PROGRAM REVIEW REPORT
INSTITUTION:
Ramapo College of New Jersey
PRCN: 200130218417 OPEID: 009344
TIN: 216000928 DUNS: 076688399
DATES OF REVIEW:
April 30 through May 4, 2001
FOCUSED REVIEW:
Campus Security Act of 1990
CALENDAR YEARS REVIEWED:
1997, 1998 and 1999
TYPE AND CONTROL:
Public Institution
ACCREDITATION:
Middle States Association of Colleges and Schools – Higher Education
SFA PROGRAM FUNDING:
Program |
FY 99/00 |
|
Pell Grant |
$ 1,680,914 |
|
FSEOG |
107,817 |
|
FWS |
245,198 |
|
FFEL |
7,369,736 |
|
DL |
594,192 |
|
Total |
$ 9,997,857 |
Source: GAPS and National Student Loan Data System
DEFAULT RATES:
1998 – 8.7% 1997 – 12.6% 1996 – 10.2%
Source: PEPS
REVIEWING ED OFFICIALS:
Steve Eisenberg
Emil Milosz
INSTITUTIONAL OFFICIALS CONTACTED:
Pamela Bischoff, Vice President for Student Affairs
Joe Mulligan, Assistant Director of Residential Life
Robert O’Brien, Director of Security
Tim Osborne, Assistant Director of Security
Mary Goldschmidt, Director of the Women’s Center
Albert Frech, Center for Housing and Counseling Services
BACKGROUND:
Ramapo College of New Jersey is a public institution of higher education, established in 1969. The college is accredited by the Middle States Association of Colleges and Schools and authorized by the New Jersey Commission on Higher Education. The college is located in Mahwah, New Jersey and offers liberal arts, sciences, and professional studies.
The institution participates in the Federal Pell Grant, Federal Supplemental Educational Opportunity Grant, Federal Work Study, Federal Perkins Loan, Federal Direct Loan, and Federal Family Education Loan programs. In fall 2000 approximately 5,200 students attended Ramapo College, including almost 300 graduate students and 235 international students.
Ramapo College of New Jersey was selected for review as a result of a complaint regarding the institution’s compliance with the Campus Security Act requirements. The complaint alleged that the college did not report three (3) drug law arrests from the school’s 1998 campus crime statistics, the crime log is neither sufficiently updated or archived, and that numerous campus incident reports for 1998 were missing or not reported in the annual Campus Security Report.
Prior to our review, the College re-reviewed all incident reports for 1997, 1998, and 1999, and determined that there were inaccuracies in the statistics they had reported in each of these years. We considered their re-review as part of our analysis.
SCOPE OF REVIEW:
Members of the New York Case Management Team conducted a program review from April 30 to May 4 on campus. The review examined the school’s compliance with administration of the Campus Security Act of 1990. The review team interviewed school officials and reviewed relevant documents, including the Security Department Policies and Practices and Campus Crime Statistics brochure, the Student Handbook, the daily crime log, the public crime log, incident reports prepared by the Campus Security Department, and the log of judicial referrals for alcohol, drugs and weapons, maintained by the Office of Residence Life. The review also included interviews with the Mahwah Police Department’s College liaison officer and the review of crime statistics maintained by the Mahwah Police Department.
During the review, some areas of noncompliance were noted. Findings of noncompliance are referenced to the applicable laws, regulations, and policies, and specify the actions to be taken by Ramapo College of New Jersey to bring the operation of the Institution into compliance with regulations and statutes.
Although the review was thorough, it was focused on the institution’s compliance with the requirements of the Campus Security Act and, therefore, cannot be assumed to be all-inclusive. The absence of any statements in the report concerning Ramapo College of New Jersey’s specific practices and procedures must not be construed as acceptance, approval, or endorsement of those specific practices and procedures. Furthermore, it does not relieve Ramapo College of New Jersey of its obligation to comply with all of the statutes or regulatory provisions governing Title IV programs.
Ramapo College of New Jersey’s response is due within 30 days of receipt of this report. The findings resulting from this program review could be referred to the Department’s Administrative Action and Appeals Division for possible administrative action. Administrative action includes the imposition of tines, or limitation, suspension or termination of the institution’s eligibility to participate in the Title IV programs.
FINDING
NO. 1 – Crime Statistics Not Accurately Disclosed in Annual Campus
Security Report
The Campus Security Report prepared by Ramapo College of New Jersey for the year 2000 included inaccurate statistics for 1997, 1998 and 1999. The report did not include all reportable incidents including three (3) drug law arrests in 1998, contained incidents that were incorrectly reported in the wrong crime category, and were not reconciled to incident logs maintained by the Mahwah Police Department.
As alleged in the complaint received by our office, Ramapo College of New Jersey’s Campus Security Report did not include three (3) on campus arrests for drug law violations by the Mahwah Police Department. Prior to our visit, College officials reviewed all incident reports for 1997, 1998 and 1999 and identified the arrests not reported. The College officials indicated that the arrests were not reported because the instructions for completing the Campus Security Report were unclear. They noted that the instructions did not require that arrests in residence halls be reported separately, and they mistakenly believed they did not have to report the incidents in the on campus category either. The following discrepancies were identified:
1998 Calendar Year Statistics – The Campus Security Report did not list any on campus arrests for drug law violations, while the incident reports prepared by the Campus Security Department included three (3) on campus arrests for the calendar year. [Incident reports C-400-98 (1 arrest made) and C-426-98 (2 arrests made)].
The complaint also alleges that Ramapo College of New Jersey did not report, or did not correctly categorize numerous crime incidents in 1997, 1998 and 1999. As previously stated, prior to tour visit the College reviewed all incident reports for the period, and identified incidents not reported or incorrectly reported. The following discrepancies were identified:
1997 Calendar Year Statistics – The Campus Security Report of Disciplinary Actions/Judicial Referrals, reported 36 liquor law violations. Six (6) of the violations occurred in 1996, and should not be included. [(Case # 012-964 (4 violations), and Case # 015-964 (2 violations)].
One (1) burglary was reported as in residence hall, and should have been reported as on campus. (C-810-97).
One (1) aggravated assault was reported as public property, and should have been reported as in residence hall. (C-134).
1998 Calendar Year Statistics – The Campus Security Report listed two (2) burglaries in residence halls. There were an additional 23 burglaries which were not reported, because they were incorrectly categorized as thefts.
Case # Location
C-002-98 Residence Hall
C-102-98 Residence Hall
C-133-98 Residence Hall
C-202-98 Residence Hall
C-218-98 Residence Hall
C-329-98 Residence Hall
C-438-98 Residence Hall
C-449-98 Residence Hall
C-459-98 Residence Hall
C-640-98 Residence Hall
C-700-98 Residence Hall
C-702-98 Residence Hall
C-806-98 Residence Hall
C-1098-98 Residence Hall
C-1498-98 Residence Hall
C-1477-98 Residence Hall
C-1636-98 Residence Hall
C-1697-98 Residence Hall
C-1773-98 Residence Hall
C-565-98 Residence Hall
C-1223-98 Campus
C-1223-98 Campus
C-1698-98 Campus
C-025-98 Campus
One (1) hate crime that was reported as in residence hall should have been reported as on campus. (Incident Report C-510-98)
As previously indicated, three (3) drug arrests were not reported for 1998, as the complainant alleged. They should have been reported as in residence hall.
The complainant also alleged that two (2) drug cases that were handled as judicial referrals (Incident Reports C-1210-98 and C-70-98) should have resulted in arrests. The incident reports did not indicate why the Mahwah Police Department was not notified.
The complainant further alleged that numerous incident reports were missing for 1998. This allegation was generally not correct. The College did have copies of incident reports identified in the complaint, although eight (8) of the incident reports were not signed. (Incident Reports C-160-98, C-238-98, C-413-98, C-810-98, C-899-98, C-967-98, C-1312-98, C-1317-98).
1999 Calendar Year Statistics – The Campus Security Report listed 16 burglaries. There were an additional five (5) burglaries which were not reported.
Case # Location
C-034-99 Campus
C-419-99 Campus
C-1003-99 Campus
C-1166-99 Campus
C-1882-99 Non-campus Bldg.
Nine (9) burglaries that were reported as in residence hall should have been reported as on campus. (Incident Reports # C-044-99, C-052-99, C-946-99, C-701-99, C-878-99, C-1159-99, C-1211-99, C-1666-99, C-1705-99).
One (1) drug arrest that was reported as in residence hall should have been reported as on campus. (Incident Report C-1868-99).
Three (3) alcohol arrests that were reported as in residence hall should have been reported as on campus. (Incident Report C-1868-99).
Two (2) aggravated assaults that were reported as in residence hall should have been reported as on campus. (Incident Reports C-595-99, C-857-99).
Crime Data Not Reconciled with Mahwah Police Department
Ramapo College’s Campus Security Officers do not have authority to make arrests. The Mahwah Police Department responds to calls from Campus Security and other staff, and from students. The Mahwah Police also conduct undercover drug operations involving Ramapo College. The College coordinates security activities with the Mahwah Police through periodic meetings with a Police Captain, who is the designated liaison.
The Mahwah Police maintains a dispatcher’s report that lists all calls to the police by location. College officials stated they did not, in the past, reconcile this dispatcher’s report to the daily crime log to ensure that the daily crime log was complete. As a result, there may have been incidents where the police responded, that were not entered on the daily crime log, and were not reported on the Annual Campus Security Report. For example, the dispatcher’s log for 1999 indicates there were two (2) calls for alcohol violations (Cases #s 7836 and 22584) and one (1) call for burglary (Case # 18217) that may have been reportable incidents. It was unclear if these incidents were crimes that should have been reported, or if they resulted in arrests or judicial referrals.
FINDING
NO. 2 – Public Crime Log Not Maintained Before April 1999
Ramapo College maintains a public crime log for the most recent 60 day period. Incidents that are more than 60 days old are transferred to an archive, and maintained for public inspection. The earliest incidents in the archive date from April 1999. There was no evidence the log was maintained before this time, as required by the 1998 Amendments to the Higher Education Act.
Failure to accurately report all of the criminal occurrences required to be included in the Campus Security Report denies students and employees the opportunity to make informed decisions about the relative security of the campus environment and to make personal security decisions.
REFERENCE: Section 485 (f) of the HEA, as amended
34 CFR 668.14(c)(2) – Program Participation Agreement
34 CFR 668.47 – Institutional Security Policies and Crime Statistics
34 CFR 668 Appendix E – Crime Definitions
REQUIREMENT: The College should review the requirements of 34 CFR 668.46 (formerly 34 CFR 668.47) to ensure the accurate reporting of data in the College’s Campus Security Report, and to comply with the other requirements of 34 CFR 668.46. The College’s reporting system should include the following:
1. Reconciliation of all incidents reported on the daily crime log to incident reports and final reporting on the Campus Security Report.
2. Reconciliations should be performed between the Mahwah Police Department’s dispatcher reports, and the College’s records.
3. The Public Crime Log should be amended to include reportable incidents between October 1998 and April 1999.
Additionally, the College must ensure that the necessary corrections are made to any erroneous prior year’s statistics that are included in the current campus Security Report.
June 11, 2001
Mr. Steve Eisenberg
Institutional Review Specialist
United States Department of Education, Region II
Office of Student Financial Assistance Programs
75 Park Place
New York, NY 10007
Dear Mr. Eisenberg:
The following is Ramapo College’s response to the U.S. Department of Education’s May, 2001 focused program review concerning compliance with the Campus Security Act. In this document, we comment on each finding and, where deficiencies were identified, provide a plan for remedying them.
We wish to thank you and Emil Milosz, for your professionalism and for your considerable care in fully and fairly investigating the allegations forwarded to you by Security On Campus, a private monitoring organization concerned with campus security on a nationwide basis.
While our own internal review which followed the departure of the former Director of Security had established that some mistakes had been made with regard to reporting, this thorough review by you and Mr. Milosz will help us to very quickly come into full compliance. We also appreciated the opportunity you afforded to Ramapo staff members to suggest improvements in the Jeanne Clery Act’s instructions for reporting crimes.
The College regrets its unintentional reporting errors and pledges to correct them when the next edition of our “Campus Crime Act” booklet is published later this summer.
Sincerely,
Alice Chandler
Interim President
FINDINGS
|
FINDING NO. 1 |
Crime Statistics Not Accurately Disclosed in Annual Campus Security Report
The Campus Security Report prepared by Ramapo College of New Jersey for the year 2000 included inaccurate statistics for 1997, 1998 and 1999. The report did not include all reportable incidents including three (3) drug law arrests in 1998, contained incidents that were incorrectly reported in the wrong crime category, and were not reconciled to incident logs maintained by the Mahwah Police Department.
Some crime statistics for 1997, 1998 and 1999 were not accurately disclosed in the 2000 report. Three (3) drug law arrests were not reported for 1998 and certain incidents, largely burglaries (i.e., ”the unlawful entry into a building or other structure with the intent to commit a felony or a theft”) were incorrectly published as thefts/larcenies (i.e., “the taking of the property of another with intent to deprive him/her of ownership”). Ramapo Security Department Incident Reports were not specifically reconciled with the Mahwah Police Department’s “dispatcher’s logs,” although College officials had met with Mahwah Police officials to reconcile summary crime reporting data, believing this was sufficient to ensure accurate reporting. Staff are now clear about the definitions they must use and will carefully reconcile our individual log entries with the Mahwah Police Department’s.
Missing Reportable Drug Arrests
As alleged in the complaint received by our office, Ramapo College of New Jersey’s Campus Security Report did not include three (3) on campus arrests for drug law violations by the Mahwah Police Department. Prior to our visit, College officials reviewed all incident reports for 1997, 1998 and 1999 and identified the arrests not reported. The College officials indicated that the arrests were not reported because the instructions for completing the Campus Security Report were unclear. They noted that the instructions did not require that arrests in residence halls be reported separately, and they mistakenly believed they did not have to report the incidents in the on campus category either. The following discrepancies were identified:
The responsible College officials actually did understand that the arrests in question had to be reported in one category or the other. An error was made and they were reported in neither category.
1998 Calendar Year Statistics – The Campus Security Report did not list any on campus arrests for drug law violations, while the incident reports prepared by the Campus Security Department included three (3) on campus arrests for the calendar year. [Incident reports C-400-98 (1 arrest made) and C-426-98 (2 arrests made)].
The 1999 Security Act Report did not list 3 drug arrests made by the Mahwah Police Department with regard to 2 separate incidents on campus (detailed in Ramapo Security Reports #s C-400-98 and C426-98). C-400-98 was an arrest of one person for possession of the drug Ketamine (“Special K”); C-426-98 recorded the arrest of 2 persons for cultivation of marijuana. In each case, the amount of drugs involved was small. These three arrests will be correctly reported in the Campus Security document issued in 2001.
Other Unreported or Improperly Reported Incidents
The complaint also alleges that Ramapo College of New Jersey did not report, or did not correctly categorize numerous crime incidents in 1997, 1998 and 1999. As previously stated, prior to our visit the College reviewed all incident reports for the period, and identified incidents not reported or incorrectly reported. The following discrepancies were identified:
1997 Calendar Year Statistics – The Campus Security Report of Disciplinary Actions/Judicial Referrals, reported 36 liquor law violations. Six (6) of the violations occurred in 1996, and should not be included. [(Case #012-964 (4 violations), and Case #015-964 (2 violations)].
Ramapo staff members did conduct a thorough review of our reporting following the departure of the former Director of Security. As a result of that review, we believe that of the 36 reported liquor law violation referrals in 1997, 15 of them (not 6) actually occurred in 1996 and should not have been reported as 1997 incidents (Case #s plus [referrals]: 007-972 [1], 008-972 [1], 013-972 [1], 015-972-A&B [2], 35-972 [1] 42-972 [2], 015-972 [3], 005-974 [2], 22-974 [1], and 23-974 [1]). (The 15 violations in 1996 took place at the end of the Fall semester and were adjudicated in 1997, hence the confusion. 21 is the accurate number of liquor law violation referrals that should have been reported.
One (1) burglary was reported as in residence hall, and should have been reported as on campus (C-810-97).
This is an accurate statement. Our data will be corrected in the 2001 report.
One (1) aggravated assault was reported as public property, and should have been reported as in residence hall (C-134).
This is an accurate statement. Our data will be corrected in the 2001 report.
1998 Calendar Year Statistics -- The Campus Security Report listed two (2) burglaries in residence halls. There were an additional 23 burglaries which were not reported, because they were incorrectly categorized as thefts.
Case # Location
C-002-98 Residence Hall
C-102-98 Residence Hall
C-133-98 Residence Hall
C-202-98 Residence Hall
C-218-98 Residence Hall
C-329-98 Residence Hall
C-438-98 Residence Hall
C-449-98 Residence Hall
C-459-98 Residence Hall
C-640-98 Residence Hall
C-700-98 Residence Hall
C-702-98 Residence Hall
C-806-98 Residence Hall
C-1098-98 Residence Hall
C-1498-98 Residence Hall
C-1477-98 Residence Hall
C-1636-98 Residence Hall
C-1697-98 Residence Hall
C-1773-98 Residence Hall
C-565-98 Campus
C-1223-98 Campus
C-1698-98 Campus
C-025-98 Campus
We believe there were a total of 23 burglaries (not 25) in 1998. It appears the incidents that should have been categorized as burglaries were mistakenly counted in the theft/larceny number that was published in our Security Report. These numbers will be corrected in our next report.
One (1) hate crime that was reported as in residence hall should have been reported as on campus. (Incident Report C-510-98).
This is an accurate statement. Our data will be corrected in the 2001 report.
As previously indicated, three (3) drug arrests were not reported for 1998, as the complainant alleged. They should have been reported as in residence hall.
This is an accurate statement. Our data will be corrected in the 2001 report.
The complainant also alleged that two (2) drug cases that were handled as judicial referrals (Incident Reports C-1210-98 and C-70-98) should have resulted in arrests. The incident reports did not indicate why the Mahwah Police Department was not notified.
These two cases were handled as referrals to the Campus Judicial System and to “Checkpoint” (a formal alcohol/other drug education and treatment program) because it was clear that the students involved had personally used small amounts of marijuana but had no role in distributing the drug. C-70-98 reported an odor of marijuana and the possible residue of a consumed marijuana cigarette. C-1210-98 was reported to former Chief Russ Hoffmann by (then) Chief Inspector, Tim Osborne. It concerned a report of “possible” marijuana smoke and remnants as well as a student’s assertion that another bag contained “acid.” It was Chief Hoffmann’s decision not to call the Mahwah Police, according to Chief Inspector (now Assistant Director of Security, Tim Osborne). The College believes these 2 particular incidents were handled correctly as internal matters given the lack of a chain of evidence upon which the police could act.
The complainant further alleged that numerous incident reports were missing for 1998. This allegation was generally not correct. The College did have copies of incident reports identified in the complaint, although eight (8) of the incident reports were not signed. (Incident Reports C-160-98, C-238-98, C-413-98, C-810-98, C-899-98, C-967-98, C-1312-98, C-1317-98.)
The College did have all the reports required but eight (8) were not signed by the responding officer. A procedure is now in place so that all reports will be signed.
1999 Calendar Year Statistics -- The Campus Security Report listed 16 burglaries. There were an additional five (5) burglaries which were not reported.
Case # Location
C-034-99 Campus
C-419-99 Campus
C-1003-99 Campus
C-1166-99 Campus
C-1882-99 Non-campus Bldg.
It is true that five (5) additional burglaries (discovered during the College’s own internal review and reported to the reviewers on site) should have been reported. The correct numbers will appear in the Campus Security Act report issued later in 2001.
Nine (9) burglaries that were reported as in residence hall should have been reported as on campus. (Incident Reports #C-044-99, C-052-99, C-946-99, C-701-99, C-878-99, C-1159-99, C-1211-99, C-1666-99, C-1705-99).
This is a correct assertion and will be accurately reported in the next edition of the Campus Security Act report.
One (1) drug arrest that was reported as in residence hall should have been reported as on campus. (Incident Report C-1868-99).
This is a correct assertion and will be accurately reported in the next edition of the Campus Security Act report.
Three (3) alcohol arrests that were reported as in residence hall should have been reported as on campus. (Incident Report C-1868-99).
This is a correct assertion and will be accurately reported in the next edition of the Campus Security Act report.
Two (2) aggravated assaults that were reported as in residence hall should have been reported as on campus. (Incident Reports C-595-99, C-857-99).
This is a correct assertion and will be accurately reported in the next edition of the Campus Security Act report.
Crime Data Not Reconciled with Mahwah Police Department
Ramapo College’s Campus Security Officers do not have authority to make arrests. The Mahwah Police Department responds to calls from Campus Security and other staff, and from students. The Mahwah Police also conduct undercover drug operations involving Ramapo College. The College coordinates security activities with the Mahwah Police through periodic meetings with a Police Captain, who is the designated liaison.
The Mahwah Police maintains a dispatcher’s report that lists all calls to the police by location. College officials stated they did not, in the past, reconcile this dispatcher’s report to the daily crime log to ensure that the daily crime log was complete. As a result, there may have been incidents where the police responded, that were not entered on the daily crime log, and were not reported on the Annual Campus Security Report. For example, the dispatcher’s log for 1999 indicates there were two (2) calls for alcohol violations (Case #s 7836 and 22584) and (1) call for burglary (Case #18217) that may have been reportable incidents. It was unclear if these incidents were crimes that should have been reported, or if they resulted in arrests or judicial referrals.
Student Affairs officials meet with the senior leadership of the Mahwah Police Department once or twice per year and talk by phone on many other occasions. The Department’s designated liaison is very receptive to requests for investigative assistance when crimes occur on the Ramapo College campus.
In the past, the College was not aware that it was possible to review the Mahwah “dispatcher’s log” to reconcile our incident numbers and so we had relied on sharing summary data only. Now that we understand that we may view this information, monthly meetings are being established between the Ramapo Security Department, the Ramapo Judicial Affairs Officer, and the designated Mahwah Police liaison to review our daily security log’s contents in relation to the Mahwah Police Department’s dispatcher’s log.
The Mahwah Police Department’s review of the extant cases mentioned above reveals that Case 7836 was a visit by a Police Lieutenant to Ramapo to check whether there were any underage drinkers at an Earth Day event for which the police had approved a request for a State alcohol permit. No violations of law were found. In Case 18217, a car in our parking lot was broken into and the incident was classified by the Mahwah Police as a burglary/theft. Ramapo College classified it as a larceny/theft and reported it as such. Case 22584 did not involve Ramapo College at all.
|
FINDING NO. 2 |
Public Crime Log Not Maintained Before April 1999
Ramapo College maintains a public crime log for the most recent 60 day period. Incidents that are more than 60 days old are transferred to an archive, and maintained for public inspection. The earliest incidents in the archive date from April 1999. There was no evidence the log was maintained before this time, as required by the 1998 Amendments to the Higher Education Act.
Failure to accurately report all of the criminal occurrences required to be included in the Campus Security Report denies students and employees the opportunity to make informed decisions about the relative security of the campus environment and to make personal security decisions.
REFERENCE: Section 485(f) of the HEA, as amended
34 CFR 668.14(c)(2) – Program Participation Agreement
34 CFR 668.47 – Institutional Security Policies and Crime Statistics
34 CFR 668 Appendix E – Crime Definitions
The required archive log for the period between October 1998 and April 1999 was not maintained. The College is currently preparing this archived report and will finish that effort by July 31, 2001.
REQUIREMENT: The College should review the requirements of 34 CFR 668.46 (formerly 34 CFR 668.47) to ensure the accurate reporting of data in the College’s Campus Security Report, and to comply with the other requirements of 34 CFR 668.46.
All aspects of the law’s requirements are being reviewed this summer in preparation for printing the September 2001 report.
The College’s reporting system should include the following:
1. Reconciliation of all incidents reported on the daily crime log to incident reports and final reporting on the Campus Security Report.
The Ramapo Security Office will reconcile all incidents reported in the daily crime log to Security Incident Reports filed and to final reporting in the Campus Security Report.
2. Reconciliations should be performed between the Mahwah Police Department’s dispatcher reports, and the College’s records.
The Ramapo College CLERY Committee will meet on a monthly basis with the Mahwah Police Department to reconcile the Dispatcher’s Log with our public log and with our Incident Reports.
The Public Crime Log should be amended to include reportable incidents between October 1998 and April 1999.
The archived Public Crime Log will be amended to include the reportable incidents between October 1998 and April 1999. This will be completed no later than July 31, 2001.
Additionally, the College must ensure that the necessary corrections are made to any erroneous prior year’s statistics that are included in the current campus Security Report.
Ramapo College will ensure that necessary corrections are made with regard to any erroneous prior year’s statistics that are included in this year’s Campus Security Report.