Top Takeaways from ICS’ OIRA Meeting on the New Title IX Regulations

Top Takeaways from ICS' OIRA Meeting on the New Title IX Regulations

As part of the process for finalizing new or revised regulations, proposed regulatory changes undergo a review by the Office of Information and Regulatory Affairs (“OIRA”); interested stakeholders can request meetings with OIRA during this review period. Currently, OIRA has stakeholder meetings scheduled through April 18, 2024 for the new Title IX sexual harassment regulations.

The ICS team recently had the opportunity to share our thoughts and recommendations with an OIRA committee via this meeting process. As a team, we prepared by strategizing to use our time in order to best benefit YOU, our current and future clients and Community Partners. While the meeting was conducted in an interesting format (no video, all teleconference) we felt as though our thoughts and suggestions were heard by the individuals on the other end. They spoke up, asked questions, challenged our reasoning for our recommendations (in a good way), and truly seemed to listen.

Our time in the meeting was relatively short, although they did extend well past our 30 minute slot. We knew we needed to be focused, concise, and strategic in order to communicate the more important concerns. Thus, we spent a good portion of our time discussing the importance of a long implementation period. This focus was two fold. First, we wanted to make sure that they understood the importance of drafting a strong policy that is not only in compliance with the regulations (however they are drafted) but also tailored and school specific. This takes time and work on your plates. You deserve the time to get it right. Second, we wanted to highlight the importance of training. Not only for you, but also training for your communities before dropping new expectations on them. While Title IX Coordinators and professionals are superheroes, it is impossible to draft policy, train your communities, AND continue to serve your students and staff simultaneously. You need some opportunity to move from drafting to training and implementation BEFORE the deadline. Also, you have to take care of your health and wellbeing, enjoy your families, and perhaps enjoy a summer vacation!

Obviously, since we were requesting all of this time for training, we also needed to ask for ways for you to pay for it. Instead of only asking for handouts/financial support, which we did not think would happen, we focused on continued support for the Title IX professionals from the top down. It is our hope that when increasing the expectations of the Title IX Coordinator (which we expect the regulations will do), the Department will highlight the importance of the role and of compliance. We want to shout from the rooftops, “leadership of districts and institutions, you need to support your TItle IX team and their efforts financially, through appropriate staffing, and support for the professionals in the work!” We strive to have clear expectations that will help guide you and your schools to success. Of course, we also highlighted that additional grants and other funding sources would be helpful too!

We hit on a lot of other topics including: the challenges that can exist with the single investigator model and how they can be overcome with proper training and filling the roles with the right staff members; the importance of continued focus on supportive measures; the excessive challenges faced by K-12 districts under the current model; and more.

All in all, it was an interesting meeting and a learning opportunity for our ICS team. Quite honestly, I felt a bit like I was back in law school with the professor peppering me with questions. Regardless, we walked in prepared and, when we ended the call, our presence was known, our requests were conveyed, and our community was represented. That is a great feeling.

I am proud of our team and we are so glad to have the opportunity to continue to support you through an upcoming transition on new regulations. When will they come?? Well the Department did not ANSWER any questions 😉 so we are all left to speculate together. I stopped holding my breath about six months ago.

Blog by ICS team member Betsy Smith. Contact us for more information about how ICS can assist your district or institution with Title IX compliance, including training, policy drafting, consulting, and more.