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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

Report Number: 2019-113

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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.The University of California: Its Admissions and Financial Decisions Have Disadvantaged California Resident Students, Report 2015‑107, March 2016. 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.

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.

Nonresident Enrollment by Campus in Academic Year 2018–19

UC Berkeley: 24.5%
UC Davis: 18.1%
UC Irvine: 18.5%
UCLA: 23.3%
UC Merced: 0.5%
UC Riverside: 3.7%
UC San Diego: 21.8%
UC Santa Barbara: 16.0%
UC Santa Cruz: 10.4%

Source: University’s data on nonresident enrollment by campus.

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 admitting less qualified nonresidents. In 2017 the Regents implemented a policy to limit nonresident enrollment to 18 percent for each of the five undergraduate campuses that had not yet grown their nonresident populations to that size. Consequently, each of these campuses can continue to grow the size of their nonresident student populations up to 18 percent. In contrast, UC Berkeley, UCLA, UC San Diego, and UC Irvine had already enrolled more than 18 percent of nonresidents when the Regents imposed the cap. For these campuses, the Regents’ policy froze nonresident enrollment at their academic year 2017–18 levels. The text box shows each campuses’ nonresident enrollment proportion during academic year 2018–19.

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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, B.2, B.3,and B.4 provide the information that the Audit Committee requested.

Figure B.1
Diversity of Admitted Students by Campus, Academic Years 2017–18 Through 2019–20

A table displaying various demographic information on admitted students to UC Berkeley, UCLA, UC San Diego, and systemwide for academic years 2017-18 through 2019-20.

Source: Analysis of applications and admissions data regarding freshman applicants.

Notes: In this figure and the figures that follow we generally use the terminology contained in the Office of the President’s applications and admissions data when referring to gender, ethnicity, and other categories of student diversity.

Figure B.2
Diversity of Students Admitted Due to Inappropriate Factors, Academic Years 2013–14 Through 2019–20

A table displaying various demographic information on students admitted to the university due to inappropriate factors for academic years 2013-14 through 2019-20.

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

A table displaying the reason for ineligibility for students admitted by exception to each campus for academic years 2017-18 through 2019-20.

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.

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

A table displaying residency trends of students admitted to UC Berkeley, UCLA, UC San Diego, and systemwide, for academic years 2015-16 through 2019-20.

Source: Analysis of applications and admissions data regarding freshman applicants selected for admission.

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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

Review and evaluate the laws, rules, and regulations significant to the audit objectives.

Reviewed relevant laws, regulations, and other background materials applicable to the university and its admissions processes.


Review and evaluate the university’s systemwide admissions policies and practices, as well as the results of the university’s internal investigations.

  • Reviewed relevant university policies and evaluated whether they are adequate for ensuring fairness and preventing improper influence in admissions by comparing them against best practices and reviewing admissions practices at select campuses.
  • 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.

For at least the UC Berkeley, UCLA, and UC San Diego campuses, assess admissions policies and practices by doing the following:

  1. Assess the factors considered when deciding which applicants to admit to the selected campuses.
  2. Evaluate fraud risks associated with the admissions process including, but not limited to, potential deceptive practices related to standardized test scores, high school grades, essays, and student‑athlete admissions.
  3. Determine the extent to which donations, influence, and legacy factor into the admissions process. To the extent possible, evaluate the diversity of students admitted due to these factors.
  4. Determine the extent to which the university considers student diversity during the admissions process and report on the diversity of admitted students.
  5. Identify and assess any trends related to the admission of nonresident and resident students since academic year 2010–11.
  • Evaluated the three campuses’ policies and procedures related to reviewing and rating admissions applications and ensuring consistency and fairness in application reviews.
  • Assessed the processes that the three campuses use to select applicants for admission to ensure consistency and fairness in those decisions; determined whether those processes create opportunity for improper influence in admissions decisions, including influence related to donations and legacy. Analyzed systemwide data and reviewed email records at each of the three campuses we reviewed to identify potential improper influence in admissions decisions, including by individuals who were hired privately by families to facilitate admissions discussions with campuses. Evaluated the diversity of the applicants we identified as admitted due to improper influence.
  • Selected 10 students from each campus and determined whether the campuses verified the students’ grades and test scores. Determined that the university obtained standardized test scores directly from the ACT and College Board. Evaluated the changes that the university made to its systemwide process for identifying fraud in applications following the systemwide internal audit and determined that those changes adequately addressed gaps in the verification of the content of student application essays.
  • Analyzed systemwide data to identify the diversity, residency status, and academic qualifications of students who applied, were admitted, and were denied admission both systemwide and at the three campuses we reviewed. Assessed trends in the university’s admission of nonresident and resident students since academic year 2010–11.
  • State law prohibits the university from considering protected characteristics—such as race and gender—in admissions decisions. Key university strategies to improve diversity of students are its Eligible in the Local Context Program and its efforts to recruit and enroll disadvantage and underrepresented students. Therefore, we focused our review of the 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.

For at least the past three years, identify how many students UC Berkeley, UCLA, and UC San Diego admitted under the university’s special admissions policy, with a focus on students admitted through the identification of a special talent or achievement. For those students, do the following, to the extent possible:

  1. Determine the categories of students admitted by exception.
  2. Evaluate the policies and practices related to verifying the eligibility of applicants admitted by exception and any follow‑up performed by the campuses to determine whether students continue to participate in the sports or other activities for which they were admitted.
  3. For a selection of students, determine whether they are still participating in the sport or other activity for which they were admitted by exception.
  4. Assess whether the above data indicates any risk of fraud in the admissions process.
  • Analyzed systemwide data to determine the number of students the campuses admitted by exception.
  • Because the three campuses did not adequately record or justify the reasons for admitting applicants for exception, we could not determine the categories of applicants the campuses admitted by exception beyond those we present in Appendix B.
  • Evaluated campus policies and procedures related to admissions by exception.
  • Identified the number of recruited student athletes and students admitted due to a special talent.*
  • Assessed policies and practices relevant to the admission of prospective student athletes and applicants with special talents to determine whether the campuses have adequate practices to prevent improper outside influence, including fraud.
  • At each campus, selected 10 prospective student athletes and 10 students with special talents whom the campus admitted, and we assessed whether the campuses adequately confirmed the recruit’s talent. Determined whether the campus monitored to ensure that prospective student athletes continued to participate in the sport for at least one year.
  • Reviewed all student athletes from academic years 2013–14 through 2018–19 for six teams at each campus to determine if each student athlete participated for at least a year and possessed adequate athletic talent in the sport they purportedly played.
  • For the student athletes who both participated for less than a year and who did not possess adequate athletic talent, reviewed additional materials—including donation records and staff emails—to determine if inappropriate factors, such as donations to the campus or favors to associates, were factors that influenced admissions decisions.

Review and assess university and campus policies and practices related to interacting with other entities involved in the admission process including, but not limited to, the College Board, ACT, and private admission consultants.

Incorporated the procedures related to this objective into objectives 3 and 4b by reviewing the process that each campus uses to make admissions decisions and assessing those processes for risk.


Evaluate the sufficiency of steps taken by the university in response to admission‑related recommendations in the California State Auditor’s March 2016 audit report (Report 2015‑107) as well as other California State Auditor recommendations, if applicable.

  • Analyzed admission trends of resident and nonresident students across the university and at the three campuses.
  • Analyzed campus data on the qualifications of admitted resident and nonresident undergraduate applicants to determine if nonresidents exceeded the qualifications of residents.
  • Obtained and reviewed resident and nonresident enrollment targets for campuses from academic years 2017–18 through 2019–20.

Review and assess any other issues that are significant to the audit.

None identified.

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.

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