Although the Notice of Proposed Rulemaking (NRPM) started the legal process for creating regulatory guidance on Title IX and sexual violence, its publication was not a true beginning: it was one stop on what for many has been tumultuous journey towards ensuring institutions of higher education are responsive to sexual harassment, sexual assault, and other types of gender-based discrimination. This is especially true for those of us engaged with the Culture of Respect Collective, an ambitious program that brings together institutions of higher education who are dedicated to ending campus sexual violence and guides them through a rigorous, two-year process of self-assessment and targeted organizational change. The first cohort of Collective schools started the program when President Trump took office in 2017 and completed their participation the month the NPRM comment period closed, in January, 2019.
Over that two year period, participating institutions faced significant uncertainty in a shifting social and political landscape: the 2011 and 2014 guidance from the Department of Education (ED) was rescinded in September 2017, and replaced with an interim Question and Answers document. Though that 2017 guidance was brief and imposed minimal standards, it intimated the new priorities of ED under Secretary Betsy DeVos. Perhaps even more impactful for the field, however, was the birth of the #MeToo movement. The light #MeToo shed on the prevalence of workplace sexual harassment solidified for higher education both the urgency of addressing sexual assault. It also highlighted the need to simultaneously stay focused on interrelated harms that are also commonplace in higher education: sexual harassment, intimate partner violence, and stalking. Additionally, the powerful surge of #MeToo helped institutions of higher education clarify the broad scope of their mission to address violence, focusing not just on undergraduate students, but also on how employees, graduate students, and others connected to higher education are impacted by sexual violence. Though the horrific and highly publicized crimes of Dr. Larry Nassar were just one extreme example of institutional failure, the crimes and the fallout at Michigan State weighed heavily upon all of higher education.
Although Collective institutions felt the unmooring impact of these national events, their participation in Collective provided a clear structure and direction for their work to address sexual violence. Through the program, they were asked to complete a comprehensive inventory of their campuswide efforts to address sexual violence, using the CORE Evaluation. Then, using their CORE Evaluation results along with other data about their campus culture and climate, participating institution developed detailed action plans that set specific targets for policy and programmatic improvements. Finally, they made a commitment to implementing those changes within this ever-changing social, political, and cultural context. At the end of the program, Collective institutions completed that same self-assessment, giving them an opportunity to clearly identify what had changed (or stayed the same) from 2017 to 2019.
The arc of the Collective was a learning process for everyone involved: Culture of Respect and NASPA staff, and a diverse set of diverse institutional partners. Though Culture of Respect staff are still weaving through the wealth of assessment data collected throughout the past two years, there are a few salient themes that are emerging. First, conversations with Collective institutions solidified how difficult this work is: not only is organizational change inherently challenging, but work related to Title IX and sexual violence on campus is fragile, complex, and politically fraught. Many Collective participants faced barriers such as changes in organizational structure (especially for Title IX offices), frequent turnover in key positions, bureaucratic delays, budget constraints and cuts, and competing staffing demands, particularly for Title IX and prevention positions.
Despite these pressures, Collective institutions have not paused or sacrificed their work to build structures for addressingsexual violence on campus. Though Culture of Respect will share more details in a formal evaluation report, we know that institutions who completed the Collective made significant improvements across the six pillars of the Culture of Respect CORE Blueprint: survivor support, clear policies, multi-tiered education, public disclosure, schoolwide mobilization, and self-assessment. And, because federal requirements were relaxed and not strengthened over that period, it is clear that institutions and their dedicated employees were motivated by a shared desire to improve their campus communities. Professionals who work in this area are passionate about envisioning and realizing a world where sexual violence is not tolerated. Students undoubtedly share that dedication. We are proud that Collective institutions stayed engaged with students throughout this process by inviting them to sit at the table on their task forces, seeking feedback from student groups and leaders, engaging and training peer educators, and much more.
Finally, one truth that has been with us throughout these past two years is the undeniable need to speak openly, act decisively, and respond compassionately to sexual violence. Collective institutions are not alone in reporting increasingly common disclosures of sexual harassment or sexual assault from students. Though painful in their frequency, the increase in Title IX reports is an indication that creating consistent, fair procedures for responding to sexual violence is necessary. It helps survivors get the support they need, and allows all of us to think about meaningful strategies for preventing these harms.
Culture of Respect is humbled to be a witness to and a partner in the essential work that is happening across the country to address sexual violence. No matter the final outcome of the proposed rule from the Department of Education, we know institutions of higher education will continue undeterred in their effort to prevent and respond to all forms of sexual violence in our communities.