CSA
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The University of
California
Qualified Students Face an Inconsistent and
Unfair Admissions System That Has Been
Improperly Influenced by Relationships and
Monetary Donations
September 2020
REPORT 2019‑113
CALIFORNIA STATE AUDITOR
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Elaine M. Howle State Auditor
September 22, 2020
2019‑113
The Governor of California
President pro Tempore of the Senate
Speaker of the Assembly
State Capitol
Sacramento, California 95814
Dear Governor and Legislative Leaders:
As directed by the Joint Legislative Audit Committee, my office conducted an audit of the University of
California’s (university) admissions process. Our review assessed the risk for fraud and inappropriate
admissions activities at four campuses and we conclude that the university has allowed for improper
influence in admissions decisions, and it has not treated applicants fairly or consistently.
From academic years 2013–14 through 2018–19, we found the four campuses we reviewed—UC Berkeley,
UCLA, UC San Diego, and UC Santa Barbara—unfairly admitted 64 applicants based on their personal or
family connections to donors and university staff. Campuses admitted 22 of these students through their
student-athlete admissions processes, even though the students did not have the athletic qualifications to
compete at the university. UC Berkeley admitted the remaining 42 students, most of whom were referred
to the admissions office because of their families’ histories as donors or because they were related or
connected to university staff, even though their records did not demonstrate competitive qualifications
for admission. By admitting 64 noncompetitive applicants, the university undermined the fairness and
integrity of its admissions process and deprived more qualified students of the opportunity for admission.
The university has also failed to ensure that campuses fairly and consistently treat the thousands
of prospective students who apply each year. Neither UC Berkeley nor UCLA have developed
methodologies for how they determine which applicants to admit. Nevertheless, both of those campuses
admitted thousands of applicants whose records demonstrated that they were less qualified than other
applicants who were denied admission. Applicants’ chances of admission were also unfairly affected by
UC Berkeley’s, UCLA’s, and UC San Diego’s failures to properly train and monitor the staff who review
and rate applications. We found that staff were sometimes overly strict or overly lenient in their review
of applications, thereby making the applicants’ chances of admission unduly dependent on the individual
staff who rated them rather than on the students’ qualifications.
The Office of the President has allowed the weaknesses in these practices to persist because it has not
conducted adequate oversight of campuses’ admissions processes. Although it conducted an internal
review of admissions processes after the recent nationwide college admissions scandal, the Office of the
President relied heavily on campuses to review themselves and did not attempt to identify inappropriate
admissions activity. Stronger standards and oversight are necessary to improve the university’s ability
to guarantee a fair and merit-based admissions process and to detect and prevent inappropriate
admissions decisions.
Respectfully submitted,
ELAINE M. HOWLE, CPA
California State Auditor
621 Capitol Mall, Suite 1200 | Sacramento, CA 95814 | 916.445.0255 | 916.327.0019 fax | www.auditor.ca.gov
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CALIFORNIA STATE AUDITOR | Report 2019-113 v
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CONTENTS
Summary 1
Introduction 5
Campus Staff Took Advantage of Weaknesses in
Admissions Processes to Inappropriately Admit
64 Students as Favors to Donors, Family, and Friends 11
Campuses Lack Key Criteria and Standards to Support
Their Admissions Decisions 31
Campuses Have Not Adequately Ensured That Reviewers
and Faculty Consistently and Fairly Evaluate Applications 39
The Office of the President Has Not Safeguarded the
University’s Admissions Process 53
Appendix A
The University Has Not Addressed Our Recommendation
to Change Its “Compare Favorably” Policy 63
Appendix B
Statistics on the Diversity of Freshman Applicants Whom
the University Admitted for Academic Years 2017–18
Through 2019–20 65
Appendix C
Scope and Methodology 69
Response to the Audit
University of California 73
California State Auditor’s Comments on the Response
From the University of California 75
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CALIFORNIA STATE AUDITOR | Report 2019-113 1
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SUMMARY
The University of California (university) is the most selective of the State’s public
postsecondary institutions. The university relies on its campuses—which are bound by
policies of its Board of Regents (Regents)—to make admissions decisions. This audit
reviewed the general admissions practices of three campuses: the University of California,
Berkeley (UC Berkeley), the University of California, Los Angeles (UCLA), and the
University of California, San Diego (UC San Diego). It also examined the admission of
athletes at those campuses and at the University of California, Santa Barbara. This report
draws the following conclusions:
Campus Staff Took Advantage of Weaknesses in Admissions
Processes to Inappropriately Admit 64 Students as Favors to
Page 11
Donors, Family, and Friends
We identified 64 applicants whom the four campuses admitted for
academic years 2013–14 through 2018–19 based on inappropriate
factors, including their families’ donations to the university and their
relationships to campus staff. The majority of these applicants were
white and at least half had annual family incomes of $150,000 or
more. Campus staff used the campuses’ weak athletics admissions
processes to admit 22 of these applicants, even though they possessed
little athletic talent. In addition, UC Berkeley admitted 42 applicants
through its regular admissions process based on their connections
to donors and staff, while concurrently denying admission to others
who were more qualified. The pervasiveness of this problem at
UC Berkeley demonstrates that campus leadership has failed to
establish a campus culture that values commitment to an admissions
process based on fairness and applicants’ merits and achievements.
Campuses Lack Key Criteria and Standards to Support Their
Admissions Decisions
Page 31
UC Berkeley and UCLA do not have criteria for selecting applicants
for admission, raising questions about why they have frequently
admitted applicants whom their reviewers identified as less
competitive while denying admission to applicants their reviewers
more highly recommended. Additionally, UC Berkeley, UCLA, and
UC San Diego lack adequate processes for identifying applicants who
do not meet eligibility requirements for admission to the university.
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Campuses Have Not Adequately Ensured That Reviewers and
Faculty Consistently and Fairly Evaluate Applications
Page 39
The campuses have not adequately trained or supervised the
reviewers who rate applications. As a result, reviewers were
sometimes overly harsh or overly lenient in the assessment of
applicants, which made applicants’ chances of admission unduly
dependent on which staff members evaluated their applications.
Further, although the campuses allowed academic departments to
have input in admissions decisions, the campuses provided little or
no oversight of the processes that academic departments use when
evaluating applications for majors in their departments, creating
risk of improper influence on their recommendations of applicants
for admission.
The Office of the President Has Not Safeguarded the University’s
Admissions Process
Page 53
The university’s Office of the President has not reviewed the campuses’
admissions processes to detect and prevent unfair or inconsistent
practices. Instead, it has allowed weaknesses to persist for years.
Further, the Office of the President has not monitored or encouraged
high school participation in its program called Eligible in the
Local Context, a critical university effort to increase campuses’
admission of disadvantaged high school students. Consequently, nearly
30 percent of eligible schools—more than 600 schools—in the State do
not participate, resulting in thousands of high school students missing
an opportunity to obtain guaranteed admission to the university.
Summary of Recommendations
Beginning with the admissions cycle for applicants applying for
academic year 2021–22, the Office of the President should require all
campuses to do the following:
• Before admitting prospective student athletes, verify their
athletic talents and review donation records for indicators of
inappropriate activity.
• Establish and follow predetermined criteria for how they will
select the applicants they admit, including the circumstances
under which they will admit an applicant whom their reviewers
have determined to be less qualified than others they reject.
CALIFORNIA STATE AUDITOR | Report 2019-113 3
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Beginning with the admissions cycle for academic year 2021–22,
the Office of the President should oversee UC Berkeley’s admissions
process for at least three admissions cycles to ensure that the
campus provides a merit‑based admissions process that is free of
improper influence.
By March 2021, the Office of the President should require that all
campuses establish proficiency standards for application reviewers
and monitor those reviewers’ ratings for consistency.
By April 2021, the Office of the President should begin regular
audits of the campuses’ admissions processes to assess them for
weaknesses, identify inappropriate admissions decisions, and
recommend improvements.
At least annually, the Office of the President should assess its
Eligible in the Local Context program to ensure that as many
high school students as possible are able to participate.
Agency Comments
The Office of the President did not state whether it would
implement our recommendations. Instead, it stated that the
university is committed to safeguarding the integrity of its
admissions practices, and that it would take prompt action to
address the issues raised in our report.
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CALIFORNIA STATE AUDITOR | Report 2019-113 5
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INTRODUCTION
University Freshman Eligibility Requirements
Background and Admissions Factors
Minimum Eligibility Requirements
The University of California (university) is the
• Completion of 15 university‑approved college
State’s most selective public postsecondary
preparatory (A‑G) courses*
education system. It has nine campuses that
offer undergraduate education, each of which • A grade point average of at least 3.0 in those courses that
are taken in the 10th and 11th grades (3.4 for out‑of‑state
is responsible for implementing the university’s
students)
admissions process and deciding which applicants
to admit to its campus.1 However, the university’s • Completion of the ACT or SAT exam with writing section†
leadership sets admissions standards and guides
Factors Campuses May Consider When Evaluating Applicants
the campuses’ conduct of admissions activities.
• Grade point average for all academic courses
Specifically, the University of California Board
of Regents (Regents)—the university’s governing • Standardized test scores†
body—adopts university policies, including those • Courses taken beyond the minimum specified in the
related to admissions. The Academic Senate, made eligibility requirements
up of university faculty members, sets conditions
• Honors, advanced placement, or college courses taken
for admission that are subject to the Regents’
• Ranking within the student’s high school class
approval, largely through its Board of Admissions
and Relations with Schools (BOARS) committee. • Quality of academic courses planned for senior year
Finally, the university’s Office of the President has
• Quality of academic performance relative to available
authority over university operations, serves as the educational opportunities
systemwide headquarters, and supports campuses’
• Academic accomplishments in light of life experiences
admissions and enrollment.
and special circumstances
• Outstanding performance in a specific academic subject
To be eligible for admission, applicants to the
university generally must meet its minimum • Outstanding work on special projects in any academic field
eligibility criteria, which the text box lists. The • Work on school or community special projects
university requires campuses to verify applicants’
• Recent improvement in academic performance
eligibility. However, eligibility is not a guarantee
of admission. The university expects campuses • Special talents, skills, or interests or other significant
experiences or achievements
to use a process known as comprehensive review
to determine which applicants to admit. • Location of high school and residence
Comprehensive review involves evaluating
Source: University undergraduate admissions policy, BOARS’s
applicants using multiple measures of achievement guidelines, and Regents board meeting minutes.
and promise while considering the context in * Applies only to California residents. Out‑of‑state residents
(nonresidents) are required to take 15 college preparatory
which each applicant has demonstrated academic
classes; however, the university does not have a preapproved
accomplishment. BOARS has issued guidelines course list for schools outside of California.
that identify 14 different factors—such as academic † In May 2020, the university suspended the testing requirement
until 2024, but allowed campuses the option to consider ACT or
grade point average, quality of academic courses
SAT scores if applicants chose to submit them for fall 2021 and
planned for senior year, and special talents—that fall 2022. Further, on August 31, 2020, a judge prohibited the
university policy allows campuses to consider university from using ACT or SAT test results in its admissions
decisions during the pendency of a related court case.
when evaluating applicants and their fitness for
admission. The text box lists these 14 factors.
1 A 10th campus—the University of California, San Francisco—offers only graduate education and
professional education in medicine, dentistry, pharmacy, and nursing.
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The Undergraduate Admissions Process
Although campuses must adhere to the policies and guidelines that
the university has established for admissions, they have significant
discretion to set their own evaluation standards and establish the
relative importance of the factors they will consider when determining
which applicants to admit. For example, most of the campuses’
comprehensive review processes include a holistic assessment of the
applicants, which does not specifically weight any of the 14 measures
of achievement as more important than others. However, a small
number of campuses weight some of the 14 factors
more heavily than others. Further, some of the
Application Rating Scales at UC Berkeley, UCLA, campuses that perform holistic assessments choose
and UC San Diego to focus almost entirely on one of the 14 factors—
specifically, the factor called special talent—when
UC Berkeley
assessing certain applicants, such as athletes.
Strongly Recommend
Campuses consequently put less emphasis on these
Recommend
applicants’ grade point averages and test scores.
Do Not Recommend
At each of the three campuses whose general
UCLA admissions process we reviewed—the University
1 Emphatically Recommend for Admission of California, Berkeley (UC Berkeley), the
2 Strongly Recommend for Admission University of California, Los Angeles (UCLA),
2.5 Recommend for Admission and the University of California, San Diego
(UC San Diego)—the campus’s office of
3 Acceptable for Admission
undergraduate admissions (admissions office)
4 Qualified – upper half of qualified pool
oversees the holistic assessment of each freshman
4.5 Qualified – lower half of qualified pool
application. These campuses have two different
5 Recommend Deny
staff—whom they refer to as readers—evaluate and
rate each application upon its receipt. Because of
UC San Diego
the volume of applications that they receive, the
1 (Highest rating)
campuses rely on a combination of permanent
2 admissions staff and temporary staff to read all of
2.5 the applications they receive. As the text box shows,
3 the three campuses use different rating scales to
4 evaluate applications. After assigning those ratings,
4.5 as part of their comprehensive review of applicants,
the campuses may also request additional
5 (Lowest rating)
information from the applicants, such as letters of
Source: Analysis of admissions policies at each campus.
recommendation, that the campuses also consider
when making admissions decisions.
After the readers have reviewed and rated each application,
admissions staff are responsible for selecting applicants for
admission. In academic year 2019–20, the three campuses we
reviewed were generally among the most selective. UC San Diego
received 99,000 freshman applications and admitted less than
one‑third of them. UC Berkeley received 87,000 and admitted
16 percent, while UCLA received 111,000 and admitted 12 percent.
CALIFORNIA STATE AUDITOR | Report 2019-113 7
September 2020
After selecting applicants for admission, the campuses offer
some applicants a place on their waitlists, from which they admit
additional applicants as space allows.
Other staff—besides those in the admissions office—participate
in the admissions process for certain applicants. These applicants
generally fit one of two profiles: they are potential athletic recruits or
they are applying to a major that requires an additional review, such
as the theater program at UCLA. In the case of athletic recruits,
coaches or other staff from the campus athletic department identify
potential applicants who have desirable talent. The campuses rely
heavily on their athletics staff to assess the applicants’ athletic
abilities. Also, majors such as business at UC Berkeley or film and
television at UCLA require applicants to submit additional records,
such as essays or portfolios of work, to demonstrate why they should
be selected for admission. Faculty and staff in those departments
then evaluate those submissions and make recommendations to the
admissions office regarding which applicants the campus should
admit. Both athletic recruits and applicants to these specific majors
generally must still meet university eligibility requirements.
The campuses’ processes for reviewing and admitting transfer
applicants are similar to, but distinct from, their freshman
admissions processes. Transfer applicants establish eligibility for
admission to the university through completion of specified college
coursework with a required minimum grade point average of 2.4 for
residents and 2.8 for nonresidents. All three campuses have only
one reader evaluate and rate each transfer application, but those
reviews vary by campus. UCLA and UC Berkeley holistically review
transfer applicants in a process similar to the freshman review
process, but they heavily emphasize the applicant’s completion of
the required coursework and academic performance. In contrast,
UC San Diego does not holistically review transfer applications,
and instead only focuses on whether the applicant meets minimum
coursework requirements, such as completing a select number of
transferable courses. Throughout this report, unless we specify
otherwise, we refer to both the freshman and transfer admissions
processes when discussing campuses’ admissions processes.
Admission by Exception
As we describe earlier, the university has established minimum
eligibility requirements for admission to ensure that incoming students
are well prepared to succeed at the university. However, university
policy provides some flexibility to campuses by allowing them to
admit a small percentage—up to 6 percent of enrolled applicants—
of applicants who do not meet those eligibility requirements. The
university refers to such an admission as an admission by exception.
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According to BOARS’s guidelines, this policy exists because
the eligibility criteria do not recognize an applicant’s full set of
achievements, talents, or personal circumstances. Furthermore,
BOARS states that this policy provides a means to identify applicants
who do not meet the technical requirements for eligibility but who
demonstrate strong likelihood of success at or exceptional potential
to contribute to the university.
Consistent with the university’s policy on comprehensive review,
readers do not consider whether applicants have met the eligibility
requirements when rating applications. Rather, as
Figure 1 shows, readers evaluate applicants based
The University’s Admission by Exception
on the 14 allowable factors we discuss earlier.
Implementation Guidelines
Campuses then select applicants for admission,
Campuses may admit applicants by exception if they generally based on those ratings. BOARS’s
demonstrate “a strong likelihood of success or exceptional guidelines issued in 2020 state that the campuses
potential to contribute to the university.” Campuses will identify the applicants from California whom
can consider applicants who fall into one of the they have selected who do not meet eligibility
following categories: requirements and record the reasons why they are
admitting these applicants despite their ineligibility.
• They have overcome personal challenges that have
affected their ability to meet eligibility requirements,
including being low‑income, refugees, first‑generation BOARS provides recommended reasons for
college attendees, veterans, or have lived in foster care. considering an applicant for admission by
exception, which the text box summarizes.2 For
• They have had nontraditional educational
example, an applicant who attended a high school
opportunities that have affected their ability to meet
that did not offer all of the required coursework
eligibility requirements.
but who still demonstrated high academic
• They have demonstrated exceptional talent,
achievement, could be a candidate for admission
accomplishments, or potential in athletics, performing
by exception. Similarly, an applicant who is a highly
arts, a specific academic area, leadership, or in
accomplished athlete but whose GPA dropped
contributing to the community.
below 3.0 could also be a candidate for admission
• They would enable campuses to establish new majors. by exception. However, not every applicant
• They possess academic achievements equivalent to admitted because of a special talent is admitted
eligible applicants but narrowly missed admissions by exception. In fact, at the three campuses we
requirements. reviewed, the majority of applicants whom the
campuses admitted because they were prospective
Source: BOARS’s guidelines.
student athletes or because of their skill in the arts
met the university’s eligibility requirements.
2 In April 2020, BOARS issued updated guidelines related to admission by exception. Among other
changes, BOARS narrowed the applicability of the guidelines to apply to only California resident
applicants as opposed to nonresidents. This change is consistent with how the university has
interpreted its admission by exception policy when assessing compliance in the annual reports
that BOARS submits to the Regents. It also added guidance related to tracking and reporting
these admissions to BOARS.
CALIFORNIA STATE AUDITOR | Report 2019-113 9
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Figure 1
Readers Do Not Consider Whether Applicants Meet University Requirements When Rating Applications
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ACCEPTED
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(cid:27)(cid:30)(cid:17)(cid:16)(cid:27)(cid:28)(cid:25)(cid:21)(cid:20)(cid:30)(cid:25)(cid:27)(cid:30)(cid:29)(cid:26)(cid:16)(cid:15)(cid:26)(cid:25)(cid:8)(cid:16)(cid:27)(cid:25)(cid:29)(cid:28)(cid:10)(cid:23)(cid:21)(cid:21)(cid:23)(cid:15)(cid:12)(cid:25)(cid:21)(cid:20)(cid:30)(cid:10)(cid:25)(cid:4)(cid:6)(cid:25)(cid:30)(cid:3)(cid:17)(cid:30)(cid:19)(cid:21)(cid:23)(cid:16)(cid:15)(cid:14)(cid:25)
(cid:7)(cid:15)(cid:23)(cid:24)(cid:30)(cid:27)(cid:26)(cid:23)(cid:21)(cid:6)(cid:25)(cid:12)(cid:9)(cid:23)(cid:28)(cid:29)(cid:15)(cid:17)(cid:30)(cid:25)(cid:28)(cid:23)(cid:27)(cid:30)(cid:17)(cid:21)(cid:26)(cid:25)(cid:17)(cid:29)(cid:10)(cid:19)(cid:9)(cid:26)(cid:30)(cid:26)(cid:25)(cid:21)(cid:16)(cid:25)(cid:27)(cid:30)(cid:19)(cid:16)(cid:27)(cid:21)(cid:25)(cid:21)(cid:20)(cid:30)(cid:25)
(cid:15)(cid:9)(cid:10)(cid:4)(cid:30)(cid:27)(cid:25)(cid:16)(cid:8)(cid:25)(cid:29)(cid:19)(cid:19)(cid:18)(cid:23)(cid:17)(cid:29)(cid:15)(cid:21)(cid:26)(cid:25)(cid:21)(cid:20)(cid:30)(cid:6)(cid:25)(cid:20)(cid:29)(cid:24)(cid:30)(cid:25)(cid:29)(cid:28)(cid:10)(cid:23)(cid:21)(cid:21)(cid:30)(cid:28)(cid:25)(cid:4)(cid:6)(cid:25)(cid:30)(cid:3)(cid:17)(cid:30)(cid:19)(cid:21)(cid:23)(cid:16)(cid:15)(cid:25)
(cid:21)(cid:16)(cid:25)(cid:21)(cid:20)(cid:30)(cid:25)(cid:2)(cid:1)(cid:23)(cid:17)(cid:30)(cid:25)(cid:16)(cid:8)(cid:25)(cid:21)(cid:20)(cid:30)(cid:25)(cid:127)(cid:27)(cid:30)(cid:26)(cid:23)(cid:28)(cid:30)(cid:15)(cid:21)(cid:14)
Source: Analysis of Regents’ policy and BOARS’s guidelines.
10 Report 2019-113 | CALIFORNIA STATE AUDITOR
September 2020
The National College Admissions Scandal
In March 2019, federal prosecutors publicly announced their
investigation into a college admission scheme that led to criminal
charges against more than 50 people—including parents, college
and university coaches, and a founder of a for‑profit college
counseling and preparation business—related to falsifying
information to facilitate the admission of more than 30 students to
more than 10 different universities. Because the university admitted
two of these students, it was one of many academic institutions
implicated in this investigation. Specifically, a former men’s soccer
coach at UCLA pled guilty to accepting bribes in return for falsely
designating two applicants as competitive athletes, one of whom
UCLA admitted. Investigators found that another applicant whom
UC Berkeley admitted had submitted fraudulent standardized test
scores to UC Berkeley. In response to the federal investigation,
in March 2019 the university initiated an internal audit of its
systemwide and campus‑specific admissions processes, which
it completed in February 2020. The audit, which the campuses
largely performed themselves, found weaknesses in several areas
of the university’s admissions processes, including its processes
related to athletic recruits and to admissions by exception. The
audit recommended several improvements to strengthen campus
admissions system processes.
The federal investigation’s identification of the two inappropriate
admissions to the university generated concern from members
of the public and the Legislature. At the direction of the Joint
Legislative Audit Committee (Audit Committee), we reviewed the
admissions processes at UC Berkeley, UCLA, and UC San Diego,
with particular focus on the risk of improper influence in
admissions decisions. We also reviewed the University of California,
Santa Barbara (UC Santa Barbara), in the areas of our audit that
related to student‑athlete admissions.
CALIFORNIA STATE AUDITOR | Report 2019-113 11
September 2020
Campus Staff Took Advantage of Weaknesses in
Admissions Processes to Inappropriately Admit
64 Students as Favors to Donors, Family, and Friends
Key Points
• Our review found that campuses admitted 64 applicants—in addition to the two
identified in the federal investigation—for academic years 2013–14 through 2018–19
on the basis of their families’ donations to campuses or their connections to campus
staff, leadership, and donors. These inappropriate admissions decisions subverted
the university’s high standards for admissions and denied more qualified applicants
educational opportunities.
• Campus staff falsely designated 22 of these applicants as student‑athlete recruits because
of donations from or as favors to well‑connected families. Each campus we reviewed
lacked sufficient processes for verifying that the applicants whom coaches identified as
student‑athlete recruits actually possessed experience or athletic talent in the sport that
they purportedly played.
• UC Berkeley inappropriately admitted 42 other applicants who were connected to
campus staff and donors. These applicants were less qualified than many others for
whom the campuses denied admission. In fact, some of these applicants received the
lowest possible scores on their applications. The involvement of multiple members
of management at UC Berkeley in these inappropriate admissions demonstrates that
campus leadership failed to foster a culture committed to the university’s principles of
fairness in admissions decisions.
In Violation of University Policy, the Campuses We Reviewed Admitted 64 Applicants Because of
Their Families’ Donations and Connections
Because the university’s admissions process determines who has access to the high‑quality
education it provides, maintaining the integrity of that process is essential. The university has
established high standards for its admissions process and has regularly stated that it bases
admissions decisions on an applicant’s merit, achievement, and life experiences. Through
those statements, the university has effectively affirmed that factors such as relationships to
university staff, parents who are alumni, and financial gifts and donations have no place in
admissions decisions.
Despite the paramount importance of adhering to its high standards, the university has admitted
some students because of inappropriate factors. As Figure 2 shows, we found 64 applicants across
all four campuses we reviewed whom the campuses admitted for academic years 2013–14 through
2018–19 because of donations from the applicants’ families or because of relationships with
campus personnel, alumni, or prominent donors. The majority of these applicants were white
and at least half had annual family incomes of $150,000 or more. In most of these 64 cases, the
campuses admitted the applicants even though those who reviewed their applications (readers)
had determined that the applicants’ levels of achievement were not competitive for admission.
12 Report 2019-113 | CALIFORNIA STATE AUDITOR
September 2020
For example, as the text box shows, UC Berkeley
admitted one applicant as an athlete based on their
Excerpts of UC Berkeley Coach Emails
family’s ability to donate significantly to the athletics
Assistant Coach to Head Coach
department.3 This admission occurred despite the
coaches’ repeated assessment before the family’s
[The family’s] recruiting agent called me up […] to have a
offer to donate that the applicant lacked the talent to
direct conversation about what needed to happen next with
compete at the campus. After the exchange the
this kid. After beating around the bush for a little bit, he said the
text box depicts, the applicant’s family made a large
family has made it clear they would like to “add to the legacy
donation to the team, and the coaches facilitated the
of the [sports team] and their family at Berkeley” to the tune of
applicant’s admission. As we describe in the sections
$[Amount redacted] donation. Figured I’d double check with you
guys before I told him “thanks/no thanks.” that follow, because of limitations in the evidence
available for our review regarding the campuses’
Head Coach to Assistant Coach
admissions processes, there were likely more
Excerpts of UC Berkeley Coach Emails $[Amount redacted] upfront for this year? inappropriate admissions at the campuses than the
64 we describe in this report.
Assistant Coach to Head Coach
Assistant Coach to Head Coach
We didn’t get that far into the conversation…wanted to touch Campus staff were able to engineer many of these
[The family’s] recruiting agent called me up […] to have a direct conversation about what needed base with you first and told him I’d get back to him later this 64 inappropriate admissions—which we describe
to happen next with this kid. After beating around the bush for a little bit, he said the family week…but he sounded very serious. in further detail in the following sections—because
has made it clear they would like to “add to the legacy of the [sports team] and their family at the campuses failed to implement important
THREE DAYS LATER…
Berkeley” to the tune of $[Amount redacted] donation. Figured I’d double check with you guys safeguards against improper influence on admissions
Assistant Coach to Recruiting Agent
before I told him “thanks/no thanks.” decisions. The missing safeguards include separating
After getting a chance to discuss our conversation with the staff decision‑making authority between multiple
Head Coach to Assistant Coach yesterday, [Head Coach] is open to opportunities and would like individuals to ensure that no single individual is
the chance to speak on the phone. If the [family] is willing to responsible for an admission decision and validating
establish their legacy with Berkeley and [the sports team] very key information about applicants before offering
soon involving the figures you suggested, we’ve already identified admission. Other missing safeguards include
specific short‑term & long‑term needs of the program. With this
Assistant Coach to Head Coach requiring staff involved in admissions decisions
could *possibly* come early admission for [applicant] to facilitate
to disclose in advance any associations to external
the process & agreement. We would need [applicant’s] transcripts,
We didn’t get that far into the conversation…wanted to touch base with you first and told him I’d organizations, such as sports clubs, or to individuals
SAT/ACT test scores, a PDF of [their] complete application & a
get back to him later this week…but he sounded very serious. who may apply in the upcoming admissions cycle.
letter of recommendation from a recent instructor to speed the
Further, a robust approach to protecting the
process along.
Three days later… integrity of admissions would include prohibiting
Source: UC Berkeley email records.
communication between development staff—those
Assistant Coach to Recruiting Agent responsible for donor relations—and those involved
in admission activities. By adopting strong policies
After getting a chance to discuss our conversation with the staff yesterday, [Head Coach] is open to and providing training about inappropriate influence
opportunities and would like the chance to speak on the phone. If the [family] is willing to establish in admissions decisions, the campuses could insulate the admissions
their legacy with Berkeley and [the sports team] very soon involving the figures you suggested, process from improper interference. In the absence of these practices,
we’ve already identified specific short‑term & long‑term needs of the program. With this could staff at the four campuses took advantage of the gaps in admissions
*possibly* come early admission for [applicant] to facilitate the process & agreement. We would processes to the detriment of the university. When it does not
need [applicant’s] transcripts, SAT/ACT test scores, a PDF of [their] complete application & a maintain an admissions process free of inappropriate influence,
the university risks admitting applicants because of their families’
letter of recommendation from a recent instructor to speed the process along.
connections or wealth while depriving other more qualified applicants
Source: UC Berkeley email records. of the opportunities that they have earned.
3 To protect the identities of the applicants we describe in this report, we withhold certain details
regarding the circumstances of their admissions and avoid the use of gendered pronouns.
CALIFORNIA STATE AUDITOR | Report 2019-113 13
September 2020
Figure 2
The University Admitted 64 Students Based on Inappropriate Factors
The University admitted 64 STUDENTS based on factors
that favored wealthy and well-connected applicants:
WELCOME NEW STUDENTS
(cid:31)(cid:30)(cid:30)(cid:29)(cid:28)(cid:27)(cid:26)(cid:25)(cid:24)(cid:23)(cid:22)(cid:26)(cid:22)(cid:21)(cid:20)(cid:26)(cid:24)(cid:23)(cid:19)(cid:18)(cid:17)(cid:23)(cid:26)(cid:23) (cid:10)(cid:13)(cid:28)(cid:29)(cid:11)(cid:23)(cid:18)(cid:19)(cid:23)(cid:26)(cid:23)(cid:13)(cid:28)(cid:15)(cid:13)(cid:23) (cid:10)(cid:13)(cid:28)(cid:29)(cid:11)(cid:23)(cid:18)(cid:19)(cid:23)(cid:26)(cid:23)
(cid:27)(cid:18)(cid:29)(cid:29)(cid:16)(cid:26)(cid:15)(cid:14)(cid:16)(cid:23)(cid:18)(cid:19)(cid:23)(cid:24)(cid:13)(cid:16)(cid:23)(cid:19)(cid:18)(cid:17)(cid:12)(cid:16)(cid:17)(cid:23) (cid:29)(cid:16)(cid:5)(cid:16)(cid:29)(cid:23)(cid:14)(cid:25)(cid:28)(cid:5)(cid:16)(cid:17)(cid:20)(cid:28)(cid:24)(cid:21)(cid:23) (cid:12)(cid:26)(cid:9)(cid:18)(cid:17)(cid:23)(cid:11)(cid:18)(cid:25)(cid:18)(cid:17)
(cid:11)(cid:28)(cid:17)(cid:16)(cid:27)(cid:24)(cid:18)(cid:17)(cid:23)(cid:18)(cid:19)(cid:23)(cid:14)(cid:25)(cid:11)(cid:16)(cid:17)(cid:15)(cid:17)(cid:26)(cid:11)(cid:14)(cid:26)(cid:24)(cid:16)(cid:23) (cid:20)(cid:24)(cid:26)(cid:4)(cid:23)(cid:12)(cid:16)(cid:12)(cid:22)(cid:16)(cid:17)
(cid:26)(cid:11)(cid:12)(cid:28)(cid:20)(cid:20)(cid:28)(cid:18)(cid:25)(cid:20)
(cid:31)(cid:30)(cid:30)(cid:29)(cid:28)(cid:27)(cid:26)(cid:25)(cid:24)(cid:8)(cid:20)(cid:23)(cid:19)(cid:26)(cid:12)(cid:28)(cid:29)(cid:21)(cid:23)(cid:7)(cid:26)(cid:20)(cid:23) (cid:10)(cid:13)(cid:28)(cid:29)(cid:11)(cid:23)(cid:18)(cid:19)(cid:23)(cid:26)(cid:23)(cid:30)(cid:17)(cid:18)(cid:12)(cid:28)(cid:25)(cid:16)(cid:25)(cid:24)(cid:23) (cid:31)(cid:30)(cid:30)(cid:29)(cid:28)(cid:27)(cid:26)(cid:25)(cid:24)(cid:8)(cid:20)(cid:23)
(cid:19)(cid:17)(cid:28)(cid:16)(cid:25)(cid:11)(cid:20)(cid:23)(cid:7)(cid:28)(cid:24)(cid:13)(cid:23)(cid:26)(cid:23)(cid:6)(cid:16)(cid:15)(cid:16)(cid:25)(cid:24) (cid:26)(cid:29)(cid:14)(cid:12)(cid:25)(cid:14)(cid:20) (cid:19)(cid:26)(cid:12)(cid:28)(cid:29)(cid:21)(cid:23)(cid:30)(cid:17)(cid:18)(cid:12)(cid:28)(cid:20)(cid:16)(cid:11)(cid:23)
(cid:26)(cid:23)(cid:29)(cid:26)(cid:17)(cid:15)(cid:16)(cid:23)(cid:11)(cid:18)(cid:25)(cid:26)(cid:24)(cid:28)(cid:18)(cid:25)
These applicants were less qualified than other applicants to
whom the campuses denied admission.
Source: Analysis of admissions records, donations, and athletics participation at UC Berkeley, UCLA, UC Santa Barbara, and UC San Diego from
academic years 2013–14 through 2019–20.
14 Report 2019-113 | CALIFORNIA STATE AUDITOR
September 2020
Coaches and Athletic Staff Falsely Designated 22 Applicants as
Qualified Athletes as Favors to Donors and Friends
At each campus, coaches and athletic staff designate applicants
whom they want to recruit for their teams as prospective student
athletes. Campuses may eventually admit these prospective student
athletes with the understanding that they will bring a valuable
talent to a campus athletic program. As the text box shows, we
reviewed prospective student‑athlete admissions from academic
years 2013–14 through 2018–19 for at least six sports teams at
each of four campuses: UC Berkeley, UCLA, UC San Diego, and
UC Santa Barbara. We found 22 instances in which coaches at those
campuses designated applicants as prospective student athletes
and each of the following was true: the applicants
lacked the necessary athletic qualifications; they
Inappropriate Admissions of Prospective did not substantially participate on the team for
Student Athletes which they were recruited; and evidence indicates
that donations or potential donations to the
We reviewed prospective student‑athlete admissions for at
university, a family’s level of influence, or familial
least six of the following teams at each campus:
connections influenced the decision to designate
• Men’s soccer
the applicants as student athletes.
• Women’s soccer
• Men’s crew In some cases, the campus appeared to admit
• Women’s crew the applicants in exchange for donations to the
• Men’s track and field athletic department. Figure 3 depicts one of these
cases, in which a UC Berkeley coach facilitated the
• Women’s track and field
admission of an applicant as a prospective student
• Men’s golf
athlete, even though the applicant had played
• Women’s golf
only a single year of the sport in high school and
• Men’s water polo at a low level of competition. After admission,
• Women’s water polo the applicant’s family donated several thousand
• Men’s swimming dollars to the team. However, the applicant
never competed with the team, and the coaches
• Women’s swimming
removed the applicant from the team after the
• Women’s basketball
season ended.
• Men’s tennis
Additionally, coaches designated some applicants
We found that each campus inappropriately admitted the
as prospective student athletes because of their
following number of applicants as student athletes:
connections to campus personnel or influential
• UC Berkeley: 13
alumni and donors. For example, a coach at
• UCLA: 4 UC Santa Barbara (Coach 1) worked with a
• UC San Diego: 1 different team’s coach (Coach 2) to admit an
applicant for Coach 2’s team who was initially
• UC Santa Barbara: 4
denied admission during the standard application
Source: Analysis of applications, admissions data, email records, process. The applicant’s family were donors to
and athletics records at each campus.
Coach 1’s team and also donated to Coach 2’s team
at the same time their child applied for admission.
CALIFORNIA STATE AUDITOR | Report 2019-113 15
September 2020
Figure 3
Staff at UC Berkeley Used Vulnerabilities in the Athletics Admissions Processes to Admit an Unqualified Applicant
1 2
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(cid:21)(cid:16)(cid:16)(cid:25)(cid:26)(cid:29)(cid:24)(cid:28)(cid:15)(cid:23)(cid:28)(cid:14)(cid:13)(cid:28)(cid:12)(cid:29)(cid:18)(cid:11)(cid:29)(cid:25)(cid:29)(cid:10)(cid:28)(cid:21)(cid:17)(cid:24)(cid:28) (cid:24)(cid:29)(cid:16)(cid:21)(cid:18)(cid:15)(cid:20)(cid:29)(cid:17)(cid:15)(cid:28)(cid:27)(cid:23)(cid:17)(cid:15)(cid:21)(cid:27)(cid:15)(cid:29)(cid:24)(cid:28)(cid:21)(cid:28)(cid:27)(cid:23)(cid:21)(cid:27)(cid:30)(cid:28)(cid:21)(cid:6)(cid:23)(cid:4)(cid:15)(cid:28)(cid:15)(cid:30)(cid:29)(cid:28)
(cid:18)(cid:29)(cid:27)(cid:29)(cid:26)(cid:9)(cid:29)(cid:24)(cid:28)(cid:15)(cid:30)(cid:29)(cid:28)(cid:25)(cid:23)(cid:8)(cid:29)(cid:7)(cid:15)(cid:28)(cid:16)(cid:23)(cid:7)(cid:7)(cid:26)(cid:6)(cid:25)(cid:29)(cid:28) (cid:21)(cid:16)(cid:16)(cid:25)(cid:26)(cid:27)(cid:21)(cid:17)(cid:15)(cid:5)
(cid:7)(cid:27)(cid:23)(cid:18)(cid:29)(cid:7)(cid:28)(cid:23)(cid:17)(cid:28)(cid:15)(cid:30)(cid:29)(cid:26)(cid:18)(cid:28)(cid:21)(cid:16)(cid:16)(cid:25)(cid:26)(cid:27)(cid:21)(cid:15)(cid:26)(cid:23)(cid:17)(cid:5)
“…[The applicant’s father] has
huge capacity and is already
a big supporter of Cal.”
DO NOT
RECOMMEND
ASSOCIATE
DIRECTOR COACH
3 4
(cid:31)(cid:30)(cid:29)(cid:28)(cid:27)(cid:23)(cid:21)(cid:27)(cid:30)(cid:28)(cid:22)(cid:21)(cid:25)(cid:7)(cid:29)(cid:25)(cid:10)(cid:28)(cid:26)(cid:24)(cid:29)(cid:17)(cid:15)(cid:26)(cid:22)(cid:26)(cid:29)(cid:24)(cid:28)(cid:15)(cid:30)(cid:29)(cid:28)
(cid:21)(cid:16)(cid:16)(cid:25)(cid:26)(cid:27)(cid:21)(cid:17)(cid:15)(cid:28)(cid:21)(cid:7)(cid:28)(cid:21)(cid:28)(cid:3)(cid:4)(cid:21)(cid:25)(cid:26)(cid:22)(cid:26)(cid:29)(cid:24)(cid:28)(cid:21)(cid:15)(cid:30)(cid:25)(cid:29)(cid:15)(cid:29)(cid:28)
(cid:21) (cid:24) (cid:17) (cid:26)(cid:18) (cid:24) (cid:29) (cid:28) (cid:27) (cid:17) (cid:15) (cid:23) (cid:23) (cid:15) (cid:18) (cid:26) (cid:28) (cid:22) (cid:15) (cid:26) (cid:30) (cid:29) (cid:21) (cid:24) (cid:15) (cid:28) (cid:28) (cid:15) (cid:30) (cid:30) (cid:29) (cid:29) (cid:28) (cid:28) (cid:30) (cid:21) (cid:21) (cid:7) (cid:24) (cid:7)(cid:23) (cid:28)(cid:24) (cid:27) (cid:23) (cid:26)(cid:21) (cid:17) (cid:15) (cid:29) (cid:29) (cid:28) (cid:28) (cid:7)(cid:23)(cid:5) STUD A E D N M T A IT T T H E L D
ETE
STU A D TE HNTL
EATTHELETE
(cid:31)(cid:30)(cid:29)(cid:28)(cid:27)(cid:26)(cid:25)(cid:27)(cid:24)(cid:27)(cid:23)(cid:29)(cid:22)(cid:21)(cid:20)(cid:19)(cid:18)(cid:18)(cid:27)(cid:21)(cid:29)
(cid:18)(cid:17)(cid:27)(cid:29)(cid:22)(cid:16)(cid:16)(cid:24)(cid:19)(cid:15)(cid:22)(cid:14)(cid:18)(cid:29)(cid:22)(cid:13)(cid:29)(cid:22)(cid:29)
(cid:13)(cid:18)(cid:12)(cid:21)(cid:27)(cid:14)(cid:18)(cid:29)(cid:22)(cid:18)(cid:17)(cid:24)(cid:27)(cid:18)(cid:27)(cid:11)(cid:29)
COACH
5 6
…(cid:7)(cid:4)(cid:6)(cid:7)(cid:29)(cid:3)(cid:4)(cid:29)(cid:17)(cid:15)(cid:25)(cid:10)(cid:2)(cid:28)(cid:15)(cid:30)(cid:29)(cid:28)(cid:21)(cid:16)(cid:16)(cid:25)(cid:26)(cid:27)(cid:21)(cid:17)(cid:15)(cid:1)(cid:7)(cid:28)
(cid:22)(cid:21)(cid:20)(cid:26)(cid:25)(cid:10)(cid:28)(cid:24)(cid:23)(cid:17)(cid:21)(cid:15)(cid:29)(cid:24)(cid:28)(cid:15)(cid:30)(cid:23)(cid:4)(cid:7)(cid:21)(cid:17)(cid:24)(cid:7)(cid:28)(cid:23)(cid:22)(cid:28)
(cid:24)(cid:23)(cid:25)(cid:25)(cid:21)(cid:18)(cid:7)(cid:28)(cid:15)(cid:23)(cid:28)(cid:15)(cid:30)(cid:29)(cid:28)(cid:15)(cid:29)(cid:21)(cid:20)(cid:5)(cid:28)
(cid:10)(cid:17)(cid:27)(cid:29)(cid:22)(cid:16)(cid:16)(cid:24)(cid:19)(cid:15)(cid:22)(cid:14)(cid:18)(cid:29)(cid:14)(cid:27)(cid:9)(cid:27)(cid:26)(cid:29)(cid:15)(cid:8)(cid:20)(cid:16)(cid:27)(cid:18)(cid:27)(cid:21)(cid:29)
(cid:7)(cid:8)(cid:26)(cid:29)(cid:18)(cid:17)(cid:27)(cid:29)(cid:18)(cid:27)(cid:22)(cid:20)(cid:11)
APPLICANT’S
FAMILY COACH
Source: Analysis of admissions records, athletics records, donations, and emails at UC Berkeley.
16 Report 2019-113 | CALIFORNIA STATE AUDITOR
September 2020
After Coach 2 requested the applicant’s admission, UC Santa Barbara’s
admissions department questioned the applicant’s qualifications,
prompting several emails between Coach 1, Coach 2, and the applicant’s
father. In one email, Coach 1 asked the father if the applicant’s high
school coach could “put something together” that would demonstrate
the applicant’s talent and referred to the admissions process as a “game.”
The high school coach eventually submitted a letter of recommendation
that included little detail about the applicant’s athletics skill and instead
focused on the applicant’s personality. UC Santa Barbara then admitted
the applicant as a student athlete despite never receiving any additional
evidence of athletic qualifications. Additionally, we found no evidence the
applicant ever competed for the team.
Coach 1 asked the father if the applicant’s high
school coach could “put something together” that
would demonstrate the applicant’s talent and
referred to the admissions process as a “game.”
In a similar example at UC San Diego, the coach of one team (Coach 1)
asked the coach of another team (Coach 2) to facilitate the admission
of an applicant who was the friend of a UC San Diego athletic board
member. In an email to the athletics director, Coach 2 stated that
Coach 1 shared with him that the board member “had helped out with
scholarships, etc. in the past, and if we could help [the board member],
it may help the department.” Although Coach 2 noted that the applicant
was not a normal recruit and “did not have the grades to get in on [their]
own,” he facilitated the admission of the applicant. Coach 2 said he did so
because he wanted to help the board member and the applicant “looked
like an ok recruit.” The applicant never participated on the team. Coach 2
further stated in the email to the athletics director that he was “not happy
to be used in that manner,” explaining that the “board member used me
to get his family friend’s kid in UCSD,” and noting that, “[the applicant]
wasn’t going to get in otherwise.” Finally, the coach wrote that he “would
handle this differently if it wasn’t for [the applicant’s] relationship to
[UC San Diego’s] board member.”
Figure 4 shows an example at UCLA where a coach facilitated the
admission of an applicant after a member of the development office—
which is the department responsible for fundraising and donor
relations—advocated for the applicant’s admission on behalf of a donor.
Although we found the applicant participated in high school in the sport
for which they were recruited, we found that they were significantly less
qualified than other recruits to the team, and they did not meaningfully
participate on the team for UCLA.
CALIFORNIA STATE AUDITOR | Report 2019-113 17
September 2020
Figure 4
At UCLA, Development Staff and Coaches Admitted an Applicant Because of a Connection to a Donor
1 2
(cid:10)(cid:23)(cid:28)(cid:25)(cid:16)(cid:16)(cid:15)(cid:24)(cid:27)(cid:25)(cid:23)(cid:20)(cid:28)(cid:9)(cid:25)(cid:21)(cid:28) (cid:7)(cid:28)(cid:21)(cid:24)(cid:22)(cid:23)(cid:24)(cid:6)(cid:24)(cid:27)(cid:25)(cid:23)(cid:20)(cid:28)(cid:18)(cid:26)(cid:23)(cid:26)(cid:10)(cid:28)(cid:20)(cid:26)(cid:28)(cid:5)(cid:4)(cid:3)(cid:7)(cid:2)(cid:28)
(cid:18)(cid:29)(cid:23)(cid:24)(cid:29)(cid:18)(cid:28)(cid:25)(cid:18)(cid:7)(cid:24)(cid:21)(cid:21)(cid:24)(cid:26)(cid:23) (cid:15)(cid:30)(cid:26)(cid:28)(cid:15)(cid:25)(cid:21)(cid:28)(cid:25)(cid:28)(cid:6)(cid:25)(cid:11)(cid:24)(cid:16)(cid:12)(cid:28)(cid:6)(cid:10)(cid:24)(cid:29)(cid:23)(cid:18)(cid:28)(cid:26)(cid:6)(cid:28)(cid:20)(cid:30)(cid:29)(cid:28)
(cid:25)(cid:17)(cid:17)(cid:16)(cid:24)(cid:27)(cid:25)(cid:23)(cid:20)(cid:2)(cid:28)(cid:10)(cid:29)(cid:6)(cid:29)(cid:10)(cid:10)(cid:29)(cid:18)(cid:28)(cid:20)(cid:30)(cid:29)(cid:28)(cid:25)(cid:17)(cid:17)(cid:16)(cid:24)(cid:27)(cid:25)(cid:23)(cid:20)(cid:28)
DENIED (cid:24)(cid:23)(cid:28)(cid:20)(cid:30)(cid:29)(cid:28)(cid:14)(cid:29)(cid:22)(cid:12)(cid:15)(cid:25)(cid:14)
(cid:20)(cid:26)(cid:28)(cid:20)(cid:30)(cid:29)(cid:28)(cid:18)(cid:29)(cid:1)(cid:29)(cid:16)(cid:26)(cid:17)(cid:11)(cid:29)(cid:23)(cid:20)(cid:28)(cid:26)(cid:19)(cid:24)(cid:27)(cid:29)(cid:28)(cid:25)(cid:21)(cid:28)(cid:25)(cid:28)
(cid:25)(cid:18)(cid:7)(cid:24)(cid:21)(cid:21)(cid:24)(cid:26)(cid:23)(cid:21)(cid:28)(cid:16)(cid:14)(cid:26)(cid:27)(cid:29)(cid:21)(cid:21)(cid:11)
(cid:17)(cid:26)(cid:20)(cid:29)(cid:23)(cid:20)(cid:24)(cid:25)(cid:16)(cid:28)(cid:25)(cid:20)(cid:30)(cid:16)(cid:29)(cid:20)(cid:24)(cid:27)(cid:28)(cid:10)(cid:29)(cid:27)(cid:10)(cid:13)(cid:24)(cid:20)(cid:8)
DONOR
3 4
(cid:10)(cid:17)(cid:20)(cid:29)(cid:14)(cid:9)(cid:25)(cid:14)(cid:18)(cid:8)(cid:28)(cid:18)(cid:29)(cid:13)(cid:29)(cid:15)(cid:26)(cid:16)(cid:7)(cid:29)(cid:23)(cid:20)(cid:28) (cid:31)(cid:30)(cid:29)(cid:28)(cid:27)(cid:26)(cid:25)(cid:27)(cid:30)(cid:24)(cid:23)(cid:22)(cid:28)(cid:21)(cid:20)(cid:25)(cid:19)(cid:28)(cid:24)(cid:18)(cid:29)(cid:23)(cid:20)(cid:24)(cid:17)(cid:24)(cid:29)(cid:18)(cid:28)(cid:20)(cid:30)(cid:29)(cid:28)(cid:25)(cid:16)(cid:16)(cid:15)(cid:24)(cid:27)(cid:25)(cid:23)(cid:20)(cid:28)
(cid:27)(cid:26)(cid:23)(cid:20)(cid:25)(cid:27)(cid:20)(cid:29)(cid:18)(cid:28)(cid:20)(cid:30)(cid:29)(cid:28)(cid:27)(cid:26)(cid:25)(cid:27)(cid:30)(cid:24)(cid:23)(cid:22)(cid:28)(cid:21)(cid:20)(cid:25)(cid:19)(cid:11)(cid:11)(cid:11) (cid:25)(cid:21)(cid:28)(cid:25)(cid:28)(cid:16)(cid:14)(cid:26)(cid:21)(cid:16)(cid:29)(cid:27)(cid:20)(cid:24)(cid:13)(cid:29)(cid:28)(cid:21)(cid:20)(cid:12)(cid:18)(cid:29)(cid:23)(cid:20)(cid:28)(cid:25)(cid:20)(cid:30)(cid:15)(cid:29)(cid:20)(cid:29)(cid:11)
“[Head coach] and I met
with [the donor] (cid:31)(cid:30)(cid:29)(cid:28)(cid:27)(cid:26)(cid:25)(cid:27)(cid:30)(cid:24)(cid:23)(cid:22)(cid:28)(cid:21)(cid:20)(cid:25)(cid:19)(cid:28)(cid:23)(cid:26)(cid:20)(cid:29)(cid:18)(cid:28)(cid:20)(cid:30)(cid:29)(cid:28)
y to e s f t o e ll r o d w ay u a p n w d i w th o h u i l m d l [ i … ke ] (cid:25) (cid:29)(cid:23) (cid:17) (cid:26) (cid:17) (cid:13) (cid:16)(cid:24)(cid:27) (cid:22) (cid:25) (cid:30) (cid:23) (cid:28)(cid:20) (cid:20) (cid:26) (cid:28)(cid:15) (cid:28)(cid:17) (cid:25) (cid:16)(cid:25) (cid:21)(cid:28) (cid:12) (cid:23) (cid:28)(cid:26) (cid:26) (cid:23) (cid:20)(cid:28) (cid:28) (cid:21) (cid:20) (cid:14) (cid:30) (cid:24) (cid:29) (cid:16)(cid:16) (cid:28) (cid:29) (cid:20)(cid:29) (cid:18) (cid:25) (cid:28) (cid:11)(cid:28) STUDE D N EN T I E A DTHLETE
on what we recommend (cid:20)(cid:30)(cid:25)(cid:20)(cid:28)(cid:12)(cid:29)(cid:25)(cid:10)(cid:28)(cid:26)(cid:10)(cid:28)(cid:20)(cid:30)(cid:29)(cid:28)(cid:23)(cid:29)(cid:9)(cid:20)(cid:28)(cid:12)(cid:29)(cid:25)(cid:10)(cid:8)
as next steps.”
“… does [the donor]
want us to help get
[the applicant] admitted…?” 5
“Last chance to object or
“As this one is a bit
push forward. Still think
nuanced, I’d be happy
this is a good idea?”
to discuss tomorrow “If you feel comfortable,
[…] so we can get back
then I think [it’s] good to
to [the donor].” ASSISTANT move ahead.”
COACH
DEVELOPMENT COACH DEVELOPMENT
6 7
“I’m happy to confirm that
[the applicant’s] admission to UCLA
STUD A E D N M T A IT T T H E L D
ETE (cid:6)
(cid:20)(cid:30)
(cid:5)
(cid:29)
(cid:4)
(cid:28)(cid:25)
(cid:10)
(cid:16)
(cid:28)(cid:25)
(cid:16)
(cid:18)
(cid:15)(cid:24)
(cid:7)
(cid:27)(cid:25)
(cid:24)
(cid:23)
(cid:20)(cid:20)
(cid:20)
(cid:29)
(cid:28)(cid:25)
(cid:18)
(cid:21)
(cid:28)
(cid:28)(cid:25)(cid:28) h al a l s o b f e y e o n u r a g p e p n r e o r v o e u d s .. . s T up h p a o n r k t . y ” ou for
(cid:21)(cid:20)(cid:12)(cid:18)(cid:29)(cid:23)(cid:20)(cid:28)(cid:25)(cid:20)(cid:30)(cid:15)(cid:29)(cid:20)(cid:29)(cid:11)
DEVELOPMENT DONOR
Source: Analysis of admissions records, athletics records, donations, and emails at UCLA.
18 Report 2019-113 | CALIFORNIA STATE AUDITOR
September 2020
It is unlikely that the 22 applicants we found represent the true number
of applicants whom coaches falsely identified as prospective student
athletes to gain the applicant’s admission because of their connections
to donors or influential individuals. First, we reviewed athletes for only
a fraction of the athletic teams at each of the campuses. Further, even
among those teams, we identified more than 400 athletes who did
not appear on their teams’ rosters for more than their first year at that
campus—indicating they stopped participating in that sport. Among
that group were several athletes who had questionable circumstances
surrounding their admission whom we did not count in our total
of inappropriate admissions. Some of these athletes had limited or
nonexistent athletic qualifications, while others were related to campus
staff or a prominent donor. Others were immediately made into a team
manager, indicating that the coaches never intended for the applicant
to compete on the team. For example, one applicant we reviewed was
only admitted after the coach rushed the applicant through the athletics
admissions process a few months before the start of the academic year.
Yet our review found no evidence that this applicant ever played the
sport they were recruited for, and the applicant never appeared on
the team’s public roster. Although the timing of this admission and its
circumstances were outliers when compared to other recruiting and
admissions activity, we found no evidence of impropriety. In fact, we
concluded that an applicant’s admission was inappropriate and included
them among the 22 we discuss in this report only when we identified
definitive evidence, such as the emails that we described above, that the
applicant’s admission was improperly influenced by their connections.
Some of these athletes had limited or
nonexistent athletic qualifications, while
others were related to campus staff or a
prominent donor.
The Campuses’ Weak Processes and Inadequate Oversight of Athletics
Admissions Processes Allowed These Inappropriate Admissions to Occur
The campuses’ athletics admissions processes are open to abuse because
they allow for a large percentage of applicants to gain admission on
the basis of much different considerations than the general applicant
pool, and there is inadequate oversight of these admissions processes.
For example, from academic years 2017–18 through 2019–20, UCLA’s
committee for reviewing student‑athlete applicants admitted about
98 percent of the cases it reviewed for fall admission. The other
campuses admitted a significant majority of student‑athlete applicants
as well. In contrast, the four campuses admitted from 14 percent to
CALIFORNIA STATE AUDITOR | Report 2019-113 19
September 2020
32 percent of all applicants. Further, in recognition of the special talents
that the prospective student athletes would bring to the campus,
the admissions process does not hold them to the same academic
or application review standards as the general applicant pool. For
example, the average grade point average for the bottom quartile of
applicants whom UCLA admitted for academic year 2019–20 was 4.15,
but the average grade point average for its admitted student athletes
was 3.74.4 Similarly, two‑thirds of the admitted student athletes whom
UC Berkeley evaluated through its holistic review process for academic
years 2017–18 through 2019–20 received the lowest possible rating
from its application readers—which is equivalent to a recommendation
that the applicant be denied admission. In combination, the high
acceptance rate and lower standards in key areas of applicant review
elevate the risk of inappropriate influence during the admissions
process because they make admission as a prospective student
athlete an attractive option for applicants who are not academically
competitive for admission through the regular admissions process.
Further increasing this risk is the degree to which many teams—
including many of the teams that we reviewed—rely on donations as
a revenue source. For example, from 2014 through 2019, 75 percent
of the UC Berkeley men’s tennis team’s budget came from donations.
Generally, coaches at the campuses are contractually responsible for
fundraising for their teams and use that funding to pay for expenses
such as team travel, athletic scholarships, and salaries for coaches and
support staff. Their reliance on donations to support the continued
existence of their teams can put pressure on coaches to use their
significant influence over the admissions process to falsely designate
applicants as qualified athletes to cultivate a positive relationship with
prospective or existing donors.
Reliance on donations to support their
teams can put pressure on coaches to use
their influence over admissions to falsely
designate applicants as qualified athletes.
Despite the vulnerability to abuse in the athletics admissions process,
none of the four campuses we reviewed implemented effective
safeguards against inappropriate admissions activity in the years
leading up to the national admissions scandal. A primary safeguard
4 Nearly 6 percent of students and 21 percent of athletes did not have a grade point average in the
applications data. Students may not have a grade point average in the data because their high
schools use a grading system that does not easily convert to the standard scale or the students did
not provide enough information on their application to calculate their grade point average.
20 Report 2019-113 | CALIFORNIA STATE AUDITOR
September 2020
is to have someone independent of the athletics department verify
that all prospective student athletes possess talent that qualifies them
as legitimate recruits. Instead of this independent verification, the
campuses largely relied on coaches’ assertions that prospective student
athletes were athletically qualified. At UC San Diego, neither the
athletic department nor undergraduate admissions verified the athletic
talent of applicants whom coaches identified. Although UC Berkeley
and UC Santa Barbara established policies for reviewing the talent of
prospective student athletes, we judgmentally selected 10 athletes at
each of these campuses to determine whether the campus had verified
talent before admitting the student. Neither campus was able to provide
evidence proving the campus had actually performed this talent review.
UCLA was able to provide documentation that it carried out a talent
review of the non‑scholarship prospective student athletes we had
selected for review. However, a single employee within the UCLA
athletics department performed this verification and did not perform
the review for scholarship athletes. In the absence of thorough and
independent talent verification, the campuses allowed the 22 cases of
inappropriate admissions we identified.
A similar, secondary safeguard is verification that student athletes
participate on the teams for which a campus recruited them. Although
some student athletes may leave a team because of injuries or other
legitimate reasons, we found that a student athlete participating for less
than one year is a possible warning sign that the athlete was admitted
inappropriately. However, during the years we reviewed, only two of the
campuses—UC Berkeley and UCLA—had policies that required student
athletes to participate in their sports for a minimum time period of at least
one year. Although these policies also required UC Berkeley and UCLA to
track whether student athletes remained on a roster, none of the campuses
we reviewed had policies for adequately investigating the circumstances of
the admission of athletes who quit the team soon after admission.
None of the campuses had implemented
adequate processes to ensure that donations
did not play a role in the admissions process.
A robust set of safeguards should also address the risk of inappropriate
influence through donations. A regular review of financial contributions
to the university matched against future and past athletic admissions
decisions could prevent and deter admissions decisions based on
donations. However, none of the campuses had implemented adequate
processes—such as an independent review of prospective and recently
admitted student athletes for associated donation history—to ensure that
donations did not play a role in the admissions process. If UC Berkeley
CALIFORNIA STATE AUDITOR | Report 2019-113 21
September 2020
had been monitoring for donations, it likely would have identified
those made by the family of the prospective student athlete that
Figure 3 features, and it could have investigated further.
The University Has Not Made Sufficient Changes Following the National
College Admissions Scandal
In response to recently publicized issues—including a soccer coach
at UCLA who admitted to falsely designating two applicants as
prospective student athletes in exchange for money—and the
systemwide internal audit, the campuses we reviewed began
implementing some safeguards for the athletics admissions
process. However, despite the implementation of these additional
safeguards, none of the campuses have fully addressed the gaps
in their athletics admissions processes. Although each campus
has established a process for verifying athletic talent, only UCLA
and UC Santa Barbara plan to require verification of talent for
all prospective student athletes. UC San Diego is planning to
verify the athletic talent of only the prospective student athletes
to whom it does not offer athletic scholarships. UC Berkeley’s
plan is similar to UC San Diego, with the exception that it
also plans to review prospective student athletes to whom the
campus plans to offer minimal scholarships of about 2 percent.
However, scholarship athletes also represent a risk with respect
to inappropriate admissions activity; a small number of the
22 applicants admitted inappropriately were scholarship athletes,
highlighting the importance of reviewing all prospective student
athletes. Athletics staff at UC San Diego stated that they do not
plan to verify the talent of scholarship athletes because they believe
that the additional level of effort would not significantly reduce the
risk of inappropriate admissions activity. In contrast, the director
of athletic compliance at UC Berkeley explained that not verifying
the talent of all prospective student athletes likely presents a risk,
but that performing those verifications would strain the athletics
department’s resources.
Scholarship athletes represent a risk with
respect to inappropriate admissions activity.
UCLA’s new process for verifying the athletic talent of prospective
student athletes, if implemented systemwide, could strengthen
the university’s safeguards against improper influence in athletics
admissions. Specifically, UCLA has begun establishing criteria
for each sport that prospective student athletes must meet to be
recruited, such as specific times within which an athlete must run a
22 Report 2019-113 | CALIFORNIA STATE AUDITOR
September 2020
specified distance or specific athletic rankings an athlete must achieve.
Evidence of meeting these criteria must come from reputable sources.
The other campuses we reviewed have not implemented a similar policy;
however, such a policy could reduce the risk that a coach would be able to
facilitate the admission of an unqualified applicant.
Additionally, UC Santa Barbara has updated its policies to require that
a committee composed of faculty and admissions staff review talent
documentation for all prospective student athletes, increasing the
independence of the talent verification process. In contrast, UCLA, and
UC San Diego have established policies for verifying athletic talent that
delegate that responsibility to their athletic departments. As a result,
the staff performing the reviews may be subject to internal pressure to
inappropriately approve a prospective student athlete’s qualifications.
Although UC Berkeley’s policy requires both athletics staff and a staff
member in the office of undergraduate admissions to verify some
applicants’ athletic talent, we selected 10 applicants to assess whether
the campus was actually performing these verifications and found it had
not for any of those 10 applicants. Requiring verification by individuals
outside of the athletics department, such as from the office of admissions
or internal audits, would better ensure the objectivity of a review.
Finally, none of the campuses have implemented complete reviews
of applicants admitted through the athletics admissions process to
determine whether donations—both preceding an admissions decision
and also received in the year following the admission—inappropriately
factored into their admission. Policies that UC Berkeley, UCLA, and
UC San Diego recently adopted provide that the campuses will check for
donations connected to recruited athletes at the time of admission, while
UC Santa Barbara has implemented a process for checking the donation
history related to all applicants to whom they are considering offering
admission. However, we observed that donations that were connected to
inappropriate admissions also occurred after applicants were admitted,
as Figure 3 demonstrates. Until the campuses address
this gap, they risk further abuse of their admissions
UC Berkeley Admitted Applicants processes, which undermines the credibility of the
Because They Were Connected to: university and the integrity of the admissions process.
• Donors and potential donors
• Campus staff UC Berkeley Frequently Gave Preferential Treatment to
• Campus managers Relatives and Friends of Faculty, Staff, and Donors
• Managers at other university campuses
At UC Berkeley, improper influence on admissions
• A manager from a local education program
decisions was not limited to its athletics department.
• A colleague from a small private college
Multiple staff in its admissions office were involved
• A counselor from a local high school with admitting 42 additional applicants because of
their relationships to donors, university staff, and
Source: Analysis of UC Berkeley’s admissions records.
others for academic years 2016–17 through 2018–19
as indicated in the text box. As a result of the staff
CALIFORNIA STATE AUDITOR | Report 2019-113 23
September 2020
members’ actions, these 42 applicants took spots that would
otherwise have belonged to applicants who had received higher
ratings. Each of these 42 applicants received reader ratings that
made it unlikely they would receive an offer of admission.5 These
admissions occurred even though UC Berkeley’s own policies
identified that a fundamental principle of its admissions process
was that it would not give preference to applicants because they
were related to donors, alumni, or employees of either the campus
or the university. However, UC Berkeley’s leadership failed
to uphold this principle and, in doing so, failed to uphold the
university’s commitment to an admissions system based on merit
and achievement.
We identified that UC Berkeley admitted 17 of the 42 applicants
because of their connections to donors or potential donors. These
admissions occurred after UC Berkeley’s development office—
which is responsible for the campus’s fundraising and donations—
referred the applicants to the admissions office. In most cases, the
executive director of operations at the UC Berkeley Foundation
within the development office made these referrals. In one case,
the development office referred a potential applicant to admissions
staff so that they could meet with the applicant in person. An
assistant director in the admissions office then informed the former
admissions director that she would meet with the “VIP student…
whose family is [a] potential donor.” After the applicant applied to
UC Berkeley, the former admissions director was the first person
to read and rate the application, assigning it a rating of Strongly
Recommend. The former admissions director then admitted the
applicant, despite the fact that the second application reader gave the
applicant the lowest possible rating of Do Not Recommend.
UC Berkeley admitted 17 of the 42 applicants
because of their connections to donors or
potential donors.
Each of these 17 applicants received uncompetitive ratings from
application readers such that they were unlikely to be admitted
to UC Berkeley without the referral they received from the
5 Our assessment of the likelihood of admission is based on the rates of admission for academic
years 2017–18 through 2019–20. Some of the 42 inappropriate admissions come from the
academic year 2016–17 admissions cycle. Consistency in admission rates by reader rating
from academic years 2017–18 through 2019–20 and a similar overall admission rate for academic
year 2016–17 indicate that the likelihood of admission in academic year 2016–17 was likely similar
to the period for academic years 2017–18 through 2019–20.
24 Report 2019-113 | CALIFORNIA STATE AUDITOR
September 2020
development office. In fact, five of these applicants received the
lowest possible rating from both of UC Berkeley’s application
readers. Under normal circumstances, these application scores
would have resulted in denial of admission.
UC Berkeley admitted another 11 of the 42 applicants because
of their connections to campus staff, university staff, or the
acquaintances of campus staff, such as the enrollment director
for a private college who was a colleague of UC Berkeley’s former
admissions director. In one example, admissions staff requested that
an applicant receive additional consideration because the applicant
was the child of a director‑level UC Berkeley staff member.
Although the applicant had already received a Do Not Recommend
score from both application readers, UC Berkeley admitted
the applicant without any justification for doing so. In a similar
example, the former associate dean of students contacted the
former director of admissions through email and asked the director
to conduct an additional review of an applicant. The former
director of admissions responded, “Shhhh. You have to keep it a
secret, but good news is coming [the applicant’s] way.” UC Berkeley
admitted this applicant even though the applicant had received the
lowest possible application rating from both readers, again without
any justification. Without connections to campus staff members,
these applicants almost certainly would not have been admitted.
UC Berkeley also admitted another 14 of the 42 applicants from its
waitlist because of their connections to donors, staff, and influential
individuals. Like other campuses, after selecting applicants for
admission, UC Berkeley offers certain other applicants a place
on its waitlist, from which it admits additional students as space
allows. To be admitted from the waitlist, applicants must accept a
waitlist offer by “opting in” to the waitlist. Only a small percentage of
applicants receive a waitlist offer, and admission from the waitlist is
competitive. For academic year 2018–19, UC Berkeley offered a place
on the waitlist to only 10 percent of applicants who were not offered
admission, and it admitted 34 percent of the applicants who opted‑in
to the waitlist. According to the campus’s public Frequently Asked
Questions document about the waitlist process, UC Berkeley focuses
primarily on the content of the original application when making
decisions about whom it will admit from the waitlist. However, it
is unlikely that UC Berkeley admitted these 14 applicants because
of their original applications. In all 14 cases, the applicants received
uncompetitive scores from readers that gave them poor chances of
being admitted. Rather, these applicants’ connections to donors, staff,
or influential individuals drove the decision to admit them.
One case from these 14 admissions decisions is particularly
problematic. UC Berkeley appears to have admitted this
student because of an inappropriate letter of support from a
CALIFORNIA STATE AUDITOR | Report 2019-113 25
September 2020
university Regent. University policy states that members of the Board
of Regents should not seek to influence inappropriately the outcome
of admissions decisions beyond sending letters of recommendation,
when appropriate, through the regular admissions process. However,
the Regent did not submit this letter through the regular admissions
process. Rather, after the campus placed this applicant on its waitlist,
the Regent wrote a letter to UC Berkeley’s chancellor advocating for
the applicant, and the chancellor’s staff sent the letter to UC Berkeley’s
development office, which in turn forwarded the letter to the
admissions office.
As indicated above, admission from the waitlist is not guaranteed,
with most applicants still being denied even after being waitlisted.
This applicant had only about a 26 percent chance of being admitted
to UC Berkeley on their own based on the ratings that readers had
assigned their application. The email records we reviewed indicate
that staff in the admissions office consulted with the development
office about who should be admitted from the waitlist. The admissions
office also prioritized the admission of applicants on the waitlist whom
staff had recommended, as well as applicants on a list that the former
admissions director created. It is therefore likely that the applicant
whom the Regent recommended would have been on a list that
received priority admission from the waitlist. Given the low likelihood
of this applicant’s admission and the prominent and influential role
that Regents have within the university, we conclude that the decision
to admit this applicant was likely influenced by the Regent’s advocacy.
Applicants who were connected to donors
and staff took the places of other applicants
whom UC Berkeley had determined were
more qualified for admission.
UC Berkeley admitted these 42 applicants while denying admission to
many others whom its application readers had rated more highly. As
Figure 5 illustrates, applicants who were connected to donors and staff
took the places of other applicants whom the campus had determined
were more qualified for admission. Although all of these 42 applicants
received scores that gave them a low chance at admission, two‑thirds
of the 42 applicants had a less than 10 percent chance of admission to
the campus. Moreover, 13 applicants had the lowest possible application
ratings, which under normal circumstances would have resulted in
virtually no chance of admission. Given the low ratings that readers had
assigned to these applicants and the absence of any other documented
reason for admitting them, we conclude their admissions were based on
their connections to campus staff or other influential individuals.
26 Report 2019-113 | CALIFORNIA STATE AUDITOR
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UC Berkeley allowed campus staff to request special consideration
for these applicants through three different processes. First,
UC Berkeley’s admissions office maintained consistent
communication with its development office over multiple years.
In those interactions, the development office often provided the
admissions office with the names of applicants connected to
donors and potential donors. In one of the years we reviewed, the
development office indicated which of the applicants were “priority.”
UC Berkeley admitted every applicant that the development office
indicated was a priority. None of these applicants had received
ratings on their applications that would have made them competitive
on their own merit for admission to UC Berkeley.
Figure 5
UC Berkeley Admitted Children of Staff and Donors Instead of More Qualified Applicants
(cid:29)(cid:19)(cid:19)(cid:18)(cid:24)(cid:17)(cid:29)(cid:23)(cid:25)(cid:27)(cid:26) (cid:29)(cid:19)(cid:19)(cid:18)(cid:24)(cid:17)(cid:29)(cid:23)(cid:25)(cid:27)(cid:20) (cid:29)(cid:19)(cid:19)(cid:18)(cid:24)(cid:17)(cid:29)(cid:23)(cid:25)(cid:27)(cid:16)
• Low income
• Child of UC Berkeley • Child of donor • Attended a
disadvantaged school
staff member
• Top 9 percent of applicant’s
high school class
(cid:31)(cid:30)(cid:29)(cid:28)(cid:30)(cid:31)(cid:27)(cid:26)(cid:27)(cid:31)(cid:29)(cid:25)(cid:24)(cid:23)(cid:22)(cid:21)(cid:27) (cid:31)(cid:30)(cid:29)(cid:28)(cid:30)(cid:31)(cid:27)(cid:26)(cid:27)(cid:31)(cid:29)(cid:25)(cid:24)(cid:23)(cid:22)(cid:21)(cid:27) (cid:31)(cid:30)(cid:29)(cid:28)(cid:30)(cid:31)(cid:27)(cid:26)(cid:27)(cid:31)(cid:29)(cid:25)(cid:24)(cid:23)(cid:22)(cid:21)(cid:27)
Do not recommend Do not recommend Recommend
(cid:31)(cid:30)(cid:29)(cid:28)(cid:30)(cid:31)(cid:27)(cid:20)(cid:27)(cid:31)(cid:29)(cid:25)(cid:24)(cid:23)(cid:22)(cid:21)(cid:27) (cid:31)(cid:30)(cid:29)(cid:28)(cid:30)(cid:31)(cid:27)(cid:20)(cid:27)(cid:31)(cid:29)(cid:25)(cid:24)(cid:23)(cid:22)(cid:21)(cid:27) (cid:31)(cid:30)(cid:29)(cid:28)(cid:30)(cid:31)(cid:27)(cid:20)(cid:27)(cid:31)(cid:29)(cid:25)(cid:24)(cid:23)(cid:22)(cid:21)(cid:27)
DO NOT RECOMMEND DO NOT RECOMMEND RECOMMEND
Source: Analysis of UC Berkeley admissions records.
The former admissions director also openly invited staff to send
her names of family and friends who had applied so that she
could personally review the applications. In 2014, 2015, and 2016,
the former admissions director sent an email to UC Berkeley
staff offering to review the applications of applicants they might
know, in one year describing that she was doing so “in the spirit of
professional camaraderie.” Although she noted in her email that
university policies do not allow the admissions office to consider
the alumni status of an applicant’s family or any other special
interests, UC Berkeley then admitted some applicants for whom
CALIFORNIA STATE AUDITOR | Report 2019-113 27
September 2020
campus staff requested that the former admissions director provide
a “second look,” even when the ratings the applicants had received
from readers were not competitive in comparison to the rest of the
applicant pool.
UC Berkeley allowed admissions staff to
request preferential treatment for relatives
and donors by using a process intended
to benefit applicants who come from
disadvantaged backgrounds.
Finally, UC Berkeley allowed admissions staff to request preferential
treatment for relatives and donors by using a process intended to
benefit applicants who come from disadvantaged backgrounds.
UC Berkeley allows admissions staff to nominate applicants for
additional consideration by placing them on a list it calls the prospect
list. The emails that UC Berkeley’s admissions leadership sent to
admissions staff indicate that the prospect list is for applicants who
participate in UC Berkeley’s outreach programs, which generally
assist disadvantaged high school and transfer students in preparing
for and applying to college. The emails from the two more recent
years—2018 and 2019—also state that the staff could add “other
applicants to watch.” Although the majority of applicants whom
admissions staff nominated were connected with these outreach
programs, staff also placed applicants on the prospect list for
inappropriate reasons, including the applicants’ connections to
donors, staff, and faculty. UC Berkeley admitted several of these
applicants while denying admission to similar or better‑rated
students whom staff legitimately had placed on the prospect list
because they had participated in a campus outreach program—the
very applicants whom the prospect list was supposed to benefit.
It is unlikely that the inappropriate admissions that we describe
in this section represent the total number of applicants whom
UC Berkeley admitted as a result of inappropriate considerations.
Although we found evidence that indicates that the development
office provided a list of applicants to the admissions office in 2017
as well, we were unable to locate that list among the email records
we reviewed. Further, the records we reviewed indicated that the
admissions office had been soliciting requests for preferential
treatment from campus staff before the period we reviewed.
Therefore, it is possible—if not likely—that UC Berkeley admitted
additional applicants because of their connections to donors and
staff beyond those that we have reported.
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The university’s admissions guidelines indicate campuses
should ensure a fair and merit‑based admissions process. These
inappropriate admissions occurred because UC Berkeley’s
leadership failed to develop a campus culture to support such a
process. Responsibility for reinforcing the principles of fairness
and merit‑based decision making lies primarily with campus
leadership, who must communicate and visibly adhere to clear
expectations that applicants will be evaluated and admitted based
solely on their merit and achievement. Instead of adhering to
these principles, managers within the admissions office—including
the former admissions director—participated in admitting these
42 applicants. Staff holding leadership positions in the admissions
office communicated freely with UC Berkeley’s development office
and facilitated the admissions of donors’ children. Staff from all
over the campus advocated for their own relatives and friends. The
former admissions director’s open invitation to staff encouraged
this inappropriate advocacy, modeling the idea that preferential
treatment for relatives of staff was acceptable.
These inappropriate admissions occurred
because UC Berkeley’s leadership failed to
develop a campus culture that supports a
fair and merit‑based admissions process.
The current director of undergraduate admissions, who was not
in his position at the time that these inappropriate admissions
occurred, agreed that the preferential treatment we observed is
unacceptable, and that donor status, legacy, and relation to faculty
and staff should not influence admissions decisions. He stated that
he was surprised and disappointed that this preferential treatment
occurred despite the existence of campus policies prohibiting those
types of considerations in admission.
The presence of some procedural safeguards to prevent improper
influence, including conflict‑of‑interest forms that staff were
asked to complete and the involvement of multiple reviewers in
some decision making, did not deter the unethical behavior that
UC Berkeley staff displayed when making these inappropriate
admissions, demonstrating that such safeguards are not
sufficient on their own. Given the pervasiveness of this problem
and seriousness of our findings, correcting the deficiencies in
UC Berkeley’s culture and approach to admissions will require
more significant intervention than establishing additional,
similar safeguards. Despite the presence of a new director of
undergraduate admissions, university leadership must assume a
CALIFORNIA STATE AUDITOR | Report 2019-113 29
September 2020
more active role in UC Berkeley’s admissions process until the
campus demonstrates that it can operate its admissions process free
of improper influence and in accordance with university standards.
Until UC Berkeley establishes a culture where management
communicates, models, and enforces expectations of a fair and
merit‑based admissions process, it risks continued preferential
treatment for relatives and friends of university donors, staff, and
faculty. Such preferential treatment undermines the fairness and
integrity of the admissions process by rewarding the opportunities a
UC Berkeley education offers to applicants who are well connected
rather than to those who are better qualified and more deserving.
Recommendations
To protect the fairness and integrity of its admissions processes, the
Office of the President should establish systemwide protocols for
admissions processes by the fall 2021 admissions cycle that prohibit
the following:
• Giving authority to any one person to make a final admissions
decision.
• Consideration of an applicant’s familial or other personal
relationships to university staff or faculty in an admissions
decision.
• Communication between a campus’s development office and its
admissions office about applicants and prospective applicants.
To protect the campuses’ athletics admissions process from abuse,
the Office of the President should require each campus to do the
following by the fall 2021 admissions cycle:
• Have at least two reviewers verify the athletic talent of all
prospective student athletes before their admittance. At least one
of these reviewers should be from a department other than the
athletics department. Each campus should develop standards
for the level of talent that prospective student athletes for each
of its teams must possess and then use those standards to verify
the talent.
• Track student athletes’ participation in the sport for which they
were recruited. If a student does not participate in the sport for
longer than one year, the campus should determine the reason
why the athlete stopped participating and, if necessary, conduct a
review of the circumstances that led to the student’s admission to
identify signs of inappropriate admissions activity.
30 Report 2019-113 | CALIFORNIA STATE AUDITOR
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• Review donations to athletic programs to determine whether
those donations made before or after an athlete’s admission may
have influenced the athletic department’s decision to request the
athlete’s admission.
The Office of the President should immediately require staff
involved in making or informing admissions decisions to report all
attempts to influence admissions decisions, regardless of source, to
their supervisors or to the director of undergraduate admissions.
Beginning with the fall 2021 admissions cycle, the Office of the
President should oversee UC Berkeley’s admissions process for
at least three years. The Office of the President should ensure
that all admissions decisions are merit‑based and conform to
the university’s policies on admissions. Further, the Office of the
President should facilitate the establishment of a culture of ethical
conduct in admissions by providing regular training to admissions
and development staff, conducting reviews of admissions
decisions, and monitoring the admissions office’s communications
about applicants to ensure no inappropriate factors influence
admissions activities.
CALIFORNIA STATE AUDITOR | Report 2019-113 31
September 2020
Campuses Lack Key Criteria and Standards to Support
Their Admissions Decisions
Key Points
• UC Berkeley and UCLA have not established criteria for selecting from among the
thousands of applicants who apply each year. Because of the campuses’ lack of criteria,
it is unclear why—in addition to the inappropriate admissions we describe in the
previous sections—they have frequently admitted applicants with lower ratings while
denying admission to applicants their readers have more highly recommended.
• All three campuses we reviewed selected applicants for admission who did not meet
university eligibility requirements, but could not demonstrate that they had identified
those applicants as ineligible, and had not documented a rationale for admitting many
of those applicants.
Campuses Have Not Established Adequate Criteria for Their Admissions Decisions, Limiting
Consistency and Transparency
As the Introduction describes on page 6, readers at each campus review and rate applications
based on the applicants’ levels of academic and nonacademic achievement. However,
once readers rate applications, a campus must choose the applicants to whom it will offer
admission. To ensure accountability in the admissions process and in recognition that this
process should be transparent, valid, and equitable, BOARS states that each campus should
develop the methodology it will use for selecting applicants. BOARS further explains that a
campus should develop its methodology based on its goals and priorities. These priorities
may include majors or areas of study that it wishes to expand or types of achievement
that it desires in its student body. For example, if a campus determines that a priority is
student activity in community service, it may implement a selection methodology to choose
applicants with a history of community service.
Despite BOARS’s guidance, UC Berkeley and UCLA have not developed methodologies for
selecting from among the thousands of applicants who apply each year for admission. In the
absence of any documented criteria for selecting applicants, it is unclear why UC Berkeley
and UCLA have admitted certain applicants while denying others. In our review of the
campuses’ admissions decisions for academic years 2017–18 through 2019–20, we found that
the two campuses’ decisions often did not reflect their readers’ ratings of applicants, as Figure 6
illustrates. For example, for academic year 2019–20, UCLA admitted into the College of Letters
and Science only 18 percent—or about 1,000—of the applicants whom its application readers
rated Recommend for Admission. However, in that same year, UCLA admitted into the College
of Letters and Science more than 1,100 applicants whom its application readers rated lower
than Recommend for Admission, including some whose ratings indicated that they were not
competitive enough to be recommended for admittance. Given that these ratings represent the
campus’s assessment of how competitive an applicant is for admission, and that UCLA’s scoring
guidance states that it will admit applicants based on those ratings, it is unclear why UCLA
would admit applicants whom it determined were less competitive than others it denied.
32 Report 2019-113 | CALIFORNIA STATE AUDITOR
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UCLA’s admissions office may have had reasons for selecting certain
lower‑rated applicants for admission over higher‑rated ones. For
example, UCLA frequently admitted athletes with lower ratings
on their applications because of the value that it believed that
those athletes would bring to its sports programs. However, for
applicants other than athletes, the campus could not provide any
documentation justifying how it chose which applicants it would admit
among those it rated Recommend for Admission, or why it admitted
lower‑rated applicants over higher‑rated applicants. We observed a
similar pattern of admissions decisions and missing justifications at
UC Berkeley. In academic year 2019–20, UC Berkeley denied about
600 applicants to the College of Letters and Science that its application
readers had rated stronger than Recommend—meaning that at least
one reader had rated the applicant Strongly Recommend—but in the
same year, UC Berkeley admitted roughly 1,600 applicants to the
College of Letters and Science that its readers had rated at or lower
than Recommend.6
Specifying in advance how a campus will make admissions decisions
aids admissions staff in ensuring those decisions are consistent.
Because of resource constraints, we would not expect the
two campuses to explicitly document their reasons for admitting
or denying each of the more than 100,000 freshman and transfer
applicants who annually apply to each campus. However, a clear
description of why the campuses would choose one applicant
over another with a similar rating would align these campuses’
processes with BOARS’s guidance. It could also better ensure
that the admissions staff make consistent and fair decisions based
on factors the campuses value. In the absence of clear criteria,
admissions decisions affecting thousands of applicants each year lack
appropriate transparency.
Both UC Berkeley and UCLA agreed with our recommendation to
develop more defined procedures for making admissions decisions.
UC Berkeley’s director of undergraduate admissions asserted that the
admissions office considers the internal priorities and institutional
goals that the campus’s chancellor has informally communicated
to it when making admissions decisions. However, he agreed that
it would improve transparency and accountability to document
how the campus’s priorities and goals inform its decision making
when choosing among similarly rated applicants. The director
of undergraduate admissions at UCLA also agreed that having
documented methodologies for selecting between similarly rated
applicants would enable UCLA to demonstrate why it might admit
one applicant and deny another with the same rating.
6 As the Introduction explains, UC Berkeley and UCLA use different rating scales, contributing to a
greater percentage of applicants rated Recommend at UC Berkeley being admitted.
CALIFORNIA STATE AUDITOR | Report 2019-113 33
September 2020
Figure 6
UC Berkeley’s and UCLA’s Lack of Criteria Casts Doubt on the Fairness of Some of Their Admissions Decisions
Top-rated applicants
Middle-rated applicants
Lowest-rated applicants
The campuses admitted
applicants they had rated as
less competitive than others to
whom they denied admission.
DENIED
ADMITTED
Welcome to the
University of California
The campuses lacked:
• Criteria for selecting which applicants to admit
• Justification for admission decisions
These deficiencies cast doubt on the fairness of those admissions decisions
Source: Analysis of policies, procedures, and admissions documentation at UC Berkeley and UCLA.
In contrast to the other two campuses, UC San Diego has
established a methodology for making admissions decisions,
and the information we reviewed indicates that it follows that
guidance. For example, its methodology for selecting applicants lists
several priorities for admission, including that it highly prioritizes
admitting applicants to its arts program who have received high
ratings from its application readers. The admissions data we
reviewed shows that UC San Diego generally admitted applicants
to its arts majors who had received its highest reader ratings
while rejecting other applicants to those programs. However,
UC San Diego’s admissions methodology lacks a clear set of criteria
to guide its decisions when it must choose from among similarly
rated applicants, limiting transparency in its admissions decisions.
Additionally, although we did not identify that these admissions
decisions were improper, the lack of a documented reason for these
admissions decisions introduces risk of inappropriate admissions.
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The Campuses Did Not Adequately Identify Applicants They Selected for
Admission Who Did Not Meet the University’s Eligibility Requirements
As the Introduction describes, university policy allows campuses to
admit a small percentage of applicants who do not meet university
eligibility requirements through a process it refers to as admission
by exception. According to BOARS’s guidelines, the university allows
admissions by exception because its eligibility requirements—such
as coursework requirements and grade point average—do not
recognize an applicant’s full set of achievements, talents, or personal
circumstances. As a result, application readers may determine that
an applicant has demonstrated extraordinary potential but still be
technically ineligible because they did not, for example, complete one of
the 15 required college preparatory (A‑G) courses.
BOARS’s guidance provides recommended reasons for considering
an applicant for admission by exception.7 These include the
applicants having overcome personal challenges, having had limited
or nontraditional educational opportunities, having special talents,
or having academic achievements equivalent to the eligibility
requirements. BOARS’s guidance further explains its expectation that
each campus’s comprehensive review process should guard against
the possibility that the applicants to whom they offer admission by
exception are admitted instead of applicants they determine to be
more qualified. BOARS reports annually to the Regents about the
number of admissions by exception systemwide.
Using the university’s application data for academic years 2017–18
through 2019–20, we identified applicants who did not meet one or
more of the university’s eligibility requirements.8 The table shows
the hundreds of those applicants whom each campus selected for
admission. Campus readers had strongly recommended most of these
applicants for admission. However, each campus also selected for
admission a small number of applicants—21 at UC Berkeley, seven
at UCLA, and 10 at UC San Diego—whose reader ratings indicate
that they were uncompetitive for admission and for whom we did
not identify another reason for why the campuses may have admitted
them, such as being an athlete or having a special talent. Regardless of
the applicant’s ratings, for the majority of the applicants in the table,
the campuses could not demonstrate that they had taken the key steps
of identifying that these applicants were ineligible and then justifying
the decision to admit them. These gaps are especially concerning for
7 In April 2020, BOARS issued updated guidelines related to admission by exception. Among other
changes, BOARS narrowed the applicability of the guidelines to apply to only California resident
applicants as opposed to nonresidents. This change is consistent with how the university has
interpreted its admission by exception policy when assessing compliance in the annual reports
that BOARS submits to the Regents. It also added guidance related to tracking and reporting these
admissions to BOARS.
8 Our review of admission by exception was focused on freshman applicants.
CALIFORNIA STATE AUDITOR | Report 2019-113 35
September 2020
the lowest rated applicants, for whom we expected campuses to have
deliberately considered and documented why they should be admitted
despite both their low ratings and status as ineligible for admission.
Table
The Campuses Selected Hundreds of Applicants for Admission Who Had Not
Met Eligibility Requirements
INELIGIBLE APPLICANTS THE
CAMPUSES SELECTED FOR ADMISSION
UC Berkeley 303
UCLA 375
UC San Diego 794
Source: Analysis of applications and admissions data regarding California resident freshman
applicants that UC Berkeley, UCLA, and UC San Diego selected for admission for academic
years 2017–18 through 2019–20 and whom did not meet university eligibility requirements.
Note: We did not include nonresident applicants in the table because university‑approved college
preparatory (A‑G) coursework is only available in California, making it unlikely that any nonresidents
would have been able to meet that eligibility requirement.
Each campus has a different approach to identifying ineligible
applicants, but none of their approaches are adequate to identify
all ineligible applicants. At UC San Diego, the senior associate
director of enrollment management asserted that the campus
reviews a list of applicants it is considering for admission in order
to identify those who are ineligible. However, the campus explained
that the query it used to create the list for academic year 2019–20
applicants identified only the applicants who had not met the exam
requirements, not those who had not met the coursework or GPA
requirements. UCLA claimed to run similar queries but could not
demonstrate that it actually did so. Finally, the strategic initiatives
advisor in the office of undergraduate admissions at UC Berkeley
acknowledged that the campus identifies only certain categories of
ineligible applicants whom it selects for admission, such as applicants
who attended home school or an unaccredited high school. He stated
that the campus does not try to identify other potentially ineligible
applicants because it is not concerned about their academic strength.
All three campuses’ practices for identifying ineligible applicants
are heavily reliant on a process that occurs after they have already
selected applicants for admission. After an applicant accepts an offer
of admission, applicants must arrange for their school to submit an
official transcript. The campus then reviews the transcript to confirm
the information the applicant provided in his or her application and
to evaluate whether the applicant has met eligibility requirements.
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According to the campuses’ practices, if the applicant is ineligible,
the campus should record at that time whether it will uphold its
admittance decision and its reason for doing so.
However, if a campus only records that it is admitting an ineligible
applicant after it has offered the applicant admission, it risks
unknowingly offering admission to ineligible applicants who do
not align with BOARS’s guidance on admission by exception. As
we discuss earlier, BOARS identifies situations in which a campus
may use admission by exception to offer admission to applicants,
and indicates that campuses should guard against the possibility
that the applicants to whom they offer admission by exception are
admitted instead of applicants they determine to be more qualified.
The processes at the three campuses we reviewed do not provide
assurance that all applicants the campuses offer admission by
exception are aligned with BOARS’s guidance on such admissions.
Deficient oversight by the Office of the President contributed to
the campuses’ poor processes for identifying ineligible applicants.
According to its executive director of undergraduate admissions,
the Office of the President had not reviewed whether campuses had
policies or procedures governing admissions by exception before
its recent internal audit. In its systemwide audit of admissions, the
Office of the President noted that campuses were not adequately
tracking the applicants they admitted by exception or documenting
their reasons for admitting such applicants. However, it did not
determine the actual number of applicants who were ineligible
at the time the campuses offered them admission, and did not
recommend that campuses identify applicants who are ineligible at
the time they are selected for admission.
Deficient oversight by the Office of
the President contributed to the
campuses’ poor processes for identifying
ineligible applicants.
Of the three campuses we reviewed, only UC San Diego developed
procedures for its admission by exception process in late 2019 in
response to the systemwide internal audit. These procedures specify
how UC San Diego will record admissions by exception and the
criteria that it will use to determine when it will admit an applicant
by exception. Although the strategic initiatives advisor in the
office of undergraduate admissions at UC Berkeley stated that the
campus had documented its procedures for admission by exception,
the document he provided to us does not in fact document such
CALIFORNIA STATE AUDITOR | Report 2019-113 37
September 2020
procedures. He provided other records demonstrating only that
UC Berkeley reviewed whether applicants were admitted by
exception at the point of enrollment, not when making admissions
offers. Finally, the director of undergraduate admissions at UCLA
stated that the campus intends to develop procedures, but it has not
yet done so.
A new state law effective as of January 2020 states, among other
things, that a university campus must have at least three senior
campus administrators approve all admissions by exception, and
must establish a policy that applies articulated standards to its
decisions to admit applicants by exception. In response to this
change in state law, BOARS updated its guidelines in April 2020
to recommend that three individuals—a campus’s director of
undergraduate admissions, another official in the admissions
office, and a member of the university’s Academic Senate who
is external to the admissions office—approve all admissions by
exception. Despite the findings of its own internal audit, the
Office of the President told us that it plans to rely on campus
reports about how the campuses use the admission by exception
policy. Until the Office of the President ensures that campuses
accurately identify the applicants whom they admit by exception
and monitor to ensure that these applicants are qualified, it risks
that uncompetitive, ineligible applicants will take the place of better
qualified applicants.
Recommendations
To ensure that the university maintains a fair and consistent
admissions process, the Office of the President should require each
campus to take the following actions:
• By March 2021, document and implement a selection
methodology that describes how it will choose applicants for
admission, particularly when the applicants have received
similar ratings from application readers. Further, the selection
strategy should specify the reasons why a campus may choose
an applicant with a low or uncompetitive rating instead of an
applicant with a higher rating.
• Develop and implement processes to use when selecting
applicants for admission for identifying applicants whom it has
selected for admission and who are not eligible for admission
to the university, and record their rationale for admitting those
applicants despite their ineligibility.
38 Report 2019-113 | CALIFORNIA STATE AUDITOR
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To provide assurance that campuses’ use of the admission by
exception policy is aligned with the policy’s purpose, beginning
in June 2021, the Office of the President should annually select a
random sample of applicants admitted by exception and verify that
campuses recorded a rationale for each admission and that each
rationale aligns with BOARS’s guidance.
CALIFORNIA STATE AUDITOR | Report 2019-113 39
September 2020
Campuses Have Not Adequately Ensured That
Reviewers and Faculty Consistently and Fairly
Evaluate Applications
Key Points
• Campuses have not adequately trained or supervised the readers who rate
applications, creating the risk that their evaluations of thousands of applicants will
be unfair or inconsistent. For instance, UC Berkeley’s readers correctly assessed
only about 60 percent of practice applications during training before the campus
allowed them to rate actual applications.
• Campuses have not taken critical steps to protect applicants from reader bias.
They have provided application readers with applicants’ demographic information,
including their names, native languages, and birthplaces, which could bias the
readers’ evaluations.
• Campuses allow academic departments to participate in evaluating applicants for
admission to their programs, but they have provided little or no oversight of the
processes that those academic departments use when evaluating applications. As a
result, these departments’ evaluations are at risk of inconsistency or bias.
The Campuses Have Not Ensured That Their Readers Rate Applications Fairly
and Consistently
Fairness and consistency are essential characteristics that the university’s admissions
processes should guarantee to all applicants. As we discuss in the Introduction, campuses
rely on a combination of internal admissions staff and external application reviewers to
serve as application readers. Generally, two readers review each freshman application and
assign it a rating that represents their assessment of the applicant’s qualifications
and fitness for admission to the campus. Although the number of applications that
each reader reviews varies, many readers review hundreds, and some review over a
thousand applications during an admissions cycle. According to BOARS’s guidelines
for implementing university undergraduate admissions policy, campuses must train
readers and monitor them throughout the evaluation process to ensure that they evaluate
applicants consistently to maintain the integrity of the applicant review. Ensuring fair and
consistent evaluation of applicants is critical because, as Figure 7 shows, even one reader’s
rating of an application has a significant impact on that applicant’s chances of admission.
40 Report 2019-113 | CALIFORNIA STATE AUDITOR
September 2020
Figure 7
At Any of the Three Campuses, a Single Reader’s Rating Can Have a
Significant Impact on an Applicant’s Chance of Admission
Just one reader rating can
significantly affect an applicant’s
chance of admission.
For example, at UCLA’s College of Letters and Science:
(cid:31)(cid:30)(cid:29)(cid:28)(cid:27)(cid:29)(cid:28)(cid:26)(cid:25)(cid:26)(cid:27)(cid:24)(cid:23)(cid:29)(cid:30)(cid:22)(cid:21)(cid:25)(cid:20)(cid:20)(cid:20) (cid:31)(cid:30)(cid:29)(cid:28)(cid:27)(cid:29)(cid:28)(cid:26)(cid:25)(cid:26)(cid:27)(cid:24)(cid:23)(cid:29)(cid:30)(cid:22)(cid:21)(cid:25)(cid:20)(cid:20)(cid:20)
2 2
STRONGLY
RECOMMEND
STRONGLY
RECOMMEND
2 3
STRONGLY RECOMMEND ACCEPTABLE FOR ADMISSION
93 31
% CHANCE OF % CHANCE OF
ADMISSION ADMISSION
Reader ratings also affected applicants' chances of
admission at UC Berkeley and UC San Diego.
Source: Analysis of admissions and application review data for applicants between academic
years 2017–18 through 2019–20 at UC Berkeley, UCLA, and UC San Diego.
Despite the importance of readers’ ratings, the three campuses
we reviewed have not established adequate processes for ensuring
that readers are properly trained or for monitoring their readers
to ensure fairness and consistency. Reader training at all three
campuses includes a presentation discussing the factors that readers
should consider when assessing applications, as well as example
applications and the appropriate ratings for those applications.
Additionally, each campus generally asks readers to evaluate a
selection of applications from a previous year (practice applications)
to teach them how to accurately evaluate applicants. According to
the campuses, they then compare readers’ ratings of the practice
applications to the campuses predetermined accurate ratings to
evaluate whether the readers are ready to rate actual applications.
To know whether this training has successfully prepared readers
to rate applications, campuses would need to identify a level of
CALIFORNIA STATE AUDITOR | Report 2019-113 41
September 2020
proficiency that they expect readers to demonstrate. For example,
a campus could require that each reader must accurately evaluate
90 percent of practice applications before reviewing actual
applications. However, none of the campuses have established
a proficiency standard for their readers or a formal process for
verifying that readers are ready to read actual applications. Instead,
the campuses rely on their supervisors to independently assess
whether readers are ready, without providing relevant written
criteria to those supervisors.
As a result of this informal approach, the campuses’ standards
for readers being ready to review applications vary significantly.
UC Berkeley’s training records for applications for the fall 2020
academic year show that, collectively, its readers correctly
evaluated about 60 percent of the practice applications.9 Such
a low proficiency rate creates a significant risk that readers will
incorrectly evaluate actual applications. Because UCLA and
UC San Diego use rating scales that are broader in range than
UC Berkeley, we analyzed training proficiency at those campuses
first by assessing how often the readers were within one point
of the correct score and found that readers demonstrated nearly
97 percent accuracy at UC San Diego and almost 99 percent at
UCLA. However, as Figure 7 demonstrates, even a rating difference
of one point can significantly affect some applicants’ chances
of admission. Therefore, we also reviewed how often readers
at UC San Diego and UCLA assigned the same score that the
campuses had determined to be the correct rating for the practice
application, and found that their rates of proficiency were only
58 percent and 75 percent, respectively.
The campuses’ standards for readers being
ready to review applications vary significantly.
Although some variation in scoring would be expected during
training, it is concerning that none of the campuses had a formal
expectation of how often its readers needed to score applications
correctly. Without such a proficiency standard, the campuses have
less assurance that their readers’ ratings are accurate and consistent.
The directors of undergraduate admissions at each campus agreed
that they should establish minimum proficiency standards for
their readers.
9 UC Berkeley could not provide training records for 20 percent of its readers. Our analysis is based
on all available records.
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In addition, none of the campuses we reviewed have adequately
monitored their readers throughout the admissions cycle. Each
campus has established rating guidelines that include the approximate
distribution of application ratings. For example, UC San Diego’s
guidance states that it expects only about 5 percent of applications
will receive the highest possible rating and that about 10 percent will
receive the lowest possible rating. If a reader deviates significantly from
these general expectations, it could be a sign that the reader is not
appropriately evaluating applicants and requires corrective instruction.
However, the campuses could not demonstrate that they adequately
monitored readers to ensure they identified and addressed such
deviations. Figure 8 shows the effect that this lack of oversight has had
at UC Berkeley, where a significant number of readers were either too
lenient or too strict during its most recent application cycle, according
to UC Berkeley’s own rating guidelines. We found the same concern at
UCLA and UC San Diego, where an applicant’s ratings were dependent
on which reader evaluated the application. In other words, at each
campus some applicants likely received lower ratings than they should
have, and others likely received higher ratings than they should have.
These overly strict or overly lenient readers each read hundreds or in
some cases more than 1,000 applications during an admissions cycle.
Given the effect of even one reader’s rating on an applicant’s chances of
admission, as Figure 7 shows, these overly strict or overly lenient readers
likely affected some applicants’ chances of admission.
The application ratings we reviewed demonstrated the importance
of strong training and monitoring. We identified multiple instances
in which readers who incorrectly rated most of their practice
applications also failed to meet campus standards when evaluating
actual applications. For example, two UC Berkeley readers—who
were both assigned to read international applications from the same
region of the world—incorrectly rated all or nearly all of their practice
applications. Both of these readers subsequently read nearly 1,000
actual applications. One reader was overly strict, rating 80 percent
of the applications with the lowest possible rating and only 4 percent
with the highest possible rating. In contrast, the other reader
assigned the lowest possible rating to only 44 percent of her assigned
applications and the highest possible rating to 20 percent.
However, performing well in rating practice applications is not a
guarantee of a reader’s strong performance when reviewing actual
applications. In fact, we found that some UCLA and UC San Diego
readers who correctly rated all or nearly all of their practice
applications were much too strict or lenient when reviewing actual
applications. For example, one UCLA reader’s training record shows
that she correctly assessed almost all practice applications. However,
when reviewing real applications this reader scored only 2 percent of
the nearly 600 applications she reviewed with the highest possible
score while scoring 24 percent with a “3” rating, which was a rating
CALIFORNIA STATE AUDITOR | Report 2019-113 43
September 2020
of “Acceptable For Admission.” By comparison, UCLA expects that
5 percent of applications will score at the top end of its scale and
that only 15 percent will score a “3” rating. According to UCLA’s
assistant director of freshman review, UCLA’s practice is to invest
time and effort in comprehensive reader training and certification
before allowing readers to read actual applications. She shared that
given its large volume of applications, the campus has limited time
and resources to monitor reader ratings and rating distributions once
reading begins. However, our findings demonstrate that campuses
must invest time and effort into monitoring reader performance
throughout the reading process, not just during training.
Figure 8
Applicants’ Ratings at Each Campus Were Highly Dependent on Who Reviewed Their Applications
Inconsistency in admissions staff’s evaluation of applicants
made some applicants’ scores highly dependent on who
evaluated their applications.
For example, showing three actual readers at UC Berkeley:
More Likely to Strongly Recommend admission
READER A 45% 20% 35%
More Likely to Recommend admission
READER B 39% 37% 24%
Likely to Not Recommend admission
80% 14% 6%
READER C
Do Not Recommend
Recommend
Our review of readers at UCLA and UC San Diego Strongly Recommend
revealed the same concern.
Source: Analysis of application review data for applicants between academic years 2017–18 through 2019–20 at UC Berkeley, UCLA, and
UC San Diego.
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Both UC Berkeley and UCLA have programmed various reports into
their application review systems that show, among other things, the
number of applications that each reader has read and the distribution
of ratings for each reader. The deputy director of undergraduate
admissions at UC Berkeley and the associate director of freshman
review at UCLA stated that their admissions staff verbally provide
constructive feedback to readers when necessary. Regardless, the
disparities in readers’ ratings at the campuses show that whatever
verbal feedback readers receive does not always rectify concerns.
UC San Diego previously established similar reports for monitoring
readers but stopped using these reports in fall 2019 when it
transitioned to a new application review system. The assistant director
of operations at UC San Diego stated that the campus could no longer
use the monitoring reports because its new application review system
lacked these reports. However, UC Berkeley and UCLA use the same
application review system as UC San Diego and, as mentioned above,
they have programmed their monitoring reports into the system.
The disparities in readers’ ratings at the
campuses show that whatever verbal feedback
readers receive does not always rectify concerns.
Each campus generally agreed that it could improve its reader
monitoring, but argued that some variability is inherent in an
application reading process. UC San Diego’s admissions director
stated that its processes include mitigating factors that improve
reader consistency, including that two readers review each application
and that it has a process for reviewing applications when the
two readers’ ratings of an application differ significantly. In fact, all
three campuses we reviewed have processes for addressing when
reader scores diverge from one another significantly. Specifically,
UCLA and UC San Diego have rating systems based on seven‑point
scales. At those campuses, when the first two readers’ ratings differ
by more than one point, the campuses have a third reader evaluate
the application. UC Berkeley has only a three‑point scale, and it
conducts a third review of an application when the first two ratings
are at the opposite ends of the scale. At each campus, the third review
determines what the applicant’s final rating will be. For example, at
UCLA and UC San Diego, the third review rating replaces the first
two review ratings. Although these processes are useful for detecting
sizeable differences in reader ratings, even small differences can have
a significant effect on an applicant’s chance of admission. Figure 7
depicts a one‑point difference in reader ratings and the resulting
sharp decline in an applicant’s chance of admission. Some deviation in
reader assessment is reasonable, but that deviation should not occur
CALIFORNIA STATE AUDITOR | Report 2019-113 45
September 2020
because of preventable problems with a reader’s use of a campus’s
evaluation criteria. Therefore, a robust process for monitoring the
accuracy of reader evaluations is critical to ensure that a campus’s
admissions decisions are fair and consistent.
Finally, according to campus staff, the majority of each campus’s
transfer applicants have only one reader evaluation. Staff who read
transfer applications are generally a subset of the internal staff at
each campus who read freshman applications. Especially in light of
the problems with some readers being overly strict or overly lenient,
a single evaluation increases the possibility that an applicant may
receive an unfair evaluation. The admissions directors at UC Berkeley
and UCLA indicated that performing a second read of transfer
applications would not be possible without additional staff resources.
According to the admissions director at UCLA, only internal staff
read transfer applications due to the complexities associated with
evaluating applicants by major, and he would not be comfortable
delegating even part of the transfer review to external readers.
However, because campuses read most transfer applications only
once, they cannot apply the same strategies for ensuring accurate and
consistent ratings that they use for freshman applications.
A single evaluation increases the possibility that
an applicant may receive an unfair evaluation.
The directors’ assertions that transfer applications are more
time‑intensive to review compared to freshman applications are
reasonable given the factors they described to us and material
we reviewed about how each reader must verify that the transfer
applicant has completed required preparatory coursework.
Nevertheless, to ensure a fair and consistent admissions process for
transfer applicants, it is essential that these applicants receive at least
two reviews of their applications, just as freshman applicants do.10
The Campuses Have Not Taken Steps That Could Safeguard Applicants
Against Reader Bias
In addition to not taking adequate steps to ensure consistency among
reader ratings, the campuses have allowed readers to view information
about freshman applicants that could bias their evaluations, such as
names, native languages, and, in some cases, gender. The Office of the
10 Some campuses in the university system offer admission to all California community college transfer
applicants who meet the minimum requirements to transfer. At such campuses, there would be no
need to perform two independent reviews of applications.
46 Report 2019-113 | CALIFORNIA STATE AUDITOR
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President provides this application information to the campuses and
allows them to determine what information they provide to their readers.
However, research shows that being able to see certain demographic and
identifying information may cause readers to subconsciously modify
their evaluation of applicants. This type of subconscious modification
of behavior is known as implicit bias, and we would expect that
the campuses would guard against its influence in the evaluation of
applicants. Nonetheless, all three campuses allow readers to see freshman
applicants’ names and native languages. UC Berkeley and UC San Diego
further allow readers to see applicants’ genders, and UC Berkeley and
UCLA allow readers to see applicants’ birthplaces.
By allowing readers to see this information, the campuses risk that
an applicant will be either disadvantaged or favored by a reader’s
implicit biases. These biases may relate to the applicant’s gender, native
language, or ethnicity—which a reader may infer, either correctly or
incorrectly, from the applicant’s name, birthplace, or native language.
None of this personal information is included in the comprehensive list
of 14 factors that BOARS allows campuses to use to evaluate and select
applicants for admission. Thus, providing it to readers is unnecessary
for the evaluation process.
By allowing readers to see applicants' names,
gender, and native languages, the campuses risk
that an applicant will be either disadvantaged or
favored by a reader’s implicit biases.
The directors of undergraduate admissions at UC Berkeley and UCLA
disagreed that readers should not be able to see names, first languages,
and birthplaces. For example, UC Berkeley’s director of undergraduate
admissions cited his belief that these data provide important
context about the applicant in each case. However, the director of
undergraduate admissions at UC San Diego stated that he had no
concerns about removing that information so that readers and staff
would not be able to see it when evaluating applicants. Each campus
trains its readers on the factors they should consider when assessing
an application. Some of these trainings include information about the
dangers of implicit bias. However, the university should do more to
reduce the risk of implicit bias. Specifically, the Office of the President
could stop providing campuses with information that has the potential
to bias reader evaluations.
In addition, UC Berkeley has not guarded against another type of
potential bias. Specifically, it allows the second application reader
to see the rating assigned by the first reader, which jeopardizes the
CALIFORNIA STATE AUDITOR | Report 2019-113 47
September 2020
independence of the second review. Once the second reader is
aware of the first reader’s rating, the second reader may be swayed
to assess the applicant differently than he or she otherwise would
have had they not seen the first reader’s rating. In contrast, neither
UC San Diego nor UCLA allows the second reader to see the first
reader’s rating. The directors of undergraduate admissions at both
campuses stated that this practice prevents the first reader’s rating
from influencing the second reader’s evaluation.
After we shared our concerns about this practice, UC Berkeley’s
admissions director asserted that beginning in fall 2020, he intends
to make the first and second reads independent of one another.
UC Berkeley’s stated intentions to improve this process are a positive
first step. However, until UC Berkeley fully implements this change,
the risk will remain that the first reader’s score could influence
the second reader’s judgment and deprive an applicant of two
independent evaluations.
The Campuses Have Allowed Academic Departments to Influence
Admissions Decisions With Little Oversight
The campuses have not ensured that all departments involved in
admissions decisions have implemented appropriate safeguards
against improper influence. Each campus allows certain academic
departments to provide direct input on admissions decisions. For
example, UC Berkeley allows a number of departments, such as its
college of engineering, to review, rate, and recommend applicants
for admission to specific programs. The arts schools at both UCLA
and UC San Diego conduct a similar application review with a
particular focus on the applicants’ special talents in arts, music, or
theater. In fact, at UCLA, academic departments influence one‑third
of all freshman admissions decisions. The weight that the admissions
offices give to recommendations from academic departments
varies by campus, but is significant. At UCLA and UC Berkeley, the
admissions offices give substantial weight to academic departments’
recommendations on freshman admissions and frequently admit the
applicants they recommend. At UC San Diego, the admissions office
considers ratings that staff in its arts departments assign to applicants
to its arts majors when deciding between applicants whom the
admissions office has similarly ranked.
The weight that the admissions offices give to
recommendations from other departments
varies by campus, but is significant.
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Given the weight that the campuses afford recommendations from
academic departments, we expected that each campus would have
ensured that the departments’ processes for reviewing, rating,
and recommending applicants conformed to best practices for
preventing improper influence. However, none of the campuses
adequately did so. Key safeguards against improper influence include
having conflict‑of‑interest policies that require reviewers to disclose
relationships and recuse themselves from reviewing applications from
applicants they know, as well as ensuring that no single individual can
make an admissions decision. We would have expected the campuses
to ensure that academic departments involved in admissions
decisions adopted these safeguards.
Because campuses have not required academic departments to
implement adequate safeguards related to admissions decisions,
the departments’ practices have been inconsistent. For example,
UC Berkeley’s management, entrepreneurship, and technology
program within its college of engineering has established a strong
process related to admissions: two readers rate each application, and
then a committee selects which applicants to recommend. However,
in contrast, UCLA’s associate dean of academic and student affairs
for the school of engineering (associate dean of engineering) stated
that he alone—one single individual—recommends applicants for
admission to most engineering majors.
In at least one instance, this UCLA practice resulted in unequal
treatment of an applicant. Specifically, we identified that
one applicant’s parent directly contacted the school of engineering
to advocate for the applicant. Although a parent making such
contact to advocate for a child may not be in itself inappropriate, a
campus should not consider such contact in its admissions decision
to preserve the fairness of its admissions process for all applicants.
However, in response to the email of the parent in question, the
associate dean of engineering requested that the parent provide
additional test scores for the applicant, which the parent did. Although
another engineering staff member noted that the applicant’s additional
test scores were poor, the associate dean of engineering recommended
the applicant for admission to the engineering program.
In regard to this engineering applicant, the associate dean stated that
he was concerned that the applicant’s math test scores were low, but
when he considered those scores together with the applicant’s holistic
rating and GPA, he believed that the applicant would be successful
as an engineering major and admitted the applicant. However, the
associate dean also acknowledged that he had treated this applicant
differently than others by responding to the parent’s email in such
a manner instead of informing the parent that they would have to
wait until admissions decisions arrived. By communicating with the
applicant’s parent, the associate dean of engineering gave the applicant
CALIFORNIA STATE AUDITOR | Report 2019-113 49
September 2020
unequal review and consideration compared to other applicants. He
was able to do so—and make a decision on his own—because the
campus had no requirement that multiple individuals participate in the
admission decision, and no conflict‑of‑interest policy for the school of
engineering prohibiting external influence in admissions decisions.
By communicating with the applicant’s parent,
the associate dean of engineering gave the
applicant unequal review and consideration.
Involving academic departments in admission decisions is reasonable
given that each department may value different traits in applicants.
For instance, engineering departments typically value an applicant’s
performance in mathematics. Similarly, staff in arts departments,
such as visual arts, dance, or theater, are better qualified than the
admissions office staff to determine which applicants’ artistic talents
are sufficient to warrant admission. However, the campuses often
assigned this responsibility without first ensuring that departments
would preserve the fairness and consistency of the admissions
process. The directors of undergraduate admissions at each
campus acknowledged that they lacked knowledge about academic
departments’ processes for reviewing and selecting applicants and
about the specific individuals responsible for the final admissions
recommendations. Each admissions director has responsibility for his
or her campus’s admissions process and for ensuring that the entire
process aligns with the university’s overall admissions principles and
policies. With that responsibility comes an implicit requirement to
also ensure that all aspects of the campus’s admissions process are free
of improper influence.
Recently—generally as a result of the Office of the President’s internal
audit of admissions practices—some academic departments have
developed or stated that they plan to develop conflict‑of‑interest
policies. These policies generally require staff to certify that they
have not reviewed applications for individuals with whom they
have personal relationships. However, adoption of this practice
among campuses and departments is inconsistent. None of the
academic departments at UC Berkeley that recommend applicants
for admission have developed these policies. UCLA developed a
certification form that it says staff must sign in order to recommend
prospective student artist applicants for admission, and the campus
provided evidence that it required those forms for applicants whom
the arts department recommended for admission for academic
year 2020–21. However, UCLA has not required the same for staff
in its engineering or nursing departments. Regardless, UCLA’s
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certifications differ from the draft certification that UC San Diego
developed, which requires staff to predisclose potential conflicts
of interest as opposed to attesting after the fact that they did not
review applications from individuals they know. Furthermore, some
departments still assign responsibility for reviewing or selecting
applicants for admission to one individual. Until the Office of the
President and the campuses ensure that all departments involved
in admissions decisions have implemented appropriate safeguards
against improper influence, the risk that such influence could
unfairly affect some admissions decisions will remain.
Finally, UC Berkeley also allowed campus staff outside of its
admissions office and academic departments to influence
admissions decisions. Unlike the other two campuses we reviewed,
UC Berkeley allowed campus staff—such as club sport coaches
and band directors—to request that the campus admit applicants
because of their special talent. To request such an admission, staff
filled out a special talent request form, on which they described the
applicant’s level of talent and potential value to a campus program.
We reviewed 28 such applicants whom UC Berkeley admitted or
placed on its waitlist and found that 23 of these applicants received
reader ratings of only Recommend or worse. Nine of the 23 received
a rating of Do Not Recommend from at least one of the two
readers who reviewed their applications. Based on their ratings, all
23 of these applicants would have had little chance of admission,
indicating that the admissions office placed significant weight
on the special talent recommendations forms when admitting or
waitlisting those applicants.
Although special talent is an acceptable factor on which to base
an admissions decision, UC Berkeley’s special talent admissions
decisions are questionable because, according to the former
manager who oversaw this process, the admissions office did not
verify or require evidence of the applicant’s special talents and
instead relied on the statement of the requesting staff member.
This former manager collected and reviewed the request forms
and determined whether to recommend students for admission.
The former manager asserted that another staff member was
responsible for deciding whether to offer admission. However,
we found no evidence of additional review following the former
manager’s recommendation for admission. During the two‑year
period that we reviewed, UC Berkeley admitted 26 of the
28 applicants the former manager recommended for admission
and waitlisted the remaining two. UC Berkeley’s current director
of undergraduate admissions, who was not in his position for the
majority of our audit period, stated that he ceased this special talent
admissions process beginning in the fall 2020 admissions cycle and
that UC Berkeley is currently revising how it will consider special
talent when making admissions decisions.
CALIFORNIA STATE AUDITOR | Report 2019-113 51
September 2020
Recommendations
To ensure that the university maintains a fair and unbiased
admissions process, the Office of the President should require each
campus to take the following actions:
• By March 2021, establish acceptable levels of application reader
proficiency and maintain training and monitoring programs
that ensure that its readers attain and sustain those levels. In
addition, it should report annually to BOARS on those efforts
and on reader consistency levels, including the frequency
with which reader ratings align with campus guidelines for
rating applications.
• Beginning with the academic year 2021–22 admissions cycle,
require each campus that does not admit all eligible transfer
applicants to ensure that two readers review all transfer
applications.
• Beginning with the academic year 2021–22 admissions cycle,
ensure that the second readers cannot see the ratings of
first readers for both freshman and transfer applications.
To better ensure that implicit bias in the evaluation of applications
does not affect applicants’ chances at admission, the Office of the
President should remove potentially biasing information from
the application information that campuses can access.
To ensure that it properly protects all admissions activity against
improper influence, the Office of the President should require each
campus’s undergraduate admissions office to do the following:
• Identify all other campus departments that participate in or
provide information that affects admissions decision making.
• Obtain, evaluate, and approve a description of the criteria and
processes that these departments use in rating and selecting
applicants to recommend for admission.
• Annually obtain a roster from each of these departments of the
individuals who will participate in admissions decision making
and their roles and ensure that no single individual is responsible
for such decisions in any given department.
• Ensure that each individual whom a department includes on
the roster it submits has received training on appropriate and
inappropriate factors on which to base admissions decisions and
has agreed to abide by the campus’s conflict‑of‑interest policies
with respect to admissions.
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CALIFORNIA STATE AUDITOR | Report 2019-113 53
September 2020
The Office of the President Has Not Safeguarded the
University’s Admissions Process
Key Points
• The Office of the President did not set minimum protocols for the campuses’
admissions processes or conduct sufficient oversight of their admissions practices.
Weak oversight of its recent internal audit meant that issues at the campuses were
undetected by campus auditors. In the absence of common protocols and adequate
oversight, the Office of the President can provide only limited assurance to the public
that its admissions processes reflect the high standards it publicly affirms.
• Although the university guarantees admission to applicants who excel at their
California high schools, it has not monitored the program that facilitates this
guarantee or expanded participation by California schools.
The Office of the President’s Inaction Has Allowed Weaknesses in Campus Admissions
Processes to Persist
The Office of the President has not used its position as the university’s central oversight
entity to detect and prevent deficient admissions practices. As the executive agency of
the university, the Office of the President is best positioned to safeguard the fairness
and consistency of the system’s admissions processes by setting minimum procedural
requirements that align with best practices and by performing periodic reviews of the
campuses’ admissions practices. However, the Office of the President has not consistently
performed these key tasks. In the absence of standardized processes and ongoing oversight,
the weaknesses in campus admissions processes that we describe throughout this report
have persisted. The admissions process is a critical pillar of the university system, and it
is essential for the university to protect it from weaknesses and inappropriate influence.
Without proactive action by the Office of the President, admissions decisions that do not
reflect the university’s standards are likely to continue and to erode public trust in the
system’s integrity.
Most troubling is that the Office of the President has not established a minimum set
of systemwide protocols and procedures to protect against impropriety, despite having
evidence that the campuses’ admissions processes are susceptible to inappropriate
activity. In 2014 UCLA identified that its athletics admissions process was vulnerable
to manipulation when it investigated two questionable athletics admissions decisions.
The campus concluded that these admissions decisions were primarily motivated by the
expectation of financial benefit to the university and that they violated university policy.
After that investigation, UCLA modified its policies to require campus staff to verify the
athletic qualifications of all nonscholarship prospective student athletes. To strengthen
the athletics admissions processes at other campuses, the Office of the President
could have expanded UCLA’s solution across the entire university system. With these
54 Report 2019-113 | CALIFORNIA STATE AUDITOR
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verification procedures in place, UC Berkeley, UC San Diego, and
UC Santa Barbara would have identified some of the unqualified
prospective student athletes we previously discuss and had the
opportunity to deny them admission.
However, even UCLA’s 2014 policy to verify nonscholarship
prospective student athletes is inadequate to prevent questionable
admissions. As we note earlier, the 22 inappropriate athletic
admissions we found included student athletes who had received
scholarships. Despite the risk of inappropriate admissions, the
Office of the President has still not required a minimum systemwide
protocol for verification of athletic qualifications. Instead, the Office
of the President has recommended that campuses adopt talent
verification procedures only for those recruited athletes who do not
receive scholarships. Therefore, even if campuses choose to comply
with this recommendation, staff wishing to inappropriately admit
an applicant may have the incentive to offer scholarship funding
in order to circumvent this verification safeguard. Further, as we
explain in more detail later, it has delegated to the campuses the
authority to determine how they will address its recommendation.
Until it adopts strong and clear requirements, the Office of the
President cannot provide a satisfactory level of assurance to the
public that its admissions processes reflect the high standards it
publicly affirms.
The university cannot claim that every
student who applies will receive fair and
consistent treatment.
The Office of the President has allowed other troubling weaknesses
in admissions processes to continue as well. The university’s desire
to provide each campus a level of autonomy to make decisions
about which applicants to admit is reasonable. However, it
should establish basic and uniform expectations for the processes
themselves, such as the expectation that each campus maintains
proficiency standards for its application readers and prohibits any
single individual from making admissions decisions. Without these
baseline admissions protocols—which should not vary by campus—
the university cannot claim that every student who applies will
receive fair and consistent treatment, regardless of the campus to
which they apply. It is for that reason that throughout this report,
we recommend that the Office of the President adopt consistent
procedural requirements for all of its campuses.
CALIFORNIA STATE AUDITOR | Report 2019-113 55
September 2020
Procedural changes alone will not ensure full accountability in the
admissions process. To detect problems, the Office of the President
will need to periodically review the campuses’ admissions practices.
Before the national college admissions scandal in March 2019, the
Office of the President had never conducted a systemwide review
of the campuses’ admissions practices. Instead, the Office of the
President had asked individual campuses to conduct self‑reviews
of their admissions processes, or in some cases, campuses initiated
admissions audits of their own accord. For example, the University
of California, Irvine (UC Irvine) conducted an internal review of
its admissions and enrollment practices to evaluate why it had
overenrolled its incoming class for the 2017–18 academic year—
an error that led it to rescind admission offers for hundreds of
students. Its review found that it had not developed campus specific
guidelines to promote consistency in the holistic review process.
UC Irvine’s review also identified that it had a weak process for
predicting how many admitted students would ultimately enroll.
To detect problems, the Office of the
President will need to periodically review the
campuses’ admissions practices.
Regular review of a process is a basic oversight tool that can
provide an organization with assurance that the process is well
designed and operating as intended. As the UC Irvine example
above demonstrates, such reviews can also identify weaknesses.
Had it performed regular reviews of the campuses’ admissions
processes, the Office of the President might have identified their
poor practices, required improvements to those practices both
at individual campuses and across the system, and prevented the
improper and inappropriate admissions we identified.
Although the Office of the President led a systemwide internal
audit of admissions practices in 2019 and 2020 in response to
the nationwide admissions scandal, its decision to rely on the
campuses to review their own admissions practices limits that
audit’s value. The Office of the President developed the scope of
the internal audit and procedures to assess campuses’ admissions
practices. However, it asked the campuses’ internal audits units
to perform the audit work. Without providing any independent
evaluation of the adequacy of the campuses’ audit work, the Office
of the President compiled the campuses’ results into a systemwide
report summarizing the weaknesses they identified. As a result,
the Office of the President was unable to detect gaps in the
campuses’ internal auditors’ reviews that it may have identified had
56 Report 2019-113 | CALIFORNIA STATE AUDITOR
September 2020
it provided stronger oversight of the campuses’ work. For example,
UC Berkeley’s internal auditor missed the campus’s failure to
comply with its policy to give no preference to an applicant based
on a relationship with donors, alumni, or employees of either the
campus or the university because it relied on campus policies and
staff assertions to determine how the campus made admissions
decisions. Consequently, the Office of the President did not learn
about a highly problematic practice at one of its premier campuses.
The deficiencies that the internal audit did uncover were
generalized observations about the campuses’ admissions processes
that did not fully address areas of concern. Specifically, the audit
observed that the campuses lacked policies and procedures to guide
their admissions processes and noted weaknesses in the level of
documentation that the campuses maintained about admissions
decisions. The audit also found that campuses varied in whether
they tracked admissions by exception and participation in athletics.
However, in key areas, the audit’s observations
were limited. For example, when the campuses’
The Campuses’ Differing Approaches to internal auditors observed that a campus had not
Implementing a Recommendation From the verified athletic talent, they did not attempt to
Office of the President determine whether applicants were qualified to
play in the sports for which they were admitted or
Office of the President issued a systemwide recommendation:
whether inappropriate factors had influenced their
Establish a policy limiting communication between admissions decisions. By not taking these
development personnel and the admissions office additional steps, the campuses’ internal auditors
regarding admissions matters. At a minimum, any were not able to determine whether any
communication regarding the admissions status of specific
inappropriate admissions took place.
applicants should be prohibited.
Campuses have each responded differently to this Moreover, for the issues the internal audit did
recommendation: uncover, the Office of the President has allowed
the campuses to develop their own corrective
• UC Berkeley indicated that it would develop such a
policy, but it had not done so as of July 2020. actions and has not ensured that they take
consistent approaches to similar problems. The
• UCLA initially stated that this practice was already in
text box provides an example of a systemwide
place, but that it would document the practice more
thoroughly. Even though, as of July 2020, the campus recommendation that the Office of the President
had not adopted a policy in writing, the campus auditors issued and of the differing approaches campuses
have considered the recommendation implemented took to addressing that recommendation. By
because of other university policies. However, none of
failing to provide the campuses with more specific
those university policies discuss communication between
direction, the Office of the President missed an
development and admissions personnel or prohibit
such communication. opportunity to bolster consistency and fairness
in the university’s overall admissions process.
• UC San Diego implemented a policy, effective
Further, we found no evidence that the Office of
December 2019, to address this recommendation.
the President plans to independently verify the
Source: The Office of the President’s systemwide audit report corrective actions that campuses have agreed to
and the corrective actions developed by UC Berkeley, UCLA, and
UC San Diego. take. Rather, it is relying on the campus internal
auditors to verify implementation of these
CALIFORNIA STATE AUDITOR | Report 2019-113 57
September 2020
corrective actions. In deferring to the campuses, the Office of the
President is repeating the weak oversight practices that led to problems
we identify throughout this report.
In fact, despite the fact that its admissions office has taken no action,
UCLA’s auditors have concluded that the admissions office has
appropriately responded to one recommendation. Specifically, the
campus chose not to follow through with its plans to better document
how it guards against communication between development and
admissions personnel. Instead of improving the documentation of
its practices, as it initially stated it would, UCLA has simply referred
back to a university policy against allowing for donations to influence
admissions decisions that had already existed at the time of the internal
audit. Campus auditors considered the reference to existing policy
sufficient to close this recommendation, an action that leaves an
important recommendation for safeguarding the integrity of admissions
substantively ignored by UCLA. The Office of the President’s chief
compliance and audit officer explained that his office relied on the audit
leadership at each campus to perform quality assurance of the work
performed during the audit and to follow up on the corrective actions
each campus took in response. However, given the shortcomings
described above, we believe that the systemwide audit office must
conduct independent oversight of campus audits pertaining to the
integrity of campus admissions processes and the corrective actions they
take in response.
The Office of the President Has Neglected a Key Program Meant to
Ensure University Access for Applicants From Disadvantaged
Backgrounds
As part of its commitment to the State’s Master Plan, which was enacted
to define specific roles for the State’s different public postsecondary
educational institutions, the university makes certain admissions
guarantees: the university guarantees admission to applicants who rank
in the top 9 percent of all graduating high school
students statewide and to applicants who rank in the
top 9 percent of their specific high school graduating Key ELC Program Participation Criteria
class. To obtain admission through the second of these
High schools must do the following:
pathways, an applicant’s high school must participate
• Be accredited.
in the university’s program known as Eligibility in the
Local Context (ELC), which allows the university to • Be located in California.
determine which students have earned guaranteed • Provide most instruction in the classroom.
admission because they are in the top 9 percent • Offer a full list of university‑approved college preparatory
of a high school’s graduating seniors. The text box coursework.
shows the key criteria that high schools must satisfy
Source: University website.
to participate in the ELC program. According to the
Office of the President’s data, about 2,100 of the 2,800
high schools in California met these criteria in 2019.
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Despite the significant number of high schools that meet the criteria
for participating in the ELC program, the Office of the President’s
neglect has limited the actual participation rate. In April 2012, BOARS
indicated that it was concerned that only 63 percent of high schools
with a university‑approved course list were participating in the ELC
program and asked the Office of the President to assess the participation
rate. The minutes from BOARS’s April 2012 meeting reflect that one
member expressed interest in knowing how many students attended the
nonparticipating high schools. In response, the Office of the President
provided an analysis to BOARS that concluded that the ELC program
served the vast majority of California students. Specifically, the Office
of the President’s further analysis of nonparticipating high schools led
it to conclude that about 95 percent of California’s eligible high schools
participated in the program. The Office of the President’s analysis did
not directly respond to the request for information about the number
of students at nonparticipating high schools, and since 2012 it has not
performed another assessment to evaluate whether participation rates
remained the same or improved, or to determine how many students
have access to the university through the ELC program.
Thousands of students graduated from high
schools that serve a majority disadvantaged
population and that did not participate in a
program intended to improve access to the
university to those students.
Using the Office of the President’s data on California high schools,
we determined that the participation level of eligible high schools
has declined since 2012. As Figure 9 shows, about 30 percent—or
more than 600—of the 2,100 high schools that met the ELC program
criteria in 2019 did not participate. Thus, the participation rate in 2019
was much lower than the corrected participation rate of 95 percent
that the Office of the President determined in its 2012 assessment.
Further, among the nonparticipating high schools, almost 30 percent—
about 170 high schools—have student populations that are at least
75 percent socioeconomically disadvantaged. More than 7,700 students
graduated from these schools in 2018. Therefore—given that the
number of students graduating likely did not change substantially—in
2019 thousands of students graduated from high schools that serve a
majority disadvantaged student population and did not participate in
the ELC program. As a result, these students did not have a chance to
compete for one of the two guaranteed admissions options available
to high school students in California. Nevertheless, the Office of the
CALIFORNIA STATE AUDITOR | Report 2019-113 59
September 2020
President acknowledged that it has not recently identified eligible
high schools that do not participate in the ELC program or contacted
nonparticipating high schools to encourage their participation.
Figure 9
The Office of the President Has Not Conducted Outreach to Improve High School Participation in Its Local
Guarantee Program
About
30
%
of high schools eligible for the
local context guarantee program
did not participate, and as a result:
SLOOHCS
HGIH
ELBIGILE
(cid:31)(cid:30)(cid:29)(cid:28)(cid:27)(cid:26)(cid:25)(cid:24)(cid:23)(cid:26)(cid:28)(cid:22)(cid:29)
19,000
(cid:21)(cid:20)(cid:23)(cid:22)(cid:19)(cid:23)(cid:26)(cid:28)(cid:27)(cid:29)(cid:18)(cid:20)(cid:17)(cid:24)(cid:29)(cid:26)(cid:16)(cid:17)(cid:27)(cid:28)(cid:29)
(cid:16)(cid:25)(cid:21)(cid:16)(cid:29)(cid:27)(cid:15)(cid:16)(cid:17)(cid:17)(cid:14)(cid:27)(cid:29)(cid:15)(cid:17)(cid:19)(cid:14)(cid:22)(cid:29)(cid:30)(cid:17)(cid:26)(cid:29)(cid:15)(cid:17)(cid:24)(cid:13)(cid:28)(cid:26)(cid:28)(cid:29)(cid:26)(cid:17)(cid:29)(cid:28)(cid:23)(cid:20)(cid:30)(cid:29)(cid:17)(cid:30)(cid:28)(cid:29)(cid:17)(cid:18)(cid:29)(cid:26)(cid:16)(cid:28)(cid:29)
(cid:19)(cid:30)(cid:25)(cid:12)(cid:28)(cid:20)(cid:27)(cid:25)(cid:26)(cid:11)(cid:10)(cid:27)(cid:29)(cid:26)(cid:9)(cid:17)(cid:29)(cid:23)(cid:22)(cid:24)(cid:25)(cid:27)(cid:27)(cid:25)(cid:17)(cid:30)(cid:27)(cid:29)(cid:21)(cid:19)(cid:23)(cid:20)(cid:23)(cid:30)(cid:26)(cid:28)(cid:28)(cid:27)(cid:8)
The Office of the President has not:
(cid:31)(cid:31)(cid:30)(cid:31)(cid:31) (cid:29)(cid:28)(cid:27)(cid:26)(cid:25)(cid:24)(cid:23)(cid:22)(cid:21)(cid:20)(cid:31)(cid:19)(cid:18)(cid:22)(cid:19)(cid:31)(cid:17)(cid:27)(cid:19)(cid:26)(cid:26)(cid:16)(cid:17)(cid:31)(cid:15)(cid:26)(cid:31)(cid:14)(cid:23)(cid:24)(cid:15)(cid:18)(cid:27)(cid:18)(cid:14)(cid:23)(cid:15)(cid:21)
(cid:31)(cid:31)(cid:30)(cid:31)(cid:31) (cid:13)(cid:21)(cid:15)(cid:21)(cid:24)(cid:12)(cid:18)(cid:28)(cid:21)(cid:20)(cid:31)(cid:11)(cid:19)(cid:10)(cid:31)(cid:17)(cid:27)(cid:19)(cid:26)(cid:26)(cid:16)(cid:17)(cid:31)(cid:20)(cid:26)(cid:31)(cid:28)(cid:26)(cid:15)(cid:31)(cid:14)(cid:23)(cid:24)(cid:15)(cid:18)(cid:27)(cid:18)(cid:14)(cid:23)(cid:15)(cid:21)
Source: Analysis of the university’s high school profile data, approved course offering data, and eligibility in the local context program participation
data from 2019. Estimated number of graduates based on 2018 graduation rates.
The Office of the President could not adequately explain why so
many high schools are not participating in the ELC program. The
Office of the President’s director of undergraduate admissions
asserted that these high schools deliberately choose not to
participate and generally do not have students applying to the
university. She explained that students from the majority of
these high schools apply to less selective public universities or
elect to attend community college. However, this reasoning
ignores that program participation and the admission guarantee
could encourage more graduates from a high school to apply
to the university. Further, because the Office of the President
60 Report 2019-113 | CALIFORNIA STATE AUDITOR
September 2020
has not examined program participation in nearly a decade, its
understanding about why high schools choose not to participate is
based on outdated information.
The Office of the President’s failure to monitor the ELC program
and ensure that it reaches as many high school students as possible
is detrimental to the university’s fulfillment of its commitment
to Californians. The university started the ELC program with
the purpose of fostering equal opportunity for all California
residents to attend the university. The ELC program can have
crucial benefits for applicants, particularly when they are from
disadvantaged backgrounds. According to a study published in
2018, ELC applicants who enrolled at the university were more
likely to graduate from college, attend graduate school, and have
higher earnings in their mid‑20s than they would if had they
enrolled at less selective public universities in California. Further,
in May 2020, the university reported that more than 80 percent of
the applicants in the fall 2019 freshman class who were guaranteed
admission through the ELC program but not in the top 9 percent
of high school graduates statewide were the first generation in
their families to attend college, and nearly 80 percent were from
underrepresented groups. These findings indicate that the program
provides significant benefits to disadvantaged or underrepresented
students who might otherwise experience limited access to the
university. These findings underscore the importance of better
oversight from the Office of the President.
Recommendations
To better safeguard the integrity of the university’s admissions
processes, the Office of the President should, by July 2021, begin
conducting regular audits of the admissions processes at each of
its undergraduate campuses, ensuring that it reviews each campus
at least once every three years. These audits should be conducted
by systemwide audit staff and include, but not be limited to,
verification of special talents, communication between admissions
staff and external parties regarding applicants, and other avenues
for inappropriate influence on admissions discussed in this
report. The audits should also endeavor to identify inappropriate
admissions activity and deficiencies in the admissions process. The
Office of the President should make the results of the audits public.
CALIFORNIA STATE AUDITOR | Report 2019-113 61
September 2020
To ensure that campuses adequately address deficiencies identified
in its own internal audit, the Office of the President should
immediately begin to assess whether the campuses have completed
the corrective actions they developed in response to systemwide
recommendations and should evaluate whether the campuses’
actions adequately address the audit’s concerns.
To increase the number of high school students who have the
opportunity to gain admission to the university through its
ELC program, the Office of the President should, beginning in
April 2021, do the following:
• Annually determine which high schools are eligible to participate
in ELC but do not. It should annually report to BOARS
the number of these high schools and their demographic
characteristics.
• Annually contact eligible high schools that are not participating
in ELC to determine their reasons for choosing not to do so.
It should assess whether the university can address barriers to
participation and, to the extent that it can increase participation,
it should take the steps to do so.
We conducted this performance audit in accordance with generally accepted government auditing
standards and under the authority vested in the California State Auditor by Government Code 8543
et seq. Those standards require that we plan and perform the audit to obtain sufficient, appropriate
evidence to provide a reasonable basis for our findings and conclusions based on the audit objectives.
We believe that the evidence obtained provides a reasonable basis for our findings and conclusions
based on our audit objectives.
Respectfully submitted,
ELAINE M. HOWLE, CPA
California State Auditor
September 22, 2020
* California State Auditor’s comment(s) appear/begin on page XX.
62 Report 2019-113 | CALIFORNIA STATE AUDITOR
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Blank page inserted for reproduction purposes only.
CALIFORNIA STATE AUDITOR | Report 2019-113 63
September 2020
APPENDIX A
The University Has Not Addressed Our Recommendation to Change Its
“Compare Favorably” Policy
In March 2016, our office reported that the university had
disadvantaged California resident applicants by admitting
nonresident applicants with lower qualifications than those of the
upper half of admitted residents.11 These admissions decisions
resulted from a change that BOARS made in 2011 to the university’s
nonresident admissions policies. Specifically, BOARS amended the
policies to specify that instead of demonstrating stronger admissions
credentials than resident applicants, nonresident applicants need
to “compare favorably” to residents to gain admission to the
university. Before it adopted the compare favorably policy, BOARS’s
meeting minutes reflected a discussion about how enrolling more
nonresidents was justified because the university enrolls greater
numbers of resident students than those for whom the Legislature
provides funding. This discussion also acknowledged that campuses
increased nonresident enrollment for the revenue that nonresident
tuition generates. In our report, we recommended that the university
replace its compare favorably policy with a standard that would
require nonresidents to have admissions credentials that place them
in the upper half of the residents it admits—an approach that we
determined was consistent with the intent of the Master Plan.
We made that recommendation because we concluded that by
adopting the compare favorably standard, the university had degraded
the access that it provided to well‑qualified resident applicants in
exchange for offering admission to nonresidents who often had
weaker academic qualifications. Specifically, the report found that
during the 10‑year period ending in academic year 2014–15, resident
enrollment had increased by 10 percent while nonresident enrollment
had increased by 432 percent. Further, the university had admitted
nearly 61,000 nonresidents whose unweighted GPA scores fell below
the upper half of admitted residents during academic years 2006–07
through 2014–15, and it admitted 9,400 nonresidents whose SAT
reading and math scores fell below the upper half of admitted
residents’ scores. The university disagreed with our recommendation
and asserted that the compare favorably policy met its primary
responsibility to residents. We stand by our recommendation because
our review of this issue during this audit demonstrates that the
university has continued to admit nonresident applicants with lower
qualifications than the residents it admits.
11 The University of California: Its Admissions and Financial Decisions Have Disadvantaged California
Resident Students, Report 2015‑107, March 2016.
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Our previous review also found that the university generally
admitted nonresident students with average grade point averages
and standardized test scores that were lower than those of
resident students. The university asserted to us that using these
two academic metrics to determine the qualifications of applicants
does not necessarily correlate with admissions decisions and that
instead the university uses a comprehensive review process to
evaluate applicants. As we discuss in this report, the result of the
comprehensive review process is a rating that readers assign to each
application, and that rating represents a campus’s full consideration
of an applicant’s accomplishments. Therefore, during this audit, we
used the comprehensive review ratings that readers had assigned to
applications to assess the relative qualifications of the resident and
nonresident applicants they admitted.
Campuses admitted most of the applicants to whom they assigned
the highest ratings, regardless of their residency status. However,
nonresident applicants at UCLA and UC San Diego who received
ratings from the middle of the rating scale were more likely to be
admitted than resident applicants with the same ratings. For
example, at UCLA’s College of Letters and Science, nonresident
applicants from the United States whom readers rated as
Recommend for Admission were almost three times more likely to
be admitted than California resident applicants who received the
same rating. Similar also to the results of our last audit, our review
shows that from academic years 2017–18 through 2019–20, the
campuses denied thousands of resident applicants admission while
simultaneously admitting nonresident applicants with lower ratings.
University‑imposed caps on nonresident
admission do not prevent the campuses from
Nonresident Enrollment by Campus in admitting less qualified nonresidents. In 2017
Academic Year 2018–19
the Regents implemented a policy to limit
nonresident enrollment to 18 percent for each
UC Berkeley: 24.5%
of the five undergraduate campuses that had not
UC Davis: 18.1%
yet grown their nonresident populations to that
UC Irvine: 18.5%
size. Consequently, each of these campuses can
UCLA: 23.3% continue to grow the size of their nonresident
UC Merced: 0.5% student populations up to 18 percent. In
contrast, UC Berkeley, UCLA, UC San Diego,
UC Riverside: 3.7%
and UC Irvine had already enrolled more than
UC San Diego: 21.8%
18 percent of nonresidents when the Regents
UC Santa Barbara: 16.0% imposed the cap. For these campuses, the
Regents’ policy froze nonresident enrollment at
UC Santa Cruz: 10.4%
their academic year 2017–18 levels. The text box
Source: University’s data on nonresident enrollment by campus.
shows each campuses’ nonresident enrollment
proportion during academic year 2018–19.
CALIFORNIA STATE AUDITOR | Report 2019-113 65
September 2020
APPENDIX B
Statistics on the Diversity of Freshman Applicants Whom the
University Admitted for Academic Years 2017–18 Through 2019–20
The Audit Committee asked us to report a variety of demographic
information for the students that the university admitted from
academic years 2017–18 through 2019–20. The Audit Committee
further requested that we report on the diversity of applicants
admitted because of donations, influence, or legacy status,
as well as the categories of applicants admitted by exception.
Figures B.1 through B.4 provide the information that the Audit
Committee requested.
66 Report 2019-113 | CALIFORNIA STATE AUDITOR
September 2020
Figure B.1
Diversity of Admitted Students by Campus, Academic Years 2017–18 Through 2019–20
UC BERKELEY UCLA UC SAN DIEGO SYSTEMWIDE
(cid:31)(cid:30)(cid:29)(cid:28)(cid:30)(cid:27)(cid:26)
(cid:31)(cid:30)(cid:29)(cid:28)(cid:27)(cid:30) 57.4% 56.7% 54.5% 56.8%
(cid:26)(cid:28)(cid:27)(cid:30) 41.4% 42.3% 45.5% 42.7%
(cid:25)(cid:24)(cid:23)(cid:24)(cid:22)(cid:21)(cid:24) 1.2% 1.0% 0.0% 0.5%
(cid:27)(cid:30)(cid:25)(cid:24)(cid:28)(cid:30)(cid:29)(cid:23)(cid:22)(cid:26)
(cid:20)(cid:28)(cid:27)(cid:19)(cid:18)(cid:22)(cid:17)(cid:24)(cid:19)(cid:28)(cid:16)(cid:15)(cid:30)(cid:14)(cid:19)(cid:13)(cid:30)(cid:24)(cid:12) 64.3% 57.1% 59.3% 68.9%
(cid:11)(cid:22)(cid:29)(cid:30)(cid:14)(cid:12)(cid:19)(cid:10)(cid:16)(cid:9)(cid:22)(cid:24)(cid:17)(cid:30)(cid:14)(cid:19)(cid:13)(cid:30)(cid:24)(cid:12) 25.5% 29.7% 21.8% 13.8%
(cid:16) (cid:8)(cid:24)(cid:12)(cid:30)(cid:17)(cid:24)(cid:28)(cid:12)(cid:19)(cid:22)(cid:24)(cid:28)(cid:27) 10.2% 13.2% 18.9% 17.3%
(cid:30)(cid:21)(cid:20)(cid:29)(cid:24)(cid:23)(cid:24)(cid:21)(cid:22)(cid:26)
(cid:31) (cid:7)(cid:18)(cid:17)(cid:19)(cid:10)(cid:28)(cid:24)(cid:16)(cid:7)(cid:29)(cid:30)(cid:17)(cid:19)(cid:10)(cid:28)(cid:24) 3.6% 4.8% 2.8% 3.7%
(cid:16) (cid:7)(cid:29)(cid:30)(cid:17)(cid:19)(cid:10)(cid:28)(cid:24)(cid:16)(cid:8)(cid:24)(cid:13)(cid:19)(cid:28)(cid:24) 0.6% 0.6% 0.4% 0.4%
(cid:16) (cid:20)(cid:6)(cid:19)(cid:10)(cid:28)(cid:24)(cid:22)(cid:5)(cid:4)(cid:28)(cid:12)(cid:19)(cid:24)(cid:22) 40.9% 36.8% 35.5% 33.7%
(cid:16) (cid:7)(cid:14)(cid:19)(cid:28)(cid:24) 15.4% 15.6% 17.3% 21.7%
(cid:16) (cid:3)(cid:6)(cid:19)(cid:12)(cid:30) 24.4% 24.7% 21.7% 20.0%
(cid:16) (cid:8)(cid:24)(cid:12)(cid:30)(cid:17)(cid:24)(cid:28)(cid:12)(cid:19)(cid:22)(cid:24)(cid:28)(cid:27) 10.2% 13.2% 18.9% 17.3%
(cid:16) (cid:25)(cid:24)(cid:23)(cid:24)(cid:22)(cid:21)(cid:24) 4.9% 4.3% 3.4% 3.2%
(cid:19)(cid:24)(cid:27)(cid:25)(cid:21)(cid:18)(cid:31)(cid:30)(cid:29)(cid:30)(cid:27)(cid:17)(cid:21)(cid:24)(cid:16)(cid:29)
(cid:31) (cid:2)(cid:30)(cid:14) 20.7% 20.2% 26.4% 32.4%
(cid:16) (cid:9)(cid:22) 79.3% 79.8% 73.6% 67.6%
(cid:19)(cid:24)(cid:27)(cid:25)(cid:21)(cid:26)(cid:15)(cid:17)(cid:29)(cid:31)(cid:14)(cid:17)(cid:31)(cid:30)(cid:26)
(cid:31) (cid:1)(cid:24)(cid:127)(cid:27)(cid:19)(cid:14)(cid:6) 41.3% 42.9% 37.9% 37.1%
(cid:1)(cid:24)(cid:127)(cid:27)(cid:19)(cid:14)(cid:6)(cid:16)(cid:28)(cid:24)(cid:13)(cid:16)(cid:28)(cid:24)(cid:22)(cid:12)(cid:6)(cid:30)(cid:17)(cid:16)(cid:27)(cid:28)(cid:24)(cid:127)(cid:129)(cid:28)(cid:127)(cid:30) 20.1% 19.7% 27.5% 28.8%
(cid:4)(cid:28)(cid:24)(cid:127)(cid:129)(cid:28)(cid:127)(cid:30)(cid:16)(cid:22)(cid:12)(cid:6)(cid:30)(cid:17)(cid:16)(cid:12)(cid:6)(cid:28)(cid:24)(cid:16)(cid:30)(cid:24)(cid:127)(cid:27)(cid:19)(cid:14)(cid:6) 38.6% 37.4% 34.7% 34.0%
(cid:25)(cid:23)(cid:20)(cid:16)(cid:16)(cid:15)(cid:26)(cid:17)(cid:27)(cid:30)(cid:17)(cid:26)(cid:21)(cid:22)(cid:13)(cid:30)(cid:26)(cid:26)(cid:31)(cid:30)(cid:29)(cid:28)(cid:27)(cid:26)(cid:25)(cid:24)(cid:23)(cid:27)(cid:29)(cid:22)(cid:21)(cid:20)(cid:19)(cid:27)(cid:18)(cid:20)(cid:23)(cid:17)(cid:19)(cid:16)(cid:26)
(cid:31) (cid:15)(cid:129)(cid:17)(cid:28)(cid:27) 41.8% 42.5% 43.0% 41.9%
(cid:16) (cid:141)(cid:129)(cid:143)(cid:129)(cid:17)(cid:143)(cid:28)(cid:24) 50.1% 49.6% 48.3% 49.1%
(cid:16) (cid:25)(cid:17)(cid:143)(cid:28)(cid:24) 6.7% 6.6% 7.3% 8.1%
(cid:16) (cid:25)(cid:24)(cid:23)(cid:24)(cid:22)(cid:21)(cid:24) 1.4% 1.3% 1.4% 0.9%
(cid:13)(cid:17)(cid:27)(cid:30)(cid:29)(cid:21)(cid:26)(cid:24)(cid:29)(cid:23)(cid:16)(cid:12)(cid:30)(cid:26)
(cid:31) (cid:144)(cid:157) €‚(cid:157)(cid:157)(cid:157) 18.3% 17.8% 21.5% 25.0%
(cid:16) (cid:144)ƒ(cid:157)‚(cid:157)(cid:157)(cid:157) €€‚€€€ 14.3% 14.0% 16.4% 16.9%
(cid:16) (cid:144)„(cid:157)(cid:157)‚(cid:157)(cid:157)(cid:157) „ €‚€€€ 12.7% 12.8% 13.6% 13.0%
(cid:16) (cid:144)„ƒ(cid:157)‚(cid:157)(cid:157)(cid:157)(cid:16)(cid:28)(cid:24)(cid:13)(cid:16)(cid:28)(cid:143)(cid:22)…(cid:30) 42.8% 43.0% 38.1% 35.6%
(cid:25)(cid:24)(cid:23)(cid:24)(cid:22)(cid:21)(cid:24)(cid:16)(cid:22)(cid:17)(cid:16)(cid:29)(cid:19)(cid:14)(cid:14)(cid:19)(cid:24)(cid:127) 11.9% 12.4% 10.4% 9.5%
(cid:30)(cid:15)(cid:24)(cid:31)(cid:24)(cid:11)(cid:15)(cid:30)(cid:26)(cid:24)(cid:29)(cid:26)(cid:21)(cid:20)(cid:30)(cid:26)(cid:15)(cid:16)(cid:23)(cid:17)(cid:15)(cid:26)(cid:23)(cid:16)(cid:29)(cid:21)(cid:30)(cid:10)(cid:21)
(cid:2)(cid:30)(cid:14) 76.4% 83.1% 76.9% 58.0%
Source: Analysis of applications and admissions data regarding freshman applicants.
Note: In this figure and the figures that(cid:9) fo(cid:22)llow we 1g6en.2e%rally use the terminolo1g0y. 4co%ntained in the Office of 1th7e.9 P%resident’s applications and ad3m6.i8ss%ions data when
referring to gender, ethnicity, and other categories of student diversity.
(cid:7)(cid:12)(cid:12)(cid:30)(cid:24)(cid:13)(cid:30)(cid:13)(cid:16)(cid:28)(cid:16)(cid:24)(cid:22)(cid:24) (cid:1)(cid:4)(cid:20)(cid:16)(cid:14)(cid:10)(cid:6)(cid:22)(cid:22)(cid:27) 7.4% 6.5% 5.2% 5.2%
CALIFORNIA STATE AUDITOR | Report 2019-113 67
September 2020
Figure B.2
Diversity of Students Admitted Due to Inappropriate Factors, Academic Years 2013–14 Through 2019–20
(cid:31)(cid:22)(cid:25)(cid:30)(cid:21)(cid:30)(cid:20)(cid:19)(cid:26)(cid:28)(cid:25)(cid:28)(cid:20)(cid:24)(cid:23)
(cid:31) (cid:12)(cid:27)(cid:25)(cid:28)(cid:15)(cid:30)(cid:24)(cid:23)(cid:12)(cid:16)(cid:21)(cid:25)(cid:28)(cid:15)(cid:30)(cid:24) 7.8%
(cid:23) (cid:12)(cid:20)(cid:28)(cid:30)(cid:24) 11%
(cid:23) (cid:31)(cid:11)(cid:28)(cid:15)(cid:30)(cid:24)(cid:26)(cid:10)(cid:9)(cid:30)(cid:18)(cid:28)(cid:24)(cid:26) 15.6%
(cid:23) (cid:13)(cid:24)(cid:18)(cid:21)(cid:25)(cid:24)(cid:30)(cid:18)(cid:28)(cid:26)(cid:24)(cid:30)(cid:29) 4.7%
(cid:23) (cid:8)(cid:11)(cid:28)(cid:18)(cid:21) 53.1%
(cid:23) (cid:7)(cid:24)(cid:6)(cid:24)(cid:26)(cid:5)(cid:24) 7.8%
(cid:18)(cid:22)(cid:31)(cid:30)(cid:26)(cid:20)(cid:23)(cid:28)(cid:26)(cid:25)(cid:17)(cid:16)(cid:30)(cid:23)
(cid:31) (cid:4)(cid:3)(cid:2)(cid:1)(cid:127)(cid:129)(cid:3)(cid:3)(cid:3) 6.3%
(cid:23) (cid:4)(cid:141)(cid:3)(cid:129)(cid:3)(cid:3)(cid:3)(cid:2)(cid:127)(cid:127)(cid:129)(cid:127)(cid:127)(cid:127) 10.9%
(cid:23) (cid:4)(cid:143)(cid:3)(cid:3)(cid:129)(cid:3)(cid:3)(cid:3)(cid:2)(cid:143)(cid:1)(cid:127)(cid:129)(cid:127)(cid:127)(cid:127) 4.7%
(cid:23) (cid:4)(cid:143)(cid:141)(cid:3)(cid:129)(cid:3)(cid:3)(cid:3)(cid:23)(cid:30)(cid:24)(cid:19)(cid:23)(cid:30)(cid:144)(cid:26)(cid:157)(cid:21) 51.5%
(cid:7)(cid:24)(cid:6)(cid:24)(cid:26)(cid:5)(cid:24)(cid:23)(cid:26)(cid:25)(cid:23)(cid:16)(cid:28)(cid:20)(cid:20)(cid:28)(cid:24) 26.6%
(cid:31)(cid:30)(cid:29)(cid:28)(cid:27)(cid:30)(cid:26)(cid:25)(cid:24)(cid:23)
(cid:31)(cid:30)(cid:29)(cid:28)(cid:27)(cid:26)(cid:25)(cid:24)(cid:28)(cid:30)(cid:23)(cid:22)(cid:21)(cid:20)(cid:28)(cid:19)(cid:21)(cid:24)(cid:18) 7398..36%% 78.1%
(cid:17)(cid:26)(cid:16)(cid:21)(cid:20)(cid:18)(cid:28)(cid:15)(cid:23)(cid:14)(cid:26)(cid:24)(cid:25)(cid:21)(cid:20)(cid:28)(cid:19)(cid:21)(cid:24)(cid:18) 17.2%
(cid:23) (cid:13)(cid:24)(cid:18)(cid:21)(cid:25)(cid:24)(cid:30)(cid:18)(cid:28)(cid:26)(cid:24)(cid:30)(cid:29) 4.7%
Source: Analysis of applications and admissions data regarding freshman applicants
Figure B.3
Reason for Ineligibility for Students Admitted by Exception, by Campus, Academic Years 2017–18 Through 2019–20
UC BERKELEY UCLA UC SAN DIEGO
(cid:31)(cid:30)(cid:29)(cid:29)(cid:30)(cid:28)(cid:27)(cid:26)(cid:25)(cid:24)(cid:23)(cid:23)(cid:22)(cid:27)(cid:22)(cid:26)(cid:21)(cid:20)(cid:22)(cid:21)(cid:19)(cid:20)(cid:19)(cid:18)(cid:24)(cid:20)(cid:17)(cid:26) 76.9% 66.4% 86.4%
(cid:25)(cid:24)(cid:16)(cid:20)(cid:29)(cid:22)(cid:15)(cid:24)(cid:20)(cid:14)
(cid:27)(cid:21)(cid:19)(cid:26)(cid:13)(cid:22)(cid:12)(cid:30)(cid:25)(cid:30)(cid:22)(cid:28)(cid:25)(cid:17)(cid:11) 15.2% 9.3% 5.3%
(cid:31)(cid:30)(cid:29)(cid:29)(cid:30)(cid:28)(cid:27)(cid:26)(cid:29)(cid:18)(cid:19)(cid:28)(cid:13)(cid:19)(cid:20)(cid:13)(cid:30)(cid:10)(cid:22)(cid:13)(cid:26) 1.6% 0.8% 1.9%
(cid:18)(cid:22)(cid:29)(cid:18)
(cid:25)(cid:24)(cid:31)(cid:9)(cid:30)(cid:28)(cid:19)(cid:18)(cid:30)(cid:24)(cid:28) 6.3% 23.5% 6.4%
TOTALS 303 375 794
Source: Analysis of applications and admissions data regarding California resident freshman applicants that UC Berkeley, UCLA, and UC San Diego
selected for admission for academic years 2017–18 through 2019–20 and whom did not meet university eligibility requirements.
* The majority of these students did not have a GPA in the applications data. Students may not have a GPA in the data because their high schools use
a grading system that does not easily convert to the standard scale or the students did not provide enough information on their applications to
calculate their grade point average.
68 Report 2019-113 | CALIFORNIA STATE AUDITOR
September 2020
In our March 2016 Report 2015‑107 (The University of California:
Its Admissions and Financial Decisions Have Disadvantaged
California Resident Students), we reported that from academic
years 2005–06 through 2014–15, the university admitted increasing
numbers of nonresident students. The figure below presents trends
in nonresident admission since that time.
Figure B.4
Residency Trends of Admitted Students, Academic Years 2015–16 Through 2019–20
(cid:31)(cid:30)(cid:29)(cid:28)(cid:27)(cid:26)(cid:25)(cid:24)(cid:28)(cid:30) (cid:21)(cid:26)(cid:19)(cid:23)(cid:22)(cid:20)(cid:28)(cid:31)
(cid:25)(cid:23)(cid:22)(cid:28)(cid:21)(cid:23)(cid:24)(cid:20) (cid:24)(cid:26)(cid:24)(cid:25)(cid:23)(cid:22)(cid:28)(cid:21)(cid:23)(cid:24)(cid:20) (cid:28)(cid:24)(cid:20)(cid:23)(cid:25)(cid:24)(cid:30)(cid:20)(cid:28)(cid:26)(cid:24)(cid:30)(cid:29)
(cid:31)(cid:30)(cid:29)(cid:28)(cid:27)(cid:29)(cid:26) 66.0% 23.5% 10.5%
(cid:31)(cid:30)(cid:29)(cid:26)(cid:27)(cid:29)(cid:25) 67.9% 24.1% 8.0%
(cid:31)(cid:30)(cid:29)(cid:25)(cid:27)(cid:29)(cid:24) 1.2% 61.9% 29.1% 9.0%
(cid:31)(cid:30)(cid:29)(cid:24)(cid:27)(cid:29)(cid:23) 65.8% 23.2% 11.0%
UC BERKELEY
(cid:31)(cid:30)(cid:29)(cid:23)(cid:27)(cid:31)(cid:30) 65.4% 23.8% 10.8%
(cid:31)(cid:30)(cid:29)(cid:28)(cid:27)(cid:29)(cid:26) 58.5% 26.7% 14.8%
(cid:31)(cid:30)(cid:29)(cid:26)(cid:27)(cid:29)(cid:25) 59.6% 26.3% 14.1%
(cid:31)(cid:30)(cid:29)(cid:25)(cid:27)(cid:29)(cid:24) 56.5% 29.5% 14.0%
(cid:31)(cid:30)(cid:29)(cid:24)(cid:27)(cid:29)(cid:23) 54.6% 31.5% 13.9%
UCLA
(cid:31)(cid:30)(cid:29)(cid:23)(cid:27)(cid:31)(cid:30) 60.9% 27.7% 11.4%
(cid:31)(cid:30)(cid:29)(cid:28)(cid:27)(cid:29)(cid:26) 61.4% 17.0% 21.6%
(cid:31)(cid:30)(cid:29)(cid:26)(cid:27)(cid:29)(cid:25) 62.4% 18.9% 18.7%
(cid:31)(cid:30)(cid:29)(cid:25)(cid:27)(cid:29)(cid:24) 61.5% 19.3% 19.2%
UC SAN DIEGO (cid:31)(cid:30)(cid:29)(cid:24)(cid:27)(cid:29)(cid:23) 59.2% 21.5% 19.3%
(cid:31)(cid:30)(cid:29)(cid:23)(cid:27)(cid:31)(cid:30) 57.2% 24.7% 18.1%
(cid:31)(cid:30)(cid:29)(cid:28)(cid:27)(cid:29)(cid:26) 71.4% 12.8% 15.8%
(cid:31)(cid:30)(cid:29)(cid:26)(cid:27)(cid:29)(cid:25) 72.0% 12.6% 15.4%
(cid:31)(cid:30)(cid:29)(cid:25)(cid:27)(cid:29)(cid:24) 69.4% 13.7% 16.9%
(cid:31)(cid:30)(cid:29)(cid:24)(cid:27)(cid:29)(cid:23) 68.7% 13.7% 17.6%
SYSTEMWIDE
(cid:31)(cid:30)(cid:29)(cid:23)(cid:27)(cid:31)(cid:30) 68.7% 13.9% 17.4%
Source: Analysis of applications and admissions data regarding freshman applicants selected for admission.
CALIFORNIA STATE AUDITOR | Report 2019-113 69
September 2020
APPENDIX C
Scope and Methodology
The Audit Committee directed the California State Auditor to
review the university’s admissions practices. Specifically, the Audit
Committee requested that we review areas of the admissions
process related to fraud prevention, inappropriate influence on
admissions decisions, and the use of admission by exception and
admission on the basis of special talent. The table below lists the
objectives that the Audit Committee approved and the methods we
used to address them.
Audit Objectives and the Methods Used to Address Them
AUDIT OBJECTIVE METHOD
1 Review and evaluate the laws, rules, Reviewed relevant laws, regulations, and other background materials applicable to
and regulations significant to the audit the university and its admissions processes.
objectives.
2 Review and evaluate the university’s • Reviewed relevant university policies and evaluated whether they are adequate for
systemwide admissions policies and ensuring fairness and preventing improper influence in admissions by comparing them
practices, as well as the results of the against best practices and reviewing admissions practices at select campuses.
university’s internal investigations. • Reviewed the university’s recent internal audit to determine its results, the basis for its
conclusions and recommendations, and to evaluate whether we could rely on the internal
audit work to address any of our audit objectives. We determined that, with the exception
of our work pertaining to the Office of the President’s process for verifying application
information, we could not rely on the work the university performed to answer any of
our audit objectives, largely because that work was not conducted in accordance with
the audit standards that state law requires us to follow.
continued on next page . . .
70 Report 2019-113 | CALIFORNIA STATE AUDITOR
September 2020
AUDIT OBJECTIVE METHOD
3 For at least the UC Berkeley, UCLA, • Evaluated the three campuses’ policies and procedures related to reviewing and rating
and UC San Diego campuses, assess admissions applications and ensuring consistency and fairness in application reviews.
admissions policies and practices by • Assessed the processes that the three campuses use to select applicants for admission to
doing the following: ensure consistency and fairness in those decisions; determined whether those processes
a. Assess the factors considered when create opportunity for improper influence in admissions decisions, including influence
deciding which applicants to admit to related to donations and legacy. Analyzed systemwide data and reviewed email records
the selected campuses. at each of the three campuses we reviewed to identify potential improper influence in
b. Evaluate fraud risks associated with admissions decisions, including by individuals who were hired privately by families to
the admissions process including, but facilitate admissions discussions with campuses. Evaluated the diversity of the applicants
not limited to, potential deceptive we identified as admitted due to improper influence.
practices related to standardized test • Selected 10 students from each campus and determined whether the campuses
scores, high school grades, essays, and verified the students’ grades and test scores. Determined that the university obtained
student‑athlete admissions. standardized test scores directly from the ACT and College Board. Evaluated the changes
c. Determine the extent to which that the university made to its systemwide process for identifying fraud in applications
donations, influence, and legacy factor following the systemwide internal audit and determined that those changes adequately
into the admissions process. To the addressed gaps in the verification of the content of student application essays.
extent possible, evaluate the diversity of
• Analyzed systemwide data to identify the diversity, residency status, and academic
students admitted due to these factors.
qualifications of students who applied, were admitted, and were denied admission both
d. Determine the extent to which the
systemwide and at the three campuses we reviewed. Assessed trends in the university’s
university considers student diversity
admission of nonresident and resident students since academic year 2010–11.
during the admissions process and report
on the diversity of admitted students. • State law prohibits the university from considering protected characteristics—such as
e. Identify and assess any trends related race and gender—in admissions decisions. Key university strategies to improve diversity
to the admission of nonresident and of students are its Eligible in the Local Context Program and its efforts to recruit and enroll
resident students since academic disadvantage and underrepresented students. Therefore, we focused our review of the
year 2010–11. university’s consideration of diversity during the admissions process on those areas.
• Reviewed university and campus efforts to recruit and enroll disadvantaged and
underrepresented students. Determined that the campuses generally followed common
or best practices for recruiting these students.
• Obtained data on ELC program participation. We interviewed admissions staff at
the campuses to determine whether or how they consider ELC status in admissions
decisions. The campuses generally reported that ELC status is one factor they consider in
admissions decisions.
4 For at least the past three years, identify • Analyzed systemwide data to determine the number of students the campuses admitted
how many students UC Berkeley, UCLA, by exception.
and UC San Diego admitted under the • Because the three campuses did not adequately record or justify the reasons for admitting
university’s special admissions policy, with applicants for exception, we could not determine the categories of applicants the
a focus on students admitted through campuses admitted by exception beyond those we present in Appendix B.
the identification of a special talent or
• Evaluated campus policies and procedures related to admissions by exception.
achievement. For those students, do the
following, to the extent possible: • Identified the number of recruited student athletes and students admitted due to a
special talent.*
a. Determine the categories of students
admitted by exception. • Assessed policies and practices relevant to the admission of prospective student athletes
b. Evaluate the policies and practices and applicants with special talents to determine whether the campuses have adequate
related to verifying the eligibility of practices to prevent improper outside influence, including fraud.
applicants admitted by exception • At each campus, selected 10 prospective student athletes and 10 students with special
and any follow‑up performed by the talents whom the campus admitted, and we assessed whether the campuses adequately
campuses to determine whether confirmed the recruit’s talent. Determined whether the campus monitored to ensure that
students continue to participate in the prospective student athletes continued to participate in the sport for at least one year.
sports or other activities for which they
• Reviewed all student athletes from academic years 2013–14 through 2018–19 for
were admitted.
six teams at each campus to determine if each student athlete participated for at least a
c. For a selection of students, determine
year and possessed adequate athletic talent in the sport they purportedly played.
whether they are still participating in
the sport or other activity for which they • For the student athletes who both participated for less than a year and who did not
were admitted by exception. possess adequate athletic talent, reviewed additional materials—including donation
d. Assess whether the above data records and staff emails—to determine if inappropriate factors, such as donations to the
indicates any risk of fraud in the campus or favors to associates, were factors that influenced admissions decisions.
admissions process.
CALIFORNIA STATE AUDITOR | Report 2019-113 71
September 2020
AUDIT OBJECTIVE METHOD
5 Review and assess university and Incorporated the procedures related to this objective into objectives 3 and 4b by reviewing
campus policies and practices related to the process that each campus uses to make admissions decisions and assessing those
interacting with other entities involved in processes for risk.
the admission process including, but not
limited to, the College Board, ACT, and
private admission consultants.
6 Evaluate the sufficiency of steps • Analyzed admission trends of resident and nonresident students across the university and
taken by the university in response to at the three campuses.
admission‑related recommendations in • Analyzed campus data on the qualifications of admitted resident and nonresident
the California State Auditor’s March 2016 undergraduate applicants to determine if nonresidents exceeded the qualifications
audit report (Report 2015‑107) as of residents.
well as other California State Auditor
• Obtained and reviewed resident and nonresident enrollment targets for campuses from
recommendations, if applicable.
academic years 2017–18 through 2019–20.
7 Review and assess any other issues that are None identified.
significant to the audit.
Source: Audit Committee’s audit request number 2019‑113, planning documents, and information and documentation identified in the table column
titled Method.
* We expanded our review of the prospective student‑athlete admissions processes to include UC Santa Barbara.
Assessment of Data Reliability
The U.S. Government Accountability Office, whose standards
we are statutorily required to follow, requires us to assess
the sufficiency and appropriateness of computer‑processed
information that we use to support our findings, conclusions,
and recommendations. In performing this audit, we relied on
various electronic data to evaluate the campuses’ application
review processes and to identify the academic qualifications and
diversity of students who applied and were admitted or denied
admission. Specifically, we obtained application and admission
data from the Office of the President and application review data
from four campuses—UC Berkeley, UCLA, UC San Diego, and
UC Santa Barbara.
To evaluate these data, we reviewed existing information about the
data, interviewed university and campus staff knowledgeable about
the data, and performed electronic testing of the data. As a result,
we identified limitations with the data. Specifically, the Office of
the President uses self‑reported information from each application.
However, this information is not necessarily updated in the data if
the Office of the President, or the campuses subsequently identify
discrepancies. Therefore, we found that the Office of the President’s
and the campuses’ data were of undetermined reliability for our
purposes. Although this determination may affect the precision
of the numbers we present, there is sufficient evidence in total to
support our findings, conclusions, and recommendations.
72 Report 2019-113 | CALIFORNIA STATE AUDITOR
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CALIFORNIA STATE AUDITOR | Report 2019-113 73
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*
1
2
3
* California State Auditor’s comments begin on page 75.
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CALIFORNIA STATE AUDITOR | Report 2019-113 75
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COMMENTS
CALIFORNIA STATE AUDITOR’S COMMENTS ON THE
RESPONSE FROM THE UNIVERSITY OF CALIFORNIA
To provide clarity and perspective, we are commenting on
the university’s response to our audit. The numbers below
correspond to the numbers we have placed in the margin of the
university’s response.
The university’s internal audit, and its recommendations, did 1
not address significant aspects of the admissions process that we
reviewed during our audit. Furthermore, our recommendations
are stronger than those made by the university’s internal audit
and address serious deficiencies that it did not identify. Left
unaddressed, these issues will continue to harm qualified applicants
who apply to the university.
Although both audits addressed the potential for inappropriate
influence in the admissions process, as we state on page 56, the
university’s audit did not detect the ways in which staff from the
development office and other university staff inappropriately
influenced admissions decisions at UC Berkeley. Further, the
internal audit did not review or make any recommendations related
to training and monitoring of application readers. Our review in
this area—the details of which we describe beginning on page 39—
found the inconsistency among readers negatively affects many
thousands of applicants each year. Finally, the internal audit did not
include an examination of whether the Office of the President has
conducted sufficient and appropriate oversight of the admissions
process. Our review found that the Office of the President has not
adequately safeguarded the admissions process, and we recommend
that it conduct regular audits of its campuses.
As we describe beginning on page 56, the Office of the 2
President has allowed campuses to respond to its internal audit
recommendations by each developing their own corrective
actions. Further, the Office of the President has not reviewed
the campuses’ implementation of those corrective actions. As a
result, the actions campuses have taken have been inadequate and
inconsistent. For example, on page 57 our report describes how
UCLA decided not to implement the Office of the President’s
recommendation to adopt a policy prohibiting communication
between development and admissions offices about prospective
students. The inadequacies in the campuses’ implementation of the
internal audit recommendations led us to recommend, on page 61,
76 Report 2019-113 | CALIFORNIA STATE AUDITOR
September 2020
that the Office of the President directly monitor the way campuses
address those recommendations—an oversight activity it had not
planned to perform.
3
We look forward to reviewing the actions the Office of the President
takes to address the deficiencies in the university’s admissions
process that we identify in our report. During our audit we had
several discussions with each of the campuses and the Office of
the President wherein we described the deficiencies we found, the
information we had reviewed to come to our conclusions, and our
recommendations for correcting the identified problems. These
discussions provided the university with sufficient information to
address the areas of inconsistency and improper influence in its
admissions process. Throughout the finalization of this report we
discussed with the university its requests for additional detailed
information from our review. Before we published this report, we
provided additional information to the university.