In addition to the 37 football players, Bensel-Meyers also analyzed the academic transcripts of two athletes in other sports.

Peters was unavailable for comment. Bensel-Meyers said that after the New York Times reported on her review Thursday, she received a letter from Peters saying that upper-level administrators at Tennessee had reviewed her material and found no wrongdoing. ESPN.com also acquired the report.

"We independently concluded that the material you submitted did not constitute a violation of a standard of conduct or NCAA regulation," Peters wrote in the letter.

In November, the university had cleared itself of any NCAA violations in its tutoring program after an ESPN.com report had cited a series of internal memos in which administrators had raised concerns about tutors writing and co-writing papers for players. The university also said there was no attempted cover-up by mid-level administrators, who had failed to make the school's NCAA rules compliance officer aware of the allegations in the memos.

The NCAA later reviewed the school's findings but declined to initiate a full-scale investigation. Bensel-Meyers said the NCAA was only concerned about specific individual cases of improper tutorial help, not what she contends is "systemic corruption of academic practices" at Tennessee.

"Because the NCAA has a vested interest in keeping profitable collegiate teams viable, using the NCAA to oversee academics within the (men's) athletic department makes as much sense as letting the fox protect the chicken farm," she said.

Besides Peters, Bensel-Meyers sent her report to Burton English, an agriculture economics professor and chairman of the faculty athletics committee that recently recommended changes in the tutoring system in the athletic department to prevent plagiarism. Among the changes were barring tutors from typing papers for athletes, better training for tutors and greater supervision over the tutoring program by faculty members.

English was unavailable for comment to ESPN.com, but told a Tennessee reporter he is aware of Bensel-Meyers' concerns and that "she has some really good issues that need to be addressed." English was present at a meeting Monday of the faculty senate executive committee, of which Bensel-Meyers is a member, when her report and the separate faculty athletic committee report were discussed.

The full faculty senate will consider the committee's recommendations, as well as Bensel-Meyers' report, on May 1. In his letter to Bensel-Meyers denying any wrongdoing, Peters encouraged her to submit any other materials that "would lead us to some other conclusion" and was confident that her "points will be debated in the weeks to come."

Despite the university's denials, Bensel-Meyers insists there are deep problems in Tennessee's academic practices with athletes.

She wrote in her report, "The records trace the fracturing of a student's hopes and dreams: how an ambitious though academically-disadvantaged student who buys into the myth of the athletic scholarship as a way to better himself fares when confronted with the economic self-interest of the institution."