Philadelphia law firm Pepper Hamilton LLP found “fundamental failure” in Baylor’s Title IX implementation and a football program operating “above the rules,” regents reported in a findings of fact document released May 26. Baylor also released 105 recommendations for improvement from Pepper Hamilton, which have been accepted as mandates.

“We provided SACSCOC with documentation of our procedures, processes and improvements across a wide range of areas,” Garland said. “We also noted that almost all of the shortcomings identified by Pepper Hamilton occurred around past practices, the vast majority of which had already been addressed or would be addressed imminently through the implementation of the recommendations.”

SACSCOC has accredited Baylor since 1914, according to the university’s “institutional effectiveness” website. It is one of six regional accrediting agencies that monitors higher education institutions in 11 states.

Baylor provides evidence of compliance every 10 years, according to its website. A scheduled reaffirmation in the accreditation process had been set for December of next year, but it could be delayed one year as Baylor practices further compliance.