By Logan Monteleone
Business and Distribution Manager
The federal Title IX policy requires U.S. institutions of higher education to create and implement a policy addressing sex-based harassment, discrimination, and assault. The policy’s goal is to protect individuals’ rights to a safe, effective, and equitable academic environment. However, there is longstanding dissatisfaction with Title IX’s implementation on college campuses, including Washington College.
“I think those are always going to be the places where we say we can do better: where people meet policy,” former Title IX coordinator and Vice President of Student Affairs Sarah Feyerherm said.
Based on insights from faculty, administrators, and students, perception of the support provided through the Title IX process at WC varies greatly. Some think that the process and its coordinators succeed in offering resources and treating parties with neutrality and respect.
Many also believe that issues surrounding timeliness, communication, and education require improvement in order for the system to effectively meet the needs of the WC community.
Defining Title IX
According to the U.S. Department of Education, the Office for Civil Rights enforces Title IX of the Education Amendments of 1972 for institutions that receive federal financial assistance. Title IX protects students, faculty, and staff from sex-based conduct that may impede their ability to effectively learn and work.
Title IX includes measures to address a range of actions that may seem minor compared to sexual violence but still have the capacity to make a person uncomfortable.
Effective since Aug. 1 of this year, the Biden administration revised the policy under the 2024 Title IX Final Rule. According to the American Council on Education, the Final Rule also eliminates the previous requirement for a live hearing with cross-examination in sexual assault cases, revises the definition of sexual harassment, and extends jurisdiction to off-campus incidents.
These changes intend to increase flexibility, fairness, and overall protection for both the complainant, or the person alleged to have experienced the prohibited conduct, and the respondent, or the person alleged to have engaged in the prohibited conduct. While the policy is reviewed at the beginning of each academic year and minor edits are made, the widespread changes implemented this past summer are the first since 2021. The students who spoke with The Elm went through the resolution process in accordance with the 2021 policy prior to the Final Rule revisions.
Title IX Coordinator and Dean of Students Gregory Krikorian said that no longer requiring a written statement from the complainant removes what he perceived as “a barrier” for reporting. Krikorian said the change also affords the Title IX coordinators “a little bit more flexibility on how [they] collect that initial complaint.”
It is also relevant to note the distinction between the federal Title IX guidelines and institution-specific policies that are written in compliance with the former, an Dept. of Ed. document of over 1,600 pages. The WC policy is approximately 70 pages in length, written by Krikorian with the assistance of a Title IX and equity services consultant from Grand River Solutions, an attorney for the College, and other resources including those provided by the Association of Title IX Administrators.
Support: Administrative Perspectives
While the College’s policy outlines a list of supportive measures the coordinator provides to the complainant and respondent, students have questioned the lack of personal concern from Title IX administrators.
Trained faculty and staff involved in the process commented on this challenge, expressing their hope that students feel cared for despite the obligation coordinators have to maintain a formal, neutral position toward both parties.
The deputy Title IX coordinator position at the College is held by four individuals drawn from different departments and offices on campus, three of whom shared their insights with The Elm.
According to the WC Title IX page, deputy coordinators assist the coordinator in responding to and receiving inquiries, conducting investigations, and designing and implementing Title IX education.
One deputy Title IX coordinator, Director of Public Safety Chief Ryan Colman, said he takes impartiality seriously in his investigative responsibilities, ensuring “that all pertinent information is captured accurately and objectively to support a fair resolution process.”
Colman’s primary responsibility is to conduct interviews with the complainant, respondent, and any witnesses.
“I approach these interviews with neutrality, aiming to collect as many facts and perspectives as possible,” Colman said.
Another deputy coordinator, Associate Professor of Studio Art Julie Wills, said she stepped into her role because she had “heard grumblings” of dissatisfaction and had been approached by individual students who “share[d] their frustrations” with her.
After learning about the process from the administrative side, however, Wills said that her initial intention to “help identify and shift shortcomings” yielded quickly to “a lot of confidence in the integrity of the college officials who handle Title IX policy.”
Although coordinators are limited in their capacity to offer personal emotional support to either party, Wills wants to make those going through the process feel cared for.
“I hope I can be a safe space for students and others to vent, and that I can offer them all the support I know how— but this is in addition to my Title IX role, as much as they may overlap,” Wills said.
As a faculty member who has had ongoing Title IX training since the fall of 2017, Chair and Associate Professor of English Dr. Courtney Rydel further explained the type of support those carrying out the process can provide.
In addition to serving on the Honor Board, Dr. Rydel belongs to the resolution process pool. This group of trained faculty members are qualified to assist coordinators in the intake of complaints and to fulfill roles including advisors, informal resolution facilitators, investigators, and decision-makers.
The lack of visible emotional support, specifically during Title IX hearings, which, as noted previously, are no longer required to be held in person, does not result from “any lack of empathy, or concern, or deep caring for our students,” Dr. Rydel said. “It’s to protect the sanctity of the process so that we can even have a process.”
While Dr. Rydel said that she understands why complainants may feel unheard by those carrying out the process, she highlighted the fact that many administrators who work in Title IX often do so out of concern for student well-being.
“The great irony is that I’m sitting on the other side of the table, and so I’m able to see how much those students are really heard, and really worried about, and really cared about,” Dr. Rydel said.
From the staff side of Title IX incidents, the same issues of dissatisfaction and a seeming lack of concern exist. Often the first person to whom faculty and staff report Title IX concerns, Director of Human Resources and Deputy Title IX Coordinator Kate Laking, said the process can “leave complainants unsatisfied…because even when vindicated, the process demands vulnerability from both parties that seems unfair when someone already feels violated at some level.”
The process begins with care from administrators; Krikorian explained that he sits down with both parties separately to walk them through the basics of the policy and to determine the next steps for resolving an incident. This initial evaluation involves providing support, resources, connections, and advocacy options.
“The most important thing we do when we receive a report…is to make sure that the person is okay,” Krikorian said. “The second thing is to make them aware of the policy and their options for going forward.”
Support: Student Perspectives
The resolution process for a Title IX complaint contains many stages, and students’ perceptions of the level of support they find at each step varies.
Sophomore Mary Clymer, who went through the process in 2023, is one among four former complainants who shared their thoughts with The Elm.
Clymer said that she felt supported by the Title IX coordinators throughout her process. “[Krikorian] was very empathetic and very neutral…[and] helped me get in touch with…on-campus counselors, and…mental health resources that I needed at the time,” Clymer said.
Clymer said that the coordinator clearly outlined “what the process was going to look like,” and she did her own research “to fill in any gaps” in her understanding of the policy. Clymer said she “felt very comfortable” asking the coordinators questions when she was uncertain.
Other students expressed more mixed perceptions of the support they received from the coordinators.
Reflecting on her experience as a student undergoing the Title IX process twice between 2022 and 2023, former News Co-Editor of The Elm Grace Apostol ‘24 noted a lack of guidance from the Title IX coordinators in understanding the details of the process contained in the nearly 70-page document.
“I just think going through the Title IX packet when…you’ve just been assaulted, is…very daunting, and not something that you want to sit down and read,” Apostol said, noting that the policy may have “triggering” language.
While the policy has been reduced significantly from the Dept. of Ed. document, Apostol called for parties to receive a “consolidated list” or “an abbreviated version of what this process is going to be” in addition to the 70-page document.
“Going through a process or not, no one wants to sit and read how many pages that that document is, it’s too much,” Apostol said.
Despite receiving a copy of the policy document, senior Kimi Adolfsen, whose process began following an incident in 2022, said she left her initial evaluation with an unclear sense of what the process would look like and with a compulsory “pamphlet for mental health” from the coordinator.
As soon as her process ended, Adolfsen said, all supportive and protective measures in place ended abruptly; no one checks in on the well-being of complainants after the hearing, she said.
Library and Academic Technology Circulation Supervisor and Oral History Research Coordinator Shannon Salandy ’23, who was a staff member at the time of her Title IX experience, also pointed out the concerning absence of follow-up care after a Title IX incident is resolved.
“If somebody goes through something that traumatic, where you feel like you want to offer them resources to get counseling, why would you not follow up with it?” Salandy said.
Salandy and Adolfsen also both commented on the line between invalidation and neutrality. Salandy said that the consistent reminders of coordinators’ obligation to impartiality throughout the process by “making it so clear that [they] have to be neutral and be on both sides…takes away from the validation of the person who…got assaulted.”
While recognizing that coordinators have to remain impartial toward both parties, Adolfsen said the coordinators “also need to validate the students’ experiences” and cannot “attack [complainants] for things that psychologically they couldn’t control.”Salandy said the team could implement new, small ways of demonstrating care without showing partiality, such as providing both parties with a follow-up care basket to represent continued support from administrators. Salandy said the coordinators could provide resources at the end of the process, similar to how they communicate to students that the “door’s open” for further support.
Advisors
The Title IX policy allows parties to seek a “support person” with whom they are comfortable and who can offer the personal support that policy administrators cannot.
While Apostol said that the process was emotionally challenging, she found the help of a trained faculty advisor, also referred to as an advocate, essential to making her experiences more manageable.
“The great thing about the Title IX process is that you have the faculty on your side,” Apostol said.
While advisors are important resources, Adolfsen said there was a “horrible” lack of clarity in the version of the policy used during her case over who is an advisor and who is an advocate, noting that “it’s not consistent for who is who and what each person does.”
Krikorian clarified that the terms “advisor” and “advocate” describe the same role, though this interchangeability is not indicated in any version of the policy. In the 2024-25 version, the word “advocate” is not present, preventing any future confusion caused by earlier versions.
According to the most recent policy, an advisor can be a friend, mentor, family member, attorney — which each party is responsible for hiring on their own — or other individual to be present for meetings, interviews, and hearings in the resolution process. If a party would like a trained advisor, the coordinator will offer to assign an advisor of the party’s choice from the resolution pool at the College, according to the policy.
Krikorian agreed that if a party is an employee of the College at the time of their incident, they are still entitled to a trained advisor on campus. However, Salandy said Krikorian “didn’t even give me a list of the people that I could go to talk to.”
Salandy questioned whether she was supposed to “find those people myself,” since she received no guidance in connecting with “somebody that I might have been more familiar with” to act as her support person throughout the process.
Currently responsible for receiving student appeals in Title IX cases, Krikorian said that having “an advocate who’s knowledgeable about the process” is strongly encouraged.
Having someone “by your side who can be there for any time you have a meeting,” Feyerherm said, “is a real key thing” for those going through the process because “being alone in [a meeting] is scary” for some students.
Feyerherm noted that the Title IX coordinator is currently seeking to train more individuals to act as advisors. Any staff, faculty, or students who are interested should contact Krikorian.
Though the process is separate from a criminal or civil court process, similar emotions and elements can create confusion over the distinction between Title IX and a legal court.
Distinction from criminal and civil courts
Title IX does not have the same jurisdiction as a legal court, but some cases can and do move into either criminal or civil courts depending on the specifics of an incident.
Dr. Rydel explained that members of the resolution pool undergo extensive training to understand that the process is “not a criminal finding,” and cannot thoroughly “investigate and find the solution.”
She also explained that there is an “educational component” to Title IX, unlike with legal courts, that seeks to make respondents aware of the ways in which they have offended or violated someone else’s boundaries.
Wills also described the differences between Title IX and a court of law. She acknowledged that, although individuals in the process reasonably expect the court notion of “serving justice,” Title IX is not able to fulfill this role.
“[Title IX] so often involves vulnerable circumstances, and in these situations we all want to see ‘justice,’” Wills said. “Title IX…is not crafted to ensure justice, as frustrating as that feels.”
Wills noted that individuals can pursue other courses of action that are able to serve justice but that “Title IX’s mandate is to ensure equal opportunities to education,” not to act as a criminal or civil court.
While students expressed frustrations with the relationship between criminal courts and Title IX jurisdiction, Laking said that she believes the investigative process is “more humanizing and restorative than the court system” because of its flexibility in resolution methods and its fairness for both parties.
Communication and Timeliness
Some of the most frequent expressions of dissatisfaction from those who have been through the process are related to its length and the communication that occurs between coordinators and parties throughout the many months that can pass before a resolution.
Salandy said that although the content of her correspondences with the Title IX Coordinator may not have always been positive, she appreciated that Krikorian adequately maintained communication and responded to requests for dialogue.
“I thought that [Krikorian] communicated very well throughout the process,” Salandy said. “Even though I feel like what he might have communicated maybe wasn’t something that I wanted, I was still happy with how he communicated.”
According to policy, processes may extend beyond the time frame but parties must be notified and provided with reason for the delay. Adolfsen said that her process lasted from early Nov. of 2022 until the appeal decision in Aug. of 2023.
“If it has to go longer, you’re supposed to give notice; Krikorian is supposed to tell us if [the process] goes longer than 160 days,” Adolfsen said, which did not happen for her.
Apostol called for stronger communication between coordinators and complainants in order for the latter to maintain a concept of the timeline and weekly progress of a case rather than allow extended periods of silence to pass during the investigative process.“I think there’s a lot of quiet moments that make you nervous as someone who’s going through the system. As a survivor of sexual assault, that’s not something you should have to check up on multiple times throughout…the process,” Apostol said.
Clymer, however, said that while she sympathizes with students who are made uncomfortable by long periods of time without communication, she did not recognize any need for additional contact.
“There was no reason for us to have contact and for me to be retraumatized again…over that period of time while there were no updates,” Clymer said.
Krikorian also acknowledged the challenge of avoiding retraumatizing complainants during the initial evaluation, as coordinators “don’t want to re-victimize the person who was making the report [by] having them tell a story over again.”
Clymer said that her confidence in the coordinators made the timespan of the process more manageable.
“I’m not going to sit here and say I didn’t get frustrated during it, because there were moments of…impatience and frustration,” Clymer said. “But at the same time, at the back of my head, like, I trusted that the coordinators…were doing their job[s].”
In order to address dissatisfaction with the Title IX process, the WC community must understand the expectations and limits of both the coordinator and the policy.
Education
Administrators and students agree that there is a need for improved education initiatives and prevention efforts to increase awareness surrounding sex-based harassment, discrimination, and assault. Many students identified the orientation presentations as the extent to which they have seen Title IX education efforts beyond the posters around campus, which feature only the contact information of the coordinators.
Apostol said the Title IX presentations were infrequent, noting the need for “educational forums not just at orientation, not just at boot camps,” but “throughout the year, especially during…red months.” Red zones are the time period at the beginning of the semester when the risk of sexual assault on college campuses is highest, according to The Center for Women and Families.
Rather than lectures from familiar WC administrators, Apostol also suggested the College invite speakers from non-profits and outside organizations to come and host round-table talks and education forums on sexual assault.
Salandy also said the College needs more robust and frequent presentations like those during first-year orientation.
“I feel like presentations could absolutely be a lot more specific in terms of the things that they are defining…and also different ways for students to protect themselves,” Salandy said.
Salandy said education needs to address circumstances beyond behavior influenced by underage drinking and teach incoming freshman about inappropriate behavior and interactions, such as boundaries while dancing at social events, that can be ambiguous or unclear for some people.
Laking said that having an understanding of the reality of the process may help in prevention efforts.
“I often think that education would be improved if we could paint a realistic picture of what it’s like to be both a complainant and respondent,” Laking said, “because anyone who understands what that’s like, and how long-term the impact of the experience can be, doesn’t want to find themselves in either position.”
Krikorian emphasized the importance of students providing feedback to determine what is and is not effective about the process and “feedback that would allow [the coordinators] to do it better.”
Recognizing that “students learn best from other students,” Krikorian said that “having student organizations be passionate around the topic” is important for education and prevention.
Krikorian suggested “taking this topic on in doing either passive or engagement activities, like a Take Back the Night march.”
Dr. Rydel suggested students organize initiatives affiliated with groups like Men Against Violence Against Women and the White Ribbon Campaign. They could also host events like V-Day performances of “The Vagina Monologues” among other student-led methods for educating and encouraging the prevention of sexual harassment, discrimination, and violence.
Another resource for improving education is looking to the websites of other institutions and to learn about the programs they host. For example, the Title IX site for St. Mary’s College of Maryland features a drop-down menu with frequently asked questions and a tab with awareness campaigns. The College of New Jersey breaks down the policy into easily navigable tabs and a graphic to explain the reporting process visually. The University of Maryland hosts regular workshops and events on topics like consent and care and “decoding” Title IX policy.
Krikorian acknowledged the reality of addressing sex-based discrimination, harassment, and assault, especially for complainants.
“There is such a low probability that any party who is a part of a Title IX or sexual harassment [or] discrimination [incident] is going to feel good at the end of this,” Krikorian said. “It’s a no-win situation for all parties involved.”
In addition to caring for and validating the experiences of complainants in Title IX resolutions, the WC community must understand the process’ many challenges –– both emotional and practical, as reflected by both complainants and coordinators –– to effectively inspire changes in education and prevention efforts surrounding Title IX on campus.
Photo by Olivia Long.
Photo Caption: Many are familiar with Title IX, but there are misunderstandings with the process.