A sub-committee met several times during fall quarter 2011 to review and discuss policies and procedures in comparison to guidance about Title IX provided by U.S. Department of Education’s Office for Civil Rights (OCR). Committee members included Richard DeShields, Gail Farmer, Barbara Hodges, Susan Lonborg, Mike Luvera, Rhonda McKinney, and Staci Sleigh-Layman.
It was found, to be compliant, the university must:
- Identify a Title IX coordinator by name, address and telephone number;
- Distribute a nondiscrimination statement to all students and employees; and
- Adopt and publish grievance procedures and policies that ensure that prompt and equitable resolution of any complaints related to sexual harassment or violence.
The CWU Director of Equal Opportunity (Staci Sleigh-Layman) currently has responsibility as Title IX Coordinator. The committee recommends that this position be identified as the primary coordinator. Four other positions should be identified as supporting coordinators. These positions include:
- Associate Dean of Students (Richard DeShields)
- Director of Police Services (Mike Luvera)
- Assistant Athletic Director for Academics and Compliance (Gary Hyatt)
- Athletics, Senior Woman Administrator (Kari Gage)
Supporting coordinators will have responsibility for informing the primary coordinator of issues related to Title IX. Procedures will be established, by the primary coordinator, to ensure that the communication and collaboration between those with Title IX responsibility, as well as education about Title IX developments, occurs in structured ways.
A specific policy addressing Title IX has been drafted (attachment A). Although the general CWU nondiscrimination policy covers compliance with Title IX, recent compliance reviews at other higher education institutions have resulted in the creation of specific Title IX policies. The university’s nondiscrimination statement and this new Title IX policy will be distributed to students and employees on a regular basis. The statement will be made available in the following ways:
- An e-mail will be sent annually to the entire university community in September of each year.
- The entry screen of SAFARI (for faculty, staff, and students) will include notice of the Title IX policy once each year, at a different time than the annual e-mail.
- A Title IX website will be developed including information on Title IX, CWU policy, how to report sexual misconduct, questions and answers, suggestions for reducing risk both as a victim and as a person accused of sexual misconduct, and helpful links. See attachment C.
Staci Sleigh-Layman, Director, Equal Opportunity and Title IX Coordinator, is responsible for ensuring that these recommendations are in place no later than April 1, 2012.
The task force reviewed university policies and procedures with an eye toward Title IX compliance. A new Title IX policy has been drafted (Proposed CWUP 2-35-015 Title IX Policy: Discrimination on the Basis of Sex and Sexual Misconduct - attachment A). The task force also found that several policies need minor revisions in order to be compliant with Title IX. Revisions of the following policies are included in this report as attachment B:
- CWUP 2-35-070 Discrimination Complaint and Resolution Policy
- CWUR 1-30-050 Discrimination Complaint and Resolution Procedure – Employees
- CWUR 4-20-004 Student Discrimination Grievance Procedures (proposed CWUP number.)
Has been a student related procedure for years but hasn’t been formalized in the policy and procedure system
- CWUR 4-20-005.3 Student Consultation Team
- Chapter 106-210 WAC – Student Conduct Code
Others may be forthcoming and will be managed through the usual policy and procedure approval process.
In addition, policy and procedures regarding background checks and sex offenders will be reviewed to ensure that communication lines are solidly established and protocols clear.