Update on Enhancements to Texas State’s Clery Act Compliance Program
I write to share an update on Texas State University’s comprehensive efforts to build and sustain a world-class Clery Act Compliance Program. I am pleased to provide this overview of our efforts during the 2019-2020 academic year and to update you on the U. S. Department of Education’s campus crime program review.
As I previously shared, in November 2019, the U.S. Department of Education’s Clery Compliance Division opened an off-site program review to evaluate the university’s compliance with the Jeanne Clery Disclosure of Campus Security Policy and Campus Crime Statistics Act (Clery Act) and the Department’s regulations. That review is ongoing.
The university worked diligently between November 2019 and March 2020 to provide the Department with information about the university’s crime statistics, campus safety and security policies and practices, and the comprehensive efforts we have engaged in to further develop our Clery Act Compliance Program.
Some of the action steps we have taken this year include:
On February 17, 2020, the university welcomed its first Clery Act Compliance Specialist, Ms. Kristina Morales. Ms. Morales previously served as the University Police Clery Compliance Officer at Texas A&M International University, a position she held for almost four years. Ms. Morales will coordinate Texas State’s Clery Act Compliance Program to ensure the university is implementing all aspects of the Clery Act with fidelity. A core part of her role is to ensure consistent processes and collaboration throughout the various departments within the university.
The university also created a new position, Assistant Vice President for Institutional Compliance and Chief Compliance Officer, to oversee all of the university’s compliance obligations under federal and state laws and regulations. Following a national search, the university has selected Mr. Bobby Mason, previously the Chief Compliance Officer and Institutional Equity Officer, Title IX Coordinator, and Equal Opportunity Officer at the University of Oklahoma, as Texas State’s first Chief Compliance Officer. Mr. Mason will join Texas State on May 4, 2020.
Enhanced Policies, Procedures, and Practices
In March 2019, Texas State established the Clery Act Compliance Committee, an interdisciplinary team of stakeholders from offices and departments across the university. The Committee meets regularly to review policies and procedures; review and reconcile crime and disciplinary data from the represented offices and departments and statistical data; and compile the federally required Annual Security and Fire Safety Report. The Clery Act Compliance Committee has strengthened the university’s collaboration among diverse units and departments, which promotes more complete and accurate statistical reporting.
Texas State now has an effective protocol in place to promptly receive, track, and assess Clery-reportable crimes. We have also identified, notified, and trained nearly 1,000 Campus Security Authorities (CSAs) via in-person and online training modules. CSAs are required to forward any reports of crimes that they receive to University Police Department (UPD) by submitting an online Clery Incident Report form.
Texas State has also enhanced its timely warning and emergency notification procedures and process for maintaining the daily crime log. The UPD revised its timely warning and emergency notification general order in fall 2019, and its timely warning and emergency notification assessment form in January 2020. The Clery Act requires a timely warning when the university determines that a reported Clery Act crime poses a serious or ongoing threat to the campus community.
Clery Act Training and Education
In addition to training nearly 1,000 CSAs, the university has provided Clery Act orientation and/or dedicated training sessions for The Texas State University System Board of Regents, senior leadership, UPD members, Department of Athletics coaching and compliance staff, Resident Advisors in the Department of Housing and Residence Life, the Council of Academic Deans, the Clery Act Compliance Committee, the Division of Student Affairs, and the Office of Equity and Inclusion. These educational sessions have included a review of Clery Act reporting responsibilities and the critical reporting elements needed for efficient and thorough Clery Act crime classification and counting. University Clery professionals have also sought and completed professional development training through the Clery Center and other national organizations.
Clery Act Compliance Program Development
In fall 2019, Texas State engaged Margolis Healy and Associates (MHA), a nationally renowned campus safety and security firm, to assist the university in the development of our Clery Act Compliance Program. As a first priority, MHA conducted a complete review of all available Clery data to provide the Department of Education and our community with updated crime statistics. Based on the review and reconciliation process, MHA created new crime disclosure tables for calendar years 2016, 2017, and 2018. Those updated statistics are included in a revised Annual Security and Fire Safety Report (ASFSR), which was distributed to all current students and employees earlier today. In addition, MHA’s work is informing important changes in processes and procedures.
MHA continues to assist the university with building the university’s Clery Act Compliance Program. MHA will provide long-term Clery Act program development assistance and mentoring, including working with the newly hired Clery Act Compliance Specialist to ensure that future documentation and recordkeeping systems are robust and meet federal compliance requirements. Specific steps at Texas State include developing systems for pan-institutional coordination and collaboration, and sustainability. To that end, we have created a dedicated webpage at clery.txstate.edu that centralizes and provides readily accessible information about the Clery Act and the university’s Clery Act Compliance Program.
The university remains committed to providing accurate and complete information to the university community about Texas State’s safety, security, and crime prevention policies, procedures, and programs. While we have made significant progress, there is more to be done. We appreciate the collaborative spirit evidenced across the university, and we welcome the partnership of all university community members as we move forward in our efforts to promote campus safety.
Denise M. Trauth