Dr. Crutcher, University of Richmond Administration, and Board of Trustees: 

United as students, alumni, faculty, and staff, we write to urge you to protect UR students’ safety and equal access to education. 

On May 6th, the Department of Education issued its Final Rule changing the Title IX obligations of all schools receiving federal funding. Consistent with the harmful rhetoric and anti-survivor ideology Secretary DeVos has brought to the Department, the Rule contains dangerous provisions that go against best practices, tip the scales against survivors, and jeopardize students’ civil right to an education free from discrimination.

The communities already most vulnerable to sexual misconduct are BIPOC, international students, and LGBTQIA+ students. These students’ right to an equal access to education is in danger of being violated by the Final Rule. 

We want the UR Administration to make the following policy changes:

1. 60-Day Time Limit for the Completion of Title IX Cases. Lengthy investigations and hearings are emotionally taxing for survivors.
2. Clear Guidelines for Live Title IX Hearings. The Final Rule’s live hearings with cross-examination can re-traumatize survivors, negatively impact their mental health, and deter other students from reporting. To prevent these consequences, we need clear and transparent guidelines that both complainants and respondents can rely on.
3. Clear Interpretation for the Revised Definition of Sexual Harassment. The University needs to craft inclusive and comprehensive interpretations of the terms “severe”, “pervasive” and “objectively offensive”. Every student deserves to have their experience with sexual harassment validated, and not disregarded, by their support system.
4. Separate Reporting and Investigation Policy for Off-Campus Sexual Misconduct. This ensures students’ access to education is not hindered based on where their unwanted sexual experience took place, as well as transparency among reporting data.
5. Interim Support Measures for All Students. Survivors need support services no matter if their unwanted sexual experience took place on-campus, in the city of Richmond, on a Greek-sponsored trip, or during study abroad.
6. Maintaining the Preponderance of Evidence Standard in all sexual misconduct, harassment, and discrimination cases. This is the fairest standard for both complainants and respondents.
7. Prompt Response to Reports of Sexual Misconduct During the COVID-19 pandemic.
8. Protections for LGBTQIA+ Students in alignment with the rescinded 2016 Department of Education guidance. All students are entitled to equal access to education regardless of gender identity.
9. Safeguarding Abuse of the Informal Resolution Process. We need clear guidelines about circumstances in which it can be used and how it will be facilitated.  
10. Make a public statement to the entire UofR community reaffirming their commitment to Black and LGBTQ+ students and to commit to the above policy changes.

We ask the UR administration to publish this public statement committing to these policy changes by July 10, 2020. 

The Spiders Against Sexual Assault and Violence (SASAV) will be sending in our final proposal of these changes with evidentiary research on June 29, 2020. Please reach out over Facebook, Instagram (@ursasav), or email with questions or concerns. 

**For those interested in a more detailed description of the final rule, a summary can be found here: https://www2.ed.gov/about/offices/list/ocr/docs/titleix-summary.pdf