Understanding the New Emergency Notification Provisions of the HEOA

Annual Security Report

What it is

The Annual Security Report is a comprehensive account of virtually everything pertaining to campus safety. For example, some of the elements included are crime statistics and reporting, emergency notification policies and procedures, missing student notification policies and more.

Who to give it to

There are three main groups that must receive either a copy of the Annual Security Report or notice of the report’s availability by October 1 of each year, beginning in 2010. These groups include:

There are several ways to distribute the report (or notice of its availability). These include:

Direct mailing through the U.S. Postal Service
Publication provided directly to each individual
Post to Internet or Intranet website

Distribute notice including:

Statement of report's availability
Exact electronic address where report is posted
Brief description of contents
Statement that paper copy will be provided upon request

Submitting the report to the Secretary of the Department of Education must be done each year, by the date and in a form specified by the Secretary.

What to include

A statement of policy regarding emergency response and evacuation procedures is the primary element of the Annual Security Report. This statement describes how the institution will immediately notify the campus community upon the confirmation of a significant emergency or dangerous situation, unless notification will compromise efforts to contain the emergency. Following is a detailed listing of the updated statement of policy elements that must be included in the Annual Security Report.

Description of how the institution will test its emergency response and evacuation procedures at least annually:

At least one test per calendar year, may be announced or unannounced

Document a description of the exercise, date, time and whether it was announced or unannounced

Procedures the institution will use to immediately notify the campus community upon the confirmationof a significant emergency or dangerous situation involving an immediate threat to the health or safety of students or employees occurring on campus, unless notification will compromise efforts to contain the emergency

Must provide follow-up information to the community as needed when emergency notification system is used

Description of the process the institution will use to:

Confirm there is an emergency/dangerous situation

Determine appropriate segments of the campus to notify

Determine content of the message

Initiate the notification system

The Annual Security Report must also contain a statement that the institution will, without delay, determine the content of the message and initiate the notification system unless notification will compromise efforts to assist a victim or mitigate the emergency. Other items the report must contain include:

List the titles of who is responsible for carrying out the actions

Procedures for disseminating emergency information to the larger community

Statement of policy regarding missing student notification procedures for students who reside in on-campus student housing facilities (only if the institution provides any on-campus student housing facility)

Important Considerations

For privacy and security purposes, the new regulations do not require institutions to publish in great detail how they would respond to specific emergencies. The new provisions also encourage the consideration for the needs of students and employees with disabilities in developing emergency response and evacuation policies and procedures.

Also, in the proposed rules, the Department of Education offers excellent advice for institutions planning and implementing a mass notification system. The Department does not specify that institutions use a particular mode of communication. The Department states that:

“Institutions may and should have multiple methods of communication with the campus community…the Department encourages institutions to consider overlapping means of communication in case one method fails or malfunctions. Additionally, institutions have the flexibility to alert only the appropriate segment or segments of the population that they determine to be at risk.”2

It is important to have the flexibility of multiple communication modes and the ability to target messages toward specific areas of the campus community. Inova OnAlert is a real-time notification system that instantly displays emergency messages on bright and visible LED signs throughout a facility. Inova OnAlert integrates seamlessly with virtually every mainstream mass notification platform. Therefore, an emergency manager can trigger an RSS/XML-based message on the Inova OnAlert signs at the same time that he is sending an emergency email or SMS/text message to any notification technology connected to the centralized system. Having multiple means of communication integrated into one emergency messaging system allows for ubiquitous messaging and valuable time savings during a crisis.

2 ”General and Non-Loan Programmatic Issues; Proposed Rule,” 74 Federal Register 161 (21 Aug 2009), pp.42397.

Find out how to make Inova OnAlert Part of Your Emergency Notification Solution