2020-06-12T11:01:46-07:00 2019-07-31 330783983 West Rhode & Roberts 2741 4th Ave San Diego CA 92103 990 2018-08-01 952944594 CALIFORNIA WESTERN SCHOOL OF LAW CALI 6195257073 225 CEDAR ST SAN DIEGO CA 92101 Bonnie Liang CFO 2020-06-12 true Cheryl Rhode P00234939 6196155380 2018 2021-01-29 14:40:06Z 225 CEDAR ST SAN DIEGO CA 92101 54914502 false false X www.cwsl.edu X 1975 CA California Western School of Law is the independent, ABA/AALS-accredited S.D. law school that prepares graduates for the practice of law through a carefully sequenced program of study combining trad. legal theory w/ hands-on learning in real & simulated client environments. 22 22 324 55 0 3401180 3112242 38470890 39733884 1695082 1349645 49770 105924 43616922 44301695 16975160 16850007 0 18291990 19580288 0 485246 11069091 12356398 46336241 48786693 -2719319 -4484998 67473553 65586641 14731609 18100087 52741944 47486554 CALIFORNIA WESTERN SCHOOL OF LAW IS AN INDEPENDENT, ABA/AALS-ACCREDITED LAW SCHOOL THAT PREPARES GRADUATES FOR THE PRACTICE OF LAW THROUGH A CAREFULLY SEQUENCED PROGRAM OF STUDY COMBINING TRADITIONAL LEGAL THEORY WITH HANDS-ON LEARNING IN REAL AND SIMULATED CLIENT ENVIRONEMENTS. CALIFORNIA WESTERNS CLINICS ARE A LEGAL RESOURCE TO THE COMMUNITY, AND THROUGH THEM THE LAW SCHOOL MAKES SIGNIFICANT, MEASURABLE CONTRIBUTIONS TO THE SOLUTION OF LEGAL PROBLEMS IN OUR COMMUNITY, OUR SOCIETY, AND OUR WORLD. false false 39333451 17104411 39733884 FOR MORE THAN 90 YEARS, CALIFORNIA WESTERN SCHOOL OF LAW HAS HELPED STUDENTS PREPARE FOR SUCCESS IN LEGAL PRACTICE AND BECOME OUTSTANDING LAWYERS SERVING THEIR CLIENTS AND THEIR COMMUNITIES. CALIFORNIA WESTERN SCHOOL OF LAW PROVIDES A RIGOROUS TRADITIONAL LEGAL EDUCATION INCLUDING J.D., LL.M., AND DUAL J.D. /MBA, AND J.D. /MSW DEGREES WITH AN EMPHASIS ON DEVELOPING PROBLEM-SOLVING, COMMUNICATION, WRITING, AND ANALYTICAL THINKING SKILLS. AT THE SAME TIME, THE LAW SCHOOL TEACHES STUDENTS THE SKILLS OF LAW PRACTICE, THROUGH SIMULATION COURSES, CLIENT-SERVICE CLINICS, AND A ROBUST EXTERNSHIP PROGRAM. THIS STRONG THEORETICAL GROUNDING AND ADVANCED SKILL BASE HELPS GRADUATES PASS THE BAR EXAM AND PROVIDE HIGH QUALITY SERVICES TO CLIENTS AND THE LEGAL PROFESSION FROM THE EARLIEST DAYS OF THEIR CAREERS. CALIFORNIA WESTERN SCHOOL OF LAW HAS BEEN NAMED TO THE PRESIDENTS HIGHER EDUCATION COMMUNITY SERVICE HONOR ROLL NUMEROUS TIMES IN RECOGNITION OF THE SCHOOLS VARIOUS COMMUNITY-FOCUSED PROJECTS AND PROGRAMS INCLUDING THE CALIFORNIA INNOCENCE PROJECT (CIP), THE LATIN AMERICAN INSTITUTE OF LAW AND JUSTICE, COMMUNITY LAW PROJECT, NEW MEDIA RIGHTS, AND MORE. OUR CIP PROJECT ATTORNEYS, STAFF AND CLINICAL STUDENTS HAVE HAD AMAZING SUCCESSES IN CHANGING PEOPLES LIVES. SINCE THE INCEPTION OF THE PROJECT, MORE THAN 25 INNOCENT PEOPLE HAVE BEEN FREED FROM PRISON FOR CRIMES THEY DID NOT COMMIT. IN ADDITION, IN 2019 THE FEATURE FILM BRIAN BANKS, ABOUT A HIGH SCHOOL FOOTBALL STAR WHO WAS WRONGFULLY CONVICTED OF A CRIME AND HELPED BY CIP, WAS RELEASED TO AUDIENCES ACROSS THE NATION AND AROUND THE WORLD. OUR LATIN AMERCIAN INSTITUTE OF LAW AND JUSTICE CURRENTLY PROVIDES SKILLS TRAINING FOR LAW STUDENTS AND LAWYERS, IN SPANISH. IN ADDITION TO IN-SERVICE CONTINUING LEGAL EDUCATION THROUGH ACCESO CAPACITACION, THE INSTITUTE SUPPORTS THE LAW SCHOOLS MAESTRIA PROGRAM, A ONE-YEAR HYBRID RESIDENTAL AND ONLINE LL.M. DEGREE PROGRAM FOCUSED ON TRIAL ADVOCACY SKILLS. OUR MEXICAN MOOT COURT COMPETITION PROGRAM CONDUCTS TRAININGS AND REGIONAL AND NATIONAL MOOT COURT COMPETITIONS THROUGHOUT MEXICO. RED INOCENTE LAUNCHES AND COORDINATES THE WORK OF INNOCENCE ORGANIZATIONS THROUGHOUT LATIN AMERICA. THE NEW MEDIA RIGHTS PROGRAM PROVIDES SERVICES TO CREATORS, CONSUMERS AND EARLY STAGE ENTREPRENEURS WHO NEED INTELLECTUAL PROPERTY, PRIVACY, AND MEDIA LAW EXPERTISE. THE PROGRAM EDUCATES THOUSANDS OF INDIVIDUALS ABOUT INTELLECTUAL PROPERTY, PRIVACY AND INTERNET LAW THROUGH WORKSHOPS, WRITTEN MATERIALS, VIDEO AND THE NEW MEDIA RIGHTS WEBSITE. THE COMMUNITY LAW PROJECT PROVIDES HIGH QUALITY LEGAL ASSISTANCE AND REFERRALS TO NEEDY INDIVIDUALS THROUGHOUT SAN DIEGO. LAW SCHOOL STUDENTS, TOGETHER WITH THE COMMUNITY LAW PROJECTS STAFF AND OVER 100 VOLUNTEER ATTORNEYS AND COMMUNITY MEMBERS, ASSIST ABOUT 1,400 INDIVIDUALS ANNUALLY. CLIENTS ARE SERVED IN WEEKLY CLINICS AND THROUGH THE COMMUNITY LAW PROJECTS INNOVATIVE COMMUNITY EDUCATION PROGRAMS, WHERE WE EDUCATE THE UNDERSERVED ON ISSUES RANGING FROM CONSUMER PROTECTION TO IMMIGRATION, ESTATE PLANNING, TENANT RIGHTS AND MORE. THE COMMUNITY LAW PROJECT PLAYS A KEY ROLE IN SAN DIEGO, WORKING TO ASSIST THE NEEDY WITH LEGAL MATTERS. LOCATED AT THE HEART OF SAN DIEGOS LEGAL, POLITICAL, AND JUDICIAL CENTER, CALIFORNIA WESTERN SCHOOL OF LAW MAINTAINS AN ANNUAL ENROLLMENT OF ABOUT 700 STUDENTS AND 150 FULL-TIME AND PART-TIME FACULTY AND STAFF MEMBERS. STUDENTS, FACULTY, AND STAFF YEARLY DONATE MORE THAN 10,000 PRO BONO AND SERVICE HOURS TO NONPROFITS, CLINICAL PROGRAMS, AND LAW OFFICES. 39333451 true true false false false false false false false true true true false false true true true false true true true false true false true false false false true true false false false false false false true false false false false false false false false false true false false false true 904 0 true 324 true true true true OC false false false true true false 0 false false false false false false false false false false false false X 22 22 true false false false false false false true true false false true true true true true true true true true false CA X X Bonnie Liang CFO 6195257073 225 CEDAR STREET SAN DIEGO CA 92101 JEFFREY D LEWIN ESQ Chairman 10.00 0.00 X X 0 0 0 ROBERT K SCOTT ESQ VICE CHAIR 4.00 0.00 X X 0 0 0 HON IRMA E GONZALEZ Secretary 4.00 0.00 X X 0 0 0 ROY MORROW BELL ESQ Trustee 4.00 0.00 X 0 0 0 GAYLE BLATT ESQ Trustee 1.00 0.00 X 0 0 0 SHERRY BAHRAMBEYGUI Trustee 1.00 0.00 X 0 0 0 DR CHUKUKA ENWEMEKA Trustee 1.00 0.00 X 0 0 0 CHARLES R GREBING ESQ Trustee 1.00 0.00 X 0 0 0 KENNETH L GREENMAN JR ESQ Trustee 4.00 0.00 X 0 0 0 HON JUDITH L HALLER Trustee 1.00 0.00 X 0 0 0 JEFFREY ISAACS ESQ Trustee 1.00 0.00 X 0 0 0 IMRAN JASWAL Trustee 1.00 0.00 X 0 0 0 J Randall Jones ESQ Trustee 1.00 0.00 X 0 0 0 MARK P MANDELL ESQ Trustee 4.00 0.00 X 0 0 0 JOHN F OBRIEN Trustee 1.00 0.00 X 0 0 0 DR ERICA PASCAL Trustee 1.00 0.00 X 0 0 0 EBERHARD R ROHM Trustee 1.00 0.00 X 0 0 0 JANINE SARTI ESQ Trustee 1.00 0.00 X 0 0 0 SURESH SUBRAMANI Trustee 1.00 0.00 X 0 0 0 RAHIL SWIGART ESQ Trustee 1.00 0.00 X 0 0 0 MICHAEL WHITTON ESQ Trustee 1.00 0.00 X 0 0 0 DUANE LAYTON Trustee 1.00 0.00 X 0 0 0 CRAIG MCCLELLAN Trustee 1.00 0.00 X 0 0 0 NIELS SCHAUMANN President/Dean 65.00 0.00 X 349532 0 36782 DONALD J SMYTHE VICE DEAN 60.00 0.00 X 179756 0 28127 PAMELA J DUFFY VP OF FIN & CFO 50.00 0.00 X 221108 0 38508 LISA JORDAN Dir Org & Legal 50.00 0.00 X 102175 0 18540 David M Blake VP of HR 40.00 0.00 X 158348 0 8396 BARBARA COX PROF. OF LAW 40.00 0.00 X 226354 0 27465 THOMAS D BARTON PROF. OF LAW 40.00 0.00 X 192754 0 30584 JUSTIN BROOKS PROF. OF LAW 40.00 0.00 X 212962 0 25246 MARIO CONTE PRAC. IN RESIDENCE 40.00 0.00 X 184585 0 19801 Phillip T Gragg Assoc. Dean 50.00 0.00 X 192603 0 28120 WILLIAM J ACEVES Prof of Law/Former officer 40.00 0.00 X 184186 0 10551 2204363 272120 48 true true false ALLIED UNIVERSAL SECURITY SER PO BOX 31001-2374 PASADENA CA 911102374 CAMPUS SECURITY 417806 BARBRI 9400 N CENTRAL EXPRESSWAY STE 613 DALLAS TX 75231 BAR EXAM REV. COURSE 393750 FIRST AMERICAN TITLE INS CO 2141 5TH AVE SAN DIEGO CA 92101 PARKING LOT 5555484 CAMPUS MGMT CORP 5201 CONGRESS AVE STE 220A BOCA RATON FL 33487 ERP 869323 PACIFIC BLG GROUP 9752 ASPEN CREEK COURT 150 SAN DIEGO CA 92126 BUILDING RENOVATION 428077 12 22993 2066720 1022529 3112242 FEDERAL WORK STUDY 611600 19019 19019 FORFEITED DEPOSITS 611600 32650 32650 OTHER PROGRAM SERVICE REV 611600 87574 87574 PERKINS LOAN PROGRAM 611600 54569 54569 TUITION AND FEES 611600 39534157 39534157 5915 5915 39733884 863400 863400 0 0 0 11044910 10558665 486245 486245 486245 54142 22993 54142 0 0 0 OTHER REVENUE 611600 105924 105924 105924 44301695 39733884 1455569 0 16841864 16841864 8143 8143 0 1319587 141002 1077884 100701 0 14103558 11671900 2275401 156257 0 3082932 2359713 683440 39779 1074211 846056 212285 15870 0 49449 10496 38488 465 70901 15051 55184 666 0 0 0 2524546 535890 1964928 23728 61039 12957 47509 573 377389 242177 134152 1060 0 0 1439428 832186 541804 65438 0 0 1524925 1215721 301854 7350 1010247 883965 116179 10103 0 1734917 1518052 199516 17349 0 MATERIALS, POSTAGE & PRINTING 1353626 1070666 262965 19995 OTHER EXPENSES 1216778 256542 944091 16145 ERP IMPLEMENTATION COSTS 976657 854574 112316 9767 PERKINS LOAN FUND 16496 16496 0 48786693 39333451 8967996 485246 1461021 567985 2577738 4499854 890347 660018 224786 248631 40000 30000 0 2578715 1409604 0 0 67196823 37455056 24260796 29741767 28121849 20952855 6120798 6631331 0 0 1197503 844596 67473553 65586641 3122047 2923373 433313 421138 8329839 11871093 2846410 2884483 14731609 18100087 X 44666573 39442346 3928542 3760528 4146829 4283680 52741944 47486554 67473553 65586641 X -4484998 -732319 -38073 X false true X true true true X RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED 25938200 181173 298367 134406 990069 64995 25228270 24337375 58706 3230384 129182 1505858 53225 25938200 22711007 161117 2755037 119931 1119688 50167 24337375 24013662 95929 -195471 118905 1061936 22272 22711007 24486536 16794 544916 113325 899990 21269 24013662 0.76070 0.16980 0.06950 false false false 6614297 6614297 32158425 15345407 16813018 13295577 12604799 690778 15128524 9504850 5623674 29741767 6631331 GOVERNMENT LOAN PROGRAM 2884483 2884483 X 26664800 -732319 -732319 27397119 16904576 16904576 44301695 31920190 31920190 16866503 16866503 48786693 Part V, Line 4: Intended uses of the endowment fund. California Western School of Law's endowment consists of a number of funds established for a variety of purposes. The endowment assets provide a predictable stream of funding for these purposes including scholarships for students, studies in select legal programs, research funds for professors and other operational costs as determined by the Board of Trustees. Part X : FIN48 Footnote The School is exempt from federal income tax pursuant to Section 501(c)(3) of the Internal Revenue Code and is also exempt from state income tax. The Financial Accounting Standards Board (FASB) issued Accounting Standards Codification No. 740-10, Accounting for Uncertainties in Income Taxes, which sets a minimum threshold for financial statement recognition of the benefit of a tax position taken or expected to be taken in a tax return. The School has reviewed its positions for all open tax years and has determined that it has no uncertain tax positions requiring accrual or disclosure. Part XI, Line 4b: Other revenue amounts included on 990 but not included in F/S PERKINS LOAN FUND REVENUE $54569 SCHOLARSHIPS $16850007 Part XII, Line 4b: Other revenue amounts included on 990 but not included in F/S PERKINS LOAN FUND EXPENSE $16496 SCHOLARSHIPS $16850007 true true false true true true true false false false false false false false false true false true Schedule E, Line 3 - Racially Nondiscriminatory Policy Publicized CALIFORNIA WESTERN SCHOOL OF LAW (THE SCHOOL) CUSTOMARILY DRAWS A SUBSTANTIAL PERCENTAGE OF ITS STUDENTS NATIONWIDE AND FROM A LARGE GEOGRAPHIC SECTION OF CALIFORNIA. IN ADDITION, THE SCHOOL DRAWS MANY INTERNATIONAL STUDENTS TO ITS PROGRAM OF LEGAL EDUCATION. THE SCHOOL FOLLOWS A RACIALLY NONDISCRIMINATORY POLICY AS TO STUDENTS AND CURRENTLY ENROLLS MEANINGFUL NUMBERS OF RACIAL MINORITY STUDENTS. THE SCHOOL DOES NOT PUBLISH ITS RACIALLY NONDISCRIMINATORY POLICY IN A NEWSPAPER OF GENERAL CIRCULATION DUE TO THE LARGE GEOGRAPHIC REGION FROM WHICH APPLICANTS ARE DRAWN. HOWEVER, THE SCHOOL'S BULLETIN, BROCHURES, PROMOTIONAL LITERATURE AND WEBSITE CLEARLY SET FORTH THE SCHOOL'S RACIALLY NONDISCRIMINATORY POLICY.Statement of Non-Discrimination:California Western School of Law does not discriminate on the basis of age; ancestry; citizenship status; color; creed; disability or medical condition; gender; pregnancy, childbirth or related medical conditions; gender identity or expression; marital, military or parental status; national origin; race; religion; sexual orientation, or any other basis prohibited by law. Schedule E, Line 4 - Explanation of Records and Materials Not Maintained Schedule E, Line 5 - Explanation of Organization Discrimination by Race Schedule E, Line 6 - Explanation of Aid or Assistance from Governmental Agency THE SCHOOL PARTICIPATES IN THE FEDERAL WORK-STUDY AND PERKINS LOAN FUND PROGRAMS. IN ADDITION, THE SCHOOL PARTICIPATES IN THE FEDERAL DIRECT STUDENT LOAN PROGRAM WHICH INCLUDES FEDERAL STAFFORD LOANS AND GRAD PLUS FEDERAL LOANS. true C. AMERICA & CARIBBEAN 0 0 INVESTMENTS 2017020 NORTH AMERICA 0 0 Program Services ACCESO CAP 39618 NORTH AMERICA 0 12 Program Services MEXICO RULE OF LAW 1617852 12 12 3674490 3674490 SCHOLARSHIPS NORTH AMERICA 18 8143 TUITION REMISSION CURRENT RATE false false false false true false false CA CT NV F/R Event 77135 22993 54142 54142 77135 22993 54142 54142 54142 true 0 0 SCHOLARSHIPS 579 16841864 BASED UPON CURRENT RATES TUITION REMISSION Grantmaker's Description of How Grants are Used JD Admissions Scholarships:JD Admissions scholarships are awarded primarily based on academic merit (i.e. LSAT score and cumulative undergraduate grade point average). There is no separate application (beyond the application for admission) required for most of the scholarships. Merit Based Scholarships:California Western School of Law (the School) offers two forms of merit based scholarships that are awarded to students at the completion of their first year of law school. The Academic Merit Scholarship is typically awarded to students with GPAs from 3.33 to 4.33. It is awarded based solely on the student's GPA. The Dean's Diversity Scholarship is typically awarded to students with GPAs from 2.67 to 4.33. It is awarded through a competitive application process. The number of scholarships offered each year varies, based on the number of eligible students and the availability of funds.LL.M./M.C.L. Scholarships:Scholarships for our on-campus LL.M/M.C.L program are awarded to the School's most academically outstanding applicants based upon academic credentials, relevant work experience, impressive academic and professional recommendations, and strong command of English (as evidenced by quality writing on the applicant's personal statement and by the applicant's "Test of English as a Foreign Language"("TOEFL") score).Students enrolled in the School's Spanish on-line LL.M. program may apply for a scholarship if they can demonstrate a commitment to trial advocacy, education, and justice system reforms. In addition, students in this program may also receive a small scholarship if they graduated from a school in Mexico that has a cooperation agreement (a "convenio") with the School. X X X true true X X X X false false false false false false false true false false BARBARA COX PROF. OF LAW 226354 8000 19465 253819 David M Blake VP of HR 147348 1000 10000 7330 1066 166744 DONALD J SMYTHE VICE DEAN 177506 2250 8000 20127 207883 JUSTIN BROOKS PROF. OF LAW 205681 2250 5031 8000 17246 238208 MARIO CONTE PRAC. IN RESIDENCE 182335 2250 8000 11801 204386 NIELS SCHAUMANN President/Dean 291982 1750 55800 8000 28782 386314 PAMELA J DUFFY VP OF FIN & CFO 218858 2250 8000 30508 259616 Phillip T Gragg Assoc. Dean 169965 1250 21388 8000 20120 220723 THOMAS D BARTON PROF. OF LAW 190504 2250 8000 22584 223338 WILLIAM J ACEVES Prof of Law/Former officer 172636 3550 8000 8000 2551 194737 Part I, Line 1a: Relevant information in regards to selections on 1a. The President/Dean Niels Schaumann receives an automobile and housing allowance per the terms of his employment contract paid to him via payroll and included as W-2 reportable wages. In addition, the School pays for the Dean's monthly membership fees to a social club (the University Club) where various business meetings are regularly held. The total fiscal year annual cost of the membership is $1,581 and is reported as a business expense. Part I, Line 7: Non-Fixed payments not listed above THE SCHOOL DID PROVIDE FOR PERFORMANCE BONUSES OR STIPENDS TO EMPLOYEES DURING THE CALENDAR YEAR 2018. PHILLIP GRAGG KEY EMPLOYEE RELOCATION X 50000 30000 false true true 30000 Client Note 1 Client Note 1 - 990-TThe information on this return is based on K-1s provided. This is the best information available at the time of filing. Upon the discovery of additional or more detailed information an amended return will be filed. Form 990, Part VI, Line 2: Description of Business or Family Relationship of Officers, Directors, Et PRESIDENT/DEAN NIELS SCHAUMANN AND TRUSTEE JOHN O'BRIEN BOTH SERVE AS BOARD MEMBERS OF THE CONSORTIUM FOR INNOVATIVE LEGAL EDUCATION, A RELATED ORGANIZATION. Form 990, Part VI, Line 11b: Form 990 Review Process The draft Form 990 is distributed to, and reviewed by, the Finance Committee of the Board of Trustees. This review consists of individual committee member review, an overview of the draft by the CFO and a question and answer period during a committee meeting. A final draft with any applicable changes from the Finance Committee review is distributed to the Board of Trustees before being submitted to the IRS. Form 990, Part VI, Line 12c: Explanation of Monitoring and Enforcement of Conflicts Each year, the officers, trustees, key employees and certain other employees of CWSL are asked to review the conflict of interest policy and to complete the annual conflict of interest disclosure form. A checklist is maintained to monitor completion of the form and to track attempts to obtain the disclosure forms from all listed individuals. The completed forms are reviewed by the Chairman of the Audit Committee of the Board of Trustees and the CFO. Any disclosed conflict of interest or potential for the appearance of a conflict of interest is discussed with the applicable parties. If any action is required, a plan is developed to address the issue. In addition, our conflict of interest policy requires immediate disclosure of any new/ modified conflict of interest or appearance of a conflict of interest to an appropriate party at the organization. The new information is then reviewed and any applicable action plan developed as discussed above. Form 990, Part VI, Line 15a: Compensation Review & Approval Process - CEO, Top Management SEE EXPLANATION INCLUDED AT PART VI, LINE 15B Form 990, Part VI, Line 15b: Compensation Review and Approval Process for Officers and Key Employees The compensation of the officers of the organization and key employees are reviewed and approved by the Board of Trustees. Various comparability data is used to determine the reasonableness of the recommended compensation. The comparability data includes: salary surveys from various sources, Form 990 compensation data from other comparable organizations and other industry specific articles/publications. The minutes of this meeting detail the members present, their vote on compensation, the documents reviewed to determine reasonableness of the compensation, the terms of the approved compensation, the date approved, the independence of the board members, and any deliberation. The minutes are completed and approved in a timely fashion. Form 990, Part VI, Line 19: Other Organization Documents Publicly Available The organization makes its governing documents, conflict of interest policy and financial statements available to the public upon request. Other Changes In Net Assets Or Fund Balances - Other Decreases PERKINS LOAN FUND RECLASS(NET- REV LESS EXP) = -$38073 FORM 990, PART XI - OTHER CHANGES IN NET ASSETS This figure includes amounts that are not reflected in the tax return detail of revenues and expenses as follows:Perkins Loan Fund reclass (38,073)The School serves as an agent for the federal government in administering the Perkins Student Financial Aid Program. Therefore, the Perkins Loan fund program activity is not reflected in the School's revenue and expense totals. The activity is recorded on the balance sheet of the School and must therefore be reflected as an adjustment to the tax return net asset reconciliation hereon. CONSORTIUM FOR INNOVATIVE LEGAL ED 225 CEDAR ST SAN DIEGO CA 92101 411884496 EDUCATIONAL PROGRAMS DE 501(C)(3) 509(A) T. II NA false false false false false false false false false false false false false false false false false true false false CONSORTIUM FOR INNOVATIVE LEGAL ED q 51016 Accrual Based