Borrow Title IX Policies With Care

March 2014 | 0 Comments  Average 0 out of 5

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One size does not fit all when it comes to Title IX policies. If you borrow ideas from another institution, make sure they’re appropriate for your campus.

When developing a Title IX policy, be careful what you borrow. A policy that seems perfect at first glance may not be appropriate for your institution. For example, consider the recent media attention around the University of Akron in Ohio, which borrowed a Title IX policy and failed to edit it to remove a reference to a committee that didn’t exist at the university.

Policies and procedures differ so very much based on the size of your institution,” said Jody Shipper, executive director of equity and diversity and Title IX coordinator at the University of Southern California (USC) in Los Angeles. In her work with other organizations, Shipper finds that one of the greatest mistakes is failing to take into account the institution’s size, culture, and community.

For example, a small liberal arts college in need of a Title IX policy may find one online that seems to meet the requirements of the “Dear Colleague” letter (DCL) from the Office for Civil Rights (OCR) at the U.S. Department of Education.

“We all borrow from each other,” she said. “So you rewrite your policy, borrowing from the University of Michigan or Ohio State, someplace very big with an excellent policy. But you’re a tiny institution. What if you have a complicated hearing? You come up with a list of people who could serve on the hearing panel. If your policy gives each party the chance to strike a name, how many trained people do you have left who can serve?”

Another common problem for smaller colleges may arise after a hearing. If both parties remain at your institution, these students may have a professor who was on the review panel and heard their whole sexual assault case. That’s unfair to the students and faculty members, she said. Larger institutions with multiple schools and several undergraduate colleges have the luxury of drawing upon a broad range of candidates to participate in hearings, thus preventing conflicts that could arise with students and faculty.

Some institutions commit to unnecessary hearings, even when they are not required by state law or by the DCL, Shipper said. Some policies found online seem to imply that the institution expects students to develop a case, but that’s the institution’s responsibility. 

Also, some policies indicate that the hearing is a fact-finding tool. Such hearings could last a few days, which adds stress to the students, administrators, and faculty. Instead of using the hearing to decipher facts, institutions could use a well-trained investigator who comes to a conclusion, she said.


By Margo Vanover Porter, a freelance business and education writer in Virginia.

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