2022-04-01T15:57:21-05:00 2021-06-30 366055558 GRANT THORNTON LLP 1000 WILSON BLVD SUITE 1400 ARLINGTON VA 22209 990 2020-07-01 231627436 PEIRCE COLLEGE PEIR 2156709128 1420 PINE STREET PHILADELPHIA PA 19102 ELIZABETH KRAPP VP FINANCE/ADMIN & TREASURER 2156709128 2022-03-25 1 ELIZABETH KRAPP XXX-XX-XXXX MARY TORRETTA P00847851 7038477500 2 AAL1 IAL1 2020 2022-09-23 18:48:47Z ELIZABETH KRAPP 1420 PINE STREET PHILADELPHIA PA 19102 23725368 0 X WWW.PEIRCE.EDU X 1963 PA SEE SCHEDULE O 13 13 214 13 0 0 5622636 5836138 15957759 14128297 1112846 1707411 374127 522492 23067368 22194338 6911875 5350877 0 0 12398507 11649134 0 0 478134 4511294 4438089 23821676 21438100 -754308 756238 35901113 40819984 4494835 3773358 31406278 37046626 X SEE SCHEDULE O 0 0 18071012 5350877 14128297 SEE SCHEDULE O 18071012 1 1 0 1 0 0 0 0 0 1 1 0 0 0 0 1 1 0 1 0 0 0 0 0 1 0 0 0 1 1 0 0 0 0 0 0 0 0 1 0 0 0 0 0 0 0 0 1 1856 0 1 214 1 0 0 0 0 0 0 0 0 0 0 0 0 X 13 13 0 0 0 0 0 0 0 1 1 0 0 1 1 1 1 1 1 1 1 0 X ELIZABETH KRAPP 2156709128 1420 PINE STREET PHILADELPHIA PA 19102 TONI PERGOLIN CHAIR 1.00 0.00 X 0 0 0 DAVID SILVERMAN BOARD MEMBER 1.00 0.00 X 0 0 0 SCOTT D SMITH BOARD MEMBER 1.00 0.00 X 0 0 0 LISA S WALKER BOARD MEMBER 1.00 0.00 X 0 0 0 RENEE B YANCEY BOARD MEMBER 1.00 0.00 X 0 0 0 WILLIAM H MORGAN VICE CHAIR 1.00 0.00 X 0 0 0 KEITH DAVISTON BOARD MEMBER 1.00 0.00 X 0 0 0 STEVEN SCOTT BRADLY BOARD MEMBER 1.00 0.00 X 0 0 0 ROBERT GRASSO BOARD MEMBER 1.00 0.00 X 0 0 0 TOM KARINSHAK BOARD MEMBER 1.00 0.00 X 0 0 0 TOM MCLAUGHLIN BOARD MEMBER 1.00 0.00 X 0 0 0 SHARMAIN MATLOCK-TURNER BOARD MEMBER 1.00 0.00 X 0 0 0 JOSHUA W B RICHARDS BOARD MEMBER 1.00 0.00 X 0 0 0 DR MARY ELLEN CARO PRESIDENT AND CEO 40.00 0.00 X 441000 0 30293 ELIZABETH M KRAPP VP FINANCE/ADMIN & TREASURE 40.00 0.00 X 193878 0 22379 TARA MCBRIDE EXEC ASST TO PRESIDENT & SECRETARY 40.00 0.00 X 82391 0 14629 DR RITA TOLIVER-ROBERTS PROVOST & VP ACADEMIC AFFAIRS 40.00 0.00 X 194787 0 24984 JOSEPH GUZZARDO VP MARKETING, COMMUN, RECRUITING STRAT 40.00 0.00 X 181169 0 35447 BRAD HODGE VP ENROLL/STUDENT SERVICES 40.00 0.00 X 169150 0 20626 ADRIAN ZAPPALA DEAN OF GRADUATE STUDIES 40.00 0.00 X 152652 0 31965 STEPHANIE DONOVAN ASSOC PROF/CHAIR HEALTH PROGRAMS 40.00 0.00 X 153296 0 18346 JAMES BURNS CIO 40.00 0.00 X 135340 0 32226 JANET EICKHOFF AVP INSTIT ADV/STRATEGIC PARTNERSHIPS 40.00 0.00 X 147562 0 19387 CATHY LITTLEFIELD PROFESSOR AND FACULTY CHAIR, BUSINESS ADMIN 40.00 0.00 X 135203 0 23642 1986428 0 273924 32 0 1 0 DCW MEDIA 895 MARLON AVENUE RONKONKAMA NY 11779 ADVERTISING SERVICES 973233 A BOOK STORE 28312 NEWWORK PLACE CHICAGO IL 60673 BOOK STORE 403220 ALLIED UNIVERSAL SECURITY SERVICES 161 WASHINGTON STREET SUITE 700 CONSHOHOCKEN PA PA 19428 SECURITY SERVICES 106988 SALES FORCE ORG PO BOX 203141 DALLAS TX 75320 CRM PLATFORM PROVIDER 102096 4 4899587 936551 50160 5836138 TUITION AND FEES 611310 14128297 14128297 0 14128297 649207 649207 91101 0 91101 91101 91101 2587234 1529030 1058204 1058204 1058204 30800 2000 28800 28800 ALL OTHER 900099 227437 227437 COURSE EVALUATION FEES 900099 146850 146850 BOOKSTORE 323111 28304 28304 402591 22194338 14128297 0 2229903 5350877 5350877 1278489 888356 374242 15891 7754207 6533982 958802 261423 420000 352238 56920 10842 1561727 1133180 361128 67419 634711 527196 88688 18827 73406 73406 97666 97666 60000 60000 32053 32053 448459 314272 110561 23626 1071440 1071440 181695 163018 14285 4392 679946 616031 43517 20398 332181 300956 21260 9965 805 627 145 33 11773 10378 700 695 91000 91000 618081 559982 39557 18542 155930 155930 AR PROVISION FOR LOSS 301727 301727 ALL OTHER 152521 86234 40755 25532 FELLOWSHIPS 101949 101949 TEMPORARY EMPLOYEE CONT 26582 26582 875 296 30 549 21438100 18071012 2888954 478134 433453 538649 33841 44646 246922 201462 983200 940350 362004 382613 28761022 20079552 9299552 8681470 24479041 29955057 63100 75737 0 0 35901113 40819984 862909 962865 229990 186581 2755482 2618978 488729 4934 157725 0 4494835 3773358 X 28427691 32829408 2978597 4217218 31406288 37046626 35901123 40819984 756238 4884100 0 X 0 1 X 1 1 1 X RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED 0 0 0 0 0 0 0 0 0 1 60000 0 0 60000 0 PART II-B, LINE 1G ATTENDED MEETINGS WITH MEMBERS OF THE PENNSYLVANIA HOUSE AND SENATE IN ORDER TO EDUCATE MEMBERS ON PEIRCE COLLEGE AND TO DISCUSS THE IMPACT OF THE UNIVERSITY ON THE SURROUNDING REGION. THE GOAL OF THESE MEETINGS WAS TO RAISE THE PROFILE OF PEIRCE COLLEGE AND SEEK PARTNERSHIPS WITH THE COMMONWEALTH OF PENNSYLVANIA. 3309000 3462 900309 100702 21012 4260 4086797 3271824 4090 151809 94934 19835 3954 3309000 3175705 5848 203515 90566 18783 3895 3271824 996102 1970244 232966 16312 5842 1453 3175705 251810 758155 13863 996102 0.18090 0.14530 0.67380 1 0 27670 27670 19140506 12193192 6947314 0 9592846 7886360 1706486 0 8681470 X 21896508 4884099 -1916534 2967565 18928943 32052 3233343 3265395 22194338 16256171 -3235343 -3235343 19491514 32052 1914534 1946586 21438100 PART V, LINE 4: INTENDED USE OF ENDOWMENT FUNDS: THE COLLEGE'S ENDOWMENT CONSISTS OF DONOR-RESTRICTED AND BOARD DESIGNATED FUNDS TO BE HELD IN PERPETUITY, WITH INCOME BEING USED FOR SCHOLARSHIPS, OPERATING EXPENSES, AND FACULTY AWARDS. PART X, LINE 2: THE COLLEGE FOLLOWS THE ACCOUNTING GUIDANCE FOR UNCERTAINTIES IN INCOME TAX POSITIONS WHICH REQUIRES THAT A TAX POSITION BE RECOGNIZED OR NOT RECOGNIZED BASED ON A "MORE LIKELY THAN NOT" THRESHOLD. THIS APPLIES TO POSITIONS TAKEN OR EXPECTED TO BE TAKEN IN A TAX RETURN. THE ASSESSMENT OF THE TAX POSITION IS BASED SOLELY ON THE TECHNICAL MERITS OF THE POSITION, WITHOUT REGARD TO THE LIKELIHOOD THAT THE TAX POSITION MAY BE CHALLENGED. THE COLLEGE HAS PROCESSES PRESENTLY IN PLACE TO ENSURE THE MAINTENANCE OF ITS TAX-EXEMPT STATUS, TO IDENTIFY AND REPORT UNRELATED INCOME, DETERMINE ITS FILING AND TAX OBLIGATIONS IN JURISDICTIONS FOR WHICH IT HAS NEXUS, AND TO REVIEW OTHER MATTERS THAT MAY BE CONSIDERED TAX POSITIONS. AS OF JUNE 30, 2021 AND 2020, MANAGEMENT HAS DETERMINED THAT THE COLLEGE HAS NO MATERIAL UNCERTAIN TAX POSITIONS THAT WOULD REQUIRE RECOGNITION OR DISCLOSURE IN THE ACCOMPANYING FINANCIAL STATEMENTS. PART XI, LINE 2D - OTHER ADJUSTMENTS: RECLASS OF SCHOLARSHIPS -1,916,534. PART XI, LINE 4B - OTHER ADJUSTMENTS: RECLASS OF PELL/ PHEAA 3,235,343. RECLASS OF FUNDRAISING EVENT -2,000. PART XII, LINE 2D - OTHER ADJUSTMENTS: RECLASS OF PELL/PHEAA -3,235,343. PART XII, LINE 4B - OTHER ADJUSTMENTS: RECLASS OF SCHOLARSHIPS 1,916,534. RECLASS OF FUNDRAISING EVENT -2,000. 1 1 1 1 1 1 1 0 0 0 0 0 0 0 0 1 0 1 SCHEDULE E, PART I, LINE 6A GOVERNMENT ASSISTANCE: PEIRCE COLLEGE RECEIVED ASSISTANCE FROM THE U.S. DEPARATMENT OF EDUCATION FOR THE FOLLOWING PROGRAMS: FEDERAL PELL GRANT, FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANT, FEDERAL WORK STUDY, AND THE CARL D. PERKINS CAREER AND TECHNICAL EDUCATION GRANT. PEIRCE COLLEGE RECEIVED, VIA THE CARES ACT, THE GOVERNOR'S EMERGENCY EDUCATION RELIEF AND HIGHER EDUCATION EMERGENCY RELIEF FUNDS. PEIRCE COLLEGE ALSO RECEIVED A PENNSYLVANIA INSTITUTIONAL ASSISTANCE GRANT AND A GRANT FROM THE PENNSYLVANIA HIGHER EDUCATON ASSITANCE AGENCY. SCHEDULE E, PART I, LINE 3 PEIRCE COLLEGE IS AN EQUAL OPPORTUNITY INSTITUTION. THE COLLEGE IS COMMITTED TO ENSURING EQUAL OPPORTUNITY IN ALL EMPLOYMENT DECISIONS, POLICIES, AND PRACTICES, AND IN CONNECTION WITH ALL EDUCATIONAL PROGRAMS AND ACTIVITIES (INCLUDING BUT NOT LIMITED TO RECRUITMENT, ADMISSIONS, ACCESS TO PROGRAMS AND COURSE OFFERINGS, COUNSELING, FINANCIAL AID AND SCHOLARSHIPS, EMPLOYMENT, USE OF FACILITIES, AND COLLEGE-SPONSORED EXTRACURRICULAR ACTIVITIES). THE COLLEGE WILL NOT ENGAGE IN OR TOLERATE UNLAWFUL DISCRIMINATION, HARASSMENT, OR RETALIATION ON THE BASIS OF RACE, GENDER, ETHNICITY, RELIGION, A RELIGIOUS GROUP'S ACTUAL OR PERCEIVED SHARED ANCESTRY OR ETHNIC CHARACTERISTICS, AGE, NATIONAL ORIGIN, COLOR, DISABILITY, MARITAL STATUS, FAMILIAL STATUS, VETERAN STATUS, ANCESTRY, GENETIC CHARACTERISTICS, PREGNANCY, CHILDBIRTH, OR MEDICAL CONDITIONS RELATED TO PREGNANCY OR CHILDBIRTH, CREED, CITIZENSHIP, SEXUAL ORIENTATION, GENDER IDENTITY OR EXPRESSION, MILITARY STATUS, OR ANY OTHER PROTECTED CLASSIFICATIONS IN ITS EMPLOYMENT, ADMISSIONS, PROGRAMS AND ACTIVITIES AS REQUIRED BY TITLE IX OF THE EDUCATIONAL AMENDMENTS OF 1972, THE AMERICANS WITH DISABILITIES ACT OF 1990, SECTION 504 OF THE REHABILITATION ACT OF 1973, TITLE VII OF THE CIVIL RIGHTS ACT OF 1964, THE AGE DISCRIMINATION ACT OF 1975, AND OTHER APPLICABLE STATUTES AND COLLEGE POLICIES. THE COLLEGE'S POLICY ON EQUAL OPPORTUNITY SUPPORTS AND IS CONSISTENT WITH THE COLLEGE'S COMMITMENT TO ENHANCING DIVERSITY AND INCLUSIVENESS. EXECUTIVE LEADERSHIP BREAKFAST 30800 30800 2000 30800 30800 2000 2000 28800 1 FEDERAL PELL GRANT 777 2400072 0 FEDERAL SEOG 247 242461 0 UNRESTRICTED SCHOLARSHIPS 834 1465646 0 RESTRICTED BY DONOR SCHOLARSHIPS 81 208427 0 PHEAA 357 835271 0 HIGHER EDUCATION EMERGENCY RELIEF STUDENT GRANT 199 199000 0 SCHEDULE I, PART I, LINE 2 PROCEDURE FOR MONITORING USE OF GRANT FUNDS INSIDE U.S.: ALL FINANCIAL AID GRANTS ARE USED FOR THE INTENDED PURPOSE WHICH IS TO PROVIDE AID TO STUDENTS WITH FINANCIAL NEED TO COVER THE STUDENTS' COST OF ATTENDANCE. THESE GRANTS INCLUDE FEDERAL PELL GRANTS, FEDERAL SEOG GRANTS, AND STATE PHEAA GRANTS. THE COLLEGE ALSO AWARDS DONOR RESTRICTED GRANTS THAT ARE PROVIDED FROM FOUNDATIONS, ALUMNI SCHOLARSHIP DONATIONS, AND OTHER DONORS. ADDITIONALLY, THE COLLEGE PROVIDES INTERNAL INSTITUTIONAL GRANTS TO ELIGIBLE STUDENTS. THE GRANTS ARE AWARDED AND POSTED TO THE ELIGIBLE STUDENTS' ACCOUNTS BY THE FINANCIAL AID OFFICE. THESE ACCOUNTS ARE RECONCILED BY THE ACCOUNTING DEPARTMENT AND THE FINANCIAL AID OFFICE ON A MONTHLY BASIS. THE FINANCIAL AID OFFICE COMPLIES WITH THE U.S. DEPARTMENT OF EDUCATION GUIDELINES AS WELL AS ANY DONOR RESTRICTED GRANT GUIDELINES. THE FINANCIAL AID OFFICE REPORTS STUDENT GRANT AWARDS TO THE U.S. DEPARTMENT OF EDUCATION AND PHEAA THROUGHOUT THE YEAR AND ALSO SUBMITS THE REQUIRED ANNUAL FISAP REPORT TO THE U.S. DEPARTMENT OF EDUCATION. AN ANNUAL A-133 AUDIT (FINANCIAL STATEMENTS AND REPORT OF INDEPENDENT CERTIFIED PUBLIC ACCOUNTS IN ACCORDANCE WITH OMB CIRCULAR A-133) IS CONDUCTED BY THE COLLEGES' EXTERNAL INDEPENDENT AUDITORS. X X X X 0 0 0 0 0 0 0 1 0 DR MARY ELLEN CARO PRESIDENT AND CEO 353500 0 87500 0 0 0 19600 0 10693 0 471293 0 0 0 DR RITA TOLIVER-ROBERTS PROVOST & VP ACADEMIC AFFAIRS 194787 0 0 0 0 0 12304 0 12680 0 219771 0 0 0 JOSEPH GUZZARDO VP MARKETING, COMMUN, RECRUITING STR 181169 0 0 0 0 0 11397 0 24050 0 216616 0 0 0 ELIZABETH M KRAPP VP FINANCE/ADMIN & TREASURE 193878 0 0 0 0 0 12228 0 10151 0 216257 0 0 0 BRAD HODGE VP ENROLL/STUDENT SERVICES 169150 0 0 0 0 0 10621 0 10005 0 189776 0 0 0 ADRIAN ZAPPALA DEAN OF GRADUATE STUDIES 152652 0 0 0 0 0 8212 0 23753 0 184617 0 0 0 STEPHANIE DONOVAN ASSOC PROF/CHAIR HEALTH PROGRAMS 153296 0 0 0 0 0 8065 0 10281 0 171642 0 0 0 JAMES BURNS CIO 135340 0 0 0 0 0 8449 0 23777 0 167566 0 0 0 JANET EICKHOFF AVP INSTIT ADV/STRATEGIC PARTNERSHIP 147562 0 0 0 0 0 9391 0 9996 0 166949 0 0 0 CATHY LITTLEFIELD PROFESSOR AND FACULTY CHAIR, BUSINES 135203 0 0 0 0 0 7158 0 16484 0 158845 0 0 0 PART I, LINE 7 NON-FIXED PAYMENTS: THE CHIEF EXECUTIVE OFFICER OF THE COLLEGE PARTICIPATES IN A BOARD OF TRUSTEES APPROVED EXECUTIVE COMPENSATION PROGRAM WHICH INCLUDES AN INCENTIVE COMPENSATION PLAN. THE ANNUAL AMOUNT IS CAPPED AT A PERCENTAGE OF SALARY. THE PLAN IS BASED ON THE ACHIEVEMENT OF CERTAIN PROGRAMMATIC GOALS AND OBJECTIVES FOR THE COLLEGE. THE PLAN IS APPROVED BY THE EXECUTIVE COMMITTEE AND THE EXECUTIVE COMMITTEE REVIEWS AND APPROVES THE ANNUAL AWARD BASED ON THE PERFORMANCE ACHIEVED ON THE AGREED-UPON GOALS. X 1 50160 FMV 0 1 0 PART I, COLUMN (B): THE ORGANIZATION IS REPORTING THE NUMBER OF CONTRIBUTIONS IN COLUMN (B). FORM 990, PART III, LINE 1 ORGANIZATION'S MISSION: PEIRCE COLLEGE EMPOWERS ADULT LEARNERS TO IMPROVE THEIR LIVES BY ACHIEVING CAREER GOALS THROUGH ACADEMIC OFFERINGS ALIGNED WITH EVOLVING WORKFORCE NEEDS. FORM 990, PART I, LINE 1 DESCRIPTION OF ORGANIZATION MISSION: PEIRCE COLLEGE IS A PRIVATE ACCREDITED INSTITUTION OFFERING ASSOCIATE'S/BACHELOR'S/MASTER'S DEGREES IN CAREER ORIENTED PROGRAMS GEARED TOWARDS ADULT LEARNERS. FORM 990, PART III, LINE 4A PROGRAM SERVICE: FOUNDED IN 1865, PEIRCE COLLEGE IS A PRIVATE, SPECIALIZED INSTITUTION PROVIDING PRACTICAL LEADING-EDGE CURRICULA TO PRIMARILY WORKING ADULT LEARNERS. THE COLLEGE AWARDS THE MASTER OF SCIENCE IN ORGANIZATIONAL LEADERSHIP AND MANAGEMENT, THE MASTER OF SCIENCE IN HEALTH CARE ADMINISTRATION, AND THE BACHELOR OF SCIENCE AND ASSOCIATE IN SCIENCE DEGREES. THE DEGREE PROGRAMS ARE IN ACCOUNTING, BUSINESS ADMINISTRATION, CRIMINAL JUSTICE, GENERAL STUDIES, HEALTH INFORMATION ADMINISTRATION, HEALTH INFORMATION TECHNOLOGY, HEALTHCARE ADMINISTRATION, HUMAN RESOURCE MANAGEMENT, INFORMATION TECHNOLOGY AND PARALEGAL STUDIES. PEIRCE COLLEGE OFFERS ITS PROGRAMS UTILIZING TWO INTERCHANGEABLE DELIVERY FORMATS: ON CAMPUS AT ITS CENTER CITY PHILADELPHIA LOCATION AND ONLINE THROUGH WEB BASED DISTANCE LEARNING. PEIRCE COLLEGE IS ACCREDITED BY THE MIDDLE STATES COMMISSION ON HIGHER EDUCATION. THE BACHELOR OF SCIENCE AND ASSOCIATE IN SCIENCE DEGREES AND THE CERTIFICATE OF PROFICIENCY IN PARALEGAL STUDIES ARE RECOGNIZED AND APPROVED BY THE AMERICAN BAR ASSOCIATION (ABA). THE ACCREDITATION COUNCIL FOR BUSINESS SCHOOLS AND PROGRAMS (ACBSP) ACCREDITS PEIRCE COLLEGE'S BACHELOR OF SCIENCE AND ASSOCIATE IN SCIENCE DEGREES AND CERTIFICATES OF PROFICIENCY IN BUSINESS ADMINISTRATION AND ACCOUNTING. FORM 990, PART VI, SECTION B, LINE 11B THE FORM 990 WAS PREPARED BY A NATIONALLY RENOWNED ACCOUNTING FIRM IN CONJUNCTION WITH THE ORGANIZATION'S FINANCIAL DEPARTMENT. THE FORM IS THEN SUBMITTED TO AN AUDIT, RISK & COMPLIANCE MANAGEMENT COMMITTEE OF THE BOARD FOR APPROVAL. A COPY OF THE DRAFT 990 IS THEN CIRCULATED TO THE FULL BOARD OF TRUSTEES FOR DISCUSSION AND COMMENT ON THE INFORMATION CONTAINED IN THE 990 PRIOR TO ITS FILING WITH THE INTERNAL REVENUE SERVICE. FORM 990, PART VI, SECTION B, LINE 12C CONFLICT OF INTEREST POLICY MONITORING & ENFORCEMENT: THE COLLEGE REQUIRES EACH EMPLOYEE INCLUDING THE PRESIDENT/CEO AND OTHER KEY EMPLOYEES TO COMPLETE AND SIGN A WRITTEN CONFLICTS OF INTEREST STATEMENT THAT INCLUDES QUESTIONS THAT CAN DETERMINE IF THE EMPLOYEE HAS A RELATIONSHIP, FINANCIAL INTEREST OR BUSINESS AFFILIATION THAT RESULTS IN A CONFLICT OF INTEREST. THESE STATEMENTS ARE COMPLETED ANNUALLY BY THE EMPLOYEE AND AT ANY TIME AN EMPLOYEE BECOMES AWARE OF FACTS WHICH REQUIRE AN ADDITIONAL OR UPDATED DISCLOSURE. THESE STATEMENTS ARE RETURNED TO HUMAN RESOURCES FOR REVIEW AND IF NECESSARY FURTHER ACTION MAY BE REQUIRED. THE COLLEGE ALSO REQUIRES EACH TRUSTEE INCLUDING TRUSTEE OFFICERS TO COMPLETE AND SIGN A CONFLICT OF INTEREST QUESTIONNAIRE THAT CAN DETERMINE IF THE TRUSTEE HAS A RELATIONSHIP, FINANCIAL INTEREST OR BUSINESS AFFILIATION THAT RESULTS IN A CONFLICT OF INTEREST. THESE QUESTIONNAIRES ARE COMPLETED ANNUALLY BY EACH TRUSTEE AND RETURNED TO THE BOARD SECRETARY AND ARE REVIEWED BY THE OFFICE OF THE PRESIDENT AND IF NECESSARY FURTHER ACTION MAY BE REQUIRED. IF A CONFLICT OF INTEREST IS IDENTIFIED, THE FOLLOWING PROCEDURES ARE FOLLOWED: (A) AN INTERESTED PERSON MAY TAKE A PRESENTATION AT A BOARD OR COMMITTEE MEETING, BUT AFTER THE PRESENTATION, HE/SHE SHALL LEAVE THE MEETING DURING THE DISCUSSION OF, AND THE VOTE ON, THE BUSINESS RELATIONSHIP INVOLVING THE POSSIBLE CONFLICT OF INTEREST. (B) THE CHAIRPERSON OF THE BOARD OR COMMITTEE SHALL, IF APPROPRIATE, APPOINT A DISINTERESTED PERSON OR COMMITTEE TO INVESTIGATE ALTERNATIVES TO THAT PROPOSED BUSINESS RELATIONSHIP. (C) AFTER EXERCISING DUE DILIGENCE, THE BOARD OR COMMITTEE SHALL DETERMINE WHETHER THE COLLEGE CAN OBTAIN WITH REASONABLE EFFORTS A MORE ADVANTAGEOUS BUSINESS RELATIONSHIP FROM A PERSON OR ENTITY THAT WOULD NOT GIVE RISE TO A CONFLICT OF INTEREST. (D) IF A MORE ADVANTAGEOUS BUSINESS RELATIONSHIP IS NOT REASONABLY POSSIBLE UNDER CIRCUMSTANCES NOT PRODUCING A CONFLICT OF INTEREST, THE BOARD OR COMMITTEE SHALL DETERMINE BY A MAJORITY VOTE OF THE DISINTERESTED TRUSTEES WHETHER THE BUSINESS RELATIONSHIP IS IN THE COLLEGE'S BEST INTEREST, FOR ITS OWN BENEFIT, AND WHETHER IT IS FAIR AND REASONABLE. IN CONFORMITY WITH THE ABOVE DETERMINATION, IT SHALL MAKE ITS DECISION AS TO WHETHER TO ENTER INTO THE BUSINESS RELATIONSHIP. FORM 990, PART VI, SECTION B, LINE 15 LINE 15A, PROCESS FOR DETERMINING COMPENSATION: MARY ELLEN CARO WAS ELECTED PRESIDENT AND CEO OF PEIRCE COLLEGE IN APRIL OF 2018. THE COMPENSATION ESTABLISHED FOR CARO WAS DETERMINED AS A RESULT OF A COMPENSATION STUDY CONDUCTED IN 2017 AS PART OF THE PRESIDENTIAL SEARCH COMMISSIONED BY THE BOARD OF TRUSTEES. THE COMPENSATION DATA WAS COMPILED USING INFORMATION FROM OTHER COLLEGES AND UNIVERSITIES AS A GUIDE IN DETERMINING REASONABLE COMPENSATION FOR THE PRESIDENT POSITION. LINE 15B, PROCESS FOR DETERMINING COMPENSATION: THE COMPENSATION FOR THE KEY EMPLOYEES OF PEIRCE COLLEGE WAS DETERMINED BY LOCAL AND REGIONAL MARKET SURVEYS AND INFORMATION AND DATA FROM LOCAL AND REGIONAL PUBLICATIONS AND PAPERS. THIS INFORMATION, ALONG WITH INTERNAL EQUITY, DETERMINE THE BASIS HIRE-IN SALARY OF KEY EMPLOYEES. ANNUALLY, KEY EMPLOYEES ARE EVALUATED BY THE PRESIDENT USING A PERFORMANCE MANAGEMENT DOCUMENT (PMD) WHICH IS STANDARD REVIEW USED BY ALL MANAGERS THROUGHOUT THE COLLEGE. THIS PROCESS ALSO DETERMINES THE PERCENT OF MERIT INCREASES RECEIVED. THE MERIT INCREASE PERCENTAGES ARE DETERMINED AS PART OF THE BUDGET PROCESS AND THE LEVEL OF PERCENTAGE INCREASES GIVEN TO THE KEY EMPLOYEES IS BASED ON THE SCORING OUTCOME OF THEIR PMD. FORM 990, PART VI, SECTION C, LINE 19 HOW DOCUMENTS ARE MADE AVAILABLE TO THE PUBLIC: THE COLLEGE MAKES ITS FORM 990 AVAILABLE TO THE PUBLIC BY RESERVING A COPY AT ITS PLACE OF BUSINESS. THE FORM 990 IS LIKEWISE PUBLISHED ON THE INTERNET AT WWW.GUIDESTAR.ORG. THE ORGANIZATION'S GOVERNING DOCUMENTS AND CONFLICT OF INTEREST POLICY WILL BE PROVIDED AT THE DISCRETION OF MANAGEMENT, IF REQUESTED.