2021-02-25T08:02:12-06:00 2020-06-30 366055558 GRANT THORNTON LLP 1000 WILSON BLVD SUITE 1400 ARLINGTON VA 22209 990 2019-07-01 231627436 PEIRCE COLLEGE PEIR 2156709128 1420 PINE STREET PHILADELPHIA PA 19102 ELIZABETH KRAPP VP FINANCE/ADMIN & TREASURER 2156709128 2021-02-24 1 MARY TORRETTA P00847851 7038477500 2019 2022-09-23 18:48:47Z ELIZABETH KRAPP 1420 PINE STREET PHILADELPHIA PA 19102 27415509 0 X WWW.PEIRCE.EDU X 1963 PA SEE SCHEDULE OPEIRCE COLLEGE IS A PRIVATE ACCREDITED INSTITUTION OFFERING ASSOCIATE'S/BACHELOR'S/MASTER'S DEGREES IN CAREER ORIENTED PROGRAMS GEARED TOWARDS ADULT LEARNERS. 12 12 281 13 0 0 5428524 5622636 18019912 15957759 923088 1112846 254469 374127 24625993 23067368 7246536 6911875 0 0 12260331 12398507 0 0 719654 4899299 4511296 24406166 23821678 219827 -754310 36116863 35901123 4120326 4494835 31996537 31406288 X SEE SCHEDULE O 0 0 19881340 6911875 15957759 SEE SCHEDULE O 19881340 1 1 0 1 0 0 0 0 0 1 1 0 0 0 1 1 1 0 1 0 0 0 0 0 0 0 0 0 1 1 0 0 0 0 0 0 0 0 1 0 0 0 0 0 0 0 0 1 2204 0 1 281 1 0 0 0 0 0 0 0 0 0 0 0 0 X 12 12 0 0 0 0 0 0 0 1 1 0 0 1 1 1 1 1 1 1 1 0 X ELIZABETH KRAPP 2156709128 1420 PINE STREET PHILADELPHIA PA 19102 DR MARY ELLEN CARO PRESIDENT AND CEO 40.00 0.00 X 402595 0 32994 DR RITA TOLIVER-ROBERTS PROVOST & VP ACADEMIC AFFAIRS 40.00 0.00 X 186624 0 38067 ELIZABETH M KRAPP VP FINANCE/ADMIN & TREASURER 40.00 0.00 X 186145 0 28723 JOSEPH GUZZARDO VP MARKETING, COMMUN, RECRUITING STRAT 40.00 0.00 X 176943 0 28405 JANET EICKHOFF VP INSTIT ADV/STRATEGIC PARTNERSHIPS 40.00 0.00 X 180436 0 11295 BRAD K HODGE VP ENROLL/STUDENT SERVICES 40.00 0.00 X 167360 0 20230 HARRIET GOLEN VP HUMAN RESOURCES - END APR 2020 40.00 0.00 X 155439 0 12313 ADRIAN ZAPPALA DEAN OF GRADUATE STUDIES 40.00 0.00 X 141882 0 32021 JAMES BURNS CHIEF INFORMATION OFFICER 40.00 0.00 X 124429 0 32272 STEPHANIE DONOVAN ASSOC PROF/CHAIR HEALTH PROGRAMS 40.00 0.00 X 126711 0 28440 TARA MCBRIDE EXEC ASST TO PRESIDENT & SECRETARY 40.00 0.00 X 75032 0 15021 TONI PERGOLIN CHAIR 1.00 0.00 X X 0 0 0 WILLIAM H MORGAN VICE CHAIR 1.00 0.00 X X 0 0 0 KEITH DAVISTON BOARD MEMBER 1.00 0.00 X 0 0 0 MARK EDWARDS BOARD MEMBER - END SEPT 2019 1.00 0.00 X 0 0 0 ROBERT G 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 BOARD MEMBER 1.00 0.00 X 0 0 0 SHARMAIN MATLOCK-TURNER BOARD MEMBER 1.00 0.00 X 0 0 0 JOSHUA W B RICHARDS BOARD MEMBER 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 1923596 0 279781 35 0 1 0 A BOOK COMPANY 28312 NETWORK PLACE CHICAGO IL 60673 BOOK PROVIDER 477982 ALLIED UNIVERSAL SECURITY SERVICES 161 WASHINGTON STREET SUITE 700 CONSHOHOCKEN PA 19428 SECURITY SERVICES 269009 2 5315692 306944 49113 5622636 TUITION AND FEES 611310 15957759 15957759 15957759 590190 590190 128173 0 128173 128173 128173 4870797 4348141 522656 522656 522656 ALL OTHER 900099 106841 106841 COURSE EVALUATION FEES 900099 104475 104475 BOOKSTORE 323111 34638 34638 245954 23067368 15957759 0 1486973 6911875 6911875 1238224 865065 358092 15067 8168935 6806673 881394 480868 490454 405266 63215 21973 1855353 1229069 555056 71228 645541 530919 81426 33196 90974 90974 102336 102336 25000 25000 29638 29638 451789 276489 172888 2412 871515 871515 97720 84513 10777 2430 716832 649450 45877 21505 546468 495100 34974 16394 12662 10401 968 1293 14960 11644 2086 1230 91431 91431 640289 580102 40979 19208 144035 144035 PROV. FOR LOSSES ON A/R 394919 394919 ALL OTHER 185666 94108 64245 27313 TEMPORARY EMPLOYEE CONT 74769 21571 53198 MEALS AND BANQUETS 20293 12580 2176 5537 23821678 19881340 3220684 719654 1217236 433453 81417 33841 166745 246922 1113559 983200 151772 362004 28761022 19461470 9830552 9299552 23489378 24479041 66204 63110 0 0 0 0 36116863 35901123 736875 862909 258364 229990 2888510 2755482 488729 236577 157725 4120326 4494835 X 29050596 28427691 2945941 2978597 31996537 31406288 36116863 35901123 -754310 164061 0 X 0 1 X 1 1 1 X RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED 0 0 0 0 0 0 0 0 0 1 25000 0 0 25000 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 UNIVERSITY 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. 3271824 4090 151809 94934 19835 3954 3309000 3175705 5848 203515 90566 18783 3895 3271824 996102 1970244 232966 16312 5842 1453 3175705 251810 758155 13863 996102 253476 -1391 275 251810 0.18200 0.17400 0.64400 1 0 27670 27670 19117342 11639176 7478166 0 9616010 7822294 1793716 0 9299552 REIMBURSEMENT CONTINGENCY 157725 157725 X 16595611 164061 -2698292 -2534231 19129842 29638 3907888 3937526 23067368 17185860 -3907888 -3907888 21093748 29638 2698292 2727930 23821678 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: ORGANIZATION'S LIABILITY FOR UNCERTAIN TAX POSITIONS UNDER FIN 48: THE COLLEGE FOLLOWS THE ACCOUNTING GUIDANCE FOR UNCERTAINTIES IN INCOME TAX POSITIONS WHICH REQUIRES THAT A TAX POSITION BE RECOGNIZED OR NOT RECOGNIZED BASED ON A MORE LIKELY THAN NOT THRESHOLD. THIS APPLIES TO POSITIONS TAKEN OR EXPECTED TO BE TAKEN IN A TAX RETURN. THE ASSESSMENT OF THE TAX POSITION IS BASED SOLELY ON THE TECHNICAL MERITS OF THE POSITION, WITHOUT REGARD TO THE LIKELIHOOD THAT THE TAX POSITION MAY BE CHALLENGED. THE COLLEGE HAS PROCESSES PRESENTLY IN PLACE TO ENSURE THE MAINTENANCE OF ITS TAX-EXEMPT STATUS, TO IDENTIFY AND REPORT UNRELATED INCOME, DETERMINE ITS FILING AND TAX OBLIGATIONS IN JURISDICTIONS FOR WHICH IT HAS NEXUS, AND TO REVIEW OTHER MATTERS THAT MAY BE CONSIDERED TAX POSITIONS. THE TAX YEARS ENDED JUNE 30, 2017, 2018, 2019, AND 2020 ARE STILL OPEN TO AUDIT FOR BOTH FEDERAL AND STATE PURPOSES. AS OF JUNE 30, 2020 AND 2019, MANAGEMENT HAS DETERMINED THAT THE COLLEGE HAS NO MATERIAL UNCERTAIN TAX POSITIONS THAT WOULD REQUIRE RECOGNITION OR DISCLOSURE IN THE ACCOMPANYING FINANCIAL STATEMENTS. PART XI, LINE 2D - OTHER ADJUSTMENTS: SCHOLARSHIPS -2,698,292. PART XI, LINE 4B - OTHER ADJUSTMENTS: PELL/ PHEAA GRANT 3,907,888. PART XII, LINE 2D - OTHER ADJUSTMENTS: PELL/ PHEAA GRANT -3,907,888. PART XII, LINE 4B - OTHER ADJUSTMENTS: SCHOLARSHIPS 2,698,292. 1 1 1 1 1 1 1 0 0 0 0 0 0 0 0 1 0 1 SCHEDULE E, PART I, LINE 3 PUBLICATION OF RACIALLY NON DISCRIMINATORY POLICY: PEIRCE COLLEGE GIVES SCHOLARSHIPS AND GRANTS TO STUDENTS BASED UPON FINANCIAL NEED AND ACADEMIC EXCELLENCE. THE SELECTION OF RECIPIENTS IS MADE BASED UPON OBJECTIVE CRITERIA. NO ONE IS DISCRIMINATED AGAINST BASED UPON RACE, RELIGION, GENDER, ETHNIC BACKGROUND, AGE, HANDICAP, STATUS AS A DISABLED VETERAN, OR ANY OTHER REASON. PEIRCE COLLEGE'S EQUAL OPPORTUNITY POLICY IS LOCATED ON ITSCONSUMER INFORMATION PAGE, WHICH IS LOCATED ON THE COLLEGE HOMEPAGE. A LINK TO THIS PAGE IS INCLUDED IN EMAILS TO PROSPECTIVE STUDENTS AND APPLICANTS. THE COLLEGE'S EQUAL OPPORTUNITY POLICY IS ALSO LOCATED IN THE STUDENT HANDBOOK AND COLLEGE CATALOG. A LINK TO THE HANDBOOK IS ACCESSIBLE TO ALL STUDENTS ON THE MAIN PAGE OF THE PEIRCE COLLEGE STUDENT PORTAL AND IN ALL OF THEIR COURSES VIA THE COLLEGE'S LEARNING MANAGEMENT SYSTEM. SCHEDULE E, PART I, LINE 6A 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, THE CARL D. PERKINS CAREER AND TECHNICAL EDUCATION GRANT, AND HIGHER EDUCATION EMERGENCY RELIEF FUND. PEIRCE COLLEGE ALSO RECEIVED A PENNSYLVANIA INSTITUTIONAL ASSISTANCE GRANT AND A GRANT FROM THE PENNSYLVANIA HIGHER EDUCATON ASSITANCE AGENCY. 1 FEDERAL PELL GRANT 995 3167329 FEDERAL SEOG 227 205645 UNRESTRICTED SCHOLARSHIPS 1023 2258195 RESTRICTED BY DONORS SCHOLARSHIPS 92 234452 PHEAA 440 740559 HIGHER EDUCATION EMERGENCY RELIEF STUDENT GRANTS 914 305695 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 AWARDS DONOR RESTRICTED GRANTS THAT ARE PROVIDED FROM FOUNDATIONS, ALUMNI SCHOLARSHIP DONATIONS, AND OTHER DONORS. ADDITIONALLY, THE COLLEGE PROVIDES INTERNAL INSTITUTIONAL 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 RESTRICTED GRANT GUIDELINES. 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. AN ANNUAL A-133 AUDIT (FINANCIAL STATEMENTS AND REPORT OF INDEPENDENT CERTIFIED PUBLIC ACCOUNTS IN ACCORDANCE WITH OMB CIRCULAR A-133) IS CONDUCTED BY THE COLLEGES' EXTERNAL INDEPENDENT AUDITORS. X X X X 0 0 0 0 0 0 0 0 0 DR MARY ELLEN CARO PRESIDENT AND CEO 322595 0 80000 0 0 0 11200 0 21794 0 435589 0 0 0 DR RITA TOLIVER-ROBERTS PROVOST & VP ACADEMIC AFFAIRS 186624 0 0 0 0 0 11030 0 27037 0 224691 0 0 0 ELIZABETH M KRAPP VP FINANCE/ADMIN & TREASURER 186145 0 0 0 0 0 11085 0 17638 0 214868 0 0 0 JOSEPH GUZZARDO VP MARKETING, COMMUN, RECRUITING STR 176943 0 0 0 0 0 3500 0 24905 0 205348 0 0 0 JANET EICKHOFF VP INSTIT ADV/STRATEGIC PARTNERSHIPS 175436 0 5000 0 0 0 875 0 10420 0 191731 0 0 0 BRAD K HODGE VP ENROLL/STUDENT SERVICES 167360 0 0 0 0 0 9877 0 10353 0 187590 0 0 0 HARRIET GOLEN VP HUMAN RESOURCES - END APR 2020 155439 0 0 0 0 0 9877 0 2436 0 167752 0 0 0 ADRIAN ZAPPALA DEAN OF GRADUATE STUDIES 141882 0 0 0 0 0 7747 0 24274 0 173903 0 0 0 JAMES BURNS CHIEF INFORMATION OFFICER 124429 0 0 0 0 0 7971 0 24301 0 156701 0 0 0 STEPHANIE DONOVAN ASSOC PROF/CHAIR HEALTH PROGRAMS 126461 0 250 0 0 0 7178 0 21262 0 155151 0 0 0 X 1 49113 FMV 0 0 1 0 PART I, COLUMN (B): THE ORGANIZATION IS REPORTING THE NUMBER OF CONTRIBUTIONS IN COLUMN (B). 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, SPECIALIZED INSTITUTION PROVIDING PRACTICAL LEADING-EDGE CURRICULA TO PRIMARILY WORKING ADULT LEARNERS. THE COLLEGE AWARDS THE MASTER OF SCIENCE IN ORGANIZATIONAL LEADERSHIP AND MANAGEMENT, THE MASTER OF SCIENCE IN HEALTH CARE ADMINISTRATION, AND THE BACHELOR OF SCIENCE AND ASSOCIATE IN SCIENCE DEGREES. THE DEGREE PROGRAMS ARE IN ACCOUNTING, BUSINESS ADMINISTRATION, CRIMINAL JUSTICE, GENERAL STUDIES, HEALTH INFORMATION ADMINISTRATION, HEALTH INFORMATION TECHNOLOGY, HEALTHCARE ADMINISTRATION, HUMAN RESOURCE MANAGEMENT, INFORMATION TECHNOLOGY AND PARALEGAL STUDIES. PEIRCE COLLEGE OFFERS ITS PROGRAMS UTILIZING TWO INTERCHANGEABLE DELIVERY FORMATS: ON CAMPUS AT ITS CENTER CITY PHILADELPHIA LOCATION AND ONLINE THROUGH WEB BASED DISTANCE LEARNING. PEIRCE COLLEGE IS ACCREDITED BY THE MIDDLE STATES COMMISSION ON HIGHER EDUCATION. THE BACHELOR OF SCIENCE AND ASSOCIATE IN SCIENCE DEGREES 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 OF SCIENCE AND ASSOCIATE IN SCIENCE DEGREES 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 FINANCIAL DEPARTMENT. THE FORM IS THEN SUBMITTED TO AN AUDIT, RISK & COMPLIANCE MANAGEMENT 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 ON THE INFORMATION CONTAINED IN THE 990 PRIOR TO ITS FILING WITH THE INTERNAL REVENUE SERVICE. FORM 990, PART VI, SECTION B, LINE 12C CONFLICT OF INTEREST POLICY MONITORING & ENFORCEMENT: THE COLLEGE REQUIRES EACH EMPLOYEE INCLUDING THE PRESIDENT/CEO AND OTHER KEY EMPLOYEES TO COMPLETE AND SIGN A WRITTEN CONFLICTS OF INTEREST STATEMENT THAT INCLUDES QUESTIONS THAT CAN DETERMINE IF THE EMPLOYEE HAS A RELATIONSHIP, FINANCIAL INTEREST OR BUSINESS AFFILIATION THAT RESULTS IN A CONFLICT OF INTEREST. THESE STATEMENTS ARE COMPLETED ANNUALLY BY THE EMPLOYEE AND AT ANY TIME AN EMPLOYEE BECOMES AWARE OF FACTS WHICH REQUIRE AN ADDITIONAL OR UPDATED DISCLOSURE. THESE STATEMENTS ARE RETURNED TO HUMAN RESOURCES FOR REVIEW AND IF NECESSARY FURTHER ACTION MAY BE REQUIRED. THE COLLEGE ALSO REQUIRES EACH TRUSTEE INCLUDING TRUSTEE OFFICERS TO COMPLETE AND SIGN A CONFLICT OF INTEREST QUESTIONNAIRE THAT CAN DETERMINE IF THE TRUSTEE HAS A RELATIONSHIP, FINANCIAL INTEREST OR BUSINESS AFFILIATION THAT RESULTS IN A CONFLICT OF INTEREST. THESE QUESTIONNAIRES ARE COMPLETED ANNUALLY BY EACH TRUSTEE AND RETURNED TO THE BOARD SECRETARY AND ARE REVIEWED BY THE OFFICE OF THE PRESIDENT AND IF NECESSARY FURTHER ACTION MAY BE REQUIRED. IF A CONFLICT OF INTEREST IS IDENTIFIED, THE FOLLOWING PROCEDURES ARE FOLLOWED: (A) AN INTERESTED PERSON MAY TAKE A PRESENTATION AT 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 CHAIRPERSON 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 WHETHER THE BUSINESS RELATIONSHIP IS IN THE COLLEGE'S BEST INTEREST, FOR ITS OWN BENEFIT, AND WHETHER IT IS FAIR AND REASONABLE. IN CONFORMITY WITH THE ABOVE DETERMINATION, IT SHALL MAKE ITS DECISION AS TO WHETHER TO ENTER INTO THE BUSINESS RELATIONSHIP. FORM 990, PART VI, SECTION B, LINE 15 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 CONDUCTED IN 2017 AS PART OF THE PRESIDENTIAL SEARCH COMMISSIONED BY THE BOARD OF TRUSTEES. THE COMPENSATION DATA WAS COMPILED USING INFORMATION FROM OTHER COLLEGES AND UNIVERSITIES AS A GUIDE IN DETERMINING REASONABLE COMPENSATION FOR THE PRESIDENT POSITION. 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 MANAGEMENT DOCUMENT (PMD) WHICH IS STANDARD REVIEW USED BY ALL MANAGERS 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 PMD. ONCE THE MERIT INCREASES FOR THE KEY EMPLOYEES ARE DETERMINED AND APPROVED BY THE PRESIDENT, THE BOARD OF TRUSTEES IS INFORMED OF THE INCREASES. 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. THE ORGANIZATION'S GOVERNING DOCUMENTS AND CONFLICT OF INTEREST POLICY WILL BE PROVIDED AT THE DISCRETION OF MANAGEMENT, IF REQUESTED.