December 17, 2001
Mr. Fred Zook, Ph.D.
President Via Federal Express
Salem International University USA Air Bill #
223 West Main Street, P.O. Box 500 8134584056663
Salem, WV 26426-0500
OPE ID: 00382000
PRCN: 200130318804
Dear Dr. Zook:
On June 11-22, 2001 and August 21-24, 2001, Mr. James Moore and Mr. Fred Wynn, Institutional Review Specialists, conducted a program review focusing on Salem International University’s (the University) compliance with The Jeanne Clery Disclosure of Campus Security Policy and Campus Crime Statistics Act (the Act). The findings of the review are presented in the enclosed report.
Our review disclosed several weaknesses in the University’s campus security operations in general and its approach to the Act in particular. This program review report contains specific findings of non-compliance. These findings are referenced to the applicable Federal laws and regulations. Each finding also sets forth specific corrective actions. These corrective actions are specifically designed to assist the University toward full compliance with the Act and to provide accurate and complete campus security information to the campus community.
In addition to these specific findings of non-compliance contained in this report, our review identified serious weaknesses in the University’s approach to campus security that further complicate full compliance with the Act. Section E contains several recommendations that were developed as a result of our identification of these weaknesses. These recommendations should be incorporated in the development and implementation of a comprehensive corrective action plan.
Please review and provide a substantive response to each finding. The University’s response must state with particularity the causes for the finding, progress on all required corrective actions, and all other specific steps taken by the University to correct these findings. Your response should be sent directly to this office, to the attention of Mr. James Moore within 60 days unless otherwise noted.
This report contains required actions that necessitate the development and implementation of various policies and procedures, as well as, specific amendments to statistics as previously reported for calendar years 1997, 1998, and 1999. It is essential that the individuals charged with the responsibility for administering the provisions of the Act fully understand its requirements and have sufficient resources to implement those requirements.
I would like to express my appreciation for the courtesy and cooperation extended during our site visit. If you have any questions regarding this report, please call the Philadelphia Case Management Team at (215) 656-6442. Your continued cooperation throughout the program review process is greatly appreciated.
Sincerely,
John S. Loreng
Team Leader
Enclosure
Cc: Mr. Stephen H. Maxwell, Director of University Finance
Mr. John Folsom, Director of Campus Security
Mr. Jerry Schearer, Assistant Dean of Students
Institutional Review Data Sheet
Salem International University
Date of Review: June 11-22, 2001; August 21-24, 2001
Years Reviewed: 1997, 1998, and 1999
OPE-ID Number: 00382000
TIN: 550357051
Type and Control: Private, Non-Profit
Accreditation: North Central Association of Schools and Colleges
Reviewing ED Officials: James Moore
Fred Wynn
George Blissman, Special Agent
Office of the Inspector General
Institutional Officials Contacted:
Dr. Ronald Ohl, President
Mr. Stephen Maxwell, Director of University Finance
Mr. John Folsom, Director of Campus Security
Mr. Jerry Schearer, Assistant Dean of Students and Director of Campus Activities
Ms. Jenny Waters, Director of Housing and Residence Life
Dr. Susan Sieber, Director of Student Health Services
Mr. Don Apparius, Dean of Students
Dr. Phyllis Freedman, Director of Campus Library
Non-institutional Officials Contacted:
Mr. E.T. Howell, Chief, Salem Police Department
Mr. Kenneth Yost, City Manager, City of Salem
Mr. C.P. Meathrill, Captain, Salem Police Department
Mr. Michael Koacher, Special Agent, Federal Bureau of Investigation
Mr. George Hess, United States Immigration and Naturalization Service
Mr. Grant Smith, Harrison County Drug Task Force
INTRODUCTION
A. THE UNIVERSITY
independent
university. In 1989, the
institution became an affiliate of the Teikyo Group, an international network
of postsecondary institutions headed by Teikyo University in Japan. At this time it was renamed Salem
Teikyo University. In 2001, the
institution was renamed Salem International University (the University). In the same year, Informatics Inc., a
wholly owned subsidiary of Informatics Holdings Ltd., a Singapore corporation,
purchased the University. The
institution offers Bachelor’s and Masters Degrees in fields such as
Business, Information Technology, Education, and Biotechnology. Currently, the University enrolls
approximately 700 students. Situated on some 138 acres, the University’s campus is comprised
of buildings and facilities on 84 separate parcels at the main location and
throughout the Salem-Clarksburg area.
B. BACKGROUND
In February 2000, Mr. E.T.
Howell, Police Chief, City of Salem Police Department (SPD), contacted the U.S.
Department of Education’s Office of the Inspector General for
Investigations. Chief Howell raised
concerns that University officials were actively frustrating the SPD’s
law enforcement efforts on campus. This allegation included but is not limited to the destruction of
evidence, obstruction, as well as attempts by the University to limit the
SPD’s access to the campus, its employees, and students. He also stated that that he believed
that the University was not in compliance with the crime statistics reporting
requirements of the Jeanne Clery Disclosure of Campus Security Policy and
Campus Crime Statistics Act (the Act).
As an example of these
concerns, Chief Howell detailed an incident that involved the disappearance of
three Chinese youths during a summer student exchange program.
In August 1998, the
University (then Salem Teikyo) hosted a summer youth camp co-organized by the
institution and the Ameson Education and Cultural Exchange Foundation
(Ameson). In addition to the
educational benefit to students, the arrangement also served the economic and
institutional interests of the parties. Namely, the program provided a source of prospective students for the University and a revenue stream for Ameson who received a per student fee.
After arriving in the
United States, three students who were to participate in the exchange through
other institutions entered a waiting vehicle at the John F. Kennedy
International Airport in New York City and were subsequently not seen
again. Local authorities were
notified at the time. Three other
students in the group were to participate in the exchange program through
Salem-Teikyo University and were transported to the campus. Shortly after their arrival on campus,
these youths disappeared from the campus, leaving most of their possessions in
their dormitory rooms. It is
important to note that University officials never formally reported this
incident to any law enforcement agency.
In lieu of reporting the
incident to law enforcement, the University conducted its own
investigation. Based on our review
of available records, it appears that this investigation was limited to an
informal search of University grounds and the surrounding area and telephone
contacts with Ameson. As a result
of its investigation, the University concluded that the youths’ disappearance
was probably pre-arranged, that they were safe, and most likely living with
family members in the United States. Nevertheless, Ameson determined that the incident required some action
and severed its association with the recruiting agent that arranged the missing
student’s participation in the exchange program. During the course of its investigation,
it appears that the role of the recruiting agent in the disappearance or the
possibility that the youths were the victim of false pretenses or deception was
not considered or examined. The
University is still unable to provide any substantive evidence that these
youths did not meet with foul play.
By their own means, the
Federal Bureau of Investigation (FBI) and local law enforcement authorities
eventually learned of this incident in October 1998 and attempted to ascertain
the facts for themselves. However,
due in no small measure to the University’s failure to report, the
FBI’s inquiries were inconclusive. As of the date of this program review report, the
United States Immigration and Naturalization Service has not been able to
verify the location of the youths in question.
Although it is unlikely
that this event would have resulted in any mandatory reporting under the Act,
the University’s reluctance to notify the proper investigative agencies
lends credence to allegations that campus criminal matters are not properly
documented, reported, or investigated. Based on the preceding as well as information developed by the
Philadelphia Case Management Team and the Office of the Inspector General –
Investigations, it was determined that a program review focused on campus
security was called for in this case.
A program review was conducted from June 11-22, 2001 and from August 21-24, 2001, to examine the institution’s compliance with the Jeanne Clery Disclosure of Campus Security and Campus Crime Statistics Act (the Act). Specifically, our stated objective was to determine the accuracy and completeness of campus crime statistics and policy disclosures as published in the University’s Campus Security Reports for calendar years 1997, 1998, and 1999. While our procedures provide for the identification of indications of fraud and misuse, the program review is an administrative monitoring activity, not an audit or criminal investigation. The program review team examined the institution’s records related to campus security including incident reports maintained by the Office of Campus Security and the Office of Student Affairs. Additional documentation from the Judicial Board and Student-Faculty Conduct Committee records for current and former students were also reviewed. Several hundred hardcopy records were analyzed during this program review.
Information was requested from various other offices. However, little documentation was available regarding their role in the campus security process. These offices include the Office of Health Services and the Office of the Registrar. Representatives of these offices stated that they had no documentation relevant to our review. The Housing and Residence Life Office (HARLO) made only minimal documentation available for our review. Additional documentation including HARLO training materials, policy and procedure manuals, and various memoranda and notes were also examined. Available records from the City of Salem Police Department, including incident reports, patrol logs, and other documents were analyzed as well. It is important to note that the SPD’s records were not systematically organized for the years under review. However, the current Chief of Police and the City Manager have instituted new procedures that will provide for more complete records in the future.
In addition to the review
of documents listed above, the review team also contacted 23 current and former University employees as well as
current and former students to further ascertain the institution’s
compliance with the Act. The
interviews conducted with these individuals helped the case team obtain a more
complete picture of institutional policies and practices related to campus
security. Many of these
individuals are not identified on the Institutional Review Data Sheet at their
request. Throughout the program
review process, Special Agent George Blissman of the Office of the Inspector
General – Investigations provided valuable assistance to the program
review team.
During the review, several areas of non-compliance were noted. Many of these findings and the circumstances under which they arose have caused special concern for the program review team. Therefore, the University is advised to answer the issues noted in this program review report in as accurately, completely, and timely a manner as possible. The review team will carefully analyze the University’s response and initiate appropriate action. Such action may include a formal referral of this matter to the U.S. Department of Education’s Office of the Inspector General – Investigations or the Department’s Office of Administrative Actions and Appeals. The Office of the Inspector General – Investigations will make a separate determination as to whether or not additional action is appropriate. Such actions may include a criminal investigation and/or a referral to the Office of the United States Attorney.
Findings of non-compliance are referenced to the applicable statutes and regulations and specify corrective actions that must be taken to bring campus security operations into compliance with the statutes and regulatory provisions of the Jeanne Clery Disclosure of Campus Security Policy and Campus Crime Statistics Act.
Although the review was thorough, it cannot be assumed to be
all-inclusive. The absence of
statements in this report regarding the University’s specific practices
and procedures must not be construed as acceptance, approval, or endorsement of
those specific practices and procedures. Furthermore, nothing in this report shall relieve the University of its
obligation to comply with all statutory and regulatory provisions governing the
Title IV Programs.
C. FINDINGS AND REQUIREMENTS
FINDING # 1: LACK OF ADMINISTRATIVE CAPABILITY
The General Provision Regulations that govern the Title IV, Student Financial Assistance Programs establish certain standards that all participating institutions must maintain if they are to deemed administratively capable. During the campus security program review, several significant exceptions were identified that call the University’s ability or willingness to comply with the Act into serious question. This finding reinforces and supplements a similar determination regarding our review of the University’s administration of the Title IV, HEA, Student Financial Assistance Programs (see our August 13, 2001 report – PRCN: 200130318775). The following serious findings detail multiple indications that the University lacks an adequate system of internal controls and administrative capability:
2. Failure to Report Specific Incidents;
3. Miscoding of Specific Incidents;
4. Failure to Coordinate Information from All Sources;
5. Failure to Issue Timely Warnings;
6. Failure to Report Hate Crimes in Prior Reports;
7. Failure to Distribute the Campus Security Report in Accordance with Federal Regulations; and,
8. Required Policy Statements Omitted or Incomplete.
In addition to these
specific findings of non-compliance, the review team identified numerous
conditions that cause special concern with regard to the University’s
commitment to an effective campus security operation and compliance with the
Act. The program review team feels strongly that the following concerns have directly contributed to the findings identified in this program review report:
1. The annual budget for the Office of Campus Security is insufficient to meet the security needs of the University. Specifically, the Office of Campus Security’s annual budget for Fiscal Year 2000 was $2,075. Total enrollment during fiscal year 2000 was approximately 625 students. Therefore, the budgetary appropriation for the Office of Campus Security amounted to less than $4.00 per student. With the exception of employee wages, this amount is intended to fund all Office of Campus Security operations including equipment, uniforms, supplies, and repairs. During the site visit, the Director of Campus Security stated that his budget was nearly exhausted as of June 2001. The review team found no variance in expenditures for this fiscal year that might account for the shortfall. Therefore, the review team is forced to conclude that the Office of Campus Security operates with few resources as a matter of course.
2. The annual salaries of the Office of Campus Security staff are exceedingly low and are not sufficient to attract and retain high quality personnel. The University has been fortunate to retain 3 experienced staff members. However, the Director has been authorized to only offer newer hires full-time temporary positions at or near the minimum wage. As such, turnover and low morale have become a serious issue. Currently, only the Director receives an annual salary of over $20,000.
3. As of the time of this program review report, the Security Department consists of four officers, and only three of these officers are routinely involved in regular security patrols. This makes it very difficult for the Security Department to provide effective 24-hour, 7-day coverage. All relevant University publications clearly state that the Office of Campus Security is on duty around the clock.
4. Campus Security personnel are frequently required to perform tasks unrelated to campus security. Such requirements reduce the amount of security coverage on campus and hinder the Security Department’s ability to carry out their required duties. For the years under review, additional duties of campus security personnel included:
· Delivering mail to the main post office;
· Installing telephone and Internet cables;
· Answering telephones;
· Picking up items for the Business Office;
· Picking up money for the Snack Bar;
· Assisting the Physical Plant;
· Working on the SIU cooling system if needed; and
·
Picking up newspapers and watering the lawn for the university president while the president is out of town.
Impaired administrative capability increases the likelihood that the applicable statutes and regulations that govern the Title IV Programs will not be followed. With regard to the Act, such an impairment may result in the campus community being deprived of important security information. Impaired administrative capability and weak internal controls are an indication that an institution lacks the ability or willingness to comply with Federal regulations.
REFERENCE:
34 CFR § 668.14, General Provision Regulations, as amended, June 22, 2000
34 CFR § 668.16, General Provision Regulations, as amended, November 1, 1999
34 CFR § 668.46, General Provision Regulations, as amended, November 1, 1999
REQUIREMENT:
To continue participation
in any Title IV, Higher Education Amendment (HEA) program, an institution must
demonstrate that it is capable of adequately administering the program under
the standards established by the Secretary. The Secretary considers an institution to have
administrative capability if it: administers the Title IV, HEA programs in
accordance with all statutory provisions of, or applicable to, Title IV of the
HEA, and all applicable regulatory provisions prescribed under the statutory
provisions; has written procedures for or written information indicating the
responsibilities of the various offices. These standards apply to all aspects of the Title IV Program regulations
including the provisions of the Jeanne Clery Disclosure of Campus Security
Policy and Campus Crime Statistics Act at 34 CFR § 668.46.
As a result of this
finding, the University is required to take all necessary corrective actions to
cure the exceptions identified in this program review report. In addition, the University must
develop and implement a comprehensive system of policies and procedures to
ensure that these findings do not recur. Additional instructions on this comprehensive review are outlined in the requirement for finding # 2.
Based on our evaluation of
all available information, the Philadelphia Case Management Team will determine
appropriate additional actions and advise the University of these in our Final
Program Review Determination letter.
FINDING # 2: FAILURE TO REPORT SPECIFIC INCIDENTS
A. Incidents not Reported
The institution failed to report all required incidents in its 2000 Campus Security Report. For the crime category of Forcible Sex Offenses, the University reported “0” incidents for all years under review. It should be noted that, since the inception of the Act, the University has never reported a sex offense in its Campus Security Reports. The review team acquired documentation that clearly shows that the University knew about the incidents in the chart below. Based on information developed by the review team, we have determined that there exists a high likelihood that additional incidents of this type occurred and that appropriate documentation was not provided for our review or was never generated in the first place.
DATE OF
INCIDENT
|
TYPE OF
INCIDENT |
INCIDENT REPORT FILED (Y/N) – DATE |
|
10/30/1997 |
Forcible Sex Offense |
Yes; 10/30/1997 |
|
11/01/1997 |
Forcible Sex Offense |
Yes; 11/01/1997 |
|
05/07/1998 |
Forcible Sex Offense |
Yes; 05/07/1998 |
|
09/02/1998 |
Forcible Sex Offense |
Yes; 09/02/1998 |
|
09/18/1999 |
Forcible Sex Offense |
Yes; 09/18/1999 |
Documents acquired by the review
team clearly illustrate that University officials were aware of these
incidents. These documents support
the review team’s determination that the following offices that have responsibility for reporting under the Act were aware of the above referenced incidents:
Date of Offense Individuals/Offices Aware of Offense
10/30/97 Campus
Security; President’s Office; Dean of Students
11/01/97 Campus Security
05/07/98 Campus
Security; President’s Office; Dean of Students; Director of Housing and Residence Life
09/02/98 Campus
Security; President’s Office; Dean of Students; Director of Housing and
Residence Life; Provost’s Office
09/18/99 Campus Security; Dean of Students; Director of Housing and Residence Life
The institution was unable
to fully explain why none of these incidents was included in the Campus
Security Report. During an
interview on June 13, 2001, the SIU Director of Campus Security said no sexual
assaults were reported to his office for “the past few years”. He explained that, four years ago,
there was an incident where the student “may have gone directly to the
Salem Police Department.” He
said he was not aware of any incidents of sexual assaults on campus since then. On October 16, 1998, the Director of
Campus Security told Special Agents Robert G. Koehler and Lawson B. Allen of
the Federal Bureau of Investigation that there were two sexual assaults at the
institution “over the last two years”. Specifically, he mentioned that he heard that there had been
a rape on campus on October 2, 1998. The review team found no evidence that the Office of Campus Security or
any other University office did any follow-up work, made any inquiries, offered
any assistance to the alleged victim, or made any contacts to ascertain the
details of the incident. However,
the review team was unable to locate any documents regarding this case and so
no details are included herein. During an August 21, 2001 interview, the Director of Campus Security told the review team that he did not recall making the above statement to Special Agents Koehler and Allen.
After seeing copies of incident reports for some of the incidents listed above, the Director of Campus Security offered the following explanations:
With respect to the
November 1, 1997 incident, it is important to note that the Director of Campus
Security is a former Chief of Police for the City of Salem. As a former chief, the Director should
be familiar with the Uniform Crime Reporting System requirements. Moreover, as Director of Campus
Security and as the official principally responsible for Clery Act reporting,
the Director should be aware that the inclusion of this incident on both
reports would not result in duplicative disclosure. With regard to the September 18, 1999 incident, the
Director, once again as the designated official for Clery Act reporting, should
have known that statistics in the Campus Security Report represent
“incidents of crimes reported” to a campus security authority or
law enforcement. In our
interviews, the Director did not claim to be unaware of these incidents. In addition, the review team is aware
that University personnel with Clery Act reporting responsibilities attended a
training session that covered these requirements. Indeed, the review team has acquired copies of the training
materials from this session that clearly set forth the Act’s reporting
requirements.
In each of the five
forcible sex offenses listed in this finding, the review team located
documentation of these incidents in the files maintained by the Office of
Campus Security. These files are
one of the main sources of information used to compile the Campus Security
Report. During the program review,
several current and former employees of the University’s Office of Campus
Security stated that it was not possible for the Director to not be aware of
incidents where an incident report was generated. Moreover, given the inconsistent and at times contradictory
reasons given as to why the incidents were not included in the Campus Security
Report, the review team must consider the possibility that the omission of
these incidents may have resulted from the deliberate and/or willful acts of
one or more University officials. The review team will make that assessment based on our review of the
University’s response and other available information.
Please be advised that the
review team will carefully analyze the University’s response to this
finding of non-compliance and initiate appropriate action. Such action may include an additional
referral for violations of the Campus Sexual Assault Victims’ Bill of
Rights Act of 1992.
B. Under-Reporting of Incidents
In addition to the failure to report certain categories of crime, the University also under-reported certain incidents of crime. Due to systemic weaknesses in the record keeping used by the relevant offices, it is impossible to determine which incidents were used to arrive at the statistics in the Campus Security Report and which were omitted. During our site visit, the review team requested that the Director of Campus Security provide the specific documentation that served as the basis for all statistics as published in the Campus Security Report. The Director was unable to document a substantial audit trail for these statistics. The following chart details the under-reporting problem with respect to the crime category of burglary:
|
Year |
Category |
Number of Incidents Reported |
Actual Number of Incidents |
|
1997 |
Burglary |
0* |
16 |
|
1998 |
Burglary |
5 |
14 |
|
1999 |
Burglary |
11 |
26 |
* No burglaries were reported for 1997. This category is included here and not in Part A of this finding because some of these incidents may have included on the report as larcenies (which are not required to be reported).
It appears that several factors contributed to this case of under-reporting. These factors include but are not limited to the following:
· Poorly Written and/or Incomplete Incident Reports;
· No Systematic Compilation or Maintenance of Incident Reports and other records;
· Inclusion of Categories of Crime, such as Larcenies, not Required by the Act;
· Poor Training of Security Staff; and,
· Lack of Adequate Administrative Oversight.
Within the crime category of burglary, many incident reports contain information that clearly meets the UCR definition of a burglary but were coded as “stolen property,” “theft,” “Cubes” (a reference to a specific residence hall), or were simply not coded at all. Additionally, incident reports are not stored in any routinized manner that provides for adequate custody, control, or easy reference of relevant documents. It is also clear that security officers have not been given adequate training on report writing or incident classification. Additionally, it is clear that the Director of Campus Security has not been given the administrative authority and resources necessary to develop and implement a comprehensive system of quality controls.
Failure to include all required statistics in the Campus Security Report deprives the campus community of important safety and security information and effectively negates the intent of the Act. Such failure may cause readers of the report to have an incomplete perspective of campus security, which may result in persons not taking all necessary steps to provide for their own safety.
REFERENCE:
Appendix E to Part 668 – Crime Definitions in Accordance With the Federal Bureau of
Investigation’s Uniform Crime Reporting Program
REQUIREMENT:
Federal regulations
require that participating institutions compile and publish accurate and
complete statistics concerning the occurrence on campus of the following
incidents: murder, manslaughter, sex offenses, robbery, aggravated assault,
burglary, motor vehicle theft, and arson. Statistical disclosure of arrests and disciplinary actions related to
violation of Federal or state drug, liquor, and weapons laws are also required. Certain policies and procedures are
required to be published in the Campus Security Report as well. The Act also requires the Campus
Security Report be distributed to all current students and employees and that
prospective students and employees are advised of it availability. To comply with these requirements, it
is absolutely essential that all incidents of crimes on campus that are
reported to a campus security authority or law enforcement are included in the
Campus Security Report.
In response to this
finding, the University must conduct a comprehensive review of its campus
security policies and procedures with specific attention to the coding of
incidents, the collection and compilation of data, the production of the
report, and its distribution. This
assessment must be used as the basis for the development of a substantive
corrective action plan. This
corrective action plan must state with particularity the causes of
non-compliance in past reports, the specific steps that will be taken to
address these weaknesses, and all new processes and procedures. This plan must also provide for an
adequate audit trail for all published statistics as well as proper custody and
control of data. Additionally, the
corrective action plan must also delineate all responsible parties with regard
to data collection and analysis, production, publishing, and distribution of
the Campus Security Report.
This plan must accompany
the University’s response to this program review report. Once the corrective action plan is
reviewed and approved by the review team, the University will be required to
prepare and distribute a supplemental Campus Security Report for calendar years
1997, 1998, 1999, and 2000.
In our Final Program
Review Determination letter, the Philadelphia Case Management Team will advise
the University of additional actions that will be pursued as a result of the
non-compliance identified in this finding.
FINDING # 3: MISCODING OF SPECIFIC INCIDENTS
The University did not properly code the incidents listed on Appendix A. As a result, the statistics for certain crime categories were not accurately disclosed in the University’s Campus Security Report. The causes and effects of this finding relate closely to those identified in finding # 2B. In many cases, incident reports were not filed out in an accurate and complete manner. In other cases, incident reports were coded with little or no adherence to the crime definitions set forth in the Uniform Crime Reporting (UCR) System. And in still other cases, the incidents were not coded at all. The task of writing and reviewing incident reports is often delegated to students or employees with no training. Many of these reports are written in the form of first-hand or eyewitness accounts, with no coding or addenda by the Campus Security Office. This is true even though the stated policy of the Office of Campus Security is that an actual incident report should be generated for all cases. Moreover, the review team was forced to make an independent determination of which incident reports were used to compile the statistics in the Annual Campus Security Report. The institution was unable to demonstrate how it calculated the report’s statistics.
Because the
University’s approach to compiling Campus Security Reports relies so
heavily on the quality of hardcopy, hand-written incident reports, it is
essential that these records be completed, maintained, and reviewed with the
utmost care. Based on our review,
it is clear that this has not been happening in this case. This failure led to inaccurate and
incomplete data being disseminated to the campus community in Campus Security
Reports.
This condition deprives
the campus community of important safety and security information and may
inhibit the reader’s ability to make informed security decisions, and
thus negates the intent of the Act itself.
REFERENCE:
Disclosure of Campus Security Policy and Campus Crime Statistics Act,
20 USC § 1092 (f), as amended
Section 485 (f), Higher Education Act, as amended
34 CFR § 668.46(b), General Provision Regulations, as amended, November 1, 1999
34 CFR § 668.46(c), General Provision Regulations, as amended, November 1, 1999
REQUIREMENT:
Federal regulations require that participating institutions compile and publish accurate and complete statistics concerning the occurrence on campus of the following incidents: murder, manslaughter, sex offenses, robbery, aggravated assault, burglary, motor vehicle theft, and arson. Statistical disclosure of arrests and