Feb 19, 2016 11:16 AM EST By Russell Westerholm, UniversityHerald Reporter

The Clery Act is a federal law that requires any college or university that receives federal money to report criminal complaints that take place on or near campus. In the realm of sexual misconduct, Title IX works in tandem with the Clery Act, requiring schools to adequately investigate sex crimes and provide support to complainants.

For campus sexual assault survivor advocates, the most resounding signal that a school is not compliant with these laws is when it reports zero incidents on an annual report.

Between the 2008 and 2011 academic years, Baylor University reported no sex crimes to the U.S. Education Department, The Associated Press learned from a data review. Baylor's sexual assault policies and practices have been called into question for high profile cases involving two football players: Tevin Elliott and Sam Ukwuachu.

McLennan County Assistant District Attorney Hilary LaBorde prosecuted both players' cases and both players were convicted of sexual assault. Ukwuachu allegedly raped a female student-athlete at Baylor in 2013 shortly after transferring from another school, while Elliott was convicted for a 2012 incident.

However, ESPN's Outside the Lines spoke to five women who accused Elliott of raping them between Oct. 2009 and April 2012. The women said they received inadequate support from Baylor administrators when they reported their rapes. OTL's report indicated the school did not properly conduct investigations into such complaints.

The AP compared Baylor's sex crime reports to two other private institutions in Texas: TCU and SMU, which reported 13 and 15 sexual assaults, respectively, from 2008 to 2011. Nationwide, only Wilmington University in New Castle, Del. reported no sexual assaults over that span.

From 2012 to 2014, Baylor reported 12 sexual assaults, whereas TCU reported 31 and SMU 16. The ED issued a "Dear Colleagues" letter to every college and university receiving federal money (just about all of them) in April 2011, reminding them of their responsibilities under Title IX and urging them to hire a Title IX Coordinator. OTL noted Baylor did not hire one until the fall 2014 semester.

The rise in sexual assault reports can be attributed to the Dear Colleagues letter and to the Obama Administration's campaigns to curb campus sexual assault, which has highlighted the statistic indicating one in every five women in college experience sexual assault. The ED is currently investigating more than 100 schools across the nation for Title IX complaints.

As one of those schools, Baylor recently announced it would implement "an administrative action plan" to improve its Title IX compliance. Whenever a school is under Title IX investigation, they conduct these kinds of reviews and reform their policies based on their findings.

"There's always a red flag that goes up when a school reports zero incidents," Neena Chaudhry, senior counsel for the National Women's Law Center, told The AP. "I don't think it's a good sign when you're not getting any reports because it's probably not true."

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