April 26, 2010 William N. Johnston, President Certi?ed Mail Wesley College Return Receipt Requested 120 North State Street 7006 3450 0000 1573 6692 Dover, DE 19901-3875 RE: Final Program Review Determination OPE 1D100143300 PRCN: 200640326783 Dear President Johnston: As you know, the US. Department of Education?s Philadelphia School Participation Team conducted a program review of Wesley College?s (Wesley; the College) administration of programs authorized pursuant to Title IV of the Higher Education Act of 1965, as amended, 20 U.S.C. 1070 _e_t _sgq. (Title IV, HEA programs). This program review focused on the College?s compliance with the requirements of the Jeanne Clery Disclosure of Campus Security Policy and Campus Crime Statistics Act. Wesley?s of?cial response was dated October 13, 2006. Purpose: Final determinations have been made conceming all of the violations and concerns identi?ed during the program review. The purpose of the attached Final Program Review Determination (FPRD) letter is to advise the College of the Department?s ?nal determinations and to explain the additional action steps that are needed to resolve and close the program review. Due to the serious nature of the violations identified during the program review, this FPRD is being referred to the Administrative Actions and Appeals Division for consideration of possible adverse administrative action. Such action may include a fine, or the limitation, suspension or termination of the Title IV eligibility of the College pursuant to 34 C.F.R. Part 663, Subpart G. If initiates any action, a Wesley will receive a separate notification that provides information on appeal rights and procedures for ?ling an appeal. Federal Student Aid - School Participation Team - NE The Wanamaker Building [00 Penn Square East, Suite 51! Philadelphia, PA i910?7-3323 FEDERAL STUDENT AID Iiliirgi-START HERE. GO FURTHER. William N. Johnston, Ed. D., President Wesley College Campus Security FPRD Cover Letter - page ii 2 While the College may not appeal this Final Determination, Wesley will have full appeal rights in the event that initiates an adverse administrative action as a result of the violations of the Glory Act identi?ed in this FPRD. Upon completion of the ?Supplemental Corrective Measures? outlined in Section of this FPRD, the program review will be closed. Record Retention: Program records relating to the period covered by this program review must be retained until the later of: resolution of the violations, weakness, and other issues identi?ed during the program review or the end of the retention period applicable to Title IV-related records under 34 C.F.R. 668.24 and We would like to express our appreciation for the courtesy, cooperation and patience shown to us throughout the program review process. If you have any questions about this FPRD or the program review process, please contact Mr. James L. Moore, on (215) 656-6495. Sincerely, PouQc? <9 Nancy Paula i?'ord Area Case Director Attachment as Stated cc: Mr. Walter Beaupre, Director, Office of Safety and Security, Wesley Mr. Eric Nelson, M.B.A., VP. of Finance and Director of Human Resources, Wesley Mr. J. Michael Hall, M.B.A., Financial Aid Manager, Student Financial Planning, Wesley Elizabeth Sibolski, President, Middle States Association CHE Ms. Maureen Laffey, Director, Delaware Higher Education Commission TA RT .. FEDERAL STUDENT AID i Prepared for Wesley College OPE ID: 00143300 PRCN: 200640326783 Prepared by US. Department of Education Federal Student Aid School Participation Team ?Philadelphia Final Program Review Determination April 26, 2010 ederalStudentAid.ed.gov William N. Johnston, d. 0., President Wesley College Fine! Program Review Determination Page I Table of Contents Page A. Institutional Information .. 2 B. Background .. 3 C. Scepe of the Review .. 4 D. Findings and Final Determinations .. 4 1. Failure to Issue ?Timely Warnings" in Accordance with Federal Regulations . . 5 2. Failure to Maintain Daily Crime Log in Accordance with Federal Regulations . . . .. 7 3. OmissiOn of Required Policy Statements Improper Formatting of Campus Secority Reports .. 9 E. Supplemental Corrective Measures .. l0 William N. 5110., President Wale? College Final Proan Review Determination - Page it 2 A. Institutional Information Wesley College 120 North State Street Dover, DE 19901-3875 Type: Private, Non-Pro?t Highest Level of Offering: Master's Degree Accrediting Agency: Middle States Association of Colleges and Schools Current Total Student Enrollment: 2,500 (Approx. Fa112008) 01' Students Receiving Title IV: 80% (Approx) Title IV Funding Levels: 2006-2007 2007-2008 20084009 Federal Pell Grant Program 8 1,268,776 1,638,447 5 1,926,298 Federal Family Education Loan Program 11,759,099 12,384,845 8 14,430,509 Fed. Supp. Educ. Opp. Grant Program 8 195,485 233,333 266,667 Federal Work Study Program 8 217,428 353,909 550,601 Federal Perkins Loan Program 8 98,800 97,200 8 121,250 Fed. Acad. Competiveness Grant Prog. 8 28,550 3 47,775 40,776 Total 13,568,138 8 14,755,509 17,336,101 Federal Family Education Loan Program Default Rate: Cohort Year Rate 2007 10.4% 2006 5.7% 2005 3.9% Federal Perkins Loan Program Default Rate: Year Ending gat_e 6/30f2007 17.6% 68072006 19.7% 6/30f2005 12.5% Founded in 1873, Wesley College (Wesley; the College) offers programs of study in more than 30 academic fields. The main campus, located in the City of Dover, is situated William N. Johnston. Ed. 0., President Wes-14v College Final Program Review Determination - Page ii 3 on 50 acres and includes 19 buildings. The Wesley has additional locations in New Castle, DE and at Dover Air Force Base. As of Fall 2008, approximately 2,100 students were enrolled at the main campus while an additional 400 students attended the additional locations. Wesley maintains an Of?ce of Safety and Security (038), which provides a 24/7 presence on campus. Security of?cers do not have law enforcement powers and therefore are not authorized to carry weapons or make arrests. Wesley officials state that the 083 has an excellent working relationship with Federal, state, and local, law enforcement agencies. B. Background The Jeanne Clery Disclosure of Campus Security Policy and Campus Crime Statistics Act (Clery Act) requires all institutions that receive Title IV funding to provide accurate and complete campus crime information to their students and employees. Each year, institutions must prepare, publish, and distribute an annual campus security report (CSR). The Clery Act requires the disclosure of crime statistics and dissemination of information about campus safety policies, procedures, programs, and protocols that prepare members of the campus community to be well-informed consumers and employees. The Clery Act also requires institutions to notify students and employees of reported crimes and current threats on an ongoing basis by maintaining an open daily crime log and issuing timely warnings. Institutions have an obligation to provide current and prospective members of the campus community with accurate, complete, and timely information about campus safety. Access to such information allows community members to make infonned'decisions about their educational and employment choices and to take an active role in their personal safety and to protect their personal property. On May 5, 2006, Security on Campus, Inc. (SOC) ?led a complaint with the US. Department of Education (the Department) alleging that Wesley College had violated several provisions of the Glory Act. This complaint was ?led on behalf of a group of Wesley students, including students associated with the College?s newspaper, The Whetstone. The complaints alleged that Wesley failed to issue a timely warning in response to a forcible sex offense that occurred on February l2, 2006, when a female student reported to Wesley?s 088 that she had been raped by an acquaintance in her Carpenter Hall room. 088 subsequently noti?ed the Dover Police Department. The acoused student was arrested three days later on?campus. The campus community learned of the incident through a local newspaper. The Whetstone reporters alleged they were denied access to the daily crime log and that the events pertaining to the incident were not disclosed by the College. Institutional officials cited limitations imposed by the Federal Educational Records Privacy Act (FERPA) as the reason for not disclosing the incident. Student journalists also noted that the incident was not documented in the daily crime log as required by the Clery Act. Finally, the complaint stated that certain required policy disclosures were not included in the CSR. As the agency charged with enforcement of the Glory Act, the Department conducted a program review to evaluate the allegations raised by the complainants. WilliamN. Johnston, Erin, President Wesley College Final Program Review Determination - Page ii 4 C. Scope of Review The Department conducted an off-site focused program review of Wesley?s compliance with the Glory Act. Wesley was noti?ed of the initiation of the review in a letter dated September 13, 2006. The Department?s letter explained the allegations and the Glory Act requirements. The letter also required Wesley to submit a comprehensive response to the allegations as well as speci?c information regarding its safety and security programs. Wesley submitted its initial response on October 13, 2006. Throughout the program review process, supplemental information was requested by the Department and provided by the complainants and the College. Mr. James L. Moore, 111, Senior Institutional Review Specialist, conducted the review. The focus of the review was to evaluate Wesley?s compliance with the Glory Act. For more detail on the statutory requirements, please see 485(1) of the Higher Education Act of 1965, as amended (HEA), 20 11.8.0 ?1092(f). The Department?s implementing regulations can be found at 34 C.F.R. 668.41-668.46. During the review, we analyzed all the materials that were submitted by SOC in suppon of the complaint and by Wesley. We have completed our analysis and are issuing this Final Program Review Determination (F PRD) letter to advise the College of the Secretary?s ?nal diSposition of this matter. Disclaimer: Although the review was thorough, it cannot be assumed to be all-inclusive. The absence of statements in the report concerning Wesley College?s speci?c practices and procedures must not be construed as acceptance, approval, or endorsement of those speci?c practices and procedures. Furthermore, it does not relieve Wesley of its obligation to comply with all of the statutory and/or regulatory provisions governing the Title lV, HEA programs. D. Findings and Final Determinations The purpose of this letter is to: (I) advise Wesley of the Department?s ?nal determinations regarding violations of the Clery Act; (2) provide instructions regarding additional corrective actions needed to bring Wesley?s operations into compliance with the Glory Act; (3) provide information regarding next steps; and, (4) close the program review, subject to the satisfactory completion of the requirements outlined in Section of this FPRD. This section identi?es the ?ndings of the program review and the Department?s ?nal determinations. The ?ndings and the ?nal determinations are based on a thorough examination of records gathered during the program review including the College?s of?cial response. Willem N. Johnston, can" President Wesley College Fina! Program Review Detenninarion - Page ii 5 Finding 1: Failure to Issue ?Timer Warnings? in Accordance with Federal Regulations Citation: For purposes of crime prevention; institutions must issue timely warnings to students and employees to inform them of reported crimes that pose a threat to the health and safety of the campus community. See ?485(f)(3) of the REA. These warnings must be issued to the campus community in any case where an incident of crime listed in 34 CPR. 668.46 l) or that represents a threat to students or employees is reported to a campus security authority. 34 C.F.R. 668.46 In addition, institutions are required to include a number of detailed policy statements in the annual campus security report. 34 GER. 668.46 The policy statements must include the institution?s policy for the issuance of timely warnings and clear notice of the procedures that students and other must follow to report crimes and other emergencies that occur on campus. 34 CFR. 668. 46 Noncompliance: Wesley did not issue a timely warning in response to a forcible sex offense that occurred on February 12, 2006 when a female student reported that she had been raped by an acquaintance in her Carpenter Hall room. Wesley?s Of?ce of Safety and Security subsequently noti?ed the Dover Police Department (DPD) about the incident. DPD investigated and arrested the accused student three days later on the Wesley campus. The following is a timeline of major events: Febr_u_a;y 12, 2006: The assault occurs in the early morning hours. Later the same day, the victim reports the incident to 083. An incident report is taken and the complainant provides a detailed statement of the events. Wesley security officials immediately determine that the complainant is a victim of a sexual assault. She is taken to Kent General Hospital where a sexual assault kit is administered and additional medical testing and evaluations are performed. The Dover Police Department and victims services officials are contacted. Febmary 13, 2006: The assailant contacts the complainant by instant message. In a series of messages, the complainant expresses anger, fear and pain that were brought on by the attack. The assailant substantively confesses to the commission of the crime via instant message. February 12 -15, 2006: The assailant continues to live in a residence hall and was free to move about the campus. February 15, 2006: The assailant is arrested by DPD of?cers on a charge of rape in the second degree, a Class felony in the State of Delaware. February 16, 2006: A report prepared by Wesley?s counseling staff is sent to the College?s Dean of Students. The report notes that the incident did not appear to be a case of regret sex or in any sense a consensual sex act but rather was a violent serebased attack. William N. Johnston, Ed. 0., Praident Wesley (foliage Final Review Determination Page ii 6 Feb% 20, 2006: The alleged assailant is formally dismissed from Wesley College. On these facts, Wesley should have issued a timely warning on February 12, 2009. As of that date, Wesley?s Dean of Students or of?cials acting on his behalf were the only persons permitted to issue timely warnings. Wesley?s response to the Department asserts that, ?Wesley?s Dean of Students investigated the February 12 incident by, inter alia, speaking to the victim and the accused student.? However, our examination indicates that these interviews were conducted as part of a disciplinary proceeding. That proceeding did not begin until February 15, 2006, the same day that the assailant was arrested by the Dover Police Department. Moreover, nothing in the facts or the records presented by Wesley indicate that the College collected or evaluated any information for the express purpose of determining if it was necessary to issue a timely warning on February 12, 2006. The campus community was not noti?ed of the sexual assault that occurred on February 12, 2006 through any timely warning issued by Wesley College rather campus community members learned of the incident through reporting in the local newspaper. In response to student and employee concerns, the Dean of Students, speaking to representatives from The Whetstone, asserted that there were legal constraints on any disclosure. In published reports, the Dean of Students claimed that FERPA prohibited any release of information. The complaint and published reports noted that neither students nor staff members including those who lived and worked in the hall where the incident occurred or in the hall where the accused lived were noti?ed about the events. Several students expressed their concern in the campus newspaper, The Whetstone. The Whetstone?s managing editor wrote a commentary for the March edition, which included the following: ?Like most students and area residents, I didn?t learn about the rape until I read about it in the Dover Post. . .l ?nd it a disservice to the students, particularly the women, that the Wesley administration gave no report of the incident (by explaining the nature of the violent attack through email, voicemail, ?ier, or proclamation). . .Quite frankly, the fact that no outstanding been initiated leaves me with the distinct impression that the administration is desperate to conceal and/or dismiss the incident, rather than work to ameliorate it. . .I would personally rather be informed so that I may take the necessary precautionary steps to protect myself, since the school feels no inclination.? In a response to SOC and in its of?cial response to the Department, the College did not stress the FERPA argument but focused instead on its position that there was no ?continuing threat? posed by the perpetrator?s continued presence on campus. The College asserted that the perpetrator was subsequently banned from the campus and noted that the ban covered the retrieval of personal property, which could only be done under the supervision of the Dover Police Department. This incident did pose a clear and ongoing threat to the health and safety of the campus and therefore, a timely warning should have been issued. For these reasons, the Mlliam N. Johnston, President Wesley College Final Progrwn Review Daemu'narion - Page ii 7 Department has determined that Wesley did not act reasonably or within the discretion granted to institutions with regard to the issuance of timely warnings. Moreover, FERPA only regulates the release of educational records and information and never limits an institution?s ability to issue timely warnings. The timely warning required by the Glory Act and the Department?s regulations does not require disclosure of records and information protected by FERPA. Failure to issue timely warnings of serious and/or on-going threats deprives members of the campus community of vital, time-sensitive crime information, denies members the opportunity to take adequate steps to provide for their own safety, and effectively negates the Act?s intent. To ensure adequate corrective actions are taken before the publication of the next CSR due October 1, 2010, Wesley is required to undertake the ?Supplemental Corrective Measures? set forth in Section of this FPRD. Finding 2: Failure to Maintain Daily Crime Log in Accordance with Federal Reggietioos Citation: Institutions with a police or campus security department must maintain ?a written, easily understood daily crime log? listing all crimes that occurred: l) on campus, including residence halls; 2) in a non?campus buildings or on non-campus property; 3) on public property; or 4) within the campus police or security department?s patrol area that it becomes aware of or are reported to it. This reporting requirement applies to all crimes, not merely those crimes listed in 34 C.F.R. ?668.46 and (3). The crime log must include the nature, date, time, general location, and disposition of each reported offense. The crime log must be kept up to date and be freely accessible to any requester. 34 C.F.R. 668.46 09. Noneompliance: Wesley College failed to maintain an accurate, complete, and open daily crime log in accordance with the Department?s regulations. This ?nding is based on the Department?s examination of materials submitted in support of SOC's complaint including representations by student journalists who assert that they were denied access to the crime log. Additionally, the Department has acquired other records and published reports . that indicate that the College did not comply with the crime log requirements during the review period. These materials include an April 20, 2006 e-mail written by the Dean of Students that stated, ?the Of?ce of Safety and Security will immediately deveIOp a daily crime log reporting the date, nature, and location of the crime. This log will be made available to the public upon request. Training concerning the release of this log will be provided to William N. Johnston, 15:10., President Wesley College Final Program Review Determination - Page it 8 all officers.? The same message also stated that, ?The incident was reported in our daily log including the names of both the alleged victim and the accused. Consequently, to release that security log would have violated the victim?s con?dentiality. The format of the daily crime log, which will be implemented immediately, will enable us to release important information should there be such requests.? These messages strongly indicate that no Cler Act-compliant crime log was readily available prior to the ?ling of the complaint and supports the representation of the who requested access to the log. In its of?cial response, the College stated in part that, ?At the time of the February 12 incident, Wesley maintained a Cleryscornplaint crime log. Following the February 12 incident a student journalist asked a College Security Officer to view the log. The of?cer mistakenly, did not direct the journalist to the daily crime log. Instead, he believing he was complying with the mandates of FERPA refused the journalist access to the incident report, which contained the victim?s name. After the initial denial, the student journalist made no further request or inquiry. . .Both befom and a?er the February 12 incident, the College maintained and permitted access to its daily crime log in full compliance with the Glory Act and its regulations. Further, since the February 12 incident, the College has provided additional instruction to its security of?cers on Clery Act requirements.? Moreover, the Department has determined that it was incumbent on the College to contact the student journalist and ensure that access to the log was granted. More importantly, the numerous public statements and explanations, especially by the Dean of Students, make clear that a Glory-compliant daily crime log was not in place prior to the ?ling of the complaint that gave rise to this program review. For these reasons, the Department has determined that Wesley College was not in compliance with the open daily crime log requirement. The Glory Act is first and foremost a consumer information law intended to provide students, employees, and other stakeholders with vital information that they can use to make good safety decisions and effectively assist in providing for their own security. The crime log is especially important because it provides more timely information that supplements the long-view trend data in the statistical disclosures. Failure to comply with the daily crime log requirements deprives the campus community of this critical information and serves to negate the intent of the Act. To ensure adequate corrective actions are taken before the publication of the next CSR due October 1, 20m, Wesley is required to undertake the ?Supplemental Corrective Measures? set forth in Section of this FPRD. William N. Johanna, Etta, President Wesley College Final Program Review Determination - Page 9 Finding ti 3: Omission of Reguired Policy Statements Improper Formatting of Campus Security Reports Citation: The Clery Act and the Department?s regulations require institutions to include several policy statements in their campus security reports. These disclosures are intended to inform the campus commde about the institution?s security policies, procedures and programs and the availability of resources and channels of recourse. In general, these policies include topics such as the law enforcement authority and practices of campus police and security forces, incident reporting procedures for students and employees, and policies that govern the preparation of the report itself. Institutions are also required to disclose alcohol and drug policies and educational programs. Policies pertaining to sexual assault education, prevention, and adjudication must also be disclosed. A noti?cation to students must also be included in the report that advises the campus community that victims of sexual assaults may change their academic or living arrangements, etc. 48505 of the 34 GER. 668. 46 The Clery Act also establishes a structure for the disclosure of crime statistics that must be followed. This structure ensures that CSRs for different institutions will present the required information in a consistent format and thereby provides a mechanism for meaningful comparison. 34 CFR. 668. 46 Noncompliance: Wesley did not include certain required policy statements in its CSR's during the review period. In other cases, the published disclosures made were too vague to give actual notice to users of the report. Additionally, crime statistics and other required information ?elds were not included or were formatted improperly. One of the reviewed by the Department was entitled, ?Annual Security Information Report 2004.? However, this report contains crime statistics for calendar years 2002, 2003, and 2004. This report was submitted in reSponse to our request for the most recent CSR. Therefore, the Department has determined that this report was Wesley?s CSR that was required to be distributed on or before October 1, 2005. Speci?c required disclosures that could not be identified in Wesley?s 2005 CSR are: l) a detailed description of the College?s procedures for preparing the annual disclosure of crime statistics; 2) a statement regarding any procedures for the reporting of crimes on a voluntary and con?dential basis by professional or pastoral counselors; and, 3) a statement advising interested parties where they may obtain law enforcement information regarding registered sex offenders in accurdance with the Violent Crime Control and Law Enforcement Act of 1994. Other required statements were not adequate, including the statement of the College?s policy on the issuance of timely warnings. Although there is a brief allusion to ?securin alerts" under the heading, ?The Of?ce of Safety and Security,? the CSR contains no Milieu: N. Johnston, can, President Wesley College Final Program Review Determination - Page 1?0 detailed informatioo about the types of incidents that may trigger a warning, the decision- making process for determining if a warning is indicated, the of?cials charged with issuing warnings, or the means by which such warnings will be disseminated. Lastly, Wesley?s 2005 CSR contains no statistical ?elds for incidents or arrests occurring on non?campus property or public property as required. Additionally, the CSR provides no geographical breakdown for disciplinary referrals. The omission of these required ?elds violates the HBA and the Department?s regulations and limits the ability of users of the report to make meaning?Jl comparisons and may have resulted in the underreporting of incidents that may have occurred in the excluded geographical areas. In its response, Wesley did not speci?cally address the issue of excluded or inadequate statements of policy 0r procedure. However, the College did provide some additional information on its policies and procedures as requested. Speci?cally, Wesley submitted more detailed policies and procedures regarding: l) the preparation and distribution of the 2) requests for crime statistics from law enforcements and internal campus security authorities; 3) the issuance of timely warnings; 4) maintenance of and access to the daily crime log; and, 5) the College?s response to sexual harassment and sexual assault. These materials should be integrated into the College?s CSR to further strengthen the improved policies and procedures and formatting that were made part of subsequent Based on the facts outlined above, the Department has determined that Wesley did not comply with all of the Glory Act?s policy, procedure, and programming disclosure requirements during the review period. Accurate and complete disclosure of policies and properly formatted statistics allow members of the campus community to be fully informed and actively provide for their own safety. Any failure in this area deprives the campus community of vital information and effectively negates the intent of the Act. To ensure adequate corrective actions are taken before the publication of the next CSR due October 1, 2010, Wesley is required to undertake the ?Supplemental Corrective Measures? set forth in Section of this FPRD. E. Supplemental Corrective Measures The Department has care?illy considered the College?s response and supporting documentation. The Department also takes note of some improvements that have already been implemented by Wesley. For example, a text message noti?cation system was implemented during the 2007-2008 academic year. This system is operated by the Of?ce of Information Technology and provides another means of reaching students and employees in the event of a health or safety emergency. The review team also examined the College?s 2006 crime log, which was implemented as a corrective action following the ?ling of the SOC complaint. The format and content of the new log appears to meet the Department?s requirements. Additionally, subsequent WilliamN. Johnston. ?110., President Wesley College Fina! Program Review Dererndnarian Page ii I I that were posted to the College?s website included some eXpanded and improved policy statements. Also, the formatting of subsequent reports was improved. To ensure that all necessary corrective actions are in place, Wesley must prepare a status report that addresses ?lrther the violations and weaknesses identi?ed in this FPRD. The College must conduct a thorough review of its Clery Act compliance program focusing on the violations and weaknesses identi?ed in this FPRD, their causes, and specific actions already taken or planned for the future that will ensure that they do not recur. Wesley must appoint an institutional of?cial with suf?cient knowledge and authority to gather infermation and prepare the status report. The status report will allow the Department to better ascertain the extent of the noncompliance during the review period, ensure the adequacy of corrective actions, and provide a baseline for further monitoring. At a minimum, the College?s status report must address the follo'wing: - For Finding ii I: a re-examination of the College?s timely warning policy. Wesley must review and, if necessary, revise its policies, procedures, and methods for identifying threats to the health and safety of students and employees, composing clear messages, and distributing the messages quickly to the campus community. The new policy must be published in the CSR due by October 1, 2010. Additionally, the College must review its internal operating procedure for timely warnings and ensure that it is workable, adequately supported in terms of staffing and technology, is suf?ciently detailed, and that essential staff is properly training on executing the timely warning and emergency noti?cation plans. 0 For Finding 2: a re-examination of the College?s daily crime log policies and procedures. Wesley must review and, if necessary, revise its policies and procedures regarding the maintenance of an accurate and complete daily crime log. Also, Wesley must provide adequate training to all security personnel to ensure that they are aware of the log?s existence, location, and purpose, understand its contents, and know to provide immediate access to all requestors. I For Finding 3: a comprehensive review of all policy, procedural, and programmatic disclosures required to be published in the CSR. The College must then take all necessary action to update and improve this information to ensure that each disclosure prevides clear and accurate notice to students and employees about each covered topic. Wesley also must appoint a person or group to re-evaluate the accuracy and completeness of the CSR and ensure that its contents are kept current with all Clery Act provisions including those required by the recently enacted Higher Education Opportunity Act, 10?3 15 and the Department?s implementing regulations. William N. Johnston. Eda, President Wariqr College Final Program Review Determination Page ii 12 Lastly, the status report must address how the College with bring all caran security Operations into compliance with the Federal Educational Records Privacy Act (FERPA). On several occasions, the review team identi?ed instances wherein Wesley incorrectly applied the FERPA standards. For example, the Dean of Students cited FERPA concerns as the reason why pertinent information was not provided to the campus community. Please provide copies of any documents or records referred to in your status report that were not already provided to the Department. Please submit your status report within 60 days of the date of this FPRD to: Mr. James L. Moore, Senior Institutional Review Specialist US. Department of Education The Wanamaker Building 100 Penn Square East, Suite 511 Philadelphia, PA 19107 Once the status report is submitted and accepted by the Department, the program review will be closed. However, the College is reminded that corrective actions, whether already enacted or proposed for the throne, do not diminish the seriousness of the violations identi?ed during the program review. This program review was conducted to monitor and enforce the Ciery Act and to assist Wesley toward ?ill compliance. The review team will continue to provide technical assistance and recommendations to institutional o?ieials upon request. Technical assistance and recommendations are intended to facilitate ongoing improvement and are Only advisory. Program records relating to the period covered by this program review must be retained until the later of: resolution of the violations, weakness, and other issues identi?ed during the program review or the end of the retention period applicable to Title IV?related records under 34 CPR. 668.24 and Thank you for your cooperation and patience throughout the program review process. Please direct any questions about this PRD to Mr. James L. Moore, on (215) 656-6495.