higher education. Conflict with religious institutions Some scholars have criticized the AAUP's "antipathy toward religious colleges and universities." And the AAUP has censured numerous religious institutions, including Brigham Young University and The Catholic University of America. Others have criticized the AAUP's current stance regarding academic freedom in religious institutions as contradicting its 1940 statement on academic freedom, which permits religious institutions to place limits on academic freedom if those limitations are clearly stated. In 1970, the AAUP criticized its 1940 statement, positing that most religious institutions "no longer need or desire" to place limits on academic freedom. In 1988, the AAUP offered up another interpretation, stating that the "1970 de-endorsement clause" requires a religious institution to forfeit its "right to represent itself as an 'authentic seat of higher learning.'" But the AAUP's Committee A did not endorse it, thus the issue on whether a religious institution can place limits on academic freedom if those limitations are clearly stated appears to be unresolved. Contingent faculty In recent decades, the AAUP has added a focus on addressing the dramatic increase in faculty positions off the tenure track. An increasing percentage of faculty has become "contingent," or non-tenure track. Many are hired into part-time positions, often multiple part-time positions which together equal a full-time load or more, but with dramatically lower pay, little job security, and few or no fringe benefits. As of 2005, 48 percent of all faculty served in part-time appointments, and non-tenure-track positions of all types accounted for 68 percent of all faculty appointments in American higher education. The AAUP has released a number of reports on contingent faculty: in 2008, a report on accreditors' guidelines pertaining to part-time faculty and a report of an investigation involving alleged violations of the academic freedom and due process rights of a full-time contingent faculty member; and in 2006, an index providing data on the number of contingent faculty at various colleges. Also in 2006, the AAUP adopted a new policy dealing with the job protections that should be afforded to part-time faculty members. In 2003, it released its major policy statement Contingent Appointments and the Academic Profession. The statement makes new recommendations in two areas: increasing the proportion of faculty appointments that are on the tenure line as well as improving job security and due process protections for those with contingent appointments. Collective bargaining In 2009, AAUP began its reorganization the formal