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Accrediting Commission for Community and Junior Colleges Western Association of Schools and Colleges
Special Visit Team Report
Compton Community College 1111 East Artesia Blvd. Compton, CA 90221
This report represents the findings of the Special Visit Team that visited the college on July 20 - 21, 2004
Dr. E. Jan Kehoe, Team Chair Dr. Deborah G. Blue Dr. Barbara Beno
Special Visit Team Report on Compton Community College July 20-21, 2004
Introduction
On May 21, 2004, the California State Chancellor’s Office took control of Compton Community College District by imposing a State Trustee with authority to override the decisions of the Board of Trustees. The State Trustee was imposed because the College’s ending balance for the previous fiscal year, 2002–3, was projected as a negative two hundred and seventy-five thousand dollars, and information in Spring 2004 indicated that the College ran out of general funds on April 1, 2004, two months before the end of its fiscal year.
These events prompted the Accrediting Commission for Community and Junior Colleges, Western Association of Schools and Colleges (ACCJC), to contact the College and arrange a special visit by the Executive Director of the Commission, Dr. Barbara Beno, on June 13, 2004. During that visit, Dr. Beno met with the State Trustee, the College President, the Academic Vice President, faculty and classified staff leadership, the Accreditation Liaison Officer, and members of a fiscal crisis team provided to the College by the State. Dr. Beno found evidence that the College was significantly out of compliance with several basic accreditation standards. As a result, the Commission sent a team of three individuals to conduct a Special Visit to Compton Community College on July 20 and 21, 2004. The purpose of the visit was to determine the fiscal viability of Compton Community College and to assess the degree to which the College was out of compliance with Commission Standards.
The July special visit team consisted of Dr. E. Jan Kehoe, chair, President of Long Beach City College and Vice-Chair of the ACCJC; Dr. Deborah Blue, Associate Director of the ACCJC; and Dr. Barbara Beno, Executive Director of the ACCJC. During its two day visit to the College, the team met with the State Trustee, members of the Board of Trustees, the College President, the Executive Vice President, the faculty union co-presidents, the Faculty Senate President, a Supervisor of the confidential staff, a member of the Personnel Commission, the Executive Director of the Personnel Commission, the Academic Vice President, the Director of Human Resources, the Vice President of Student Affairs, the Director of Information Technology, the Director of Financial Aid, the Director of Maintenance and Operations, the Director of Research, and a faculty member. During the visit, the college staff was helpful and cooperative. The team was supplied with all documents it had requested in advance and was sent several additional documents subsequent to the visit. During the visit, at the end of an interview with board members, the President of the Board of Trustees made what was perceived as a threat of physical harm to a team member. That perceived threat was subsequently followed up with appropriate law enforcement agencies.
In late May 2004, a Fiscal Crisis Management Assistance Team (FCMAT) was sent to the College to provide assistance in evaluating and auditing the District�s fiscal condition. The FCMAT team was subsequently expanded to include experts in Human Resources and Personnel, and Information Technology, in addition to Fiscal Management. The FCMAT team was unable to use the College records to close the College�s fiscal �books� for the 2002-03 fiscal year, and subsequently had to do what would normally be staff work to create substantive reports to close those books so that an audit could be undertaken. The Special Visit Team interviewed the FCMAT team�s director at ACCJC offices in Novato in June and talked with FCMAT members during the two visits to the college in June and July. The FCMAT team developed a report on fiscal, personnel, and technology practices at the College. In order to avoid imposing two investigative teams on the College at the same time, the ACCJC agreed to use the FCMAT report as a source of information and evidence for the Special Visit Team Report on Compton Community College. It is appended to this Special Visit Team Report
Institutional and Accreditation Background Information
Compton Community College District is a single-college district serving the cities of Carson, Compton, Lynwood, Paramount, and Willowbrook. It has a five member Board of Trustees that is elected by the district. The College serves approximately 9,000 students, and its Full-Time Equivalent Students (FTES) in 2002-03 was 6,120, down a few hundred from the previous year.
Compton Community College was first accredited by the ACCJC in 1966. In the last decade the College�s has not been able to consistently and continuously meet or exceed accreditation standards. In 1993, the College was placed on Warning following a comprehensive evaluation, and in spring 1994, the College was placed on Probation. At that time, the Commission�s action letter included concerns about the Board of Trustee�s understanding of their role as a policy board and their willingness to work constructively with the College president, the College�s fiscal stability and fiscal control systems, and the College�s personnel policies and practices. College progress in addressing these concerns resulted in it being removed from Probation and placed again on Warning in January 1995 and subsequently removed from Warning in June 1996.
The College�s last comprehensive review occurred in Spring 1999, at which time the visiting team expressed concerns about the College�s personnel practices, its failure to develop a comprehensive educational, fiscal, physical and human resources planning process, and evidence of problems in on-campus communication. College receptiveness to the accreditation team�s findings and recommendations was limited. While the team was still at the College, the President wrote a memo entitled �Thanks and Final Thoughts� that was intended to provide further response to concerns the team had been tracking from previous accreditation visit reports in 1993 to 1995 and had expressed during the 1999 visit.
�I believe that it is quite clear that it cannot be substantiated that the Board has not delegated to me the full authority to administer this institution. The Trustees do not engage in micromanagement. In addition, the Board has implemented a series of recommendations designed to increase its effectiveness, including the adoption of a vision statement and the development and implementation of a self-evaluation instrument and code of ethics.� (Memo to �Members of the Accreditation Site Visit Team�, March 18, 1999.)
The College President wrote the team chair and Commission executive director after the visit to object to a portion of the team report that expressed observations and concerns: �Specifically, the College disagrees with the contention that problems exist in its hiring policies and practices; in effective and comprehensive communication between segments of the campus community, and in the successful integration of the budgeting and planning processes.� (Letter dated May 10, 1999.)
Findings and Conclusions of the Special Visit Team
The 2004 Special Visit Team�s findings focus on four main areas: fiscal management and stability of the College, College governance practices, and personnel practices. The team also has findings in the areas of assessment and institutional planning, technology and academic processes of program review, and curriculum and program design. The findings in the area of fiscal management and stability have significant spill-over to the areas of human resources and of Board and administrative leadership and governance. The College is significantly out of compliance with Standards I B, III A, C and D, and IV (all). It is also out of compliance with portions of Standard I A, II A and B, and Standard III B as well as with many standards that deal with institutional integrity in Standard I, II, III and IV.
Fiscal Management and Stability of the College (Standard III D)
The Special Visit Team found Compton Community College to lack even minimal compliance with all of the key areas of fiscal management described in the overview or Preamble of Standard III D, quoted below, and its subparts. Financial resources are sufficient to support student learning programs and services and to improve institutional effectiveness. The distribution of resources supports the development, maintenance and enhancement of programs and services. The institution plans and manages its financial affairs with integrity and in a manner that ensures financial stability. The level of financial resources provides a reasonable expectation of both short-term and long-term financial solvency. Financial resources planning is integrated with institutional planning.
The visiting team found that Compton Community College has suffered from extremely weak fiscal and administrative leadership and a relatively comprehensive lack of appropriate fiscal management, fiscal planning, and fiscal control systems to ensure fiscal stability. Of particular concern is the financial instability of the College and the degree to which the integrity of the college has been compromised by the actions of institutional leaders.
The College has been unable to close its books for two years in a row, and neither its external auditor (who has worked for the college for seventeen years) nor its Board of Trustees exercised appropriate fiscal oversight to investigate the causes of flawed accounting or to require better financial management practices. (Standard IV B.1, 1. b and c.) This suggests the Board and the administration may be considered negligent in fulfilling their responsibilities.
The Board itself has contributed to fiscal conditions that would be found problematic in an external audit. The Board�s use of institutional credit cards for personal expenses, its requirement that the President purchase five college automobiles for use by the Board, and its decision to hire Board assistants and multiple attorneys have all contributed to the misuse of college funds and the diversion of needed college resources from the educational programs and needs of the College and its students. The Board�s use of college automobiles has been investigated and reported by the Los Angeles Times (fall 2003) and is the subject of a legal investigation; it has also resulted in a lawsuit against the district for an accident caused by a non-district employee who was permitted to use one of the cars. (Standards III D.2.d., e., and g.)
The College president has, furthermore, failed to exercise appropriate supervision and discipline on senior administrative staff who have allowed the fiscal condition of the College to deteriorate to its present state. (Standards III D.2 a., b., c., and d.; Standards IV B.1.j., IV B.2. and B.2.c. and d.) In interviews with the Team, the President stated that he tried to hire a qualified business officer over the years; however, his hiring recommendations were rejected repeatedly by the Board of Trustees. Absent a permanent qualified business officer during many of the past several years, the College continued to employ a long-time college employee as Interim Business Officer. The College Business Officer appears to have been incompetent and lacked the understanding of simple fiscal management responsibilities, such as: accounting for categorical funds, balancing the budget, and generating monthly reports. This individual was unable or unwilling to address recommendations made by the external auditors about fiscal management in the last few completed audits, which were deemed to be Qualified due to grave errors in either practices or due to lack of adequate controls. Most of the discrepancies noted remained uncorrected or were repeated year after year.
The failure of the President to exercise oversight of his own staff is complicated by the fact that in the skewed job description and reporting structure of the College, the Deputy Superintendent / Executive Vice President exercises control over Human Resources/Personnel, many special projects that are categorically funded, the Vice Presidents for Academic Affairs and Student Affairs and the Dean of Administrative Operations. In effect, the Executive Vice President supervises all educational programs of the College. He also served as the functional leader of most administrative service areas including maintenance and operations, capital construction, and the college police department The President directly supervises the Deans of Human Resources/Risk Management and Information Technology, and the directors of Business Affairs and Fiscal Affairs. The Deputy Superintendent/Executive Vice President reports to the President, but the President has not effectively evaluated or controlled him. College staff refer to the Executive Vice President as the �real president� and the President as the �external president.� College documents that contain communications from the faculty to or about the President refer to him as removed from the academic affairs of the College.
While the College President provides direct supervision to the Director of Business Services (the position is presently filled by a long-term �interim�), many individuals told the visiting team that the Board works directly with the Director of Business Services and that the Deputy Superintendent/Executive Vice President also directs the Director. (These matters of governance will be described in a later section of this report.) The team heard from several sources that Board interference in college operations and a Board practice of working around the College President by going directly to the Deputy Superintendent/Executive Vice President may have contributed to the President�s inability to exercise authority over his senior administrative staff in many matters, including fiscal matters. The President indicated he placed the Director of Business Services on administrative leave in late spring 2004 because he was taking direction from the Board.
The College�s financial management practices are poor and are not based in a knowledge of the college�s revenues. The College has operated with a structural deficit for the last few years, and its planned expenditures have exceeded its expected revenues in the two most recent fiscal years. Recommendations from its Qualified audit reports have gone un-addressed for many years. Some of those recommendations concern the need to provide more accountability for the Board�s use of college resources.
Compton Community College has not completed annual independent audits on its financial condition and fiscal management practices as required by the ACCJC�s Eligibility Requirement 18. Compton Community College�s last timely audit occurred in 2000-2001. The College�s 2001-02 audit was completed sometime in fall 2002 and submitted to the State in January 2003. However, the audit has several qualifications, and the District will be making adjustments to the 2001-02 fiscal year ending balance over the next months as the FCMAT team completes records for that fiscal year. At the time of the team visit, the College had not closed its books for the 2002-03 fiscal year and had ended the 2003-04 fiscal year without closing its books. It was therefore just completing a second fiscal year in which it did not know its beginning year balance. (Standard III D.1.b, c, and d; Standard III D.2 and D.2.a, b, c, and d.)
FCMAT staff has been providing necessary technical assistance to supplant inadequate staff work in order to adjust the books on the 2001-02 fiscal year. They �forced� closed the 2002-03 fiscal year books in order to develop a �budget� for the 2003-04 fiscal year from which to analyze the College�s financial health at the end of that fiscal year. As of July 2004, in contradiction to State budget planning requirements, the College had not yet developed a draft budget for the 2004-05 (current) fiscal year. FCMAT and the State Trustee planned to develop a zero based budget for the 2004-05 fiscal year by September 1, 2004. (Standard III D.2.and D.2.a. through d.)
As FCMAT and the State Trustee did their work between May and the team visit in July, they discovered that the College had �lost� monies for the 2002-03 fiscal year, and that the ending balance would be about $299,000 rather than the negative $275,000 that was anticipated and that contributed to the State�s decision to impose a monitor. The FCMAT team and the State Trustee also �found� approximately $462,000 owed the College for a special program in 2003-04, and identified deferred income of approximately $1,000,000 that, if collected, will give the College an ending balance for 2003-04 of about $400,000.
That money was �found�, however, is not reassuring. The College lacks the appropriate fiscal accounting procedures and controls to collect monies owed to it by other entities such as federal programs, and so has failed to collect revenues due the College. (Standard III D.2.d.) The College spent all of the monies it knew it had and has no reserve. Without the new found funds of almost $1.5 million, the College would have had nearly $1 million deficit as an ending balance. (Standard III D.2.c.) Furthermore, Compton Community College paid its bills throughout the 2003-04 fiscal year by drawing on its Capital construction and restricted funds to �float� overdrafts in its General fund and
Compton Community College also faces fiscal liabilities that probably exceed its ending balance for the 2003-04 fiscal year. The College has improperly used consultants to do what would be considered employee work. When this situation is resolved, the individuals will be considered to have been employees. The College has failed to pay those employees payroll taxes for some time. Payment of past taxes (the College share as well as the employee share, for which the College is now liable), and associated fines for failure to pay, create significant financial liabilities for the College.
By drawing on its Bond funds placed in its bank accounts in late spring 2004, the College has �borrowed� these funds to use for operating expenses. Under California state law, the borrowed money must be repaid within one year.
Compton has been involved in litigation with vendors that was unresolved at the time of this team visit, but which could cost the District hundreds of thousands of dollars. A lawsuit against the District is pending by an individual injured in a car crash involving a District car driven by a relative of a Trustee.
The District hired approximately 170 �Independent Contractors� in 2002-03. A FCMAT examination of a sample of these contractors indicates that all of them were likely not qualified to be contractors. If the IRS finds the District to have hired contractors inappropriately, it will require payment of back payroll taxes as well as fines. Litigation of personnel matters is also likely to add to district legal costs.
The Fair Political Practices Commission has recently imposed a fine of $100,000 for the College�s failure to file required annual conflict of interest statements for its employees and consultants for the last 20 years.
Finally, the College has Title IV, Title III and other federal funds. Given that the College has been using all of its cash for operating expenses, it is likely that the College is out of compliance with federal and other regulations regarding the use of categorical funds. Program audits of categorical funds are likely to identify further fiscal liabilities for the College. (Eligibility Requirement 17, Standard III D. Preamble, and D.2.a., d and e.)
The Board itself pursues benefits that have a negative fiscal impact on Compton Community College. (Standard IV B.1.a., b., c., d. and e.) The Board has contracted with five different attorneys, and uses their services at will, allegedly without the approval or participation of the President. These contracts cost money. The District purchased five vehicles that were primarily for use by Board members. The Los Angeles Times reported last year that those vehicles were being used for personal business rather than exclusively for college business. One of those vehicles was involved in an accident while driven by a relative of a Board member, and there is pending litigation against the District as a result.
The Board hired a personal assistant for each Board member, and for some time employed those assistants up to 40 hours per week. The Board has used College credit cards for non-business expenses and reimbursed the College much later. The Board has used the new college bus (a luxury cruiser, not a �school bus�) for non-educational purposes, namely for trips to Las Vegas that appear to have been for raising funds for political purposes of Board members. These kinds of expenditures are relatively unusual for a small, public college in the WASC region. The expenditures are extraordinary considering the College has not been able to close its books, to have an unqualified audit, or maintain a reserve over the last several years. The expenditures signal the lack of connection between expenditure decisions and any realistic assessment of District financial resources as well as a Board failure to ensure the integrity and fiscal stability of the institution. (Standard III D. Preamble, and D.1.b, and 2. a., c., d., and e., and Standard IV B.1.)
The College�s contracting practices do not meet accreditation standards. In the set-up and delivery of several off-campus educational programs, the College has engendered Board conflict of interest, lost control over its educational programs, and made financial arrangements detrimental to the college�s well-being. (Standard II A.1. and 2., and Standard III D.2.e. and f.) The College has set up several off-campus �educational programs� at community sites in its service areas. According to statements of college staff, some of these programs were directed by Board interests (their stated rationale being to reach underserved communities) and were designed to channel College funds to the community entities. The College contract with some of the sites provided fifty percent of the FTES-generated revenues that the College earned be redirected to the community agencies or individuals responsible for recruiting students to the sites. In all cases, this was bad financial management, as Compton Community College used those off-campus sites to generate FTES to meet its state funding cap. The revenues generated from those sites were needed to fund basic campus operations. In at least one case, the checks sent to the community agency have actually been paid to a (former) Board member in a corrupt scheme to defraud the College. College faculty have reported that some of the programs did not go through the college curriculum and design process.
Individual board members have been involved in negotiating with prospective contractors, undermining the College�s bidding process and creating a conflict of interest for the Board in their role as decision makers on district contracts. (Standard III D.2.f., and Standard IV B.1.) In one case a Board assistant made a presentation to the Board on behalf of one vendor. Poorly conceived and executed contracts for construction and for technology, as noted in the FCMAT Report, have left the district with an inadequate and incomplete infrastructure. The Board has not pursued legal actions to resolve contractor deficiencies in the College�s favor, despite being advised to do so by the Superintendent and a construction attorney hired by the president. In the case of the new Math/Science and Vocational Technology buildings, the Board followed the advise of a program manager rather than the college president and settled a case by paying a contractor $1.8 million additional monies for incomplete work. Last year, the College purchased and was in the process of installing computers before the Board approved the purchase contract.
The College appears to lack the staff expertise to efficiently manage its fiscal operations. (Standard III A. Preamble and A.1.) The Business Officer/Chief Financial Officer position over the last ten years has only been intermittently filled by a permanent employee. Rather, the District has more regularly used a �temporary� Business Officer with long affiliation with the District. The team was informed by several individuals that this individual works directly with the Board, around the President. (Standard IV B.1.j., B.2.a., c. and d.) This unethical behavior by this individual as well as the Executive Vice President is not sanctioned by the College, but appears to be an ingrained part of college culture and practice. The College does not have or enforce a written code of professional ethics for all of its personnel. (Standard III A.1.d.) The Board has not developed and used a code of current ethics to guide its own behavior, and clearly does not adhere to the standards that require the Board to delegate operational matters to the College President and allow him to administer and implement Board policy without interference. (Standard IV B.1.j.)
Some persons interviewed indicated that the Board has historically rejected the President�s recommendations for individuals to fill the permanent position in order to retain the temporary Business Officer. The President and others report that when the District hired, for a brief time, an experienced higher education business officer, he tried to lead the College through a fiscal planning and budgeting process. In that process, he advocated for stricter fiscal controls and more realistic budget planning. It is said that the Board acted to terminate this individual. (Standard III D.2.g.) The Board�s own use of College resources, including those resources that have a direct impact on the institutions� fiscal integrity and stability, suggest that the Board has had an inappropriate interest in keeping the College�s fiscal management weak and therefore responsive to Board desires to use the College�s resources for their own purposes.
The College�s technology systems do not provide effective support for sound fiscal management. The College purchased software called �Protocol� for budgeting purposes. The Protocol software vendor has not provided the technical assistance necessary to train College staff, and the staff lacks the necessary training for the College to get it to work properly. The Business Officer abandoned use of the financial module after staff was trained. The Protocol software does not have functioning components to manage personnel/human resources data or student data. (Standard III C. Preamble and C 1.a., b., c. and d.) The College uses a Legacy VAX system to keep track of personnel. The College payroll is handled through Los Angeles County Board of Education, which uses PeopleSoft software. The problems associated with multiple, incompatible software systems are compounded by the lack of a position control system at the College, and there is only an untimely, manual connection between decisions to hire individuals and assignment of a budget line item to pay for their salaries. (Standard III A.6., III D.1.c., and III D.2.) Thus, people are hired without a prior budget allocation to pay them. Individuals may be paid with the revolving funds until the College takes the necessary steps to place them on the payroll. The College is effectively unable to keep payroll costs within budget, or at times to even know what they will really be.
A FCMAT analysis of staff skills in the Business Office indicates that many staff lack basic knowledge of accounting practices. Some staff keep manual books because they cannot use the computerized accounting system. The College accounts, when reviewed by the assistant to the Business Officer during the State Trustee�s first months at the College, required hundreds of corrections. The College has not conducted adequate training to keep staff skills current (Standard III A.5), and its several incompatible accounting systems create redundancies and increased risk of errors and misuse of funds.
The Chief Business Officer (temporary) has failed to ensure that three audits were completed, and that the College developed a realistic budget for the next ensuing fiscal year. The College account is kept with the Los Angeles County Board of Education, which monitors total fund balances only. Lacking knowledge of accounting principles and lacking accurate electronic data on budget balance, the College has, over the last few years, been issuing checks when the General Fund balance in the college account was negative. Thus, as the College went negative in its General Fund, it automatically was borrowing from its other funds. FCMAT reported in June 2004 that every College fund except its Bond fund was negative.
Conclusions
Compton Community College is out of compliance with all of Standard III D, Financial Resources, and with Eligibility Requirements 17 and 18. It is also out of compliance with portions of Standard IV which refer to the roles and responsibilities of governing boards and college presidents, including Standard IV B.1, a. through c., e., and j., and with portions of Standard III A, Human Resources and Standard III C, Technology Resources.
Recommendations
The Team recommends that:
Human Resources and Personnel Practices (Standard III A)
Compton College has significant numbers of serious problems with its Personnel system that place it out of compliance with Commission standards and which create financial costs and liabilities for the District. It is out of compliance with all of the general principles contained in the introduction or Preamble to Standard III.A., Human Resources:
The institution employs qualified personnel to support student learning programs and services wherever offered and by whatever means delivered, and to improve institutional effectiveness. Personnel are treated equitably, are evaluated regularly and systematically, and are provided opportunities for professional development. Consistent with its mission, the institution demonstrates its commitment to the significant educational role played by persons of diverse backgrounds by making positive efforts to encourage such diversity. Human resource planning is integrated with institutional planning.
Foremost among team concerns is the institutional practice of employing persons outside of college personnel procedures. The College has hired employees by going around its own hiring policies and practices, and it has hired a very large number of consultants whose work and working conditions do not meet the requirements of the IRS laws for consultants�thus these individuals are likely more evidence of the College practice of hiring around its own policies and procedures.
Compton Community College uses a Personnel Commission to advertise and recruit pools of eligible candidates for classified positions at the College. The Commission is also responsible for testing applicants, setting the interview process, and ranking the final applicants. Hiring policies require that individuals be hired (or offered the job) in the rank order that their name appears on the Personnel Commission list.
Several staff reported that the college routinely hires friends and associates of trustees. Some staff indicated that the Executive Vice President has ordered employees to assign to work individuals that were hired outside of the routine personnel process. One staff member indicated that new �employees� hired by this senior administrator would �appear� for assignment in his work unit although the unit had not requisitioned a new employee or sought to fill a vacancy. The team heard reports of individuals hired outside of the formal hiring policy being placed in jobs without training, endangering themselves and others. College staff informed the team that the College�s TANF and CARE programs were used as a source of job placement for �special friends� of a board member since hiring for those programs falls outside the Personnel Commission procedures.
The State Trustee documented that the College hired 170 �independent contractors� over the 2003-04 fiscal year, and that an audit revealed that the entire sample of positions audited did not meet IRS rules for independent contractors. (Standard III A. Preamble, A.3. and 4.) This contracting has created a financial liability for the District described elsewhere in this report.
The State Trustee informed the team that many of the employees in the Business Office are provisional employees who have worked far beyond the limit of their permitted term. (Standard III A.2., 3., 4., 5., and 6.) Minutes of meetings of the Board of Trustees in which college staff are complaining to the Board about the excessive use of provisional employees, confirm the practice of using �temporary� staff for extensive periods without filling the permanent vacancy through established hiring procedures. The Business Officer position described earlier in this report is one of these positions. FCMAT auditors informed the team that there is only one employee with accounting training and experience in the fiscal operations, but there are up to 11 individuals with �accounting duties.� The College does not ensure that its personnel are qualified by appropriate education and experience (Standard III A.1.) and the College has not provided sufficient professional development to upgrade employee skills (Standard III A.5.) The individual in charge of Risk Management is a lower level �Confidential� employee; this work is usually assigned to supervisory level employees in other colleges in the region, and the skills necessary to perform the functions of Risk Management are not contained in the skills required of confidential employee classification.
College documents that contain hiring policies or describe duties and responsibilities of employee groups are generally outdated. The Team reviewed a Faculty Handbook unrevised since August 1994, an Employee�s Personnel Policy and Procedure Manual published in May 1994, and Management Hiring Policy published in 1992. A Staff Diversity Handbook was in draft condition at the time of the Team visit, but no previous edition was in evidence. (Standard III A.3.) Staff at all levels reported that the college does not follow policy to implement staff evaluations on a regular basis and according to policy. The faculty indicated that faculty evaluations are not provided regularly to tenured faculty and that they have no input into administrative evaluations. Much of the faculty evaluation process is described in the collective bargaining agreement, but the agreement leaves out the criteria for evaluation. Administrators reported they are not routinely evaluated. One administrator showed the team a self-evaluation the administrator prepared in hopes of eliciting an evaluation from the supervisor; none was forthcoming. The President told the team that the Board has not completed his last evaluation and did not conduct regular evaluations over the past several years. (Standard III A.1. b. and c.) The FCMAT Report states that the college�s job descriptions are seriously outdated at all levels of the organization, that minimum qualifications statements are inadequate for the positions, and that the College has inadequate practices for ensuring established equivalencies for education and experience of job applicants result in qualified applicants being forwarded for interview. Many of the job incumbents lack sufficient skill to do their jobs effectively. (Standard III A. 2.) The Report also states that the College does not have adequate criminal background checks and has not acted to relieve employees who were found to have lied about their criminal histories on their applications. In one case, an employee who used a fraudulent degree on an employment application has not been disciplined. (Standard III A.1. a. and d.)
According to several college staff, the Personnel Commission has exceeded its authority and responsibility by maintaining college personnel records for employees. The Team was informed that the Commission has employee service records and evaluation and disciplinary records in its offices, and that, in the interest of �preserving� them, has refused to turn them over to the Human Resources department. The Team�s interview with the Executive of the Personnel Commission confirmed tensions between the Commission and Human Resources. (Standard III A.3.a. and b.) The College is not following its own policies as they pertain to the selection and seating of members of the Personnel Commission. At the time of the Team visit, a new Commissioner appointed by the union was seated despite the fact that his selection was not approved by the Board of Trustees, as required.
Finally, the Team must note that there is evidence of poor morale and a climate of fear and intimidation at the College, and that the control of the Executive Vice President over personnel functions is one of the mechanisms through which illicit use of the personnel system and intimidation are exercised. Some employees indicated they feared for their physical well-being if it was revealed what they said to the team. Some employees stated that employees are assigned to a graphics program located at the back of the warehouse as punishment for failing to follow the directives of senior administration even when their skills are not appropriate to a job in graphics. (Standard III A.4)
Conclusions
Compton Community College is seriously out of compliance with most of Standards III.A. The College personnel practices appear to be negatively affected by incompetence in the Personnel office, politicizing of personnel practices by the Board of Trustees and the Executive Vice President, and an inability or unwillingness to follow existing personnel policies.
Recommendations
The Team recommends that:
7. The College should review all job descriptions and revise them to ensure that they represent current skill sets needed to fulfill the duties and responsibilities assigned to each position
8. The College should develop criteria for selection and retention of personnel, and that it hire new employees and review the qualifications of current employees to ensure that they are qualified by education, training, and experience to adequately support the college.
9. The College should conduct personnel evaluations on a regular basis, and demonstrate that it has used these to improve performance. Evaluations for all individuals who are responsible for student learning outcomes should have as a component of their evaluation effectiveness in producing those outcomes.
10. The College should establish and implement a written code of ethics for all personnel, and establish, in policy, how violations of the code will be effectively addressed.
11. The College should review its current personnel policies to determine whether they are equitable, adjust them as needed, and administer them in a fair and equitable manner.
12. The College should address its confused and top heavy administrative structure and develop appropriate titles and job descriptions that are based on institutional needs, not on personal qualifications, traits, or histories of incumbents.
13. The College should establish a program for staff and professional development to ensure employees develop and retain skills necessary to support educational and institutional quality at the College.
Leadership and Governance (Standard IV)
The governance structure and practices of Compton Community College reflect the very real diversion of the institution from its mission of providing quality education for its community to its use as a resource for Board members, employees, contractors and vendors. The College cannot be said to have ethical and effective leadership that is focused on institutional values that place student learning at the center of its operation. (Standard IV. A. all) The daily involvement of the Board of Trustees in administrative functions creates an undermining of the Superintendent/President�s authority and role and threatens the job security of those administrators who do not take the Board�s direction as communicated by Board members or the Executive Vice President.
The administrative organization of the College is confused and dysfunctional. The College has a large number of administrative staff, many of who have the word �executive� added to their job title (Such as executive dean), some of whom are �y� rated at salaries that are above the salary scale, whose reporting structure is overlapping. Some report to multiple bosses. This proliferation of positions and titles, and the confounded reporting structures (both formal and informal) suggest the administrative structure represents the particular strengths or weaknesses of employees rather than a conscious and rational attempt to create an effective administrative structure that advances the educational mission and organizational effectiveness of the college. (Standard IV B.2, all.)
The President�s role, as described by Standard IV A.1. and IV B.2, a. through e., is simply not fulfilled in a manner that meets the standard. Many issues discussed in this Team Report attest to the fact that the President has been disempowered or has failed to assume responsibility for college operations that are rightfully controlled by the college chief executive. The President�s presentation of self is as somewhat of a �victim� of college politics, and to that end, the President has failed to consistently exercise his voice or his professional judgment in the best interests of the College and its mission.
The confusion over the role of the Superintendent/President, and over his responsibility and authority, originates in the District�s decision to hire a Deputy Superintendent/Executive Vice President and to assign to that position many of the important functions of the college while at the same time assigning to the Superintendent/President few specific responsibilities. The team reviewed the employment contracts for the two positions and found them to be very similar, with the exception that in some cases where the President reports to the Board, the Deputy Superintendent reports to the President. Both have similar benefits and retreat rights to an administrative post if their contracts are not renewed. However, they differ largely on the responsibilities assigned to the positions in item five of the contracts. The Superintendent/ President�s specific job duties, identified in item five of his contract, include the following short list: �the President shall be the Chief Executive Officer and Secretary of the Board of Trustees. As such the President shall have the primary responsibility for implementing and executing District policy. �
The Deputy Superintendent/Executive Vice President�s contract gives him specific areas of control in item number five, as follows:
�The Deputy Superintendent shall have specific responsibility for the Office of Institutional Development, Police, Maintenance and Operations, the Library, Nursing, Institutional Research and Public Information, and shall supervise the generation of grant proposals and private sector solicitations, supervise the foundation and alumni activities, and manage other offices and functions of the District as may be directed by the Superintendent/President, including Academic Affairs, Student Affairs, Evening/Extended Affairs and Special Projects.�
Staff of the College state that the Deputy Superintendent is often referred to as the �internal president.� The description of job duties appears to confirm their perception that the Deputy Superintendent has been given responsibility for most of the College operations. That leaves little for the Superintendent/President to control, particularly because the Deputy Superintendent�s responsibilities are defined by contract, not delegated and controlled by the Superintendent/President. (Standard IV.B.2 and .a.) Although the College has a formal decision making structure, administrators, faculty and staff indicate that the established governance structure is not followed, that decisions are made among a limited group of individuals and announced to the College ex post facto. The College faculty voted no confidence in the President twice in the last few years. (Standard IV A. 1 and 3.)
The College has not complied with the policies and standards of the Commission since the last comprehensive accreditation visit and has demonstrated, through its communications with the Commission at the time of the last comprehensive visit, an unwillingness to accept the recommendations and observations provided through the peer review process, to its own detriment. (Standard IV A.4.)
The Board of Trustees is a key source of problems that riddle the college governance processes. As documented in the discussions of Board interference in personnel decisions and fiscal management, and in the Board�s use of college resources, and pattern of working around the authority of the college President described elsewhere in this report, the College does not have a governing board that assumes its responsibility for establishing policy to ensure the quality, integrity and effectiveness of student learning programs and services and the financial stability of the institution. (Standard IV B.1.)
Rather than protecting the institution from undue influence, the Board has on too many occasions facilitated the exercise of undue influence on the College. (Standard IV B.1.a.). The Board has required that its personal associates be hired, has participated in fraud with regard to off-campus community based programs, and exercised undue influence on behalf of vendors bidding on contracts. The Board does not have an effective program for Board development, nor does it have an up to date Code of Ethics or enforce its old Code. The Board has failed to fully and carefully evaluate itself through a reasonably designed and useful evaluation process. The Board�s self evaluation instrument presumes the Board knows and adheres to its role as a policy making entity, and assumes that the Board members can honestly evaluate their own behavior. The Board�s relatively weak ethics policy does not include a conflict of interest statement, and the policy does not establish a means for the Board to take action when individuals violate the policy. (Standards IV B.1.a., b., c., d., e., f., g., and h.) The Board should seek input in addition to its own self perception to the annual Board review and conduct the review each year. The Board is strongly advised to seek assistance from an outside entity such as the Association of Governing Boards in conducting annual performance review of the Board that provides realistic assessment of Board conduct.
The Board has made an egregious lapse with respect to Standard IV B.1.j, which requires the Board to �delegate full responsibility� to the President to implement and administer board policies without board interference and to hold him accountable for the operation of the College. The reasons for this Team conclusion have been documented throughout this report and are summarized below.
Many of the college staff interviewed spoke of the Board�s tendency to become involved excessively and improperly in personnel decisions. Board-favored employees have the ability to corrupt the entire personnel structure of the College. They cannot be held accountable for their work, and they can exert pressures on other employees to do the Board�s bidding. They can also provide the Board with direct leverage on college operations around the authority of the President.
Many staff identified specific instances in which they claimed the Board�s favored individuals were provided jobs without going through the Personnel Commission process. The climate of suspicion and mistrust of the Board is extensive. Some staff indicated that it is rumored that the Board accepts cash payments or other favors in return for approving items placed on the Board agenda for consideration and action. Several employees told this team that it has become relatively routine for staff to work directly with Board members in order to get their items approved or even considered by the Board. Some staff report that they had to exchange favors with Board members to get their items on the agenda. In interviews with this team, the President stated that he has been unable to control or function effectively with the Board. He acknowledged that the significant number of responsibilities assigned formally to the Executive Vice President make that individual the Board�s chief contact for much of their interference in college administration and management.
The Board contributes to perceptions that it is operating at other than the policy level by the way it conducts Board business. It has an established practice of adjourning scheduled board meetings and calling special board meetings to deal with the agenda items postponed by the adjournment. Between January 1 and July 1, 2004, there were twelve scheduled board meetings (two per month as called for in policy). The Board also conducted seven special board meetings caused by failure to complete, or the adjournment of, scheduled board meetings. This team�s review of agenda items and minutes of these special meetings indicate they often dealt with contracts and purchases. The adjournment and reconvening of Board meetings to deal with necessary decisions about contracts and vendors has the impact of reducing participation and attendance of the public that may have come to scheduled meetings, as well as other vendors, college staff and campus leadership, for the purpose of providing input. (Standard IV B.1.a., b., c., and e.)
The College staff and FCMAT members told the team of numerous occasions in which the Board of Trustees created a Board agenda independently of the President and informed him very late, cancelled scheduled Board meetings and rescheduled them, and convened closed sessions of the Board of Trustees without the President�s involvement. By setting alternative agendas, the Board is able to delay items the staff may have placed on the agenda, and to delay implementation of college plans and activities. By removing themselves to closed session, the Board is able to meet to discuss college business without the President available, contributing to Board involvement in management of the College.
The Board has, as described elsewhere in this report, also neglected to provide fiduciary oversight of the financial management and condition of Compton Community College. Two years of qualified audit reports remained unaddressed at the time of the Team visit, and the college had a planned budget in which expenditures exceeded revenues. The Board has either failed to understand or has ignored for its own benefits external and internal documents pertaining to the college�s fiscal condition. This violates a very basic Board responsibility as described in Eligibility Requirement # 3, as well as in Standards IV B.1., and 1.c.
Conclusions
Compton College has severe problems in the area of Leadership and Governance and is out of compliance with all of Standard IV. This failure of leadership and governance can be attributed largely to the misconduct of the Board of Trustees, the confused administrative structure promulgated by the Board in designing the job descriptions for Superintendent/President and Deputy Superintendent/Executive Vice President, and by the Colleges� creation of an administrative structure in which titles and responsibilities developed for individual employees proliferate and logical division of labor and delegation of responsibilities is absent. The absence of a working collegial governance system has harmed the academic quality of the college as well as its fiscal health and stability. Recommendations
The Team recommends that:
14. The college should review and revise its entire governance process to ensure that appropriate and significant voice is provided to administrators and faculty on matters of academic significance, and that budgetary and other resource use decisions be made through a sound governance and decision making process. 15. The Board of Trustees should take immediate action to curtail its behavior pattern of working directly with college staff, vendors, and consultants and delegate to the President the full responsibility for administration and implementation of policy. 16. The Board of Trustees should review and revise its Ethics Policy to make it an effective guide to Board behavior, and to include a new Conflict of Interest Statement, and a process for addressing behavior that violates its revised ethics policy. 17. The Board of Trustees should develop and immediately implement an ongoing training schedule that will provide the Board with the skills to adhere to a governance process that recognizes the roles of the Board, the college administration including the president, and the faculty and staff, and that enables them to recognize and carry out their fiduciary responsibilities to the Compton Community College District. The American Association of Community College Trustees, the ACCJC, and the Association of Governing Boards should be used to provide initial training to the trustees on the basic skills and principles of boardsmanship.
18. The Board should seek immediate training to enable it to understand basic financial documents such as the college budget, the external audit, and the chief financial policies and requirements of the California Community College system in order to facilitate the Board�s assumption of its appropriate role of providing for the fiscal integrity and well being of the College. 19. The governing board, administrators, faculty, and staff should demonstrate that they are working for the good of the institution and its students by developing and implementing sound governance policies and procedures that build on employee ethics statements, sound research and analysis of institutional and student needs, and that promote the educational mission of the college.
20. The Board should design and implement an annual evaluation of the Board and its performance that is holistic and includes meaningful input by board members, college leadership and members of the public. In consultation with the President, the Board should develop an annual plan for Board development that educates current and new Board members. 21. The District should immediately review and revise its policies, organizational charts and executive contracts to create and implement a job description that gives to the President the responsibilities for all operations of the college. 22. That a strengthened presidency create an organizational structure that is planned and staffed to reflect the College�s needs for expertise and leadership in administration, including human resources and financial management; in academic matters, including instructional, student support services and learning resources: and in physical facilities management, including physical plant construction and maintenance and technological equipment support and maintenance.
23. That the newly trained Board reaffirm its delegation of administrative responsibility to the College President, and that it complete annual evaluations of the College President according to policy.
Technology (Standard 111 C)
Compton Community College�s technological resources are insufficient to support student learning and services. (Standard III C. all.) Some of the details of difficulties with its business services and personnel information systems are described earlier in this report. The Board practice of negotiating directly with vendors and making a selection based on such private negotiations has added to difficulties with technology on campus. But, there are additional difficulties with technology on campus that demonstrate the college lacks the staff expertise and procedures to ensure that technology resources are used to support student learning programs and services and to improve institutional effectiveness. (Standard III C. all)
When the Special Visit Team was preparing for the visit, it was unable to use e-mail to effectively communicate with campus personnel because the e-mail system was not functioning. The Team�s messages went unanswered, probably because the e-mail system was not operating properly. The State Trustee told the Team that upon his arrival at the College, he found the e-mail system running at 100% and yet unable to handle incoming e-mail; it was probably being used by a hacker that had captured its capacity. The State Trustee has since ensured the security of the campus e-mail system, and it is functioning again.
Student services such as registration and enrollment are not adequately supported by technology to a basic level common among other public colleges in the state. The student services functions of Protocol do not ensure the integrity of student data. Students are not able to register and enroll for classes via the internet, a function that is fairly common now in other California public colleges, and that would benefit Compton�s students. Students cannot gain ready access to their own class schedules or records of classes previously taken. Registration is still a largely manual, drawn-out process.
The College is still in the process of setting up computers that it purchased for faculty last year. The College has not provided sufficient support for its staff to learn and use the existing technology on campus. The team learned that many faculty do not know how to use e-mail, the business office staff are unable to use the accounting software purchased for fiscal management purposes, the use of educational technology for instructional purposes is very limited, the College�s web page has not been kept current, and there was no effective plan for the distribution of technological resources in a manner integrated with educational planning.
Conclusions
Compton College�s technological infrastructure does not currently meet the accreditation requirement that it support student learning programs and effective operation of the institution. The College lacks a fully functioning student data system, adequate accounting systems, and an adequate web page. Its faculty are still, in some cases, learning to use desktop computers that have been purchased many months ago. The College has not had adequate administrative oversight to ensure that its information systems function, or that decisions to purchase new hardware are adequately researched prior to issuance of the RFP. The College�s purchasing process has been contaminated by a poor bidding process and Board of Trustees interference.
Recommendations
The Team recommends that:
24. The College should conduct an assessment of its current technological capacity and challenges and review this assessment in a manner that includes broad-based campus interests from instruction, student services, administrative and fiscal services including business and personnel services, and library and learning resources. Because the institution�s staff may lack the capacity to envision how technology can be used to enhance institutional effectiveness, it is recommended the college use consultant expertise to conduct this review and planning process. 25. The College should ensure that it has technical staff with sufficient expertise to direct the use of its information technology systems, and establish appropriate administrative oversight of the technical functions of the college to ensure that they operate to support its organizational and educational effectiveness. 26. The College should resolve the issue of its multiple and incompatible information systems and obtain or implement technological components that allow it to effectively manage administrative (especially fiscal and human resources) and educational programs of the College. 27. The College should develop procedures for contracting and purchasing hardware and software that ensure the integrity of the institution and the efficacy of products and services purchased.
Research, Planning and Institutional Effectiveness (Standard I.B.) The Special Visit Team found that Compton College lacks the rudimentary elements of an ongoing research, evaluation, planning and improvement cycle that allows the college to accurately assess its own effectiveness and make improvements. The college research office has gathered into table format much �environmental� data on high school graduates, service area population characteristics (from the Census) and some labor market data but has very limited, if any, ability to analyze college data on students. The team was presented with a draft set of tables that were being prepared for the Self Study review. The tables listed expected student achievement variables but had no data in them. The institutional research office informed the team that the College cannot get the data from its own records systems without special programming, which the research office cannot do. The student data system deficiencies are one reason this data is inaccessible. In addition, it appears that the research offices� data needs are a low priority to the individuals who can access the data. Both the researcher and the programmers report to the Deputy Superintendent/Executive Vice President, who is given responsibility for research in his employment contract. (Standard I.B. Preamble)
Faculty state that there is no real institutional planning that occurs at the College. While some faculty have designed and are beginning to implement a new program review model, the lack of institutional data and analyses result in program reviews that reflect faculty perspective, not student achievement. The Deputy Superintendent provided the Special Visit Team with blue binders that contained the 2004-06 Strategic Plan; these were dated July 2004. They appear to have been produced just in time for the Team visit. However, faculty indicated that the �blue books� were simply the previous year�s plans recycled and that planning is a process that is orchestrated �top-down� and does not reflect real input by all academic and other units. A review of the blue books found that in one program, hand-written notes appear to have been added from a meeting held in Spring 2004. The faculty who took those notes stated that s/he did not intend them to substitute for a program plan, but that they were added to the blue book by someone �above� to make it appear that there was faculty input. Regardless of the origins of the July 2004 �Plan,� interviews with staff on campus suggest few believe the plan is valid or is even used to guide institutional decision-making. (Standard I.B.3. and 4.)
When asked about whether there is an ongoing campus dialogue about institutional quality and enhancement of student learning, all respondents said �no.� While some faculty have been trying to implement a new program review model that incorporates defined student leaning outcomes for the program, they stated that their materials are not given consideration by the wider college community and do not end up playing a role in institutional decisions regarding resource distribution.
Recommendations
The Team recommends that:
28. The College should establish a functioning research office with access to student and other institutional data records and with capacity (human and technological) to establish ongoing institutional effectiveness studies.
29. The College should establish a sound program review model and process based on data and analyses of student achievement and student learning, and that it establish and implement an immediate schedule to conduct program review on all academic and student support programs in the next two years.
30. The College should establish, document, publish and implement an institutional evaluation, planning, resources allocation and improvement model that will meet Commission standards. This model should be evaluated at the end of its first full cycle and annually thereafter to ensure that it is effective in improving educational programs.
Team Summary
Compton Community College is significantly out of compliance with major Commission standards, and its administrative, governance and fiscal difficulties are so severe as to threaten the College�s continued operation. The College�s educational quality and integrity have been severely compromised. The College is in such a state of administrative chaos that there is presently no real academic leadership to help the College address its educational deficiencies. The State Trustee assigned to the College has the authority to overrule Board decisions, but absent a significant change in the College�s Board behavior, administrative capacity, and overall staff ability to pull together, the Trustee faces an uphill battle trying to recreate the college as a sound institution. The team believes this College may not survive without a collective effort on the part of all employees to discard old patterns of behavior and conform to principles of good practice contained in the Standards of Accreditation.
Summative Team Recommendations to the Commission
Compton Community College is scheduled for a comprehensive review in the Spring of 2005. The College has discussed a request to delay its comprehensive review until it can resolve some of its fiscal and leadership problems and has sent a letter requesting same.
The Special Visit Team recommends that the Commission composes the next comprehensive review team to provide a very thorough review of the College�s educational programs and services, and that the Commission requires the College to demonstrate that it has met all FCMAT recommendations as well as Special Visit Team recommendations at the time of its next comprehensive review.
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