AAU joined ACE and other higher education associations in submitting joint comments in response to the Department of Education’s proposed changes to Title IX regulations . The comments acknowledged universities’ commitment to preventing sex-based discrimination and thanked ED for crafting a rule that “reflects the administration’s attentiveness to this important issue.” The comments urged ED to adopt “flexibility, simplicity, and clarity” as its main guiding principles for refining the regulations and to “stop the churn of perpetually changing rules,” which cause confusion on campus communities and undermine “the perceived legitimacy of institutional processes.”
The associations’ comments are organized in three sections, with the first focused on identifying provisions that “provide greater flexibility and clarity for campuses” and that “would aid efforts to address sex-based discrimination.” The second focuses on implementation challenges and raises concerns about the effective date of the final rule as well as the possibility of the final regulations being applied retroactively. The letter urged the department to give institutions at least eight months to prepare for the adoption of the rule and to set an effective date at the start of an academic year. The third section focuses on provisions that could benefit from “additional flexibility and clarification.”
Last week, AAU also submitted its own comment letter on the proposed regulations.