Higher education finance PPoint Project 2
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Higher education finance PPoint Project 2
- 1. Cheryl Fox EDU 647.90 Dr. Gregory Nayor HIGHER EDUCATION FINANCE AT STANFORD UNIVERSITY
- 2. Introduction This presentation will discuss higher education finance at Stanford University. The first part will discuss the different types of budgets that exist and how the budgets are developed. The middle will highlight the tools and applications used in creating and maintaining the budgets as well as some factors influencing their makeup. The final part will bring to light some social, political, and ethical concerns about budgets, as well as present a critique of the budget process.
- 3. History & Facts • Founded by Leland and Jane Lathrop Stanford in 1885 • Opened on October 1, 1891 where tuition was free • Private • Co-educational – even when it first opened • Non-denominational – even when it first opened • Covers 8,180 acres and located in Stanford, California • 7 schools: • School of Earth Sciences • Graduate School of Business • School of Humanities and Sciences • School of Engineering • School of Medicine • Graduate School of Education • Stanford Law School • 1,651 undergraduate degrees-2014 Figure 1. Stanford University Campus. U.S. News & World Report http://colleges.usnews.rankingsandreviews.com/best-colleges/stanford-1305 (Stanford University. (n.d.). In Wikipedia.) (Stanford University. (2015). Stanford: Facts 2014- Academics)
- 4. Institutional Mission • “Its nature, that of a university with such seminaries of learning as shall make it of the highest grade, including mechanical institutes, museums, galleries of art, laboratories, and conservatories, together with all things necessary for the study of agriculture in all its branches, and for mechanical training, and the studies and exercises directed to the cultivation and enlargement of the mind; • Its object, to qualify its students for personal success, and direct usefulness in life; • And its purposes, to promote the public welfare by exercising an influence in behalf of humanity and civilization, teaching the blessings of liberty regulated by law, and inculcating love and reverence for the great principles of government as derived from the inalienable rights of man to life, liberty, and the pursuit of happiness” (Stanford University. (2015). Stanford’s Mission)
- 5. Finance Department Organization/Structure Figure 2. Stanford University Budget Office. This figure illustrates the UBO hierarchy. http://web.stanford.edu/dept/pres-provost/budget/misc/UBO%20Org%20Chart.pdf
- 6. University Budget Office (UBO) Mission • Lead the development & management of Consolidated Budget and General Funds Budget of the university • Manage the resources available for university operating expenditures • Assist staff in establishing, maintaining, and overseeing budgets • Including training • Develop and maintain systems that can support budget development and reporting • Educate, guide, and report to internal and external constituents about budgets and finances • Provide the annual budget plan • Perform recurring studies and one-time analyses (Stanford University. (2015). University Budget Office Mission)
- 7. Budgets at Stanford • “Budget” - amalgamation of thousands of smaller budgets • Each smaller budget is created and managed by units which govern each of them • Primary control on local unit budgets is available funding • Big “budget” is overseen by Provost • Fiscal Year – September 1 ----> August 31 • Decentralized structure at Stanford • Schools and other units are allowed freedom in creating/executing budgets • Consolidated Operating Budget • General Funds Budget • Capital Funds Budget (Stanford University. (2015). Budget Plan 2014/15)
- 8. Consolidated Operating Budget • Aggregate of all of Stanford’s smaller budgets • Revenues – • Student income • University-sponsored research • Health care services income • Expendable gifts • Investment income • Projected to exceed $5 billion in 2014/15 fiscal year • Expenses – • Salaries & benefits • Financial aid • Other operating expenses (Stanford University. (2015). Budget Plan 2014/15)
- 9. General Funds Budget • Funds that can be used for any purpose • Supports many of the core academic & support functions of the university • Half will cover: • Salaries • Benefits • Non-salary costs • Existing facility operating costs • Remainder will cover: • Compliance/Regulations • Security • Necessary administrative activities • 2014/2015 ~$1.25 billion (Stanford University. (2015). Budget Plan 2014/15)
- 10. Capital Funds Budget • Investments for: • Energy facility • Parking structures • Maintenance projects • Housing projects • Building projects • Bass Biology Research Building • Business School Graduate Residences • Manzanita Undergraduate Dorm • New housing needs for faculty/staff/students in coming years • Accelerate efforts to move more non-academic & administrative functions to satellite campus in Redwood City • ~$655.4 million projected in expenditures in 2014/15 (Stanford University. (2015). Budget Plan 2014/15)
- 11. Budget Process Figure 3. Budget Process at Stanford University (per 2005). https://www.google.com/url?sa=t&rct=j&q=&esrc=s&source=web&cd=4&cad=rja&uact=8&ved=0CDkQFjAD&url=http%3A%2F%2Fweb.stanford.edu%2Fdept%2Fpres- provost%2Fbudget%2Fhyperion%2FSU_Budget_Process_and_Systems_Presentation.ppt&ei=H2TNVKOCCNaQsQTZkYCwBQ&usg=AFQjCNHDpkkjq53aQ56uskyzV37lTecJJg&bvm= bv.85076809,d.eXY
- 12. Budget Process (continued) Figure 4. Annual Budget Cycle at Stanford University (per 2005). https://www.google.com/url?sa=t&rct=j&q=&esrc=s&source=web&cd=4&cad=rja&uact=8&ved=0CDkQFjAD&url=http%3A%2F%2Fweb.stanford.edu%2Fdept%2Fpres- provost%2Fbudget%2Fhyperion%2FSU_Budget_Process_and_Systems_Presentation.ppt&ei=H2TNVKOCCNaQsQTZkYCwBQ&usg=AFQjCNHDpkkjq53aQ56uskyzV37lTecJJg&bvm= bv.85076809,d.eXY
- 13. Projected Statement of Activities & GAAP • Stanford uses a fund approach to manage itself • Presents a Statement of Activities • In accordance with GAAP (generally accepted accounting principles) • Summarizes all changes in net assets during year • Four categories of funds: • Current funds • Endowment principle funds • Plant funds • Student loan funds • Convert Consolidated Budget Statement of Activities • Eliminate fund transfers • Remove capital equipment purchases • Record depreciation expense for the current year’s asset use • Adjust fringe benefit expenses • Reclassify financial aid • Adjust health care services • Adjust for internal investment management expenses • Adjust for debt service • Eliminate net internal revenue/expense • Include Stanford Sierra Camp • Eliminate hospital equity transfers (Stanford University. (2015). Budget Plan 2014/15)
- 14. Tools & Applications Used in Budget Process • iBudgets (Stanford University. (2015). Overview: About the iBudgets Module of Oracle Financials) • Oracle Hyperion Financial Reporting (Stanford University. (2015). Overview: Oracle Financials Reporting) • Peoplesoft HRMS (Central Virginia Community College. (n.d.). What is PeopleSoft HRMS?) • Microsoft Excel & Access (Stanford University. (2015). Overview: Oracle Financials Reporting)
- 15. Factors Influencing Budgets • Enrollment numbers • Student income paid • Donations • Increasing healthcare costs / salary costs • Operating costs • Utilities, maintenance • Taxes/entitlements • Increase of financial aid to students • Increasing burden of compliance • Privacy costs • Affordability • Debt capacity (Stanford University. (2015). Budget Plan 2014/15)
- 16. Social, Political, and Ethical Concerns • Obama’s free two-year college for all (Mangan, K. (2015). Obama Proposes Free Community College For Millions of Students) • Cost of tuition (Stanford University. (2015). Stanford: Facts 2014 – Administration & Finances) • Cost to give back to the community (Stanford School of Medicine. (2015). Emergency Medicine) (Stanford University. (2015). Online High School) • Faulty GAAP accounting practice (Weiler, H. N. (2010). Universities in Trouble) • Shady contractor deals
- 17. Critique & Analysis • Decentralization has positives/negatives • Dr. George S. McClellan – Indiana University • Positives/negatives (Hibel, A. (n.d.). Budgets in Higher Education) • Positives outweigh negatives
- 18. Conclusion • Stanford University is a $5.1 billion enterprise • Decentralized method • Each unit creates/manages own budget • Two main budgets: • COFB • General Funds Budget • Overseen by University Budget Office • Capital Funds Budget • Unit budgets ----> Provost’s Budget Group • Provost makes final decision about General Funds • Many factors influence budget • Social, political, and ethical concerns should be considered
- 19. References • Central Virginia Community College. (n.d.). What is PeopleSoft HRMS? Retrieved from http://www.cvcc.vccs.edu/Human%20Resources/Downloads/HRMS%20Training%20-%20Full- time%20Employees.pdf • Harker, A. (2005). Discussion of Stanford University Budget Processes & Systems [Powerpoint Slides]. Retrieved from https://www.google.com/url?sa=t&rct=j&q=&esrc=s&source=web&cd=4&cad=rja&uact=8&ved=0C DkQFjAD&url=http%3A%2F%2Fweb.stanford.edu%2Fdept%2Fpres- provost%2Fbudget%2Fhyperion%2FSU_Budget_Process_and_Systems_Presentation.ppt&ei=H2TNV KOCCNaQsQTZkYCwBQ&usg=AFQjCNHDpkkjq53aQ56uskyzV37lTecJJg&bvm=bv.85076809,d.eXY • Hibel, A. (n.d.). Budgets in Higher Education – The Keys to Successful Financial Management. Retrieved from http://www.higheredjobs.com/HigherEdCareers/interviews.cfm?ID=445 • Mangan, K. (2015). Obama Proposes Free Community College For Millions of Students. Retrieved from http://chronicle.com/article/Obama-Proposes-Free-Community/151097/ • Stanford School of Medicine. (2015). Emergency Medicine. Retrieved from http://emed.stanford.edu/donate/ • Stanford University. (2015). Budget Plan 2014/15. Retrieved from http://web.stanford.edu/dept/pres-provost/budget/plans/BudgetBookFY15.pdf • Stanford University. (n.d.). In Wikipedia. Retrieved January 30, 2015, from http://en.wikipedia.org/wiki/Stanford_University
- 20. References (continued) • Stanford University. (2015). Online High School. Retrieved from https://ohs.stanford.edu/ • Stanford University. (2015). Overview: About the iBudgets Module of Oracle Financials. Retrieved from http://web.stanford.edu/group/fms/fingate/staff/fundsmgmt/about_iBugets.html • Stanford Unversity. (2015). Overview: Oracle Financials Reporting. Retrieved from http://web.stanford.edu/group/fms/fingate/staff/finreporting/oracle.html • Stanford University. (2015). Stanford: Facts 2014 - Academics. Retrieved from http://facts.stanford.edu/academics/undergraduate-profile • Stanford University. (2015). Stanford: Facts 2014 – Administration & Finances. Retrieved from http://facts.stanford.edu/administration/finances • Stanford University. (2015). Stanford University: University Budget Office Mission. Retrieved from http://web.stanford.edu/dept/pres-provost/budget/mission/ • Stanford University. (2015). Stanford’s Mission. Retrieved from http://exploredegrees.stanford.edu/stanfordsmission/#text • Stanford University. (2015). UBO Organizational Chart. Retrieved from http://web.stanford.edu/dept/pres-provost/budget/misc/UBO%20Org%20Chart.pdf • U.S. News & World Report. (2015). Stanford University [Photograph]. Retrieved from http://colleges.usnews.rankingsandreviews.com/best-colleges/stanford-1305 • Weiler, H. N. (2010). Universities in Trouble: The Current Crisis in American Higher Education. Retrieved fromhttp://web.stanford.edu/~weiler/Texts10/HSoG_Stanford_Talk.pdf
Editor's Notes
- Introduction. This presentation will discuss higher education finance at Stanford University. The first part will discuss the different types of budgets that exist and how the budgets are developed. The middle will highlight the tools and applications used in creating and maintaining the budgets as well as some factors influencing their makeup. The final part will bring to light some social, political, and ethical concerns about budgets, as well as present a critique of the budget process.
- Stanford University was founded by Leland and Jane Lathrop Stanford in 1885. It officially opened on 10/1/1891. Tuition was free, and it remained free until 1920. It is a private school, but never has been and still is not affiliated with any church (hence it is non-denominational). At a time when many schools only accepted men, when it opened it also accepted women! It sits on over 8,000 acres in Stanford, California. It consists of 7 schools: School of Earth Sciences; Graduate School of Business; School of Humanities and Sciences; School of Engineering; School of Medicine; Graduate School of Education and the Stanford Law School. There were 1,651 undergraduate degrees awarded in 2014.
- The institutional mission of Stanford goes all the way back to when it was founded. It consists of three parts: its nature, its object, and its purposes. You can read each here.
- Here we see the hierarchical organizational structure of the Stanford University Budget Office (as of October 2011). The UBO oversees the Consolidated Operating Budget.
- The University Budget Office’s Mission consists of the following seven points: to lead the development & management of the consolidated and general funds budgets of the university; to manage the resources available for university operating expenditures; to assist staff (including training) in establishing, maintaining, and overseeing budgets; to develop and maintain different electronic systems that can support budget development and reporting; to educate, guide, and report budget and financial information to internal and/or external constituents; to create and provide the university, community and public with the annual budget plan; and to be able to perform recurring studies as well as one-time financial analyses for the university.
- The overall budget at Stanford is a merger of thousands of smaller budgets that are created and managed by the seven different schools, the departments within the schools, and the faculty and staff all over Stanford University. Stanford University does not place control on the local budgets. The limit of the local budgets is how much funding each unit has available to it. In addition, except for a few governing policies, the central administration generally does not place limits on spending. The overall budget is overseen and managed by the chief financial officer of the university, the Provost. Stanford’s fiscal year runs from September 1st through August 31st so they produce an annual budget. Allowing each department and area of the university the freedom to create and manage their own budget is what is called decentralization. Not all higher education universities have this, but Stanford prides itself on this and wants all of its departments, staff, and faculty to feel that they have freedom in creating and managing their own budgets, as long as they use their funds as their donors intend. The 2014/2015 Budget Plan consists of two main parts: 1) The Consolidated Operating Budget (which includes a General Funds budget) and 2) a Capital Funds Budget. Each of these will be explained in more detail in the upcoming slides.
- The CONSOLIDATED OPERATING BUDGET consists of the amalgamation (merger) of all of the smaller budgets that Stanford has on its campus. It is calculated by adding the revenues the school makes and then subtracting the expenses it has to pay for the entire fiscal year. The tuition rate increase for 2014/15 is expected to be ~3.5% resulting in a rate of $44,184 for undergraduates. Room and board is separate. Sponsored research continues to be the single largest revenue source to the university. Health care services income consists mainly of payments from the hospitals to the School of Medicine for faculty physician services. Gifts are just donations made to the university by donors. Investment income is income paid out to operations from the endowment and from other investment income. Salaries and benefits compensation is expected to increase in ‘14/’15 by 7.3%. Financial aid (need-based/athletic/graduate student) is anticipated to increase 3.3%. Other operating expenses include graduate stipends, operations and maintenance, utilities, capital equipment, materials and supplies, travel, library materials, subcontracts, and professional services, and are expected to grow at 2.6%.
- The GENERAL FUNDS BUDGET is part of the Consolidated Budget. These are funds that are set aside for the university to use for any purpose and support many of the core academic and support functions of the university. About half of the funds from this budget will cover inflationary adjustments for salaries, benefits, non-salary costs, and existing facility operating costs. The remaining funds will go to cover compliance with government regulations, security and necessary administrative activities. These administrative costs keep increasing, which cut into funds which could be used for academic programs. The General Funds Budget is projected to be about $1.25 billion for the 2014/15 fiscal year.
- The CAPITAL FUNDS BUDGET reflects Stanford’s mission to continually update its facilities for students, faculty, and staff. There are many projects currently underway at Stanford, and many more to come in the 2014/15 fiscal year. Investments have been set aside for such things as an energy facility, parking structures, various maintenance and housing projects, and new building projects like the Anne T. and Robert M. Bass Biology building and some others. Almost $400 million is set aside for the new satellite campus in Redwood City. In total, it is projected that Stanford will spend about $655 million towards capital funds in the 2014/15 fiscal year.
- Stanford’s overall Budget Process can be seen here, taken from a talk given in 2005 by Dr. Andrew Harker, the Director of Budget Management at Stanford University. The Board of Trustees (BoT) makes the policy decisions on the salary programs, tuition, and financial aid for the university. Then, after various groups on campus provide input on capital planning, rate projections, compensation analysis and tuition as well as financial aid analysis, they submit their findings along with the BoT’s policy decisions to the Budget Office. With all of this information, the Budget Office then creates a long range forecast. The Budget Group (these folks work with the Provost of the university) provides oversight and gives advice on the strategic priorities of the university. All the while, the individual departments/units are separately working on developing their own budgets (decentralization). All of the smaller unit budgets, along with each school’s balances sheets (which show each school’s revenues & expenses) as well as any new initiatives created, are submitted to the Budget Group and the Provost of the whole University. The Provost then makes his/her allocation decisions about distributing General Funds to the Academic and Administrative Units, decides on the amount in the University Reserves, and lastly makes decisions on any major program priorities and initiatives. All three of these components make up the whole Consolidated Budget Plan which is submitted to the Board of Trustees in June.
- Since the Fiscal Year at Stanford runs from September 1st (“9/1”) to August 31, if you start at the top left of this chart (in purple) and work clockwise around, you can see the way the annual budget cycle takes root. The current “9/1” Consolidated Budget is loaded into the financial reporting system. The past year’s financials are analyzed and the GAAP’s (generally accepted accounting principles) are tied to the funds by projected statements of activities (this will be discussed in another slide). All of the different departments and units on campus are to submit their preliminary budget letters and budget meetings begin with the Provost’s Budget Group. In the Winter, budget meetings continue, and the Board of Trustees makes its approvals (as we saw in the last slide), and projection and variance analysis occurs. The Spring is the time where the individual units/departments should be submitting their 6-month year-end projections and variance analyses (including next year’s Consolidated Budget forecast) to the Provost’s Budget Group. In addition, the Human Resource Offices should enter proposed salaries for next year. Given all of the smaller budgets, a larger budget plan should be presented to the BoT for approval. Come the Summer, all information from all academic & administrative departments gathered should be entered into a financial system for analysis. The fiscal year closes.
- The Overall Projected Consolidated Operating Budget is checked against what is called a Statement of Activities. Since Stanford is a not-for-profit school and receives numerous restricted donations, it uses what is called a fund approach to manage itself internally. The Statement of Activities that Stanford creates is in accordance with the GAAP (generally accepted accounting principles) which refer to the standard framework of financial accounting principle guidelines used in various settings. Some places may choose to not follow these guidelines, but Stanford does. All this statement is, is a summary of all the changes in net assets that Stanford has accrued during the year. Cash resources are classified into four different types of funds: current (for operating activities); endowment principle (all endowments); plant (all funds for capital projects); and student loan (funds to be lent to students). In order to convert the Consolidated Operating Budget into the Statement of Activities under GAAP, one must look at revenue and expense classifications, transfers, and adjustments. The adjustments made to the Consolidated Budget to align it with the GAAP basis Statement of Activities include: eliminating fund transfers; removing capital equipment purchases; recording depreciation expenses for the current year’s asset use; adjusting the fringe benefit expenses; reclassifying financial aid; adjusting health care services; adjusting for internal investment management services; adjusting for debt services; eliminating net internal and external revenue and expenses, including the Stanford Sierra Camp the Alumni Association runs; and eliminating the hospital equity transfers.
- Some tools that Stanford uses in the budget process include iBudgets, Hyperion Financial Planning, PeopleSoft, and Microsoft Excel & Access. Stanford was not happy with the available financial reporting software out there, so they created their own – iBudgets. It’s a web-based interface system that allows users to initiate modifications to the expenses or revenues portion of the 9/1 Consolidated Budget. One can also create a new budget using iBudget. Oracle Hyperion Financial Reporting generates highly formatted, excellent-quality GAAP-compliant financial and management reports. Peoplesoft HRMS is a Human Resources Management System that collects personal information (such as name, age, address, phone number) of personnel and students at the university. It also deals with payroll and paycheck information, where personnel can view their wage information and history, their paycheck information, check their leave balances and sick time accrued. The common Excel and Access are also used in financial budgeting processes.
- A university’s budget is made up of various elements. Enrollment numbers are a major factor, because it is one of the major sources of income. Tuition costs are tied to the number of students and costs can either increase or decrease with enrollment rates. Stanford is a private school and is heavily dependent on the donations from private corporations and the school’s alumni. Without this source of income, their budget could suffer a huge shortfall. In the 2013/14 fiscal year, Stanford raised $928.5 million from 82,300 donors. In order to retain top talent, Stanford has to pay top-tier wages to their faculty. With health care costs skyrocketing, fees paid in benefits to faculty and staff will also increase. Costs of basic utilities and maintenance also increase year to year. States and Federal taxes are one of the largest expenses to the school. This is especially the case because they own over 8,000 acres of land and have constructed many buildings on it. With a stagnant economy, more students may be applying for financial aid. The yearly tuition to go to Stanford is over $44,000. All universities are subject to federal regulations of compliance, and to maintain this practice is very expensive. The university also has to set aside a large sum of money for investing in new or existing capital projects. These projects help bring revenue to the school, obtain support from private corporations, and attract the highest quality of students and teachers. In order to manage all of these elements, Stanford uses budgets to meet demands of increasing enrollment, fund capital projects, and make sure they do not overspend. This leads to the question of how much debt can a university take on in financing all of these projects?
- President Obama just proposed free community college to all Americans. If passed, some lower-income students might choose to attend a two-year institution to complete a few lower-level general education requirements to try and save some money since the tuition is so high at Stanford. Some minority and non-affluent applicants may be discouraged attending Stanford due to the high cost of tuition. This could cause Stanford to miss out on high-quality talent. It also could alienate Stanford as a school for rich white students. One of the keys to Stanford remaining successful is if they continue to attract a high diversity of students. Stanford gives back to the community in many ways. Stanford’s Emergency Department (in the University Hospital and Lucile Packard Children’s Hospital) is a vital resource to the local community and is open 24 hours a day/7 days a week, and provides assistance to anyone, regardless of their ability to pay. This can place a huge burden on Stanford’s financial budget – especially if a disaster or pandemic strikes, and these ERs are the first to be used. In addition to post-secondary studies, Stanford provides an online high school for students in grades 7-12. Therefore, in addition to the tertiary curriculum it provides for students in its 7 schools, it must budget out additional resources for exceptionally talented high school students that are looking to get a jump-start on their college preparedness. There is also a possibility that universities may alter their financial statements in order to obtain more money or loans. The Projected Statement of Activities may not correlate with the Consolidated Budget and the university may not truly be following the GAAP. When the value of Stanford’s endowment decreased significantly in 2009, it had a substantial impact on the operating budget. The Provost expected a drop in the investment income of 16% in the 2010 budget over the previous year. Staff was laid off, capital projects were cancelled, and faculty positions were frozen. Additionally, when using funds out of the Capital Budget, perhaps the university is not being ethical when they choose a certain contractor to complete a job.
- As was stated in previous slides, Stanford uses a decentralization technique for creating its budgets. There are positives and negatives when using this technique. Dr. George S. McClellan, the Vice Chancellor of Student Affairs & Enrollment at Indiana University, says the decentralizing process can really empower department heads and other campus community members, allowing for creativity and a sense of ownership into the budgets that they help create and work with. Unfortunately, decentralization can also cause a disconnect between resources and the priorities, can cause an unhealthy competition around the budget, and it can take much longer to move through the planning process since so many people are working on so many different budgets. People may also become disappointed or upset when the budgets they work on don’t end up completely looking the way they want to when the Provost gets a hold of them in the end. I think that since Stanford is a private school, gets so many donations and does not depend on the state for money, and the local budgets are only limited by how much they get in funds, I truly believe that the decentralization technique works quite well for this university. Giving local units power to create and edit their own budgets really gives them a sense of authority and creativity, and when all of the units work together, the overall result is one that is more positive than negative.
- Stanford University is a $5.1 billion enterprise. It is important that budgets have proper financial oversight. In order to do this, Stanford relies on using a decentralized method which allows for each operating unit to create and manage their own budgets. Stanford accounts for the distribution of funds through the use of two main budget types: 1) the Consolidated Operating Funds Budget (COFB) and 2) the Capital Funds Budget. The COFB contains the General Funds Budget. The University Budget Office oversees the COFB. In order to get their budgets approved, individual units must present their annual proposals to the Provost’s Budget Group. The group audits each budget, but the Provost makes the final decision as to how much of a General Fund each unit will receive. Once approved, each unit is responsible for completing certain budgeting activities throughout the Annual Budget Cycle. These responsibilities are divided into four quarters and includes functions such as using electronic computer equipment to enter, manage, and edit their budgets. Many factors can influence Stanford’s budgets including enrollment, donations, capital investment, and operating cost. Lastly, Stanford has to understand the many social, political, and ethical concerns that can occur at a university which can shape how the budget is designed. These can include making a Stanford education affordable for the non-affluent, effects of federal legislation on enrollment rates & costs of doing business, and using acceptable GAAP practices.
- References above.
- References above.