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Biennial Drug & Alcohol Report Cincinnati College of Mortuary Science Biennial Report of Institutional Compliance with the Drug-Free Schools and Campuses Regulations Period of Review: July 2016 June 2018 GENERAL STATEMENT Committed to the success of each student, the Cincinnati College of Mortuary Science ( CCMS ) offers a rigorous curriculum which exceeds accreditation standards and prepares students to become some of the nation s leading funeral service professionals. CCMS adheres to the Drug-Free Schools and Communities Act Amendments of 1989. It will uphold all federal, state, and local laws regarding alcohol and other drugs. It will impose sanctions for violations of the standards of conduct that include all laws as well as student complicity in violations and conduct unbecoming a CCMS student. CCMS strictly prohibits alcohol usage on campus unless granted an exception to this rule by the President. CCMS DRUG POLICY CCMS adheres to the Drug-Free Schools and Communities Act Amendments of 1989. It will uphold all federal, state, and local laws regarding alcohol and other drugs. It will impose sanctions for violations of the standards of conduct that include all laws as well as student complicity in violations and conduct unbecoming a CCMS student. All students and employees are hereby notified that the unlawful manufacture, distribution, dispensing, possession or use of illicit drugs and alcohol is prohibited on CCMS Property, as is the possession of drug paraphernalia. Any student or employee must notify the school of any criminal drug and alcohol statute conviction no later than 5 days after such conviction. Employees must also comply with the Drug-Free Workplace, Drug, and Alcohol policies applicable to them.

Violation of Drug and Alcohol Policy Intoxication or Negative Behavior Involving Use of Drugs or Alcohol: Identification of a student presumed to be in violation of the Drug and Alcohol policy is based on observable behaviors that may indicate the presence or use of alcohol or drugs. Observable behavior includes but is not limited to: alcohol on the breath, cognitive impairment, slurred speech, motor incapacity, etc. The President or his/her designee is required to assume impairment and protect the safety and rights of others by having the individual vacate the CCMS campus if necessary. The student must then submit to drug testing at his/her expense. If the student s test comes back positive, the student must undergo counseling and/or treatment before returning to CCMS. Other penalties may include community service or suspension/termination of enrollment or employment. A student or employee may be suspended or dismissed for a single violation. Furthermore, additional penalties may be warranted. Other Violations of Drug and Alcohol Policy (manufacture, distribution, etc.): Depending on the situation, penalties could include counseling and/or treatment before returning to CCMS, community service, or suspension/termination of enrollment or employment. Other penalties may include community service or suspension/termination of enrollment or employment. A student or employee may be suspended or dismissed for a single violation. Furthermore, additional penalties may be warranted. Surgeon General Warning According to the Surgeon General, women who drink or take drugs during pregnancy risk birth defects. Consumption of drugs and alcohol impairs your ability to drive a car or operate machinery and may cause health problems such as memory impairment or lack of sound judgment. It could form grounds for termination of enrollment, loss of financial aid or employment. Alcohol Use and Effects Alcohol consumption can cause marked changes in behavior, even in low doses, which include the inability to drive, accidents, aggression, and abuse. High doses can lead to personality disorders, inability to learn, illness, and death. Repeated use of alcohol leads to dependence. Withdrawal can produce depression, anxiety, tremors, hallucinations, convulsions, and damage to major organs of the body. Mothers who drink during pregnancy may give birth to infants with fetal alcohol syndrome, including abnormalities and retardation. These children are also at risk for becoming alcoholics. Drug Use and Effects According to the National Institute on Drug Abuse, a variety of significant health risks are associated with the use of illicit drugs. Applicable Laws 1. CCMS will uphold all federal, state and local laws regarding alcohol and other drugs. The following excerpts are from federal and State of Ohio laws regarding 2

the unlawful possession, use, or distribution of illicit drugs, including alcohol, are not all-inclusive, may not read in the exact manner of the laws, and are not to be relied upon as legal advice or guidance. 2. Persons under the age of 21 who pay for, share the cost of, or attempt to purchase, or possess or consume beer or intoxicating liquor in any public place either from a sealed or unsealed container or by the glass or by the drink, or furnish false information as to name, age or other identification, are subject to a fine of up to $1,000 dollars and imprisonment of up to 6 months. 3. Persons shall not knowingly furnish false information as to the name, age, or other identification of any person under 21 years of age for the purpose of obtaining alcoholic beverages. 4. No person under 21 shall knowingly show or give false information for the purpose of obtaining or purchasing alcoholic beverages. 5. No person shall manufacture, sell, or distribute identification cards for the purpose of establishing a person's age that displays the great seal of the State of Ohio or in any way represents the card as the official Ohio card. 6. No person shall display or possess false identifications cards or operator's licenses, or lend such identification cards to any other person. 7. No person shall sell, buy, or furnish beer or intoxicating liquor to a person under the age of 21, unless for established religious purposes, or unless the person under 21 is accompanied by a parent, spouse, or legal guardian. 8. No person who is the owner or occupant of any public place shall knowingly allow anyone under 21 to remain in the place while possessing or consuming beer or intoxicating liquor unless given by the person's parent, spouse, or legal guardian. 9. No person shall consume intoxicating liquor in a motor vehicle. 10. No person shall drive a motor vehicle while under the influence of alcohol and/or any drug of abuse. 11. No person shall violate Open Container Laws of local city ordinances. Federal and State Penalties For Illegal Sale And Possession of A Controlled Substance Federal Law prohibits, among other things, the manufacturing, distributing, selling and possession of controlled substances as outlined in 21 U.S.C., 801 through 971. Depending on the amount, first offense maximum penalties for trafficking marijuana range from five years imprisonment and a fine of $250,000 to imprisonment for life and 3

a fine of $4,000,000. Depending on the amount of a first offense, maximum penalties for trafficking other controlled substances (e.g., methamphetamine, heroin, cocaine, cocaine base, PSD, LSD, fentanyl and fentanyl analogue, range from five years to life imprisonment and fines from $2,000,000 to $4,000,000. First offense penalties for illegal possession of controlled substance range from up to one year in prison or a fine of at least $1,000. Under Ohio law, no person shall knowingly corrupt another with drugs by forcing them to use a controlled substance (penalty imprisonment from 6 months to 10 years). No person shall knowingly traffic in controlled or illicit substances, including marijuana (depending on drug, fine of $100 to $20,000 and jail sentence of 6 months to 10 years). No person shall knowingly obtain, possess, or use a controlled substance (fine from $100 to $15,000 and prison not more than 8 years for marijuana; fines up to $20,000 and jail terms up to 10 years for other drugs). No personal shall make, obtain, possess, or use drug abuse instruments (up to 90-day jail terms, fines of $750, and suspension of driver s license for six months to five years). No person shall knowingly use, possess with purpose to use, manufacture, or advertise drug paraphernalia (fine up to $1,000 and imprisonment up to six months). No person shall knowingly possess, make, sell or deliver counterfeit controlled substances (up to 180 days in jail and a $1,000 fine, but with aggravating circumstances, this will become a felony of the fourth degree with prison term of 6 to 18 months and fine up to $5,000). The City of Cincinnati and Springfield Township may also have laws that apply to drugs and alcohol. Addiction/Recovery Resources CCMS encourages students and employees to educate themselves, seek counseling, or seek treatment. The following are resources available to students and employees in the community: Ohio Behavioral Health Directory https://prod.ada.ohio.gov/directory/ Ohio Department of Mental Health and Addiction Services http://mha.ohio.gov/ Substance Abuse Treatment Facility Locator http://findtreatment.samhsa.gov/locator EVALUATION OF CURRENT PROGRAMS College Programs CCMS is a fully accredited institution offering two academic programs the Associate of Applied Science and Bachelor of Mortuary Science. Prior to matriculation at CCMS, applicants must complete prerequisite general education courses at the college level to satisfy the transfer credits necessary to enroll at CCMS. 4

Activities CCMS provides students the opportunity to immerse themselves in the academic programs. It offers limited activities for student involvement, including Alpha Tau Epsilon Fraternity, Delta Gamma Pi Sorority, Phi Theta Kappa (PTK) Honor Society, Student Council, and Study Groups. There are no on-campus residential facilities. The fraternity is inactive. The sorority is self-governing. College Security CCMS s campus is located in Cincinnati, Ohio, where the Springfield Township Police Department provides services. The officers patrol the campus and surrounding areas regularly. The Springfield Township Police are fully commissioned officers by the governor of the state of Ohio. The officers have full arrest powers and are armed. They have the authority to ask persons for identification and to determine whether individuals have lawful business at the College. The Springfield Township Police can and do respond to student-related incidents that occur on campus. The Springfield Township Police have direct communication with the fire department and ambulance services to facilitate rapid response in any emergency situation. CCMS is equipped with a security system featuring cameras and a cloud-based storage system that allows administrators to access it remotely 24/7. The CCMS campus will be locked 24 hours per day, except for special events such as open house, graduation, etc. Each student, staff, and faculty member is issued an ID badge that is programmed to allow access to particular external and internal doors. Students and employees are required to wear their ID badges around their neck, on a lanyard, at all times during school hours and events, with the exception of during Clinical Lab/Gross Lab. Lost ID badges should be reported to the Chief Operating Officer immediately, and will be subject to a replacement fee. Visitors to CCMS will be buzzed in at the main external door, required to check-in, and will then be issued a visitor badge by a designated CCMS employee. The Chief Operating Officer for CCMS regularly monitors the maintenance of facilities, landscaping, and lighting on campus. All lights are on timers and employees are told to notify the Chief Operating Officer if any lights are out. Panic alarms are located throughout the interior of the facility. Recording cameras operate 24 hours a day, 7 days a week, and are located throughout the campus. CCMS does not have resident housing for students. 5

Counseling DRUG AND ALCOHOL CASES 2015-2016 2016-2017 2017-2018 Referrals or request for counseling for alcohol use Referrals or request for counseling for drug use Referred to outside treatment programs 0 0 0 0 0 0 0 0 0 TOTALS 0 0 0 Student Discipline Alcohol Other Substances 2016-2017 2017-2018 2016-2017 2017-2018 Disciplinary sanction 0 0 0 0 Suspended 0 0 0 0 TOTALS 0 0 0 0 6

Financial Aid CCMS is committed to compliance with all federal laws that impact its students' eligibility for financial aid, and it follows them as directed. Student ineligibility for Grants, Loans, or Work Assistance For possession of a controlled substance, ineligibility period is: For sale of a controlled substance, ineligibility period is: First conviction 1 year First conviction 2 years Second conviction 2 years Second conviction Indefinite Third conviction Indefinite GENERAL ASSESSMENT CCMS fosters a drug and alcohol free environment. RECOMMENDATIONS RECOMMENDATION: CCMS will continue efforts to include drug and alcohol prevention principles during orientation. RECOMMENDATION: Monitor industry-relevant reports relative to drug and alcohol use and perceptions on college campuses, and determine whether such should prompt surveys and data collection concerning the same on CCMS s campus. RECOMMENDATION: Continue maintaining the Student Handbook to provide information in critical areas. 7

CERTIFICATION OF REVIEW PROCESS Under The Drug-Free Schools and Campuses Act, during September 2018, CCMS reviewed the strengths and weaknesses of the programs in place at CCMS and to ensure college compliance with the Drug-Free Schools and Communities Act and Amendment, 1989/Drug-Free Workplace Act, 1988. The review of policy documents noted the following: 1. CCMS appears to be in compliance with the Act, and has an adequate policy in place. 2. The college distributes its alcohol and drug policy and to all employees and students via the handbook upon enrollment. 3. The biennial review of college drug prevention programs and policy is now conducted at the conclusion of each biennial period. This report covers July 1, 2016 through June 30, 2018 (fiscal calendar end). The review is designed to ensure effectiveness of the policy and the programs which are in place as well as to recommend measures which can be implemented to ensure that the programs are effective. 4. The review process evaluated disciplinary actions that have been taken during the biennial period for consistency with CCMS policy to ensure that sanctions are consistent and utilized. CCMS has had no reported issues. 5. CCMS tracks the number of drug and alcohol related offenses that occur on campus. Statistics would be gathered without disclosing the names of those involved in compliance with the students FERPA rights. 6. The President has reviewed and signed this report. This report reflects an accurate review of the policies, programs, and review process in effect at CCMS for the review period July 1, 2016 through June 30, 2018. 8

CERTIFICATION OF ADOPTION AND ACCEPTANCE The President supports the drug and alcohol policies of CCMS and encourages employees and students who may have difficulties with these issues to seek assistance through appropriate channels. By: President Printed Name Date 9

Compliance Checklist Drug-Free Schools and Campuses Regulations Compliance Checklist taken, in part, from Complying with the Drug-Free Schools and Campuses Regulations [34 CFR Part 86], a publication of the Higher Education Center for Alcohol and Other Drug Prevention, funded by the U.S. Department of Education. 1. Does the institution main a copy of its drug prevention program? Yes X No If yes, where is it located? At CCMS, the drug prevention program is maintained in the Student Handbook, both in electronic and physical form. 2. Does the institution provide annually to each employee and each student, who is taking one or more classes for any type of academic credit except for continuing education units, written materials that adequately describe and contain the following? a) Standards of conduct that prohibit unlawful possession, use, or distribution of illicit drugs and alcohol on its property or as a part of its activities. Students: Yes X No Staff and Faculty: Yes X No b) A description of the health risks associated with the use of illicit drugs and the abuse of alcohol. Students: Yes X No Staff and Faculty: Yes X No c) A description of the applicable legal sanctions under local, state, or federal law. Students: Yes X No Staff and Faculty: Yes X No d) A description of applicable counseling, treatment or rehabilitation or re-entry programs. Students: Yes X No Staff and Faculty: Yes X No e) A clear statement of the disciplinary sanctions the institution will impose on students and employee, and a description of those sanctions. Students: Yes X No Staff and Faculty: Yes X No This Biennial Report is posted on the CCMS web site by going to https://www.ccms.edu/drugs-alcohol/. It is also available in physical form at the reception desk 3. Are the above materials distributed to students on one of the following ways: 10

a) Mailed to each student (separately or included in another mailing) Yes X (electronically) No b) Through campus post office boxes Yes No X c) Class schedules which are mailed to each student Yes No X d) During orientation Yes X No e) Do the means of distribution provide adequate assurance that each student receives the materials annually? Yes X No 4. Are the above materials distributed to staff and faculty in one of the following ways? a) Mailed Staff: Yes X (electronically) No Faculty: Yes X (electronically) No b) Through campus post office boxes Staff: Yes No X Faculty: Yes No X c) During new employee orientation Staff: Yes X No Faculty: Yes X No 5. Does the means of distribution provide adequate assurance that each staff and faculty member receives the materials annually: Staff: Yes X No Faculty: Yes X No 11

6. Does the institution s distribution plan make provisions for providing these materials to staff and faculty who are hired after the initial distribution? Staff: Yes X No Faculty: Yes X No 7. In what ways does the institution conduct biennial reviews of its drug prevention program to determine effectiveness, implement necessary changes, and ensure that disciplinary sanctions are enforced? CCMS reviews each drug and alcohol case at all steps of the discipline process to ensure continuity of action and to provide a broad base of input in the decision-making process. 8. Who is responsible for conducting these biennial reviews? CCMS s President designates the parties responsible for the biennial review. During the 2016-2018 review period the committee included the Vice President, President, and outside general counsel. 9. If requested, has the institution made available, to the Secretary and the public, a copy of each requested item in the drug prevention program and the results of the biennial review? 10. Comments Yes No X CCMS is committed to a zero tolerance of alcohol and drug use and, while it has had no incidents of such use, it is committed to taking steps help both students and employees comply with their commitments. Disciplinary sanctions are spelled out well, and efforts are made to assist those who seek help to change their behavior. Annual statistics have not varied. CCMS is not satisfied with any alcohol or other drug use in light of its policies. E: Compliance/Drugs & Alcohol/Biennial Drug & Alcohol Report/2018 Published 20180920 23494628.1 12