UTSA's Clery Act Audit
We always want you to be safe and feel safe at UTSA—whether you are in class, in your residence hall, at work, or participating in one of the many campus activities that makes our university the transformative place it should be for all of us. That is why I want you to hear directly from me about some important matters related to campus security.
Today, the U.S. Department of Education’s Office of Inspector General (OIG) released the results of an audit it conducted of UTSA’s campus crime reporting during calendar years 2015-2017.
I want to assure you we are taking this report very seriously and make you aware of some of the many steps we have taken—and plan to pursue moving forward—to address the issues raised in the audit.
Every U.S. college and university that participates in federal financial aid programs is required to publish annual data regarding the number of reported crimes that occurred on or near its campuses as a requirement of the Jeanne Clery Act. The OIG engages in reviews of institutions’ Clery programs and information to ensure they are compliant with this law.
The OIG initiated its audit of UTSA in the fall of 2019 and submitted initial findings to me this past August. As part of OIG’s audit process, we were provided an opportunity to submit a response addressing the issues it identified and to contest findings where warranted. Subsequent to reviewing the information we provided, the OIG has released its final report. Based on these findings and the OIG’s recommended corrective actions, the Department of Education will determine if we will be required to pay any fines.
By way of perspective, several other universities have likewise undergone similar audits to evaluate their controls over their campus crime statistics. The Department of Education also engages in regular and comprehensive institutional reviews of Clery compliance matters.
The Audit’s Findings
The OIG audit found that UTSA inadequately reported 55 of 173 eligible campus crime incidents between January 2015 and December 2017. The final report notes that these inaccuracies were a result of UTSA’s lack of effective processes during the three-year audit period to identify critical information sources, coordinate data collection and track the data. Contributing factors included a lack of management oversight, high staff turnover during the audit period, and misinterpretation of the reporting guidance provided in the Department of Education Handbook for Campus Safety and Security Reporting (2016 Edition).
How UTSA is Addressing the Issues
Since becoming president of UTSA in September of 2017, improving our Clery Act compliance has been one of my top priorities. Our work to address these issues started in early 2018, long before the OIG initiated its review of UTSA in 2019.
Soon after I arrived at UTSA, I became aware of the significant gaps in our processes based on information identified during an internal assessment conducted in 2016. I immediately initiated efforts to overhaul and improve our Clery Act procedures and am glad to report that our current practices no longer reflect those described in the OIG report.
Some of the initiatives and changes we implemented over the last three years include:
- Developing UTSA’s Safe Campus website to provide the campus community with clarity and awareness regarding the processes UTSA has in place to prevent and report sexual violence and misconduct
- Creating a structure to identify, notify and certify training for UTSA’s Campus Security Authorities (CSAs)
- Implementing the ARMS Record Management System to enhance data management and automate UTSA’s daily crime log
- Implementing the Maxient records management system as an intake vehicle for Clery-related issues and to improve tracking and documentation of Title IX-related complaints of sexual violence or harassment
- Establishing a Clery Compliance Committee to provide additional oversight, with representatives from Business Affairs, Student Affairs, Academic Affairs, Inclusive Excellence, the Equal Opportunity Services/Title IX Office, the President’s Office and Athletics
- Taking aggressive and immediate steps to address campus sexual misconduct matters when they arose, in some cases launching thorough independent investigations to ensure all avenues were explored
- Establishing the UTSA Tracy Rule to codify our misconduct policy for student-athletes, the first university in the nation to take this step
- Implementing a practice of regular updates to the campus community regarding our work to prevent sexual assault and misconduct on campus and to raise awareness regarding advocacy services and reporting options
Additional information regarding these actions can be found in our response to the OIG.
On a broader scale, our commitment to providing a safe and welcoming campus environment for all Roadrunners to study, work and live is resolute. My presidential initiatives on Preventing Sexual Assault and Misconduct, Inclusive Excellence and Enriching Campus Wellbeing all aim to advance our efforts, knowing that our work in these critical areas is never “done” but is an ongoing journey where we must challenge ourselves to discover opportunities for improvement and continually strive to be better.
Our campus community is fully committed to continuing to make the investments necessary to build a model Clery Act compliance program here at UTSA. This fall, we hired Margolis Healy and Associates, a national consulting practice with vast Clery Act expertise, to conduct a thorough assessment of our past and current campus security functions. We expect to formally receive this report in the next few weeks and will make it available on our Safe Campus website. The report will help us see where gaps may still exist and makes recommendations for next steps.
We are actively working to implement our consultant’s early recommendations, with additional enhancements on the horizon that will include:
- Training additional qualified staff to become CSAs
- Further developing and/or revising our policies and procedures
- Establishing a Clery Act Data Integrity Working Group that reports directly to our newly formed Clery Compliance Committee
While we have more work to do, I am proud of the significant improvements we have already made to reinforce our institutional commitment to transparency. Clear and accurate crime data reporting is imperative and vital to holding ourselves accountable as an institution while empowering our stakeholders to evaluate our progress.
With your support and collaboration, I know that UTSA will continue to make great progress toward our shared goal of becoming a national model for a focused, institutional commitment to the safety and security of our university community.