1. Designing Drug and Alcohol Abuse Prevention Programs to Meet Biennial Review Requirements Complying with the Drug-Free Schools and Campuses Act EDGAR (34 CFR Part 86) D. Berty / TICUA / MIMSAC 20141

2. Alcohol and College Students: Researchers estimate that each year — 1,825 college students between the ages of 18 and 24 die from alcohol-related unintentional injuries, including motor vehicle crashes. 12 12 696,000 students between the ages of 18 and 24 are assaulted by another student who has been drinking. 13 13 97,000 students between the ages of 18 and 24 are victims of alcohol-related sexual assault or date rape. 14 14 Hingson et al. Magnitude of and trends in alcohol-related mortality and morbidity among U.S. college students ages 18-24, 1998-2005. Journal of Studies on Alcohol and Drugs, July (Suppl 16): 12-20, 2009.July (Suppl 16): 12-20 D. Berty / TICUA / MIMSAC 20142

3. “The Drug-Free Schools and Campuses Act now requires colleges to develop, announce, and enforce an unequivocal set of policies for preventing the misuse of alcohol and other drugs on campus.” Environmental Management: A Comprehensive Strategy for Reducing Alcohol and Other Drug Use on College Campuses. The Higher Education Center, 1998, pg. 11 D. Berty / TICUA / MIMSAC 20143

4. Creation of Drug Free Schools and Campuses Act Codified along with Safe and Drug Free Workplace Act in 1986 Initiation of Biennial Review in 1990 D. Berty / TICUA / MIMSAC 20144

5. The Chronicle of Higher Education April 11, 2012 “…a report last month by the U.S. Department of Education's Office of Inspector General: Enforcement of the law, it says, has been basically zero. Now, that may change…” Education Department's Report on Alcohol and Drugs May Prompt Crackdown D. Berty / TICUA / MIMSAC 20145

6. Part 86 of the Drug-Free Schools and Campuses Regulations requires as a condition of receiving funds or any other form of financial assistance under any federal program, an institution of higher education (IHE) must certify that it has adopted and implemented a program to prevent the unlawful possession, use, or distribution of alcohol and other illicit drugs (AOD)by students and employees. D. Berty / TICUA / MIMSAC 20146

7. Is intended to:  Ensure campuses meet minimum standards for AOD programming, policies, and disciplinary procedures for students and employees.  Ensure campuses review the effectiveness of their prevention programming on a biennial basis, implement changes to improve upon programmatic and policy efforts, and ensure sanctions are consistently enforced. D. Berty / TICUA / MIMSAC 20147 EDGAR Part 86

8. Creating a program that complies with the Regulations requires an IHE to: 1.Prepare a written AOD policy 2.Develop a sound method for distribution of the policy to every student and IHE faculty & staff member each year 3.Prepare a biennial report on the effectiveness of its AOD programs and the consistency of policy enforcement D. Berty / TICUA / MIMSAC 20148

9. Require an IHE to submit a written certification to the Secretary of Education that it has adopted and implemented an AOD prevention program as described in the Regulations. Establish a minimum set of requirements for college substance use policies. Colleges also may have additional obligations under state law. Establish an expectation that colleges address substance abuse issues based on current research, evaluation, best practices, and recent court decisions in lawsuits brought against IHEs by college and university students and employees. D. Berty / TICUA / MIMSAC 20149

10. Some forms of federal funding and assistance require IHE’s to certify compliance. In most cases, certification is included within the “Representations and Certifications” portion of funding applications and proposals D. Berty / TICUA / MIMSAC 201410

11. Presidential or Senior Administrator Certification IHE’s also must have the senior leading administrator (President) certify minimally every five years upon the arrival of a new senior leading administrator D. Berty / TICUA / MIMSAC 201411

12. Failure to Comply with the Drug-Free Schools and Campuses Regulations If an IHE fails to submit the necessary certification or violates its certification, the Secretary of Education may terminate all forms of financial assistance, whether from the Department of Education or other federal agencies, and may require repayment of such assistance, including individual students' federal grants, such as Pell. The Department of Education also may arrange to provide technical assistance toward the development of a plan and agreement that brings the IHE into full compliance as soon as feasible. The "Secretary annually reviews a representative sample of IHE drug prevention programs." If the Secretary of Education selects an IHE for review, the IHE shall provide the Secretary access to personnel records, documents, and any other necessary information requested for this review. D. Berty / TICUA / MIMSAC 201412

13. Required Documentation Sec.86.103 requires that IHEs retain the following records for 3 years after the fiscal year in which the record was created:  The annually distributed notification or policy document  Prevention program certification of the biennial review  Results of the biennial review  Any other records reasonably related to the IHE’s compliance with certification D. Berty / TICUA / MIMSAC 201413

14. If selected for review, the IHE will provide access to personnel, records, documents, and any other related information requested by the Secretary to review the IHE’s adoption and implementation of its AOD prevention program D. Berty / TICUA / MIMSAC 201414

15. Standards of conduct that clearly prohibit the unlawful possession, use, or distribution of illicit drugs and alcohol on school property or as part of any school activities The written annual notification or policy also must include: 1.A list of applicable legal sanctions under federal, state, or local laws for the unlawful possession or distribution of illicit drugs and alcohol 2.A description of the short- and long-term health risks associated with the use of illicit drugs or abuse of alcohol 3.A list of drug and alcohol programs (counseling, treatment, rehabilitation, and re-entry) that are available to employees or students 4.A clear statement that the IHE will impose disciplinary sanctions on students and employees for violations of the standards of conduct and a description of those sanctions, up to and including expulsion or termination of employment and referral for prosecution Annual Notification D. Berty / TICUA / MIMSAC 201415

16. Standards of conduct that clearly prohibit the unlawful possession, use, or distribution of illicit drugs and alcohol on school property or as part of any school activities  May range from statements prohibiting illegal activities related to alcohol and other drugs to statements reflecting the IHE's more specific expectations  Apply to all on-campus activities and to off-campus activities that are considered to be school-sponsored  Have been interpreted to apply to student-sponsored social activities or professional meetings attended by employees, if these activities or meetings are under the auspices of the IHE D. Berty / TICUA / MIMSAC 201416 Standards of Conduct

17. Legal Sanctions 1. A list of applicable legal sanctions under federal, state, or local laws for the unlawful possession or distribution of illicit drugs and alcohol. An alcohol and drug policy should stipulate that anyone who violates the policy is subject both to the institution's sanctions and to criminal sanctions D. Berty / TICUA / MIMSAC 201417

18. Example of Legal Sanctions… Federal Trafficking Penalties include substantial fines and imprisonment up to life. State sanctions depend on the classicization of the controlled substance, the particular activity involved (possession or trafficking), and whether multiple convictions are involved. Under state law, the most severe penalties for drug violations are for possession with intent to sell. On a first offense conviction, one may receive a fine of up to $xxx and/or imprisonment for XX years. Sanctions for violations of state alcohol laws vary according to the severity of the offense, with a vehicular violation calling for imprisonment in jail for XX hours and a $xxx fine. D. Berty / TICUA / MIMSAC 201418

19. Health Risks 2. A description of the short- and long-term health risks associated with the use of illicit drugs or abuse of alcohol. Statements of health risks associated with the use of alcohol and other drugs represent the minimum level of information schools must distribute. Resource: Controlled Substances Act D. Berty / TICUA / MIMSAC 201419

20. Example of Risks… Use and abuse of alcohol and other drugs can lead to accident, injury, and other medical emergencies. Alcohol, especially in high doses, or when combined with medications or illegal drugs claims the lives. If you see someone unconscious call 911; doing so may save their life. Driving after drinking even relatively small quantities of alcohol can substantially increase one’s risk of crash involvement. Even after just one drink, one may experience some loss of ability to think about complex problems or accomplish complex tasks. Drinkers also may lose some control over impulse behavior. To become dependent upon chemicals such as alcohol and/or illicit drugs is to put your health and life at risk. Chemical dependency is a condition in which the use of mood altering substances affect any area of life on a continuing basis. Medical research has established very strong evidence that alcohol abuse contributes significantly to cancer and heart disease. Evidence also links the use of illicit drugs to serious short- and long-term health problems. There is clear evidence of serious negative effects on babies due to the use of alcohol and illicit drugs by the mother. D. Berty / TICUA / MIMSAC 201420

21. Drug & Alcohol Programs 3.A list of drug and alcohol programs (counseling, treatment, rehabilitation, and re-entry) that are available to employees or students May include community resources or the means by which students and employees can access community resources D. Berty / TICUA / MIMSAC 201421

22. Disciplinary Sanctions 4. A clear statement that the IHE will impose disciplinary sanctions on students and employees for violations of the standards of conduct and a description of those sanctions, up to and including expulsion or termination of employment and referral for prosecution. Responsibility for the enforcement of standards of conduct is not specifically mentioned in 34 C.F.R. Part 86 Responsibility for enforcing standards of conduct should comply with the school’s internal policies and procedures and be consistently applied D. Berty / TICUA / MIMSAC 201422

23. Example… Disciplinary Sanctions: The University will impose disciplinary sanctions on students and employees consistent with local, State, and federal laws for violation of the Standards of Conduct as described in this policy. All persons should be aware that violations could result in expulsion from the university, termination of employment, or referral for prosecution. D. Berty / TICUA / MIMSAC 201423

24. Distribution of the Policy The Department of Education requires that each IHE distribute its AOD policy annually in writing. Delivery may be electronic if the IHE has established that electronic delivery goes to the individual and that electronic communication is one of the IHE’s primary modes of communication IHE must demonstrate appropriate method of distributing to those whose mailings are returned or bounced back D. Berty / TICUA / MIMSAC 201424

25. If new students enroll or new employees are hired after the annual distribution, these students and employees also must receive the materials. Merely making the materials available to those who wish to take them does not satisfy the requirements of the Regulations. Distribution must be intentional, passive methods do not meet requirements or expectations D. Berty / TICUA / MIMSAC 201425

26. How does YOUR Institution Distribute its Policy? D. Berty / TICUA / MIMSAC 201426

27. The Biennial Review The law further requires an institution of higher education to conduct a biennial review of its program to:  determine its effectiveness and implement changes if they are needed  ensure that the sanctions developed are consistently enforced The Drug-Free Schools and Campuses Regulations require IHEs to review their AOD programs and policies every two years. D. Berty / TICUA / MIMSAC 201427

28. The Drug-Free Schools and Campuses Regulations require IHEs to review their AOD programs and policies every two years.  No specific date in which report is to be filed  Since regulations began in 1990, common for reviews to be conducted during even years  Review report should be completed and filed by December 31  Review report should cover the 2 previous academic years D. Berty / TICUA / MIMSAC 201428

29. The Biennial Review, continued Because the Regulations do not specify what a biennial review should include or how it should be conducted, schools have considerable leeway in determining how to conduct and what to include in their biennial review. D. Berty / TICUA / MIMSAC 201429

30. Biennial Review Best Practices  Comprehensive program focuses on evidence- based strategies of practice  Data collection of students’ behaviors and perceptions  Program focuses on meeting needs of students at various levels (drinkers/users, non-drinkers/non-users, problem drinkers, etc. )  Creation of a strategic plan of action  Creation of a task-force or campus-based coalition D. Berty / TICUA / MIMSAC 201430

31. First -- Review Campus AOD Program Relies on:  Clear description of problems  Strategic interventions  Desired outcomes  Sound evaluation plan D. Berty / TICUA / MIMSAC 201431

32. Review Campus AOD Program Conduct a Program & Interventions Inventory  List activities that compose prevention program  Identify the effectiveness of these efforts at meeting goals and outcomes Conduct a Policy Inventory D. Berty / TICUA / MIMSAC 201432

33. D. Berty / TICUA / MIMSAC 201433 1.Each included materials to compliment the report 2.Each included information on assessment and evaluation of program effectiveness 3.Each detailed goals and goal achievements 4.Each included recommendations for revising programs and policies 5.Each used a task force to complete the review HEC Analysis of Model Biennial Reviews

34. D. Berty / TICUA / MIMSAC 201434 Thorough Biennial Reviews Include: 1.A description of AOD comprehensive program/intervention elements and policies 2.A statement of AOD program/intervention and policy goals and a discussion of goal achievement 3.Summaries of AOD program/intervention and policy strengths 4.Summaries of AOD program/intervention and policy weaknesses and problems 5.Procedures for distributing AOD document to students and employees 6.Copies of the documents distributed to students and employees 7.Recommendations for revising AOD programs 8.Supporting documentation and evidence

35. Socioecological Model by Network Standards IndividualGroupInstitutionCommunityPolicy Education Enforcement Assessment Community Mobilization D. Berty / TICUA / MIMSAC 201435 Typology Matrix

36. Socioecological Model by NIAAA Tiers IndividualGroupInstitutionCommunityPolicy Tier I – evidence with college students Tier II – evidence with gen populations Tier III - promising Tier IV – doesn’t work D. Berty / TICUA / MIMSAC 201436

37. Socioecological Model by SAMHSA Prevention Strategies IndividualGroupInstitutionCommunityPolicy Information Dissemination Education Alternatives Problem Identification/ Referral Community- Based Processes Environmental /Policy D. Berty / TICUA / MIMSAC 201437

38. Additional Options Other useful resources can be found in the standards for prevention programs developed by:  The Council for the Advancement of Standards in Higher Education (CAS Standards)  American College Health Association (ACHA) D. Berty / TICUA / MIMSAC 201438

39. Leadership from college and university presidents and other senior administrators is key to institutionalizing prevention as a priority on campus. D. Berty / TICUA / MIMSAC 201439

40. “The primary vehicle for creating environmental change on campus should be a campus-based AOD task force…” Environmental Management…1998, pg.14 D. Berty / TICUA / MIMSAC 201440

41. Who is Responsible? Governance/Accountability  Compliance Office  Senior Level Administrator  AOD Prevention Program  Task Force/Coalition D. Berty / TICUA / MIMSAC 201441

42. Initiating a Biennial Review Determine why the institution benefits from conducting this process…  It’s the law – avoid penalties  Increase program and policy effectiveness  Increase safe and supportive learning environment  Determines priorities D. Berty / TICUA / MIMSAC 201442

43. “We have learned a considerable amount about the drinking habits of college students and the consequences that follow since NIAAA first reported on the matter in 1976. Surprisingly, drinking levels have remained relatively stable on and around college campuses over the last 30 years, with roughly two out of five male and female students engaging in excessive, or binge, drinking. Excessive drinking results in a wide range of consequences, including injuries, assaults, car crashes, memory blackouts, lower grades, sexual assaults, overdoses and death. Further, secondhand effects from excessive drinking place non–binge- drinking students at higher risk of injury, sexual assaults, and having their studying disrupted.” D. Berty / TICUA / MIMSAC 201443

44. Initiating a Biennial Review Determine how this process should be implemented…  Timelines  Task Force/Coalition/Sub-Committees  Data Collection Processes  Suggestions/Recommendations  Reporting/Publicizing D. Berty / TICUA / MIMSAC 201444

45. Initiating a Biennial Review Determine who should be included in this process…  Student Affairs Staff  Academic Affairs  Campus Security/Police  Business Affairs  Community Members  Students D. Berty / TICUA / MIMSAC 201445

46. The Department of Education established a set of principles of effectiveness in AOD prevention for those receiving OSDFS funds… D. Berty / TICUA / MIMSAC 201446

47. Evaluating Effectiveness  Design programs based on a thorough and objective needs assessment  Establish measurable goals linked to identified needs  Implement activities proven (through research and evaluation) to be effective in preventing high-risk drinking and illicit drug use  Use evaluation results to refine and strengthen program and goals D. Berty / TICUA / MIMSAC 201447

48. Effective AOD Programs  Are logically linked to identified problems  Have attainable outcomes  Use evidence-based strategies to achieve those outcomes D. Berty / TICUA / MIMSAC 201448

49. The Department of Education has not specified particular criteria or measures to gauge program effectiveness beyond requiring that evaluations of program effectiveness do not rely solely on anecdotal observations. D. Berty / TICUA / MIMSAC 201449

50. Review Current Campus AOD Data Collect and review data that describes alcohol and other drug problems and culture:  CORE Survey  National College Health Assessment  Policy Violations  Transports  Diagnoses D. Berty / TICUA / MIMSAC 201450

51. Estimates of the rates of alcohol use and related consequences are imperfect. Lack of knowledge of standard drink sizes and the effects of alcohol on memory formation all complicate the collection of accurate data from traditional self-report surveys. Underreporting of sexual assaults leads to difficulty in estimating the true extent of the problem. Lack of college identifiers in mortality records and the fact that alcohol levels are tested too infrequently in non–traffic-related deaths leaves uncertainty regarding the actual number of college students who die each year from alcohol-related causes. Similarly, college identifiers are not present in most crime reports and hospital reports. D. Berty / TICUA / MIMSAC 201451

52. IHEs also must determine the number of drug and alcohol-related incidents and fatalities that:  Occur on the institution’s campus or as part of any of the institution’s activities  Are reported to campus officials  Determine the number and type of sanctions described in paragraph that are imposed by the institution as a result of drug and alcohol-related incidents and fatalities on the institution’s campus or as part of any of the institution’s activities; and  Ensure that the sanctions required by paragraph are consistently enforced D. Berty / TICUA / MIMSAC 201452

53. Consider including process summary or performance metrics for each program or intervention:  Number of times program or intervention delivered  Number of students, staff, faculty participating  Satisfaction survey results D. Berty / TICUA / MIMSAC 201453

54. Consider including:  Assessment data on student learning outcomes, attitudinal changes, behavior changes gained through programs  Evaluation and Research data collected through programs D. Berty / TICUA / MIMSAC 201454

55. Second: Conduct a Policy Review  Identify and list policies  Articulate effectiveness and consistency of enforcement D. Berty / TICUA / MIMSAC 201455

56.  Assess how effective policies are at moving the IHE toward its AOD goals and outcomes  Assess how consistently policies are enforced  Assess if everyone, regardless of affiliation, is held to the same policy standards and offered the same interventions – measure enforcement consistency D. Berty / TICUA / MIMSAC 201456

57.  Document that similar situations are treated similarly – and, if not, explain why…  Use a chart that identifies each case and presents details of each offense  Document level of effort expended to detect violations  Document level of expertise of those responsible for detecting/adjudicating AOD offenses D. Berty / TICUA / MIMSAC 201457

58. The Biennial Review The more thorough biennial reviews include: descriptions of the AOD program elements; 1.A statement of AOD program goals and a discussion of goal achievement 2.Summaries of AOD program strengths and weaknesses 3.Procedures for distributing AOD policy to students and employees 4.Copies of the policies distributed to students and employees 5.Recommendations for revising AOD programs D. Berty / TICUA / MIMSAC 201458

59. Institutions should address:  The rigor and effectiveness of AOD prevention programming  The comprehensiveness and consistency of campus policies and sanctions  The extent to which processes critical to success are employed  The degree to which AOD prevention efforts have been institutionalized D. Berty / TICUA / MIMSAC 201459

60. HEC Suggested Review Report Contents  Introduction/Overview  Certification  Biennial Review Process  AOD Comprehensive Program Goals & Objectives for Biennium being reviewed  Annual Policy Notification Process  AOD Prevalence & Incidence Rate Data  AOD Needs Assessment & Trend Data  AOD Policy, Enforcement & Compliance Inventory & Related Outcomes/Data  AOD Intervention Inventory & Related Outcomes/Data  AOD Goal Achievement & Objective Achievement  AOD Strengths & Weaknesses  Recommendations for next Biennium  Goals and Objectives for next Biennium D. Berty / TICUA / MIMSAC 201460

61. What Do To Do With the Report Unless requested do not send to Department of Education…  Send copy to President for signature and certification  Send signed copy to Financial Aid  Send signed copy to Grant’s Office  Copies to places where someone would think that an alcohol report would be obtained  Place online for public access D. Berty / TICUA / MIMSAC 201461

62. What is meant by a “Program”?  Clear guidance is not really given  Some institutions believe that notification and biennial review constitute compliance  Current best practices and science of prevention are strongly suggested as components of a comprehensive, evidence- based, environmental management AOD prevention program D. Berty / TICUA / MIMSAC 201462

63. Department of Education: Principles of Program Effectiveness  Based alcohol, drug, and violence prevention programs on needs assessment data  Develop measurable program goals and objectives  Implement programs with research evidence of effectiveness,  Periodically evaluate programs relative to their goals and objectives D. Berty / TICUA / MIMSAC 201463

64. Model Programs Department of Education Identified 22 Campus- based Model Programs (1999-2004) Shared Common Elements: 1.Each included materials to compliment the report 2.Each included information on evaluation of program effectiveness 3.Each detailed goals and goal attainment 4.Each included recommendations for revising policies and programs 5.Each used a task force/working group to complete the review D. Berty / TICUA / MIMSAC 201464

65. Model Programs… 22 Programs Shared Common Core elements of effectiveness  Exercise leadership  Build coalitions  Choose evidence-based programs  Implement strategic planning  Conduct a program evaluation  Work toward sustainability  Take the long view D. Berty / TICUA / MIMSAC 201465

66. Department of Education: 12 campus-based model programs (2005-2007) Insights on prevention programs, projects, campaigns:  Link prevention to the institution’s mission, values, and priorities  Strategic planning is an ongoing, dynamic process  Engage the campus community in data collection and evaluation  Promote student involvement  Pay attention to strategic timing  Hone communication skills Model Programs… D. Berty / TICUA / MIMSAC 201466

67. Summaries of Program Strengths Favorable Compliance  The institution has developed and maintains an AOD prevention policy.  The institution distributes annually to each student/employee a copy of the AOD policy.  The institution provides services and activities to promote a strong AOD campus environment.  The institution conducts a biennial review of its AOD prevention program and policy to determine effectiveness, implements necessary changes, and ensures that disciplinary sanctions are enforced.  The institution tracks the number of drug- and alcohol- related legal offenses and referrals for counseling and treatment. D. Berty / TICUA / MIMSAC 201467

68. Summaries of Program Weaknesses Compliance Concerns  AOD policy is distributed to new employees; need to implement annual distribution to all employees.  Ensure that on-line and on-ground students who enroll during non-traditional terms or who are graduate or summer students only are receiving the policy.  Ensure that the AOD policy is readable; currently, small print in handbook is difficult to read.  Recommendation made that "No Smoking" signs be placed about campus. D. Berty / TICUA / MIMSAC 201468

69. “Although it is beyond the scope of this review to examine efforts to prevent excessive drinking on college campuses, it should be noted that important strides have been made in this area (Carey et al. 2012). In addition, data from MTF suggest that levels of binge drinking are decreasing among 12th graders, particularly males. Hopefully, as our understanding of the nature of the problem continues to improve with better measurement strategies, improvements in prevention approaches combined with declines in precollege drinking will lead to reductions in both the levels of alcohol consumption by college students and the negative consequences that result.” The Burden of Alcohol Use: Excessive Alcohol Consumption and Related Consequences Among College Students Aaron White, Ph.D., and Ralph Hingson, Sc.D. Alcohol Research: Current Reviews, Volume 35, Issue Number 2, 2013 D. Berty / TICUA / MIMSAC 201469

70. Resources:  CAS  The Network  America College Health Association  NIAAA Report  CHASCo www.ticua.org www.ticua.org D. Berty / TICUA / MIMSAC 201470

71. EDGAR Checklist 1. Does the institution maintain a copy of its drug prevention program? If yes, where is it located? D. Berty / TICUA / MIMSAC 201471

72. 2. Does the institution provide annually to each employee and each student, who is taking one or more classes for any type of academic credit except for continuing education units, written materials that adequately describe and contain the following: a)Standards of conduct that prohibit unlawful possession, use, or distribution of illicit drugs and alcohol on its property or as apart of its activities; b)A description of the health risks associated with the use of illicit drugs and the abuse of alcohol; c)A description of applicable legal sanctions under local, state, or federal law; d)A description of applicable counseling, treatment, or rehabilitation or re-entry programs; A clear statement of the disciplinary sanctions the institution will impose on students and employees, and a description of those sanctions D. Berty / TICUA / MIMSAC 201472

73. 3. How are the above materials distributed to students? Mailed to each student (separately or included in another mailing) Through campus post office boxes Class schedules which are mailed to each student During freshman orientation During new student orientation In another manner (describe) 4.Does the means of distribution provide adequate assurance that each student receives the materials annually? D. Berty / TICUA / MIMSAC 201473

74. 5.Does the institution’s distribution plan make provisions for providing these materials to students who enroll at some date after the initial distribution? 6.How are the above materials distributed to staff and faculty? Mailed – Snail Through campus post office boxes During new employees orientation In another manner (describe) 7.Does the means of distribution provide adequate assurance that each staff and faculty member receives the materials annually? 8.Does the institution’s distribution plan make provisions for providing these materials to staff and faculty who are hired after the initial distribution? D. Berty / TICUA / MIMSAC 201474

75.  Conduct student AOD use survey  Conduct opinion survey of its students, staff and faculty  Evaluate comments obtained from a suggestion box  Conduct focus groups  Conduct intercept interviews  Assess effectiveness of documented mandatory drug treatment referrals for students and employees  Assess effectiveness of documented cases of disciplinary sanctions imposed on students and employees  Other (please list)  By whom 9.How and by whom does the institution conduct biennial reviews of its drug prevention program to determine effectiveness, implement necessary changes, and ensure that disciplinary sanctions are enforced? D. Berty / TICUA / MIMSAC 201475

76. 10.If requested, has the institution made available, to the Secretary and the public, a copy of each required item in the drug prevention program and the results of the biennial review? 11.Where is the biennial review documentation located? Name Title Department Phone Email 12.Comments D. Berty / TICUA / MIMSAC 201476

77. Diane Berty, Ed.D. Vice President TN Independent Colleges & Universities Association 1031 17 th Ave S. Nashville, TN 37212 615/242-6400 ext. 203 615/242-8033 fax berty@ticua.org D. Berty / TICUA / MIMSAC 201477