Report 2022-109 Recommendation 14 Responses

Report 2022-109: California State University: It Did Not Adequately or Consistently Address Some Allegations of Sexual Harassment (Release Date: July 2023)

Recommendation #14 To: University, California State

To assist campuses in providing a harassment-free environment for their students and employees, the Chancellor's Office should, by July 2024, create a policy—such as an attachment to its sexual harassment policy—for conducting regular compliance reviews of its campus Title IX offices to determine whether they are complying with relevant portions of federal law, state law, CSU policy, and best practices for preventing, detecting, and addressing sexual harassment and related misconduct. The Chancellor's Office should publicize the results of these reviews to the extent possible considering confidentiality concerns, and it should similarly publicize any steps it has taken or plans to take to address areas of concern it identifies. In preparation for performing this work, the Chancellor's Office should determine the number of additional staff that it will need to conduct these reviews.

1-Year Agency Response

In June 2024, the Chancellor's Office updated its Nondiscrimination Policy with an attachment on Title IX / Discrimination, Harassment, and Retaliation (DHR) Program Compliance Reviews. The Chancellor's Office will conduct regular compliance reviews of the Title IX / DHR programs of each university campus. These reviews will be conducted by a systemwide director for civil rights in partnership with the university campus under review. The review will be undertaken at least once every three years.

Beginning in Fall 2024, four to five university campuses will be reviewed in each of the next five consecutive semesters. The sixth consecutive semester will be used by the Chancellor's Office to write a comprehensive, systemwide report of the findings from the compliance review cycle. The first round of reviews is anticipated to be completed by February 2025.

Upon completion of the compliance review process, the Chancellor's Office shall create a comprehensive report of the aggregate results to be published online, while maintaining appropriate confidentiality and privacy.

California State Auditor's Assessment of 1-Year Status: Partially Implemented

The Chancellor's Office's updated attachment for compliance reviews states that it will conduct regular compliance reviews of Title IX/DHR programs of each university campus to be completed at least once every three years. The updated attachment indicates that the compliance review will determine whether the campuses' practices are in alignment with Nondiscrimination Policy, state and federal law, and best practices for identifying, preventing, and addressing sexual harassment and related conduct. The attachment also indicates that the Chancellor's Office shall create a comprehensive report of the aggregate results to be published online, while maintaining appropriate confidentiality and privacy. It further indicates that the report will include any identified action items or steps taken to address identified areas of concern. The Chancellor's Office also provided an organizational chart and assignments for the staff that will conduct these reviews. Now that the Chancellor's Office has established this process, we will assess this recommendation as partially implemented until the Chancellor's Office provides examples of its compliance reviews of campuses and its publication of the results of these reviews.

6-Month Agency Response

The Chancellor's Office is developing the process by which it will conduct regular compliance reviews and the mechanism for reporting the results. The process is expected to be finalized by July 2024. Reviews are expected to begin in August 2024 and results from the first round of reviews are anticipated by February 2025.

California State Auditor's Assessment of 6-Month Status: Pending

60-Day Agency Response

The Chancellor's Office Nondiscrimination Policy workgroup met in August 2023 to discuss the development of a policy, or an attachment to the current sexual harassment policy, for conducting regular compliance reviews of the campus Title IX offices.

California State Auditor's Assessment of 60-Day Status: Pending

All Recommendations in 2022-109

Agency responses received are posted verbatim.