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Cozen O'Connor Assessments

As part of a California State University effort to improve Title IX/DHR processes, the Cozen O’Connor Institutional Response Group assessed how the CSU and its 23 campuses respond to reports and incidents of discrimination and harassment—which includes all conduct that falls under Title IX.

Cozen O’Connor compiled its findings in a report, which identifies core observations for improvements both at the system level, and those applicable to each of the 23 CSU campuses.

Background

In March 2022 the CSU Board of Trustees commissioned the Cozen O’Connor law firm to conduct a comprehensive systemwide assessment of the CSU’s implementation of its Title IX and discrimination, harassment and retaliation (DHR) programs following concerning reports of sexual harassment and other misconduct.

The assessment — which included visits at all 23 CSU campuses and the Chancellor’s Office and feedback from more than 18,000 students, staff and faculty — aims to strengthen the CSU’s institutional culture by examining current practices and providing insights, recommendations and resources to advance Title IX and DHR training, awareness, prevention, intervention, compliance and support systems, as well as addressing campus culture and climate.

Systemwide Recommendations

Cozen O’Connor provided a systemwide report, with a list of detailed recommendations for systemwide oversight of Title IX at the 23 CSU campuses — including Cal Poly. The report’s systemwide recommendations include:

  • Enhanced and expanded oversight by the Chancellor’s Office;
  • Better tracking of data;
  • Written policies on reporting conduct of concern not rising to the level of discrimination or a policy violation; and
  • Additional training, support and resources for more meaningful education and prevention.

Cal Poly Recommendations

Cozen O’Connor’s Cal Poly-specific campus report offers many detailed recommendations for enhancing Title IX programming at Cal Poly, many of which tie directly to the broader, systemwide recommendations. Cal Poly will work closely with the Chancellor’s Office and other campuses to implement these recommendations.

In the areas of Infrastructure and Resources and Internal Protocols, the report notes that Cal Poly’s current Title IX programming is strong — among the most robustly staffed in the CSU system. The campus’s investment allows Civil Rights and Compliance Office (CRCO) staff to have high fluency in Title IX and produce very accurate reports.

The report notes the need to strike a balance between showing care of individual campus community members and working to ensure compliance with the Title IX law. Cal Poly has recognized the value of expanding its care programming and has already hired a “care manager” within CRCO.

The office will now take steps toward adding further resources to enhance the intake, support, and training functions to round out CRCO’s services and help promote CRCO as more than an investigative and adjudicatory resource. Recommendations include:

  • Determining the possibility for adding additional Title IX staff;
  • Taking part in the CSU’s effort to implement a case- and document-management system across the 23 campuses; and
  • Building a stronger partnership between Cal Poly’s CRCO/Title IX program and Safer, the university’s confidential advocacy resource.

Related to Communications, the report makes several recommendations, including increasing frequency of campuswide communications; improving website content and annual reports; and undertaking a marketing campaign aimed at raising awareness.

In Prevention, Education, Training and Awareness, the report recommends several steps — in close consultation with the Chancellor’s Office — toward aligning, evaluating and improving upon the university’s existing programming, including assigning one individual to oversee all campus prevention and education planning, and developing a university wide, cross-disciplinary Prevention and Education Oversight Committee.

The report also encourages the system to examine ways to better address Responding to Other Conduct of Concern — conduct that does not rise to the level of violating the Nondiscrimination Policy. This could include unprofessional or abusive conduct, microaggressions, acts of intolerance, and other disruptive behavior. The Chancellor’s Office will lead this work, and Cal Poly will work closely with its colleagues there to determine how to implement that work on campus.

Implementation Team

This work will require a collective, accountable and decisive response, one that acknowledges our history yet points to a future where our institutional culture is forever changed.

Cal Poly has assembled an implementation team comprised of faculty, staff and administrators to immediately advance progress. The team is a broad cross-section of campus stakeholders who are responsible for recommending how to implement Cozen O'Connor's suggestions. Additionally, the team is charged with developing a communications plan designed to keep the campus community apprised about the implementation process and status.

The team includes:

  • Maren Hufton, Title IX Coordinator, DHR Administrator and Clery Director (co-chair)
  • Jen Haft, Chief of Staff (co-chair)
  • Elizabeth Adan, Chair, Women's, Gender and Queer Studies Department and Professor, Interdisciplinary Studies Liberal Arts (ISLA) Department
  • Sam Andrews, ASI President
  • Rachel Fernflores, Professor Philosophy Department
  • Debi Hill, Associate Vice President of Student Affairs
  • George Hughes, Assistant Vice President, Public Safety and Chief of Police
  • Al Liddicoat Vice President, University Personnel and Chief Human Resources Officer
  • Matt Lazier, Assistant Vice President for Communications and Media Relations
  • Joy Pedersen, Assistant Vice President for Student Affairs & Dean of Students
  • Kara Samaniego, Assistant Director of Wellbeing

What we've done

  • January 2023 - Cozen O'Connor's site visit to Cal Poly.
  • April 2023 - Cal Poly's Cozen O'Connor Implementation Team identified.
  • April/May 2023 - Chancellor's Office staff and Cozen O'Connor staff meeting with campus Implementation Team to detail core findings and observations. These meetings provided extensive orientation to the assessment and set the stage for campus.
  • July 2023 - CSU Title IX Discrimination Harassment Assessment report released by Cozen.
  • October 2023 - Kickoff Meeting with Implementation Team Members.

Next steps

  • Submit a developed communications plan to the Chancellor's Office with the goal of keeping campus apprised of the implementation plan details and process.
  • Implement the use of a shared case management system, Maxient.
  • Develop an implementation plan.

Resources and Links

CSU Cozen O’Connor Website
Communications and updates, more information on the Title IX/DHR Assessment and the 2023 California State Auditor Report.

Communications & Sponsor Plan for Campus Implementation Teams

Take a closer look at the comprehensive timeline and key milestones of our campus initiatives. Click the button below to review detailed plans, progress updates, and feedback.

Communications & Sponsor Plan for Campus Implementation Teams

# Date(s) / Key Milestones Medium / Modality Audience Key Messages Preparer Sender Feedback received/Action Items Status
EX September 8 and 11, 2023 Live Workshop (via Zoom); same content delivered each date All Campus Implementation Team Chairs
  • Share overview of initiative including key dates and activities
  • Share templates including sample project schedule and communications plan
  • Next Steps (e.g. next meeting, action items)
  • Q&A
 CO Team (McCarthy, Anson, Pursley, Clegg, Jones) CO Team (Clegg) Send a copy of the presentation to all Implementation Team Chairs; Open to feedback via email or in follow-up meetings or consults Delivered 9/7/23
9/25/23 Meeting Cabinet
  • Shared iTeam Charge and Expectations
 Al Liddicoat Al Liddicoat Cabinet is onboard and requested regular updates throughout the process and implementation. Complete
10/2/23 Meeting Cal Poly iTeam Members
  • Review committee charge and Cozen O'Connor Report recommendations
  • Discuss timeline and deliverables. First major deliverable is to complete the Communications Plan Template.
 Co-Chairs (Hufton, Haft) iTeam co-chairs Walked through presentation and opened for Q&A. Charged team with completing initial draft of comms plan template. Will come back as a team to review and define final plan. Complete
10/6/23 Meeting Cal Poly iTeam Members, CO Liaison and Cozen O'Connor Staff
  • Cozen O'Connor provided background and update on process
  • Group participate in discussion about the report and iTeam charge
  • Cozeon O'Connor reviewed next steps with input from the CO regarding the communications plan
 Alex Pursley (CO Liaison) J. Haft Team engaged in conversation. Complete
10/2/23 Website Campus, Community and Website Guests
  • Develop a website (utilize CP Humboldt as example)
  • Provide process and charge of iTeam
  • Provide list of iTeam members
  • Provide status and progress updates
  • Archive key documents and communications
  • Provide transparency and loop for community feedback
 J. Haft and J. Hoffman J. Haft Group was in agreement, will send request to the developer; will bring back draft page for the iTeam to review/comment In process
10/19/202 Meeting Cal Poly iTeam Members
  • Discuss and review communications plan for submission to the CO
  • Review draft website and provide updated content for publication
  • Discuss and review next steps
 Co-Chairs (Hufton, Haft) J. Haft In process
10/25/23 MustMail Campus wide email
  • Introduction iTeam
  • Share overview of initiatives including key dates and website development (public data will be shared)
 J. Haft and M. Lazier OOP Send advanced copy of note to iTeam for review In process
10/25/23 Email Alias Campus and Community
  • Develop and provide email alias (campus feedback/input throughout the process - Include in all campus messages)
 J. Haft J. Haft Complete
11/1/23 CRCO Brand Kit Development (Rebranding of CRCO) Maren Hufton - Introduction to external marketing firm to help with this.
Spring 2024 Campus Email All campus
  • Provide a year in review of the work already being done in the realm of violence prevention, advocacy, compliance, and university response/annual report
 iTeam iTeam co-chairs
Campus Focus Groups Various student, faculty, and staff organizations (ASI, IHC, SHAC, Cultural Clubs, Clubs and Orgs Leaders, Greek Life Councils, Athletics)
  • Present the campus plan
  • Collect feedback on proposed implementation plan
  • Provide food
  • Evaluate feedback and make necessary adjustments to the Implementation Plan
 iTeam iTeam Representatives Identify location, date, time
Early December Campus Forum Students, Faculty, Staff
  • Present the campus plan
  • Collect feedback
  • Provide food
  • Evaluate feedback and make necessary adjustments to the Implementation Plan
 iTeam iTeam co-chairs
Pending ASI Availability Board meeting ASI Board of Directors
  • Share highlights of the report
 iTeam iTeam Representative(s)
Start of academic quarters (Winter/Spring) Campus Email Faculty/Staff Students
  • Reminder about campus resources (employees and students)
  • Notification of important dates and events
 CARE, CRCO and Safer, Ombuds Student Affairs Academic Affairs
Workshop Employees Employee continuing education workshops by Safer - https://safer.calpoly.edu/faculty-training; invitations to monthly newsletter Safer Safer
As needed Mustang Monday Social Media Students
  • Provide status updates on the work completed to date
  • Provide next steps
 iTeam Student Affairs VP Student Affairs
As needed Parent and Family Newsletter Parents
  • Provide status updates on the work completed to date
  • Provide next steps
 iTeam Student Affairs VP Student Affairs
Meeting/listening session (likely via Zoom), also possibly survey or similar anonymized input mechanism Instructional Department Heads and Chairs - typical meetings via Zoom Solicit input from department heads and chairs campuswide about what infrastructure/resources they need and what kinds and/or frequency of communications needed iTeam Faculty Supporters - Elizabeth Adan and Rachel Fernflores
Workshop and/or website Faculty, but also need to consider staff Importance of and how to draft syllabus statements and other course messaging for students on faculty roles as Title IX mandated reporters and/or related to DHR (CTLT may be able to assist here) Title IX/DHR Student Affairs Academic Affairs Student Affairs Academic Affairs
In person or Zoom/phone interview with Mustang News Campus community Proactive outreach - Review of recommendations, implementation plan development process, feedback loop, Implementation plan Matt Lazier Matt Lazier
Campus Email All campus Provide a year in review of the work already being done in the realm of violence prevention, advocacy, compliance and university response/ annual report iTeam
Winter/Spring Briefings Cabinet Provide quarterly briefings to cabinet Co-Chairs (Hufton, Haft)
Quarterly Briefing President's Leadership Council
  • Summarize the work of the Implementation Team - Communications plan
  • Provide overview of the report outcomes and work toward an implementation plan
  • The Implementation Plan will be shared with the campus community in January 2024.
  • List upcoming related programs and available resources - link to website
Quarterly Briefing Department Chairs
  • Summarize the work of the Implementation Team - Communications plan
  • Provide overview of the report outcomes and work toward an implementation plan
  • The Implementation Plan will be shared with the campus community in January 2024.
  • List upcoming related programs and available resources - link to website
December Email Campus community
  • Summarize the work of the Implementation Team - Communications plan
  • Provide overview of the report outcomes and work toward an implementation plan
  • The Implementation Plan will be shared with the campus community in January 2024.
  • List upcoming related programs and available resources - link to website
 iTeam Title IX/CRCO
January/February Email Campus Community
  • Recap work of the iTeam
  • Provide background and link to approved implementation plan
  • Acknowledge the Plan will also be shared via email with the campus community
  • List upcoming related programs and available resources - link to website
 iTeam Title IX/CRCO
February/March Email Campus Community
  • Recap work of iTeam
  • Provide next steps for Cal Poly Implementation Plan
  • Provide update on progress of CO work and overlap with CP work
  • Introduce any major changes as outcome of implementation plan that impacts work of others across campus
 iTeam Title IX/CRCO
Winter/spring e-postcard in student (and employee?) portal Students, Employees Postcard similar to red folder that explains basic facts, such as who the mandated reporters are, what the resources are Not sure, but maybe a collaboration? ITS
April ASI Sexual Assault Awareness Month Students Large scale collection point thoughts and ideas, training opportunities ASI
January/February Portal Students Single source for campus resources i.e. mental health, physical wellbeing, financial, etc. ASI