After 14-month review, officials suggest tweaks to GW’s compliance rules

At the end of a 14-month internal study of its workplace culture, a group of top officials gave positive marks to GW for meeting or exceeding nearly all national standards of compliance.

The faculty-led task force proposed 35 policy changes to add safeguards for minors and promote a culture of transparency at GW, with about half of those proposals already completed or set in motion.

Top leaders must now decide whether to take steps such as expanding background checks for all new faculty, improving training for trustees and banning pornography on GW information systems.

University President Steven Knapp launched the review in July 2012 as an attempt to uncover potential gaps in leadership that could perpetuate a scandal like the decade of child abuse uncovered at Penn State. He said considering and, possibly implementing, the proposals would be a long process, and any issues with GW’s culture were “always the hardest ones to work on.”

Ten of the ideas have been handed to senior leaders for approval, though the review’s co-leader Doug Shaw, an associate dean in the Elliott School of International Affairs, said none were “hard recommendations” to address glaring issues.

While some proposals, such as hiring a compliance office for the athletics department, bore financial considerations, none involved such major “resource constraints” that they could not happen.

“I don’t think there’s anything we couldn’t do readily,” he said. “The question is, are we comfortable with the scope of where we are?”

Knapp said expanded background checks is “something we’re going to look at,” as colleges across the country do more to dig into a professor’s past before hiring them. The University already conducts about 1,000 checks per year for its staff hires, which Knapp said raises another question: “‘If it’s fair for staff, why isn’t it fair for faculty?”

Sabrina Ellis, the vice president for human resources, said her office would “definitely need more resources” to hold the 250 or so background checks each year for new professors.

She added that while GW “took proactive steps early on to conduct background checks for staff, the broader conversation around background checks in higher education has recently evolved to include faculty.”

The University has already updated its policies for minors visiting campus, outlining signs of abuse or neglect of minors, listing “dos” and “don’ts” for interacting with people under 18 years old and providing contact information to report suspicious activity.

“Basically, as the steering committee recognized and identified what the University needed to do, they didn’t just wait. They said, ‘Let’s get going and start the processes to get these things done,’” University spokeswoman Candace Smith said.

To further increase security for children, the report calls for a University-wide protocol for working with minors on or off campus.

GW may also create a specific ban on viewing or storing pornography on “university information systems.” University policies already prohibit students and faculty from using GW computers in an “obscene, harassing, or otherwise inappropriate manner.”

But schools such as Johns Hopkins, Cornell and Dartmouth universities explicitly forbid using their information technology to access child pornography, and the University of Virginia bans retrieving any sexually explicit material.

The 22-page report calls on administrators to consider hiring more full-time employees to handle compliance with NCAA standards. The University, which enrolls the second-highest number of athletes compared to its peer institutions in the A-10, now has one of the smallest compliance staffs.

The University-wide review was launched in July 2012 under the leadership of Senior Vice President and General Counsel Beth Nolan and nearly a dozen other top administrators.

To carry out those recommendations, GW created another task force led by Shaw and professor Toni Marsh. Shaw said that team, which has already changed or is working to change 18 University policies, is meant to work in tandem with top leaders’ efforts.

“This was a consulting project more than an investigative project. We weren’t red-teaming the senior leaders. We were reliant on them for many reasons,” Shaw said. “They were compliant. There was no reason to suspect anything.”

Friday’s recommendations also include the work by a dean-led committee that evaluated whether GW’s culture encouraged employees to report concerns of potential University policy breaches.

That effort, spearheaded by former business school dean Doug Guthrie and nursing school dean Jean Johnson, included interviews with each dean and vice president across the University. Morphing into a long-term effort, the dean-led “Culture Project” will tackle issues of transparency and civility throughout the year.

GW is one of the first private universities in the nation to plan changes in light of the 2011 child sex abuse scandal. More than 60 other universities, mostly those with the country’s largest sports programs, have also reviewed and updated their practices after internal reviews.

During Penn State’s investigation, former prosecutors and law enforcement officials hired by the law firm Freeh Sporkin & Sullivan laid out 120 recommendations for restoring a broken structure of compliance.

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