Audit of the Massachusetts Maritime Academy
March 3, 2022 · Massachusetts Maritime Academy · Read the full official report on mass.gov ↗
Published March 3, 2022 Audit covers July 1, 2017 – December 31, 2019 Under Suzanne M. Bump · 2011–2023
source
“MMA did not maintain a current and complete daily crime log.”
Read the plain-English breakdown
This is a state performance audit of Massachusetts Maritime Academy covering July 1, 2017 through December 31, 2019, focused on whether the school followed parts of the federal Clery Act on campus crime and safety reporting.
“In this performance audit, we examined MMA’s compliance with certain aspects of the Jeanne Clery Disclosure of Campus Security Policy and Campus Crime Statistics Act (Clery Act), as amended.”
The auditor checked whether the academy properly tracked campus crimes, reported crime statistics and required safety policies, and gave required safety training to new students and employees.
“Below is a list of our audit objectives, indicating each question we intended our audit to answer, the conclusion we reached regarding each objective, and where each objective is discussed in the audit findings.”
Accurate campus safety records help students, workers, parents, and the public understand safety risks and make informed decisions.
“The lack of a current and complete daily crime log could prevent stakeholders (students, employees, and the general public) from obtaining information about incidents within MMA’s geography.”
If you are a student, employee, parent, or visitor, this matters because the school’s safety reports are supposed to help you judge risks on and around campus.
“This could prevent them from accurately assessing risks to their personal safety and the security of their property and dealing properly with those risks.”
The academy did not fully comply with the campus safety reporting rules the audit reviewed, but it said it had started making fixes, including outside help and a new compliance process.
“MMA’s response to our audit findings indicates that it is fully committed to taking the necessary steps to ensure compliance with its Clery Act obligations.”
The report recommends that MMA create and enforce policies, train staff, improve monitoring, document crime data properly, and make its annual reports accurate and complete.
“MMA should establish monitoring controls (e.g., a formal supervisory review or a quality assurance process) to ensure that the information in its ASRs is accurate and complete.”
The findings are significant because failure to follow the Clery Act could affect the academy’s ability to participate in federal student aid programs.
“Further, noncompliance with the requirements of the Clery Act related to the maintenance of a daily crime log could result in MMA losing the opportunity to participate in federal Title IV programs.”
The Clery Act is a federal law that requires colleges to tell students, employees, and the public about campus safety policies and certain campus crimes.
“It is a federal consumer protection statute that provides current and prospective students and employees of institutions of higher education, as well as the general public, with important information about public safety on campuses of institutions of higher education.”
What the Auditor checked
- Did not comply Does MMA record all crimes committed within its geography in a daily crime log in accordance with the Clery Act (Section 1092[f] of Title 20 of the United States Code [USC]) and related requirements (Section 668.46 of Title 34 of the Code of Federal Regulations [CFR] and the 2016 edition of the United States Department of Education’s [US ED’s] Handbook for Campus Safety and Security Reporting)?
- Did not comply Does MMA report Clery Act crime statistics and certain required statements about policies in its annual security reports (ASRs) in accordance with the Clery Act (20 USC 1092[f]) and related requirements (34 CFR 668.46 and the 2016 edition of US ED’s Handbook for Campus Safety and Security Reporting)?
- Did not comply Does MMA provide education programs to newly enrolled students and newly hired employees in accordance with the Clery Act (20 USC 1092[f]) and related requirements (20 USC 1011i, 34 CFR 668.46[j][1], and No. 202 of Volume 79 of the Federal Register)?
What the Auditor found
Why it matters: Students, employees, and the public may not have accurate information about campus incidents, and the academy could risk participation in federal Title IV programs.
Standard: Section 1092(f)(4)(A) of Title 20 of the United States Code and Section 668.46(f)(2) of Title 34 of the Code of Federal Regulations ( Section 1092(f)(4)(A) of Title 20 of the United States Code; Section 668.46(f)(2) of Title 34 of the Code of Federal Regulations )
3 recommendations
- MMA should develop policies and procedures that require its SSO staff to identify all Clery Act crimes and report them to PSO within two business days after they are reported to SSO.agency: already implemented
- MMA should establish monitoring controls to ensure that these policies and procedures are followed.
- MMA should ensure that SSO staff members are properly trained on how to identify Clery Act crimes and report them to PSO staff members for inclusion in the daily crime log.
Agency response & Auditor reply
Agency: "The Office of the Commandant of Cadets/Dean of Students, which oversees housing and student conduct among other areas, has instituted notification of all Clery reportable incidents to Public Safety within two business days of the incident."
Auditor: "MMA’s response to our audit findings indicates that it is fully committed to taking the necessary steps to ensure compliance with its Clery Act obligations."
Why it matters: Current and prospective students, employees, and the public may draw incorrect conclusions about campus safety, and the academy could risk participation in federal Title IV programs.
Standard: Section 668.46(c) and Section 668.46(c)(11)(i) of Title 34 of the Code of Federal Regulations, and the 2016 edition of the United States Department of Education’s Handbook for Campus Safety and Security Reporting ( 34 CFR 668.46(c); 34 CFR 668.46(c)(11)(i) )
2 recommendations
- MMA should develop policies and procedures that require its staff to record and report incidents using the Clery Act crime categories (as well as their locations, including whether they occurred in residential facilities), to retain the documentation, and to make a reasonable effort to obtain statistics on Clery Act crimes that occur within its geography from local or state police.
- MMA should provide periodic training to its staff regarding how to properly review campus crime records and how to categorize and report the information from these records in ASRs using the Clery Act crime categories.
Agency response & Auditor reply
Agency: "Beginning back in 2020 (as a result of the audit team’s earlier on-site visit), the Chief of Police/Director of Public Safety completed Foundations of the Clery Act formal training and began outreach to request statistics from local and state police agencies for inclusion in the ASR."
Auditor: "MMA has already taken several corrective actions and is in the process of implementing others to remediate the deficiencies noted in this report."
Why it matters: New students and employees may not be fully informed about campus crime and alcohol abuse risks or prepared to prevent or respond to harm.
Standard: Section 668.46(j)(1)(i) of Title 34 of the Code of Federal Regulations ( 34 CFR 668.46(j)(1)(i) )
2 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.
Agency response & Auditor reply
Agency: "Crime prevention and awareness training is now delivered to all incoming students in person over two sessions during the 13 day orientation program each summer."
Auditor: "MMA has already taken several corrective actions and is in the process of implementing others to remediate the deficiencies noted in this report."
Why it matters: Current and prospective students, employees, and the public may draw incorrect conclusions about campus safety, and the academy could risk participation in federal Title IV programs.
Standard: Clery Act annual security report requirements, including 34 CFR 668.46(b)(2)(iii), 20 USC 1092(f)(1)(E), 34 CFR 668.46(b)(11)(vii), 20 USC 1011i(a)(1), 34 CFR 668.46(c)(11)(i), and 34 CFR 668.46(b)(2)(iv) ( 34 CFR 668.46(b)(2)(iii); 20 USC 1092(f)(1)(E); 34 CFR 668.46(b)(11)(vii); 20 USC 1011i(a)(1); 34 CFR 668.46(c)(11)(i); 34 CFR 668.46(b)(2)(iv) )
2 recommendations
- MMA should ensure that the staff members who are responsible for preparing its ASRs are properly trained on what information must be disclosed therein.
- MMA should establish monitoring controls (e.g., a formal supervisory review or a quality assurance process) to ensure that the information in its ASRs is accurate and complete.
Agency response & Auditor reply
Agency: "Members of the Clery Compliance Committee will engage in annual training, via the Clery Center [a nonprofit organization that helps institutions of higher education meet the requirements of the Clery Act] or another entity, to ensure continued compliance with requirements."
Auditor: "MMA has already taken several corrective actions and is in the process of implementing others to remediate the deficiencies noted in this report."