Seize the SCHA Opportunity to Revitalize Your Campus Safety Framework
The Stop Campus Hazing Act (SCHA) creates a timely opportunity to streamline campus safety policies. Institutions can leverage the SCHA implementation process across 2025 and 2026 to comprehensively review and update their existing Jeanne Clery Campus Safety Act (Clery Act) policies.
SAFE Campuses, LLC’s team of experts can help your institution navigate this process, ensuring your policies are compliant with both the Clery Act and the SCHA. Get Started on Your Clery Act Compliance Review: Contact SAFE Campuses, LLC today at cleryquestions@safecampuses.biz.
The Clery Act’s Equal Emphasis on Policy and Crime Statistics
For decades, the public’s main view of the Clery Act has often been on crime statistics, or perhaps timely warnings. However, the law has always emphasized the importance of disclosing current campus safety policies as well. This is reflected in its original name: the “Jeanne Clery Disclosure of Campus Security Policy and Campus Crime Statistics Act” (emphasis added).
Understanding When Your ASR is “For”: Reflecting Policies of the Publication Year
The Clery Act statute includes four express references to disclosing “current” policies, and when “hazing” policy is added later this year on June 23, 2025 it will have five. This is why every policy summary in the Annual Security Report (ASR) should be current as of the date of publication.
This statutory requirement is recognized in the U.S. Department of Education’s Handbook for Campus Safety and Security Reporting, 2016 Edition: “The statements or descriptions in your annual security report must accurately reflect your institution’s current procedures and practices.”
Consequently, the ASR is considered to be “for” the year of publication, not solely for the most recent calendar year of crime statistics. This aligns with the 2016 Handbook, which states, “For example, for your 2015 report, enter statistics separately for 2012, 2013 and 2014”. The reports published this year (2025) will be the “2025” Annual Security Reports, not the “2024” reports.
Navigating Clery Act Requirements: From Specific Questions to Mandatory Policy Elements
Some Clery Act policy statements require institutions to answer specific questions (e.g., do campus security personnel have arrest powers?). Others, such as those related to gender-based violence, mandate the inclusion of specific policy elements, effectively requiring institutions to adopt these policies (e.g., prohibiting dating violence, domestic violence, sexual assault, and stalking).
SCHA Mandates: Integrating Hazing Policies into the 2026 ASR for Comprehensive Compliance
Hazing disclosures, like those for gender-based violence, will mandate specific standards under the SCHA. Institutions must include in their October 1, 2026* ASR:
- Hazing prevention and awareness programs
- Procedures for reporting and investigating hazing
- Compliance with local, State, and Tribal anti-hazing laws
To ensure compliance, institutions should have their hazing prevention policies and programs in place by the start of the 2026-2027 academic year. These policies must align with the institution’s “standards of conduct relating to hazing” established by July 1, 2025, which will inform the twice a year “Campus Hazing Transparency Report.” Additionally, the January 1, 2025 start date for hazing statistics collection will ensure a full year of data for the 2026 ASR.
*The Stop Campus Hazing Act was enacted on December 23, 2024. The Act provides that its amendments “apply with respect to the annual security report…for the calendar year that is 2 years after such date of enactment”. The first calendar year after is 2025, and the second is 2026. The ASR “for” the second year after is therefore the 2026 ASR, due by October 1st of that year. We have sought verification of this interpretation from the U.S. Department of Education.
This blog does not provide legal advice and does not create an attorney-client relationship. If you need legal advice, please contact an attorney directly.