In the News

CSAJ Files Title IX Federal Comments

February 06, 2019

Our work across the country, rich partnerships, and the research lead us to the “inexorable conclusion: the Department’s proposed rule will only serve to jeopardize the financial security of survivors of sexual assault in educational environments. Changes under the proposed rule would, in effect: discourage the reporting of sexual assault; disable critical education staff from promptly, compassionately and effectively responding; disproportionately impact off-campus and non-traditional students by imposing different standards for reporting on and off campus harassment complaints –indeed requiring that schools ignore off-campus complaints; exacerbate the trauma and costs of sexual assault by limiting “supportive measures” to survivors; and will institute both a muddy and ineffective investigation process that goes against all evidence-based standards of trauma-informed investigations. These all have costs: financial and personhood costs to survivors, as well costs to educational institutions that the regulation fails to account for in its cost savings calculations.”

CSAJ explains how the proposed regulation would lead to survivors’ increased personal devastation from the “economic ripple effect” of violence, overlooks key costs to educational institutions, is an unprecedented use of federal regulations to dictate specific activities universities should undertake in investigating and adjudicating sexual harassment, and fails to effectuate Title IX’s anti-discrimination mandate by telling schools when they cannot protect students against sex discrimination.

Read our full comment here.