Report 2012-032 Recommendation 7 Responses

Report 2012-032: California's Postsecondary Educational Institutions: Some Institutions Have Not Fully Complied With Federal Crime Reporting Requirements (Release Date: October 2012)

Recommendation #7 To: Academy of Art University

To ensure that they comply with the Clery Act by correctly reporting all applicable crimes and disclosing all required campus security policies, institutions should thoroughly review the Clery Act crime statistics and security policy disclosures in their annual security reports for accuracy before publication.

6-Month Agency Response

The following procedures are now in place to ensure that any new disclosures required by the U.S. Department of Education are reflected in the Academy of Art University Annual Security Report.

1. The Executive Vice President of Financial Aid and Compliance will review any new disclosure requirement by the Department of Education. This information will be obtained by attendance at Clery conferences, annual attendance at the National Association of Financial Aid Administrators conference, updates on the Department of Education Federal Student Aid website and updates contained in the Department of Education Federal Student Aid Handbook.

2. At the request of the Executive Vice President of Financial Aid and Compliance, a meeting will take place with the Executive Vice President of Financial Aid and Compliance, Director of Campus Safety and the Communication Center Dispatcher to review the new requirements. The location of the requirements in the Annual Security Report will also be determined at this meeting.

3. A draft Annual Security Report will be generated containing the new requirements for a final review by the Executive Vice President of Financial Aid and Compliance.

4. The final Annual Security Report will contain the new disclosure requirements on or before the Department of Education effective date.

The school is already aware of new requirements signed into law on March 7, 2013. The Violence Against Women Reauthorization Act of 2013 goes into effect in 2014. This update is currently in step #1 above.

California State Auditor's Assessment of 6-Month Status: Fully Implemented

60-Day Agency Response

According to the Academy, the annual security report will be updated each year. To ensure that the report includes only Clery reportable crimes, the report will be reviewed for accuracy by the Academy's Clery officer and director of security. These reviews will occur throughout the year as well as at year end before the report is released for publication. Also, as mentioned under recommendation 1.1.a, Academy staff will stay current on new disclosure requirements by attending Clery conferences and monitoring Clery updates. However, although the Academy indicated that it will be taking steps to stay informed of the disclosures required by Education, it did not mention the steps it would take to ensure that any changes to its campus security procedures related to those disclosures are reflected in its annual security report. (See 2013-406, p. 104)

California State Auditor's Assessment of 60-Day Status: Partially Implemented

All Recommendations in 2012-032

Agency responses received after June 2013 are posted verbatim.