On January 28, 2019, the Department of Education closed the public comment period on the proposed cuts to Title IX protections. AWIS Members, Partners and allies were invited to tell Secretary Betsy DeVos how the rule changes would detrimentally impact students and educators in academia, including you. The talking points below helped guide response when submitting a public comment. 

Talking Points

1. Opening paragraph

Introduce yourself and your affiliation with the Association for Women in Science, the leading advocate for women in STEM with a global network of 100,000 members, partners and allies. Identify other credentials and experience that may distinguish your comment from others. Include your personal or professional experience with Title IX and/or sexual harassment or discrimination.

Example: My name is _____________(fill in the blank), and I am _______ (title or affiliation) and member/supporter of the Association for Women in Science, the leading advocate for women in STEM with a global network of 100,000 members, partners and allies. It is the duty of the Department of Education to develop and implement policies that establish a safe space for students and educators to learn, teach, and research. As an advocate on behalf of the Association for Women in Science, I urge you to reconsider these troubling changes.

2. Explain how the rule would harm students, educators and survivors and include personal experiences that tie in to the issue

Use the following talking points to guide your response.

Takes away colleges’ responsibility to investigate complaints

Narrowing the definition of sexual harassment means that colleges and universities are no longer obligated to investigate all complaints. Pursuing investigations for only the most egregious violations only green lights inappropriate behavior in places meant for students to learn and thrive. Every sexual violence complaint deserves an investigation.

Raises standard of proof for complainants

The standard of proof in civil suits is fair to both the accused and accuser. However, the regulations as proposed force survivors to provide “clear and convincing evidence,” a standard which sets a much higher bar for survivors to prove sexual harassment. The changes award undeserved power to the accused, meaning more instances of sexual violence will go unpunished and more survivors will be silenced.

Schools can ignore complaints from lower-tier school employees

A student is more likely to trust and have a stronger rapport with resident advisors, teaching assistants and other lower-tier school employees. They are therefore more likely to share complaints with trusted individuals. With the proposed changes, schools can ignore complaints from lower-tier school officials, RAs and TAs and must only respond when complaints are brought to deans and other designated, top-tier school officials. This is a reversal from the existing standard that required schools to respond whenever a complaint is brought up to any school employee.

3. Conclusion paragraph

Reiterate the reason for writing.

The changes as outlined undermine the very essence of protecting students and educators in academia for which Title IX was designed. Justice and fairness to survivors must be at the core of any changes to Title IX. I look forward to hearing from you.

Source: ACLU.