As I have been preparing for the Biennial Review presentation that I will be delivering at the Illinois Higher Education Center’s June Affiliate meeting, it dawned on me that within a few weeks, we will actually be observing the 20th anniversary of the implementation of this act. Many may not recall or even know that during the summer of 1990, every college and university was required to send a certificate signed by their president to the Department of Education indicating that they indeed were meeting the letter of the law. Furthermore, the legislation requires annual distribution of alcohol and other drug policy to all staff and faculty on a yearly basis, as well as a biennial review of the alcohol and other drug prevention program each institution was required to certify that is had.
Since that time, enforcement of this mandate has been sparse. While the actual legislation indicates that the Secretary of Education will annually review a sample of Institution of Higher Education prevention programs, only on occasion has this occurred. Furthermore, should an institution fail to comply with the legislation, all federal funding could be lost, and in some cases previously provided funding could be required to be returned to the federal government. I have never heard of this sanction being enforced. The only time my biennial reviews have been audited have been when some external auditor reviewing financial aid wanted to know if we had written a report and how we distributed policy. A quick phone conversation has usually been sufficient to move the auditor on to his or her next set of queries.
I must admit that in the past I have had some ambivalence regarding this unfunded mandate. I’ve always thought that the amount of time and resources devoted to complying with the regulations could be better spent on other endeavors. Students, staff, and faculty seldom read the written policy document, now available on-line through our university on-line registration and information program. As an information only approach, I know that it does not meet an evidence-based approach at changing behavior. Yet it must be done, and several hours and days each year are spent reviewing, revising, and updating.
Furthermore, trying to collect program descriptions, utilization statistics from these programs, as well as any outcome data (if any even exists) to conduct a review of the comprehensive ATOD program that the various parts of the university employ has been a challenge. While the recommendation is to enact a committee to review such data, getting data is difficult enough, much less getting folks together to review and comment seems unattainable. Once the report is written, I provide it to the various offices which should have a copy in the case some (most likely an auditor) need to see it. I often wonder if anyone else has actually read the document.
As I continue to prepare my presentation for this Friday, I continue to think about statements made at last week’s NASPA Assessment conference. There are multiple reasons for assessment that go beyond doing it because the accreditors require us to assess programs; we should assess programs because that is how we improve our practice and that is how organizations learn. My past attitude toward the Drug Free and Schools and Campuses Act’s Biennial Review: was wrong. Instead of looking at it as something being forced down my neck that seldom did anyone else care about as long as I was taking care of it, I should have been looking at the biennial review process as an opportunity to better serve our students and institutions, improve our practice, and help our organizations learn. I hope that others will join me in this view and look forward to conducting their biennial review with enthusiasm!
Eric S. Davidson
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