On January 24, AAU submitted comments on the Department of Education's Notice of Proposed Rulemaking (NPRM) on Title IX.
Our comment letter identifies key concerns and asks the Department to:
- Remove requirements that institutions permit cross-examination and appoint aligned advisors.
- Remove the requirement that universities apply the same standard of evidence and process across all disciplinary processes.
- Clarify whether the Department intends to preempt other relevant laws and whether and under what circumstances an institution may forbid and investigate behavior that falls outside the Department’s definition of “sexual harassment.”