2015-01-30T14:28:16-06:00 2014-06-30 131517563 LOEB & TROPER LLP 655 THIRD AVENUE 12TH FLOOR NEW YORK NY 10017 990 2013-07-01 133669731 THE CENTER FOR REPRODUCTIVE RIGHTS INC CENT 9176373600 120 WALL STREET 14TH FLOOR NEW YORK NY 10005 NANCY NORTHUP PRESIDENT AND CEO 9176373600 2015-01-20 1 ISRAEL TANNENBAUM P01589203 2128674000 2013 2016-02-25 16:41:14Z NANCY NORTHUP 120 WALL STREET 14TH FLOOR NEW YORK NY 10005 23548625 0 X WWW.REPRODUCTIVERIGHTS.ORG X 1992 DE THE CENTER FOR REPRODUCTIVE RIGHTS, INC. IS A NONPROFIT LEGAL ADVOCACY ORGANIZATION DEDICATED TO PROMOTING AND DEFENDING WOMEN'S REPRODUCTIVE RIGHTS WORLDWIDE. THE CENTER USES THE LAW TO ADVANCE REPRODUCTIVE FREEDOM AS A FUNDAMENTAL HUMAN RIGHT THAT ALL GOVERNMENTS ARE LEGALLY OBLIGATED TO PROTECT, RESPECT, AND FULFILL. 19 18 125 63 0 0 27477486 17212570 0 507783 801072 827112 -77569 -98825 28200989 18448640 95548 121294 0 0 8912049 11202203 287778 279457 2553172 5564535 7166227 14859910 18769181 13341079 -320541 34604882 35499034 1333382 1860613 33271500 33638421 X SEE SCHEDULE O 0 0 5197480 107708 507783 THE U.S. LEGAL PROGRAM STRIVES TO PROTECT AND ADVANCE REPRODUCTIVE LIBERTY AND ACCESS TO REPRODUCTIVE HEALTH CARE IN THE UNITED STATES BY EMPLOYING DIVERSE STRATEGIES GROUNDED IN THE CENTER'S LEGAL EXPERTISE. THE LEGAL VICTORIES OF THE U.S. LEGAL PROGRAM, INCLUDING TWO LANDMARK U.S. SUPREME COURT DECISIONS, HAVE PROTECTED MILLIONS OF WOMEN'S HEALTH AND EVERY AMERICAN'S CONSTITUTIONAL RIGHTS. IT HAS SECURED MEDICAID FUNDING FOR LOW INCOME WOMEN SEEKING ABORTIONS; SAFEGUARDED CONFIDENTIAL REPRODUCTIVE HEALTHCARE SERVICES FOR ADOLESCENTS, ENSURED THAT WOMEN RECEIVE MEDICALLY SOUND AND UNBIASED INFORMATION, AND PROTECTED MEDICAL PRIVACY. 4984664 13586 THE GLOBAL LEGAL PROGRAM STRENGTHENS REPRODUCTIVE HEALTH LAWS AND POLICIES IN MORE THAN 50 COUNTRIES IN ASIA, AFRICA, EUROPE, AND LATIN AMERICA AND THE CARIBBEAN AS WELL AS IN THE UNITED NATIONS. IN THE PAST DECADE, THE CENTER HAS SPEARHEADED THE USE OF INTERNATIONAL LITIGATION AND COMPLEMENTARY LEGAL ADVOCACY WITH GREAT SUCCESS, WINNING LANDMARK VICTORIES IN HUMAN RIGHTS FORA, INCLUDING VARIOUS DECISIONS THAT HOLD GOVERNMENTS ACCOUNTABLE FOR ENSURING ACCESS TO ABORTION SERVICES WHERE THEY ARE LEGAL. 2959926 THE COMMUNICATIONS PROGRAM INFORMS A WIDE RANGE OF EXTERNAL AUDIENCES ON THE CENTER'S ACTIVITIES AND IMPACT, DEVELOPING AND IMPLEMENTING MESSAGES THAT PROMOTE THE ORGANIZATION'S OVERALL MISSION AND GOALS. IT WORKS WITH THE U.S., GLOBAL, AND GOVERNMENT RELATIONS PROGRAMS TO PUBLICIZE NEW CASES AND REPORTS, LEGAL VICTORIES, AND ADVOCACY EFFORTS THROUGH THE MEDIA, AS WELL AS THE CENTER'S OWN WEB PROPERTIES AND PUBLICATIONS AND DEVELOPS AND EXECUTES MAJOR NATIONAL AND INTERNATIONAL PUBLIC AWARENESS AND ADVOCACY CAMPAIGNS. 1781290 THE CENTER'S GOVERNMENT RELATIONS PROGRAM WORKS WITH CONGRESS AND THE EXECUTIVE BRANCH TO PROTECT AND PROMOTE REPRODUCTIVE RIGHTS AND HEALTH. IT ADVOCATES FOR DOMESTIC AND FOREIGN POLICY THAT ADVANCES REPRODUCTIVE HEALTH AND FREEDOM AND ALLOWS WOMEN AND FAMILIES TO PROSPER. 1781290 14923360 1 1 0 1 0 0 0 0 0 1 1 0 0 0 1 1 1 0 0 1 1 0 1 1 1 0 0 0 1 1 0 0 0 0 0 0 0 0 1 0 0 0 0 0 0 0 0 1 70 0 125 1 0 1 KE CO NP 0 0 0 1 1 0 0 0 0 X 19 18 0 0 0 0 0 0 0 1 1 0 0 1 1 1 1 1 1 1 1 0 AL AK AZ AR CA CT FL GA HI IL KS KY MD MA MI MN MS NH NJ NM NY NC OH OK OR PA RI SC TN VA WV WI CO X X SU LIM 9176373612 120 WALL STREET 14TH FLOOR NEW YORK NY 10005 NANCY NORTHUP PRESIDENT AND CEO 40.00 X X 358169 0 34979 REBECCA COOK CHAIR 3.00 X X 0 0 0 NICKI GAMBLE VICE CHAIR 3.00 X X 0 0 0 BARKLEY STUART SECRETARY 1.00 X X 0 0 0 LAURIE CAMPBELL TREASURER 1.00 X X 0 0 0 AIMEE BOONE CUNNINGHAM ASSISTANT SECRETARY 1.00 X X 0 0 0 NONNIE BURNES ASSISTANT SECRETARY 1.00 X X 0 0 0 JOSE ALVAREZ DIRECTOR 1.00 X 0 0 0 CYNTHIA BLUMENTHAL DIRECTOR 1.00 X 0 0 0 JULIE CHIAKEN DIRECTOR 1.00 X 0 0 0 PHYLLIS COHEN DIRECTOR 1.00 X 0 0 0 ROBERTA GOSS DIRECTOR 1.00 X 0 0 0 JONATHAN KAUFELT DIRECTOR 1.00 X 0 0 0 MONICA HARRINGTON DIRECTOR 1.00 X 0 0 0 PAULA JOHNSON DIRECTOR 1.00 X 0 0 0 AMY METZLER RITTER DIRECTOR 1.00 X 0 0 0 JANET LEVINGER DIRECTOR 1.00 X 0 0 0 JAMIE LEVITT DIRECTOR 1.00 X 0 0 0 LOIS WHITMAN DIRECTOR 1.00 X 0 0 0 LAURA MCQUADE EVP AND COO 40.00 X 239364 0 45339 LUISA CABAL VICE PRESIDENT OF PROGRAMS 40.00 X 190032 0 31284 ANNE MATSUI DIRECTOR OF DEVELOPMENT 40.00 X 184799 0 33255 CHRISTOPHER ISELI DIRECTOR OF COMMUNICATIONS 40.00 X 164282 0 22095 BEBE ANDERSON DIRECTOR OF U.S. LEGAL PRO 40.00 X 161920 0 21576 JANET CREPPS SENIOR COUNSEL 40.00 X 136387 0 37842 JULIANNA GONEN DIRECTOR OF GOVERNMENT RELATIONS 40.00 X 134692 0 29208 LILIAN SEPULVEDA DIRECTOR OF GLOBAL LEGAL 40.00 X 133872 0 10838 JULIE RIKELMAN LITIGATION DIRECTOR 40.00 X 132766 0 37365 MELISSA UPRETI REGIONAL DIRECTOR, ASIA 40.00 X 121989 0 773 1958272 0 304554 11 0 1 0 SUNSHINE SACHS & ASSOCIATES 136 MADISON AVENUE 17TH FL NEW YORK NY 10016 MARKETING 301010 MINDSET DIRECT 1700 JEFFERSON ST SUITE 200 ARLINGTON VA 22205 PROFESSIONAL FUNDRAISER 205669 THE RABEN GROUP 1640 RHODE ISLAND AVENUE NW WASHINGTON DC 20036 STRATEGIC CONSULTING 180000 3 884947 16327623 2983817 17212570 ATTORNEY FEES 541100 507783 507783 507783 441447 441447 5323507 4937842 385665 385665 385665 40625 884947 162143 -121518 -121518 22693 22693 22693 18448640 507783 0 728287 107708 107708 13586 13586 1560039 1132978 91606 335455 7535901 6204863 440472 890566 348554 301374 18430 28750 1087920 854680 99517 133723 669789 539676 40195 89918 25068 21237 1585 2246 50250 50250 105564 105564 279457 279457 43490 43490 1843704 1663394 71464 108846 352142 352142 1283745 1036320 90412 157013 191708 132278 42176 17254 1220907 911200 220193 89514 1013782 994609 2798 16375 206068 153377 607 52084 157171 101276 42849 13046 64889 45060 13970 5859 DUES/FEES/SUBSCRIPTIONS 292096 216627 11547 63922 DIRECT MAIL 266801 266801 48842 35411 11088 2343 18769181 14923360 1292649 2553172 516235 1263922 10970790 13149355 13248618 9812831 389296 547112 2412361 2187538 369417 224823 8988704 10329329 121822 171662 34604882 35499034 984037 1568915 238500 241312 110845 50386 1333382 1860613 X 13337189 15126228 18930191 17508073 1004120 1004120 33271500 33638421 34604882 35499034 X -320541 691423 -3961 X X 0 1 X 1 0 X 13995741 8459375 4831432 27477486 17212570 71976604 13995741 8459375 4831432 27477486 17212570 71976604 23654946 48321658 240817 244983 105242 254610 441447 1287099 2960 6497 9457 9993 6593 2423 37539 22693 79241 73352401 492372 0.65880 0.58900 X PART II LINE 10 MAPPING PROJECT OXFORD MLR REBATE RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED 190070 254653 444723 18324458 18769181 1000000 250000 0 0 740774 454960 876465 1000000 3072199 4608299 115558 50818 94139 444723 705238 185194 113740 219116 250000 768050 1152075 9357 825 1113 190070 201365 1526520 253080 75120 7421 1697059 1414016 191422 71928 6990 1526520 1380457 72517 35574 3384 1414016 1508851 -53635 67665 7094 1380457 1379718 205053 69039 6881 1508851 0.27210 0.59170 0.13620 0 0 855551 736935 118616 474898 394293 80605 1081912 1056310 25602 224823 DEFERRED RENT PAYABLE 50386 50386 X 24418816 691423 5326204 -3961 6013666 18405150 43490 43490 18448640 24051895 5326204 5326204 18725691 43490 43490 18769181 PART V, LINE 4: THE ENDOWMENT FUND WAS ESTABLISHED TO SUPPORT A LEGAL FELLOWSHIP POSITION AT THE CENTER FOR REPRODUCTIVE RIGHTS. PART X, LINE 2: THE CENTER HAS DETERMINED THAT THERE ARE NO MATERIAL UNCERTAIN TAX POSITIONS THAT REQUIRE RECOGNITION OR DISCLOSURE IN THE FINANCIAL STATEMENTS. YEARS ENDING DECEMBER 31, 2011 AND SUBSEQUENT REMAIN SUBJECT TO EXAMINATION BY APPLICABLE TAXING AUTHORITIES. PART XI, LINE 2D - OTHER ADJUSTMENTS: LOSS ON DISPOSAL OF FIXED ASSET -3,961. 1 EUROPE (INCLUDING ICELAND AND GREENLAND) 1 2 PROGRAM SERVICES REPRODUCTIVE RIGHTS ADVOCACY AND LITIGATION 642729 SOUTH AMERICA 1 2 PROGRAM SERVICES REPRODUCTIVE RIGHTS ADVOCACY AND LITIGATION 63210 SOUTH ASIA 1 3 PROGRAM SERVICES REPRODUCTIVE RIGHTS ADVOCACY AND LITIGATION 283598 SUB-SAHARAN AFRICA 1 3 PROGRAM SERVICES REPRODUCTIVE RIGHTS ADVOCACY AND LITIGATION 635606 CENTRAL AMERICAN AND THE CARIBBEAN 1 5 PROGRAM SERVICES REPRODUCTIVE RIGHTS ADVOCACY AND LITIGATION 404361 EUROPE (INCLUDING ICELAND AND GREENLAND) GRANTS 9000 SOUTH ASIA GRANTS 1308 SUB-SAHARAN AFRICA GRANTS 1157 CENTRAL AMERICAN AND THE CARIBBEAN GRANTS 2121 5 15 0 0 5 15 2040969 2121 2043090 STIPEND FOR INTERNS EUROPE (INCLUDING ICELAND AND GREENLAND) 1 9000 WIRE TRANSFER STIPEND FOR INTERNS SOUTH ASIA 3 1308 WIRE TRANSFER STIPEND FOR INTERNS SUB-SAHARAN AFRICA 1 1157 WIRE TRANSFER STIPEND FOR INTERNS CENTRAL AMERICA AND THE CARIBBEAN 2 2121 WIRE TRANSFER 0 0 0 0 0 0 PART I, LINE 2: THE GRANTS WERE IN THE FORM OF STIPENDS PAID TO INTERNS FOR THEIR WORK ON REPRODUCTIVE HEALTH AND HUMAN RIGHTS. THE INTERNS REGULARLY SUBMIT TO THEIR SUPERVISORS ACTIVITY REPORTS WHICH PROVIDE AN UPDATE ON THE STATUS OF THE DELIVERABLES. THE SUPERVISORS THEN REVIEW THE ACTIVITY REPORTS TO ENSURE THAT THE INTERNS COMPLY WITH THE TERMS OF THEIR INTERNSHIP. THE INTERNS ARE GIVEN DEADLINES BY THEIR SUPERVISORS TO COMPLETE THEIR TASK. THE SUPERVISORS REGULARLY CHECK IN WITH THEIR INTERNS BEFORE THE DEADLINE TO SEE IF THEY HAVE PROGRESSED WITH THEIR TASKS. X X X X X X 1 SIMPATICO CONSULTING LLC 40 WEST 116TH STREET A215 NEW YORK NY 10016 GALA CONSULTANT 0 1264875 40000 1224875 MINDSET-DIRECT 1700N JEFFERSON ST SUITE 200 ARLINGTON VA 22205 DIRECT MAIL CONSULTANT AND COPY WRITER 0 997587 201806 795781 PUBLIC INTEREST COMMUNICATIONS 7700 LEESBURG PIKESUITE 301 NORTH FALLS CHURCH VA 22043 TELEFUNDRAISER 0 25869 37651 -11782 2288331 279457 2008874 AL AK AZ AR CA CO CT DE DC FL GA HI IA ID IN IL KY KS LA MA MD ME MO MS MN MI MT NE NC NY NM NJ NH NV ND OH OR OK PA RI SC SD TX TN VA VT WA WV WI WY GALA CAMPAIGN 925572 884947 40625 51249 54864 25016 31014 925572 884947 40625 51249 54864 25016 31014 162143 -121518 SCHEDULE G, PART I, LINE 2B, COLUMN (V) FOR MINDSET DIRECT, THE CENTER PAID $201,806 FOR THE MANAGEMENT OF THE CENTER'S DIRECT RESPONSE FUNDRAISING PROGRAM, $48,500 FOR COPYWRITING, DESIGN, ART AND ONLINE CAMPAIGN MESSAGING SERVICES AND $3,306 OF EXPENSE REIMBURSEMENTS. ACCORDING TO THE AGREEMENT WITH MINDSET DIRECT, THE FUNDRAISING PROGRAM CONSULTANCY FEES SHALL BE $12,500 PER MONTH EFFECTIVE JULY 1, 2013 AND WILL CONTINUE FOR 12 MONTHS. THE CENTER SHALL ALSO BE INVOICED FOR PROGRAM ENHANCEMENTS SUCH AS COPY DEVELOPMENT AND AN ESTIMATE OF THESE COSTS WILL BE PREPARED PRIOR TO UNDERTAKING AND MINDSET WILL NOT PROCEED UNTIL APPROVAL FROM THE CENTER IS RECEIVED. THE CENTER SHALL BE RESPONSIBLE FOR OUT-OF-POCKET COSTS SUCH AS TRAVEL, POSTAGE AND OVERNIGHT OR COURIER SERVICES. FOR PUBLIC INTEREST COMMUNICATIONS, INC., THE CENTER PAID $37,543.00 FOR CONDUCTING TELEFUNDRAISING CAMPAIGNS AND $108 OF EXPENSE REIMBURSEMENTS. ACCORDING TO THE AGREEMENT WITH PUBLIC INTEREST COMMUNICATIONS, INC., THE CENTER WILL PAY BASED ON A FEE SCHEDULE PER TYPE OF DONOR'S COMPLETED DECISION. THE CENTER SHALL ALSO PAY FOR ALL OUT-OF-POCKET EXPENSES INCURRED BY THE PUBLIC INTEREST COMMUNICATIONS, INC. FOR SIMPATICO CONSULTING LLC, THE CENTER PAID $40,000 FOR THE CENTER'S FALL 2013 GALA. ACCORDING TO THE AGREEMENT WITH SIMPATICO CONSULTING LLC, THE CENTER SHALL PAY THE TOTAL FEE OF $40,000 AND BE RESPONSIBLE FOR REIMBURSING OUT-OF-POCKET EXPENSES. 1 STIPENDS TO LEGAL FELLOWS 2 107708 PART I, LINE 2: THE GRANTS WERE IN THE FORM OF STIPENDS PAID TO FELLOWS FOR THEIR WORK ON REPRODUCTIVE HEALTH AND HUMAN RIGHTS. THE FELLOWS REGULARLY SUBMIT TO THEIR SUPERVISORS ACTIVITY REPORTS WHICH PROVIDES AN UPDATE ON THE STATUS OF THEIR DELIVERABLES. THE SUPERVISORS THEN REVIEW THE ACTIVITY REPORTS TO ENSURE THE FELLOWS COMPLIANCE WITH THE TERMS OF THEIR AGREEMENT. X X X 0 0 0 0 0 0 0 1 0 NANCY NORTHUP PRESIDENT AND CEO 306927 0 50000 0 1242 0 19125 0 15854 0 393148 0 0 0 LAURA MCQUADE EVP AND COO 213659 0 25000 0 705 0 18441 0 26898 0 284703 0 0 0 LUISA CABAL VICE PRESIDENT OF PROGRAMS 179642 0 10000 0 390 0 14821 0 16463 0 221316 0 0 0 ANNE MATSUI DIRECTOR OF DEVELOPMENT 182226 0 0 0 2573 0 14049 0 19206 0 218054 0 0 0 CHRISTOPHER ISELI DIRECTOR OF COMMUNICATIONS 163944 0 0 0 338 0 12421 0 9674 0 186377 0 0 0 BEBE ANDERSON DIRECTOR OF U.S. LEGAL PRO 159708 0 0 0 2212 0 12341 0 9235 0 183496 0 0 0 JANET CREPPS SENIOR COUNSEL 135196 0 0 0 1191 0 10525 0 27317 0 174229 0 0 0 JULIANNA GONEN DIRECTOR OF GOVERNMENT RELATIONS 134285 0 0 0 407 0 10364 0 18844 0 163900 0 0 0 JULIE RIKELMAN LITIGATION DIRECTOR 132482 0 0 0 284 0 10763 0 26602 0 170131 0 0 0 PART I, LINE 7 STAFF MEMBERS WHO ARE AT THE C-SUITE LEVEL, WHICH ARE STAFF MEMBERS ON THE EXECUTIVE TEAM, ARE ELIGIBLE FOR A BONUS AT THE BEGINNING OF THE FISCAL YEAR, BASED ON THEIR PERFORMANCE FROM THE PREVIOUS FISCAL YEAR. X 13 2983817 COMPARE TO MARKET 0 0 1 0 PART I, COLUMN (B): THE ORGANIZATION IS REPORTING THE NUMBER OF CONTRIBUTIONS RECEIVED. FORM 990, PART VI, SECTION B, LINE 11 THE FINANCE AND AUDIT COMMITTEE IS AUTHORIZED BY THE BOARD OF DIRECTORS TO REVIEW AND APPROVE THE FORM 990. THE ORGANIZATION'S AUDIT FIRM PROVIDES THE FINANCE AND AUDIT COMMITTEE WITH A DRAFT OF THE FORM 990 WHICH THE COMMITTEE THEN REVIEWS FOR COMPLETENESS AND ACCURACY. THE AUDIT FIRM THEN ADDRESSES ANY CONCERNS OR REVISIONS TO THE FORM 990 PROPOSED BY THE FINANCE AND AUDIT COMMITTEE. THE FINANCE AND AUDIT COMMITTEE THEN VOTES FOR THE APPROVAL OF THE FORM 990 THROUGH AN ELECTRONIC PROXY VOTE. THEN,THE CENTER PROVIDES A COPY OF THE FORM 990 TO ITS BOARD OF DIRECTORS PRIOR TO FILING. FORM 990, PART VI, SECTION B, LINE 12C AT THE BEGINNING OF EACH FISCAL YEAR, THE CENTER'S DIRECTORS, TRUSTEES AND STAFF COMPLETE CONFLICT-OF-INTEREST FORMS TO DISCLOSE IF THEY OR THEIR IMMEDIATE FAMILY HAVE INTERESTS WHICH WOULD ALLOW THEM TO BENEFIT FINANCIALLY FROM DECISIONS MADE IN THEIR CAPACITY. THE CENTER'S DIRECTOR OF ADMINISTRATION THEN REVIEWS THE CONFLICT-OF-INTEREST DISCLOSURE FORMS AND IF A CONFLICT IS IDENTIFIED, THE EXECUTIVE VICE PRESIDENT AND CHIEF OPERATING OFFICER WILL BE NOTIFIED AND DISCUSS THE CONFLICT WITH THE APPROPRIATE PARTIES AND WILL TAKE FURTHER ACTION IF NECESSARY. FORM 990, PART VI, SECTION B, LINE 15 EVERY THREE YEARS, THE CENTER CONDUCTS A COMPENSATION AND BENEFITS ANALYSIS TO DETERMINE IF THE CENTER'S COMPENSATION, LEAVE AND BENEFIT PROGRAMS ARE COMPETITIVE WITH COMPARABLE ORGANIZATIONS. FOR THE MOST RECENT COMPENSATION AND BENEFITS ANALYSIS THE CENTER UNDERTOOK IN 2014, THE CENTER ANALYZED SALARY AND BENEFITS INFORMATION PROVIDED BY 12 COMPARABLE COMPANIES, DATA FROM NOT-FOR-PROFIT ASSOCIATIONS AND INPUT RECEIVED FROM THE CENTER'S STAFF THROUGH AN IN-HOUSE CUSTOM SURVEY. SALARIES AND BENEFITS OF STAFF POSITIONS THAT WERE FOUND TO BE BELOW THAT OF COMPARABLE COMPANIES WERE ADJUSTED ACCORDINGLY. ALSO, THE CENTER CONDUCTS AN ANNUAL PERFORMANCE EVALUATION FOR ITS MANAGEMENT AND THE REST OF ITS STAFF. THE CENTER THEN APPLIES MERIT INCREASES BASED ON THE RESULTS OF THE EVALUATION. ANNUALLY, THE CENTER DISCLOSES TO ITS EXECUTIVE COMMITTEE THE COMPENSATION AND BENEFITS OF MEMBERS OF MANAGEMENT. ANNUALLY, THE BOARD OF DIRECTORS ALSO REVIEW THE PERFORMANCE OF THE CENTER'S PRESIDENT AND CEO AND SETS THE COMPENSATION OF THE PRESIDENT AND CEO BASED ON THE RESULTS OF THE REVIEW. FORM 990, PART VI, SECTION C, LINE 19 THE CENTER'S FINANCIAL STATEMENTS ARE PART OF ITS ANNUAL REPORT WHICH IS AVAILABLE ONLINE IN THE CENTER'S WEBSITE. THE CENTER PROVIDES GOVERNING DOCUMENTS AND ITS CONFLICT-OF-INTEREST POLICY TO THE PUBLIC UPON REQUEST. FORM 990, PART XI, LINE 9: LOSS ON DISPOSAL OF FIXED ASSETS -3,961. FORM 990 PART XII LINE 2C THE PROCESS HAS NOT CHANGED FROM THE PRIOR YEAR.