IF AT ANY TIME THEIR CIRCUMSTANCES CHANGE. THESE QUESTIONNAIRES ARE RETURNED TO HUMAN RESOURCES FOR REVIEW TO DETERMINE IF ANY FURTHER ACTION IS REQUIRED. ANNUALLY THE COLLEGE REQUIRES EACH TRUSTEE, INCLUDING TRUSTEE OFFICERS, TO COMPLETE AND SIGN A CONFLICT OF INTEREST QUESTIONNAIRE TO DETERMINE IF THE TRUSTEE HAS A RELATIONSHIP, FINANCIAL INTEREST OR BUSINESS AFFILIATION THAT COULD RESULT IN A CONFLICT OF INTEREST. TRUSTEES ARE REQUIRED TO UPDATE THEIR DISCLOSURE IF AT ANY TIME THEIR CIRCUMSTANCES CHANGE. THESE QUESTIONNAIRES ARE RETURNED TO THE BOARD SECRETARY FOR REVIEW BY THE OFFICE OF THE PRESIDENT TO DETERMINE IF ANY FURTHER ACTION IS REQUIRED. IF A POTENTIAL CONFLICT OF INTEREST IS IDENTIFIED, THE FOLLOWING PROCEDURES ARE FOLLOWED: (A) AN INTERESTED PERSON MAY PARTICIPATE IN A BOARD OR COMMITTEE MEETING, BUT AFTER THE PRESENTATION, HE/SHE SHALL LEAVE THE MEETING DURING THE DISCUSSION OF, AND THE VOTE ON, THE BUSINESS RELATIONSHIP INVOLVING THE POSSIBLE CONFLICT OF INTEREST. (B) THE CHAIR PERSON OF THE BOARD OR COMMITTEE SHALL, IF APPROPRIATE, APPOINT A DISINTERESTED PERSON OR COMMITTEE TO INVESTIGATE ALTERNATIVES TO THAT PROPOSED BUSINESS RELATIONSHIP. (C) AFTER EXERCISING DUE DILIGENCE, THE BOARD OR COMMITTEE SHALL DETERMINE WHETHER THE COLLEGE CAN OBTAIN WITH REASONABLE EFFORTS A MORE ADVANTAGEOUS BUSINESS RELATIONSHIP FROM A PERSON OR ENTITY THAT WOULD NOT GIVE RISE TO A CONFLICT OF INTEREST. (D) IF A MORE ADVANTAGEOUS BUSINESS RELATIONSHIP IS NOT REASONABLY POSSIBLE UNDER CIRCUMSTANCES NOT PRODUCING A CONFLICT OF INTEREST, THE BOARD OR COMMITTEE SHALL DETERMINE BY A MAJORITY VOTE OF THE DISINTERESTED TRUSTEES IF THE BUSINESS RELATIONSHIP IS IN THE COLLEGE'S BEST INTEREST, FOR ITS OWN BENEFIT, AND IF IT IS FAIR AND REASONABLE. BASED ON THAT DETERMINATION, THE BOARD OR COMMITTEE WILL DECIDE WHETHER OR NOT TO ENTER INTO THE BUSINESS RELATIONSHIP. FORM 990, PART VI, SECTION B, LINE 15 FORM 990, PART VI, LINE 15A PROCESS FOR DETERMINING COMPENSATION: MARY ELLEN CARO WAS ELECTED PRESIDENT AND CEO OF PEIRCE COLLEGE IN APRIL OF 2018. THE COMPENSATION ESTABLISHED FOR CARO WAS DETERMINED AS A RESULT OF A COMPENSATION STUDY COMMISSIONED BY THE BOARD OF TRUSTEES IN 2017 AS PART OF THE PRESIDENTIAL SEARCH. THE COMPENSATION DATA WAS COMPILED USING INFORMATION FROM OTHER COLLEGES AND UNIVERSITIES AS A GUIDE IN DETERMINING REASONABLE COMPENSATION FOR THE PRESIDENT POSITION. AFTER REVIEWING THAT DATA, THE COMPENSATION WAS DETERMINED TO BE REASONABLE BY INDEPENDENT MEMBERS OF THE BOARD AND CONTEMPORANEOUSLY DOCUMENTED IN THE MEETING MINUTES. ANNUALLY, THE BOARD OF TRUSTEES REVIEWS DR. CARO'S COMPENSATION. FORM 990, PART VI, LINE 15B PROCESS FOR DETERMINING COMPENSATION: THE COMPENSATION FOR THE KEY EMPLOYEES OF PEIRCE COLLEGE WAS DETERMINED BY LOCAL AND REGIONAL MARKET SURVEYS AND INFORMATION AND DATA FROM LOCAL AND REGIONAL PUBLICATIONS AND PAPERS. THIS INFORMATION, ALONG WITH INTERNAL EQUITY, DETERMINE THE BASIS HIRE-IN SALARY OF KEY EMPLOYEES. ANNUALLY, KEY EMPLOYEES ARE EVALUATED BY THE PRESIDENT USING A PERFORMANCE REVIEW WHICH IS THE STANDARD REVIEW USED BY ALL EMPLOYEES THROUGHOUT THE COLLEGE. THIS PROCESS ALSO DETERMINES THE PERCENT OF MERIT INCREASES RECEIVED. THE MERIT INCREASE PERCENTAGES ARE DETERMINED AS PART OF THE BUDGET PROCESS AND THE LEVEL OF PERCENTAGE INCREASES GIVEN TO THE KEY EMPLOYEES IS BASED ON THE SCORING OUTCOME OF THEIR PERFORMANCE REVIEW. FORM 990, PART VI, SECTION C, LINE 19 HOW DOCUMENTS ARE MADE AVAILABLE TO THE PUBLIC: THE COLLEGE MAKES ITS FORM 990 AVAILABLE TO THE PUBLIC BY RESERVING A COPY AT ITS PLACE OF BUSINESS. THE FORM 990 IS LIKEWISE PUBLISHED ON THE INTERNET AT WWW.GUIDESTAR.ORG. PEIRCE COLLEGE MAKES ITS CONFLICT OF INTEREST POLICY, GOVERNING DOCUMENTS AND FINANCIAL STATEMENTS AVAILABLE TO THE PUBLIC TO THE EXTENT REQUIRED BY LAW.