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Ethics Board Docket No. 2021-889 <br /> Page 5 of 13 <br /> However, he continued to perform the same business development duties that had been <br /> previously approved and compensated under the 2016 arrangement with President Alexander. <br /> (d) Following his promotion,the University's Human Resources department continued <br /> processing and disbursing the supplemental compensation payments without interruption, under <br /> the previously approved compensation structure. These payments were processed through <br /> LSUHSC-NO's formal payroll system, were properly recorded in university financial records, <br /> were transparent, were subject to taxation, and were visible to internal audit personnel. <br /> (e) He did not personally initiate, request, or approve the continuation of supplemental <br /> payments after his promotion. Rather, the University's administrative mechanisms and Human <br /> Resources department executed these payments as they had prior to his promotion, maintaining <br /> continuity with the previously approved compensation structure. <br /> (� He reasonably and in good faith relied upon the advice and guidance of Louis Colletta, <br /> who served as Chief of Staff to the LSU System and held a senior administrative position within <br /> the University. Mr. Colletta specifically advised him, Dr. Hollier, and Human Resources <br /> personnel that no new presidential approval was required for the continuation of the <br /> supplemental compensation following his promotion. <br /> (g) Mr. Colletta's interpretation of LSU Permanent Memorandum 3 (PM-3) was that the <br /> policy operated prospectively rather than retrospectively. This interpretation was subsequently <br /> documented in the 2021 LSU Internal Audit of LSUHSC-NO, which quoted Mr. Colletta's <br /> advice as follows: "Colletta instructed the Chancellor's Administrative Officer to move forward <br /> with the request and provided an opinion to Higginson that the policy was prospective, not <br /> retrospective; therefore, President approval was unnecessary." <br />