![]() The resolution agreement between OCR and the District requires expected elements, including designating and training a Title IX Coordinator, publishing a nondiscrimination statement, revising policies and procedures, reviewing complaints for a period of time and addressing inadequacies in their processing, and conducting training. Develop a procedure for documenting the date and substance of each report and any actions taken in response.Update your trainings to ensure they adequately explain your institution’s policies for handling complaints of sexual harassment.OCR found here that the District’s processing of complaints did not align with its policies. Your policies should say what you do, but then you need to do what they say. Review some cases and make sure they follow your policies.OCR found twenty-five separate policies addressing nondiscrimination, sexual harassment, sexual violence, and sexual misconduct, leading to difficulties in implementation and application. Streamline your policies to the extent appropriate, and ensure Title IX personnel understand which policies and procedures apply based on the parties involved and the conduct alleged.Here, the role “Anti-Harassment Compliance Officer” did not suffice for OCR. Use the title “Title IX Coordinator.” Even if the individual in that role has another broader title, such as Director of Nondiscrimination, add Title IX Coordinator to that title.There are a number of reminders and suggestions that institutions might take away from reading OCR’s letter to the District, including the following: OCR also raised additional concerns that were not described as violations, including that District staff were not adequately trained on Title IX, and that the District did not respond equitably to complaints of sexual assault during certain academic years. properly maintain records in accordance with the regulations. ![]()
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