Report 2015-032 Recommendation 19 Responses

Report 2015-032: California's Postsecondary Educational Institutions: More Guidance Is Needed to Increase Compliance With Federal Crime Reporting Requirements (Release Date: July 2015)

Recommendation #19 To: University, California State

To ensure that its respective institutions comply with the Clery Act, the CSU Office of the Chancellor should develop written policies and procedures to provide guidance to its institutions on how to report accurate Clery Act crime statistics and ensure that all required disclosures are included in its respective institutions' annual security reports. The CSU Office of the Chancellor should then annually revisit the written policies and procedures to ensure that they are up to date.

Annual Follow-Up Agency Response From October 2018

In August 2018, the Chancellor's Office established Section 4450.00 of the Integrated California State University Administrative Manual, Clery Act Daily Crime Log. This policy outlines details about the types of crimes that must be entered in the daily crime log as well as the information those entries must include. Further, the policy includes details about the maintenance of the crime log and provides a suggested format.

California State Auditor's Assessment of Annual Follow-Up Status: Fully Implemented

Annual Follow-Up Agency Response From February 2018

In March 2017 the Chancellor's Office (CO) issued Executive Order (EO) 1107, Implementation of the Jeanne Clery Disclosure of Campus Security Policy and Campus Crime Statistics Act (Clery Act). In addition to the EO itself, in September 2017, the CO issued a memorandum to all campus presidents to highlight Clery Act reporting and provide additional resources and services to help ensure campus compliance. In the year since the issuance of EO 1107, the CO has continued to work on reviewing and revising the written policies and procedures related to Clery Act compliance to ensure they are up to date. For example, the CO is currently in the process of revising the template used for the annual security reports. We will continue to revise the template as needed due to any changes in policies that result from Clery Act compliance issues. In addition, the CO continues to work with the Clery Center, an internal Clery subject matter expert, and the CSU legal department to ensure the template is kept current. A scheduled timeline for implementation of the new CSU annual security report template has been presented to Clery directors at the campuses as well as to campus vice presidents responsible for public safety. In March 2018, the CO will be meeting with Clery directors to train them on the planned updates for the annual security reports.

Moreover, the CO contracts with the Clery Center on behalf of the 23 campuses and 22 of the campuses requested and received a desk review of their annual security reports by the Clery Center which identified areas to improve upon. The CO received from the Clery Center a summary analysis of issues identified through these reviews; these issues are being addressed.

The CO has also continued to work with each of the campuses to implement Clery Compliance Teams as outlined in the EO.

Finally, the review of the written policies and procedures will continue to be performed at least annually.

California State Auditor's Assessment of Annual Follow-Up Status: Partially Implemented

Although the CSU Chancellor's Office executive order 1107 includes guidance that we found robust in most areas, the CSU Chancellor's Office needs to improve the direction it provides to institutions regarding their daily crime logs. Until the CSU revises the executive order to include details regarding its institutions' maintenance of a daily crime log to help prevent errors from occurring, we will continue to report this recommendation as partially implemented.

Annual Follow-Up Agency Response From November 2017

In March 2017, the Chancellor's Office issued Executive Order (EO) 1107, Implementation of the Jeanne Clery Disclosure of Campus Security Policy and Campus Crime Statistics Act (Clery Act). The EO provides guidance to California State University campuses on how to report accurate Clery Act crime statistics and ensure that required disclosures are included in the annual security reports. In addition to the EO itself, in September 2017, the Executive Vice Chancellor and Chief Financial Officer issued a memorandum to all campus presidents to highlight Clery Act reporting and provide additional resources and services to help ensure campus compliance with the reporting requirements. For example, the Chancellor's Office has established a partnership agreement with the Clery Center and assembled Clery Cohorts to further assist with completing the annual security reports. Moreover, in October 2017, the Chancellor's Office conducted two days of "Clery Center CSU Clery Compliance Team Training." The related training manual included detailed guidance in the form of a 64-page checklist to help ensure compliance with all reporting requirements. In March 2018, we will revisit the written policies and procedures to ensure that they are up to date.

California State Auditor's Assessment of Annual Follow-Up Status: Partially Implemented

Annual Follow-Up Agency Response From October 2016

As we reported in July, we continue to make progress developing recommended policies and procedures. On June 23, 2016, the Department of Education issued guidance which significantly impacts campus safety policies and procedures under the Clery Act. By January 2017, we plan to finalize for CSU Campuses policies and procedures regarding accurate reporting of Clery Act crime statistics and completeness of required annual security report disclosures in accordance with new regulatory guidance. We then plan to conduct the first annual review of the policies and procedures one year after they are finalized.

California State Auditor's Assessment of Annual Follow-Up Status: Not Fully Implemented

1-Year Agency Response

We continue to make progress developing recommended policies and procedures. On June 23, 2016, the Department of Education issued guidance which significantly impacts campus safety policies and procedures under the Clery Act. By January 2017, we plan to finalize for CSU Campuses policies and procedures regarding accurate reporting of Clery Act crime statistics and completeness of required annual security report disclosures in accordance with new regulatory guidance. We then plan to conduct the first annual review of the policies and procedures one year after they are finalized.

California State Auditor's Assessment of 1-Year Status: Pending

6-Month Agency Response

We are still in the process of developing the recommended policies and procedures. We anticipate having guidance for CSU campuses on accurate reporting of Clery Act crime statistics and completeness of required annual security report disclosures no later than July 2016. We plan to conduct the first annual review of the policies and procedures one year after they are finalized.

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

60-Day Agency Response

We are currently in the process of developing the recommended policies and procedures. We anticipate having guidance for CSU campuses on accurate reporting of Clery Act crime statistics and completeness of required annual security report disclosures no later than July 2016. We plan to conduct the first annual review of the policies and procedures one year after they are finalized.

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

All Recommendations in 2015-032

Agency responses received are posted verbatim.