I don't think ND needs to scapegoat anyone. But it is their responsibility to make sure that the system contains safeguards against a situation like this.
I am concerned that there is no mea culpa here. The school needs to accept responsibility for providing an unsafe environment and make sure that a system is in place that prevents this ever happening again. They need to provide closure to the Sullivan family. Instead, they seem to figure that if they sling enough bullshit against the wall, it will all go away.
It won't go away, and all they are doing is making it worse for everyone involved. The bottom line is that ND is a lot better at talking about doing the right thing than actually doing it.