Campus SaVE Compliance: A Workbook for Creating & Implementing Your Campus SaVE Program
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About this ebook
By the end of this workbook, you will have the basis for a VAWA/Campus SaVE Compliance Portfolio that includes all required policies, procedures and documents.
As part of the 2013 reauthorization of the Violence Against Women Act (VAWA), the Campus Sexual Violence Elimination (SaVE) Act was added, and as of July 2015, every academic institution that disseminates Title IX federal funds is required to implement a Campus SaVE Program. Compliance with these laws is essential to ensuring your institution of higher education remains eligible to disseminate Title IX funds in the form of student loans.
This workbook uses the accelerated Done In A Day® model to prepare plans and materials that need to become operational immediately. Each chapter includes:
• Sample language
• Outlines of content that must be included in specific documents
• Action items designed to facilitate the preparation of essential materials
• A list of resources, including documents in the public domain that can be adapted and modified for use at your institution
Campus SaVE Compliance: A Workbook for Creating & Implementing Your Campus SaVE Program, by Dr. Peggy M. Jackson, contains all the key components necessary to implement your Campus SaVE Program and ensure your institution complies with VAWA/Campus SaVE.
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Campus SaVE Compliance - Paul C. Jackson, DM, PE
CHAPTER 1
INTRODUCTION
Two very important laws serve as the basis for the structure and content of this workbook: the Clery Act and the Violence Against Women Act (VAWA). As part of the 2013 reauthorization of VAWA, the Campus Sexual Violence Elimination (SaVE) Act was added, and as of July 2015, every academic institution that disseminates Title IX federal funds is required to implement a Campus SaVE Program. Compliance with these laws is essential to ensuring your institution of higher education remains eligible to disseminate Title IX funds in the form of student loans.
While putting together the policies, procedures and best practices to come into compliance - and remain in compliance - is not difficult, it may seem daunting. Placing it on the back burner, however, is not an option.
The Done In A Day® (DIAD) method of planning and compliance used in this workbook is an important means by which you can accelerate the process. DIAD emphasizes a structured preparation time that concentrates on assembling the plan and developing strategies for execution. With DIAD, no paralysis by analysis
is allowed! The preparation time is structured to identify the data, information and other resources necessary to make things happen. Decision-making is compressed to accelerate the completion of tasks.
Because compliance planning for VAWA/Campus SaVE follows a specified inventory of policies, procedures and best practices outlined by the federal government, public-domain documents can be adapted and modified. That’s why this workbook focuses on what policies and procedures need to be in place, who are the key players in implementation, and how to most effectively present important information to students and employees. We call the collection of written materials - including policies, procedures and educational materials - the VAWA Compliance Portfolio
; it will contain everything you need to get and keep your institution in compliance. This workbook will help you put together your portfolio.
JEANNE CLERY ACT
The Crime Awareness and Campus Security Act was passed into law by Congress in 1990 in response to the 1986 rape and murder of Jeanne Clery, a 19-year-old student at Lehigh University in Pennsylvania. The law was subsequently renamed the Jeanne Clery Disclosure of Campus Security Policy and Campus Crime Statistics Act. The person who attacked Clery, now serving a life sentence, was also a Lehigh student who was not known by Clery prior to the assault.
The Clery Act requires colleges and universities to do the following:
Disclose their security policies; the VAWA/Campus SaVE Act has stipulated additional policies to be disclosed and described.
Keep a public crime log.
Publish an annual crime report, called the Annual Security Report and more commonly known as the Clery Report.
The report must be published every year by Oct. 1. All students must receive a letter or e-mail from the institution advising them when the current report is ready for review. Many colleges and universities post their current Clery Report on their website.
Provide timely warnings to students and campus employees about a crime that poses an immediate or ongoing threat to them. Most institutions now provide warnings via text message. Students are either strongly advised or required to sign up for these text messages.
The law also ensures certain basic rights for victims of campus sexual assaults, and it requires the US Department of Education to collect and disseminate campus crime statistics. Under the Clery Act, an institution is required to disclose crime incidents that occur in any of three geographic categories: on campus, on public property within or adjacent to campus, or in noncampus buildings or property owned or operated by the school.
VAWA: 2013 REAUTHORIZATION
With the reauthorization of the Violence Against Women Act (VAWA) in 2013, President Barack Obama also signed the Campus Sexual Violence Elimination (SaVE) Act. Campus SaVE amended the Clery Act to address implementation of new policies and data collection related to sexual violence. Campus SaVE requires all institutions that participate in federal student-aid programs to improve reporting about the scope of sexual violence on campus, guarantee enhanced rights for victims, provide for standards in institutional-conduct proceedings and provide campus-wide prevention-education programming.
The intent of the Campus SaVE Act is to strengthen the Clery Act to more effectively address - and ultimately reduce - sexual violence on college campuses, including domestic violence, dating violence and stalking. Because the Clery Act requires institutions to comply with campus safety- and security-related stipulations as a condition of receiving federal funds, amending it to include Campus SaVE Act requirements helps ensure compliance.
The VAWA/Campus SaVE Act requires the annual Clery Report to include descriptions of new policies and procedures relating to sexual-assault crimes and victims’ rights. It also adds to the types of crimes that need to be reported. Listed crimes include: sexual assault, domestic violence, dating violence, stalking, murder, manslaughter, robbery, aggravated assault, burglary, motor-vehicle theft and arson. Institutions are also required to report hate crimes, specifically, as crimes of prejudice. These crimes include larceny-theft; simple assault; intimidation; destruction, damage or vandalism of property; and other crimes regarding bodily injury when the victim was selected based on gender, sexual orientation, race, ethnicity, disability or religion.
The VAWA statutory provisions went into effect in October 2014, and the US Department of Education expects institutions to be making a good-faith effort to fully comply with those requirements - immediately.
COMPLIANCE EXPECTATIONS
Fortunately, the expectations for compliance with the amended Clery Act and VAWA are spelled out clearly in the materials created by the federal government. These materials can be found on the White House Task Force to Protect Students from Sexual Assault website, www.notalone.gov; the US Department of Education website, www.ed.gov; and on various commercial websites. This workbook synthesizes the extensive information available in the public domain, so you can concentrate on building an effective Campus SaVE Program rather than on spending all your time researching sample information. The information on compliance presented here is exclusively from public-domain sites, including those of the White House, the Department of Justice and the Department of Education, as well as the California State University website, www.calstate.edu.
An important expectation that is not always made clear in the government documents is that Campus SaVE requirements include employees, as well as students. This means the institution’s director of human resources and Title IX coordinator need to work collaboratively to ensure compliance. (We discuss their specific responsibilities in Chapter 2.) All students and all employees need to know the following:
What defines prohibited behavior
How to