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The law firm Cozen O’Connor released its full external review of California State University’s Title IX and Discrimination, Retaliation and Harassment (DHR) procedures yesterday, recommending a slew of reporting and adjudication changes that it estimates will cost the system about $25 million a year.

The firm detailed its preliminary findings in June, saying that while CSU had made efforts to improve and comply with the investigation, its Title IX complaint and adjudication processes were “insufficient” and “unreliable.”

The full report—which is over 1,600 pages, including the 236-page systemwide report and reports for each of the 23 campuses—goes into more detail, noting that the subjects interviewed about their experience with the Title IX process consistently expressed feelings of “institutional betrayal and grave disappointment in response to these incidents.”

The report found that “there is significant work to be done” to bring many of the campuses’ procedures up to the standards of the federal Clery Act and concluded that a “paradigm shift” was necessary at the system level to facilitate the distinct changes needed at each campus and ensure they are effective and consistent.

CSU leaders ordered the review after former chancellor Joseph Castro resigned over accusations that he mishandled a case of sexual misconduct involving a friend and colleague when he was president of Fresno State. The system was plagued by other scandals as well, including a case at Sonoma State University involving the then president’s husband and another at Chico State in which a professor was alleged to have threatened the lives of multiple colleagues after his affair with a student was discovered.

Last August, records reviewed by EdSource showed that between 2017 and 2021, the system found 54 cases of misconduct across 12 of its campuses.

In an interview with Inside Higher Ed last month, CSU interim chancellor Jolene Koester said she would take Cozen O’Connor’s recommendations to heart, however “uncomfortable and difficult to hear” they might be.

“This is not a box-checking exercise,” she said. “It’s important that the skepticism with which something like this might be met is responded to with commitment, resources and no equivocation from myself or any of our campus leaders.”