Title IX: Activating your campus for notice and comment

I’ve been in violence prevention for almost a decade and the changes proposed within the NPRM are devastating. My position is funded by a federal grant which means I am limited in how I can engage professionally in the notice and comment process. But, I have a secret weapon: Luck. I am lucky in a “sought out and developed” kind of way. I am fortunate to work with a group of peer educators who are driven and committed to ending interpersonal violence at our institution. And while my hands may be tied, theirs are not. And they have gotten to work using them. 

I want to outline the incredible and inspiring work these students have done to mobilize around the notice and comment period at our institution in order to share what is possible on your campus. None of their efforts are making them shift focus or sacrifice a great deal of time. Instead, they are leaning on the relationships that the Campus Advocacy, Prevention, and Education (CAPE) Project Office has created across campus to drive this work. Below is a snapshot of our campus-wide engagement efforts:

Leveraging impassioned peer educators

Allison is a sophomore Political Science major, on the Doane Forensics Team, and in her first year as a peer educator for the CAPE Project. Fired up about potential Title IX changes, she worked to create an impassioned persuasive speech centered around maintaining practices, as permitted, from the 2011 Dear Colleague Letter. Additionally, Allison created an infographic of the key proposed changes and has led the work of my peer educators during this notice and comment period.

SART and Policy Taskforce Comment

Our Sexual Assault Response Team and Policy Taskforce met with the intent of crafting a university comment, led by our Title IX Coordinator. Key to the success of this tactic:

• Finding a time where your key stakeholders and subject matter experts are available, including internal and external partners
• Educating those around the table on the changes being proposed
• Deciding on which proposals to focus the comments
• Delegating who would gather data for which section
• Creating a shared document to data dump
• Having the Title IX Coordinator task specific individuals to help write parts of the comment
• Disseminating the final comments for approved by the SART and Policy Taskforce
• Finalizing suggested edits and submitting for formal approval

Lunchtime Notice and Comment Period Submissions

Peer Educators have partnered with Chi Delta, a sorority that is passionate about ending sexual violence, to collect comments during lunch hours outside the cafeteria. They have worked with IT to have laptops available, and will provide infographics about the changes, sample statements, and takeaway cards with information if someone cannot immediately submit a statement. This initiative will take place during the second week of classes. To get things started, peer educators attended a Chi Delta meeting to educate sorority members about the proposed changes and to ask for help and support. The lunchtime information tables will be staffed and supported by Chi Delta sorority members and peer educators.

Title IX Write Out Loud

Our Writing Center holds a monthly Write Out Loud event. Students receive a prompt, sign up for a time slot, and are given the opportunity to share their original writing with the campus community during an evening at our coffeehouse. Allison and her forensics coach are working with the Writing Center to create a prompt centered on the Title IX proposed rule changes. This event will be partly educational, answering what is Title IX and what are the proposed changes? The other part of this event is centered on activism and submitting a comment.

• Allison, in coordination with the CAPE Project Office, invited the Writing Center and Forensics Team to work with the peer educators to coordinate the event. The event is scheduled to showcase speakers who will educate the audience, including peer educators, forensics students and the campus Title IX Coordinator who can answer questions that the students may have about the proposed rule. Laptops will be available for students who wish to submit comments as part of the event.

Ultimately, the best advice I can provide is to get yourself an Allison, or any fired up peer educators and activists. 

These peer educators have thought outside the box for these different events, partnering with new and diverse groups that would not normally be part of the Title IX fight. To reach their goals they are focused, above all, on education, including: What is changing and how will that impact reporting, survivors, and the judicial process? And they are similarly focused on activism and how they can get their peers invested and commenting.

Tying education and activism has been successful on our campus because they are meeting our students where they are. If they don’t know about Title IX, it’s not a problem, they will provide the summary. If students don’t know why it applies to interpersonal violence, this is not a problem either. They will provide information about their right to an educational environment free from discrimination. If students are fired up about the proposed changes, then they’re in luck. The peer educators will sit them in front of a laptop and help them submit a comment. 

At the end of the day, we understand that all the comments submitted through our outreach activities may not be the type of comment that requires the Department of Education to write a well-crafted response. However, we’ve engaged and educated students, developed a quick response, built relationships with different organizations across campus, and made a statement as a university. Who knows? Maybe we’ll inspire some of those students to become more involved in violence prevention or policy advocacy in the long term.

The notice and comment period for the proposed Title IX rule closes on Monday, January 28. Comments can be submitted here and additional resource guides for those wishing to submit comments have been published by NASPA here.