The U.S. Department of Education (DOE) did not publish a new edition of The Handbook for Campus Safety and Security Reporting in 2017; however, that did not slowdown the Trump Administration from refining the terms of Clery Act compliance.
On April 20, 2017, the DOE enacted an increase in the Clery Act violation fines that nearly doubles fines to $54,789 per violation.
Subsequently, in September the DOE made significant changes by merging the Clery Act with Title IX of the Education Amendments of 1972. Though the Clery Act is historically known for requiring institutions to report annual crime statistics, there are also regulations that address sexual violence and emergency management.
As a result, Campus Safety Magazine hosted a webinar entitled The Clery Act’s Emergency Communications Requirements: Five Steps to Compliance to help you and your university avoid the increased fines while keeping the campus community safe. From this webinar, here are three of the most important steps we think universities should focus on in 2018:
1. Understand the Clery Act requirements for Timely Warning and Emergency Notification.
Steve Goldman, a crisis management expert and lecturer at Massachusetts Institute of Technology (MIT), and Suzanne Blake, manager of the MIT office of emergency management and business continuity, break down the warning and notification requirements in this table:
| Criteria | Timely Warning | Emergency Notification |
| WHAT | Crimes that continue to pose a threat. | Any significant emergency or dangerous situation that poses an immediate threat to the health or safety of students or employees. |
| WHERE | On-campus, non-campus, and public property that falls in your Clery Act geography. | On-campus only (includes on-campus “public property” that falls in your Clery Act geography). |
| WHO | Entire campus community. | Can be tailored to the segment of the community that is threatened. |
| WHEN | Sent when enough information is available to adequately describe the threat. | Sent immediately upon confirmation of the threat.
|
2. Create clear, defendable policies and procedures
The Handbook for Campus Safety and Security Reporting states that your emergency response and evacuation procedures must include a description of the processes you will use to:
- Confirm there is an emergency or dangerous situation.
- Determine the appropriate audience to alert.
- Determine the message content.
- Disseminate notifications to the campus community.
- Test procedures and document the results (at least annually).
3. Implement procedures and document them in your Annual Security Report
Universities are required to publish an annual security report that contains safety- and security-related policy statements, along with crime statistics. This report must be distributed to current students and employees. Likewise, prospective students and employees must be informed about the availability of the report.
It is important to note, emergency communications are not complete just because the plans are written and published. The Clery Act makes universities responsible for reflecting on their current plans and operations in an effort to stimulate discussions about changes that could be made to further ensure the safety of their campus community.
