HUM 106 – Assignments and RubricsCOURSE DESCRIPTIONDiscuss

HUM 106 – Assignments and Rubrics
COURSE DESCRIPTION
Discusses aesthetic theory and provides critical analysis of
examples from modern art in poetry, painting and music. Also
discusses the arts of photography, dance, architecture,
sculpture, theater, and film.
INSTRUCTIONAL MATERIALS
Required Resources
1. Sam Hunter. 2005. Modern art 3rd ed. Pearson. HUM106
textbook.
Supplemental Resources
1. Museum of Contemporary Art Chicago. No date.
https://mcachicago.org/Home
2. Museum of Contemporary Art Sydney Australia. 2004.
http://www.mca.com.au/
3. San Francisco Museum of Modern Art. 2011.
http://www.sfmoma.org/
4. Tate Modern. No date. http://www.tate.org.uk/modern/
5. The Museum of Modern Art. 2011.http://www.moma.org/
COURSE LEARNING OUTCOMES
1. Discuss the value of visual art for an individual and society.
2. Analyze the essential relationship between any work of art
and the various kinds of influences on the artist and audience
that shape the interpretation of the art.
3. Compare and contrast artists and their works in the context of
their styles and their historical periods, while distinguishing
their styles one another and using the proper terminology.
4. Explain the formal elements of various styles of modern art
both in general and in specific works.
5. Describe the relationship between individual artistic
expression and the cultural, social, political, and historical

forces which give rise to these expressions.
6. Summarize the diverse artistic trends in modern art in
designated time periods.
7. Classify key artists and styles in the visual arts from the
Impressionist period to the present.
8. Explain the cultural and stylistic developments in modern
arts.
9. Analyze the diversity of opinions and perspectives about art,
artistic styles, and developments.
10. Summarize significant contributions in modern art from
women, ethnic minorities, non-western cultures and in various
time periods.
11. Explain various terms, qualities, and themes of visual art
from the late 1800s to the present.
12. Use technology and information resources to research issues
in modern art.
13. Write clearly and concisely about modern art, using proper
writing mechanics.
WEEKLY COURSE SCHEDULE
The standard requirement for a 4.5 credit hour course is for
students to spend 13.5 hours in weekly work. This includes
preparation, activities, and evaluation regardless of delivery
mode.
Week
Preparation, Activities, and Evaluation
Points
1
Preparation
· Reading(s)
· Chapter 1: Modernism and Its Origins in the 19th Century
· Chapter 2: Seurat, Cezanne, and the Language of Structure
Activities
· Discussions
Evaluation
· None

20
2
Preparation
· Reading(s)
· Chapter 3: Gauguin, van Gogh, and the Language of Vision
· Chapter 4: Art Nouveau in Painting and Design
· e-Activity
· Visit one of these Art Nouveau Websites and explore the
history, styles, and works of representative Art Nouveau artists
highlighted. Be prepared to discuss.
· National Gallery of Art “Anatomy of an Exhibition,” located
at http://www.nga.gov/feature/nouvea u/exhibit_city.shtm
· Art Nouveau, located at
http://en.wikipedia.org/wiki/Art_Nouveau
· Art Lex, located at
http://www.artlex.com/ArtLex/a/artnouveau.html
Activities
· Discussions
Evaluation
· Reflective Journal 1: My Experience with Art

20
40
3
Preparation
· Reading(s)
· Chapter 5: Early Modern Sculpture: From Rodin to Brancusi
· Chapter 6: Tradition and Innovation in Architecture: 1880 -
1914
· e-Activity
· Visit the Great Buildings Website, located at
http://www.greatbuildings.com/architects/Frank_Lloyd_Wright.
html, and view five of the buildings (different from the ones in
the text) designed by Frank Lloyd Wright. Be prepared to
discuss. (Note: If this site is not available, locate another
Website that shows Frank Lloyd Wright’s buildings.)
Activities
· Discussions
Evaluation
· Assignment 1: The Critic’s Choice
20

120
4
Preparation
· Reading(s)
· Chapter 7: Expressionism in France: Matisse and the Fauves
· Chapter 8: Expressionism in Germany: The Bridge and the
Blue Rider
Activities
· Discussions
Evaluation
· Reflective Journal 2: Social Influences on Artists
20
40
5
Preparation
· Reading(s)
· Chapter 9: The Cubist Revolution: Braque and Picasso
· Chapter 10: From Cubism to Abstract Art: Futurism,
Suprematism, De Stijl
Activities
· Discussions
Evaluation
· Reflective Journal 3: Proposed Cultural Event
Note: If you believe that you have a legitimate reason for
attending a “virtual” activity, you must contact the instructor no
later than Week 5 for your request to be considered.

20
40
6
Preparation
· Reading(s)
· Chapter 11: Dada and Fantastic Art
· Chapter 12: Surrealism: The Resolution of Dream and Reality
· Chapter 13: The Shaping of the New Architecture: 1918-40
Activities
· Discussions
Evaluation
· Assignment 2: My Work – My Vision
30
140
7
Preparation
· Reading(s)
· Chapter 14: The School of Paris Between the Wars
· Chapter 15: International Abstraction: Constructivism and the
Brauhaus
· Chapter 16: American Art in the Wake of the Armory Show
Activities
· Discussions
Evaluation

· Reflective Journal 4: Art in Everyday Life
30
40
8
Preparation
· Reading(s)
· Chapter 17: The New York School: Abstract Expressionism
· Chapter 18: The Postwar European School: L′Art Informel,
Expressionist Figuration, Welded Sculpture
· Chapter 19: American Art of the Sixties: Pop Art and
Minimalism
Activities
· Discussions
Evaluation
· Assignment 3: My Personal Artwork or Discovery
30
110
9
Preparation
· Reading(s)
· Chapter 20: Europe’s New Realism, Pop Art, and Abstraction

· Chapter 21: The Diffusion of the New Architecture: 1954-75
· Chapter 22: The Post-Minimal/Post-Modern Seventies: From
Conceptual Art to New Image
· e-Activity
· Go to the Sydney Opera House Website, located at
http://www.sydneyoperahouse.com/About/Venues.aspx. Select
and review the information and pictures found in these three
areas: Building Program, History & Heritage, and Venues. Be
prepared to discuss.
Activities
· Discussions
Evaluation
· None
30
10
Preparation
· Reading(s)
· Chapter 23: The Post-Modern Eighties: From Neo-
Expressionism to Neo-Conceptualism
· Chapter 24: A New Fin de Siecle / A New Century
· Chapter 25: Post- and Neo-Modernism in Architecture
Activities
· Discussions
Evaluation

· Assignment 4: Impressions of Museum or Gallery Exhibit
30
200
11
Preparation
· Reading(s): None
Activities
· Discussions
Evaluation
· None
20
GRADING SCALE – UNDERGRADUATE
Assignment
Total Points
% of
Grade
Assignment 1: The Critic’s Choice
120
12%
Assignment 2: My Work – My Vision
140
14%
Assignment 3: My Personal Artwork or Discovery
110

11%
Assignment 4: Impressions of Museum or Gallery Exhibit
200
20%
Reflective Journals (4 journals worth 40 points apiece)
160
16%
Participation (27 discussions worth 10 points apiece)
270
27%
Totals
1,000
100%
Points
Percentage
Grade
900 – 1,000
90% – 100%
A
800 – 899
80% – 89%
B
700 – 799
70% – 79%
C
600 – 699
60% – 69%
D
Below 600
Below 60%
F

HUM 106 – Experience of Modern Art
©2019 Strayer University. All Rights Reserved. This document
contains Strayer University Confidential and Proprietary
information and may not be copied, further distributed, or
otherwise disclosed in whole or in part, without the expressed
written permission of Strayer University.
HUM106 Student Version 1194 (03-04-2019) Final Page 1 of 3
Due Week 3 and worth 120 points
Imagine you are an art critic who has just seen a specific
artwork for the first time at an art gallery opening. Select a
specific piece of art from Chapters 1-4, and research the
background of the artists and the movement that it represents.
Write a critique for the city newspaper.
Write a two to three (2-3) page paper in which you:
1. Describe the artwork in terms of subject, medium,
composition, and use of color.
2. Classify the work of art, highlighting the style, movement,
and any innovation the artist displayed.
3. Analyze the relationship between the work of art and the
influences on the artist that shape the interpretation of the art.
4. Explain your personal view of the work and make a
recommendation for or against the public viewing the work.
5. Include three (3) references to support your claims. (The text
may be used as one (1) reference.)
Your assignment must follow these formatting requirements:
· This course requires use of new Strayer Writing Standards
(SWS). The format is different from other Strayer University

courses. Please take a moment to review the SWS
documentation for details.
· Be typed, double spaced, using Times New Roman font (size
12), with one-inch margins on all sides; citations and references
must follow SWS or school-specific format. Check with your
professor for any additional instructions.
· Include a cover page containing the title of the assignment, the
student’s name, the professor’s name, the course title, and the
date. The cover page and the reference page are not included in
the required assignment page length. Include the name of the
artist and title of the art piece being discussed under the title of
the paper.
The specific course learning outcomes associated with this
assignment are:
· Analyze the essential relationship between any work of art and
the various kinds of influences on the artist and audience that
shape the interpretation of the art.
· Explain the formal elements of various styles of modern art
· Classify key artists and styles in the visual arts from the
· Use technology and information resources to research issues in
modern art
· Write clearly and concisely about modern art using proper
writing mechanics.
Grading for this assignment will be based on answer quality,
logic/organization of the paper, and language and writing skills,
using the following rubric.
Points: 120
Criteria
Unacceptable
Below 60% F

Meets Minimum Expectations
60-69% D
Fair
70-79% C
Proficient
80-89% B
Exemplary
90-100% A
1. Describe the artwork in terms of subject, medium,
Weight: 30%
Did not submit or incompletely described the artwork in terms
of subject, medium, composition, and use of color.
Insufficiently described the artwork in terms of subject,
medium, composition, and use of color.
Partially described the artwork in terms of subject, medium,
Satisfactorily described the artwork in terms of subject,
medium, composition, and use of color.
Thoroughly described the artwork in terms of subject, medium,
2. Classify the work of art, highlighting the style, movement,
and any innovation the artist displayed.
Weight: 20%
Did not submit or incompletely classified the work of art,
highlighting the style, movement, and any innovation the artist
displayed.
Insufficiently classified the work of art, highlighting the style,
movement, and any innovation the artist displayed.
Partially classified the work of art, highlighting the style,
Satisfactorily classified the work of art, highlighting the style,

Thoroughly classified the work of art, highlighting the style,
3. Analyze the relationship between the work of art and the
influences on the artist that shape the interpretation of the art.
Weight: 20%
Did not submit or incompletely analyzed the relationship
between the work of art and the influences on the artist that
Insufficiently analyzed the relationship between the work of art
and the influences on the artist that shape the interpretation of
the art.
Partially analyzed the relationship between the work of art and
the influences on the artist that shape the interpretatio n of the
art.
Satisfactorily analyzed the relationship between the work of art
the art.
Thoroughly analyzed the relationship between the work of art
the art.
4. Explain your personal view of the work and make a
Weight: 15%
Did not submit or incompletely explained your personal view of
the work and made a recommendation for or against the public
viewing the work.
Insufficiently explained your personal view of the work and
made a recommendation for or against the public viewing the
work.
Partially explained your personal view of the work and made a
Satisfactorily explained your personal view of the work and
made a recommendation for or against the public viewing the
work.
Thoroughly explained your personal view of the work and made
a recommendation for or against the public viewing the work.

6. Include 3 references to support your claims. (The text may be
used as one reference.)
Weight: 5%
No references provided
Does not meet the required number of references; all references
poor quality choices.
Does not meet the required number of references; some
references poor quality choices.
Meets number of required references; all references high quality
choices.
Exceeds number of required references; all references high
quality choices.
7. Clarity, writing mechanics, and formatting requirements
Weight: 10%
More than 8 errors present
7-8 errors present
5-6 errors present
3-4 errors present
0-2 errors present
Create a dialogue between two artists discussing their work(s)
with an interviewer asking questions in front of an audience at
an art gallery (much like a panel discussion format). Have Gris
or Picasso dialogue with Matisse, Cezanne Gauguin, or van
Gogh. Each one should explain his work(s), influences,
philosophy, style, themes, and meaning, highlighting the reason
for the work(s)’ importance to and impact on the world of art.
Use the style of dialogue used in a play. For example:
Interviewer: Senor Picasso and Monsieur Matisse, which work
do you consider your most significant accomplishment and why
do you think so?
Picasso: (Confidently) I have so many that are significant, but
one that I think is truly a work of genius and innovation is
[insert the Title of the Artwork]. This work shows the

innovation the art world refers to as Cubism. I was the founder
of that movement and perfected the style. No other artist has
had that type of influence in the world of art.
Matisse: (Somewhat insulted). If I may be so bold, Senor
Picasso, but I think my work has had a greater influence. My
[insert the Title of the Artwork] has had a lasting impression, if
you excuse the term, on thousands of artists. For example, …
1. Create dialogue for selected artist #1 that refl ects his
influences, philosophy, style, themes, and meaning of his
work(s).
2. Create dialogue for selected artist #2 that reflected his
work(s).
3. Create dialogue for selected artist #1 that highlights the
reason for work(s)’s importance and impact on the world of art.
5. Create appropriate interview questions that facilitate the
dialogue and highlighted the comparison between the two (2)
artists.
6. Include three (3) references that help support the artists’
comments. (The text may be used as one (1) reference.)
12), with one-inch margins on all sides; references must follow
SWS or school-specific format. Check with your professor for
any additional instructions.

the required page length.
assignment are:
· Discuss the value of visual art for an individual and soci ety.
· Describe the relationship between individual artistic
modern art.
writing mechanics.
Points: 140
Criteria
Unacceptable
Below 60% F
60-69% D
Fair
70-79% C
Proficient
80-89% B

Exemplary
90-100% A
1. Create dialogue for selected artist #1 that reflects his
work(s).
Weight: 20%
Did not submit or incompletely created dialogue for selected
artist #1 that reflected his influences, philosophy, style, themes,
and meaning of his work(s).
Insufficiently created dialogue for selected artist #1 that
reflected his influences, philosophy, style, themes, and meaning
of his work(s).
Partially created dialogue for selected artist #1 that reflected his
work(s).
Satisfactorily created dialogue for selected artist #1 that
of his work(s).
Thoroughly created dialogue for selected artist #1 that reflected
his influences, philosophy, style, themes, and meaning of his
work(s).
2. Create dialogue for selected artist #2 that reflects his
work(s).
Weight: 20%
artist #2 that reflected his influences, philosophy, style, themes,
and meaning of his work(s).
of his work(s).
Partially created dialogue for selected artist #2 that reflected his
work(s).

of his work(s).
Thoroughly created dialogue for selected artist #2 that reflected
his influences, philosophy, style, themes, and meaning of his
work(s).
Weight: 15%
artist #1 that highlights the reason for work(s)’s importance and
impact on the world of art.
highlights the reason for work(s)’s importance and impact on
the world of art.
Partially created dialogue for selected artist #1 that highlights
the reason for work(s)’s importance and impact on the world of
art.
the world of art.
Thoroughly created dialogue for selected artist #1 that
the world of art.
Weight: 15%
artist #2 that highlights the reason for work(s)’s importance and
impact on the world of art.
the world of art.
Partially created dialogue for selected artist #2 that highlights
the reason for work(s)’s importance and impact on the world of
art.

the world of art.
Thoroughly created dialogue for selected artist #2 that
the world of art.
5. Create appropriate interview questions that facilitate the
dialogue and highlighted the comparison between the two (2)
artists.
Weight: 15%
Did not submit or incompletely created appropriate interview
questions that facilitated the dialogue and highlighted the
comparison between the two (2) artists.
Insufficiently created appropriate interview questions that
facilitated the dialogue and highlighted the comparison between
the two (2) artists.
Partially created appropriate interview questions that facilitated
the dialogue and highlighted the comparison between the two
(2) artists.
Satisfactorily created appropriate interview questions that
Thoroughly created appropriate interview questions that
6. Include 3 references that help support the artists’ comments.
(The text may be used as one reference.)
Weight: 5%
choices.
quality choices.

Weight: 10%
7-8 errors present
5-6 errors present
3-4 errors present
0-2 errors present
Imagine you are trying to sell a work of art to a wealthy art
collector. Describe a painting or watercolor that you have
created or discovered from the 20th or 21st Century that has
special meaning to you. Describe it in terms of content, style,
color, composition, theme or intent, highlighting how this
artwork makes you (or the viewer) feel.
1. Provide a copy of the painting or water color, and describe
the piece in terms of content, style, color, and composition.
2. Explain the artwork’s theme and intent.
3. Classify the artwork within the modern art movements and
explain why it belongs there.
4. Explain how this artwork makes you (or the viewer) feel. (If
you created the work, explain why you did so and your feelings
toward the process and the completed work.)
5. Include two (2) references that help support your claims.
(The text may be used as one (1) reference.)

12), with one-inch margins on all sides; references must follow
SWS or school-specific format. Check with your professor for
the required page length. Identify the artwork and artists under
the title of your paper.
assignment are:
modern art.
writing mechanics.
Points: 110
Criteria
Unacceptable
Below 60% F
60-69% D
Fair

70-79% C
Proficient
80-89% B
Exemplary
90-100% A
1. Provide a copy of the painting or water color, and describe
the artwork in terms of content, style, color, and composition.
Weight: 30%
Did not submit or incompletely provided a copy of the painting
or water color, and incompletely described the artwork in terms
of content, style, color, and composition.
Insufficiently provided a copy of the painting or water color,
and insufficiently described the artwork in terms of content,
style, color, and composition.
Partially provided a copy of the painting or water color, and
partially described the artwork in terms of content, style, color,
and composition.
Satisfactorily provided a copy of the painting or water color,
and satisfactorily described the artwork in terms of content,
style, color, and composition.
Thoroughly provided a copy of the painting or water color, and
thoroughly described the artwork in terms of content, style,
color, and composition.
2. Explain the artwork’s theme and intent.
Weight: 20%
Did not submit or explain the artwork’s theme and intent.
Insufficiently explained the artwork’s theme and intent.
Partially explained the artwork’s theme and intent.
Satisfactorily explained the artwork’s theme and intent.
Thoroughly explained the artwork’s theme and intent.
3. Classify the artwork within the modern art movements and
explain why it belongs there.
Weight: 20%
Did not submit or incompletely classified the artwork within the

modern art movements and did not explain why it belongs there.
Insufficiently classified the artwork within the modern art
movements and insufficiently explained why it belongs there.
Partially classified the artwork within the modern art
movements and partially explained why it belongs there.
Satisfactorily classified the artwork within the modern art
movements and satisfactorily explained why it belongs there.
Thoroughly classified the artwork within the modern art
movements and thoroughly explained why it belongs there.
4. Explain how this artwork makes you (or the viewer) feel. (If
you created the work, explain why you did so and your feelings
toward the process and the completed work.)
Weight: 15%
Did not submit or incompletely explained how this artwork
makes you (or the viewer) feel. (If you created the work, did not
explain why you did so and your feelings toward the process
and the completed work.)
Insufficiently explained how this artwork makes you (or the
viewer) feel. (If you created the work, insufficiently explained
why you did so and your feelings toward the process and the
completed work.)
Partially explained how this artwork makes you (or the viewer)
feel. (If you created the work, partially explained why you did
so and your feelings toward the process and the completed
work.)
Satisfactorily explained how this artwork makes you (or the
viewer) feel. (If you created the work, satisfactorily explained
completed work.)
Thoroughly explained how this artwork makes you (or the
viewer) feel. (If you created the work, thoroughly explained
completed work.)
5. Include 2 references that help support your claims. (The text
may be used as one reference.)
Weight: 5%

choices.
quality choices.
Weight: 10%
7-8 errors present
5-6 errors present
3-4 errors present
0-2 errors present
As a way of experiencing the Humanities beyond your
classroom, computer, and textbook, you are asked to attend a
“cultural event” and report on your experience. This assignment
requires the following:
· Submit your cultural event choice to the instructor for
approval before the end of Week 5.
· Visit a museum or gallery exhibition of modern art before the
end of Week 9.
· Write a report of the visit.
· Summarize the report in a PowerPoint presentation.
Write a three to four (3-4) page paper (750-1,000 words) in
which you:
1. Identify the date visited, location, name, and background of

the museum or specific exhibition. (If virtual, identify the
Website along with the other information.)
2. Describe three (3) works, noting the artist, title, subject, and
the time period of each work.
3. Compare the style, influences, and meaning or intent of each
piece, highlighting any changes (if any) from the first to last
piece.
4. Explain your reasons for selecting the pieces in a discussion
of the reasons for the artist’s popularity and / or impact on the
art world.
5. Summarize the main points of three (3) works discussed in
your paper in a PowerPoint presentation of at least three (3)
slides. Each of the slides should have three to four (3-4) short
bullet points and notes about the works in the slide notes
section. Include a cover page for the PowerPoint. Add the slides
with notes to your paper.
6. Include four (4) references that help support your claims.
(The text may be used as one (1) reference.)
Visiting a Museum
· It makes sense to approach a museum the way a seasoned
traveler approaches visiting a city for the first time. Find out
what is available to see. In the museum, find out what sort of
exhibitions are currently housed in the museum and start with
the exhibits that interest you. If there is a travelling exhibition,
it’s always a good idea to see it while you have the chance.
Then, if you have time, you can look at other things in the
museum.
· Make notes as you go through the museum and accept any
handouts or pamphlets that the museum provides free. Whil e
you should not quote anything from the printed material when
you do your report, the handouts may help to refresh your
memory later.
· The quality of your experience is not measured by the amount
of time you spend in the galleries or the number of works of art
that you actually see. The most rewarding experiences can come

from finding three (3) pieces of art or exhibits which intrigue
you and then considering those works in leisurely
contemplation. Most museums even have benches where you can
sit and study a particular piece.
· If you are having a difficult time deciding which pieces to
write about, ask yourself these questions: (1) If the museum you
are visiting suddenly caught fire, which three (3) pieces of art
or exhibits would you most want to see saved from the fire? (2)
Why would you choose those two (2) particular pieces?
Note:If a student is unable to attend a cultural event in person
due to circumstances beyond the student’s control, then the
instructor will recommend an alternate event/activity for the
student to “attend” online. The “virtual” event/activity is
usually only for students who, due to their physical location,
cannot possibly attend an event/activity in person; typically,
these students are stationed overseas or have no means of
transportation. If you believe that you have a legitimate reason
for attending a “virtual” activity, you must contact the
instructor no later than Week 5 for your request to be
considered.
12), with one-inch margins on all sides; citations and references
must follow SWS Style format. Check with your professor for
· Include a cover page containing the tile of the assignment, the
the required assignment page length.
· Include a PowerPoint presentation. The PowerPoint

presentation is not included in the page count.
assignment are:
· Discuss the value of visual art for an individual and society.
· Explain various terms, qualities, and themes of visual art from
the late 1800s to the present.
the study of modern art.
writing mechanics.
Points: 200
Criteria
Unacceptable
Below 60% F
60-69% D
Fair
70-79% C

Proficient
80-89% B
Exemplary
90-100% A
1. Identify the date visited, location, name, and background of
the museum or specific exhibition. (If virtual, identify the
Website along with the other information.)
Weight: 5%
Did not submit or incompletely identified the date visited,
location, name, and background of the museum or specific
exhibition. (If virtual, incompletely identified the Website
along with the other information.)
Insufficiently identified the date visited, location, name, and
background of the museum or specific exhibition. (If virtual,
insufficiently identified the Website along with the other
information.)
Partially identified the date visited, location, name, and
partially identified the Website along with the other
information.)
Satisfactorily identified the date visited, location, name, and
satisfactorily identified the Website along with the other
information.)
Thoroughly identified the date visited, location, name, and
thoroughly identified the Website along with the other
information.)
2. Describe three (3) works, noting the artist, title, subject, and
the time period of each work.
Weight: 15%
Did not submit or incompletely described three (3) works,
incompletely noted the artist, title, subject, and the time period
of each work.

Insufficiently described three (3) works, insufficiently noted the
artist, title, subject, and the time period of each work.
Partially described three (3) works, partially noted the artist,
title, subject, and the time period of each work.
Satisfactorily described three (3) works, satisfactorily noted the
Thoroughly described three (3) works, thoroughly noted the
3. Compare the style, influences, and meaning or intent of each
piece, highlighting any changes (if any) from the first to last
piece.
Weight: 30%
Did not submit or incompletely compared the style, influences,
and meaning or intent of each piece, highlighting any changes
(if any) from the first to last piece.
Insufficiently compared the style, influences, and meaning or
intent of each piece, highlighting any changes (if any) from the
first to last piece.
Partially compared the style, influences, and meaning or intent
of each piece, highlighting any changes (if any) from the first to
last piece.
Satisfactorily compared the style, influences, and meaning or
Thoroughly compared the style, influences, and meaning or
4. Explain your reasons for selecting the pieces in a discussion
of the reasons for the artist’s popularity and / or impact on the
art world.
Weight: 15%
Did not submit or incompletely explained your reasons for
selecting the pieces in a discussion of the reasons for the
artist’s popularity and / or impact on the art world.
Insufficiently explained your reasons for selecting the pieces in
a discussion of the reasons for the artist’s popularity and / or

impact on the art world.
Partially explained your reasons for selecting the pieces in a
discussion of the reasons for the artist’s popularity and / or
Satisfactorily explained your reasons for selecting the pieces in
a discussion of the reasons for the artist’s popularity and / or
Thoroughly explained your reasons for selecting the pieces in a
discussion of the reasons for the artist’s popularity and / or
5. Summarize the main points of three (3) works discussed in
your paper in a PowerPoint presentation of at least three (3)
slides. Each of the slides should have three to four (3-4) short
bullet points and notes about the works in the slide notes
section. Include a cover page for the PowerPoint. Add the slides
and with notes to your paper.
Weight: 20%
Did not submit or incompletely summarized the main points of
three (3) works discussed in your paper in a PowerPoint
presentation of at least three (3) slides. Each of the slides
should have three to four (3-4) short bullet points and notes
about the works in the slide notes section. Did not submit or
incompletely included a cover page for the PowerPoint. Added
the slides and with notes to your paper.
Insufficiently summarized the main points of three (3) works
discussed in your paper in a PowerPoint presentation of at least
three (3) slides. Each of the slides should have three to four (3-
4) short bullet points and notes about the works in the slide
notes section. Insufficiently included a cover page for the
PowerPoint. Added the slides and with notes to your paper.
Partially summarized the main points of three (3) works
notes section. Partially included a cover page for the

Satisfactorily summarized the main points of three (3) works
notes section. Satisfactorily included a cover page for the
Thoroughly summarized the main points of three (3) works
notes section. Thoroughly included a cover page for the
6. Include 4 references that help support your claims. (The text
may be used as one reference.)
Weight: 5%
choices.
quality choices.
Weight: 10%
7-8 errors present
5-6 errors present
3-4 errors present
0-2 errors present
Reflective Journals
Journals should be ¾ to 1 page or 2 to 3 developed paragraphs.
assignment are:

· Discuss the value of visual art for an individual and society.
writing mechanics.
-----
Reflective Journal 1: My Experience with Art
Address these points:
1. Describe your experience with art before taking this class.
2. Explain your feelings about art in general and modern art in
specific.
3. Explain your reasons for taking this course.
-----
Reflective Journal 2: Social Influences on Artists
1. Explain how social influences have an impact on many artists
and their works. Use examples from movements and examples
explored in the chapters up to this point.
2. Explain how current events have been influencing art in such
areas as movies and music. Use examples to illustrate your
views.
-----

Reflective Journal 3: Proposed Cultural Event
1. Identify the site that you plan to visit for Assignment 4:
Impressions of Museum or Gallery Exhibit.
2. Identify your goals of the visit.
3. Explain your reasons for the selection. (If you select a virtual
site, explain your reasons.)
Note:If a student is unable to attend a cultural event in person
due to circumstances beyond the student’s control, then the
instructor will recommend an alternate event/activity for the
student to “attend” online. The “virtual” event/activity is
usually only for students who, due to their physical location,
cannot possibly attend an event/activity in person; typically,
these students are stationed overseas or have no means of
transportation. If you believe that you have a legitimate reason
for attending a “virtual” activity, you must contact the
instructor no later than Week 5 for your request to be
considered.
Reflective Journal 4: Art in Everyday Life
1. Describe the places you see art (sculpture, architecture,
photography) in everyday life.
2. Comment on the importance of art in everyday life.
3. Discuss the importance of art to you personally.
Grading for Reflective Journal assignments will be based on
answer quality, logic/organization of the paper, and language
and writing skills, using the following rubric.
Points: 40
Assignment: Reflective Journal
Criteria

Unacceptable
Below 60% F
60-69% D
Fair
70-79% C
Proficient
80-89% B
Exemplary
90-100% A
1. Discuss points assigned.
Weight: 60%
Did not submit or incompletely discussed points assigned.
Insufficiently discussed points assigned.
Partially discussed points assigned.
Satisfactorily discussed points assigned.
Thoroughly discussed points assigned.
2. Complete page requirement.
Weight: 30%
Did not submit or incompletely completed page requirement.
Insufficiently completed page requirement.
Partially completed page requirement.
Satisfactorily completed page requirement.
Thoroughly completed page requirement.
Weight: 10%
7-8 errors present
5-6 errors present
3-4 errors present
0-2 errors present

HUM 106 – Assignments and Rubrics
CHAPTER 9
Lessons from the Academy
ERM Implementation in the University Setting
ANNE E. LUNDQUIST
Western Michigan University
T
he tragedy at Virginia Tech, infrastructure devastation at
colleges and uni-
versities in the New Orleans area in the aftermath of Hurricane
Katrina,
the sexual abuse scandal at Penn State, the governance crisis at
the Uni-
versity of Virginia, American University expense-account
abuse, and other high-
profile university situations have created heightened awareness
of the potentially
destructive influence of risk and crisis for higher education
administrators.1 The
recent Risk Analysis Standard for Natural and Man-Made
Hazards to Higher Educa-
tion Institutions (American Society of Mechanical Engineers –
Innovative Technolo-
gies Institute 2010) notes that “resilience of our country’s
higher education insti-
tutions has become a pressing national priority” (p. vi).

Colleges and universities
are facing increased scrutiny from stakeholders regarding issues
such as invest-
ments and spending, privacy, conflicts of interest, information
technology (IT)
availability and security, fraud, research compliance, and
transparency (Willson,
Negoi, and Bhatnagar 2010). A statement from the review
committee assembled to
examine athletics controversies at Rutgers University is not
unique to that situa-
tion; the committee found that “the University operated with
inadequate internal
controls, insufficient inter-departmental and hierarchical
communications, an
uninformed board on some specific important issues, and
limited presidential
leadership” (Grasgreen 2013).
The situation at Penn State may be one of the clearest signals
that risk man-
agement (or lack thereof) has entered the university
environment and is here to
stay. In a statement regarding the report, Louis Freeh, chair of
the independent
investigation by his law firm, Freeh Sporkin & Sullivan, LLP,
into the facts and
circumstances of the actions of Pennsylvania State University,
said the following:
In our investigation, we sought to clarify what occurred . . . and
to examine the Uni-
versity’s policies, procedures, compliance and internal controls
relating to identi-
fying and reporting sexual abuse of children. Specifically, we
worked to identify

any failures or gaps in the University’s control environment,
compliance programs
and culture which may have enabled these crimes against
children to occur on
the Penn State campus, and go undetected and unreported for at
least these past
14 years.
143
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144 Implementing Enterprise Risk Management
The chair of Penn State’s board of trustees summed it up
succinctly after the
release of the Freeh Report (Freeh and Sullivan 2012) regarding
the university’s
handling of the sexual abuse scandal: “We should have been
risk managers in a
more active way” (Stripling 2012).
The variety, type, and volume of risks affecting higher
education are numer-
ous, and the public is taking notice of how those risks are
managed. Accreditation
agencies are increasingly requiring that institutions of higher
education (IHEs)
demonstrate effective integrated planning and decision making,
including using
information gained from comprehensive risk management as a
part of the gover-
nance and management process.2 Credit rating agencies now
demand evidence of

comprehensive and integrated risk management plans to ensure
a positive credit
rating, including demonstration that the board of trustees is
aware of, and involved
in, risk management as a part of its decision making.3 Through
its Colleges and
Universities Compliance Project, the Internal Revenue Service
(IRS) is considering
how to hold IHEs responsible for board oversight of risk,
investment decisions,
and other risk management matters.4 The news media has a
heightened focus on
financial, governance, and ethical matters at IHEs, holding them
accountable for
poor decisions and thus negatively affecting IHE reputations. In
response to this,
many IHEs have implemented some form of enterprise risk
management (ERM)
program to help them identify and respond to risk.
THE HIGHER EDUCATION ENVIRONMENT
Colleges and universities have often perceived themselves as
substantially differ-
ent and separate from other for-profit and not-for-profit entities,
and the outside
world has historically viewed and treated them as such.
Colleges and universities
have been viewed as ivory towers, secluded and separated from
the corporate (and
thus the federal regulatory and, often, legal) world. Higher
education was largely a
self-created, self-perpetuating, insular, isolated, and self-
regulating environment.
In this culture, higher education institutions were generally
governed under the
traditional, independent “silos of power and silence”

management model, with
the right hand in one administrative area or unit often unaware
of the left hand’s
mission, objectives, programs, practices, and contributions in
another area.
John Nelson (2012), managing director for the Public Finance
Group (Health-
care, Higher Education, Not-for-Profits) for Moody’s Investors
Service, observed
that higher education culture is somewhat of a contradiction in
that colleges and
universities are often perceived as “liberal,” whereas
organizationally they tend
to be “conservative and inward-looking.”5 Citing recent
examples at Penn State
and Harvard, he noted that colleges and universities can be
“victims of their own
success”; a past positive reputation can prevent boards from
asking critical ques-
tions, and senior leadership from sharing troubling information
with boards, and
this can perpetuate a culture that isn’t self-reflective, thus
increasing the likelihood
for a systemic risk management or compliance failure. The
Freeh Report (2012)
is instructive regarding not only the Penn State situation, but
the hands-off and
rubber-stamp culture of university boards and senior leaders
more broadly. The
Freeh Report found that the Penn State board failed in its duty
to make reason-
able inquiry and to demand action from the president, and that
the president,
a senior vice president, and the general counsel did not perform
their duties.

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LESSONS FROM THE ACADEMY 145
The report calls these inactions a “failure of governance,”
noting that the “board
did not have regular reporting procedures or committee
structure to ensure dis-
closure of major risks to the University” and that “Penn State’s
‘Tone at the Top’
for transparency, compliance, police reporting, and child
protection was com-
pletely wrong, as shown by the inaction and concealment on the
part of its most
senior leaders, and followed by those at the bottom of the
University’s pyramid of
power.”
In his text regarding organizational structures in higher
education, How Col-
leges Work, Birnbaum (1988) notes that, organizationally and
culturally, colleges
and universities differ in many ways from other organizations.
He attributes this
difference to several factors: the “dualistic” decision-making
structure (comprised
of faculty “shared governance” and administrative hierarchy);
the lack of metrics
to measure progress and assess accountability; and the lack of
clarity and agree-
ment within the academic organization on institutional goals
(based, in part, on
the often competing threefold mission of most academic

organizations of teaching,
research, and service). Because of these organizational
differences, Birnbaum notes
that the “processes, structures, and systems for accountability
commonly used in
business firms are not always sensible for [colleges and
universities]” (p. 27).
While noting that colleges and universities are unique
organizations,
Birnbaum also observes that they have begun to adopt more
general business prac-
tices, concluding that “institutions have become more
administratively centralized
because of requirements to rationalize budget formats,
implement procedures that
will pass judicial tests of equitable treatment, and speak with a
single voice to pow-
erful external agencies” (p. 17).
This evolution to a more businesslike culture for IHEs has been
evolving since
the 1960s and has brought significant societal changes while
seeing the federal gov-
ernment, as well as state governments, begin to enact specific
legislation affecting
colleges and universities.6 The proliferation of various laws and
regulations, cou-
pled with the rise of aggressive consumerism toward the end of
the 1990s, has led to
an increased risk of private legal claims against institutions of
higher education—
and their administrators—as well as a proliferation of
regulatory and compliance
requirements. Higher education is now generally treated like
other business enter-

prises by judges, juries, and creative plaintiffs’ attorneys, as
well as by administra-
tive and law enforcement agencies, federal regulators—and the
public.
Mitroff, Diamond, and Alpaslan (2006) point out that despite
their core edu-
cational mission, colleges and universities are really more like
cities in terms of
the number and variety of services they provide and the
“businesses” they are in.
They cite the University of Southern California (USC) as an
example, noting that
USC operates close to 20 different businesses, including food
preparation, health
care, and sporting events, and that each of these activities
presents the university
with different risks. Jean Chang (2012), former ERM director at
Yale University,
observed that IHEs are complicated businesses with millions of
dollars at stake,
but they don’t like to think of themselves as “enterprises.”
Organizational Type Impacts Institutional Culture
While Birnbaum (1988) notes that IHEs differ in important
ways from other orga-
nizational types, especially for-profit businesses, he also
concludes that colleges
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and universities differ from each other in important ways.
Birnbaum outlines five
models of organizational functioning in higher education:
collegial, bureaucratic,
political, anarchical, and cybernetic. In Bush’s (2011) text on
educational leader-
ship, he groups educational leadership theories into six
categories: formal, colle-
gial, political, subjective, ambiguity, and cultural. In their
discussion of organiza-
tional structure, Bolman and Deal (2008) provide yet another
method for analysis
of organizational culture, identifying four distinctive “frames”
from which people
view their world and that provide a lens for understanding
organizational culture:
structural, human resources, political, and symbolic.
Each of these models can provide a conceptual framework by
which to under-
stand and evaluate the culture of a college or university.
Understanding the orga-
nizational type of a particular institution is imperative when
considering issues
such as the process by which goals are determined, the nature of
the decision-
making process, and the appropriate style of leadership to
accomplish goals and
implement initiatives. What works in one university
organizational type may not
be effective in another. The leadership style of senior
administration may be oper-
ating from one frame or model while the culture of the faculty
may be operating
from another, thus affecting policy and practice in positive or
negative ways.

While not true across the board, for-profit organizations tend to
operate from
what Bush as well as Bolman and Deal refer to as the formal or
structural models
and Birnbaum terms bureaucratic. The structural frame
represents a belief in ratio-
nality. Some assumptions of the structural frame are that
“suitable forms of coordi-
nation and control ensure that diverse efforts of individuals and
units mesh” and
that “organizations work best when rationality prevails over
personal agendas”
(Bolman and Deal 2008, p. 47). Understanding this cultural and
framing difference
is important when considering the adoption and implementation
of ERM in the
university environment, and can help to explain why many
university administra-
tors and faculty are skeptical of the more corporate approach
often taken in ERM
implementation outside of higher education.
Bush observes that the collegial model has been adopted by
most universities
and is evidenced, in part, by the extensive committee system.
Collegial institu-
tions have an “emphasis on consensus, shared power, common
commitments and
aspirations, and leadership that emphasizes consultation and
collective responsi-
bilities” (Birnbaum, p. 86). Collegial models assume that
professionals also have a
right to share in the wider decision-making process (Bush 2011,
p. 73). Bush points
out that collegial models assume that members of an

organization agree on orga-
nizational goals, but that often various members within the
institution have differ-
ent ideas about the central purposes of the institution because
most colleges and
universities have vague, ambiguous goals. Birnbaum describes
the collegium (or
university environment) as having the following characteristics:
The right to participate in institutional affairs, membership in a
congenial and sym-
pathetic company of scholars in which friendships, good
conversation, and mutual
aid flourish, and the equal worth of knowledge in various fields
that precludes
preferential treatment of faculty in different disciplines. (p. 87)
ERM (or risk management and compliance initiatives in
general) tend to be
viewed as more corporate functions and to align with formal,
structural, and
bureaucratic aims, goal setting, planning, and decision making.
The chart in
Exhibit 9.1 outlines management practices and how they are
viewed from the
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147
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formal/structural and collegial/human resources models. As will
become clear
in the University of Washington ERM implementation case
described in this chap-
ter, the culture of higher education in general, and the
institution-specific culture
of the particular organization, cannot be ignored when adopting
or implementing
an ERM program, and may be the most important element when
making ERM
program, framework, and philosophy decisions.
Risks Affecting Higher Education
One way in which colleges and universities are becoming more
like other organi-
zations is the type and variety of risks affecting them. Risk and
crisis in higher edu-
cation may arise from a variety of sources: a failure of
governance or leadership;
a business or consortium relationship; an act of nature; a crisis
related to student
safety or welfare or that of other members of the community; a
violation of federal,
state, or local law; or a myriad of other factors. The University
Risk Management
and Insurance Association (URMIA 2007) cites several drivers
that put increased
pressure and risk on colleges and universities, including
competition for faculty,
students, and staff; increased accountability; external scrutiny
from the govern-
ment, the public, and governing boards; IT changes; competition
in the market-
place; and increased levels of litigation. A comprehensive, yet

not exhaustive, list
of risks affecting higher education is outlined in Exhibit 9.2.
Risks unmitigated at
the unit, department, or college level can quickly lead to high-
profile institutional
risk when attorneys, the media, and the public get involved.
Helsloot and Jong
(2006) observe that higher education has a unique risk as it
relates to the genera-
tion and sharing of its core task: “to gather, develop, and
disseminate knowledge”
(p. 154), noting that the “balance between the unfettered
transfer of knowledge, on
the one hand, and security, on the other, is a precarious one” (p.
155).
EMERGENCE OF ERM IN HIGHER EDUCATION
In the corporate sector, interest in the integrated and more
strategic concept of
enterprise risk management (ERM) has grown significantly in
the past 15 years
(Arena, Arnaboldi, and Azzone 2010). Certain external factors
affected the adop-
tion and implementation of ERM practices in corporations,
including significant
business failures in the late 1980s that occurred as a result of
high-risk financing
strategies (URMIA 2007). Governments in several European
countries took actions
and imposed regulatory requirements regarding risk
management earlier than was
done in the United States, issuing new codes of practice and
regulations such as the
Cadbury Code (1992), the Hampel Report (1998), and the
Turnbull Report (1999). In
2002, the Public Company Accounting Reform and Investor

Protection Act (other-
wise known as Sarbanes-Oxley, or SOX) was enacted in the
United States. In 2007,
the Securities and Exchange Commission (SEC) issued guidance
placing greater
emphasis on risk assessment and began to develop requirements
for enterprise-
wide evaluation of risk. In February 2010, the SEC imposed
regulations requiring
for-profit corporations to report in depth on how their
organizations identify risk,
set risk tolerances, and manage risk/reward trade-offs
throughout the enterprise.
While widespread in the corporate sector, in large part due to
regulatory com-
pliance, ERM is fairly new in higher education. Gurevitz (2009)
observes that
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Exhibit 9.2 Risks Affecting Higher Education
Institutional Area Types of Risk
Boards of Trustees and
Regents, President,
Senior Administrators
Accreditation
Board performance assessment
CEO assessment and compensation

Conflict of interest
Executive succession plan
Fiduciary responsibilities
IRS and state law requirements
Risk management role and responsibility
Business and Financial
Affairs
Articulation agreements
Bonds
Budgets
Business ventures
Cash management
Capital campaign
Contracting and purchasing
Credit rating
Debt load/ratio
Endowment
Federal financial aid
Fraud
Gift/naming policies
Insurance
Investments
Loans
Outsourcing
Transportation and travel
Recruitment and admissions model
Compliance with
Federal, State, and
Local Laws, Statutes,
Regulations, and
Ordinances
Americans with Disabilities Act (ADA)/Section 504

Copyright and fair use
Drug-Free Schools and Communities Act
Family Educational Rights and Privacy Act (FERPA)
Health Insurance Portability and Accountability Act of
1996 (HIPAA)
Higher Education Opportunity Act IRS regulations
Integrated Postsecondary Education Data System (IPEDS)
Jeanne Clery Disclosure of Campus Security Policy and
Campus Crime Statistics Act (Clery Act)
National Collegiate Athletic Association
(NCAA)/National Association of Intercollegiate
Athletics (NAIA) regulations
Record retention and disposal
Tax codes
Whistle-blower policies
Campus Safety and
Security
Emergency alert systems for natural disaster or other
threat
Emergency planning and procedures
Incident response
(continued)
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Exhibit 9.2 (Continued)
Campus Safety and
Security (continued)
Infectious diseases
Interaction with local, state, and federal authorities
Minors on campus
Terrorism
Theft
Violence on campus
Weapons on campus
Weather
Information Technology Business continuity
Cyber liability
Electronic records
Information security
Network integrity
New technologies
Privacy
System capacity
Web page accuracy
Academic Affairs Academic freedom
Competition for faculty
Faculty governance issues
Grade tampering
Grants
Human subject, animal, and clinical research
Intellectual property
Internship programs
Joint programs/partnerships

Laboratory safety
Online learning
Plagiarism
Quality of academic programs
Student records
Study abroad
Tenure
Student Affairs Admission/retention
Alcohol and drug use
Clubs and organizations
Conduct and disciplinary system
Dismissal procedures
Diversity issues
Fraternities and sororities
Hate crimes
Hazing
International student issues
Psychological disabilities issues
Sexual assault
Student death
Student protest
Suicide
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Exhibit 9.2 (Continued)
Employment/Human
Resources

Affirmative action
Background checks
Discrimination lawsuits
Employment contracts
Grievances
Labor laws
Performance evaluation
Personnel matters
Sexual harassment
Termination procedures
Unions
Workplace safety
Physical Plant Building and renovation
Fire
Infrastructure damage
Off-site programs
Public-private partnerships
Residence hall and apartment safety
Theft
Other Alumni
Athletics
External relations
Increased competition for students, faculty, and staff
Increased external scrutiny from the public, government,
and media
Medical schools, law schools
Vendors
educational institutions “have been slower to look at ERM as an
integrated busi-
ness tool, as a way to help all the stakeholders—trustees,
presidents, provosts,

CFOs, department heads, and frontline supervisors—identify
early warning signs
of something that could jeopardize a school’s operations or
reputation.” In 2000,
the Higher Education Funding Council of England enacted
legislation requir-
ing all universities in England to implement risk management as
a governance
tool (Huber 2009). In Australia, the Tertiary Education Quality
Standards Agency
(TEQSA 2013) evaluates the performance of higher education
providers against a
set of threshold standards and makes decisions in relation to
their performance
in line with three regulatory principles, including understanding
an institution’s
level of risk.
In the United States, engaging in risk management efforts and
programs for
IHEs is not specifically required by accrediting agencies or the
federal govern-
ment. Perhaps because it is not required, ERM has not been a
top focus for boards
and senior administrators at IHEs. Tufano (2011) points out that
risk management
in the nonprofit realm, including higher education, is
significantly less developed
than in much of the corporate world and often still has a focus
on avoidance of
loss rather than setting strategic direction. Mitroff, Diamond,
and Alpaslan’s (2006)
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survey assessing the state of crisis management in higher
education revealed that
colleges and universities were generally well prepared for
certain crises, particu-
larly fires, lawsuits, and crimes, in part because certain
regulations impose require-
ments. They were also well prepared for infrequently
experienced but high-profile
situations such as athletics scandals, perhaps based on their
recent prominence in
the media. However, they were least prepared for certain types
of crises that were
frequently experienced such as reputation and ethics issues, as
well as other non-
physical crises such as data loss and sabotage.7 A survey
conducted by the Asso-
ciation of Governing Boards of Universities and Colleges and
United Educators
(2009) found that, of 600 institutions completing the survey,
less than half of the
respondents “mostly agreed” that risk management was a
priority at their insti-
tution. Sixty percent stated that their institutions did not use a
comprehensive,
strategic risk assessment to identify major risks to mission
success. Recent high-
profile examples may be beginning to change that. The Freeh
Report regarding
Penn State determined that “the university’s lack of a robust
risk-management sys-
tem contributed to systemic failures in identifying threats to
individuals and the
university and created an environment where key administrators

could ‘actively
conceal’ troubling allegations from the board” (Stripling 2012).
ADOPTING AND IMPLEMENTING ERM IN
COLLEGES AND UNIVERSITIES
In 2001, PricewaterhouseCoopers and the National Association
of College and
University Business Officers (NACUBO) sponsored a think tank
of higher educa-
tion leaders to discuss the topic of ERM in higher education,
likely in response to
widespread discussion in the for-profit sector and in
anticipation of potential reg-
ulatory implications for higher education. The group included
Janice Abraham,
then president and chief executive officer of United Educators
Insurance, as well
as senior administrators from seven universities.8 The focus of
their discussion
was on the definition of risk; the risk drivers in higher
education; implementa-
tion of risk management programs to effectively assess, manage,
and monitor risk;
and how to proactively engage the campus community in a more
informed dia-
logue regarding ERM. Their conversation produced a white
paper, “Developing
a Strategy to Manage Enterprisewide Risk in Higher Education”
(Cassidy et al.
2001). In 2007, NACUBO and the Association of Governing
Boards of Universities
and Colleges (AGB) published additional guidance in their
white paper, “Meeting
the Challenges of Enterprise Risk Management in Higher
Education.” The Uni-
versity Risk Management and Insurance Association (URMIA)

also weighed in
with its white paper, “ERM in Higher Education” (2007). In
2013, Janice Abraham
wrote a text published by AGB and United Educators, entitled
Risk Management:
An Accountability Guide for University and College Boards.
These documents provide
guidance and information to institutions considering the
implementation of an
ERM program and discuss the unique aspects of the higher
education environment
when considering ERM implementation.
Several authors have discussed the transferability of the ERM
model to higher
education, even with the cultural and organizational differences
that abound
between the for-profit environment and higher education.
URMIA (2007) con-
cluded that “the ERM process is directly applicable to
institutions of higher
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education, just as it is to any other ‘enterprise’; there is nothing
so unique to the col-
lege or university setting as to make ERM irrelevant or
impossible to implement”
(p. 17). Whitfield (2003) assessed the “feasibility and
transferability of a general
framework to guide the holistic consideration of risk as a
critical component of

college and university strategic planning initiatives” (p. 78) and
concluded that
“the for-profit corporate sector’s enterprise-wide risk
management framework is
transferable to higher education institutions” (p. 79).
National conferences for higher education associations such as
NACUBO,
AGB, URMIA, and others had presentations on ERM. Insurers
of higher educa-
tion, such as United Educators and Aon, as well as consultants
such as Accenture
and Deloitte, among others, provided workshops to institutions
and published
white papers of their own, such as the Gallagher Group’s “Road
to Implemen-
tation: Enterprise Risk Management for Colleges and
Universities” (2009). In the
early 2000s, many IHEs rushed to form committees to examine
ERM and hired risk
officers in senior-level positions, following the for-profit
model.9 However, when
specific regulations such as those imposed by the SEC for for -
profit entities did not
emerge in the higher education sector, interest in highly
developed ERM models at
colleges and universities began to wane. Gurevitz (2009) points
out that the early
ERM frameworks weren’t written with higher education in mind
and were often
presented “in such a complicated format that it made it difficult
to translate the
concepts for many universities.”
Institutions with ERM programs have taken various paths in
their selection

of models and methods and have been innovative and
individualized in their
approaches. There is no comprehensive list of higher education
institutions with
ERM programs, and not all IHEs with integrated models use the
term ERM.
Exhibit 9.3 shows a snapshot of IHEs that have adopted ERM; a
review of their
websites demonstrates the various risk management approaches
adopted by IHEs
and the wide variability in terminology, reporting lines,
structure, and focus. In
many instances, those IHEs with highly developed programs
today had some form
of “sentinel event” (regulatory, compliance, student safety,
financial, or other)
that triggered the need for widespread investigation and,
therefore, the develop-
ment of more coordinated methods for compliance, information
sharing, and deci-
sion making. In other situations, governing board members
brought their business
experience with ERM to higher education, recognizing the
“applicability and rel-
evance of using a holistic approach to risk management in
academic institutions”
(Abraham 2013, p. 6).
Regardless of the impetus, the current focus appears to be on
effectively link-
ing risk management to strategic planning. Abraham points out
that many higher
education institutions are recognizing that an effective ERM
program, with the
full support of the governing board, “will increase a college,
university or system’s

likelihood of achieving its plans, increase transparency, and
allow better allocation
of scarce resources. Good risk management is good governance”
(p. 5). Ken Barnds
(2011), vice president at Augustana College, points out that
“many strategic plan-
ning processes, particularly in higher education, spent an
insufficient amount of
time thinking about threats and weaknesses.” Barnds believes
that “an honest and
thoughtful assessment of the college’s risks . . . would lead
[Augustana] in a pos-
itive, engaged, and proactive direction.” A recent Grant
Thornton (2011) thought
paper urges university leaders to think about more strategic
issues as part of their
risk management, including board governance, IRS scrutiny of
board oversight
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www.it-ebooks.info
practices, investment performance in university endowments,
indirect cost rates
in research, changes in employment practices, and outsourcing
arrangements.
Regardless of terminology, there is an increased priority on
taking a more
enterprise-wide approach to risk management and moving from
a compliance-

driven approach to a comprehensive, strategic approach across
and throughout
the organization that is used to positively affect decision
making and impact mis-
sion success and the achievement of strategic goals. Tufano
(2011) points out
that even in the corporate environment, top leaders are not
inclined to work
through a detailed step-by-step risk management process, but
rather take a top-
level approach. In the university environment, this means
asking three fundamen-
tal questions: What is our mission? What is our strategy to
achieve it? What risks
might derail us from achieving our mission? Richard F. Wilson,
president of Illinois
Wesleyan University, may best summarize the current
perspective of senior-level
higher education administrators:
When I first started seeing the phrase “enterprise risk
management” pop up in
higher education literature, my reaction was one of skepticism.
It seemed to me yet
another idea of limited value that someone had created a label
for, to make it seem
more important than it really was. Although some of that
skepticism remains, I find
myself increasingly in sympathy with some of its basic tenets . .
. [especially] the
analysis that goes into decisions about the future. Most
institutions are currently
engaged in some kind of strategic planning effort driven, in
part, by the need to
protect their financial viability and vitality for the foreseeable
future. . . . Bad plans

and bad execution of good ideas can put an institution at risk
fairly quickly in the
current environment. Besides examining what we hope will
happen if a particular
plan is adopted, we should also devote time to the consequences
if the plan does
not work. I still cannot quite get comfortable incorporating
enterprise risk man-
agement into my daily vocabulary, but I have embraced the
underlying principles.
(Wilson 2013)
THE UNIVERSITY OF WASHINGTON: A JOURNEY
OF DISCOVERY
The University of Washington (UW) has a robust enterprise risk
management
(ERM) program that is moving into its seventh year. The
program began with
what administrators10 at UW call a “sentinel event,” settling a
Medicare and
Medicaid overbilling investigation by paying the largest fine by
a university for a
compliance failure—$35 million. This led the new president,
Mark Emmert, to for-
mally charge senior administrators in 2005 with the task of
identifying best prac-
tices for “managing regulatory affairs at the institutional level
by using efficient
and effective management techniques” (UW ERM Annual
Report 2008, p. 4). At
the outset in 2006, the objective for UW was to “create an
excellent compliance
model built on best practices, while protecting its decentralize d,
collaborative, and
entrepreneurial culture” (Collaborative ERM Report 2006, p.
vi). The ERM pro-

cess at UW has been what Ann Anderson, associate vice
president and controller,
terms “a journey of discovery.” ERM has developed and
evolved at UW, mov-
ing from what UW administrators describe as an early
compliance phase, through
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a governance phase to a mega-risk phase. Currently, the
University of Washing-
ton is focused on two objectives: (1) strengthening oversight of
top risks, and (2)
enhancing coordination and integration of ERM activities with
decision-making
processes at the university. This case study will describe the
decision-making and
implementation process at UW, as well as outline various tools
and frameworks
that UW adopted and adapted for use not only in the higher
education setting in
general, but to fit specifically within the university’s
decentralized culture.
Institutional Profile
Founded in 1861, the University of Washington is a public
university enrolling
some 48,000 students and awarding approximately 10,000
degrees annually (see
Exhibit 9.4). The institution also serves approximately 47,000
extension students.

There are nearly 650 student athletes in UW’s 21 Division I
men’s and women’s
teams. There is a faculty/staff of over 40,000, making UW the
third-largest
employer in the state of Washington. The university is
comprised of three cam-
puses with 17 major schools and colleges and 13 registered
operations abroad. It
has a $5.3 billion annual budget, with $1.3 billion in externally
funded research and
$2.6 billion in clinical medical enterprise. UW has been the top
public university
in federal research funding every year since 1974 and has been
among the top five
universities, public and private, in federal funding since 1969.
The university has
an annual $9.0 billion economic impact on the state of
Washington.
Culture at UW
When appointed to serve on the President’s Advisory
Committee on ERM
(PACERM) in 2007, Professor Daniel Luchtel commented, in
the context of talking
about risk assessments, that “the number of issues and their
complexity is stun-
ning. The analogy that comes to mind is trying to get a drink of
water from a fire
hose” (2007 ERM Annual Report, p. 4). As with most higher
education institutions,
especially research universities, along with the core business of
the teaching and
learning of undergraduate and graduate students, the faculty are
focused on the
creation of new knowledge. “The University of Washington is a

decentralized yet
collaborative entity with an energetic, entrepreneurial culture.
The community
members are committed to rigor, integrity, innovation,
collegiality, inclusiveness,
and connectedness” (Collaborative Enterprise Risk Management
Final Report
2006, p. v).
Faculty innovation and the idea of compliance don’t always go
hand in hand
in higher education, and UW is no exception. Research
associate professor David
Lovell, vice-chair of the Faculty Senate in 2007–2008,
expresses it well:
“Compliance” [is] not necessarily a good word for faculty
members. . . . What lies
behind [that] is the high value faculty accord to personal
autonomy. . . . The notion
of a culture of compliance sounds like yet another extension of
impersonal, corpo-
rate control, shrinking the arena of self-expression in favor of
discipline and con-
formity. . . . Over the last ten months, I’ve come to understand
that you’re not here
to get in our way, but to make it possible for us faculty legally
to conduct the work
we came here to do. . . . I hope that working together, we can
try to spread such
understanding further, so that we can make compliance—or
whatever term you
choose—less threatening to faculty and frustrating to staff.
(Annual ERM Report
2008, pp. 6–7)

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26.3% ASIAN AMERICANS
UNDERGRADUATE
32,291
48,022 students were enrolled at the UW in the fall of 2009
STUDENTS
GRADUATE
11,592
PROFESSIONAL
1,907
11% ASIAN AMERICANS
11.7% UNDERREPRESENTED MINORITIES
5.2% INTERNATIONAL STUDENTS
19.2% ASIAN AMERICANS

WOMEN
55.8%
WOMEN
54%
WOMEN
52.4%
MEN
47.6%
MEN
46%
MEN
44.2%
GATES CAMBRIDGE
SCHOLARS
4MARSHALL
SCHOLARS
7RHODES
SCHOLARS
SCHOLARS

46
35
Exhibit 9.4 University of Washington Student Profile
From University of Washington Fact Book:
http://opb.washington.edu/content/factbook.
Organizationally, the institution is divided into silos, which has
historically
focused risk mitigation within those silos.
Implementation History at UW
On April 22, 2005, President Mark Emmert sent an e-mail to the
deans and cabinet
members in which he said: “With the most recent example of
compliance issues, we
have again been reminded that we have not yet created the
culture of compliance
that we have discussed on many occasions.” He went on to say
that “the creation
of a culture of compliance needs to be driven by our core values
and commitment
to doing things the right way, to being the best at all we do. . . .
We need to know
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that the manner in which we manage regulatory affairs is
consistent with the best

practices in existence.”
The Sentinel Event: Largest Fine at a Medical School
The Collaborative Enterprise Risk Management Report for the
University of Wash-
ington (2006) began with the following: “Over the past few
years, the UW has
been confronted by a series of problems with institution-wide
implications, includ-
ing research compliance, financial stewardship, privacy matters,
and protection of
vulnerable populations” (p. v). The situation with the highest
impact on the uni-
versity began when Mark Erickson, a UW compliance officer,
filed a complaint
alleging fraud in the UW’s Medicare and Medicaid billing
practices. The 1999 com-
plaint prompted a criminal investigation, guilty pleas from two
doctors, and a
civil lawsuit resulting in the $35 million settlement, the largest
settlement made
by an academic medical center in the nation. The federal
prosecutor claimed that
“many people within the medical centers were aware of the
billing problems”
and that “despite this knowledge, the centers did not take
adequate steps to cor-
rect them” (Chan 2004). UW’s 2006 ERM Annual Report
acknowledges that, in
addition to the direct cost of the fines, there were also indirect
costs in terms of
additional resources for reviews of university procedures,
increased rigor and fre-
quency of audits, and an incalculable damage to the university’s
reputation. The
federal prosecutor acknowledged that UW’s efforts to reform its

compliance pro-
gram have been “outstanding” (Chan 2004). He further noted
that since the law-
suit was filed, the university “has radically restructured their
compliance office.
The government is very pleased with the efforts the UW is
taking to take care of
these errors.”
Leadership from the Top: President Outlines the Charge
At the time of the medical billing scandal, Lee L. Huntsman was
president of
UW. Huntsman had formerly been the acting provost, associate
dean for scien-
tific affairs at the school of medicine, and a professor of
bioengineering. The UW
Board of Regents had appointed Huntsman in a special session
when Richard
McCormick, the incumbent, accepted the presidency at Rutgers.
Huntsman served
for 18 months as president and continued as Special Assistant to
the President and
Provost for Administrative Transition until 2005 and as a senior
adviser to the uni-
versity for several more years. Mark A. Emmert, former
chancellor of Louisiana
State University and a UW alumnus, was appointed as the 30th
president of UW
and professor with tenure at the Evans School on June 14, 2004.
In April 2005, President Emmert charged V’Ella Warren, Vice
President
for Financial Management, and David Hodge, Dean of the
College of Arts and
Sciences, with conducting a preliminary review of best practices

in compliance
and enterprise risk management in corporate and higher
education institutions.
Warren engaged the Executive Director of Risk Management,
Elizabeth Cherry,
and the Executive Director of Internal Audit, Maureen Rhea, to
conduct a literature
search on enterprise risk management, particularly in higher
education. Cherry
and Rhea engaged Andrew Faris, risk management analyst, to
assist, and the three
spent nearly two years (from 2004 to 2006) conducting the
literature search and
finding out how risk management was functioning on other
campuses. As they
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conducted their research, they continued to report their findings
to Vice President
Warren. They also piloted the risk assessment process with
various departments
at UW.
Based on their findings and discussions with Vice President
Warren, a draft
report was compiled to provide initial guidance of the
development of a UW-
specific framework. The report provided an overview of various
approaches to
compliance, described best practices at four peer universities
(University of Texas

system, University of Minnesota, University of Pennsylvania,
and Stanford Uni-
versity), identified the common problems encountered in several
recent compli-
ance problems at UW, and offered suggestions for actions that
UW might take in
the effective management of compliance and risk. President
Emmert then charged
Warren and Hodge to cochair the recommended Strategic Risk
Initiative Review
Committee (SRIRC). The role of the SRIRC was to continue to
investigate best prac-
tices in university risk management and make recommendations
about a structure
and framework for compliance that would fit the UW culture. In
a memo to the
SRIRC regarding that review, Warren and Hodge noted that they
had “developed
a framework for university-wide risk and compliance
management which builds
on [UW]’s decentralized and collaborative character.” President
Emmert also made
it clear that the proposed model should be driven by UW’s core
values as well as
promote “effective use of people’s time and energy.” In a memo
to the deans and
cabinet members in 2005, President Emmert declared that UW
did not “want or
need another layer of bureaucracy.”
The SRIRC was comprised of broad university representation,
including
the Executive Vice President, the Associate Vice President for
Medical Affairs,
the Senior Assistant Attorney General, the Vice Provost-elect
for Research, the

Vice Provost for Planning and Budgeting, the Chancellor of the
University of
Washington–Tacoma, the Athletic Director, the Dean of the
School of Public Health
and Community Medicine, the Provost and Vice President for
Academic Affairs,
the Dean of the School of Nursing, the Special Assistant to the
President for Exter-
nal Affairs, the Vice President of Student Affairs, two faculty
members, and two
students. Meeting throughout the fall semester, the SRIRC
reviewed the prelim-
inary research material provided by Hodge and Warren and their
team and dis-
cussed a variety of issues, including the structure for risk
management, how risk
assessment has been and could be conducted, communication
issues, methods for
reporting risks, ways to report progress, and others. For each
initiative, they asked
the following three questions: Does this proposal add value?
What obstacles are appar-
ent and how can they be addressed? How could this proposal be
improved?
In addition to formal meetings, Cherry, Rhea, and Faris
conducted one-on-one
meetings with the SRIRC members to gather more information
about how they
viewed implementation at the university. Because one of the
recommenda-
tions was the creation of a Compliance Council, meetings were
also conducted
throughout the campus with director-level personnel to survey
their interests
and suggestions regarding that aspect of the proposed model.

Prior to the formal
implementation of the ERM program, resources were also
dedicated to create an
infrastructure to sustain the recommended model. Faris’s role as
risk manager
was formally revised to create a full-time ERM analyst position
within the Office
of Financial Management in the Finance and Facilities division
and a half-time
ERM project manager position was created, filled by Kerry
Kahl.
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Advisory Committee Recommendations: Create a
Culture-Specific ERM Program
In February 2006, Hodge and Warren put forth to President
Emmert a Collabora-
tive Enterprise Risk Management Proposal developed by the
SRIRC. The proposal
recommended that “the UW adopt an integrated approach to
managing risk and
compliance, commonly called enterprise risk management
(ERM).” They acknowl-
edged that the proposed changes were not intended to “replace
what already
works across the university,” but rather to “augment the
existing organization with
thoughtful direction, collaboration, and communication on
strategic risks” (Collab-
orative ERM Final Report, February 13, 2006). At the outset,

the SRIRC acknowl-
edged that the structure and priorities of the ERM program
would likely evolve
and develop over time, but the members of the committee were
confident that
they had created a “strong, yet flexible framework within which
to balance risk
and opportunity” (February 14, 2006, memo to President
Emmert).
While the report acknowledged the impetus for the creation of
the ERM pro-
gram (the $35 million compliance failure fine), it focused on the
positive impact
an ERM program could have for UW, beyond addressing
compliance concerns.
The report defined key terms and made recommendations based
on three basic
parameters: scope of the framework, organizational structure for
the framework,
and philosophy of the program. Each aspect was framed in the
context of the liter-
ature review and campus comparisons; UW-specific
recommendations were put
forth based on SRIRC discussion and analysis.
Scope of the Risk Framework
The report reviewed and discussed the various approaches taken
by organizations
in practicing risk management, from a basic practice of risk
transfer through insur-
ance to a more integrated institution-wide approach. It
acknowledged that, prior
to implementation, some key decisions would need to be made:
Would the scope

of the program be institution-wide or targeted at the school,
college, or unit level?
Would it include all risks (compliance, finances, operations, and
strategy) or be
focused on certain categories of risk? ERM was cited as “the
most advanced point
on the continuum,” a model that integrates risk into the
organization’s strategic
discussions. The report also summarized a Centralized
Compliance Management
approach. This model, rather than encompassing all risks, would
focus primarily
on legal and regulatory compliance. It was noted that “while
both are university-
wide approaches, they vary in a number of important aspects,
including scope,
objective, and benefits” (p. 6).
The report also summarized the ERM models at four IHEs,
based on interviews
with compliance and audit managers at those institutions.
Noting that all four were
institution-wide approaches, Pennsylvania and Texas were
identified as having
adopted a more corporate philosophy; Minnesota, a compliance
approach with a
centralized style; and Stanford, a collaborative ERM approach
(see Exhibit 9.5). The
report recommended developing a “collaborative, institution-
wide risk manage-
ment model” for UW, one that “ensures that UW creates an
excellent compliance
model based on best practices, while protecting its
decentralized, collaborative,
and entrepreneurial culture” (p. 28).

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Minnesota
Stanford
Pennsylvania
Texas•
•
•
•
Washington
Enterprise
Risk
Management
Centralized
Compliance
Management
Control

Collaboration
Exhibit 9.5 UW’s Approach to Risk Management Compared to
Other Institutions
From University of Washington Collaborative Enterprise Risk
Management Final Report, February 13,
2006.
Organizational Structure
Based on a review of the literature and discussions with risk and
audit managers
at other universities, the report also summarized various models
and structures
for organizing the risk management activities. One method was
to appoint a cen-
tral risk officer with institution-wide oversight and
responsibility. With this model,
key decisions would need to be made regarding reporting lines
and the placement
of that position within the organization. The report also outlined
UW’s current
approach to risk management, noting that it had moved beyond
the insurance
approach, “which is usually reactive and ad hoc,” but also
observing that respon-
sibility for specific risks was currently distributed among the
institution’s orga-
nizational silos (p. 15). It further noted that “the UW does not
formally integrate
risk and compliance into its strategic conversations at the
university-wide level”
(p. 15). While acknowledging the good progress being made in
several areas
(including UW Medicine, the newly restructured Department of
Audits, and the

Office of Risk Management), the report highlighted the
weaknesses of the current
approach, including the fact that “due to the size,
decentralization, and complexity
of the institution, a proliferation of compliance, audit, and risk
management activ-
ities has grown up around separate and distinct risk areas, each
largely operating
in a self-defined stovepipe” (p. 18).
Philosophy of the Program
The report also discussed the philosophy of a proposed risk
management pro-
gram, asking whether the preferred approach should focus on
enforcing law and
regulation—a compliance or control approach—or be one that
“encouraged coop-
eration between faculty and staff to develop flexible compliance
approaches—a
collaborative approach” (p. 2). After sharing the findings from
the literature review
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and the institutional profiles of the peer institutions, the report
outlined three guid-
ing principles to shape the evolution of compliance and risk
management at UW:
(1) foster an institution-wide perspective, (2) ensure that
regulatory management
is consistent with best practices, and (3) protect UW’s

decentralized, collaborative,
entrepreneurial culture. In light of these principles, the report
made the following
eight recommendations, detailing the key elements and
implementation sugges-
tions for each:
1. Integrate key risks into the decision-making deliberations of
senior leaders
and Regents.
2. Create an integrated, institution-wide approach to
compliance.
3. Ensure that good information is available for the campus
community.
4. Create a safe way for interested parties to report problems.
5. Minimize surprises by identifying emerging compliance and
risk issues.
6. Recommend solutions to appropriate decision makers.
7. Check progress on compliance and risk initiatives.
8. Maintain a strong audit team.
EVOLUTION OF ERM AT UW
The SRIRC report acknowledged that the ERM concept was not
new, but that it has
not been fully implemented at many organizations, especially in
higher education.
The development of risk management within an organization
was discussed, not-
ing that the management of risk develops along a continuum,
with early mod-
els focused on hazard risks only and mitigation being
accomplished primarily
through the purchase of insurance. As risk models evolve at an
organization, other
risk types are added to the model and more cross-functional

participation by other
units begins to occur. Ultimately, strategic risks are added to
the conversation and
there is an integration of information from all units across the
university. It is at
this point that risk can be viewed as both an opportunity and a
threat and where
mitigation priorities can be more clearly linked to the strategic
objectives of the
organization.
In 2006, when the ERM program and model were proposed, UW
viewed itself
as being in the middle of the continuum (see Exhibit 9.6). The
report noted:
Although many operational units, committees, and
administrative bodies handled
the risks faced in their own environments well, there is little
cross-functional shar-
ing of information. The opportunity aspect of risk is therefore
not fully utilized
by the University and risk mitigation priorities are not
consistently driven by the
institution’s strategic objectives. (p. 4)
The 2012 ERM Annual Report observes that “the ERM program
has continued
to evolve, developing structural mechanisms to support the 8
initial recommenda-
tions” (p. 2).
Faris and Kahl commented that the first few years of
implementation of ERM
at UW were focused on risk assessments. They spent most of
their time (both work-

ing with the ERM committees and in their roles as ERM staff)
performing risk
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UW Evolution of ERM
Risk Categories
Strategic – Mega
Financial
Operational
Compliance
Separate Partial Full
Functions - - - - - Integration - - - - -
Degree of Cross - Functional Integration
What we have accomplished
Where UW’s program is headed
Exhibit 9.6 Evolution of ERM at the University of Washington
From University of Washington 2009 ERM Annual Report, p. 4.
assessments using the risk mapping process (e.g., writing a risk
statement, ranking
the risks for likelihood and impact, plotting the risks on a 5 × 5

map). In the first
four or five years, they conducted nearly 35 risk assessments
across the univer-
sity. Based on broad cross-functional topics identified by the
President’s Advisory
Committee on ERM (PACERM), the risk assessments were
facilitated by Faris and
Kahl with temporary teams put together to meet three to five
times over the course
of the year to write risk statements, rank them, and put together
suggestions for
mitigation.
The first five years of ERM at UW were “formative” and
focused on the fol-
lowing key activities:
� Developing a common language around risk
� Conducting individual risk assessments
� Focusing discussion and mitigation on financial and
enrollment challenges
� Comparing financial strength (as gauged by Moody’s
Investors Service)
against peers
� Drafting an initial compendium of enterprise-wide success
metrics
Well-written, clear annual reports to the president, the Board of
Regents, and
the UW community helped to connect the dots and keep the
strategic overar-
ching goals front and center, even as employees at the unit level
were continu-
ously engaged in the more operational aspects of ERM. Exhibit
9.7 summarizes

the implementation time line from the formalized inception of
ERM at UW to the
present. A review of the chart shows how the UW has continued
to focus on mov-
ing from an initial focus on hazard risk to a more integrated,
strategic approach to
enterprise risk management.
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Exhibit 9.7 University of Washington ERM Implementation
Time Line
Academic
Year Initiatives∗
2005–2006 President Emmert charged administrators with
review of best practices and
development of broad institutional compliance/risk framework
for UW.
Warren and Hodge drafted report with overview of institution-
wide
approaches, best practices at four peer universities, common
compliance
problems faced by UW, and suggestions for next steps.
2006–2007 Developed a central focus and common language for
evaluating risk across
the university.
ERM structure formed (including PACERM, Compliance

Council).
First UW-wide risk map was compiled.
Office of Risk Management dedicated one FTE to ERM
initiative.
Dedicated $4.8 million in funds for
integrity/compliance/stewardship
initiatives, including animal care, student life counseling,
human subjects,
global activities, and IT security.
Information about ERM program included in reinsurance
renewal
discussions with international underwriters.
First Annual Report to the Board of Regents.
2007–2008 Identified key strategic and mega risks for the
institution.
Expanded Compliance Council to form COFi.
Rolled out Enterprise Risk Management Toolkit for units to do
self-assessments.
UW Medicine and Department of Athletics presented annual
reports on their
compliance programs and ongoing efforts to minimize risks and
address
current issues.
Continued development of the Institutional Risk Register.
Internal Audit department expanded from nine to 15 staff.
2008–2009 Focused on financial crisis and demographics.
PACERM formed two mega-risk subgroups to apply ERM
processes at a

strategic level: extended financial crisis and faculty recruitment
and
retention.
HR advance planning for economic downturn and major
reduction in state
funding.
Office of Risk Management conducted first Employment
Practices Liability
Seminar.
ERM web pages were enhanced.
Hired a new Executive Director for Audits.
Second ERM Report to the Board of Regents.
2009–2010 Development of the UW Integrated Framework
based on COSO model.
PACERM focused discussion on how to remain competitive.
Initial exploration of enterprise-wide dashboard of success
metrics.
Use of risk assessments in business case alternatives and
research proposals.
2010–2011 PACERM evaluated the university’s academic
personnel profile and oversaw
major information technology projects.
Assessed institutional financial strength in comparison to peers
(Moody’s).
More than 200 ERM Toolkits provided to universities and
companies.
2011–2012 Development of enterprise-wide dashboard of
success metrics.

UW’s work recognized as a “Best Practice” by the Association
of Governing
Boards for Universities and Colleges (AGB).
∗ All initiatives, including others not detailed in this chart, are
outlined in more detail in the UW ERM
Annual Reports, available at the website:
http://f2.washington.edu/fm/erm.
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ERM STRUCTURE AT UW
The organizational structure for ERM at UW arose out of the
initial recommen-
dations of the SRIRC. In its aggregate, the UW ERM program is
comprised of the
following areas, working together to create an effective
structure: UW units; ERM
staff; Compliance, Operations, and Finance Council (COFi
Council); President’s
Advisory Committee on ERM (PACERM); Internal Audit; and
the UW President
and Provost (see Exhibit 9.8).
UW Units
At the unit level, staff and faculty take ownership of the
activities that give rise
to risk. They conduct risk and opportunities identification and
self-assessments.
They develop strategies and take action to mitigate and monitor

risk. They are
encouraged to share a summary of their risk assessments with
the Office of Risk
Management.
ERM Program Staff
There are 1.5 full-time equivalent (FTE) ERM program staff
located in the office of
the associate vice president/controller for UW. This staff
supports the work of the
various committees and units, in part by establishing the ERM
framework, stan-
dards, and templates. They monitor and participate in risk
assessments for the pur-
pose of providing the enterprise view. They provide
administrative support and
University President and Provost UW Environment (e.g., right
side of cube)
President’s Advisory Committee
on Enterprise Risk Management (PACERM)
Entity Level
(e.g., top-down view of strategic risks,
mega risks, and opportunities)
Compliance, Operations, Finance Council (COFi)
Division or Function Level
(e.g., middle up, cross-functional view of
compliance, operations, and financial risks)

Research
Academic
Affairs
Athletics
Health
Care
Risk and
Safety
Finance
Information
Technology
Human
Resources
Eight functional areas of risk
Core Functions Support Services
Attorney
General
Risk
Management
Environmental
Health & Safety

Unit Level
(e.g., bottom-up view of risks and opportunities)
Examples of UW Units
Exhibit 9.8 University of Washington ERM Structure
From University of Washington 2010 ERM Annual Report, p.
10.
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summary information and analyses to the ERM committees.
They also provide
professional development in a train-the-trainer format.
Compliance, Operations, and Finance Council (COFi)
The COFi Council, led by the Executive Director of Audits,
takes a middle-up,
cross-functional view of risks and opportunities, particularly
items that have
university-wide potential impact or where supervisory authority
for various
aspects of the risk reside in different departments or divisions
across the univer-
sity. The COFi Council has oversight of risk assessments at the
division or func-
tional level. It provides approval of methods to monitor risks
and identifies topics
for outreach, particularly items that have university-wide
potential impact or that
involve cross-departmental or divisional silos. The six primary

goals of the COFi
Council are to:
1. Engage in a continual, cross-functional process that results in
effective prior-
itization of institutional responses to compliance, financial, and
operational
risks, and consider the impact to strategic and reputational
risks.
2. Ensure that the institutional perspective is always present in
risk and com-
pliance management discussions.
3. Identify strategies to address emerging risks and compliance
management
issues.
4. Support risk and compliance management training and
outreach efforts
throughout the university.
5. Provide external auditors and regulators with information
about the uni-
versity’s risk and compliance programs.
6. Avoid the creation of additional bureaucracy by minimizing
redundancy
and maximizing resources.
President’s Advisory Committee on ERM (PACERM)
PACERM, cochaired by the Provost and the Senior Vice
President for Finance and
Facilities, has oversight of risk assessments at the entity level.
Taking a top-down

view of risks and opportunities, PACERM advises the university
president and
other senior leaders on the management of risks and
opportunities that may signif-
icantly impact strategic goals and/or priorities. They review the
ERM dashboard
(e.g., key risk indicators and key performance indicators).
According to V’Ella
Warren and Ana Mari Cauce, cochairs of PACERM in 2008–
2009, PACERM “is the
one place where participants set aside their individual
organizational perspectives,
and really think about the major risks and opportunities from an
institution-wide
view” (2009 ERM Annual Report, p. 6).
Internal Audit
Internal Audit provides independent verification and testing of
internal controls.
The department also provides administrative support and
summary information
to the COFi Council.
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UW President and Provost
The President and Provost play a key role in acknowledging,
validating, and sup-
porting the ERM program. They verbally refer to key documents
such as the ERM

framework, PACERM and COFi Council charters and
assessments, and the ERM
dashboard. They provide entity-level reporting to the Regents.
UW’S ERM MODEL
After a careful review of models in the corporate sector and
within higher educa-
tion, UW settled on the following regarding its ERM model:
� Assess risks in the context of strategic objectives, and
identify interrelation
of risk factors across the institution, not only by function.
� Cover all types of risk: compliance, financial, operational,
and strategic.
� Foster a common awareness that allows individuals to focus
attention on
risks with strategic impacts.
� Enhance and strengthen UW’s culture of compliance while
protecting the
decentralized, collaborative, entrepreneurial nature of the
institution.
Adopting and Adapting the COSO Model
UW has defined ERM according to its interpretation of the
Committee of Spon-
soring Organizations (COSO) model, adapting the framework to
fit the university
environment and the UW in particular (see Exhibit 9.9). COSO
describes ERM
University of Washington

Enterprise Risk Management – Integrated Framework
O
pe
ra
tio
ns
ERM
Process
Risk
Categories
Leadership, Culture, Values
Strategic Goals
Risk / Opportunity Identification
Risk / Opportunity Assessment
A
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rn
a
tiv
e
s

U
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it L
e
v
e
l
D
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n
L
e
v
e
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E
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L
e
v
e
lResponse
Control Activities
Information & Communication
Monitoring & Measuring
UW
E
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a
Exhibit 9.9 University of Washington’s ERM Integrated
Framework
From University of Washington Enterprise Risk Management
Toolkit, p. 7. Copyright 2007, University
of Washington.
www.it-ebooks.info
as “a process, effected by an entity’s board of directors,
management, and other
personnel, applied in strategy setting and across the enterprise,
designed to
identify potential events that may affect the entity, and manage
risk to be within
its risk appetite, to provide reasonable assurance regarding the

achievement of
entity objectives” (COSO 2004). Adopted in 2009–2010, the
2010 ERM Annual
Report notes:
The UW ERM Integrated Framework offers a schema to
integrate the views of risk
that have historically been addressed in silos or through a
fragmented approach.
The ERM framework bridges the gap between lower-level issues
and upper-level
issues, and it allows us to be explicit about the multiple levels
on which the ERM
process is deployed as a risk and/or opportunity management
mechanism. (p. 4)
Risk Categories
The top of the cube identifies risk types, including compliance,
operations, and
financial risks. Strategic risks can impact the mission. Mega
risks are major external
events over which the institution has no control, but for which
the institution can
prepare.
UW Environment
The right side of the cube views the organizational structure at
three levels: entity,
which entails all operations and programs; division or function,
looking at a major
risk in depth; and unit, where individual departments can use
the tools to assess
their risks. A fourth level of ERM used in the UW environment
is to evaluate
alternatives.

ERM Process
The front of the cube outlines the traditional eight steps from
the COSO model,
including setting the tone and context for ERM at the top,
identifying risks in con-
junction with strategic goals, and through the complete cycle
with implementation
and follow-up.
The report notes:
UW’s “cube” integrates the several ERM facets into a whole,
and enables ERM to
be applied in a very intentional manner: Starting any new risk
assessment requires
identifying the appropriate level of the organization or
environment at which the
assessment will be made; focusing on which set of risks
(compliance—strategic—
mega risks) to cover; and applying all the steps in the ERM
cycle to ensure a com-
plete assessment and follow through.
The UW views ERM as integrating risk discussions into
strategic deliberations
and identifying the interrelation of risk factors across activities.
Using the COSO
model, its eight-step process involves the following (see Exhibit
9.10):
1. Leadership, culture, and values. Setting the tone at the top.
2. Strategic goals. At the entity or institutional level (top
down), the division
or function level (risk topic across shared goals of VPs and
deans—”middle

up”), the unit level (such as a department, school, or college—
bottom up),
or the alternatives level (investment alternatives or business
options).
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ERM PROCESS
Leadership, Culture
and Values
Strategic
Goals
Risk
Identification
Risk
Assessment
Controls
Response
Monitoring and
Measuring

Information and
Communication
Exhibit 9.10 University of Washington ERM Process
Toolkit, p. 8. Copyright 2007, the
University of Washington.
3. Risk identification. In the appropriate context, name the
harm, loss, or com-
pliance violation to avoid, as well as the opportunities to be
identified.
This typically begins with listing broad risk activities or subject
areas. Risks
can be identified at the entity, division, functional, unit, or
alternatives
level. This process includes the use of risk statements and
opportunity
identification.
4. Risk assessment. In the appropriate context, analyze the risk
or opportunity
in terms of likelihood and impact (see Exhibit 9.11). Create a
risk map, rank-
ing or prioritizing risks to inform decisions regarding response.
For oppor-
tunities, rate the likelihood of occurrence on a scale of 1 to 5 (1
= rare, not
expected to occur in the next five years; 5 = almost certain,
expected to occur
more than once per year). Also rank the positive impact,
considering what
impact the opportunity would have on the institution’s ability to
achieve
goals or objectives (1 = insignificant, with little or no impact on

objectives
and no impact to reputation and image; 5 = outstanding, could
significantly
enhance the capability to meet objectives and could
significantly enhance
reputation and image).
5. Response. Selecting the appropriate response involves
comparing the cost
of implementing the option against benefits derived from it.
Responses
include avoid, mitigate, transfer, or accept the risk. For
opportunities, the
response can be exploit, enhance, share, or ignore.
6. Controls. Document internal controls for top risks, and rank
for effective-
ness. For UW, internal controls are narrowly defined to describe
the meth-
ods used by staff or faculty that help ensure the achievement of
goals and
objectives, such as policies, procedures, training, and
operational and phys-
ical barriers.
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IM
P
A
C

T
Catastrophic
- 5 -
Disastrous
- 4 -
Serious
- 3 -
Minor
- 2 -
Insignificant
- 1 -
5
4
3
2
1
Rare
- 1 -
10
8
6

4
2
Unlikely
- 2 -
15
12
9
6
3
Possible
- 3 -
20
16
12
8
4
Likely
- 4 -
25

20
15
10
5
Almost Certain
- 5 -
LIKELIHOOD
Risk Level
Extreme
High
Substantial
Medium
Low
Score Range
19.5 – 25
12.5 – 19.4
9.5 – 12.4
4.5 – 9.4
1 – 4.4

Exhibit 9.11 University of Washington Risk Assessment:
Likelihood and Impact
Toolkit, p. 17. Copyright 2007, the
University of Washington.
7. Information and communication. Communicate with
stakeholders and take
action (the transition from analysis to action). Designate a risk
owner for
each of the top risks.
8. Monitoring and measuring. Monitor performance to confirm
achievement
of goals and objectives, and monitor risk to track activities that
prevent
achievement of goals and objectives.
Tools and Techniques
As its ERM program has developed and evolved, UW has
learned from its expe-
rience and is positioned to share information not only
internally, but with oth-
ers in higher education as well. The university has developed a
comprehensive
Enterprise Risk Management Toolkit, copyrighted in 2007, with
the second edition
released in 2010. The second edition includes an expanded
section on the ERM pro-
cess and has new material on evaluating opportunities. It is
comprised of a manual
and a set of spreadsheets that provides a framework for
assessing and understand-
ing institutional risks. The UW allows access to the Toolkit for

UW staff, faculty,
and students, federal agencies, Washington State agencies, and
other institutions
of higher education at no charge through the UW Center for
Commercialization
Express Licensing Program.
As is typical with most universities, the tools utilized by UW
for conducting
the risk assessment process are Microsoft Office products.
Excel is used to catalog
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risk assessment inventories and Word for report writing. While
the administrators
have explored many options for software to aid in the process
(and to potentially
provide outcomes such as dashboards), they find that, having
been developed in
the corporate for-profit environment, none of those options are
particularly suited
to capturing the needs of the higher education environment.
They note, however,
that at the unit level, many departments are investing in unit-
specific software to
aid in their data management. For example, the Finance and
Budgeting Office is
investigating software to run stress tests and financial
simulations, and the Human
Resources Office is examining payroll software. This allow s the
units to be able to

more quickly evaluate risk specific to their areas, but UW finds
that its ability to
aggregate risks for examination at the entity level can be
accomplished effectively
with its low-tech process.
OUTCOMES AND LESSONS LEARNED
UW administrators can chart the evolution of their ERM
program and the effec-
tiveness it has on the university. They note that the early wins
were at the unit
level, when specific departments, such as Information Security
and Environmental
Health and Safety, integrated the ERM process with their well-
established strategic
planning processes. Those units used the risk assessment tools
to identify and rank
risks that could hinder or prevent the achievement of their
strategic goals. Integra-
tion of ERM at the entity level is happening more slowly, but
issues that impact
everyone at the UW, such as faculty recruitment and retention
or responding to
the external financial crisis, now can happen in a more
integrated fashion as the
understanding of ERM evolves. For several years, due to severe
budget reductions,
the Office of Planning and Budgeting consciously added some
questions about
risk assessment into the budget request process. Vice presidents
and deans were
asked to address the impact of budget reductions in terms of
risk. This happened,
in part, because two key members of the Budget and Planning
Office, as well as
the Provost, have been involved with the PACERM.

UW administrators have a few other observations about their
process and how
and why it has worked. First, they note that they were aware
from the outset that
the environment at UW is highly decentralized and that
appointing an “ERM czar”
or chief risk officer (CRO) wouldn’t fit with the culture. They
made a deliberate
choice not to formalize ERM through a senior-level position,
but rather to engage
in implementation through a committee structure. Second, they
involved faculty
members from the beginning. This helped with a sense of shared
purpose. Faculty
members came to see the business side of academia, and staff
and administrators
better understood the point of view of scholars engaged in
teaching and learning.
Third, the senior leadership has stayed dedicated to the ERM
process, even with
transitions in the president and other senior administrators. The
2011 ERM Annual
Report points out the benefits to the UW of the ERM approach:
The value of ERM is both qualitative (e.g., risk and opportunity
maps) and quanti-
tative (e.g., dashboards to contextualize and display metrics).
Qualitative benefits
accumulate because the risk mapping process allows groups
throughout the Uni-
versity to collectively prioritize issues, and ensure that the
effort and resources
involved in root cause analysis, measurement, and monitoring
are applied only

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to the most significant concerns. Each iteration of the ERM
process results in
new capabilities, and insight gained into maintaining the
University’s competitive
advantage—particularly from managing our financial risks and
strategic opportu-
nities better than our peers. (p. 5)
UW has been strategic, deliberate, and inclusive as it continues
on its journey
to develop and enhance its ERM program, learning lessons from
what works and
adapting new strategies in order to improve or modify its
program. ERM began
at UW in 2006 “by establishing a collaborative approach and
structure to consider
broad perspectives in identifying and assessing risk” (2012
Annual Report, p. 3).
This strategy has helped UW overcome some of the traditional
challenges fac-
ing universities when implementing ERM, including addressing
concerns about
the real effectiveness of risk assessment, getting agreement on
definitions of risk
assessment impact, identifying risk owners, and moving beyond
the “risk discus-
sion” to focus on mitigation (2012 Annual Report, p. 3). In her
November 2012 pre-
sentation on UW’s ERM program to the Pacific Northwest
Enterprise Risk Forum,

Ann Anderson, Associate VP and Controller, outlined the
following seven key
lessons that UW has learned by engaging in ERM for almost
eight years:
1. Clarify the roles of the various risk committees.
2. Develop a “work plan” for the committees.
3. Develop engaging agendas, focused at the appropriate level.
4. Don’t overemphasize “lowest common denominator” risks.
5. Gather data/information to develop expertise on specific
risks.
6. Avoid discussing low-level, narrow risks—too time-
consuming!
7. Don’t get into the weeds with implementation and process.
Delegate actions
to responsible parties.
WHAT NEXT?: CURRENT PRIORITIES
AND FUTURE DIRECTION
As the 2010 ERM Annual Report points out, the process of
involving people in
risk assessments, even with the most well-developed risk
assessment tools, is only
part of the process. “Successfully maintaining a large-scale
organizational initia-
tive such as ERM requires a comprehensive, broad based
approach that is widely
understood and used regularly to clearly articulate where risks
and opportunities
exist throughout the University” (p. 4). As ERM moves forward
at UW, the focus is
on a “greater refinement of institutional success metrics,
increased assessments of
risks identified, and continued expansion across the university
to incorporate risk

assessment into decision-making and strategic planning” (2012
Annual Report,
p. 2). The objectives for 2013–2014 are: (1) strengthen
oversight of the top risks and
(2) enhance coordination and integration of ERM activities with
decision-making
processes. Several initiatives will help UW achieve these
objectives, including seek-
ing input and approval from the PACERM in order to elevate
the monitoring of
the top risks; a comparison of the institutional-level risks with
unit-level risks; the
development of quantitative visual representations of the risks,
metrics, and tar-
gets; engaging the community more broadly in risk
management; integrating risk
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management with the budget and planning cycle for the
university; a retrospec-
tive analysis of risks and mitigation investments; and a forward-
looking analysis
to highlight gaps and areas of concern. They are also in the
process of developing
specific deliverables and measures as indicators of success,
such as executive-level
risk registers, dashboards of key risks, and a foundation and
structure to integrate
risk maps and dashboards with the planning and budgeting
cycle.

CONCLUSION
UW’s ERM implementation process and lessons learned are
consistent with the
guidance offered by the National Association of College and
University Attorneys
(NACUA). In a 2010 conference presentation, NACUA
identified the following
eight critical success factors:
1. Establish the right vision and realistic plan.
2. Obtain senior leadership buy-in and direction.
3. Align with mission and strategic objectives.
4. Attack silos at the outset.
5. Set objectives and performance indicators.
6. Stay focused on results.
7. Communicate vision and key outcomes.
8. Develop a sustainable process versus a one-time project.
While complex and time-consuming, effective development of a
culture-
specific ERM program can have positive outcomes for colleges
and universities.
Institutions such as UW that view ERM as a long-term
investment in institutional
health, rather than a fad or simply a set of tools (such as
spreadsheets and heat
maps), position themselves well not only to respond to the
external demands from
credit ratings agencies, accreditors, and federal regulators, but
to situate them-
selves to make key strategic decisions, informed by both
quantitative and qual-
itative data, to enhance their organization, leading to increased
enrollment and
graduation and strategic disbursement of resources for teaching
and research, as

well as increasing the likelihood that, due to their integrated,
proactive approach,
they will avoid future compliance scandals. Perhaps the two
most important deliv-
erables on UW’s 2013–2014 agenda are those that demonstrate
its awareness of
the importance of the human resources component in its
collegial environment:
outreach to faculty and other administrators to obtain broader
validation of risks
and to identify additional mitigation activities, and an iterative
process to involve
senior leaders, the Provost, the President, and the Regents in
monitoring the top
risks. Through this process, UW is building a culture not only
of compliance, but
of shared responsibility for the future health of the university.
QUESTIONS
1. How does ERM adoption and implementation in the higher
education environment
differ from the for-profit environment?
2. What type of culture is at the University of Washington? Why
is culture important to
consider when implementing ERM?
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3. What were some of the key factors in the early stages of
UW’s ERM adoption and imple-

mentation that led to its current success within the
organization?
4. Why did UW decide to adopt a committee structure to
administer its ERM program
rather than designate a senior level Chief Risk Officer?
5. Who are some of the key players involved in the decision-
making about the ERM model
and its current administration?
NOTES
1. Many colleges and universities were affected by Hurricane
Katrina in the New Orleans
area (see the American Association of University Professors
[AAUP] Special Commit-
tee Report on Hurricane Katrina and New Orleans Universities
at https://portfolio
.du.edu/downloadItem/92556). The independent report by Louis
Freeh and his law
firm, Freeh Sporkin & Sullivan, LLP, documents the facts and
circumstances of the
actions of Pennsylvania State University surrounding the child
abuse committed by
a former employee, Gerald A. Sandusky (available at
http://progress.psu.edu/the-
freeh-report). The AAUP’s Committee on College and
University Governance
reported on breakdowns in governance at the University of
Virginia as the
board attempted to remove president Sullivan
(www.aaup.org/report/college-
and-university-governance-university-virginia-governing-
board). American Univer-
sity trustees removed then president Ladner in 2005 after

investigation of expense
abuses of university funds
(http://usatoday30.usatoday.com/news/education/2005-
10-11-au-president_x.htm). The most tragic of these situations
was, of course, the shoot-
ings at Virginia Tech on April 16, 2007. On December 9, 2010,
the U.S. Department of
Education issued a final ruling that Virginia Tech had violated
the Clery Act by fail-
ing to issue a “timely warning” to students and other members
of the campus commu-
nity following the initial shootings early on the morning of
April 16, 2007. In comment-
ing on the verdict, Stetson Professor of Law Peter Lake stated,
“Higher education is
under the microscope now. The accountability level has
definitely changed” (S. Lipka,
“Jury Holds Virginia Tech Accountable for Students’ Deaths,
Raising Expectations at
Colleges,” Chronicle of Higher Education, March 14, 2010).
2. In order to disperse federal financial aid and grant degrees,
institutions in the
United States are accredited by one of several accrediting
bodies. One example of
the way in which accreditors are emphasizing risk management
in their review is the
Southern Association of Colleges and Schools Commission on
Colleges (SACS COC)
(www.sacscoc.org/) Standard 3.10.4: The institution
demonstrates control over all of
its physical and financial resources. The University of Virginia
demonstrates evidence
of this standard on its website by articulating the organizational
structure and inte-
grated policies and procedures related to internal and external

audit, internal controls,
fixed assets, procurement, facilities management, and risk
management, among others
(www.virginia.edu/sacs/standards/3-10-4.html).
3. The recent Special Comment by Moody’s, “Governance and
Management: The Under-
pinnings of University Credit Ratings,” declares that
“governance and management
assessments often account for a notch or more in the final rating
outcome compared
with the rating that would be indicated by purely quantitative
ratio analysis” (Kedem
2010, p. 1). In Moody’s consideration of five broad factors that
contribute to its eval-
uation of governance and management, the report cites
“oversight and disclosure
processes that reduce risk and enhance operational
effectiveness” (p. 2). The report
further notes: “Effective internal controls and timely external
disclosure about stu-
dent outcomes, research productivity, financial performance,
and organizational effi-
ciency will become the hallmark of effective university
leadership and will become
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increasingly critical in mitigating new risks to individual
universities and the sector
overall” (p. 3).

4. One significant area of change has been the Internal Revenue
Service’s increased over-
sight of compliance issues affecting tax-exempt entities,
including colleges and univer-
sities. In 2008, under prompting by members of the U.S. Senate
Finance Committee, the
IRS developed a 33-page compliance questionnaire (IRS Form
14018) and sent it to a
cross section of 400 institutions of higher education. The form
focused on a number of
potentially sensitive subjects, including the types and amounts
of executive compen-
sation, the investment and use of endowment funds, and the
relationship between an
institution’s exempt activities and other taxable business
activities. The IRS also revised
its Form 990, “Return of Organization Exempt from Income
Tax,” beginning with the
2008 tax year. The purpose of the changes is to increase the
transparency and account-
ability of tax-exempt organizations and to ensure compliance
with the Internal Revenue
Code by requiring more detailed information in several
categories. The changes focus
not only on revenue, investment, and spending issues, but also
on governance, conflicts
of interest, and whistle-blower policies and procedures.
5. Based on a March 13, 2012, phone interview.
6. The Higher Education Act, up for renewal again in 2014, is a
law almost 50 years old
that governs the nation’s student-aid programs and federal aid
to colleges. It was signed
into law in 1965 as part of President Johnson’s Great Society
agenda of domestic pro-

grams, and it has been reauthorized nine times since then, most
recently in 2008. Addi-
tional examples at the federal level include Section 504 of the
Rehabilitation Act of 1973,
the Americans with Disabilities Act (ADA) (1990), Family
Educational Rights and Pri-
vacy Act (FERPA) (1974, 1998, 2009), Health Insurance
Portability and Accountability
Act (HIPAA) (1996), Clery Act (1990), and Campus Sex Crimes
Prevention Act (2000),
among others. Lawsuits brought against institutions of higher
education in which they
and/or certain administrators at those institutions are accused of
violating a particular
federal law or a related legal right can lead to case decisions
that impact that institution
and perhaps others. Lawsuits can also have a significant impact
even if they result in a
settlement rather than a court decision. In May 2006, a group of
12 current and former
deaf students at Utah State University sued the institution in
U.S. District Court alleg-
ing that it had violated the Rehabilitation Act and the ADA by
failing to provide enough
fully qualified interpreters. The lawsuit also named the Utah
State Board of Regents as
defendants. After negotiations, the lawsuit was settled in April
2007 with the univer-
sity agreeing to hire qualified, full-time interpreters at a ratio of
one translator for every
two deaf students. The lawsuit, the issues it raised, and its
ultimate resolution received
significant media attention, as well as attention from various
organizations around the
country promoting the interests of students who are deaf or have
hearing deficiencies.

7. Mitroff, Diamond, and Alpaslan (2006) note that “colleges
and universities are in the
very early stages of establishing their crisis management
programs, and much remains
to be done. The recent experience in New Orleans and
elsewhere suggests that develop-
ing and maintaining a well-functioning crisis management
program is an operational
imperative for college and university leaders” (p. 67).
8. One of those administrators was Elizabeth Cherry, Director
of Risk Management, from
the University of Washington (UW). As will be discussed in the
case study, the UW was
embroiled in several high-profile risk situations at the time and
was undergoing the first
of several presidential transitions.
9. See A. P. Liebenberg and R. E. Hoyt, “The Determinants of
Enterprise Risk Management:
Evidence from the Appointment of Chief Risk Officers,” Risk
Management and Insurance
Review 6:1 (2003): 37–52. Their study uses a logistic model to
examine the characteristics
of firms that adopt ERM programs, most of which signal the
fact that they have an ERM
program through the hiring of a CRO.
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10. Many thanks to Andrew Faris, Enterprise Risk Management

Analyst at the Uni-
versity of Washington, and Kerry Kahl, ERM Project Manager
at UW. They pro-
vided information via an interview in April 2012 that is
incorporated throughout this
case study. Additional information for the case study comes
from Annual Reports,
memos, and other documents found on the University of
Washington ERM website:
http://f2.washington.edu/fm/erm.
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Chan, Sharon Pian. 2004. “UW Failed to Address Overbilling,
Probe Finds.” Seattle
Times, May 1, 2004. Available at
http://seattletimes.com/html/localnews/2001917467_
uwmed01m.html.
Chang, Jean. 2012. Skype interview, March 2.

Committee of Sponsoring Organizations of the Treadway
Commission. 2004. Enterprise
Risk Management—Integrated Framework. Available at
www.idkk.gov.tr/html/themes/
bumko/dosyalar/yayin-dokuman/COSOERM.pdf.
Committee of Sponsoring Organizations of the Treadway
Commission. 2011. Internal
Control—Integrated Framework. Available at
www.coso.org/documents/coso_framework
_body_v6.pdf.
Freeh, Sporkin & Sullivan, LLP. 2012. “Report of the Special
Investigative Counsel Regard-
ing the Actions of the Pennsylvania State University to Related
the Child Sexual Abuse
Committed by Gerald A. Sandusky,” July 12. Available at
http://progress.psu.edu/the-
freeh-report.
Gallagher Higher Education Practice. 2009. “Road to
Implementation: Enterprise Risk
Management for Colleges and Universities.” Arthur Gallagher &
Co. Available at
www.nacua.org/documents/ERM_Report_GallagherSep09.pdf.
www.it-ebooks.info
Grant Thornton LLP. 2011. “Best-Practice Tips for Boards,
Presidents and Chancel-
lors Regarding Enterprise Risk Management.” OnCourse,

January. Retrieved from
www.grantthornton.com/staticfiles/GTCom/Not-for-
profit%20organizations/
On%20Course/On%20Course%20-%20Jan%2011%20-
%20FINAL.pdf.
Grasgreen, Allie. 2013. “Report Shows How Rutgers Botched
Handling of Former Coach,
Reiterates 5-year-old Recommendations to Improve Athletics.”
Inside Higher Education.
Available at www.insidehighered.com/news/2013/07/23/report-
shows-how-rutgers-
botched-handling-former-coach-reiterates-5-year-old.
Gurevitz, Susan. 2009. “Manageable Risk.” University
Business. Available at www.university
business.com/article/manageable-risk.
Helsloot, I., and W. Jong. 2006. “Risk Management in Higher
Education and Research in the
Netherlands.” Journal of Contingencies and Crisis Management
14:3.
Huber, C. 2009. “Risks and Risk-Based Regulation in Higher
Education Institutions.” Ter-
tiary Education and Management 15:2.
Kedem, K. 2010. “Special Comment: Governance and
Management: The Underpinnings of
University Credit Ratings.” Moody’s Investors Service, Report
128850.
Mitroff, I. I., M. A. Diamond, and M. C. Alpaslan. 2006. “How
Prepared Are America’s
Colleges and Universities for Major Crises?: Assessing the
State of Crisis Management.”

Change 38:1, 61–67.
National Association of College and University Business
Officers and the Association of
Governing Boards of Universities and Colleges. 2007. “Meeting
the Challenges of Enter-
prise Risk Management in Higher Education.” Available at
www.ucop.edu/riskmgt/
erm/documents/agb_nacubo_hied.pdf.
Nelson, John. 2012. Phone interview, March 13.
Stripling, Jack. 2012. “Penn State Trustees Were Blind to Risk,
Just Like Many Boards.”
Chronicle of Higher Education, July 12. Available at
http://chronicle.com/article/Penn-
State-Trustees-Were-Blind/132943/.
Tertiary Education Quality Standards Agency. 2013. Available
at www.teqsa.gov.au/
Tufano, Peter. 2011. “Managing Risk in Higher Education.”
Forum Futures. Available at
http://net.educause.edu/ir/library/pdf/ff1109s.pdf.
University Risk Management and Insurance Association. 2007.
“ERM in Higher Education.”
Available at
www.urmia.org/library/docs/reports/URMIA_ERM_White_Pape
r.pdf.
Whitfield, R. N. 2003. “Managing Institutional Risks: A
Framework.” Doctoral dissertation.
Retrieved from ProQuest Dissertation and Theses database,
AAT 3089860.
Willson, C., R. Negoi, and A. Bhatnagar. 2010. “University

Risk Management.” Internal Audi-
tor 67:4, 65–68.
Wilson, Richard. 2013. “Managing Risk.” Inside Higher
Education, May 20. Available at
www.insidehighered.com/blogs/alma-mater/managing-risk.
ABOUT THE CONTRIBUTOR
Anne E. Lundquist has had 20 years of increasing administrative
responsibilities in
higher education, having served as the dean of students at four
liberal arts colleges.
She received a BA in religious studies from Albion College and
an MFA in creative
writing from Western Michigan University. Currently, she is a
PhD candidate in
the Educational Leadership program at Western Michigan
University with a con-
centration in higher education administration, where she works
with the vice pres-
ident of student affairs on student affairs assessment and
strategic planning and
with the internal auditor and University Strategic Planning
Committee on ERM
implementation. Her dissertation research study is titled
“Enterprise Risk Man-
agement (ERM) in Colleges and Universities: Administration
Processes Regarding
www.it-ebooks.info

the Adoption, Implementation and Integration of ERM.” Using
her expertise in
several areas, she has presented and been the author of articles
on risk manage-
ment, institutional liability, students with psychiatric
disabilities, assessment and
strategic planning, intercultural competence, and the
development and implemen-
tation of integrated community standards/restorative justice
judicial models. She
is the coauthor of The Student Affairs Handbook: Translating
Legal Principles into Effec-
tive Policies (LRP Publications, 2007). She has had three recent
risk management
publications in peer-reviewed journals: URMIA Journal (2011,
2012) and New Direc-
tions for Higher Education, Special Issue, Disability and Higher
Education (with Allan
Shackelford, July 2011).
Special thanks to Andrew Faris, Enterprise Risk Management
Analyst at the
University of Washington, for sharing information about the
university’s ERM pro-
cess, answering questions, and providing material for the case
study.
www.it-ebooks.info
Communicating professionally and ethically is one of the
essential skill sets we can teach you at Strayer. The following
guidelines will ensure:

· Your writing is professional
· You avoid plagiarizing others, which is essential to writing
ethically
· You give credit to others in your work
Visit Strayer’s Academic Integrity Center for more information.
Winter 2019
https://pslogin.strayer.edu/?dest=academic-support/academic-
integrity-center
Strayer University Writing Standards 2
� Include page numbers.
� Use 1-inch margins.
� Use Arial, Courier, Times New Roman, or Calibri font style.
� Use 10-, 11-, or 12-point font size for the body of your text.
� Use numerals (1, 2, 3, and so on) or spell out numbers (one,
two, three, and so on).
Be consistent with your choice throughout the assignment.
� Use either single or double spacing, according to assignment
guidelines.
� If assignment requires a title page:
· Include the assignment title, your name, course title, your
professor’s name, and the
date of submission on a separate page.

� If assignment does not require a title page (stated in the
assignment details):
a. Include all required content in a header at the top of your
document.
or b. Include all required content where appropriate for
assignment format.
Examples of appropriate places per assignment: letterhead of a
business letter
assignment or a title slide for a PowerPoint presentation.
� Use appropriate language and be concise.
� Write in active voice when possible. Find tips here.
� Use the point of view (first, second, or third person) required
by the assignment
guidelines.
� Use spelling and grammar check and proofread to help
ensure your work is error free.
� Use credible sources to support your ideas/work. Find tips
here.
� Cite your sources throughout your work when you borrow
someone else’s words or ideas.
Give credit to the authors.
� Look for a permalink tool for a webpage when possible
(especially when an electronic
source requires logging in like the Strayer Library). Find tips
here.
� Add each cited source to the Source List at the end of your
assignment. (See the Giving

Credit to Authors and Sources section for more details.)
� Don’t forget to cite and add your textbook to the Source List
if you use it as a source.
� Include a Source List when the assignment requires research
or if you cite the textbook.
� Type “Sources” centered on the first line of the page.
� List the sources that you used in your assignment.
� Organize sources in a numbered list and in order of use
throughout the paper. Use the
original number when citing a source multiple times.
� For more information, see the Source List section.
General Standards
Use Appropriate
Formatting
Title Your Work
Write Clearly
Cite Credible
Sources
Build a
Source List
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http://libdatab.strayer.edu/login?url=http://search.ebscohost.co
m/login.aspx?direct=true&db=ers&AN=98402046&site=eds-

live&scope=site
https://cdnapisec.kaltura.com/index.php/extwidget/preview/part
ner_id/956951/uiconf_id/38285871/entry_id/1_w9soryj6/embed/
dynamic
Writing Assignments
Strayer University uses several different types of writing
assignments. The Strayer University
Student Writing Standards are designed to allow flexibility in
formatting your assignment and
giving credit to your sources. This section covers specific areas
to help you properly format
and develop your assignments. Note: The specific format
guidelines override guidelines in the
General Standards section.
Paper and Essay
Specific Format
Guidelines
PowerPoint or
Slideshow Specific
Format Guidelines
� Use double spacing throughout the body of your assignment.
� Use a consistent 12-point font throughout your assignment
submission. (For
acceptable fonts, see General Standards section.)
� Use the point of view (first or third person) required by the
assignment guidelines.

� Section headings can be used to divide different content
areas. Align section
headings (centered) on the page, be consistent, and include at
least two section
headings in the assignment.
� Follow all other General Standards section guidelines.
� Title slides should include the project name (title your work
to capture attention if
possible), a subtitle (if needed), the course title, and your name.
� Use spacing that improves professional style (mixing single
and double spacing as
needed).
� Use a background color or image on slides.
� Use Calibri, Lucida Console, Helvetica, Futura, Myriad Pro,
or Gill Sans font styles.
� Use 28-32 point font size for the body of your slides (based
on your chosen font
style). Avoid font sizes below 24-point.
� Use 36-44 point font size for the titles of your slides (based
on chosen font style).
� Limit content per slide (no more than 7 lines on any slide
and no more than 7
words per line).
� Include slide numbers when your slide show has 3+ slides.
You may place the
numbers wherever you like (but be consistent).

� Include appropriate images that connect directly to slide
content or presentation
content.
� Follow additional guidelines from the PowerPoint or
Slideshow Specific Format
Guidelines section and assignment guidelines.
Giving Credit to Authors and Sources
When quoting or paraphrasing another source, you need to give
credit by using an in-text
citation. An in-text citation includes the author’s last name and
the number of the source from
the Source List. A well-researched assignment has at least as
many sources as pages (see
Writing Assignments for the required number of sources). Find
tips here.
Option #1: Paraphrasing
Rewording Source Information in Your Own Words
· Rephrase the source information in your words.
Be sure not to repeat the same words of the author.
· Add a number to the end of your source (which will tie
to your Source List).
· Remember, you cannot just replace words of the
original sentence.
ORIGINAL SOURCE

“Writing at a college level requires informed
research.”
PARAPHRASING
As Harvey wrote, when writing a paper for
higher education, it is critical to research and
cite sources (1).
When writing a paper for higher education,
it is imperative to research and cite sources
(Harvey, 1).
Option #2: Quoting
Citing Another Person’s Work Word-For-Word
· Place quotation marks at the beginning and the end of
the quoted information.
· Add a number to the end of your source (which will tie
to your Source List).
· Do not quote more than one to two sentences
(approximately 25 words) at a time.
· Do not start a sentence with a quotation.
· Introduce and explain quotes within the context of
your paper.
ORIGINAL SOURCE
“Writing at a college level requires informed
research.”

QUOTING
Harvey wrote in his book, “Writing at a college
level requires informed research” (1).
Many authors agree, “Writing at a college
level requires informed research” (Harvey, 1).
http://libdatab.strayer.edu/login?url=http://search.ebscohost.co
m/login.aspx?direct=true&db=ers&AN=98402046&site=eds-
live&scope=site
Page Numbers
When referencing multiple pages in a text book or other
large book, consider adding page numbers to help the
reader understand where the information you referenced
can be found. You can do this in three ways:
a. In the body of your paper;
or b. In the citation;
or c. By listing page numbers in the order they were
used in your paper on the Source List.
Check with your instructor or the assignment guidelines to
see if there is a preference based on your course.
IN-TEXT CITATION
(Harvey, 1, p. 16)

In the example, the author is Harvey, the source list number
is 1, and the page number that this information can be
found on is page 16.
Multiple Sources (Synthesizing)
Synthesizing means using multiple sources in one sentence
or paragraph (typically paraphrased) to make a strong
point. This is normally done with more advanced writing,
but could happen in any writing where you use more than
one source.
The key here is clarity. If you paraphrase multiple sources
in the same sentence (of paragraph if the majority of the
information contained in the paragraph is paraphrased),
you should include each source in the citation. Separate
sources using semi-colons (;) and create the citation in
the normal style that you would for using only one source
(Name, Source Number).
SYNTHESIZED IN-TEXT CITATION
(Harvey, 1; Buchanan, 2)
In the example, the authors Harvey and Buchanan were
paraphrased to help the student make a strong point.
Harvey is the first source on the source list, and Buchanan is
the second source on the source list.
Traditional Sources

Discussion Posts
When quoting or paraphrasing a source for discussion
threads, include the source number in parenthesis after the
body text where you quote or paraphrase. At the end of
your post, type the word “Sources” and below that include
a list of any sources that you cited.
If you pulled information from more than one source,
continue to number the additional sources in the order that
they appear in your post.
For more information on building a Source List Entry, see
Source List section.
SAMPLE POST
The work is the important part of any writing
assignment. According to Smith, “writing
things down is the biggest challenge” (1).
This is significant because…
The other side of this is also important. It is
noted that “actually writing isn’t important as
much as putting ideas somewhere useful” (2).
SOURCES
1. William Smith. 2018. The Way Things Are.
http://www.samplesite.com/writing
2. Patricia Smith. 2018. The Way Things Really
Are. http://www.betterthansample.com/tiger
A web source is any source accessed through an internet
browser. Before using any source, first determine its credibility.

Then decide if the source is appropriate and relevant for your
project. Find tips here.
Home Pages
A home page is the main page that loads when you type
a standard web address. For instance, if you type Google.
com into the web browser, you will be taken to Google’s
home page.
If you do need to cite a home page, use the webpage’s
title from the browser. This found by moving your mouse
cursor over the webpage name at the top of the browser.
When citing a homepage, it is likely because there is a news
thread, image, or basic piece of information on a company
that you wish to include in your assignment.
Specific Web Pages
If you are using any web page other than the home page,
include the specific title of the page and the direct link (when
possible) for that specific page in your Source List Entry.
If your assignment used multiple pages from the same author/
source, create separate Source List Entries for each page
when possible (if the title and/or web address is different).
Web Sources
https://owl.purdue.edu/owl/research_and_citation/conducting_re
search/evaluating_sources_of_information/index.html
Effective Internet Links
When sharing a link to an article with your instructor and
classmates, start with a brief summary and why you chose

to share it.
Be sure to check the link you’re posting to be sure it will
work for your classmates. They should be able to just click
on the link and go directly to your shared site.
Share vs. URL Options
Cutting and pasting the URL (web address) from your browser
may not allow others to view your source. This makes it hard
for people to engage with the content you used.
To avoid this problem, look for a “share” option and choose
that when possible so your classmates and professor
get the full, direct link. Always test your link(s) before
submitting to make sure they work.
If you cannot properly share the link, include the article as an
attachment. Interested classmates and your professor can
reference the article shared as an attachment. Find tips here.
POOR EXAMPLE
Hey check out this article: http://www.
Jobs4You.FED/Jobs_u_can_get
BETTER EXAMPLE
After reading the textbook this week, I
researched job sites. I found an article on how
to find the best job site depending on the job
you’re looking for. The author shared some
interesting tools such as job sites that collect job
postings from other sites and ranks them from
newest to oldest, depending on category. Check

out the article at this link: http://www.Jobs4You.
FED/Jobs_u_can_get
Charts, images, and tables should be centered and followed by
an in-text citation. Design your page and place a citation
below the chart, image, or table. When referring to the chart,
image, or table in the body of the assignment, use the citation.
On your Source List, provide the following details of the visual:
· Author’s name (if created by you, provide your name)
· Date (if created by you, provide the year)
· Type (Chart, Image, or Table)
· How to find it (link or other information – See Source List
section for additional details).
Charts, Images, and Tables
https://nyti.ms/24L5XkV
Source List
The Source List (which includes the sources that you used in
your assignment) is a new page
you add at the end of your paper. The list has two purposes: it
gives credit to the authors that
you use and gives your readers enough information to find the
source without your help. Build
your Source List as you write.
· Type “Sources” at the top of a new page.
· Include a numbered list of the sources you used in your paper
(the numbers

indicate the order in which you used them).
1. Use the number one (1) for the first source used in the paper,
the number
two (2) for the second source, and so on.
2. Use the same number for a source if you use it multiple
times.
· Ensure each source includes five parts: author or
organization, publication date,
title, page number (if needed), and how to find it. If you have
trouble finding
these details, then re-evaluate the credibility of your source.
· Use the browser link for a public webpage.
· Use a permalink for a webpage when possible. Find tips here.
· Instruct your readers how to find all sources that do not have
a browser link
or a permalink.
· Separate each Source List Element with a period on your
Source List.
AUTHOR PUBLICATION DATE TITLE PAGE NO. HOW TO
FIND
The person(s) who
published the source. This
can be a single person,
a group of people, or an
organization. If the source
has no author, use “No
author” where you would
list the author.

The date the source was
published. If the source
has no publication date,
use “No date” where you
would list the date.
The title of the
source. If the
source has no title,
use “No title”
where you would
list the title.
The page
number(s) used. If
the source has no
page numbers,
omit this section
from your Source
List Entry.
Instruct readers how to find
all sources. Keep explanations
simple and concise, but
provide enough information
so the source can be located.
Note: It is your responsibility
to make sure the source can
be found.
Michael Harvey
In the case of multiple

authors, only list the first.
2013
This is not the same as
copyright date, which is
denoted by ©
The Nuts &
Bolts of College
Writing
p. 1
Include p. and
the page(s) used.
http://libdatab.strayer.edu/
login?url=http://search.
ebscohost.com/login.aspx
Setting Up the
Source List Page
Creating a
Source List Entry
Source List Elements
1. Michael Harvey. 2013. The Nuts & Bolts of College Writing.

p. 1. http://libdatab.strayer.edu/
login?url=http://search.ebscohost.com/login.aspx
1. Michael Harvey. 2013. The Nuts & Bolts of College Writing.
p. 1. http://libdatab.strayer.edu/login?url=http://search.
ebscohost.com/login.aspx
2. William R. Stanek. 2010. Storyboarding Techniques chapter
in Effective Writing for Business, College and Life. http://
libdatab.strayer.edu/login?url=http://search.ebscohost.com/login
.aspx?direct=true&db=nlebk&AN=359141&site=e
ds-live&scope=site&ebv=EB&ppid=pp_23
3. Zyad Hicham. 2017. Vocabulary Growth in College-Level
Students’ Narrative Writing. http://libdatab.strayer.edu/
login?url=http://search.ebscohost.com/login.aspx?direct=true&d
b=edsdoj&AN=edsdoj.9b7fad40e529462bafe3a936
aaf81420&site=eds-live&scope=site
4. Anya Kamenetz. July 10, 2015. The Writing Assignment That
Changes Lives. https://www.npr.org/sections/
ed/2015/07/10/419202925/the-writing-assignment-that-changes-
lives
5. Brad Thor. June 14, 2016. The Best Writing Advice I Ever
Got. http://time.com/4363050/brad-thor-best-writing-advice/
6. Karen Hertzberg. June 15, 2017. How to Improve Writing
Skills in 15 Easy Steps. https://www.grammarly.com/blog/
how-to-improve-writing-skills/
7. Roy Peter Clark. 2008. Writing Tools: 55 Essential Strategies
for Every Writer. p.55-67. Book on Amazon.com.

8. C.M. Gill. 2014. The Psychology of Grading and Scoring
chapter in Essential Writing Skills for College & Beyond.
Textbook.
9. ABC Company’s Policy & Procedures Committee. No Date.
Employee Dress and Attendance Policy. Policy in my office.
10. Henry M. Sayre. 2014. The Humanities: Culture, Continuity
and Change, Vol. 1. This is the HUM111 textbook.
11. Savannah Student. 2018. Image. http://www.studentsite.com
12. Don Dollarsign. 2018. Chart.
http://www.allaboutthemoney.com
13. Company Newsletter Name. 2018. Table. Company
Newsletter Printed Copy (provided upon request).

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