Report 2013-124 All Recommendation Responses

Report 2013-124: Sexual Harassment and Sexual Violence: California Universities Must Better Protect Students by Doing More to Prevent, Respond to, and Resolve Incidents (Release Date: June 2014)

Recommendation for Legislative Action

To ensure that all universities provide sufficient training, the Legislature should amend state law to require universities to train all of their employees annually, consistent with their role, on their obligations in responding to and reporting incidents of sexual harassment and sexual violence involving students.

Description of Legislative Action

The Legislature has not taken any action to address this specific recommendation.

California State Auditor's Assessment of Annual Follow-Up Status: No Action Taken

Description of Legislative Action

Legislation has not been enacted addressing this specific recommendation.

California State Auditor's Assessment of Annual Follow-Up Status: No Action Taken

Description of Legislative Action

Assembly Bill 1778 would have, commencing January 1, 2018, required the governing boards of each community college district, the Trustees of the California State University, the Regents of the University of California, and the governing boards of independent postsecondary institutions, in order to receive state funds for student financial assistance, to conduct annual training of their respective employees on the employee's obligations in responding to and reporting incidents of sexual assault, domestic violence, dating violence, and stalking involving students. This bill was vetoed by the Governor.

California State Auditor's Assessment of Annual Follow-Up Status: Legislation Proposed But Not Enacted

Description of Legislative Action

AB 1778 was introduced on February 3, 2016, and would require the governing boards of each community college district, the Trustees of the California State University, the Regents of the University of California, and the governing boards of independent postsecondary institutions, in order to receive state funds for student financial assistance, to conduct annual training of their respective employees on the employee's obligations in responding to and reporting incidents of sexual assault, domestic violence, dating violence, and stalking involving students.

California State Auditor's Assessment of Annual Follow-Up Status: Legislation Introduced

Recommendation for Legislative Action

To ensure that students are provided the education at the most ideal time, the Legislature should amend state law to expressly require that incoming students be provided education on sexual harassment and sexual violence as close as possible to when they arrive on campus but no later than the first few weeks of their first semester or quarter.

Description of Legislative Action

The Legislature has not taken any action to address this specific recommendation.

California State Auditor's Assessment of Annual Follow-Up Status: No Action Taken

Description of Legislative Action

Legislation has not been introduced to address this specific recommendation.

California State Auditor's Assessment of Annual Follow-Up Status: No Action Taken

Description of Legislative Action

Legislation has not been introduced to address this recommendation.

California State Auditor's Assessment of 1-Year Status: No Action Taken

Recommendation for Legislative Action

To ensure that all students are reminded of and know how to access their university's sexual harassment policies, the Legislature should amend state law to require universities to provide this information in additional prominent locations frequented by students, such as residence halls and other university housing and athletic facilities. Further, to reflect evolving technology, the Legislature should consider the most effective means of providing this information to students and that it may not be effective to post the policy in its entirety. An alternative would be to post summary information that explains how students can access the full policy.

Description of Legislative Action

The Legislature has not taken any action to address this specific recommendation.

California State Auditor's Assessment of Annual Follow-Up Status: No Action Taken

Description of Legislative Action

Legislation has not been introduced to address this specific recommendation.

California State Auditor's Assessment of Annual Follow-Up Status: No Action Taken

Description of Legislative Action

Legislation has not been introduced to address this recommendation.

California State Auditor's Assessment of 1-Year Status: No Action Taken

Recommendation #4 To: University, California State

The Office of the Chancellor should direct all of the universities within the CSU system to comply with the recommendations in this audit report. Also, to ensure that its universities are complying with Title IX requirements, the Office of the Chancellor should conduct routine Title IX reviews. When conducting these compliance reviews, the Office of the Chancellor should determine whether universities have implemented this report's recommendations.

Annual Follow-Up Agency Response From January 2016

Since our last response, the Chancellor's work group and the Systemwide Title IX Compliance Officer continue to work with the campuses to assist with implementation of the CSA's 23 recommendations. Based on our most recent follow up with the campuses, they have achieved a 96% full implementation rate, with 100% completion of all recommendations expected by spring 2016. The remaining 4% involve recommendations that have been initiated but won't be completed until 2016. In addition, the Systemwide Title IX Compliance Officer conducted reviews at three campuses in 2015 and plans to conduct five more by November 2016, averaging eight campus reviews each year. Because all campuses have been asked to comply with the CSA's 23 recommendations and we have begun conducting the routine campus Title IX reviews, we consider the recommendation to be fully implemented.

California State Auditor's Assessment of Annual Follow-Up Status: Fully Implemented

Annual Follow-Up Agency Response From October 2015

The Chancellor's work group and the Systemwide Title IX Compliance Officer continue to work with the campuses to assist with implementation of the CSA's 23 recommendations. Last June, we reported an estimated 77 percent implementation rate, noting our expectation that full implementation would be achieved once the fall term began and all additional training programs could be provided to students, faculty and staff. While the fall term began for most campuses in mid to late August, our campuses on the quarter system started less than two weeks ago. The work group is currently in the process of confirming with each campus that all recommendations have been fully implemented now that the fall term is underway. We will report that information very soon. In addition, our Systemwide Title IX Compliance Officer is scheduled to begin conducting the first of the campus Title IX reviews on November 4, 2015.

California State Auditor's Assessment of Annual Follow-Up Status: Not Fully Implemented

1-Year Agency Response

The Chancellor's systemwide work group continues to work with all of the campuses to assist with implementation of all the CSA's 23 recommendations. The campuses have been working diligently and we estimate they have achieved a 77 percent implementation rate. Many of the remaining recommendations are related to actions that need to occur at or near the beginning of the academic year and as a result, we expect full implementation by the campuses within the next few months as the fall term begins. Finally, the Systemwide Title IX Compliance Officer plans to begin conducting the routine Title IX reviews in October 2015, once all the campuses have had adequate time to fully implement the recommendations and begin evaluating their effectiveness. In the meantime, we believe that the work group is fulfilling the same function as the routine reviews because the group is working with the campuses to ensure that the recommendations are being implemented.

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

6-Month Agency Response

The Office of the Chancellor is working with all of the campuses within the system to comply with the audit recommendations. In addition, the Chancellor created a systemwide work group to coordinate with each campus in order to review current campus practices and assist with implementation of the CSA's recommendations. The Chancellor's Office has hired a systemwide Title IX Compliance Officer who started work on December 1, 2014. The Title IX Compliance Officer will be responsible for conducting routine Title IX reviews to ensure the campuses have fully implemented the CSA's recommendations.

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

The Office of the Chancellor provided additional information indicating that Title IX reviews will begin in 2016 with each campus being reviewed approximately every three years. However, because the Office of the Chancellor has yet to conduct the Title IX reviews and is still working with the universities through the work group to ensure our recommendations are implemented, we evaluated this recommendation as partially implemented.

60-Day Agency Response

The Office of the Chancellor is working with all campuses to comply with the recommendations. Toward that end, the Chancellor has created a systemwide work group to coordinate with each campus in order to review current campus practices and assist with implementation of the CSA's recommendations. Further, the Office of the Chancellor expects to hire a systemwide Title IX compliance officer before the end of the calendar year who will assume responsibility for routine Title IX reviews, including making a determination as to whether the campuses have implemented the CSA's recommendations. As noted in our June 4 response, because some of the CSA's recommendations pertain to faculty and staff represented by unions, training requirements related to those groups must be collectively bargained, which is in process.

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

Recommendation #5 To: University of California

The Office of the President should direct all of the universities within the UC system to comply with the recommendations in this audit report. Also, to ensure that its universities are complying with Title IX requirements, the Office of the President should conduct routine Title IX reviews. When conducting these compliance reviews, the Office of the President should determine whether universities have implemented this report's recommendations.

Annual Follow-Up Agency Response From November 2017

The Office of Ethics, Compliance and Audit Services has contracted with a third party to conduct Title IX compliance reviews at each University location. The locations were evaluated for compliance with UC policy, campus local procedures, guidance from the Office of Civil Rights, and the recommendations from California State Auditor Report 2013-124. If a location was found to be not in compliance with recommendations from the State audit, this was noted as an observation in the report. Management is developing and implementing action plans to respond to the recommendations in the reports. The Office of Ethics, Compliance and Audit Services will periodically follow up on the status of these actions plans.

California State Auditor's Assessment of Annual Follow-Up Status: Fully Implemented

The third party that UC's response refers to conducted Title IX reviews during 2016 and 2017, and these reports indicate that the recommendations of our report were among those items reviewed. Additionally, UC's Office of Ethics, Compliance and Audit Services has announced plans to conduct routine Title IX compliance reviews at each university location at least once every three years. The scope of the reviews will be determined based on a preliminary risk assessment and at a minimum will include an assessment of the location's implementation of recommendations from our report.

Annual Follow-Up Agency Response From October 2016

The Office of Ethics, Compliance, and Audit Services has made visits to each of the UC campuses to review implementation of the President's Task Force Recommendations and determine each campus status. Ongoing monitoring is occurring regarding implementation. Additionally, Title IX compliance audits have been conducted by a third party to assure Title IX compliance. Management will be developing and implementing action plans to respond to observations in fiscal year 2016-17.

California State Auditor's Assessment of Annual Follow-Up Status: Not Fully Implemented

Although the Office of Ethics, Compliance, and Audit Services has begun conducting Title IX reviews, the reviews focus on implementation of the President's Task Force Recommendations. Officials stated the Task Force recommendations incorporate the State Auditor's recommendations and that the Office of Ethics, Compliance, and Audit Services has directed all of the campuses to comply with the recommendations in the State Auditor's report and that those recommendations were referenced regularly in these discussions. However, it was unable to provide documentation that shows the status of all universities implementing each of our specific recommendations. Therefore, we have assessed this recommendation as partially implemented.

Annual Follow-Up Agency Response From September 2015

The Office of the President through the work of the President's Task Force on Preventing and Responding to Sexual Violence and Sexual Assault has instituted programs and processes for the system that address the recommendations in the audit report (http://www.ucop.edu/ethics-compliance-audit-services/_files/compliance/SVSA-jan-report.pdf). The Task Force developed key recommendations regarding reporting, the complaint processes, utilization of consistent nomenclature, uniform advocacy and case management services, and education and training. The systemwide Office of Audit Services has started routine Title IX audit reviews that will be included in internal audit plans. The reviews will cover all campuses and include an evaluation of the implementation of the recommendations in the audit report.

In the next year, the Office of Ethics, Compliance and Audit Services will make campus visits to assess the status of the implementation of the recommendations from this audit.

California State Auditor's Assessment of Annual Follow-Up Status: Not Fully Implemented

1-Year Agency Response

The Office of the President through the work of the President's Task Force on Preventing and Responding to Sexual Violence and Sexual Assault has instituted programs and processes for the system that address the recommendations in the audit report (http://www.ucop.edu/ethics-compliance-audit-services/_files/compliance/SVSA-jan-report.pdf). The Task Force developed key recommendations regarding reporting, the complaint processes, utilization of consistent nomenclature, uniform advocacy and case management services, and education and training. The systemwide Office of Audit Services has started routine Title IX audit reviews that will be included in internal audit plans. The reviews will cover all campuses and include an evaluation of the implementation of the recommendations in the audit report.

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

Although the Office of the President has marked this recommendation as Fully Implemented, it is just initiating the Title IX reviews, which will include an evaluation of universities' implementation of our recommendations. In addition, some of the recommendations developed by the President's Task Force, which it refers to in its response, are also still in progress and are all not yet fully implemented. Therefore, we have assessed this recommendation as Partially Implemented.

6-Month Agency Response

The Office of the President is continuing its work to address all of the recommendations in the audit report across all UC campuses. The systemwide Office of Audit Services will ensure that routine Title IX reviews are included in internal audit plans beginning in fiscal year 2015-16. These reviews will include an evaluation of the implementation of the recommendations in this report.

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

60-Day Agency Response

The Office of the President, UC Berkeley and UCLA are all working to address all of the recommendations in the audit report. The systemwide Office of Audit Services will ensure that routine Title IX reviews are included in internal audit plans beginning in fiscal year 2015-16. These reviews will include an evaluation of the implementation of the recommendations in this report.

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

Recommendation #6 To: Chico, California State University

To help ensure that university faculty and staff do not mishandle student reports of incidents, all faculty and staff should receive training annually, consistent with their role, on their obligations in responding to and reporting incidents of sexual harassment and sexual violence.

1-Year Agency Response

CSU Chico has developed training for all staff and faculty to ensure that employees can properly handle reports or incidents of sexual violence or harassment. The training has been rolled out to Management and other non-represented employees. The CSU has also secured the agreement from each of the bargaining units related to the training component, and roll out to these members is expected to continue through June and July.

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

The university provided evidence of the training that was rolled out in July. Therefore, this recommendation is marked as fully implemented.

6-Month Agency Response

CSU Chico, working through the Chancellor's Office, has developed annual training for all staff and faculty. It is envisioned that the training rollout will begin in 2015 to select groups of employees and to all employees upon completion of our meet and confer obligations with the respective unions.

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

60-Day Agency Response

CSU Chico continues to work with the Chancellor's Office to develop annual training for all staff and faculty, however implementation is subject to meet and confer obligations with the respective unions.

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

Recommendation #7 To: San Diego, California State University

To help ensure that university faculty and staff do not mishandle student reports of incidents, all faculty and staff should receive training annually, consistent with their role, on their obligations in responding to and reporting incidents of sexual harassment and sexual violence.

Annual Follow-Up Agency Response From October 2016

All faculty, staff and administrators are registered for an online annual Sexual Violence Awareness and Prevention training. New employees are registered for the training upon hire. Completion of the training is mandatory and the completion is overseen by the Office of Employee Relations and Compliance. Employees who fail to complete the training in a timely manner are subject to discipline.

California State Auditor's Assessment of Annual Follow-Up Status: Fully Implemented

Annual Follow-Up Agency Response From October 2015

All faculty and staff have been registered for an online Sexual Violence Awareness and Prevention training. Completion of this training is mandatory. Completion by managers and staff is due on October 15, 2015 and completion by faculty (pursuant to an agreement during meet and confer) is due on February 22, 2016. Faculty and staff who fail to complete the training in a timely manner will be subject to discipline.

California State Auditor's Assessment of Annual Follow-Up Status: Not Fully Implemented

1-Year Agency Response

Training was provided to approximately 300 faculty and staff in October 2014. The training was offered to all faculty and staff at that time but could not be required until after union discussions. The Chancellor's Office did not know the outcome of those discussions until May 2015. Now that we have agreement from the unions, all faculty and staff will be required to receive the annual training. The campus is in the process of registering all employees for an online Sexual Violence awareness training with a required completion date of October 15, 2015.

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

6-Month Agency Response

Faculty and staff training was provided on October 22, 2014. SDSU is working with the Chancellor's Office to bargain mandatory annual training with the unions.

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

60-Day Agency Response

Faculty and staff training is scheduled for October 2014. SDSU is working with the Chancellor's Office to determine appropriate steps for mandating completion of annual training

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

Recommendation #8 To: University of California, Berkeley

To help ensure that university faculty and staff do not mishandle student reports of incidents, all faculty and staff should receive training annually, consistent with their role, on their obligations in responding to and reporting incidents of sexual harassment and sexual violence.

Annual Follow-Up Agency Response From October 2018

In 2018, UC Berkeley released a new module for faculty and supervisory employees. As such, annually, every employee is required to complete an interactive training—whether in-person or online—to ensure that university faculty and staff do not mishandle student reports of incidents. This training requirement is ongoing, required annually of each employee, and the campus systematically ensures compliance of the training requirement via the Learning Management System. The training addresses key prevention strategies, employee obligations, response to disclosures, and confidential and reporting resources.

California State Auditor's Assessment of Annual Follow-Up Status: Fully Implemented

Annual Follow-Up Agency Response From November 2017

UC Berkeley requires all employees to complete annual training in order to improve the campus response to and prevention of sexual violence and sexual harassment. This training requirement is ongoing and required annually of each employee. The campus systematically ensures compliance of the training requirement via the Learning Management System. The training addresses key prevention strategies, employee obligations, response to disclosures, and confidential and reporting resources. In addition to the annual training requirement, University leadership provides essential notices, reminders, and updates to the campus prevention and response efforts twice annually.

California State Auditor's Assessment of Annual Follow-Up Status: Partially Implemented

The training that UC Berkeley refers to was established in accordance with a requirement for annual training in UC's revised systemwide Sexual Violence and Sexual Harassment policy. UC's Office of the President mandated how campuses would meet the requirement and specified that in the first year of the two-year cycle, employees would be required to take a training course that differed depending on if they were faculty or staff. However, in the second year, the training requirement is to be met by a message from campus leadership reinforcing the contents of the policy and employee reporting obligations. Although we believe that such reinforcement messages can be beneficial, they are not a substitute for a training course for faculty and staff, and thus we have assessed this recommendation as partially implemented.

Annual Follow-Up Agency Response From October 2016

As part of the University's ongoing efforts to improve how it prevents and responds to sexual violence and sexual harassment on UC campuses, the Office of the President developed two new eCourses specifically geared towards the new Sexual Violence Sexual Harassment Policy implemented January 2016. All University employees were required to complete one of the online courses depending on their job status by May 1, 2016, or based on the mandated training schedule as prescribed by AB125. Also, in person Live Theater on sexual violence and sexual harassment was offered February 28, 2016 that supplemented online training for staff and faculty.

Additionally, to supplement the University's mandatory online sexual harassment and prevention training, the campus developed a customized curriculum for senior leaders including the Chancellor's cabinet, Council of Deans, and Department Chairs to enhance the understanding of UC policy, procedures and responsibilities in creating a culture of education and prevention.

California State Auditor's Assessment of Annual Follow-Up Status: Not Fully Implemented

Although nonsupervisory employees were required to attend training on sexual violence and sexual harassment, this is not annual ongoing training. Further, the supervisory training that is required under AB 125 is conducted every two years and does not address our recommendation. Therefore, we have assessed this recommendation as not fully implemented.

Annual Follow-Up Agency Response From September 2015

The UC President's Task Force on Preventing and Responding to Sexual Violence and Sexual Assault is in its implementation phase and includes the initiation of mandatory training for staff and faculty on an annual basis. Systemwide working groups are vetting the content (which must be consistent across all UC campuses), and developing plans to launch this online training in January 2016. This mandatory training requirement emanates from the UC system, as opposed to a particular campus, and decisions about timing are made at the systemwide level.

California State Auditor's Assessment of Annual Follow-Up Status: Not Fully Implemented

1-Year Agency Response

As part of the implementation of recommendations from the UC systemwide Task Force on Preventing and Responding to Sexual Violence and Sexual Assault, the UC Office of the President is purchasing modules for online training that will contain all the content elements required in CA AB 1825, VAWA/Campus SaVE, and other relevant laws. Faculty and staff required training will now be administered annually instead of every two years. This online education will be considered a floor and not a ceiling, with in-person workshops and other educational tools being developed to supplement the mandatory online education. These supplemental tools will be developed by members of the newly created Coordinated Community Review Team (CCRT) - a new campus structure emerging from the UC Task Force that replaces the Title IX Compliance Advisory Committee. In addition, staff involved in the investigation and adjudication of complaints, as well as others involved in "first responder" roles have undergone specific trauma-focused training related to sexual violence, and will undertake this kind of training on an annual basis.

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

UC Berkeley is still working on providing mandatory training to all faculty and staff. Per the UC systemwide Task Force recommendations, the roll-out of annual faculty and staff programs is targeted for January 2016. Therefore, we have assessed this recommendation as partially implemented.

6-Month Agency Response

All supervisors and faculty are required to complete an online sexual harassment prevention program every two years. The program has been updated and modified to include reporting responsibilities and information required under the Violence Against Women Act (VAWA). President Napolitano's Task Force will be making recommendations concerning training and education for all staff and faculty.

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

60-Day Agency Response

All supervisors and faculty are required to complete an online sexual harassment prevention program every two years. The program has been updated and modified to include reporting responsibilities and information required under the Violence Against Women Act (VAWA). The policy notice will be distributed annually to reinforce training and awareness, including reporting obligations. Working with University of California Office of the President to develop supplemental AB1825 training. President Napolitano's Task Force will be making recommendations concerning training and education for all staff and faculty.

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

Recommendation #9 To: University of California, Los Angeles

To help ensure that university faculty and staff do not mishandle student reports of incidents, all faculty and staff should receive training annually, consistent with their role, on their obligations in responding to and reporting incidents of sexual harassment and sexual violence.

Annual Follow-Up Agency Response From October 2020

The development of the Responsible Employee module was paused during the review of the Department of Education Title IX regulations, and subsequent revisions to the systemwide Sexual Violence and Sexual Harassment Policy and student, staff, and faculty investigation and adjudication frameworks. The Systemwide Title IX Office is finalizing the Responsible Employee module for faculty and staff and anticipates making it available to campuses in January 2021. Faculty and Supervisors will continue to take their 2 hour AB 1825 training every two years, and will take this Responsible Employee module in the in-between years. Non-Supervisory staff will continue to take the existing Sexual Harassment Prevention course every two years, and will take the new Responsible Employee module in the in-between year. If the systemwide training is not finalized by January 2021, UCLA will provide the responsible employee information.

California State Auditor's Assessment of Annual Follow-Up Status: Partially Implemented

Annual Follow-Up Agency Response From October 2020

UCLA continues with the practice reported in May of 2017 with the following updates:

1. The Title IX Office has partnered with a vendor to provide refresher training for all graduate and professional students.

2. Yearly training is required of special populations, such as Athletes, Fraternities/Sororities, the Band, ROTC and other populations UCLA deems "at risk."

3. The Title IX Office is working with campus partners to identify a new vendor and complete an agreement to provide online refresher trainings for undergraduate students. We hope to reach an agreement by January 2021.

California State Auditor's Assessment of Annual Follow-Up Status: Partially Implemented

Annual Follow-Up Agency Response From October 2019

The Office of the President is finalizing an in-house Responsible Employee module for faculty and staff and anticipates making it available to campuses during the Spring 2020 semester. Faculty and Supervisors will continue to take their 2 hour AB 1825 training every two years, and will take this Responsible Employee module in the in-between years. Non-Supervisory staff will continue to take the existing Sexual Harassment Prevention course every two years, and will take the new Responsible Employee module in the in-between year.

California State Auditor's Assessment of Annual Follow-Up Status: Pending

Annual Follow-Up Agency Response From October 2018

The Office of the President has confirmed a contract is in place with a vendor to provide all UC campuses with an online "refresher" training course for faculty and staff to meet this recommendation. The roll out of this training course is scheduled for January 2019. Faculty and Supervisors will continue to take their 2 hour AB 1825 training every two years, and will take this "refresher" online course in the in between years. Non-Supervisory staff will continue to take the existing Sexual Harassment Prevention course every two years, and will take the new "refresher" online course in the in between year.

California State Auditor's Assessment of Annual Follow-Up Status: Partially Implemented

As noted in UCLA's response, it expects to fully implement this recommendation in January 2019.

Annual Follow-Up Agency Response From November 2017

UCLA requires all employees to receive annual training in order to improve the campus response to and prevention of sexual violence and sexual harassment. This training is ongoing and provided annually to each employee. The training addresses UC Policy and procedures, key prevention strategies and confidential resources and reporting options. UCLA sends additional messages with this information throughout the year.

California State Auditor's Assessment of Annual Follow-Up Status: Partially Implemented

The training that UCLA refers to was established in accordance with a requirement for annual training in UC's revised systemwide Sexual Violence and Sexual Harassment policy. UC's Office of the President mandated how campuses would meet the requirement and specified that in the first year of the two-year cycle, employees would be required to take a training course that differed depending on if they were faculty or staff. However, in the second year, the training requirement is to be met by a message from campus leadership reinforcing the contents of the policy and employee reporting obligations. Although we believe that such reinforcement messages can be beneficial, they are not a substitute for a training course for faculty and staff, and thus we have assessed this recommendation as partially implemented.

Annual Follow-Up Agency Response From October 2016

The UC President's Task Force on Preventing and Responding to Sexual Violence and Sexual Assault has required that all staff receive training on the sexual violence and sexual harassment prevention and response. In that regard, UCOP has worked with Campus Clarity to develop an online module that is distributed and tracked through the Learning Management System (LMS). In addition, staff from the Title IX office and other offices have conducted multiple in-person trainings for supervisory and non-supervisory staff. In addition to these in-depth training efforts, UCLA has sent multiple communications to faculty and staff reminding them of their obligation to report sexual harassment and sexual violence as set forth in the UC Policy on Sexual Violence and Sexual Harassment. In person life theater has also presented training to faculty and staff on sexual violence and sexual assault.

California State Auditor's Assessment of Annual Follow-Up Status: Not Fully Implemented

Although nonsupervisory employees were required to attend training on sexual violence and sexual harassment, this is not annual ongoing training. Further, the supervisory training that is required under AB 125 is done every two years and does not address our recommendation. Therefore, we have assessed this recommendation as not fully implemented.

Annual Follow-Up Agency Response From September 2015

The UC President's Task Force on Preventing and Responding to Sexual Violence and Sexual Assault is in its implementation phase and includes the initiation of mandatory training for staff and faculty on an annual basis. Systemwide working groups are vetting the content (which must be consistent across all UC campuses), and developing plans to launch this online training in January 2016. This mandatory training requirement emanates from the UC system, as opposed to a particular campus, and decisions about timing are made at the systemwide level.

California State Auditor's Assessment of Annual Follow-Up Status: Not Fully Implemented

1-Year Agency Response

UCLA continues to provide to faculty and supervisory staff the online training content developed by UC Office of the President ("UCOP"), which includes information on responding to and reporting incidents of sexual harassment. UCLA tracks compliance with this online training via the Learning Management System. UCOP will be updating the content of this online training. The Prevention Education and Response Steering Committee, consisting of education and response providers for students, faculty and staff, meets to share updates on content and delivery of prevention education and response information, and to ensure that prevention education and response are consistent and compliant with relevant laws and requirements (e.g., Violence Against Women Act ("VAWA"), UC President's Task Force on Preventing and Responding to Sexual Violence and Sexual Assault ("President's Task Force")).

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

Although UCLA has marked this as Fully Implemented, it only refers to faculty and supervisory staff in its response. However, the recommendation states that all faculty and staff should receive training annually, consistent with their role on their obligations in responding to and reporting incidents of sexual harassment and sexual violence. UCLA has indicated all faculty and staff will be required to attend training beginning in January 2016. Therefore, we have assessed this recommendation as Partially Implemented.

6-Month Agency Response

All supervisors and faculty are required to complete an online sexual harassment prevention program every two years. The program has been updated to include subject matter mandated by VAWA and student harassment issues. The policy notice will be distributed annually to reinforce training and awareness, including reporting obligations. President Napolitano's Task Force will be making recommendations concerning training and education for all staff and faculty. Responsible employees in the student affairs organization (including Residential Life staff) received training in Fall quarter consistent with their role and responsibility in responding to, and reporting, incidents of sexual harassment and sexual violence. This training was also offered to advisors and counselors in academic departments.

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

60-Day Agency Response

All supervisors and faculty are required to complete an online sexual harassment prevention program every two years. The program has been updated to include subject matter mandated by VAWA and student harassment issues. The policy notice will be distributed annually to reinforce training and awareness, including reporting obligations. President Napolitano's Task Force will be making recommendations concerning training and education for all staff and faculty.

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

Recommendation #10 To: Chico, California State University

To help ensure that resident advisors handle incidents of sexual harassment and sexual violence appropriately, all universities should provide supplemental training on sexual harassment and sexual violence, including rape awareness training, for resident advisors twice a year.

6-Month Agency Response

To help ensure that resident advisors handle incidents of sexual harassment and sexual violence appropriately, University Housing in conjunction with Student Judicial Affairs, The Title IX Coordinator, and Safe Place provided training to the Resident Advisor staff on August 12, 2014. A second training to build on the matters covered in August is scheduled for January 13, 2015.

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

Chico marked this as not fully implemented because the second training, scheduled for January 2015, had not yet occurred at the time of its six-month response. However, it has subsequently demonstrated that it fully implemented this recommendation.

60-Day Agency Response

To help ensure that Resident Advisors handle incidents of sexual harassment and sexual violence appropriately, University Housing in conjunction with Student Judicial Affairs and Safe Place has already provided the first training to the Resident Advisor staff on August 12, 2014.

Updated training will be repeated in January 2015 and ongoing each semester thereafter.

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

Recommendation #11 To: San Diego, California State University

To help ensure that resident advisors handle incidents of sexual harassment and sexual violence appropriately, all universities should provide supplemental training on sexual harassment and sexual violence, including rape awareness training, for resident advisors twice a year.

1-Year Agency Response

Resident Advisors were trained on August 14, 2014 and January 20, 2015. SDSU will continue to provide training to Resident Advisors at the beginning of each semester.

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

6-Month Agency Response

Resident Advisors were trained on August 14, 2014 and training will be provided at the beginning of the Spring 2015 Semester.

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

60-Day Agency Response

Resident Advisors were trained on August 14, 2014 and a training will be provided at the beginning of the Spring 2015 Semester.

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

Recommendation #12 To: University of California, Berkeley

To help ensure that resident advisors handle incidents of sexual harassment and sexual violence appropriately, all universities should provide supplemental training on sexual harassment and sexual violence, including rape awareness training, for resident advisors twice a year.

6-Month Agency Response

UC Berkeley has moved to once a semester training schedule for all RAs (Resident Advisors). Prior to the beginning of Fall term, all RAs were trained on how to respond to incidents of sexual harassment and sexual violence. During the week of January 12, 2015, all RAs will attend refresher training created and presented by our Office for the Prevention of Harassment and Discrimination and built around results of the RA survey conducted in late fall measuring what training information needs to be reviewed. Summer RAs (Resident Advisers) will also receive both face to face and video trainings.

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

60-Day Agency Response

All Resident Advisors attend in person training on sexual harassment and sexual violence prior to student move-in. Additionally, they view a 30 minute video explaining their responsibilities as Campus Security Authorities and take a quiz affirming their understanding of mandatory reporting. In January, RAs (Resident Advisors) will attend refresher training. Summer RAs (Resident Advisors) will also receive both trainings.

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

Recommendation #13 To: University of California, Los Angeles

To help ensure that resident advisors handle incidents of sexual harassment and sexual violence appropriately, all universities should provide supplemental training on sexual harassment and sexual violence, including rape awareness training, for resident advisors twice a year.

6-Month Agency Response

All Resident Advisors (RAs) received training (new RA's 14 hrs and returning RA's 8 hrs), on rape awareness and how to appropriately respond to incidents of sexual harassment and sexual violence, prior to the quarter starting.

Winter supplemental training is scheduled for January 14, 2015 (2 hrs) for all RAs and supervisors. This training will be developed and presented by by a nationally recognized trainer in sexual assault prevention and education, Dr. Allen Berkowitz. This is in collaboration with the UCLA Sexual Health Coalition and the Title IX Officer, the Dean of Students, CARE @ CAPS (Campus Assault Resources & Education at Counseling & Psychological Services), and leadership staff in Residence Life.

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

UCLA marked this as not fully implemented because the second training, scheduled for January 2015, had not yet occurred at the time of its six-month response. However, it has subsequently demonstrated that it fully implemented this recommendation.

60-Day Agency Response

All Resident Advisors (RAs) receive training prior to the start of the Fall quarter and will receive supplemental training in Winter. Training is developed and presented by a collaboration of the Title IX Officer, the Dean of Students, CARE @ CAPS (Campus Assault Resources & Education at Counseling & Psychological Services), and leadership staff in Residence Life.

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

Recommendation #14 To: Chico, California State University

To help ensure that athletic coaches handle incidents of sexual harassment and sexual violence appropriately, all universities should provide supplemental training on sexual harassment and sexual violence, including sexual assault, annually for all athletic coaches.

6-Month Agency Response

CSU Chico Athletic coaches received Title IX training at a professional development session held on December 10, 2014. It was intended to build on the training received by the student-athletes in August 2014, and which the coaches attended. The training was conducted by Safe Place and Student Judicial Affairs in conjunction with the Title IX Coordinator.

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

60-Day Agency Response

To help ensure that athletic coaches handle incidents of sexual harassment and sexual violence appropriately, coaches will receive professional development which will review reporting obligations and address how to handle incidents of sexual harassment and sexual violence. Sessions will be conducted by Safe Place and Student Judicial Affairs in conjunction with the Title IX Coordinator.

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

Recommendation #15 To: San Diego, California State University

To help ensure that athletic coaches handle incidents of sexual harassment and sexual violence appropriately, all universities should provide supplemental training on sexual harassment and sexual violence, including sexual assault, annually for all athletic coaches.

6-Month Agency Response

The Title IX Coordinator provided in-person training to all Athletics Department staff, including athletic coaches, on September 8, 2014. In addition, a follow-up email was sent to all Athletics Department staff, including coaches, attaching the Powerpoint presentation, the annual notification, and a guidance document, on September 12, 2014. Similar training will recur annually.

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

60-Day Agency Response

Pursuant to the recommendation, SDSU will provide supplemental sexual harassment and sexual assault training annually to all athletic coaches.

Training for coaches and Athletics personnel will be completed by September 30, 2014.

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

Recommendation #16 To: University of California, Berkeley

To help ensure that athletic coaches handle incidents of sexual harassment and sexual violence appropriately, all universities should provide supplemental training on sexual harassment and sexual violence, including sexual assault, annually for all athletic coaches.

6-Month Agency Response

All coaches were required to attend a one hour specialized training provided by Jackson Katz, a national expert in gender violence, on December 2, 2014. Additionally, the Title IX Office and other campus partners are providing in-person presentations at quarterly coaches meetings.

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

60-Day Agency Response

In 2014-15, working to provide in-person presentations to coaches at quarterly coaches meetings. OPHD (Office for the Prevention of Harassment and Discrimination) and IA (Inter Collegiate Athletics) exploring purchase of online tool to supplement biennial AB1825 training.

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

Recommendation #17 To: University of California, Los Angeles

To help ensure that athletic coaches handle incidents of sexual harassment and sexual violence appropriately, all universities should provide supplemental training on sexual harassment and sexual violence, including sexual assault, annually for all athletic coaches.

6-Month Agency Response

Coaches received specialized training in the Fall. Training was developed and presented by a collaboration of the Title IX Officer, the Dean of Students, CARE at CAPS, and leadership staff in Athletics. Required training for all athletics coaches and staff (200+) is complete as of December 2014.

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

60-Day Agency Response

All Coaches receive specialized training in the Fall. Training is developed and presented by a collaboration of the Title IX Officer, the Dean of Students, CARE @ CAPS (Campus Assault Resources & Education at Counseling & Psychological Services), and leadership staff in Athletics.

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

Recommendation #18 To: Chico, California State University

All universities should provide their education on sexual harassment and sexual violence to incoming students as close as possible to when they arrive on campus but no later than the first few weeks of their first semester or quarter. Further, universities should provide periodic refresher educational programs, at least annually, to all students on campus to ensure that they are aware of how to handle and report incidents of sexual harassment and sexual violence.

Annual Follow-Up Agency Response From October 2016

In October of this year, CSU Chico rolled out refresher training for all students. We are primarily using an online module that will be updated each year to ensure variety of the content. We are also providing for in-person "equivalent" trainings that can be attended by students in lieu of the online module. The training requirement is enforced through registration holds.

California State Auditor's Assessment of Annual Follow-Up Status: Fully Implemented

Annual Follow-Up Agency Response From September 2015

CSU Chico has not yet fully implemented mandatory refresher training for all students. Rather than relying on on-line training, CSU Chico's preference is to interact with students face to face in various capacities (in the classroom, during their social interactions, at special events, etc.), as it is believed to be a better method for achieving social change. Due to the labor-intensive nature of this approach, we need additional time to sort out the related logistics. We are in the process of developing a list of the various events, classes, programs, and trainings that a student can attend to meet the annual training obligation. The tracking/logging systems that are necessary to put this in place are also being explored. Most likely there will need to be an online option for students who are unable to attend an in person event, and we are exploring methods by which we can deliver this option. We continue to offer refresher training on a voluntary basis, and have a number of programs occurring on campus to deliver the information to students.

California State Auditor's Assessment of Annual Follow-Up Status: Not Fully Implemented

1-Year Agency Response

Refresher training is now available to students on the Title IX website. Additionally, CSU Chico partnered with a student group to host a screening of The Hunting Ground. The film was followed with a discussion led by a panel comprised of individuals involved with our prevention efforts on campus. Our Title IX team also attended events associated with Take Back the Night and provided information and outreach on reporting options and general information about our sexual violence prevention efforts. Members of our Title IX Team participated in the CSU Chico student led "Town Hall" meetings related to Sexual Assault. It is anticipated that these efforts will continue in the coming years, as an additional avenue to remind students about the information learned through our incoming student training. Additionally, we have developed programming around bystander intervention that will be rolled out throughout the 2015-16 year, and which will include information on reporting and resources. CSU Chico has not yet implemented mandatory refresher training, as the past year has been focused on assuring that high risk groups are trained annually, as well as ensuring that our Title IX team is fully staffed. Rather than relying on on-line training, CSU Chico's preference is to interact with students face to face in various capacities (in the classroom, during their social interactions, at special events, etc.), as it is believed to be a better method for achieving social change. The logistics of how to track such training and ensuring that we reach all students each year are still being ironed out.

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

6-Month Agency Response

CSU, Chico provides training through a third-party provider. The recent training period began August 4, 2014. Students are encouraged to complete the training before coming to campus, and must complete the training prior to beginning Spring classes. As of December 1, 2014, the completion rate was 95%. In addition, students arriving in the spring semester must take the training prior to fall registration.

CSU Chico is in the process of making voluntary refresher training available for students anytime through the CSU, Chico portal, and is working to create a number of additional training opportunities which will be available to students.

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

60-Day Agency Response

CSU, Chico is currently offering training through a third-party provider. The training period began August 4, 2014 and students are encouraged to complete the training before coming to campus. The final deadline for students is October 24, 2014.

Voluntary refresher training is available for students anytime through the CSU, Chico portal, including for students starting in the spring semester. In addition, students arriving in the spring semester must take the training prior to fall registration.

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

CSU Chico has implemented the first part of the recommendation by requiring students to complete the sexual harassament and sexual violence portion of the training by September 12th. However, CSU Chico has not yet implemented a mandatory refresher training program for all students.

Recommendation #19 To: San Diego, California State University

All universities should provide their education on sexual harassment and sexual violence to incoming students as close as possible to when they arrive on campus but no later than the first few weeks of their first semester or quarter. Further, universities should provide periodic refresher educational programs, at least annually, to all students on campus to ensure that they are aware of how to handle and report incidents of sexual harassment and sexual violence.

Annual Follow-Up Agency Response From October 2016

SDSU's WebPortal is an online portal where our students register for classes and check their grades. Every student must utilize WebPortal. We have programmed WebPortal to require students to read and acknowledge receipt of resource information and refresher training information relating to sexual violence awareness and prevention every six months. Students who do not acknowledge that they have reviewed the information will be unable to access the WebPortal (and in turn will be unable to access information relating to their grades or to register for classes). SDSU will change the content of the refresher information every six months to cover various topics relating to sexual violence awareness and prevention so that students will review different content every six months.

California State Auditor's Assessment of Annual Follow-Up Status: Fully Implemented

Annual Follow-Up Agency Response From October 2015

San Diego State University administrators are currently working with a cross-divisional group of campus officials to determine how best to ensure that all students complete a refresher program on sexual violence awareness and prevention. This is a complex discussion given the number of students and the limitations of our student system. We are committed to finding a sustainable and effective solution and we anticipate a decision and plan to be implemented by January 2016.

California State Auditor's Assessment of Annual Follow-Up Status: Not Fully Implemented

1-Year Agency Response

All incoming students are now required to view a 30 minute presentation on sexual harassment and sexual violence during New Student Orientation. SDSU hosted a series of awareness and prevention programming for all students during the beginning of the Fall semester and during Sexual Assault Awareness Month (April). SDSU will provide educational programs each year.

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

San Diego State provides education on sexual harassment and sexual violence to incoming students close to the time they arrive on campus. In addition, San Diego provides refresher programs to all students. However, San Diego State has yet to determine a method to ensure students are attending the refresher programs.

6-Month Agency Response

All incoming students are now required to view a 30 minute presentation on sexual harassment and sexual violence during New Student Orientation. This was implemented to new students during Fall 2014. In addition, SDSU will send an email to all incoming students at the start of each semester that provides resource information and refresher training on the issue.

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

60-Day Agency Response

All incoming students are now required to view a 30 minute presentation on sexual harassment and sexual violence during New Student Orientation. In addition, SDSU will send an email to all incoming students at the start of the semester that provides resource information and refresher training on the issue. Further, incoming students are required to complete the Sexual Violence online training, as part of the e-Checkup to Go program, during their first semester.

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

San Diego State provided education on sexual harassment and sexual violence to incoming students close to the time they arrive on campus. However, San Diego State has not yet implemented a refresher educational program for all students on campus.

Recommendation #20 To: University of California, Berkeley

All universities should provide their education on sexual harassment and sexual violence to incoming students as close as possible to when they arrive on campus but no later than the first few weeks of their first semester or quarter. Further, universities should provide periodic refresher educational programs, at least annually, to all students on campus to ensure that they are aware of how to handle and report incidents of sexual harassment and sexual violence.

Annual Follow-Up Agency Response From October 2018

UC Berkeley requires all students—undergraduate, graduate, and professional—to, on an annual-basis, complete a refresher training. The training covers key concepts including preventing violence and harassment and how to handle and report incidents. Participation and completion of the training is required for all continuing students, and UC Berkeley ensures student complete the training through an integrated compliance system. The interactive training uses a variety of teaching and learning approaches and is customizable, thus, ensuring the content can be updated each year. Additionally, UC Berkeley offers a number of programs, some required, which further address the prevention, intervention, and response to violence and harassment.

UC Berkeley continues to require all new students—both graduate and undergraduate—participate in prevention education early in the students' first term. All new students complete at least three educational points of contact.

California State Auditor's Assessment of Annual Follow-Up Status: Fully Implemented

Annual Follow-Up Agency Response From November 2017

UC Berkeley provides education, prevention, and information regarding campus and community resources to all students. All new students (graduate & undergraduate) participate in prevention education early in the students' first term. New students complete at least (3) educational points of contact before instruction begins, including an online training module, in-person session, a letter, and print resources. The content for these educational experiences includes definitions of key concepts & policies; confidential support resources & reporting resources; rights & options; bystander intervention skills; and how to support someone that has experienced violence or harassment. Students must complete all of the education sessions, and non-completion will result in an enrollment block.

We have expanded our Sexual Violence and Sexual Harassment prevention efforts, including hiring additional staff and establishing new student-focused and campus-wide prevention efforts. The campus continues to provide periodic refresher educational programs for all students and employees. The Chancellor and Provost provide at least two letters to every member of the campus community outlining prevention resources, where to get support, & information about reporting incidents of sexual harassment and violence. The campus provides several key educational opportunities including a comprehensive, coordinated, and evidence-based prevention activities, key public awareness events; small group prevention sessions, and peer education programs led by several key departments and student-led groups.

UCB submits that the provision of these educational programs and the letters fully implement the CSA's recommendations, which stated that UCB had to provide periodic refresher educational programs but did not state that UCB had to collect reading or engagement metrics. UCB does, however, expect every student to see and read the refresher letters and engage in prevention and education programming.

California State Auditor's Assessment of Annual Follow-Up Status: Partially Implemented

Consistent with our assessment of UC Berkeley's response to this recommendation in 2016, we do not consider this recommendation fully implemented because it does not ensure that all students take a refresher educational program at least annually. In its response this year, UC Berkeley asserts that our recommendation states that UC Berkeley had to provide such programs but did not state that UC Berkeley had to collect reading or engagement metrics. However, we do not agree that periodic refresher educational programs can be considered provided to all students, as we recommended, if participation is not required. Further, as we stated on page 28 of our report, voluntary educational programs can be useful; however, to ensure that every student on campus is consistently and regularly made aware of how to handle and report incidents of sexual harassment and sexual violence, universities should require all students to complete mandatory refresher training.

Annual Follow-Up Agency Response From October 2016

Campus leaders have assessed, and continue to explore, several options to provide effective and meaningful annual refreshers. The campus provides periodic refresher educational programs for all students. Each academic year, the Chancellor and Provost provide two letters to every member of the campus community outlining prevention resources, where to get support, and information about reporting incidents of sexual harassment and violence. Furthermore, the campus provides several key educational opportunities including a comprehensive, coordinated, and evidence-based social norms education; key public awareness events (e.g. Take Back the Night, guest speakers); small group prevention sessions, and peer education programs led by several key campus departments and student-led groups.

All new students—both graduate and undergraduate—participate in prevention education soon after joining the campus community. All new students receive at least three educational points of contact before the start of instruction, including an online training module, in-person session, a letter, and print resources. The content for these educational experiences includes definitions of key concepts and policies (e.g. consent, sexual harassment, sexual assault, domestic violence, stalking); confidential support resources and reporting resources; rights and options, bystander intervention skills; and how to support someone that has experienced violence or harassment. Students must complete all of the education sessions (i.e. both the online module and the in-person session); non-completion will result in an enrollment block for the following term.

California State Auditor's Assessment of Annual Follow-Up Status: Not Fully Implemented

UCB provides letters to students on reporting options and resources available to students who have experienced sexual violence. In addition, UCB provides several key educational opportunities to all students. UCB stated the letters provided to all students each semester serve as the annual refresher about expectations of the UCB community. However, UCB cannot ensure students are reviewing the letters. Further, the educational programs that are offered are optional. Therefore, we have marked this recommendation as not fully implemented.

Annual Follow-Up Agency Response From September 2015

Nothing new to report from the June submission.

California State Auditor's Assessment of Annual Follow-Up Status: Not Fully Implemented

1-Year Agency Response

All incoming students will receive prevention education which includes definitions of key concepts and policies (e.g. consent, sexual harassment, sexual assault, domestic violence, stalking); confidential support resources and reporting resources; rights and options, bystander intervention techniques; and how to support a friend that has experienced violence. Undergraduate students will receive at least three educational touchpoints prior to the start of instruction, including an online training module, two in-person trainings, and print resources. Every year, the campus will engage all students in several key educational opportunities including a comprehensive, coordinated, and evidence-based social norms education; key public awareness events (e.g. Take Back the Night); and peer education programs led by several key campus departments and student-led groups.

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

Although UC Berkeley has marked this recommendation as Fully Implemented, it has yet to determine a mechanism to ensure students are attending the educational opportunities annually. Therefore, we have assessed this recommendation as Partially Implemented.

6-Month Agency Response

Bear Pact,a mandatory in-person education program for all new students, was held on August 26, 2014, during the first week of classes. Bear Pact is a program that incorporates existing and recently enhanced programs related to alcohol abuse, sexual harassment and sexual violence prevention, and mental wellness. Bear Pact supplements and enhances online training offered through AlcoholEdu during the summer months prior to students arrival for the Fall term.

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

UC Berkeley did not address the second part of the recommendation regarding refresher training to all students at least annually. When asked about this, UC Berkeley stated it is waiting for President Napolitano's task force to address the refresher training to all students. This recommendation is only partially implemented.

60-Day Agency Response

New this fall, UCB (University of California, Berkeley)is offering a mandatory in-person education program entitled 'Bear Pact' for all new students during the first week of classes and after housing arrival. Bear Pact is a program that incorporates existing and recently enhanced programs related to alcohol abuse, sexual harassment and sexual violence prevention, and mental wellness. Bear Pact supplements and enhances online training offered through AlcoholEdu during the summer months prior to students arrival for the Fall.

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

UC Berkeley has implemented the first part of the recommendation by offering a mandatory in-person education program entitled "Bear Pact" for all new students during the first week of classes. UC Berkeley has not yet provided details on steps it plans on taking to provide refresher training at least annually for all students.

Recommendation #21 To: University of California, Los Angeles

All universities should provide their education on sexual harassment and sexual violence to incoming students as close as possible to when they arrive on campus but no later than the first few weeks of their first semester or quarter. Further, universities should provide periodic refresher educational programs, at least annually, to all students on campus to ensure that they are aware of how to handle and report incidents of sexual harassment and sexual violence.

Annual Follow-Up Agency Response From October 2019

1. Yearly training is required of special populations, such as Athletes, Fraternities/Sororities, Student Organizations, and other populations UCLA deems "at risk."

2. We have contracted with a vendor to provide ongoing online training for undergraduate and graduate students. The ongoing online trainings are expected to rollout in January 2020.

California State Auditor's Assessment of Annual Follow-Up Status: Pending

Annual Follow-Up Agency Response From October 2018

UCLA continues with the practice reported in May of 2017 with the following updates:

1. Yearly training is required of special populations, such as Athletes, Fraternities/Sororities, Student Organizations, and other populations UCLA deems "at risk."

2. The Title IX Office is working with campus partners to establish a mechanism for enforcement on the refresher training for continuing students. Currently, the enforcement used for new students is by placing holds on student records. However, with over forty five thousand students, the logistics of placing holds for continuing students has caused unexpected delays. We expect to have a mechanism in place for enforcement of the refresher training for graduate students in the winter of 2018 and for undergraduate students beginning fall of 2019; the content material for these "refresher" trainings is already available to us.

California State Auditor's Assessment of Annual Follow-Up Status: Partially Implemented

As the UCLA campus indicates in its response, it expects to take actions to fully implement this recommendation by fall 2019.

Annual Follow-Up Agency Response From November 2017

UCLA's practice with respect to incoming students remains consistent with 2016, and satisfies the CSA recommendations with respect to incoming students. With respect to periodic refresher educational programs, UCLA provides multiple periodic refresher educational programs throughout the year, including providing students with an online training course in the spring (a companion to "Think About It").

In addition to the online refresher course, supplementary programming is marketed to various communities (Greek Life, athletics, student leaders, on campus residents) to allow for a full range of students to access and be exposed to campus resources and a prevention framework. The framework intends to target across the social ecological model addressing individual attitudes, relational health, community values, and media and legislative literacy, in an attempt to create a consistent understanding of both problem and solution. Efficacy of programs is higher when the content is tailored to the group and participants have chosen to be there.

In addition, UCLA's senior leadership sends periodic messages to students and the reminding them of their rights, resources and options.

UCLA submits that the provision of these educational programs, and the communications, fully implement the CSA's recommendation, which stated that UCLA had to provide such programs but did not state that UCLA had to require that returning students participate in such programs.

California State Auditor's Assessment of Annual Follow-Up Status: Partially Implemented

Consistent with our assessment of UCLA's response to this recommendation in 2016, we do not consider this recommendation fully implemented because it does not ensure that all students take a refresher educational program at least annually. In its response this year, UCLA asserts that our recommendation states that UCLA had to provide such programs but did not state that UCLA had to require that returning students participate in such programs. However, we do not agree that periodic refresher educational programs can be considered provided to all students, as we recommended, if participation is not required. Further, as we stated on page 28 of our report, voluntary educational programs can be useful; however, to ensure that every student on campus is consistently and regularly made aware of how to handle and report incidents of sexual harassment and sexual violence, universities should require all students to complete mandatory refresher training.

Annual Follow-Up Agency Response From October 2016

In accordance with mandates from UCOP, UCLA requires that every incoming student receive three points of education within the first six weeks of fall quarter. First, every incoming student (undergraduate, graduate and professional) must participate in an online education program ("Think About It," by Campus Clarity). Second, in-person sexual violence and sexual harassment education is provided to every new student. A large number of the new students (undergraduate and graduate) receive this in-person training at orientation. Students who do not attend the training at orientation must attend one of several other in-person training sessions that are provided. Participation in both the online education module and the in-person orientation is tracked, and students who do not complete both the in-person training and the online training receive a registration hold on their records. Third, in addition to this in-person and online training, all students (incoming and returning) receive additional written communication about sexual violence prevention. This written communication includes information about the reporting options and resources available to students who have experienced sexual violence.

Refresher training occurs throughout the year for all students. Such refresher training is delivered in a variety of ways, including: written communications (such as the one described above); online trainings; a forum convened by the Title IX office to discuss the UC Policy on Sexual Violence and Sexual Harassment; workshops and trainings conducted by the Campus Assault Resources & Education (CARE) office; and a variety of other in-person trainings and prevention awareness workshops offered throughout the year.

California State Auditor's Assessment of Annual Follow-Up Status: Not Fully Implemented

UCLA stated written communication is provided to students on reporting options and resources available to students who have experienced sexual violence. Further, UCLA stated the campus provides several key educational opportunities to all students. However, attendance is not required at these educational opportunities. Therefore, UCLA cannot ensure all students take a refresher educational program at least annually. For this reason, we have marked this recommendation as not fully implemented.

Annual Follow-Up Agency Response From September 2015

Over 6200 of our approximately 9000 incoming students have completed the mandatory online education program, "Think About It." 100% compliance will be achieved through record holds. Approximately 95% of the incoming students received the in-person prevention education through orientation, and make-up sessions are scheduled.

All incoming graduate students are also being required to participate in mandated online prevention education. In-person presentations have occurred at graduate school orientation and orientations of the professional schools. Similar presentations are scheduled to occur at the various graduate divisions.

The University will send a letter to all students within the first six weeks of school reminding all students of their confidential resources and reporting options for sexual harassment and sexual violence.

Although it is too early to provide refresher training for the 2015-16 academic year (which has just begun), UCLA did provide such refresher training in the 2014-15 academic year. Specifically, in April 2015, Chancellor Block sent a letter to all students informing them of their confidential resources and reporting options.

California State Auditor's Assessment of Annual Follow-Up Status: Not Fully Implemented

1-Year Agency Response

Incoming freshmen to receive training in orientation, during the summer, and refresher training at the start of the quarter. Transfer students to receive online education at the start of Fall quarter. Record holds will ensure 100% compliance. The Prevention Education Steering Committee members will ensure training is compliant with relevant laws and requirements (e.g., Violence Against Women Act ("VAWA"), UC President's Task Force on Preventing and Responding to Sexual Violence and Sexual Assault ("President's Task Force")). Core concepts, developed by President's Task Force, will be covered at the initial stage (first 6 weeks at UC), on an ongoing basis (at least twice per year (i.e., semester or quarter) without duplication). Targeted groups will receive additional education opportunities with tailored content. The newly hired Assistant Director at CARE will assist in development and delivery of prevention education.

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

Although UCLA has marked this as Fully Implemented, it is still working on the refresher training that will be provided to all students annually.

6-Month Agency Response

Incoming freshmen (first year - FY) received training in orientation, during the summer, and refresher training at the start of the quarter. Record holds ensured compliance and we have 100% compliance.

Transfer students received online education which was completed at the start of Fall quarter, and record holds ensured 100% compliance.

The university is in the process of determining how to best provide periodic refresher educational programs to all students at least annually.

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

60-Day Agency Response

Incoming freshmen (first year - FY) and incoming undergraduate transfers (TR) receive training in orientation during the summer, and an online refresher program close to the start of the quarter. New undergraduates receive: the Bruin Support & Safety brochure, a new student handbook that includes the Student Conduct Code, and a "True Bruins Care" card with information on resources and support.

FYs: A 1-hr presentation from the Office of the Dean of Students that includes the definition of consent; the confidential resources and reporting options for students who are victims of sexual harassment, sexual violence, domestic violence, and stalking; reporting options for students who are victims of sexual harassment, sexual violence, domestic violence, and stalking; and potential sanctions for those found responsible.

A 2-hr comprehensive presentation that includes policies and procedures in regards to sexual harassment, sexual violence, domestic violence, and stalking as well as confidential resources, reporting options, and bystander intervention training.

An online alcohol and other drugs education program with a component on the policies as well as prevention of sexual violence (1.5 hours).

TRs: A 20-minute presentation from the Office of the Dean of Students with content similar to that includes the definition of consent; the confidential resources and reporting options for students who are victims of sexual harassment, sexual violence, domestic violence, and stalking; reporting options for students who are victims of sexual harassment, sexual violence, domestic violence, and stalking; and potential sanctions for those found responsible.

Two online alcohol and other drugs education programs with component on the policies as well as prevention of sexual violence including bystander intervention (takes approximately 3.5 hours)

Additionally, UCLA intends to provide refresher training annually to all students.

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

UCLA provides an online refresher program close to the start of the quarter. Further, UCLA intends to provide refresher training annually to all students.

Recommendation #22 To: Chico, California State University

All universities should provide supplemental training on sexual harassment and sexual violence, including sexual assault, for all student athletes on an annual basis. Further, the universities should provide supplemental training on sexual harassment and sexual violence, including rape awareness, to all student members of fraternities and sororities on an annual basis. The universities should also determine which student organizations participate in activities that may place students at risk and ensure that they receive annual, supplemental training on sexual harassment and sexual violence, including rape awareness. Each of the trainings should be focused on situations the members of the respective student groups may encounter.

1-Year Agency Response

CSU, Chico has implemented supplemental sexual harassment and sexual violence training, including rape awareness, for identified student groups: student athletes and student organizations (including fraternities and sororities) on an annual basis. Trainings focused on situations the members of the respective groups may encounter.

CSU Chico's student athletes were trained in August 2014, and the next training is scheduled for August 2015.

New members of sororities and fraternities received introductory Title IX training on September 20, 2014, as part of their orientation. CSU Chico hosted a Sexual Violence and Sexual Harassment training for members of the Fraternity and Sorority community in January 2015. The event was attended by over 350 individuals, and focused heavily on situations tailored to this student group. This large training for the Greek community was followed by a smaller presentation focused on bystander intervention and involved leaders in the Greek community.

CSU Chico also presented Title IX training and awareness as part of the Spring Greek orientation, attended by over 400 new members.

Rather than identify specific clubs or student groups, CSU Chico currently requires training for all student groups/clubs as part of their annual recognition process.

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

6-Month Agency Response

CSU, Chico has developed and is in the process of implementing supplemental sexual harassment and sexual violence training, including rape awareness, for identified student groups: student athletes and student organizations (including fraternities and sororities) on an annual basis. Trainings focuses on situations the members of the respective groups may encounter.

CSU Chico's student athletes were trained in August 2014.

New members of sororities and fraternities received introductory Title IX training on September 20, 2014, as part of their orientation. Training for all fraternity and sorority members is scheduled in January 2015.

CSU Chico continues to identify and present training to student groups as part of their annual recognition process.

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

60-Day Agency Response

CSU, Chico has developed and is in the process of implementing supplemental sexual harassment and sexual violence training, including rape awareness, for identified student groups: student athletes, student organizations including fraternities and sororities on an annual basis. Trainings focus on situations the members of the respective groups may encounter.

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

The information developed by CSU Chico is still in draft form.

Recommendation #23 To: San Diego, California State University

All universities should provide supplemental training on sexual harassment and sexual violence, including sexual assault, for all student athletes on an annual basis. Further, the universities should provide supplemental training on sexual harassment and sexual violence, including rape awareness, to all student members of fraternities and sororities on an annual basis. The universities should also determine which student organizations participate in activities that may place students at risk and ensure that they receive annual, supplemental training on sexual harassment and sexual violence, including rape awareness. Each of the trainings should be focused on situations the members of the respective student groups may encounter.

1-Year Agency Response

Members of Greek organizations, student-athletes, and Associated Students'(A.S.)Board of Directors and the A.S. Councils have been enrolled in supplemental online training through Agent of Change. We will require completion of the training by these students by the end of each fall semester and will place registration holds for students who do not complete the training.

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

6-Month Agency Response

The CSU is currently negotiating a contract with a provider of online sexual violence prevention training. Members of fraternities and sororities, student-athletes and students who are members of high-risk student organizations will be required to complete this training.

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

60-Day Agency Response

The CSU is currently negotiating a contract with a provider of online sexual violence prevention training. Members of fraternities and sororities, student-athletes and students who are members of high-risk student organizations will be required to complete this training.

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

Recommendation #24 To: University of California, Berkeley

All universities should provide supplemental training on sexual harassment and sexual violence, including sexual assault, for all student athletes on an annual basis. Further, the universities should provide supplemental training on sexual harassment and sexual violence, including rape awareness, to all student members of fraternities and sororities on an annual basis. The universities should also determine which student organizations participate in activities that may place students at risk and ensure that they receive annual, supplemental training on sexual harassment and sexual violence, including rape awareness. Each of the trainings should be focused on situations the members of the respective student groups may encounter.

Annual Follow-Up Agency Response From October 2016

UC Berkeley implemented in-person education about the prevention of and response to sexual violence and harassment for leaders of all registered student organizations. Organizations that do not participate in the education program do not receive access to the privileges available to registered student organizations (e.g. funding, space reservations, etc.). Also, each semester, UC Berkeley determines which student organizations would benefit from supplemental prevention education based on an assessment of the group's activities, culture, and norms. In partnership with the student organization and a prevention expert, UC Berkeley develops and implements a tailored workshop, training, or module. Furthermore, any student organization found responsible for violating the Code of Conduct for sexual violence and sexual harassment is subject to a range of sanctions and, in addition, supplemental education and training.

UC Berkeley continues to implement annual in-person prevention education for all student-athletes and all students in fraternities and sororities. Content is tailored for the culture, norms, and issues relevant to each population and includes rape awareness.

California State Auditor's Assessment of Annual Follow-Up Status: Fully Implemented

Annual Follow-Up Agency Response From September 2015

UC Berkeley has more than 1,000 registered students groups on campus. Based on the auditor's recommendation and our desire to enhance the ways in which we educate student organizations and communities about sexual violence, we provide in person trainings and resources to groups who are either new to our campus community, or those that engage in off campus travel or activities. The campus previously submitted training documents used to train the signatories of these student organizations, as well as a schedule of those trainings. The students who attend these trainings on behalf of their organizations are given access to materials and are able to share the information to the remaining membership in a "train the trainer" format.

It is important to note, the campus does not keep rosters of student organizations. As a university we support our students' freedom of association within their co-curricular lives. Requiring students to list their names on organizational rosters limits their ability to freely associate in organizations that are identity or issues based. For instance, if we required rosters, some students may not join organizations that are identity or politically focused because they may wish to keep that aspect of their lives or particular area of interest, private. Our current practice supports healthy identity development and allows students to freely engage in activities and organizations that promote self-exploration and a healthy sense of self.

California State Auditor's Assessment of Annual Follow-Up Status: Partially Implemented

Although UC Berkeley provided evidence of the training that it provided to student representatives of various student groups, the materials provided had minimal information on sexual harassment and sexual violence. The recommendation states student organizations identified by the university should receive annual supplemental training on sexual harassment and sexual violence, including rape awareness. The training should be focused on situations the members of the respective student groups may encounter. Therefore, we assessed this recommendation as Partially Implemented.

1-Year Agency Response

All student leaders (signatories) of registered student organizations (RSO) are required to complete an online training and certification with increased attention to topics of sexual harassment, sexual violence, and active bystander intervention. In addition, beginning in Fall of 2015, targeted student groups and an increased number of student leaders (signatories) of all RSOs will receive supplemental, in-person annual training on sexual harassment and sexual violence which includes information about bystander intervention, confidential resources, rights and options, and reporting. Targeted student groups will consist of all members of the newly formed registered student organizations each semester. New student organizations will be placed on a probationary status until members attend a once per semester training. There will also be an increase in the number of student leaders who must attend the mandatory, in-person student organization orientation--at least half of student signatories required for registration with the university must attend. In addition, all students in RSOs, with particular attention to organizations that travel, will receive education and information regarding bystander intervention and supporting someone impacted by sexual harassment and violence. Student organizations found responsible for policy violations will receive sanctions that may include appropriate training and education related to violence prevention.

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

Although UC Berkeley marked this as Fully Implemented, it did not provide support for the training provided to other targeted groups, such as newly formed registered student organizations. UC Berkeley has updated training for athletes, fraternity, and sorority members. Therefore, we have assessed this recommendation as Partially Implemented.

6-Month Agency Response

In the Fall of 2014, UC Berkeley undertook comprehensive supplemental training on sexual harassment and sexual violence across various student groups. All student athletes were required to attend a 90 minute specialized training provided by Jackson Katz, a national expert in gender violence, on December 2.

Fraternity and Sorority leadership including key positions (Presidents, Risk Managers, and Social Chairs) attended mandatory training on August 25, 2014; the IFC (Inter Fraternity Council) hosted a New Member Academy and New Member Educators Summit on September 21, training new incoming fraternity members and those fraternity leaders who conduct their new member education process. On November 18, the Dean of Students hosted a Greek (fraternity/sorority) forum on sexual violence and assault prevention, including Greek students, alumni advisors, inter/national headquarters representatives, and University leadership. On October 8, 2014 the Inter-fraternity Council unanimously voted to mandate one educational program on sexual assault prevention each semester for each IFC chapter, and unanimously voted to create a new position of Vice President for Health & Safety. A main role for the VP is to look at ways to prevent sexual assault in the CalGreeks community. Other Greek Councils are creating similar structures in their leadership.

All RSOs (Registered Student Organizations) were required to send one member identified as a signatory (i.e. someone who has signing authority and scheduling privileges) to Student Organization Orientation, where pertinent topics were discussed including leadership identity, campus policies and practices, and information regarding campus resources and services. This was a requirement in order to be recognized as a RSO. This practice will continue moving forward.

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

Berkeley has made efforts to ensure all student athletes and fraternity and sorority members receive additional supplemental training on sexual harassment and sexual violence, including rape awareness annually. However, Berkeley has not identified certain student groups to provide annual, supplemental training on sexual harassment and sexual violence, including rape awareness.

60-Day Agency Response

OPHD (Office for the prevention of Harassment and Discrimination) and IA (Intercollegiate Athletics) exploring purchase of online tool to supplement training students already receive. In 2015, may use in-person presentations to student athletes at various intervals. (June 2015)

This Fall, enhanced training and programs are being offered from the LEAD (Leadership, Engagement, Advising and Development) Center Fraternity & Sorority Advising and Leadership Development team that includes information and resources regarding Sexual Misconduct and Title IX. These trainings have been developed collaboratively; including the input of campus experts and authorities with responsibility and oversight for the material covered. (Fall 2014 and ongoing)

This fall, all RSOs (Registered Student Organizations) will be required to send one member identified as a signatory (i.e. someone who has signing authority and scheduling privileges) to Student Organization Orientation, where pertinent topics will be discussed including leadership identity, campus policies and practices, and information regarding campus resources and services. After September 13th, benefits will be suspended to the those student groups not in compliance until they participate. This is a new approach and fall 2014 will be the first time this process has been implemented. (Fall 2014 and ongoing)

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

Recommendation #25 To: University of California, Los Angeles

All universities should provide supplemental training on sexual harassment and sexual violence, including sexual assault, for all student athletes on an annual basis. Further, the universities should provide supplemental training on sexual harassment and sexual violence, including rape awareness, to all student members of fraternities and sororities on an annual basis. The universities should also determine which student organizations participate in activities that may place students at risk and ensure that they receive annual, supplemental training on sexual harassment and sexual violence, including rape awareness. Each of the trainings should be focused on situations the members of the respective student groups may encounter.

Annual Follow-Up Agency Response From October 2016

UCLA provides supplemental in-person training on sexual violence and sexual harassment prevention to every student athlete (male and female). The training discusses a number of issues related to sexual violence and sexual harassment prevention. Last year, UCLA conducted in-person training to every athlete on a team-by-team basis. This year, in addition to training its athletes on issues related to sexual assault, UCLA has partnered with the One Love Foundation, an organization founded in memory of Yeardley Love (a female college athlete who was killed by her college athlete ex-boyfriend) to train the athletes on relationship violence prevention and intervention.

Supplemental training is also provided to student members of fraternities and sororities. Last year, UCLA required every fraternity and sorority member to attend an in-person training session that discussed issues related to sexual violence. In addition, UCLA launched the VIP Program where every fraternity and sorority designated one member of their house to become a prevention education liaison. The VIPs participated in numerous trainings throughout the year, and shared much of what they learned with their individual chapters. This year, the VIPs worked with UCLA to develop prevention education content tailored to the fraternities and sororities, and helped UCLA facilitate the in-person supplemental training provided to fraternity and sorority members.

UCLA also provides tailored training to other student organizations that participate in activities that may place students at risk for sexual violence. Recipients of such supplemental training include: registrants of student clubs through Student Organizations, Leadership & Engagement (SOLE); students who play club sports; students in student government; and students who work as tour guides for UCLA. UCLA is continuing to identify higher-risk student groups who could benefit from supplemental tailored training on sexual violence prevention.

California State Auditor's Assessment of Annual Follow-Up Status: Fully Implemented

Annual Follow-Up Agency Response From September 2015

UCLA provided tailored in-person training to our athletes and our members of fraternities and sororities during the 2014-15 academic year.

This year, we are in the midst of providing tailored in-person programming to our almost 700 student athletes, team by team. We are also in process of delivering tailored in-person training to our 3500-person Greek Life Community.

Working with Student Organizations Leadership & Engagement ("SOLE"), as well as all club sports, UCLA is finalizing an online sexual violence prevention training module, which will be delivered to leaders of all registered SOLE organizations and all club sports participants.

We have delivered multiple in-person trainings to UCLA's Community Programs Office.

California State Auditor's Assessment of Annual Follow-Up Status: Not Fully Implemented

Annual Follow-Up Agency Response From September 2015

UCLA provided tailored in-person training to our athletes and our members of fraternities and sororities during the 2014-15 academic year.

This year, we are in the midst of providing tailored in-person programming to our almost 700 student athletes, team by team. We are also in process of delivering tailored in-person training to our 3500-person Greek Life Community.

Working with Student Organizations Leadership & Engagement ("SOLE"), as well as all club sports, UCLA is finalizing an online sexual violence prevention training module, which will be delivered to leaders of all registered SOLE organizations and all club sports participants.

We have delivered multiple in-person trainings to UCLA's Community Programs Office.

California State Auditor's Assessment of Annual Follow-Up Status: Not Fully Implemented

Annual Follow-Up Agency Response From September 2015

UCLA provided tailored in-person training to our athletes and our members of fraternities and sororities during the 2014-15 academic year.

This year, we are in the midst of providing tailored in-person programming to our almost 700 student athletes, team by team. We are also in process of delivering tailored in-person training to our 3500-person Greek Life Community.

Working with Student Organizations Leadership & Engagement ("SOLE"), as well as all club sports, UCLA is finalizing an online sexual violence prevention training module, which will be delivered to leaders of all registered SOLE organizations and all club sports participants.

We have delivered multiple in-person trainings to UCLA's Community Programs Office.

California State Auditor's Assessment of Annual Follow-Up Status: Not Fully Implemented

Annual Follow-Up Agency Response From September 2015

Over 6200 of our approximately 9000 incoming students have completed the mandatory online education program, "Think About It." 100% compliance will be achieved through record holds. Approximately 95% of the incoming students received the in-person prevention education through orientation, and make-up sessions are scheduled.

All incoming graduate students are also being required to participate in mandated online prevention education. In-person presentations have occurred at graduate school orientation and orientations of the professional schools. Similar presentations are scheduled to occur at the various graduate divisions.

The University will send a letter to all students within the first six weeks of school reminding all students of their confidential resources and reporting options for sexual harassment and sexual violence.

Although it is too early to provide refresher training for the 2015-16 academic year (which has just begun), UCLA did provide such refresher training in the 2014-15 academic year. Specifically, in April 2015, Chancellor Block sent a letter to all students informing them of their confidential resources and reporting options.

California State Auditor's Assessment of Annual Follow-Up Status: Not Fully Implemented

1-Year Agency Response

Targeted training for the student groups identified in the President's Task Force and other student groups will be provided in person with tailored content. The newly hired Assistant Director at CARE will assist in development and delivery of prevention education, including supplemental training to targeted groups.

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

Although UCLA marked this as Fully Implemented, the training to other student organizations is still being developed. UCLA has updated training for athletes, fraternity, and sorority members.

6-Month Agency Response

Specific sexual misconduct training for athletes, including training in sexual assault, has been completed for all but one team. All trainings will be completed by the end of Fall quarter 2014.

All new and prospective members of fraternities and sororities received the "Blame It on the Alcohol" sexual violence prevention training during recruitment. All returning members are receiving "it's On Us to Stand" training in Fall quarter, which focuses on bystander intervention techniques in settings relevant to greek life.

All new organizations in UCLA Student Organizations, Leadership & Engagement (SOLE) have been trained. All returning organizations will be trained through the module that is being finalized in Recreation and will be sent to all signatories of returning organizations along with all Recreation club sports participants and student staff.

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

60-Day Agency Response

UCLA has comprehensive plans to provide additional targeted training in the Fall quarter. Special populations that will receive this additional training include all members of fraternities and sororities, and all members of intercollegiate and club sports teams. Training for fraternities and sororities is developed by a collaboration of the Title IX Officer, the Dean of Students, CARE@CAPS (Campus Assault Resources & Education at Counseling & Psychological Services), and leadership in Student Affairs. Training for Athletics and Recreation is developed by a collaboration of the Title IX Officer, the Dean of Students, CARE@CAPS(Campus Assault Resources & Education at Counseling & Psychological Services), and the leadership of staff in Athletics and Recreation.

UCLA is developing plans for additional targeted training for all student organizations.

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

Recommendation #26 To: Chico, California State University

To ensure compliance with federal law and guidance, all universities should review their educational programs for incoming students and employees and modify them as needed, as outlined in the Reauthorization Act and the 2014 guidance issued by the OCR.

1-Year Agency Response

Staff and faculty orientation was reviewed for compliance with the Reauthorization Act and the 2014 OCR guidance, and now includes specific information on reporting obligations concerning Title IX matters such as where to make such reports, how to advise students concerning the obligation to makes such reports, and resources to ensure that victims are not revictimized. Attendees are also provided hardcopies of relevant policies and the campus wide electronic notice that is issued near the start of each academic year. The information provided at new employee orientation is intended to be a stepping stone for the more detailed training provided to employees as per recommendation No. 6. The combination of these two pieces will ensure that employees receive the most pressing information shortly after hire, and the remaining aspects of the recommended information upon prompt completion of the required training.

The incoming student training concerning sexual violence has been updated to include site specific information and resources for victims and others desiring to make reports. During completion of the student training module, students must click a box acknowledging receipt of our university policies and resources in order to successfully complete the program.

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

6-Month Agency Response

To ensure compliance with federal law and guidance, staff and faculty orientation now includes specific information on reporting obligations concerning Title IX matters including where to make such reports, how to advise students concerning the obligation to makes such reports, and resources to ensure that victims are not revictimized. Attendees are also provided hardcopies of relevant policies and the campus wide electronic notice that is issued near the start of each semester. The information provided at new employee orientation is intended to be a stepping stone for the more detailed training provided to employees as per recommendation No. 6. The combination of these two pieces will ensure that employees receive the most pressing information shortly after hire, and the remaining aspects of the recommended information upon prompt completion of the required training. Full implementation will be in place upon completion of our meet and confer obligations as outlined in our response to recommendation No. 6

The incoming student training concerning sexual violence has been updated to include site specific information and resources for victims and others desiring to make reports. During completion of the student training module, students must click a box acknowledging receipt of our university policies and resources in order to successfully complete the program.

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

60-Day Agency Response

To ensure compliance with federal law and guidance, staff and faculty orientation now includes specific information on reporting obligations concerning Title IX matters. Attendees are also provided a hard copy of the campus wide electronic notice that is issued near the start of each semester.

The incoming student training concerning sexual violence has been updated to include site specific information and resources for victims and others desiring to make reports. During completion of the student training module, students must click a box acknowledging receipt of our university policies and resources in order to successfully complete the program.

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

Chico State is still in the process of implementing changes to its educational programs for incoming students and employees. The changes it has made are still in draft form.

Recommendation #27 To: San Diego, California State University

To ensure compliance with federal law and guidance, all universities should review their educational programs for incoming students and employees and modify them as needed, as outlined in the Reauthorization Act and the 2014 guidance issued by the OCR.

1-Year Agency Response

SDSU has reviewed and revised its student and employee education programs to ensure that the content of the education on sexual violence is consistent with federal law and guidance.

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

6-Month Agency Response

SDSU is in the process of reviewing and revising its employee education programs to ensure that the content of the education on sexual violence is consistent with federal law and guidance.

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

60-Day Agency Response

SDSU is in the process of reviewing and revising its employee education programs to ensure that the content of the education on sexual violence is consistent with federal law and guidance.

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

Recommendation #28 To: University of California, Berkeley

To ensure compliance with federal law and guidance, all universities should review their educational programs for incoming students and employees and modify them as needed, as outlined in the Reauthorization Act and the 2014 guidance issued by the OCR.

1-Year Agency Response

The Title IX Officer reviews all mandated sexual harassment and sexual violence education content to ensure that it meets the requirements outlined in federal and state law. In addition, the Coordinated Community Review Team will participate in the coordination of prevention and awareness programs moving forward. This new committee replaces the Title IX Compliance Advisory Committee.

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

6-Month Agency Response

Current educational programs for incoming students and employees will be reviewed systemwide during phase two of President Napolitano's Task Force for Preventing and Responding to Sexual Violence and Sexual Assault.

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

60-Day Agency Response

Current educational programs for incoming students and employees will be reviewed systemwide during phase two of President Napolitano's Task Force for Preventing and Responding to Sexual Violence and Sexual Assault.

All training programs have been updated and modified to reflect changes in federal law and the 2014 guidance issued by the OCR (Office for Civil Rights), including reporting responsibilities and information required under the Violence Against Women Act (VAWA).

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

The Office of the President through the Task Force for Preventing and Responding to Sexual Violence and Sexual Assault is planning to review training programs systemwide.

Recommendation #29 To: University of California, Los Angeles

To ensure compliance with federal law and guidance, all universities should review their educational programs for incoming students and employees and modify them as needed, as outlined in the Reauthorization Act and the 2014 guidance issued by the OCR.

1-Year Agency Response

The Title IX Coordinator reviews all training materials and works with campus counsel to ensure that Prevention Education programs are compliant with relevant laws and requirements (e.g., Violence Against Women Act ("VAWA")). In addition, the President's Task Force has developed "core concepts" for initial, ongoing and targeted training. The Prevention Education Steering Committee, working with Title IX Coordinator, will ensure prevention education covers these core concepts.

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

6-Month Agency Response

All training programs have been updated and modified to reflect changes in federal law and the 2014 guidance issued by the OCR, including reporting responsibilities and information required under the Violence Against Women Act (VAWA).

Additionally, current educational programs for incoming students and employees will be reviewed system wide during phase two of the Task Force for Preventing and Responding to Sexual Violence and Sexual Assault.

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

60-Day Agency Response

All training programs have been updated and modified to reflect changes in federal law and the 2014 guidance issued by the OCR, including reporting responsibilities and information required under the Violence Against Women Act (VAWA).

Additionally, current educational programs for incoming students and employees will be reviewed system wide during phase two of the Task Force for Preventing and Responding to Sexual Violence and Sexual Assault.

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

Recommendation #30 To: Chico, California State University

To comply with state law, all universities must ensure the appropriate distribution of their written policy on sexual harassment to all university employees at the beginning of every academic year.

6-Month Agency Response

To comply with state law, CSU, Chico sent a letter to all faculty and staff regarding their reporting obligations. The letter included a link to the Title IX website with resources, as well as a link to the University policies and complaint procedures for addressing incidents of sexual harassment.

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

60-Day Agency Response

To comply with state law, CSU, Chico will send letters at the beginning of the semester to all faculty and staff regarding their reporting obligations. The letters include a link to the Title IX website with resources, as well as a link to the University policy and complaint procedures for addressing incidents of sexual harassment.

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

Recommendation #31 To: San Diego, California State University

To comply with state law, all universities must ensure the appropriate distribution of their written policy on sexual harassment to all university employees at the beginning of every academic year.

6-Month Agency Response

SDSU sent an email to all employees on August 26, 2014 that provides resource information and refresher training on the issue of sexual violence. This email is an annual notification that, in the future, will be sent at the start of the academic year and will include a link to the Title IX brochure. Additionally, this communication is posted on department bulletin boards. All new employees are provided with a copy of this annual notification as part of the new hire paperwork.

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

60-Day Agency Response

SDSU will distribute its written policy on sexual harassment to all university employees via email at the beginning of every academic year.

SDSU will send an email to all employees that provides resource information and refresher training on the issue. This email will be sent at the start of the semester and will include a link to the Title IX brochure. Additionally, this communication will be posted on department bulletin boards.

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

Recommendation #32 To: University of California, Berkeley

To comply with state law, all universities must ensure the appropriate distribution of their written policy on sexual harassment to all university employees at the beginning of every academic year.

6-Month Agency Response

A campus-wide memo distributing the policy to all faculty, staff and students was sent on October 20, 2014. Text from the memo can be found here: https://calmessages.berkeley.edu/archives/message/36748

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

60-Day Agency Response

Policy will be distributed to campus via email from the Chancellor at the beginning of Fall 2014 term, and then annually going forward. Additionally, campus will launch a public awareness campaign on sexual violence targeted to undergraduate students at the beginning of the 2014-15 school year. Posters, flyers and other materials will refer students to survivorsupport.berkeley.edu for information, policies and resources.

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

Recommendation #33 To: University of California, Los Angeles

To comply with state law, all universities must ensure the appropriate distribution of their written policy on sexual harassment to all university employees at the beginning of every academic year.

6-Month Agency Response

The written policy on sexual harassment was distributed to all university employees on December 10, 2014.

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

60-Day Agency Response

The written policy on sexual harassment will be distributed to all university employees at the beginning of every academic year and will include information with respect to reporting responsibilities.

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

Recommendation #34 To: Chico, California State University

All universities should appropriately post the university's policy on sexual harassment. The policy should be posted prominently in the university's main administrative building and in other areas on campus where notices are posted, including key locations such as residence halls and athletic facilities. Similarly, the notice of nondiscrimination should be posted prominently throughout the university. If, because of the length of the policy on sexual harassment, it is not effective to post it in its entirety, the universities should post summary information that explains how students can access the full policy.

60-Day Agency Response

In order to ensure appropriate distribution of the university's written policy on sexual harassment the university has taken the following measures:

Posted Executive Order 1095 along with its Attachments A (Notice of Non-Discrimination on the Basis of Gender or Sex) and C (Rights and Options for Victims) in the following areas along with a poster summarizing these documents.

- Administration Building

- Residence Halls

- Student Union

- WREC Center

- Athletics

- Student Health Center

- Student Services Center

The University will continue to rely most heavily on the online version of the policies, as that has proven to be the most accessed and accessible format for dissemination.

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

Recommendation #35 To: San Diego, California State University

All universities should appropriately post the university's policy on sexual harassment. The policy should be posted prominently in the university's main administrative building and in other areas on campus where notices are posted, including key locations such as residence halls and athletic facilities. Similarly, the notice of nondiscrimination should be posted prominently throughout the university. If, because of the length of the policy on sexual harassment, it is not effective to post it in its entirety, the universities should post summary information that explains how students can access the full policy.

Annual Follow-Up Agency Response From October 2015

SDSU has posted summary information on its nondiscrimination policy across campus. The posters have been posted in all colleges, in various locations within the university library, in administrative offices and residential housing facilities.

California State Auditor's Assessment of Annual Follow-Up Status: Fully Implemented

1-Year Agency Response

SDSU is in the process of posting summary information on its nondiscrimination policy and sexual harassment policy with an explanation on how students can access the full policy in prominent places across campus.

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

6-Month Agency Response

SDSU is in the process of posting summary information on its nondiscrimination policy and sexual harassment policy with an explanation on how students can access the full policy in prominent places across campus.

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

60-Day Agency Response

SDSU is in the process of posting summary information on its nondiscrimination policy and sexual harassment policy with an explanation on how students can access the full policy in prominent places across campus.

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

Recommendation #36 To: University of California, Berkeley

All universities should appropriately post the university's policy on sexual harassment. The policy should be posted prominently in the university's main administrative building and in other areas on campus where notices are posted, including key locations such as residence halls and athletic facilities. Similarly, the notice of nondiscrimination should be posted prominently throughout the university. If, because of the length of the policy on sexual harassment, it is not effective to post it in its entirety, the universities should post summary information that explains how students can access the full policy.

6-Month Agency Response

The University's policy on sexual harassment and notice of nondiscrimination are disseminated electronically by the Chancellor at the beginning of each academic year. The campus annual security report containing the full Student Code of Conduct and prominent links to the UC Policy on Sexual Harassment and Sexual Violence and the sexual violence survivor support website, and educational resources is disseminated to every student in October. Included in student orientation materials is information on confidential resources, reporting options, and how to file a complaint. Additionally, the campus launched a public awareness campaign on sexual violence targeted to undergraduate students at the beginning of the 2014-15 school year. Posters, flyers and other materials refer students to survivorsupport.berkeley.edu for information, policies and resources.

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

60-Day Agency Response

Policy will be distributed to campus via email from the Chancellor at the beginning of Fall 2014 term, and then annually going forward. Additionally, campus will launch a public awareness campaign on sexual violence targeted to undergraduate students at the beginning of the 2014-15 school year. Posters, flyers and other materials will refer students to survivorsupport.berkeley.edu for information, policies and resources.

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

Recommendation #37 To: University of California, Los Angeles

All universities should appropriately post the university's policy on sexual harassment. The policy should be posted prominently in the university's main administrative building and in other areas on campus where notices are posted, including key locations such as residence halls and athletic facilities. Similarly, the notice of nondiscrimination should be posted prominently throughout the university. If, because of the length of the policy on sexual harassment, it is not effective to post it in its entirety, the universities should post summary information that explains how students can access the full policy.

6-Month Agency Response

The University's policy on sexual harassment and notice of nondiscrimination is posted (in hard copy) in the residence halls and campus administrative offices, including, but not limited to, the Office of the Dean of Students, academic offices, UCPD, CAPS, and Athletics. Additionally, summary information explaining how to access the full sexual harassment policy is posted on digital screens in the residence halls; Murphy Hall, the campus' administrative building; recreation facilities and other university venues, and is included in printed materials provided to students, staff, and faculty and community members. The entire Student Conduct Code was included in student orientation materials, along with a Bruin Support and Safety brochure which provides information on confidential resources, reporting options, and how to file a complaint.

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

60-Day Agency Response

The University's policy on sexual harassment and notice of nondiscrimination will be posted in the Office of the Dean of Students and in residence halls for the start of the Fall quarter.

Summary information explaining how to access the full sexual harassment policy is posted on digital screens in the residence halls; Murphy Hall, the campus' administrative building; and other university housing. Included in student orientation materials is the entire Student Conduct Code; and a Bruin Support and Safety brochure which provides information on confidential resources, reporting options, and how to file a complaint.

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

Recommendation #38 To: San Diego, California State University

To ensure that all incoming students receive education on sexual harassment and sexual violence, San Diego State and UC Berkeley should impose consequences, such as registration holds, on those not receiving the education.

1-Year Agency Response

All incoming students for Academic Year 2015-16 will be required to complete an online training program. Failure to complete the training will result in registration holds pending completion.

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

San Diego State is now requiring incoming students to attend sexual harassment and sexual violence education. If students do not attend the training a registration hold will be put in place.

6-Month Agency Response

All incoming students are required to view a 30 minute presentation on sexual harassment and sexual violence during New Student Orientation. Those who do not attend orientation are required to complete the training online. Completion of this training will be regularly monitored and students will receive reminders to complete the training in a timely manner. Students who fail to complete the training will be contacted directly and required to attend an in-person presentation. Further, incoming students are required to complete the Sexual Violence online training, as part of the e-Checkup to Go program, during their first semester. San Diego State is reviewing other options to enforce the training requirements.

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

60-Day Agency Response

All incoming students are required to view a 30 minute presentation on sexual harassment and sexual violence during New Student Orientation. Those who do not attend orientation are required to complete the training online. Completion of this training will be regularly monitored and students will receive reminders to complete the training in a timely manner. Students who fail to complete the training will be contacted directly and required to attend an in-person presentation. Further, incoming students are required to complete the Sexual Violence online training, as part of the e-Checkup to Go program, during their first semester. San Diego State is reviewing other options to enforce the training requirements.

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

Recommendation #39 To: University of California, Berkeley

To ensure that all incoming students receive education on sexual harassment and sexual violence, San Diego State and UC Berkeley should impose consequences, such as registration holds, on those not receiving the education.

6-Month Agency Response

Mandatory education was enforced with registration and enrollment blocks. First year students who did not comply with the mandate by October 1 were blocked from enrolling in the subsequent semester. Students were provided the opportunity to attend Bear Pact, scheduled EmpowerU sessions, or take the Haven online module to satisfy the requirement. Compliance to date is at 99% of all incoming first year undergraduate students.

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

60-Day Agency Response

Proposal for implementation has been drafted and is currently under review. It includes mandatory education and proposal for administrative registration block for undergraduate students that do not receive education.

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

Recommendation #40 To: San Diego, California State University

San Diego State should widely distribute its Title IX brochure to ensure that all students and employees are aware of how to handle incidents of sexual harassment and sexual violence.

6-Month Agency Response

A link to the Title IX Brochure was sent to all employees via email on August 26, 2014. A link to the Title IX Brochure was sent to all students via email on August 27, 2014.

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

60-Day Agency Response

SDSU will email a link to the Title IX brochure to all employees and students on an annual basis.

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

Recommendation #41 To: Chico, California State University

Chico State, San Diego State, and UCLA should ensure that the content of the education on sexual violence they provide to incoming students covers the topics outlined in California Education Code, Section 67385.7(b).

60-Day Agency Response

The Title IX training currently provided to incoming freshman, transfer, international, continuing education, distance learning, and graduate students meets and covers all requirements outlined by Section 67385 (b) of the California Education Code.

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

Recommendation #42 To: San Diego, California State University

Chico State, San Diego State, and UCLA should ensure that the content of the education on sexual violence they provide to incoming students covers the topics outlined in California Education Code, Section 67385.7(b).

60-Day Agency Response

SDSU has reviewed and revised its New Student Orientation programming to ensure that it covers the topics outlined in California Education Code, Section 67385.7(b), specifically (1) Common facts and myths about the causes of sexual violence; (2) Dating violence, rape, sexual assault, domestic violence, and stalking crimes, including information on how to file internal administrative complaints with the institution of higher education and how to file criminal charges with local law enforcement officials; (3) The availability of, and contact information for, campus and community resources for students who are victims of sexual violence; (4) Methods of encouraging peer support for victims and the imposition of sanctions on offenders; (5) Information regarding campus, criminal, and civil consequences of committing acts of sexual violence.

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

Recommendation #43 To: University of California, Los Angeles

Chico State, San Diego State, and UCLA should ensure that the content of the education on sexual violence they provide to incoming students covers the topics outlined in California Education Code, Section 67385.7(b). Although we recognize that state law requests, rather than requires, the UC system to
provide this education, we believe doing so is important to better inform students.

60-Day Agency Response

The information requested is already included by UCLA in the training provided for incoming students: California Education Code, Section 67385.7. (b) The educational and preventive information provided pursuant to this section shall include, but not necessarily be limited to, all of the following: (1) Common facts and myths about the causes of sexual violence. (2) Dating violence, rape, sexual assault, domestic violence, and stalking crimes, including information on how to file internal administrative complaints with the institution of higher education and how to file criminal charges with local law enforcement officials. (3) The availability of, and contact information for, campus and community resources for students who are victims of sexual violence. (4) Methods of encouraging peer support for victims and the imposition of sanctions on offenders. (5) Information regarding campus, criminal, and civil consequences of committing acts of sexual violence.

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

UCLA updated its 2014-2015 new student orientation that was provided to incoming students in the summer to ensure all items outlined in the Education Code mentioned above were included.

Recommendation #44 To: University of California, Berkeley

UC Berkeley should follow through with its current plan to staff the confidential survivor advocate position by the start of the fall 2014 semester.

6-Month Agency Response

The Director of Sexual Assault Prevention and Student Advocacy was hired and officially started October 27, 2014. Position serves as a confidential student advocate.

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

60-Day Agency Response

Position was posted in July, search process is underway.

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

Recommendation #45 To: Chico, California State University

To comply with state law, Chico State, San Diego State, and UC Berkeley must ensure the appropriate distribution of the university's written policy on sexual harassment to all incoming students at new student orientations.

1-Year Agency Response

The university has designed information pamphlets and handouts which summarize system wide Executive Order 1095 (CSU's policy implementing updates to Title IX and VAWA) and list appropriate resources available to students. This information is included in the new student orientation packet and is currently being distributed as part of our Summer orientation program. Additionally, a representative from our Title IX team has secured table space and an opportunity to provide materials and information to attendees of the orientation program.

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

6-Month Agency Response

The university has designed a brochure, door hanger, and a poster which summarize system wide Executive Order 1095 (CSU's policy implementing updates to Title IX and VAWA) and list appropriate resources available to students. This information will be included in the new student orientation packet which will be distributed to students beginning in Summer 2015. Executive Orders 1095 and 1097 have been added to the curriculum of courses required for Summer Orientation Staff.

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

60-Day Agency Response

The university has designed a brochure, door hanger, and a poster which summarize system wide Executive Order 1095 (CSU's policy implementing updates to Title IX and VAWA) and list appropriate resources available to students. This information will be included in the new student orientation packet which is distributed to all incoming students.

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

Chico State is still in the process of finalizing the materials that will be distributed to incoming students at student orientation.

Recommendation #46 To: San Diego, California State University

To comply with state law, Chico State, San Diego State, and UC Berkeley must ensure the appropriate distribution of the university's written policy on sexual harassment to all incoming students at new student orientations.

6-Month Agency Response

Incoming students who attended new student orientation were provided with a copy of the Student Handbook that contains a summary of the university's policy, along with a link to the full policy. Students who did not attend new student orientation are required to complete an online course containing information on the policy with a link to the full policy. All students received an email that includes a summary of the policy and a link to the policy on August 27, 2014.

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

60-Day Agency Response

Incoming students who attended new student orientation were provided with a copy of the Student Handbook that contains a summary of the university's policy, along with a link to the full policy. Students who did not attend new student orientation are required to complete an online course containing information on the policy with a link to the full policy. All students will receive an email that includes a summary of the policy and a link to the policy at the start of the fall semester.

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

Recommendation #47 To: University of California, Berkeley

To comply with state law, Chico State, San Diego State, and UC Berkeley must ensure the appropriate distribution of the university's written policy on sexual harassment to all incoming students at new student orientations.

60-Day Agency Response

Bear Tracks publication was distributed to all students during summer student orientation which includes links to detailed information on policies, including sexual violence & harassment, and related resources for students.

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

Recommendation #48 To: San Diego, California State University

San Diego State should identify an individual to serve as a resource advocate and to be a central point of contact and a confidential resource available to help students obtain the services needed when they experience an incident of sexual harassment or sexual violence.

1-Year Agency Response

SDSU has contracted with the Center for Community Solutions (CCS), San Diego County's rape crisis center to provide a full-time Sexual Assault Victim Advocate (SAVA). The SAVA has an office located in the Student Health Center and serves as a central point of contact and confidential resource available to help students obtain necessary services when they experience an incident of sexual harassment or sexual violence

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

6-Month Agency Response

SDSU is in the process of recruiting and accepting applications for a position to serve as a resource advocate and to be a central point of contact and confidential resource available to students

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

60-Day Agency Response

SDSU is in the process of recruiting for a position to serve as a resource advocate and to be a central point of contact and confidential resource available to students

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

Recommendation #49 To: University of California

The Office of the President should clarify in the UC policies that a complainant must have and be informed about the right to end the early resolution process at any time and request that his or her complaint be handled under the university's formal process.

Annual Follow-Up Agency Response From October 2019

The University issued a revised Sexual Violence and Sexual Harassment (SVSH) Policy on July 31, 2019. The new policy requires that Title IX Officers inform parties who agree to participate in the informal process that the process is voluntary, that they have the right to terminate the process at any time, and that termination before resolution may lead to a formal investigation. The revisions further state that if the informal process is terminated before resolution is reached, the Title IX Officer will initiate a formal investigation unless the complainant prefers that no investigation occur (in which case the Title IX Officer will honor the complainant's wishes unless she or he determine that an investigation is necessary to mitigate a risk to the campus community). According to the proposed revisions, then, the Complainant has the right to end the informal process at any time and have her or his complaint handled through the university's formal process.

California State Auditor's Assessment of Annual Follow-Up Status: Fully Implemented

Annual Follow-Up Agency Response From October 2018

In accordance with CSA's recommendations in its June 2018 report to UC, the Systemwide Title IX Office drafted revisions to the Systemwide Sexual Violence and Sexual Harassment (SVSH) Policy requiring that campus Title IX Officers inform parties who agree to participate in the informal process that the process is voluntary, that they have the right to terminate the process at any time, and that termination before resolution may lead to a formal investigation. The revisions further state that if the informal process is terminated before resolution is reached, the Title IX Officer will initiate a formal investigation unless the complainant prefers that no investigation occur (in which case the Title IX Officer will honor the complainant's wishes unless she or he determine that an investigation is necessary to mitigate a risk to the campus community). According to the proposed revisions, then, the Complainant has the right to end the informal process at any time and have her or his complaint handled through the university's formal process. The University began the requisite formal review process for the revised SVSH Policy in September 2018, and anticipates issuing the revised SVSH Policy by July 2019.

California State Auditor's Assessment of Annual Follow-Up Status: Pending

Annual Follow-Up Agency Response From November 2017

As the CSA has previously recognized, the UC Policy on Sexual Violence Sexual Harassment ("SVSH Policy") clearly delineates between a Formal Investigation and Alternative Resolution, and provides that a complainant has the right to request a Formal Investigation at any time. The recommendation states that a complainant should be informed of this right, and the SVSH Policy does inform the complainant of that right. The applicable federal guidance provides that a "complainant must be notified of the right to end the informal process at any time and begin the formal stage of the complaint process." (See OCR's Revised Sexual Harassment Guidance (2001)). The relevant federal guidance thus contemplates the right to request a formal investigation, but does not state that a formal investigation must be conducted upon a complainant's request. The federal guidance provides that, "in addressing allegations of sexual harassment, the good judgment and common sense of teachers and school administrators are important elements of a response that meets the requirements of Title IX" (See 2001 Guidance at ii.) UC believes the SVSH Policy is consistent with relevant federal guidance.

California State Auditor's Assessment of Annual Follow-Up Status: Partially Implemented

As we stated in our assessment comments on UC's response in 2016, although the revised Sexual Violence/Sexual Harassment policy states complainants have the right to request a formal Investigation at any time, it also states that the Title IX Officer has final authority for determining whether to initiate a formal Investigation. In its response this year, UC states that although the relevant federal guidance contemplates the right to request a formal investigation, it does not state that a formal investigation must be conducted upon a complainant's request. However, it continues to be our view, as we discussed in our report on page 52, that "the discretion within the UC policy to not initiate a formal investigation when requested to do so does not align with instructions in {federal guidance}, which indicate that the complainant must be notified of the right to end the informal process at any time."

Annual Follow-Up Agency Response From October 2016

The University's Policy on Sexual Violence/Sexual Harassment has been revised and became effective January 1, 2016.

California State Auditor's Assessment of Annual Follow-Up Status: Not Fully Implemented

Although the revised Sexual Violence/Sexual Harassment policy states complainants have the right to request a Formal Investigation at any time, it also states that the Title IX Officer has final authority for determining whether to initiate a Formal Investigation. As we discuss in our report on p.52 "In our view, the discretion within the UC policy to not initiate a formal investigation when requested to do so does not align with instructions in [federal guidance], which indicate that the complainant must be notified of the right to end the informal process at any time"

Annual Follow-Up Agency Response From September 2015

The University's policy on sexual harassment/sexual violence (http://policy.ucop.edu/doc/4000385) has been revised in accordance with the Final Regulations on amendments to the Violence Against Women Act (VAWA) issued on October 20, 2014 and recently enacted changes in California law. This update of the policy will be implemented no later than July 1, 2015. In addition, a full revision of the policy is underway and a final policy revision is scheduled to be complete in January 2016. The current UC Policy for Sexual Harassment and Sexual Violence, and the contemplated revised UC Policy for Sexual Harassment and Sexual Violence, do not permit mediation for cases involving sexual violence. The current, and contemplated revised UC Policy, expressly state that early resolution is voluntary and not required before beginning a formal investigation.

California State Auditor's Assessment of Annual Follow-Up Status: Not Fully Implemented

1-Year Agency Response

The University's policy on sexual harassment/sexual violence (http://policy.ucop.edu/doc/4000385) has been revised in accordance with the Final Regulations on amendments to the Violence Against Women Act (VAWA) issued on October 20, 2014 and recently enacted changes in California law. This update of the policy will be implemented no later than July 1, 2015. In addition, a full revision of the policy is underway and a final policy revision is scheduled to be complete in Fall 2015. The current UC Policy for Sexual Harassment and Sexual Violence, and the contemplated revised UC Policy for Sexual Harassment and Sexual Violence, do not permit mediation for cases involving sexual violence. The current, and contemplated revised UC Policy, expressly state that early resolution is voluntary and not required before beginning a formal investigation.

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

6-Month Agency Response

The University is updating its policy on sexual harassment/sexual violence in accordance with the Final Regulations on amendments to the Violence Against Women Act (VAWA) issued on October 20, 2014 and recently enacted changes in California law. The updated policy will be implemented no later than July 1, 2015. President Napolitano's Task Force on Preventing and Responding to Sexual Violence and Sexual Assault developed key recommendations regarding implementing reporting and the complaint processes, utilization of consistent nomenclature, uniform advocacy and case management services, and education and training. The Task Force continues its work implementing its recommendations to ensure that students receive the University's policy on sexual harassment/sexual violence, and have a clear understanding of their rights and expectations when filing a complaint.

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

60-Day Agency Response

The University revised its policy on sexual harassment/sexual violence in February 2014 to bring the policy in line with amendments to the Violence Against Women Act (VAWA). We will update our policy accordingly after the final rule for VAWA is promulgated in November. President Napolitano's Task Force for Preventing and Responding to Sexual Violence and Sexual Assault is reviewing current practices regarding dissemination of policy, information on reporting and the complaint process, and utilization of consistent nomenclature to ensure that students receive the University's policy on sexual harassment/sexual violence, and have a clear understanding of their rights and expectations when filing a complaint.

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

Recommendation #50 To: University of California

The Office of the President should clarify in the UC policies that if a university chooses to use the early resolution process, the Title IX coordinators and other university staff involved in resolving the complaint should have and document ongoing communication with complainants demonstrating their attempts to resolve the matter to mutual agreement of all relevant parties.

1-Year Agency Response

The current UC Policy on Sexual Harassment and Sexual Violence (http://policy.ucop.edu/doc/4000385) includes that steps taken and agreements reached through the Early Resolution process should be documented. Title IX offices are aware of the need to document ongoing communication with complainants. These processes will be reviewed --- as part of the University's internal audit plans.

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

6-Month Agency Response

The University is updating its policy on sexual harassment/sexual violence in accordance with the Final Regulations on amendments to the Violence Against Women Act (VAWA) issued on October 20, 2014 and recently enacted changes in California law. The updated policy will be implemented no later than July 1, 2015. President Napolitano's Task Force on Preventing and Responding to Sexual Violence and Sexual Assault developed key recommendations regarding implementing reporting and the complaint processes, utilization of consistent nomenclature, uniform advocacy and case management services, and education and training. The Task Force continues its work implementing its recommendations to ensure that students receive the University's policy on sexual harassment/sexual violence, and have a clear understanding of their rights and expectations when filing a complaint.

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

60-Day Agency Response

The University revised its policy on sexual harassment/sexual violence in February 2014 to bring the policy in line with amendments to the Violence Against Women Act (VAWA). We will update our policy accordingly after the final rule for VAWA is promulgated in November. President Napolitano's Task Force for Preventing and Responding to Sexual Violence and Sexual Assault is reviewing current practices regarding dissemination of policy, information on reporting and the complaint process, and utilization of consistent nomenclature to ensure that students receive the University's policy on sexual harassment/sexual violence, and have a clear understanding of their rights and expectations when filing a complaint.

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

Recommendation #51 To: University of California

The Office of the President should clarify in the UC policies that if university officials approve an extension to an investigative timeline, the extension should be restricted to a single extension of no more than 30 days, except in limited circumstances that are beyond the university's control.

Annual Follow-Up Agency Response From October 2019

The University issued a revised Sexual Violence and Sexual Harassment (SVSH) Policy on July 31, 2019. The revised SVSH Policy states that the Title IX Officer will consider, approve, and communicate extensions according to written guidance from the Systemwide Title IX Office. Concurrent with revised SVSH Policy, the Systemwide Title IX Office issued mandatory guidelines to the Title IX offices that define and provide examples of good cause, specify a standard extension period of 30 days, and require that extensions be communicated to parties before the timeframe expires. The guidelines also specify at what point an extension must be approved by the Systemwide Title IX Coordinator. These changes are consistent with the recommendations in CSA's June 2018 report.

California State Auditor's Assessment of Annual Follow-Up Status: Fully Implemented

Annual Follow-Up Agency Response From October 2018

The SVSH Policy currently provides that, upon extension of the timeframe specified in the Policy for good cause, the Title IX Officer will notify the Complainant and Respondent in writing of the reason for the extension and the projected new timeline. In accordance with CSA's recommendations in its June 2018 report to UC, the Systemwide Title IX Office revised the SVSH Policy to specify that the Title IX Officer will consider, approve, and communicate extensions according to written guidance from the Systemwide Title IX Office. The University began the requisite formal review process for the revised SVSH Policy in September 2018, and anticipates issuing the revised policy by July 2019. Following consultation with its campus partners, the Systemwide Title IX Office will develop and issue the referenced guidelines prior to or concurrently with issuance of the revised SVSH Policy, by July 2019. The written guidance will, among other things, define and provide examples of good cause, specify a standard extension period, and require that extensions be communicated to parties before the timeframe expires. Although the guidelines will not limit number of extensions to one, they will specify at what point an extension must be approved by the Systemwide Title IX Coordinator.

California State Auditor's Assessment of Annual Follow-Up Status: Pending

Annual Follow-Up Agency Response From November 2017

UCOP acknowledges that the SVSH Policy does not state that an investigation's extension shall be limited to no more than 30 days except in limited circumstances that are beyond the university's control.

Federal regulations provide that a prompt, fair and impartial proceeding is one that is "[c]ompleted within reasonably prompt timeframes designated by an institution's policy, including a process that allows for the extension of timeframes for good cause with written notice to the accuser and the accused of the delay and the reason for the delay." 34 CFR 668.46(k)(3)(i)(A). Current federal guidance provides that "[t]here is no fixed time frame under which a school must complete a Title IX investigation." (OCR "Q&A on Sexual Misconduct" (September 2017).)

Balancing the need for a fairness and impartiality, along with the need for promptness, UCOP maintains that the SVSH Policy provision that a Formal Investigation "shall be completed promptly, typically within 60 business days of its initiation, unless extended by the Title IX Officer for good cause followed by written notice to the Complainant and Respondent of the reason for the extension and the projected new timeline," is compliant with relevant law, guidance and best practices.

California State Auditor's Assessment of Annual Follow-Up Status: Will Not Implement

UC's response indicates that it does not plan to implement this recommendation, citing current federal guidance which states that there is no fixed time frame under which a school must complete a Title IX investigation. However, our recommendation was not based on the existence of a federally-mandated time frame. Instead, it was based on the lack of timeliness we noted among certain investigations we tested and our observation that UC's policy did not restrict how long approved extensions could be, as discussed on page 61 of our report. This was in contrast to the policy of the California State University system for extensions, which we noted allowed no more than 30 working days from the original due date. Further, although UC's response refers to the portion of its policy that states that investigations shall be completed typically within 60 business days, unless extended for good cause, it should be noted that a provision within the appendix to the policy could allow for even more time. That provision states that the process, including all appeals, will be completed within 120 business days, unless extended for good cause.

Annual Follow-Up Agency Response From October 2016

UC Policy on Sexual Violence and Sexual Harassment was revised and was effective January 1, 2016. The new student adjudication process was finalized and implemented in January 2016. The new student investigation model includes timelines and addresses the process for extensions of timelines.

California State Auditor's Assessment of Annual Follow-Up Status: Not Fully Implemented

As we note on page.61 of our report, the UC system policy at the time we conducted our audit stated that a formal investigation should be completed within 60 working days in most cases and allowed for approval of timeline extensions. However, the UC system policy did not restrict how long the extensions could be. Therefore, we recommended the UC system policy be clarified to restrict extensions if approved to a single extension of no more than 30 days, except in limited circumstances that were beyond the university's control. The UC system's current policy has been revised to state "the University will complete the process, including all appeals, within 120 business days from the date of Title IX's receipt of a report. This deadline and all deadlines contained herein may be extended for good cause shown and documented. The complainant and respondent will be notified in writing of any extension." However, this does not restrict the number of extensions nor does it state the 120 business days will be extended only in limited circumstances. Further, it allows more time to finalize a formal investigation.

Annual Follow-Up Agency Response From September 2015

The current UC Policy on Sexual Harassment and Sexual Violence (http://policy.ucop.edu/doc/4000385) includes provisions regarding the need for approval for extensions of investigative timelines. A full revision of the policy is underway and a final policy revision is scheduled to be complete in January 2016. In addition, the Student Adjudication Model Framework is being finalized and addresses the issue of timelines and extensions.

California State Auditor's Assessment of Annual Follow-Up Status: Not Fully Implemented

1-Year Agency Response

The current UC Policy on Sexual Harassment and Sexual Violence (http://policy.ucop.edu/doc/4000385) includes provisions regarding the need for approval for extensions of investigative timelines. In addition, a full revision of the policy is underway and a final policy revision is scheduled to be complete in Fall 2015.

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

6-Month Agency Response

The University is updating its policy on sexual harassment/sexual violence in accordance with the Final Regulations on amendments to the Violence Against Women Act (VAWA) issued on October 20, 2014 and recently enacted changes in California law. The updated policy will be implemented no later than July 1, 2015. President Napolitano's Task Force on Preventing and Responding to Sexual Violence and Sexual Assault developed key recommendations regarding implementing reporting and the complaint processes, utilization of consistent nomenclature, uniform advocacy and case management services, and education and training. The Task Force continues its work implementing its recommendations to ensure that students receive the University's policy on sexual harassment/sexual violence, and have a clear understanding of their rights and expectations when filing a complaint.

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

60-Day Agency Response

The University revised its policy on sexual harassment/sexual violence in February 2014 to bring the policy in line with amendments to the Violence Against Women Act (VAWA). We will update our policy accordingly after the final rule for VAWA is promulgated in November. President Napolitano's Task Force for Preventing and Responding to Sexual Violence and Sexual Assault is reviewing current practices regarding dissemination of policy, information on reporting and the complaint process, and utilization of consistent nomenclature to ensure that students receive the University's policy on sexual harassment/sexual violence, and have a clear understanding of their rights and expectations when filing a complaint.

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

Recommendation #52 To: Chico, California State University

All universities should create and use a document to share with students that explains what students should expect from the complaint process. At a minimum, it should include an overview of the university's sexual harassment policy, the investigation process, relevant timelines, the legal standard that must be applied to the investigation, and issues related to confidentiality, as well as expectations regarding notification of case status updates and outcomes.

6-Month Agency Response

CSU, Chico has developed a handout (Title IX/DHR Fact Sheet for Students) that provides a brief overview of what students should expect from the complaint process. All prospective complainants are also given extensive Victim's Rights information, and a copy of the complete Executive Order which details the investigation process and standards used.

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

60-Day Agency Response

CSU, Chico is developing a handout (Complaint Process Fact Sheet) that will provide a brief overview of what students should expect from the complaint process. All prospective complainants will also be given a more extensive Victim's Rights packet.

Development and evaluation of these resources will be completed during the fall, with implementation in early 2015.

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

Recommendation #53 To: San Diego, California State University

All universities should create and use a document to share with students that explains what students should expect from the complaint process. At a minimum, it should include an overview of the university's sexual harassment policy, the investigation process, relevant timelines, the legal standard that must be applied to the investigation, and issues related to confidentiality, as well as expectations regarding notification of case status updates and outcomes.

1-Year Agency Response

SDSU has created a document that summarizes the complaint process which is provided to all complainants. It includes an overview of the university's sexual harassment policy, the investigation process, relevant timelines, the legal standard that must be applied to the investigation, the differences between the informal vs. formal investigation process and issues related to confidentiality, as well as expectations regarding notification of case status updates and outcomes.

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

6-Month Agency Response

The campus has initiated actions to implement this recommendation and is in the process of developing related tools and procedures.

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

60-Day Agency Response

The campus has initiated actions to implement this recommendation and is in the process of developing related tools and procedures.

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

Recommendation #54 To: University of California, Berkeley

All universities should create and use a document to share with students that explains what students should expect from the complaint process. At a minimum, it should include an overview of the university's sexual harassment policy, the investigation process, relevant timelines, the legal standard that must be applied to the investigation, and issues related to confidentiality, as well as expectations regarding notification of case status updates and outcomes.

6-Month Agency Response

The Center for Student Conduct and the Office for the Prevention of Harassment and Discrimination have updated flowcharts to include information on relevant timelines, legal standards for investigations, and expectations regarding status updates.

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

60-Day Agency Response

Flowchart document created with input from students now being distributed to all students participating in the complaint process. Complainants are also given survivor checklist and resource flyers.

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

UC Berkeley has created a flowchart document and survivor checklist that incorporates several of the items identified in our recommendations. However, UC Berkeley needs to ensure these documents include information on relevant timelines, the legal standard that must be applied to the investigation, and expectations regarding status updates.

Recommendation #55 To: University of California, Los Angeles

All universities should create and use a document to share with students that explains what students should expect from the complaint process. At a minimum, it should include an overview of the university's sexual harassment policy, the investigation process, relevant timelines, the legal standard that must be applied to the investigation, and issues related to confidentiality, as well as expectations regarding notification of case status updates and outcomes.

1-Year Agency Response

Information about what students should expect from the complaint process, including an overview of the university's sexual harassment policy, the investigation process, relevant timelines, the legal standard that must be applied to the investigation, and issues related to confidentiality, as well as expectations regarding notification of case status updates and outcomes, was provided to entering FY and TR students in orientation. The U.S. Department of Education's Office for Civil Rights is currently reviewing the UC Systemwide Policy on Sexual Harassment and Sexual Violence and accompanying implementing procedures. At the conclusion of this review, we will re-evaluate the policy language regarding investigation resolution options and how to best communicate those changes with students.

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

Although UCLA describes information provided in new student orientation, it subsequently provided evidence of information provided to both the complainant and respondent that explains what the students should expect from the complaint process. Therefore we have assessed this recommendation as fully implemented.

6-Month Agency Response

Information about what students should expect from the complaint process, including an overview of the university's sexual harassment policy, the investigation process, relevant timelines, the legal standard that must be applied to the investigation, and issues related to confidentiality, as well as expectations regarding notification of case status updates and outcomes, was provided to entering FY and TR students in orientation. The checklist used to ensure that Dean of Students officials explain, among other things, the complaint process, a checklist concerning students' rights and responsibilities and available resources is now retained in the case file. The UC Police Department (PD) has created a document, "Reporting a Sexual Assault to the UCLA Police Department." The document will be shared across the campus and includes information describing what students can expect after making a police report.

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

60-Day Agency Response

This information is included in orientation for all new students (FY and TR). Various documents have been developed or are in development, including one by the Police Department (PD) describing what the students can expect after making a police report. The checklist used to ensure that Dean of Students officials explain, among other things, the complaint process, a checklist concerning students' rights and responsibilities and available resources is now retained in the case file.

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

Recommendation #56 To: Chico, California State University

All universities should ensure that the differences between an informal or early resolution process and a formal investigation process are clearly explained to ensure that students know what to expect from each process. Further, they should explain that students whose cases are being handled under an informal or early resolution process have the right to move to a formal process at any time.

1-Year Agency Response

CSU, Chico has developed internal tools to assist investigators with consistent documentation in student case files and to ensure that students were fully informed about the complaint process including the differences between the formal and informal complaint processes. This includes an internal checklist for investigators to ensure that all appropriate matters are addressed at the intake interview. Use of these forms has begun.

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

6-Month Agency Response

CSU, Chico has developed internal tools to assist investigators with consistent documentation in student case files that students were fully informed about the complaint process, including the differences between the formal and informal complaint processes. This includes an internal checklist for investigators to ensure that all appropriate matters are addressed at the intake interview. Use of these forms will begin in January 2015.

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

60-Day Agency Response

CSU, Chico is developing internal tools that will assist investigators with consistently documenting in student case files that students were fully informed about the complaint process, including the differences between the formal and informal complaint processes. These will include an internal checklist for investigators, as well as an acknowledgement form to be signed by complainants and respondents.

Development of these resources will be completed this fall, with implementation in early 2015.

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

Recommendation #57 To: San Diego, California State University

All universities should ensure that the differences between an informal or early resolution process and a formal investigation process are clearly explained to ensure that students know what to expect from each process. Further, they should explain that students whose cases are being handled under an informal or early resolution process have the right to move to a formal process at any time.

1-Year Agency Response

SDSU has created a document that summarizes the complaint process which is provided to all complainants. It includes an overview of the university's sexual harassment policy, the investigation process, relevant timelines, the legal standard that must be applied to the investigation, the differences between the informal vs. formal investigation process and issues related to confidentiality, as well as expectations regarding notification of case status updates and outcomes.

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

6-Month Agency Response

The campus has initiated actions to implement this recommendation and is in the process of developing related tools and procedures.

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

60-Day Agency Response

The campus has initiated actions to implement this recommendation and is in the process of developing related tools and procedures.

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

Recommendation #58 To: University of California, Berkeley

All universities should ensure that the differences between an informal or early resolution process and a formal investigation process are clearly explained to ensure that students know what to expect from each process. Further, they should explain that students whose cases are being handled under an informal or early resolution process have the right to move to a formal process at any time.

Annual Follow-Up Agency Response From October 2019

The University issued a revised Sexual Violence and Sexual Harassment (SVSH) Policy on July 31, 2019. The new policy requires that Title IX Officers inform parties who agree to participate in the informal process that the process is voluntary, that they have the right to terminate the process at any time, and that termination before a resolution may lead to a formal investigation. The revisions further state that if the informal process is terminated before resolution is reached, the Title IX Officer will initiate an official investigation unless the complainant prefers that no investigation occur (in which case the Title IX Officer will honor the complainant's wishes unless she or he determined that an investigation is necessary to mitigate a risk to the campus community). According to the proposed revisions, then, the complainant has the right to end the informal process at any time and have her or his complaint handled through the University's formal process. The revised SVSH Policy provides other details about the Alternative Resolution process, including examples of forms it may take, the timeline, the parties' right to written notices, and the Title IX Officer's role. The SVSH Policy also provides an overview of the formal investigation process; this process is explained in detail in the University's revised SVSH Student Adjudication Framework (Appendix E), also issued on July 31, 2019. These policies inform students of the differences between the informal resolution process and the formal investigation process and what to expect from each. The guidance for administering the Alternative Resolution process is consistent across all UC campuses.

California State Auditor's Assessment of Annual Follow-Up Status: Fully Implemented

Annual Follow-Up Agency Response From October 2018

In accordance with CSA's recommendations in its June 2018 report to UC, the Systemwide Title IX Office drafted revisions to the Systemwide Sexual Violenceand Sexual Harassment (SVSH) Policy which provide for the Complainant to end the informal process at any time and have her or his complaint handled through the university's formal process. See update to recommendation 49 for more detail on these systemwide SVSH policy changes.

Pending formal changes to the Systemwide SVSH Policy, the staff in Berkeley's Office for the Prevention of Harassment and Discrimination (OPHD) engages in the following process: OPHD complaint resolution officers explain the difference between Alternative Resolution and formal investigation and inform complainants of their right to go to formal investigation. OPHD complaint resolution officers inform Complainants and Respondents interested in an Alternative Resolution that the process is voluntary, that they have the right to terminate the process at any time, and that termination before resolution may lead to a formal investigation. This notification is done verbally at the beginning stages of the initial assessment of a complaint. In situations where both parties then agree to an Alternative Resolution, OPHD complaint resolution officers follow up in writing with the parties, confirming the individuals' prior agreement with executing an Alternative Resolution strategy, and reiterating what actions will follow as part of the Alternative Resolution. The Complaint Resolution officer further specifies that at the end of the Alternative Resolution process, if the resolution is not successful, or new issues arise, a Formal Investigation may still need to be implemented.

California State Auditor's Assessment of Annual Follow-Up Status: Pending

Annual Follow-Up Agency Response From November 2017

As the CSA has previously recognized, the UC Policy on Sexual Violence Sexual Harassment ("SVSH Policy") clearly delineates between a Formal Investigation and Alternative Resolution, and provides that a complainant has the right to request a Formal Investigation at any time. The recommendation states that a complainant should be informed of this right, and the SVSH Policy does inform the complainant of that right. The applicable federal guidance provides that a "complainant must be notified of the right to end the informal process at any time and begin the formal stage of the complaint process." (See OCR's Revised Sexual Harassment Guidance (2001).) The relevant federal guidance does not state that a formal investigation must be conducted upon a complainant's request. The federal guidance further provides that, "in addressing allegations of sexual harassment, the good judgment and common sense of teachers and school administrators are important elements of a response that meets the requirements of Title IX." (See 2001 Guidance at ii.) UCB believes the SVSH Policy is consistent with relevant federal guidance.

California State Auditor's Assessment of Annual Follow-Up Status: Partially Implemented

As we stated in our assessment comments on UC Berkeley's response in 2016, although the revised Sexual Violence/Sexual Harassment policy states complainants have the right to request a formal investigation at any time, it also states that the Title IX Officer has final authority for determining whether to initiate a formal investigation. In its response this year, UC Berkeley notes that the relevant federal guidance does not state that a formal investigation must be conducted upon a complainant's request. However, it continues to be our view, as we discussed in our report on page 52, that "the discretion within the UC policy to not initiate a formal investigation when requested to do so does not align with instructions in {federal guidance}, which indicate that the complainant must be notified of the right to end the informal process at any time."

Annual Follow-Up Agency Response From October 2016

When UCB or UCLA receive a report that a student has experienced sexual violence or sexual harassment, they conduct outreach to the student. In that written outreach, the student is informed of their right to report sexual violence to the University and provided a full copy of the UC Policy on Sexual Violence and Sexual Harassment (UC SVSH Policy). They are also offered the confidential survivor advocate (CARE Advocate) as a resource and informed that the confidential advocate could explain the University's reporting and resolution processes to them before they make their decision to report.

UCB and UCLA implement thorough intake processes when complaints are filed. During this process staff explain to both complainants and respondents both complaint resolution strategies allowed under the UC Policy on Sexual Violence and Sexual Harassment. Also, formal notice letters informing both parties of the allegations made, applicable policies, rights of both parties, and available resources, are accompanied by a full version of the UC SVSH Policy.

The Title IX/Student Conduct procedures that are provided to students participating in this process include detailed information about both paths to resolution and references the UC SVSH Policy. Moreover, both UCB and UCLA have confidential CARE (complainant's) advocates and respondent services providers who are trained in the Title IX procedures, and who can explain to students the differences between the two resolution strategies. Any student can access these resources, regardless of whether they wish to report formally. Students who are participating in a Title IX process are expressly advised of their options to access either the CARE (complainant's) advocate or the respondent services provider.

(Please see attached document for the continuation.)

California State Auditor's Assessment of Annual Follow-Up Status: Not Fully Implemented

The attached document that UCB referred to provided a few more sentences regarding the relevant portions of the revised UC Policy on Sexual Violence and Sexual Harassment.

Students are provided information that clearly explains the process for early resolution or formal review, and the revised Sexual Violence/Sexual Harassment policy states complainants have the right to request a formal investigation at any time. However, it also states that the Title IX Officer has final authority for determining whether to initiate a formal investigation. As we discuss in our report on p.52, "In our view, the discretion within the UC policy to not initiate a formal investigation when requested to do so does not align with instructions in [federal guidance], which indicate that the complainant must be notified of the right to end the informal process at any time". Therefore, we did not assess this recommendation as fully implemented.

Annual Follow-Up Agency Response From September 2015

Nothing new to report from the June submission.

California State Auditor's Assessment of Annual Follow-Up Status: Not Fully Implemented

1-Year Agency Response

The U.S. Department of Education's Office for Civil Rights is currently reviewing the UC Systemwide Policy on Sexual Harassment and Sexual Violence and accompanying implementing procedures. At the conclusion of this review, we will re-evaluate the policy language regarding investigation resolution options and how to best communicate those changes with students.

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

6-Month Agency Response

UCB has developed new informational tools (narrative and graphic representations), as well as an improved intake process that ensures that students have multiple opportunities to understand the complaint resolution strategies employed under the sexual harassment and violence policy, and the differences between those strategies.

The President's Task Force will be reviewing practices and standards in responding to reports of sexual misconduct across all UC locations, including best practices to support fair and objective adjudication procedures. The UC Policy is also being revised.

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

60-Day Agency Response

UCB (University of California, Berkeley) has developed new informational tools (narrative and graphic representations), as well as an improved intake process that ensures that students have multiple opportunities to understand the complaint resolution strategies employed under the sexual harassment and violence policy, and the differences between those strategies.

The President's Task Force will be reviewing practices and standards in responding to reports of sexual misconduct across all UC (University of California) locations, including best practices to support fair and objective adjudication procedures. The UC (University of California) Policy is also being revised.

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

UC Berkeley has created tools to help explain the different options available to students who report incidents of sexual violence and sexual harassment. However, its practices and standards in responding to reports of incidents of sexual violence and sexual harassment are being reviewed.

Recommendation #59 To: University of California, Los Angeles

All universities should ensure that the differences between an informal or early resolution process and a formal investigation process are clearly explained to ensure that students know what to expect from each process. Further, they should explain that students whose cases are being handled under an informal or early resolution process have the right to move to a formal process at any time.

Annual Follow-Up Agency Response From October 2019

The University issued a revised Sexual Violence and Sexual Harassment (SVSH) Policy on July 31, 2019. The new policy requires that Title IX Officers inform parties who agree to participate in the informal process that the process is voluntary, that they have the right to terminate the process at any time, and that termination before a resolution may lead to a formal investigation. The revisions further state that if the informal process is terminated before resolution is reached, the Title IX Officer will initiate an official investigation unless the complainant prefers that no investigation occur (in which case the Title IX Officer will honor the complainant's wishes unless she or he determined that an investigation is necessary to mitigate a risk to the campus community). According to the proposed revisions, then, the complainant has the right to end the informal process at any time and have her or his complaint handled through the University's formal process. The revised SVSH Policy provides other details about the Alternative Resolution process, including examples of forms it may take, the timeline, the parties' right to written notices, and the Title IX Officer's role. The SVSH Policy also provides an overview of the formal investigation process; this process is explained in detail in the University's revised SVSH Student Adjudication Framework (Appendix E), also issued on July 31, 2019. These policies inform students of the differences between the informal resolution process and the formal investigation process and what to expect from each. The guidance for administering the Alternative Resolution process is consistent across all UC campuses.

California State Auditor's Assessment of Annual Follow-Up Status: Fully Implemented

Annual Follow-Up Agency Response From October 2018

In addition to continuing with our practice of providing Complainants with information about their rights, resources, and reporting options via initial outreach e-mails, in the Fall of 2016, the UCLA Title IX Office incorporated information during in-person trainings of the Complainant's right to decide whether and how much to participate. Additionally, information about differences between an informal "Alternative Resolution", and a formal investigation process are clearly explained to Complainants at an initial intake meeting to ensure they are aware of what to expect from each process. Part of the conversation includes providing the Complainant with information about their right to move to a formal process at any time.

Furthermore, Complainants Rights, Reporting Options, and Resources are available on the Title IX website, and the University sends a campus wide e-mail in the fall to all community members informing them of their rights, options and resources.

In accordance with CSA's recommendations in its June 2018 report to UC, the Systemwide Title IX Office drafted revisions to the Systemwide Sexual Violence and Sexual Harassment (SVSH) Policy which provide for the Complainant to end the informal process at any time and have her or his complaint handled through the university's formal process. See update to recommendation 49 for more detail on these systemwide SVSH policy changes.

Estimated Completion Date: June 2019

California State Auditor's Assessment of Annual Follow-Up Status: Pending

Annual Follow-Up Agency Response From November 2017

As the CSA has previously recognized, the UC Policy on Sexual Violence Sexual Harassment ("SVSH Policy") clearly delineates between a Formal Investigation and Alternative Resolution, and provides that a complainant has the right to request a Formal Investigation at any time. The recommendation states that a complainant should be informed of this right, and the SVSH Policy does inform the complainant of that right. The applicable federal guidance provides that a "complainant must be notified of the right to end the informal process at any time and begin the formal stage of the complaint process." (See OCR's Revised Sexual Harassment Guidance (2001)). The relevant federal guidance thus contemplates the right to request a formal investigation, but does not state that a formal investigation must be conducted upon a complainant's request. The federal guidance provides that, "in addressing allegations of sexual harassment, the good judgment and common sense of teachers and school administrators are important elements of a response that meets the requirements of Title IX" (See 2001 Guidance at ii.) UCLA believes the SVSH Policy is consistent with relevant federal guidance.

California State Auditor's Assessment of Annual Follow-Up Status: Partially Implemented

As we stated in our assessment comments on UCLA's response in 2016, although the revised Sexual Violence/Sexual Harassment policy states complainants have the right to request a formal investigation at any time, it also states that the Title IX Officer has final authority for determining whether to initiate a formal investigation. In its response this year, UCLA notes that the relevant federal guidance does not state that a formal investigation must be conducted upon a complainant's request. However, it continues to be our view, as we discussed in our report on page 52, that "the discretion within the UC policy to not initiate a formal investigation when requested to do so does not align with instructions in {federal guidance}, which indicate that the complainant must be notified of the right to end the informal process at any time."

Annual Follow-Up Agency Response From October 2016

The response will be provided via email as the length of the response exceeds the character limit.

California State Auditor's Assessment of Annual Follow-Up Status: Not Fully Implemented

UCLA's email response discussed how UCLA informs students about the informal investigation process as well as the formal investigation process. In addition, it discussed the revised UC systemwide sexual violence and sexual harassment policy.

Students are provided information that clearly explains the process for early resolution or formal review, and the revised Sexual Violence/Sexual Harassment policy states complainants have the right to request a formal investigation at any time. However, it also states that the Title IX Officer has final authority for determining whether to initiate a formal investigation. As we discuss in our report on p.52, "In our view, the discretion within the UC policy to not initiate a formal investigation when requested to do so does not align with instructions in [federal guidance], which indicate that the complainant must be notified of the right to end the informal process at any time". Therefore, we did not assess this recommendation as fully implemented.

Annual Follow-Up Agency Response From September 2015

All student complainants and respondents receive a copy of the UC Interim Policy for Sexual Harassment and Sexual Violence, which sets forth the procedures for early resolution and formal investigation.

Issuance of the final Policy is anticipated by January 2016.

California State Auditor's Assessment of Annual Follow-Up Status: Not Fully Implemented

1-Year Agency Response

UCLA is committed to clearly explaining to all members of its community the investigation and adjudication procedures for sexual harassment and sexual violence complaints. The revised Interim UC Policy for Sexual Harassment and Sexual Violence clearly explains the differences between the Early Resolution process and Formal Investigation. Under this policy, participation in the Early Resolution process is expressly and strictly voluntary at all stages. Mediation, even if voluntary, may not be used in cases involving sexual violence.

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

6-Month Agency Response

UCLA only has a formal investigative process which is described in the Student Code of Conduct and is explained to the students by the Dean of Students assigned to the case; there is no informal investigation process. Should the accused accept responsibility for a violation, the Dean may sanction without holding a formal hearing in front of the Student Conduct Committee (early resolution). If there is no admission of responsibility, the case will proceed through the full hearing process.

The President's Task Force will be reviewing practices and standards in investigating and adjudicating reports of sexual misconduct across all UC locations, and making recommendations for standardization including best practices to support fair and objective procedures. The UC Policy is also being revised.

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

60-Day Agency Response

UCLA only has a formal investigative process which is explained to the students by the Dean of Students assigned to the case; there is no informal investigation process. Should the facts determined by the investigation result in admission of responsibility by the accused, the case may reach early resolution. If there is no admission of responsibility, the case will proceed through the full hearing and determination process.

The President's Task Force will be reviewing practices and standards in responding to reports of sexual misconduct across all UC locations, including best practices to support fair and objective adjudication procedures. The UC Policy is also being revised.

California State Auditor's Assessment of 60-Day Status: No Action Taken

As we mention on p.52 of the report, "The UC policy states that UC encourages early resolution and that the parties' participation in the early resolution process is voluntary. According to the policy, early resolution may include an inquiry into the facts, but does not typically include a full investigation, and early resolution options include mediating an agreement between the parties, referring the parties to counseling, or targeted educational programs, among others. The policy states that some reports of sexual harassment and sexual violence may not be appropriate for early resolution, and that the Title IX officer has the discretion to make this determination. The policy mentions that in cases where early resolution is inappropriate or in cases where early resolution is unsuccessful, a formal investigation may be conducted." Also on p. 52 of the report we state, "Information provided by three of the universities we reviewed indicates that they used an informal or early resolution process to resolve a majority of student Title IX complaints." We go on to mention on p.53 that "UCLA uses the early resolution process only when the accused student accepts responsibility for violating the university's conduct code, and based on information provided by the university for our five-year review period, it resolved 58 percent of its complaints using the early resolution process."

The intent of this recommendation is to ensure that students are being informed of what to expect from each process. UCLA has not demonstrated how it plans on informing students.

Recommendation #60 To: Chico, California State University

All universities should provide regular updates on the status of their investigations to students filing or responding to complaints. Additionally, the universities should notify the students of the resolution of the complaints. To demonstrate that they took these actions, the universities should maintain appropriate records.

1-Year Agency Response

CSU, Chico has developed case management tools that will assist Investigators in monitoring complaint timelines, including target dates for issuing status notifications and notices of complaint resolution. Template status update letters have been developed and are in use.

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

6-Month Agency Response

CSU, Chico has developed case management tools that will assist Investigators to facilitate monitoring of complaint timelines, including target dates for issuing status notifications and notice of complaint resolution. Template status update letters are being developed and their use is anticipated in early 2015.

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

60-Day Agency Response

CSU, Chico is developing case management tools that will assist Investigators to facilitate monitoring of complaint timelines, including target dates for issuing status notifications and notice of complaint resolution. Development of these resources will continue through the fall, with implementation targeted for early 2015.

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

Recommendation #61 To: San Diego, California State University

All universities should provide regular updates on the status of their investigations to students filing or responding to complaints. Additionally, the universities should notify the students of the resolution of the complaints. To demonstrate that they took these actions, the universities should maintain appropriate records.

1-Year Agency Response

The campus has developed procedures to ensure that complainants are provided with regular updates and regularly documents these status updates in case files.

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

6-Month Agency Response

The campus has initiated actions to implement this recommendation and is in the process of developing related tools and procedures.

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

60-Day Agency Response

The campus has initiated actions to implement this recommendation and is in the process of developing related tools and procedures.

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

Recommendation #62 To: University of California, Berkeley

All universities should provide regular updates on the status of their investigations to students filing or responding to complaints. Additionally, the universities should notify the students of the resolution of the complaints. To demonstrate that they took these actions, the universities should maintain appropriate records.

60-Day Agency Response

OPHD (Office for Prevention of Harassment and Discrimination) and CSC (Center of Student Conduct) send email updates to parties and now keep records of these updates.

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

Recommendation #63 To: University of California, Los Angeles

All universities should provide regular updates on the status of their investigations to students filing or responding to complaints. Additionally, the universities should notify the students of the resolution of the complaints. To demonstrate that they took these actions, the universities should maintain appropriate records.

1-Year Agency Response

The Title IX Office has acquired a systemwide database that will track sexual harassment and sexual violence complaints. This database will assist in tracking and record-keeping for such complaints. The current practice is to notify all sexual harassment or sexual violence victim complainants of the resolution of their complaints. UCLA's newly hired Response Team Coordinator (a position created by the President's Task Force) will assist in tracking complaints and investigations and keeping appropriate records.

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

6-Month Agency Response

UCLA Dean of Students has this process in place and is working to ensure documentation is maintained.

The UC Police Department (PD) has created a document, "Reporting a Sexual Assault to the UCLA Police Department." The document will be shared across the campus and includes information describing what students can expect after making a police report. The PD case management system will be used for tracking the actions.

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

60-Day Agency Response

UCLA Dean of Students has this process in place and is working to ensure documentation is maintained.

The PD is currently developing a written protocol for timely updates to individuals, who have reported sexual assault and domestic/dating violence crimes. The PD case management system will be used for tracking the actions.

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

Recommendation #64 To: Chico, California State University

To ensure that the universities conduct investigations as promptly as possible, they should regularly evaluate the timeliness of investigations in a systematic manner and ensure that they complete investigations within established timelines.

1-Year Agency Response

CSU Chico has conducted a review of the timeliness of complaints, and identified areas for improvement. To address these concerns, CSU Chico has added three staff members to help conduct Title IX investigations. CSU Chico has also established monthly "case review" meetings with all investigators to ensure timelines are being met.

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

6-Month Agency Response

CSU, Chico is developing internal case management tools that will assist investigators in adhering to timelines by recording and tracking the date of the initial incident, date a complaint was filed, target dates for status notification, and deadlines for completing the investigation and notification of outcome. An initial review and evaluation of timeliness issues is scheduled to be completed by January 30, 2015. Additionally, CSU Chico is preparing to hire additional investigators to help ensure that investigations are completed promptly and within established timelines.

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

60-Day Agency Response

CSU, Chico is developing internal case management tools that will assist investigators in adhering to timelines by recording and tracking the date of the initial incident, date a complaint was filed, target dates for status notification, and deadlines for completing the investigation and notification of outcome. Development and evaluation of these tools will continue through the fall, with implementation targeted for early 2015.

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

Recommendation #65 To: San Diego, California State University

To ensure that the universities conduct investigations as promptly as possible, they should regularly evaluate the timeliness of investigations in a systematic manner and ensure that they complete investigations within established timelines.

1-Year Agency Response

The campus logs all Title IX complaints in a spreadsheet. This log contains information relating to the timeliness of investigations and is regularly reviewed by the Title IX Coordinator.

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

6-Month Agency Response

The campus has initiated actions to implement this recommendation and is in the process of developing related tools and procedures.

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

60-Day Agency Response

The campus has initiated actions to implement this recommendation and is in the process of developing related tools and procedures.

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

Recommendation #66 To: University of California, Berkeley

To ensure that the universities conduct investigations as promptly as possible, they should regularly evaluate the timeliness of investigations in a systematic manner and ensure that they complete investigations within established timelines.

60-Day Agency Response

OPHD (Office for the Prevention of Harassment and Discrimination) created a tracking log of current case progress, with reminders of cases nearing the end of the recommended 60 day timeline for completion. Case log reiviewed daily. OPHD (Office for the Prevention of Harassment and Discrimination) will monitor data and recommend process improvements and/or resource changes to ensure adherence to this recommendation.

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

Recommendation #67 To: University of California, Los Angeles

To ensure that the universities conduct investigations as promptly as possible, they should regularly evaluate the timeliness of investigations in a systematic manner and ensure that they complete investigations within established timelines.

1-Year Agency Response

The Title IX Office has acquired a systemwide database that will track sexual harassment and sexual violence complaints, and will allow Title IX to better monitor for timeliness. UCLA's newly hired Response Team Coordinator (a position created by the President's Task Force) will assist in tracking complaints and investigations and will continually assess timeliness of investigations and resolutions. The Case Management Team, consisting of members of the Title IX Office, UCPD, Student Conduct, CARE and other stakeholders, meets weekly to review and evaluate cases individually and in a systematic manner. The CMT collects and reviews metrics regarding the handling of reports and investigations, and in that regard assesses the timeliness of cases. In addition, CMT participants often discuss issues that can impact timing of specific cases, and deliberate regarding how to handle such issues.

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

6-Month Agency Response

UCLA Dean of Students has this process in place and is working to ensure documentation is maintained.

The Title IX Office plans to have a system in place to monitor investigation timeliness by Spring quarter 2015.

The Staff Diversity & Compliance Office is revising its current "inventory" system of monitoring complaints to now feature a formulaic-based spreadsheet that will automatically establish due dates and other "triggers" to ensure investigation timeliness in responding to complaints filed internally and externally (outside agencies).

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

60-Day Agency Response

UCLA Dean of Students has this process in place and is working to ensure documentation is maintained.

The Title IX Office plans to have a system in place to monitor investigation timeliness by Spring quarter 2015.

The Staff Diversity & Compliance Office is revising its current "inventory" system of monitoring complaints to now feature a formulaic-based spreadsheet that will automatically establish due dates and other "triggers" to ensure investigation timeliness in responding to complaints filed internally and externally (outside agencies).

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

Recommendation #68 To: Chico, California State University

To identify ways to better serve their students, all universities should create a summary of student incidents of sexual harassment and sexual violence reported to the various departments on campus. Each university should evaluate its summary data to identify trends specific to the demographics, as well as the timing, location, and frequency of incidents, to better inform its strategies to protect students and direct its outreach efforts.

Annual Follow-Up Agency Response From October 2016

Data is being collected from various locations on campus, including the University Police Department, the Student Health Center, and Title IX offices. In January of 2016, the data collected from the first half of the academic year was reviewed with the Title IX Team. Recommendations were made for future data collection, as well as training ideas developed. Outreach efforts were discussed as well. Data collection efforts are ongoing.

California State Auditor's Assessment of Annual Follow-Up Status: Fully Implemented

Annual Follow-Up Agency Response From September 2015

CSU Chico has disseminated data collection documents for use by campus locations that see a high volume of reports, and has started to collect data from these locations. As of this date, we have not collected sufficient data to conduct a meaningful evaluation of trends. We will be trending and evaluating the data in December 2015, and use that data to inform our strategies around student protection, and to help direct our spring outreach efforts, as well as our efforts next fall.

California State Auditor's Assessment of Annual Follow-Up Status: Not Fully Implemented

1-Year Agency Response

CSU Chico has created and distributed a data collection document for use by campus locations that see a high volume of reports. The collected data will be used to guide the efforts of our Title IX Team. Chico will create a summary of incidents seen in the current academic/fiscal year to help guide our efforts until a suitable sample size can be created from the use of the data collection sheets. The Title IX team has also secured the cooperation and support of various colleges and professors to create, conduct, and analyze a campus climate survey around the issue of sexual misconduct. It is anticipated that the survey will be conducted in the Spring 2016 semester.

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

Although CSU Chico has marked this recommendation as Fully Implemented, we have assessed it as Partially Implemented. CSU Chico is still working on collecting, trending, and evaluating the data it receives from various departments on campus to better inform its strategies to protect students and direct its outreach efforts.

6-Month Agency Response

CSU, Chico has created a work group (a subcommittee of the Title IX Oversight Committee) of unit directors from areas that currently collect data to review current reporting practices and develop an operational plan to expand data collection efforts to include more descriptive statistics and frequency data as described in the recommendation. The work group has developed a template and will begin pilot testing its procedures for collecting, analyzing and reporting data during spring 2015. The work group anticipates being able to analyze and share the results with the Oversight Committee at the end of the academic year in order to begin evaluating trends and implications for future prevention and response efforts.

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

60-Day Agency Response

CSU, Chico has created a work group (a subcommittee of the Title IX Oversight Committee) of unit directors comprising areas that currently collect data to review current reporting practices and develop an operational plan to expand data collection efforts to include more descriptive statistics and frequency data as described in the recommendation. The work group will continue its planning activities throughout the fall, and will establish and begin pilot testing its procedures for collecting, analyzing and reporting data during spring, 2015. The work group anticipates being able to analyze and share the results with the Oversight Committee at the end of the academic year in order to begin evaluating trends and implications for future prevention and response efforts.

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

Recommendation #69 To: San Diego, California State University

To identify ways to better serve their students, all universities should create a summary of student incidents of sexual harassment and sexual violence reported to the various departments on campus. Each university should evaluate its summary data to identify trends specific to the demographics, as well as the timing, location, and frequency of incidents, to better inform its strategies to protect students and direct its outreach efforts.

Annual Follow-Up Agency Response From October 2016

SDSU logs all incidents and conducts an annual review of Title IX incidents reported to the various departments across campus. The review includes the Title IX Coordinator, Deputy Title IX Coordinators, and the Sexual Violence Task Force. In reviewing the incidents, we look for trends in order to better inform our strategies to protect students and direct our outreach efforts. In addition to our annual incidents, we also review our bi-annual Campus Climate Survey results, which is an anonymous survey that goes out to all students and for which we had a 30% participation rate for our first survey in Spring 2015 (next survey will be completed in Spring 2017). Based on the log of reported incidents, the biggest trend that we are seeing is a decrease in formal complaints/ investigations and an increase in the number of complainants requesting interim remedies and academic accommodations without filing a formal complaint. We believe that this is due to a more educated student population who understand their rights under Title IX to receive interim remedies and academic accommodations even if they choose not to file a complaint. Based on both the annual incident log and the Campus Climate Surveys results, we are focusing efforts on educating women in sororities, trainings focused on educating students from underrepresented communities, and our LGBT community, as well as programming targeting our male students to address issues of masculinity and rape culture. Discussions regarding trends and necessary programming occur at every Sexual Violence Task Force meeting.

California State Auditor's Assessment of Annual Follow-Up Status: Fully Implemented

Annual Follow-Up Agency Response From February 2016

A subcommittee of the Sexual Violence Task Force has completed a review of student survey data relating to the prevalence of sexual violence at SDSU. This survey data provides important information relating to trends and risk markers.

California State Auditor's Assessment of Annual Follow-Up Status: Partially Implemented

The documentation provided by San Diego State evaluated the data submitted through the student survey. However, the documentation provided did not describe how it informed the strategies San Diego State has in place to protect students and direct its outreach efforts. In addition, our recommendation specifically discusses a summary of incidents that were reported to various departments on campus. This review was not included in the documentation provided. Therefore, we have assessed this recommendation as partially implemented.

Annual Follow-Up Agency Response From October 2015

SDSU meets regularly to discuss Title IX complaints and to review complaint logs. The identification of trends to better inform SDSU's strategies relating to awareness, prevention and support will take at least two years to fully identify. Looking at only one year's worth of data provides an incomplete picture given the already identified cycles relating to the increase of sexual assaults that occur during the red-zone and during the start of the spring semester.

California State Auditor's Assessment of Annual Follow-Up Status: Not Fully Implemented

1-Year Agency Response

The campus has developed a log for all Title IX complaints. This log contains summary information relating to complaints of sexual harassment and sexual violence. The Title IX Coordinator, in collaboration with the Deputy Title IX Coordinators, the co-chairs of the Sexual Violence Task Force and select university leadership, will evaluate the summary data at the end of each fiscal year to identify trends to better inform its strategies to protect students and direct outreach efforts.

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

Although San Diego State has marked this recommendation as Fully Implemented, we have assessed it as Partially Implemented. San Diego State has not yet identified demographic trends that will better inform its strategies to protect students and direct its outreach efforts.

6-Month Agency Response

The Title IX Coordinator is currently in the process of compiling 2013/14 data. The Title IX Coordinator, in collaboration with the Sexual Violence Task Force, will evaluate the summary data to identify trends to better inform its strategies to protect students and direct outreach efforts.

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

60-Day Agency Response

The Title IX Coordinator is currently in the process of compiling 2013/14 data. The Title IX Coordinator, in collaboration with the Sexual Violence Task Force, will evaluate the summary data to identify trends to better inform its strategies to protect students and direct outreach efforts.

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

Recommendation #70 To: University of California, Berkeley

To identify ways to better serve their students, all universities should create a summary of student incidents of sexual harassment and sexual violence reported to the various departments on campus. Each university should evaluate its summary data to identify trends specific to the demographics, as well as the timing, location, and frequency of incidents, to better inform its strategies to protect students and direct its outreach efforts.

Annual Follow-Up Agency Response From October 2016

The procurement of the Advocate GME tracking system was completed, June, 2016. While continuing to work on customizing the Advocate GME system for campus use, including addressing privacy and security requirements, the Office of Prevention, Harassment and Discrimination has created a database. The system includes a comprehensive log of all cases of sexual harassment and sexual violence involving students. This summary log tracks various details of incidents and the parties involved in those incidents. This summary data is used both in day to day implementation of our Title IX "Stop, Prevent and Remedy" obligation, but also for broader analysis of UC systemic trends. OPHD sends detailed data reports from its current system on a weekly and monthly basis to campus leadership, as well as to representatives at UCOP.

The campus Coordinated Community Response Team will also review the data set described above on a periodic basis throughout the year and make recommendations for further campus action.

The Title IX Officer continues to convene a weekly Case Management Team (CMT) meeting (including Title IX, Student Conduct, confidential advocacy services, Respondent Services, UCPD) that reviews every sexual violence or sexual harassment report involving students. The CMT discusses trends, demographics and other factors that inform prevention and response strategies. Moreover, UCB collects quarterly metrics data on all reports of sexual violence and reports of sexual harassment, and submits this information to UCOP.

California State Auditor's Assessment of Annual Follow-Up Status: Fully Implemented

Annual Follow-Up Agency Response From September 2015

Nothing new to report from the June submission.

California State Auditor's Assessment of Annual Follow-Up Status: Not Fully Implemented

1-Year Agency Response

The Office for the Prevention of Harassment and Discrimination is purchasing Advocate GME, a web based case tracking system that will allow for the production of this data. System implementation is planned for June and July 2015. UCB is in the midst of contractual arrangements now. Even before purchasing this system, the Berkeley campus and all UC campuses have been collecting these data and submitting them to the UC Office of the President, where systemwide trends are being tracked.

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

Although UC Berkeley marked this recommendation as Fully Implemented, it is still working on implementing Advocate GME, a web-based case management system. The system will be customized to include an evaluation of demographic trends as we describe in our recommendation.Therefore, we have marked this recommendation as Partially Implemented.

6-Month Agency Response

UCB is currently evaluating additional ways in which summary data can be gathered, evaluated and presented. UCB has several cross functional campus groups that meet regularly to discuss issues and share information related to sexual violence, including the Sexual Misconduct Response Team, the Title IX Working Group and the Title IX Compliance Advisory Committee. In addition, the UCOP Task Force has recommended consistent systemwide data collection mechanisms. The Title IX and Center for Student Conduct Offices are working with UCOP to evaluate data systems now. This recommendation should be fully implemented in June 2015.

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

60-Day Agency Response

Currently evaluating additional ways in which summary data can be gathered, evaluated and presented. UCB (University of California, Berkeley) has several cross functional campus groups that meet regularly to discuss issues and share information related to sexual violence, including the Sexual Misconduct Response Team, the Title IX Compliance Advisory Committee.

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

Recommendation #71 To: University of California, Los Angeles

To identify ways to better serve their students, all universities should create a summary of student incidents of sexual harassment and sexual violence reported to the various departments on campus. Each university should evaluate its summary data to identify trends specific to the demographics, as well as the timing, location, and frequency of incidents, to better inform its strategies to protect students and direct its outreach efforts.

Annual Follow-Up Agency Response From October 2016

The UC Policy on Sexual Violence and Sexual Harassment (SVSH Policy) requires that any University employee who is not a Confidential Resource and who receives, in the course of employment, information that a student has suffered sexual violence, sexual harassment or other conduct prohibited by the SVSH Policy shall promptly notify the Title IX Officer. This ensures that the Title IX office receives all reports of student incidents of sexual harassment and sexual violence reported to the various departments on campus.

Since October 2015, UCLA's Title IX Office has been operating the Advocate GME case management system, which records and tracks every incident reported to the Title IX office. The case management system has enabled UCLA's Title IX office to evaluate summary data and better inform its strategies to protect students.

In addition, the Title IX coordinator convenes a weekly Case Management Team (CMT) meeting (including Title IX, Student Conduct, Complainant's advocate, Respondent Services, UCPD) that reviews every sexual harassment or sexual violence report involving students. The CMT discusses trends, demographics and other factors that inform prevention and response strategies. Moreover, UCLA collects quarterly metrics data on all reports of sexual violence and reports of sexual harassment, and submits this information to UCOP

California State Auditor's Assessment of Annual Follow-Up Status: Fully Implemented

Annual Follow-Up Agency Response From September 2015

The Case Management Team continues to meet weekly to discuss sexual violence incidents. The other teams previously mentioned continue to meet on a regular basis.

Moreover, the Title IX office has been collecting summary data on all reports it receives of sexual harassment and sexual violence.

UCLA has purchased a web-based case management system which is expected to go live on October 2, 2015. We expect the system to be loaded and operational in November 2015.

California State Auditor's Assessment of Annual Follow-Up Status: Not Fully Implemented

1-Year Agency Response

The Title IX Office is purchasing a web based case tracking system that will allow for the production of this data. System implementation is planned for June and July 2015. Even before purchasing this system, UCLA and all UC campuses have been collecting these data and submitting them to the UC Office of the President, where systemwide trends are being tracked.

UCLA is continuing to evaluate how it can better collect and review summary data. In addition, UCLA has convened a number of cross functional campus groups to share information, including the Case Management Team, the Consultation and Response Team, the Behavioral Intervention Team, the Safe Campus Team, the Clery Committee and the Coordinated Community Review Team.

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

Although UCLA has marked this as Fully Implemented, the database that will be able to conduct an analysis of specific demographic trends is still in progress. Therefore, we have assessed this recommendation as partially implemented.

6-Month Agency Response

The Case Management Team for Sexual and Gender-Based Violence and Misconduct now includes UCPD, Title IX, Student Conduct, Staff Compliance, and Victim Advocacy, and meets bi-weekly.

The Coordinated Community Review Team for Sexual and Gender-Based Violence and Misconduct meets quarterly. These teams address prevention, education, advocacy, and response including investigation and adjudication, to best support students. The President's Task Force will be reviewing additional ways in which summary data can be gathered and evaluated, and making recommendations for standardization.

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

60-Day Agency Response

UCLA is in the process of identifying additional ways in which summary data can be gathered and evaluated. UCLA already has several groups that meet periodically to discuss issues and share information related to sexual violence: Campus Coordinated Response, Consultation and Response, Safe Campus, Case Review, and Crime Incident Review.

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

Recommendation #72 To: Chico, California State University

Chico State should ensure that it fully resolves all complaints that are reported to it and that it imposes appropriate discipline.

1-Year Agency Response

CSU Chico has trained all investigators, developed checklists and templates, as well as case management procedures to ensure that all complaints are fully resolved, and that appropriate discipline is imposed. We have also committed to report to the Chancellor's Office and publish on the campus website, statistics regarding Sexual Misconduct, Dating and Domestic Violence, and Stalking, annually. The information shall be reported in a manner that protects the privacy of the persons involved, including victims, Respondents, and witnesses.

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

6-Month Agency Response

CSU Chico has initiated a review of its complaint processes and procedures, and is in the process of developing additional tools to ensure the full implementation of this recommendation.

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

60-Day Agency Response

CSU Chico has initiated a review of its complaint processes and procedures, and is in the process of developing additional tools to ensure the full implementation of this recommendation.

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

Recommendation #73 To: San Diego, California State University

San Diego State should implement its Sexual Violence Task Force and ensure that it includes participants such as high-level campus administrators, academic leaders, and student leaders.

60-Day Agency Response

SDSU has identified members of the Sexual Violence Task Force and anticipates the initial meeting of the task force to occur within the next 60 days.

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

San Deigo State has established its Sexual Violence Task Force (task force) and provided evidence showing the task force had its initial meeting.

All Recommendations in 2013-124

Agency responses received are posted verbatim.