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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.


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.