Title IX Task Force Findings

The current reporting system is difficult to navigate, and the process of reporting has been described as an adverse and potentially re-traumatizing experience, creating significant barriers to reporting and pursuing a complaint.

 

Members of Reporting Subgroup

Mandy Bidinger, Executive Assistant for the Dean of Students and Interim University Title IX Coordinator, Interim Title IX Project Manager; Jennifer Deckert, Faculty Senate Representative, Associate Professor of Dance; Kirsten Kennedy, Associate Vice President for Student Housing and Sustainability.

 

Prioritized Action Items and Timeline for Deployment

 

1. Office Structure

Action Item / Completion Goal
Develop an organization structure and consider modification to maximize effectiveness within the Title IX regulations, include a dedicated intake and outreach function within a centralized USC office responsible for receiving reports of sexual and gender-based harassment, interpersonal violence and sexual violence, implementing supportive measures, investigating and adjudicating formal complaints, and overseeing appropriate individual and campus-wide remedies.

Details
Upon the recommendation of the Title IX Task Force, the subgroup, with work from other key constituents, has developed an organizational structure for a new Title IX Office that modifies the EOP reporting line so that it no longer reports to the Office of General Counsel (which is strongly disfavored by the U.S. Department of Education). The organization structure for the new Title IX Office will include, at a minimum, a dedicated and full-time Title IX Coordinator with oversight of all student, staff, and faculty matters; at least one intake and outreach coordinator, with the recognition that volume of reports may require an expanded team over time; an education and prevention coordinator; dedicated investigators and individuals trained to facilitate informal resolutions; a database manager to assist with case management, assessment, and reporting; and, appropriate administrative support. 

The structure, roles, and responsibilities of this new are a driving force behind updating the university’s procedures and the development of this office is considered a high-priority item. We are aware that Cozen O’Connor has provided a number of potential organizational structures as well as models that have been implemented at other institutions. This subcommittee understands the many decisions involving structure, funding, and staffing and recognize that the creation of this office requires significant investment and commitment by the university. The President will be responsible for approving the finalized structure. This new structure is anticipated to be approved and hiring will begin in Fall of 2021.

 

2. Policy Updates

Action Item / Completion Goal
The University will implement a review of campus policies and procedures to address barriers to reporting and minimize re-traumatization regarding sexual and gender-based harassment, interpersonal violence and sexual violence.

Details
The objectives are to (1) ensure the policies provide the jurisdiction and authority to respond to historical allegations and/or reports by individuals who are no longer affiliated with the University and (2) re-examine university reporting options and ensure reporting options, including on-line, in-person, by phone, and by email are clearly identified and consistently communicated. A policy group has been identified and includes the Title IX Coordinator, General Counsel, and expert advice from Cozen O’Connor. The policy group will consult Faculty & Staff Senates, Human Resources, SAVIP, Office of EOP, and Student Conduct as liaisons to develop these and other policy changes. The policy is expected to be updated during the 2021-2022 academic year.

 

3. Updated Reporting Form

Action Item / Completion Goal
Improve the ease of reporting and clarity of reporting form by developing one form.

Details
There were two separate online forms used to report interpersonal violence, each with complex and differing language which made it difficult for the typical university constituent to know how, where, and what to report. Responding to the feedback from the Title IX Task Force, one consolidated new form was created and implemented in the reporting system at the start of the Fall 2021 semester for all sexual and gender-based harassment and violence, including sexual assault, dating violence, domestic violence, and stalking. This new form is routed to the Title IX Coordinator for triage and response. EOP will continue to manage intake for all other forms of discrimination and harassment and the EOP form has been updated to clearly disclose that it is not to be used for reports relating to sexual and gender-based harassment or interpersonal violence. This is also a high priority item as we begin to address barriers to reporting and help simplify the process for complainants.

 

4. Consolidated Maxient Systems

Action Item / Completion Goal
The University will consolidate its three case management systems into one shared system for better case management, communication, assessment and reporting.

Details
This will occur by January 1, 2022 with training for all end-users in Summer 2022. For more detail on procedural and financial considerations related to this, see Appendix A.

 

5. Communication Review to Complainants and Respondents

Action Item / Completion Goal
Launch updated website and forms for better access to information and improved communication.

Details
The Title IX Task Force recommended a review of all websites, forms, and template communications to be more user-friendly, interpersonally sensitive, and non-threatening in tone and content to the complainant and respondent. With the launch of the Interpersonal Violence website and the new consolidated form, efforts will be focused in 2021-2022 academic year to review any template communications sent from EOP, Office of Student Conduct, Human Resources, Provost Office and SAVIP to ensure the readability, accessibility, consistency, and tone of these communications. Through the Public Affairs awareness campaign team, the Digital Strategy team, and DoIT, these enhanced communication efforts will increase transparency and ease the navigation of the Title IX process. The Interpersonal Violence website was updated August 2021.

 

6. 24-Hour Response to Reports

Action Item / Completion Goal
Ensure that all reports receive a response within 24 hours.

Details
USC is committed to ensuring a 24-hour response for reports to the Title IX Office or EOP. While most reports Monday-Thursday currently receive a response within 24 hours, reports over the weekend do not. In Fall of 2021, the university will utilize its 24/7 on call advocates working with the SAVIP office to receive notifications of a report to the on-call phone. Upon receipt of the notification, SAVIP will reach out to the reporter within 24 hours to ensure a timely and trauma-informed response pending outreach by the Title IX office and/or EOP. Once the intake and outreach coordinator position is filled (recommendation #1), they will also contribute to these efforts. The institution’s ability to meet the 24-hour response will be one of the metrics used to determine success.

 

7. Map Process

Action Item / Completion Goal
Map process from reporting to investigation to adjudication/ discipline.

Details
While there is already an existing pdf process map (Appendix B) and the Interpersonal Violence website outlines the resolution process, Office of Communications and the new Title IX Office will collaborate to create comprehensible web content that provides additional information about the process. In addition, a Title IX Resource Guide will be created to give complainants and respondents more in-depth information consistent with federal compliance obligations. This will be created by Spring of 2022.

 

8. Annual Reporting

Action Item / Completion Goal
Develop a communications plan that enables information, resources, and access to annual data to increase awareness and understanding within the community.

Details
The Office of the Dean of Students prepares an annual education and initiatives report for education and prevention efforts surrounding Title IX with students (Appendix C). These initiatives will be expanded into the new Title IX Office to include faculty/staff education, as well as prevention efforts and will be published on the website and disseminated through university communications. 

Because of the complexities of publishing annual data regarding Title IX reports, formal complaints and resolutions, the new Title IX Office, in consultation with campus partners, will collaborate to determine how best to share accurate and comprehensive aggregate information that does not include personally-identifiable details. These efforts will be guided by the new consolidated system for case management. The Title IX Task Force’s report published data from 2016-2020 that included the annual number of cases reported to EOP, SAVIP, and DLES and broke down the complaints by the role of faculty, staff, or student and the respondent’s affiliation with the university. The next report released in Fall 2022 will include annual data from the 2020-2021 academic year in addition to the other data points that have been identified for inclusion.

 

9. App-based Report

Action Item / Completion Goal
Use an app-based reporting portal to provide a mobile, user-friendly, and accessible reporting option.

Details
The recommendation from the Title IX Task Force was to implement an app-based reporting mechanism. The Rave Guardian App is already widely distributed to students, faculty, and staff and includes a link to the Interpersonal Violence website, the ability to submit anonymous reports, and a connection to our Student Care and Outreach Team. The implementation group worked with USCPD to update the app during the Summer of 2021 in coordination with the interpersonal violence communications campaign. Information about the app and education about its functionality was disseminated to USC community on August 16th, 2021 and is highlighted here.

 

10. Academic Liaisons

Action Item / Completion Goal
Integrate the new centralized Title IX Office with decentralized academic units and suggested academic liaisons who would receive reports, assist in the delivery of training, liaise with the centralized office, and serve as a visible resource within each unit.

Details
At the current case load and the extensive knowledge needed for this item, it is not considered an immediate priority and can be revisited when cases increase and/or we have identified this as an additional responsibility for the Council of Academic Diversity Officers with financial compensation.