From the top down: deconstructing Title IX
VCU announced a new Title IX administrative structure, policy and student training module in conjunction with state law this month.
VCU announced a new Title IX administrative structure, policy and student training module in conjunction with state law this month.
Effective July 1, Virginia law requires academic transcripts indicate student suspension or dismissal due to a sexual violence offense, employees report any information about an act of sexual violence to the Title IX coordinator “as soon as practicable” and that campus law enforcement notify the Commonwealth’s attorney of felony sexual assault investigations within 48 hours.
“I remind you of new Virginia state laws that take effect today and are related to combating campus sexual violence at our Commonwealth’s public universities, including VCU,” read a July 1 email from the office of VCU president Michael Rao.
A subsequent July 10 email stated VCU’s “Office of Equity and Access Services,” is successor to the, now eradicated, “Office of Institutional Equity,” which housed the university’s Title IX coordinator.
“I think it’s difficult to predict how the most recent changes will affect students,” said Laura Rugless, the university’s new Title IX coordinator and Director of Equity and Access Services.
The recent establishment of Rugless’ office is the second revision to VCU’s organizational placement of the Title IX coordinator in two years.
The new Title IX administrative structure also requires the Office of Equity and Access Services report directly to the Office of the President’s senior executive director Brian Shaw. Formerly, the Office of Institutional Equity reported to the vice president for Finance and Administration.
In addition, VCU launched a “new comprehensive policy regarding Title IX,” earlier this month.
Rao announced the “Interim Policy on Sexual Misconduct/Violence and Sex/Gender Discrimination” in an Aug. 3 email.
Rao’s email also explained a mandatory online training module for all incoming students in addition to the interim policy.
“Not Anymore,” is an interactive, online education program, designed to prevent sexual assault, intimate partner violence and stalking. Rao’s email states the program was reviewed and selected by VCU faculty and students, including student survivors of violence.
“The program has been rated very favorably by our students, and students around the country,” Rugless said of “Not Anymore.”
Returning students will be “encouraged” to complete an updated program, and faculty and staff training is in development, according to Rao’s Aug. 3 email.
VCU Police Chief John Venuti said that last year VCU also hosted a pilot training on trauma-informed sexual assault investigations for the National Center for Campus Safety.
“I am currently working on implementing a new program for VCU called ‘You Have Options,’” Venuti said.
In regard to Virginia law requiring campus PD report sexual assault investigations within 48 hours — Venuti’s department is way ahead of the curve.
“VCU Police has been notifying the Richmond Commonwealth’s Attorney’s Office about investigations of felony sexual assault since I became police chief in 2010,” Venuti said, who was appointed to the governor’s task force on combating campus sexual violence last year.
Venuti said he asked the Commonwealth’s Attorney’s office to appoint a prosecutor specifically to handle VCU’s cases to increase consistency when working with survivors.
“This arrangement has been very beneficial for us and we are consistently in contact with the CA’s office on investigations and to communicate public outreach opportunities,” Venuti said.
In April 2014, president Rao signed an Office of Civil Rights Resolution Agreement, concluding federal review of VCU’s Title IX compliance in response to two separate complaints of mishandled cases.
The resolution agreement exempted VCU from the U.S. Department of Education’s May 2014 list of schools under investigation for non-compliance with Title IX. The list included James Madison University, University of Virginia, the College of William & Mary and the University of Richmond.
At press time, University of Virginia and College of William & Mary are still listed.
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