Clery Center's Title IX NPRM 2022 Public Comment

Clery Center's Title IX NPRM 2022 Public Comment

Over the past ten years Clery Center has consistently advocated for policy changes that enhance campus safety provisions for the crimes of dating violence, domestic violence, sexual assault, and stalking. From participating in negotiated rulemaking for the 2013 Violence Against Women Act amendments to the Clery Act , to providing a written public comment to the 2019 Title IX Notice of Proposed Rulemaking, offering a statement of position to the 2020 Title IX regulations, and participating in the Department of Education’s virtual public hearings in 2021 we have sought alignment between the Clery Act and Title IX to erase confusion and increase equity for survivors. 

Yesterday we submitted our public comment in response to the  2022 Notice of Proposed Rulemaking for Title IX. We are encouraged by changes in these proposed regulations that seek to restore the agency of institutions in determining grievance procedures that best fit their campus communities and eliminate requirements that limit the types of harassment that fall within the bounds of Title IX. However, we identified where we still see room for improvement in order to clarify areas of intersection between Title IX and the Clery Act. You can read the full version of our public comment here to see how we underscore, among other things:

  • The importance of clarifying reporting responsibilities and whether and how those responsibilities intersect or diverge with those of campus security authorities (CSAs)
  • The need to restore the role of advisor of choice to its original intent within the Clery Act
  • The value in aligning expectations for similar requirements under each law, particularly in regards to accommodations provisions and sharing information about disciplinary sanctions 

We hope that the Department of Education internalizes our feedback in finalizing the Title IX rules so that student and employee survivors of dating violence, domestic violence, sexual assault, and stalking have clear avenues and resources provided to them by their institutions and that institutions have clarity around their own requirements and expectations. 

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