Between 2009 and 2013, Green River College failed to meet its obligations both under a federal consumer protection law that mandates the reporting of campus crime statistics and dictates how college campuses report those statistics to the public, and under the Drug-Free Schools and Communities Act.
Such is the conclusion of the Preliminary Program Review report recently completed by the Department of Education’s Clery Act Compliance Division of Federal Student Aid (CACD), based on data obtained from 2008 to 2014.
“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,” the report states.
Among the 13 findings, the report cites the college’s “lack of administrative capability,” and its failures: “to compile and disclose accurate and complete crime statistics; to properly disclose crime statistics by location; to maintain an accurate and complete crime log; to maintain an accurate and complete fire log; to properly request crime statistics from local law enforcement agencies; to comply with Drug and Alcohol Abuse Prevention Program requirements; and to actively notify prospective students of the college’s 2014 and 2015 annual safety reports and annual fire safety reports.”
Compliance with the program is required for Title IV funding, and Green River received more than $13 million in Title IV funding in 2015-2016. Because of the violations, however, the college may face fines, which the CACD will determine in a process separate from the review.
The CACD has told the college it will take at least 60 days, and perhaps much longer, to complete that process. The CACD has asked the college to respond to its findings within 60 days.
The U.S. Department of Education began its on-site program review to evaluate Green River College’s compliance with both federal acts on Nov. 16, 2015.
In an email disclosing the report, which the Department of Education has not yet released, Green River College President Suzanne M. Johnson said no one was surprised by the findings.
“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,” Johnson wrote in an email disclosing the report.
“While the Department of Education has not made this report public, I feel it’s important to share it with the Green River community,” Johnson wrote.
Johnson said the college has already taken a number of steps, to date, to improve its reporting of crime statistics, among them the following:
• 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;
• Improved transparency of communications for college issues that present safety concerns.
• In May of 2016, changed the crime incident log to “Report Exec,” nationally-recognized software that 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 areas the Clery Act defines 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 every February.
Changed procedures to standardize writing, reviewing, and classifying incident reports to ensure occurrence within two business days.
After the U.S. Department of Education reviews GRC’s responses, the college will receive a final report, which it will share with the public.
The Green River College Board of Trustees discussed the report at its regular meeting on Oct. 19. After the meeting, the preliminary Clery report was made available on the Green River College website.