98 5 Atlantic Ave nu e, Su it e 10 0, A l a me d a, C A 9 4 5 01 • phone: 5 10.74 8.9 0 01 • e-fax: 5 10.9 95. 147 7 • www.wscuc.org

August 3, 2017 Dr. Robin Romans Accreditation Liaison Officer University of Southern California Los Angeles, CA 90089-4019

Dear Dr. Romans:

We have been reading news reports about Dr. Carmen Puliafito and the complaints the university has received about his behavior over the past ten years. Given WSCUC requirements related to Integrity and Transparency (particularly CFR 1.7—timely and fair responses to complaints and grievances) and Organizational Structures and Decision-Making Processes (particularly CFR 3.6—leadership is characterized by integrity and accountability), I write today to seek further information regarding how USC has handled the series of events involving the former dean of the Keck School of Medicine. I understand that privacy rights may limit what can be disclosed, but I would appreciate receiving the following information at your earliest convenience, but no later than September 8, 2017:

• A chronology of the complaints received about the former dean (date of complaint, nature of complaint, and complainant---student, staff, faculty member or patient);

• The actions the university took to address the complaints; • The steps the university is now taking to investigate its policies and procedures

related to the issues raised by this series of events; • The current status of the investigation and expected date of completion.

I look forward to receiving the requested information. Please let me know if you have any questions.

Sincerely,

Barbara Gross Davis Vice President

OFFICE OF THE PROVOST Robin Romans, Ph.D.

Associate Vice Provost

University of Southern California 3551 Trousdale Parkway, Suite 102, Los Angeles, California 90089-4019 • Tel: 213 740 2101 • rromans@usc.edu

August 21, 2017 Dr. Barbara Gross Davis 985 Atlantic Avenue, Suite 100 WASC Senior College and University Commission Alameda, CA 94501 Dear Barbara, Thank you for your letter of August 3 and for following up with me over the phone. As we agreed, I cannot discuss aspects of the situation with our former medical school dean that might violate confidentiality and privacy laws, nor will I speculate about press allegations absent an actual complaint submitted to WSCUC. However, I am happy to summarize our process for dealing with student, staff, and faculty complaints. USC implemented policies to avoid workplace conflicts and prevent abuses, and to ensure employee and student wellness. This includes policies on workplace safety and conduct, harassment prevention training, and information on how students, staff, and faculty can lodge complaints. Complaint avenues include the Office of Equity and Diversity, which receives allegations of harassment, and the Office of Compliance, which offers a 24-hour help and hotline to report (confidentially and without fear of retribution, and anonymously if the complainant wishes) knowledge or belief that any law or university policy has been violated. All university officials welcome reports of problems involving ethical violations, lack of professionalism, or failure by administrators to live up to USC’s expectations. In addition, all members of each school’s academic community are asked every five years to confidentially assess the dean’s performance before reappointment of a dean is considered. In this particular case, all complaints received were addressed through university personnel procedures, including disciplinary action, monetary consequences, professional development coaching, and, more recently, initiation of termination proceedings. Suspicions about patient care were brought to the medical staff for their investigation and action, in accordance with California law. We communicated directly with our academic community to relay what we know currently. In addition, we have initiated an objective external review by a team from the firm of Gibson, Dunn & Crutcher to determine exactly what happened. Finally, we have formed a Task Force on Workplace Standards and Employee Wellness, co-led by the presidents of the Academic Senate and Staff Assembly, “…to examine our policies, procedures, and practices so that we understand what we could have done better and make improvements to do just that.”

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Page 2 – WSCUC I have attached two announcements to provide more detail on the actions described above. It is important to us that our colleagues at WSCUC know how seriously we take this situation and how we have responded. Of course, should WSCUC receive an actual complaint from someone, we will respond accordingly. Sincerely,

Robin Romans

98 5 Atlantic Ave nu e, Su it e 10 0, A l a me d a, C A 9 4 5 01 • phone: 5 10.74 8.9 0 01 • e-fax: 5 10.9 95. 147 7 • www.wscuc.org

November 13, 2017 Dr. Robin Romans Associate Vice Provost University of Southern California 3551 Trousdale Parkway, Suite 102 Los Angeles, CA 90089-4019 Dear Robin, Thank you for your letter of August 21, 2017 providing information about the steps USC has taken to address the series of events involving the former dean of the Keck School of Medicine, Dr. Carmen Puliafito. We appreciate learning about the implementation of policies and practices to avoid workplace conflicts and prevent abuses, and about the avenues and offices available to the university community for filing complaints, allegations of sexual harassment, or perceived violations of ethical and professional behaviors. The supplementary materials you attached provided additional details and helped us understand what has been communicated to the university community and the public. USC has hired an outside law firm to investigate what happened and what can be learned from this incident. In addition, USC has formed an internal Task Force on Workplace Standards and Employee Wellness to examine the university’s policies, procedures and practices, to identify what could have been done better, and to make improvements as needed. As appropriate, we would be interested in the findings from these two efforts. Thank you for providing this helpful information about how USC has responded to this issue. Sincerely,

Barbara Gross Davis, Ph.D. Vice President, WASC Senior College and University Commission

98 5 Atlantic Ave nu e, Su it e 10 0, A l a me d a, C A 9 4 5 01 • phone: 5 10.74 8.9 0 01 • e-fax: 5 10.9 95. 147 7 • www.wscuc.org

May 29, 2018 Robin Romans Associate Vice Provost University of Southern California University Park Campus Los Angeles, CA 90089-0012 Dear Robin: Thank you for forwarding the news about the resignation of President Max Nikias and for the conversation on Friday about the serious complaints against Dr. George Tyndall. I am writing to seek information regarding the relationship of USC’s handling of the accusations involving the former campus gynecologist to WSCUC requirements related to:

• Integrity and Transparency (particularly CFR 1.7--- timely and fair response to complaints and grievances and CFR 1.8--- honest and open communication with WSCUC including notification of material matters)

• Student Learning and Success (particularly CFR 2.13--- appropriate student services planned, implemented and evaluated)

• Organizational Structures and Decision-making Processes (particularly CFR 3.6--- leadership is characterized by integrity and accountability)

I would appreciate receiving, at your earliest convenience but no later than June 22, 2018, information about:

• The steps the university is taking to investigate its policies and procedures related to the issues raised by these serious complaints;

• The current status of the investigation and expected date of completion. Please let me know if you have any questions. Sincerely,

Barbara Gross Davis, Ph.D. Vice President

OFFICE OF THE PROVOST

Robin Romans, Ph.D. Associate Vice Provost

University of Southern California 3551 Trousdale Parkway, Suite 102, Los Angeles, California 90089-4019 • Tel: 213 740 2101 • rromans@usc.edu

234148-1

June 20, 2018 Dr. Barbara Gross Davis 985 Atlantic Avenue, Suite 100 WASC Senior College and University Commission Alameda, CA 94501 Dear Barbara, Thank you for your letter of May 29 and for following up with me over the phone. The circumstances surrounding former USC gynecologist Dr. George Tyndall are distressing to us all. Nothing is more important to us than the safety and wellbeing of our students. We are resolved, first and foremost, to supporting former patients and second, to determining how we can best move forward as a community. The University’s approach to this crisis is proceeding along three tracks. First, we have contacted former patients of the physician to learn directly about their experiences at the health center. In addition, to ensure we reach those affected and others who may have additional information, we have posted a notice to our website. It provides information and resources, including links for reporting concerns about the former doctor’s behavior. It also includes a dedicated number to call where concerns can be shared (anonymously, whenever requested). Second, we are cooperating with all investigations by local law enforcement, professional medical boards, and public entities, including the US Department of Education’s recently announced Title IX investigation by the Office of Civil Rights (OCR). Furthermore, Rick Caruso, newly elected Chair of the USC Board of Trustees, announced that the Board has retained O’Melveny & Myers LLP to conduct an independent investigation into the matter at the student health center. Mr. Caruso’s announcement is available here. The Board promises that the investigation will be independent, comprehensive, expeditious, and transparent. The investigation is now underway. The goal is to complete it by the time our students return in mid-August. Third, we are reviewing our systems and redesigning them to ensure no such breach occurs ever again. An action plan has been announced and is available here. The plan has been in development over the course of several months. As the process of implementation begins, feedback from academic and administrative units will be incorporated and the plan will likely evolve. As all of this continues, the University will also undergo a transition in

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Page 2 – WASC, Senior College & University Commission leadership; our current president has announced that he is stepping down. As a matter of keeping our colleagues at WSCUC informed about important happenings at USC, I will update you as that process continues and a search committee is named. In addition to the links provided above, I have attached the announcement by the chair of the USC Board of Trustees and the action plan. It is important to us that WSCUC knows how seriously the University community takes this situation and how we have responded. We also understand that WSCUC may receive complaints from individuals affected by this crisis. Should that occur, we stand ready to respond in any way needed. Sincerely,

Robin Romans Accreditation Liaison Officer (ALO)

98 5 Atlantic Ave nu e, Su it e 10 0, A l a me d a, C A 9 4 5 01 • phone: 5 10.74 8.9 0 01 • e-fax: 5 10.9 95. 147 7 • www.wscuc.org

July 31, 2018 Dr. Robin Romans Associate Vice Provost University of Southern California 3551 Trousdale Parkway, Suite 102 Los Angeles, CA 90089-4019 Dear Robin, Thank you for your letter of June 20, 2018 providing information about the steps USC has taken to address the deeply disturbing behavior of former USC gynecologist Dr. George Tyndall. We appreciate learning about USC’s efforts to contact and support former patients of the physician and others who have concerns about Dr. Tyndall. We also appreciate receiving a copy of USC’s action plan that revisits the university’s core values, restructures university operations, revises university’s policies and practices, and ensures accountability to prevent future egregious behaviors by those responsible for the safety and wellbeing of students. The supplementary materials you attached provided additional details and helped us understand what has been communicated to the university community and the public. We understand that USC is cooperating with a number of entities investigating this matter including local law enforcement, professional medical boards, and the Office of Civil Rights. USC has also hired an outside law firm to investigate what happened and what can be learned from this incident. Please provide by October 1, 2018 the findings of the independent investigation conducted by O’Melveny & Myers, LLP. USC has endured two serious scandals in a short period of time and will be undergoing a transition in presidential leadership. We recognize the challenges facing the university and the work that is needed to renew and restore confidence in the operations of the university. USC is scheduled for its next reaffirmation of accreditation in spring 2021 (Thematic Pathway for Reaffirmation). At that time, the review team and the Commission will look carefully at the steps USC has taken to change the conditions that led to these scandals. Please let me know if you have any questions. Sincerely,

Barbara Gross Davis, Ph.D. Cc: Jamienne S. Studley, President

OFFICE OF THE PROVOST

Robin Romans, Ph.D. Associate Vice Provost

University of Southern California 3551 Trousdale Parkway, Suite 102, Los Angeles, California 90089-4019 • Tel: 213 740 2101 • rromans@usc.edu

234148-1

October 1, 2018 Dr. Barbara Gross Davis 985 Atlantic Avenue, Suite 100 WASC Senior College and University Commission Alameda, CA 94501 Dear Barbara, Thank you for your letter of July 31 requesting an update on “the findings of the independent investigation conducted by O’Melveny & Myers, LLP.” Though that investigation has not been completed, there is much to report about relevant changes at USC. In order to communicate directly with our students, staff, faculty, and other members of our extended Trojan Family, we have launched our Commitment to Change website, on which much of what is described below also appears. Below are several important updates related to the ongoing investigations, changes at USC Student Health, and improvements in the area of complaint reporting. First, the O’Melveny & Meyers, LLP investigation is ongoing. As of mid-August, the O’Melveny team reported to the Chair of the USC Board of Trustees that they have made considerable progress interviewing witnesses and reviewing documents but more needs to be done. The USC Board has authorized the O’Melveny team to continue their work. In addition, the University continues to cooperate with local law enforcement and with the Office of Civil Rights (OCR) investigation by the US Department of Education. Provost Michael Quick just announced to the USC academic community that the OCR will visit USC on Wednesday, October 10. The OCR will hold a community meeting and schedule individual meetings with those who request one. The Provost’s announcement of the OCR visit is attached. I will continue to keep WSCUC updated on this and other news. Second, the University has made several changes to ensure the safety and wellbeing of our students throughout USC Student Health. In August 2017, USC brought its student health systems under our academic medical center, Keck Medicine of USC, in order to further professionalize our care and bring the resources of our academic medical center to provide the best services possible to our students. As students returned to campus, we announced the addition of three new female physicians to the USC Student Health medical team and the addition of ten new counseling positions to meet our students’ counseling and mental health needs.

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Page 2 – WASC, Senior College & University Commission Finally, the University announced the creation of the new Office of Professionalism and Ethics (OPE) to improve the area of complaint reporting. This new office is dedicated to handling complaints and sensitive investigations at all levels on both of USC’s campuses. The Office of Professionalism and Ethics will provide regular updates to the chair of the Audit and Compliance Committee of the USC Board of Trustees, as well as the President of the university. This will ensure that serious complaints reach the trustees and the university’s senior leadership in a timely manner. As I relayed to WSCUC on September 9, the search for a new president is well underway. Further updates are available on our Presidential Search website. As a matter of keeping our colleagues at WSCUC informed about important happenings at USC, I will continue to update you as that process moves forward. As is always the case, it is important to us that WSCUC knows how seriously the University takes this situation and how we are moving forward as a community. We also understand that WSCUC may receive separate complaints from individuals affected by recent events. Should that occur, we stand ready to respond in any way needed. Sincerely,

Robin Romans Accreditation Liaison Officer (ALO)

98 5 Atlantic Avenue, Su it e 10 0, A l a me d a, C A 9 4 5 01 • phone: 5 10.74 8.9 0 01 • e-fax: 5 10.9 95. 147 7 • www.wascsenior.org

March 19, 2019 Dr. Robin Romans Accreditation Liaison Officer University of Southern California Los Angeles 90089-4019 California Dear Dr. Romans: We have been reading news reports about the federal investigation into admissions at several universities accredited by the WASC Senior College and University Commission. Given WSCUC requirements related to Integrity and Transparency (particularly CFR 1.6 --- the institution treats students fairly and equitably through established policies and procedures; CFR 1.7—the institution exhibits integrity and transparency) and Organizational Structures and Decision-Making Processes (particularly CFR 3.6—leadership is characterized by integrity and accountability), I write today to seek further information regarding how USC is handling fraudulent admissions applications and federal charges against athletic personnel accused of accepting bribes. I understand that privacy rights may limit what can be disclosed and that events continue to unfold, but I would appreciate receiving the following information:

• The actions the university has taken to address the federal indictments; • The steps the university is now taking to investigate its policies and procedures as a

result of charges of bribery and fraud; • The current status of the investigation and expected date of completion.

In addition, I would appreciate an update on each of the following:

• The status of the internal and external investigations of the former dean of the Keck School of Medicine and changes in policies and procedures that have taken place at USC as a result;

• The status of the internal and external investigations of the former gynecologist and

changes in policies and procedures that have taken place at USC as a result. USC has faced a number of deeply troubling events in a relatively short period of time, and the WSCUC Governing Board Policy expects boards to exercise appropriate authority over institutional integrity, policies, and operations. Could you please provide the following information about the USC Board of Trustees:

• Names and affiliations of the board members, with each member’s start and end date of service on the board;

• Names of board members with expertise in higher education; • Names of board members with expertise in risk management; • List of board subcommittees, their charges, and members of each;

98 5 Atlantic Avenue, Su it e 10 0, A l a me d a, C A 9 4 5 01 • phone: 5 10.74 8.9 0 01 • e-fax: 5 10.9 95. 147 7 • www.wascsenior.org

• Frequency of board and subcommittee meetings; • Percentage of members who attended full board and subcommittee meetings in the

last two years; • Procedures for the selection, nomination, and removal of board members; • Description of the role of the board in the changes in policies and procedures that

have taken place at USC as a result of the events surrounding the former dean of the Keck School of Medicine, the former gynecologist, and the federal investigation into admissions;

• Efforts of the board to change the conditions at USC that have led to wrongdoing and to renew and restore confidence in the operations of the university.

I look forward to receiving the requested information as soon as possible, but no later than May 6, 2019. Please let me know if you have any questions. Sincerely,

Barbara Gross Davis, Ph.D. Vice President

OFFICE OF THE PROVOST

Robin Romans, Ph.D. Associate Vice Provost

University of Southern California 3551 Trousdale Parkway, Suite 102, Los Angeles, California 90089-4019 • Tel: 213 740 2101 • rromans@usc.edu

May 6, 2019 Dr. Barbara Gross Davis 985 Atlantic Avenue, Suite 100 WASC Senior College and University Commission Alameda, CA 94501 Dear Barbara, Thank you for your letter of March 19, 2019, requesting further information and updates covering three broad areas: First, “how USC is handling fraudulent admissions applications and federal charges against athletic personnel accused of accepting bribes.” Second, updates on the investigations into the former medical school dean and former student health gynecologist and a description of “the changes in policies and procedures that have taken place at USC as a result.” Third, information about the membership and structure of the USC Board of Trustees. Admissions USC took immediate actions upon the March 12, 2019 announcement of federal charges. We are taking all necessary steps to safeguard the integrity of our admissions process and to ensure we conduct ourselves in a manner consistent with our values. Our actions to date are outlined below.

• Cooperation. We have been actively cooperating with the United States Department of Justice. The Department of Justice continues to emphasize that USC is a victim in its investigation.

• Employment Actions. We immediately terminated the two employees associated with the allegations.  We also placed on leave one faculty member who was named as a parent in the federal charging documents.  The leave is a required procedural step for evaluating termination of tenured faculty.  To the extent we discover additional facts, we will take appropriate employment action in light of those facts.

• Internal Investigation. We are conducting an internal investigation, led by USC’s Office of Professionalism and Ethics, into potential wrongdoing related generally to the facts alleged in the federal charging documents. At the current moment, we do not have a date by which we expect that investigation to be complete.

• Policies and Procedures. USC has greatly strengthened its process for reviewing applications of prospective student-athletes, effective April 2019. The improved processes provide multiple levels of oversight and ensure that our Admissions staff receives accurate information about these prospective students. Every student-athlete candidate’s file will be reviewed on three levels – by the head coach, the senior

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sports administrator overseeing the team, and the USC Office of Athletics Compliance – before being sent to the Admissions staff. The head coach will certify in writing that the student is being recruited for athletic abilities. Athletic rosters will be audited at the beginning and end of every academic year and cross-checked with admissions lists. This enhanced process is currently in force for any student-athlete considered for admission during the 2019-20 academic year.

• Student Reviews. USC determined which applicants in the current admissions cycle may be connected to the conduct alleged by the government. Those applicants have been denied admission. A case-by-case review is also underway of current students for whom the university has information to believe that their admission warranted a thorough review. We will make informed decisions, based on the particular facts of each case, as the reviews are completed.  USC has placed holds on the records of those students under review. This prevents the students from registering for classes (until they have agreed to participate in the review of their case), withdrawing from the university, or acquiring transcripts while their cases are under review. Among many factors investigators could consider in reviewing each case are any developments in the criminal cases, including plea deals by parents. Following these case-by-case reviews, we will take the proper action related to each student’s status, up to revoking admission or expulsion.

Updates on the status of the internal and external investigations of the former Medical School Dean and Student Health Center Gynecologist, and changes in policies and procedures that have taken place as a result. The University initiated an objective external review into the circumstances surrounding the medical school dean, conducted by Gibson, Dunn & Crutcher LLP. Their privileged review is complete. Regarding the conduct of the Engemann Student Health Center gynecologist, the investigation by a Special Committee of the Board of Trustees is continuing. O’Melveny & Myers LLP is working with the Special Committee. It is a privileged investigation. As you know from my October 1, 2018 letter, the Department of Education’s Office of Civil Rights visited USC on October 10. They held a community meeting and individual meetings for anyone who requested it. It is our understanding that the OCR investigation remains ongoing, as does, to our understanding, an investigation by the Los Angeles Police Department. We continue to cooperate fully with each of these investigations. While continuing our cooperation with ongoing investigations, we made several important changes in response to these allegations. As reported in my October 1, 2018 letter, between the summer of 2017 and the fall of 2018, USC brought our student health systems under the auspices of Keck Medicine of USC, added three new female physicians and ten new counseling positions to the USC Student Health Center, and established the new Office for Professionalism and Ethics to serve as a single, centralized resource for all complaint monitoring and investigations. The Vice President of Professionalism and Ethics has a direct line of access to the President of the university and to the chair of the Audit and Compliance Committee of the Board of Trustees. This structure gives the Office of Professionalism and

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Ethics independence, promotes transparency, and ensures that any complaint or report registered by a member of the university community will be investigated, tracked, and adjudicated fairly and as quickly as possible. We have made more changes since our October 1, 2018 letter. In November 2018, Interim President Wanda M. Austin launched the President’s Culture Commission to oversee efforts to improve campus culture. The USC Office of the Ombuds was formed in January 2019. The office will provide a safe place for faculty, students and staff to navigate policies, issues, concerns and conflicts without fear of reprisal or judgement. Following national searches, the University has added two new ombudsmen and a new Vice President for Ethics and Compliance. USC launched our Commitment to Change website in order to communicate directly to our students, staff, faculty, alumni, and other members of the extended Trojan Family about these many changes. Updates can be viewed here: https://change.usc.edu/category/updates/. Board of Trustees In response to your requests for information regarding USC’s Board of Trustees, I have attached a list of voting trustees and their election dates (please note that trustees are elected to five-year terms with a mandatory retirement age of 80). In addition, I can share the following:

• A number of trustees currently serve or previously served on boards and committees in the higher education space, including Robert Bradway, Ramona L. Cappello, Alan Casden, Ronnie Chan, Frank Cruz, Suzanne Dworak-Peck, Daniel Epstein, Stanley Gold, Ming Hsieh, Ken Klein, Jaime Lee, Kathy Leventhal, Bill McMorrow, John Mork, Oscar Munoz, Rod Nakamoto, J. Kris Popovich, Leonard Schaeffer, Mark Stevens, and Ronald Sugar.

• Many trustees have experience with risk management in various settings. We would be pleased to add further information to the extent WSCUC would like more information about specific areas within risk management.

• Please see the attached list of the 11 standing committees of the Board of Trustees and their respective powers and duties.

• The Board holds its annual meeting on or about the first Wednesday of June. The Board holds regular meetings on or about the first Wednesday of February, October, and December, and either March or April. Special meetings of the Board may be called at any time by the chairperson of the Board or by any five trustees or by the president of the university. Each standing committee meets at its discretion and may establish regular meeting dates. The Executive Committee holds regular meetings on or about the first Wednesday of January, March, May, September, and November. The attached list includes an asterisk by the names of current voting members of the Executive Committee.

• The Board Personnel Committee makes nominations for trustees and submits nominations to the Executive Committee. Once the Executive Committee approves a

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specific nominee, the president may invite that individual to serve as a trustee, subject to approval by the Board by unanimous written consent or by election at a meeting of the Board.

• Beginning in March 2018, the trustees reviewed an action plan developed in response to recommendations following an investigation of actions by the former Dean of the Keck School of Medicine of USC. This action plan was formalized and presented to the USC community on May 22, 2018. The plan document and corresponding information is available online at https://actionplan.usc.edu/. The action plan contains a comprehensive set of recommendations including establishing:

• The President’s Campus Culture Commission • The Campus Culture and Wellness Council • An Office of Professionalism and Ethics • New Human Resources leadership positions • The USC office of Ombuds Services • New Communications leadership positions

The university continues to modify and incorporate new priorities into the action plan. Updates about these ongoing changes can be seen on the university’s Commitment to Change website at https://change.usc.edu/. Thank you, again, for your thoughtful review of these materials. Please feel free to follow up with me if you have additional questions. Sincerely,

Robin Romans Accreditation Liaison Officer (ALO)