THE LASTING IMPACT OF THE 2011 DEAR COLLEAGUE LETTER ON SEXUAL VIOLENCE: A QUALITATIVE STUDY ON COLLEGE CAMPUS POLICIES AND PROCEDURES By Emily Nichols A DISSERTATION Submitted to Michigan State University in partial fulfillment of the requirements for the degree of Human Development and Family Studies – Doctor of Philosophy 2020 THE LASTING IMPACT OF THE 2011 DEAR COLLEAGUE LETTER ON SEXUAL VIOLENCE: A QUALITATIVE STUDY ON COLLEGE CAMPUS POLICIES AND ABSTRACT PROCEDURES By Emily Nichols Higher education institutions face national scrutiny for their response to sexual violence. There have been numerous calls from the federal government to develop more appropriate sexual violence procedures and policies, but college campuses around the country still struggle to adapt to federal recommendations. One particular set of guidelines, the 2011 Dear Colleague Letter on Sexual Violence from the U.S. Department of Education Office for Civil Rights, has been a key source of assistance and frustration for higher education institutions. The 2011 Dear Colleague Letter outlined explicit procedures to address and prevent student sexual violence allegations. College campuses were charged to improve on-campus investigation, adjudication, and conduct procedures under strict compliance with Title IX and develop prevention and intervention sexual violence services. College campuses across the nation established new comprehensive policies and procedures aimed to better address the needs of sexual violence victims. Despite attempts towards positive change, the 2011 Dear Colleague Letter was withdrawn in September 2017, with little knowledge about the impact of the guidance on college campuses or how the withdrawal will impact the development of campus sexual violence policies and procedures moving forward. This study consists of a qualitative design using the tenets of thematic analysis. Data was collected from current Title IX Coordinators and Deputy Title IX Coordinators at Midwestern public higher education institutions by conducting semi-structured interviews exploring their perceptions of how the 2011 Dear Colleague Letter facilitated positive change and created challenges for the development and maintenance of sexual violence procedures. Furthermore, interviews explored recommendations for developing effective sexual violence policies and procedures following the withdrawal of the 2011 Dear Colleague Letter on Sexual Violence. Research findings contribute to the growing knowledge of literature informing the development of future campus sexual violence procedures and policies. Copyright by EMILY NICHOLS 2020 To my husband, family, and friends. v ACKNOWLEDGEMENTS Over the past twelve years, three degrees, and one dissertation at Michigan State University, I have been fortunate to experience the support of countless family, friends, professors, and mentors. I would first like to thank my husband, Kevin, for being my number one fan and cheerleader since coming into my life. You have held my hand through the highs and lows of this experience, and I can’t put into words how much I appreciate your constant encouragement. To my parents, Ellen and Alan, and sister, Katie, for always pushing me to achieve my dreams. You have supported me through every twist and turn of my life, and I wouldn’t be the woman I am today without your love. To my in-laws, thank you for accepting me into your family and your constant support in all aspects of life. I am forever grateful to have had an amazing doctoral committee direct me through this process. Your guidance throughout this program has been phenomenal, and I would not be the scholar and clinician I am without your mentorship. I would first like to thank my advisor and doctoral committee chair, Dr. Marsha Carolan. I am forever thankful for all that you have done for me during the course of this program. I will never forget how you welcomed me with open arms into this program when I first told you about my interest. You are so much more than an advisor to me. Thank you for always advocating for me and pushing me. Dr. Adrian Blow, you have been a wonderful mentor and program director. You make the Couple and Family Therapy Program a true family experience. Dr. Andrea Wittenborn, thank you taking a chance on me by becoming a member of my committee when I needed a helping hand. Your expertise, knowledge, and advice are invaluable to the students in this program. Dr. Kathleen Burns-Jager, thank you for your willingness to join my committee when I needed help the most. I also want to vi thank Dr. Jayne Schuiteman for all your mentorship over years starting at the Women’s Resource Center until now. You were the person that motivated me to obtain a doctoral degree in the first place, and I would not be where I am without your support. Finally, thank you to all the friends and colleagues that have been along for my ride at MSU. From East Shaw Hall to the halls of Human Ecology, your love and companionship have played a huge role in my completion of this program. Thank you. Go Green! vii TABLE OF CONTENTS LIST OF TABLES ..................................................................................................................... xi LIST OF FIGURES ................................................................................................................... xii CHAPTER 1: INTRODUCTION .............................................................................................. 1 Statement of the Problem ............................................................................................... 1 Purpose of the Study ...................................................................................................... 4 Research Questions ....................................................................................................... 5 Theoretical Framework: Organizational Readiness to Change Theory ........................ 6 Conceptual Framework .................................................................................................. 7 Format of Manuscripts .................................................................................................. 8 Manuscript One: A Critical Analysis of the Impact of the 2011 Dear Colleague Letter on Sexual Violence ............................................................... 8 Manuscript Two: Recommendations for Effective Sexual Violence Policies and Procedures on College Campuses: Perspectives of Title IX Coordinators ......................................................................................... 9 REFERENCES .............................................................................................................. 11 CHAPTER 2: LITERATURE REVIEW ................................................................................... 16 Significance of Problem ................................................................................................. 16 Definition ........................................................................................................... 16 Adverse consequences ....................................................................................... 16 College sexual violence victims ......................................................................... 17 Campus reporting and re-traumatization ........................................................... 18 Campus Sexual Violence Policy Review ....................................................................... 19 Title IX ............................................................................................................... 19 Clery Act ............................................................................................................ 20 Prior Dear Colleague Letters addressing sexual violence .................................. 20 2011 Dear Colleague Letter ............................................................................... 22 Campus Resources to Address Sexual Violence ........................................................... 23 Investigation and conduct .................................................................................. 23 Prevention and education ................................................................................... 25 Intervention ........................................................................................................ 26 Withdrawal of the 2011 Dear Colleague Letter ............................................................. 27 Need to understand impact of the 2011 Dear Colleague Letter ......................... 28 REFERENCES .............................................................................................................. 29 CHAPTER 3: METHODS ......................................................................................................... 37 Overview of the Research Design .................................................................................. 37 Qualitative Approach .................................................................................................... 38 Sampling and Participants .............................................................................................. 39 Sample ................................................................................................................ 39 viii Inclusion and exclusion criteria ......................................................................... 40 Recruitment procedures ..................................................................................... 40 Data Collection Protocol ................................................................................................ 42 Data collection ................................................................................................... 42 Implementation of interviews ............................................................................ 43 Data management ............................................................................................... 43 Data Analysis: Thematic Analysis ................................................................................. 44 Familiarization of data ....................................................................................... 44 Open coding ....................................................................................................... 45 Re-examination of codes .................................................................................... 45 Checking themes against data set ...................................................................... 46 Defining the scope of themes ............................................................................. 46 Developing analytical narratives ........................................................................ 46 Trustworthiness .............................................................................................................. 47 Role of the researcher ........................................................................................ 47 APPENDICES ............................................................................................................... 49 APPENDIX A: RECRUITMENT EMAIL ........................................................ 50 APPENDIX B: RECRUITMENT FLYER ........................................................ 51 APPENDIX C: STUDY CONSENT FORM ..................................................... 52 APPENDIX D: STUDY INTERVIEW GUIDE ................................................ 55 REFERENCES .............................................................................................................. 60 CHAPTER 4: MANUSCRIPT ONE ........................................................................................ 63 A Critical Analysis of the Impact of the 2011 Dear Colleague Letter on Sexual Violence. ................................................................................................................... 63 Abstract ...................................................................................................................................... 63 Introduction .................................................................................................................... 63 Methods ......................................................................................................................... 67 Participant recruitment and sample .................................................................... 67 Data collection ................................................................................................... 70 Interview protocol .............................................................................................. 70 Data analysis ...................................................................................................... 71 Results ........................................................................................................................... 72 Progress regarding sexual violence policies and procedures on college campuses .......................................................................................... 72 Accountability of institutions to address sexual violence ...................... 72 Guidance was necessary for change to occur ............................ 74 Development of process ......................................................................... 75 Trauma-informed process .......................................................... 75 Awareness of sexual violence on college campuses .............................. 77 Increase in reporting .................................................................. 78 Greater understanding of responsible employees ...................... 79 Support from administration is vital ...................................................... 81 Barriers in developing sexual violence policies and procedures on college campuses ............................................................................................................ 82 Lack of resources ................................................................................... 82 ix Resistance from faculty .......................................................................... 84 Guidance lacked clarity .......................................................................... 85 Discussion and Implications .......................................................................................... 87 Limitations ......................................................................................................... 89 Conclusion ......................................................................................................... 90 REFERENCES .............................................................................................................. 91 CHAPTER 5: MANUSCRIPT TWO ........................................................................................ 96 Recommendations for Effective Sexual Violence Policies and Procedures on College Campuses: Perspectives of Title IX Coordinators ..................................................................... 96 Abstract ...................................................................................................................................... 96 Introduction .................................................................................................................... 96 Methods ......................................................................................................................... 100 Participant recruitment and sample .................................................................... 100 Data collection procedures ................................................................................. 102 Data analysis ...................................................................................................... 103 Results ........................................................................................................................... 104 Clarify the 2011 Dear Colleague Letter, but don’t throw away ....................... 104 Continue to develop a fair process with respondent rights ............................... 106 Process advocates .................................................................................. 107 Treat as a student conduct issue versus a criminal issue ................................. 108 Avoid cross-examination ...................................................................... 109 Develop coordinated collaboration ................................................................... 110 Understand your role an appreciate the work of others ........................ 112 Develop relationships with off-campus community partners ............... 113 Expand training, but uncertain on how ............................................................. 114 Discussion and Implications ......................................................................................... 115 Limitations ........................................................................................................ 120 Conclusion ........................................................................................................ 121 REFERENCES .............................................................................................................. 122 CHAPTER 6: INTEGRATING OF MANUSCRIPTS .............................................................. 126 Concluding Remarks ...................................................................................................... 126 Manuscript One .............................................................................................................. 126 Manuscript Two ............................................................................................................. 127 Integration of Findings ................................................................................................... 128 Implications for Couple and Family Therapy ................................................................ 130 Contributions to Existing Research ............................................................................... 131 REFERENCES .............................................................................................................. 134 x LIST OF TABLES Table 4.1 Participant characteristics .......................................................................................... 69 Table 5.1 Participant characteristics .......................................................................................... 101 Table 5.2 Recommendations for more effective sexual violence policies and procedures ....... 116 xi LIST OF FIGURES Figure 1.1 Conceptual framework: Organizational supports and resistance to college campus sexual violence policy and procedure changes following the implementation and withdrawal of the 2011 Dear Colleague Letter on Sexual Violence ................................... 8 xii Statement of the Problem CHAPTER 1: INTRODUCTION Sexual violence is a pervasive issue facing college campuses today, with 20%-25% of college women experiencing sexual victimization at some point during their college tenure (Fisher, Cullen & Turner, 2000; Gross, Winslett, Roberts, & Gohm, 2006; Karjane, Fisher, & Cullen, 2002; Koss, Gidycz, & Wisniewski, 1987; Tjaden & Thoennes, 2000). Women between the ages of 16 and 24 are at the highest risk for experiencing sexual violence, with 79.6% of all female rape victims suffering the event prior to age 25 (Black, et al., 2011; Rennison, 1999). Furthermore, college women are at the highest risk for experiencing various forms of sexual violence, including unwanted sexual contact or touching, sexual coercion, and rape (American Academy of Pediatrics, 2001; Fisher, et al., 2000; Humphrey & White, 2000). College-aged sexual violence victims experience a multitude of negative mental health outcomes, including anxiety, depression, and PTSD (Campbell, Greeson, Bybee, & Raja, 2008; Kilpatrick, Amstadter, Resnick, & Ruggiero, 2007; Klump, 2006; Pico-Alfonso, et al., 2006; Sarkar & Sarkar, 2005; Tjaden & Thoennes, 2006). Additionally, college-aged sexual violence victims report negative academic consequences such as decreased class attendance, quality of course work, and academic performance (Jordan, Combs, & Smith, 2014; van Roosmalen & McDaniel, 1998). Despite the high rates of sexual violence on college campuses, studies suggest sexual violence is widely underreported, with some studies indicating as low as 2%-5% of college-aged victims file formal reports (Fisher, et al., 2000; Fisher, Daigle, Cullen, & Turner, 2003; Karjane, Fisher, & Cullen, 2005; Tjaden & Thoennes, 2000). College-aged sexual violence victims indicate multiple reasons for not filing formal reports, including concerns of not being believed, 1 feelings of self-blame, alcohol use during the sexual violence event, fear of perpetrator retaliation, and stigma associated with being labeled a victim (Cleere & Lynn, 2013; Fisher, et al., 2000; Fisher, et al., 2003; Sable, Danis, Mauzy, & Gallagher, 2006; Wolitzky-Taylor, et al., 2011). Moreover, many victims note they do not report sexual violence to formal campus officials and service providers due to a fear of experiencing re-traumatization, or “victim- blaming behaviors and practices” conducted by campus offices and service providers which may cause additional stress and trauma for the victim (Amar, 2008; Amar, Strout, Simpson, Cardiello, & Beckford, 2014; Brubaker, 2009; Campbell & Raja, 1999, p. 262; Fisher, et al., 2003; Hassija & Gray, 2013). Despite attempts to combat these concerns through the development of campus- based prevention, intervention, investigation, and conduct services, the issue continues to plague colleges and universities around the country (DeGue, et al., 2014; Fisher, et al., 2000; Orchowski, Meyer, & Gidycz, 2009; Sabina & Ho, 2014). Title IX of the 1972 Education Amendments is the current federal policy in place to combat sexual violence on college campuses (Ali, 2011; Lhamon, 2014; 2015b). Title IX states, “No person in the United States shall, on the basis of sex, be excluding from participation in, be denied the benefits of, or be subjected to discrimination under any educational program or activity receiving federal financial assistance” (Title IX). The policy requires all colleges and universities receiving federal funding to address sexual violence by responding to victims’ service needs and ensuring that all students have equal access to prevention education (Ali, 2011; Lhamon, 2014; 2015b). All students are protected under Title IX and schools must take immediate action to address any claims of sexual violence while creating a safe environment on campus by preventing sexual violence against students in the future (Ali, 2011; Lhamon, 2014; 2015b). 2 There have been significant federal efforts to clarify Title IX guidelines on college campuses in recent years. In 2011, the U.S. Department of Education Office for Civil Rights issued the 2011 Dear Colleague Letter on Sexual Violence, which provided further direction and recommendations for how college campuses can best address sexual violence under Title IX (Ali, 2011; Lhamon, 2014). The 2011 Dear Colleague Letter required colleges and universities to hire a Title IX coordinator to oversee campus compliance with Title IX, review and investigate all complaints of sexual violence, and develop training for all campus faculty, staff, and students on how to appropriately respond to claims of sexual violence (Ali, 2011; Lhamon, 2014). Despite the 2011 Dear Colleague Letter recommending the development and improvement of services for reporting and investigation, studies note students still underutilize these services when provided on campus (Holland & Cortina, 2017; Sabina & Ho, 2014). Campus advocates have noted victims feel campus administrators dismiss their claims of sexual violence, fail to hold accused parties accountable, and instead blame victims for sexual violence experiences (Moylan, 2017). These claims are alarming as colleges and universities face significant liability if they do not have adequate sexual violence policies and procedures or appropriately respond to sexual violence claims (Cantalupo, 2014; Potter, et al., 2016). In September 2017, the 2011 Dear Colleague Letter on Sexual Violence was withdrawn by the Department of Education with the aim of developing a new guidance that provides more fairness to those accused of sexual violence in the future (Jackson, 2017; U.S. Department of Education, 2017). The withdrawal document noted concerns around investigation and conduct mandates, and the pressure these mandates placed on higher education institutions (Jackson, 2017; U.S. Department of Education, 2017). Despite these concerns, insufficient information is known about how campuses adapted policies and procedures since the introduction of the 2011 3 Dear Colleague Letter that may help other campuses understand how to adequately address sexual violence. Additionally, colleges and universities across the nation are now attempting to continue the advancement of sexual violence policies and procedures following the withdrawal, while waiting for what could be a drastically different guidance from the U.S. Department of Education. Purpose of the Study This study addresses how sexual violence policies and procedures on college campuses were affected by the implementation of the 2011 Dear Colleague Letter on Sexual Violence, and later withdrawal of the guidance in September 2017. The purpose of this study is threefold. The first goal is to understand how the 2011 Dear Colleague Letter facilitated positive change and growth regarding sexual violence policies and procedures on college campuses. Numerous studies have demonstrated how college campuses are struggling to combat sexual violence on college campuses (DeGue, et al., 2014; Fisher, et al., 2000; Orchowski, et al., 2009; Sabina & Ho, 2014). Additionally, multiple studies have addressed what college campuses could be doing to better prevent and address sexual violence on college campuses (Coker, et al., 2011; Littelton, Buck, Rosman, & Grills-Taquechel, 2012; Madden, 2018). However, little is known about what has worked well on campuses in regard to sexual violence policies and procedures, such as what has been accomplished or effective, due to the introduction of the 2011 Dear Colleague Letter on Sexual Violence. The second goal is to explore how the 2011 Dear Colleague Letter created challenges or barriers for college campuses as attempts were made to improve sexual violence policies and procedures. It is vital to understand any unintentional consequences that resulted from the guidance so that implementation of future guidance on sexual violence does not repeat similar mistakes. The final goal is to cultivate recommendations for developing effective sexual 4 violence policies and procedures on college campuses following the withdrawal of the 2011 Dear Colleague Letter in 2017. Specifically, this study aims to learn what Title IX Coordinators and Deputy Title IX Coordinators recommend are best practices moving forward now that the 2011 Dear Colleague Letter has been withdrawn and a new guidance on how college campuses should address sexual violence is being developed by the federal government. When the 2011 Dear Colleague Letter was revoked in September 2017, there was limited data on the influence of the guidance on college campuses, and little is still known about how campuses are moving forward with sexual violence policies and procedures as a new guidance is being outlined, but has yet to be implemented (Jackson, 2017; U.S. Department of Education, 2017). Overall, this study hopes to provide clarity on how the 2011 Dear Colleague Letter on Sexual Violence had a lasting impact on the way college campuses address sexual violence despite its withdrawal, and what we can learn about effective campus response to sexual violence in the future from the experts who work with these policies on college campuses every day. Research Questions The research questions guiding this study are as follows: • Primary Research Question: How do federal policies regarding campus response to sexual violence affect service provision on college campuses? • Sub-Research Question One: How did the 2011 Dear Colleague Letter on Sexual Violence facilitate progress and growth in policies and procedures on college campuses? • Sub-Research Question Two: How did the 2011 Dear Colleague Letter on Sexual Violence create challenges or barriers to addressing sexual violence on college campuses? 5 • Sub-Research Question Three: What are recommendations for developing effective sexual violence policies and procedures on college campuses following the withdrawal of the 2011 Dear Colleague Letter on Sexual Violence? Theoretical Framework: Organizational Readiness to Change Theory The overall theoretical framework informing the study is Organizational Readiness to Change Theory (Weiner, 2009). The goal of theory on Organizational Readiness to Change is to understand the deliberate efforts organizations make to get an organization from one state to a more desired state in which the overall effectiveness of the organization is improved (Weiner, 2009). There are multiple ways in which to define organizational change, but broadly it is described as “any modification in organizational composition, structure, or behavior” (Weiner, 2009; Bowditch & Buono, 2001). Weiner’s (2009) Organizational Readiness to Change Theory examines how systems within an organization are “psychologically and behaviorally prepared” to implement changes within the organization regarding policies and procedures (Weiner, 2009). Research demonstrates that as organizations attempt to make changes, they often face resistance (Weiner, 2009; Strebel, 1996); therefore, it is vital to examine what elements inside and outside of the organization lead to resistance versus positive change. More specifically, one must understand what supports and commitments exist within an organization that lead to positive changes and effectiveness within the organization, as well as what barriers and lack of commitment exist within an organization that leads to resistance to change. When the 2011 Dear Colleague Letter of Sexual Violence was introduced by the federal government, colleges and universities across the nation were tasked to make changes regarding their sexual violence policies and procedures (Ali, 2011; Lhamon, 2014). Although changes were facilitated in order to be in accordance with the guidance, many institutions were not prepared 6 and did not have the structure in place to adhere to the strict guidelines of the 2011 Dear Colleague Letter (Jackson, 2017; U.S. Department of Education, 2017). By examining what organizational supports and barriers were in place on college campuses in regard to adapting sexual violence policies and procedures, and how these either led to or prevented change, we can better understand how elements of the 2011 Dear Colleague Letter were effective in developing positive change, and what elements resulted in obstacles. Additionally, this theory allows the researcher to examine how these positive changes and obstacles have been maintained or altered following the withdrawal of the 2011 Dear Colleague Letter. Conceptual Framework By framing the study through an Organizational Readiness to Change lens, the data will reflect how the implementation and later withdrawal of the 2011 Dear Colleague Letter on Sexual Violence influenced college campus sexual violence policies and procedures. Furthermore, using the Organizational Readiness to Change Theory will allow the data to demonstrate what supports and commitments within campuses facilitated positive growth and changes around how to respond to sexual violence, and what barriers and resistance existed within these organizations that may have led to challenges when attempting to advance sexual violence policies and procedures. Figure 1.1 displays the study’s conceptual framework, which demonstrates how the 2011 Dear Colleague Letter facilitated positive changes and potential obstacles to change, as well as how these changes are influenced by the withdrawal of the guidance. Additionally, the conceptual framework demonstrates how organizational support and resistance within college campuses may have contributed to the positive growth or barriers that developed as a result of the 2011 Dear Colleague Letter guidance. 7 Figure 1.1 Conceptual framework: Organizational supports and resistance to college campus sexual violence policy and procedure changes following the implementation and withdrawal of the 2011 Dear Colleague Letter on Sexual Violence Organizational Readiness to Change Organizational Supports and Commitment to Change College Campus Sexual Violence Policies and Procedures (Prevention, Intervention, Investigation, and Adjudication) How implementation influences changes Organizational Barriers and Resistance to Change Positive Changes and Growth How withdrawal influences changes Challenges and Barriers to Change Implementation of the 2011 Dear Colleague Letter on Sexual Violence 2017 Withdrawal of the 2011 Dear Colleague Letter on Sexual Violence Format of Manuscripts Manuscript One: A Critical Analysis of the Impact of the 2011 Dear Colleague Letter on Sexual Violence. All federally funded colleges and universities in the United States are required under Title IX to address issues of gender discrimination, such as sexual violence (Ali, 2011; Lhamon, 2014; 2015b). Multiple studies have addressed the difficulties college campuses have faced while attempting to improve prevention, intervention, investigation, and conduct services for victims of sexual violence (DeGue, et al., 2014; Fisher, et al., 2000; Orchowski, et al., 2009; Sabina & Ho, 2014). The 2011 Dear Colleague Letter on Sexual Violence was introduced by the federal government as an attempt to clarify what standards 8 college campuses need to meet in order to combat sexual violence, and to push campuses to use evidence-based practices in all sexual violence services (Ali, 2011; White House Task Force to Protect Students from Sexual Assault, 2014). Since the introduction of the 2011 Dear Colleague Letter, research continues to focus on how college campuses are not meeting the standards to appropriately address the needs of sexual violence victims, while sparsely addressing what sexual violence policies and procedures have been effective, or what continues to create barriers to developing better sexual violence policies and procedures (DeGue, et al., 2014; Holland & Cortina, 2017; Perkins & Warner, 2017; Sabina & Ho, 2014). To better understand how the 2011 Dear Colleague Letter impacted the way college campuses address sexual violence policies and procedures, manuscript one focuses on the ways in which the guidance led to positive growth and change on college campuses, while also creating additional barriers to change. Title IX Coordinators and Deputy Title IX Coordinators, who oversee the development and execution of sexual violence policies and procedures on their college campuses, were asked to share their perceptions of how the 2011 Dear Colleague Letter pushed colleges and universities to make improvements, while also causing potential challenges. Additionally, participants were asked about what supports and obstacles existed on their college campuses that aided improvements or created barriers to change regarding sexual violence policies and procedures. Manuscript Two: Recommendations for Effective Sexual Violence Policies and Procedures on College Campuses: Perspectives of Title IX Coordinators. Despite the unknown about how the 2011 Dear Colleague Letter on Sexual Violence affected sexual violence policies and procedures on college campuses, the guidance was withdrawn in September 2017, noting the pressures the guidance placed on campuses and lack of fairness for those accused of sexual violence (Jackson, 2017; U.S. Department of Education, 2017). The 9 second manuscript will explore Title IX Coordinators’ and Deputy Title IX Coordinators’ recommendations for developing effective sexual violence policies and procedures on college campuses. As media outlets report on rumors of potential changes in a new guidance, it is vital to understand how those who work most closely with campus sexual violence policies and procedures believe colleges and universities should address sexual violence. Suggestions regarding what Title IX Coordinators and Deputy Title IX Coordinators believe a federal guidance should speak to will be addressed. 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Title IX of the Educational Amendments of 1972, Pub. L. No. 92-318, 86 Stat. 235 (1972). Tjaden, P., & Thoennes, N. (2000). Full report of the prevalence, incidence, and consequences of violence against women: Findings from the National Violence Against Women Survey: Research report. Washington, D.C.: National Institute of Justice and the Centers for Disease Control and Prevention. Tjaden, P., & Thoennes, N. (2006). Extent, nature and consequences of rape victimization: Findings from the National Violence against Women Survey. Washington, DC: National Institute of Justice. U.S. Department of Education. (2017). Q&A on campus sexual misconduct. Washington, DC: U.S. Department of Education, Office for Civil Rights. van Roosmalen, E., & McDaniel, S. A. (1998). Sexual harassment in academia: A hazard to women’s health. Women’s Health, 28, 33-54. Weiner, B. J. (2009). A theory of organizational readiness for change. Implementation Science, 4(67). https://doi.org/10.1186/1748-5908-4-67 White House Task Force to Protect Students from Sexual Assault. (2014). Not alone: The first report of the White House Task Force to Protect Students from Sexual Assault. Wolitzky-Taylor, K., Resnick, H. S., McCauley, J. L., Amstadter, A. B., Kilpatrick, D. G., & Ruggiero, K. J. (2011). Is reporting of rape on the rise? A comparison of women with reported versus unreported rape experiences in the National Women’s Study-Replication. Journal of Interpersonal Violence, 26, 807-832. 15 Significance of Problem CHAPTER 2: LITERATURE REVIEW Definition. The Centers for Disease Control and Prevention (CDC) defines sexual violence as “a sexual act that is committed or attempted by another person without freely given consent of the victim or against someone who is unable to consent or refuse” (Basile, Smith, Breiding, Black, & Mahendra, 2014, p. 11). Sexual violence consists of a range of behaviors including completed or attempted forced penetration of a victim (rape), unwanted sexual contact or touching of the genitalia, anus, groin, breast, inner thigh, or buttocks of any person without their consent (sexual assault), or creating a sexually hostile environment by making unwanted sexual comments or threats (sexual harassment) (Basile, et al., 2014). Acts of sexual violence are motivated by the need to control or harm someone; not by an uncontrollable sexual urge or desire (Basile, et al., 2014). According to the National Intimate Partner and Sexual Violence Survey conducted in 2010, approximately 18.3% of women will experience rape or attempted rape in their lifetimes, with the majority experiencing rape prior to the age of 25 (79.6%) (Black, et al., 2011). Additionally, 13% of women report the experience of sexual coercion during their lifespan (Black, et al., 2011). Adverse consequences. Multiple studies describe a plethora of psychological, mental, and physical health problems as a result of experiencing sexual violence. During the immediate aftermath of sexual violence, victims experience a range of psychological emotions, including shock, shame, guilt, confusion, fear, denial, distrust, and withdrawal (Gidycz & Koss, 1991; Glenn & Byers, 2009; Klump, 2006; Vidal & Petrack, 2007). Victims commonly report negative mental health outcomes, such as increased depression symptoms, anxiety, PTSD, suicidal ideation, self-harm, and decreased self-esteem (Campbell, Greeson, Bybee & Raja, 2008; Jordan, 16 Campbell, & Follingstad, 2010; Kilpatrick, Amstadter, Resnick, & Ruggiero, 2007; Klump, 2006; Pico-Alfonso, et al., 2006; Sarkar & Sarkar, 2005; Tjaden & Thoennes, 2006). Physical symptoms resulting from sexual violence include decreases in overall health, pelvic pain, headaches, sexually transmitted diseases, and somatic symptoms such as abdominal pain, urination, and pain during intercourse (Campbell, et al., 2008; Golding, 1994; Sarkar & Sarkar, 2005; Vidal & Petrak, 2007). Additionally, research demonstrates sexual violence leads to an increase in sexual partners and activity, increased use of alcohol and drugs during sexual activities, decreased condom use, and increases in sexual dissatisfaction, distress, shame, and dysfunction in victims (Campbell, Self, & Ahrens, 2004; Glenn & Byers, 2009; Littleton, Grills- Taquechel & Axsom, 2009) College sexual violence victims. Sexual violence is a prolific health issue plaguing college campuses around the nation. Evidence suggests 20%-25% of women have experienced sexual violence while in college (Fisher, Cullen, & Turner, 2000; Gross, Winslett, Roberts, & Gohm, 2006; Karjane, Fisher, & Cullen, 2002; Koss, Gidycz & Wisniewski, 1987; Tjaden & Thoennes, 2000), with highest prevalence occurring during the first year of college (Humphrey & White, 2000). In addition to the adverse mental health outcomes (e.g. anxiety, depression, and PTSD) (Campbell, et al., 2008; Kilpatrick, et al., 2007; Klump, 2006; Pico-Alfonso, et al., 2006; Sarkar & Sarkar, 2005; Tjaden & Thoennes, 2006) and physical health concerns (e.g. pelvic pain, headaches) (Campbell, et al., 2008; Golding, 1994; Sarkar & Sarkar, 2005; Vidal & Petrak, 2007), college women report harmful academic consequences, such as lower grades, class attendance, and quality of work (Jordan, Combs, & Smith, 2014; van Roosmalen & McDaniel, 1998). Additionally, college-aged sexual violence victims are at an increased risk for dropping out of school compared to non-victim students (Jordan, et al., 2014). 17 Campus reporting and re-traumatization. Studies indicate that as low as 2%-5% of college-aged sexual violence victims report their violence experiences to campus officials (Fisher, et al., 2000; Fisher, Daigle, Cullen, & Turner, 2003; Karjane, et al., 2002; Tjaden & Thoennes, 2000). Victims note concerns that campus officials lack sensitivity while handling claims (Amar, 2008; Holland & Cortina, 2017; Moylan, 2017), and fear experiencing re- traumatization when interacting with campus officials (Amar, 2008; Holland & Cortina, 2017; Moylan, 2017). Most sexual violence incidents on college campuses do not fit the stereotypical conception of sexual violence as most experiences happen in private settings and are perpetrated by acquaintances, friends, or romantic partners of the victim (Cleere & Lynn, 2013; Fisher, et al., 2000; Wolitzky-Taylor, et al., 2011). Due to the private and intimate context in which many campus sexual violence events occur, it is typical for the victim and perpetrator to be the only witnesses to the violence, making it difficult for victims to prove a sexual violence incident occurred (Hartmann, 2015). The seclusion of the sexual violence events creates more opportunities to potentially blame the victim and rationalize perpetrator behaviors, which can lead victims to feel re-traumatized (Hartmann, 2015). According to Campbell and Raja (1999), re-traumatization is “the unresponsive treatment rape victims receive from social system personnel, such as victim-blaming behaviors and practices engaged in by community service providers, which further the rape event, resulting in additional stress and trauma for victims” (p. 262). Re-traumatization typically stems from formal service providers treating victims in an insensitive manner, not providing enough assistance, or not providing assistance that is deemed helpful to the victim (Campbell & Raja, 1999). The experience of re-traumatization can increase pre-existing negative mental health outcomes, such as symptoms of depression, anxiety, PTSD, and psychological distress (Campbell, et al., 2008). 18 Re-traumatization can also lead to feelings of isolation, suicidal ideation, chronic physical health issues such as headaches and pain, and weight changes (Campbell, et al., 2008), and further decreases in academic performance and attendance (Jordan, et al., 2014). Multiple attempts at guidance and policies have been introduced over the years in an attempt to address these issues surrounding campus sexual violence policies and procedures. Campus Sexual Violence Policy Review Over the years there have been multiple federal policies aimed to address sexual violence on college campuses. Although Title IX is the primary federal policy informing college campuses on responding to sexual violence, the past 40 years have witnessed a plethora of policies and guidelines which have shaped how colleges and universities currently address sexual violence. Title IX. Title IX of the 1972 Education Amendments is a landmark federal regulation for sexual violence victims on college campuses (Ali, 2011; Lhamon, 2014; 2015b). Traditionally, Title IX was known for advancing women’s participation in athletics, but over time became the groundbreaking mechanism for combating sexual violence on college campuses (Ali, 2011; Lhamon, 2014; 2015b). All students on college campuses are protected under Title IX from gender and sexual discrimination (Ali, 2011; Lhamon, 2015b). Title IX requires all federally funded colleges and universities to respond appropriately to sexual violence through service provision and investigation, and maintain equal access to prevention education (Ali, 2011; Lhamon, 2014; 2015b). Furthermore, Title IX requires colleges and universities to take immediate action when addressing claims of sexual violence and schools must create a safe environment on campus through prevention means (Ali, 2011; Lhamon, 2014; 2015b; Newins & White, 2018). Ultimately, Title IX is intended to decrease sexual violence on college campuses 19 and provide appropriate measures to treat and assist resolution when a claim is made on campus (Newins & White, 2018). Clery Act. In addition to Title IX, the Jeanne Clery Disclosure of Campus Security Policy and Campus Crime Statistics Act (Clery Act) was signed into law in 1990, requiring any college or university participating in federal student aid programs to disclose all campus safety information and to publicly outline basic requirements for handling incidents of sexual violence (Ali, 2011; Karjane, et al., 2002). Under the Clery Act, colleges and universities are mandated to outline all policies and procedures for reporting and investigating complaints of sexual violence, possible sanctions for policy violations, and available campus resources (Ali, 2011; Karjane, et al., 2002). Additionally, all colleges and universities are required to produce an Annual Security Report (ASR) that details any crimes reported on campus from the previous year and the outcome of any on-campus investigation procedure (Ali, 2011; Karjane, et al., 2002). Although colleges and universities must publish all campus-related reports and investigation outcomes of sexual violence claims to create transparency around the process, confusion continued regarding how higher education institutions conduct internal investigations of sexual violence complaints, prevent future events of sexual violence, and appropriately treat existing victims (Ali, 2011; Cantalupo, 2014). Prior Dear Colleague Letters addressing sexual violence. Between 1997 and 2006, multiple Dear Colleague Letter guidance documents were issued by the U.S. Department Education Office of Civil Rights to better clarify how colleges and universities should respond to claims of sexual violence, particularly sexual harassment, under Title IX. The 1997 Dear Colleague Letter stated that sexual harassment of students was prohibited under Title IX (U.S. Department of Education, 1997). Specifically, the guidance prohibited Quid Pro Quo 20 Harassment, defined as when “a school employee explicitly or implicitly conditions a student’s participation in education program or activity or bases an education decision and student’s submission to unwelcome sexual advances, requests for sexual favors, or other verbal, nonverbal, or physical conduct of sexual nature” (U.S. Department of Education, 1997, p. 1). Additionally, the 1997 Dear Colleague Letter guidance provided clarity around the definition of what constitutes a hostile environment created from sexual harassment, and required campuses regulated by Title IX to have grievance procedures in place for students to make formal complaints of sexual discrimination (U.S. Department of Education, 1997). In 2001, the U.S. Department of Education Office of Civil Rights issued a new Dear Colleague Letter to replace the 1997 guidance (U.S. Department of Education, 2001). The 2001 Dear Colleague Letter was issued to reaffirm compliance standards applied to investigations of sexual harassment under Title IX (U.S. Department of Education, 2001). Although similar to the 1997 Dear Colleague Letter, the new guidance responded to Supreme Court decisions on campus sexual harassment cases, which found that campuses could be found liable for monetary damages if an instructor sexually harasses a student and a school official of authority has knowledge of the harassment, but the official was deliberately indifferent in addressing the claim of sexual harassment (U.S. Department of Education, 2001). Additionally, the 2001 guidance noted schools must evaluate requests for confidentiality in the context of the school’s responsibility to provide a safe and nondiscriminatory environment (U.S. Department of Education, 2001). The 2006 Dear Colleague Letter noted the multiple attempts by universities to address sexual harassment, but further clarified standards for addressing sexual harassment on college campuses after high rates of sexual harassment continued on campuses (Monroe, 2006). 21 2011 Dear Colleague Letter. The most recent, and most strict, federal effort to clarify Title IX guidelines on college campuses has generated significant national attention. In 2011, the Department of Education Office for Civil Rights issued another Dear Colleague Letter, which provided further direction and recommendations for how college campuses can best address sexual violence under Title IX (Ali, 2011). The 2011 Dear Colleague Letter on Sexual Violence requires colleges and universities to hire a Title IX coordinator to oversee all campus compliance with Title IX, review and investigate all complaints of sexual violence, and develop training for all campus faculty, staff, and students on how to appropriately respond to claims of sexual violence (Ali, 2011; Lhamon, 2015a). Additionally, the 2011 Dear Colleague Letter clarified that under Title IX, all responsible campus employees (e.g. faculty, staff, and some students) other than confidential resources, such as campus therapists and counselors, are mandated to report any claims of sexual violence to the campus Title IX Coordinator for further investigation (Ali, 2011; Newins & White, 2018). In an attempt to provide more trauma-informed services to sexual violence victims, college campuses were required to use the preponderance of evidence standard when conducting investigations of sexual violence claims under the new guidance (Ali, 2011). The guidance elaborated on the extent students were protected under Title IX, noting that all students are protected whether the sexual violence act occurred on-campus or off-campus (Ali, 2011; White House Task Force to Protect Students from Sexual Assault, 2014). Furthermore, the 2011 Dear Colleague Letter indicated that campuses must adopt and publish grievance procedures and a notice of nondiscrimination as means of prevention against sexual violence (Ali, 2011; White House Task Force to Protect Students from Sexual Assault, 2014). Finally, the guidance indicated that in order to be in full compliance with Title IX, college campuses must take 22 proactive measures to prevent sexual violence, such as implementing education programs and making victim services widely available (Ali, 2011; White House Task Force to Protect Students from Sexual Assault, 2014). Despite the 2011 Dear Colleague Letter recommending the development and improvement of services for reporting and investigation, studies have suggested that students still underuse these services when provided on campus (Holland & Cortina, 2017; Sabina & Ho, 2014). Campus advocates have noted victims still feel campus administrators dismiss their claims of sexual violence, fail to hold the accused parties accountable, and instead blame the victims for their sexual violence experiences (Moylan, 2017). These claims are alarming because colleges and universities face substantial liability if they do not appropriately respond to and investigate claims of sexual violence (Cantalupo, 2014; Potter, et al., 2016). Additionally, multiple campuses noted difficulties around adherence to the guidance and indicated feasibility issues around implementing the strict recommendations around investigation (Cantalupo, 2014). Despite these concerns, there is still insufficient information about how the 2011 Dear Colleague Letter directly influenced change on college campuses regarding sexual violence policies and procedures, particularly how the guidance led to improvements or complications around investigation, intervention, and prevention services. Campus Resources to Address Sexual Violence Investigation and conduct. Limited research exists examining the campus sexual violence investigation and adjudication or conduct process. The manner in which colleges and universities handle claims of sexual violence varies from campus-to-campus (Potter, et al., 2016). Neither Title IX nor the 2011 Dear Colleague Letter set forth a formal procedure to investigate and adjudicate claims of sexual violence (Veidlinger, 2016). Policies, procedures, 23 definitions, and terms that determine what constitutes sexual violence and how to respond differ depending on the campus (Potter, et al., 2016; Veidlinger, 2016). Although 93% of colleges and universities are found to publish their sexual violence policies on their websites, there are still inconsistencies regarding investigation policies and procedures, definitions of sexual violence, and how due process is established (Graham, et al., 2017; Konradi, 2016). Many campuses conduct a form of formal grievance process that examines claims of sexual violence through the use of individual fact-finders who work under Title IX Coordinators (Amar, Strout, Simpson, Cardiello, & Beckford, 2014; Cantalupo, 2014; Karjane, et al., 2002; Karjane, Fisher & Cullen, 2005; Veidlinger, 2016). The individual fact-finders who conduct these investigations are typically university employees who gather all evidence pertaining to the claims, including any documentary evidence, and interviews with the complainant (the victim), respondent (the accused), or any other potential witnesses (Amar, et al., 2014; Karjane, et al., 2015; Veidlinger, 2016). Once all evidence is gathered and analyzed, a report is generated and provided to each party summarizing all evidence collected and the determination of policy or conduct violation based on the evidence (Veidlinger, 2016). Unlike a criminal investigation where the accused must be “guilty beyond a reasonable doubt,” campus investigation and adjudications use a “preponderance of evidence” standard in which the complainant only needs to determine the policy or conduct violation was more likely than not to have occurred (Amar, et al., 2014; Veidlinger, 2016). According to Holland and Cortina (2017), universities have created multiple positions to conduct these investigations; however, employee and unit titles are different from campus-to-campus. The campus investigation process has been met with some controversy due to the procedure’s resemblance to criminal investigations (Cantalupo, 2014). Evidence suggest campus 24 administrators believe once a claim of sexual violence is reported, the university has a responsibility to investigate the claim while balancing the needs of both the complainant and respondent (Amar, et al., 2014; Karjane, et al., 2005). Some have argued that by providing more rights to the respondents and balancing the needs of both parties, victims are hindered as their reports are exposed to those they accused of sexual violence and may then encounter their respondents on campus (Cantalupo, 2014; Holland & Cortina, 2014; Karjane, et al., 2005). Others note the importance of providing equal rights to both parties and believe the 2011 Dear Colleague Letter went too far in overcorrecting for the needs of complainants (Jackson, 2017). This potentially creates an investigation and conduct system that not only causes further harm to victims but doesn’t allow due process to those who are accused of committing sexual violence (Harper, Maskaly, Kirkner, & Lorenz, 2017). Prevention and education. Despite the recent innovation of multiple sexual violence prevention and education programs, limited research exists regarding the effectiveness of these programs. Campus sexual violence prevention and education has historically focused on self- defense training, and risk reduction or rape avoidance programs for women; however, these programs present inconsistent results (Ullman, 2007). These programs may obtain helpful points (Gidycz, et al., 2015; Ullman, 2007), but often put the onus on the victim to prevent sexual violence versus bystanders and the individuals who perpetrate the violence. Recent studies on prevention have focused on examining bystander intervention through prevention education programs including Safe Dates, Coaching Boys to Men, and Green Dot, among others (Banyard, Moynihan, & Plante, 2007; Breklin & Forder, 2001; Coker, et al., 2011; DeGue, et al., 2014; Fisher, Daigle, & Cullen, 2008; Foshee, et al., 1996; Miller, et al., 2012). Although there are differences among procedures and audiences of these programs, the goals of 25 each center on creating allies or helpers when they encounter sexual violence (Katz & Moore, 2013). Bystander intervention approaches believe that all individuals have a responsibility to address sexual violence on campus, whether before, during, or after the act occurs (Barnyard, et al., 2004; McMahon, Postmus, & Koenick, 2011). These approaches focus on increasing campus community members’ awareness of sexual violence myths and tactics, while training students on how to intervene when events of sexual violence present themselves (Banyard, et al., 2004; Banyard, et al., 2007). According to Katz and Moore (2013), students who attend bystander intervention trainings were more likely to report prosocial attitudes, increased bystander efficiency, and intent to help others. Students were also less likely to accept rape myths, but there was no evidence to support whether these programs influenced perpetrator behaviors or rates (Katz & Moore, 2013), suggesting limited information on whether education and prevention programs actually decrease rates of sexual violence. Additionally, there is limited research on how campus officials go about development of prevention and education programs that fit the needs of their individual campuses. Intervention. The 2011 Dear Colleague Letter required college campuses nationwide to improve their intervention response to sexual violence (Ali, 2011; Sabina & Ho, 2014). In response, campuses have worked to augment campus-based services, such as violence-specific counseling and crisis centers, and victim-centered police investigations (Ali, 2011; Krebs, Lindquist, Berzofsky, Shook-Sa, & Peterson, 2016; Sabina & Ho, 2014). However, there is evidence to suggest services are still underutilized by victims (Krebs, et al., 2016; Sabina & Ho, 2014). Only 20% of college-aged sexual violence victims utilize any campus-based service (e.g. campus police, physical health, or mental health service) (Nasta, et al., 2005), and the prevalence 26 of service utilization varies significantly between studies (Amstadter, McCauley, Resnick, & Kilpatrick, 2008; Krebs, et al., 2016; Nasta, et al., 2005; Sabina & Ho, 2014). Mental health services are utilized most frequently for sexual violence experiences (Amstadter, et al., 2010; Gurette & Caron, 2007; Lindquist, et al., 2013; Krebs, et al., 2016; Prospero & Vohra-Gupta, 2008, Sabino & Ho, 2014), with one study indicating 90% of sexual violence help seekers used mental health services such as therapy or counseling (Walsh, Banyard, Moynihan, Ward, & Cohn, 2010). Amstadter, et al. (2010) found roughly half of sexual violence victims sought out a mental health professional, while 38% sought medical attention. Multiple studies have found the sexual violence service utilization process is complex, as victims are likely to seek help from various resources and at different time points following victimization (DeLoveh & Cattaneo, 2017; Patterson, Greeson, & Campbell, 2009; Tjaden & Thoennes, 2006), in addition to being affected by different contextual influences (e.g. campus climate or attitude about sexual violence) (Liang, Goodman, Tummala-Nara, & Wintraub, 2005). Therefore, it is difficult to determine how the 2011 Dear Colleague Letter influenced sexual violence service provision on college campuses, and future research is needed to explore how the guidance played a role in service development prior to the withdraw of the guidance. Withdrawal of 2011 Dear Colleague Letter In September of 2017, the U.S. Department of Education Office for Civil Rights withdrew the Dear Colleague Letter on Sexual Violence issued in 2011 (Jackson, 2017; U.S. Department of Education, 2017). With the withdrawal of the 2011 guidance, college campuses are referred to follow the previous 2001 and 2006 Dear Colleague Letters documents as the U.S. Department of Education develops a new guidance to replace the 2011 Dear Colleague Letter (Jackson, 2017). According to the Office for Civil Rights, the 2011 guidance placed 27 inappropriate pressure on colleges and universities to develop and adopt sexual violence policies and procedures that did not afford fairness, particularly to those accused of committing sexual violence (Jackson, 2017; U.S. Department of Education, 2017). It was noted that the 2011 Dear Colleague Letter was not successful in helping colleges and universities to clarify Title IX requirements, and instead made Title IX compliance more confusing (Jackson, 2017). However, limited evidence has been presented to support these claims or how the withdrawal of the guidance will further impact colleges and universities. Need to understand impact of the 2011 Dear Colleague Letter. Despite the implementation of multiple guidance documents on sexual violence, limited research has been conducted to determine the influence of these guidance documents. Perhaps most significant, the 2011 Dear Colleague Letter set out to drastically revamp the ways college campuses investigate, intervene, and prevent sexual violence (Ali, 2011; Lhamon, 2015b; White House Task Force to Protect Students from Sexual Assault, 2014). Research must establish how the guidance helped college campuses facilitate positive change regarding policy and procedures, while also exploring how the guidance failed to assist, and potentially hinder, campuses in their attempts to combat sexual violence. 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Journal of Interpersonal Violence, 26, 807-832. 36 Overview of Research Design CHAPTER 3: METHODS There were three main goals to this study. The first was to explore how the 2011 Dear Colleague Letter on Sexual Violence facilitated positive change regarding sexual violence policies and procedures on college campuses. Secondly, the study aimed to understand institutional challenges that developed as a result of adherence issues with the 2011 Dear Colleague Letter. The final goal of the study was to acquire recommendations for developing effective sexual violence policies and procedures on college campuses following the withdrawal of the 2011 Dear Colleague Letter in 2017. This study applied a qualitative design informed by the thematic analysis approach (Braun & Clark, 2006). Data collection involved the use of in-depth, semi-structured interviews with 15 participants who identified as being currently employed as Title IX Coordinators or Deputy Title IX Coordinators at public higher education institutions in the Midwest United States. The interview guide included tour and process questions that explored how elements of the 2011 Dear Colleague Letter on Sexual Violence affected their college campuses, and how the withdrawal influenced campus sexual violence procedures and policies moving forward, including their recommendations for developing effective policies and procedures. Data analysis employed an analytical method of data familiarization, open coding, re-examining initial codes and linked data, checking codes against the entire data set, developing themes, defining the scope and focus of each theme, and developing an analytical narrative for each theme (Braun & Clark, 2006). Various audit strategies were utilized during the course of the study to ensure trustworthiness of the data analysis, including the use of an audit trail, debriefing, and member checking. 37 Qualitative Approach Qualitative research is an exploratory process of inquiry that aims to understand in-depth fundamental reasons and motivations behind human behavior (Creswell, 2013). Qualitative methods are compatible for exploratory studies as the methodology aims to gain a detailed understanding of the underlying meanings within certain phenomena in areas where limited research exists (Creswell, 2013; Marshall & Rossman, 2011; Merriam, 2009). Qualitative research allows the researcher to be the primary means of analysis by conveying the meaning of textual data generated from working closely to the perspectives and experiences of the study sample (Merriam, 2009). Themes and theories are then furthered developed through the rich descriptions that emerge from participant experiences (Merriam, 2009). Qualitative methodologies are widely used within sexual violence research due the approach’s ability to bring voice to underserved populations and those who work with these populations (Chan, Teram & Shaw, 2017). Scholars have noted the benefits of using qualitative methods with those who work in the sexual violence field as it allows these individuals the opportunity to talk through their experiences while feeling valued about their expertise and knowledge regarding sexual violence (Chan, et al., 2017; Ullman, 2005). This is particularly important for Title IX Coordinators and Deputy Title IX Coordinators due to their critical role developing campus sexual violence policies and procedures, and their previous exclusion from the research on campus response to sexual violence. Additionally, qualitative methodology allows for the advancement of new theories and approaches, while providing a critical evaluation of current sexual violence procedures and policies (Chan, et al., 2017; Testa, Livingston, & VanZile-Tamsen, 2011) 38 Sampling and Participants Sample. A sample of 15 Title IX Coordinators and Deputy Title IX Coordinators from public higher education institutions were recruited via email between the months of October 2018 and February 2019. All federally funded public colleges and universities are required to designate at least one employee to oversee Title IX compliance of their campus in adherence to Title IX (Lhamon, 2015a; 2015b; U.S. Department of Education, 2015); therefore, Title IX Coordinators and Deputy Title IX Coordinators from these specific institutions in the Midwest United States were targeted for the study. Email addresses of potential participants were obtained by searching each campus website as Title IX requires all federally funded higher education institutions to publicly post how the Title IX Coordinator can be contacted with a report of sexual violence (Lhamon, 2015a; 2015b; U.S. Department of Education, 2015). Title IX Coordinators and Deputy Title IX Coordinators were best suited to discuss the lasting impacts of the 2011 Dear Colleague Letter on Sexual Violence on college campuses due to their substantial role in overseeing all campus sexual violence policies and procedures, including investigation, conduct, prevention, and intervention services (Lhamon, 2015b). This study utilized a non- probability, purposive sampling method as participants were specifically recruited due to their status as a Title IX Coordinator or Deputy Title IX Coordinator at a public college or university in the Midwestern United States (Rubin & Babbie, 2017). The researcher recruited a total number of 15 participants prior to reaching saturation regarding final themes (Fusch & Ness, 2015). The research purposely recruited Title IX Coordinators and Deputy Title IX Coordinators from multiple sites (e.g. different public colleges and universities). This allowed for an additional level of confidentiality for participants as it protects the results from being tied to a specific 39 institution. Using multiple sites also allowed for analysis comparison between different types and sizes of public colleges and universities. For example, the amount of resources available at larger institutions to address sexual violence is more expansive than resources at smaller institutions. Such findings have important implications for developing future sexual violence policies and procedures by providing valuable information on how to adapt these methods to different university and college settings. Inclusion and exclusion criteria. In order to be eligible to participate, individuals had to meet the following criteria. First, participants were required to be currently employed as either a Title IX Coordinator or Deputy Title IX Coordinator at the time of their interview. One participant did not have the specific title of Title IX Coordinator or Deputy Title IX Coordinator but did oversee the student conduct process at their institution. This was deemed as the equivalent of being a Deputy Title IX Coordinator, as the role of other Deputy Title IX Coordinators in the study included overseeing the student conduct process. Second, participants had to be employed at a public college or university that receives some form of federal funding as these higher education institutions are required under Title IX to employ one or more individuals to oversee all sexual violence policies and procedures on their campuses (Lhamon, 2015b). Third, participants were required to be employed in the field of higher education for a period no less than 18 months at the time of recruitment, as this meant the individual was employed on a college campus before and after the withdrawal of the 2011 Dear Colleague Letter. Potential participants were excluded if they did not meet the inclusion requirements. Recruitment procedures. Potential participants were recruited through personal invitation by email. A database of potential participants was created by locating the contact information (e.g. email and phone number) of all Title IX Coordinators form public colleges and 40 universities in 9 Midwestern states. All public universities and colleges which receive any type of federal funds are required under Title IX to publicly post online the name, office, and contact information for the institution’s Title IX coordinator (Lhamon, 2015b). By recruiting from multiple states, participants could feel more at ease regarding confidentiality. Initial emails were sent to all potential participants from 6 of the Midwestern states with information regarding the study, including description of research study, length of interview, and contact information if the individual was interested in being interviewed for the study. The invitation used during recruitment also included a description of the informed consent process and confidentiality. This was important for this sample as there could have been concerns about discussing the sexual violence policies and procedures of their current institution of employment. Participants were given the option of conducting the interview in a private location of their choice, face-to-face in-person or audio conference, to ensure feelings of safety. All participants were notified of monetary compensation in the form of a $50 digital Amazon gift card for their participation in the interview. A flyer with information on the research study was also included in the recruitment email. Appendix A contains a copy of the initial recruitment email that was sent to all potential participants. Appendix B contains a copy of the recruitment flyer that was attached to recruitment emails. Once eligibility was confirmed, contact information was secured and an interview was arranged. The research study’s consent form (Appendix C) listing all confidentiality information was sent to participants prior to their interviews and discussed prior to the start of each interview. The researcher initially sent out three rounds of recruitment emails to a total of 81 potential participants, which resulted in a total of 14 interested participants, and 12 eventual participants. In order to reach the desired number of at least 15 participants, an additional round 41 of recruitment with 18 more potential participants from 3 additional states was conducted, which resulted the 3 additional participants, and final sample of 15 participants. Data Collection Protocol Study procedures were approved by the Michigan State University Institutional Review Board. Prior to the start of each interview, participants were asked to provide assent to participate in the study and to be audio-recorded during the interview. A semi-structed interview guide was used during each interview. An extensive list of probes and follow-up questions reflecting the theoretical framework were utilized throughout the interview guide. Appendix D contains a copy of the semi-structured interview guide used in the research study. Data collection. Interviews were semi-structured and included broad, open-ended questions such as tour questions, follow-up questions, and probes regarding certain content areas informed by the theoretical framework. In-depth interviews are an essential method of qualitative data collection (Creswell, 2013; Rubin & Rubin, 2012), and are compatible with thematic analysis (Braun & Clark, 2006). Individual interviews offer the opportunity to collect in-depth, detailed narratives about each participant’s unique experiences (Creswell, 2013; Marshall & Rossman, 2011). Twelve of the interviews were face-to-face interactions, either in-person or through Zoom video conference in an attempt to build rapport between participants and the interviewer, which was essential for the study due to its sensitive nature (Rubin & Rubin, 2012). The remaining 3 interviews were conducted over Zoom audio conference without video or over the phone, at the request of the participant. The interview questions were aimed at creating an opportunity to identity relevant themes according to the participants in relation to the research topic (Rubin & Rubin, 2012). The format allowed for modifications during the course of the 42 research study when reoccurring, relevant themes were identified during the interviewing process and not originally included in the interview guide (Rubin & Rubin, 2012). Implementation of interviews. Prior to the start of each interview, the interviewer would provide the participant with a copy of the consent form (Appendix C). The interviewer explained all content included in the consent form, including information on the study background, research team member contact information for further questions following the interview, procedures for ensuring participant’s confidentiality, and contact information for the Human Research Project Program within the Institutional Review Board at Michigan State University. The consent form also explained any potential risks participants might experience by participating in the research study, as well as the benefits to participating in the study. After going through each portion of the consent form, participants were allowed to ask any question regarding the study they wish to be clarified. Once all participant questions were answered, the participant was asked to provide assent to participate in the study, and to be audio recorded prior to beginning the interview. Verbal assent to participant and be audio recorded was included at the beginning of all recordings. Following the completion of each interview, participants were asked whether they would be able to accept the $50 digital Amazon gift card as compensation for participating in the study. Nine participants declined compensation for participating, and 6 participants were sent a digital gift card through email following the interview. Data management. Raw data from the interview, such as electronic recordings, were saved on the researcher’s password protected computer file with restricted access. Any hard copy files were kept in a secured, locked cabinet in the primary investigator’s office. Electronic versions of transcriptions were also saved using password protected computer files. All IRB recommendations were obeyed to ensure safety of the data. 43 Data Analysis: Thematic Analysis Data analysis followed the tenets of thematic analysis, which identifies, analyzes, and reports emerging patterns across data sets to provide detailed and rich descriptions of the phenomenon being explored by the research question (Braun & Clark, 2006). Thematic analysis organizes the data set according to relevant themes previously identified in literature while also allowing for alternative emerging themes through the data analysis process (Boyatis, 1988; Braun & Clark, 2006). Thematic analysis utilizes six steps of analysis, including; 1) analytical method of familiarization of the data, 2) open coding, 3) re-examining initial codes and linked data, 4) checking codes against the entire data set, 5) developing themes while defining the scope and focus of each theme, 6) and developing an analytical narrative for each theme (Braun & Clark, 2006). The study utilized a semantic level of analysis, followed by a latent level of analysis to thematic analysis (Braun & Clark, 2006). Semantic thematic analysis was conducted to identify themes within the explicit meaning of data (Braun & Clark, 2006; Vaismoradi, Turunen, & Bondas, 2013). Semantic level of analysis allowed for themes to emerge that demonstrate the significance of patterns in relation to previous literature (Braun & Clark, 2006; Vaismoradi, et al., 2013). A latent level of analysis followed, during which additional critical interpretation from the researcher was used to identify underlying themes beyond the explicit meaning of the data (Boyatis, 1988; Braun & Clark, 2006). Latent level of analysis allowed for the emergence of themes that explored additional meaning and assumptions that complement the sematic analysis process (Braun & Clark, 2006). Each step of the thematic analysis process is described below. Familiarization of data. All interviews were audio recorded and transcribed, and later analyzed through lens of thematic analysis (Braun & Clark, 2006). The first step of analysis 44 required familiarization with all the data collected from the interview process following transcription of the data (Braun & Clark, 2006). The researcher read through the entire data set multiple times to establish familiarization with the data (Braun & Clark, 2006). By first becoming acquainted with the data and not initially coding, the researcher became more aware of important themes that emerged when developing codes during the next stage of analysis (Braun & Clark, 2006). Open coding. After becoming familiar with the data set, the researcher underwent an open coding process. During the open coding phase, concise codes which identified the repeated concepts within the data were generated (Braun & Clark, 2006). Codes are distinct concepts and categories that are represented throughout the entire data set and form the basic units of the analysis (Braun & Clark, 2006). This initial coding process allowed the research to conduct a semantic level of analysis by breaking down the data into preliminary concepts that appeared to be a pattern throughout the data set (Braun & Clark 2006, Vaismoradi, et al., 2013). Once the entire data set went through the open coding phase, all generated codes were organized so that all relevant codes were extracted from the data set and set aside together for future analysis (Braun & Clark, 2006). The purpose of this phase was to bring attention to the codes that were relevant to the research questions and previous literature so that the codes and the data connected to these codes could be further examined in the analysis process. Codes that were deemed not relevant, meaning the codes not related to the research questions of the study, were put aside to be reexamined in a later stage of analysis (Boyatzis, 1998; Braun & Clark, 2006). Re-examination of codes. During the third stage of thematic data analysis, the researcher inspected for larger initial themes within the data set by re-examining the extracted codes and corresponding data (Braun & Clark, 2006). These identified themes represented any significant 45 broader and underlying patterns of meaning within the data set (Braun & Clark, 2006). All data corresponding to an identified theme were pooled together within a memo, which allowed for review of the viability of each potential theme (Braun & Clark, 2006). Checking themes against data set. Once the themes were identified and related data was grouped together in a memo, each initial theme was checked against the entire data set to determine if a convincing story of data developed that answered the research question (Braun & Clark, 2006). Themes were revised, with initial themes being combined, split, or discarded based the direction of the data narrative (Braun & Clark, 2006). These themes were checked against previous scholarship and the theoretical framework (Braun & Clark, 2006). Previous codes deemed not relevant were re-examined to determine if there was some fit or underlying connection with identified themes (Braun & Clark, 2006). Defining the scope of themes. The fifth stage of data analysis consisted of developing a detailed analysis of each final theme by determining the narrative of each theme (Braun & Clark, 2006). An informative name was decided for each theme, and a narrative was determined by defining the scope and focus of each theme (Braun & Clark, 2006). Again, previous codes and data deemed irrelevant were re-examined to see if there was fit within the current detailed analysis (Braun & Clark, 2006). Developing analytical narratives. A write-up was generated during the final stage of data analysis. The write-up weaved together the analytical narrative and data extracts connected to the codes under each final theme (Braun & Clark, 2006). The final analysis was contextualized in relationship to the current literature and theoretical framework to demonstrate how the research addressed the gap within scholarship (Braun & Clark, 2006). Additionally, a 46 critical analysis interpreting new themes and unique conceptualizations associated with the data was included to compliment the analytical narrative (Braun & Clark, 2006). Trustworthiness Establishing trustworthiness is vital within qualitative research. Trustworthiness is created when the researcher demonstrates that the study results are sound, and the argument made based on the results is credible and objective (Marshall & Rossman, 2011). Due to the inherent bias of the researcher in all qualitative research because of their association and interest in the data and topic, various audit strategies were utilized during the study to ensure trustworthiness and to confirm the credibility of the findings (Marshall & Rossman, 2011). First, participants were informed during the initial consent process of their right to withdraw from the study at any time. Additionally, participants were told even if they dropped out at any time, they would still be provided the promised compensation. Memos were maintained as a log of reactions and experiences of the data collection and data analysis processes so that research bias would be monitored (Marshall & Rossman, 2011). Additionally, an expert coder (advisor) oversaw and participated in coding to ensure the accuracy and credibility of coding (Marshall, & Rossman, 2011). Finally, trustworthiness was established by maintaining a detailed audit trail throughout the entire data collection and data analysis processes to demonstrate and provide rationale for methodological decisions (Marshall & Rossman, 2011). Role of the researcher. When conducting qualitative research, it is vital to identify how the role of the researcher plays a part in the research process (England, 1994). In qualitative research, the researcher is the mechanism through which data is collected and analyzed, so it is important the researcher positions herself within the research (England, 1994; Morrow, 2005). In regard to areas of personal strength, the researcher has a strong commitment to the well-being 47 of sexual violence victims and the improvement of services that interact with victims on college campuses. Her extensive clinical background in the areas of social work and couple and family therapy provided her with a set of interview skills that facilitated rapport and trust building with participants. Her clinical background also allowed her the ability to respond to participants’ needs and reactions in a sensitive manner. Additionally, the researcher has extensive experience working with and interviewing sexual violence victims, which allowed her to understand some of the rewards and challenges that come with serving the sexual violence victim population that her participants may experience in their own work. The researcher also recognizes she is an outsider to the community interviewed. She has been a vocal advocate for student sexual violence victim rights and has pushed for campuses to improve policies and procedures around investigation, conduct, prevention and intervention. At times, the researcher has been critical of how universities and colleges conduct investigation claims. Additionally, the researcher acknowledges she has never been a Title IX Coordinator and does know what it feels like to oversee all sexual violence policies and procedures at a higher education institution. 48 APPENDICES 49 APPENDIX A: RECRUITMENT EMAIL Hello, I hope this email finds you well. My name is Emily Nichols, and I am a doctoral candidate at Michigan State University in the Department of Human Development and Family Studies. I am conducting a research study with Title IX Coordinators at federally funded institutions regarding the implementation of the 2011 Dear Colleague Letter on Sexual Violence; specifically, how this guidance improved sexual violence policies and procedures on college campuses, and potentially created barriers. Additionally, the study aims to understand Title IX Coordinators’ and Deputy Title IX Coordinators’ reactions to the withdrawal of the 2011 Dear Colleague Letter in September 2017, and any recommendations for future development of campus sexual violence policies and procedures. I am emailing you due to your current position as the Title IX Coordinator on your campus. As the Title IX Coordinator, you are the experts on how college campuses oversee and execute sexual violence policies and procedures. I would greatly appreciate the opportunity to talk with you about your experiences addressing sexual violence on college campuses. Interviews can be scheduled either face-to-face or videoconference at your preference and in accordance with your schedule. Interviews will last approximately 45-60 minutes and be audio- recorded. Participation is completely voluntary, and all efforts will be made to maintain confidentiality, including redacting any identifying information regarding your institution during transcription. Also, all participants will be compensated with a $50 digital Amazon gift card. A flyer with further information regarding the study is attached. If you would be willing to participate or have questions about the study, you may contact me by email (nicho313@msu.edu), or by phone at 231-690-5405. Thank you, Emily Nichols -- Emily Nichols, MSW Doctoral Candidate, Department of Human Development and Family Studies Michigan State University 50 APPENDIX B: RECRUITMENT FLYER 51 APPENDIX C: STUDY CONSENT FORM THE LASTING IMPACT OF THE 2011 DEAR COLLEAGUE LETTER ON SEXUAL VIOLENCE: A QUALITATIVE STUDY ON COLLEGE CAMPUS POLICIES AND PROCEDURES Michigan State University Department of Human Development and Family Studies Participant Information and Assent Form A. PURPOSE OF RESEARCH: You are being invited to participate in a research study exploring how the 2011 Dear Colleague Letter facilitated positive change and created challenges regarding sexual violence policies and procedures on college campuses. Our overall goal is to better understand how the implementation of the 2011 Dear Colleague Letter pushed institutions to improve existing sexual violence policies and procedures that better addressed the needs of victims, in addition to any institutional challenges faced due to adherence issues. Also, we aim to understand how reactions to the withdrawal of the 2011 Dear Colleague Letter in September 2017, and recommendations for developing effective sexual violence policies and procedures on college campuses in the future. You are being invited to participate in the study because you are currently employed as a Title IX Coordinator or Deputy Title IX Coordinator at public college or university who oversees your campus’ sexual violence policies and procedures. Researchers are required to provide a consent form to inform you about the study, to express that participation in this study is voluntary, to explain risks and benefits of participation, and to empower you to make an informed decision about participating. You are free to ask the researchers any questions you may have about the study and participation. B. WHAT WILL PARTICIPANTS DO: Your participation is voluntary. If you consent to be interviewed for this study, you will be asked to participate in one 45-60 minute in-person or audioconference interview about your perceptions of how the 2011 Dear Colleague Letter shaped campus sexual violence policies and procedures, and reactions to the withdrawal of The Dear Colleague Letter had on your campus. We will ask about your perceptions of how the guidelines from the 2011 Dear Colleague Letter facilitated positive change on your campus’ sexual violence procedures and policies. We will also ask questions about your perception of how the implementation of the 2011 Dear Colleague Letter created challenges around developing appropriate sexual violence policies and procedures on your campus. Last, we are interested in your recommendations for developing effective sexual violence policy and procedures following the withdrawal of the Dear Colleague Letter in September 2017. In order to better process your interview responses, we will ask if you are willing to be audio-recorded during your interview. Participants will be provided with study findings upon completion of the study if the participant asks for the results. 52 C. POTENTIAL BENEFITS: You will not directly benefit from your participation in this study, but some questions may prompt self-reflection. Your participation in this study may create transparency around campus sexual violence policies and procedures. What is learned through this study will hopefully lead to an improved overall understanding of effective campus sexual violence policies and procedures. D. POTENTIAL RISKS: There are minimal risks to participating in this study. We take confidentiality very seriously and will strive to make your participation in this study as confidential as possible. All identifying information will be redacted during transcription, and the recruitment process will ensure a variety of participants are included in the study. Due to the topic of the study, some questions may be sensitive to the participant and cause a level of discomfort. Your participation is voluntary, and you may stop participating in the study at any time without penalty to you. You may also choose to not answer any questions during the interview that you wish to not answer. E. PRIVACY AND CONFIDENTIALITY: The researchers will make all efforts to keep your information confidential to the maximum extent of the law. Only the researchers conducting the study and the MSU Institutional Review Board staff will have access to your study information. There are certain instances, such as a court order, where we may have to disclose data. Your information will be kept confidential by assigning you a participant ID code to de-identify your personal identity. Your name will not be used in any study reports and we will de-identify any information in your interview responses that can be linked to you, such as university units, so that no individual participant can be identified in reports, publications, or presentations. We will also be purposing collecting data from participants at a variety of campuses across the Midwest so results cannot be linked to a specific institution. All data, including audio-recordings, will be stored in password protected computer files and a locked file cabinet maintained by research study team in the office of the primary researcher. F. YOU RIGHTS TO PARTICIPATE, SAY NO, OR WITHDRAW: Participation in this research project is completely voluntary. You have the right to say no at any time during the research process. You may also change your mind about participation at any point and withdraw from the study. There are no possible consequences for withdrawing from the study. You may choose not to answer specific questions or to stop participating at any time without penalty or loss of benefits to which you are otherwise entitled. G. COSTS AND COMPENSATION FOR BEING IN THE STUDY: 53 There are no costs to you for taking part in this study. We will provide you with a $50 digital Amazon gift card for participating in the study. H. CONFLICTS OF INTEREST The research study team has no conflicts of interest, such as financial interests, in conducting this study. I. CONTACT INFORMATION FOR QUESTIONS AND CONCERNS: If you have concerns or questions about this study, such as scientific issues, how to do any part of it, or to report an injury, please contact the following members of the research team: • Marsha Carolan, PhD Michigan State University 13B Human Ecology Building, East Lansing, MI, 48824 517-432-3327 carolan@msu.edu • Emily Nichols, MSW, Doctoral Candidate Michigan State University 331C DeVos Center, Grand Rapids, MI 49504 231-690-5405 nicho313@msu.edu If you have questions or concerns about your role and rights as a research participant, would like to obtain information or offer input, or would like to register a complaint about this study, you may contact, anonymously if you wish, the Michigan State University’s Human Research Protection Program at 517-355-2180, Fax 517-432-4503, or e-mail irb@msu.edu or regular mail at 4000 Collins Rd., Ste. 136, Lansing, MI 48910. J. INFORMED ASSENT: By saying “yes,” you are indicating your willingness to participate in the study. By saying “yes,” again you agree to be audio-recorded 54 APPENDIX D: STUDY INTERVIEW GUIDE THE LASTING IMPACT OF THE 2011 DEAR COLLEAGUE LETTER ON SEXUAL VIOLENCE: A QUALITATIVE STUDY ON COLLEGE CAMPUS POLICIES AND PROCEDURES Michigan State University Department of Human Development and Family Studies Interview Guide A. INTRODUCTION: Thank you for taking time to be interviewed for our study. As the Title IX Coordinator or Deputy Title IX Coordinator of your institution, you are charged with one of the most difficult jobs on college campuses today, and I appreciate your willingness to share some of those experiences with me. For this interview, I am would like to talk with you about three areas. First, I am interested in learning about your perceptions of how the 2011 Dear Colleague Letter on Sexual Violence facilitated positive change regarding sexual violence policies and procedures on your college campus. Secondly, I am interested in learning about your perceptions of how the 2011 Dear Colleague Letter hindered some changes and created challenges for sexual violence policy and procedure development on your campus. Finally, I am interested in your recommendations for developing effective sexual violence policies and procedures on college campuses following the withdrawal of 2011 Dear Colleague Letter in September 2017. We will not be using the name of your institution during this interview as an additional means of confidentiality. B. BACKGROUND QUESTIONS: Before I start on the questions regarding the 2011 Dear Colleague Letter, I am first going to ask a few general questions about your role as the Title IX Coordinator or Deputy Title IX Coordinator. All identifying information will late be redacted to ensure your confidentiality. • First, how long have you been the Title IX Coordinator at your current institution? • What was your previous employment prior to being your institution’s Title IX Coordinator? • What was your previous experience addressing sexual violence procedures and policies prior to starting your position as the Title IX Coordinator? • What made you want to take on the role of your institution’s Title IX Coordinator? Could you describe for me your day-to-day experiences as a Title IX Coordinator? • What are your main responsibilities as your campus’ Title IX Coordinator? 55 C. GENERAL DEAR COLLEAGUE LETTER QUESTIONS: Next, would you describe what your understanding was of the overall goal of the 2011 Dear Colleague Letter? • PROBES: o Such as improving services for sexual violence victims on college campus? Or creating more transparency around policies and procedures on campuses? • FOLLOW-UP QUESTION(S): o In what ways do you feel the 2011 Dear Colleague Letter accomplished its overall o Was there anything that you believe prevented the 2011 Dear Colleague Letter goal? from accomplishing its overall goal? D. FACILITATION QUESTIONS How do you believe the 2011 Dear Colleague Letter facilitated positive change and growth on your college campus in regard to sexual violence policies and procedures? • FOLLOW-UP QUESTIONS § Could you give an example of a policy that was improved? o In what ways were policies updated? o In what ways were intervention services (such as counseling and advocacy), o In what ways were investigation and adjudication procedures expanded upon or o In what ways were educational and prevention services expanded upon or expanded upon or improved? improved? improved? What do you believe made your campus prepared or able to make these changes at the time? • PROBES: Such as administration, students, services, staff, community? • FOLLOW-UP QUESTIONS o What support did you have within your university to develop these positive § How did these supports contribute to the change and growth on your changes? campus? campus? o How would you describe the commitment to change among different sectors on § PROBES: Such as administration, students, services, staff, community? § Was this commitment shared among the different sectors on campus? 56 What do you believe was the most significant change made on your campus as a result of the 2011 Dear Colleague Letter? • FOLLOW-UP QUESTIONS o What makes this change significant for your campus? o How has that change been maintained or sustained on your campus? How do you believe the culture or climate around sexual violence was changed for the better on your campus as a result of the changes made from the guidelines of the 2011 Dear Colleague Letter? • FOLLOW-UP QUESTION: How has the attitude towards sexual violence changed in a positive way on your campus? E. CHALLENGES QUESTIONS How do you believe the 2011 Dear Colleague Letter created challenges for your college campus in regard to the sexual violence policies and procedures? • FOLLOW-UP QUESTIONS o In what ways do you feel as though the 2011 Dear Colleague Letter went too far o In what ways were policies unable to be updated? in expectations for college campuses? too far? impacted? advocacy) go too far? § Could you give an example of a policy or procedure that was negatively o In what ways did expectations for intervention services (such as counseling and o In what ways did expectations for investigation and adjudication procedures go o In what ways did expectations for educational and prevention services go too far? What do you believe are the institutional barriers that made it difficult for your campus to be ready or able to make changes at the time the 2011 Dear Colleague Letter was implemented? • PROBES: Such as administration, students, services, staff, community? • FOLLOW-UP QUESTIONS o Were there any areas in which there was a lack of support within the university § How did these barriers contribute to the challenges you faced on your that influenced these barriers? campus? o How would you describe any lack of commitment to change among the different § Were there any ways in which this lack of commitment was shared among sectors on campus? the different sectors on campus? 57 your campus? F. DEAR COLLEAGUE LETTER WITHDRAWAL QUESTIONS The 2011 Dear Colleague Letter was withdrawn by the Department of Education in September 2017. What was your initial reaction to the withdrawal? What do you believe was the most significant barrier or challenge on your campus to implementing some of recommended guidelines from the 2011 Dear Colleague Letter? • FOLLOW-UP QUESTIONS o What do you believe made this barrier significant for your campus? o How do you believe this barrier was systemically maintained at your institution? How do you believe the culture or climate around sexual violence on your campus was negatively impacted as a result of the changes made from the guidelines of the 2011 Dear Colleague Letter? • PROBES: How has the attitude towards sexual violence changed in a negative way on • FOLLOW-UP QUESTIONS: o Was the withdrawal something you were expecting? § What caused you to expect the withdrawal? § If so, had you made any changes or plans on campus in preparation for the withdrawal? o Have any of the changes you made as a result of the 2011 Dear Colleague Letter been affected as a result of the withdrawal? § How has the withdrawal of the 2011 Dear Colleague Letter had an impact on current sexual violence policies and procedures on your campus? There has been recent news regarding the development of a new guidance to replace the 2011 Dear Colleague Letter. What is your understanding of changes expected of college campuses from the rumored new guidance? • FOLLOW-UP QUESTIONS: o What were your reactions to the potential changes of the new guidance? o How would this new guidance impact your campus? As the Title IX Coordinator on your campus, you are the expert on sexual violence policies and procedures. If you were in charge of writing this new guidance, what would you recommend college campuses do to better address sexual violence? • FOLLOW-UP QUESTIONS: o What are your suggestions for improving intervention services? 58 services? o What are your suggestions for improving investigation and adjudication o What are your suggestions for improving prevention and education services? o What would you suggest college campuses could to collaborate better between the different sectors on campus, such as administration, faculty, staff, and students? o What supports do you believe campuses would like from the federal government to better address sexual violence on college campuses. Finally, how do you see your campus moving forward in regard to sexual violence policies and procedures? • FOLLOW-UP QUESTIONS o What are next steps for your campus in regard to improving sexual violence o How do you see college campuses across the nation moving forward? policies and procedures on your campus? That is all the questions that I have for you today. Is there anything we did not address in this interview that you feel would be important to share for others to better understand how campuses have been affected by the implementation of 2011 Dear Colleague Letter and withdrawal this past year? 59 REFERENCES 60 REFERENCES Boyatzis, R. E., (1998). Transforming qualitative information: Thematic analysis and code development. Thousand Oaks, CA: Sage. Braun, V., & Clarke, V. (2006). Using thematic analysis in psychology, Qualitative Research in Psychology, 3(2), 77-101. Chan, T. M., Teram, E., & Shaw, I. (2017). Balancing methodological rigor and the needs of research participants: A debate on alternative approaches to sensitive research. Qualitative Health Research, 27(2), 260-270. Creswell, J. W. (2013). Qualitative inquiry and research design: Choosing among five approaches. (3rd ed.) Los Angeles: SAGE Publications. England, K. (1994). Getting personal: reflexivity, positionality, and feminist research. Professional Geographer, 46, 80-89. Fusch, P. I., & Ness, L. R. (2015). Are we there yet? Data saturation in qualitative research. The Qualitative Report, 20(9), 1408-1416. Lhamon, C. E. (2015a). Dear Colleague Letter on Title IX Coordinators. Washington, DC: US Department of Education, Office for Civil Rights. Lhamon, C. E. (2015b). Title IX Resource Guide. Washington, DC: US Department of Education, Office for Civil Rights. Marshall, C., & Rossman, G. B. (2011). Designing qualitative research. (5th ed.). Thousand Oaks, CA: Sage Publications. Merriam, S. B. (2009). Qualitative research: A guide to design and implementation. San Francisco, CA: Jossey-Bass. Morrow, R. A. (1994). Critical Theory and Methodology. (3rd ed.). Thousand Oaks, CA: Sage Publications. Learning. Rubin, A., & Babbie, E. R. (2017). Research methods for social work. Boston, MA; Cengage Rubin, H. J., & Rubin, I. S. (2012). Qualitative interviewing: The art of hearing data. Thousand Oaks: Sage Publications. 41-57. 61 Testa, M., Livingston, J. A., & VanZile-Tamsen, C. (2011). Advancing the study of violence against women using mixed methods: Integrating qualitative methods into a quantitative research program, Violence Against Women, 17(2), 236-250. Ullman, S. E. (2005). Interviewing clinicians and advocates who work with sexual assault survivors: A personal perspective on moving from quantitative to qualitative methods. Violence Against Women, 11, 1-27. U.S. Department of Education. (2015). Title IX and Sex Discrimination. Washington, DC: U.S. Department of Education, Office for Civil Rights. Vaismoradi, M., Turunen, H. and Bondas, T. (2013), Content analysis and thematic analysis: Implications for conducting a qualitative descriptive study. Nursing & Health Sciences, 15, 398-405. 62 CHAPTER 4: MANUSCRIPT ONE A Critical Analysis of the Impact of the 2011 Dear Colleague Letter on Sexual Violence This qualitative study explores how the 2011 Dear Colleague Letter on Sexual Violence Abstract advanced sexual violence policies and procedures on college campuses, while also creating barriers to change. This study is part of a larger one examining the overall impact of the 2011 Dear Colleague Letter and recommendations for continued improvement of services addressing sexual violence on college campuses. In-depth interviews conducted with Title IX Coordinators and Deputy Title IX Coordinators indicated the 2011 guidance forced campuses to be accountable to address sexual violence, develop trauma-informed procedures, and generated a greater awareness of sexual violence, which led to increased reporting. Barriers focused on the lack of resources to create change, issues of clarity in the guidance, and resistance from faculty to make changes. Introduction The issue of sexual violence has plagued college campuses around the nation. Approximately 20%-25% of college-aged women experience sexual violence during a four-year college tenure (Fisher, Cullen, & Turner, 2000; Gross, Winslett, Roberts, & Gohm, 2006; Karjane, Fisher, & Cullen, 2002; Koss, Gidycz & Wisniewski, 1987; Tjaden & Thoennes, 2000). Victims of sexual violence frequently report negative mental health (e.g. anxiety, depression, self-harm, suicidal ideation, and PTSD) (Campbell, Greeson, Bybee, & Raja, 2008; Kilpatrick, Amstadter, Resnick, & Ruggiero, 2007; Klump, 2006; Pico-Alfonso, et al., 2006; Sarkar & Sarkar, 2005; Tjaden & Thoennes, 2006) and sexual health (e.g. STIs, increase in sexual partners and activity, increase in painful sexual intercourse, decrease in sexual satisfaction, and decreased 63 condom use) outcomes (Campbell, Self, & Ahrens, 2004; Glenn & Byers, 2009; Littleton, Grills- Taquechel & Axsom, 2009), in addition to an overall decrease to their physical health (Campbell, et al., 2008; Golding, 1994; Sarkar & Sarkar, 2005; Vidal & Petrak, 2007). Additionally, college-aged victims report a multitude of negative consequences impacting their academic careers including lower grades, drops in class attendance, poorer quality of course work, and an increased risk for dropping out of college compared to students who do not experience sexual violence (Jordan, Combs, & Smith, 2014; van Roosmalen & McDaniel, 1998). A significant concern of college-aged sexual violence victims is the fear of experiencing re-traumatization when reporting their experiences of sexual violence (Amar, 2008; Hartmann, 2015; Holland & Cortina, 2017). Research has demonstrated the low levels of sexual violence reports on college campuses is related to concerns of how campus officials handle the victim’s claims (Amar, 2008; Holland & Cortina, 2017; Moylan, 2017). According to victims, campus officials often do not handle claims of sexual violence with the appropriate levels of sensitivity (Amar, 2008; Holland & Cortina, 2017; Moylan, 2017). Furthermore, lack of evidence and witnesses to sexual violence experiences often makes it difficult for victims to prove the sexual encounter was nonconsensual (Hartman, 2015). The experience of re-traumatization typically occurs when service providers, such as campus officials, appear unresponsive and unsympathetic to the experiences of sexual violence victims (Campbell & Raja, 1999). This is especially problematic as re-traumatization can further intensify symptoms of depression, anxiety, and PTSD that manifest after a sexual violence event (Campbell, et al., 2008). Several policies and guidelines addressing campus sexual violence have been presented over the years at the federal level. Title IX of the 1972 Education Amendments is the primary federal regulation addressing sexual violence on college campuses as it protects all students from 64 gender and sexual discrimination (Ali, 2011; Lhamon, 2014; 2015b). Under Title IX, federally funded colleges and universities are required to address all claims of sexual violence with appropriate investigation, intervention, and prevention services (Ali, 2011; Lhamon, 2014; 2015b). Despite the presence of Title IX for multiple decades, colleges and universities across the nation have struggled to adequately respond to sexual violence on their campuses (DeGue, et al., 2014; Fisher, et al., 2000; Orchowski, Meyer, & Gidycz, 2009; Sabina & Ho, 2014) The 2011 Dear Colleague Letter on Sexual Violence was a federal guidance implemented following the rise in national attention on how college campuses have responded poorly to sexual violence claims (Ali, 2011; Lhamon, 2014). The 2011 Dear Colleague Letter provided strong recommendations for how campuses should best address sexual violence and was the strictest guidance to date (Ali, 2011; Lhamon, 2014). Recommendations for improving the response to sexual violence on college campuses included hiring a Title IX Coordinator to oversee all sexual violence claims and coordinate campus response, training improvements for faculty and students, and the development of trauma-informed procedures for addressing sexual violence reports (Ali, 2011; Lhamon, 2014). Some studies have demonstrated that multiple campuses continue to struggle to implement sexual violence policies and procedures (Holland & Cortina, 2017; Sabina & Ho, 2014), but little is known about how change from the 2011 Dear Colleague Letter generated effective policy and procedures changes for addressing sexual violence. Limited research has been conducted about the impact of this specific guidance on the current status of campus response to sexual violence. Despite this lack of research, the 2011 Dear Colleague Letter on Sexual Violence was withdrawn by the U.S. Department of Education in September 2017 (Jackson, 2017; U.S. Department of Education, 2017). In order to develop more effective guidance and policy in the future, this study sought to explore how the 2011 Dear Colleague on 65 Sexual Violence may have led to positive growth, as well as generated barriers to change, on college campuses The study addresses gaps in the existing literature by examining Title IX Coordinators’ and Deputy Title IX Coordinators’ perceptions of how the 2011 Dear Colleague Letter on Sexual Violence resulted in positive changes on college campuses regarding sexual violence policies and procedures, and any barriers to change that may have resulted from the guidance. The study specifically addresses: 1) how the 2011 Dear Colleague Letter on Sexual Violence facilitated progress and growth in policies and procedures on college campuses; 2) what campus supports existed to facilitate the process and growth in sexual violence policies and procedures; 3) how the 2011 Dear Colleague Letter on Sexual violence created challenges or barriers to addressing sexual violence on college campuses; and 4) what campus resistance existed when attempting to make changes regarding sexual violence policies and procedures. The study is informed by the Organizational Readiness to Change Theory, which aims to understand the process organizations go through to get from one state to a more desired one wherein the organization’s effectiveness has improved (Weiner, 2009). More specifically, the theory explores how organizations prepare to make policy and procedure changes by identifying supports and commitments within the organization that led to positive changes, and barriers the led to resistance to change (Werner, 2009; Strebel, 1996). The 2011 Dear Colleague Letter on Sexual Violence recommended college campuses to make organizational changes regarding sexual violence response (Ali, 2011; Lhamon, 2014). Examining the supports and commitments on college campuses can lead to a better understanding of how campuses developed more effective sexual violence policies and procedures, while exploring resistance to change assists in understanding the barriers that arose as a result of the guidance. 66 Methods This study utilized a qualitative design by applying a thematic analysis approach to data analysis (Braun & Clark, 2006). Qualitative design was employed as it allows for the researcher to develop a nuanced understanding of the underlying meaning within specific phenomena when limited research exists (Creswell, 2013; Marshall & Rossman, 2011; Merriam, 2009). Furthermore, qualitative methodology informed by thematic analysis allows for the emergence of new theories and approaches while conducting a critical analysis and evaluation of current sexual violence policies and procedures on college campuses (Chan, Teram, & Shaw, 2017; Testa, Livingston, & VanZile-Tamsen, 2011). Study procedures were reviewed and approved by Michigan State University’s Institutional Review Board. Participant recruitment and sample. Between the months of October 2018 and February 2019, a non-probability, purposive sampling method was used to recruit 15 Title IX Coordinators and Deputy Title IX Coordinators from public higher education institutions. In order to participate in the study, individuals needed to be 1) currently employed as either a Title IX Coordinator or Deputy Title IX Coordinator at the time of their interview; 2) employed at a public college or university that receives some form of federal funding as these higher education institutions are required under Title IX to employ one or more individuals to oversee compliance to sexual violence policies and procedures on their campuses (Lhamon, 2015a, U.S. Department of Education, 2015); and 3) employed in the field of higher education for a period no less than 18 months as this allowed for the individual to be employed prior to the withdrawal of the 2011 Dear Colleague Letter. One participant did not have the specific title of Title IX Coordinator or Deputy Title IX Coordinator but did oversee the student conduct process at their institution. This was deemed as the equivalent of being a Deputy Title IX Coordinator by the study research 67 team, as the role of other Deputy Title IX Coordinators in the study included overseeing their campus student conduct process. All other potential participants were excluded if they did not meet the inclusion criteria. Potential participants were recruited through personal invitation via email. A database of potential participant contact information (e.g. email and phone number) was created for all Title IX Coordinators from public colleges and universities in certain Midwestern states. Contact information for each potential participant was found by searching each public higher education institution’s website as all public universities and colleges receiving federal funds are required under Title IX to publicly post the name, office, and contact information for the institution’s Title IX Coordinator (Lhamon, 2015b). Initial emails were sent to all potential participants from 6 Midwestern states with information on the study, including a description, time commitment for the interviews, and the researcher’s contact information if there was interest in the study. A description of the informed consent process and confidentiality were also included in the initial recruitment email. Participants were offered the opportunity to conduct the interview in a face-to-face private location of their choice or audio conference, to ensure feelings of safety. Prior to the start of the interview, participants were notified of a $50 digital Amazon gift card as monetary compensation for their participation in the study. A flyer including details of the research study was included as an attachment on the recruitment email. Once eligibility was confirmed, an interview time was arranged. The consent form for the research study listing all confidentiality information was sent through email to participants after confirmation of the interview time and discussed prior to the start of each interview. 68 The researcher sent out three rounds of recruitment emails to a total of 81 potential participants, which resulted in a total of 14 interested individuals, and 12 eventual participants who conducted interviews. In order to reach the desired number of at least 15 participants, an additional round of recruitment with 18 more potential participants from 3 additional Midwestern states was conducted. The expanded round of recruitment resulted in 3 additional participants. A total of 15 participants completed interviews, lasting approximately 45 to 90 minutes. Table 4.1 provides an overview of participant characteristics. Table 4.1 Participant characteristics Participant Characteristic Current Position at Time of Interview Title IX Coordinator Deputy Title IX Coordinator Interim Title IX Coordinator Head of Student Conduct Length of Current Position Less than 1 year 1-3 years 4-6 years 7-9 years 10 or more years Previous Employment to Current Position Connected to Title IX Yes, and employed in Higher Education Yes, but employed outside of Higher Education No, but employed in Higher Education Hold Additional Titles/Positions at Current Institution Yes No Number of Students Enrolled at Institution 0-10,000 students 10,001-20,000 students 20,001-30,000 students 30,000 or more students Institution Part of a University System Yes No 69 n 9 3 2 1 4 4 5 1 1 9 1 5 12 3 4 6 2 3 6 9 % 60.0% 20.0% 13.3% 6.7% 26.7% 26.7% 33.3% 6.7% 6.7% 60.0% 6.7% 33.3% 80.0% 20.0% 26.7% 60.0% 13.3% 20.0% 40.0% 60.0% Data collection. Interviews were conducted with all 15 participants and performed by the first author. Interviews were semi-structured, including broad, open-ended questions such as tour questions, follow-up questions, and probes regarding certain content areas informed by the theoretical framework. Twelve of the interviews were face-to-face interactions (in-person or through a secure Zoom video conference) in an attempt to build rapport between participants and the interviewer. The other 3 interviews were conducted over a secure Zoom audio conference without video or over the phone at the request of the participant. The interview questions were developed to help identity relevant themes to the participants in relation to the research question (Rubin & Rubin, 2012). The data collection format allowed for modifications to the interview guide throughout the research process when reoccurring, relevant themes were identified during the interviewing period and not originally included in the interview guide (Rubin & Rubin, 2012). Interview protocol. Before the beginning of each interview, participants were provided with a copy of the study consent form. The interviewer went through each part of the consent form with the participants, including study background information, research team member contact information for further questions following the interview, procedures for ensuring participant’s confidentiality, and contact information for the Human Research Project Program within the Institutional Review Board at Michigan State University. The consent form also addressed the benefits to participating in the study and any potential risks one might experience by participating in the research study. After reviewing each section of the consent form, participants were allowed to ask any questions or clarifications regarding the study. Once all questions were answered, the participant was asked to provide assent to participate in the study, and to be audio recorded prior to beginning the interview. Verbal assent to participant and be 70 audio recorded was included at the beginning of each recording. Following the completion of each interview, participants were asked whether they would be able to accept the $50 digital Amazon gift card as compensation for participating in the study. Nine participants declined compensation for participating, and 6 participants were sent the digital Amazon gift card through email following the end of the interview. All electronic recordings were saved on the interviewer’s password protected computer file with restricted access. Electronic versions of transcriptions were also saved using password protected computer files. All IRB recommendations were obeyed to ensure safety of the data. Data analysis. Thematic analysis was utilized to analyze the data for this study (Braun & Clark, 2006). After transcribing each audio recorded interview, the researcher started the thematic analysis approach by familiarizing herself with the data (Braun & Clark, 2006). This step included reading each transcript multiple times to become aware of potential themes that might emerging during the coding process (Braun & Clark, 2006). In addition to reading through each transcript, the researcher also listened to the audio recordings while reading the transcript one additional time to ensure accuracy of the transcript. After reading over the transcripts multiple times, the researcher uploaded a copy of each transcript onto a NVivo 12 software system to conduct the coding process. The researcher next went through an open coding process during which she identified repeated concepts and ideas within the data set that appeared to be a pattern (Braun & Clark, 2006). Once each transcript underwent the open coding process, the researcher reviewed all the generated codes to determine which were relevant to the study’s research questions (Braun & Clark, 2006). Codes deemed irrelevant were separated but placed aside to be re-evaluated later in the analysis process for potential inclusion as certain codes could be deemed appropriate at a later time (Braun & Clark, 2006). Once an initial set of relevant 71 codes was determined, the researcher re-examined each transcript and collected corresponding data under each code to determine broader themes and patterns within the data set (Braun & Clark, 2006). The data collected for each theme was collected and placed into a memo to determine the validity of the theme (Braun & Clark, 2006). These themes were then tested against the data set to determine if themes needed to be discarded, split, combined (Braun & Clark, 2006). At this point, a second researcher reviewed the list of codes and themes against the data set to help determine credibility of the coding. For each final theme deemed relevant, a detailed narrative was developed to be used in the research report, and these narratives were woven together to answer the study’s research questions in connection to the prior literature and theoretical framework. (Braun & Clark, 2006). Results Progress regarding sexual violence policies and procedures on college campuses. Participants noted multiple ways in which the 2011 Dear Colleague Letter on Sexual Violence resulted in positive changes on their college campuses in regard to sexual violence policies and procedures. Themes of positive change emerged regarding the increased accountability to address sexual violence by colleges and universities, the development of more expansive and trauma-informed policies and procedures for addressing claims of sexual violence on campus, and greater awareness of sexual violence by students and the role of responsible employees. A final theme regarding the necessity of administration support for changes after the implementation of the 2011 Dear Colleague Letter on Sexual violence also materialized from the data set. Accountability of institutions to address sexual violence. Multiple participants indicated that a positive result of the 2011 Dear Colleague Letter on Sexual Violence was how universities 72 were being held accountable for addressing sexual violence on their campuses. Participants tended to note that prior to the 2011 guidance, many higher education institutions were not adequately tackling the issue of sexual violence, and in certain cases did not understand that sexual violence had to be addressed under Title IX. The 2011 guidance was the catalyst that pushed institutions to change their practices to better meet the needs of victims so that their education was not negatively impacted. For example, one participant, who was their university’s current Deputy Title IX Coordinator and had prior experience in the student conduct process, stated the guidance served as a call to action: “I think it was a call to action for accountability on the end of institutions to address what was known to be a pretty epidemic issue that was not always handled with the severity that I think society was ready to see it handled with… There were multiple cases of one-offs, of colleges or institutions handling something incredibly poorly for a student or deferring to legal processes overall. It was sort of the call to action to say, “No, sexual assault is actual gender discrimination” … I think that was a major light bulb moment for a lot of practitioners to say, "Wait, gender assault is gender discrimination and it can impact somebody’s ability to go to school and be a student." And I think from there we started a better national conversation.” A second participant, who had been their institution’s Title IX Coordinator for over nine years, also noted the importance of the guidance holding campuses accountable as students’ academics were severely burdened by the experience of sexual violence: “My understanding of the goal of that letter was to put processes in place that would hold universities accountable for looking into allegations of sexual violence… There’s no greater burden, or no greater barrier to completing school, than to be a victim of sexual violence and have to go sit in the classroom of your rapist.” Another participant concluded that the 2011 Dear Colleague Letter was the moment for many universities in which old systems of inaction towards sexual violence were no longer acceptable: 73 “Universities were gonna have to do what they should have been doing all along, right?... I’m glad to say and proud to say I’ve never, at least knowingly, been part of a school that hasn’t done what they were supposed to do. But [I] read plenty of articles over the years and seen plenty of cases that show that many schools were not doing what they were supposed to do. And so, to me, that 2011 rule letter just said, "Hey, enough is enough, and universities, schools, whatever, are gonna have to follow these guidelines." Guidance was necessary for change to occur. In addition to believing that the 2011 Dear Colleague Letter was the tool to hold colleges accountable for addressing claims of sexual violence, participants tended to believe no changes would have taken place without the introduction of the guidance. One participant stated that prior to the introduction of the 2011 Dear Colleague Letter, they had never seen a student held responsible for committing sexual violence in their many years working in student conduct: “It pains me to say this, but in full transparency, I worked in student conduct for a long time and I can tell you we had a system that never once held a respondent responsible for sexual misconduct until we started doing the work that we needed to do and understanding what we didn’t even know… We went from a world where we hadn’t held anybody responsible to finding individuals responsible for sexual misconduct and so perhaps providing justice for victims, and so that’s pretty powerful.” A participant, who had been the Title IX Coordinator at their current institution for over 4 years, found the 2011 Dear Colleague Letter was necessary in order for campuses to just hire a Title IX Coordinator: “I mean there was certainly, no matter what the reasoning behind it, the fear of not complying pushed the universities to do things and make changes on a timeline that they probably wouldn’t otherwise… Just the simple hiring of positions, the boom of hiring Title IX Coordinators and investigators post 2011. It created a whole new industry where they have never existed before.” Another participant, who had been both Deputy Title IX Coordinator and Interim Title IX Coordinator at their institution, believed that many campuses attempted to support victims of 74 sexual violence in the past, but the 2011 Dear Colleague Letter was the moment in which an actual process of addressing claims of sexual violence became a requirement: “I think prior to 2011 most would say, "Hey, we’re trying to be supportive of students who report. We’re trying to address institutional issues," but that is not in a coordinated, lucrative, proactive way. Before 2011, I’d been in higher education for a dozen years and I would say everyone wanted to do good work for students in relation to those issues. But again, I think the 2011 guidance really said, "No we really mean it now." And that’s when institutions were able to accomplish this, "Oh we really mean it, now let’s build actual structure." Development of process. Due to the 2011 Dear Colleague Letter on Sexual Violence holding higher education institutions accountable for addressing sexual violence, many campuses had to either develop or evolve their processes for investigating and adjudicating sexual violence claims. Participants tended to believe the 2011 guidance was the impetus for most campuses designing a detailed and expansive protocol to handle reports of sexual violence. For example, a participant with multiple years of experience working with Title IX on college campuses, stated their university’s policy substantially expanded regarding definitions and current institutional processes as a result of the federal guidance: “Our sexual harassment or sexual misconduct policy went from about a 6 or 7 page [document] to what now weighs in at 37 pages (laughs), and I never thought I’d ever be all super excited as a policy person, but I’ve turned into that person. I don’t want to give the impression that we didn’t receive and resolve these, but a sexual harassment and misconduct policy needs a whole lot of preamble kind of language… It needs to define important concepts like consent, incapacitation, coercion, what is sexual harassment, what is sexual exploitation, all of the offenses that are bundled up in a sexual harassment policy. And ours also is going to define all the parties’ roles in this, what is the process we’re going to use to respond, investigate, adjudicate. There’s a mechanism for appeals. So, it meant putting a whole lot more flesh on that bone.” Trauma-informed process. In particular, participants tended to speak on how their policies and procedures were revamped to consider the impact of trauma on victims going through these processes. One participant reiterated this belief by noting how their institution’s 75 sexual violence policies and procedures were re-worked to incorporate much more detail on how to handle the effects of sexual violence: “We re-wrote our policies and our procedures. There was a lot more detail about what [we] needed to do. I think that the part of the guidance where it says that schools are required to remedy the effects of sexual violence, basically that type of support for victims, that was completely different than the way people had thought of it before. So, we’ve got tons and tons of stuff here for supporting victims of sexual violence, and we take that really seriously. And that, I think, was new coming out of that [guidance].” Another participant discussed how the guidance pushed their institution to develop an investigation process in which victims are not required to re-tell their sexual violence experiences multiple times: “We’ve developed a system here where, all of the remedial measures are handled by one person, me, so they don’t have to go from person to person or re-tell their story. Nobody has to know why; it just gets done. And I think that’s been huge because I betcha we’ve been successful in retaining students who otherwise would’ve dropped out and I can’t even imagine how many people have dropped out over the years, because they just didn’t have the energy or they didn’t want to tell anybody what happened, and just gave up trying to get the help that they needed.” This same participant also expanded on how creating processes informed by how trauma can impact victims has allowed their school to help these students have better opportunities to succeed in school moving forward: “We are very rapidly and quickly providing measures to equalize the individual who has suffered that discrimination. So, they’re down here, they’re struggling in their suffering, and we’re providing these measures, to give them a shot at staying a student and succeeding. And, I think that is the biggest change here, that we’re doing things for those individuals to help them survive and cope. And, like I say, have a shot at succeeding.” One of the participants noted how the 2011 guidance made campuses realize experiences of sexual violence could significantly hinder a student’s academic experience: ‘I think that there’s just more highly important understanding that the disruption of this to people is very real. The setback, the trauma of it is very real, and we 76 don’t want to start the bidding with students with, "Well, given how significant this is, it would just be best for you to withdraw." Um, that’s a bad place to start. The idea is to end it and prevent it and remedy the effects of it as people experience that. And that can just be daily work, daily effort, time and care to the individual person.” The same participant continued to note that universities should be able to provide support to students when they experience trauma: “The earth isn’t going to tip off its access to provide a little additional help and support when people are experiencing this particular kind of thing. They [students] came here for a goal, to achieve their professional and personal and educational goals. Let’s keep them on that trajectory and support them." A final participant spoke to how the 2011 Dear Colleague Letter on Sexual Violence got schools to realize that even in cases where there is not enough evidence to demonstrate sexual violence occurred, schools should still be able to provide support that is trauma-informed: “I think we have to recognize that two people can go into a sexual encounter and both come out of it with a sincerely held belief as to the degree of consent that was involved. I’ve been doing this long enough to recognize that unfortunately the truth is very hard to get to. And that shouldn’t prevent us from providing support to people who believe that they have been victimized. Even if we can’t develop the case or get the evidence that’s appropriate to kicking someone out of school, that doesn’t mean we can’t help someone who was victimized, and I think our process is split accordingly to make sure that that happens.” Awareness of sexual violence on college campuses. Participants commonly spoke on how the 2011 Dear Colleague Letter on Sexual Violence positively generated more awareness of the frequency and impact of sexual violence, and how that has changed the culture of how people on campus combat the issue. One participant noted how students are much more likely to act when they witness sexual violence: “There has been significant positive change in terms of the culture and climate. Students are aware it [sexual violence] happens and that it shouldn’t happen. [Students are] increasingly more comfortable taking proactive steps to interrupt behavior that could potentially lead to victimization of others.” Another participant stated that students are now much more likely to know who and 77 where to report sexual violence compared to before the 2011 Dear Colleague was introduced when most students were unaware of the Title IX position. “They [students] can name who the Title IX Coordinator [is]. Most people, if they can’t necessarily name you by name, but they know my position, they know my position exists. That wouldn’t have happened before that guidance… I don’t know that as an employee I could have told you who that Title IX Coordinator was.” Multiple participants also addressed how awareness of sexual violence on college campuses has grown so significantly since the 2011 guidance, that it is now an expectation from incoming students and their parents that their potential universities take steps to address the issue. One participant commented: “When the Dear Colleague letter was coming out… there were examples of student activists who would write down things that campus administrators would say to them when they would report, and they [campus administrators] would be saying just horrible things that you can’t believe anyone would say… And then skipping to today, when you have an absolute expectation that sexual violence will be talked about in orientation, there’s parents and students asking, "Well, what programs do you have? What services do you have for survivors? Tell me about your advocacy program, or your prevention program.” And even getting emails from high school students saying, “I wanna know what kinds of services you have because this is gonna make a decision in where I decide to attend.” It’s like night and day… Night and day.” An additional participant found the 2011 guidance was justified as students are now coming to college with the knowledge of how to have conversations around sexual violence, alcohol, and consent: “They’re [students] coming in knowing what incapacitation is. They’re coming in knowing how to have, at least are aware of conversations around alcohol and consent. So, I think that it was worth it.” Increase in reporting. Participants tended to note that as the 2011 Dear Colleague Letter produced more awareness around sexual violence, their campuses saw an increase in the reports of sexual violence on campus. One participant mentioned how the reports of sexual violence on their campus have significantly increased since the introduction of the guidance: 78 “Probably just our increased, total increase in number of complaints, which since 2012 would have increased 300-and-some percent. So, that to me is an indication that education awareness and programming is having the desired effect.” A second participant also indicated a connection between the awareness of sexual violence and reporting numbers: “So, I started in 2014. From then until now there’s been a 466 percent increase in reports. That’s a function of our visibility. It’s a function of our equality process that students can resonate with. They wouldn’t have that if we hadn’t been doing the work.” One participant who stated there was an increase in reports of sexual violence after the guidance, noted their institution is now seeing a plateau in reporting, and expands on how they believe this process directly related to victims being more comfortable and safer coming forward to their campuses with their experiences of sexual violence: “We’ve been tracking our reports of incidents every year. And we have doubled the number of reports every year for the last three years. We’re finally starting to plateau. I view that as a good sign. Because I understand the reality is that bad stuff happens on campus, has been happening on campus, and is not happening at a greater rate than it used to. If anything, it’s happening at a lower rate than it used to. But the fact that people feel comfortable coming forward and reporting means that they trust the institution to do something about it. We’re at that stage now where we’re dealing with trying to act as a filter so that people who are coming forward with maybe not the best claims get routed in different ways, and more constructive ways, to keep the process honest, to maintain the integrity of the process. That’s a good place for us to be.” Greater understanding of responsible employees. One specific element of the 2011 Dear Colleague Letter on Sexual violence that may be connected to the increase in reports of sexual violence is the larger awareness and understanding of the role of responsible employees on campus. As one participant stated: “I think that for one thing employees, whether they’re student employees or regular staff employees and faculty, I think they pretty much for the most part understand that they have an obligation to tell someone about issues like that [sexual violence]. And, I don’t think that an awareness like that ... well, just didn’t exist before.” 79 Another participant spoke to how the 2011 Dear Colleague Letter’s insistence on training responsible employees who understand the impact of sexual violence and the importance of being accommodating led to increased reporting numbers: “There’s no question that the availability and the publication of those resources and the knowledge that is now required to be placed into responsible employees, into their arsenal has resulted in, I think, a higher rate of reporting and a higher rate of acceptance of resources… Most of them are counseling health, external resources for dealing with trauma, allowing somebody to maybe get an academic accommodation because of something that occurred. All of these things I think are as a result of this requirement that we treat these events as bars to the educational system.” Furthermore, one participant addressed how the 2011 Dear Colleague Letter radically changed how their institution trained resident assistants around their role as responsible employees. This participant expressed how initially there were concerns about having students being responsible for reporting claims of sexual violence, but this process is now one of their most successful in terms of helping victims to make informed decisions about reporting: “It started with the letter, but then when the White House issued the guidance right around the letter, one of the other significant, significant changes, and I could still tell you it was on page 54 out the guidance, that’s how clear it was because I remember reading the guidance, and it talked about the role of Resident Assistants and that basically were RAs meant to be responsible employees who would have to report if this had come to them. And totally, totally changing how we train RAs around sexual misconduct that’s reported to them from a Title IX perspective. So much so that one of the webinars or something I had done at that time talked about training RAs to be able to say, “If what you’re about to tell me will revolve around sexual misconduct, understand that I will be required to report” … I can still remember the initial role plays that we did and the hours and hours of training, because it was so counterintuitive to how we had trained RAs in the past. And now that we’ve been doing it for, I think it was just our sixth or seventh year of that. It’s funny, I had just three sexual assault reports in the last two weeks. All three came from student staff. All three ended up having to do that. And they’re like, it works so well… I can remember when people were like, this will never work. So, I think there has been something there, there was something in that that sort of forced us to think about it differently. It felt like it’s smack dab in the face of everything we’d been taught and there was no way we could make it work. And I honestly have to say I think it’s working.” 80 Support from administration is vital. Participants commonly noted the importance and role of administrative support when making substantial changes to their campus sexual violence policies and procedures. Participants tended to feel that the 2011 Dear Colleague Letter was a mechanism for getting their institutions’ administration on board and actively participating in this issue. One participant stated: “A very clear expectation from leadership at each of these institutions, meaning the president or provost, or chancellor of student affairs saying, "This is a priority. You need to work together to figure it out." A second participant stated that the support of the administration after the 2011 Dear Colleague Letter contributed a larger cultural shift around sexual violence on campus. “Because we got senior leadership from across the campus involved every single time there’s a sexual assault, and I think that it basically helped create culture change because we were dealing with it all the time and it wasn’t just in one place. It involved everyone.” Another participant stated that even when administration was restrictive in their support around areas like funding, they still ensured that there had to be one person on campus charged with making changes around campus sexual violence procedures: “I think one positive impact was senior administrators, presidents, vice presidents, people who control the purse strings went, "Oh this is actually something we have to do." And while they might not have put money behind it, they said someone has to do it and gave that to someone. That doesn’t necessarily mean they expanded their administrator role… but someone has to do it, it is now another duty to be assigned and you’re it. So, I think that was a positive thing. Multiple participants noted even when administration was unaware of the significance of Title IX and sexual violence on college campus, they were willing to take the necessary steps to ensure to students that responding to sexual violence in an appropriate and supportive manner was a priority of their institutions after the 2011 guidance: “We have a Chancellor who would be the first person to say he knew nothing 81 about Title IX, but was willing to hear and understand what the issues were and then trusted those of us who were sort of charged with implementing the guidance to do it, and he cleared roadblocks for us. We’re a governance state… and so for us, so many things have to go through governance. Well, he really allowed us to circumvent that by saying, "This isn’t a governance issue. You’d need to have roadblocks clear to do what you need to do.” One participant stated that the 2011 Dear Colleague Letter created such a significant change on campus regarding how they address sexual violence, that their administration has communicated to their students their plans to remain committed to Title IX after the withdrawal of the 2011 guidance: “So, we had a policy and a process, and our university president actually wrote an editorial that was published in our paper saying let’s be clear…It didn’t repeal and set aside Title IX, it’s a federal law. That’s still sitting there, safe and sound… the granddaddy of Civil Rights legislation. So, take care in knowing that wasn’t withdrawn, and our university policy, process, staffing, all of that, is just as it was the 16th as it will be on the 18th of September. So, we won’t be having some seismic shift of some kind here on our campus.” Barriers in developing sexual violence policies and procedures on college campuses. Although positive changes were the dominate themes to emerge from the data, there were additional overall themes demonstrating how the 2011 Dear Colleague Letter on Sexual Violence created challenges for campuses upon introduction. The themes that emerged regarding barriers to developing campus sexual violence policies and procedures centered on a lack of resources and funding to make the necessary changes to better address sexual violence, resistance from faculty to be mandated reporters and create accommodations for students who had been victimized, and a lack of clarity when the 2011 guidance was initially introduced. Lack of resources. Participants commonly noted that despite the positive shifts their campuses made towards addressing sexual violence, it was often without proper funds, trained staff, or time. The term “unfunded mandate” was repeated by multiple participants as they tended to feel as though the 2011 Dear Colleague Letter made it appear as though universities had to 82 make changes regarding how sexual violence is addressed, but without any additional assistance needed to suitably develop those changes. As one participant stated: “I have two words for you. Unfunded mandate… We were staffed for a university of a certain size, both in res[ident] life, in student life and development, in our office, in athletics… in the health center, and counseling and psychological services, and all of a sudden… we went from basically hardly any of these [sexual violence] cases, to more than 100 in a year. And the amount of time and resources that are spent on that, including public safety is staggering.” Another participant highlighted how campuses need financial support in order to adequately hire and train staff to conduct appropriate sexual violence investigations and run prevention services, but that is difficult to do with so many other priorities in higher education that also need funding: “Lots and lots of money… You’ve probably heard the term unfunded mandates… A school has to have a Title IX Coordinator, well then you have to have sufficient number of a staff who are highly trained, to do to a competent investigation, to preserve the rights and integrity of the institution and all the parties involved in a complaint. I mean, those people don’t just grow on trees… There’s a guidance that people who do this work need annual training, and the school needs to provide primary prevention and awareness programming to students, then funding the higher ed[ucation] from the state and from the federal government, it’s like, okay… how many other priorities do we have, and how do we carve out adequate resources to do this?” Another participant spoke to how at smaller institutions, even if committed to and supportive of addressing sexual violence issues, the staff already had multiple other roles at their university. They felt as though the 2011 Dear Colleague Letter resulted in already over-worked employees having even more responsibilities. “I would say, I haven’t ever felt lack of support. Because I think people realize how important it [sexual violence] is. I would say at my previous school, it was a small school, so there were some advantages… but you didn’t have the resources behind it, right? It’s like, okay. How are the three of us, who wear three hats already, gonna do these new things? How are we gonna add this to our repertoire? How are we gonna get trained, and be adept at doing these things when it’s this small group of people? So that was very challenging.” 83 Resistance from faculty. According to participants, one of the biggest barriers to implementing changes suggested in the 2011 Dear Colleague Letter was reluctance from faculty members on their campuses to go along with the changes to responsible employee policies and interim measures. Some participants reported certain faculty on campus disagreeing that sexual violence was an issue on college campuses. For example, one participant stated: “I had a lot of faculty members say “This [sexual violence] isn’t that big a problem. You know, kids will be kids, boys will be boys. And the really severe ones… we think we have a good handle on those.” But I didn’t, that didn’t seem to be true to me.” Participants repeatedly discussed the issues faculty members had around being mandated reporters. One participant mentioned faculty didn’t feel it was their role to report incidents of sexual violence when disclosed by a student: “If I was going to point out the one area where the most resistance comes from, and I don’t think this will be unique to our institution, it’s faculty. It’s the not wanting to be, you know, wanting to keep that hands off, and you know my training tip for them always is okay, let’s say somebody comes to you... Wouldn’t you rather know how to deal with this than be in the dark? Because inevitably somebody’s gonna come, but again, I don’t think that’s unique to our institution by any stretch of the imagination.” While some participants mentioned faculty resistance to their roles as reporters due to not viewing it as part of their jobs, many noted faculty were uncomfortable being mandated reporters because they worried reporting would further hurt the student. For example, one participant stated: “I mean certainly there were faculty and particular disciplines, departments that really resisted the idea that they had to tell the Title IX Coordinator personally identifiable information, names or even call them at all because they felt like they were violating the trust of the person who disclosed to them, so that was a challenge.” Outside of reporting claims of sexual violence, participants commonly stated that faculty resisted providing appropriate accommodations for victims in their classrooms. One participant 84 provided a specific example of how a faculty member pushed back on accommodations when both the complainant and respondent were in the same class. “I’m thinking of one case early in my career in particular where the complainant and respondent were in the same major. This was a very small cohort, and so until this matter was resolved, it was my recommendation ... well, out of fairness and due process for the respondent in this complaint, that person can’t be denied access, and opportunity, and education, and instruction, and all the classes, but these two in the same space at the same time really can’t happen at the moment. And rightfully so, you have some faculty who were like, "So, I’m doing handstands and back flips… Providing a whole separate setting for the respondent in this complaint?" And there was a little push back and they said to me, "Well, we’ll just go to the General Council and see what they say." And not to sound like I’m a smart aleck, but it was like, "You know, I’ll just go ahead and transfer your call because I can tell you what they’re going to say. So, you do have to be kind of willing ... you have to stand your ground and advocate for your policy and process and say to individual faculty or department chairs, "I appreciate this constrains your resources as well. And for the benefit of everyone, round up the people that need to be rounded up, and find a solution to this by the end of the week." That keeps everybody in class… until such time as somebody might be removed for violating your student code, where you can change up sections or all that kind of stuff. It can’t be business as usual. Business as usual is business highly unusual, so just make it work.” Despite showing initial resistance when the 2011 Dear Colleague Letter was introduced, one participant mentioned that faculty on their campus have started to come around on the idea of being reporters and passed resolution to increase their training on campus sexual violence: “Finally, this past spring, the faculty, on their own, came around to the idea that it [training] needs to be mandated. I don’t know if it was me too [Me Too Movement], or what happened, but they passed a resolution saying, the university needs to mandate all training. Okay, (laughs) I said that’s fine, I’m glad you got there.” Guidance lacked clarity. The final barrier reported by participants was the lack of clarity within 2011 Dear Colleague Letter document. Participants mentioned feeling confused when the initial guidance first came out, particularly around the issues of how to handle interim measures, investigation timelines, and whether the guidance was required versus recommended. In regard to the issue around interim measures, one participant noted: 85 “The place where I think it [the guidance] was the least clear, which was also probably the area that needed the most clarity, was in what does an interim measure look like… Who gets that, and how do you decide that? There’s still no guidance about that really. So it was, because of the lack of clarity, kind of overlooked in some ways and it didn’t give where you kind of wanted the mandate to go out and say here’s how you remedy discrimination and here’s what people are entitled to ... you didn’t have that. So, it still allowed for that kind of argument of we don’t do that for other students, so why do we need to do that here.” Participants noted the 60-day investigation timeframe recommendation was also perplexing when the guidance was introduced, with many questions about why 60 days was ultimately decided for the final suggestion. One participant noted that with certain cases, 60 days isn’t long enough to conduct a thorough investigation: “I think the thing that ultimately went too far in the guidance, was the timeline issue… Sixty days was just improbable in some cases, it just couldn’t happen in some cases. We were also fearful about what happens if we go 65 [days], will there be an investigation and so I don’t know that I felt like there was really anything in there that the spirit of it, like a reasonable timeline makes sense. Sixty days just didn’t seem to make sense.” Ultimately, the aspect identified as needing the most clarification among participants was whether the 2011 guidance was only a recommendation for how campuses should address sexual violence versus a requirement, or what would happen if the propositions in document were not taken as required. One participant stated: “At the same time, it was, I don’t wanna say confusing, but it was, you know, I remember reading it several times when it first came out and wondering, "Is this what we have to do, or is this saying what we should do?" Another participant reiterated this sentiment of confusion, but noted they still felt the guidance was important because it got college campuses talking about what needed to be accomplished to better address sexual violence: “I think when it first dropped, everyone was not sure what was going on. There was still the question of jurisdiction, whether or not OCR could even mandate the things they were talking about and, you know, was this just a recommendation or 86 was this something people were going to need to comply with? But it really got some conversations started. I think that was important.” Discussion and Implications This study explored Title IX Coordinators’ and Deputy Title IX Coordinators’ perceptions of how the 2011 Dear Colleague Letter on Sexual Violence resulted in both positive changes and barriers to change regarding campus policies and procedures for addressing sexual violence. Title IX Coordinators in the study found the 2011 Dear Colleague Letter was an important piece of federal guidance that held higher education institutions accountable for addressing sexual violence. As prior literature indicated, many campuses were not doing their part to address sexual violence (DeGue, et al., 2014; Fisher, et al., 2000; Orchowski, et al., 2009; Sabina & Ho, 2014). Victims of sexual violence felt unsupported on college campuses and participants of this study feel the 2011 Dear Colleague Letter forced campuses to address this necessary issue. This indicates that 2011 Dear Colleague Letter was a vital piece of federal guidance that got college campuses around the nation to address sexual violence in a more appropriate and effective way. This study also found that participants felt the 2011 Dear Colleague Letter on Sexual Violence got higher education institutions to develop more detailed processes for investigating and adjudicating sexual violence claims, in a way that is trauma informed. Participants of this study felt that the 2011 guidance got campuses to address prior issues of campus officials being insensitive to victims (Amar, 2008; Amar, Strout, Simpson, Cardiello, & Beckford, 2014; Brubaker, 2009; Fisher, Daigle, Cullen, & Turner, 2003; Hassija & Gray, 2013) by creating a process for addressing sexual violence that takes into consideration how that experience may impact one’s mental health and education, which allowed these students a better chance at success in their academics moving forward. 87 Title IX Coordinators and Deputy Title IX Coordinators in this study also believed that the 2011 Dear Colleague Letter on Sexual Violence led to a greater awareness of the prevalence and impact of sexual violence on college campuses by employees and students. Participants noted that students are now more aware of who to contact to report an experience of sexual violence and employees are aware of their responsibilities to address sexual violence, although they may not agree with this responsibility. Participants felt this awareness was directly related to a significant increase in reporting events of sexual violence on their campus. The importance of this impact cannot be highlighted enough as the existing literature noted the historical underreporting of sexual violence on college campuses (Fisher, et al., 2000; Fisher, et al., 2003; Karjane, Fisher, & Cullen, 2005; Tjaden & Thoennes, 2000). As participants noted, this awareness created an expectation from current incoming students that campuses must adequately address sexual violence that will not go away moving forward. Despite the multiple ways participants noted the 2011 Dear Colleague Letter led to progress in addressing sexual violence on college campuses, Title IX Coordinators and Deputy Title IX Coordinators from the study still indicated multiple barriers and challenges as a result of the 2011 guidance. Participants in this study found their higher education institutions did not have the appropriate resources available to make the changes recommended in the 2011 Dear Colleague Letter. Participants noted they often did not have the people or the funding to build up the appropriate services to address sexual violence in a timely manner. Developing pathways for collaboration and resource sharing between campuses is a recommendation emerging from this study. Participants of this study also emphasized issues around faculty resistance to change. Understanding to how get faculty effectively involved in addressing sexual violence on college campuses it vital to continuing progress around addressing issues of sexual violence on 88 college campuses. Finally, Title IX Coordinators and Deputy Title IX Coordinators also stated that 2011 guidance lacked clarity at times which created confusion around appropriate interim measures and timelines, but that they would not get rid of the 2011 Dear Colleague Letter on Sexual Violence. It is imperative to improve the prior federal guidance so that it incorporates clear language and outlines specific expectations, but the Title IX Coordinators in this study did not believe it should have been withdrawn by the U.S. Department of Education. Although not mentioned by enough participants to be considered a theme, it was noted by one participant how the 2011 Dear Colleague Letter on Sexual Violence did not do enough to address accessibility of sexual violence services for marginalized student populations, such as students of color or the LGBTQIA+ community. The participant noted that ethnic minority and LGBTQIA+ students had not demonstrated the same increases in reporting as heterosexual, white female students. In order to better address this disparity, college campuses need to develop and evaluate services that recognize the unique challenges underrepresented student communities faces in the aftermath of sexual violence Limitations. The presented research study had some limitations. First, only 15 participants out of the eligible 99 agreed to participate in the study. It is possible that Title IX Coordinators and Deputy Title IX Coordinators who have experienced more success in creating effective sexual violence policy and procedure changes were willing to be interviewed for the study. A second limitation is that only Title IX Coordinators were considered for the study when there are multiple other positions on campus that may have different perspectives on how the 2011 Dear Colleague Letter shaped their current services. Campus advocates and therapists may have a different perceptive on what defines an effective sexual violence policy and procedure. A third limitation is participants found it difficult to speak to the changes in intervention and 89 counseling services as the role of Title IX Coordinator tends to focus more heavily on investigation and conduct procedures. Future studies should explore the perceptions of these other services providers, as well as students’ perspectives of the impact of the 2011 Dear Colleague Letter on Sexual Violence. Conclusion Despite these limitations, this study indicated multiple ways in which the 2011 Dear Colleague Letter on Sexual Violence advanced the way college campuses respond to sexual violence while creating minor challenges. The results suggest college campuses should continue to develop and implement more advanced trauma-informed policies and procedures for addressing sexual violence. The 2011 Dear Colleague Letter on Sexual Violence contributed to forward progress for sexual violence awareness, prevention and investigation on college campuses. Despite its official withdrawal by the subsequent administration, it was the beacon that was necessary to provide a spotlight on this epidemic and overlooked problem. 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Implementation Science, 95 CHAPTER 5: MANUSCRIPT TWO Recommendations for Effective Sexual Violence Policies and Procedures on College Campuses: Perspectives of Title IX Coordinators Abstract This qualitative study explores Title IX Coordinator and Deputy Title IX Coordinator recommendations for improving college campus policies and procedures addressing sexual violence following the withdrawal of the 2011 Dear Colleague Letter on Sexual Violence. This study is part of a larger study examining the impact and challenges of the 2011 Dear Colleague Letter on college campuses. Semi-structured interviews with 15 Title IX Coordinators and Deputy Title IX Coordinators found recommendations to keep much of the 2011 Dear Colleague Letter in place, while improving supports for respondents, avoiding cross-examination, expanding collaboration with on-campus and off-campus services, and improving training programs. Introduction College campuses across the nation are struggling to address the issue of sexual violence. College-aged women are at the highest risk for experiencing sexual violence (Black, et al., 2011; Rennison, 1999) with approximately 20%-25% of college-aged women experiencing sexual violence while enrolled in college (Fisher, Cullen, & Turner, 2000; Gross, Winslett, Roberts, & Gohm, 2006; Karjane, Fisher, & Cullen, 2002; Tjaden & Thoennes, 2000). Studies note that victims of sexual violence report an assortment of negative mental health symptoms, such as depression, anxiety, and PTSD (Campbell, Greeson, Bybee, & Raja, 2008; Kilpatrick, Amstadter, Resnick, & Ruggiero, 2007; Klump, 2006; Pico-Alfonso, et al., 2006; Sarkar & Sarkar, 2005; Tjaden & Thoennes, 2006). Additionally, college-aged victims of sexual violence 96 are likely to experience negative academic outcomes, including lower grades, decreased class attendance, and a drop in the quality of schoolwork (Jordan, Combs, & Smith, 2014; van Roosmalen & McDaniel, 1998). Along with the negative impact of sexual violence on victims’ well-being, research has demonstrated that sexual violence is significantly underreported on college campuses, with as little as 2%-5% of college victims making formal reports of their experiences (Fisher, et al., 2000; Fisher, Daigle, Cullen, & Turner, 2003; Karjane, Fisher, & Cullen, 2005; Tjaden & Thoennes, 2000). Studies indicate multiple reasons why sexual violence victims on college campuses do not report their experiences, including fears of retaliation by their perpetrators, concerns of not being believed, and feelings of self-blame for the experience (Cleere & Lynn, 2013; Fisher, et al., 2000; Fisher, et al., 2003; Sable, Danis, Mauzy, & Gallagher, 2006; Wolitzky-Taylor, et al., 2011). Furthermore, college victims report fears of experiencing re- traumatization, or “victim blaming behaviors and practice” performed by campus officials which result in additional trauma and distress (Amar, 2008; Campbell & Raja, 1999, p. 262; Holland & Cortina, 2017). Multiple federal policies and guidance documents have been introduced over the years to address the issue of how college campuses respond to sexual violence. The primary policy addressing sexual violence on college campuses is Title IX of the 1972 Education Amendments (Ali, 2011; U.S. Lhamon, 2014; 2015b). Under Title IX, all federally funded higher education institutions are required to create a safe environment on campus through prevention efforts and by immediately responding to any claim of sexual violence (Ali, 2011; Lhamon, 2014; 2015b). In addition to Title IX, there have been further federal policies and guidelines intended to advance the methods college campuses use to address sexual violence. The 1990 Jeanne Clery 97 Disclosure Policy and Campus Crime Statistics Act (Clery Act) required college campuses to publicly disclose campus safety information and requirements for addressing sexual violence (Ali, 2011; Karjane, et al., 2002), and various Dear Colleague Letter guidance documents from 1997 to 2006 clarified standards for addressing sexual harassment on campuses (Monroe, 2006; U.S. Department of Education, 2001) The most significant effort to clarify Title IX was the 2011 Dear Colleague Letter on Sexual Violence. The 2011 Dear Colleague Letter noted the insufficient job college campuses had done to address sexual violence and provided strict guidelines for universities and colleges to better handle claims of sexual violence (Ali, 2011). Recommendations under the 2011 Dear Colleague Letter on Sexual violence included hiring a Title IX Coordinator to manage compliance to Title IX on each campus, investigating all reports of sexual violence involving a campus affiliated individual, and creating responsible employee training for campus employees, as all faculty, staff, and student employees were now mandated to report any claims of sexual violence to the university (Ali, 2011; Lhamon, 2015a). Since the introduction of the 2011 Dear Colleague Letter on Sexual Violence, studies suggest that services for sexual violence are still underutilized (Holland & Cortina, 2017; Sabina & Ho, 2014). There are still concerns around campus administrators dismissing reports of sexual violence and campuses failing to hold those accused of sexual violence accountable (Holland & Cortina, 2017; Moylan, 2017). One report indicated that campuses have had difficulties adhering to the strict recommendations of the guidance (Cantalupo, 2014). Currently, very limited research exists examining the effectiveness and influence of the 2011 Dear Colleague Letter on Sexual Violence. The first part of this study set out to understand how the 2011 Dear Colleague Letter on Sexual Violence led to progress addressing sexual violence on college campuses, as 98 well as how the guidance may have hindered campuses from making appropriate changes. The findings to this part of the study are addressed in a prior manuscript. Despite the limited research regarding the effectiveness of the 2011 Dear Colleague Letter on Sexual Violence, the guidance was withdrawn by the U.S. Department of Education in September 2017 (Jackson, 2017; U.S. Department of Education, 2017). The U.S. Department of Education noted two primary reasons for withdrawing the guidance. First, the guidance placed too much pressure and was too strict on higher education institutions, setting campuses up to fail in regard to compliance (Jackson, 2017; U.S. Department of Education, 2017). Second, the guidance created an unfair system in favor of complainants, those who report an experience of sexual violence, versus respondents, those who are accused of committing sexual violence (Jackson, 2017; U.S. Department of Education, 2017) This study addresses a significant gap in prior research by exploring the recommendations of Title IX Coordinators and Deputy Title IX Coordinators for addressing sexual violence on college campuses following the withdrawal of the 2011 Dear Colleague Letter on Sexual Violence. This study specifically aims to better understand what individuals who manage sexual violence policies and procedures on campuses today believe are the next steps colleges and universities should take to improve current best practices for responding to sexual violence. In order to develop an effective new guidance to replace the 2011 Dear Colleague Letter, it is vital to ask those who oversee Title IX compliance about what further changes should be made to campus sexual violence policies and procedures as these individuals are uniquely qualified as the experts who do this work every day on college campuses. 99 Methods Participant recruitment and sample. Study procedures were approved by Michigan State University’s Institutional Review Board. A total of 15 Title IX Coordinators and Deputy Title IX Coordinators from public higher education institutions were recruited using a non- probability, purposive sampling method between the months of October 2018 and February 2019. To meet eligibility, potential participants had to meet the following criteria: 1) be currently employed at the time of the interview as either a Title IX Coordinator or Deputy Title IX Coordinator; 2) be employed at a public higher education institution that receives federal funding as all federally funded higher education institutions must hire an individual who oversees compliance of Title IX; and 3) be employed in higher education for no less that 18 months at the time of the interview as this time frame meant participants would have been employed when the 2011 Dear Colleague Letter was withdrawn by the U.S. Department of Education. One of the 15 participants did not have the title of either Title IX Coordinator or Deputy Title IX Coordinator but oversaw the student conduct process on their campus. This individual was deemed eligible for the study because the role of other Deputy Title IX Coordinators who participated in the study included overseeing the student conduct process on their campuses. Other potential participants were excluded if inclusion criteria was not met. Potential participants were sent an email invitation to participate in the study. To determine who to invite to participate in the study, a database of email and phone number contact information of Title IX Coordinators from public higher education institutions in 9 Midwestern states was created by the researcher. Information for the database was collected by searching each campus website as Title IX requires federally funding institutions to publicly display the contact information for their Title IX Coordinators (Lhamon, 2015b). The initial round of 100 recruitment emails was sent to potential participants from 6 of the Midwestern states and included information on the description of the study and interviews, researcher contact information, and consent and confidentiality procedures. The recruitment email also outlined compensation for participating in the study ($50 digital Amazon gift card). To generate safety, participants could decide between a face-to-face interview in a private location of their preference or to interview through audio conference. Fifteen total interviews, lasting 45 to 90 minutes, were conducted. Eighty-one potential participants were contacted during each of the first three rounds of recruitment, which resulted in 14 interested individuals, of which 12 conducted interviews for the study. To reach the desired number of 15 participants, another round of recruitment was conducted with 18 additional potential participants from 3 more Midwestern states. The extra round of recruitment brought in the last 3 participants. Table 5.1 consists of an overview of participant characteristics. Table 5.1 Participant characteristics Participant Characteristic Current Position at Time of Interview Title IX Coordinator Deputy Title IX Coordinator Interim Title IX Coordinator Head of Student Conduct Length of Current Position Less than 1 year 1-3 years 4-6 years 7-9 years 10 or more years Previous Employment to Current Position Connected to Title IX Yes, and employed in Higher Education Yes, but employed outside of Higher Education No, but employed in Higher Education Hold Additional Titles/Positions at Current Institution Yes No 101 n 9 3 2 1 4 4 5 1 1 9 1 5 12 3 % 60.0% 20.0% 13.3% 6.7% 26.7% 26.7% 33.3% 6.7% 6.7% 60.0% 6.7% 33.3% 80.0% 20.0% Table 5.1 (cont’d) Number of Students Enrolled at Institution 0-10,000 students 10,001-20,000 students 20,001-30,000 students 30,000 or more students Institution Part of a University System Yes No 4 6 2 3 6 9 26.7% 60.0% 13.3% 20.0% 40.0% 60.0% Data collection procedures. The first author conducted all 15 participant interviews. Qualitative interviews followed a semi-structed guide with broad and open-ended questions. Interview questions were developed to aid the emergence of themes related to the overall research question (Rubin & Rubin, 2012). Modifications to the interview guide where made during the data collection process only when relevant themes not clearly identified in the initial guide were identified during the interviewing process (Rubin & Rubin, 2012). Twelve of the interviews were face-to-face in-person or through the use of a secure Zoom video conference, which allowed for the interviewer to build rapport with the participants. The remaining 3 interviews were performed either over the phone or through a secure Zoom audio conference upon the request of each participant. A copy of the study consent form was provided to each participant prior to the start of each interview. All sections of the consent form were reviewed verbally by the interviewer and participants were then given the opportunity to ask any questions regarding the study prior to the start of the interview. Once all questions were addressed and before the start of the interview, participants were asked if they assent to participate in the research study and be audio recorded. If the participant assented to both components, the recording was started, and the participant was asked again whether they assented to participate and be audio recorded on record. Once each interview was finished, participants were asked if they would like to accept the $50 digital 102 Amazon gift card as compensation for participating in the study. Six participants of the 15 accepted compensation and were sent digital Amazon gift cards through email following the interview, while remaining 9 participants declined to be compensated. The electronic recording of each interview was saved as a file with restricted access on the interviewer’s password protected computer. All transcription documents for each interview were also saved as password protected files on the interviewer’s password protected computer. All IRB recommendations were followed to ensure protection of the data. Data analysis. The study employed the tenets of thematic analysis to analyze the study data (Braun & Clark, 2006). Once each interview was transcribed, the researcher familiarized herself with the data set by reading through each transcript multiple times and listening to the audio-recording while reading through each transcript to ensure accuracy (Braun & Clark, 2006). This allowed the researcher to be cognizant of possible themes that could emerge during the coding process (Braun & Clark, 2006). A copy of each transcript was then uploaded onto a NVivo 12 software system to complete the coding process. An open coding process followed during which the researcher identified any repeated concepts or patterns that appeared in the data set (Braun & Clark, 2006). After each transcript went through the open coding process, all generated codes were reviewed by the researcher to determine relevancy to the study research questions (Braun & Clark, 2006). Each transcript was re-examined by the researcher using the relevant codes to define larger themes (Braun & Clark, 2006). To establish the validity of each theme, all data for each theme was collected and organized in a memo and tested against the data set to see if any themes were unnecessary, should be merged together, or divided into two separate themes (Braun & Clark, 2006). A second researcher then reviewed the list of codes and themes with corresponding data to determine credibility of the coding process. Rich narratives 103 for all final themes were created for the final research report and integrated to address the study’s research questions (Braun & Clark, 2006). Results Clarify the 2011 Dear Colleague Letter, but don’t throw away. The predominate theme of the study indicated that participants tended to feel that much of the 2011 Dear Colleague Letter of Sexual Violence needed to be kept in place, but that specific elements of the guidance needed to be updated or clarified. Participants overwhelmingly spoke about the need for colleges and universities to not get rid of the changes that led to necessary improvements made from the 2011 Dear Colleague Letter. Overall, it was noted that the 2011 Dear Colleague Letter may have asked too much of campuses due to a lack of resources to support the suggested changes outlined in the guidance. Additionally, participants tended to feel as though certain aspects of the 2011 Dear Colleague Letter were unclear, so the recommendation to clarify the guidance, but not eliminate the guidance was apparent. For example, one Title IX Coordinator recommended going back to the 2011 guidance, but strengthening components around due process: “I would go back (laughs) to the [2011] guidance. I think I would reinstate the guidance that has been there. I think it was working well. I think though that there are campuses out there that have done a poor job… I would maybe beef up the due process requirements so that schools were doing more like what we already are doing which is being very specific about what the allegation is so that respondents can truly respond and be prepared to respond… I think if you could just beef up due process with the old guidance… If I were in charge that’s probably what I would do.” Another participant supported keeping the 2011 Dear Colleague Letter on Sexual Violence in place, but with certain clarifications by pointing out that the 2011 guidance was part of a progressive evolution that will continue to advance in the future. The participant noted that students now have expectations for how campuses should address sexual violence, and federal 104 guidance needs to reflect those expectations while considering the impact on all parties involved in the report: “I think that we should not scrap the work that’s been done to date. One, because it was building on guidance going back to 2001… We have to remember that this has been an evolution and can continue to evolve, but doesn’t need to be essentially scrapped and rewritten… We have to remember that students are now much more sophisticated than they were even in 2011 in understanding the impact of this [sexual violence]. And there are certain things that they’re going to expect. In writing the new guidance, I think making it clear, whatever language makes sense to folks, what equity really means… What due process means, and not due process for either a respondent or a complainant, but due process in terms of removing somebody from an educational setting… What impacts that can have on both parties and the witnesses that are involved because everyone who’s involved in the process is impacted… Recognizing that it’s not just the person whose education is being taken away through a conduct process that’s ultimately suffering. It’s the person who came forward with a concern, that first felt the effects of discrimination, and we have to make sure that we’re still remedying that… We can’t disregard that.” A second participant also commented on how the 2011 Dear Colleague Letter on Sexual Violence created a standard for how campuses address sexual violence that will prevent any drastic changes to the policies and procedures put in place from the 2011 guidance: “There’s an entire generation of students who’ve come up through their public- school experience and this [the 2011 guidance] is what they know. This is their standard. These are the behaviors that are unacceptable, and if you’re targeted by these behaviors, someone will help you. And so, I don’t think we can put the genie back in the bottle. I think it’s done and out, and it’s become a marked expectation. I have parents who come to campus with the visits for their kids, and they’re asking on the tours or they want to meet with me because they want to know about Title IX. "What are you all doing here about this stuff?" And so, I think that’s important too. They may be able to roll back some of the specific legal points, but as far as the cultural piece, I think we’re on our way. And it’s not going back.” Another participant also commented that getting rid of the 2011 Dear Colleague Letter on Sexual Violence takes away from the progress that was made since it was implemented as the withdraw could be a sign to students that addressing sexual violence is no longer of importance. “Best practices of what we know didn’t shift, and I don’t think that it paid 105 credence to eight years of practice and work and going through things to get to a really better place… Some things we could agree are really good practices on the college campus level. And I think unfortunately it also was a signifier to students that it doesn’t matter anymore. So, it’s problematic.” Continue to develop a fair process with respondent rights. One specific aspect of the 2011 guidance that participants recommend be clarified was how to develop a fair process for both complainants and respondents to address reports of sexual violence. Participants tended to note that the 2011 Dear Colleague Letter led to necessary changes to make a more trauma- informed process for complainants, but that the language of the guidance gave the appearance that respondents did not have the same rights towards their education. According to one participant: “I think that the guidance was very much focused on support for the victims, and protecting those people, but I don’t actually think it excluded the accused. I think, though, that because of the focus on the victim, the message was sometimes muddled in some places and places [campuses] created procedures and processes that were really only supporting one side. The victim and not the [respondent]. Here at [participant’s campus], for every single thing we do, we do it equally for both parties.” Another participant recommended campuses be deliberate in how they provide resources for both respondents and complainants. The participant noted that there needed to be a shift towards more services for victims as complainants were severely lacking in support prior to the 2011 guidance, but now campuses need to re-examine how supports are provided to respondents: “We need to be as intentional about how we’re supporting respondents in the process… and supporting complainants. For me having had the experience of the work before this, there was an imbalance before [the 2011 guidance] … There’s been a piece that’s now been over-looked, and we have a much better understanding, I would say, of how to do it really well with one party [complainants] and need to figure out what that means for the other party [respondents].” This point was emphasized by an additional participant who recommended campuses develop supports for respondents as the next step in allowing for a fair process for all involved, 106 but noted there are some resource issues around being able to provide services for both parties: “I think we’re not where we could be, and the next piece of it is ensuring equal due process. We simply do not have the resources to afford to both victim and respondent…We try to do that as equitably as possible. But again, that’s what I mean by it’s not finished… What exact resources are now required for the responding party, and what timeliness does the responding [party] have to have notification that this is going on.” One final participant recommended one way to ensure a fair process between respondents and complainants was having campuses strengthen their due process procedures by outlining the specific rights of each students: “The process has to be supportive of both sides of the voice. Yes, you can do things to support a survivor of violence, of alleged violence, but you can do that in a way that also ensures the other student is still there, the other student still has access to his or her or their education. If you look at all of the reports, particularly the counter lawsuits these days, the student [respondent] feels like their rights are violated, in terms of a process, for doing an investigation and coming to an outcome. Some institutions I think were so scared of an OCR investigation they simply dumped the student who was alleged, and those students didn’t have a sense of what their rights were in our process, or their processes didn’t include that stuff. So again, the response to that could be that those institutions now have a robust two sides of the conversation process.” Process advocates. Participants suggested one way to create more fair process between respondents and complainants was to use process advocates to help students understand their rights during the sexual violence investigation and adjudication process. One participant spoke about a program at their institution that allowed for respondents to have support: “We had a program for a while, where there was a group of staff members who work in a particular office that would be designated to be kind of process advisors for respondents. They’ll never be equal, and they shouldn’t be equal support systems, because respondents were not traumatized. They don’t need trauma informed and victim centered support, but they need a different kind of support. So, we made that available, and we just want [to be] very explicit in making sure they [respondents] know how to get those resources.” A second participant also recommended they would mandate process advocates as a previous investigator on their campus noted their utility on a prior campus: 107 “One of our prior investigators that we had had come from an institution where they had actual process advocates, and I’ve been striving to get that put in place. We just don’t have the resources to do that, but I think process advocates and trying to get people to understand the difference between an advocate and a process advocate is imperative. I definitely think that that will be something that I would mandate.” Treat as a student conduct issue versus a criminal issue. Although participants highlighted the need to expand supports and resources to ensure the respondent of sexual violence reports is aware of their rights during the process, Title IX Coordinators were adamant in their recommendations against creating a campus investigation and conduct process that resembles a criminal investigation. Participants tended to state many don’t understand the unique role of Title IX on campus and that conduct procedures regarding sexual violence are meant to address policy violations on campus and are not meant to determine guilt through a legal process. One participant commented: “There’s a lot more people from the outside that are saying, "Hey… the accused or the respondents are not getting a fair shake. This should be decided in a court of law” … What I’ve always based our situation on is we’re deciding code of conduct violations. We’re not deciding the law. So, when people on our campuses said, "Well, why don’t we just use the [state’s] legal definition of rape?" And I’ll say, "No, we’re not deciding the law.” A second participant, who was the Interim Title IX Coordinator on their campus, reiterated this point by noting the student conduct process around sexual violence reports should determine if the school’s student code was violated, not if a law was broken: “We aren’t running courts of law out of our student conduct office. We’re running student conduct out of our student conduct [offices]. So, the evidentiary standard, the handling of evidence, nobody is going to finish a university process and lose their liberty. You might lose their opportunity at that particular school, which I know for some schools, including my own, is a very high-status thing. As students could choose carefully what university [they go to], and they’ve invested money in this, and they want their credential from that school. I don’t mean to suggest that it’s one size fits all… but it’s a very different thing to be examining, did this violate our student code versus did this break the law.” 108 One Deputy Title IX Coordinator noted feeling uneasy about raising the standard of evidence to prove if a conduct violence occurred to better resemble the legal system: “The standard of evidence piece [making the standard resemble the criminal process], I think, is problematic. Because again, it pushes us more to sort of this quasi-judicial thing that I’m not comfortable with. The feeling that the parties need to have lawyers… As an attorney myself, the fewer of us the better, honestly. And most of the stuff in my toolkit is college administrator stuff informed by the legal piece of it, but I don’t like the message it sends to victims, that our starting place is, "We kind of don’t believe you." Like that’s not where we are… We look at the actual instances of false reports, and they’re vanishingly small. And it’s a boogeyman that’s kind of trotted out. And it’s got a lot deeper base than any of this... It’s just something I’m not comfortable with, the standard of evidence piece… Also, just in the cases I’ve looked at, very few of them hinge on 51%. You know, quite often you’re going to meet the higher evidentiary standard regardless and especially as you get to a more serious, if I’m looking at expelling a student from my institution, I’m not going to do it on 51%. I mean, the realities of it and how people make decisions. But I worry about the message that it sends is, "We would rather you not report," or, "If you report, it will be 25% more difficult for you to get satisfaction." Avoid cross-examination. One legal procedure that Title IX Coordinators and Deputy Title IX Coordinators believed was especially inappropriate for a student conduct procedure involving sexual violence was cross-examination. Participants tended to believe that cross- examination procedures between respondents and complainants would be problematic and would result in the re-traumatization of complainants, which would lead to a decrease in sexual violence reports. One participant noted: “Even when live hearings are done very, very well, it is so hard for people who have been victimized or harmed by somebody else to sit there and hear the way in which [respondents] think about [the incident] … To add on top of that some kind of right for [respondents] to directly cross-examine or for their agent to do so is incredibly problematic. I think obviously it’s going to have a chilling effect on reporting.” This theme was validated by another participant also believed complainants would no longer want to move forward with cases if cross-examination was required: “If it [the new guidance] swings so far to say that this student is going be able to 109 directly cross-examine this student or their lawyer or their whoever it is can do [cross-examination], then we’re going to see far less cases go to hearing because the victims are not going accept that… They’re [the victims] just going be like forget it. So, then that would be unfortunate.” Furthermore, a participant detailed how a proper sexual violence conduct process allows for both complainants and respondents to ask questions without cross-examination so that victims are not put in a place to be cross-examined by their possible perpetrator: “The other piece is the cross-examination piece. I think direct cross examination is the poison pill in both federal guidelines and in the state proposals I’ve seen. It is the worst. It’s the hardest thing for me to get past because we don’t have an adversarial system right now. It’s more of a tribunal or administrative system. And it’s not set up for two people to be in a room and a victim to be cross- examined directly by the person who might have raped them. I can’t think of anything that would be more traumatizing to them than that in this context. And it’s amazing to me that people feel like that’s somehow a good idea. Our model allows for questioning, but it’s facilitated… If we have a hearing, the parties are in the same room, but we put a screen up between them if it’s a sufficiently serious thing or one side requests it. And if they have questions, they’re both speaking directly to the decision-makers because we have an informal process where I make the decision, but you can also opt to go to a hearing panel as well. The hearing panel’s administrators or faculty. And you pass a note up, and the chair of the panel reads the question you’ve got. If they believe it’s a valid question, they’ll direct a question. But I don’t like the idea of people speaking directly to one another in situations like this. Our policy specifically forbids us from attempting any kind of mediation or informal conflict resolution in a case of sexual assault. And it seems odd that we would allow that dynamic to play out.” Develop coordinated collaboration. Across participants, the recommendation to develop strategic collaboration efforts between campus departments and off-campus services came up regularly. Participants commonly noted that it is important to develop relationships with other units who are working to effectively address sexual violence. Opening lines of communication allows for more efficiency when addressing claims of sexual violence as well as transparency around process. One participant spoke about the importance establishing collaboration with multiple units even prior to a report of sexual violence: “I definitely think the coordinated coalition is valuable, of your internal folks and 110 external folks, your prosecutor, your sheriff and local police chief as well as your campus police chief. Communication, that’s ongoing, that’s prior to a really big incident… building those relationships is incredibly important so that you can all work together when you have a case that requires that. That’s really powerful. I think networks of professionals that are working in this field, however that makes sense.” Another participant seconded the importance of getting a committee of important stakeholders together around the issue of sexual violence and noted that collaboration allows for the sharing of resources: “You have to collaborate. As hard as it may be and as stereotypical as getting a committee together, you have to get the right people at the table from time to time and review what you’re doing. You want to have 20 people in there talking about what to do. You want to have the players, the health educators, the faculty members that are doing things around [sexual violence], even the conduct person that’s got some boxes they have to check off ... Just get the major players in the room at least a couple times a year to talk about what they’re going to be doing so, "Oh, we’re both going do this? Let’s work together." Get the community organizations in there to talk about what they can provide because you’re always going to have staff or people on campuses say, "I would love to do this, but I don’t have the time. I’d love to do this. I don’t have the money." So, bring in outside groups to collaborate as well, that may have the time or the money or maybe that’s their full-time job. But you have to figure out a way to effectively collaborate.” Another Title IX Coordinator with multiple years of experience stated coordinated collaboration on campus around sexual violence is vital as it everyone’s job on campus to ensure students are successful as sexual violence can negatively impact a student’s ability to stay in school in multiple ways: “Here’s all the units that typically work with sexual assault. Everybody has to work with sexual assault if we really want these individuals to be able to stay. It really comes down to can we keep them in school, can we retain this student, can we ultimately help them graduate? That’s everybody’s job regardless of what silo you’re in. Everybody has a role and that role may be just reporting that [sexual violence] happened and then it may be someone on the Title IX team’s role to make sure there’s resources, somebody else to provide those resources, somebody else to help that student that can’t make it to class, to talk to that faculty member about what other alternative arrangement can be made. It is the one area where there’s opportunity for everyone to have a role in student success. And I think 111 when you sort of phrase it that way, it’s easier to be collaborative. But you have to give those kinds of examples, how sexual assault can touch a student in so many ways.” Understand your role and appreciate the work of others. Not only do campuses need to develop effective collaborative teams, participants stressed the importance of units understanding their role in the collaborative process and appreciating the work of others who also address sexual violence through other methods. Title IX Coordinators and Deputy Title IX Coordinators tended to affirm units asking for help and reaching out to other services when dealing with an aspect of sexual violence that is not their expertise. One participant who oversaw Title IX compliance on their campus for over 9 years admitted they needed a team of diverse sexual violence experts on campus: “The other thing is to create a team like we have. Our team is really eclectic. And everybody has their strengths. We understand the work that each of us does. It is not all the same. They come from res[idence] life, from student life and development, from the women’s center, from our office, from conduct in student life and development, dean of students. It just really gives a very broad lens in a meeting to the group of people that need it. Because I’m not an expert in those areas.” Furthermore, one participant stated that at times there can be conflict around what units should address specific responses to sexual violence, but it’s best for students when services understand they are not always the expert and ask for help from other services to create collaboration. “I think far too many institutions say we got this. We can do this. We can manage this, and that’s true both internally [of] offices, divisions, academic, student affairs, business affairs, whatever, kind of go, "Well this is our space, not your space.” So how do you work through those sometimes appropriate, sometimes inappropriate, ownership of their resources, their people, their areas of expertise… Be humble enough to ask for help. I am not a prevention expert… I hoped that I act as an advocate, but I am not an advocate who does that work all the time. I am not a law enforcement officer. But I can name for you our chief of police, the chief of police of the county next over, and our sheriff because I know them and we have a built a relationship about the care of our students… The 112 institution itself has to be humble enough to open the door to go "What can we do better?" I have an advocate who sits on my campus, we have two new branch campuses, they’re going to start having advocates sit on their campus, because I’ve reached out to those organizations who do advocacy in those communities. You know it can only happen if you open the door.” Develop relationships with off-campus community partners. Participants commonly noted the importance of forming relationships with community partners when certain services were unavailable on campus. Specifically, this was important for smaller college campuses that did not have the same on-campus resources, such as people and funding, to fill all the roles necessary to appropriately respond to sexual violence on their campus. One participant spoke about being at multiple higher education institutions that did not have the resources available on campus to develop expansive support for victims: “I haven’t been at institutions that have really had the resources to develop a really robust, internal victim advocacy program… In my past institution, we were, in the largest city in the state, so we focused on creating agreements with the experts in our local area to provide that support on our campus.” Participants also highlighted that off-campus community partners and experts on sexual violence provide an outside perspective that allows for campuses to impact the larger community: “I think you need to get the people at the table internally, but you really have to get some experts externally as well that don’t necessarily have a stake in any sort of ownership in the institution, but can kind of get outside of everyone, and help explain why we’re doing this, and how it impacts the larger community. We’ve been working with our state advocacy groups and local rape crisis centers to try to help people understand this isn’t just a problem that’s impacting college campuses, this is something that they deal with the larger community, all the time…. How do we make these solutions that make sense for everyone? And then it takes people out of their little silos of ownership.” One participant stated that off-campus collaboration can include different campuses working with one another to share their best practices: “Even though we compete for the same students, ultimately I just believe we, all 113 of us [campuses] want the same outcome which is students to be successful, and so I think they’ll continually be sharing of resources, and sharing of best practices, and sharing of ways of doing business around this issue that will continue to help move campuses forward. I think it’s harder in this political climate because it does feel sometimes like it’s us against the world, us being the collective campuses, again thinking most campuses are trying to do the right thing… But I continue to think that campuses, and it’s so not a liberal or conservative. I think people turn it into that, but when it comes to sexual misconduct it’s not about that… I think campuses will continue to want to be better than what’s happening at the national level. I just think for the most part, it’s good people who work in higher ed[ucation] [who] want to do the right thing. Especially, around Title IX.” Expand training, but uncertain on how. The final recommendation that emerged focused on improving and expanding training around sexual violence on college campuses. Recommendations for improving trainings tended to focus on the need to be clearer regarding the roles of responsible employees and more expansive prevention education for students that address the issues of bystander intervention and consent. One participant spoke on adapting a public health model on prevention with an implied mandate which led to higher participation rates: “We have updated our prevention services by incorporating what we would call more of a public health model of prevention. Getting in with the different levels we have students at. With our first-year students, they receive, an online education, an in-person education during orientation, and then we actually scaffold it further and require every student because, we do have little known requirement to attend, in their first semester of school, a community conversation about bystander intervention, bystander actions, problematic behaviors, and of course, consent and sexual misconduct policy. That was instituted about two years ago. It’s an implied mandate, and we ended up having about 75% of our student population participate under the implied mandate.” Despite almost all participants noting the need to expand training, few specifics were given in regard to how to best train employees and students around sexual violence. Participants noted the difficulty in determining the current effectiveness of different training programs, and that there were many programs available that are not helpful. One participant stated: 114 “There’s still a lot of debate out there about what’s actually effective. I’ve seen really good home-grown programs, and really terrible ones. Similarly, to some of those programs that are bought and paid for out there. Some of them are awful, some of them are great.” Another participant put out a challenge to the U.S. Department of Education to develop effective training to administer to campuses across the nation or a recommendation list of appropriate sexual violence trainings for employees working on this issue: “I think some trainings. I think the Department of Education… even though we’re getting some good trainings by NCUR [National Council on Undergrad Research] and our professional organizations, I think the Department of Education should have some trainings around the country that says, "Okay, you know, we put out this guidance. Now here are Department of Education approved trainings." You know, I’m not saying you’re going to come out of there with a certification. But at least these are trainings approved by the Department of Education that says you should go do this so you can learn how to run our system. And I think that would be an enormous help… Would take some of the anxiety away from practitioners because I know when I first started doing this, a lot of the decisions I made were driven by fear. I’m like, "Okay, I’m not sure what I should do next. But I don’t want this to happen. I’m not sure. I don’t want this to happen." Whereas, hopefully, now, I mean, it’s only four years later, but hopefully now I’m a little more skilled in the practice ... [Fear’s] not driving it, but that’s always in the back of my head. I’ve met people over the years after I was in it for a few years that are like, "Oh, I just found out I’m the Deputy Title IX coordinator." And it’s like no resources, no nothing, and I can imagine what that is like. There are some very great organizations out there doing the training. But I just wish the, the Department of Education would come out and say, "Hey, you know, instead of hiring 500 new investigators, we’re going to have this training arm that’s going to go out and do all these things." And, it’s going be cost-effective and, if you want to get to it, you can get to it.” Discussion and Implications This study explored Title IX Coordinators’ and Deputy Title IX Coordinators' recommendations for improving sexual violence policies and procedures on college campuses following the withdraw of the 2011 Dear Colleague Letter on Sexual Violence. Table 5.2 consists of an overview of the recommendations provided by the Title IX Coordinators and Deputy Title Coordinators who participated in the study and brief explanations of those 115 recommendations to develop more effective sexual violence policies and procedures provided by the participants. Table 5.2 Recommendations for more effective sexual violence policies and procedures Recommendation Clarify the 2011 Dear Colleague Letter, but don’t throw away. Continue to develop a fair process with respondent rights. Process advocates. Treat as a student conduct issue versus a criminal issue. Avoid cross-examination. Explanation Participants recommended keeping most of the 2011 Dear Colleague Letter on Sexual Violence in place as the changes from the guidance were necessary improvements to addressing sexual violence on college campuses. Instead, participants recommended clarifying specific aspects around due process to strengthen the guidance. Participants recommended strengthening policies around respondent rights in sexual violence cases. Campuses need to be more deliberate in providing resources for both respondents and complainants by outlining the specific rights of each student throughout the process while still providing trauma-informed services to complainants. Participants recommended developing process advocate positions to help students understand their rights during the sexual violence investigation and adjudication or conduct processes. Participants recommended against developing campus investigation and adjudication or conduct processes that resembles a criminal investigation as these procedures are meant to address policy violations of student codes on college campuses versus determining guilt through a legal process. Participants recommended against using cross- examination as they felt it was inappropriate for the student adjudication or conduct process. Participants believed incorporating cross- examination would lead to the re-traumatization of victims and declines in sexual violence reporting. 116 Table 5.2 (cont’d) Develop coordinated collaboration. Understand your role and appreciate the work of others. Develop relationships with off-campus partners. Expand training, but uncertain on how. Participants recommended developing strategic collaborative partnerships with diverse campus departments and off-campus services. Participants noted coordinated collaboration would lead to more efficiency and effectiveness when addressing claims of sexual violence. Participants recommended valuing the work of other units addressing sexual violence on campus and reaching out to other services when in need of these units’ expertise. Participants recommended forming relationships with community partners when services and resources were unavailable on campus. Participants noted outside perspectives from community partners allows for campuses to impact the larger community around sexual violence issues. Participants recommended expanding training regarding the roles of responsible employees and consent. However, limited details were provided on how to improve trainings as participants noted the difficulty in determining the effectiveness of current training programs. Title IX Coordinators and Deputy Title IX Coordinators in this study overwhelming recommended to continue the work of the 2011 Dear Colleague Letter on Sexual Violence, but to expand on specific elements of the guidance regarding due process. Participants indicated that the 2011 Dear Colleague Letter was a natural part of the evolution of how campuses responded to sexual violence dating back to prior federal policies and guidelines (Ali, 2011; Karjane, et al., 2002; Lhamon, 2014; 2015b; Monroe, 2006; U.S. Department of Education, 1997; 2001), and felt the progress made from the 2011 guidance set the standard for how college campuses must address sexual violence moving forward. However, some Title IX Coordinators in the study worried that eliminating the 2011 Dear Colleague Letter on Sexual Violence sends a problematic 117 message to students that sexual violence is no longer an important issue to address, potentially pushing back the progress campuses made to address victims feeling unsupported on campus in the past. This indicates that although many of changes resulting from the 2011 Dear Colleague Letter on Sexual Violence will not go away, many victims of sexual violence may not feel campuses are not taking cases of sexual violence seriously enough to report their experiences. Title IX Coordinators and Deputy Title IX Coordinators in this study indicated the main updates should focus on creating a fairer process when responding to claims of sexual violence, specifically ensuring that both respondents and complainants have supports on campus and pathways for understanding their rights throughout the process. Participants in the study supported the existing literature that victims of sexual violence on college campuses did not have proper supports before the introduction of the 2011 Dear Colleague Letter on Sexual Violence (DeGue, et al., 2014; Fisher, et al., 2000; Orchowski, Meyer, & Gidycz, 2009; Sabina & Ho, 2014), but note more work needs to be done to ensure the process is still fair for respondents. Specifically, multiple participants recommended campuses develop the role of process advocates to aid both parties throughout the investigating and adjudicating process to ensure respondents and complainants are aware of their rights throughout the investigation and adjudication process. Participants believed although it is vital to continue to improve trauma-informed services for victims of sexual violence on college campuses due to the historical lack of services, respondents must also be made aware of their rights and supported throughout the investigation and adjudication process. Multiple campuses find their investigation and adjudication processes for sexual violence claims scrutinized due to process errors, and developing more intentional ways of supporting both parties would decrease these issues. 118 Title IX Coordinators were adamant that addressing sexual violence on campus remain a student conduct issue versus developing a process that resembles the criminal or legal process. Participants in the study pointed out college campuses are examining student policy violations and not whether a respondent broke a law. Allowing this process to address student conduct issues creates a system for victims of sexual violence to still receive support even if there is not enough evidence to prove a policy violation occurred. The most prevalent recommendation was to avoid incorporating cross-examination procedures into the process as this would lead to re- traumatization of the student who believes they experienced sexual violence, and a decrease in reporting. This aligns with prior literature that indicates students do not report their experiences of sexual violence to formal officials due to fear of experiencing re-traumatization (Amar, 2008; Holland & Cortina, 2017). Incorporating cross-examination would be in direct contrast of trauma-informed services for sexual violence victims, and college campuses would no longer receive the current amount of reports regarding sexual violence. Title IX Coordinators and Deputy Title IX Coordinators in the study recommended developing a coordinated collaboration with both on-campus resources as well as off-campus resources. Participants in the study expressed the importance reaching out and respecting the other on-campus resources as these other services have expertise on addressing sexual violence through different avenues. Students’ lives often intersect with various college departments so to ensure a student who experiences sexual violence still succeeds, each of these departments needs to be part of the team supporting the student. Title IX Coordinators in the study also noted that collaboration with off-campus services is vital, especially if a college or university does not have the available on-campus resources. Community collaboration also allows campuses to address the issue of sexual violence at a broader level. 119 The final recommendation of Title IX Coordinators and Deputy Title IX Coordinators in the study was to expand training, especially around areas of being a responsible employee for faculty and staff, and consent for students. However, participants indicated they were unsure of how to improve existing trainings as there are currently several trainings, but it is difficult to determine which are effective, especially with limited resources. One participant did recommend the U.S. Department of Education develop a comprehensive training or list of trainings to administer to different campuses across the nation. Further research is necessary to develop appropriate trainings for college campuses on sexual violence and determine the effectiveness of existing trainings. Limitations. The research study had some minor limitations. First, there were only 15 individuals that completed interviews out of the 99 eligible individuals who were invited to participate in the study. Additionally, Title IX Coordinators and Deputy Title IX Coordinators who agreed to be interviewed for the study may be those who have had more success and support on their campuses in developing sexual violence policies and procedures. Title IX Coordinators and Deputy Title IX Coordinators who have experienced more challenges implementing federal guidelines may hold different values regarding what campuses should do to develop best practices regarding sexual violence. Second, only Title IX Coordinators and Deputy Title Coordinators were considered for this study, when other campus employees such as campus advocates and therapists who work with sexual violence victims also have a unique and possibly different perspective on what they would recommend as best practices for addressing sexual violence. An additional study should aim to explore these stakeholders’ recommendations as the Title IX Coordinators in this study found it difficult to speak on what they would advise to improve regarding intervention and counseling services. 120 Conclusion Despite these limitations, this study identified multiple recommendations to improve current practices on college campuses addressing sexual violence. First, this study recommends re-instating the 2011 Dear Colleague Letter on Sexual Violence with minor changes to address clarifying concerns. The 2011 Dear Colleague Letter led to substantial progress on college campuses regarding responding to sexual violence, and despite establishing standards that still exist for addressing sexual violence, the withdrawal sends a problematic message to victims of sexual violence that campuses may not continue these standards. The results suggest that minor changes to the 2011 Dear Colleague Letter should be developed, included requiring process advocates to ensure both respondents and complainants are supported and know their rights during the investigation and adjudication process. Additionally, requiring college campuses to develop investigation and adjudication practices that resemble the criminal process, such as practicing cross-examination, is highly problematic as it will lead to increased re-traumatization of victims and decreases in reporting. College campuses should also reach out, appreciate, and collaborate with both internal and external campus services. Coordinated collaboration with on- campus departments better supports students and gives them a better chance for academic success, while off-campus partners allow for a broader impact. Finally, further research must address developing effective training programs for campuses centered on better preparing campus employees to respond to sexual violence. 121 REFERENCES 122 REFERENCES Ali, R. (2011). Dear colleague letter. Washington, DC: U.S. Department of Education, Office for Civil Rights. Amar, A. F. (2008). 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Is reporting of rape on the rise? A comparison of women with reported versus unreported rape experiences in the National Women’s Study-Replication. Journal of Interpersonal Violence, 26, 807-832. 125 CHAPTER 6: INTEGRATION OF MANUSCRIPTS Concluding Remarks This study set out to understand the impact of the 2011 Dear Colleague Letter on Sexual Violence on college campus policies and procedures. More specifically, the study aimed to explore how Title IX Coordinators believed the 2011 Dear Colleague Letter pushed colleges and universities to make positive changes in regard to responding to sexual violence on their campuses, as well as how the guidance may have resulted in barriers to change. By understanding how this guidance led to positive changes and created barriers, we can better understand how federal guidance bests support higher education institutions when developing best practices for addressing sexual violence on campus. Furthermore, the study sought to examine Title IX Coordinators’ recommendations to developing effective sexual violence policies and procedures on their campuses following the withdrawal of the 2011 Dear Colleague Letter on Sexual Violence. Manuscript One Based on the experiences of Title IX Coordinators and Deputy Title IX Coordinators in this study, it is reasonable to believe that the 2011 Dear Colleague Letter on Sexual Violence was a vital federal guidance that led to necessary changes in how campuses handle reports of sexual violence. Manuscript one found multiple ways in which the 2011 Dear Colleague Letter resulted in progress towards how college campuses address sexual violence. According to the participants, the 2011 Dear Colleague Letter made college campuses accountable for responding to sexual violence when many were not appropriately tackling the issue. Participants also felt the guidance resulted in the development of more robust and trauma-informed processes for addressing sexual violence claims. Additionally, the 2011 guidance resulted in increased 126 awareness on sexual violence on college campuses, which led to increases in reporting and campus employees understanding their role in addressing claims of sexual violence. Challenges created by the 2011 Dear Colleague Letter identified by Title IX Coordinators and Deputy Title IX Coordinators in the study included a lack of resources to implement the recommendations of the guideline, issues around clarity of the guidance which resulted in confusion on how to implement aspects of the document, and resistance from faculty members regarding their roles to address sexual violence. Implications of this study indicate that the 2011 Dear Colleague Letter on Sexual Violence resulted in necessary changes for college campuses that students now expect from their campuses. The guidance resulted in multiple positive changes towards addressing sexual violence that campuses should continue to implement despite minor challenges the guidance introduced. Manuscript Two Through the second manuscript, it was evident that the Title IX Coordinators and Deputy Title IX Coordinators in this study recommended the 2011 Dear Colleague Letter on Sexual Violence be clarified to address areas of confusion but should not have been withdrawn by the U.S. Department of Education. Participants felt the 2011 guidance was part of a natural evolution to addressing this issue on campuses that set the standard for how higher education should respond to sexual violence in the future, and concerns remain about how the withdrawal may send a problematic message to students. Participants recommended continued efforts to develop a fair process for handling claims of sexual violence that allows for both respondents and complainants to also be supported through process advocates. Title IX Coordinators in the study also emphasized the need for higher education to treat reports of sexual violence as a student conduct issue versus a legal issue. In particular, it is recommended that campuses avoid using 127 cross-examination as this would lead to the re-traumatization of victims, which the 2011 guidance aimed to prevent, and decreases in reporting. The findings also highlight the need for building coordinated collaboration with both on-campus and off-campus partners and that these collaborators should respect the expertise of each other. The final recommendation highlighted in the study was expanding training around the role of responsible employees and consent for students, despite a lack of certainty on how to develop effective training. Implications for this study suggest the withdrawal of the 2011 Dear Colleague Letter was premature, with Title IX Coordinators and Deputy Title IX Coordinators recommending keeping much of the 2011 guidance in place. It was believed developing processes for responding to sexual violence on college campuses that resemble the criminal procedure would bring campuses back to a time when sexual violence was not adequately handled for victims. Integration of Findings The findings outlined in manuscripts one and two share one major overlapping theme; the 2011 Dear Colleague Letter on Sexual Violence was an effective and necessary tool for progress in responding to sexual violence on college campuses, but minor changes need to be made to further improve the process. The 2011 Dear Colleague Letter was a catalyst for necessary change as it held college campuses accountable for addressing sexual violence when many were using processes that further harmed victims of sexual violence and rarely found respondents responsible. Due to the significant progress that occurred, it was disadvantageous to withdraw the 2011 Dear Colleague Letter when it is more appropriate to clarify certain aspects of the guidance, such as outlining appropriate interim measures, timelines, and ensuring a fair process where both complainants and respondents are supported throughout the process. 128 Both manuscripts addressed the importance of utilizing a trauma-informed approach when addressing claims of sexual violence. One of the major outcomes of the 2011 Dear Colleague Letter was the increased development and use of policies and procedures that considered the impact of trauma and would not create more suffering for students who feel they have experienced sexual violence. With the withdrawal of the 2011 guidance, there is significant fear that campuses will restore old procedures that were re-traumatizing for victims or develop a new process resembling the legal system that requires cross-examination, allowing the opportunity for victims of sexual violence to be questioned face-to-face by their possible perpetrators. Title IX Coordinators and Deputy Title IX Coordinators in the study were adamant there would be significantly less students reporting their experiences of sexual violence if cross- examination became required. Instead, campuses should focus on how to ensure victims of sexual violence are supported in their academic experiences across all levels of campus life while also ensuring that respondent students have rights and are made aware of these rights during the investigation and adjudication process. Consistent in both results was that the 2011 Dear Colleague Letter on Sexual Violence created a standard for which higher education must now adhere to when developing sexual violence policies and procedures. The introduction of the 2011 guidance generated an awareness for how sexual violence can impact a victim’s academic experience and how campuses must then respond to ensure these students are supported in their education. The results demonstrate that current and incoming students, and their parents, have expectations for how sexual violence must be addressed on campuses. Furthermore, the withdrawal of the guidance may cause college students to feel as though higher education does not see the importance of this issue. Students will hold their campuses accountable for addressing sexual violence, so despite the withdrawal of 129 the 2011 Dear Colleague Letter of Sexual Violence, campuses must answer to the demands of their students when addressing sexual violence. Implications for Couple and Family Therapy The findings of this study create important implications for the field of couple and family therapy. This study found that although Title IX Coordinators and Deputy Title IX Coordinators believed the 2011 Dear Colleague Letter on Sexual Violence resulted in the development of campus policies and procedures that were trauma-informed to reduce re-traumatization, the withdrawal of the guidance creates questions about whether campuses will continue to utilize trauma-informed practices. Additionally, uncertainly about whether a new guidance from the U.S. Department of Education will recommend or require campuses to adopt cross-examination practices that allow victims of sexual violence to be questioned about the experience by their possibly perpetrator could further hinder the well-being and mental health of victims on college campuses. The findings of this study indicate Title IX Coordinators and Deputy Title IX Coordinators believe this change would directly result in the re-traumatization of victims on campus and lead to decreases in reporting claims of sexual violence on campus, essentially reversing the progress made by the 2011 guidance. Couple and family therapists, as well as other related therapy and counseling professionals, must be prepared to address not only the impact of sexual violence on their clients who report being victimized while at college, but also how the client’s institution has failed to meet their educational support needs and potentially further traumatize them. Research indicates that mental health services are the most commonly utilized support resource for sexual violence on college campuses (Amstadter, et al., 2010; Gurette & Caron, 2007; Krebs, Lindquist, Berzofsky, Shook-Sa, & Peterson, 2016; Lindquist, et al., 2013; Sabino & Ho, 2014; Walsh, 130 Banyard, Moynihan, Ward, & Cohn, 2010); therefore, couple and family therapists must be prepared to meet the complex and systematic mental health needs of college sexual violence victims. As confidential reporting services, on-campus mental health centers including couple and family therapy training clinics, are often an outlet for student victims of sexual violence, who may fear making formal reports to campus officials moving forward, to explore and process the experience. Couple and family therapists are also uniquely qualified to address the systematic issues of sexual violence with victims as most couple and family therapy models are influenced by systems theory (Nichols, 2012). Additionally, experiential couple and family therapy models such as Emotional Focused Therapy and Satir’s Human Validation Model, as well as Narrative Therapy, allow for victims of sexual violence to address painful emotional experiences brought on by sexual violence and re-stablish security and safety following possibly re-traumatization by institutions (Witting, Jenson, & Brown, 2016). Contributions to Existing Research The presented research addresses several limitations in as well as support to the existing literature. First, multiple studies indicated a lack of appropriate policies and procedures to address sexual violence on college campuses prior to the implementation to the 2011 Dear Colleague Letter on Sexual Violence (DeGue, et al., 2014; Fisher, Cullen, & Turner, 2000; Orchowski, Meyer, & Guidycz, 2009; Sabina & Ho, 2014), but little was known on how the 2011 Dear Colleague Letter may have resulted in effective changes on college campuses. The findings of this study demonstrate that participants felt the 2011 guidance not only addressed the lack of support for victims of sexual violence on campus, but that the guidance was responsible for holding higher education institutions accountable in addressing the issue. The findings indicate that the 2011 Dear Colleague Letter was also responsible for campuses developing more 131 comprehensive and trauma-informed procedures for investigating and adjudicating sexual violence claims. Prior research found victims of sexual violence on college campuses often did not report their experiences to campus officials due to fear of experiencing re-traumatization (Amar, 2008; Amar, Strout, Simpson, Cardiello, & Beckford, 2014; Brubaker, 2009; Campbell & Raja, 1999; Fisher, Daigle, Cullen, & Turner, 2003; Hassija & Gray, 2013). Multiple participants spoke on how the 2011 Dear Colleague Letter directly resulted in their institutions adapting a trauma-informed approach that better supported victimized students. They also noted how the guidance was responsible for generating more awareness around the prevalence and impact of sexual violence on college campuses, as well as who students can make reports to on campus, which participants felt was directly connected to an increase in the number of sexual violence reports on their campuses. The increase in reporting as a result of the 2011 Dear Colleague Letter on Sexual Violence is substantial as prior research indicates sexual violence has been extremely underreported on college campuses (Fisher, et al., 2000; Fisher, et al., 2003; Karjane, Fisher, & Cullen, 2005; Tjaden & Thoennes, 2000). Although participants felt that the 2011 Dear Colleague Letter on sexual violence addressed the lack of support and resources for victims of sexual violence on college campuses reported in prior research (DeGue, et al., 2014; Fisher, et al., 2000; Orchowski, et al., 2009; Sabina & Ho, 2014), many noted the need to continue to improve the process for addressing sexual violence so that it is fair for respondents. However, participants were adamant that the process should not evolve to resemble a criminal procedure in which cross-examination is allowed as this would re-traumatize victims and negatively impact the progress made from the 2011 Dear Colleague Letter around developing trauma-informed procedures and reporting. Lastly, although college campuses have historically lacked supports and resources for victims of 132 sexual violence, research has demonstrated that the policies and procedures for addressing sexual violence on college campuses has evolved over time (Ali, 2011; Karjane, et al., 2002; Lhamon, 2014; 2015b; Monroe, 2006; U.S. Department of Education, 1997; 2001). The findings of this study indicate that the 2011 Dear Colleague Letter on Sexual Violence was an appropriate and necessary part of that evolution process for addressing sexual violence. Moving forward in this progression is always necessary but withdrawing the 2011 Dear Colleague Letter on Sexual Violence halts that progress by potentially sending a message that sexual violence is no longer a significant concern on campuses in the United States. This study establishes the importance of the 2011 Dear Colleague Letter on Sexual Violence, and demonstrates the concerns related to the withdrawal by the U.S. Department of Education. 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