Institutions don’t get investigated simply because they lacked a policy. They are investigated because they couldn’t demonstrate performance when it mattered most. When leaders do what’s right to support preparation and response, compliance typically takes care of itself.
Following December’s tragic campus shooting and the pain and confusion that followed, the U.S. Department of Education (ED) initiated a review of Brown University, citing concerns about delayed or inaccurate Emergency Notifications and effectiveness of campus security systems. Drawing upon ED’s announcement and what was required for the Liberty University review, we can confidently assume the following requests apply to any institution under investigation:
- Complete crime audit trails,
- Copies of all Timely Warnings and Emergency Notifications,
- Dispatch and call logs,
- Standard operating procedures for active shooter response,
- Complete, un-redacted records,
- Full cooperation, with the possibility of fines or Title IV consequences for failure to comply.
“An institution shall make its records readily available for review by the Secretary or the Secretary’s authorized representative at an institutional location designated by the Secretary or the Secretary’s authorized representative.” (34 C.F.R. § 668.24(d)(2))
When ED investigates, they don’t ask “Did you have an app?” They are requesting a president to:
- Show us your institution-wide audit trail.
- Show us your notification policy, protocols, and timestamps.
- Show us all campus-wide incident reports and data going back years.
- Show us dispatch logs, documented decisions, and response procedures.
- Show us evidence of sustained compliance and your oversight.
- Demonstrate your investments in, and support of, administrative capability.
This is the stark reality of Clery Act enforcement that raises the uncomfortable question: If ED opened a review at your institution tomorrow, could you demonstrate:
- Real-time coordinated response?
- Documented responder activity?
- Verified notification timelines?
- Searchable, defensible crime logs?
- Clear emergency protocols that were followed?
Now, the challenger question: Why do institutions continue to stick with systems that operators do not trust, that engagement data doesn’t support, and that cannot clearly demonstrate operational accountability?
- Is it because change feels hard?
- Because procurement fatigue is real?
- Because replacing a legacy system feels politically risky?
Let’s measure these answers to very real-world risks and consequences:
- Compared to the impact of failing in a critical moment?
- Compared to federal investigation?
- Compared to public loss of trust?
- Compared to a preventable headline?
- Compared to fines running into the millions?
Consider this: If your safety technology were audited or tested in a live crisis tomorrow, would it protect lives on your campus, or would it expose your institution to:
- Unmitigated harm and trauma,
- Reputational damage,
- Loss of campus community confidence,
- Enrollment impact,
- Federal fines,
- Civil lawsuits based on duty of care,
- Board, alumni, and governmental scrutiny.
The real risk isn’t in switching systems.
The real risk is defending a system that fails when seconds matter to your campus community… which is all that matters.
Engage CriticalArc Consulting and begin your transformation journey today to lead with clarity, confidence, and control of your institution’s narrative.
Posted 6th Mar 2026
