Overview
During our audit period, MMA did not ensure that all of its newly enrolled students and newly hired employees were assigned, and had completed, the primary crime prevention and awareness training for topics such as dating violence, domestic violence, sexual assault, stalking, and alcohol abuse within established timeframes.
If MMA does not ensure that its newly enrolled students and newly hired employees receive this training on time, they may not be fully informed about the types of crime and alcohol abuse that may occur within MMA’s geography. Further, the students and employees may not be fully prepared to prevent, or protect themselves from, any harm that might come from these situations. Finally, noncompliance with Clery Act requirements regarding appropriate student and staff training could result in MMA losing the opportunity to participate in federal Title IV programs.
Newly enrolled MMA students and newly hired employees were assigned primary crime prevention and awareness training in MMA’s online training software, EVERFI. We determined the following regarding MMA students who were newly enrolled and employees who were newly hired during the audit period.
- Only 1,220 (80.9%) of MMA’s 1,508 newly enrolled students were assigned primary crime prevention and awareness training in EVERFI, and only 1,160 (95.1%) of those 1,220 students completed it. Only 611 (52.7%) of those 1,160 students completed the training within MMA’s established 30-day timeframe.
- Only 39 (86.7%) of the 45 newly hired employees were assigned the training; 38 (97.4%) of the 39 employees completed it. Only 31 (81.6%) of those 38 employees completed the training within MMA’s established 30-day timeframe.
According to MMA officials, in addition to primary crime prevention and awareness training, MMA assigned alcohol abuse awareness training to its newly enrolled students and newly hired employees. We determined the following regarding the 1,508 new students enrolled in MMA during our audit period:
- Only 1,217 (80.7%) were assigned alcohol abuse awareness training; only 445 (36.6%) of the 1,217 were assigned the training within MMA’s 30-day prescribed timeframe.
- Of these 1,217 students, 1,138 (93.5%) completed the training; only 543 (47.7%) of the 1,138 did so within MMA’s prescribed 30-day timeframe.
None of the 45 newly hired employees hired during the audit period was assigned alcohol abuse awareness training.
Authoritative Guidance
According to 34 CFR 668.46(j)(1)(i), institutions of higher education, such as MMA, must provide “primary [crime] prevention and awareness [training] programs for all incoming students and new employees.”
MMA does not have written policies and procedures regarding Clery Act training for newly enrolled students and newly hired employees. However, MMA’s dean of human resources and Title IX co-coordinator told us that MMA requires all newly enrolled students and newly hired employees to participate in Clery Act training for primary crime prevention and awareness and alcohol abuse awareness. The dean added that this training was supposed to be assigned to these students and employees in EVERFI within 30 days of enrollment or hire and must be completed by the students or employees within 30 days of assignment.
Reasons for Issue
MMA does not have any policies and procedures that ensure that its officials assign required Clery Act training to all newly enrolled students and newly hired employees or that assignees complete the training in the manner prescribed by the act and MMA’s practice.
Recommendations
- MMA should establish policies and procedures that ensure that Clery Act–required training is assigned to, and completed by, all newly enrolled students and newly hired employees.
- MMA should establish monitoring controls to ensure that staff members adhere to these policies and procedures.
| Date published: | March 3, 2022 |
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