1 Highe Education Cente fo Alcohol and Othe Dug Abuse and Violence Pevention Education Development Cente, Inc. 55 Chapel Steet Newton, MA COMPLYING WITH THE DRUG-FREE SCHOOLS AND CAMPUSES REGULATIONS U.S. Depatment of Education [EDGAR Pat 86] A Guide fo Univesity and College Administatos
3 Complying With the Dug-Fee Schools and Campuses Regulations [EDGAR Pat 86] A Guide fo Univesity and College Administatos Revised by Beth DeRicco, Ph.D., CPP-R A publication of the Highe Education Cente fo Alcohol and Othe Dug Abuse and Violence Pevention Funded by the U.S. Depatment of Education
4 This publication was funded by the Office of Safe and Dug-Fee Schools at the U.S. Depatment of Education unde contact numbe ED-04-CO-0137 with Education Development Cente, Inc. The contacting office s epesentative was Richad Lucey, J. The content of this publication does not necessaily eflect the views o policies of the U.S. Depatment of Education, no does the mention of tade names, commecial poducts o oganizations imply endosement by the U.S. govenment. This publication also contains hypelinks and URLs fo infomation ceated and maintained by pivate oganizations. This infomation is povided fo the eade s convenience. The U.S. Depatment of Education is not esponsible fo contolling o guaanteeing the accuacy, elevance, timeliness, o completeness of this outside infomation. Futhe, the inclusion of infomation o a hypelink o URL does not eflect the impotance of the oganization, no is it intended to endose any views expessed, o poducts o sevices offeed. U.S. Depatment of Education Magaet Spellings Secetay Office of Safe and Dug-Fee Schools Deboah A. Pice Assistant Deputy Secetay Fist pinted Mach 1997 Repinted July 2006 This publication is in the public domain. Authoization to epoduce it in whole o in pat is ganted. While pemission to epint this publication is not necessay, the citation should be: U.S. Depatment of Education, Office of Safe and Dug-Fee Schools, Highe Education Cente fo Alcohol and Othe Dug Abuse and Violence Pevention, Complying With the Dug-Fee Schools and Campuses Regulations [EDGAR Pat 86]: A Guide fo Univesity and College Administatos, Washington, D.C., To ode copies of this publication, wite to: The Highe Education Cente fo Alcohol and Othe Dug Abuse and Violence Pevention Education Development Cente, Inc. 55 Chapel Steet Newton, MA ; TDD Relay-Fiendly, Dial 711 Fax: This publication is also available on the following Web site: U.S. Depatment of Education s Highe Education Cente fo Alcohol and Othe Dug Abuse and Violence Pevention at Layout by Hemali Patel, Ceative Sevices, EDC ii
5 Contents Acknowledgments...iv Pupose of the Guide...1 Executive Summay...3 CHAPTER 1. Intoduction...5 Cetification Requiements...5 Requiement to Comply With the Dug-Fee Schools and Campuses Regulations...6 Othe Legal Requiements...6 CHAPTER 2. Annual Notification...7 Distibution of the Annual Notification...9 Distibution to Students...9 Distibution to Employees...10 CHAPTER 3. The Biennial Review...13 Content and Fomat...13 Reviewing the AOD Pevention Pogam...14 Pepaing the Biennial Review and Repot...15 Contents of the Biennial Review Repot...15 Measuing Enfocement Consistency...19 Measuing Policy and Pogam Effectiveness...19 Illustations Fom Selected Biennial Reviews...22 Notes...25 Resouces...29 Appendices...31 Appendix 1: EDGAR Pat 86 Contents and Subpats A Geneal, B, and D...32 Appendix 2: Pat 86 Compliance Checklist...42 Appendix 3: Fedeal Tafficking Penalties...45 Appendix 4: Univesity of Geogia: Policy on Alcohol and Othe Dugs...46 Appendix 5: Stategic Objectives and Tactics Focused on Envionmental Change...47 Appendix 6: Supplemental Checklist...50 iii
6 Acknowledgments We wish to thank the individuals listed below fo eviewing daft manuscipts of this publication. We appeciate the comments they povided to help us assue that this publication has a solid scientific foundation and contains clea messages. To the extent that we achieved that goal, the cedit is theis. To the extent we did not, the fault is ous. Julie Banes, Univesity of Nothen Iowa Diane Bety, Austin Peay State Univesity, Tennessee Heathe Dunn Calton, Califonia State Univesity, Sacamento Deb Walke, Nothen State Univesity, South Dakota This vesion of Complying With the Dug-Fee Schools and Campuses Regulations [EDGAR Pat 86]: A Guide fo Univesity and College Administatos is a evision by Beth DeRicco of the ealie vesion that was pepaed in 1997 by T. Pittayathikhun; R. Ku; D. Rigby; M. Mattsson; and W. DeJong. iv
7 Pupose Pupose of the Guide This guide descibes the equiements of the 1989 amendments to the Dug-Fee Schools and Communities Act (DFSCA), as aticulated in the Education Depatment Geneal Administative Regulations (EDGAR) Pat 86, 1 the Dug- Fee Schools and Campuses Regulations* and ways in which institutions of highe education (IHEs) have met these equiements. Pat 86 petains to Dug and Alcohol Abuse Pevention. This guide is designed to suppot pesonnel esponsible fo peventing the illegal use of alcohol and othe dugs (AOD) on campus, especially staff designated as AOD pevention coodinatos and those in student affais, esidential life, health sevices, and campus secuity. Senio administatos, including pesidents, deans, and legal counsel, also may find this guide a valuable esouce. The pupose and goals of the DFSCA ae not new ideas fo the nation s IHEs. Recognizing the seious effects of AOD abuse on the academic pefomance and, moe geneally, on the well-being of thei students, many IHEs adopted pevention measues well befoe the passage of the Dug-Fee Schools and Communities Act. In the yeas since compliance with Pat 86 became mandatoy, 2 IHEs have gained significant expeience designing, developing, and implementing AOD pevention pogams. An impotant aspect of the DFSCA is the equiement that campuses closely examine thei pevention pogam on a biennial basis. The biennial eview is designed to document an IHE s pevention effots. A eview that looks at the scope and effectiveness of a campus pevention pogam is citical to ceating a compehensive effot and complying with the egulations. Complying with the spiit and not just the lette of the law suppots IHEs in thei AOD pevention effots and povides significant benefits and oppotunities fo the entie institution and its students. An impotant aspect of the DFSCA is the equiement that campuses closely examine thei pevention pogam on a biennial basis. Additionally, the 2002 epot by the National Institute on Alcohol Abuse and Alcoholism (NIAAA), A Call to Action: Changing the Cultue of Dinking at U.S. Colleges, 3 and the 2003 epot by the Institute of Medicine (IOM), Reducing Undeage Dinking: A Collective Responsibility, 4 indicate that compliance with Pat 86 will incease the likelihood of success in educing consequences of heavy episodic and illegal alcohol use. These epots ae an impotant complement to this publication and ae especially useful fo conducting a biennial eview. Reflecting on the NIAAA and IOM epots will help campuses identify gaps in thei evidence-based pactices and assist in making ecommendations fo futue pogammatic effots a necessay pat of evey biennial eview. Complying with the spiit and not just the lette of the law suppots IHEs in thei AOD pevention effots and povides significant benefits and oppotunities fo the entie institution and its students. * These egulations can be eviewed in the Fedeal Registe, Vol. 55, No. 159, Aug. 16, 1990, pp , o online at 1
8 Complying With the Dug-Fee Schools and Campuses Regulations This guide assists IHEs in impoving thei pevention pogams by looking at the Pat 86 equiements and how some IHEs have met them. The guide also is intended to help IHEs avoid ovelooking any aspects of Pat 86 equiements that might esult in noncompliance. The intoductoy chapte pesents the cetification equiements IHEs must meet unde the egulations and notes the consequences of failue to comply; it also povides infomation on meeting legal equiements not coveed unde Pat 86 egulations. The subsequent chaptes addess the two geneal equiements of the Pat 86 egulations. Chapte 2 outlines the equiements of the witten annual notification and descibes seveal fomats that IHEs have used to pesent infomation equied unde the egulations to thei students. Chapte 3 discusses the pepaation of biennial eviews and povides excepts fom epots of seveal IHEs. This guide assists IHEs in impoving thei pevention pogams by looking at the Pat 86 equiements and how some IHEs have met them. 2
9 Executive Summay Executive Summay The Dug-Fee Schools and Campuses Regulations (EDGAR Pat 86) lay out seveal equiements with which all IHEs eceiving any fom of fedeal funding must comply, one of which is a biennial eview. The egulations stuctue and fomat povide enough flexibility that a campus can tailo its biennial eview and epot to suit the paticula cicumstances of the campus and povide a spingboad fo a thoough eview, evaluation, and adaptation of its AOD pevention pogam. Regulation Requiements AOD Pevention Pogam. IHEs eceiving fedeal funds o financial assistance must develop and implement a pogam to pevent the unlawful possession, use, o distibution of illicit dugs and alcohol by students and employees. The pogam must include annual notification of the following: standads of conduct; a desciption of sanctions fo violating fedeal, state, and local law and campus policy; a desciption of health isks associated with AOD use; a desciption of teatment options; and a biennial eview of the pogam s effectiveness and the consistency of the enfocement of sanctions. Cetification. Fo cetain foms of fedeal funding o assistance, IHEs must cetify that they have an AOD pevention pogam; the cetification is included commonly in the Repesentations and Cetifications section of an application o poposal. Requiement to Comply. IHEs must povide a copy of thei biennial epot to the U.S. Depatment of Education o its epesentative on equest. The Secetay o his/ he designee may eview the epot and suppoting documentation as necessay and, whee an IHE is noncompliant, may take action anging fom poviding technical assistance to help the campus come into compliance to teminating all foms of fedeal financial assistance. Othe Legal Obligations. IHEs also may be subject to elated equiements unde state and fedeal law and judicial ulings. IHEs should seek advice on this point fom the institution s geneal counsel o othe elevant national esouces. Annual Notification To comply with the Pat 86 egulations, IHEs must notify all students and employees annually of cetain infomation. The notification must include the following: (1) standads of conduct; (2) possible legal sanctions and penalties; (3) statements of the health isks associated with AOD abuse; (4) the IHE s AOD pogams available to students, staff, and faculty; and (5) disciplinay sanctions fo violations of the standads of conduct. IHEs must make the notification in witing and in a manne that ensues all students and employees eceive it. Biennial Review Content of Review. To comply with the egulations, evey two yeas an IHE must conduct a eview of its AOD pogam to detemine effectiveness and the consistency of sanction enfocement, in ode to identify and implement any necessay changes. The Depatment of Education ecommends that IHEs conduct the biennial eview in even-numbeed yeas and focus thei epot on the two peceding academic yeas. 3
10 Complying With the Dug-Fee Schools and Campuses Regulations Fomat of Repot. The egulations do not specify how IHEs must conduct thei eviews o how they should stuctue thei epots. IHEs theefoe have leeway to conduct thei eviews in ways that best meet the needs and cicumstances of thei campuses. Many campuses that have conducted successful and poductive biennial eviews have included pogam inventoies, policy inventoies, and enfocement analyses. Thei epots have included suppoting documentation fo each of these categoies, such as desciptions o copies of the pogams and policies, pocedues fo annual notifications, and desciptions of and suppoting documentation fo the means of assessing pogam effectiveness and enfocement consistency. Campuses often call togethe a boad-based task foce o committee to conduct this eview.
11 Intoduction Chapte 1 Intoduction Cetification Requiements The Pat 86 egulations equie that, as a condition of eceiving funds o any othe fom of financial assistance unde any fedeal pogam, an institution of highe education (IHE) 5 must cetify that it has adopted and implemented a pogam to pevent the unlawful possession, use, o distibution of illicit dugs and alcohol by students and employees 6 both on the institution s pemises and as pat of any of its activities, in ode to comply with the Dug-Fee Schools and Campuses Regulations (EDGAR Pat , Subpat B). When applying fo fedeal assistance, IHEs cetify to the existence of such pogams, typically as pat of a standad gant o contact application unde the povisions efeed to as Reps and Cets (Repesentations and Cetifications). Additionally, Subpat B indicates that IHEs must etain all ecods elated to DFSCA compliance fo thee yeas (see EDGAR Pat 86 Contents and Subpats A Geneal, B, and D in appendix 1). Ceating a pogam that complies with the egulations equies an IHE to do the following: Annually notify each employee and student, in witing, of standads of conduct; a desciption of appopiate sanctions fo violation of fedeal, state, and local law and campus policy; a desciption of health isks associated with AOD use; and a desciption of available teatment pogams. Develop a sound method fo distibuting annual notification infomation to evey student and staff membe each yea. 3. Pepae a biennial epot on the effectiveness of its AOD pogams and the consistency of sanction enfocement. A checklist adapted fom the DFSCA egulations designed to help IHEs detemine thei compliance with Pat 86 appeas in appendix 2. The Dug-Fee Schools and Campuses Regulations establish a set of minimum equiements fo campus substance use pogams. 7 Colleges and univesities may have additional obligations unde state law. Also impotant may be ecent cout decisions in lawsuits bought against IHEs by college and univesity students and employees 8 and the way in which these decisions might affect pevention pogams and policies. Consultation with an attoney knowledgeable in this aea is highly ecommended. Additional esouces may be povided by the Council on Law in Highe Education and the National Association of College and Univesity Attoneys. When applying fo fedeal assistance, IHEs cetify to the existence of such pogams, typically as pat of a standad gant o contact application unde the povisions efeed to as Reps and Cets (Repesentations and Cetifications).
12 Complying With the Dug-Fee Schools and Campuses Regulations Requiement to Comply With the Dug-Fee Schools and Campuses Regulations Accoding to the Pat 86 egulations, if an IHE fails to submit the necessay cetification when equested to do so o violates its cetification, the Secetay of Education may teminate all foms of financial assistance, whethe fom the Depatment of Education o othe fedeal agencies, and may equie epayment of such assistance, including individual students fedeal gants, such as Pell gants. 9 The Depatment of Education also may aange to povide technical assistance towad the development of a plan and ageement that bings the IHE into full compliance as soon as is feasible. 10 The possibility of loss of fedeal funding exists in the povision that [t]he Secetay annually eviews a epesentative sample of IHE dug pevention pogams. 11 If the Secetay of Education selects an IHE fo eview, the IHE shall povide the Secetay access to pesonnel ecods, documents, and any othe necessay infomation equested fo this eview. 12 Bickel and Lake have witten a thoough examination of case law elated to AOD issues in thei book The Rights and Responsibilities of the Moden Univesity. 13 A numbe of cout ulings have made clea that, while colleges and univesities cannot be expected to contol student conduct, they must ensue that thei activities, offeings, and pogams meet minimum standads of cae, and they must take steps to deal with dangeous situations on campus. Othe Legal Requiements Some campus administatos mistakenly believe that Pat 86 alone is what defines thei legal esponsibilities in AOD pevention. In fact, Pat 86 pesents only one aspect of the legal landscape. Equally impotant ae ecent judicial ulings in negligence suits against colleges and univesities. A numbe of cout ulings have made clea that, while colleges and univesities cannot be expected to contol student conduct, they must ensue that thei activities, offeings, and pogams meet minimum standads of cae, and they must take steps to deal with dangeous situations on campus. In shot, colleges and univesities have the same esponsibilities as othe popety ownes. Meeting these equiements means having clea ules and a standad of fim and consistent enfocement. Stetson College law pofessos 6
13 Annual Notification Chapte 2 Annual Notification A list of dug and alcohol pogams (counseling, teatment, ehabilitation, and e-enty) that ae available to employees o students A clea statement that the IHE will impose disciplinay sanctions on students and employees fo violations of the standads of conduct and a desciption of those sanctions, up to and including expulsion o temination of employment and efeal fo posecution 15 The Dug-Fee Schools and Communities Act and the U.S. Depatment of Education s suppoting egulations equie that IHEs adopt and implement pogams to pevent the unlawful possession, use, o distibution of illicit dugs and alcohol by all students and employees on school pemises o as pat of any of its activities (EDGAR Pat 86 Subpat A 86.3). The egulations contain specific ecommendations fo the content of an IHE s witten notification and specify the items that the annual notification to students and employees must compise. 14 The annual notification must include the following: The egulations contain specific ecommendations fo the content of an IHE s witten notification and specify the items that the annual notification to students and employees must compise. Standads of conduct that clealy pohibit, at a minimum, the unlawful possession, use, o distibution of illicit dugs and alcohol by students and employees A list of applicable legal sanctions unde fedeal, state, o local laws fo the unlawful possession o distibution of illicit dugs and alcohol A desciption of the health isks associated with the abuse of alcohol o use of illicit dugs IHEs have fulfilled the annual notification equiements in a numbe of diffeent ways, depending on thei campus envionment, available esouces, and ceativity. Many campuses incopoate the annual notification items into a campus AOD policy and distibute that policy as pe the equiements. Each of the equiements is discussed in the section that follows. Many campuses incopoate the annual notification items into a campus AOD policy and distibute that policy as pe the equiements. 1. Standads of Conduct Standads of conduct ae boad statements that goven the behavio of students, staff, and faculty as membes of the IHE community. Standads may ange fom statements that simply pohibit illegal activities elated to alcohol and othe dugs o they may eflect moe specific expectations established by the IHE. Accoding to EDGAR Subpat B , the standads of conduct should apply to all students who ae egisteed at an IHE fo at least one couse fo any type of cedit, except fo continuing education units. Students who hold pat-time jobs within the institution ae coveed by both student and employee policies. At some campuses, students woking as employees ae coveed while on duty unde the employee policy; othewise, they ae coveed unde the student policy.
14 Complying With the Dug-Fee Schools and Campuses Regulations An IHE s standads of conduct also apply to all oncampus activities and to off-campus activities that ae consideed to be sponsoed by the institution, such as officially sanctioned field tips. 16 The standads of conduct also have been intepeted to apply to student-sponsoed social activities o pofessional meetings attended by employees, if these activities o meetings ae consideed IHE-sponsoed activities. If a fatenity o sooity is ecognized by an IHE, then its activities may be consideed to be activities of the IHE and may be coveed by its standads of conduct, even if the fatenity o sooity is located off campus Legal Sanctions Appendix 3 of this guide contains a desciption of fedeal penalties and sanctions fo illegal tafficking and possession of a contolled substance (the desciption appeas in appendix A of the Fedeal Registe announcement of the Dug-Fee Schools and Campuses Regulations). This epesents the minimum level of infomation about fedeal laws that IHEs must povide to students and employees in ode to comply with the egulations. IHEs also must include in thei policies a copy o summay of the elevant sections of thei state penal codes and local odinances dealing with illegal substances, including sanctions fo policy violations. An AOD policy should stipulate that a student o employee who violates the AOD policy is subject both to the institution s sanctions and to ciminal sanctions povided by fedeal, state, and local law. The egulations do not equie any paticula appoach fo including this infomation in an IHE s policy. Many IHEs use a chat to pesent a summay of fedeal, state, and local laws and sanctions. Othes use a combination of styles as may be effective fo thei campus audiences. 3. Health Risks The egulations also equie campuses, as pat of thei pevention pogams, to distibute infomation about the health isks associated with alcohol abuse and illicit dug use (EDGAR Subpat B ). IHEs should focus on shaing infomation about substances coveed by the Contolled Substances Act (21 U.S.C. 811). A publication such as the U.S. Depatment of Justice s Dugs of Abuse 18 can be used to guide campus pesonnel in disseminating infomation about health isks associated with AOD use. Some policy statements summaize health isks in the fom of a chat. Some campuses have used a chat that shows, fo each pohibited class of substances (nacotics, depessants, stimulants, hallucinogens, cannabis, alcohol, and tobacco), the following: An AOD policy should stipulate that a student o employee who violates the AOD policy is subject both to the institution s sanctions and to ciminal sanctions povided by fedeal, state, and local law. The isk of dependence Possible shot-tem effects Possible long-tem effects The effects of ovedose Othe campuses may include the health isks potion of thei policy as a desciptive paagaph and a chat. The Univesity of Geogia descibes the health isks of alcohol in a clea, easy-to-ead fomat. The naative uses nontechnical language to descibe the effects and possible isks of using alcohol (see appendix 4). 8
15 Annual Notification 4. Dug and Alcohol Pogams Pat 86 equies, at a minimum, that IHEs include in thei annual notification a desciption of alcohol and othe dug pogams (pevention, counseling, teatment, ehabilitation, and e-enty) available to students, staff, and faculty Disciplinay Sanctions The egulations futhe equie that the witten annual notification include a desciption of the ange of disciplinay sanctions an IHE may impose if the standads of conduct ae violated, plus an explicit statement that these sanctions will be imposed. 20 It should be noted that disciplinay sanctions that apply to faculty and staff may diffe fom one anothe depending on the tems set foth in union contacts. Responsibility fo the enfocement of standads of conduct is not mentioned explicitly in EDGAR Pat 86, but it is clea fom the egulations that IHE administatos ae esponsible fo enfocing the standads of conduct set foth in policy guidelines and othe documents and that they should do so consistently. 21 In most cases, this esponsibility is shaed among campus police o secuity pesonnel, health povides, college o student affais staff, faculty, and students (especially whee thee is a student hono code). It is impotant to emembe that a student disciplinay committee o othe judicial body at the IHE does not have the sole esponsibility fo imposing sanctions fo violations of the institution s policy on alcohol and othe dugs. Depending on the paticula campus, the housing office, academic depatments, athletics pogam, and othe depatments also can impose sanctions against students who violate thei specific AOD policies. Disciplinay sanctions that apply to faculty and staff may diffe fom one anothe depending on the tems set foth in union contacts. Distibution of the Annual Notification Pat 86 equies that each IHE distibute its AOD annual notification in witing. 22 Many campuses incopoate the items equied fo annual notification into a policy document. If new students enoll o new employees ae hied afte the annual distibution date, these students and employees also must eceive the mateials. Concening the obligation of IHEs to povide each student and employee with a copy of the IHE s annual notification, the Depatment of Education has stated that meely making the mateials available to those who wish to take them does not satisfy the equiements of the egulations, as that does not ensue distibution to evey student and employee. The IHE must descibe what it does to ensue distibution to all students and employees in ode to establish compliance with the egulations. Although many IHEs found it difficult at fist to distibute the policy to evey student, faculty, and staff membe each yea, with expeience they have found moe costefficient methods fo poducing and distibuting thei policies and fo encouaging students, faculty, and staff to ead them. One successful technique used with students has been to include the policy in mateials that the institution aleady distibutes and to which students often efe, such as egistation mateials, academic calendas, o class schedules. Some IHEs have established distibution systems in which students and employees must sign a statement attesting to thei having eceived the mateials, but that is not expessly equied by the egulations. Distibution to Students The U.S. mail system is a popula method fo ensuing distibution to all students. Accoding to the egulations, if an IHE uses mailing as a means of distibution and
16 Complying With the Dug-Fee Schools and Campuses Regulations the mailing to a paticula student is etuned, the IHE should use the method it nomally would to locate and delive a mailing to a paticula student unde those cicumstances. Lowe-cost options fo student distibution also can meet the equiement, such as distibuting the witten annual notification in equied classes and duing oientation and advising sessions; including it in the egistation packet each student eceives; enclosing it with invoices fo student financial accounts; o incopoating it into othe mateials (e.g., yealy calenda, schedule of classes, student handbook). IHEs inceasingly exploe electonic mail ( ) as anothe option when all students, faculty, and staff have access to IHE accounts. The Depatment of Education has not developed official policy on allowing electonic dissemination in fulfillment of the equiement that IHEs must distibute thei AOD annual notification in witing. That is not to say that colleges and univesities cannot use electonic dissemination, howeve; if they choose to do so, they must ensue they can povide easonable assuance to the Depatment (if audited) that this method of dissemination ensues distibution to all students and employees. Seveal campuses have found that a combination of distibution techniques woks best. Distibution to Employees One way to distibute the annual notification to employees is to enclose it once a yea with employees paychecks. Some IHEs enclose it with the annual W-2 fom, which eaches evey employee egadless of length of employment. Anothe option is to include the notification in annually distibuted faculty and staff handbooks. Giving the witten annual notification to employees only at the beginning of thei employment does not meet the equiement that it be distibuted annually. While the egulations do not place an affimative duty on IHEs to ensue that employees ead the mateials, in keeping with the spiit of the egulations, institutions should take steps to encouage employees to ead the policies (see sideba Stategies fo Engaging the Attention of Students and Employees on p. 11). The Depatment of Education has not developed official policy on allowing electonic dissemination in fulfillment of the equiement that IHEs must distibute thei AOD annual notification in witing. That is not to say that colleges and univesities cannot use electonic dissemination, howeve; if they choose to do so, they must ensue they can povide easonable assuance to the Depatment (if audited) that this method of dissemination ensues distibution to all students and employees. 10
17 Annual Notification Stategies fo Engaging the Attention of Students and Employees Ceate a Readable Policy. Policies that ae witten with an engaging (as opposed to a legalistic) style, use bulleted lists, and, if the budget allows, include appealing gaphics ae most likely to hold the inteest of students and employees. Distibute Policy Summaies. Some IHEs codify annual notification infomation in a campus AOD policy. One IHE, fo example, distibutes a thee-page lette annually to students. The lette summaizes the AOD policy, which incopoates the annual DFSCA notification and efes students to the student handbook fo complete infomation. Incopoate the Policy Into Fequently Read Documents. Expeienced administatos suggest that the policy has a bette chance of being ead if it is incopoated into othe documents that ae known to hold students inteest. Campuses have incopoated infomation into IHE-specific date books, calendas, and class schedules. Povide Incentives fo Reading the Policy. Some campuses employ a stategy to encouage students to ead the annual notification that takes advantage of the campus class egistation system. Annual notification infomation can be linked to telephone, online, and in-peson egistation. Fo example, befoe the egistation pocess begins, students might be asked if they have ead the univesity s annual notification on AOD use that was given to them with thei othe egistation mateials. If a student answes no, he o she is povided with an oppotunity to eview the infomation befoe egistation can poceed. This appoach povides a documented ecod of a student s affimation of having eceived the annual notification statement and ecods the student s avowal of having ead the mateial. Distibute the Policy as Widely as Possible. Some of the ways in which campuses addess wide distibution is though bochues; student, staff, and faculty handbooks and oientation mateials; mass mailings; postes in academic and esidential buildings; doo hanges in esidence halls; and flyes attached to paking pemits. One campus pinted thei policy that incopoates annual notification equiements in the fo-cedit class schedule. 11