February 4, 2014 The Honorable Catherine E.

Lhamon Assistant Secretary for Civil Rights Department of Education 400 Maryland Ave., SW Dear Assistant Secretary Lhamon, Thank you for the opportunity to provide feedback and ideas related to ending sexual assault on college campuses. The American Association of University (AAUW) has long supported freed m from violence and fear of violence me c l w rkpl ce d c mmu e .1 Our 170,000 members and supporters nationwide are gratified to see the current administration prioritize ending campus sexual assault by creating a new Task Force on Campus Sexual Assault, and by the stron w rk be d e by e ep r me f Educ Off ce f r v l R . When campus environments are hostile because of sexual harassment, assault, or violence, students c le r dm u rue educ l pp r u e . AAU w re e rc revealed that two-thirds of college students experience sexual harassment.2 In addition, a 2007 campus sexualassault study by the U.S. Department of Justice found that around 28 percent of women are targets of attempted or completed sexual assault while they are college students.3 The following six suggestions are executive actions that the Department of Education, in coordination with other agencies, could take to continue to prioritize the elimination of sexual assault on college campuses. AAUW recommends the Department: 1. Improve Transparency in Enforcement, Resources AAUW appreciates that the Department has risen to the challenge of increasing numbers of Title IX (and Clery) complaints and is investigating schools. Unfortunately, much of the informatio re rd e e ve bur ed e ep r me f Educ website. There does not appear to be a comprehensive list of all Title IX voluntary resolution agreements e ep r me web e. Fur erm re, there does not appear to be a comprehensive list of all ongoing investigations or complaints filed. Resources for those who would like to consider filing a complaint are not on all of the web pages where information about complaints or guidance does appear. Finally, providing a list of Title IX coordinators at every school would be an invaluable resource to survivors. In addition, Clery Act investigations, which in some cases go hand-in-hand with Title IX investigations, seem to be best found on the studentaid.gov website. This connection makes sense to those of us who know e lery Ac statutory link to financial aid, but for many students or survivors a one-stop resource would be helpful. The Department has made clear through its commitment to stopbullying.gov that it is possible to create a useful resource

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that combines the information students, parents, schools, and survivors need, and we urge the Department to consider a similar option for campus sexual assault. We do understand that there may be privacy limitations to providing transparency around complaints and investigations and are eager to learn more about those limitations and brainstorm on ways to work with those concerns. 2. Include Campus Civil Rights Compliance in College/University Ratings Connected, in part, to the above-mentioned need for better compiled information is this administration college ratings system to help students and parents gauge how schools perform on a number of measures. AAUW has weighed in on some possible aspects of the ratings system and reaffirms that compliance with civil rights laws must be a part of those ratings. If there is an ongoing investigation regarding Title IX or Clery noncompliance, that information should be captured in the ratings system. If there is a voluntary resolution agreement in place, that should appear in the ratings system. Just as students should ask why graduation rates are low, or loan repayment rates are low, they should also have the information necessary to inquire how colleges and universities are complying with federal investigations and resolutions around their compliance with civil rights laws. 3. Support Climate Surveys as a Best Practice AAUW encourages the Task Force to consider existing grant programs to pilot school climate and victimization surveys and to demonstrate their importance to maintaining a safe environment for all students. If that is not possible, perhaps examples of climate surveys could be recommended in best practices communicated to schools. The Department has included climate surveys in the voluntary resolution agreements for several schools, and we agree they are valuable for schools to assess particular needs on their campuses. In addition, reconciling climate surveys with crime statistics can help motivate systemic change and improve reporting. Developing a successful approach to these types of surveys by including them as a condition or part of grants offered, or recommending them as a best practice to schools, would help move more colleges and universities towards conducting them. 4. Appoint a Special Assistant for Gender Equity AAUW has long called for the Department of Education to fill the position of a Special Assistant for Gender Equity (SAGE). The need for the SAGE position was identified by AAUW in the early 1990 and Congress amended the U.S. Department of Education Organization Act to create the position in 1994. The statute states: The Special Assistant shall promote, coordinate, and evaluate gender equity programs, including the dissemination of information, technical assistance, and coordination of research activities. The Special Assistant shall advise the Secretary and Deputy Secretary on all matters relating to gender equity. While the position remains in the statute, it has not been filled since 2000. We believe now is the time to fill this position. A Special Assistant for Gender Equity would be critical to the Department of Educ eff r pr m e c rd e d ev lu e

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gender equity programs, including the intra- and inter- departmental work that accompanies reducing sexual assault on college campuses. 5. Provide Guidance to Schools around Title IX and LGBT Students AAUW continues to hear that there is some confusion about the application of Title IX to LGBT ude educ l pp r u e pec f c lly r u d exu l r me d exu l violence. This can occur when colleges and universities misunderstand or misrepresent relationships and intimate partner violence, and/or apply sex stereotyping to LGBT students when they report and move through disciplinary proceedings. Additional guidance from the Department of Education to colleges and universities could help to ensure LGBT ude cce educ c mpr m ed. 6. Support Specific Needs of Immigrant and Minority Students As the Department moves forward with making resources more clearly available online, it would help non-native-English-speaking students understand their rights better if several of the FAQs about Title IX, especially the information regarding filing a complaint, were available in other languages. In addition, Deferred Action for Childhood Arrivals (DACA) students may not fully understand their rights under Title IX neither may their colleges and universities and an FAQ or letter explaining those rights and options would be helpful. In addition, in recommending best practices to schools the Department could suggest strategies to ensure that translation services are available for disciplinary proceedings and for counseling and reporting. T k y u f r e pp r u y re AAU u e f r execu ve c e d c mpu sexual assault. We look forward to continuing to work together on this important issue. Please do not hesitate to contact me at 202/785-7720, or Anne Hedgepeth, government relations manager, at 202/785-7724 if you have any questions. Sincerely,

Lisa M. Maatz Vice President for Government Relations

American Association of University Women. (2013). 2013-14 AAUW Public Policy Program. www.aauw.org/resource/principles-and-priorities/ 2 AAUW. (2005). Drawing the Line: Sexual Harassment on Campus. www.aauw.org/learn/research/upload/DTLFinal.pdf. 3 Christopher P. Krebs, Ph.D. ; Christine H. Lindquist, Ph.D. ; Tara D. Warner, M.A. ; Bonnie S. Fisher, Ph.D. ; Sandra L. Martin, Ph.D. (December 2007). The Campus Sexual Assault (CSA) Study, Final Report. NIJ Grant No. 2004-WG-BX-0010. www.ncjrs.gov/pdffiles1/nij/grants/221153.pdf.
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