The NCAA said Thursday that Penn State "now needs to respond" to possible violations of the association's principle of institutional control with the release of the Freeh Report.

The assertion was made in an NCAA statement Thursday morning, distributed within minutes after the release of the Freeh Report which concluded that the top administrators at Penn State had "total disregard" for Jerry Sandusky’s victims.

The NCAA statement indicates that the association could be ready to proceed with a formal investigation, although that wasn’t stated outright. An NCAA spokesman told CBSSports.com that NCAA action could include, "something other than a formal enforcement investigation."

That could include merely public censure, the spokesman said. We do know that the NCAA does now have a traditional way to investigate Penn State, although it would not be linked directly to Sandusky. This fine blog by CBSSports.com's Bruce Feldman details how it could happen. As Feldman further pointed out Thursday, the NCAA sets precedent frequently in its investigations and penalties. 

"Suffice to say that if there is information that points to an impropriety as it relates to the administration of the athletics program, that's valid [for the NCAA to investigate Penn State]," said association spokesman Bob Williams.

"What people are kind of missing here, this is extraordinary in a bad way," an NCAA source said. "The Division I rulebook could never anticipate this ... Our rulebook is very specific in the way institiuions administer athletic programs … This is something different." 

In Thursday's statement, the NCAA said Penn State needs to respond to four key questions contained in the November letter written by NCAA president Mark Emmert to acting president Rodney Erickson. The questions regard compliance, institution control and ethics.

Here is a summary of those questions:

1. How has Penn State and/or its employees complied with the NCAA articles of the constitution that are cited in the letter?

2. How has Penn State exercised institutional control over the issues identified in and related to the (original) grand jury report?

3. Have each of the alleged persons to have been involved … behaved consistent with principles and requirements governing ethical conduct and honestly?

4. What policies and procedures does Penn State have in place to monitor, prevent and detect the issues identified in (the grand jury report)?

For the first time since Emmert's letter was written, the NCAA has reacted to its contents in view of the Sandusky case. In it, Emmert warned that Penn State could be found to have lacked institutional control. He cites Article 2.1 in the NCAA Manual: "It is the responsibility of each member institution to control its intercollegiate athletics program in compliance with the rules and regulations … the institution's president or chancellor is responsible for the administration of all aspects of the athletics program …"

Emmert also cites bylaws regarding ethical conduct and the head coach promoting "an atmosphere for compliance."

Former Penn State president Graham Spanier was fired in the wake of the Sandusky scandal. Former AD Tim Curley and former vice president Gary Schultz are accused of lying to a grand jury.

There was "an active agreement to conceal" according to Louis Freeh, whose organization wrote the report. In the Freeh report is a list of 120 recommendations to Penn State.

"It is critical that Penn State ... never forget these failures," said Freeh during a Thursday morning press conference regarding the report.