Report 2017-125 All Recommendation Responses

Report 2017-125: The University of California: It Must Take Additional Steps to Address Long-Standing Issues With Its Response to Sexual Harassment Complaints (Release Date: June 2018)

Recommendation #1 To: University of California Board of Regents

To achieve prompt resolution of sexual harassment complaints against faculty respondents, the Regents should ensure that the Academic Senate further defines its bylaws with written requirements for the Privilege and Tenure Committee (tenure committee) that specify exact time frames for completing the phases of the disciplinary process. The following change should take effect by July 2019:

Require that a hearing be scheduled to begin within 60 calendar days from the date the chancellor files charges with the tenure committee unless the committee chair extends this time frame for good cause, which the written requirements should define.

1-Year Agency Response

In April 2019, the Academic Senate approved changes to Academic Senate by-law 336, effective July 1, 2019, which require that a hearing be scheduled to begin within 60 calendar days from the date the chancellor files charges with the Privilege and Tenure Committee unless the Privilege and Tenure Committee chair extends this time frame for good cause. Good cause is defined in the revised bylaws as "material or unforeseen circumstances sufficient to justify the extension sought." The revised bylaws further stipulate that a request to delay the start of the hearing beyond the 60 days must include adequate documentation of the basis for the request.

Completion Date: April 2019
Response Date: July 2019

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

6-Month Agency Response

On September 26, 2018, at the behest of the chair of the Board of Regents' Committee and Audit Committee, the Chair of the UC Academic Senate reported on the progress in implementing changes to Senate privilege and tenure procedures to incorporate the specific time frames for hearings to commence and report recommended by the California State Auditor. The Academic Senate Chair reported that Academic Senate leadership and leadership of the University Committee on Privilege and Tenure (UCPT) and the University Committee on Rules and Jurisdiction (UCRJ) were discussing how the committees would further define Academic Senate by-laws to incorporate the CSA recommendations. The Academic Senate Chair outlined to the Regents' committee the process of amending the Academic Senate by-laws, along with other steps the Academic Senate intended to take in implementing the revised procedures.

UCPT has met through the Fall, and has drafted a revision to Academic Senate by-law 336 governing Privilege and Tenure disciplinary hearings, which incorporates the new time frames. UCRJ has reviewed the draft, and their input and comments are reflected in the draft.

On December 12th, 2018, the Academic Council discussed UCPT's proposed draft revision of Senate by-law 336. On December 13th, 2018, the draft by-law was transmitted to the divisions and committees of the Academic Senate for a 90-day review, after which any revisions to be incorporated will be reviewed by UCPT and UCRJ. The revised by-law will be an action item for the April, 2019 meeting of the Academic Council, and if approved by the Council, will be an action item for the June, 2019 meeting of the Academic Assembly, who exercise final approval authority. Changes to the Senate by-laws and procedures will be completed in accordance with deadlines for implementation set by the CSA.

Estimated Completion Date: July 2019
Response Date: December 2018

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

The Academic Senate has drafted changes to its bylaws; those changes are progressing through the review process.

60-Day Agency Response

On June 21, 2018, the day the audit report was released, The Chair of the Board of Regents issued a communication to leadership of the Academic Senate asking the Senate to, as soon as possible, begin the process to implement these recommendations by July 2019, and provide periodic updates to the Regents on its progress.

On July 31, 2018, the Chair of the Academic Council sent a response to Chair Kieffer indicating that the Academic Council unanimously supported enacting the recommendations for achieving prompt resolution of sexual harassment complaints and has already asked the University Committee on Privilege and Tenure (UCPT) and the University Committee on Rules and Jurisdiction (UCRJ) to examine the recommendations on Council's behalf. Specifically, Council asked those committees to consider a bylaw change and/or the development of a guidance document for campus P&T committees which would also include a checklist for each step of the P&T hearing process, as well as a simple visual representation of the overall complaint, investigation, and disciplinary process that would be available to all members of the University community. The Academic Council Chair also indicated in his communication that he fully expects the Academic Senate to take substantive action and meet the July 2019 deadline, and that Academic Senate leadership would be pleased to provide the Regents with periodic updates.

The Regents have asked the Chair of the Academic Council to provide an update on the Senate's progress implementing these recommendation at the September 2018 meeting of the Board of Regents.

Estimated Completion Date: July 2019
Response Date: August 2018

California State Auditor's Assessment of 60-Day Status: No Action Taken

The Regents and the Academic Senate have issued communications expressing their intent to implement the recommendation by the July 2019 deadline. We look forward to reviewing the progress of the Academic Senate in its six-month response.

Recommendation #2 To: University of California Board of Regents

To achieve prompt resolution of sexual harassment complaints against faculty respondents, the Regents should ensure that the Academic Senate further defines its bylaws with written requirements for the tenure committee that specify exact time frames for completing the phases of the disciplinary process. The following change should take effect by July 2019:

Require that the tenure committee issue a recommendation within 30 calendar days of concluding the hearing. The written requirements should define when a hearing is considered concluded.

1-Year Agency Response

Completion Date: April 2019
Response Date: July 2019

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

6-Month Agency Response

Estimated Completion Date: July 2019
Response Date: December 2018

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

The Academic Senate has drafted changes to its bylaws; those changes are progressing through the review and approval process.

60-Day Agency Response

The Regents have asked the Chair of the Academic Council to provide an update on the Senate's progress implementing these recommendation at the September 2018 meeting of the Board of Regents.

Estimated Completion Date: July 2019
Response Date: August 2018

California State Auditor's Assessment of 60-Day Status: No Action Taken

Recommendation #3 To: University of California

To ensure prompt resolution of sexual harassment complaints against faculty respondents, the Office of the President should amend the appropriate policies to require that the chancellor or designee issue a final decision about discipline within 14 calendar days following receipt of the tenure committee's recommendation. This change should take effect by July 2019.

1-Year Agency Response

On July 31, 2019, the University issued a revised Investigation and Adjudication Framework for Senate and Non-Senate Faculty (Faculty Framework). The revised framework requires that chancellors or their designees issue a final disciplinary decisions within 14 days of receiving the Privilege and Tenure Committee's recommendation. President Napolitano issued the framework with instructions that campuses make corresponding amendments to their local procedures. The revised framework is posted online.

Completion Date: July 2019
Response Date: July 2019

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

The Office of the President has modified its framework to specify that a chancellor or their designee issue a final decision about discipline within 14 calendar days following receipt of the tenure committee's recommendation.

6-Month Agency Response

The Systemwide Title IX Office drafted revisions to the University's framework governing the investigation and adjudication of sexual harassment complaints against faculty to require that the chancellor or designee issue a final disciplinary decisions within 14 days of receiving the Privilege and Tenure Committee's recommendation. The Systemwide Title IX Office is engaging in the appropriate consultation with affected stakeholders to finalize the changes. Once finalized the University will disseminate and publish the revised procedure, and require that campuses make corresponding amendments to their local procedures.

Estimated Completion Date: July 2019
Response Date: December 2018

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

The Office of the President has drafted changes to its framework and is in the process of reviewing and approving those changes.

60-Day Agency Response

The University will amend its framework governing the investigation and adjudication of sexual harassment complaints against faculty to require that the chancellor or designee issue a final disciplinary decisions within 14 days of receiving the Privilege and Tenure Committee's recommendation. Once finalized the University will disseminate and publish the revised procedure, and require that campuses make corresponding amendments to their local procedures.

Estimated Completion Date: July 2019
Response Date: August 2018

California State Auditor's Assessment of 60-Day Status: No Action Taken

The University has expressed its intent to implement this recommendation. We look forward to reviewing the University's progress in its six-month response.

Recommendation #4 To: University of California

To ensure prompt resolution of sexual harassment complaints against faculty respondents, the Office of the President should do the following:

After the Academic Senate develops written requirements to specify exact time frames, complete an annual review of all cases involving Senate faculty to determine the length of time the adjudication process lasted. If an adjudication process takes longer than the time frames specified, the Office of the President should work with the Regents and the Academic Senate to develop further measures to enforce a more prompt adjudication process. The Office of the President should complete its first review by October 2020.

Annual Follow-Up Agency Response From November 2020

The Systemwide Title IX Office (STIXO) reviewed data showing the length of the adjudication process for faculty respondents during the one-year period following the Academic Senate's bylaw revision to include specific timeframes for the start and end of the privilege and tenure (P&T) hearing.

The data showed that these timelines improved, and generally complied with the revised bylaws. Specifically, of the four cases charged under the SVSH Policy that went to a P&T hearing: two hearings started before the deadline, with a cushion of 11-14 days, and two hearings concluded before the deadline, with a cushion of 21-26 days. On the other hand, timelines were extended in three cases, by 5, 12 and 71 days. In the outlier (71-day) case, the hearing start date was delayed due to scheduling difficulties caused by the location and number of witnesses, and by the Thanksgiving and winter holidays and curtailment (which are not subtracted from the timeline). Campuses determined that there was "good cause" for all three extensions.

STIXO's review showed that campuses were not consistent in how they requested, approved and documented good cause extensions. For example, in 3 cases (including the outlier) the length of the approved extension was not clear and in one case the extension was approved by in-house counsel rather than the chair of the P&T committee or hearing committee, as specified in the Bylaws. Academic Senate leadership agreed to take additional measures to improve consistency in these areas, which should also lead to continued improvements in timeliness.

Based on the data, and considering that the timelines and related procedures have only been in place for a year, STIXO determined it is not necessary to work with the Regents to develop additional measures at this time. However, STIXO will continue assessing timeliness on an annual basis and engage the Regents on measures to improve timeliness if necessary.

Completion Date: October 2020

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

1-Year Agency Response

The Systemwide Title IX Office will continue gathering data from campuses on all investigations involving faculty respondents, including timelines and outcomes. Following effectiveness of the Academic Senate's Bylaw revisions that specific timelines, the Systemwide Title IX Office will annually review disciplinary outcomes for all faculty respondents to assess whether timeliness is improving, using earlier data as a baseline, and whether time frames developed by the Academic Senate are met. The Systemwide Title IX Director will meet regularly with leadership of the Academic Senate to identify and address any obstacles to resolving cases within the developed time frames and, as necessary, work with the Regents and Academic Senate to develop additional measures to improve timeliness.

Estimated Completion Date: October 2020
Response Date: July 2019

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

The Academic Senate has revised its bylaws to include specific timelines and the systemwide office has described its plan for assessing the timeliness of disciplinary outcomes for all faculty respondents.

6-Month Agency Response

The Systemwide Title IX Office will continue gathering data from campuses on all investigations involving faculty respondents, including timelines and outcomes. Following the Academic Senate's development of specific timelines, the Systemwide Title IX Office will annually review disciplinary outcomes for all faculty respondents to assess whether timeliness is improving, using earlier data as a baseline, and whether time frames developed by the Academic Senate are met. The Systemwide Title IX coordinator will meet regularly with leadership of the Academic Senate to identify and address any obstacles to resolving cases within the developed time frames and, as necessary, work with the Regents and Academic Senate to develop additional measures to improve timeliness.

Estimated Completion Date: October 2020
Response Date: December 2018

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

The systemwide office has described its plan for implementing this recommendation. Following the Academic Senate's development of specific timelines, we will expect to see the systemwide office's annual review of the timeliness of disciplinary outcomes for all faculty respondents based on the data it has collected as well as any actions it may need to take in response to these reviews.

60-Day Agency Response

Estimated Completion Date: October 2020
Response Date: August 2018

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

Recommendation #5 To: University of California

To ensure that the campuses impose appropriate disciplinary sanctions and to determine whether any additional remedies need to be provided, the Office of the President should modify university policy to ensure that campus coordinators consult on the appropriateness of the discipline for respondents found to have violated university policy. This policy change should take effect by July 2019.

1-Year Agency Response

On July 31, 2019, the University issued the revised Faculty Framework and a revised Investigation and Adjudication Framework for Staff and Non-Faculty Academic Personnel (Staff and NFAP Framework). As revised, the frameworks require that Chancellors or their designees consult with their campus Title IX Officers before deciding discipline for all faculty, staff, and non-faculty academic personnel respondents found responsible for violating the SVSH Policy. President Napolitano issued the frameworks with instructions that campuses make corresponding amendments to their local procedures. The revised frameworks are posted online.

Completion Date: July 2019
Response Date: July 2019

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

6-Month Agency Response

The Systemwide Title IX Office drafted revisions to the frameworks governing the investigation and adjudication of sexual harassment complaints against faculty and staff to require that chancellors or their designees consult with their campus Title IX Officers before deciding discipline for all faculty and staff respondents found responsible for violating the UC Sexual Violence and Sexual Harassment (SVSH) Policy. The Systemwide Title IX Office is engaging in the appropriate consultation with affected stakeholders to finalize the changes. Once finalized the University will disseminate and publish the revised procedures, and require that campuses make corresponding amendments to their local procedures.

Estimated Completion Date: July 2019
Response Date: December 2018

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

The Office of the President has drafted revisions to its frameworks and is in the review and approval process.

60-Day Agency Response

The University will amend its framework governing the investigation and adjudication of sexual harassment complaints against faculty and staff to require that chancellors or their designees consult with their campus Title IX Officers before deciding discipline for all faculty and staff respondents found responsible for violating the UC Sexual Violence and Sexual Harassment (SVSH) Policy. The Systemwide Title IX Office will work with its partners in Academic Personnel and Human Resources to determine whether other University policies require corresponding changes. Once finalized the University will disseminate and publish the revised procedures, and require that campuses make corresponding amendments to their local procedures.

Estimated Completion Date: July 2019
Response Date: August 2018

California State Auditor's Assessment of 60-Day Status: No Action Taken

The University has expressed its intent to implement this recommendation. We look forward to reviewing the University's progress in its six-month response.

Recommendation #6 To: University of California

1-Year Agency Response

On July 31, 2019, President Napolitano issued a revised systemwide SVSH Policy. As revised, the policy specifies that the Title IX Officer must document agreements reached through the informal resolution process in accordance with guidelines issued by the Systemwide Title IX Office. On July 15, 2019, the Systemwide Title IX Office issued the referenced guidelines, which identify the required elements for capturing the agreement between a complainant and respondent to use the informal process and require the campuses to integrate these required elements into their processes.

Completion Date: July 2019
Response Date: July 2019

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

6-Month Agency Response

The Systemwide Title IX Office drafted revisions to the SVSH Policy specifying that the Title IX Officer must document agreements reached through the informal resolution process in accordance with guidelines issued by the Systemwide Title IX Office. The guidelines will identify required elements for capturing the agreement between a complainant and respondent to use the informal process and require the campuses to integrate these required elements into their processes. Formal review of the SVSH Policy revisions required by University procedures concluded on December 17, 2018. The Systemwide Title IX Office is considering comments received during the formal review, and will finalize the SVSH Policy and submit it to the Office for Civil Rights (OCR) for review and approval in February 2019. Following consultation with its campus partners, the Systemwide Title IX Office will develop and issue the referenced guidelines by July 2019.

Estimated Completion Date: July 2019
Response Date: December 2018

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

The Office of the President has drafted revisions to its sexual harassment policy. Those revisions are in the review and approval process.

60-Day Agency Response

The Systemwide Title IX Office drafted revisions to the SVSH Policy specifying that the Title IX Officer must document agreements reached through the informal resolution process in accordance with guidelines issued by the Systemwide Title IX Office. The guidelines will identify required elements for capturing the agreement between a complainant and respondent to use the informal process and require the campuses to integrate these required elements into their processes. The Systemwide Title IX Office is informally consulting with University stakeholders on the draft SVSH Policy revisions, and will begin the formal review process required by University procedures in September 2018. Following consultation with its campus partners, the Systemwide Title IX Office will develop and issue the referenced guidelines prior to or concurrently with issuance of the revised SVSH Policy, by July 2019.

Estimated Completion Date: July 2019
Response Date: August 2018

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

Recommendation #7 To: University of California

To ensure that campuses administer the informal process correctly for complaints alleging conduct that would violate university policy, by July 2019 the Office of the President should identify required elements for communications that inform a complainant and respondent of the informal and formal processes available to address the complaint, as well as what to expect of each process, and that also inform the complainant of his or her right to end the informal process at any time by requesting the formal process. The Office of the President should require the campuses to integrate these required elements into their processes.

1-Year Agency Response

On July 31, 2019, President Napolitano issued a revised systemwide SVSH Policy. As revised, the policy requires that campus Title IX Officers inform parties who agree to participate the informal process that the process is voluntary, and that they have the right to terminate the process at any time, to be accompanied by an advisor, and to receive written notice of the outcome. The draft SVSH Policy revisions further specify that the Title IX Officer must provide written notifications to parties about their rights and what to expect in connection with resolution processes in accordance with guidelines issued by the Systemwide Title IX Office. The Systemwide Title IX Office issued guidelines on July 15, 2019 that identify required elements for communications that inform a complainant and respondent of the informal and formal processes available to address the complaint, as well as what to expect of each process, and that also inform the parties of their right to end the informal process at any time by requesting the formal process.

Completion Date: July 2019
Response Date: July 2019

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

6-Month Agency Response

The Systemwide Title IX Office drafted revisions to the SVSH Policy requiring that campus Title IX Officers inform parties who agree to participate the informal process that the process is voluntary, and that they have the right to terminate the process at any time, to be accompanied by an advisor, and to receive written notice of the outcome. The draft SVSH Policy revisions further specify that the Title IX Officer must provide written notifications to parties about their rights and what to expect in connection with the informal and formal resolution processes in accordance with guidelines issued by the Systemwide Title IX Office. The guidelines will identify required elements for communications that inform a complainant and respondent of the informal and formal processes available to address the complaint, as well as what to expect of each process, and that also inform the complainant of his or her right to end the informal process at any time by requesting the formal process. Formal review of the SVSH Policy revisions required by University procedures concluded on December 17, 2018. The Systemwide Title IX Office is considering comments received during the formal review, and will finalize the SVSH Policy and submit it to the Office for Civil Rights (OCR) for review and approval in February 2019. Following consultation with campus Title IX Officers, the Systemwide Title IX Office issued interim frameworks governing the informal resolution process in November 2018. The Systemwide Title IX Office will use these frameworks to develop the guidance referenced in the SVSH Policy by July 2019.

Estimated Completion Date: July 2019
Response Date: December 2018

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

The Office of the President has drafted the necessary policy and is in the review and approval process.

60-Day Agency Response

The Systemwide Title IX Office drafted revisions to the SVSH Policy requiring that campus Title IX Officers inform parties who agree to participate the informal process that the process is voluntary, and that they have the right to terminate the process at any time, to be accompanied by an advisor, and to receive written notice of the outcome. The draft SVSH Policy revisions further specify that the Title IX Officer must provide written notifications to parties about their rights and what to expect in connection with the informal and formal resolution processes in accordance with guidelines issued by the Systemwide Title IX Office. The guidelines will identify required elements for communications that inform a complainant and respondent of the informal and formal processes available to address the complaint, as well as what to expect of each process, and that also inform the complainant of his or her right to end the informal process at any time by requesting the formal process. The Systemwide Title IX Office is informally consulting with University stakeholders on the draft SVSH Policy revisions, and will begin the formal review process required by University procedures in September 2018. Following consultation with its campus partners, the Systemwide Title IX Office will develop and issue the referenced guidelines prior to or concurrently with issuance of the revised SVSH Policy, by July 2019.

Estimated Completion Date: July 2019
Response Date: August 2018

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

Recommendation #8 To: University of California

To ensure that campuses administer the informal process correctly for complaints alleging conduct that would violate university policy, by July 2019 the Office of the President should modify university policy to require that the campus office either participate directly in the resolution with the respondent and responsible campus officials or that the campus office receive written confirmation from the responsible campus officials describing the resolution and documenting that it took place.

1-Year Agency Response

On July 31, 2019, President Napolitano issued a revised systemwide SVSH Policy. As revised, the policy specifies that the Title IX Officer must maintain oversight and appropriate involvement in the informal resolution process. The revised SVSH Policy further specifies that, upon conclusion of an informal resolution process, the Title IX Officer must obtain documentation from other campus officials involved in the resolution, if any, in accordance with guidelines issued by the Systemwide Title IX Office. On July 15, 2019, the Systemwide Title IX Office issued guidelines developed in consultation with the campus that govern the Alternative Resolution process and address the Title IX office's responsibility to maintain oversight and obtain the requisite documentation.

Completion Date: July 2019
Response Date: July 2019

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

6-Month Agency Response

The Systemwide Title IX Office drafted revisions to the SVSH Policy specifying that the Title IX Officer must maintain oversight and appropriate involvement in the informal resolution process. The draft SVSH Policy revisions further specify that, upon conclusion of an informal resolution process, the Title IX Officer must obtain documentation from other campus officials involved in the resolution, if any, in accordance with guidelines issued by the Systemwide Title IX Office. Formal review of the SVSH Policy revisions required by University procedures concluded on December 17, 2018. The Systemwide Title IX Office is considering comments received during the formal review, and will finalize the SVSH Policy and submit it to the Office for Civil Rights (OCR) for review and approval in February 2019. Following consultation with campus Title IX Officers, the Systemwide Title IX Office issued interim frameworks governing the alternative resolution process in November 2018. The Systemwide Title IX Office will use these frameworks to develop the guidance referenced in the SVSH Policy by July 2019.

Estimated Completion Date: July 2019
Response Date: December 2018

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

The Office of the President has drafted necessary policy and is in the review and approval process.

60-Day Agency Response

The Systemwide Title IX Office drafted revisions to the SVSH Policy specifying that the Title IX Officer must maintain oversight and appropriate involvement in the informal resolution process. The draft SVSH Policy revisions further specify that, upon conclusion of an informal resolution process, the Title IX Officer must obtain documentation from other campus officials involved in the resolution, if any, in accordance with guidelines issued by the Systemwide Title IX Office. The Systemwide Title IX Office is informally consulting with University stakeholders on the draft SVSH revisions, and will begin the formal review process required by University procedures in September 2018. Following consultation with its campus partners, the Systemwide Title IX Office will develop and issue the referenced guidelines prior to or concurrently with issuance of the revised SVSH Policy, by July 2019.

Estimated Completion Date: July 2019
Response Date: August 2018

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

Recommendation #9 To: University of California

To ensure that campuses retain adequate and consistent documentation for complaints they handle through the informal and formal processes, the Office of the President should determine the types of documents campuses should retain. The Office of the President should consider the types of complaint information, correspondence, and interview notes that would be necessary when determining a campus's response to a complaint. The Office of the President should modify university policy to include these requirements, and they should take effect by July 2019.

1-Year Agency Response

On July 31, 2019, President Napolitano issued a revised systemwide SVSH Policy. As revised, the policy specifies that Title IX Officers must maintain documentation upon completion of a resolution process in accordance with guidelines issued by the Systemwide Title IX Office. On July 15, 2019, the Systemwide Title IX Office issued guidelines developed in consultation with the campus Title IX officers that specify the documentation Title IX Officers must maintain upon closure following initial assessment of a report or closure of a resolution process, including a formal investigation or alternative resolution.

Completion Date: July 2019
Response Date: July 2019

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

6-Month Agency Response

The Systemwide Title IX Office drafted revisions to the SVSH Policy specifying that Title IX Officers must maintain documentation upon completion of a resolution process in accordance with guidelines issued by the Systemwide Title IX Office. Formal review of the SVSH Policy revisions required by University procedures concluded on December 17, 2018. The Systemwide Title IX Office is considering comments received during the formal review, and will finalize the SVSH Policy and submit it to the Office for Civil Rights (OCR) for review and approval in February 2019. Following consultation with its campus partners, the Systemwide Title IX Office will develop and issue the referenced guidelines by July 2019.

Estimated Completion Date: July 2019
Response Date: December 2018

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

The Office of the President has drafted necessary policy and is in the review and approval process.

60-Day Agency Response

The Systemwide Title IX Office drafted revisions to the SVSH Policy specifying that Title IX Officers must maintain documentation upon completion of a resolution process in accordance with guidelines issued by the Systemwide Title IX Office. The Systemwide Title IX Office is informally consulting with University stakeholders on the draft SVSH Policy revisions, and will begin the formal review process required by University procedures in September 2018. Following consultation with its campus partners, the Systemwide Title IX Office will develop and issue the referenced guidelines prior to or concurrently with issuance of the revised SVSH Policy, by July 2019.

Estimated Completion Date: July 2019
Response Date: August 2018

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

Recommendation #10 To: University of California

To ensure timely completion of investigations, the Office of the President should modify university policy to address investigation extensions. The policy changes should include, but not be limited to, defining good cause for an extension as material or unforeseen circumstances directly related to the complaint, specifying a standard extension period, requiring that an extension be requested and granted before the initial 60 business-day period expires, and specifying the time frame within which a campus must notify the parties about each approved extension. The policy should also outline examples of the material or unforeseen circumstances that could warrant an extension and specify the number of extensions available for an investigation before requiring approval from the systemwide coordinator. The changes should take effect by July 2019.

1-Year Agency Response

On July 31, 2019, President Napolitano issued a revised systemwide SVSH Policy. The revised policy provide that, upon extension of the timeframe specified in the policy for good cause, the Title IX Officer will notify the parties in writing of the reason for the extension and the projected new timeline.

On July 15, 2019, the Systemwide Title IX Office issued guidelines developed in consultation with the campus Title IX officers that provide examples of good cause, specify a standard extension period, require that extensions be communicated to parties before the timeframe expires, and specify when extensions must be approved by the Systemwide Title IX Director.

Completion Date: July 2019
Response Date: July 2019

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

6-Month Agency Response

The SVSH Policy currently provides that, upon extension of the timeframe specified in the Policy for good cause, the Title IX Officer will notify the Complainant and Respondent in writing of the reason for the extension and the projected new timeline. The revisions specify that the Title IX Officer will consider, approve, and communicate extensions according to written guidance from the Systemwide Title IX Office. Formal review of the SVSH Policy revisions required by University procedures concluded on December 17, 2018. The Systemwide Title IX Office is considering comments received during the formal review, and will finalize the SVSH Policy and submit it to the Office for Civil Rights (OCR) for review and approval in February 2019. Following consultation with its campus partners, the Systemwide Title IX Office issued interim frameworks governing timeline extensions in November 2018. The frameworks define and provide examples of good cause, specify a standard extension period, and require that extensions be communicated to parties before the timeframe expires. The Systemwide Title IX Office will use these frameworks to develop the guidance referenced in the SVSH Policy by July 2019. The guidance will specify the when extensions must be approved by the Systemwide Title IX Coordinator.

Estimated Completion Date: July 2019
Response Date: December 2018

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

The Office of the President has drafted necessary policy and is in the review and approval process.

60-Day Agency Response

The SVSH Policy currently provides that, upon extension of the timeframe specified in the Policy for good cause, the Title IX Officer will notify the Complainant and Respondent in writing of the reason for the extension and the projected new timeline. The revisions specify that the Title IX Officer will consider, approve, and communicate extensions according to written guidance from the Systemwide Title IX Office. The Systemwide Title IX Office is informally consulting with University stakeholders on the draft SVSH revisions, and will begin the formal review process required by University procedures in September 2018. Following consultation with its campus partners, the Systemwide Title IX Office will develop and issue the referenced guidelines prior to or concurrently with issuance of the revised SVSH Policy, by July 2019. The written guidance will define and provide examples of good cause, specify a standard extension period, require that extensions be communicated to parties before the timeframe expires, and specify the when extensions must be approved by the Systemwide Title IX Coordinator.

Estimated Completion Date: July 2019
Response Date: August 2018

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

Recommendation #11 To: University of California

To ensure that the campuses send complete notifications at the start and end of an investigation, the Office of the President should identify required elements for the campuses to include in these notifications and require the campuses to integrate these required elements in their notifications by July 2019.

1-Year Agency Response

The Faculty Frameworks, Staff and Non-Faculty Academic Personnel Frameworks and SVSH Student Investigation and Adjudication Framework (Student Framework) all enumerate the notices parties are to receive at the start and end of an investigation. In addition, President Napolitano issued a revised systemwide SVSH Policy on July 31, 2019. As revised, the policy specifies that that Title IX Officers must issue notifications to parties in accordance with guidelines issued by the Systemwide Title IX Office. On July 15, 2019, the Systemwide Title IX Office issued guidelines developed in consultation with the campus Title IX officers that identify elements that must be included in the notifications.

Completion Date: July 2019
Response Date: July 2019

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

The guidelines the systemwide office issues identity the elements that campuses must include in a notification at the start and end of an investigation.

6-Month Agency Response

The Systemwide Title IX Office University drafted revisions to the SVSH Policy specifying that Title IX Officers must issue notifications to parties at the start and end of an investigation in accordance with guidelines issued by the Systemwide Title IX Office. Formal review of the SVSH Policy revisions required by University procedures concluded on December 17, 2018. The Systemwide Title IX Office is considering comments received during the formal review, and will finalize the SVSH Policy and submit it to the Office for Civil Rights (OCR) for review and approval in February 2019. Following consultation with its campus partners, the Systemwide Title IX Office will develop and issue the referenced guidelines by July 2019. The guidelines will identify elements that must be included in the notifications.

Estimated Completion Date: July 2019
Response Date: December 2018

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

The Office of the President has drafted necessary policy and is in the review and approval process.

60-Day Agency Response

The Systemwide Title IX Office University drafted revisions to the SVSH Policy specifying that Title IX Officers must issue notifications to parties at the start and end of an investigation in accordance with guidelines issued by the Systemwide Title IX Office. The Systemwide Title IX Office is informally consulting with University stakeholders on the draft SVSH revisions, and will begin the formal review process required by University procedures in September 2018. Following consultation with its campus partners, the Systemwide Title IX Office will develop and issue the referenced guidelines prior to or concurrently with issuance of the revised SVSH Policy, by July 2019. The guidelines will identify elements that must be included in the notifications.

Estimated Completion Date: July 2019
Response Date: August 2018

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

Recommendation #12 To: University of California

To ensure that the campuses are using the administratively closed classification correctly and consistently, the Office of the President should modify university policy to include criteria for identifying and classifying complaints as closed. These criteria should identify the circumstances in which it is appropriate to close cases and the documents that campuses should retain. The criteria should also define what services campuses should provide to complainants and detail the type of communication campuses should provide to them. These modifications should take effect by July 2019.

1-Year Agency Response

On July 31, 2019, President Napolitano issued a revised systemwide SVSH Policy. As revised, the policy explaining the circumstances under which it is appropriate for Title IX Officers to close reports following their initial assessment (i.e., without a formal resolution process), and that such closures must be made in accordance with written guidelines issued by the Systemwide Title IX Office. On July 15, 2019, the Systemwide Title IX Office issued guidelines developed in consultation with the campus Title IX officers that detail the communication campuses should provide to parties, identify the documentation campuses should retain, and provide other instruction to promote consistent application of administrative closure.

Completion Date: July 2019
Response Date: July 2019

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

6-Month Agency Response

The Systemwide Title IX Office drafted revisions to the SVSH Policy explaining the circumstances under which it is appropriate for Title IX Officers to close reports following their initial assessment (i.e., without a formal resolution process), and that such closures must be made in accordance with written guidelines issued by the Systemwide Title IX Office. The revisions further provide that the Title IX Officers will still, where appropriate, take steps to stop, prevent and remedy misconduct, and provides examples of such steps. Formal review of the SVSH Policy revisions required by University procedures concluded on December 17, 2018. The Systemwide Title IX Office is considering comments received during the formal review, and will finalize the SVSH Policy and submit it to OCR for review and approval in February 2019. Following consultation with its campus partners, the Systemwide Title IX Office will develop and issue the referenced guidelines by July 2019. The guidelines will detail the communication campuses should provide to parties, identify the documentation campuses should retain, and provide other instruction to promote consistent application of administrative closure.

Estimated Completion Date: July 2019
Response Date: December 2018

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

The Office of the President has drafted necessary policy and is in the review and approval process.

60-Day Agency Response

The Systemwide Title IX Office University drafted revisions to the SVSH Policy explaining the circumstances under which it is appropriate for Title IX Officers to close reports following their initial assessment (i.e., without a formal resolution process), and that such closures must be made in accordance with written guidelines issued by the Systemwide Title IX Office. The revisions further provide that the Title IX Officers will still, where appropriate, take steps to stop, prevent and remedy misconduct, and provides examples of such steps. The Systemwide Title IX Office is informally consulting with University stakeholders on the draft SVSH Policy revisions, and will begin the formal review process required by University procedures in September 2018. Following consultation with its campus partners, the Systemwide Title IX Office will develop and issue the referenced guidelines prior to or concurrently with issuance of the revised SVSH Policy, by July 2019. The guidelines will detail the communication campuses should provide to parties, identify the documentation campuses should retain, and provide other instruction to promote consistent application of administrative closure.

Estimated Completion Date: July 2019
Response Date: August 2018

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

Recommendation #13 To: University of California

To ensure that the systemwide office has appropriate direction and the systemwide coordinator has the necessary authority, the Office of the President should work with the systemwide coordinator to develop a strategic plan for the systemwide office that delineates how it will approach achieving consistency systemwide. This plan should also ensure that the systemwide office updates university policy to comply with federal and state requirements and best practices, that it reviews and approves local procedures for compliance with university policy, that it oversees campus Title IX activities, and that it improves the university's use of campus data on sexual harassment complaints. The Office of the President should grant the systemwide coordinator the authority needed to enforce the desired plan, and it should develop the plan by December 31, 2018.

6-Month Agency Response

The Systemwide Title IX Coordinator worked with the Office of Strategy and Program Management and the location Title IX Officers to create a strategic plan. The plan addresses methods of achieving consistency across the system and the Systemwide Title IX Office's role in achieving it; the office's role in and approach to reviewing University policies and procedures, including local implementing procedures, for consistency, legal compliance and best practices; the office's role and approach to overseeing the campus Title IX offices; and how to maximize the utility of data collected from the campuses. To ensure the Systemwide Title IX Coordinator has the authority necessary to implement the strategic plan, and that the authority is adequately understood by campus leaders, the Office of the President informed the Chancellors and Title IX Officers in December 2018 that the Title IX Officers will have a solid-line dual report to the Systemwide Title IX Coordinator.

Completion Date: January 2019
Response Date: February 2019

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

60-Day Agency Response

The Systemwide Title IX Coordinator will work with the Office of Strategy and Program Management and the Office of the President to create a strategic plan. The plan will address what consistency is desired across the system and the Systemwide Title IX Office's role in achieving it; the office's role in and approach to reviewing University policies and procedures, including local implementing procedures, for consistency, legal compliance and best practices; the office's role and approach to overseeing the campus Title IX offices; and how to maximize the utility of data collected from the campuses. The Office of the President and Systemwide Title IX Coordinator will work together to ensure the coordinator has the authority necessary to implement the strategic plan, and that the authority is adequately understood by campus leaders.

Estimated Completion Date: December 2018
Response Date: August 2018

California State Auditor's Assessment of 60-Day Status: No Action Taken

The systemwide office has expressed its intent to implement this recommendation. We look forward to reviewing its progress in its six-month response.

Recommendation #14 To: University of California

To ensure that university policy complies with best practices, the systemwide office should amend that policy by July 2019 to incorporate the following provision in addition to the other changes that it has already agreed upon in its resolution with OCR:

A statement that the policy applies to third parties.

1-Year Agency Response

On July 31, 2019, President Napolitano issued a revised systemwide SVSH Policy. As revised, the policy states that it applies to third parties.

Completion Date: July 2019
Response Date: July 2019

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

6-Month Agency Response

The Systemwide Title IX Office drafted revisions to the SVSH Policy specifying that the Policy covers conduct committed by or against third parties, such as contractors, vendors, visitors, and guests.

Formal review of the revisions required by University procedures concluded on December 17, 2018. The Systemwide Title IX Office is considering comments received during the formal review, and will finalize the SVSH Policy and submit it to the Office for Civil Rights (OCR) for review and approval in February 2019. The University originally intended to issue the revised policy by July 2019. However, proposed federal regulations may require that the University further revise the policy, which would delay its issuance.

Estimated Completion Date: July 2019
Response Date: December 2018

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

The Office of the President has drafted necessary policy and is in the review and approval process.

60-Day Agency Response

The Systemwide Title IX Office University drafted revisions to the SVSH Policy specifying that the Policy covers conduct committed by or against third parties, such as contractors, vendors, visitors, and guests.

The office is informally consulting with University stakeholders on the draft revisions, will begin the formal review process required by University procedures in September 2018, and will issue the revised policy by July 2019.

Estimated Completion Date: July 2019
Response Date: August 2018

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

Recommendation #15 To: University of California

A statement that the policy applies to online behavior or social media that may affect an individual's educational experience.

1-Year Agency Response

On July 15, 2019, President Napolitano issued a revised systemwide SVSH Policy. As revised, the policy makes clear that it applies to online behavior or social media.

Completion Date: July 2019
Response Date: July 2019

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

6-Month Agency Response

The Systemwide Title IX Office drafted revisions to the SVSH Policy stating that conduct prohibited by the Policy may occur through electronic media, such as the internet, social networks, cell phones, texts, or other similar devices or forms of contact. Formal review of the SVSH Policy revisions required by University procedures concluded on December 17, 2018. The Systemwide Title IX Office is considering comments received during the formal review, and will finalize the SVSH Policy and submit it to OCR for review and approval in February 2019. The University originally intended to issue the revised policy by July 2019. However, proposed federal regulations may require that the University further revise the policy, which would delay its issuance.

Estimated Completion Date: July 2019
Response Date: December 2018

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

The Office of the President has drafted necessary policy and is in the review and approval process.

60-Day Agency Response

Estimated Completion Date: July 2019
Response Date: August 2018

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

Recommendation #16 To: University of California

A statement that the university may initiate a complaint.

1-Year Agency Response

On July 31, 2019, President Napolitano issued a revised systemwide SVSH Policy specifies circumstances under which the University may initiate an investigation.

Completion Date: July 2019
Response Date: July 2019

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

6-Month Agency Response

The Systemwide Title IX Office drafted revisions to the SVSH Policy specifying that the University may initiate a complaint investigation without a complainant, and providing examples of when it may be appropriate to do so. The current SVSH Policy, and the proposed revisions, address when the University may initiate an investigation despite a complainant's preference that it not do so. Formal review of the SVSH Policy revisions required by University procedures concluded on December 17, 2018. The Systemwide Title IX Office is considering comments received during the formal review, and will finalize the SVSH Policy and submit it to OCR for review and approval in February 2019. The University originally intended to issue the revised policy by July 2019. However, proposed federal regulations may require that the University further revise the policy, which would delay its issuance.

Estimated Completion Date: July 2019
Response Date: December 2018

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

The Office of the President has drafted necessary policy and is in the review and approval process.

60-Day Agency Response

Estimated Completion Date: July 2019
Response Date: August 2018

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

Recommendation #17 To: University of California

The date that identifies or defines the start of an investigation.

1-Year Agency Response

On July 31, 2019, President Napolitano issued a revised systemwide SVSH Policy. The policy specifies the date that defines the start of an investigation.

Completion Date: July 2019
Response Date: July 2019

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

6-Month Agency Response

The Systemwide Title IX Office University drafted revisions to the SVSH Policy specifying that the investigation begins on the date the Title IX Officer notifies the parties in writing of the charges to be investigated. Formal review of the SVSH Policy revisions required by University procedures concluded on December 17, 2018. The Systemwide Title IX Office is considering comments received during the formal review, and will finalize the SVSH Policy and submit it to OCR for review and approval in February 2019. The University originally intended to issue the revised policy by July 2019. However, proposed federal regulations may require that the University further revise the policy, which would delay its issuance.

Estimated Completion Date: July 2019
Response Date: December 2018

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

The Office of the President has drafted necessary policy and is in the review and approval process.

60-Day Agency Response

The Systemwide Title IX Office University drafted revisions to the SVSH Policy specifying that the investigation begins on the date the Title IX Officer notifies the parties in writing of the charges to be investigated. The office is informally consulting with University stakeholders on the draft revisions, will begin the formal review process required by University procedures in September 2018, and will issue the revised policy by July 2019.

Estimated Completion Date: July 2019
Response Date: August 2018

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

Recommendation #18 To: University of California

The allowable length of an extension for an investigation and what constitutes good cause for an extension.

1-Year Agency Response

On July 31, 2019, President Napolitano issued a revised systemwide SVSH Policy. As revised, the policy states that extensions will be considered and granted in accordance with written guidelines issued by the Systemwide Title IX Office. On July 15, 2019, the Systemwide Title IX Office issued guidelines that specify the allowable length of an extension and what constitutes good cause for an extension.

Completion Date: July 2019
Response Date: July 2019

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

6-Month Agency Response

The Systemwide Title IX Office University drafted revisions to the SVSH Policy specifying that the Title IX Officer will consider, approve, and communicate timeline extensions according to written guidance from the Systemwide Title IX Office. Formal review of the SVSH Policy revisions required by University procedures concluded on December 17, 2018. The Systemwide Title IX Office is considering comments received during the formal review, and will finalize the SVSH Policy and submit it to OCR for review and approval in February 2019. The University originally intended to issue the revised policy by July 2019. However, proposed federal regulations may require that the University further revise the policy, which would delay its issuance. Following consultation with its campus partners, the Systemwide Title IX Office issued interim frameworks governing timeline extensions in November 2018. The interim frameworks define and provide examples of good cause for extension of an investigation and specify a standard extension period. The Systemwide Title IX Office will use these frameworks to develop the guidance referenced in the SVSH Policy by July 2019.

Estimated Completion Date: July 2019
Response Date: December 2018

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

The Office of the President has drafted necessary policy and is in the review and approval process.

60-Day Agency Response

Estimated Completion Date: July 2019
Response Date: August 2018

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

Recommendation #19 To: University of California

An explanation of how a campus can protect confidentiality when implementing interim measures.

1-Year Agency Response

On July 31, 2019, President Napolitano issued a revised systemwide SVSH Policy. As revised, the policy addresses how campuses can protect confidentiality when implementing interim measures.

Completion Date: July 2019
Response Date: July 2019

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

6-Month Agency Response

The Systemwide Title IX Office University drafted revisions to the SVSH Policy specifying that, when determining interim, remedial, and supportive measures, the Title IX Officer will assess the extent to which the University is able to maintain the parties' privacy while also ensuring the measures are effective, and explain to the parties any limitations on its ability to maintain their privacy. Formal review of the SVSH Policy revisions required by University procedures concluded on December 17, 2018. The Systemwide Title IX Office is considering comments received during the formal review, and will finalize the SVSH Policy and submit it to OCR for review and approval in February 2019. The University originally intended to issue the revised policy by July 2019. However, proposed federal regulations may require that the University further revise the policy, which would delay its issuance.

Estimated Completion Date: July 2019
Response Date: December 2018

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

The Office of the President has drafted necessary policy and is in the review and approval process.

60-Day Agency Response

The Systemwide Title IX Office University drafted revisions to the SVSH Policy specifying that, when determining interim, remedial, and supportive measures, the Title IX Officer will assess the extent to which the University is able to maintain the parties' privacy while also ensuring the measures are effective, and explain to the parties any limitations on its ability to maintain their privacy. The Systemwide Title IX Office is informally consulting with University stakeholders on the draft revisions, will begin the formal review process required by University procedures in September 2018, and will issue the revised policy by July 2019.

Estimated Completion Date: July 2019
Response Date: August 2018

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

Recommendation #20 To: University of California

An explanation of what information a campus can keep confidential and what information it must disclose.

1-Year Agency Response

On July 31, 2019, President Napolitano issued a revised systemwide SVSH Policy. As revised, the policy addresses what information a campus can keep confidential and what information it must disclose.

Completion Date: July 2019
Response Date: July 2019

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

6-Month Agency Response

The Systemwide Title IX Office University drafted revisions to the SVSH Policy addressing limitations on the University's ability to protect the privacy of parties involved in a report of conduct prohibited by the Policy. Formal review of the SVSH Policy revisions required by University procedures concluded on December 17, 2018. The Systemwide Title IX Office is considering comments received during the formal review, and will finalize the SVSH Policy and submit it to OCR for review and approval in February 2019. The University originally intended to issue the revised policy by July 2019. However, proposed federal regulations may require that the University further revise the policy, which would delay its issuance.

Estimated Completion Date: July 2019
Response Date: December 2018

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

The Office of the President has drafted necessary policy and is in the review and approval process.

60-Day Agency Response

The Systemwide Title IX Office University drafted revisions to the SVSH Policy addressing limitations on the University's ability to protect the privacy of parties involved in a report of conduct prohibited by the Policy. The Systemwide Title IX Office is informally consulting with University stakeholders on the draft revisions, will begin the formal review process required by University procedures in September 2018, and will issue the revised policy by July 2019.

Estimated Completion Date: July 2019
Response Date: August 2018

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

Recommendation #21 To: University of California

The requirement to give the complainant the right to end the informal process and begin a formal process.

1-Year Agency Response

On July 31, 2019, President Napolitano issued a revised systemwide SVSH Policy. As revised, the policy states that complainants and respondents have the right to end the informal process and begin a formal process.

Completion Date: July 2019
Response Date: July 2019

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

6-Month Agency Response

The Systemwide Title IX Office drafted revisions to the SVSH Policy specifying that the complainant has the right to end the informal process and move to a formal investigation at any time before the parties have agreed to the terms of the informal resolution. Formal review of the SVSH Policy revisions required by University procedures concluded on December 17, 2018. The Systemwide Title IX Office is considering comments received during the formal review, and will finalize the SVSH Policy and submit it to OCR for review and approval in February 2019. The University originally intended to issue the revised policy by July 2019. However, proposed federal regulations may require that the University further revise the policy, which would delay its issuance.

Estimated Completion Date: July 2019
Response Date: December 2018

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

The Office of the President has drafted necessary policy and is in the review and approval process.

60-Day Agency Response

Estimated Completion Date: July 2019
Response Date: August 2018

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

Recommendation #22 To: University of California

Procedures to ensure that the informal process provides prompt and equitable resolution of complaints.

1-Year Agency Response

On July 31, 2019, President Napolitano issued a revised systemwide SVSH Policy. As revised, the policy specifies a timeframe for resolution of the alternative resolution process, and provides that upon extension of the timeframe for good cause, the Title IX Office will notify the Complainant and Respondent in writing the reason for the extension and the projected new timeline. The policy revisions also specify that the Title IX Officer will consider, approve, and communicate extensions according to written guidelines from the Systemwide Title IX Office. On July 15, 2019, the Systemwide Title IX Office issued guidelines that define and provide examples of good cause, specify a standard extension period, explain at what point approval of extensions is required from the Systemwide Title IX Office, explain the parties' rights in the process, specify the notices to be provided to parties, and otherwise define the process.

Completion Date: July 2019
Response Date: July 2019

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

6-Month Agency Response

The Systemwide Title IX Office drafted revisions to the SVSH Policy specifying a timeframe for the informal resolution process, and requiring that upon extension of the timeframe for good cause, the Title IX Officer will notify the Complainant and Respondent in writing the reason for the extension and the projected new timeline. The revisions specify that the Title IX Officer will consider, approve, and communicate extensions according to written guidance from the Systemwide Title IX Office. Formal review of the SVSH Policy revisions required by University procedures concluded on December 17, 2018. The Systemwide Title IX Office is considering comments received during the formal review, and will finalize the SVSH Policy and submit it to OCR for review and approval in February 2019. Following consultation with campus Title IX Officers, the Systemwide Title IX Office issued interim frameworks governing the timelines for formal investigations in November 2018. The frameworks define and provide examples of good cause and specify a standard extension period. The Systemwide Title IX Office will use these frameworks to develop the guidance referenced in the SVSH Policy by July 2019.

Estimated Completion Date: July 2019
Response Date: December 2018

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

The Office of the President has drafted necessary policy and is in the review and approval process.

60-Day Agency Response

To ensure the informal resolution process is prompt, the Systemwide Title IX Office drafted revisions to the SVSH Policy specifying a timeframe for the informal resolution process, and requiring that upon, extension of the timeframe for good cause, the Title IX Officer will notify the Complainant and Respondent in writing of the reason for the extension and the projected new timeline. The revisions specify that the campus Title IX Officers will consider, approve, and communicate extensions according to written guidance from the Systemwide Title IX Office. To ensure the informal process is equitable, the Systemwide Title IX Office drafted revisions to the SVSH Policy specifying that, in accordance with guidance issued by the Systemwide Title IX Office, the campus Title IX Officers will provide written notifications to parties about their rights and what to expect in connection with the processes; inform parties who agree to participate that the process is voluntary and that they have the right to terminate it at any time before the parties have agreed to the terms of the informal resolution; maintain oversight and appropriate involvement in the process and obtain documentation of resolutions from other involved campus officials, if any; and document agreements reached through the process. The Systemwide Title IX Office is informally consulting with University stakeholders on the draft SVSH Policy revisions, and will begin the formal review process required by University procedures in September 2018. Following consultation with its campus partners, the Systemwide Title IX Office will develop and issue the referenced guidance prior to or concurrently with issuance of the revised SVSH Policy, by July 2019.

Estimated Completion Date: July 2019
Response Date: August 2018

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

Recommendation #23 To: University of California

To address any patterns or systemic problems of sexual harassment, the systemwide office should do the following by July 2019:

Continue to improve and finalize the data collection process, including identifying data points that campuses should gather for each complaint and data points for tracking repeat respondents.

6-Month Agency Response

The Systemwide Title IX Office worked with the Office of Institutional Research and Academic Planning IRAP) and campus Response Team Coordinators (RTCs) to expand and refine the metrics for data it collected by and from the locations. The Systemwide Title IX Office is currently collecting data from locations using the revised metrics, which will improve accuracy and facilitate analysis to allow the Systemwide Title IX Office and campus Title IX offices to, among other things, better track repeat respondents.

Completion Date: December 2018
Response Date: December 2018

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

60-Day Agency Response

The Systemwide Title IX Office will work with the Office of Institutional Research and Academic Planning to refine the metrics, streamline the process, improve accuracy, and facilitate the analysis of data collected by and from the campuses to allow the Systemwide Title IX Office and campus Title IX offices to, among other things, better track repeat respondents. The improved process will be in place by July 2019.

Estimated Completion Date: July 2019
Response Date: August 2018

California State Auditor's Assessment of 60-Day Status: No Action Taken

The systemwide office has expressed its commitment to implement this recommendation. We look forward to reviewing its progress in its six-month response.

Recommendation #24 To: University of California

To address any patterns or systemic problems of sexual harassment, by July 2019 the systemwide office should work with each campus to develop and implement processes and data reports to assist the campus in regularly identifying patterns and systemic problems related to sexual harassment and in instituting sexual harassment prevention education and training in those areas that need it.

Annual Follow-Up Agency Response From August 2021

The Systemwide Title IX Office worked with IRAP and the campus Response Team Coordinators to refine and expand the metrics for data it collects from the locations; the new metrics improve accuracy and facilitate analysis and reports to allow the Systemwide Title IX Office and campus Title IX offices to, among other things, better identify patterns and systemic problems and to better target prevention education and training to areas that need it.

The Systemwide Title IX Office required that campus Title IX Offices implement processes to assist them in regularly identifying patterns to inform training and outreach, among other measures, and that they confirm implementation of these processes to the Systemwide Title IX Office; these requirements are memorialized in the data metrics reporting instructions and written guidelines the Systemwide Title IX Office issued to the campuses on July 15, 2019.

In consultation with IRAP, in July 2019 the Systemwide Title IX Office adopted internal protocols for working with, providing systemwide data to, and monitoring each campus to ensure it is utilizing data to identify and respond to patterns and problems.

The Systemwide Title IX Office worked with a vendor to create a common case management system (CMS) for use by all campuses and the Systemwide Title IX Office. The CMS will allow the campuses and the Systemwide Title IX Office to run custom campus-specific and systemwide reports that allow them to identify location-specific and systemwide patterns and trends. The CMS was launched in December 2020, and all campuses are using the new system for reports under UC's Sexual Violence and Sexual Harassment (SVSH) Policy.

Completion Date: August 2021

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

With the confirmed implementation of the University of California's case management system, we now consider this recommendation fully implemented.

Annual Follow-Up Agency Response From October 2020

The Systemwide Title IX Office worked with a vendor over the past year to create a common case management system (CMS) for use by all campuses and the Systemwide Title IX Office. The CMS will allow the campuses and the Systemwide Title IX Office to run custom campus-specific and systemwide reports that allow them to identify location-specific and systemwide patterns and trends. The CMS is in the final phase of testing by the Systemwide Title IX Office and campuses, and will go live across the UC system in December 2020. Implementation was delayed due to a combination of the Title IX regulations issued by the U.S. Department of Education in May 2020, which required that UC substantially change its systemwide policies and therefore the structure of the CMS, as well as the effects of COVID-19 on University operations.

The Systemwide Title IX Office hired a full-time data analyst in August 2019. The analyst has worked closely with the vendor and campus Title IX offices to build and implement the CMS systemwide. The analyst's responsibilities also include reviewing and analyzing campus data, and assisting the campus Title IX officers and Systemwide Title IX Director in identifying and responding to trends systemwide.

Completion Date: July 2019

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

Although the office of the president has make significant progress in addressing our recommendation, this recommendation is partially implemented because the office of the president has not yet implemented its data system. As noted in the response, the system has an implementation or 'go live' date of December 2020.

1-Year Agency Response

In consultation with IRAP, in July 2019 the Systemwide Title IX Office adopted internal protocols for working, providing systemwide data to, and monitoring each campus to ensure it is utilizing data to identify and respond to patterns and problems.

The Systemwide Title IX Office contracted with a vendor to implement (by January 2020) a common case management system (CMS) for use by all campuses and the Systemwide Title IX Office. The CMS will allow the campuses and the Systemwide Title IX Office to run custom campus-specific and systemwidewide reports that allow them to identify location-specific and systemwide patterns and trends.

The Systemwide Title IX Office is in the final stages of hiring a full-time data analyst whose job responsibilities will include working with the vendor and campuses to implement the CMS systemwide; gathering, reviewing and analyzing data collected from campuses; and assisting the campus Title IX officers and Systemwide Title IX Director in identifying and responding to trends systemwide.

Completion Date: July 2019
Response Date: August 2019

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

Although the office of the president has make significant progress in addressing our recommendation, this recommendation is partially implemented because the office of the president has not yet implemented its data system or completed its hiring of the analyst to review and analyze sexual harassment data.

Auditee did not substantiate its claim of full implementation

6-Month Agency Response

The Systemwide Title IX Office worked with IRAP and campus RTCs to expand and refine the metrics for data it collected by and from the locations. The new metrics will improve accuracy and facilitate analysis to allow the Systemwide Title IX Office and campus Title IX offices to, among other things, better identify patterns and systemic problems and to better target prevention education and training to areas that need it. The Systemwide Title IX Office will work with each location to ensure it is utilizing data to identify and respond to patterns and problems.

Estimated Completion Date: July 2019
Response Date: December 2018

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

The systemwide office describes that it has expanded and reined metrics for data collection. It has expressed intent to work with the campuses to use the data. We look forward to reviewing its progress in its 1-year response.

60-Day Agency Response

The Systemwide Title IX Office will work with the Office of Institutional Research and Academic Planning to refine the metrics, streamline the process, improve accuracy, and facilitate the analysis of data collected by and from the campuses to, among other things, allow the campuses to better identify patterns and systemic problems and to better target prevention education and training to areas that need it.

Estimated Completion Date: July 2019
Response Date: August 2018

California State Auditor's Assessment of 60-Day Status: No Action Taken

The systemwide office has expressed its intent to implement the recommendation. We look forward to reviewing its progress in its six-month response.

Recommendation #25 To: University of California

To address any patterns or systemic problems of sexual harassment, by July 2019 the systemwide office should work with each campus to implement ongoing data quality control processes in order to ensure sexual harassment complaints data are accurate and complete.

Annual Follow-Up Agency Response From August 2021

The Systemwide Title IX Office worked with IRAP and the campuses to expand and refine the metrics for data it collects from the locations.

The Systemwide Title IX Office required that campuses adopt data control processes and certify their implementation each time they report data to the Systemwide Title IX Office; these requirements are memorialized in the data metrics reporting instructions and written guidelines the Systemwide Title IX Office issued to the campuses on July 15, 2019.

In consultation with IRAP, in July 2019, the Systemwide Title IX Office adopted internal protocols for working with each campus to ensure the quality of their data.

The Systemwide Title IX Office hired a full-time data analyst in August 2019. The analyst's job responsibilities include identifying and correcting missing or inadequate information included in data reports provided by the campuses.

The Systemwide Title IX Office worked with a vendor to create a CMS for use by all campuses and the Systemwide Title IX Office. The CMS has built-in quality control features. The CMS was launched in December 2020, and all campuses are using the new system for reports under the SVSH Policy.

Completion Date: August 2021

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

With the confirmed implementation of the University of California's case management system, we now consider this recommendation fully implemented.

Annual Follow-Up Agency Response From October 2020

The Systemwide Title IX Office worked with a vendor to create a CMS for use by all campuses and the Systemwide Title IX Office. The CMS has quality control features that will be built into the CMS on all campuses. It is in the final testing phase and will go live across the system in December 2020.

Completion Date: July 2019

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

Although the office of the president has make significant progress in addressing our recommendation, this recommendation is partially implemented because the office of the president has not yet implemented its data system. As noted in its response, the system go live date is December 2020.

Auditee did not substantiate its claim of full implementation

1-Year Agency Response

The Systemwide Title IX Office worked with IRAP and the campuses to expand and refine the metrics for data it collects from the locations.

In consultation with IRAP, in July 2019, the Systemwide Title IX Office adopted internal protocols for working with each campus to ensure the quality of their data.

The Systemwide Title IX Office contracted with a vendor to implement ((by January 2020) a CMS for use by all campuses and the Systemwide Title IX Office. The Systemwide Title IX Office is working with the vendor to ensure quality control features are built into the CMS on all campuses.

The Systemwide Title IX Office is in the final stages of hiring a full-time analyst whose job responsibilities include identifying and correcting missing or inadequate information included in data reports provided by the campuses.

Completion Date: July 2019
Response Date: July 2019

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

Although the office of the president has make significant progress in addressing our recommendation, this recommendation is partially implemented because the office of the president has not yet implemented its data system or completed its hiring of the analyst to review and analyze sexual harassment data.

Auditee did not substantiate its claim of full implementation

6-Month Agency Response

The Systemwide Title IX Office worked with IRAP and the campus RTCs to expand and refine the metrics for data collected by and from the locations. The Systemwide Title IX Office will ensure each campus has adopted and is implementing an ongoing quality control process to improve the accuracy and completeness of data.

Estimated Completion Date: July 2019
Response Date: December 2018

California State Auditor's Assessment of 6-Month Status: No Action Taken

The systemwide office has expressed its intent to implement the recommendation. We look forward to reviewing its progress in its 1-year response.

60-Day Agency Response

The Systemwide Title IX Office will work with the Office of Institutional Research and Academic Planning to refine the metrics, streamline the process, improve accuracy, and facilitate the analysis of data collected from the campuses. As part of this process, the Systemwide Title IX Office ensure each campus has adopted and is implementing an ongoing quality control process to improve the accuracy and completeness of data.

Estimated Completion Date: July 2019
Response Date: August 2018

California State Auditor's Assessment of 60-Day Status: No Action Taken

The systemwide office has expressed its intent to implement the recommendation. We look forward to reviewing its progress in its six-month response.

Recommendation #26 To: University of California

To address any patterns or systemic problems of sexual harassment, by July 2019 the systemwide office should identify and review campuses' complaints data to identify outliers in their use of the formal, informal, and administratively closed processes.

Annual Follow-Up Agency Response From August 2021

The Systemwide Title IX Office worked with IRAP and the campuses to expand and refine the metrics for data it collects from the locations. In consultation with IRAP, in July 2019 the Systemwide Title IX Office adopted internal data protocols that explain how the Systemwide Title IX Office will use the data collected to help it identify and meaningfully respond to patterns and trends at the locations and systemwide, including identifying outliers in use of case resolution processes.

The Systemwide Title IX Office hired a full-time data analyst in August 2019. The analyst's responsibilities include implementing the CMS systemwide; reviewing and analyzing the data collected from campuses; and assisting the campus Title IX officers and Systemwide Title IX Director in identifying and responding to trends systemwide.

The Systemwide Title IX Office worked with a vendor over the past year to create a common CMS for use by all campuses and the Systemwide Title IX Office. The CMS will allow the Systemwide Title IX Office to run custom campus-specific and systemwide reports that allow them to identify location-specific and systemwide patterns and trends. The CMS was launched in December 2020, and all campuses are using the new system for reports under the SVSH Policy.

Completion Date: August 2021

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

With the confirmed implementation of the University of California's case management system, we now consider this recommendation fully implemented.

Annual Follow-Up Agency Response From October 2020

The Systemwide Title IX Office worked with a vendor over the past year to create a common CMS for use by all campuses and the Systemwide Title IX Office. The CMS is will allow the Systemwide Title IX Office to run custom campus-specific and systemwide reports that allow them to identify location-specific and systemwide patterns and trends. It is in the final testing phase and will go live across the system in December 2020.

Completion Date: July 2019

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

Auditee did not substantiate its claim of full implementation

1-Year Agency Response

The Systemwide Title IX Office contracted with a vendor to implement (by January 2020) a common CMS for use by all campuses and the Systemwide Title IX Office. The CMS will allow the campuses and the Systemwide Title IX Office to run custom campus-specific and systemwidewide reports that allow them to identify location-specific and systemwide patterns and trends.

The Systemwide Title IX Office is in the final stages of hiring a full-time analyst who will have significant responsibility for implementing the new case management system systemwide; for gathering, reviewing and analyzing the data collected from campuses; and assisting the campus Title IX officers and Systemwide Title IX Director in identifying and responding to trends systemwide.

Completion Date: July 2019
Response Date: July 2019

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

Although the office of the president has make significant progress in addressing our recommendation, this recommendation is partially implemented because the office of the president has not yet implemented its data system or completed its hiring of the analyst to review and analyze sexual harassment data.

Auditee did not substantiate its claim of full implementation

6-Month Agency Response

The Systemwide Title IX Office worked with the IRAP and campus RTCs to expand and refine the metrics for data it collected by and from the locations. The new metrics will improve accuracy and facilitate analysis to allow the Systemwide Title IX Office and campus Title IX offices to, among other things, allow the Systemwide Title IX Office to identify whether any campuses are outliers with respect to their use of the formal, informal, and administratively closed process.

Estimated Completion Date: July 2019
Response Date: December 2018

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

The systemwide office has expressed its intent to implement the recommendation. We look forward to reviewing its progress in its 1-year response.

60-Day Agency Response

The Systemwide Title IX Office will work with the Office of Institutional Research and Academic Planning to refine the metrics, streamline the process, improve accuracy of, and facilitate the analysis of data collected from the campuses to, among other things, allow the Systemwide Title IX Office to identify whether any campuses are outliers with respect to their use of the formal, informal, and administratively closed process.

Estimated Completion Date: July 2019
Response Date: August 2018

California State Auditor's Assessment of 60-Day Status: No Action Taken

The systemwide office has expressed its intent to implement the recommendation. We look forward to reviewing its progress in its six-month response.

Recommendation #27 To: University of California

To ensure that each campus hires the most qualified individuals to perform Title IX-related functions, the systemwide office should, in consultation with the campuses, develop a list of key Title IX positions and the associated minimum and desirable qualifications. The systemwide office should ensure that effective July 2019, each campus follows those qualifications when hiring new staff.

1-Year Agency Response

On July 15, 2019, the Systemwide Title IX Office issued guidelines developed in consultation with the Title IX Offices and human resources professionals in OP identify the key positions necessary for the campus Title IX offices to effectively implement the SVSH Policy and perform other critical functions, and define the desired minimum and maximum qualifications for each position. Campuses must update existing employees' job descriptions to include the qualifications, and must include them in job descriptions and announcements for new employees. The guidelines include a plan for monitoring local compliance with the guidelines for new and existing staff.

Completion Date: July 2019
Response Date: July 2019

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

6-Month Agency Response

The Systemwide Title IX Office is in the process of reviewing the structure and staffing of the campus Title IX offices. It will collect and review relevant job descriptions and job announcements, and consult human resources professionals and the campus title IX Officers to identify the key positions necessary for the offices to effectively implement the SVSH Policy and perform other critical functions, and define the desired minimum and maximum qualifications for each. The Systemwide Title IX Office will develop written guidelines for the Title IX offices that identify the key positions and associated qualifications, and a plan for monitoring local compliance with the guidelines when hiring new staff.

Estimated Completion Date: July 2019
Response Date: December 2018

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

The systemwide office has expressed its intent to implement the recommendation. We look forward to reviewing its progress in its 1-year response.

60-Day Agency Response

The Systemwide Title IX Office will review the structure and staffing of the campus Title IX offices, collect and review relevant job descriptions and job announcements, and consult human resources professionals and the Campus IX Officers to identify the key positions necessary for the offices to effectively implement the SVSH Policy and perform other critical functions, and define the desired minimum and maximum qualifications for each. The Systemwide Title IX Office will develop written guidelines for the Title IX offices that identify the key positions and associated qualifications, and a plan for monitoring local compliance with the guidelines when hiring new staff.

Estimated Completion Date: July 2019
Response Date: August 2018

California State Auditor's Assessment of 60-Day Status: No Action Taken

The systemwide office has expressed its intent to implement the recommendation. We look forward to reviewing its progress in its six-month response.

Recommendation #28 To: University of California

To ensure that all investigators and staff performing Title IX-related functions have necessary and consistent training, the systemwide office should amend university policy to take effect July 2019 to make clear the Title IX training requirements. The policy should specify the number of training hours required of each investigator and staff member, the period within which the training must be completed, and the minimum number of training hours within each period.

1-Year Agency Response

On July 31, 2019, President Napolitano issued a revised systemwide SVSH Policy. As revised, the policy states that campus Title IX Officers must provide training for investigators and other key members of their staff in accordance with written guidelines issued by the Systemwide Title IX Office. On July 15, 2019, the Systemwide Title IX Office issued guidelines developed in consultation with the campus Title IX officers and human resources professionals in OP. The guidelines specify the number of training hours required of key Title IX staff, including investigators, the period within which the training must be completed, and the minimum number of training hour within each period.

Completion Date: July 2019
Response Date: July 2019

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

6-Month Agency Response

written guidelines issued by the Systemwide Title IX Office. Formal review of the SVSH Policy revisions required by University procedures concluded on December 17, 2018. The Systemwide Title IX Office is considering comments received during the formal review, and will finalize the SVSH Policy and submit it to OCR for review and approval in February 2019. The Title IX Office will develop the referenced guidance in consultation with its campus partners and learning and development professionals by July 2019. The written guidance will specify the number of training hours required of Title IX investigators and staff, the period within which the training must be completed, and the minimum number of training hour within each period.

Estimated Completion Date: July 2019
Response Date: December 2018

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

The Office of the President has drafted necessary policy and is in its review and approval process.

60-Day Agency Response

written guidelines issued by the Systemwide Title IX Office. The Systemwide Title IX Office is informally consulting with University stakeholders on the draft SVSH Policy revisions, and will begin the formal review process required by University procedures in September 2018. The Title IX Office will develop the referenced guidance in consultation with its campus partners and learning and development professionals prior to or concurrently with the revised SVSH Policy, by July 2019. The written guidance will specify the number of training hours required of Title IX investigators and staff, the period within which the training must be completed, and the minimum number of training hour within each period.

Estimated Completion Date: July 2019
Response Date: August 2018

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

Recommendation #29 To: University of California

To ensure that all investigators and staff performing Title IX-related functions have necessary and consistent training, the systemwide office should amend university policy to take effect July 2019 to make clear the Title IX training requirements. The policy should specify the topics that the training must cover and the minimum number of training hours required on each topic.

1-Year Agency Response

Completion Date: July 2019
Response Date: July 2019

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

6-Month Agency Response

The Systemwide Title IX Office drafted revisions to the SVSH Policy stating that campus Title IX Officers must provide training for investigators and other key members of their staff in accordance with written guidelines issued by the Systemwide Title IX Office. Formal review of the SVSH Policy revisions required by University procedures concluded on December 17, 2018. The Systemwide Title IX Office is considering comments received during the formal review, and will finalize the SVSH Policy and submit it to OCR for review and approval in February 2019. The Systemwide Title IX Office will develop the referenced guidance in consultation with its campus partners and learning and develop professionals by July 2019. The written guidance will specify the topics the training must cover and the hours required on each topic.

Estimated Completion Date: July 2019
Response Date: December 2018

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

The Office of the President has drafted necessary policy and is in its review and approval process.

60-Day Agency Response

written guidelines issued by the Systemwide Title IX Office. The Systemwide Title IX Office is informally consulting with University stakeholders on the draft SVSH Policy revisions, and will begin the formal review process required by University procedures in September 2018. The Systemwide Title IX Office will develop the referenced guidance in consultation with its campus partners and learning and develop professionals prior to or concurrently with the revised SVSH Policy, by July 2019. The written guidance will specify the topics the training must cover and the hours required on each topic.

Estimated Completion Date: July 2019
Response Date: August 2018

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

Recommendation #30 To: University of California

To ensure that all investigators and staff performing Title IX-related functions have necessary and consistent training, the systemwide office should amend university policy to take effect July 2019 to make clear the Title IX training requirements. The policy should set training topics and the requisite number of hours by topic that new employees must complete and the period within which the new employee must do so.

1-Year Agency Response

On July 31, 2019, President Napolitano issued a revised systemwide SVSH Policy. As revised, the policy states that campus Title IX Officers must provide training for investigators and other key members of their staff in accordance with written guidelines issued by the Systemwide Title IX Office. On July 15, 2019, the Systemwide Title IX Office issued guidelines developed in consultation with the campus Title IX officers and UCOP human resources professionals. The guidelines specify the training topics and requisite number of hours by topic that new and existing employees must complete and the period within which the new employee must do so.

Completion Date: July 2019
Response Date: July 2019

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

6-Month Agency Response

The Systemwide Title IX Office drafted revisions to the SVSH Policy stating that campus Title IX Officers must provide training for investigators and other key members of their staff in accordance with written guidelines issued by the Systemwide Title IX Office. Formal review of the SVSH Policy revisions required by University procedures concluded on December 17, 2018. The Systemwide Title IX Office is considering comments received during the formal review, and will finalize the SVSH Policy and submit it to OCR for review and approval in February 2019. The Title IX Office will develop the referenced guidance in consultation with its campus partners and learning and develop professionals prior to or concurrently with the revised SVSH Policy, by July 2019. The written guidance will specify the training topics and requisite number of hours by topic that new employees must complete and the period within which the new employee must do so.

Estimated Completion Date: July 2019
Response Date: December 2018

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

The Office of the President has drafted necessary policy and is in its review and approval process.

60-Day Agency Response

written guidelines issued by the Systemwide Title IX Office. The Systemwide Title IX Office is informally consulting with University stakeholders on the draft SVSH Policy revisions, and will begin the formal review process required by University procedures in September 2018. The Title IX Office will develop the referenced guidance in consultation with its campus partners and learning and develop professionals prior to or concurrently with the revised SVSH Policy, by July 2019. The written guidance will specify the training topics and requisite number of hours by topic that new employees must complete and the period within which the new employee must do so.

Estimated Completion Date: July 2019
Response Date: August 2018

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

Recommendation #31 To: University of California

To ensure that all investigators and staff performing Title IX-related functions have necessary and consistent training, the systemwide office should amend university policy to take effect July 2019 to make clear the Title IX training requirements. The policy should require that each campus develops and implements processes to track staff training.

1-Year Agency Response

On July 31, 2019, President Napolitano issued a revised systemwide SVSH Policy. As revised, the policy states that campus Title IX Officers must provide training for investigators and other key members of their staff in accordance with written guidelines issued by the Systemwide Title IX Office. On July 15, 2019, the Systemwide Title IX Office issued guidelines developed in consultation with the campus Title IX officers and UCOP human resources professionals. The guidelines specify that the campuses will develop and implement processes to track training by employees at their location, to include: employee reporting and documentation, and manager verification. The guidelines also specify that the campuses must annually certify compliance to the Systemwide Title IX Office, and that the Systemwide Title IX Office will conduct additional monitoring to ensure compliance.

Completion Date: July 2019
Response Date: July 2019

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

6-Month Agency Response

The Systemwide Title IX Office drafted revisions to the SVSH Policy stating that campus Title IX Officers must provide and track training for investigators and other key members of their staff in accordance with written guidelines issued by the Systemwide Title IX Office. Formal review of the SVSH Policy revisions required by University procedures concluded on December 17, 2018. The Systemwide Title IX Office is considering comments received during the formal review, and will finalize the SVSH Policy and submit it to OCR for review and approval in February 2019. The Title IX Office will develop the referenced guidance in consultation with its campus partners and learning and develop professionals prior to or concurrently with the revised SVSH Policy, by July 2019. The written guidance will require that each campus develop and implement processes to track staff training.

Estimated Completion Date: July 2019
Response Date: December 2018

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

The Office of the President has drafted necessary policy and it is in its review and approval process.

60-Day Agency Response

written guidelines issued by the Systemwide Title IX Office. The Systemwide Title IX Office is informally consulting with University stakeholders on the draft revisions, and will begin the formal review process required by University procedures in September 2018. The Title IX Office will develop the referenced guidance in consultation with its campus partners and learning and develop professionals prior to or concurrently with the revised SVSH Policy, by July 2019. The written guidance will require that each campus develop and implement processes to track staff training.

Estimated Completion Date: July 2019
Response Date: August 2018

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

Recommendation #32 To: University of California

To ensure that all investigators and staff performing Title IX-related functions have necessary and consistent training, the systemwide office should amend university policy to take effect July 2019 to make clear the Title IX training requirements. The policy should specify that the systemwide office will monitor each campus to ensure it adheres to the training requirements.

1-Year Agency Response

On July 31, 2019, President Napolitano issued a revised systemwide SVSH Policy. As revised, the policy states that campus Title IX Officers must provide training for investigators and other key members of their staff in accordance with written guidelines issued by the Systemwide Title IX Office. On July 15, 2019, the Systemwide Title IX Office issued guidelines developed in consultation with the campus Title IX officers and UCOP human resources professionals. The guidelines specify that the campuses must annually certify compliance to the Systemwide Title IX Office, and that the Systemwide Title IX Office will conduct additional monitoring to ensure compliance.

Completion Date: July 2019
Response Date: July 2019

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

6-Month Agency Response

written guidelines issued by the Systemwide Title IX Office. Formal review of the SVSH Policy revisions required by University procedures concluded on December 17, 2018. The Systemwide Title IX Office is considering comments received during the formal review, and will finalize the SVSH Policy and submit it to OCR for review and approval in February 2019. The Title IX Office will develop the referenced guidance in consultation with its campus partners and learning and develop professionals prior to or concurrently with the revised SVSH Policy, by July 2019. The written guidance will specify that the Systemwide Title IX Office will monitor each campus to ensure it adheres to the training requirements, and outline a process for that monitoring.

Estimated Completion Date: July 2019
Response Date: December 2018

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

The Office of the President has drafted necessary policy and it is in its review and approval process.

60-Day Agency Response

written guidelines issued by the Systemwide Title IX Office. The Systemwide Title IX Office is informally consulting with University stakeholders on the draft SVSH Policy revisions, and will begin the formal review process required by University procedures in September 2018. The Title IX Office will develop the referenced guidance in consultation with its campus partners and learning and develop professionals prior to or concurrently with the revised SVSH Policy, by July 2019. The written guidance will specify that the Systemwide Title IX Office will monitor each campus to ensure it adheres to the training requirements, and outline a process for that monitoring.

Estimated Completion Date: July 2019
Response Date: August 2018

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

All Recommendations in 2017-125

Agency responses received are posted verbatim.