Ms. Sandra G. Nugent Director, Acquisition Integrity ... · O!ce of the President...

Office of the [email protected] (p) 404.659.6536 (f) 830 Westview Drive SW, Atlanta, Georgia 30314

June 1, 2016

Ms. Sandra G. Nugent Director, Acquisition Integrity Program National Aeronautics and Space Administration Office of the General Counsel 300 E Street, N. W. Washington, D. C. 20546

Subject: Morehouse College, Award #NAG5-13633, Grant #NNK06EA02g – Settlement Agreement

Dear Ms. Nugent:

Morehouse College hereby submits its fourth annual report on the Morehouse College Ethics and Compliance Program (the “E&C Program”) as required under the Settlement Agreement for Morehouse College, which became effective August 1, 2011 (the “Agreement”). As with previous reports, this report includes: (1) a summary of the E&C Program, with specific details for the period of July 1, 2014 through June 30, 2015 pertaining to our obligations in connection with these activities as they relate to the National Aeronautics and Space Administration (“NASA”); and (2) an independent audit of our E&C Program as required by the Settlement Agreement (Attachment A). This summary supplements the audit report by providing additional context and explanations and/or management responses, as well as detailing the efforts taken regarding the notations from the audits.

A. The Ethics and Compliance Program

The Office of General Counsel & Compliance (“OGC”) remains responsible for theday-to-day management of the program. As of February 29, 2016, the position ofDirector of Ethics and Compliance was vacated by Ms. Doris Coleman.Accordingly, the Office of General Counsel and Compliance is currentlyundergoing a reorganization. To ensure we fully leverage the positions withoversight of the Compliance Program, the College seeks to replace Ms. Colemanwith a higher-education trained attorney to lead the College’s ongoing complianceefforts. Beginning this summer, the College will launch a recruitment process toreplace that position. In the interim, the College’s staff attorney, Crystal Lucas, hasassumed many of the duties formerly managed by Ms. Coleman. This ensured alevel of continuity and quality in the oversight and services provided.

In addition, a key partner for the Compliance Program is the Office of Sponsored Programs (“OSP”), which is within the Division of Academic Affairs. OSP has also undergone a reorganization after the departure of the former Director of Sponsored Programs in 2014. The Provost recognized that faculty leadership on the grants compliance issue was key, and established a new structure of associate provosts that includes an Associate Provost for Research, Scholarship and Creative Production. OGC and OSP work closely together to ensure post-award grants compliance.

More broadly, the Compliance Program is focused on:

• Establishing and promoting a culture of compliance with appropriate oversight, monitoring and support of all institutional compliance functions;

• Developing a world class program that protects our institution from internal and external threats, enhances our brand and strengthens relationships with stakeholders;

• Coordinating and supporting compliance auditing and monitoring; and coordinating departmental compliance initiatives and mitigation efforts through collaborative partnerships with business units and the broader Morehouse community;

• Providing ethics and compliance training for employees;

• Ensuring that effective and consistent disciplinary standards are in place;

• Preparing and regularly conducting compliance risk assessments across the campus community;

• Leveraging our participation with the Higher Education Compliance Alliance (HECA) of the National Association of College and University Attorneys (NACUA) to ensure our continued compliance with key federal laws and regulations by developing tools to manage our compliance program.

B. Chief Ethics and Compliance Officer

During the period of this report, I served as the General Counsel and Chief Compliance Officer of the College. I am a member of the College’s Senior Leadership Team and report directly to the President.

C. Ethics and Compliance Culture Shift

During the FY15, the College completed its strategic planning process. This process included numerous meetings with stakeholders from all areas of the College,

ranging from the Board of Trustees to our front line employees. Ethical and compliant behavior remained a prevalent theme and value of the College that was echoed in each of the various meetings with stakeholders. The overall theme of Morehouse’s Strategic Plan is “Toward Character and Capital Preeminence.” This theme of ethics and compliance is woven throughout the strategic plan, particularly in the area of Capital Preeminence, where the College is committing to better stewarding resources and improving organizational culture.

In pursuit of preeminence, the College embraces a broad set of ethical business conduct principles that aim to reduce the prospect of criminal and other improper conduct. In addition, the E&C Program equips the College’s business units with best practices and organizational procedures to bolster our ability to deliver services in a compliant environment.

The College continually engages faculty and staff in discussions about ethics and compliance. Employees are trained to understand the College’s ethics and compliance imperatives, and their individual compliance responsibilities. All new employees are required to complete an on-line compliance training course. After completion of that course, the Office of the General Counsel & Compliance meets one-on-one with all new employees to further discuss the College’s expectations around accountability, integrity, responsibility and commitment. All new employees also receive a package of compliance related information including a brochure on compliance, the ethics reporting line, and information on relevant policies and procedures (Attachment B).

Appropriate NASA OIG Fraud Hotline Posters are displayed throughout the campus community and are located on the College’s website. Employees can go directly to the following agency website to report fraud, waste or abuse to NASA at http://itcd.hq.nasa.gov/directory/hotlines.pdf or they can call the anonymous hotline at 1-800-424-9183 (Attachment C).

The Ethics and Compliance website provides comprehensive information about the program and includes policies, procedures, education and training programs, important regulatory links and frequently asked questions. (http://www.morehouse.edu/administration/ethics/index.html).

C. Confidential Disclosure Compliance Program - Ethics Line Reporting

The College encourages employees to report concerns and issues to their managers and supervisors, the Office of Human Resources, the Chief Ethics and Compliance Officer, the Director of Ethics and Complinace or the Chief Audit Officer by using the usual communication channels and problem-solving procedures. Employees

may also report anonymously to the Ethics Line, which is a confidential channel for expressing concerns and raising issues about workplace and business practices. Morehouse does not tolerate retaliation against anyone who makes a good faith report regarding a violation or potential violation of our code, policies or procedures.

A toll-free number is available for verbal reporting (888-299-9540) and a web address for the submission of written reports (www.tnwinc.com/Morehouse). In addition, all Ethics Line reports are summarized to the Audit Committee of the Board of Trustees.

D. Policies and Procedures

The College maintains written policies and procedures to provide guidance to employees on the compliance culture, and also to define the values and boundaries of expected individual and business behavior and personal conduct. These policies and procedures are contained in the Policies and Procedures Manual, which is accessible to employees via the Tigernet web page. Compliance related policies and procedures are also located on the Ethics and Compliance web page at https://www.morehouse.edu/administration/ethics/policies.html.

E. Code of Conduct

All employees are expected to adhere to our Code of Conduct (“Code”) as a condition of their continued employment. Any employee who violates our Code, or any policy or procedure, is subject to appropriate disciplinary action. Our Code is located on the Ethics and Compliance web page at: (https://www.morehouse.edu/administration/ethics/pdf/Code-of-Conduct-0516-2013.pdf).

Both the Office of Human Resources and the Office of General Counsel & Compliance lead enforcement of the Code of Conduct.

F. Ethics and Compliance Infrastructure

The College’s governance-level oversight responsibilities for the Program is assigned to the Audit Committee of the Board of Trustees. In 2013, upon the appointment of the new Chief Compliance Officer, it was determined that with the onboarding of an entirely new administration, direct oversight for compliance should be at the highest level of the organization to ensure appropriate collaboration and accountability. Therefore, as noted last year, the College has delegated the responsibilities of its Senior Advisory Compliance Committee to the Senior Leadership Team, which is comprised of the President, Chief Academic Officer, General Counsel & Chief Compliance Officer, Chief Operating Officer,

Chief Financial Officer, Chief Information Officer, Vice President of Student Development, Interim Vice President of Institutional Advancement, Chief Development Officer, Associate Vice President of Human Resources, and the Associate Vice President for Enrollment Management.

The Senior Leadership team met twice a week to consider compliance matters, among other topics. For example, the Senior Leadership Team reviews the outcomes and remediation efforts required of audits conducted for the institution. In addition, as General Counsel and Chief Compliance Officer, I met monthly with each senior leader to discuss the challenges faced in their departments so that we could continually assess needed process improvements from a compliance perspective. This high-level consideration of compliance issues has proven effective to ensure an appropriate tone and understanding at the top.

G. Monitoring and Accountability

The College continues to monitor and conduct risk assessments to evaluate and prioritize compliance related risks related to federal grants and ensure that supervisory controls are being performed and documented. The Senior Leadership Team conducts ongoing risk assessments as the pre-cursor to developing a full enterprise risk management program. The Director of Ethics and Compliance conducts random checks of grants related programs and serves as a resource to partner with business units to identify areas that need improvement.

H. Remediation and Mitigation

The Senior Leadership Team and the Office General Counsel & Compliance actively partner together and with various business units to identify, mitigate and remediate risks. Many of the identified risks do not impact the grants programs at Morehouse. Still, through our educational and collaborative approach, we are building an organic approach to remediating and mitigating by encouraging business units to be proactive in addressing risks. This work continues to prove effective by strengthening those collaborative relationships. The Office of General Counsel & Compliance aims to provide the framework for the business units to routinely and effectively carry out tasks that are part of the compliance and controls structure of the College.

I. Compliance Training and Education

As reported in last year’s report, the College shifted its annual federal awards training requirement from April to December. In December 2014, responsible officials and employees of the College completed two (2) hours of federal compliance training, and they continue to do so each December. As required by

this agreement, a training schedule and topic outline of the training course is attached to this report (Attachment D). In addition, OGC began a “Higher Education Compliance” training series for the College. The first session occurred during this period and provided tactical training for business units on the College’s requirements around compliance.

J. Independent Audit and Audit Plan

The Audit Work Plan (Attachment E? ) is attached. In July 2015, the College hired a new Chief Audit Officer to run our Internal Audit and Advisory function. On April 14, 2016, the College submitted its audit plan for this cycle. The College actually began the audit sooner than in previous years, under the leadership of the Chief Audit Officer.

As detailed in the audit results that are included with this submission, the auditors did not identify any significant deficiencies or material weaknesses involving the internal control over NSF and NASA programs. There are again, however, two noted findings pertaining to the issuance of scholarships and ensuring that the recipients meet the scholarship requirements. In previous years, this was the result of checks and balances that failed at the programmatic level where the awards were given out. This year, the issue is around the improper recording of costs. Both errors have been corrected; however, the College is providing more training at all levels of the payment process, including the administrative employees who process the paperwork for the awarding of scholarships.

Response to Audit Notations

Pursuant to the terms of the Agreement, below I have outlined the corrective measures and/or responses to the FY15 Compliance Program Audit conducted by the College’s internal auditor and the audit of grant expenditures conducted by Banks, Finley, White & Co.

FY2015 Compliance Program Audit

• Provisions 8(d) – 8(f) of the Agreement: This year’s audit revealed that the College was non-compliant on these terms during the relevant time period that relate to the ensuring that the College has written policies and/or procedures on the issues pertaining to cost-sharing, sub-recipients and accurate reconciliation of accounting records. First, this flagged issue was resolved in the course of the College updating its policies and procedures with the new uniform guidance. It is of note that in the FY14 compliance audit this issue was not raised.

• Provision 10 of the Agreement: This was noted last year and the College indicated the same response that due to the reorganization of the College and the restructuring of certain positions, the College had elevated this compliance committee to the full

Senior Leadership team. Technically, the Chief Procurement Officer was not in the meetings; however, he reports to the Chief Financial Officer where the substantial authority pertaining to procurement resides. After last year’s submission, without any additional feedback from NASA or NSF, the College proceeded with this practice.

• Provision 13(c) of the Agreement: In previous years, the audit relied on the College’s standard procedure to conduct background checks of new employees; however, many of the Relevant Employees are not new employees, and in fact have longstanding careers with the College, since before the College began conducting background checks. Therefore, the new independent auditor could not rely on that policy as making reasonable efforts in regards to the Relevant Employees during the relevant period. The College does have purchasing and procurement approvals that prevents anyone, except for the CFO and the President from being able to exercise substantial authority without the check and balance of either a supervisor, member of the Business & Finance team or senior leader authorizing any such transaction and will continue to make reasonable efforts to ensure that such authority is limited with appropriate checks and balances.

• Provision 15(a): The College did submit the report albeit not thirty (30) days in advance. This was an oversight and the College will endeavor in next year’s audit, which is slated to be the final year, to provide the plan within the specified time.

• Provision 18): This is a challenge for the College because when we use an independent auditor to conduct part or all of the audit, it is not part of their standard practices to release their work papers. Last year, an external auditor completed both parts of the audit. In years before FY14, the internal auditor did conduct the compliance program audit, and so the new internal auditor is searching for those documents. Once located, they will be stored in the Office of Internal Audit and Advisory Services consistent with this provision.

• Provision 20(b) & (d): This provision pertains to the two-hour training requirement for Relevant Employees. As Chief Compliance Officer, I notified the Relevant Employees of the need to complete the training; however, the list contained errors and the individuals who failed to participate in the training, did so because they were unintentionally omitted from the list. To ensure that the list is complete, we will have the internal auditor verify the list of Relevant Employees to ensure everyone completes the training. We will also have the internal auditor verify that the certificates are placed in everyone’s files.

Independent Audit by Banks, Finley, White & Co.

• Finding Regarding Room & Board Charges for NOYCE STEM: This finding resulted from improper charging of room and board charges. To ensure that everyone in each stage of the process for charging grants is aware of allowable and unallowable charges, the College is providing additional training to the administrative staff, supervisory staff, and the grants accounting staff.

• Findings Regarding GPA Discrepancy/Ineligibility for NOYCE Scholarship Recipient: This finding resulted from a student with a 2.70 GPA who needed to have a 2.75 GPA to qualify for the program. This error is being mitigated by adding two additional layers of checks and balances, including the Scholarship Administrator assuming responsibility for monitoring compliance with GPA requirements.

The College remains committed to strengthening the E&C Program, and taking the corrective measures as outlined here and in the reports. The E&C Program continues to assist College administrators and the Board of Trustees in identifying, avoiding, and mitigating risks by fostering a culture of ethical behavior and compliance marked by integrity, openness, honesty, accountability and adherence to all applicable laws and regulations.

The College seeks to ensure that our employees and students are aware of and comply with all program requirements in an effort to reduce the prospect for unlawful conduct and that our behavior is consistent with the values and mission of this College.

Please contact me should you have any questions or need additional information.

Sincerely,

MOREHOUSE COLLEGE

Lacrecia G. Cade General Counsel & Chief Compliance Officer

Additional Attachments:

• Independent Auditor’s Audit Work Plan 2014 • Independent Auditor’s Report, 2014 • Financial Statements, Schedules of Expenditures of Federal

Awards, and OMB A-133, June 30, 2014

Office of the [email protected] (p) 404.659.6536 (f) 830 Westview Drive SW, Atlanta, Georgia 30314

June 1, 2016

Mr. Alan Boehm Office of Inspector General National Science Foundation Assistant Inspector General for Investigations 4201 Wilson Blvd. Arlington, VA 22230

Subject: Morehouse College, Award #NAG5-13633, Grant #NNK06EA02g – Settlement Agreement

Dear Mr. Boehm:

Morehouse College hereby submits its fourth annual report on the Morehouse College Ethics and Compliance Program (the “E&C Program”) as required under the Settlement Agreement for Morehouse College, which became effective August 1, 2011 (the “Agreement”). As with previous reports, this report includes: (1) a summary of the E&C Program, with specific details for the period of July 1, 2014 through June 30, 2015 pertaining to our obligations in connection with these activities as they relate to the National Aeronautics and Space Administration (“NASA”); and (2) an independent audit of our E&C Program as required by the Settlement Agreement (Attachment A). This summary supplements the audit report by providing additional context and explanations and/or management responses, as well as detailing the efforts taken regarding the notations from the audits.

A. The Ethics and Compliance Program

The Office of General Counsel & Compliance (“OGC”) remains responsible for the day-to-day management of the program. As of February 29, 2016, the position of Director of Ethics and Compliance was vacated by Ms. Doris Coleman. Accordingly, the Office of General Counsel and Compliance is currently undergoing a reorganization. To ensure we fully leverage the positions with oversight of the Compliance Program, the College seeks to replace Ms. Coleman with a higher-education trained attorney to lead the College’s ongoing compliance efforts. Beginning this summer, the College will launch a recruitment process to replace that position. In the interim, the College’s staff attorney, Crystal Lucas, has assumed many of the duties formerly managed by Ms. Coleman. This ensured a level of continuity and quality in the oversight and services provided.

In addition, a key partner for the Compliance Program is the Office of Sponsored Programs (“OSP”), which is within the Division of Academic Affairs. OSP has also undergone a reorganization after the departure of the former Director of Sponsored Programs in 2014. The Provost recognized that faculty leadership on the grants compliance issue was key, and established a new structure of associate provosts that includes an Associate Provost for Research, Scholarship and Creative Production. OGC and OSP work closely together to ensure post-award grants compliance.

More broadly, the Compliance Program is focused on:

• Establishing and promoting a culture of compliance with appropriate oversight, monitoring and support of all institutional compliance functions;

• Developing a world class program that protects our institution from internal and external threats, enhances our brand and strengthens relationships with stakeholders;

• Coordinating and supporting compliance auditing and monitoring; and coordinating departmental compliance initiatives and mitigation efforts through collaborative partnerships with business units and the broader Morehouse community;

• Providing ethics and compliance training for employees;

• Ensuring that effective and consistent disciplinary standards are in place;

• Preparing and regularly conducting compliance risk assessments across the campus community;

• Leveraging our participation with the Higher Education Compliance Alliance (HECA) of the National Association of College and University Attorneys (NACUA) to ensure our continued compliance with key federal laws and regulations by developing tools to manage our compliance program.

B. Chief Ethics and Compliance Officer

During the period of this report, I served as the General Counsel and Chief Compliance Officer of the College. I am a member of the College’s Senior Leadership Team and report directly to the President.

C. Ethics and Compliance Culture Shift

During the FY15, the College completed its strategic planning process. This process included numerous meetings with stakeholders from all areas of the College,

ranging from the Board of Trustees to our front line employees. Ethical and compliant behavior remained a prevalent theme and value of the College that was echoed in each of the various meetings with stakeholders. The overall theme of Morehouse’s Strategic Plan is “Toward Character and Capital Preeminence.” This theme of ethics and compliance is woven throughout the strategic plan, particularly in the area of Capital Preeminence, where the College is committing to better stewarding resources and improving organizational culture.

In pursuit of preeminence, the College embraces a broad set of ethical business conduct principles that aim to reduce the prospect of criminal and other improper conduct. In addition, the E&C Program equips the College’s business units with best practices and organizational procedures to bolster our ability to deliver services in a compliant environment.

The College continually engages faculty and staff in discussions about ethics and compliance. Employees are trained to understand the College’s ethics and compliance imperatives, and their individual compliance responsibilities. All new employees are required to complete an on-line compliance training course. After completion of that course, the Office of the General Counsel & Compliance meets one-on-one with all new employees to further discuss the College’s expectations around accountability, integrity, responsibility and commitment. All new employees also receive a package of compliance related information including a brochure on compliance, the ethics reporting line, and information on relevant policies and procedures (Attachment B).

Appropriate NASA OIG Fraud Hotline Posters are displayed throughout the campus community and are located on the College’s website. Employees can go directly to the following agency website to report fraud, waste or abuse to NASA at http://itcd.hq.nasa.gov/directory/hotlines.pdf or they can call the anonymous hotline at 1-800-424-9183 (Attachment C).

The Ethics and Compliance website provides comprehensive information about the program and includes policies, procedures, education and training programs, important regulatory links and frequently asked questions. (http://www.morehouse.edu/administration/ethics/index.html).

C. Confidential Disclosure Compliance Program - Ethics Line Reporting

The College encourages employees to report concerns and issues to their managers and supervisors, the Office of Human Resources, the Chief Ethics and Compliance Officer, the Director of Ethics and Compliance or the Chief Audit Officer by using the usual communication channels and problem-solving procedures. Employees

may also report anonymously to the Ethics Line, which is a confidential channel for expressing concerns and raising issues about workplace and business practices. Morehouse does not tolerate retaliation against anyone who makes a good faith report regarding a violation or potential violation of our code, policies or procedures.

A toll-free number is available for verbal reporting (888-299-9540) and a web address for the submission of written reports (www.tnwinc.com/Morehouse). In addition, all Ethics Line reports are summarized to the Audit Committee of the Board of Trustees.

D. Policies and Procedures

The College maintains written policies and procedures to provide guidance to employees on the compliance culture, and also to define the values and boundaries of expected individual and business behavior and personal conduct. These policies and procedures are contained in the Policies and Procedures Manual, which is accessible to employees via the Tigernet web page. Compliance related policies and procedures are also located on the Ethics and Compliance web page at https://www.morehouse.edu/administration/ethics/policies.html.

E. Code of Conduct

All employees are expected to adhere to our Code of Conduct (“Code”) as a condition of their continued employment. Any employee who violates our Code, or any policy or procedure, is subject to appropriate disciplinary action. Our Code is located on the Ethics and Compliance web page at: (https://www.morehouse.edu/administration/ethics/pdf/Code-of-Conduct-0516-2013.pdf).

Both the Office of Human Resources and the Office of General Counsel & Compliance lead enforcement of the Code of Conduct.

F. Ethics and Compliance Infrastructure

The College’s governance-level oversight responsibilities for the Program is assigned to the Audit Committee of the Board of Trustees. In 2013, upon the appointment of the new Chief Compliance Officer, it was determined that with the onboarding of an entirely new administration, direct oversight for compliance should be at the highest level of the organization to ensure appropriate collaboration and accountability. Therefore, as noted last year, the College has delegated the responsibilities of its Senior Advisory Compliance Committee to the Senior Leadership Team, which is comprised of the President, Chief Academic Officer, General Counsel & Chief Compliance Officer, Chief Operating Officer,

Chief Financial Officer, Chief Information Officer, Vice President of Student Development, Interim Vice President of Institutional Advancement, Chief Development Officer, Associate Vice President of Human Resources, and the Associate Vice President for Enrollment Management.

The Senior Leadership team met twice a week to consider compliance matters, among other topics. For example, the Senior Leadership Team reviews the outcomes and remediation efforts required of audits conducted for the institution. In addition, as General Counsel and Chief Compliance Officer, I met monthly with each senior leader to discuss the challenges faced in their departments so that we could continually assess needed process improvements from a compliance perspective. This high-level consideration of compliance issues has proven effective to ensure an appropriate tone and understanding at the top.

G. Monitoring and Accountability

The College continues to monitor and conduct risk assessments to evaluate and prioritize compliance related risks related to federal grants and ensure that supervisory controls are being performed and documented. The Senior Leadership Team conducts ongoing risk assessments as the pre-cursor to developing a full enterprise risk management program. The Director of Ethics and Compliance conducts random checks of grants related programs and serves as a resource to partner with business units to identify areas that need improvement.

H. Remediation and Mitigation

The Senior Leadership Team and the Office General Counsel & Compliance actively partner together and with various business units to identify, mitigate and remediate risks. Many of the identified risks do not impact the grants programs at Morehouse. Still, through our educational and collaborative approach, we are building an organic approach to remediating and mitigating by encouraging business units to be proactive in addressing risks. This work continues to prove effective by strengthening those collaborative relationships. The Office of General Counsel & Compliance aims to provide the framework for the business units to routinely and effectively carry out tasks that are part of the compliance and controls structure of the College.

I. Compliance Training and Education

As reported in last year’s report, the College shifted its annual federal awards training requirement from April to December. In December 2014, responsible officials and employees of the College completed two (2) hours of federal compliance training, and they continue to do so each December. As required by

this agreement, a training schedule and topic outline of the training course is attached to this report (Attachment D). In addition, OGC began a “Higher Education Compliance” training series for the College. The first session occurred during this period and provided tactical training for business units on the College’s requirements around compliance.

J. Independent Audit and Audit Plan

The Audit Work Plan (Attachment E? ) is attached. In July 2015, the College hired a new Chief Audit Officer to run our Internal Audit and Advisory function. On April 14, 2016, the College submitted its audit plan for this cycle. The College actually began the audit sooner than in previous years, under the leadership of the Chief Audit Officer.

As detailed in the audit results that are included with this submission, the auditors did not identify any significant deficiencies or material weaknesses involving the internal control over NSF and NASA programs. There are again, however, two noted findings pertaining to the issuance of scholarships and ensuring that the recipients meet the scholarship requirements. In previous years, this was the result of checks and balances that failed at the programmatic level where the awards were given out. This year, the issue is around the improper recording of costs. Both errors have been corrected; however, the College is providing more training at all levels of the payment process, including the administrative employees who process the paperwork for the awarding of scholarships.

Response to Audit Notations

Pursuant to the terms of the Agreement, below I have outlined the corrective measures and/or responses to the FY15 Compliance Program Audit conducted by the College’s internal auditor and the audit of grant expenditures conducted by Banks, Finley, White & Co.

FY2015 Compliance Program Audit

• Provisions 8(d) – 8(f) of the Agreement: This year’s audit revealed that the College was non-compliant on these terms during the relevant time period that relate to the ensuring that the College has written policies and/or procedures on the issues pertaining to cost-sharing, sub-recipients and accurate reconciliation of accounting records. First, this flagged issue was resolved in the course of the College updating its policies and procedures with the new uniform guidance. It is of note that in the FY14 compliance audit this issue was not raised.

• Provision 10 of the Agreement: This was noted last year and the College indicated the same response that due to the reorganization of the College and the restructuring of certain positions, the College had elevated this compliance committee to the full

Senior Leadership team. Technically, the Chief Procurement Officer was not in the meetings; however, he reports to the Chief Financial Officer where the substantial authority pertaining to procurement resides. After last year’s submission, without any additional feedback from NASA or NSF, the College proceeded with this practice.

• Provision 13(c) of the Agreement: In previous years, the audit relied on the College’s standard procedure to conduct background checks of new employees; however, many of the Relevant Employees are not new employees, and in fact have longstanding careers with the College, since before the College began conducting background checks. Therefore, the new independent auditor could not rely on that policy as making reasonable efforts in regards to the Relevant Employees during the relevant period. The College does have purchasing and procurement approvals that prevents anyone, except for the CFO and the President from being able to exercise substantial authority without the check and balance of either a supervisor, member of the Business & Finance team or senior leader authorizing any such transaction and will continue to make reasonable efforts to ensure that such authority is limited with appropriate checks and balances.

• Provision 15(a): The College did submit the report albeit not thirty (30) days in advance. This was an oversight and the College will endeavor in next year’s audit, which is slated to be the final year, to provide the plan within the specified time.

• Provision 18): This is a challenge for the College because when we use an independent auditor to conduct part or all of the audit, it is not part of their standard practices to release their work papers. Last year, an external auditor completed both parts of the audit. In years before FY14, the internal auditor did conduct the compliance program audit, and so the new internal auditor is searching for those documents. Once located, they will be stored in the Office of Internal Audit and Advisory Services consistent with this provision.

• Provision 20(b) & (d): This provision pertains to the two-hour training requirement for Relevant Employees. As Chief Compliance Officer, I notified the Relevant Employees of the need to complete the training; however, the list contained errors and the individuals who failed to participate in the training, did so because they were unintentionally omitted from the list. To ensure that the list is complete, we will have the internal auditor verify the list of Relevant Employees to ensure everyone completes the training. We will also have the internal auditor verify that the certificates are placed in everyone’s files.

Independent Audit by Banks, Finley, White & Co.

• Finding Regarding Charges for NOYCE STEM: This finding resulted from improper charging of room and board charges. To ensure that everyone in each stage of the process for charging grants is aware of allowable and unallowable charges, the College is providing additional training to the administrative staff, supervisory staff, and the grants accounting staff.

The College remains committed to strengthening the E&C Program, and taking the corrective measures as outlined here and in the reports. The E&C Program continues to assist College administrators and the Board of Trustees in identifying, avoiding, and mitigating risks by fostering a culture of ethical behavior and compliance marked by integrity, openness, honesty, accountability and adherence to all applicable laws and regulations.

The College seeks to ensure that our employees and students are aware of and comply with all program requirements in an effort to reduce the prospect for unlawful conduct and that our behavior is consistent with the values and mission of this College.

Please contact me should you have any questions or need additional information.

Sincerely,

MOREHOUSE COLLEGE

Lacrecia G. Cade General Counsel & Chief Compliance Officer

Additional Attachments:

• Independent Auditor’s Audit Work Plan 2014 • Independent Auditor’s Report, 2014 • Financial Statements, Schedules of Expenditures of Federal

Awards, and OMB A-133, June 30, 2014

MOREHOUSE COLLEGE FY2015 Compliance Program Audit Plan

BACKGOUND Morehouse College (the “College”) entered into a Settlement Agreement with the United States in connection with review of past grant agreements with the National Science Foundation (NSF) and the National Aeronautics and Space Administration (NASA). As part of the settlement agreement, the College was required to establish a Compliance Program to ensure compliance with the terms and conditions applicable to any NSF and NASA awards; to ensure compliance with laws and regulations governing NSF and NASA awards; and, to demonstrate the College’s commitment to the prevention of fraud, false statements, and misuse of funds awarded the College from NSF and NASA. In connection with the Compliance Program, the Chief Audit Officer of the College is required to have conducted in whole or in part, on an annual basis, a comprehensive, statistically-valid, independent audit of the College’s compliance with the Settlement Agreement and with Federal laws and regulations regarding the use and expenditure of NSF and NASA awards. AUDIT PLAN Consistent with the Settlement Agreement, there are two components of the audit. The first relates to ensuring compliance with the terms and conditions applicable to any NSF and NASA awards. The second component of the audit relates to assessing the efficacy of the College’s Compliance Program. With respect to the first component of the audit, the College through Internal Auditing and Advisory Services (IAAS) has contracted with the firm of Banks, Finley, White & Co. (BFW), Certified Public Accountants, to perform the compliance audit of current year grant awards from NSF and NASA. The audit will be performed in accordance with Government Auditing Standards and OMB Circular A-133, Audits of States, Local Governments, and Non-Profit Organizations and the OMB Circular A-133 Compliance Supplement, specifically Part 5 – Cluster of Programs – Research and Development Programs. Based on the requirements of the Compliance Supplement, the audit will include determining compliance with requirements in the following areas:

Activities Allowed or Unallowed Allowable Costs/Cost Principles Matching Reporting Subrecipient Monitoring, if applicable Special Tests and Procedures, if applicable

In each of the areas above and as applicable, statistical samples of transactions will be pulled from the universe of transactions of all NSF and NASA grant award expenditures during the audit period.

Additionally, procedures will be performed relative to documenting the College’s internal control procedures over grant awards in the following areas:

Control Environment Risk Assessment Information and Communication Monitoring Control Activities

Materiality level for compliance requirements for this audit has been set at 5% of the program expenditures. The second component of the audit will be designed to verify compliance and efficacy of the College’s Compliance Program as detailed in the Settlement Agreement. This portion of the audit will be performed by the College’s Chief Audit Officer. Areas to be included in the audit are as follows:

Review of compliance standards and procedures to prevent and detect violations of law and submission of improper payments to the federal government

Ensuring College leadership is knowledgeable of compliance standards and procedures Ensuring a high level person is assigned to ensure implementation and effectiveness of

compliance standards and procedures Ensuring that due diligence procedures are in place to ensure improper person is excluded

from positions of substantial authority within the College Ensuring procedures are in place to communicate compliance standards and procedures to

relevant employees through training and dissemination of relevant information Ensuring the College has taken steps to prevent and detect violations of law Review of policies and procedures the prevent and detect violations of law are enforced

consistently Review of procedures are in place to respond appropriately to any violations of law when

detected The period covered by the audit will be July 1, 2014 through June 30, 2015. AUDIT SERVICE TEAM The audit team will be as follows: Undria Stalling, CIA, CFE Morehouse College, Chief Audit Officer Gregory C. Ellison, CPA BFW, Engagement Partner Shannon Golden BFW, Senior Auditor Tracey Hill BFW, Staff Auditor

The service team possesses both the technical skills and understanding of the audits of federal expenditures and knowledge of the Settlement Agreement. Also each member has satisfied the CPE and independence requirements pursuant to GAO standards. The Chief Audit Officer will be the lead project manager on the engagement. BFW will submit its final report on the grant compliance audit to the Chief Audit Officer who, along with her audit of the Compliance Program, will submit the final report to appropriate parties within NSF and NASA.

www.morehouse.edu404.681.2800 (p) 830 Westview Drive SW, Atlanta, Georgia 30314

ATTACHMENTS

Attachment No.

Description

A Morehouse College and NASA/NSF Settlement Agreement B Ethics and Compliance Program C Morehouse College Strategic Plan through 2018 D New Employee Compliance Packet E NASA OIG Fraud Hotline Posters F Training G Audit Work Plan H Certification of Independent Audit I Audit of Grant Expenditures for NASA/NSF J Compliance Program Audit K FY15 A-133 Audit


ATTACHMENT A


ATTACHMENT B


ATTACHMENT C

1

MOREHOUSE COLLEGE STRATEGIC PLAN Toward Character & Capital Preeminence.

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Toward Character & Capital Preeminence | 3

Over the heads of her students, Morehouse holds a crown that she challenges them

to grow tall enough to wear.

HOWARD THURMAN ’23

educator, minister, theologian, philosopher, author, mystic

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Education must enable one to sift and weigh evidence,

to discern the true from the false, the real from the unreal, and the facts from the fiction. …

But education which stops with efficiency may prove the greatest menace to society.

…

We must remember that intelligence is not enough. Intelligence plus character—that is the goal of true education.

The complete education gives one not only power of concentration, but worthy objectives upon which to concentrate.

MARTIN LUTHER KING JR. ‘48

civil rights leader, non-violent change agent, humanitarian


MESSAGE FROM THE PRESIDENT It is with great pride and resolve that I introduce the strategic plan for Morehouse College that will take us into the year 2018 and beyond. This plan, quite simply, is about achieving the world of our dreams through two primary drivers - character preeminence and capital preeminence. At my inauguration as the 11th President of Morehouse College, I shared that capital preeminence means having a first-rate campus and character preeminence means producing first-rate men. When we are recognizably and completely preeminent in both, we will have the world of our dreams.

Black boys and black men are under assault in this country and this world. Education policies, police and justice practices, and limitations on access and opportunities in the innovation economy are 21st century examples of remaining artifacts of the Jim Crow era. Old and new constructs reinforce unequal negative impacts on black boys and black men everywhere from the United States to Brazil and beyond to Africa and Europe. Morehouse must remain a counterforce to these challenges by providing a pathway for our men to ascend through and beyond these challenges to a transformed place for them individually and for us collectively. We must develop in our students the acuity to see and understand these challenges; nurture and reinforce the necessary integrity to overcome these challenges; affirm the agency of our young men; provide opportunities to demonstrate strength in brotherhood and build each man’s capacity to take action and have a meaningful, consequential impact in the world. This is the heart of the mission of Morehouse College.

There is an urgency to find new, efficient and sustainable ways of continuing this mission while keeping the cost of a Morehouse education within our students’ reach. Now, more than ever, we have to compete and prevail in an academic marketplace where students and their parents seek and deserve economic and demonstrable value in our instructional programs and in the overall quality of our living-learning environment. New and emerging technologies, innovative pedagogies, and the availability of new educational delivery systems have come to the fore, while students today must be prepared for a world vastly different than that of the 20th century. We live in a digital, knowledge, creative and innovation economy, and to ensure success in this 21st century, our students have to be stronger than ever before at the intersection between critical and imaginative thinking.

It is in this context that we carefully examined best practices and evaluated the current efficacy of our offerings and operations. And with that viewpoint, we have taken a deep, hard look at Morehouse that has led to a path forward replete with disruptive, yet meaningful improvements aimed at ensuring we can continue to do what no other institution can – produce Morehouse Men.

This strategic plan responds to the challenges before us by placing our distinctive mission, high expectations and enduring values at the core of our value proposition. To sustain and strengthen our prominence in producing generations of leaders, the path to preeminence requires a renewed focus on teaching, mentorship and leadership by the faculty, as well as ensuring we have the right blend of first-class technology and talented staff. It also requires that we grow and better manage the College’s resources. With this new strategic plan, we identify the guideposts along this path.

We invite those who appreciate the value proposition of Morehouse to joins us on this path to preeminence. It will be filled with challenges and victories, but at the finish line, we will be closer to the world of our dreams.

John S. Wilson, Jr. ‘79 President

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THE NEXT HUNDRED YEARS:

Toward Character & Capital Preeminence This plan provides Morehouse College a compelling direction for the next three years. Like all other institutions of higher learning, Morehouse College must assess its own history and development and determine where it sits in the greater society now and in the years ahead. Much of Morehouse College’s success in the last 149 years has evolved because of its ability to assess its strengths and weaknesses and match those against the trends of the greater society.

In 1967, Edward A. Jones wrote A Candle in the Dark, a comprehensive history of Morehouse College over its first hundred years. Drawing on and including remarks outlining the vision of Benjamin Mays, president of Morehouse from 1940 to 1967, A Candle in the Dark concludes with cautions, aspirations, and directives for the College over the next hundred years. Together, Jones’s and Mays’s ideas serve as a prophetic endorsement of the theme of our current strategic focus. Jones shares:

Morehouse had begun as an elementary school ministering to the needs of freedman athirst for knowledge and eager to function as free men in democratic society. Its first building was an unpretentious Black church; its first students, a handful of adults not granted the opportunity to learn to read. As its students’ educational levels advanced, so did the school’s curriculum. But whether as an elementary school, or as a college, Morehouse addressed itself through its educational program to one overall objective: the making of men. Its unique achievement is that it took in Black boys and prepared them for graduate school, professional school, and for life—and all this in a segregated society.

Jones continues by pointing out the importance of education in his time and the need for all institutions to plan carefully if they are to prepare students in ways that are relevant. His charge could not be more germane today. Information is ubiquitous, technology permits a greater diversity of engagement, and the range of possibilities and options for many students is expansive. Concurrently, we have seen widening disparities in K-12 schools’ capacity to provide a quality education, and college costs continue to rise. The result has been a growing inequality in access to today’s knowledge and innovation economy.

These factors demand that we think differently about how we educate the next generation of citizens. It is in our institutional DNA to take on these inherent inequities. To this point, Mays shares that “this is easier said than done.” He continues:

The future of Morehouse is not written in the stars. Whereas during its first century Morehouse was considered first rate as a segregated institution, it must in its second century be first rate for all….

Morehouse’s future will depend in large measure on the imagination and creativity of its President, faculty, and Board of Trustees. New ideas must be developed by which new programs and new and better ways of executing those programs will make support relatively easy to obtain. Faculties must be secured that are not afraid to experiment and to depart from the ‘beaten path of yesteryears.’ … Morehouse’s ability to secure funds in its second century will rely on the quality of its educational programs, the effectiveness of its teaching, and the caliber of its student body. …

The same methods and ways of doing things will not suffice. Colleges which are averse to change will not command support.

But these things cannot be done without greater support. With the right programs, Morehouse must increase its endowment… for plant expansion, scholarships, and special projects. … In the first century, we could say, ‘No college could have done so much with so little and so few.’ In the second, we must say, ‘No college could have done any more with what it had than Morehouse.’


Nearly 50 years after President Mays’ leadership, our call to achieve character and capital preeminence identifies these same commitments—character preeminence is “the making of men,” with attention not just to the intellectual, but to the emotional, social, and ethical development of world-class leaders. Capital preeminence means moving beyond “[doing] so much with so little” to having the physical, technological, human, and financial infrastructure to provide the best conditions and environment for that full development.

Jones and Mays make clear the necessity of Morehouse in their time and throughout the College’s history. We insist and affirm that Morehouse is needed now and into the future as much as in its first 150 years. There is simply no other institution as poised for success in “the making of men” of both intelligence and character than Morehouse College. This strategic plan is bold in its insistence that character preeminence is of even greater value today than ever before—so much so that it is worthy of the centrality it is given in this plan. Morehouse has developed men of great character and accomplishment, and this plan recognizes that the world needs more such men.

But the plan also recognizes that this “cannot be done without greater support” and improved stewardship of resources. Higher education is besieged with disruptive change and, as Mays instructs, it is imperative that we think imaginatively, experiment, and develop new programs and new ways of doing things. This strategic plan supports that principle, but just as critically, embraces our powerfully unique mission.

This plan outlines the task to steer a path towards institutional renewal during a time when the higher education community at large continues to face unprecedented challenges and legitimate questions about its long-term future. Just as several companies crumbled in the wake of the Great Recession, experts project that a similar thinning of institutions will occur in higher education over the next decade. Only those institutions able to increase operational effectiveness and efficiency, and fully prepare its students to boldly face the demands and rigors of the 21st century will survive and be successful. Morehouse will be one of these institutions by realizing character and capital preeminence.

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OUR TRULY DISTINCTIVE MISSION: Rich History & Enduring Values

The mission of Morehouse College is to develop men with disciplined minds to lead lives of leadership and service

by emphasizing the intellectual and character development of its students and by assuming a special responsibility for teaching

the history and culture of black people.

Since the founding of Morehouse College in 1867, the faculty, staff, and leadership have worked to inspire, engage, challenge, support, and mentor its students with the expressed intent of fomenting their intellectual and character development. How we have articulated success in that endeavor has evolved over time. President John Hope (1906-1931), perhaps the first to be called “a maker of men,” insisted that “a Morehouse Man cannot fail.” He argued that Morehouse Men should be prepared for “the work of their generation” and must “defy anything less [than] … fairness and real brotherhood.”

President Benjamin Mays’s (1940-1967) 14 points promoted students being “radical thinkers, proud, confident and impactful; attendant to social justice needs and the needs of their fellow students; in control, humble and respected; [and] striving for the best.” And President Hugh Gloster ‘31 (1967-1986) added that Morehouse Men should “learn as much about American Negro literature and history and the race problem and race relations” as possible.

More recently, during President Walter Massey’s tenure (1995-2007), the seven pillars—academic excellence, respect, integrity, awareness, truth, compassion, and spirituality—were introduced to capture the values students must seek to cultivate in themselves. President Robert Franklin (2007-2012) described a Renaissance man who exhibited five wells: well-read, well-traveled, well-spoken, well-dressed, and well-balanced. And President Wilson (2013- ) has said that “a Morehouse Man is one who moves through the world with obvious competence and confidence, able at once to compete and work in the world that is, and yet imagine and work for the world that must yet be.”

We have combined and integrated these definitions to provide a new characterization of the Morehouse Man, one which speaks to our unique mission and tries to capture the enduring values from all 150 years of our history. In particular, we seek to produce men of acuity, integrity and agency; men who commit to brotherhood; and men who strive to lead consequential lives.

Equally important, these values not only define the Morehouse Man and exemplify our history, but they also guide our embrace of students and reflect our unique character as an institution.


ACUITY + INTEGRITY + AGENCY Academic excellence, developing a keenness of thought, being well-read, well-spoken, creative thinkers—these are all elements of acuity. Espousing acuity means welcoming challenge, critical self-reflection, and continuous learning, and aspiring not just to intellectual excellence, but to an abounding personal excellence. It means striving for the best, seeking truth, and engaging in evidence-based analysis. Acuity is not just amassing knowledge, but building understanding.

Truth, awareness, and morality are pillars contributing to our definition of integrity. Integrity is about cultivating the courage to do what is right and standing firm with the same high principles in all situations, even when no one is looking. Integrity is a pursuit of wholeness—discovering one’s true, full self and working to be that person, as complex as that identity may be, privately and publicly, personally and professionally, in thought and in action. We must produce men who seek to be “steadfast, honest, true” and this principle must live in the way we conduct our work.

Developing acuity and practicing integrity are a part of growth, and growth is an act of will, an expression of agency. Those who demonstrate agency take charge of their circumstances, assert themselves through rigorous academic pursuits to refine and test their capabilities, challenge their (and others’) assumptions, and actively seek new roles and responsibilities for themselves. Those who exhibit agency push themselves to their limits, fully believing they have within them the ability to learn, grow, and successfully adapt to the changing and unknowable future.

Morehouse has graduated countless scholars who have performed at the highest levels in their respective disciplines with unmatched integrity. And while Dr. Martin Luther King Jr. may be the most recognized of these alumni, he was also a powerful example of acuity and agency distinctive of students who have been inspired by mentors at Morehouse. The College has graduated entrepreneurs, disruptors, educators, and advocates who exemplify agency and like King, they have gone on to utilize their independent spirit and to make their marks on a universal society.

We will continue to prepare men who demonstrate acuity, practice integrity and exhibit agency.

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BROTHERHOOD Every quality we hope to nurture in our students requires developing independence, but we know that there is at least as much to be gained in developing the right interdependence. One of the most unique and profoundly powerful forces at Morehouse is the sense of brotherhood. Brotherhood is more than just the easy flow of laughs and applauding of achievement. It is a commitment to standing together with fellow students. It is the spirited exchange of ideas where you listen and you are heard. It is a willingness to challenge friends when their actions contradict our expressed values. And it is supporting each other through struggles ranging from academic lows to waning faith.

Brotherhood means working in collaboration, learning as much from each other as from the classroom. It is abundantly present among the men of Morehouse, but is intended to extend beyond fellow students. As an institutional ideal, brotherhood extends to all the faculty and staff in the way we work and learn together, challenge and support each other. The goal is to achieve our most important objective—the making of men. And beyond the ‘House, brotherhood represents a value to be sought in all the personal, local and global communities our students will find themselves within.

We celebrate our alumni who continue to take the value of brotherhood with them when they depart and extend it into their own communities. We will continue to shape men who commit to brotherhood.

CONSEQUENTIAL It is perhaps the case that no principle is so persistently held at Morehouse as that of being “attendant to the social justice needs” of the brothers and sisters of one’s generation. That means having the awareness to see and understand those needs, and possessing the spirit, respect, and ethic that compel one to take action. It means finding allies, developing relationships, having the capacity to lead and the humility to follow when needed for the sake of getting done the work that is needed. And ultimately, it means using the full power of acuity, integrity, agency, and brotherhood to have a positive impact. In short, we expect and push our students to not only do well for themselves, but to do good in the world—to lead consequential lives. Moreover, we will continue pushing to ensure that Morehouse remains consequential as an institution.

This requires identifying challenges, recognizing one’s responsibility and power to make a difference, having the capacity to confront adversity with intelligence and compassion, and taking the steps necessary to promote change. Indeed, the names of the men who have been major players on the world stage are legion and there are thousands of Morehouse Men who may not be well known but who have, nevertheless, made important contributions. We will continue our rich tradition of producing men who strive to lead consequential lives.


Morehouse is the number one baccalaureate origin institution for black male doctorate recipients in science and engineering, life sciences, physical sciences, social sciences, education, and the humanities over the decade ending 2012, according to the National Science Foundation. We are the top producer of underrepresented minority physics baccalaureates among non-Ph.D. granting institutions over the three years ending in 2013, as measured by the American Physical Society. The College is the only non-majority college or university to produce four Rhodes Scholars.

There are many institutions that can lay claim to having graduated CEOs and athletes, artists and politicians, teachers, leaders, scholars and doctors, but only a small few to graduate a Nobel laureate in peace, an Olympic gold medalist, Grammy winner and Academy Award nominee, a surgeon general, cabinet secretaries and U.S. Congressmen. We are one such institution. Our mission is clear and our successes abundant.

In this strategic plan, we trumpet the tremendous value proposition inherent in a student embrace that focuses on building acuity, integrity and agency; promotes brotherhood; and challenges students to be consequential in the world. While this value is evidenced by the accomplishments of our alumni, it begins with a faculty and staff who have high expectations for these students, works to help students hear “the sound of the genuine,” These words are also from Howard Thurman and help students, in the words of Howard Thurman, realize that “the most important thing in life for any man at any time is the development of his own best self, the incentive to actualize his own potential.”

Continuing this work into the 21st century will require us to ensure that these ideals live in how we do every part of our work. It means creating a culture of acuity, integrity, and agency at the institutional level. Morehouse must be a place of learning not just among students, but among faculty, staff, administrators, and trustees. It must be a place of ethical behaviors and practices. And it must be a place where we each take responsibility and are held accountable. It means extending brotherhood to the entire Morehouse community to promote collaborative thinking and support. And it means striving to ensure that Morehouse strengthens its ability to have an impact in the world, maintains a voice in the important conversations that shape our world and the lives of black men, in particular, and ultimately becomes consequential.

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We can do this work because we think differently— fundamentally differently—about black men and black boys,

their potential, their strengths, and the possibilities.

Our approach is to help our young men hear the sound of the genuine— not to see them as deficient or broken in need of being fixed,

but full of potential and gifts and genius, waiting to be discovered, engaged and amplified.

DAVID WALL RICE ‘95 assistant provost for student success, associate professor of psychology


FIVE GUIDING PRINCIPLES In service to our unwavering mission and to ensure our ideals are reflected in the men we graduate and in Morehouse, as an institution, we have identified five principles essential to our capacity to be successful. These principles are applicable to and should live in everything we do. We must:

PRINCIPLE 1: ACCENTUATE OUR DISTINCTIVENESS We are like no other institution in the world. It is not just that we are all-male, or historically black, or that we assume the special responsibility for teaching the history and culture of black people. It is not only that we demand disciplined minds, leadership, and service along with liberal learning and the development of character. It is the combination of these strengths that multiplies our capacity to have an impact in the world and makes us extraordinarily unique. We must champion our singular position in all that we do. This distinctiveness has always been there. It is captured in the words and ideas of Thurman and Mays, and reflected in the accomplishments of our alumni, those who not only excel in their respective fields as scientists, corporate executives, lawyers, academics, and artists, but who do so much more for each other, their local communities, and the world.

It is critical that we ensure this distinctiveness is as deeply rooted in our curriculum, our student development activities, and in the way we engage the work of the College.

PRINCIPLE 2: EMBRACE AN INNOVATION IMPERATIVE Within today’s rapidly shifting higher education landscape, we must break from existing paradigms. We must experiment, take risks, and find the courage to face possible failure, armed with mechanisms to assess, learn, and try again. This means encouraging creativity and play in students, faculty and staff, ensuring opportunities to be trained on new tools, allowing ideas to flow from anyone at any level, and being willing to offer new courses in new ways. It may mean that we continue to do some things in traditional ways, but it means doing so intentionally with full understanding of other possibilities when we do.

PRINCIPLE 3: RISE TO FINANCIAL STRENGTH We must develop the unrestricted resources required to seize opportunities, try new ideas, and support the needs of the institution in perpetuity. Endowed funds liberate us to focus on our primary objective. But we will need to do even more if we are to avoid simply passing expenses on to our students. We must develop strategic partnerships with industry; leverage the time, effort, and expertise of alumni and friends; and accept gifts of space, intellectual and social capital, or experiential opportunities.

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PRINCIPLE 4: ATTRACT THE BEST TALENT POSSIBLE We must strive to be known for the talent in our community. We should seek in the students we admit, and in the faculty and staff we hire, the ability to learn and adapt, to think imaginatively, and to execute effectively. We need to demand not only a command of knowledge in relevant areas, but also a commitment to working hard and consistently advancing one’s skill and craft. With the landscape changing as rapidly as it is, we will be successful only if our community is committed to growing in excellence over time.

Morehouse already attracts great talent as many are both drawn and deeply dedicated to supporting this very special institutional mission. But the College will need to recommit to helping faculty and staff develop new skills as technologies, operational design, and pedagogies evolve. We must use this principle to inform our recruiting practices and our mechanisms for development. And we must recognize, empower and applaud all members of our community—faculty, staff, and students—who exhibit leadership and enact change in support of our shared objectives.

We should strive to truly know each other in this community and to help each other realize our full potential. And we must be intentional in the constructive assessment of our work, in the management of those people and tasks for which we are responsible, and in the service we provide to others. Our success will be measured as Morehouse evolves into an all the more sought-after destination by esteemed academicians, adept staff, and the world’s most talented students—a unique place of tremendous personal and professional growth.

PRINCIPLE 5: DEVELOP OPERATIONAL & SERVICE EXCELLENCE Becoming simultaneously more efficient, respectful, effective, and responsive is essential. We must, as an institutional practice, continually assess our engagement to ensure we are performing at the highest level, and we must change behaviors, systems, and policies when we are not. And we must invest in the development of both the people and infrastructure necessary to deliver on the promise of excellence.


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TOWARD CHARACTER PREEMINENCE Achieving character preeminence equates to fully realizing our primary objective: the making of men—men who exhibit in their understanding, actions, and benevolence our values, tradition, and expectations. Pursuant to this, we have five goals:

GOAL 1: STRENGTHEN THE ACADEMIC PROGRAM Ø Reestablish, redefine, and consolidate centers of excellence in key areas:

v Science, Technology, Engineering, Arts and Math (STEAM) Center

v Morehouse Research Institute (MRI)

v Ideas, philosophies, people and issues that influenced King

Ø Ensure curriculum is delivering on transformative student outcomes, most notably supporting our students becoming exactly who they most aspire to be: doctors, artists, lawyers, businessmen, academicians, innovators and entrepreneurs, teachers, and more

Ø Implement a new general education program

Ø Recruit, retain, reward and support outstanding faculty

INITIATIVES v STEAM Center: A center that brings together science, technology, engineering, the arts,

and mathematics and amplifies the capacity for Morehouse to significantly impact the diversity of those prepared to enter today’s innovation economy, with particular attention on increasing the number and quality of black men and other underrepresented groups in the technology innovation space

v MRI: A research institute that bridges the divide from questioning to acting on the issues, conditions, and challenges, as well as the possibilities, models of success, and achievements that impact, hurt and propel the lives of black boys and men. Specifically seeking to understand, through academic research and robust dialogue, black men in relation to:

§ Violence, police, law, and community § Education and teacher preparation § Health and health disparities § Sports and entertainment, including strong partnering with Journalism and

Sports, Kinesiology and Sports Science, and CTEMS programs § Others as relevant

v KING: A center dedicated not just to King, but to the full breadth of his ideas, influencers,

impact, philosophies, development, and relationships. § Major sources of conflict: race and ethnicity; economic and social class; religion

and faith; gender and sexuality


§ Strategies: violent vs. nonviolent; hierarchical vs. social/networked; law and policy vs. economic pressure vs. moral/faith arguments, etc.

§ Development, evolution and relevance § Others as relevant

v Ensure curriculum is delivering on transformative student outcomes, particularly in: § Health sciences, including everything from doctors to health innovators to

public health professionals § Law, through the King Initiative and the Department of Political Science § Ph.D.s/researchers § Business and entrepreneurism, through the STEAM Initiative, as well as the

Division of Business and Economics § Teachers

v General Education: Create a smaller, distributive model more closely aligned with clear learning objectives that are connected to our mission and to the preparation of students for 21stcentury needs, including:

§ Proficiency in technology/digital media/data § Having a global prospective in the curriculum § Understanding black history, life and culture § Writing and communication § Developing the ability to see problems in the world and find solutions § Providing opportunities to develop creative thinking and effective leadership

skills v Recruit, retain, reward and support outstanding faculty with:

§ Endowed positions and faculty fellowships § Enhanced infrastructure for scholarship and research, particularly with

students

MEASURES OF SUCCESS § Programs organized and fundraising begun by Summer 2016 for each with

partial foundational start by Fall 2016

§ 20% to 30% of the resources raised by Summer 2017

§ Increased presence in the national conversations on black men, technology, social justice, etc.

§ Students active in producing outcomes or research in each area

§ Enhanced reputation (going from current US News and World Report ranking of 133 to 125).

§ Improved post-graduation outcomes from current rate of 85% (employment + grad rate) to 91%

§ Greater success in national awards and scholarships

§ Improved graduation rates:

• Average 4-year graduation rate improve from 34% to 38% with a stretch goal of 45% or higher

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• Average 6-year graduation rates from 53% to 56% with a stretch goal of 60% or higher

§ Students who are better prepared for the global, interdisciplinary economy

§ Establishment of three to five new endowed positions with support for position, benefits and student support funding

§ Secured funds that support three to five sabbaticals each year

§ Supported summer research opportunities supports students and at least five faculty each summer

§ Increasing competitiveness for faculty positions by as measured by obtaining 12-24 applications for each faculty position

§ Providing salaries for faculty in the 50th percentile of market rates with additional incentive compensation systems for the most highly productive faculty

§ New assessment mechanisms and procedures that allow us to identify ineffective faculty within a few years and acknowledge effective faculty. This should result in greater satisfaction with faculty performance

§ Faculty load maintained at 3/3 or 3/4 for most faculty, with a load 3/2 in some cases, and over particular periods 2/2

GOAL 2: SUPPORT PEDAGOGICAL EXPLORATION AND INNOVATION

Ø Explore and pilot online, hybrid and other modes of teaching

Ø Expand active-learning, experiential-learning opportunities

Ø Strengthen faculty development

INITIATIVES v Pilot online and hybrid courses: Explore online and hybrid delivery on both a small

scale—individual courses that would be part of our existing program—and a large scale, potentially offering a whole new way for students to engage and earn a degree from Morehouse, that is consistent with expectations of the on-campus Morehouse experience

v Pilot intensive short courses during breaks: Assess one-week to four-week intensive courses (demanding students to commit 12 hours per day)

v Incorporate active learning opportunities into General Education: Integrate research and other discovery-based courses into the general education core

v Support experiential-learning opportunities during the summer: Provide faculty research grants that engage students; restructure student summer programs to allow for more learning through projects; partner with industry, alumni, and colleagues at


other institutions to offer a range of experiences to complement the academic/curricular learning

v Develop mechanism for faculty to cultivate new ideas for courses: Provide regular opportunities for faculty to go from ideation to pilot and assessment, ultimately leading to full implementation of good ideas

v Strengthen faculty development center: Provide the time, space and support for faculty to engage in the scholarship of teaching and learning, collaborate on research projects, and share their work

MEASURES OF SUCCESS § Launch at least twelve (12) new online/hybrid courses piloted by 2018 with

several becoming institutionalized

§ Pilot two (2) short courses by January 2017; Pilot six (6) short courses by January 2018

§ Establish solid corporate, alumni or other partnerships to support intensive courses being offered through our career services programs by 2018

§ Support up to ten (10) faculty working with three to five students each over the summer with experiential learning activities by Summer 2018

§ Increase the number and level of engagement at research cafés where faculty share outcomes of summer or sabbatical research, as well as increasing SOTL workshops and other faculty learning engagements

§ Increase the number and improve the veracity of assessment reports of piloted courses as part of the curriculum review process leading to standardization of ideation to pilot to implementation by 2018

GOAL 3: STRENGTHEN ADVISING AND MENTORING » Improve information about courses and the full academic experience

» Deploy technology that supports improved, more robust advising by faculty and divisional advisors

» Deploy a “One-Stop” approach to enrollment

» Improve Career Services and other post-Morehouse planning services

» Strengthen support for prestigious scholarships, fellowships and awards

INITIATIVES v Design and deploy improved course catalog: Create a 21st century mechanism for

students to understand courses, degree requirements, pathways to careers, experiential learning opportunities, scholarships, and more, so that students can exercise better agency over completing their Morehouse education

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v Deploy Civitas: Implement predictive analytics tool that allows us to monitor and support student success

v Deploy Starfish: Implement this tool that allows us to act on the information above to provide timely interventions for students

v Deploy One-Stop/Compass: Create a new (to Morehouse) approach ensuring that students can solve financial aid, registration and other issues on their own most of the time, and have an easy, single way to navigate all these issues

v Become a model of excellence in career and professional development

v Deploy a student career portal: Implement technology designed to help students navigate much of the career exploration and options on their own and prepare information for better discussions once a career adviser is engaged

v Create a Prestigious Fellowships and Awards office: Support students and recent alumni through the process of identifying and applying for awards; and identify students who would make good candidates for prestigious awards

MEASURES OF SUCCESS v Improved course catalog launched by 2018

v Technology deployed that allows us to manage and deliver course catalog; and catalog available to all constituents that is up to date with latest information on courses, degree and major requirements, etc.

v Civitas fully launched and implemented for all students by 2018

v Starfish fully launched and implemented by 2018

v One-Stop/Compass fully deployed and increase in student satisfaction with services in enrollment—financial aid, registrar’s office, etc.

v Create a career and professional development center and deploy career portal by 2017

v Greater satisfaction with career placement, most notably for those students who are not business or economics majors

v Maintain percentage of placement in grad school and employed at 85%, even as percentage of graduates increases

v Create a Prestigious Fellowships and Awards office by 2018


GOAL 4: ENHANCE THE LIVING-LEARNING ENVIRONMENT » Implement a residential college model:

› Add faculty and peer engagement space to residence halls › Develop and engage students in curriculum complementary to academic program

» Create vibrant on-campus social, intellectual programming

» Strengthen athletics program

INITIATIVES v Deploy residential college model: Restructure dean and intervention model, leverage

faculty in holistic teaching and learning, reorganize residences to accommodate meaningful groups, including STEM residences and career-based themed living

v Continue Crown Forum After Dark and create similar events: Engage students in intellectual and social events with speakers; productions that they produce and are involved in; and other work that marries the curricular with the co- and extra-curricular in meaningful ways.

v Strengthen Athletic Program to have a positive influence on admissions:

§ Improve facilities (in part to attract top talent in basketball, football, and baseball, and track most notably)

§ Partner with alumni and friends of the College to offer interaction with world-class athletes and those in athletics

§ Connect athletics with academic program, most notably in Kinesiology and Sports Science, Journalism and Sports, STEAM and MRI efforts

MEASURES OF SUCCESS v The new residential college model completely deployed and engaged by 2018

v Significant increase in attendance at Crown Forum events and decrease in students not fulfilling Crown Forum requirements prior to graduation

v Combined results of more students wanting to live on campus, yielding higher on-campus occupancy, which leads to better academic performance

v Increase in quality of athletic talent coming to Morehouse

v Increased wins and successes in athletic competitions

v Improved attendance at athletic events

v Increased opportunities for students intersecting sports and academics

22 orehouse Plan

GOAL 5: ATTRACT, RECRUIT & ADMIT A DIVERSE NEW GENERATION OF STUDENTS

» Clarify our value proposition

» Expand and diversify pool of domestic students

» Recruit and matriculate a larger pool of international students

» More effectively leverage summer and pre-college programs

» Improve credit transfer policies for transfer students

» Design new ways for students to engage Morehouse

INITIATIVES v Clarify our value proposition: Engage in branding and marketing work, particularly in print

materials for students and families and online. Engage outside groups, such as, parent and alumni associations

v Expand and diversify pool of domestic students. Expand recruitment into additional domestic markets by increasing staff and reaching new high schools and spaces of students.

v Recruit and matriculate a larger pool of international students. Increase diversity by expanding recruitment into additional international markets such as African nations, the Caribbean, China, Brazil, and France.

v More effectively leverage summer and pre-college programs/improve credits transfer policies for transfer students.

§ Improve yield through events, which can include "Transfer Days" and additional "Admitted Students" days.

§ Maximize the admission and recruitment by implementing a model that plans, monitors, appraises, and reviews job performance of those involved in recruitment

§ Strategically award institutional scholarship to yield the best "fit" students and to close need gap.

v Design new ways for students to engage Morehouse. Deploy technology, such as:

§ Target-X, a customer relationship management tool, to manage admission funnel; understand and leverage trends; monitor critical measurements such as production, productivity and quality; and support improved customer service;

§ Social media tools to reach out to students where they are and to operate more efficiently, using email marketing software and other social media tools.


MEASURES OF SUCCESS v Number of Applicants/Admits:

§ Increase number of applications from under 3000 to over 3500

§ Number of students admitted decreases from over 1900 to under 1900, preferably 1800

§ Admissions rate moves from above 75% to nearly 50%, preferably below 50% to improve selectivity

§ Number of first-time freshmen from just over 600 to 625, and eventually up to 650

§ Number of transfers growing from 75 to 125, and eventually up to 150

§ Number of Students attending "Admitted Students" weekend from 400 to 475, eventually going to 500

v Diversity of Applicants/Admits:

§ Percentage of African Americans moves from nearly 95% to 90%

§ Percentage of Hispanics moves from 10% to 15%

§ Percentage of International students moves from 2% to 10%

v Quality of Applicants/Admits:

§ Admitted GPA maintained at 3.36 with a stretch goal to move to 3.5 GPA

§ Increase enrolled GPA from 3.1 to 3.2 with a stretch goal of 3.3 and higher

§ Enrolled ACT maintained at 22/23, which is five points over the black male average

(*SAT scoring changed as of January 2016, so we are unable to use this measure until new data points are clearly established).

v Transfer Policy:

§ Complete update to transfer policy that allows large percentage of transfer credits to convert to Morehouse credit, including application of technology solution that automates this conversion

24 orehouse Plan

TOWARD CAPITAL PREEMINENCE Morehouse College must create a financial base to adequately support the fulfillment of its mission. Morehouse College must free itself of a small endowment, limited financial aid, deferred maintenance, and uncompetitive salaries. The world needs us to be free. Our mission demands that we be free. Capital preeminence is a freedom agenda. In order to fully educate first-rate men of intelligence and character, we must establish a significantly larger endowment, a modern campus, and new, more extensive partnerships. And we must be accurate, transparent, and efficient in the work that we do. Pursuant to this, we have five goals:

GOAL 6: ATTRACT, RECRUIT, AND RETAIN A 21ST-CENTURY WORKFORCE

Ø Work toward a more competitive compensation model

Ø Clarify and improve the full life cycle of faculty and staff

Ø Engage in innovative ways of bringing talent to Morehouse

INITIATIVES v Competitive Compensation Model: Implement a competitive compensation program for

staff that rewards performance and keeps pace with market based salary data

v Clarify full-life cycle:

§ Promotions: Clear pathways to promotion, greater rank, higher salary

§ Onboarding to retirement: Clear support throughout the entire life cycle of employment with opportunities for learning, being mentored, mentoring, and transitioning

v Innovative ways to bring talent:

§ Partnering with industry

§ Partnering with alumni and friends of the College—perhaps most notably in short-term intensive courses

§ “Fellows”—academics, leaders, thinkers—on loan from other institutions or partnering in interesting ways for short-term work

MEASURES OF SUCCESS v Improve staff salaries to close to the 50th percentile of market salaries with clear

measures for performance-driven compensation.

v Improved employee engagement, as measured by an annual employee engagement survey


v Increase competitiveness for positions by pursuing strategies that increase applications for jobs.

v Increased percentage of faculty who come from partner organizations

v Increase number of special engagements with alumni or friends of the College

GOAL 7: IMPROVE ORGANIZATIONAL CULTURE Ø Expand skill-building and training opportunities

Ø Improve data governance

Ø Improve assessment and feedback mechanisms

Ø Engage in strategic prioritization and project management

Ø Support collaboration across departments

INITIATIVES v Expand training: particularly in areas of technology and process; provide the space, time

and opportunity for faculty and staff to be continual learners

v Deploy a data dictionary and deploy tools that support compliance

v Improve assessment: This is one of the largest tasks. We must become a culture of assessing, looking at and using the assessment to make improvements, and documenting the full cycle

v Strategic prioritization: We must put the right people on the right tasks at the right times to achieve the highest priority results most effectively

v Collaboration: Create a cooperative working environment that supports process improvement (typically with the student outcome at the center) as opposed to functional optimization

v All of the above: Champion the values of accountability, effectiveness, transparency, and efficiency as an organization

MEASURES OF SUCCESS v Complete and implement data dictionary by Fall 2016, and complete business process

redesigns of data centers and input processes resulting in more accurate, consistent data that will drive real-time, informed decision making.

v Build a culture of institutional assessment that prepares us for our accreditation review by SACSCOC by 2018

v Cultural shift from siloed operations to collaborative work, focusing on execution, outcomes and objectives to create more efficient operations.

26 orehouse Plan

GOAL 8: Develop World-Class Infrastructure Physical Space: Complete master plan for campus

» Technology: Optimize technology solutions to objectives

» Operations: Implement continual improvement process practices

» Data & Information: Enhance capacity and practices to collect and use data

» Communications: Increasing the use of digital media, find new ways to tell our unique stories

INITIATIVES v Physical Space: Complete master plan, including:

§ Plans for the athletic spaces

§ Plan and begin executing on sequences of moves that allow for construction of new building(s) to begin

§ Focus on environmentally friendly, sustainable options that promote energy efficiency, are flexible and capable of being repurposed

§ Spaces that are responsive to student development and academic objectives, allowing for innovations in pedagogy related based on the construction and energy efficiency objective

§ Making the space a magnetic destination for students, faculty, staff and guests

§ Integrate and connect the new campus to the surrounding communities.

v Technology:

§ Improve WiFi infrastructure (fiber optics, copper, switches, and all the other hidden infrastructure)

§ Deploy new phone system allowing for e-faxing, digital voicemail

§ Move major systems to the cloud

§ Install physical and cyber security systems

§ Upgrade classroom and other shared technology

§ Increase staffing to improve help desk and service

v Operations: Be in a continuous state of process improvement, always identifying priorities relative to the objectives established in this plan by using appropriate data to take action in an effort to improve process and inform next priorities, and then repeat the cycle

v Communications: Fundamentally, we must do a better job of telling our story to all of our various constituents—internally, but mostly externally


MEASURES OF SUCCESS v Completed master plan and phasing that meet values above by 2017

v Successful completion of technology initiatives by 2018

v Implementation of continuous improvement processes in all divisions of the College.

v Demonstrated shift in the culture whereby data-driven decision-making, collaboration, execution of outcomes, and continuous assessment and adjustment are pervasive throughout College administration and operations.

v More publications issued both online and in print; Morehouse in the news (positively) more often; and positive statistics and accomplishments more widely known

GOAL 9: EXPAND AND BETTER STEWARD RESOURCES » Improve stewardship of all assets, most specifically across the key areas of:

› Procurement › Benefits › Gifts and grants › Physical space › Financial resources

» Better engage planning

» Strengthen, manage, and leverage strategic relationships

» Improve safety

» Expand fund-raising capacity

» Improve operating and financial efficiencies

INITIATIVES v Stewardship: Deploy best practice, full-cycle asset management practices from intake to

allocation to spending to reporting with the objective of achieving fiscal integrity

v Planning: Engage a more inclusive and transparent budgeting process that allows us to leverage our resources in a manner that is aligned and consistent with strategic priorities while lengthening the planning cycle

v Strengthen relationships: Develop best-practice donor reports rich with detailed information regarding the impact of their contributions to the College (in turn encouraging further investment in Morehouse); focus on elevating “customer service” across all departments and units; establish clear standards of accountability and service in all constituent engagements, from parents to alumni to friends

v Safety: Establish a secure perimeter around the College, allowing our students to feel and be protected as they move through the campus

28 orehouse Plan

v Expand fund-raising capacity: Increase the size of the Advancement Office significantly, adding more robust research capabilities and technology capabilities; focus on the ability to raise unrestricted aid, capital resources, and endowed professorships

v Efficiencies: Deploy best practices in procurement with appropriate technologies to ensure we have the best financial vehicles in a way that ensures appropriate oversight, auditing, internal controls and data security, thereby minimizing compliance and audit findings

MEASURES OF SUCCESS v Improved relationships with donors leading to increase in fundraising efforts

v A balanced budget by 2018

v Improved experience by constituents as measured by an established system of assessment

v Improved crime statistics demonstrating a decrease in violent and/or property crimes on campus

v Increase in annual fundraising dollars.

v Decrease in audit findings/compliance findings

GOAL 10: EXPLORE MORE COST-EFFECTIVE EDUCATIONAL MODELS

» Pilot alternative Morehouse experiences, including online courses and engagements for audiences other than our traditional students

» Examine ways to reduce the student cost of earning a Morehouse degree

INITIATIVES Many institutions are implementing strategies to combat the high cost of tuition. Various cost-cutting propositions include developing online programs, accelerated degree programs or other policies that aim to minimize cost, only to learn hard lessons about the unsustainability, unexpected start-up costs, or other challenges associated with their efforts. A smaller number of institutions have been rewarded for taking bold new steps.

Given the current state of affordability and the lessons shared by other institutions, we know that it is imperative to not only experiment, but also proceed carefully. Therefore, rather than commit to pursuing a new educational and financial model in the next three years, our goal is to gather enough evidence to position us well for such a pursuit. In particular, we will:

› Pilot intensive short-courses during breaks: (see Goal 2)

§ We will consider similar academic programs and course-offerings during the summer and other College breaks with a common hope for these and other courses is that we selectively open them to non-Morehouse students


§ We will explore high school (including dual-degree students), students attending other colleges, and adult students hoping to funnel some of these students into the academic year program, even if only for a semester

§ In addition, we could offer certificates, exchanges, or other programs; coordinated with student-success initiatives (courses that help bridge gaps in preparation, for example); or simply fun, interesting opportunities for intellectual engagement

› Pilot online and hybrid courses: (see Goal 2)

› Strengthen our current pipeline programs: We already offer several middle school and high school programs, but we can be much more deliberate about how those programs feed the student pool for future Morehouse students and how we generate revenue from those programs

› More effectively use auxiliary services: As we improve physical space (and even now), we can increase our use of all of our assets as ways to bring in new revenue, being careful not to interfere with the curricular, co-curricular, and extra-curricular work with students

MEASURES OF SUCCESS

› Compilation of evidence of strategically aligned with the Morehouse mission that can be submitted for consideration to the leadership and the board

› Participation in various think-tanks/forums on higher education business models

› Being prepared to explore a new business model fully in 2019

30 orehouse Plan

PROFILES OF PREEMINENCE: Morehouse Men, Faculty & Staff

SPIKE LEE ’79 FILMMAKER, DIRECTOR, PRODUCER

Spike Lee is an American film director, producer, writer, and actor. His production company, 40 Acres and a Mule Filmworks, has produced over 35 films since 1983. Lee was born Shelton Jackson Lee on March 20, 1957, in Atlanta, Georgia. At a very young age, he moved from pre-civil rights Georgia, to Brooklyn, New York.

Lee came from an artistic, education-grounded background; his father was a jazz musician, and his mother, a schoolteacher. After graduating from Morehouse College, Lee attended the Tisch School of Arts graduate film program at New York University.

DR. DELORES STEPHENS PROFESSOR OF ENGLISH A native Virginian, E. Delores B. Stephens holds degrees from Spelman College (B.A. in English) from which she graduated as valedictorian; Atlanta University from which she holds the M.A. in English and American Literature (thesis published in the microfilm collection of the University of Kentucky); and from Emory University (Ph.D. in English). In addition, she earned a certificate for completion of a summer of academic work in Nineteenth Century British Literature from the University of London and a Testamur (one year) from the University of Exeter (Great Britain) for study of British literature – Shakespeare and Twentieth-Century Writers. Before joining the faculty at Morehouse College in 1964, she was on the faculty at the Atlanta School of Business and at Norfolk State University.

CALVIN BUTTS ’72 PASTOR, ACADEMICIAN In 1972, Calvin Butts received his B.A. degree from Morehouse College; while a student, he pledged Kappa Alpha Psi fraternity and was active in civil rights. After the assassination of Martin Luther King, Jr., Butts and several other Morehouse students took to the streets in anger. After graduation, Butts returned to New York where he earned his master of divinity degree in church history in 1975 from Union

Theological Seminary and later his doctorate of ministry in church and public policy from Drew University. While still in graduate school, Butts was hired to work at Abyssinian Baptist Church where he began as an office assistant and worked his way up to assistant pastor, eventually being named head pastor in 1989.


PAUL JUDGE ’98 INVENTOR, ENTREPRENEUR, INVESTOR Paul Q. Judge is an award-winning technologist, entrepreneur, and speaker. Judge was a technical expert for the Federal Trade Commission in the 2005 Report to Congress on the Effectiveness of the CAN-SPAM Act. In 2003, he founded the

Anti-Spam Research Group in the Internet Research Task Force.

Judge attended Morehouse College in Atlanta earning a B.S. in computer science with a minor in mathematics in three years. He then matriculated at Georgia Tech, completing M.S. and Ph.D. degrees in Computer Science in 2002. Judge then did post doctorate work at Georgia Tech in 2003. Judge joined the founding team of CipherTrust in 2000 and served as Chief Technology Officer until the company was acquired in 2006. Judge served as Senior Vice President and Chief Technology Officer of Secure Computing Corp. until 2007. Judge founded Purewire in 2007, acquired by Barracuda Networks in 2009. He is cofounder and Executive Chairman of Pindrop Security, provider of phone anti-fraud and authentication solutions, founded in 2011. Most recently he is co-founder of Luma, a wireless networking company.

EDWIN MOSES ’77 ATHLETE, HUMANITARIAN

Edwin Corley Moses accepted an academic scholarship to Morehouse College where he majored in physics and industrial engineering, while competing for the Maroon Tiger track team. Moses won gold medals in the 400 m hurdles at the 1976 and 1984 Olympics. Between 1977 and 1987, Moses won 107 consecutive finals (122 consecutive races) and set the world record in his event four times. In addition to his running, Moses was also an innovative reformer in the areas of Olympic eligibility and drug testing. In 2000, he was elected the first Chairman of the Laureus World Sports Academy, an international service organization of world-class athletes. In 1994 Moses received an MBA from Pepperdine University and was inducted into the National Track and Field Hall of Fame.

DAVID MORROW ’80 GLEE CLUB DIRECTOR, PROFESSOR OF MUSIC David Morrow is a native of Rochester, New York. He earned the Bachelor of Arts degree from Morehouse College in 1980. While at Morehouse, he became a member of Phi Beta Kappa, was awarded the Kemper Harreld Award for Excellence in Music, received departmental honors, and graduated Valedictorian

of his class. He received the Master of Music degree from the University of Michigan in 1981 and was elected to Pi Kappa Lambda. He received the Doctor of Musical Arts degree from the University of Cincinnati College Conservatory of Music in 1995. Dr. Morrow has been a member of the Music faculty at Morehouse College since 1981. He served as Assistant Director of the Morehouse College Glee Club until 1987, when he succeeded Dr. Wendell P. Whalum as Director of the Glee Club.

32 orehouse Plan

VERY SIMPLY, CHARACTER PREEMINENCE MEANS PRODUCING FIRST-RATE MEN, WHILE CAPITAL PREEMINENCE MEANS HAVING A FIRST-RATE CAMPUS. AND WE WILL HAVE THE WORLD OF OUR DREAMS WHEN WE ARE RECOGNIZABLY AND COMPLETELY PREEMINENT IN BOTH.

Toward Character & Capital Preeminence.

The most important thing in life for any man at any time is the development of his own best self, the incentive to actualize his own potential.

The sound of the genuine is flowing through you. Don’t be deceived and thrown off by all the noises …. You may be famous; you may be whatever the other ideals are which are a part of this generation …. Cultivate the discipline of listening to the sound of the genuine in yourself.


34 orehouse Plan

morehouse.edu

830 Westview Drive SW

Atlanta, Georgia 30314


ATTACHMENT D


ATTACHMENT E


ATTACHMENT F

Morehouse College Staff Development Program

Syllabus

3/17/15

Higher Education Compliance 101 This course is designed to familiarize Morehouse College employees with the compliance culture of the College. Participants will explore the specific federal and state regulations that apply to the various constituencies the College serves, and how each individual and department is instrumental to meeting and exceeding the College’s compliance requirements. This course is required for all managers and supervisors and recommended for all employees. PreRequisite: None Materials Needed: None Instructors: Lacrecia G. Cade, General Counsel Doris Coleman, Director of Ethics and Compliance

This class will explore:

Ø Governance & The Compliance Culture – Participants will learn about the governance structure of Morehouse College and the responsibility of each member in the Morehouse community to ensure that the mission of the College is fulfilled in a manner that is consistent and observant of the governing regulations and core ethics of the institution.

Ø The Panacea of Governing Laws –This section will explore the underlying federal laws that the various regulations governing Morehouse flow from: the Higher Education Opportunity Act (“HEOA”), the Family Educational Rights and Privacy Act (“FERPA”), the American with Disabilities Act “(ADA”), Title IX of the Civil Rights Act, Title VII of the Civil Rights Act, Health Information Portability and Accountability Act (“HIPAA”) etc. Participants will gain an understanding of the policy reasons behind the laws and regulations to ensure that those policy principles are routinely considered as decisions are made at Morehouse. This will be a summary overview of the various laws.

Ø The Morehouse Sea of Regulatory Compliance – What regulations apply to

Morehouse? Why do they apply to Morehouse? What does that mean for my department? What does that mean for me? These are all questions that we will explore.

Ø Grants Compliance – Morehouse is the recipient of millions of dollars in grants money.

Faculty and staff are the shepherds of these funds and the awarding agencies, governmental and non-governmental, impose strict requirements that must be followed. Participants will have a brief discussion of the broader implications for grants compliance for the entire institution with real-word scenarios to consider.

Ø Federal Regulations Pertaining to Sexual Violence – Title IX, VAWA, Campus SAVE

and Clery are hot topics throughout higher education. Participants will get an overview of these laws and the corresponding regulations and how they impact our campus. Participants will learn about training resources and Morehouse internal policies pertaining to Title IX.

Ø Retaliation and Whistleblower – It is part and parcel to establishing a compliance culture to create an environment where people can freely and without undue pressure alert the appropriate members of the community when there may be activity occurring that places the institution at risk. Participants will learn about how they can play an active role in ensuring we remain a community free from retaliation.

+

Higher Education Compliance 101Lacrecia G. Cade & Doris ColemanOffice of General Counsel and Compliance

+Higher Education Compliance 101

n Compliance Culture

n Compliance Orientation

n Compliance At Morehouse

+The Department of Education is

Calling . . .

Financial Aid

Registrar

Faculty

Students

Business and

Finance

Legal

+Morehouse Governance Structure

n Shared Governance

n What Does That Mean At Morehouse?

n College Officers

n Presidents

n Vice Presidents

n Board of Trustees

n Fiduciary Responsibility

n Committees – Audit, Educational Policy, Student Affairs, Investment, Finance, Athletics

n All College Employees

n We ALL have a responsibility

+Governing Laws

n Higher Education Opportunity Act “HEOA”n Federal Student Aid

n Student Academic Progressn Drug and Alcoholn Affordabilityn Ratingsn Student Bill of Rights

n Family Education Rights and Privacy Act “FERPA”

n Student Education Records

+Governing Laws

n Americans with Disabilities Act “ADA”

n Accessibility

n Employment Discrimination

n Accomodations

n Title VII

n Employment Discrimination

n Sexual Harassment

n HIPAA

+Grants Compliance

n Grant Sources

n Federal Government

n State Government

n Private Foundations

n Individuals

n Office of Sponsored Programs

n Sub-recipients

n Grants accounting

n Federal Requirements

n EDGAR

n A-133 Audits

n Key Issues

n Grants Substantive Compliance

n Expenditures

n Reporting

+Higher Education Compliance 101

n Governance & The Compliance Culture

n The Panacea of Governing Laws

n The Morehouse Sea of Regulatory Compliance

n Grants Compliance

n Federal Regulations Pertaining to Sexual Violence

n Retaliation and Whistleblower

n THE END

COMPLIANCE TRAINING

A. The U. S. Federal Sentencing Enacted in Guidelines• Enacted in 1991 as the Organizational

Sentencing Guidelines (Chapter 8)

•To make penalties for crime uniform & to encourage “good corporate citizenship”

COMPLIANCE TRAINING

• Penalties include fines, restitution, sanctions, imprisonment & corporate probation for organizations that do not have a corporate compliance program

• Probation includes federal monitoring & adoption of a mandatory compliance program.

• An organization with a compliance program will receive reduced fines, probation and criminal prosecution.

COMPLIANCE TRAINING

B. 7 Steps to an Effective Compliance Program1. Establish Policies, Procedures and Controls

● must have a full life cycle mgmt. of policies and procedures including authoring, approvals, version control, audit trail, archive & alerts● link policies/procedures to applicable laws/regulations. Critical for

demonstrating proof of compliance during an audit

2. Exercise Effective Compliance and Ethics Oversight● must have multiple layers of mgmt. involved in the ethics &

compliance process knowledgeable of the program

3. Exercise Due Diligence to Avoid Delegation of Authority to Unethical Individuals● must delegate this responsibility to someone whose behavior does not

include a history of engaging in illegal behavior/activities

COMPLIANCE TRAINING

3. Exercise Due Diligence to Avoid Delegation of Authority to Unethical Individuals (cont’d)● includes third party risk mgmt. such as vendor compliance & risk management● policies & procedures sent to all employees, third parties, or vendors

4. Communicate & Educate Employees on compliance and Ethics Program ● regular communication of program throughout organization● education & training; internal risk assessments; development of action plans

5. Monitor and Audit Program for Effectiveness● ensure that program is followed by employees; monitor high risk areas● create mechanisms for auditing & reporting on the effectiveness of the program● ensure compliance assessments on a quarterly or monthly basis● ensure remediation is completed w/deadlines

COMPLIANCE TRAINING6. Ensure Consistent Promotion of the Program & Enforcement of Violations

● appropriate disciplinary mechanism in place to address discipline of individuals responsible for compliance offenses.

● ability to capture compliance related incident information & track the progress of compliance investigations

7. Respond Appropriately to Incidents and Take Steps to Prevent Future Incidents

● take steps to respond to an offense or incident

● automate the investigative process

● establish external hotlines to provide for anonymity

COMPLIANCE TRAINING

What is Fraud Against the Federal Government?

False Claims Act – Federal Sentencing Guidelines – Commonly Used Civil Statute

q Provides civil remedies for submitting a false claim for payment by the government or making a false statement in order to obtain such payment.

Remedies:- Treble damages (3 times the amount the government was

harmed)- Civil penalties of $5,500 to $11,000 per false claim

COMPLIANCE TRAININGC. Organizations Who Have Violated These Guidelines

q Morehouse College, 2011 – NSF & NASA grants resulting in a 5 year mandatory compliance agreement. Misuse of federal grant funds for personal use by former faculty member (first class travel unrelated to grants), purchase of equipment & services unrelated to grants. MH paid $1.2 million to the federal government in a civil settlement agreement.

q Clarke Atlanta – 2006 – Misused funds from a US Department. Of Energy contract. They were not able to account for most of the $24 million in research grants it administered from 1990-2002 (False Claims Act). Entered into a 5-yr. mandatory compliance agreement and agreed to pay $5 million in 2006. Misconduct was raised by a Whistleblower who received 22% of the $24 million.

COMPLIANCE TRAINING

q Clarke Atlanta – 2014 –NCAA violations/Basketball Program – An assistant coach & former basketball volunteer coach acted unethically & provided impermissible benefits to student athletes (cash, airline tickets, meals). 3 yrs. probation from 2014-2017, $5k fine; vacation of all their men’s basketball wins; revocation of the 2011 SIAC conference championship for women’s tennis; limited scholarships for men’s basketball to a total of 9; for women a limit of 2.

q Emory –2008 – Top psychiatrist earned more than $2.8 million from drug makers via consulting agreements from 2000-2007; failed to report $1.2 million of that income to Emory & violated federal research rules. Had previously signed a letter of agreement w/Emory that he would earn less than $10k a year.

COMPLIANCE TRAINING

C. Organizations Who Have Violated These Guidelines (cont’d)q The University of the District of Columbia agreed to pay $530,000 to the federal

government to resolve allegations that they submitted false claims for payment on an NSF grant, failed to maintain adequate documentation to ensure (establish a stem program).

q A University of Michigan administrator embezzled more than $85k; purchased at least 75 computers & computer related items ; then sold the equipment for personal gain.

q A researcher at Ohio State misused nearly $100,000 in grant money in 2006. He was accused of double dipping from federal grant money from NIH. He applied for two research grants from the same agency to pay for two nearly identical projects.

COMPLIANCE TRAINING

D. Oversight of Compliance – Bursting the Dot.Com or Technology. Bubble1. Year 2000 - New economy – investors getting rich off unprofitable stocks w/high prices &

higher price/earnings ratios w/firms like software companies and all things computer and Internet. Cisco Systems, for example, traded at more than 150 times earnings in March of 2000.

2. Year 2001 – Terrorist Attacks – helped shape other financial events of the decade. Devastating human loss and economic loss. 9/11 caused a catastrophic financial loss for the US. In addition:

q Enron, the emergence of corporate fraud & corporate governance. Considered the “IT” company – biggest fraud/financial maneuvering (hiding debt & fabrication of numbers). Established fake shell companies, recorded false revenues by recording one dollar of revenue multiple times –creating the appearance of earnings figures.

COMPLIANCE TRAINING3. 2001-2002- Arthur Anderson, one of the top 5 public accounting firms was caught up in

the corporate fraud scandal of Enron and lead to its downfall. Enron hid billions of $$s of debt from its shareholders in failed deals & projects; pressured its auditors, Arthur Anderson, to ignore the issues. Shareholders lost ore than $60 billion. The stock market continued to fall as did investor confidence. Anderson’s Chief Auditor ordered the shredding of thousands of documents – made the phrase “cook the books” a household word.

q Another corporate giant fails - Tyco International – 2002 – once considered a blue chip company, symbolized excesses of executive compensation at shareholders’ expense. CEO stole hordes of money from the company in the form of unapproved loans (w/o board approval) and fraudulent stock sales. CEO and CFO convicted of stealing $600 million from the company. He will always be remembered for the $2 million party he threw for his wife on a Mediterranean island that featured entertainers dressed in togas & an appearance at company expense, $6,000 shower curtain.

COMPLIANCE TRAININGThese corporate scandals led to the passage of the Sarbanes-Oxley Act of 2002.

The Sarbanes-Oxley Act of 2002 (often shortened to SOX) is legislation passed by the U.S. Congress to protect shareholders and the general public from accounting errors and fraudulent

practices in the enterprise, as well as improve the accuracy of corporate disclosures (public companies)

The Act requires all financial reports to include an internal control report. This is designed to show that not only are the company's financial data accurate, but the company has confidence in them

because adequate controls are in place to safeguard financial data. Year-end financial reports must contain an assessment of the effectiveness of the internal controls. The issuer's auditing

firm is required to attest to that assessment.

COMPLIANCE TRAINING

Sarbanes-Oxley Act

A CEO or CFO who submits a wrong certification is subject to a fine up to $1 million and imprisonment for up to ten years. If the wrong certification was submitted

"willfully", the fine can be increased up to $5 million and the prison term can be increased up to twenty years.

Some portions or SOX are also applicable to private companies.

COMPLIANCE TRAINING

What Should I Do

q Promote integrity

q Look for the “lie”

q Recognize fraud indicators and irregularities

q Report potential wrongdoing (do not wait for proof)

q When in doubt, report suspicions & ask questions

q Cooperate with external auditors & the federal government


ATTACHMENT G

MOREHOUSE COLLEGE FY2015 Compliance Program Audit Plan

BACKGOUND Morehouse College (the “College”) entered into a Settlement Agreement with the United States in connection with review of past grant agreements with the National Science Foundation (NSF) and the National Aeronautics and Space Administration (NASA). As part of the settlement agreement, the College was required to establish a Compliance Program to ensure compliance with the terms and conditions applicable to any NSF and NASA awards; to ensure compliance with laws and regulations governing NSF and NASA awards; and, to demonstrate the College’s commitment to the prevention of fraud, false statements, and misuse of funds awarded the College from NSF and NASA. In connection with the Compliance Program, the Chief Audit Officer of the College is required to have conducted in whole or in part, on an annual basis, a comprehensive, statistically-valid, independent audit of the College’s compliance with the Settlement Agreement and with Federal laws and regulations regarding the use and expenditure of NSF and NASA awards. AUDIT PLAN Consistent with the Settlement Agreement, there are two components of the audit. The first relates to ensuring compliance with the terms and conditions applicable to any NSF and NASA awards. The second component of the audit relates to assessing the efficacy of the College’s Compliance Program. With respect to the first component of the audit, the College through Internal Auditing and Advisory Services (IAAS) has contracted with the firm of Banks, Finley, White & Co. (BFW), Certified Public Accountants, to perform the compliance audit of current year grant awards from NSF and NASA. The audit will be performed in accordance with Government Auditing Standards and OMB Circular A-133, Audits of States, Local Governments, and Non-Profit Organizations and the OMB Circular A-133 Compliance Supplement, specifically Part 5 – Cluster of Programs – Research and Development Programs. Based on the requirements of the Compliance Supplement, the audit will include determining compliance with requirements in the following areas:

Activities Allowed or Unallowed Allowable Costs/Cost Principles Matching Reporting Subrecipient Monitoring, if applicable Special Tests and Procedures, if applicable

In each of the areas above and as applicable, statistical samples of transactions will be pulled from the universe of transactions of all NSF and NASA grant award expenditures during the audit period.

Additionally, procedures will be performed relative to documenting the College’s internal control procedures over grant awards in the following areas:

Control Environment Risk Assessment Information and Communication Monitoring Control Activities

Materiality level for compliance requirements for this audit has been set at 5% of the program expenditures. The second component of the audit will be designed to verify compliance and efficacy of the College’s Compliance Program as detailed in the Settlement Agreement. This portion of the audit will be performed by the College’s Chief Audit Officer. Areas to be included in the audit are as follows:

Review of compliance standards and procedures to prevent and detect violations of law and submission of improper payments to the federal government

Ensuring College leadership is knowledgeable of compliance standards and procedures Ensuring a high level person is assigned to ensure implementation and effectiveness of

compliance standards and procedures Ensuring that due diligence procedures are in place to ensure improper person is excluded

from positions of substantial authority within the College Ensuring procedures are in place to communicate compliance standards and procedures to

relevant employees through training and dissemination of relevant information Ensuring the College has taken steps to prevent and detect violations of law Review of policies and procedures the prevent and detect violations of law are enforced

consistently Review of procedures are in place to respond appropriately to any violations of law when

detected The period covered by the audit will be July 1, 2014 through June 30, 2015. AUDIT SERVICE TEAM The audit team will be as follows: Undria Stalling, CIA, CFE Morehouse College, Chief Audit Officer Gregory C. Ellison, CPA BFW, Engagement Partner Shannon Golden BFW, Senior Auditor Tracey Hill BFW, Staff Auditor

The service team possesses both the technical skills and understanding of the audits of federal expenditures and knowledge of the Settlement Agreement. Also each member has satisfied the CPE and independence requirements pursuant to GAO standards. The Chief Audit Officer will be the lead project manager on the engagement. BFW will submit its final report on the grant compliance audit to the Chief Audit Officer who, along with her audit of the Compliance Program, will submit the final report to appropriate parties within NSF and NASA.


ATTACHMENT H


CERTIFICATION OF INDEPENDENT AUDIT

This is to certify that a copy of the independent auditors written reports and findings for July 1, 2014 to June 30, 2015 are submitted as a supplement to this Annual Compliance Report. I further certify that the internal auditor had the requisite independence in connection with the Audit Plan contained in this report.

Lacrecia G. Cade General Counsel, Chief of Staff and Chief Compliance Officer


ATTACHMENT I


ATTACHMENT J

FY2015 Compliance Program AuditReport No. 2016-102Section Compliance Requirement (Compliant/Non-

Compliant)

IAAS Assessment/ Recommendation

Section I -

Preamble

1a Morehouse shall implement a compliance program to ensure

compliance with the terms and conditions applicable to any

NSF or NASA awards; ensure compliance with all relevant laws

and regulations governing NSF awards; and to demonstrate

Morehouse’s commitment to the prevention of fraud, false

statements, and misuse of funds related to NSF/NASA awards

by Morehouse, its officers, faculty and “relevant employees.”

Compliant The institution's compliance program under the Settlement Agreement has been

operational since December 1, 2011. The program has a charter detailing scope and

authority. On-demand training is available on various topics as it relates to federal

regulations and fraud. In FY2015, the compliance program had a separate budget

for operational purposes. Activity within the compliance program is periodically

reported to the Audit Committee of Morehouse's Board of Trustees. Such activity

was reported to the Audit Committee during FY15.

1b The Compliance Program is based upon an assessment of the

risk of unlawful activities.

Compliant The risk assessment utilized to determine the specific focus of compliance within

NASA/NSF was provided. A submission was made to the Audit Committee of the

Board of Trustees detailing the "Top 5 Compliance Issues of Focus for FY15." One of

the issues identified, "Grants - NASA/NSF, A-133."

1c The Compliance Program shall have adequate financial and

human resources.

Compliant The institution provided financial resources via a separate compliance program

budget.During the FY15 period, the Compliance Program was staffed as follows:

Chief Compliance Officer - Lacrecia Cade

Director of Institutional Compliance - Doris Coleman

2 Relevant employees are principal investigators (Pls), co-Pls,

independent contractors, sub-recipients and any other person

who is responsible for the design, conduct, administration or

other activity funded or supported by NSF or NASA awards

N/A The College understands the compliance requirements as written.

3 Awards, herein means any cooperative agreement, grant,

contract, sub-contract or other instrument whereby

Morehouse receives NSF or NASA funds.


Page 1

FY2015 Compliance Program AuditReport No. 2016-102Section II -

Requirements4 The period of future compliance obligations assumed by

Morehouse commenced August 1, 2011 and will be complete

upon receipt and approval by NSF OIG of the compliance

program’s fifth and final annual report.


5 The scope of the Compliance Program shall be limited to any

NSF or NASA-funded activity taking place during the term of

the plan and NSF or NASA funds awarded or disbursed during

the compliance period.

Compliant All NSF and NASA funded activities are subject to the Compliance Program.

6 All reports and notifications required under the compliance

program shall be sent to NSF OIG and NASA AIP.

Compliant The audit plan used to conduct the FY15 Compliance Audit was provided to both

agencies for their review. In addition, the Independent Auditor's Report, the A-133

Report, and the Annual Written Report for the FY15 period was also submitted to

both agencies as well as other required agencies.

Section II A (i) -

Compliance

Program8 The Compliance Program shall include identification of

relevant employees. Each of those roles and responsibilities

shall be described so that their relationship to Morehouse's

responsibilities under NSF and NASA awards is clear, from

each individual position up to and including Morehouse's

responsible signatory officials.

Compliant A listing of all active NASA and NSF federal awards during FY15 were provided by the

Grants Accounting Department which included relevant employees for the

respective award. Roles and responsibilities of relevant employees in the position of

PIs/PDs are provided in institutional policy.

8a All individuals in such positions will be provided with (or have

electronic access to) written policies and/or procedures

applicable to their positions for: a code of conduct holding

Morehouse personnel to high ethical standards of

professional conduct and integrity, including addressing

conflicts of interests;

Compliant During FY15 all such positions had electronic access in TigerNet to institutional policy

as it relates to "A Code of Conduct" and "Conflict of Interests".

Page 2

FY2015 Compliance Program AuditReport No. 2016-1028b accurate time and effort reporting under NSF and NASA

awards to meet the standards of the cost principles specified

in OMB Circular A-21 and codified as 2CFR part 220, and the

federal administrative requirements contained in 2CFR part

215.

Compliant During FY15 all such positions had electronic access in TigerNet to institutional policy

as it relates to Time and Effort Reporting.

8c accurate charging of costs under NSF and NASA awards; the

requisite approval(s) and verification needed for invoices,

reimbursements, or costs to be submitted to the federal

government for payment.

Compliant There is documented policy on cost transfers which address accurate charging of

costs from other budgets. This is expanded in newly revised grant policy and

procedures during FY16 to encompass the general subject matter related to accurate

charging of costs.

8d accurate monitoring, managing and reporting of cost sharing. Non-compliant Finding: Although written policy and procedures pertaining to cost sharing were not

in place during FY15, this subject matter was included in the institution's newly

revised policy and procedures during FY16 and provided to applicable relevant

employees.

8e accurate monitoring of sub-recipients and consultants, and

sub-recipient and consultant charges.

Non-compliant Finding: Although written policy and procedures pertaining to sub-recipient

monitoring were not in place during FY15, this subject matter was included in the

institution's newly revised policy and procedures during FY16 and provided to

applicable relevant employees.8f accurate reconciliation of accounting records. Non-compliant Finding: Although written policy and procedures pertaining to the reconciliation of

accounting records were not in place during FY15, this subject matter was included

in the institution's newly revised policy and procedures during FY16 and provided to

applicable relevant employees.

8g proper document management and retention. Compliant Written institutional policy and procedures on document management and

retention was in place during FY15 and accessible electronically to all employees.

Page 3

FY2015 Compliance Program AuditReport No. 2016-102Section II A (ii) -

Compliance

Officer

9 The President shall appoint a senior level administrator,

reporting to the president as Compliance Officer. The

Compliance Officer shall monitor Morehouse’s internal

controls to ensure compliance with all applicable Federal laws

and regulations regarding the use and expenditure of NSF and

NASA award funds.

Compliant The Chief Compliance Officer of the institution is Lacrecia Cade, Esq. Ms. Cade also

serves the role of Chief of Staff and General Counsel.

Recommendation : The Chief Compliance Officer position and the incumbent should

be reflected in the employment records of the College.

Section II A (iii) -

Compliance

Committee

10 The Compliance Officer shall chair a Compliance Committee

that shall be responsible for ensuring implementation of the

Compliance Program throughout Morehouse. In addition to

the Compliance Officer, the members of the Compliance

Committee shall include appropriately screened officers,

including: the Director of Sponsored Programs; the Chief

Financial Officer; the Provost; the Chief Audit Officer; and the

Chief Procurement Officer.

Non-Compliant The College delegated the responsibilities of the Compliance Committee to the

Senior Leadership Team. During FY15, this included the Chief Academic Officer

(Provost), General Counsel & Chief Compliance Officer, Chief Operating Officer, Chief

Financial Officer, Chief Information Officer, Vice President of Student Development,

Vice President of Institutional Advancement, Vice President of Student

Development, and the Associate Vice President of Human Resources. During FY15,

the Chief Audit Officer position was vacant, in addition; the College had no Director

of Sponsored Programs position during the period under review. The Office of

Sponsored Programs reported to the Associate Provost for Research, Scholarship,

and Creative Production.

According to the Chief Compliance Officer (CCO), issues pertaining to the Compliance

Program were discussed periodically with this team. An agenda of topics covered

was provided by the CCO which details subject matter related to the NSF/NASA

Agreement. According to the CCO, discussion ensued around the compliance

program agreement and the respective requirements, as well as the results of the

FY14 audit.

Page 4

FY2015 Compliance Program AuditReport No. 2016-102

Finding: The Chief Procurement Officer was not a part of the Senior Leadership Team

and thus not a part of the Compliance Committee, although reporting to the Chief

Financial Officer. This specific modification to the composition of the committee,

specifically the exclusion of the Chief Procurement Officer, was not included in an

authorized written amendment as prescribed by the Settlement Agreement.

Note: During the latter part of FY16, the Compliance, Enterprise Risk Management,

and Policy Committee was created. One of the primary task of this committee is to

supplement and progress the Compliance Program of the institution. The requisite

positions prescribed by the Settlement Agreement are all members of the

Committee, noting that the Associate Provost of Research- fully represents the

position, Director of Sponsored Programs, as there is no such position currently

reflected at Morehouse.Section II A (iv) -

Written Policies

11 Morehouse shall implement written policies regarding its

commitment to ensure compliance with all laws and

regulations related to the receipt of NSF/NASA awards. They

shall be included as part of the annual training and any

policies modified during the term of this Compliance Program

shall be included as part of the annual report sent to NSF OIG

and NASA's Director AIP. Morehouse's compliance policies

shall include disciplinary procedures for dealing with

employees who fail to meet the terms and conditions of NSF

and NASA awards.

Compliant Morehouse had implemented various policies and procedures demonstrating its

commitment to ensure compliance with laws and regulations related to NSF/NASA

awards. In addition, Morehouse had adopted and implemented a "Disciplinary

Action Policy for Non-Compliance" effective November 2011 which prescribes

disciplinary procedures for employees who fail to adhere to policy.

Compliance training occurred during March 2015. According to the training

presentation slides, reference to policy, procedures, and internal controls were

included in the training, with attention given to what was in place at Morehouse

College.

No policy modifications pertaining to NSF/NASA awards were made during the FY15

period.

Page 5

FY2015 Compliance Program AuditReport No. 2016-102Section II A (v) -

Posting and

Displaying NSF

OIG's Fraud

Hotline Poster12 (1) Morehouse must prominently display NSF OIG's fraud hotline

poster in common work areas within and throughout the

College Campus and divisions and worksites performing work

under any NSF award.

Compliant It is unknown if a physical inventory of NSF's posters and their respective locations

was performed during FY15, as the former Director of Ethics and Compliance had

separated from the College during the commencement of this audit. However, an

unannounced physical inventory was performed in FY16 (April 2016) by internal

audit staff and NSF posters were located in various buildings and facilities, including

worksites where NSF work was being performed. There also were a few locations

where these posters had previously been located but were no longer in place.

12 (2) Post on its website an electronic version of the NSF OIG's

fraud hotline poster in a manner easily accessible to

Morehouse's relevant employees.

Compliant The electronic version of the poster is located on the website of the Office of

Sponsored Research and Programs under the link "Agencies Compliances."

12 (3) Request that any subcontractor working on an NSF award post

the NSF OIG's fraud hotline poster in its common areas.

Compliant Based on records obtained from Morehouse's Grants Accounting Department, there

were no NSF awards in which Morehouse engaged subcontractor's during the FY15

period.

Page 6

FY2015 Compliance Program AuditReport No. 2016-102Section II B - Audit

Requirements

13 Morehouse's Chief Audit Officer shall have conducted, on an

annual basis, a comprehensive, statistically-valid,

independent audit of Morehouse's compliance with this

agreement as well as all applicable Federal laws and

regulations regarding the use and expenditure of NSF award

funds, including applicable NSF award conditions, federal laws

or regulations, and OMB Circulars. This audit shall include

each component of Morehouse that receives or has oversight

responsibility with respect to NSF awards and shall be

conducted in accordance with Generally Accepted Auditing

Standards with a statistically-valid sample.

Compliant Morehouse's Chief Audit Officer and an externally contracted firm (Banks, Finley,

White & Co) performed a compliance audit of Morehouse College's Compliance

Program against the Settlement Agreement and of NSF/NASA expenditures with

applicable Federal laws and regulations.

13 (a) The audit will also assess the efficacy of Morehouse's

compliance program as to whether: Morehouse has

established compliance standards and procedures to prevent

and detect violations of law and submission of improper

payment to the federal government.

Compliant The portion of the FY15 Annual Compliance Audit performed by the institution's

Internal Auditing and Advisory Services Department determined the efficacy of

Morehouse's compliance program.

13 (b) Morehouse’s leadership is knowledgeable about such

standards and procedures and whether a high level person is

assigned or retained have overall responsibility to ensure the

implementation and effectiveness of the standards and

procedures.

Compliant Selected leaders of Morehouse were interviewed to gain an understanding of their

knowledge of the compliance standards and procedures. The overwhelming

majority of the leaders interviewed were knowledgeable of the compliance program

and the position and individual deemed with the overall responsibility of the

program.

Page 7

FY2015 Compliance Program AuditReport No. 2016-10213 (c ) Morehouse has made reasonable efforts to exclude from

substantial authority any individual whom Morehouse knew

or should have known through exercise of due diligence, has a

history of engaging in violations of law, or other conduct

inconsistent with an effective program to prevent and detect

violations of law.

Non-Compliant Finding: The College was unable to demonstrate this requirement had been met for

all individuals deemed by the College as substantial authority personnel respective

to NSF/NASA awards that were active during FY15.

Recommendation: Efforts should be taken by the College to provide a reasonable

level of assurance that such individuals with substantial authority over respective

awards are not engaging in violations of law that may have bearing on their ability

to administer such awards.13 (d) Morehouse has made reasonable steps to communicate its

compliance standards and procedures to relevant employees

through effective training programs and otherwise

disseminating information appropriate to such individuals'

respective roles and responsibilities.

Compliant Training was provided to most relevant employees on compliance related matters

during FY15. On-demand training on various federal award topics in addition to

various policy and procedures were also accessible by all relevant employees on

Tigernet during FY15.

13 (e) Morehouse took reasonable steps to ensure that its program

to prevent and detect violations of law is followed; that

compliance standards and procedures are effective; and that

a system is in place for employees and agents may report or

seek guidance regarding potential or actual violations of law,

without fear of retaliation, including mechanisms for

anonymous reporting.

Compliant Institutional policy and procedures were in place during FY15 pertaining to

Whistleblowers and Retaliation and the protection afforded by the institution for

reporting - an effort to prevent and detect violations of law. There was also the

anonymous reporting mechanism - the Ethics Hotline used for the same purpose - to

prevent and detect violations of law.

13 (f) Morehouse’s program to prevent and detect violations of law

was enforced consistently through appropriate incentives and

as necessary, disciplinary measures for employees engaging in

violations of law and for failing to take reasonable steps to

prevent or detect violations of law.

Compliant During FY15, there was no known violation of laws pertaining to any NSF or NASA

federal award.

13 (g) Morehouse has taken reasonable steps, if a violation of law

was detected, to respond appropriately and to prevent future

violations of law.

N/A During FY15, there was no known violation of laws pertaining to any NSF or NASA

federal award.

Page 8

FY2015 Compliance Program AuditReport No. 2016-10215 (a) Morehouse will provide a working copy of the audit plan to

NSF OIG and to NASA's Director AIP thirty (30) days prior to

the initiation of the audit. The plan will be designed to: (1)

ensure compliance with the terms and conditions applicable

to any NSF and NASA awards and (2) assess the efficacy of

Morehouse’s compliance program.

Non-Compliant Finding: Although the FY15 audit plan was submitted to both the NSF OIG and NASA

AIP, it was not submitted 30 days prior to the initiation of the audit. Transition

among key institutional personnel associated with this step was a significant factor in

the delayed submission. The College was prepared to perform any additional

auditing procedures deemed necessary by both agencies to meet the objectives of

the audit.

15 (b) Morehouse will submit to NSF OIG and NASA's Director AIP a

copy of the independent auditor’s written report and findings

as a supplement to the annual written report.

Compliant The independent auditor's report and any findings were submitted to NSF OIG and

NASA's Director AIP as a supplement to the annual written report.

15 (c ) The audit may be conducted in whole or in part by

Morehouse’s Internal Auditors, provided Morehouse provides

NSF OIG and NASA’s AIP adequate assurance in writing,

certified by the compliance officer, that the internal auditors

have the requisite independence in connection with the audit

plan.

Compliant The audit was conducted through Morehouse's Internal Auditing and Advisory

Services Department (IAAS), a portion completed by the Chief Audit Officer and a

portion contracted out to the external firm, Banks, Finley, White & Co. The

Internal Audit Function maintains the requisite independence required to complete

the audit. As designated in the approved Internal Audit Charter, the Chief Audit

Officer reports functionally to both the College President and the Chair of the Audit

Committee. The Chief Audit Officer has direct and unrestricted accessibility to the

Chair of the Audit Committee.

The Chief Compliance Officer provided certification of the Chief Audit Officer's

objectivity and independence of the IAAS function within the annual written report.

16 Any and all reviews conducted at Morehouse, which reveal

situations that might constitute or indicate noncompliance

with NSF and NASA requirements are to be timely disclosed to

the individual conducting the annual internal audit and to the

Compliance Officer.

Compliant An internal review of a specific NSF award was performed during FY15 by the

Associate Provost for Research, Scholarship, and Creative Production and a faculty

member (former Chief Audit Officer) to determine compliance. The results of this

review were disclosed to the newly appointed Chief Audit Officer and the Chief

Compliance Officer.

Page 9

FY2015 Compliance Program AuditReport No. 2016-102Section II C -

Annual Written

Reports

17 (a) Morehouse will annually provide NSF OIG AND NASA with a

written report identifying deficiencies discovered by annual

audits or any other audit or review, and the corrective actions

Morehouse has taken to address such deficiencies. The

report will also be sent to the OIG of any other federal agency

from which Morehouse has received or disbursed funds

during the period.

Compliant The annual written report captured all of the elements of this requirement. The

report was sent to all applicable federal agencies.

17 (b) The reports shall include a certification by Morehouse’s

Compliance Officer that all deficiencies have been addressed

to ensure Morehouse’s compliance with all requirements of

Federal law, regulations, and the Compliance Program.

Compliant The annual written report details the required certification.

18 All audit work papers and other supporting documents for

audits or reviews of compliance shall be retained by

Morehouse for eight years after the effective date shall be

made available to NSF OIG and NASA AIP upon request.

Non-Compliant Finding: The newly appointed Chief Audit Officer is in the process of attempting to

secure workpapers and supporting documentation for completed Annual NSF/NASA

Compliance Audits. It is anticipated this compliance requirement will be met for the

FY16 compliance audit.

19 A “material violation” is one that has a significant adverse

impact on the administrative, financial, or programmatic

aspects of either NSF or NASA awards.


Morehouse has a duty to:

19 (a) Immediately report every material violation or material

weakness discovered during any audit or review to NSF OIG

and NASA’s Director AIP; remedy the material violation or

weakness within 30 days of learning of it; notify NSF OIG and

NASA’s Director AIP what actions were taken to correct it; or

Compliant There was no known material violations or material weaknesses discovered during

any audit or review during FY15 or during the current time period.

Page 10

FY2015 Compliance Program AuditReport No. 2016-102Section II D -

Training20 (a) Morehouse shall institute and maintain a comprehensive

training compliance program designed to ensure that each

officer and relevant employee is aware of all applicable laws,

regulations, and standards of conduct that such individual is

expected to follow with regard to NSF and NASA awards, and

the consequences both to the individual and Morehouse that

will ensure from any violation of such requirements.

Compliant Training records, on-demand training related to various federal award topics, and

accessible policy and procedures help to ensure the comprehensiveness of the

compliance program.

20 (b) Each officer and relevant employee shall receive at least two

hours of initial training that shall include the contents of this

Compliance Program as well as the relevant award

requirements, and shall receive additional compliance

training of at least two hours on an annual basis.

Non-Compliant Finding: Three relevant employees did not appear to receive the required two-hours

of annual training. No evidence was provided to support training had been

received. The Director of Institutional Compliance, responsible for oversight of the

training, is no longer with the institution.

20 (c) A schedule and topic outline of the training shall be included

in the annual report submitted to NSF OIG and NASA’s

Director AP.

Compliant This information has been included in the Annual Report.

20 (d) A certificate will be placed in the personnel file of each officer

and employee completing the training stating the date, topic,

and hours of training received.

Non-Compliant Finding: Beyond the three relevant employees that did not appear to receive the

required training, two additional relevant employees did not have the required

training certificates in their personnel files.

Page 11

FY2015 Compliance Program AuditReport No. 2016-102Section II E -

Confidential

Disclosure

Compliance

Program

21 (a) Morehouse shall establish a confidential disclosure

mechanism enabling Morehouse, and relevant employees to

disclose anonymously to Morehouse’s Compliance Officer any

practices, procedures, or acts deemed by the employee to be

in appropriate.

Compliant Morehouse offers a 24-hour manned Ethics Line for employees and anyone else to

make confidential disclosures. The Ethics Line is managed by an independent

provider. Suspected or known instances of improper acts, inappropriate acts or

unethical behavior may be reported.

The Ethics Line information can be found by all employees on the Office of Ethics

and Compliance Website, the Internal Auditing and Advisory Website, on Tigernet,

and at various Awareness Centers located throughout the Morehouse Campus.

21 (b) Morehouse shall make the confidential disclosure mechanism

known to each relevant employee as part of the training

described above.

Compliant Awareness of the Ethics Line is made available to all new employees through New

Hire Orientation conducted by the Office of Ethics and Compliance. Ethics Line

Awareness Centers are located throughout the campus in strategic locations

accessible by relevant employees. Information pertaining to the Ethics Line is also

located in various locations on the College's website: 1) Office of Ethics and

Compliance, 2) Internal Auditing and Advisory Services, and 3) Tigernet.

In addition, compliance training provided during March 2015 included discussion on

reporting potential wrongdoing and the use of the Ethics Line.

21 (c ) Morehouse shall require the internal review of all such

credible disclosures and ensure that proper follow-up is

conducted.

Compliant All such disclosures received through the Ethics Line are routed to the appropriate

parties for further review and/or investigation if sufficient information has been

provided.21 (d ) Morehouse shall include in its annual report, a summary of

communications received under the confidential disclosure

compliance program, and the results of the internal review

and follow-up of such disclosures.

Compliant A summary of the communications received through the Ethics Hotline for FY15 and

the results has been included in the annual report. There were no disclosures made

pertaining to a NSF, NASA or any federal award.

Page 12

FY2015 Compliance Program AuditReport No. 2016-102Section III - NSF

OIG Inspection,

Audit, and Review

Rights

22 NSF OIG and NASA’s Director AIP have the right to examine

and copy Morehouse records and interview Morehouse

employees for the purpose of verifying and evaluating: (a)

Morehouse's compliance with the terms of this Compliance

Program; and (b) Morehouse's compliance with any NSF

requirements.


23 In the event that NSF OIG or NASA’s Director believes

Morehouse has breached any of its obligations under the

Compliance Program, NSF OIG shall notify Morehouse’s

authorized organizational representative (AOR), specifying the

nature and extent of the alleged breach. Morehouse will have

30 days from the receipt of the notice to: (a) cure said breach;

or (b) otherwise satisfy NSF OIG and NASA’s Director AIP that

(1) it is in full compliance with this Compliance Program; (2)

the breach cannot be reasonably cured within 30 days, but

that Morehouse has taken effective action to cure the breach

and is pursuing such action with diligence.


24 If at the end of the 30 day period NSF OIG and NASA’s Director

AIP determine Morehouse continues to be in breach of any of

its obligations under the Compliance Program, they will

inform Morehouse’s AOR of its conclusion that Morehouse is

in default. They may also initiate proceedings to undertake

appropriate administrative action, including but not limited to

the suspension or termination of any or all NSF/NASA awards

and/or suspension or debarment of Morehouse.


Page 13

FY2015 Compliance Program AuditReport No. 2016-102

25 Federal courts have jurisdiction over any matters pertaining

to the Compliance Program. The execution of the settlement

agreement (SA) shall be final as to all matters alleged in the

settlement agreement.


26 Absent a breach, so long as Morehouse is fully satisfying the

conditions stipulated by the Compliance Program, NASA and

NSF OIG agree to refrain from instituting, directing, or

maintaining any administrative action seeking suspension or

debarment of Morehouse, or its current or former trustees,

officers, agents, servants, or employees, other than Dr.

Herbert Charles or Dr. Darlene Charles, for the covered

conduct.


Section IV - Costs

28 All costs, whether direct or indirect, incurred by or on behalf

of Morehouse in connection with the following are

unallowable costs under the cost principles applicable to

government awards: (1) matters covered by this Compliance

Program; (2) the negotiation of this Compliance Program and

the Settlement Agreement (including attorney's fees) and (3)

any payments made pursuant to the Settlement Agreement.

Compliant Morehouse's Compliance Program had its own separate budget for FY15. The

budget was funded with Unrestricted Funds. Expenses incurred in completing the

annual compliance audit for FY15 (utilization of the external accounting firm - Banks,

Finley, and White) were covered by unrestricted funds.

Section V -

Modification30 Any modification to the Compliance Program shall not be

effective until a written amendment is signed by

representatives duly authorized to execute such amendment.

Compliant No modifications have been made to the Compliance Program, as there are no

signed amendments on file within the Office of Ethics and Compliance or the Legal

Department.

Page 14

FY2015 Compliance Program AuditReport No. 2016-102Section VI -

Integration Clause

31 The Compliance Program and settlement agreement to which

it is attached and incorporated by reference embodies the

entire settlement agreement and understanding of the parties

with respect to the subject matter contained herein. There

are no restrictions, promises, representations, warranties,

covenants, or undertakings other than those expressly set

forth or referred to in the Compliance Program and the

Settlement Agreement. This Compliance Program, together

with the Settlement Agreement supersedes any and all prior

Settlement Agreements and understandings between the

parties with respect to the subject matter, except for the

terms and conditions of individual awards.


Page 15


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