College Responds To Clery Investigation Findings

Green River College has released their response to the findings by the Department of Education (DOE) in regards to the Clery Act.

In November 2015, the DOE began an investigation into the college’s Clery Act standards. The Clery Act dictates how crime, fire, and safety statistics are recorded and reported. Last September, the findings of the investigation were released and showed that the college failed in 13 areas and must respond to the findings.

The first finding by the DOE was that the college did not adequately “develop and implement Clery Act and DFSCA-compliant programs during the review period, and the overall compliance program evidences a lack of supervisory oversight and training,” according to the college’s response, available on the website.

The college must develop a plan of action and conduct a self-study during the 2015-2017 calendar years, led by college officials with knowledge of the program.

The response from the college was concurrence, although they did find issue with one aspect of the finding. “GRC disagrees with Finding 1 to the extent that it suggests the College lacks a willingness to comply with federal regulations.”

“The College did have a program including employees (administrators and safety staff) who had program compliance responsibilities and the goal of complying with the relevant federal regulations,” the report states.

Since the audit in 2015, the college has made multiple improvements that include the hiring of a former administrator to assist the vice president of Student Affairs while the self-study was conducted.

The second discrepancy was the failure to produce and distribute annual safety reports (ASR) from the years of 2008 to 2013. This is in part with another finding, finding 4, which outlines concerns with the 2014 annual safety report.

The DOE requested that the college reviews and revises their current policies and procedures that govern the release of the ASR.

Again, the college concurred in response to the finding but disagreed with parts of it. “Prior to the oversight of the VPSA of the Campus Safety and Transportation, that department was under the impression that entering the crime data annually into the CSSDACT was meeting the regulations for doing annual safety reports,” the report said.

In order to rectify this finding, the college has addressed the discrepancies by releasing ASR and Annual Safety and Fire Reports (ASFR) for the years of 2015 and 2016, created a Clery Compliance Committee and set a date for the beginning of corrective actions.

Findings three, four, and five are similar in nature to finding two, dealing with the release and distribution of ASR and ASFR.

The college failed to produce and distribute annual fire safety reports from 2010 to 2013 in finding three.

In finding four, the college failed to release the ASR for 2015 within regulatory timeframes, while finding five was the failure to notify students of the release of the 2014 and 2015 ASR and ASFR’s.
The college also failed to request crime statistics from local law enforcement.

The DOE requested that the college submit copies of correspondence and its request for the statistic from local law enforcement.

Again, the college both concurred and disagreed with the finding.

The college concurred with the fact that the ASFR for 2014 did not have statistics from local law enforcement, but disagrees with the fact that statistics were not properly solicited.

The college will fully comply in the future with the DOE’s criteria for identifying information of each crime, according to the report.

The DOE also a reported a failure to compile and disclose accurate and complete crime statistics on 61 accounts. The college both agreed and disagreed with certain incidents outlined by the Department.

The college concurred with the fact that there was a lack of training and took action to rectify by hiring new safety staff and modified policies concerning the classification of locations to meet Clery regulations.
The college agreed with the Department’s finding eight, that the college failed to properly disclose crime statistics by location.

The Clery Act requires specific location tagging both on and off campus locations.

In response, the college determined non-campus Clery geography, created new maps with the correct Clery geography and will continue to define Clery locations along with proper training for these regulations.
The rest of the findings, eight through 13, the college concurred with, making any adjustments requested by the DOE as well as any others they felt necessary.

A descriptive outline of all of these findings and the response is available on the college’s website under the campus and campus safety sections.

The college can still face fines for these discrepancies. There is a possibility of up to $35,000 per finding, for which there are 13.
This means the college could face up to $455,000 in these fines if the Department of Education decides to do so.