INSTITUTION: Ramapo College of New Jersey

PRCN: 200130218417 OPEID: 009344
TIN: 216000928 DUNS: 076688399

DATES OF REVIEW:

FOCUSED REVIEW:

CALENDAR YEARS REVIEWED:

TYPE AND CONTROL:

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REVIEWING ED OFFICIALS:

INSTITUTIONAL OFFICIALS CONTACTED:

BACKGROUND:

Ramapo College of New Jersey is a public institution of higher education, established in 1969. The college is accredited by the Middle States Association of Colleges and Schools and authorized by the New Jersey Commission on Higher Education. The college is located in Mahwah, New Jersey and offers liberal arts, sciences, and professional studies.

The institution participates in the Federal Pell Grant, Federal Supplemental Educational Opportunity Grant, Federal Work Study, Federal Perkins Loan, Federal Direct Loan, and Federal Family Education Loan programs. In fall 2000 approximately 5,200 students attended Ramapo College, including almost 300 graduate students and 235 international students.

Ramapo College of New Jersey was selected for review as a result of a complaint regarding the institution's compliance with the Campus Security Act requirements. The complaint alleged that the college did not report three (3) drug law arrests from the school's 1998 campus crime statistics, the crime log is neither sufficiently updated or archived, and that numerous campus incident reports for 1998 were missing or not reported in the annual Campus Security Report.

Prior to our review, the College re-reviewed all incident reports for 1997, 1998, and 1999, and determined that there were inaccuracies in the statistics they had reported in each of these years. We considered their re-review as part of our analysis.

SCOPE OF REVIEW:

Members of the New York Case Management Team conducted a program review from April 30 to May 4 on campus. The review examined the school's compliance with administration of the Campus Security Act of 1990. The review team interviewed school officials and reviewed relevant documents, including the Security Department Policies and Practices and Campus Crime Statistics brochure, the Student Handbook, the daily crime log, the public crime log, incident reports prepared by the Campus Security Department, and the log of judicial referrals for alcohol, drugs and weapons, maintained by the Office of Residence Life. The review also included interviews with the Mahwah Police Department's College liaison officer and the review of crime statistics maintained by the Mahwah Police Department.

During the review, some areas of noncompliance were noted. Findings of noncompliance are referenced to the applicable laws, regulations, and policies, and specify the actions to be taken by Ramapo College of New Jersey to bring the operation of the Institution into compliance with regulations and statutes.

Although the review was thorough, it was focused on the institution's compliance with the requirements of the Campus Security Act and, therefore, cannot be assumed to be all-inclusive. The absence of any statements in the report concerning Ramapo College of New Jersey's specific practices and procedures must not be construed as acceptance, approval, or endorsement of those specific practices and procedures. Furthermore, it does not relieve Ramapo College of New Jersey of its obligation to comply with all of the statutes or regulatory provisions governing Title IV programs.

Ramapo College of New Jersey's response is due within 30 days of receipt of this report. The findings resulting from this program review could be referred to the Department's Administrative Action and Appeals Division for possible administrative action. Administrative action includes the imposition of tines, or limitation, suspension or termination of the institution's eligibility to participate in the Title IV programs.

FINDING NO. 1 - Crime Statistics Not Accurately Disclosed in Annual Campus Security Report

The Campus Security Report prepared by Ramapo College of New Jersey for the year 2000 included inaccurate statistics for 1997, 1998 and 1999. The report did not include all reportable incidents including three (3) drug law arrests in 1998, contained incidents that were incorrectly reported in the wrong crime category, and were not reconciled to incident logs maintained by the Mahwah Police Department.

Missing Reportable Drug Arrests

As alleged in the complaint received by our office, Ramapo College of New Jersey's Campus Security Report did not include three (3) on campus arrests for drug law violations by the Mahwah Police Department. Prior to our visit, College officials reviewed all incident reports for 1997, 1998 and 1999 and identified the arrests not reported. The College officials indicated that the arrests were not reported because the instructions for completing the Campus Security Report were unclear. They noted that the instructions did not require that arrests in residence halls be reported separately, and they mistakenly believed they did not have to report the incidents in the on campus category either. The following discrepancies were identified:

1998 Calendar Year Statistics - The Campus Security Report did not list any on campus arrests for drug law violations, while the incident reports prepared by the Campus Security Department included three (3) on campus arrests for the calendar year. [Incident reports C-400-98 (1 arrest made) and C-426-98 (2 arrests made)].

Other Unreported or Improperly Reported Incidents

The complaint also alleges that Ramapo College of New Jersey did not report, or did not correctly categorize numerous crime incidents in 1997, 1998 and 1999. As previously stated, prior to tour visit the College reviewed all incident reports for the period, and identified incidents not reported or incorrectly reported. The following discrepancies were identified:

1997 Calendar Year Statistics - The Campus Security Report of Disciplinary Actions/Judicial Referrals, reported 36 liquor law violations. Six (6) of the violations occurred in 1996, and should not be included. [(Case # 012-964 (4 violations), and Case # 015-964 (2 violations)].

One (1) burglary was reported as in residence hall, and should have been reported as on campus. (C-810-97).

One (1) aggravated assault was reported as public property, and should have been reported as in residence hall. (C-134).

1998 Calendar Year Statistics - The Campus Security Report listed two (2) burglaries in residence halls. There were an additional 23 burglaries which were not reported, because they were incorrectly categorized as thefts.

Case #	Location
C-002-98	Residence Hall
C-102-98	Residence Hall
C-133-98	Residence Hall
C-202-98	Residence Hall
C-218-98	Residence Hall
C-329-98	Residence Hall
C-438-98	Residence Hall
C-449-98	Residence Hall
C-459-98	Residence Hall
C-640-98	Residence Hall
C-700-98	Residence Hall
C-702-98	Residence Hall
C-806-98	Residence Hall
C-1098-98	Residence Hall
C-1498-98	Residence Hall
C-1477-98	Residence Hall
C-1636-98	Residence Hall
C-1697-98	Residence Hall
C-1773-98	Residence Hall
C-565-98	Residence Hall
C-1223-98	Campus
C-1223-98	Campus
C-1698-98	Campus
C-025-98	Campus

One (1) hate crime that was reported as in residence hall should have been reported as on campus. (Incident Report C-510-98)

As previously indicated, three (3) drug arrests were not reported for 1998, as the complainant alleged. They should have been reported as in residence hall.

The complainant also alleged that two (2) drug cases that were handled as judicial referrals (Incident Reports C-1210-98 and C-70-98) should have resulted in arrests. The incident reports did not indicate why the Mahwah Police Department was not notified.

The complainant further alleged that numerous incident reports were missing for 1998. This allegation was generally not correct. The College did have copies of incident reports identified in the complaint, although eight (8) of the incident reports were not signed. (Incident Reports C-160-98, C-238-98, C-413-98, C-810-98, C-899-98, C-967-98, C-1312-98, C-1317-98).

1999 Calendar Year Statistics - The Campus Security Report listed 16 burglaries. There were an additional five (5) burglaries which were not reported.

Case #	Location
C-034-99	Campus
C-419-99	Campus
C-1003-99	Campus
C-1166-99	Campus
C-1882-99	Non-campus Bldg.

Nine (9) burglaries that were reported as in residence hall should have been reported as on campus. (Incident Reports # C-044-99, C-052-99, C-946-99, C-701-99, C-878-99, C-1159-99, C-1211-99, C-1666-99, C-1705-99).

One (1) drug arrest that was reported as in residence hall should have been reported as on campus. (Incident Report C-1868-99).

Three (3) alcohol arrests that were reported as in residence hall should have been reported as on campus. (Incident Report C-1868-99).

Two (2) aggravated assaults that were reported as in residence hall should have been reported as on campus. (Incident Reports C-595-99, C-857-99).

Crime Data Not Reconciled with Mahwah Police Department

Ramapo College's Campus Security Officers do not have authority to make arrests. The Mahwah Police Department responds to calls from Campus Security and other staff, and from students. The Mahwah Police also conduct undercover drug operations involving Ramapo College. The College coordinates security activities with the Mahwah Police through periodic meetings with a Police Captain, who is the designated liaison.

The Mahwah Police maintains a dispatcher's report that lists all calls to the police by location. College officials stated they did not, in the past, reconcile this dispatcher's report to the daily crime log to ensure that the daily crime log was complete. As a result, there may have been incidents where the police responded, that were not entered on the daily crime log, and were not reported on the Annual Campus Security Report. For example, the dispatcher's log for 1999 indicates there were two (2) calls for alcohol violations (Cases #s 7836 and 22584) and one (1) call for burglary (Case # 18217) that may have been reportable incidents. It was unclear if these incidents were crimes that should have been reported, or if they resulted in arrests or judicial referrals.

FINDING NO. 2 - Public Crime Log Not Maintained Before April 1999

Ramapo College maintains a public crime log for the most recent 60 day period. Incidents that are more than 60 days old are transferred to an archive, and maintained for public inspection. The earliest incidents in the archive date from April 1999. There was no evidence the log was maintained before this time, as required by the 1998 Amendments to the Higher Education Act.

Failure to accurately report all of the criminal occurrences required to be included in the Campus Security Report denies students and employees the opportunity to make informed decisions about the relative security of the campus environment and to make personal security decisions.

REFERENCE:

REQUIREMENT: The College should review the requirements of 34 CFR 668.46 (formerly 34 CFR 668.47) to ensure the accurate reporting of data in the College's Campus Security Report, and to comply with the other requirements of 34 CFR 668.46. The College's reporting system should include the following:

1. Reconciliation of all incidents reported on the daily crime log to incident reports and final reporting on the Campus Security Report.
2. Reconciliations should be performed between the Mahwah Police Department's dispatcher reports, and the College's records.
3. The Public Crime Log should be amended to include reportable incidents between October 1998 and April 1999.

Additionally, the College must ensure that the necessary corrections are made to any erroneous prior year's statistics that are included in the current campus Security Report.

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