REPORT OF THE WASC VISITING TEAM

SPECIAL VISIT

The Master’s University and Seminary

Date of the Visit:

November 1-2, 2018

TEAM ROSTER:
John Jackson, Chair
President, William Jessup University

Jack Paduntin, Assistant Chair

Chief Academic Officer, TCS Education System

Cherron Hoppes, Member

Vice President and Chief Academic Officer, Helix Education

Jeffery Keith, Member

Chair, Board of Trustees, Alliant International University

Tamela Hawley, WSCUC Visit Liaison

Vice President, WASC Senior College and University Commission
Table of Contents
Introduction ............................................................................................................................... 3
Issue 1 – Board Independence .................................................................................................... 6
Issue 2 – Personnel and Management Practices ........................................................................ 8
Questionable Personnel Practices ....................................................................................................... 8
Organizational Culture ...................................................................................................................... 10
Issue 3 – Operational Integrity ................................................................................................. 13
Conflicts of Interest in Contract Awards ............................................................................................ 13
Institutional Aid and Awarding Structures ........................................................................................ 16
Issue 4 – Leadership ................................................................................................................. 17
Full-Time Chief Executive Officer....................................................................................................... 17
Qualified Administrators to Provide Effective Educational Leadership and Management ................ 19
Commendations and Recommendations .................................................................................. 20
Commendations: ............................................................................................................................... 20
Recommendations: ........................................................................................................................... 21

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 Introduction

In Spring 2018, an Accreditation Visit Team (AVT) convened to review The Master’s

University and Seminary (TMUS) for reaffirmation of accreditation through the Western

Association of Schools and Colleges (WASC) Senior Commission on Colleges and Universities

(WSCUC or Commission). As a result of the recommendations from the AVT, the Commission

placed the institution on probation and outlined a follow up Special Visit to be conducted

within months of the Commission’s decision. The issues and recommendations of the

Commission were documented in a formal notice to the institution dated July 18, 2018;

included in those recommendations was a required Special Visit in November, 2018. A Special

Visit Team (SVT) was identified and the follow up visit was scheduled for November 1-2, 2018.

This report was developed by the SVT in response to the issues and recommendations

identified in the Commission’s letter. For ease of tracking each, the SVT developed a framework

to address each recommendation and related Criteria for Review (CFR) within the issues

identified. In some cases, the recommendations overlap the identified issues. In this case, the

recommendations have been addressed across the issues and may be referenced in more than

one area of the report. As a result, this report follows the alignment of the matters in question

as identified below:

Issue 1: Board Independence

Requirement 1: The Board should immediately review the WSCUC Independent
Governing Board Policy and conform its composition and actions to achieve compliance
(CFRs 3.7, 3.9, and Independent Governing Board Policy)
Requirement 6: The institution should implement practices to insure the resolution of
all reported conflicts of interest. (CFRs 3.6, 3.7)

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Issue 2: Personnel and Management Practices
Requirement 2: It is recommended that the Board immediately establish a special task
force to address concerns related to hostile work environment issues as well as
personnel actions that are inconsistent with the institution’s personnel policies. A
confidential third-party analysis of the results of survey data and staff comments and
accompanying recommendations could be helpful to the Board in that process. (CFR 1.3,
1.6, 1.7, 3.6)
Requirement 4: The Board should ensure that the President and his leadership team,
and those in their span of control, follow institutional policy in personnel decisions and
require regular reporting on staff and faculty transitions and evaluations, with note of
the importance of honoring the Whistleblower Act and related policy in the Employee
Handbook. This should include an independent review of all faculty and staff departures
over the last three years. (CFRs 1.6, 1.7, 3.2, 3.6, 3.7, 3.9)
Requirement 5: Institutional leadership should assiduously follow the policies of the
Faculty Handbook and generally recognized higher education practices, with the Provost
being directly accountable to the board for reporting on faculty hiring, releases, and
awarding of degrees. (CFRs 1.3, 2.1, 2.2, 2.4, 3.10, 4.6)
Requirement 8: All leaders at the director through executive level should be familiar
with professional standards and practices and able to assure that the institution satisfies
regulatory requirements. (CFRs 1.3, 1.6, 1.8, 3.6, 3.7)
Issue 3: Operational Integrity
Requirement 2: It is recommended that the Board immediately establish a special task
force to address concerns related to hostile work environment issues as well as
personnel actions that are inconsistent with the institution’s personnel policies. A
confidential third-party analysis of the results of survey data and staff comments and
accompanying recommendations could be helpful to the Board in that process. (CFR 1.3,
1.6, 1.7, 3.6)
Requirement 3: The Commission is extremely concerned that the institution may be in
violation of required reporting responsibilities under the Clery Act, VAWA, and FERPA
and that the COO, who has been assigned to handle these responsibilities, is unaware of
the requirements and processes mandated by these statutes. The institution should
take immediate steps to assure that it understands and is compliant the federal
requirements. (CFR 3.6, 3.8)
Issue 4: Leadership
Requirement 2: It is recommended that the Board immediately establish a special task
force to address concerns related to hostile work environment issues as well as

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 personnel actions that are inconsistent with the institution’s personnel policies. A
confidential third-party analysis of the results of survey data and staff comments and
accompanying recommendations could be helpful to the Board in that process. (CFR 1.3,
1.6, 1.7, 3.6)
Requirement 4: The Board should ensure that the President and his leadership team,
and those in their span of control, follow institutional policy in personnel decisions and
require regular reporting on staff and faculty transitions and evaluations, with note of
the importance of honoring the Whistleblower Act and related policy in the Employee
Handbook. This should include an independent review of all faculty and staff departures
over the last three years. (CFRs 1.6, 1.7, 3.2, 3.6, 3.7, 3.9)
Requirement 5: Institutional leadership should assiduously follow the policies of the
Faculty Handbook and generally recognized higher education practices, with the Provost
being directly accountable to the Board for reporting on faculty hiring, releases, and
awarding of degrees. (CFRs 1.3, 2.1, 2.2, 2.4, 3.10, 4.6)
Requirement 7: The institution should ensure that the President (CEO) is a full-time role
and that the Board responsibly monitors compliance with this standard. (CFR 3.8)
Requirement 8: All leaders at the director through executive level should be familiar
with professional standards and practices and able to assure that the institution satisfies
regulatory requirements. (CFRs 1.3, 1.6, 1.8, 3.6, 3.7) -- This requirement is associated
with Issue 2 - Personnel and management practices; and Issue 4 – Leadership
In preparation for the SVT visit, as outlined in the practices expected from WSCUC

institutions, TMUS prepared a report addressing a response to each of the issues and related

recommendations. The SVT was provided time for a deep analysis of the institutional response

and followed up with the Accreditation Liaison Officer (ALO) with additional requests for

materials and to confirm the visit schedule with the intention of validating the information

provided in the institutional report through a series of interviews with key parties on campus.

The SVT gathered for additional preparation and to launch the visit on October 31, 2018.

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 Issue 1 – Board Independence

The Commission’s letter dated July 18, 2018 indicated that TMUS “does not meet the

WSCUC requirement for governing board independence since many members of the Board are

employed by the institution or another organization for which the president has authority.

According to the WSCUC Governing Board Policy, ‘for an institutional governing board to be

considered independent, a majority of its members may not have interests that influence their

impartial decision making, create multiple and potentially conflicting relationships, or result in

competing loyalties.’ Board members cannot independently evaluate a Chief Executive Officer

to whom they report. (CFRs 3.7, 3.9, and Independent Governing Board Policy).”

According to the materials provided by TMUS, and validated during the onsite visit, the

Board has spent substantive time since receiving the Commission’s letter reviewing its

composition and policies in order to comply fully with WSCUC’s CFRs and policies related to

Board independence. Among the completed actions, a Board composition matrix was

developed to accurately assess the status of the current members and their current level of

independence. Through this analysis, the Board determined that the majority of current board

members (13 of 22 members) are independent as defined by WSCUC policies, thus fulfilling CFR

3.9. In addition, since the time of the AVT, the Board Chair has transitioned to leadership that is

fully independent from any affiliation with the institution or related entities outside of the work

of the Board.

Through the process of assessment, the Seminary then determined changes in practice

were necessary and subsequently developed a proposal that eliminates the need for Board

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members representing the Seminary to serve either as associate deans or faculty associates

(adjunct professors) in the Seminary’s distance education program. As a result, board members

who were previously involved in that program will no longer serve in any official administrative

or teaching capacity, nor will they receive compensation as faculty associates of TMUS. This

step will further strengthen the Board’s effort to resolve any perceptions of inappropriate

relationships with the institution that they oversee.

In addition, the Board has established a practice whereby through annual review it will

reaffirm the policy that no board member will be employed full-time in any organization that is

under the direct authority of the president, excluding de minimis payments and honoraria (CFR

3.7). The Board has appointed a subcommittee to produce a member handbook that includes

requirements for board membership, expectations for member involvement, and protocols for

board composition and activities (CFR 3.9). As part of an annual board composition review the

Board examine compliance with the policy as part of the annual planning retreat to ensure it is

maintaining the requisite competencies and diversity goals established as part of this effort.

Reporting of composition criteria will be documented annually as part of the conflict of interest

attestation process.

In reviewing the documents submitted, and while in discussion with the Board chair and

several members of the Board, the SVT acknowledged evidence to support the claim of

progress being made regarding this issue and that there is a specific plan for future actions that

will ensure ongoing compliance. The Board showed a strong commitment to upholding the

CFRs and its immediate actions demonstrated its intention to maintain Board independence.

The team recognized that the identified actions are critical for TMUS to be compliant with the

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WSCUC standards. Ongoing efforts to monitor the intentions and ongoing practices of the

Board will be necessary to ensure adherence to the applicable CFR’s in this area.

Issue 2 – Personnel and Management Practices

Issue 2 clearly intersects with matters also addressed in Issue 4 – Leadership. This

particular section will examine the question of personnel actions and practices as they relate to

the institution’s own policies and procedures outlined in the faculty and employee handbooks

and the overall organizational culture.

Questionable Personnel Practices

The Commission’s letter gave attention to an observation of the AVT regarding a pattern

of personnel actions and practices in hiring for the campus that was regularly inconsistent with

documented policies found in the TMUS Employee and Faculty Handbooks. In addition, the

AVT, through the visit’s confidential email, and WSCUC staff, through the formal grievance

process, received numerous reports of a campus culture that had led to a climate of fear,

intimidation, bullying, and uncertainty among many of faculty and staff (CFR 1.3, 1.6, 1.7, 1.8,

3.2, 3.6, 3.7, and 3.9).

In speaking with an independent auditor charged to review the policies for hiring,

promotion, and evaluation at TMUS, it is clear the institution is moving towards establishing

best practices in human resource operations. The team did find evidence of various pockets in

the institutional leadership who, either out of lack of knowledge or lack of concern, often step

outside of those established policies, bringing the practice of hiring, promotion, and evaluation

in to question again. For the institution to avoid issues such as lack of qualified administrators

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(CFR 3.8), it will be imperative that all members of the campus community inform themselves

of the human resources policies that have been established and operate within those

parameters.

As a result of those findings in the AVT report, the Commission recommended that

TMUS immediately establish a special task force to address concerns related to the issues of the

work environment and personnel actions and policies by suggesting that an independent

consultant may be helpful (CFR 1.3, 1.6, 1.7, and 3.6). In addition, the Commission

recommended that the Board closely monitor the president and his leadership team in relation

to these areas of concern, particularly citing the importance of honoring the Whistleblower Act

and related policies in the TMUS Employee Handbook. (CFRs 1.6, 1.7, 3.2, 3.6, 3.7, and 3.9).

In the institutional report, TMUS rationalized the changes in key leadership as necessary to be

responsive to declines in enrollment. Management believed that their personnel actions were

authorized by the Board in support of that effort. Through the visit process, TMUS managers

acknowledged these changes resulted in uncertainty and apprehension among the faculty and

staff. In response to the Commission recommendations, the TMUS Board deployed a task force

(comprised of members of the Board) to supervise an internal investigation into the

institutional and employee culture at TMUS. The primary task of this subcommittee was to

review the data collected by a third-party firm, Ruffalo Noel Levitz (RNL), hired in April 2018, to

conduct an institution-wide Employee Satisfaction Survey. The survey results were obtained

and have been reviewed by various constituencies, including institutional legal counsel who is

serving as an independent party for the purposes of this review, in an effort to better

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understand the perceived culture of the organization and opportunities to improve. The results

were also presented to the Board in its October 2018 meeting.

The SVT reviewed survey results, which showed that seminary faculty and staff scored

their satisfaction as being above the national comparative mean. At the University, the overall

results of the survey indicated that while their satisfaction rating was close to the national

mean, there are some areas that fell short, particularly in the area of communication. It should

be noted that this survey was conducted amongst current employees.

Organizational Culture
As a direct result of the Commission’s action letter and the results of the Employee

Satisfaction Survey, TMUS reported that the University’s leadership team has been working to

improve communication with faculty and staff. Specifically, the Provost sends a bi-weekly

update/newsletter to keep faculty and staff apprised of both institutional direction and any

personnel changes. In addition, since August 2018, monthly university faculty and staff

meetings have been instituted with the President. These meetings are scheduled to continue,

thereby providing a platform for employees to ask questions, raise concerns, and stay informed

regarding institutional direction. Similarly, the Seminary also sends out regular emails to the

campus community notifying them whenever a personnel change has taken place. In addition,

the Senior VP holds monthly staff meetings for all faculty and staff, a weekly directors’ meeting

for all administrative leadership personnel, and a rotating departmental level meeting once per

week. The Dean of faculty leads a weekly seminary faculty meeting. The purpose of these

meetings is to ensure that every level of faculty and staff is informed in a timely fashion about

institutional direction and decision-making.

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 In the interview sessions, faculty and staff expressed their appreciation of recent

improvements and that they now feel more connected. The SVT noted that several staff at the

meetings were TMUS alumni who indicated that they have known their supervisors since they

were students at TMUS and they felt comfortable seeking out for information from them. While

some staff acknowledge that communication was their concern, they shared that the recent

actions taken by TMUS’ leadership make them feel that the institution is moving in the right

direction with its new communication strategies. It was clear that while these efforts were

appreciated, there was an underlying apprehension that the institution would again return to a

time with an information void much like what was experienced prior to the AVT visit.

According to the institutional report, the Board has assumed oversight of leadership’s

adherence to personnel policies and is reviewing all recent faculty and staff departures. The SVT

found evidence of a task force appointed by the Board to investigate workplace culture that is

also performing an independent review of all faculty and staff departures over the past three

years to determine patterns in those departures, to take corrective actions where necessary

and to certify a renewed commitment to institutional policy. In addition, the Board has set an

expectation that the Provost provides a report at every meeting regarding personnel transitions

at the university. They have similarly required the Senior VP of the Seminary to produce the

same report for the Seminary.

In light of the Commission’s recommendations, the institutional grievance policy was

reviewed by administration, and then reviewed with the faculty and staff at the University on

October 5, 2018. The grievance policy at the Seminary was also reviewed with faculty on

September 5, 2018, in a regularly scheduled faculty meeting. TMUS also plans to implement

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comprehensive employee reviews for all staff and faculty during the 2018–2019 academic year.

TMUS acknowledges that regular personnel reviews are critical to maintaining a healthy staff.

Personnel reviews have occurred intermittently over the past year and will be standardized for

all staff members per the recommendation of the AVT. This comprehensive review process will

be fully implemented by January 2019. Additionally, strict processes and protocols are being

developed for all faculty and staff departures, to prevent the potential for ad hoc dismissals

from the organization.

In the course of SVT interviews, TMUS faculty shared their positive view about the

institution. Many have served the institution for a long time and are committed to its success.

Collectively, faculty see that the probation has adversely impacted the University and that the

university has employed corrective actions to regain its reputation.

It must be noted that both faculty and staff stated that they felt that the recent actions

led by the board and TMUS’s leadership has contributed significant positive influence in

improving the well-being of the institution. The SVT felt that trust is being restored with better

communication and policies are being investigated, understood and followed. The Board’s

intervention on the targeted issues has produced positive results in a timely fashion. Several

new initiatives will need to be monitored and followed through to yield further desirable

outcomes. The SVT was heartened that the Board and Administration appear to have taken

substantive and comprehensive action on Issue 2 and we commend a continued development

of this arena of activity.

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 The appointment of an Interim Vice President of Administration, replacing the COO

identified as problematic during the AVT visit and called out in multiple confidential emails to

the SVT as well as in formal grievances submitted to WSCUC staff, has been seen as a positive

response to the concerns referenced in the AVT report regarding a hostile work environment.

The VPA has conducted multiple meetings with staff members in a variety of departments.

Many staff reported positive improvement in communication and staff morale. The SVT

celebrates the progress that has been achieved thus far and expresses cautious optimism that

the future will continue to build upon the gains that have been experienced in the months

following the AVT report.

Issue 3 – Operational Integrity

Following the Accreditation Visit report of Spring 2018, the Special Visit team was

particularly concerned to understand the response of TMUS leadership to significant concerns

regarding contract awarding practices for related party transactions, financial aid awarding

practices, and Title IX, Clery Act, FERPA, and VAWA regulatory compliance. This section will

specifically address the first two issues, leaving the last to be addressed under Issue 4 –

Leadership.

Conflicts of Interest in Contract Awards

A substantive and challenging matter in the AV report was the reported award of

contracts to a related party. This matter was noted in the report as a matter of concern, and

was consistently referenced in the confidential emails and among the community meetings of

the AV. The Commission action letter outlined the concern that “The institution’s 2017

financial audit contains a specific finding on appearance of conflicts of interest with the

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President’s son-in-law supervising a contract from which he benefits, as well as institutional aid

that exceeds typical aid awards being awarded to friends and relatives. Of particular concern to

the Commission is that the auditor first identified these practices as ‘significant findings’ more

than six months prior to the accreditation team’s visit and there was not sufficient evidence

that solutions had been fully implemented by the institution. Additionally, as a result of inquiry

by the visiting team and panel prompted by Third Party Complaints to the Commission, the

Commission is concerned about the institution’s attention to the requirements of the Clery Act

and the Violence Against Women’s Act (VAWA). The Commission is concerned about the

capacity of the institution’s leadership to operate with integrity, high performance, appropriate

responsibility, and accountability (CFRs 3.6, 3.7).”

TMUS’ response in the institutional report identified this area of concern as a top

priority for the Board of Directors and the senior leadership, who seek to demonstrate the fiscal

and operational integrity that ought to characterize a Christian institution. The report went on

to identify several actions that were completed to resolve this issue.

Since the time of the Commission letter, the Board has been engaged in monitoring the

issue with the contracts involving the President’s son-in law. It is important to note that on

December 7, 2017, TMUS enlisted the help of an outside auditing firm to determine if a

transaction with a related party had resulted in excessive benefit compensation. This effort was

made four months prior to the AVT visit (in March 2018) and followed immediately after the

2017 audit report was received. TMUS’ institutional report stated that one month prior to the

AVT’s visit, on February 2, 2018, the Board passed a motion to adopt ECFA (Evangelical Council

for Financial Accountability) Standard 6, a robust standard requiring related party transaction

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process and annual conflict of interest form disclosures. Finally, on February 20, 2018, TMUS

solicited the counsel of Anglin Flewelling Rasmussen Campbell & Trytten LLP (AFRCT),

requesting a legal opinion on the relationship between TMUS and several companies owned by

the President’s son-in-law.

The Board has continued to engage with legal counsel to resolve any apparent conflicts

of interest by means of a competitive bidding process per the ECFA guidelines. The stated

desire of both the Board and senior leadership is to operate with full integrity and

transparency, adhering to proper protocols and following best practices in the issuing of all

contracts. The Board has also tasked the VP of Finance (CFO) with the responsibility of reporting

all potential conflicts of interest to the finance committee for regular review. This has been

added as a recurring agenda item for all future finance committee meetings.

The SVT is satisfied with the rigor and depth of the contract issuance process and affirms

TMUS for the breadth and depth of its process. However, we continue to encourage TMUS to

recognize the reality of community and public perception and to exercise great discretion when

related party matters are a potential matter of interest. Annual conflict of interest forms (as

required by ECFA and as a matter of best practice standards) should be filed by board members

and senior leaders of TMUS.

In keeping with the AVT report, the SVT commends a recognition of the Whistleblower

Act and that attention be paid to the provision of a third-party reporting framework that would

be outside of the supervisory reporting structure of the institution as a way to address this, and

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other concerns, that necessitate a confidential and protected way to raise concerns about the

operational integrity of the organization.

Institutional Aid and Awarding Structures

A second issue flagged during the 2017 financial audit involved related-party financial

aid awards. In response, the Board of Directors commissioned the VP of Finance (CFO) and the

Office of Financial Aid to review the current financial aid awarding process to evaluate

compliance with governmental regulations and internal policies. Like the prior issue, the

Board’s response was initiated prior to the AVT visit in March 2018; the Board affirmed the

importance of following existing institutional policy related to financial aid. Additionally, a

scholarship committee (consisting of the VP of Finance (CFO), COO, Director of Financial Aid, VP

of Development, the Director of Student Life, and an independent member of the Board) was

established to review all awarding of discretionary scholarship funds.

In August 2018, the Board also instructed the university to conduct a full five-year audit

of all financial aid awards from restricted funds to determine if, and when, any violations may

have occurred. In order to bring campus-wide awareness to financial aid policies, the VP of

Finance (CFO) also distributed a copy of the awarding process to all departments related to

financial aid on October 1, 2018. According to the institutional report, three awards were

irregular and corrective action has been taken to ensure a like circumstance is not repeated for

future awards.

The Institutional Special Visit report demonstrated a significant number of tangible steps

to address each one of the concerns mentioned. In our site visit, we were able to confirm and

extend our conversation on the matters of concern. Our concerns were largely ameliorated in

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these areas, though we note the importance of continuing to build upon the progress made in

the previous 7 months.

Issue 4 – Leadership
The AVT and Commission raised the concern about the current president and senior

leadership by pointing out, “The institution is not in compliance with the requirement in CFR

3.8 regarding the Chief Executive Officer. In addition, some individuals have been hired without

job descriptions being provided and/or searches being conducted [SVT note – please see Issue 2

regarding these issues]. Some institutional leaders lack higher education experience,

preparation, and knowledge of key higher education regulatory expectations and professional

standards for institutions of higher education. For example, when asked by the visiting team,

the COO was unaware of the Clery Act, VAWA, and the Family Education Right to Privacy Act

(FERPA). In addition, cabinet members interviewed by the visiting team were unaware of the

American Association of College Registrars and Admissions Officers (AACRAO), National

Association of College and University Business Officers (NACUBO), and National Association of

Student Personnel Administrators (NASPA), professional organizations relevant to their

respective roles as higher education administrators (CFR 3.6, 3.8).”

Full-Time Chief Executive Officer

WSCUC expectations regarding the role of the Chief Executive Officer (CEO) are very

clear. The institution must have a full-time CEO whose primary responsibility is to the

institution (CFR 3.8). An institution as comprehensive as TMUS, as one member of the

community stated, “deserves full-time attention.” It appears to be an open understanding in

the campus community that the current CEO’s commitments to Grace Community Church and

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its related ministries has prevented the CEO from putting full-time attention to the matters of

the University and Seminary.

The team was heartened to learn that the Board has established a very specific plan of

succession with the intention to conduct a national search, appointing a new CEO focused on

the needs of TMUS as a full-time role. The current plan speaks to an 18-month process to

conduct the search and provide a smooth transition. It appears that in the meantime, the

current CEO has done more to put his energy and attention in a more full-time fashion.

However, there is significant concern in the community that “he is only one man” and the

faculty and staff are well aware of his other obligations.

This commentary brings into question the institution’s compliance with CFR 3.8. The

SVT consensus is that the institution is not in compliance on this single issue. The team must,

however, concede that the process of replacing a CEO of long-standing tenure (over 30 years)

with deep connections to the community that so generously supports the institution is not one

to take lightly or with undue haste. The team encouraged the Board chair to move with a high

level of expedience given the importance of this role and compliance with WSCUC standards.

Should the Board continue its plans to conduct a national search with a new leader in place no

later than the end of the 2019-2020 academic year, the team supports this effort to bring the

institution in to compliance.

The Board must also take its role in evaluating the CEO very seriously, conducting a

formal evaluation annually to ensure the new CEO’s behavior and actions allow the institution

to return to full compliance on CFR 3.8.

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Qualified Administrators to Provide Effective Educational Leadership and Management
CFR 3.8 also calls for a sufficient number of qualified administrators to provide effective

educational leadership and management. During the prior visit for re-affirmation, the team

expressed grave concern over the lack of experience and expertise demonstrated by the COO,

Kory Welch. Since that visit, the institution has taken steps to move Mr. Welch into an advisory

capacity for the Office of the President.

Compounding the seriousness of the identified issues, the volume of confidential email

reports made to both the AVT and SVT process were notable. Some of those messages

addressed the ongoing concerns of Mr. Welch’s role on campus while many of those reports

referenced sexual assault matters from years ago but indicated an ongoing concern about

TMUS’ handling of such complaints.

The TMUS institutional report in indicated substantial preparation and certification by a

number of staff members. In response to this issue and to increase institutional awareness of

all issues related to Title IX, TMUS arranged for key personnel from both the university and the

seminary to attend Civil Rights Investigator Certification Training in Jacksonville, FL on

September 27–28, 2018. Attendance at this two-day seminar provided additional education to

key campus leaders on the reporting process and all related requirements.

In addition to the external training opportunities, TMUS recently developed new Clery

Act online training for the institution’s Campus Security Authorities (CSAs), in addition to two

training seminars which are historically hosted in August and September. Additionally, new

online training is being offered to general staff beginning in October 2018. The two online

training videos were developed as a result of the university’s membership with The Clery

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Center, an industry standard leader in both areas of compliance. Several campus-wide training

seminars regarding Title IX were held in September 2018. In-person seminars related to Clery,

VAWA, and Title IX were being planned for TMUS’ executives.

This portion of Issue 4 encompasses several legal compliance concerns. The senior

leadership and the Board have taken multiple necessary steps to resolve this complex issue.

While these responses are reactive, they will guide TMUS to be compliant in the years to come.

Lack of knowledge of senior leadership in these areas can jeopardize TMUS’ operational

integrity as well as contribute to the perceived concerns of safety on campus. The leadership,

with the Board’s guidance, must ensure that new and current key personnel are well versed in

this important issue in higher education.

Commendations and Recommendations

The SVT acknowledges the sincere attempt of the senior leadership and the Board of

TMUS to resolve issues raised in the latest Commission action letter. Based on evidence

provided in the Institutional Report, additional supplemental documents, and interviews of the

Board of Directors, administrators, faculty, staff and students, the following commendations

and recommendations are offered to the institution.

Commendations:
• Extensive nature of the Board response and engagement with the WSCUC report is to be
commended.
• Staff and Administration are demonstrating a commitment to the mission and vision of
the organization.
• Specific steps have been taken regarding compliance with Federal Clery Act provisions.
• The Board has focused on long term institutional strategy in their provisions for
succession and sustainability.

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 • Recent improvement in the areas of communication, operations transparency,
engagement of the Board, and commitment of the community.

Recommendations:
• The Board and Administration should continue to communicate regarding personnel
actions and leadership succession. Continue to remove barriers to cultural health and
harmony, whether personal or structural in nature.
• Ensure that the Board leads and successfully completes the Presidential transition for
the University so that appropriate Board and Administration roles can be restored to a
normative state.
• Conduct a national search for the presidential role and ensure that the President of the
University reports directly to the Board.
• Establish systematic 2-way communication practices to promote consistent and
sustainable flow of information among administrator, faculty, staff and students.
• Establish third party reporting frameworks for staff grievances and ethical concerns to
be shared outside of the University.
• Ensure that the corrective actions recently taken based on recommendations from the
last reaffirmation visit are sustainable and consistent.
• Establish plans for immediate actions, short-term and long-term actions and
communicate these action plans within the University community.

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