Message from the President: Findings of Clery Investigation
By Suzanne M. Johnson, October 18, 2017
Dear Green River College Community:
As many of you know, on November 16, 2015, the U.S. Department of Education formally initiated an on-site program review to evaluate Green River College’s compliance with the Clery Act and the Drug-Free Schools and Communities Act (DFSCA). Passed in 1990, the Clery Act is a federal consumer protection law that mandates the reporting of campus crime statistics and dictates the manner in which those statistics are reported to the public. Compliance with the program is required for Title IV funding; Green River received over $13 million in Title IV funding in 2015-2016.
The Department of Education’s Clery Act Compliance Division of Federal Student Aid (CACD) has now provided a preliminary Program Review Report of the College’s compliance with the Clery Act from data obtained from 2008 to 2014 and has requested that the College respond to its findings within 60 days. While the Department of Education has not made this report public, I feel it’s important to share it with the Green River community.
Due to the violations found during the review period, the College faces the possibility of fines. The fines will be determined in a process separate from the review, and the College has been told that process will take at least 60 days, if not significantly longer. We will share the results of that process with you once we receive them.
During the period from 2009 to 2014, Green River failed to meet its obligations under the Clery Act and DFSCA. “Green River College substantially failed to develop and implement adequate Clery Act and DFSCA-compliant programs during the review period. The overall compliance program evidenced a lack of supervisory oversight, and affected personnel were largely unaware of their obligations to ensure substantive compliance with the Clery Act and DFSCA.” In total, there were 13 findings:
- Lack of Administrative Capability
- Failure to Produce and Distribute Annual Security Reports in 2008, 2009, 2010, 2011, 2012 and 2013
- Failure to Produce and Distribute Annual Fire Safety Reports in 2008, 2009, 2010, 2011, 2012 and 2013
- Failure to distribute the 2015 Annual Security Report within Regulatory Timeframes
- Failure to Actively Notify Prospective Students of the College’s 2014 and 2015 Annual Safety Reports and Annual Fire Safety Reports
- Failure to Properly Request Crime Statistics from Local Law Enforcement Agencies
- Failure to Compile and Disclose Accurate and Complete Crime Statistics
- Failure to Properly Disclose Crime Statistics by Location
- Failure to Maintain an Accurate and Complete Crime Log
- Failure to Maintain an Accurate and Complete Fire Log
- Omissions/Inadequacy of Required Safety Policy Statements
- Discrepancies between Crime Statistics included in the Annual Safety Report and Crime Data reported to CSSDACT
- Failure to comply with Drug and Alcohol Abuse Prevention Program Requirements
CACD’s conclusions regarding Green River College’s performance from 2009-2013 do not come as a surprise. Our own assessment, confirmed by the findings of the review, makes it clear that we did not have clear policies, procedures and resources for Clery reporting. As we and many of our peer institutions have learned, the requirements of the Clery Act are complex and require multiple resources.
What Green River College Has Done
The College has taken the following steps, thus far, to improve its reporting of crime statistics:
- Created an internal Clery Compliance Committee in 2015 with representatives from Campus Safety, Title IX, Housing, Judicial Affairs, Facilities, College Relations, and Human Resources.
- Hired a new Director of Campus Safety and an Assistant Director of Campus Safety.
- Implemented new technology to track and code Clery crimes.
- Provided additional training for staff responsible for Clery reporting and CSAs.
- Increased professionalization of Campus Safety policies and procedures.
- Utilized professional consultants to advise on manners in which to improve policies and procedures.
- Improved transparency of communications for College issues that present safety concerns. Examples include: community-wide safety bulletins, annual Title IX report of formal and informal complaints, etc.
- Changed Crime Incident Log to nationally recognized software “Report Exec” in May, 2016. This software supports Clery information reporting requirements, including specific location data and incident report disposition.
- Reviewed and re-mapped all Green River College Clery geography to establish which areas were defined by the Clery Act as “On Campus, On-Campus Residential, and Public Property.”
- Reviewed all Green River College off-campus activity, class or workshop locations, including the dates and times of use, to identify Clery Act defined Non-Campus Property and established procedures to update this data annually every February.
- Changed procedure to standardize writing, reviewing, and classifying incident reports to insure occurrence within two business days.
- Standardized procedures for gathering Clery crime and fire data.
- Initiated process to cross-check and verify accuracy of data with Green River College Annual Safety and Fire Reports data and the CSSDACT data.
- Established eight new policies and revised three other policies to address Clery Act and associated requirements.
- Timely distribution of 2016 Annual Safety and Fire Report.
The College has 60 days to respond to the findings in this preliminary report. After the U.S. Department of Education reviews our responses, the College will receive a final report. We will share the final report when it becomes available.
The preliminary report will be discussed during the regular meeting of the Green River College Board of Trustees on Thursday, October 19, 2017. Following the meeting, the preliminary Clery report will be made available on the Green River College website.
Since 2015, Green River College has fully cooperated with CACD’s review and significantly invested in remedying our shortcomings. We are working to provide the resources, policies and organizational structures needed to fully meet our reporting responsibilities, and more importantly, the needs of the community. Green River College will continue to work diligently to ensure the safety of our campus community and compliance with state and federal regulations.
The safety of our Green River College community is a paramount concern, and we have learned much from this experience.
Suzanne M. Johnson, Ph.D.
President, Green River College