Georgetown University submitted its formal comment regarding proposed Title IX regulations to the U.S. Department of Education on Jan. 31, following months of student activism and input.

The final submission comes after Vice President for Student Affairs Todd Olson and Vice President for Institutional Diversity and Equity Rosemary Kilkenny shared the draft comment in an email to the student body Jan. 23. The university collected anonymous feedback to the comment through an online form.

FILE PHOTO: KIRK ZIESER/THE HOYA The University submitted its comment to the proposed changes to Title IX regulations after giving students 8 days to review and submit responses to their initial draft.

The proposed regulation changes do not uphold a fair, just and supportive grievance process, the the comment reads.

“Georgetown is concerned that the proposed regulations create an overly legalistic process that will unnecessarily restrain reporting, traumatize students, lead to less accountability, and create inequities,” the comment reads.

Secretary of Education Betsy DeVos released proposed changes to Title IX regulations in November 2018 that include altering the definition of sexual harassment from actions “severe or pervasive” to “severe and pervasive,” a narrowing of requirements.  

The comment specifically highlights the redefinition of sexual harassment and the introduction of cross-examination of both accused students and accusers during Title IX hearings as unwelcome changes to Title IX regulations.

More than 370 community members and student advocates influenced the university’s final comment, according to university spokesperson Matt Hill.

“While the university’s comment cannot effectively do justice to every thoughtful and compelling remark from our community, many individual viewpoints, along with our core Jesuit values, were essential in shaping our comment,” Hill wrote in an email to The Hoya.

The university held listening sessions in December where students voiced how they hoped the university would respond to the proposed Title IX regulation changes. The administration waited to formally comment on the Title IX changes until it had gathered student feedback from all 11 listening sessions. Administrators then rebuked the proposed changes at the Students Taking Action against Interpersonal Violence town hall on Jan. 15.

Chair of Georgetown’s women’s and gender studies department You-Me Park expressed appreciation for the university’s comment.

“The University comment is thorough and great,” Park wrote in an email to The Hoya. “I am proud to work for the University that formulated such well-thought-out and unequivocal responses to the new regulations.”

The Department of Education’s focus on the monetary benefits of implementing the changes reveals its flawed priorities, Park wrote.

“We need to make it clear that our students’ wellbeing and health come before monetary gain, whatever the amount, and that any changes to our policies will be undertaken to improve processes and not simply to save money,” Park wrote.

The Department of Education estimates implementing the regulation changes will save schools $286.4 million to $367.7 million over the next ten years because universities will not have to conduct investigations.

The regulation should be re-evaluated to be more inclusive and equitable, according to WGST major Tina Tehrani (COL ’19). As it stands, Title IX requires that schools do not discriminate against students on the basis of sex, but does not extend to discrimination against pregnant or parenting students or discrimination on the basis of sexual orientation and gender identity.

“I believe the current changes cause more damage than progress,” Tehrani wrote in a statement to The Hoya. “The changes should not go against the entire basis of Title IX. No discrimination means no discrimination.”

Though hundreds participated in forming the university’s comment, many community members submitted separate comments as well. Park also invited students in the WGST senior capstone class, a seminar only open to seniors pursuing a major or minor in WGST, to write a joint letter and publish their own public comment.

The WGST seniors’ comment was submitted to the federal register during the Department of Education’s 60-day public comment period after its Nov. 16 release of its proposed regulation changes. Any individual or group could submit public comments online or by mail for review by the Department of Education. The comment period opened Nov. 29 and officially ended Jan. 30.

The WGST seniors’ letter raised four concerns with the proposed changes. The letter said that the proposed regulation prioritizes money over student well-being, creates loopholes that limit which cases are investigated, neglects to apply to K-12 education and allows for religious exemptions which could disproportionately affect pregnant, parenting or LGBTQ students.

STAIV, a student group advocating for the university to reform its responses to instances of sexual misconduct on campus, also encouraged its members to submit their own comments.

The group held a “Notice and Comment Party” on Jan. 24 in cooperation with GUSA’s Sexual Assault and Student Safety policy team to provide a casual gathering where students could eat pizza while learning how to write a comment.

On Jan. 25, STAIV released a Google form on its Facebook, by which students could write their personal comments on the Title IX changes for STAIV to formalize and submit to the Department of Education on the students’ behalf.

STAIV has engaged in long-term advocacy against the Title IX changes, and has had several meetings with university administrators, according to STAIV member Hanna Chan (COL ’19). These meetings led to the university’s 11 Title IX listening sessions and the STAIV town hall, which facilitated discussion surrounding Title IX and interpersonal violence at Georgetown.

Chan, a Women and Gender Studies major, received help and guidance on her advocacy from Park, who wrote that she is pleased with work of her students who are seniors.

“Our senior class will continue to lead and reflect student activism on campus,” Park wrote.

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