History
In 2023, the CSU Board of Trustees engaged the Cozen O'Connor Institutional Response Group to conduct a systemwide review assessing the effectiveness of the CSU in responding to discrimination, harassment, and retaliation (DHR), especially related to sex and gender. The goal was to improve CSU’s culture through an external review of current Title IX practices at each of the universities, as well as at a systemwide level.
In its assessments, Cozen found that some unprofessional behaviors at the CSU were not covered by policy and were not consistently addressed. At the same time, a state audit by the Joint Legislative Audit Committee (JLAC) also called for CSU-wide procedures to address inappropriate conduct that didn't meet the legal definition of harassment.
In response, the CSU gathered input from students, faculty, staff, and other stakeholders to create new guidelines to address conduct that, while disruptive and/or harmful, may not clearly violate university policy - behaviors now considered “other conduct of concern” (OCC).