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Gaps in USMMA’s Sexual Assault Prevention and Response Program Limit Its Effectiveness

Mandated by the National Defense Authorization Act for Fiscal Year 2017
Project ID: 
ST2018039

What We Looked At
The National Defense Authorization Act for Fiscal Year 2017 (NDAA) mandated that, by March 31, 2018, we report on the effectiveness of the United States Merchant Marine Academy’s (USMMA or the Academy) Sexual Assault Prevention and Response (SAPR) program. We assessed (1) the SAPR program’s policies and procedures; (2) the Department’s and Academy’s progress and challenges in prioritizing and addressing recommendations from past studies and current action plans, including the 2017 Culture Change Action Plan; and (3) the Department’s and Academy’s responses to reports of sexual assault or harassment involving members of the Academy. To meet an NDAA requirement, we consulted experts from the Centers for Disease Control and Prevention (CDC).

What We Found
Due to weaknesses in its infrastructure—which includes policies, procedures, and staffing—the Academy’s SAPR program does not fully align with the CDC’s strategies for effective sexual violence prevention efforts on college campuses. Critical gaps remain in comprehensive prevention and evaluation. For example, USMMA has not ensured that policies prohibiting sexual assault and sexual harassment are reinforced in the Midshipmen Regulations or established a reliable methodology for collecting sexual harassment data. 

MARAD and USMMA have made progress implementing recommendations from past studies and action plans but have missed target dates and lack a risk-based approach to prioritization. USMMA reported completion of 62 of 138 recommendations (about 45 percent) derived from past studies and action plans, including those necessary to maintain its accreditation. 

USMMA’s lack of full compliance with its procedures, particularly for sexual harassment, limits its ability to respond to incidents and report to Congress. For example, USMMA lacks documentation related to reports of sexual harassment, which impacts its ability to provide survivor services and accurately assess its progress in addressing sexual harassment.

Our Recommendations
USMMA concurred with all 10 of our recommendations to improve the SAPR program’s effectiveness.

 

Recommendations

Open

Closed

Closed on 09.25.2018
No. 1 to MARAD

Update policy or develop procedures to place a greater emphasis on prevention in the SAPR training program and incorporate the Centers for Disease Control's elements of a comprehensive prevention program, such as providing bystander intervention training at all levels (students, faculty, staff, and leadership).

No. 2 to MARAD

Complete a Sexual Assault Review Board review of all Academy policies and procedures, including the Midshipmen Regulations, to identify any gaps or inconsistencies with SAPR messaging and revise the policies and procedures accordingly.

No. 3 to MARAD

Communicate the revised policies and procedures to all Academy stakeholders.

No. 4 to MARAD

Establish and formalize in policy or procedures methodologies to evaluate the effectiveness of the SAPR program and its practices, including metrics to evaluate training outcomes.

No. 5 to MARAD

Revise sexual assault policies and procedures and sexual harassment policies to clearly provide for documenting, tracking, and maintaining reports, such as by cross-referencing to the records maintenance standard operating procedure.

No. 6 to MARAD

Develop and implement procedures for prioritizing responses to recommendations based on risk and aligning resources accordingly.

No. 7 to MARAD

Develop and implement controls to ensure staff at all levels and faculty are held accountable for taking actions to support the SAPR program, including completing assigned action items.

No. 8 to MARAD

Align the investigative reporting practice with the standard operating procedure for investigating an unrestricted report of sexual assault.

No. 9 to MARAD

Develop and implement a procedure for reporting, investigating, and responding to sexual harassment complaints.

Closed on 05.25.2018
No. 10 to MARAD

Develop and implement a procedure for validating the Academy's data on reported sexual assault and sexual harassment incidents.