What happened
Institutions must distribute their Annual Security Reports (ASRs) to enrolled students and current employees by October 1. This year's report is the first that must include hazing statistics under the Stop Campus Hazing Act, signed on December 23, 2024, which amended the Clery Act, now formally the Jeanne Clery Campus Safety Act. As of this writing, we have found no new Department of Education guidance in September specific to the first year of hazing statistics.
What changed
The Act made three changes that converge in this reporting cycle.
- Statistics. The ASR must now include the number of hazing incidents that occurred within Clery geography and were reported to campus security authorities or local police. Incidents are counted per incident. The statute applies this requirement to the report for the calendar year two years after enactment, which is the 2026 report, and required institutions to begin collecting hazing statistics no later than January 1, 2025.
- Policy statements. The ASR must include a statement of policy on hazing prevention and awareness programs, including research-informed, campus-wide prevention programming for students, staff, and faculty, along with procedures for reporting hazing and the process used to investigate reports.
- A separate public record. Institutions must also maintain a Campus Hazing Transparency Report on their public website, updated at least twice each year, identifying student organizations found responsible for hazing violations. Information must remain posted for five calendar years.
The Federal Student Aid Handbook defines hazing as any intentional, knowing, or reckless act committed against a person, regardless of that person's willingness to participate, that occurs in connection with initiation into, affiliation with, or maintenance of membership in a student organization, and that causes or creates a risk of physical or psychological injury above the reasonable risk encountered at the institution or in the organization.
What it means for institutions
First-year numbers will receive attention they have not received before, from families, journalists, and eventually program reviewers. They will also sit next to the Transparency Report, which is built from a different data stream. The ASR counts reports made to campus security authorities and police. The Transparency Report reflects findings of responsibility against organizations. The two will rarely match, and that is expected, but an institution should be able to explain why they differ.
What compliance leaders should review this week
- Confirm that the hazing table counts incidents, not victims or participants, and that each counted incident falls within Clery geography.
- Reconcile the ASR count against the Transparency Report and against student conduct records. Document the reason for each difference.
- Confirm that the hazing policy statement in the ASR matches the policy the institution actually adopted, including reporting avenues, the investigation process, and the prevention programs described.
- Confirm that the prevention programming described in the ASR actually occurred and that you can produce attendance or delivery records.
- Write a short methodology memo covering how incidents were identified, classified, and counted, and who made close calls. File it with your ASR records.
- Confirm distribution. The October 1 obligation is to distribute the report to students and employees, not only to post it.
What remains uncertain
- Which years appear in the first table. The FSA Handbook describes Clery statistics for the three most recent calendar years, while the statute required hazing data collection to begin January 1, 2025. We have not found a Department statement on how the first hazing table should treat 2023 and 2024. Whatever approach your institution takes, state it in a footnote to the table and in the methodology memo.
- Overlap with other categories. The Handbook chapter does not address how to handle an incident that is both hazing and another Clery crime, such as an aggravated assault. Document the classification decision and apply it consistently.
- Review practice. How the Department will examine first-year hazing statistics in program reviews is not yet known. Contemporaneous documentation is the best available protection.