{"id":7243,"date":"2020-11-16T11:34:31","date_gmt":"2020-11-16T11:34:31","guid":{"rendered":"http:\/\/onlineclassesguru.com\/?p=7243"},"modified":"2020-11-16T11:34:31","modified_gmt":"2020-11-16T11:34:31","slug":"erm-implementation-2","status":"publish","type":"post","link":"https:\/\/onlineclassesguru.com\/index.php\/2020\/11\/16\/erm-implementation-2\/","title":{"rendered":"ERM Implementation"},"content":{"rendered":"<style type=\"text\/css\"><\/style><p>CHAPTER 9 Lessons from the Academy ERM Implementation in the University Setting ANNE E. LUNDQUIST Western Michigan University The tragedy at Virginia Tech, infrastructure devastation at colleges and universities in the New Orleans area in the aftermath of Hurricane Katrina, the sexual abuse scandal at Penn State, the governance crisis at the University of Virginia, American University expense-account abuse, and other highprofile university situations have created heightened awareness of the potentially destructive influence of risk and crisis for higher education administrators.1 The recent Risk Analysis Standard for Natural and Man-Made Hazards to Higher Education Institutions (American Society of Mechanical Engineers\u0096Innovative Technologies Institute 2010) notes that \u0093resilience of our country\u0092s higher education institutions has become a pressing national priority\u0094 (p. vi). Colleges and universities are facing increased scrutiny from stakeholders regarding issues such as investments and spending, privacy, conflicts of interest, information technology (IT) availability and security, fraud, research compliance, and transparency (Willson, Negoi, and Bhatnagar 2010). A statement from the review committee assembled to examine athletics controversies at Rutgers University is not unique to that situation; the committee found that \u0093the University operated with inadequate internal controls, insufficient inter-departmental and hierarchical communications, an uninformed board on some specific important issues, and limited presidential leadership\u0094 (Grasgreen 2013). The situation at Penn State may be one of the clearest signals that risk management (or lack thereof) has entered the university environment and is here to stay. In a statement regarding the report, Louis Freeh, chair of the independent investigation by his law firm, Freeh Sporkin &amp; Sullivan, LLP, into the facts and circumstances of the actions of Pennsylvania State University, said the following: In our investigation, we sought to clarify what occurred . . . and to examine the University\u0092s policies, procedures, compliance and internal controls relating to identifying and reporting sexual abuse of children. Specifically, we worked to identify any failures or gaps in the University\u0092s control environment, compliance programs and culture which may have enabled these crimes against children to occur on the Penn State campus, and go undetected and unreported for at least these past 14 years. 143 www.it-ebooks.info 144 Implementing Enterprise Risk Management The chair of Penn State\u0092s board of trustees summed it up succinctly after the release of the Freeh Report (Freeh and Sullivan 2012) regarding the university\u0092s handling of the sexual abuse scandal: \u0093We should have been risk managers in a more active way\u0094 (Stripling 2012). The variety, type, and volume of risks affecting higher education are numerous, and the public is taking notice of how those risks are managed. Accreditation agencies are increasingly requiring that institutions of higher education (IHEs) demonstrate effective integrated planning and decision making, including using information gained from comprehensive risk management as a part of the governance and management process.2 Credit rating agencies now demand evidence of comprehensive and integrated risk management plans to ensure a positive credit rating, including demonstration that the board of trustees is aware of, and involved in, risk management as a part of its decision making.3 Through its Colleges and Universities Compliance Project, the Internal Revenue Service (IRS) is considering how to hold IHEs responsible for board oversight of risk, investment decisions, and other risk management matters.4 The news media has a heightened focus on financial, governance, and ethical matters at IHEs, holding them accountable for poor decisions and thus negatively affecting IHE reputations. In response to this, many IHEs have implemented some form of enterprise risk management (ERM) program to help them identify and respond to risk. THE HIGHER EDUCATION ENVIRONMENT Colleges and universities have often perceived themselves as substantially different and separate from other for-profit and not-for-profit entities, and the outside world has historically viewed and treated them as such. Colleges and universities have been viewed as ivory towers, secluded and separated from the corporate (and thus the federal regulatory and, often, legal) world. Higher education was largely a self-created, self-perpetuating, insular, isolated, and self-regulating environment. In this culture, higher education institutions were generally governed under the traditional, independent \u0093silos of power and silence\u0094 management model, with the right hand in one administrative area or unit often unaware of the left hand\u0092s mission, objectives, programs, practices, and contributions in another area. John Nelson (2012), managing director for the Public Finance Group (Healthcare, Higher Education, Not-for-Profits) for Moody\u0092s Investors Service, observed that higher education culture is somewhat of a contradiction in that colleges and universities are often perceived as \u0093liberal,\u0094 whereas organizationally they tend to be \u0093conservative and inward-looking.\u00945 Citing recent examples at Penn State and Harvard, he noted that colleges and universities can be \u0093victims of their own success\u0094; a past positive reputation can prevent boards from asking critical questions, and senior leadership from sharing troubling information with boards, and this can perpetuate a culture that isn\u0092t self-reflective, thus increasing the likelihood for a systemic risk management or compliance failure. The Freeh Report (2012) is instructive regarding not only the Penn State situation, but the hands-off and rubber-stamp culture of university boards and senior leaders more broadly. The Freeh Report found that the Penn State board failed in its duty to make reasonable inquiry and to demand action from the president, and that the president, a senior vice president, and the general counsel did not perform their duties. www.it-ebooks.info LESSONS FROM THE ACADEMY 145 The report calls these inactions a \u0093failure of governance,\u0094 noting that the \u0093board did not have regular reporting procedures or committee structure to ensure disclosure of major risks to the University\u0094 and that \u0093Penn State\u0092s \u0091Tone at the Top\u0092 for transparency, compliance, police reporting, and child protection was completely wrong, as shown by the inaction and concealment on the part of its most senior leaders, and followed by those at the bottom of the University\u0092s pyramid of power.\u0094 In his text regarding organizational structures in higher education, How Colleges Work, Birnbaum (1988) notes that, organizationally and culturally, colleges and universities differ in many ways from other organizations. He attributes this difference to several factors: the \u0093dualistic\u0094 decision-making structure (comprised of faculty \u0093shared governance\u0094 and administrative hierarchy); the lack of metrics to measure progress and assess accountability; and the lack of clarity and agreement within the academic organization on institutional goals (based, in part, on the often competing threefold mission of most academic organizations of teaching, research, and service). Because of these organizational differences, Birnbaum notes that the \u0093processes, structures, and systems for accountability commonly used in business firms are not always sensible for [colleges and universities]\u0094 (p. 27). While noting that colleges and universities are unique organizations, Birnbaum also observes that they have begun to adopt more general business practices, concluding that \u0093institutions have become more administratively centralized because of requirements to rationalize budget formats, implement procedures that will pass judicial tests of equitable treatment, and speak with a single voice to powerful external agencies\u0094 (p. 17). This evolution to a more businesslike culture for IHEs has been evolving since the 1960s and has brought significant societal changes while seeing the federal government, as well as state governments, begin to enact specific legislation affecting colleges and universities.6 The proliferation of various laws and regulations, coupled with the rise of aggressive consumerism toward the end of the 1990s, has led to an increased risk of private legal claims against institutions of higher education\u0097 and their administrators\u0097as well as a proliferation of regulatory and compliance requirements. Higher education is now generally treated like other business enterprises by judges, juries, and creative plaintiffs\u0092 attorneys, as well as by administrative and law enforcement agencies, federal regulators\u0097and the public. Mitroff, Diamond, and Alpaslan (2006) point out that despite their core educational mission, colleges and universities are really more like cities in terms of the number and variety of services they provide and the \u0093businesses\u0094 they are in. They cite the University of Southern California (USC) as an example, noting that USC operates close to 20 different businesses, including food preparation, health care, and sporting events, and that each of these activities presents the university with different risks. Jean Chang (2012), former ERM director at Yale University, observed that IHEs are complicated businesses with millions of dollars at stake, but they don\u0092t like to think of themselves as \u0093enterprises.\u0094 Organizational Type Impacts Institutional Culture While Birnbaum (1988) notes that IHEs differ in important ways from other organizational types, especially for-profit businesses, he also concludes that colleges www.it-ebooks.info 146 Implementing Enterprise Risk Management and universities differ from each other in important ways. Birnbaum outlines five models of organizational functioning in higher education: collegial, bureaucratic, political, anarchical, and cybernetic. In Bush\u0092s (2011) text on educational leadership, he groups educational leadership theories into six categories: formal, collegial, political, subjective, ambiguity, and cultural. In their discussion of organizational structure, Bolman and Deal (2008) provide yet another method for analysis of organizational culture, identifying four distinctive \u0093frames\u0094 from which people view their world and that provide a lens for understanding organizational culture: structural, human resources, political, and symbolic. Each of these models can provide a conceptual framework by which to understand and evaluate the culture of a college or university. Understanding the organizational type of a particular institution is imperative when considering issues such as the process by which goals are determined, the nature of the decisionmaking process, and the appropriate style of leadership to accomplish goals and implement initiatives. What works in one university organizational type may not be effective in another. The leadership style of senior administration may be operating from one frame or model while the culture of the faculty may be operating from another, thus affecting policy and practice in positive or negative ways. While not true across the board, for-profit organizations tend to operate from what Bush as well as Bolman and Deal refer to as the formal or structural models and Birnbaum terms bureaucratic. The structural frame represents a belief in rationality. Some assumptions of the structural frame are that \u0093suitable forms of coordination and control ensure that diverse efforts of individuals and units mesh\u0094 and that \u0093organizations work best when rationality prevails over personal agendas\u0094 (Bolman and Deal 2008, p. 47). Understanding this cultural and framing difference is important when considering the adoption and implementation of ERM in the university environment, and can help to explain why many university administrators and faculty are skeptical of the more corporate approach often taken in ERM implementation outside of higher education. Bush observes that the collegial model has been adopted by most universities and is evidenced, in part, by the extensive committee system. Collegial institutions have an \u0093emphasis on consensus, shared power, common commitments and aspirations, and leadership that emphasizes consultation and collective responsibilities\u0094 (Birnbaum, p. 86). Collegial models assume that professionals also have a right to share in the wider decision-making process (Bush 2011, p. 73). Bush points out that collegial models assume that members of an organization agree on organizational goals, but that often various members within the institution have different ideas about the central purposes of the institution because most colleges and universities have vague, ambiguous goals. Birnbaum describes the collegium (or university environment) as having the following characteristics: The right to participate in institutional affairs, membership in a congenial and sympathetic company of scholars in which friendships, good conversation, and mutual aid flourish, and the equal worth of knowledge in various fields that precludes preferential treatment of faculty in different disciplines. (p. 87) ERM (or risk management and compliance initiatives in general) tend to be viewed as more corporate functions and to align with formal, structural, and bureaucratic aims, goal setting, planning, and decision making. The chart in Exhibit 9.1 outlines management practices and how they are viewed from the www.it-ebooks.info Exhibit 9.1 Distinctions between Structural and Collegial Elements of Management? Elements of Management Formal\/Structural Collegial\/Human Resources Bolman and Deal Bush Institutional Birnbaum Institutional Bolman and Deal Bush Birnbaum Level at which goals are determined Institutional Institutional through agreement and consensus Process by which goals are determined Vertical and lateral processes Set by leaders Based on organizational structure and roles Agreement Agreement Consensus Relationship between goals and decisions Organizations exist to achieve established goals Decisions based on goals Conscious attempt to link means to ends and resources to objectives Shared sense of direction and commitment Decisions based on goals Strong and coherent culture and value consensus informs decisions Nature of the decision process Rational; rules, policies, and standard operating procedures Rational Rational; compliance with rules and regulations Egalitarianism; teams Collegial Deliberative consensus Nature of structure Organizations increase efficiency and enhance performance through specialization and division of labor Objective reality; hierarchical Designed to accomplish large-scale tasks by systematically coordinating the work of many individuals Organizations exist to serve human needs; must be a good fit between organization and people Lateral Collegium Style of leadership Established authority Leader establishes goals and initiates policy Leader is concerned with planning, directing, organization, staffing, and evaluating Doesn\u0092t control or overly structure; sensitive to both task and process; use of teams Leader seeks to promote consensus Leader is \u0093first among equals,\u0094 consultation and collective responsibilities ?Adapted from Bush (2011), 199 (Figure 9.1). 147 www.it-ebooks.info 148 Implementing Enterprise Risk Management formal\/structural and collegial\/human resources models. As will become clear in the University of Washington ERM implementation case described in this chapter, the culture of higher education in general, and the institution-specific culture of the particular organization, cannot be ignored when adopting or implementing an ERM program, and may be the most important element when making ERM program, framework, and philosophy decisions. Risks Affecting Higher Education One way in which colleges and universities are becoming more like other organizations is the type and variety of risks affecting them. Risk and crisis in higher education may arise from a variety of sources: a failure of governance or leadership; a business or consortium relationship; an act of nature; a crisis related to student safety or welfare or that of other members of the community; a violation of federal, state, or local law; or a myriad of other factors. The University Risk Management and Insurance Association (URMIA 2007) cites several drivers that put increased pressure and risk on colleges and universities, including competition for faculty, students, and staff; increased accountability; external scrutiny from the government, the public, and governing boards; IT changes; competition in the marketplace; and increased levels of litigation. A comprehensive, yet not exhaustive, list of risks affecting higher education is outlined in Exhibit 9.2. Risks unmitigated at the unit, department, or college level can quickly lead to high-profile institutional risk when attorneys, the media, and the public get involved. Helsloot and Jong (2006) observe that higher education has a unique risk as it relates to the generation and sharing of its core task: \u0093to gather, develop, and disseminate knowledge\u0094 (p. 154), noting that the \u0093balance between the unfettered transfer of knowledge, on the one hand, and security, on the other, is a precarious one\u0094 (p. 155). EMERGENCE OF ERM IN HIGHER EDUCATION In the corporate sector, interest in the integrated and more strategic concept of enterprise risk management (ERM) has grown significantly in the past 15 years (Arena, Arnaboldi, and Azzone 2010). Certain external factors affected the adoption and implementation of ERM practices in corporations, including significant business failures in the late 1980s that occurred as a result of high-risk financing strategies (URMIA 2007). Governments in several European countries took actions and imposed regulatory requirements regarding risk management earlier than was done in the United States, issuing new codes of practice and regulations such as the Cadbury Code (1992), the Hampel Report (1998), and the Turnbull Report (1999). In 2002, the Public Company Accounting Reform and Investor Protection Act (otherwise known as Sarbanes-Oxley, or SOX) was enacted in the United States. In 2007, the Securities and Exchange Commission (SEC) issued guidance placing greater emphasis on risk assessment and began to develop requirements for enterprisewide evaluation of risk. In February 2010, the SEC imposed regulations requiring for-profit corporations to report in depth on how their organizations identify risk, set risk tolerances, and manage risk\/reward trade-offs throughout the enterprise. While widespread in the corporate sector, in large part due to regulatory compliance, ERM is fairly new in higher education. Gurevitz (2009) observes that www.it-ebooks.info LESSONS FROM THE ACADEMY 149 Exhibit 9.2 Risks Affecting Higher Education Institutional Area Types of Risk Boards of Trustees and Regents, President, Senior Administrators Accreditation Board performance assessment CEO assessment and compensation Conflict of interest Executive succession plan Fiduciary responsibilities IRS and state law requirements Risk management role and responsibility Business and Financial Affairs Articulation agreements Bonds Budgets Business ventures Cash management Capital campaign Contracting and purchasing Credit rating Debt load\/ratio Endowment Federal financial aid Fraud Gift\/naming policies Insurance Investments Loans Outsourcing Transportation and travel Recruitment and admissions model Compliance with Federal, State, and Local Laws, Statutes, Regulations, and Ordinances Americans with Disabilities Act (ADA)\/Section 504 Copyright and fair use Drug-Free Schools and Communities Act Family Educational Rights and Privacy Act (FERPA) Health Insurance Portability and Accountability Act of 1996 (HIPAA) Higher Education Opportunity Act IRS regulations Integrated Postsecondary Education Data System (IPEDS) Jeanne Clery Disclosure of Campus Security Policy and Campus Crime Statistics Act (Clery Act) National Collegiate Athletic Association (NCAA)\/National Association of Intercollegiate Athletics (NAIA) regulations Record retention and disposal Tax codes Whistle-blower policies Campus Safety and Security Emergency alert systems for natural disaster or other threat Emergency planning and procedures Incident response (continued) www.it-ebooks.info 150 Implementing Enterprise Risk Management Exhibit 9.2 (Continued) Institutional Area Types of Risk Campus Safety and Security (continued) Infectious diseases Interaction with local, state, and federal authorities Minors on campus Terrorism Theft Violence on campus Weapons on campus Weather Information Technology Business continuity Cyber liability Electronic records Information security Network integrity New technologies Privacy System capacity Web page accuracy Academic Affairs Academic freedom Competition for faculty Faculty governance issues Grade tampering Grants Human subject, animal, and clinical research Intellectual property Internship programs Joint programs\/partnerships Laboratory safety Online learning Plagiarism Quality of academic programs Student records Study abroad Tenure Student Affairs Admission\/retention Alcohol and drug use Clubs and organizations Conduct and disciplinary system Dismissal procedures Diversity issues Fraternities and sororities Hate crimes Hazing International student issues Psychological disabilities issues Sexual assault Student death Student protest Suicide www.it-ebooks.info LESSONS FROM THE ACADEMY 151 Exhibit 9.2 (Continued) Institutional Area Types of Risk Employment\/Human Resources Affirmative action Background checks Discrimination lawsuits Employment contracts Grievances Labor laws Performance evaluation Personnel matters Sexual harassment Termination procedures Unions Workplace safety Physical Plant Building and renovation Fire Infrastructure damage Off-site programs Public-private partnerships Residence hall and apartment safety Theft Other Alumni Athletics External relations Increased competition for students, faculty, and staff Increased external scrutiny from the public, government, and media Medical schools, law schools Vendors educational institutions \u0093have been slower to look at ERM as an integrated business tool, as a way to help all the stakeholders\u0097trustees, presidents, provosts, CFOs, department heads, and frontline supervisors\u0097identify early warning signs of something that could jeopardize a school\u0092s operations or reputation.\u0094 In 2000, the Higher Education Funding Council of England enacted legislation requiring all universities in England to implement risk management as a governance tool (Huber 2009). In Australia, the Tertiary Education Quality Standards Agency (TEQSA 2013) evaluates the performance of higher education providers against a set of threshold standards and makes decisions in relation to their performance in line with three regulatory principles, including understanding an institution\u0092s level of risk. In the United States, engaging in risk management efforts and programs for IHEs is not specifically required by accrediting agencies or the federal government. Perhaps because it is not required, ERM has not been a top focus for boards and senior administrators at IHEs. Tufano (2011) points out that risk management in the nonprofit realm, including higher education, is significantly less developed than in much of the corporate world and often still has a focus on avoidance of loss rather than setting strategic direction. Mitroff, Diamond, and Alpaslan\u0092s (2006) www.it-ebooks.info 152 Implementing Enterprise Risk Management survey assessing the state of crisis management in higher education revealed that colleges and universities were generally well prepared for certain crises, particularly fires, lawsuits, and crimes, in part because certain regulations impose requirements. They were also well prepared for infrequently experienced but high-profile situations such as athletics scandals, perhaps based on their recent prominence in the media. However, they were least prepared for certain types of crises that were frequently experienced such as reputation and ethics issues, as well as other nonphysical crises such as data loss and sabotage.7 A survey conducted by the Association of Governing Boards of Universities and Colleges and United Educators (2009) found that, of 600 institutions completing the survey, less than half of the respondents \u0093mostly agreed\u0094 that risk management was a priority at their institution. Sixty percent stated that their institutions did not use a comprehensive, strategic risk assessment to identify major risks to mission success. Recent highprofile examples may be beginning to change that. The Freeh Report regarding Penn State determined that \u0093the university\u0092s lack of a robust risk-management system contributed to systemic failures in identifying threats to individuals and the university and created an environment where key administrators could \u0091actively conceal\u0092 troubling allegations from the board\u0094 (Stripling 2012). ADOPTING AND IMPLEMENTING ERM IN COLLEGES AND UNIVERSITIES In 2001, PricewaterhouseCoopers and the National Association of College and University Business Officers (NACUBO) sponsored a think tank of higher education leaders to discuss the topic of ERM in higher education, likely in response to widespread discussion in the for-profit sector and in anticipation of potential regulatory implications for higher education. The group included Janice Abraham, then president and chief executive officer of United Educators Insurance, as well as senior administrators from seven universities.8 The focus of their discussion was on the definition of risk; the risk drivers in higher education; implementation of risk management programs to effectively assess, manage, and monitor risk; and how to proactively engage the campus community in a more informed dialogue regarding ERM. Their conversation produced a white paper, \u0093Developing a Strategy to Manage Enterprisewide Risk in Higher Education\u0094 (Cassidy et al. 2001). In 2007, NACUBO and the Association of Governing Boards of Universities and Colleges (AGB) published additional guidance in their white paper, \u0093Meeting the Challenges of Enterprise Risk Management in Higher Education.\u0094 The University Risk Management and Insurance Association (URMIA) also weighed in with its white paper, \u0093ERM in Higher Education\u0094 (2007). In 2013, Janice Abraham wrote a text published by AGB and United Educators, entitled Risk Management: An Accountability Guide for University and College Boards. These documents provide guidance and information to institutions considering the implementation of an ERM program and discuss the unique aspects of the higher education environment when considering ERM implementation. Several authors have discussed the transferability of the ERM model to higher education, even with the cultural and organizational differences that abound between the for-profit environment and higher education. Assignment:<br \/>\nRead Chapter 9 scenario, and address the following question,\u00a0\u201cWhat were some of the key factors in the early states of UW\u2019s\u00a0ERM adoption and implementation that led to its current success within the organization.\u201d<br \/>\nInstructions for Initial Posts:<br \/>\nAfter reading the scenario, start a new discussion thread.\u00a0Points are deducted if your submission:<\/p>\n<p>Does not adhere to the University\u2019s academic dishonesty and plagiarism policies.<br \/>\nDoes not answer the question(s) thoroughly meaning with more than 3 paragraphs<br \/>\nContains contractual phrases, as an example shouldn\u2019t\u201d \u201ccouldn\u2019t\u201d\u00a0or \u201cdidn\u2019t,\u009d or similar<br \/>\nUses vague words such as \u201cproper,\u201d \u201cappropriate,\u201d \u201cadequate,\u201d or similar to describe a process, function, or a procedure.<\/p>\n<p>As an example, \u201cproper incident response plan,\u201d \u201cappropriate IT professional,\u201d \u201cadequate security,\u201d or similar. These words are subjective because they have a different meaning to different individuals.<\/p>\n<p>requried APA format and intext citations from 2 sources including text book<br \/>\nImplementing Enterprise Risk Management<br \/>\nAuthor John Fraser; Betty Simkins; Robert Kolb; Kristina Louise Narvaez<\/p>\n<p><center><a href=\"http:\/\/onlineclassesguru.com\/orders\/ordernow\"><img decoding=\"async\" src=\"https:\/\/encrypted-tbn0.gstatic.com\/images?q=tbn:ANd9GcTyj99p60XCLyLk1htB7-1neRt8-2QdnenNlQ&usqp=CAU\"target=\"_http:\/\/onlineclassesguru.com\/orders\/ordernow\"\/><\/center><p>","protected":false},"excerpt":{"rendered":"<p>CHAPTER 9 Lessons from the Academy ERM Implementation in the University Setting ANNE E. LUNDQUIST Western Michigan University The tragedy at Virginia Tech, infrastructure devastation at colleges and universities in the New Orleans area in the aftermath of Hurricane Katrina, the sexual abuse scandal at Penn State, the governance crisis at the University of Virginia,&#8230;<\/p>\n","protected":false},"author":1,"featured_media":0,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"footnotes":""},"categories":[1],"tags":[],"class_list":["post-7243","post","type-post","status-publish","format-standard","hentry","category-uncategorized"],"yoast_head":"<!-- This site is optimized with the Yoast SEO plugin v17.0 - https:\/\/yoast.com\/wordpress\/plugins\/seo\/ -->\n<title>ERM Implementation - onlineclassesguru<\/title>\n<meta name=\"robots\" content=\"index, follow, max-snippet:-1, max-image-preview:large, max-video-preview:-1\" \/>\n<link rel=\"canonical\" href=\"https:\/\/onlineclassesguru.com\/index.php\/2020\/11\/16\/erm-implementation-2\/\" \/>\n<meta property=\"og:locale\" content=\"en_US\" \/>\n<meta property=\"og:type\" content=\"article\" \/>\n<meta property=\"og:title\" content=\"ERM Implementation - onlineclassesguru\" \/>\n<meta property=\"og:description\" content=\"CHAPTER 9 Lessons from the Academy ERM Implementation in the University Setting ANNE E. 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