Webinar: How to Meet Title IX Training Requirements in 2020
Helpful Resources on Title IX Final Rule:
- Updates to Title IX Training from Get Inclusive: https://getinclusive.com/updates-to-title-ix-training-from-get-inclusive
- Ten Things to Know About the New Title IX Regulations (ATIXA): https://cdn.atixa.org/website-media/atixa.org/wp-content/uploads/2020/05/11155019/ATIXA-R3-Webinar-Slides_5.11.20.pdf
- Summary of Major Provisions of the Department of Education's Title IX Final Rule (PDF): https://www2.ed.gov/about/offices/list/ocr/docs/titleix-summary.pdf
- Key takeaways from Parker Poe: https://www.jdsupra.com/legalnews/key-initial-takeaways-from-the-u-s-97949/
- UTSA reaffirms commitment to zero tolerance of sexual assault and misconduct: https://www.utsa.edu/today/2020/05/story/titleix-utsa-commitment-safe-campus.html
- ACE Engage Webinar: Discuss the Title IX Final Rule: https://player.vimeo.com/video/417654788
- OCR Webinar: Title IX: An Introduction to the New Regulations: https://www.youtube.com/watch?v=TdfT5R8ibm4&feature=youtu.behttps://www.youtube.com/watch?v=TdfT5R8ibm4&feature=youtu.be
We huddled with the team this morning, Get Inclusive and talked about some of the books that we're reading right now. And as always, for anyone on the webinar today that is interested in any of these books. Send me an email and I will send you a copy. I probably can't send four copies to everybody, but if one of these is of interest, you may have my e-mail already. But if not, it's email@example.com.
The book on the left "Superior" is one of the best books I've read this year. For those that are familiar with Guns, Germs and Steel and sort of books of that sort, that really go look at historical context in depth. But it's through the lens of race and it just is just an incredible book. And I know that this is a time where all of us are trying to understand the complexity of issues that our society is facing. But we also want others in our family and in our communities to do so. That as well. And I've found that sharing books is one way, one small way to start in that direction. So if any of these books are of interest to you, send me an e-mail and I will send you a copy. And we will. let's jump in to today's presentation. How to meet Title IX requirements in 2020. My goodness, what a complex life we all are leading right now. There are lots of issues. We have day jobs. We have night jobs. We have weekend jobs. The new regs are complicated. Leslee Morris there's no one better from a tax than TNG to come in and spend some time with us on this topic. The rules of the road, please ask questions. There's a Q&A box you can up. You can upload questions that you see that have come in from others that will tell Leslie and I that those are of a higher priority. We will be recording and any resources that are discussed today will also be shared. We've also compiled quite a few resources that will be sending out after the webinar. The folks might find of interest. OK. This is the format we're going. We asked the pride, the what point of registration. We asked you to submit your questions. We received a lot. Those have been shared with Leslie ahead of time. I have Leslie. I have a slide for each one, so we'll try to keep continuity there. But if I miss one that you want to talk about, you can. This obviously the show is yours, so this can go.
How are we need to at the end of that time on the webinar today, many of your partners and know get inclusive already. And so you work with us. And so a lot of the questions that came in related to how our training is going to be adjusted or modified to meet the new regs. And so we're going to spend 20 minutes on that. For those of you who are not interested in that, that's what that's fine. You can job for those of you who would like to stay at May, even if you're not a partner with us, it may relate to how you're thinking about whatever solution you do have. So so it may be worth your while, but I'll let you know when that intermission comes and you can make a decision at that point in time. Leslee Morris really, really quickly here. Got it. We want to jump into the content. A senior associate with TNG and received her J.D. and mediation training from the University of Colorado School Law.
She was admitted to the Colorado Bar in 2000 and served as an associate of assets, the Office of the University Counsel at C.U. specializing in employment discrimination cases. Most recently, Leslie was Title IX Complaints and Grievances Coordinator for National University in San Diego, California. Leslie, welcome and thank you. My name is Preston Clark. I'm the president here at Get Inclusive. I am also an attorney. Far less of an expert than Leslie is in a previous life. I was assistant general counsel for the University of Miami and in a previous life I was also the president of Ever PHI. Have been in and around these topics and issues for a long time, wearing different hats across my career. Thank you all for being with us.
For those who don't know about Get Inclusive, we are an online Title IX training provider. Very different from a Texan TNG in that we we we focus on sexual assault, the timeline related topics for students and employees, whereas obviously a lot of what it takes in DNG do is focused on the development of Title IX coordinators and investigators. Let's jump into it. We don't have much time. Leslie, thank you again. I've ordered these in some way that I thought it was thematically coherent. Maybe I didn't do a good job. Let's jump into them. The first one is, can a small institution have wanted you to cater for both students and employees?
Thank you so much. I do just want to say thank you, Preston, for that, for what you said at the beginning of this. I'm not going to lie. I personally am having a very hard time focusing on things like this right now with all of the absolute injustices that are happening all over this country that I really appreciate you making the book recommendations and only read one of them. But I will read the others. And I really appreciate you sending that out at the beginning. So thank you.
You are going to miss me up because I reordered my questions based on themes, but I'll do my best. I went through all the well.
Well, I actually. Then let's let's do that. Leslie, how all try to catch up with you?
No, it's all right. Thank you. OK. OK.
I was a little bit so yes. You certainly could have one adjudicator for both your students and employees. One benefit of that would be consistency of decisions. One drawback of that would be that you do have to account for the unavailability of that adjudicator. You cannot have a delay based on the fact that that person is unavailable. So you want to make sure at least that you have a backup trained if that person is unavailable. I will also say just having been a solo adjudicator for many years, it's a lot for one person to do on their own. It's a lot of responsibility. So, yes, you could do it. But there are some caveats.
It's going to take me into a doozy around. Can I expect you to minimize. Yeah, sorry. That was quite a transition.
Oh, good. Can I explain it? No, I can't because it's very poorly written. But I will do my best. So this question. I love that someone's a close reader. Page twenty. Twenty five. Yes. Someone has read all of the pages of the regs and all of the preamble. So great.
So you probably know that the new regs require that for institutions of higher education, that a hearing occurs before there is a decision made on sexual harassment, domestic violence, dating violence, stalking cases, and that at that hearing, if one of the parties, OP's not to participate in the cross examination portion of the hearing, then any statement that they made cannot be considered. The current Office for Civil Rights and Betsi Davos has really leaned in to this idea that cross-examination gets to the truth of things. I don't know that I agree with it, but that's where they are. So that's where we are. I don't know exactly what this means. There's a weird sort of allowance for that. If a question is asked for or a panel member and the party chooses not to answer it, then the panel can still consider statements versus if that question is asked by an adviser. So one thing you might want to consider as you're structuring your what your cross-examination will look like at a hearing is if a question is posed on cross and the party chooses not to answer it.
Does the panel then one to answer that, ask that question themselves? Because then that seemingly would allow for consideration of the statements, which seems very bizarre. We need clarification from OCR on this point. It's really confusing. If this relates to the second part of that, that statement about cross examination, there's a second part that sort of says you can't draw any negative inferences from someone not participating in cross. And what they have in some of the commentary preceding the regs that really is meant that they don't want the hearing board to make a negative inference from there, that they're using neutral language. But the regs, the commentary makes clear their intent is that if a respondent chooses not to come to the hearing because they have a parallel criminal process going on, that the panel then doesn't sort of assume that they're guilty because they didn't come or responsible. So that I don't I'm not sure which of which of the things that pertains to you. But hopefully hopefully I answered most of it. Hopefully more clarity to come from OCR and the cross-examination. It's extremely confusing.
Great. Thank you for that. I'm also so we're going to move through the questions that were set prior to the webinar at registration the best we can. And I'm also monitoring the Q&A box to see if one to get uploaded and we can load those in as well. But we'll continue on with what's here. How can we Ferenz obviously valid timelike complaints from not being submitted due to the new guidelines.
So thank you for having submitted this question, because this is something that I'm extremely concerned about. I think this is likely the result and perhaps the intent of the regs is that, you know, there definitely will be some dissuasion from complainants or about. Previously we called reporting parties coming forward. I don't know that there's a lot that we can do about it.
There is this allowance in the regs that the Title nine can coordinator can step in and decide to such essentially be the person who initiates the grievance process by signing a formal complaint. So there is some allowance for situations for the Title nine coordinator if they're aware of something, to then look and sort of make an evaluation based on things like, you know, is there a weapon involved? Is there violence? Is this someone who we've had previous reports about before? There's an allowance for the Title nine coordinator to step in and sort of get that grievance process underway. But keeping people. But I think, you know, there is definitely a legitimate concern that people will not reach out for two to even consider the grievance process given this cross-examination requirement and how long the process is going to take. What we can do about that? I don't know. I mean, my my honest experience just working in higher ed since 2005 is have a robust become victim advocacy program. If your victim advocates know you as the as the people adjudicating the Title nine process, they may be able to sort of create situations where you can come in as an investigator or a title, not maybe not an investigator that might be not warranted, but as Title nine coordinator, go in and meet with someone and say, you know, we're not going to share names right now.
We're not going to talk about the allegations in depth. But I can tell you about the process, what it looks like. I can tell you what we're doing to make sure that it's not abusive. So that could be something that you could do to maybe sort of assuage some of that. The other thing I will say is that probably we should all be doubling down on our prevention efforts right now, because if we can prevent things from happening at all, then maybe we can avoid some of this very complicated process that has now been put upon us. So to the extent that you can, you know, reiterate your bystander options, your trainings, recall anything prevention focused, I would say that as educators. That's a really good thing that we should be doing. OK.
Great. Thank you. How should we address complainants requests for anonymity under the new regs?
Right. So we know under the new regs someone really can't be anonymous. Right. There are first of all, the complaint has to be signed. Whatever that means, even if it's an e-mail signature. And second of all, the written notice of allegations that goes to respondent upon receipt of the complaint must require the name of the complainant. So somebody can't really be anonymous. That's a good conversation for a Title nine coordinator to have with somebody who is considering bringing a complaint forward. It's really important to be transparent about our process.
If someone does make a complaint and then decide that they don't want to go forward with it and the Title nine phony alert coordinator has not decided that it's one of those situations where where we want to go forward regardless, then the complainant can withdraw their complaint if they sort of make that complaint and then realize maybe they don't want to proceed but aren't anonymous complaints really are not an option under the regs.
Please help clarify the change about investigations, reports off campus.
So we're not really tied to where something happened when we're considered whether we're obligated to report excuse me, whether we're obligated to respond or whether we choose to respond. Right. Remember, the regs only set a floor of when you have to respond to something, but you, as an educator, as a recipient of federal funds, as an institution, can decide that you want to respond to things that don't that don't necessarily fall within those narrow confines. So when it comes to off campus incidents. Right. It's really all about did you have control over the respondent and over the context of the of the reported harassment? Did it occur in your programs?
And the third the third the third step that maybe is where this question is being prompted has to do with incidents that occur on property that is owned or controlled by a student organization that is recognized by the institution. So this really is meant for fraternity and sorority houses. So if you have a recognized student organization like a fraternity or sorority and an incident occurs on their property, that falls within the jurisdiction that that the regs have prescribed.
Great. Thank you. Should the time line coordinator be present in the lives hearing?
I thought about this one when I was preparing for this. I don't really know. I think the Title 942 could be present. It certainly could be the case that the decision maker or the panel is going to have questions, at least when you're. Hearing panel is getting used to having these hearings. There's probably going to be a lot of sort of bumps in the road when we're figuring out how to do this and do it well.
My preference would be that the Title nine coordinator be available, but not actually be present in the hearing. You can see from the rags, right. They're really trying to create this barrier between decision makers and the investigator and coordinator. So my suggestion would be just to sort of keep that all clean. Maybe the coordinator would be better being available, but not actually being there.
Great. Before I jump to the next. For those who were here at the beginning or just to to reiterate it, there is a queue and a box in Zoome, which you will see. You can submit questions there. But most importantly, ask everyone to take a minute to read some of the questions that are already posted. There's a thumbs up button. And if you press that and vote those questions up as we get to the end of our time here, I'll try to make sure that we are prioritizing any questions. Of course. Leslie is going to have to agree to answer it. But if you could help vote the ones that you think are most relevant to the most people, we have about 500 people on this today. So we're going to try to do our best to to do to reach as many people as we can in a short period of time.
How do perent obviously valid hopes we did this one already.
Great. We just got shorter, Leslie. This is great. And this one's very particular related. So this is going to be fun. So we're going to be able to go back and look at some of the questions posted. But while I'm going through these, Enea, do you want to give any perspectives on on how on the tax side and how it takes in and TNG you can work with? This isn't a cap. I didn't place this question. This is a real question. So this wasn't a setup.
Anything you want to add on this one?
Yeah, of course. I would just say I mean, obviously there are there are lots of groups at law firms, all kinds of groups out there that provide training. I work for Texas because I think they're the best. But there is a whole litany of people that can do trainings.
Some are better than others, of course. I would also say that there are so many out there. I know those couple. There's a couple of questions. One, too, about funding. I know so many schools are facing funding restrictions right now. There are so many people out there out there doing these trainings. If it was me and I worked at a school and I was trying to get my staff trained up, I wouldn't hesitate to call somebody and be like, hey, is your pricing flexible because there is such competition right now for this? That said, a tax is one, of course. Do you have the capacity to provide advisory hearing officer training advisers? And can we actually do it? Yes, we can. We have something called I think it's called like the third party neutral service, where we can certainly serve as as as advisers, as hearing officers, decision makers.
Yes, we can do that. So.
Ok. We. So, Leslie, we have a question that has 11 upvotes. I'm not sure if you can see the questions or not from you. You see the one from Rick.
Was it in the Q&A? Let me pull up the Q&A. It is OK. I could read it, but it's long. And I know Rick, Rick, Rick and Rick, they reached out long time.
All right, Rick. It's going to be hard because Rick probably knows just as much as I do, if not more. Hi, Rick.
Nice to see you out there. Glad you're still working in this field. OK, assuming behavior that would be covered under Title nine, such as nonconsensual penetration.
What recommendations for due process in cases that don't qualify as Title nine because of jurisdiction? Right. So there'll be some situations where the Title nine Cordia co-ordinator will look at the allegations and decide that the allegations would.
Relate to conduct that would fall under Title II. But jurisdictionally it's prohibited. OK, so we're on the same page. Is it palatable for the same behaviors that might be taking place across the street from one another to be operated under a different procedural standards or should due process plus apply based on the conduct involved? I knew it was going to be a doozy of a question. So the background for people who don't know what what records are referring to is that the the regs are making it clear that if you're Title nine process doesn't apply, for example, because you are proscribed from applying it because of jurisdiction reasons, you can then apply a different process. So say, for example, example, your student conduct process applies to conduct that occurs off campus.
You could use that process to resolve those other types of allegations. So is it palatable for the same behaviors to be operative?
I think so. I don't exactly know what OCR intended by this, but I think that that is is what is permissible.
I would say, you know, of course, the leadership, the due process requirements, I mean, these regs are extremely due process heavy. But many states also have due process protections. Right. I'm in California and California. We have to have cross exam whenever credibility could be an issue. So I would say maybe look to your state laws in those instances to make sure that you're meeting your due process protections under your state law.
That's I think I'm gonna let us move on. It's a it's a great question, but I think let us move on, if that's OK.
Ok, great. Thank you. Everyone's voting, this is this makes our life easier. Thank you. How would we get. How would we get a copy of the book? OK. We'll come back to that at the end.
But for those who join late, we talked about a few books relating to to race, social justice and other topics. And I'll tell you about how you can get a copy at the end. Not holding that, but I want to keep moving while we have Leslie here.
Ken respondants choosing not to participate in a hearing due to pending external investigations mean we can't proceed at all.
No, it certainly does not mean that it may make it more difficult for decision makers to make a determination. But let's think about that situation where there is videotape evidence. Right. There are many cases and those of you who have been doing this work or in student contact for a lot for for a long time. No, no. We certainly, in almost all cases will go forward regardless of a respondent's willingness to participate or not. We'll still give them all the notices they're entitled to, but we still certainly can proceed.
Great. And for those wondering about the slide, these are new questions coming in now. So these don't match with the slides. These are ones that are coming into the Q&A. Thank you for that. I'm gonna go to looks like there's a question from Beverly. If you see that one, let's see if the title I coordinator files the complaint. Can they investigate that complaint? I'm an institution where my coordinators also the investigator, is no longer allowed under the new regs.
If the I see it.
The title line coordinator, oh, good question. If the Title nine coordinator files the complaint, can they investigate the complaint? I don't really know the answer to that. I'm going to say so she's in an institution where the title nine Chordata is also the investigator. The title nine coordinator in general can be the investigator. So that does a general rule is fine under the new regs in your situation, where the title More Title nine coordinator filed the complaint. I guess it depends a little bit on how involved they are in the filing of the complaint. In other words, where they sort of just acting, you know, sort of just in the capacity of a complainant just to sort of do the formality or were they involved sort of in gathering information? If if it's the latter, then you may want to have a little bit of a separated process, whereas if it's the former, it probably would be OK.
So in general, it is permissible both. There will be circumstances where you probably should look more specifically on a case by case basis.
I'm sorry, I'm jumping back because I see there's some. Discussions regarding Christopher's question. But then to not look at any of their testimony or evidence, I don't know if you see this thread that's underneath Christopher's comment that you already answered last week, 30 more. We can jump on to the next one.
Or if you think this is worth double clicking on hold for to you, I'll just acknowledge simony, kind of whom Annique is too nice to. Nice to see you out there. So can we. Right. This is a very complicated situation and OCR has not really given us any clarity. They did provide a little bit of information on their blog a couple of weeks ago. If people saw that about relying on the statements of people, even if they don't submit to cross-examination. So what they are really will not. It seems like, again, it's very murky, but what it seems like they do not want the hearing, panel or board to rely upon is any sort of factual assertion that are respondent allegedly made. So if a respondent participated in an interview or submitted a written statement, then the hearing board won't be able to consider that. If they don't participate. But if the respondent made statements to the complainant, the complainant can still share that information. So it's a complicated situation. We definitely need more clarity on that. But maybe look at that blog from OCR on May 22nd. I think it was May 22nd to see if that fits like their most recent blog posting to see if that gives you any more clarity on that.
Great. Looks like the next one up is from Bill Spear. Can students agree to participate in the cross examination, but then plead the Fifth? For some are all questions and still have their state and be considered by the decision maker.
Yes. We don't know. This is a very good question. We don't really have an answer on that. It's something that we're talking about at a tick sun, trying to come to some sort of consensus on. That's a great question. If they answer some questions and on others, how does that work? We really don't know. This may be something where you want to develop some written language in your policy about how you're going to deal with the situation, because in lieu of clarity from OCR, we really just don't have good guidance on this. It's not addressed in the commentary, as Bill probably knows of all the all the commentary preceding the regs. They don't provide clarity, just the right. This part of the regs about cross examination is not well written. There's not a lot of information. And we need a lot of a lot more a lot more clarity from OCR to help us do this well. But I appreciate the question. Thank you, Bill.
Ok. We just have a few more minutes here. I'm concerned my institution is removing the coordinator under H.R. Department and V.P. of Student Services. This is a proper best practice for higher ed.
You see that one is Oscar Garcia.
I don't really see a problem with it. It may not be ideal, but I don't think it's a problem.
I mean, a bigger consideration for me would just be that making sure that whoever is involved in the title name Title nine team has the confidence of both students and employees, regardless of where that exists.
Let's see if we can squeeze in a couple more here before we jump to the next part, and then you raise only reference to delegating beyond the title and coordinators for receiving reports disclosures.
Do you believe this lack of direct opinion gives us the ability to delegate in other areas? Example Title IX Cornaro offer supportive measures on Cawdor. Will assess confidentiality requests, etc..
So if if I think the question is whether the Title nine cowriter can delegate other parts of the responsibilities, I would say some of it I would say yes.
Yeah, I think that probably is permissible. I don't depending on the size of your institution, it probably is more optimal for this to live with the title nine Chordata, because that's clearly the intent of OCR. But if you have a large institution and you have a coordinator who has many other responsibilities, I think it would be permissible to delegate those things. Just be clear, your policy that that's what you're doing so that it's transparent to the people who are who are the potential parties.
The next highest vote going continuing this, this, this order and the new rage. The only reference to delegates beyond the time I'm currently receiving is this one. We just ended up sorry. We keep going. Do we have to have one decision maker or do we have to have a judicial committee?
Either option is fine. There are benefits and drawbacks to each. I will say if you decide to have one decision maker, please be sure that they have lots of administrative support. Because if you think just about the challenges of scheduling. One of these hearings, let alone making sure that the parties have access access to the evidence that they're required to have at the hearing and addressing all of the things that could come up. Just make sure that if you have one person, that they have some support.
A panel that is that is that is the recommendation, a panel of three. It also protects against if there's a challenge to the bias, if you have only one person. And there's the challenge that they're biased in some way. Then you have to go to it to whoever else you have trained to do it. So but you could have one person.
Oh, I see. And we have a new top vote getter and I missed it, so let me jump back to the top. And maybe we can do one more and then I'll let you get back to Leslie sent. An informal resolution is not allowed when the respondent is the employee and the complainant is a student. Does that mean that the only option for a student would be a formal hearing with cross-examination from the adviser who may be an attorney to the student?
Sadly, yes. That is correct.
You cannot use it for which I think we lost your audio.
Oh, really? Anything. OK.
Yes. And thank you for the question. And yes, you are correct. You cannot use informal resolution for allegations that an employee sexually harassed. OK.
Ok, I think we I think we got that answer in. It started here. Shake it there a little bit. I think that the answer came through, Leslie. I'm just going to look I know we're at a time and we can't jump to the second part for those interested in doing so. Let me just look through this really, really quickly. I appreciate so much engagement here. And if your question doesn't get answered, I apologize. We tried to do our best to collect as many of these ahead of time. When we talk about not considering information submitted by a party, does that mean that the nonparticipation carries the same weight as participating? We'll end on that one.
I'm I'm not quite sure how to. Let me see. I'm Rick. Sorry. We're back at the top. I don't see that one, is it? Is that in my OK. It's Preston.
Yeah, it's it's moving to right there because we're getting so many votes. It's also hard to track.
And now I've lost it, of course, so I apologize, imperfect system with this many people, unfortunately. And we try to go to a different one and then we'll let you go.
What about see Briggs, see this one? What do the new regs say about the need to provide equal advise options for both parties? Will colleges need to provide a lawyer as another party if the party has legal representation?
It's a good question. I'm glad that I'm glad that somebody brought up the advisor issue. So I will speak briefly to that. I'm not taking too much time away from your second half of your meeting.
So, no, you're good.
I quote, The only requirement that you provide an adviser only pertains to the cross examination portion, part of a live hearing. There is no requirement that you provide adviser outside of that. That is the only time you may want to consider whether it would be rather awkward for someone to step in at that point and and serve in that role. So you may want to consider whether you want to provide it adviser earlier in the process. But the only requirement that you provide an adviser applies to that cross-examination. There is no requirement that you make an attorney, make that person that that person does not have to be an attorney. There's actually very little required in the way of having any training for that person to step in as their role as the adviser. So you could definitely be looking at inequities at the abilities or skill levels of of advisers at the cross examination portion. But the only requirement is that they are provided at no charge at the portion of the hearing for cross exam and that advisers are chosen at the recipients discretion. So whoever the recipient, such the recipient being you, whoever you should choose to serve as an adviser.
Ok. That's that's great.
And Jessica, I got a comment from Jessica that sounds like less of your audio is fine. Maybe I was hearing you staggered. So, you know, good.
Sounds like everyone heard the message. So I want to I want to stay on track here and be mindful of your time. We did. We got a series of questions relating to how Get Inclusive is adapting our training to meet the new regs. I know that some of you are not interested, and that's why I wanted to sort of give a clean break and say I hope that this was was valuable to you. If you're interested in how we're responding, we're on my time line training provider. Most of you know us and work with us already. But for those who don't. If you're curious, you may stay. We talked about at the beginning for those that came in late, we talked about making some of these books available. Also, restate how you can get a copy of these. Right. When we end in about 15 minutes. But, Leslie, the best way for folks to follow up with you or anything, any last closing words or anything you'd like to share before before we let you go?
I honestly just want to thank everybody for being here and for hanging in there. It's a challenging time to be in education with these ranks. I find them really difficult for those of us who really care, especially about the well-being of our students employees and the safety of our campuses. I think it's challenging. So I just want to thank you all for hanging in there. And we will work through this together and work with it as long as we need to. Thank you very much for letting me join you today. I really appreciate it.
Yeah. We thank you, Angie. Yeah, OK.
Thank you. Thank you, Leslie. We'll let you go. I have a few questions to run through that were submitted. I'll run through these in the next hour. I'll keep this as fast as possible and then I'll let you get get back to Yarl's Day. But again, thank you, Leslie, for your participation. The the.
We'll start with.
And the move my screen around here a little bit. My dashboard. How get inclusive employee training, address the change in scope of manager mandatory reporters. So we you know, again, just for context, my background is both. You know, I sat in the general counsel office of a major university have also worked in or on Title nine. But these are complicated regs. So we also, as we did on this webinar, we went to Leslie and we went to Texas and DNG for guidance on on how get inclusive as a training provider was going to address these these topics and these issues. So ah ah, we are here to serve you. Ultimately, we believe that that the majority of institutions are going to continue to train all employees on mandatory reporting requirements. The difference is where the mandate comes from. We assume that most institutions we're talking to are going to persist from a policy perspective with the mandatory reporting structure. And so we are preparing to to meet those requirements in that way with you for the institutions that plan to change their policies or to take a different posture as it relates to different populations or sub populations that will have different obligations or responsibilities on campus. We're here to work with you in our capacity to understand that. So we're we're not here to to pass judgment necessarily. We know that some institutions have political reasons that they may be contemplating a change in who are reporters, who can be confidential advisers on down the line.
And so from an education perspective, we're here to support you. We're also here to support you from a policy perspective. And so we're seeing. I'll jump to the next question. Many institutions. To the extent you are updating internal policies or definitions or things that you want to be included in your title line, employee training or student training, as it may be, as you. If you're a partner of ours, you already know this. But we enable that our technology and our platform enable that. So you can upload the policy into the training experience when when the learner goes through it, they will they will be asked to review the policy and, of course, be asked to acknowledge the policy. And so you will have, in addition to your training record, that The Nante Smith finished the training on X date. You also have proof of acceptance or acknowledgement of the policy. This is one that we got a bunch of questions on. We'll get inclusive, enabled campuses to post our training online to meet the new posting requirements outlined in Section one six point four or five feet and D. So our interpretation is that that this section does not apply to Title nine employee training. It is relating to investigator training or title line coordinator training. And so we think that this is a an issue that takes a TNG and others are needing to address.
We're not here to pass the. We're not here to to to to debate that point. If you come to us as an institution and you say, no, we've interpreted it differently, we need to make your training available publicly out on the website. We'll probably say we don't agree with you. But if you need to do that, then we can facilitate that. So from an idea, from an intellectual property perspective, from a business model perspective, we we don't we're not we're not going to hold a firm ground on that. We are businesses different from a TEQSA. And, you know, for our purposes, if you want to post it there, then let's post it there. Let's let's do it. How we'll get inclusive address conflicts between Title IX and state law. I think many of you are very, very well versed on this, probably even more well versed than will some of you may be more versed in Lesli. You probably all more well versed than I. But how we are interpreting the regs as they've always been interpreted, is that this is a flaw, that there shouldn't be a lot of conflict from a timeline and state law perspective. And so, you know, we reserve in our previous conversations with Leslie, we're sort of poking around and trying to find an instance where an actual conflict came up. One of our partners in Texas asked the question relating to mandatory reporters and again, like, don't see a conflict there because because the fact that the state law is more is not more restrictive or has has greater mandates.
Like, that's fine because, again, it's not in direct conflict to sidelining. This is a flaw in this capacity. When will our course avail updates be available? June 15th. So we're just days away from from new updates. To the extent that, again, you are making changes and you are responding to this in real time. We're here to help facilitate. And so if it's if, you know, we will have our updates ready. To the extent that you want to have conversations about how, you know, you maybe want a message from your president, maybe you want to reinforce to your faculty and staff that despite the change, that these are your new rules and these are your values and these are your policies. We're open to partnering with you and to find good ways to do that. We're having some campuses indicate that they want to do a welcome video or a video that's inside the employee training. That's a message from your time line coordinator or the president or others. Happy to facilitate that and to incorporate that into training to make sure that wherever you see, wherever you have concerns, where there might be new confusion relative to the changes that you're you know, you're putting your population in a position to have the greatest understanding of of of what the requirements are and what your expectations are.
I'm just going to go quickly to see if there's any questions specifically relating to what we're doing.
Ok, cool. OK. So I think that we're good. All I'll give you back some time. I'm going to do a quick poll. I'm just going to run. This is the most succinct way that I can ask you what you would like from us going forward. I'm just going to post this really quickly and I'll leave it up there for about 30 seconds. Wow. Well, I'm leaving this up here. Sorry. I'll read it for you. How can we help? And this is we this is the get inclusive. We are they it takes a we like to learn. If you're not a partner, many of you are a partner. But if you're not and you'd like to learn more. We do employee training. We do student training on everything from from sexual assault, sexual violence, us peregian all the way to employee training, frantic harassment training requirements that might be state mandated, like in the case of California, New York and Illinois, or not mandated as the case may be. a.D.A for NCAA student and student athlete, athletic staff training mental health. Yeah, on down. So you can if you're interested in learning more, that's great. I'd like to learn more about working with the TEQSA. Many of you probably already do. So I don't know how much I can facilitate there, but I'm happy to bridge that introduction. We're going to continue inviting experts like Leslie to webinars. So if you'd like to be invited to the next one, please let us know. And then we have a list of summary of resources. So we'll, of course, send the webinar recording. But if you'd like articles, there's some great content out there, right? There's there's a lot out there. And we've spent a lot of time distilling it. And so to the extent that you'd like a list of links and resources, please indicate that.
Ok. I promise. I mean, close this out and we'll end here in about two seconds. So we started this today talking about.
You know, we have a multitude of complex issues we're dealing with as a society. This morning I went out to the team again, inclusive, and I said, what books are you reading? What can I share with the group? The book on the left is one that I read this year that has just changed my view, deepen the history for me and understanding of what race means at the global level and certainly in the US. It's sort of almost like guns, germs and steel, but of race. And I just I highly recommend that book, Way Fragility is sold out on Amazon. But I have it on back order. I bring these books out because if you'd like a copy of one of these, I probably can't send for copies, everybody. But if you'd like a copy of one, you can e-mail me at firstname.lastname@example.org. And I'll send you a copy. You might not get it for two or three weeks, but. But these issues aren't going away, unfortunately, so it'll be just as relevant three weeks from now as it is today. So please shoot me an email. Let me know and I'll be happy to send you a copy. That's it. I hope that this was worthwhile. Feel free to send me a note if you'd like us to discuss other topics or if you will give us feedback. This is not what you expected or if we didn't go deep enough for you. Like a different format in the future. We're here to serve. You were here to get better. I hope it was valuable. I know that this is a difficult and complex time for all of us. And whatever we can do to help make your life a little bit easier. We'd like to be able to do that. So, again, thank you, everyone, for your time. Good luck out there. And if there's anything we can do again, please, please, please let us know.