UNIVERSITY SYSTEM of MARYLAND 10630 LITTLE PATUXENT PARKWAY, SUITE 450 COLUMBIA. MD 21044 OFFICE OF INTERNAL AUDIT Dr. Freeman A. Hrabowski, President University of Maryland, Baltimore County 1000 Hilltop Circle Baltimore, Maryland 21250 November 21, 2017 Dear Dr. Hrabowski: We have completed our compliance audit of crime statistics reported by the University of Maryland, Baltimore County (UMBC) Police Department. Our objectives were to determine whether crime statistics are documented in a complete, accurate and timely manner. We also determined whether crime statistics and safety information were made available to constituents as required by the Jeanne Clery Disclosure of Campus Security Policy and Campus Crime Statistics Act (Clery Act). We conducted our examination in accordance International Standards for the Professional Practice of Internal Auditing. As such, we interviewed personnel, reviewed records and information, observed processes, and performed such tests deemed necessary. In our opinion, and except for the area identified in our report, UMBC complied with tested attributes of Clery Act reporting requirements. Our comments and recommendations are attached. In accordance with University System of Maryland policy, please respond to our report by January 8, 2017. Your response should address our comments and recommendations, either giving enough information for Internal Audit to evaluate your planned corrective action relative to our recommendation, or providing support for a solution other than the one recommended in the audit report. Please include time frames for the proposed actions. We thank your office, as well as, UMBC Police Department for their cooperation and assistance during our assessment. Please contact us if you have any questions. Sincerely, David Mosca, CPA Director, Internal Audit cc: Dr. Robert L. Caret Mr. Ben Lowenthal Mr. Joseph Vivona Ms. Sharon Doherty-Ritter Ms. Lynne Schaefer Deputy Chief Paul Dillon Chief Mark Sparks INSTITUTIONS BOWIE STATE UNIVERSITY COPPIN STATE UNIVERSITY STATE UNIVERSITY SALISBURY UNIVERSITY TOWSON UNIVERSITY UNIVERSITY OF BALTIMORE UNIVERSITY OF MARYLAND. BALTIMORE UNIVERSITY OF MARYLAND. BALTIMORE COUNTY UNIVERSITY OF MARYLAND. COLLEGE PARK UNIVERSITY OF MARYLAND EASTERN SHORE UNIVERSITY OF MARYLAND UNIVERSITY COLLEGE UNIVERSITY OF MARYLAND CENTER FOR ENVIRONMENTAL SCIENCE REGIONAL CENTERS UNIVERSITIES AT SHADY GROVE UNIVERSITY SYSTEM OF MARYLAND AT HAGERSTOWN UNIVERSITY SYSTEM OF MARYLAND Maintaining Audit Report Confidentiality An audit report is usually addressed to the President (or designee) of the institution. Copies of the ?nal audit report are also sent to appropriate administrators, including the Chancellor, the Vice President for Business and Finance, and the department head. Because all internal audit reports are con?dential, they must be protected and distributed only on a ?need to know? basis. External auditors who are performing an authorized audit may obtain internal audit reports by contacting the Director of Internal Audit. Reports may eventually become public under the Maryland Public Information Act, but should not be released until clearance has been received through the Internal Audit Of?ce. University of Maryland, Baltimore County (UMBC) Jeanne Clery Act Compliance November 2017 AUDIT CONCLUSIONS TABLE OF CONTENTS Audit Areas Reasonable to Strong Controls in Place Opportunity for Improvement Page EXECUTIVE SUMMARY BACKGROUND OBJECTIVE, SCOPE AND OPINION AREAS FOR INIPROVEMENT: PROCED Adequate crime reporting and crime log procedures are in place. Timely warnings are disseminated. Policies and procedures are in place regarding the compilation of crime statistic information. TEST OFSTATISTICS: Statistics are accurately and completely reported in the Annual Security Report and to the Department of Education. (Finding A B) 4&5 Crimes are properly classi?ed in the reported statistics. Statistics are reported to the Department of Education. Crime Log is Complete and Accurate. Annual Security Report is provided to constituents annually by October 1 in accordance with requirements set forth in the Handbook. Supporting documentation is maintained. POLICYSTA TEMENTS: The required statements are included in the Annual Security Report. The required ?re safety information is disclosed in an annual safety report. University of Maryland, Baltimore County (UMBC) Jeanne Clery Act Compliance November 2017 EXECUTIVE SUMMARY SUMMARY OF COMMENTS AND RECOMMENDATIONS A. From 2013 to 2015, statistics reported to the Department of Education (DOE) and in the University of Maryland, Baltimore County?s (UMBC) Annual Security Report (ASR) did not agree in various crime offenses each year. UMBC Police Department has made the updates for the 2016 ASR issued in October 2017 and the DOE records for 2015. UMBC Police Department should review the crime statistics entered into the DOE website before the of?cial submission and review Clery guidance for any updates on an annual basis. B. Crime statistics reported in ASR and its supporting of documents crime logs and reports) did not agree in the offenses of fondling and drug abuse Violations for the years of 2013 and 2014. UMBC Police department has made the prOper updates for the 2016 ASR issued in October 2017 and no additional issues were identi?ed subsequent to 2014. II. University of Maryland, Baltimore County (UMBC) Jeanne Clery Act Compliance November 2017 BACKGROUND University of Maryland, Baltimore County (UMBC) is a regionally accredited four-year comprehensive institution offering distinct graduate and undergraduate programs. Located in Baltimore County, the student enrollment for the fall semester of 2016 was 13,640, with approximately 795 total faculty members. UMBC Police Department is a full-service law enforcement agency that provides a full range of police and security services to the University community. The mission of the UMBC Police Department is to provide a safe and secure environment, that enhances the quality of life for the university community. UMBC Police department investigates crimes as well as incidents that may impact campus safety to seek solutions to raise a sense of security. To fulfill this mission, the department provides a quality work environment and personnel development of the members through effective training and leadership. The UMBC Police Department is also responsible for the reporting of the Jeanne Clery Disclosure of Campus Security Policy and Campus Crime Statistics Act (Clery Act). This federal law requires US. colleges and universities to disclose information about crime on and around their campuses. Because the law is tied to participation in federal student ?nancial aid programs, it applies to most institutions of higher education both public and private. Violators can be ?fined? up to $54,789 per infraction by the Department of Education. The Clery Act requires institutions to publish an annual security report every year by October 1St that contains three years of campus crime statistics and certain security policy statements on basic victim?s rights. The report is to be made available automatically to all current students and employees, While prospective students and employees are to be noti?ed of its existence and afforded an Opportunity to request a copy. Statistics must also be reported to the Department of Education. OBJECTIVE, SCOPE AND OPINION Our objectives were to determine whether crime statistics are documented in a complete, accurate and timely manner. We also determined whether crime statistics and safety information were made available to constituents as required by the Jeanne Clery Disclosure of Campus Security Policy and Campus Crime Statistics Act (Clery Act). Clery Act requirements were audited to determine whether: 0 Security policies are deveIOped and disclosed to required constituents; 0 Statistics on criminal activity are compiled and provided to constituents as required by Clery guidelines; 0 Crime statistics are provided to the Department of Education; ?1 0 Reported crimes include campus and local law enforcement statistical information; Timely warning processes are in place to alert the campus community about crimes that pose a serious or continuing threat. 0 2013 Violence Against Women Act (VAWA) reporting requirements are addressed, including additional policy statements and added crime categories for dating violence, domestic Violence, and stalking. The scepe of our audit included crime statistics for calendar years 2013, 2014, 2015 and 2016. In our opinion, and except for the area identi?ed in our report, UMBC generally complied with tested attributes of Clery Act reporting requirements. AREAS FOR IMPROVEMENT A. Ensure Annual Security Report Statistics Agree to the Department of Education?s Published Statistics Comment: In thirteen instances, statistics reported to the Department of Education (DOE) did not agree to statistics reported in the UMBC Annual Security Report (ASR). Discrepancies were noted in the following categories: a 2013: Forcible sex offenses, Rape, and Hate Crimes. 2014: Fondling, Burglary, Dating Violence, Stalking, Drug Abuse Violations, Liquor Law Violations, and Unfounded Crimes. 2015: Dating Violence, Drug Abuse Violations and Fire. The differences were caused by not identifying a new Clery crime reporting category, and absence of secondary review prior to submitting ?nal data to DOE. Based on the Clery Handbook, crime statistics from the Annual Security Report are required to be submitted to the DOE on an annual basis. Students, faculty and the public using the DOE website may be Viewing inaccurate information. Action Taken: In October 2017, UMBC Police Department updated the DOB and 2017 ASR to report the correct crimes for 2015 and 2014. Recommendation: UMBC Police Department should establish a secondary review of the crime statistics entered into the DOE website before the of?cial submission and review Clery guidance publications for any updates on an annual basis. B. Ensure ASR Statistics Agree to Supporting Documentation Comment: UMBC Police Department should ensure ASR statistics agree to supporting documentation used to compile those statistics. There were ?ve instances where the statistics were not accurately reported according to supporting documentation from the crime log and reports. Crime Location eraFi .. Drug Abuse On 2013 Violations Campus Arrests Drug Abuse Student 2013 28 32 Violations - Housing Arrests Facilities Fondling Student 2014 3 4 Housing Drug Abuse On 2014 5 4 Violations - Campus Arrests Drug Abuse Student 2014 4 3 Vioiations Housing Arrests Facilities The differences were caused by clerical errors when entering the data into the ASR. Students, faculty and the public using the ARS report may be viewing inaccurate information. Action Taken: In October 2017, UMBC Police Department updated the DOE and ASR records to report the correct crimes for 2015 and 2014. In addition, there were no discrepancies noted for 2015 and 2016 because the Police Department improved procedures and ensured data collected from supporting documentation were correctly input into ASR. University of Maryland, Baltimore County (UMBC) Jeanne Clery Act Compliance November 2017 Audit Team Patricia R. Vaz Internal Auditor Maureen Higgins, MS, CPA Internal Audit Manager Office of the President University of Maryland, Baltimore County 1000 Hilltop Circle Baltimore, MD 2125 WEB: www.umbc.edu January 5, 2018 Mr. David Mosca, CPA Director, Internal Audit University System of Maryland Office of Internal Audit 10630 Little Patuxent Parkway, Suite 450 Columbia, MD 21044 RE: USM UMBC Campus Crime Statistics (Clery Act) Audit, UMBC Police Department UMBC Response Dear Dave: Thank you for your report dated November 21st, 2017 resulting from the review of the crime statistics reported by the University of Maryland, Baltimore County (UMBC) Police Department for calendar years 2013, 2014, 2015 and 2016. I understand that there was one (1) area (accuracy of statistical reporting) out of eleven (11) in which there was opportunity for improvement, that resulted in two (2) findings. Enclosed please find our response outlining our corrective action plan for these findings. If you have any questions or need additional information, please contact Sharon Doherty-Ritter, Director in our Management Advisory Services Department, at 410-455-1620. Again, we thank you for your continued support. Sincerely, Freeman A. Hrabowski, III President cc: Robert L. Caret Joseph F. Vivona Lynne C. Schaefer Terry Cook Sharon D. Doherty-Ritter Chief Mark Sparks Deputy Chief Paul Dillon University of Maryland, Baltimore County (UMBC) Jeanne Clery Act Compliance November 2017 ________ Audit Areas Reasonable to Strong Controls in Place Opportunity for Improvement EXECUTIVE SUMMARY Page 2 BACKGROUND 3 OBJECTIVE, SCOPE AND OPINION 3 AREAS FOR IMPROVEMENT: PROCEDURES: Adequate crime reporting and crime log procedures are in place. Timely warnings are disseminated. Policies and procedures are in place regarding the compilation of crime statistic information. TEST OF STATISTICS: Statistics are accurately and completely reported in the Annual Security Report and to the Department of Education. (Finding A & B) Crimes are properly classified in the reported statistics. Statistics are reported to the Department of Education. Crime Log is Complete and Accurate. Annual Security Report is provided to constituents annually by October 1 in accordance with requirements set forth in the Handbook. Supporting documentation is maintained. POLICY STATEMENTS: The required statements are included in the Annual Security Report. The required fire safety information is disclosed in an annual safety report. 1 P P P P P P P P P P P 4&5 University of Maryland, Baltimore County (UMBC) Jeanne Clery Act Compliance November 2017 ________ EXECUTIVE SUMMARY SUMMARY OF COMMENTS AND RECOMMENDATIONS A. From 2013 to 2015, statistics reported to the Department of Education (DOE) and in the University of Maryland, Baltimore County’s (UMBC) Annual Security Report (ASR) did not agree in various crime offenses each year. UMBC Police Department has made the updates for the 2016 ASR issued in October 2017 and the DOE records for 2015. UMBC Police Department should review the crime statistics entered into the DOE website before the official submission and review Clery guidance for any updates on an annual basis. B. Crime statistics reported in UMBC’s ASR and its supporting of documents (i.e., crime logs and reports) did not agree in the offenses of fondling and drug abuse violations for the years of 2013 and 2014. UMBC Police department has made the proper updates for the 2016 ASR issued in October 2017 and no additional issues were identified subsequent to 2014. 2 University of Maryland, Baltimore County (UMBC) Jeanne Clery Act Compliance November 2017 ________ I. BACKGROUND University of Maryland, Baltimore County (UMBC) is a regionally accredited four-year comprehensive institution offering distinct graduate and undergraduate programs. Located in Baltimore County, the student enrollment for the fall semester of 2016 was 13,640, with approximately 795 total faculty members. UMBC Police Department is a full-service law enforcement agency that provides a full range of police and security services to the University community. The mission of the UMBC Police Department is to provide a safe and secure environment, that enhances the quality of life for the university community. UMBC Police department investigates crimes as well as incidents that may impact campus safety to seek solutions to raise a sense of security. To fulfill this mission, the department provides a quality work environment and personnel development of the members through effective training and leadership. The UMBC Police Department is also responsible for the reporting of the Jeanne Clery Disclosure of Campus Security Policy and Campus Crime Statistics Act (Clery Act). This federal law requires U.S. colleges and universities to disclose information about crime on and around their campuses. Because the law is tied to participation in federal student financial aid programs, it applies to most institutions of higher education both public and private. Violators can be “fined” up to $54,789 per infraction by the Department of Education. The Clery Act requires institutions to publish an annual security report every year by October 1st that contains three years of campus crime statistics and certain security policy statements on basic victim’s rights. The report is to be made available automatically to all current students and employees, while prospective students and employees are to be notified of its existence and afforded an opportunity to request a copy. Statistics must also be reported to the Department of Education. II. OBJECTIVE, SCOPE AND OPINION Our objectives were to determine whether crime statistics are documented in a complete, accurate and timely manner. We also determined whether crime statistics and safety information were made available to constituents as required by the Jeanne Clery Disclosure of Campus Security Policy and Campus Crime Statistics Act (Clery Act). Clery Act requirements were audited to determine whether: • • • Security policies are developed and disclosed to required constituents; Statistics on criminal activity are compiled and provided to constituents as required by Clery guidelines; Crime statistics are provided to the Department of Education; 3 • • • Reported crimes include campus and local law enforcement statistical information; Timely warning processes are in place to alert the campus community about crimes that pose a serious or continuing threat. 2013 Violence Against Women Act (VAWA) reporting requirements are addressed, including additional policy statements and added crime categories for dating violence, domestic violence, and stalking. The scope of our audit included crime statistics for calendar years 2013, 2014, 2015 and 2016. In our opinion, and except for the area identified in our report, UMBC generally complied with tested attributes of Clery Act reporting requirements. III. AREAS FOR IMPROVEMENT A. Ensure Annual Security Report Statistics Agree to the Department of Education’s Published Statistics Comment: In thirteen instances, statistics reported to the Department of Education (DOE) did not agree to statistics reported in the UMBC Annual Security Report (ASR). Discrepancies were noted in the following categories: • • • 2013: Forcible sex offenses, Rape, and Hate Crimes. 2014: Fondling, Burglary, Dating Violence, Stalking, Drug Abuse Violations, Liquor Law Violations, and Unfounded Crimes. 2015: Dating Violence, Drug Abuse Violations and Fire. The differences were caused by not identifying a new Clery crime reporting category, and absence of secondary review prior to submitting final data to DOE. Based on the Clery Handbook, crime statistics from the Annual Security Report are required to be submitted to the DOE on an annual basis. Students, faculty and the public using the DOE website may be viewing inaccurate information. Action Taken: In October 2017, UMBC Police Department updated the DOE and 2017 ASR to report the correct crimes for 2015 and 2014. Recommendation: UMBC Police Department should establish a secondary review of the crime statistics entered into the DOE website before the official submission and review Clery guidance publications for any updates on an annual basis. UMBC RESPONSE: We agree with the recommendation. The UMBC Police Department will establish a secondary review of crime statistics entered into the DOE website, before the official submission beginning with the next required submission. Additionally, we will review Clery guidance publications for any updates on an annual basis. 4 University of Maryland, Baltimore County (UMBC) Jeanne Clery Act Compliance November 2017 ________ B. Ensure ASR Statistics Agree to Supporting Documentation Comment: UMBC Police Department should ensure ASR statistics agree to supporting documentation used to compile those statistics. There were five instances where the statistics were not accurately reported according to supporting documentation from the crime log and reports. Crime Location Year Drug Abuse Violations Arrests Drug Abuse Violations Arrests Fondling On Campus Drug Abuse Violations Arrests Drug Abuse Violations Arrests 2013 Annual Security Report Total 40 Total Supported by UMBC Documentation 41 Student Housing Facilities Student Housing Facilities On Campus 2013 28 32 2014 3 4 2014 5 4 Student Housing Facilities 2014 4 3 The differences were caused by clerical errors when entering the data into the ASR. Students, faculty and the public using the ARS report may be viewing inaccurate information. Action Taken: In October 2017, UMBC Police Department updated the DOE and ASR records to report the correct crimes for 2015 and 2014. In addition, there were no discrepancies noted for 2015 and 2016 because the Police Department improved procedures and ensured data collected from supporting documentation were correctly input into ASR. UMBC RESPONSE: The UMBC Police Department will continue reporting crime data using the improved procedures. 5