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Cozen O'Connor Report FAQ
Frequently Asked Questions
In March 2022, the CSU Board of Trustees, in response to troubling reports of sexual harassment and other misconduct, commissioned the Institutional Response Group of the Cozen O’Connor law firm to conduct a comprehensive, systemwide independent assessment of the CSU’s implementation of Title IX and other anti-discrimination programs.
The assessment, the largest and most comprehensive review of its kind, included visits to all 23 CSU campuses and the Chancellor’s Office and feedback from more than 18,000 students, staff, and faculty. Its goal was to strengthen the culture in the workplace and the classroom so that it is better aligned with the CSU’s core values. The assessment considered current practices and provided insights, recommendations and resources to advance the CSU's Title IX and DHR training, awareness, prevention, intervention, compliance and support systems, as well as campus culture and climate.
On July 17, 2023, the Cozen group made public its report, which includes individual reports for each of the 23 campuses, including Sacramento State.
Title IX is a federal law that requires educational institutions receiving funds to address discrimination and harassment based on sex. This law factors into Sacramento State’s policies on investigating and providing resources for anyone who has experienced sexual exploitation, sexual misconduct (including sexual battery and rape), dating or domestic violence, and stalking.
DHR stands for discrimination, harassment and retaliation.
Cozen O’Connor visited campus from Oct. 11-13, 2022, and held follow-up meetings on Zoom. The Cozen group conducted 21 meetings with 37 administrators and other key University partners, some of whom they spoke with multiple times. They also sought feedback from students, staff, and faculty in-person, through a systemwide online survey, via email, and during individual meetings on Zoom.
The Cozen group’s core findings and recommendations include:
- The Office for Equal Opportunity (OEO) is under-resourced to serve the needs of the University. Because of this, OEO has not been able to plan and engage in as much community outreach, or as many prevention and education programs as needed and as occurred prior to the COVID-19 pandemic.
- Some segments of the campus community, especially students, have a lack of fundamental understanding of what OEO is, what it does, services and resources it offers, and where it is on campus. The Cozen group recommends the University take steps to increase community awareness and visibility of OEO.
- Some campus partners expressed confusion or concern about how OEO evaluates whether a case constitutes a potential Nondiscrimination Policy violation. The Cozen group also noted that OEO does not always formally separate its intake/outreach functions from its investigative function, which may contribute to an underdeveloped process for initial assessment. They recommend, among other steps, the University create a formal multidisciplinary team that meets regularly to discuss all reports related to Title IX and DHR.
- Given staffing and resource challenges, the University’s approach to prevention and education is ad hoc, rather than strategic, and prevention and education programming is minimal. The Cozen group recommends the University build a formal prevention and education program, including a dedicated prevention coordinator and a campus Prevention and Education Oversight Committee.
- The University has inconsistent documentation and record-keeping practices. Because of these inconsistencies, information is not always maintained centrally and cannot always be easily accessed by OEO or other departments. The Cozen group recommends that the University develop protocols for consistent collection and retention of data that can be easily shared, tracked, and queried.
- The Cozen group learned about significant issues, including recent bias incidents, on campus that have not been sufficiently addressed through existing processes, as well as confusion and lack of clarity between OEO and other campus partners responsible for responding to such behaviors. Though noting Sac State has already taken proactive steps to address such “other conduct of concern,” the group recommends the University work with the Chancellor’s Office and CSU Office of General Counsel to develop a formal process to address reports of conduct that are not reported to have been on the basis of protected status or that do not rise to the policy thresholds for discrimination or harassment.
Sacramento State respects the CSU’s transparency and recommendations to improve each campuses’ response to allegations of Title IX violations. The safety of the Sacramento State campus community remains our top priority. The University works to prevent harm, to respond promptly and effectively to reports of violations, and to take appropriate actions.
As a campus, we will study the entire Cozen report and, through the established Campus Title IX Implementation team, systematically and comprehensively implement the recommendations, following the charge given by the CSU Chancellor’s Office.
As an anchor university, building trust with our campus community will always remain a priority. Sacramento State is a safe campus, where everyone belongs. It will continue to take seriously and work with integrity to increase our community’s confidence in us to prevent and address sexual violence and sexual harassment.
Sac State has taken several important steps to strengthen its response to reports of Title IX violations (sexual harassment, sexual misconduct, sexual exploitation, dating and domestic violence, and stalking) and DHR (discrimination, harassment, and retaliation) since the Cozen group visit:
- Developed a Sexual Violence Prevention, Safety and Support Action Plan that is publicly displayed and updated on our website.
- Hired a second campus confidential advocate, additional Office of Equal Opportunity (OEO) investigator, an OEO administrative support coordinator, and two student outreach interns to promote the University’s Sexual Violence and Sexual Harassment educational campaign.
- Established a Campus Title IX Assessment Implementation Team to support the implementation of the recommendations in anticipation of the report released on July 17.
- Various campus departments/offices have increased their education and prevention programming efforts, including but not limited to new/updated prevention campaigns (C.L.E.A.R. Consent, Red Zone), educational videos, in-person and virtual sexual violence awareness trainings, campuswide sexual violence prevention symposiums, and others.
- Increased general and targeted training to the entire campus community that includes information on how to report and why reporting promotes the University’s commitment to creating a safe and healthy environment for all campus community members.
Sac State offers extensive prevention and education programming around sexual harassment/sexual misconduct. We recognize that filing a report takes emotional labor and we will continue to approach and handle reports with compassion and care.
- Offering targeted training for Associated Student Inc., University Housing, Athletics, executive leadership and managers, and mandatory online staff/supervisor training, prevention seminars, workshops, and tabling.
- Hosting a multitude of programming throughout Sexual Awareness Action Month (SAAM) each April.
- Collaborating with various campus programs and services and offering prevention programming each month of the 2023-24 academic year.
Implementation of the Cozen recommendations is an ongoing process, and implementing some recommendations will take two to three years.