While the U.S. Department of Education Office for Civil Rights commences its investigation regarding a Title IX complaint lodged against the University, other Big Ten schools are also grappling with the implementation of revised sexual misconduct guidelines.

In April 2011, the OCR released a Dear Colleague Letter that required universities to modify their sexual harassment policies codified by Title IX of the Education Amendments of 1972.

Under the new mandate, universities are required to have a Title IX coordinator who is in charge of “overseeing Title IX complaints and identifying and addressing any patterns or systemic problems that arise during the review of such complaints.”

The changes require universities to actively investigate instances of sexual misconduct rather than wait for survivors to bring allegations forward.

Like many other universities, after implementing an interim policy based on the recommendations, the University revised its sexual misconduct policy in 2013. The letter includes mandates, but leaves some leeway for institutions to craft their own policies.

Though universities are required to implement many of the same changes due to risk of losing federal funding, one of the main differences is the extent to which the operation is centralized.

In an e-mail interview, Gary Lewis, senior director of media and public relations at Ohio State University, said certain university offices have the power to investigate cases under their jurisdiction.

“If the respondent/accused person is a faculty or staff member, the case will be investigated by Human Resources,” Lewis wrote. “If the respondent/accused person is a student, the case will be investigated by Student Conduct.”

The University of Wisconsin-Madison employs a similar system.

Luis Piñero, assistant vice chancellor for workforce equity and diversity, Title IX coordinator and director of the school’s Office for Equity and Diversity, said its investigation process also relies on multiple offices.

“We have a system that is decentralized in some ways because the student’s issues go in one place and the employee issues go in another place,” Piñero said.

He added that the Division of Student Life, which includes the office of the Dean of Students, investigates student-against-student cases.

Within this division, Piñero said a judicial affairs unit enforces the Student Code of Conduct, which sets standards for student behavior. The Office for Equity and Diversity investigates allegations in cases such as employee-against-employee and employee-against-student.

He said that assigning only one person to deal with the entire spectrum of allegations would not be effective with such a large student body and campus. Additionally, working with the Division of Student Life ensures Title IX requirements are fulfilled.

“We work collaboratively with them and we also provide them advice to make sure that the way they are conducting their investigation fulfills the expectations under Title IX,” Piñero said.

In contrast, Michigan State University’s Office for Inclusion and Intercultural Initiatives receives all allegations. At the University of Michigan, the Office of Institutional Equity receives all claims.

While universities have an obligation to investigate all sexual harassment cases under the Title IX guidelines, situations in which a student survivor does not want the university to pursue an investigation requires a case-by-case analysis.

Paulette Granberry Russell, Michigan State’s senior adviser to the president for diversity, Title IX coordinator and director of the Office for Inclusion and Intercultural Initiatives, said if this were to occur, the office would initiate contact with the student.

“We will invite them to come in and meet with us,” Russell said. “The student can then decide if they are going to participate in the process.”

If the student opts to not participate in the investigation process, the office then evaluates whether to continue the investigation. At the University of Michigan, there is a panel in place that reviews the case and determines how to proceed.

On Monday, the Department of Education confirmed the OCR has also initiated an investigation of Michigan State’s sexual misconduct policy after a complaint was lodged.

At OSU, Lewis said it depends on each case whether or not the university will keep investigating depends on each case.

“The university will do a case by case analysis, weighing the survivor’s wishes with the potential risk to the survivor or others in the campus community,” he wrote. “In some cases, the university will investigate to the fullest extent. In others, there may be opportunities for informal interventions that will meet the needs of safety, education and Title IX.”

While the Dear Colleague Letter required universities to revise their sexual harassment policies, it also allowed universities to provide students, faculty and staff with educational and resource opportunities regarding prevention and awareness.

“It has elevated the topic to a level of prominence that has a beneficial effect,” Piñero said. “It heightens the awareness.”

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