Want to Avoid Large Fines? Start Preparing Next Year's Annual Security Report Now
October 22, 2018
Earlier this month, the U.S Department of Education (ED) said it intended to fine the University of Montana (UM) nearly $1 million for Clery Act violations. During an investigation that began in 2011, ED found that UM failed to publish accurate crime statistics in multiple Annual Security Reports (ASR) starting in 2009.
The $966,614 fine is the second largest ED has imposed on a university, only behind Pennsylvania State University and the $2.4 million it was fined following the Jerry Sandusky scandal. Clery Act fines, originally $25,000, currently stand at $55,907 per violation.
An institution’s ASR is vital to demonstrating Clery Act compliance. Satisfying myriad reporting requirements takes time and money, which can cause issues for resource-stretched campus security departments. However, you can take action now to avoid last-minute headaches and help prove your institution's compliance with Clery.
- Ensure your institution’s recently-issued ASR meets compliance standards. It’s imperative that those preparing the ASR are familiar with the "Handbook for Campus Safety and Security Reporting." And, because of the length of the handbook and the complexity, it may be prudent to have legal counsel review your report.
- Make provisions for individual ASR's if your institution has any “separate campuses.” Every campus should have its own ASR, or a single ASR which covers all campuses as long as it distinguishes between campus differences in policy, procedure, and programming.
- Prepare for 2019 by collecting 2018 crime statistics. The ASR you submitted on Oct. 1 included statistics from the past three calendar years (2015-2017). Get a head start on next year's report by compiling crime statistics from 2018 now.
Annual Security Report: 10 Questions to Ensure Compliance
Understanding the Clery Act Online Training