Having completed a series of posts covering an historical sociological framework for PSA - Part 1, Part 2, and Part 3 - it now seems appropriate to provide a modern financial perspective in support of the model. Though prior posts have applied the PSA model to higher education (HE) finances in the American and Chinese systems, it is important to offer a more nuanced financial picture. To this end, I offer a two-part series in which HE financial data from Canada and Australia is used to demonstrate the viability and desirability of PSA. Followed by Australia, this post looks at Canada.
On February 8th of this year, Alex Usher, President of Higher Education Strategy Associates (HESA), presented what he called, “A New Way of Looking at Institutional Revenues.” A standard way of analyzing higher education institution (HEI) finances is to calculate the revenue per full-time equivalent (FTE) student. It is a simple calculation that divides various revenue sources – public funding, tuition, sales, investment, etc. – by the number of FTE students. For instance, if system-wide revenue is $100 billion and there are 2 million FTE students, then the figure is $50,000 per FTE student. Since without students there is no HE industry, we might say this represents the HEI revenue made possible by students.
Usher’s perspective suggests the same sort of calculation
but with a different and equally necessary denominator – academics (faculty,
teachers, lecturers, professors). This is worth consideration, since together these
are the only essential denominators in any education system – teacher and
student. The rest is mere means - including universities and colleges.
From its inception, this has been the perspective of PSA. It
is the obvious choice of denominator if the aim is to develop a model that
converts academics from HEI employees to independent professionals in private
solo or partnership practice – as physicians, psychiatrists, architects,
lawyers, dentists and other professionals offer their equally valued services.
This is a model where HEIs are exposed as cost-intensive, unnecessary middlemen,
as mere facilitators of the HE services academics offer students and society.
I don’t need an HEI employer in order to provide my expertise
to the public - and I am not alone. PSA maintains that all fields of study (FOS)
can be at least partially and in most cases completely converted to the professional
service model. Not only is the conversion viable, it is desirable, offering numerous
benefits across metrics such as: access, equality, quality, compensation, cost,
and stability.
As we venture into the financial basis for this claim, it is
important to note that there is considerable variation in the quantity and
quality of data for HE systems around the world. Some of the variance is
shameful, some of it understandable. Mixed data profiles mean that the
financial analysis for each country does not readily include the same kinds of information
and measures – though effort has been made to standardize. Throughout the
series distinctions in data profiles are made clear, particularly when data
speculation or cross-country analysis are offered. For each country, the
analysis is broken down into several broad categories: i) tuition; ii) student aid;
iii) HEI revenue; iv) HEI expenditure; v) and government expenditure. The
financial data in each of these categories is analyzed in several ways using an
academic denominator and an academic practice expense profile unique to each
country. The aim is to demonstrate that professional private academic practice is
desirable competition or compliment for the HEI model of universities and
colleges which we have inherited.
Canada
- Professional Private Academic Practice
To begin, we turn to my birthplace, Canada, where the
available data offers a clearer picture of universities than of colleges. The national
office, Statistics Canada, collects incomplete and inconsistent data on college
academic labour or tuition and fees. Further, even within the university system,
data on full- and part-time contract academic labour is partial and sporadic.
Consequently, analysis is restricted to universities and the use of a postulated
academic staff denominator.
Methodology
Across this series several key data points are collected,
including: tuition & fees; student aid; student enrolment; teaching staff; teacher-to-student
ratio; HEI revenue; HEI expenditure; and government expenditure. However, it is
important to offer an account of the data wrangling and wringing used to zero
in on the relevant figures as they pertain to universities.
First, the all-important FTE academic denominator of 66,687
is arrived at using data from Stats Can and the Canadian Centre for Policy
Alternatives (CCPA). The Stats Can data point is 47,007 full-time university
teaching staff, including: full, associate, and assistant professors, along
with all those below the rank of assistant professor, including lecturers,
instructors and other teaching staff.[1] Based on data culled from Stats Can
and the Canadian Association of University Teachers (CAUT), the 2018 CCPA
report, “Contract U: Contract Faculty Appointments at Canadian Universities,”
claims 59% of teaching staff are full-time.[2] Using these two data points, a
total headcount of roughly 80,000 teaching staff is extrapolated, along with a
part-time teaching staff headcount of 32,800, which is converted to an FTE of
19,680 using a 0.6 multiplier. Combining the 47,007 full-time and 19,680 FTE
part-time figures we get an FTE academic denominator of 66,687.
With a 2019-20 FTE student university enrolment of 1,162,052, this gives us an FTE teacher-to-student ratio of 1:17.5.[3] This figure includes international students who in 2019 totalled 235,422, all of whom because of visa restrictions it is assumed study full time.[4]
Second, two instances of data disaggregation were required.
The first is total tuition and fees for universities broken into domestic and
international figures (Table 1 Sources C and D). This was done using the oft
cited distribution of 35% as the percentage of fees contributed to HEI coffers
by international students. So, of the tuition and fees collected by HEIs, 65%
of it comes from domestic students.[5] The second is total student aid (Table 1
Source E) broken into a university and college distribution of 58% and 42%,
respectively.[6] This aid includes all forms: loans, grants, tax credits,
CESGs, and institutional scholarships.
Third, there needs to be a number that represents the major
expenses of operating a professional private academic practice. To arrive at
this figure, a hypothetical practice was located in downtown Toronto, Canada,
with support staff and facilities that include: i) graduate teaching or
research assistance and ii) office and face-to-face classroom spaces.
i)
$33,000/year (GTA/GRA for 15 hours/week, 44 weeks/year,
at $50CND/hour) [7]
ii)
$9,600/year (private dedicated office and media-supported
classrooms) [8]
The result is an annual practice operational
expense of $42,600.
Finally, it must be noted that some of the data used in
Tables 1 and 2 – including tuition & fees; revenue; and expenditure - is sourced
from Statistics Canada which describes its coverage as “all degree-granting
universities and colleges.” This is not ideal since every attempt has
been made to restrict analysis to universities alone. However, based on the
list of degree-granting university and college members and non-members of the
Canadian Association of University Business Officers (CAUBO), this discrepancy
is negligible for the present purposes. With only a few small sized
institutions as exceptions, the CAUBO list, from which the Stats Can data is
composed, includes all the major HEIs in Canada and so within this scope of
discrepancy, the data is considered representative of the university
circumstance.[9]
The result is two tables of calculations that use various existing financial sources as revenue for the operation of a hypothetical professional private academic practice – as envisioned by PSA. Since these calculations use an academic denominator, the revenue is referred to as income for an academic in solo practice.
*PSA amenable FOS include: Executive MBA; Regular MBA;
Business, management and public administration; Mathematics, computer and
information sciences; Education; Architecture; Law; Social and behavioural
sciences, and legal studies; Visual and performing arts, and communications
technology; and Humanities.
**All student aid (E) includes: loans, grants, tax credits,
CESGs, and institutional scholarships.
Discussion
In closing out his HESA blog post suggesting the use of an academic
denominator, Alex Usher says, “Figure 5 [shown below] probably explains a great
deal about the differences in faculty salaries across the country. Basically,
if you maximize both international student numbers and the use of sessionals,
faculty can find themselves pretty well-off.”
As Usher intimates, the rosy picture for full-time tenured
and tenure-track faculty depends on vulnerable international student revenue
streams and potentially exploitive labour practices – both of which embody dangerous
slippery slopes of an economic and ethical variety. But unlike the HEI model, PSA
can avoid these conditions.
Using an FTE teacher-to-student ratio of 17.5 and an average
(under)graduate tuition and fee of $11,420 for FOS which are readily converted
to the PSA service model, we find academics stand to earn a net of
$157,250/annum - were this money paid directly to academics who offer their
services in professional society and practice, rather than to the universities
and colleges that employ them under the HEI model (see Table 1 Source A).[13]
If the calculation is restricted to undergraduate FOS readily amenable to PSA,
then the net income for professional academics is $98,642/annum (see Table 1
Source B). The income range is a consequence of the former containing graduate FOS
with relatively high tuition such as Executive MBA ($56,326) and Regular MBA ($27,397).[14]
Excluding those with senior administrative responsibilities
and faculty of medicine and dentistry, the first of these PSA incomes is consistent
with the 2019 national average of $160,183 gross/annum for full professors.[15]
When full, associate and assistant professors are combined with lecturers the
national average gross income for full-time teaching staff at
universities is $120,492, nearly $13,000 less than the net for all
PSA academics.[16] That is, based on these calculations, the net income of
$157,250 is not an average for PSA academics, but rather the income that every
single FTE academic can earn, all 66,687 of them. It is important to further
underscore how impressive is this calculation, for as the teacher-to-student
ratio of 17.5 includes international students, the $11,420 figure with which it
is multiplied is based only on the average tuition and fee for domestic
students (Table 1 Source A). In 2019-20, international students numbered
235,422 and spent on average $29,714 for undergraduate and $33,703 for graduate
FOS.[17]
As a response to funding problems, whether in-country or
through satellite campuses in foreign countries, the increased reliance on
international student tuition leaves HE systems vulnerable. As Usher notes,
“the $4.11 billion increase in international student tuition fees since 2012-13
is slightly higher than the $4.09 billion increase in operating expenditures
over the same period. Thus, 100% of all increased spending over the past seven
years has come from international student fees.”[18]
Higher education is a pillar of society that must not risk compromise
by a model that desperately operates on revenue sources susceptible to serious
and routine disruption from global economic recessions and pandemics or changes
in government policy – to name but a few of the disruptive and corruptive
forces. For instance, there is little security in Duke, NYU, and UC-Berkeley bolstering
their bottom-lines by opening foreign branch campuses or dual-degree programmes
in China, where in 2021 the State Council government almost overnight shut down
the country’s entire private education tutoring industry – a long-established
industry that by 2016 was worth $100 billion USD.[19] As anyone with business
aspirations in China knows, all such ventures are fraught with risk, especially
foreign ventures.
Aside from economic risks to the stability of HE, consider
the risk to professional ethics of an HEI model that must admit ever greater
numbers of international students from countries such as India and China, whose
L1 is not English, who come from education systems with different standards, different
methods of teaching and evaluation, different classroom cultures, and who expect
a diploma in return for their substantial investment in tuition. In these
conditions: Can HEIs afford to turn down applicants who have the financial, if
not scholastic, means to complete a degree? What admission requirements will be
used? What evaluation standards at the programme and course levels will be used?
Can part-time faculty risk their precarious employment by failing too many international
students? How diligently will cases of gaming the system be investigated and prosecuted?
These, and other, suggestive questions deserve greater
treatment than is appropriate here. But on a personal level, I will say that after
having taught in the Canadian system for over 10 years, I am now on my fourth
year in China’s HE system at institutions where students pay full price (i.e.,
no government subsidy) and my superiors have routinely asked me to lower the
failure rate in my courses, while my employment contract stipulates that I can
fail no more than 10%. Each time I have refused to do so, knowing perfectly well
it might mean non-renewal of my contract - to mention the least of harms an employer
can inflict on someone with the precarious employment status of a work visa.
In countries where the HEI model persists in its reliance on
employment precarity and international student revenue, what effect does this
have on the quality of HE – or the professional and personal integrity of
academics and students? Or the integrity of HEIs for that matter, as the case
of my PhD alma mater evinces, having been found guilty of essentially selling degrees to unqualified overseas students in 2011.
PSA is not held hostage by international student markets and
the potential compromises they invite out of economic desperation. Thanks to
the financial liberation offered by PSA, the introduction of international
students is not be a matter of fiscal necessity, thereby allowing HE systems to
participate with integrity in the international market. Not only that, there can
be greater competition and perhaps concomitant reduction in the international tuition
prices, opening access to a wider range of socio-economic backgrounds, without
the fear of conflicts of interest that can lead to compromised institutional,
professional and personal ethics.
This is so because one of PSA’s improvements on the current
HEI model is its style of independent, anonymous crowd-source evaluation that
leaves no room for grade manipulation that favors higher GPAs and graduation
rates for top-paying (international) students. At the same time, if for the
price of domestic tuition, a professional academic can take on an international
student who has a low TOEFL or IELTS score and together they manage to achieve desirable
grades that are determined PSA-style, then all the better for both the academic
and the student – the only two essential denominators.
But let me pace myself, I should save discussion of some PSA benefits for Australia. To conclude with the Canadian data, revenue and expenditure are also revealing of the sort of financial liberation that PSA offers.
Provincial funding for universities per FTE student in 2019 is $13,234. Using the FTE ratio of 17.5, PSA academics can net $188,995 per annum. The total revenue for universities in 2019-20 is $40,162,717,000, of which 60% is spent on salary and benefits for all staff (i.e., administrators, faculty, and numerous types of support staff), which if paid to the 66,687 FTE teaching staff can net each of them $321,859 per annum. These are revenues that can easily support a private academic practice that operates under the protection and direction of a professional society of academics (PSA).
Two qualifiers are worth mentioning. First, all calculations
rely on a key academic denominator figure that is stipulated due to a lack of
data. Adjustment to this denominator will affect the practice revenue (or
practitioner income). Adjusting the 0.6 multiplier used to establish the FTE
academic denominator of 66,687 by two points either way to 0.4 and 0.8 will
result in FTE denominators of 60,127 and 73,247, and FTE teacher-to-student
ratios of 19.3 and 15.8, respectively. As an example of the effect on
practitioner income, using the Source A. “Average Domestic Undergraduate and
Graduate Tuition & Fees (PSA amenable FOS)” of $11,420, net academic income
is adjusted to $177,806 and $137,836 – compared to a net income of $157,250
based the 0.6 multiplier.
Second, all net incomes are calculated using the stipulated
practice expense of $42,600 per annum, which is chosen because it approximates
face-to-face education in HEIs. But in reality, because PSA is a professional
model, its fundamental service unit is a solo private practice for which expenses
can vary considerably based on practitioner prerogative. Professional academics
might choose more economical practice finances such as a home office, online
classes, less or no use of a GTA/GRA, or shared facility expenses through
partnership such as can be found in law, architecture, or medicine. In such
cases, the operational expenses are lowered, while net income is improved – all
without the burden of increased public or private funding of the system.
Objections
There are bound to be criticisms
rising in the readers: What about research? What about collegiality? What about
student social interaction? What about cooperation between HE and other sectors
such as Business or Government? What about big science? What about endowments?
What about collegiate sports? What about student admissions? What about
government oversight? And many more besides, since PSA is offered as a
comprehensive alternative to the HEI model.
Some of these criticisms are
addressed as this series continues in its analysis of Australian finances and
have been considered throughout this blog. For now, two rather obvious concerns
deserve attention: 1) The PSA model decimates employment for HEI administrative
and support staff; and 2) The PSA model cannot provide the scope of HE services
that HEIs do.
Where jobs are concerned, let’s
begin with a general comparison of the PSA and labour union responses to work
conditions within the HE system. First, unions only make sense where there are
antagonistic employers. Second, unions necessarily add to the cost of providing
HE, since their primary function is to negotiate continuous maximization of salary
and benefits (among other cost-raising items) for their dues-paying members. Third,
as unions represent only those dues-paying academics who have managed to get
hired by HEIs, their reach is short of academic labour that might otherwise be
available to the HE system.
By contrast, PSA has no employers,
unless you stretch the concept of employer to include the students who hire
academics or you stretch it even further to construe one’s self as an employer.
Second, PSA does not add to the cost of HE provision, it reduces the cost. Finally,
through professional licensure, PSA admits any and all qualified academics into
the HE labour force, not merely those academics who can be accommodated by the
inherent capacity limitations of the HEI model.
That said, the question of job loss
is complicated by the question of whether PSA supplants or supplements the
existing HEI model. If supplement, then as add-ons to (not hires by) an
existing university or college, professional academics cover the cost of their HE
services through the operation of a private practice. This places no additional
financial strain on the HEI, including its complement of institutional
employees. In fact, where professional academics elect to use the publicly
funded infrastructure of HEI facilities and services in the operation of their private
practice, there might well be an increase in HEI revenues and support staff that
accords with professional prerogative.
Where PSA supplants on a single institution
or system-wide scale, jobs are likely to be lost. Since PSA uses private
practice and professional society as the service model, this negates the replication
of numerous functions and so jobs across each and every university or college,
as demanded by the HEI model. These jobs include administration and certain
types of support staff. Of course, some of these jobs might be absorbed by the
range of private academic practices and the professional societies that replace
HEIs as the organizer and overseer – not the employer - of academic labour.
Unlike the HEI model, professional societies are not the antagonistic employers
of their members and render union representation moot, since a state-legislated
professional society acts as representative for all interested parties:
society, academics and students.
At the same time, as is true of
established professions such as law, medicine or accounting, PSA is capable of
wide distribution, relying on businesses and public facilities throughout the
community to meet the space and service needs of academics and students in
their mutually dependent HE relationship. As such, job loss is mitigated by those
continued needs. This is in stark contrast to the HEI model which necessitates negotiations
between HEIs and select businesses for commercial access to their campus-sequester
students. Consider how this video illustrates the possible benefits a distributive
PSA model can offer not only academics and students, but the wider business
community in which it is embedded:
This leads to the second of the criticisms that might be
launched against PSA. Though I have elsewhere detailed how PSA facilitates the
full range of non-institutional support work performed by academics in HEIs, it is worth
focusing on the institutional support work they perform as employees of
universities and colleges. At least to a certain degree, as a comprehensive substitute for the HEI
model, PSA might absorb discipline or profession-centered and institution or department-centered
work normally found at HEIs.
To be a licensed member of a professional society,
practitioners are obliged to contribute to and comply with various aspects of
the administration and development of their profession through the legislated
articles of constitution for the society. We can look to law as an example of how
some of these obligations have translation in the institutional support work of
HEIs.
The Law Society of Ontario (LSO) is the legislated
licensing body for lawyers and paralegals in the province of Ontario, Canada. Its
functions include committees responsible for providing regulation and oversight
of membership licensing requirements, investigation of and tribunal for
complaints against members, ongoing professional development programs, along
with initiatives to protect and educate the general public in legal matters. As
of 2020, the LSO has 66,550 lawyer and paralegal members – essentially the entire FTE
academic labour force for all Canadian universities.[20]
There might be further HEI work that finds translation
in professional societies, such as participation in: promotion and tenure
committees; faculty search committees; or reports related to departmental or
institutional initiatives. However, there is much that is lost in translation
here.
The LSO does bestow awards such as The Law Society
Medal or the Human Rights Award, they review applications for licensure, and
write reports on society operations related to initiatives, finances, and
tribunals. But they don’t offer promotions or tenure, nor do they search for
members. Entrance to and tenure in a profession are a matter of personal choice
and performance. Nor is there any need to participate in other HEI-directed
work such as: institutional promotion events; departmental meetings; senate and
university council meetings; student convocation and commencement ceremonies; or
institutional fund-raising events or campaigns.
Though I have repeatedly characterized HEIs as
expensive, unnecessary middlemen, the present discussion might lead one to view
professional societies as similar middlemen. They are not.
The annual expenses for the LSO totalled
$230,993,000 in 2020, which was $10.9 million less than its revenues, even
after a reduction in all membership fees for the same year.[21] By comparison,
excluding the $6.001 billion spent on instruction and research, in 2019-20
Ontario universities – not colleges - spent $3.892 billion on: external
relations; physical plant; administration and general; central computing and
communications; student services; and academic support.[22]
Further, no matter what institutional support work
one might think is transferrable from the HEI model to the PSA model, this is certain:
All such work is distributed across a much larger body of academics and is
being performed for only one or a handful of integrated professional societies
across the country. This is in contrast to the HEI model where each of the over
100 universities in Canada uses its respective small cluster of academic
employees to perform identical institutional support work – not to mention the
work required by accreditation boards that essentially license HEIs to practice
HE, as professional societies license practitioners. Because legal entities
such as The Law Society of Ontario operate on a fraction of the funds and personnel
that the university system requires, the HEI model cannot hope to compete with
PSA where macro-level regulation, oversight, and “institutional” maintenance are
concerned.
Finally, professional societies do not employ professionals, as HEI
middlemen do academics. The third post of the series on
the historical roots of PSA made it clear that professional societies are founded
by practitioners – by lawyers, doctors, accountants, etc. – and that
ironically, HEIs were founded by academic practitioners. If anything, such
societies have more in common with labour unions than university and college
employers. Whatever the institutional promotional material might say, HEIs have
some shared but also distinct and often antagonistic interests to those of
academics and students.
At the same time, it might be argued that even if PSA does eliminate or reduce the burden of some of the institutional support work required by HEIs, it introduces work not normally associated with faculty positions, like: the founding and operating of a private practice that employs support staff such as GTAs or GRAs, the scheduling of classes, budgeting, accounting, printing documents, and other practice-related tasks.
The first thing to say is that one look at the list of work performed by
HEI employed academics reveals skills and knowledge that are highly
transferable to the operation of a private professional academic practice. This
is precisely the argument made by those groups within and without HEIs that
offer advice and service to PhDs who seek careers outside of academia.
Secondly, setting aside the qualified overlap and favourable
distribution of work already identified, any work that remains as unique to
professional private practice is budgeted for in PSA, including: a GTA/GRA and other support services
such as office assistance, accounting, janitorial, and the like. It is also
important to reiterate that the composition of private practice is a
professional prerogative that affords considerable variation in the costs and
that from the financial analysis offered here, it is clear that the expense of
operating a private academic practice is more than covered by the funding already
available to the HEI model. This means that much of the “new” work introduced
by private practice can be farmed out to the appropriate service providers,
should professional prerogative dictate.
The real question is not, “Could academics in
professional society perform the work required by a private practice?” The
answer to that is, yes. Rather, the question is, “Would they prefer PSA
(professional society and self-employment) to the current model of HEI
employment?”
In partial answer, this post closes by briefly
comparing PSA’s facilitation of HE and the work of academics to two HEI
attempts at facilitation: MOOCs and adjunctification.
Unlike the MOOC tech response, PSA can improve
student access to HE without eliminating face-to-face education, which offers
important benefits not easily reproduced in online formats. This is not to say
that technology is not of use to academics and students. It is to say that it
should be elective and used to improve face-to-face education, not replace it
out of some necessity caused by financial desperation that in the first place
creates the crisis in access and in the second is avoidable under PSA, which can
accommodate as many academics as the HE system demands.
On that note, student access is only one half of
the HE equation. Academics also need access and not just for their personal
career aspirations. If the teaching, research and community service work of academics
is valued by society, then under the HEI model technological facilitators such
as MOOCs are only likely to reduce the amount and variety of such work, as universities
and colleges use them to reduce the considerable expense of employee salaries
and benefits.
It is also worth noting in this context that not
only are MOOCs a direct challenge to the academic vocation, they also
jeopardize administrative, management and support staff positions within the HE
system. To a degree that has been acknowledged, PSA also jeopardizes careers,
but no where near on the scale threatened by MOOCs – a threat to which unions
have no hope of responding.
In light of such career jeopardy, though it might
not be preferred by some, opening a private practice as a professional academic
is a viable and perhaps necessary choice. In turn, under PSA the (increased)
number of academics in private practice will require an array of support staff,
if not administrative and management services, such as human resources,
advertising, accounting, marketing and student recruitment.
Finally, as with MOOCs, the increasing use of adjunct labour reduces the full
scope of academic work being done in the system, since its quality and quantity
is metered by their working conditions, which are widely recognized as
under-compensated and under-supported.
Also like MOOCs, the use of adjuncts is a desperate cost-saving measure of the
current climate. As a viable alternative model, PSA can convert qualified
adjuncts to academics that are properly compensated and facilitated in their
contribution to the full spectrum of work they perform.
As always, I invite comment and collaboration on
the PSA model.
Sources:
[2] Contract
U (policyalternatives.ca) (pg.18)
[3] The
State of Postsecondary Education in Canada 2021 (higheredstrategy.com) (pg.14)
[5] Canada’s
growing reliance on international students (irpp.org)
[6] Canada-Student-Financial-Assistance-Program-Statistical-Review-2019-2020.pdf
(pp.14-17)
[8] Office
Space in: University Avenue, Toronto, M5H 3E5 | Instant Offices
[9] University
(Regular) Members – CAUBO
[10] Revenues
of universities and degree-granting colleges (statcan.gc.ca)
[11] Expenditures
of universities and degree-granting colleges (statcan.gc.ca)
[12] The
State of Postsecondary Education in Canada 2021 (higheredstrategy.com)
(pg.37)
[13] Tuition
fees for degree programs, 2019/2020 (statcan.gc.ca) (pp. 6-7)
[14] Tuition
fees for degree programs, 2019/2020 (statcan.gc.ca) (pp.6-7)
[17] Tuition
fees for degree programs, 2019/2020 (statcan.gc.ca) (pg.4)
[18] The
State of Postsecondary Education in Canada 2021 (higheredstrategy.com) (pg.30)
[19] Feng, S. (2021) The Evolution of Shadow Education in
China: From Emergence to Capitalism. Hungarian Educational Research Journal.
11, 2, 89–100 DOI: 10.1556/063.2020.00032 (pg.94)
[20] Home |
Law Society of Ontario (lso.ca)
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