Office of Equity and Compliance

CSU Systemwide Assessment

The CSU engaged Cozen O'Connor’s Institutional Response Group (Cozen) to conduct a systemwide assessment of its Title IX and DHR programs. The CSU Systemwide Title IX and discrimination, harassment and retaliationm (DHR) Assessment by Cozen is designed to strengthen the CSU institutional culture by assessing current practices at the Chancellor’s Office (system-level) and at each CSU Campus and providing insights, recommendations, and resources to advance CSU’s Title IX and DHR training, awareness, prevention, intervention, compliance and support systems. This assessment specifically included a comprehensive analysis of Cal Poly Pomona’s Title IX and DHR programs and provided information on program strengths and opportunities.

The following individuals have been charged by the President to help develop, plan and execute the recommendations of Cozen’s assessment of Cal Poly Pomona’s Title IX/DHR programs.

Dawnita Franklin, Co-Chair, Assistant Vice President and Title IX/DHR Administrator
Nicole Hawkes, Co-Chair, Vice President and Chief of Staff, Office of the President
Kimberly Allain, Senior Associate Vice President, Employee & Organizational Development and Advancement
Robert Almand, Director of Executive Communications
Andrea Cunanan, Student (third year), Psychology and History
Rhonda Dixon, Senior Coordinator and Advocate, Survivor Advocacy Services
Chelsea Epps, CPP Campus Counsel
Dr. Jill Hargis, Interim Associate Vice President for Faculty Affairs
Yasmin Iltchi, Director, Employee/Labor Relations & Compliance
Hallie Lewis, Interim Associate Vice President for Student Health and Wellbeing
John McGuthry, Vice President & Chief Information Officer, Division of Information Technology & Institutional Planning
Emily Nunez, Student (third year), Sociology
Dr. Cindy Pickett, Presidential Associate for Inclusion and Chief Diversity Officer
Weston Prisbrey, Interim Assistant Dean for Student Health & Wellbeing
Dr. Bharti Sharma, Associate Professor, Biological Science, College of Science
George Tejadilla, Executive Director of Academic Personnel

At its meeting yesterday, the CSU Board of Trustees received the initial report of findings from the CSU Systemwide Title IX and Discrimination, Harassment and Retaliation (DHR) Assessment conducted by Cozen O’Connor’s Institutional Response Group. The report describes the process, findings and recommendations regarding programming and services at the system level (Chancellor’s Office) and at all 23 CSU campuses. The complete and final report — including campus-specific findings and recommendations — is expected to be released in June.    

CSU Assessment Themes 

As the co-chairs of the Cal Poly Pomona Implementation Team, charged by President Soraya M. Coley with the responsibility for designing and planning the steps to implement the recommendations, we provide a summary of the report here. There are five core themes that apply systemwide:   

1.    Invest in Institutional Infrastructure – The report states institutional infrastructure needs increased investment to better support the Title IX/DHR function, including appropriate levels of trained professional staff and consistent documentation and recordkeeping.  

2.    Enhance Proactive Prevention Education – The report recommends enhanced, proactive prevention education and training for campus communities regarding sexual misconduct and discrimination, harassment and retaliation based on protected class.  

3.    Insufficient Processes to Address Other Conduct of Concern – The report identifies a lack of internal coordination and consistent accountability regarding institutional responses to conduct that failed to rise to the level of a policy violation based on protected class (i.e., “Below the Bar Behaviors”).  

4.    Distrust of Senior Leadership – The report notes distrust of senior leadership and compliance processes exist across most campuses. In several cases, distrust stems from incidents involving leaders at the highest level of the CSU system.  

5.    Lack of Accountability – The report outlines a need for improvement in accountability among individual actors and Title IX and DHR programs. Factors that contribute to lack of accountability include distrust in leadership, underreporting, the percentage of cases investigated and protracted disciplinary processes. 

CPP’s Improvement Efforts and Next Steps 

These findings provide helpful direction for prioritizing our current and ongoing improvement efforts at CPP.  

An administrative working group focused on improving campus coordination of Title IX and DHR matters has been collaborating since fall 2022 to identify and resolve the process gaps between relevant administrative offices — including the Office of Equity and Compliance (OEC), Faculty Affairs and Employee/Labor Relations (ELR) — and to design more efficient and clear investigations, actions and resolutions. Through this effort, we have strengthened documentation protocols and accountability for misconduct through disciplinary procedures. We are also clarifying how stakeholders are communicated with during and after these processes. We are currently exploring new records management systems that will further strengthen institutional infrastructure and responsiveness.  

Earlier this month, President Coley announced an organizational restructuring with the formation of the People, Culture and Institutional Affairs unit to better align our people-centered functions and facilitate greater collaboration and transparency of processes and communication. This includes a plan to reestablish the Office of Conflict Resolution Services and Ombuds that will both provide reactive support and guidance for individuals and groups seeking assistance, as well as proactive training and capacity building for managing conflict.  

We are gratified by the high levels of participation among our campus community in the CSU Title IX/DHR assessment: we had the second highest response rate of all 23 campuses to the systemwide survey. This suggests a collective commitment to putting our institutional value of inclusion into practice, recognizing our need to strengthen our sexual misconduct prevention efforts, and collaborate to develop the knowledge and culture within our community. While we are proud of the culture of care demonstrated by our OEC and campus partners that was affirmed by the Cozen O’Connor team, we know that intentional efforts to enhance our capacity and development will further cultivate an environment of mutual respect and trust.       

The final Cozen O’Connor report and our own campus recommendations will be released this June. Our Implementation Team comprised of faculty, staff, students and administrators will immediately advance progress by developing, facilitating and supporting the CPP plan for improvement. This work will require a collective, accountable and decisive response, one that acknowledges our history yet points to a future where our institutional culture is forever changed. As the Implementation Team undertakes this work, we will keep the CPP community informed on the process and status through a range of communications including on the OEC website.   

As we move forward, we know that some of the recommendations are challenging and complex, influenced by a multitude of interconnected factors including long-held and deeply rooted distrust. The work will take time. It will take significant resources. It will require that we all work together to embrace change to our process, policies and most importantly to our culture. 

We look forward to sharing more information about our implementation plans in the coming months. If you have any questions, we invite you to contact the Office of Equity and Compliance at   


 Nicole Hawkes, Vice President, People, Culture and Institutional Affairs and Chief of Staff  

 Dawnita Franklin, Assistant Vice President and Title IX Coordinator/DHR Administrator