Unit: Administration and Finance Date:    September 16, 2003   Section 2: CORE REQUIREMENTS       2.1 The institution has degree-granting authority from the appropriate government agency or agencies.  (Degree-granting Authority)         Not applicable to unit level.            2.2 The institution has a governing board of at least five members that is the legal body with specific authority over the institution. The board is an active policy-making body for the institution and is ultimately responsible for ensuring that the financial resources of the institution are adequate to provide a sound educational program. The board is not controlled by a minority of board members or by organizations or interests separate from it. Neither the presiding officer of the board nor the majority of other voting members of the board have contractual, employment, or personal or familial financial interest in the institution. A military institution authorized and operated by the federal government to award degrees has a public board in which neither the presiding officer nor a majority of the other members are civilian employees of the military or active/retired military. The board has broad and significant influence upon the institution’s programs and operations, plays an active role in policy-making, and ensures that the financial resources of the institution are used to provide a sound educational program. The board is not controlled by a minority of board members or by organizations or interests separate from the board except as specified by the authorizing legislation. Neither the presiding officer of the board nor the majority of other voting board members have contractual, employment, or personal or familial financial interest in the institution.  (Governing Board)           Not applicable to unit level.             2.3 The institution has a chief executive officer whose primary responsibility is to the institution and who is not the presiding officer of the board. (Chief Executive Officer)         Not applicable to unit level.             2.4 The institution has a clearly defined and published mission statement specific to the institution and appropriate to an institution of higher education, addressing teaching and learning and, where applicable, research and public service. (Institutional Mission)         Not applicable to unit level.             2.5 The institution engages in ongoing, integrated, and institution-wide research-based planning and evaluation processes that incorporate a systematic review of programs and services that (a) results in continuing improvement and (b) demonstrates that the institution is effectively accomplishing its mission. (Institutional Effectiveness)         The Division of Administration and Finance is in compliance with Core Requirement 2.5. The division and its constituent offices engage in ongoing, integrated planning and evaluation. Documentation for these processes is in the division strategic plan and assessment reports for 2002 and 2003, which may be accessed at http://www.irs.ttu.edu/SACS/UnitWebLinks.htm.              2.6 The institution is in operation and has students enrolled in degree programs.  (Continuous Operation)         Not applicable to unit level.             2.7 The institution   2.7.1   offers one or more degree programs based on at least 60 semester credit hours or the equivalent at the associate level; at least 120 semester credit hours or the equivalent at the baccalaureate level; or at least 30 semester credit hours or the equivalent at the post-baccalaureate, graduate, or professional level. The institution provides a written justification and rationale for program equivalency. (Program Length)       Not applicable to unit level.         2.7.2 offers degree programs that embody a coherent course of study that is compatible with its stated purpose and is based upon fields of study appropriate to higher education. (Program Content)      Not applicable to unit level.         2.7.3 requires in each undergraduate degree program the successful completion of a general education component at the collegiate level that is (1) a substantial component of each undergraduate degree, (2) ensures breadth of knowledge, and (3) is based on a coherent rationale. For degree completion in associate programs, the component constitutes a minimum of 15 semester hours or the equivalent; for baccalaureate programs, a minimum of 30 semester hours or the equivalent. These credit hours are to be drawn from and include at least one course from each of the following areas: humanities/fine arts; social/behavioral sciences; and natural science/mathematics. The courses do not narrowly focus on those skills, techniques, and procedures specific to a particular occupation or profession. The institution provides a written justification and rationale for course equivalency. (General Education)     Not applicable to unit level.         2.7.4 provides instruction for all course work required for at least one degree program at each level at which if awards degree.  If the institution makes arrangements for some instruction to be provided by other accredited institutions or entities through contracts or consortia, or uses some other alternative approach to meeting this requirement, the alternative approach must be approved by the Commission on Colleges.  In all cases, the institution demonstrates that it controls all aspects of its educational program.  (Contractual Agreements for Instruction)      Not applicable to unit level.             2.8 The number of full-time faculty members is adequate to support the mission of the institution. The institution has adequate faculty resources to ensure the quality and integrity of its academic programs. In addition, upon application for candidacy, an applicant institution demonstrates that it meets the comprehensive standard for faculty qualifications.  (Faculty)         Not applicable to unit level.             2.9. The institution, through ownership or formal arrangements or agreements, provides and supports student and faculty access and user privileges to adequate library collections as well as to other learning/information resources consistent with the degrees offered. These collections and resources are sufficient to support all its educational, research, and public service programs. (Learning Resources and Services)         Not applicable to unit level.             2.10 The institution provides student support programs, services, and activities consistent with its mission that promote student learning and enhance the development of its students. (Student Support Services)         Not applicable to unit level.             2.11 The institution has a sound financial base and demonstrated financial stability, and adequate physical resources to support the mission of the institution and the scope of its programs and services. The member institution provides the following financial statements: (a) an institutional audit (or Standard Review Report issued in accordance with Statements on Standards for Accounting and Review Services issued by the AICPA for those institutions audited as part of a systemwide or statewide audit) and written institutional management letter for the most recent fiscal year prepared by an independent certified public accountant and/or an appropriate governmental auditing agency employing the appropriate audit (or Standard Review Report) guide; (b) a statement of financial position of unrestricted net assets, exclusive of plant assets and plant-related debt, which represents the change in unrestricted net assets attributable to operations for the most recent year; and, (c) an annual budget that is preceded by sound planning, is subject to sound fiscal procedures, and is approved by the governing board. Audit requirements for applicant institutions may be found in the Commission policy entitled "Accreditation Procedures for Applicant Institutions.  (Resources)          (a) As an institution whose annual financial information is audited as part of a statewide audit, Texas Tech University will obtain a review in accordance with AICPA Statements on Standards for Accounting and Review Services for its financial statements for the year ending August 31, 2004.  The Texas State Auditor’s Office will conduct the review and will issue a Standard Review Report and institutional management letter.  The target date for submission of the review report and management letter to SACS is January 15, 2005.      (b) Texas Tech University prepares an annual budget for the approval of the Board of Regents and which employs planning and financial procedures set out in Regent's Rule 07.04 entitled Budget Rules and Procedures (http://www.depts.ttu.edu/oppol/Chapter07.pdf ). The more detailed financial procedures are set out in the University Operating Policy and Procedures, Chapter 62 (http://www.depts.ttu.edu/opmanual/Contents.htm#62).   Another aspect of the budget process is the biennial legislative appropriation request, prepared in accordance with instructions from the Legislative Budget Board (http://www.lbb.state.tx.us). This request is the first step in the University appropriations for the next biennium.        (c) A statement of financial position of unrestricted net assets, exclusive of plant assets and plant-related debt, which represents the change in unrestricted net assets attributable to operations for the year ending August 31, 2004, will be prepared based on the financial information reviewed by the State Auditor’s Office.  The statement will be accompanied by management discussion and analysis as necessary to explain the financial position and results.  The target date for submission of the supplemental statement is January 15, 2005.         2.12 The institution has developed an acceptable Quality Enhancement Plan and demonstrate that the plan is part of an ongoing planning and evaluation process.  (Quality Enhancement Plan). (Not applicable for the Compliance Certification submitted by institution).               Section 3:  COMPREHENSIVE STANDARDS       Institutional Mission, Governance, And Effectiveness 3.1  Institutional Mission     3.1.1 The institution has a clear and comprehensive mission statement that guides it; is approved by the governing board; is periodically reviewed by the board; and is communicated to the institution’s constituencies.         Not applicable to unit level.             3.2  Governance and Administration     3.2.1 The governing board of the institution is responsible for the selection and the evaluation of the chief executive officer.         Not applicable to unit level.             3.2.2 The legal authority and operating control of the institution are clearly defined for the following areas within the institution’s governance structure:   3.2.2.1 the institution’s mission;   3.2.2.2 the fiscal stability of the institution;   3.2.2.3 institutional policy, including policies concerning related and affiliated corporate entities and all auxiliary services;   3.2.2.4 related foundations (athletic, research, etc.) and other corporate entities whose primary purpose is to support the institution and/or its programs.         Not applicable to unit level.             3.2.3 The board has a policy addressing conflict of interest for its members.         Not applicable to unit level.             3.2.4 The governing board is free from undue influence from political, religious, or other external bodies, and protects the institution from such influence.         Not applicable to unit level.             3.2.5 Members of the governing board can be dismissed only for cause and by due process.         Not applicable to unit level.             3.2.6 There is a clear and appropriate distinction, in writing and practice, between the policy-making functions of the governing board and the responsibility of the administration and faculty to administer and implement policy.         Not applicable to unit level.             3.2.7 The institution has a clearly defined and published organizational structure that delineates responsibility for the administration of policies.         The Office of Administration and Finance is responsible for financial, business, and human resources components of university operations. The Senior Vice President for Administration and Finance oversees the following units:       1. Budget Office (budgeting, legislative appropriations request, personnel appointments, etc.)       2. Financial Affairs (accounting, cash management, university cashier, tax reporting, etc.)       3. Business Affairs (contract administration, purchasing, travel, risk management, etc.)       4. Historically Underutilized Business (HUB) Operations (minority business affairs)       5. Human Resources (personnel management)       6. Quality Service and Professional Development (personnel orientation and training)     The Administration and Finance organizational chart is available at http://www.ttu.edu/fiscal/orgchart.pdf.             3.2.8 The institution has qualified administrative and academic officers with the experience, competence, and capacity to lead the institution.         Not applicable to unit level.             3.2.9 The institution defines and publishes policies regarding appointment and employment of faculty and staff.         Not applicable to unit level.             3.2.10 The institution evaluates the effectiveness of its administrators, including the chief executive officer, on a periodic basis.         Not applicable to unit level.             3.2.11 The institution’s chief executive officer has ultimate responsibility for, and exercises appropriate administrative and fiscal control over, the institution’s intercollegiate athletics program.         Not applicable to unit level.             3.2.12 The institution’s chief executive officer has ultimate control of the institution’s fund-raising activities.         Not applicable to unit level.             3.2.13 Any institution-related foundation not controlled by the institution has a contractual or other formal agreement that (a) accurately describes the relationship between the institution and the foundation, and (b) describes any liability associated with that relationship. In all cases, the institution ensures that the relationship is consistent with its mission.         Not applicable to unit level.             3.2.14 The institution’s policies are clear concerning ownership of materials, compensation, copyright issues, and the use of revenue derived from the creation and production of all intellectual property. This applies to students, faculty and staff.         Not applicable to unit level.       3.3  Institutional Effectiveness     3.3.1 The institution identifies expected outcomes for its educational programs and its administrative and educational support services; assesses whether it achieves these outcomes; and provides evidence of improvement based on analysis of those results.         The Office of Administration and Finance is in compliance with Comprehensive Standard 3.3.1. The office prepared a strategic plan, in accord with the university mandate, and submitted assessment reports for 2002 and 2003. See those documents for details about ways in which Administration and Finance has responded to assessment to improve the services it offers to students and to the university community at large. These documents are available at (http://techdata.irs.ttu.edu/stratreport).       PROGRAMS 3.4  Educational Programs Standards for All Educational Programs: (Includes all on-campus, off-campus and distance learning programs)  3.4.1 The institution demonstrates that each educational program for which academic credit is awarded (a) is approved by the faculty and the administration, and (b) establishes and evaluates program and learning outcomes.         Not applicable to unit level.             3.4.2 The institution’s continuing education, outreach, and service programs are consistent with the institution’s mission.         Not applicable to unit level.             3.4.3 The institution publishes admissions policies consistent with its mission.         Not applicable to unit level.             3.4.4 The institution has a defined and published policy for evaluating, awarding, and accepting credit for transfer, experiential learning, advanced placement, and professional certificates that is consistent with its mission and ensures that course work and learning outcomes are at the collegiate level and comparable to the institution’s own degree programs. The institution assumes responsibility for the academic quality of any course work or credit recorded on the institution’s transcript.         Not applicable to unit level.             3.4.5 The institution publishes academic policies that adhere to principles of good educational practice. These are disseminated to students, faculty, and other interested parties through publications that accurately represent the programs and services of the institution.         Not applicable to unit level.             3.4.6 The institution employs sound and acceptable practices for determining the amount and level of credit awarded for courses, regardless of format or mode of delivery.         Not applicable to unit level.             3.4.7 The institution ensures the quality of educational programs/courses offered through consortia relationships or contractual agreements, ensures ongoing compliance with the comprehensive requirements, and evaluates the consortial relationship and/or agreement against the purpose of the institution.         Not applicable to unit level.             3.4.8 The institution awards academic credit for course work taken on a noncredit basis only when there is documentation that the noncredit course work is equivalent to a designated credit experience.         Not applicable to unit level.             3.4.9 The institution provides appropriate academic support services.         Not applicable to unit level.       3.4.10 The institution defines and publishes general education requirements for its undergraduate programs and major program requirements for all its programs. These requirements conform to commonly accepted standards and practices for degree programs.         Not applicable to unit level.             3.4.11 The institution protects the security, confidentiality, and integrity of its student academic records and maintains special security measures to protect and back up data.         Not applicable to unit level.           3.4.12 The institution places primary responsibility for the content, quality, and effectiveness of its curriculum with its faculty.         Not applicable to unit level.             3.4.13 For each major in a degree program, the institution assigns responsibility for program coordination, as well as for curriculum development and review, to persons academically qualified in the field. In those degree programs for which the institution does not identify a major, this requirement applies to a curricular area or concentration.         Not applicable to unit level.       3.4.14 The institution’s use of technology enhances student learning, is appropriate for meeting the objectives of its programs, and ensures that students have access to and training in the use of technology.         Not applicable to unit level.         3.5  Standards Specific to Undergraduate Programs:     3.5.1 The institution identifies college-level competencies within the general education core and provides evidence that graduates have attained those competencies.       Not applicable to unit level.             3.5.2 The institution awards degrees only to those students who have earned at least 25 percent of the credit hours required for the degree through instruction offered by that institution.       Not applicable to unit level.           3.6  Standards Specific to Graduate and Post-Baccalaureate Professional Programs:     3.6.1 The institution’s post-baccalaureate professional degree programs, and its master’s and doctoral degree programs are progressively more advanced in academic content than undergraduate programs.       Not applicable to unit level.           3.6.2 The institution ensures that its graduate instruction and resources foster independent learning, enabling the graduate to contribute to a profession or field of study.       Not applicable to unit level.           3.6.3 The majority of credits toward a graduate or a post-baccalaureate professional degree is earned through the institution awarding the degree. In the case of graduate and post-baccalaureate professional degree programs offered through joint, cooperative, or consortia arrangements, the student earns a majority of credits from the participating institutions.       Not applicable to unit level.           3.7  Faculty     3.7.1 The institution employs competent faculty members qualified to accomplish the mission and goals of the institution. When determining acceptable qualifications of its faculty, an institution gives primary consideration to the highest earned degree in the discipline in accordance with the guidelines listed below. The institution also considers competence, effectiveness, and capacity, including, as appropriate, undergraduate and graduate degrees, related work experiences in the field, professional licensure and certifications, honors and awards, continuous documented excellence in teaching, or other demonstrated competencies and achievements that contribute to effective teaching and student learning outcomes. For all cases, the institution is responsible for justifying and documenting the qualifications of all its faculty.       Not applicable to unit level.           3.7.2 The institution regularly evaluates the effectiveness of each faculty member in accord with published criteria, regardless of contractual or tenured status.       Not applicable to unit level.           3.7.3 The institution provides evidence of ongoing professional development of faculty as teachers, scholars, and practitioners.       Not applicable to unit level.     3.7.4 The institution ensures adequate procedures for safeguarding and protecting academic freedom.       Not applicable to unit level.           3.7.5 The institution publishes policies on the responsibility and authority of faculty in academic and governance matters.       Not applicable to unit level.       3.8  Library and Other Learning Resources     3.8.1 The institution provides facilities, services, and other learning/information resources that are appropriate to support its teaching, research, and service mission.       Not applicable to unit level.             3.8.2 The institution ensures that users have access to regular and timely instruction in the use of the library and other learning/information resources.       Not applicable to unit level.           3.8.3 The institution provides a sufficient number of qualified staff--with appropriate education or experiences in library and/or other learning/information resources–to accomplish the mission of the institution.       Not applicable to unit level.           3.9  Student Affairs and Services     3.9.1 The institution publishes a clear and appropriate statement of student rights and responsibilities and disseminates the statement to the campus community.       Not applicable to unit level.           3.9.2 The institution protects the security, confidentiality, and integrity of its student records.       Not applicable to unit level.           3.9.3 The institution provides services supporting its mission with qualified personnel to ensure the quality and effectiveness of its student affairs programs.       Not applicable to unit level.           RESOURCES 3.10  Financial and Physical Resources     3.10.1 The institution’s recent financial history demonstrates financial stability.       JUDGMENT OF COMPLIANCE Yes, Texas Tech University is able to provide evidence supporting compliance. STATEMENT OF RATIONALE FOR JUDGMENT OF COMPLIANCE Texas Tech University defines acceptable financial stability as the ability to continue the institutional mission by providing the highest level of teaching, research and public service in times of declining state appropriations. We have sustained this commitment even with unpredictable state resources by streamlining business operations, making strategic cuts and prioritizing needs that impact our ability to provide a quality educational and research product. Appropriations for higher education in the State of Texas are formula driven based on weighted semester credit hours. However, Texas Tech University has not been fully funded for several years. This lack of funding has required the shortfall to be passed on to students in the form of tuition and fee increases. The university has attempted to minimize the impact on students by exercising a more aggressive approach in awarding financial aid. The drive in institutional advancement across campus has been to focus on scholarship and fellowship funding. However, even with the student paying more for educational services, Texas Tech University remains a bargain when compared with other universities both nationally and within Texas. As non-appropriated resources have become more important, aggressive fund raising efforts have increased. There has also been an increase in grant and contracts sponsored research. The increased emphasis on research funding has brought the university the Carnegie Foundation Doctoral Research Extensive designation (www.carnegiefoundation.org/index.htm). This increased research and sponsored activity funding provides resources to support and complement the educational process. The growth of sponsored project awards has increased dramatically over the last several years. The growth in such awards has been from $27.4 million in fiscal year 1997 to $54.7 million in fiscal year 2003 (www.ors.ttu.edu/reports.htm). External research grants and contracts provide educational opportunities for students in laboratories and by being involved with faculty in the development of scholarly activities. The mentorship of faculty in these activities is an invaluable part of graduate and undergraduate education at Texas Tech University. In addition, indirect costs recovered from external grants are an integral part of the funding process as they are used to enhance research related programs. Texas Tech University FY03 AFR Note 20:  Donor-Restricted Endowments Expenditure of endowed funds is not allowed without the express consent of the donor.  Most of Texas Tech’s endowments are held in perpetuity.  In many cases, endowment earnings are expendable for student financial assistance or other purposes as designated by the donor.  In other cases, endowment earnings are reinvested. Endowment assets are invested predominantly in the Long Term Investment Fund (LTIF).  The LTIF has experienced varying performance since its inception.  The cumulative effect of valuation changes assignable to endowment fund assets, held both by Texas Tech and Texas Tech Foundation, Inc. are summarized in the following table:   Donor-Restricted Endowments Amount of Net Appreciation   Reported in Net Assets True Endowments $20,264,972 Restricted for Nonexpendable True Endowments           5,397,462 Restricted for Expendable True Endowments 153,208 Unrestricted Term Endowments 175 Restricted for Nonexpendable Term Endowments 6,105 Restricted for Expendable   $25,821,922               3.10.2 The institution provides financial statements and related documents, including multiple measures for determining financial health as requested by the Commission, that accurately and appropriately represent the total operation of the institution.       STATEMENT OF RATIONALE FOR JUDGMENT OF COMPLIANCE Financial statements are prepared annually and presented to the TTU Vice President for Fiscal Affairs and the TTU President for review and for submission to the Texas Comptroller of Public Accounts. (See Regent’s Rule 2.04 and TTU OP 10.02 for delegation of authority rules for the Chancellor and the President related to the University’s financial affairs.) The Annual Financial Report is prepared in accordance with the Comptroller’s Annual Financial Reporting Requirements, which represent a modified format of the guidelines set by the Governmental Accounting Standards Board. These modifications are mandated by the State Comptroller’s Office to facilitate the compilation of the State of Texas Comprehensive Annual Financial Report (CAFR). TTU’s Annual Financial Report is considered for audit by the State Auditor’s Office each year as part of the audit of the State of Texas CAFR.  At the conclusion of the CAFR audit, a management letter is issued on the state level rather than on the institutional level.  For fiscal years ending August 31, 2002 and 2003, the State Auditor’s Office reported no weaknesses related to Texas Tech University in the statewide management letter issued for those two fiscal years. For the past two fiscal years, the State Auditor’s Office has engaged KPMG, LLP, to perform the federal portion of the statewide single audit.  KPMG reviewed compliance and controls over the State’s federal awards and performed audits of the Schedule of Expenditures of Federal Awards as of August 31, 2002 and 2003.  For both fiscal years, KPMG’s statewide report included minor findings related to Texas Tech University.  There were no questioned costs as a result of the findings, and TTU corrected the noted deficiencies upon notification. Link here to TTU annual financial reports. Link here to the KPMG’s Federal Portion of Statewide Single Audit Report for 2003 and 2002.  2003 KPMG report link: http://www.sao.state.tx.us/reports/2004/04-316.pdf 2002 KPMG report link: http://www.sao.state.tx.us/reports/2003/kpmg.pdf Sections of these reports applicable to TTU are on p. 135 for the 2002 KPMG report and on pp. 150-151 for the 2003 KPMG report.             3.10.3 The institution audits financial aid programs as required by federal and state regulations.       Not applicable to unit level.           3.10.4 The institution exercises appropriate control over all its financial and physical resources.       Not applicable to unit level.           3.10.5 The institution maintains financial control over externally funded or sponsored research and programs.       JUDGMENT OF COMPLIANCE Texas Tech University is able to provide a portfolio of evidence supporting compliance. STATEMENT OF RATIONALE FOR JUDGMENT OF COMPLIANCE Texas Tech University (TTU) has clear policies and procedures for both pre-award and post-award financial management of externally funded research and programs. Guidelines established by the TTU Office of Research Services (ORS) for grant and contract submission provide procedures for correct calculations of salaries, fringe benefits, travel and other parts of the budget included in the direct costs of a grant (Budget Preparation Guidelines; Budget Form). The policies on indirect costs and matching funds provide information concerning correct indirect cost rates, instructions for requesting waiver of these rates, and procedures for grants that require matching funds from the institution (Policy on Indirect Costs; Policy on Provision of Matching Funds). Texas Tech University also provides guidance for management of a grant or contract, once an award is made. This guidance from ORS as well as from the Office of Grants and Contracts Accounting includes information on and assistance with authorization of expenditures, cost-sharing, reporting of time and effort, purchasing, travel authorizations, consultants, equipment, post-award changes in the project, retroactive cost transfers, and close-out of the grant (TTU Operating Procedures Manual). The TTU financial procedures for managing grants and contracts are in compliance with the requirements of the TTU Board of Regents (BOR Rules and Regulations). The TTU Office of Audit Services periodically reviews compliance with these policies. Source Location: Board of Regents Rules and Regulations http://www.depts.ttu.edu/oppol/ TTU OP 65.02 Personnel Activity Reporting http://www.depts.ttu.edu/opmanual/OP65.02.pdf TTU OP 65.04 Cost Transfers on Federal Sponsored Projects http://www.depts.ttu.edu/opmanual/OP65.04.pdf TTU OP 65.08 Expenditures and Matching Commitments … http://www.depts.ttu.edu/opmanual/OP65.08.htm TTU OP 65.09 Budgeting Sponsored Projects http://www.depts.ttu.edu/opmanual/OP65.09.pdf TTU OP 65.10 Budgeting Sponsored Projects Prior to Receipt of Award http://www.depts.ttu.edu/opmanual/OP65.10.pdf Budget Preparation guidelines (also includes policy on cost sharing) http://www.ors.ttu.edu/nih_modular_grants_supplemental_.htm Budget forms http://www.ors.ttu.edu/budget_calculation.htm Policy on indirect cost waivers http://www.ors.ttu.edu/Farecov.html Form for indirect cost waivers http://www.ors.ttu.edu/Downloads/F&ADISCO1.doc.                3.10.6 The institution takes reasonable steps to provide a healthy, safe, and secure environment for all members of the campus community.       Not applicable to unit level.           3.10.7 The institution operates and maintains physical facilities, both on and off campus, that are adequate to serve the needs of the institution’s educational programs, support services, and mission-related activities.         Not applicable to unit level.         Section 4:  FEDERAL REQUIREMENTS   4.1 When evaluating success with respect to student achievement in relation to the institution’s mission, the institution includes, as appropriate, consideration of course completion, state licensing examinations, and job placement rates.         Not applicable to unit level.             4.2 The institution maintains a curriculum that is directly related and appropriate to the purpose and goals of the institution and the diplomas, certificates or degrees awarded.         Not applicable to unit level.             4.3 The institution makes available to students and the public current academic calendars, grading policies, and refund policies.         Not applicable to unit level.             4.4 The institution demonstrates that program length is appropriate for each of the degrees offered.         Not applicable to unit level.             4.5 The institution has adequate procedures for addressing written student complaints and is responsible for demonstrating that it follows those procedures when resolving student complaints. (See Commission Policy "The Review of Complaints Involving the Commission or its Accredited institutions.")         Not applicable to unit level.             4.6 Recruitment materials and presentations accurately represent the institution’s practices and policies.         Not applicable to unit level.             4.7 The institution publishes the name of its primary accreditor and its address and phone number.         Not applicable to unit level.             4.8 The institution is in compliance with its program responsibilities under Title IV of the 1998 Higher Education Amendments. (In reviewing the institution's compliance with these program responsibilities, the Commission relies on documentation forwarded to it by the Secretary of Education.)         Not applicable to unit level.