Report 2015-032 All Recommendation Responses

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

Recommendation for Legislative Action

The Legislature should require Justice to provide guidance to California's public and private institutions and systemwide offices regarding compliance with the requirements of the Clery Act and the Reauthorization Act.

Description of Legislative Action

As of July 16, 2020, Legislature has not taken any recent actions to address this specific recommendation.

California State Auditor's Assessment of Annual Follow-Up Status: No Action Taken

Description of Legislative Action

The Legislature has not taken any recent actions to address this specific recommendation.

California State Auditor's Assessment of Annual Follow-Up Status: No Action Taken

Description of Legislative Action

AB 1653 and AB 1654 were introduced on January 13, 2016. AB 1653 would have required California's public and private postsecondary institutions and systemwide offices to each generate a report once every biennium of the legislative session that includes specified information related to the institution's campus climate. It also would have required the Department of Justice to provide guidance to each private postsecondary educational institution on compliance with the federal law. This bill was vetoed by the Governor.

AB 1654 (Ch. 222, Statues of 2016) would have required Justice, commencing January 1, 2017, to provide guidance to California's public and private postsecondary institutions regarding compliance with specified federal law. This provision was removed from the bill prior to its enactment.

California State Auditor's Assessment of Annual Follow-Up Status: Legislation Proposed But Not Enacted

Description of Legislative Action

Assembly Bill 1653 would have required the California State University and Trustees of the California Community Colleges and the governing body of each independent institution of higher education, and encouraged each University of California campus, to each generate a report once every biennium of the legislative session that includes specified information related to the respective institution's campus climate and to post the report on the respective institution's website and submit the report to the Governor, the Attorney General, and the appropriate policy committees of the Legislature. This bill would also have required the board, the trustees, and the governing body of each independent institution of higher education, and would have encouraged the regents to create, review every two years thereafter, and, as necessary, update protocols, policies, and procedures regarding compliance with the federal Jeanne Clery Disclosure of Campus Security Policy and Campus Crime Statistics Act and the Violence Against Women Reauthorization Act of 2013. This bill was vetoed by the Governor.

California State Auditor's Assessment of Annual Follow-Up Status: Legislation Proposed But Not Enacted

Description of Legislative Action

AB 1653 and AB 1654 were introduced on January 13, 2016. AB 1653 would require the California's public and private postsecondary institutions and systemwide offices to each generate a report once every biennium of the legislative session that includes specified information related to the institution's campus climate, and also require the Department of Justice to provide guidance to each private postsecondary educational institution on compliance with the federal law.

AB 1654 would require Justice, commencing January 1, 2017, to provide guidance to California's public and private postsecondary institutions regarding compliance with specified federal laws, and would require the State Auditor to include in its mandated audit an evaluation of the institutions' compliance with state law governing crime reporting and the development and implementation of student safety policies and procedures.

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

Recommendation #2 To: University of Redlands

Redlands should review and adhere to applicable guidance related to the Clery Act, including the OPE handbook and the Uniform Crime Reporting Handbook, to ensure that it is accurately reporting its crime statistics.

60-Day Agency Response

During the reporting of calendar year 2013 crime statistics to the OPE, as well as in our ASR, we over-reported by one, the instance of an aggravated assault occurring during the commission of a robbery of a cellular telephone on public property adjacent to the campus. The University of Redlands erred in over-reporting this incident to the OPE and in the ASR as both a robbery and an aggravated assault. While both of those crimes occurred, only the criminal act of robbery should have been reported. The University of Redlands has amended the aggravated assault data in our 2015 ASR, as well as on the OPE Campus Safety and Security Survey website, of which the Completion Certificate is included as an attachment to this response letter. The University of Redlands 2015 ASR has been posted on our website and announced as available to the University community. The Notice of Availability of the 2015 ASR with this noted revision has been provided to the entire University community and is included as an attachment to this response letter.

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

Recommendation #3 To: University of California, San Diego

San Diego should review and adhere to applicable guidance related to the Clery Act, including the OPE handbook and the Uniform Crime Reporting Handbook, to ensure that it is accurately reporting its crime statistics.

60-Day Agency Response

As standard practice, the UCSD Police Department has reviewed the OPE Handbook and the Uniform Crime Reporting Handbook and will do so on a continuous basis. San Diego recently hired a full-time Clery Compliance Officer (CCO) who will assist in classifying crimes. The CCO monitors new guidance from the US Department of Education relating to Clery compliance and shares it with appropriate contacts at the University to ensure on-going compliance.

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

Recommendation #4 To: San Francisco State University

San Francisco should review and adhere to applicable guidance related to the Clery Act, including the OPE handbook and the Uniform Crime Reporting Handbook, to ensure that it is accurately reporting its crime statistics.

6-Month Agency Response

San Francisco State University established a Clery Review Committee in September 2015. The committee reviewed applicable guidance related to the Clery Act, including the OPE handbook and the Uniform Crime Reporting Handbook, and ensured adherence to the guidance as well as accurate reporting of campus crime statistics in the October 2015 annual security report.

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

60-Day Agency Response

San Francisco State University is in the process of establishing a Clery Review Committee, which will be responsible for reviewing applicable guidance related to the Clery Act and ensuring adherence to the guidance as well as accurate reporting of campus crime statistics.

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

Recommendation #5 To: Shasta College

Shasta should review and adhere to applicable guidance related to the Clery Act, including the OPE handbook and the Uniform Crime Reporting Handbook, to ensure that it is accurately reporting its crime statistics.

60-Day Agency Response

Shasta College implemented a several step tiered based process for accurately reporting and accounting for crimes on it's campuses. Shasta College Campus Safety conducted an internal audit of it's procedures and now accounts for this documentation with a several step process of approval.

In addition the college has implemented a 5 step approach to approval of the Annual Security Report.

The supporting procedure report has been submitted to California State Auditors.

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

Recommendation #6 To: Stanford University

Stanford should review and adhere to applicable guidance related to the Clery Act, including the OPE handbook and the Uniform Crime Reporting Handbook, to ensure that it is accurately reporting its crime statistics.

6-Month Agency Response

Stanford University Department of Public Safety (DPS), in accordance with the audit recommendation, has reviewed the applicable guidance related to the Clery Act, including the Clery Act Handbook and the Uniform Crime Reporting Handbook. It has also conducted refresher training (with a final quiz) for department personnel over the period September through November 2015 to ensure accurate reporting of crime statistics. DPS staff provided Clery training to university staff as well during this time frame to ensure accurate reporting of Clery crimes. DPS staff have attended and are scheduled to attend on-line (webinars) and off-site training that address Clery Act compliance in order to maintain and enhance our skills and knowledge. The Clery Compliance Coordinator also provided ongoing and regular input and guidance to university staff who are closely involved with Clery compliance related matters to ensure accurate reporting.

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

60-Day Agency Response

The State's audit identified two errors in our crime reporting statistics. We have found that both of these errors occurred as a result of human error.

In response, we have expanded our existing second-level quality control step to include additional staff to review the specifics of each case to minimize the likelihood of error.

In addition, to be specifically responsive to the recommendation to improve our Uniform Crime Reporting knowledge at the institutional level, Stanford DPS is providing additional training for lieutenants, sergeants and deputies on Clery Act compliance and UCR coding.

Stanford will be sending five staff members from the Department of Public Safety to the 5 day D Stafford and Associates Clery Act Compliance Training Academy in October 2015.

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

Recommendation #7 To: Fresno City College

Fresno should create written procedures that clearly describe the review process it will undertake to ensure that it is reporting crime statistics consistently and accurately in its annual security reports.

1-Year Agency Response

This recommendation has been fully implemented. Our department now has a specific policy regarding collecting, classifying and publishing the Annual Security and Fire Safety Report. This policy clearly describes the review process the department will undertake to ensure the accuracy and completeness of data collected for the purpose of creating and publishing the annual ASR.

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

6-Month Agency Response

Not fully implemented.

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

We followed-up with Fresno and learned that it still plans to implement this recommendation, but it has not taken any further action than that indicated in its 60-day response to this recommendation. Thus, we will continue to report this recommendation as pending.

60-Day Agency Response

During the week of March 16-19, 2015, several members of the California State Auditor's Office visited our police department for the purpose of conducting an audit on the Annual Security Report, commonly referred to as the Clery Report. In light of the this recent audit, State Center Community College District is in the process of reviewing its policies to ensure all mandated Clery policies are in place throughout our District. We are currently in the process of drafting a policy which clearly describes the review process it will undertake to ensure it is reporting crime statistics consistently and accurately in our annual security reports. We have attached a draft copy of the policy for your department to review. We anticipate this particular policy to be finalized by January 11, 2015.

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

Recommendation #8 To: University of California, San Diego

San Diego should create written procedures that clearly describe the review process it will undertake to ensure that it is reporting crime statistics consistently and accurately in its annual security reports.

1-Year Agency Response

UC San Diego has created written procedures that describe the Clery crime classification and review process to ensure consistent and accurate reporting of crime statistics in the Annual Security Report.

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

6-Month Agency Response

UC San Diego is drafting standard operating procedures relating to the review of Clery crime statistics to ensure accurate and consistent reporting in its Annual Security Report (ASR) and its online submission to the US Department of Education (USDOE). In addition, UC San Diego corrected the errors noted in the audit report in the 2015 ASR, which was distributed to the campus community on October 1, 2015.

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

60-Day Agency Response

UCSD is in the process of drafting formal written procedures to ensure that it is accurately reporting crime statistics in its Annual Security Report (ASR) and its online submission to the US Department of Education (USDOE). As standard practice, the UCSD Police Department reviews the OPE Handbook and the Uniform Crime Reporting Handbook on a continuous basis to ensure accurate classifications. The UCSD Police Department also examines new or updated offense codes to ensure proper classification within the Records Management System (RMS). Currently, each case report is reviewed for statistical accuracy against the federal definitions. Every case report undergoes a second assessment and is evaluated specifically for Clery reporting; the results are documented in a separate database. On a monthly basis, the UCSD Police Department compares RMS statistics against the Clery statistical database. The results are verified by a secondary staff employee. The preparation of the crime statistics for the ASR and online submission to the USDOE is reviewed by three staff employees within the UCSD Police Department.

San Diego recently hired a full-time Clery Compliance Officer (CCO) who will assist in classifying crimes. The CCO will also confirm that the statistics in the ASR match the web entries prior to submission. As part of a process of continuous improvement, the UCSD Police Department will implement a comparison of the RMS statistics against the ASR statistics at the sixth month mark. San Diego will correct the errors noted in the audit report in the 2014 ASR due October 1, 2015.

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

Recommendation #9 To: San Francisco State University

San Francisco should create written procedures that clearly describe the review process they will undertake to ensure that it is reporting crime statistics consistently and accurately in its annual security reports.

1-Year Agency Response

San Francisco State University has established a Clery Review Committee, which has developed written procedures to clearly describe the process they will undertake to ensure consistent and accurate reporting of statistics in the annual security reports.

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

6-Month Agency Response

San Francisco State University established a Clery Review Committee in September 2015. The committee has begun to create written procedures that clearly describe the process undertaken to ensure consistent and accurate reporting of statistics in the annual security reports.

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

60-Day Agency Response

San Francisco State University is in the process of establishing a Clery Review Committee. The committee will be responsible for creating written procedures to clearly describe the process they will undertake to ensure consistent and accurate reporting of statistics in the annual security reports.

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

Recommendation #10 To: Shasta College

Shasta should create written procedures that clearly describe the review process they will undertake to ensure that it will undertake to ensure that it is reporting crime statistics consistently and accurately in its annual security reports.

60-Day Agency Response

Shasta College implemented a several step tiered based process for accurately reporting and accounting for crimes on it's campuses. Shasta College Campus Safety conducted an internal audit of it's procedures and now accounts for this documentation with a several step process of approval.

In addition the college has implemented a 5 step approach to approval of the Annual Security Report.

The supporting procedure report has been submitted to California State Auditors.

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

Recommendation #11 To: Fresno City College

Fresno should review and adhere to applicable guidance related to the Clery Act, including the OPE handbook and the Uniform Crime Reporting Handbook, to ensure that it is including all required disclosures in its annual security reports.

1-Year Agency Response

This recommendation has been fully implemented by our department. We have reviewed the OPE handbook as well as the Uniform Crime Reporting Handbook and have included all of the necessary required disclosures in our ASR.

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

6-Month Agency Response

Not fully implemented.

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

We followed-up with Fresno and learned that it still plans to implement this recommendation, but it has not taken any further action than that indicated in its 60-day response to this recommendation. Thus, we will continue to report this recommendation as pending.

60-Day Agency Response

We are currently updating our 2015 Annual Security Report required under the Clery Act. As part of our review, we have gone through each of the mandated disclosures to ensure our ASR is complete and in full compliance with the Clery Act. We are rewriting the sections identified as missing disclosures and have referred to the Office of Postsecondary Education Handbook as well as the Uniform Crime Reporting Handbook . We anticipate completion as to this recommendation on or before October 1, 2015.

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

Recommendation #12 To: University of Redlands

Redlands should review and adhere to applicable guidance related to the Clery Act, including the OPE handbook and the Uniform Crime Reporting Handbook, to ensure that it is including all required disclosures in its annual security reports.

60-Day Agency Response

The Department of Public Safety has followed the guidelines contained in the OPE Handbook for Campus Safety and Security Reporting. However, during the audit process it was noted that the University of Redland's summary descriptions of specified policy statements or procedures should be described in their entirety. Specifically, statements which completely address all educational programs to promote the awareness and prevention of occurrences of sexual misconduct for all incoming students and new employees; the rights of victims regarding protective orders; a description of all emergency response and evacuation procedures; and a complete description of the University's Missing Student Policy pertaining to designated confidential contact information. Following discussion with the auditors regarding this recommendation, the University of Redlands documented formal procedures in written format to address this issue prior to publication of the final audit report. In addition, the University of Redlands' ASR was revised to include each of the identified statements or procedures that had previously been described in summary as opposed to in entirety. The revised ASR has been posted on the University of Redlands website and is available in print format at the Department of Public Safety. The Notice of Availability of the 2015 ASR with these noted revisions has been provided to the entire University community and is included as an attachment to this response letter.

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

Recommendation #13 To: University of California, San Diego

San Diego should review and adhere to applicable guidance related to the Clery Act, including the OPE handbook and the Uniform Crime Reporting Handbook, to ensure that it is including all required disclosures in its annual security reports.

6-Month Agency Response

As standard practice, the UC San Diego Police Department has reviewed the OPE Handbook and the Uniform Crime Reporting Handbook and will continue to do so on a regular basis. Since the issuance of the audit report, UC San Diego hired a full time Clery Compliance Officer whose job responsibilities include ensuring that the Annual Security Report (ASR) includes all required disclosures. Responsible individuals from the UC San Diego Police Department and the Clery Compliance Officer will also carefully review the revised OPE handbook once it is issued from the US Department of Education, and will revise policies and procedures as needed based on that guidance. Consistent with best practices, the Clery Compliance Officer ensures that all University policies are regularly reviewed and updated to meet Clery requirements and that all of the required disclosures are included within the ASR. In addition, UC San Diego included the missing disclosure noted in the audit report in its 2015 Annual Security Report, which was distributed to the campus community on October 1, 2015.

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

60-Day Agency Response

As standard practice, the UCSD Police Department has reviewed the OPE Handbook and the Uniform Crime Reporting Handbook and will do so on a continuous basis. Since the issuance of the audit report, San Diego has hired a full time Clery Compliance Officer whose job responsibilities include ensuring that the Annual Security Report (ASR) includes all required disclosures. Responsible individuals from the UCSD Police Department and the Clery Compliance Officer will also carefully review the revised OPE handbook once it is issued from the US Department of Education, which is expected to occur later in 2015, and will revise policies and procedures as needed based on that guidance. Consistent with best practices, the Clery Compliance Officer will ensure all University policies are regularly reviewed and updated to meet Clery requirements and that all of the required disclosures are included within the ASR. As noted in our response to the audit report, the disclosure relating to disciplinary proceedings arising from allegations of domestic violence, dating violence, sexual assault and stalking will be updated to include the appeals process in the 2014 Annual Security Report which is due October 1, 2015.

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

Recommendation #14 To: San Francisco State University

San Francisco should review and adhere to applicable guidance related to the Clery Act, including the OPE handbook and the Uniform Crime Reporting Handbook, to ensure that it is including all required disclosures in its annual security reports.

6-Month Agency Response

San Francisco State University established a Clery Review Committee in September 2015. The committee's responsibilities include the review of the applicable guidance related to the Clery Act, such as the OPE handbook and the Uniform Crime Reporting Handbook. The committee ensured that all required disclosures were included in the October 2015 annual security reports.

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

60-Day Agency Response

San Francisco State University is in the process of establishing a Clery Review Committee. Among the committee's responsibilities will be reviewing the applicable guidance related to the Clery Act to ensure that the campus is including all required disclosures in the annual security reports.

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

Recommendation #15 To: Shasta College

Shasta should review and adhere to applicable guidance related to the Clery Act, including the OPE handbook and the Uniform Crime Reporting Handbook, to ensure that it is including all required disclosures in its annual security reports.

6-Month Agency Response

Shasta College revamped the 2014 Annual Security Report to include all policy disclosures required by the Jeanne Clery Act. The report was mailed to California Auditors office.

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

60-Day Agency Response

Shasta College has implemented policies and procedures to ensure all the disclosures have been released. The 2014 Annual Security Report will be released on October 1, 2015. This report with supporting documentation will support a full completion of this objective.

In addition we have and will submit supportive policies and procedures to fully support the completion of this objective to the California State Auditors.

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

Recommendation #16 To: University of Redlands

Redlands should ensure that it includes all crimes on its daily crime log, as required under the Clery Act.

60-Day Agency Response

During the audit, three crimes that had occurred on or adjacent to the campus were not contained in the University of Redlands' Daily Crime Log. Specifically, two instances of stalking and one instance of a weapon possession on University of Redlands property had been reported to the Department of Public Safety, but those crimes were not incorporated in the Daily Crime Log available for public inspection. The University of Redlands discovered that the investigating personnel manually entered the crime descriptions in the reporting database, as opposed to utilizing the automated dropdown menu function of the reporting system. While the manual entries were sufficient for completing the investigation format, unbeknownst to the entering personnel, they subverted the automated population function of the Daily Crime Log. Amended internal procedures have subsequently been instituted to preclude a recurrence of this situation. It should be noted, however, that while the three identified crimes were not contained in the Daily Crime Log, they were all accurately reported to OPE and contained in the ASR as required by the Clery Act.

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

Recommendation #17 To: Shasta College

Shasta should ensure that it includes all crimes on its daily crime log, as required under the Clery Act.

60-Day Agency Response

This recommendation was followed by creating a policy and procedure that directs a tiered approach to approving daily crime log submissions. The policy and procedure directs that all crimes are entered into the daily crime log.This policy and procedure has been provided to the State Auditors office.

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

Recommendation #18 To: University of California

To ensure that its respective institutions comply with the Clery Act, UCOP should finalize and implement its draft policy that will provide additional guidance and oversight to its institutions.

Annual Follow-Up Agency Response From October 2018

The Clery Act Policy was issued on December 18, 2017. On May 31, 2018, the policy was update to include footnotes and/or updated reference links to reference Federal Regulations, the DOE Handbook for Campus Safety and Security Reporting, and California State Laws. https://policy.ucop.edu/doc/1100669/Clery

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

Annual Follow-Up Agency Response From November 2017

The Crime Awareness and Campus Security Policy is currently being vetted by stakeholders. The policy is estimated to be finalized and distributed by January 2018.

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

Annual Follow-Up Agency Response From October 2016

The Crime Awareness and Campus Security Policy is currently being vetted as required for all new policies. The vetting process has been delayed due to implementation of requirements related to sexual violence/sexual assault and will recommence when the academic year starts in the fall. The policy is estimated to be finalized and distributed by February 2017.

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

1-Year Agency Response

The Crime Awareness and Campus Security Policy is currently being vetted as required for all new policies. The vetting process has been delayed due to implementation of requirements related to sexual violence/sexual assault and will recommence when the academic year starts in the fall. The policy is estimated to be released by January 2017.

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

6-Month Agency Response

The Crime Awareness and Campus Security Policy has been submitted for formal vetting as required for all new policies. The policy is estimated to be released in April 2016.

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

60-Day Agency Response

The Crime Awareness and Campus Security Policy is estimated to be released in January 2016.

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

Recommendation #19 To: University, California State

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

Annual Follow-Up Agency Response From October 2018

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

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

Annual Follow-Up Agency Response From February 2018

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

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

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

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

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

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

Annual Follow-Up Agency Response From November 2017

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

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

Annual Follow-Up Agency Response From October 2016

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

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

1-Year Agency Response

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

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

6-Month Agency Response

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

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

60-Day Agency Response

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

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

Recommendation #20 To: Community Colleges Chancellor's Office

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

Annual Follow-Up Agency Response From February 2018

The California Community Colleges Chancellor's Office has developed written policies and procedures and will offer ongoing training to the community college system on how to accurately report Clery Act crime statistics and publish required disclosures in annual security reports.

The guidance includes policies and procedures, roles and responsibilities, and specific Clery Act requirements. It also includes links to additional authoritative resources such as the Office of Postsecondary Education's Handbook for Campus Safety and Security Reporting and the FBI's Uniform Crime Reporting Handbook.

The Chancellor's Office Clery Act policy can be found online at http://extranet.cccco.edu/Divisions/Legal/cleryact.aspx and will be reviewed annually. The policy will also be distributed to all responsible and interested individuals at every college.

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

1-Year Agency Response

The Chancellor's Office of the California Community Colleges will:

1. Develop a written policy for providing guidance to our 113 community colleges on:

A. How to report accurate Clery Act crime statistics.

B. How to ensure that all Clery Act required disclosures are

included in their annual security reports.

2. This policy will be developed in consultation with our Public Safety Educational Advisory Committee and shared with the Board of Governors. Draft policy and guidance has been developed and is being reviewed by the Committee.

3. Once finalized, the policy and the Chancellor's Office guidance to the colleges will be posted on the Chancellor's Office website, and all colleges will be notified. Training resources will be allocated to assist in disseminating guidance across the community college system.

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

6-Month Agency Response

The Chancellor's Office of the California Community Colleges will:

1. Develop a written policy for providing guidance to our 113 community colleges on:

A. How to report accurate Clery Act crime statistics.

B. How to ensure that all Clery Act required disclosures are

included in their annual security reports.

2. This policy will be developed in consultation with our Public Safety Educational Advisory Committee and shared with the Board of Governors. Draft policy and guidance has been developed and is being reviewed by the Committee.

3. Once finalized, the policy and the Chancellor's Office guidance to the colleges will be posted on the Chancellor's Office website, and all colleges will be notified. Training resources will be allocated to assist in disseminating guidance across the community college system.

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

60-Day Agency Response

The Chancellor's Office of the California Community Colleges will:

1. Develop a written policy for providing guidance to our 113 community colleges on:

A. How to report accurate Clery Act crime statistics.

B. How to ensure that all Clery Act required disclosures are

included in their annual security reports.

2. This policy will be developed in consultation with our Public Safety Educational Advisory Committee and shared with the Board of Governors.

3. The final policy and the Chancellor's Office guidance to the colleges will be posted on the Chancellor's Office website, and all colleges will be notified. Training resources will be allocated to assist in disseminating guidance across the community college system.

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

All Recommendations in 2015-032

Agency responses received are posted verbatim.