Last Friday, the U.S. Department of Education announced that it is seeking to impose on Penn State University a record fine of nearly $2.4 million for Clery Act violations in the highly publicized Sandusky case.
Passed by Congress in 1990, the Clery Act requires colleges and universities participating in federal financial aid programs to track and disclose information about crime on or near campus. The Department of Education is required by law to conduct periodic reviews of an institution’s compliance with the Clery Act. Until now, the highest fine was given out in 2007 when Federal Student Aid assessed a fine of $357,500 against Eastern Michigan University for Clery Act violations. Under a settlement, Eastern Michigan University paid a fine of $350,000.
In my role with the Partner Alliance for Safer Schools (PASS), I have become familiar with campus safety compliance issues. As I read the findings, I discovered an interesting twist that may trickle down to our members completing work in schools. What it boils down to is this: A Department of Education investigation of any potential violation can trigger a complete inspection of the safety and security procedures at that school or campus. These reviews may be initiated when a complaint is received, a media event raises concerns, a school’s independent audit identifies areas of non-compliance, or for many other reasons.
Penn State University, like many colleges and public high schools, is located in a designated safe and drug-free school zone, which makes federal funding for certain programs available. The Department of Education investigators – while on campus reviewing the scandal – turned their attention to compliance regulations under the funding provisions. They immediately added 11 additional violations, including:
- Failure to properly train staff
- Inadequate security reporting methods
- Failure to properly notify students of incidents
- Lack of systems for reporting situations on campus
- Non-compliant reporting methods
Why is this important to other schools? How can a systems integrator be a trusted advisor on this? We have an obligation to not only manufacture, design, sell, install, and service the communications, security, and life safety systems for schools, but also help colleges and public and private schools understand guidelines and best practices for the use of that system.
Taking this one step further, many schools use federal, state, or local tax dollars to afford the purchase of these systems, and/or they agree to certain designations that allow grant money to fund projects. I believe that – just as much as we need to be technology experts – we should help these facilities better understand the obligations of the codes, regulations, and laws. That’s a lot of additional responsibility. But I know that many of our members are well equipped to handle this, and have helped schools comply with practices and procedures as part of their value-added relationships.
I stated earlier that a “media event” can raise concerns and trigger investigations. Think of how many incidents are taking place on K-12 and college campuses today. If this trend continues, many of the schools our members work with will find themselves defending a compliance audit of some type.
We can do our part by:
- Learning the applicable codes
- Using the PASS guidelines
- Conducting risk assessments
- Becoming educated on requirements of designated zones
- Knowing the Clery Act
- Using system analytics to generate reports that add to compliance
It’s a lot to know, but integrators can add greater value each time they learn something new that supports the technology they provide and the clients they serve. –Chuck Wilson, NSCA Executive Director
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