Title IX Policy and Grievance Procedure Checklist
ATIXA Sex/Gender-Based Harassment, Discrimination and Sexual Misconduct Model Policy
ATIXA One Policy, One Process Model
A Developmental Framework for A Code of Student Conduct: The NCHERM Group Model Code Project
Discrimination and Sexual Misconduct Model
Policy & Procedures
ATIXA distributes freely and publicly its transformative ATIXA Sex/Gender Based Harassment, Discrimination and Sexual Misconduct Model Policy and Procedures, newly updated to reflect best practices, Title IX guidance and VAWA compliance mandates. Both our Policy and Procedures have helped hundreds of campuses as they strive to comply with Title IX and related legislation, as well as protect the safety of their communities. Let it help yours.
The ATIXA Model Policy and Procedure for Civil Rights Equity Grievance Resolution for all Faculty, Students and Employees
Overview | The One Policy, One Process Approach | What is the Model Policy
Why Choose a Unified Process | Choose the Model Right for You
Frequently Asked Questions | Free with Membership
Cost & Implementation Packages | Purchase the Model | Inquiries
As campuses work diligently to bring processes into compliance with Title IX, some of the more vexing challenges arise in five particular areas:
- Cross-constituency complaints (student-on-faculty, faculty-on-staff, etc.);
- Several to many different processes for resolving complaints accusing students, faculty, staff, unionized employees, etc.;
- Different processes for discrimination complaints than those used to address Title IX-related complaints;
- Incorporating Title IX equity standards into employee-on-employee complaints;
- Reconciling complaints that include both Title IX-covered behaviors and those standing outside Title IX.
Given the complexity of addressing these challenges separately — let alone taking on all five simultaneously — many campuses are realizing that Band-Aids on existing processes can work in the short-term, but that it will ultimately be better to address these challenges now with a permanent solution. But, how do we do so?
ATIXA has developed an approach called the One Policy, One Process Model (1P, 1P for short), based on the idea of a global human dignity resolution process. This model permits all discrimination complaints (age, race, sex, gender, nationality, etc.) to be resolved using one institution-wide policy, and one stand-alone resolution process, applied to all complaints involving faculty, students and staff. This process can sit outside existing processes, or can be integrated into existing human resource, affirmative action and student conduct models. It harnesses the existing resources of many departments to minimize the need for added staff and expense. 1P, 1P is not only Title IX compliant, it serves the best practices of the civil rights approach with an emphasis on meaningful remedies, social justice, victim empowerment and advocacy, comprehensive investigation and prompt, humane, non-adversarial resolution of everything from bias incidents to stalking, to rape and intimate partner violence.
The ATIXA One Policy, One Process Model is a unified policy addressing sexual misconduct and other forms of discrimination. The Model covers everyone equally with the same kind and degree of protection of their rights.
A unified process can be centrally administered and overseen, often by expanding the Title IX Coordinator role in the form of an institutional equity officer. Unification simplifies the investigation function and avoids duplicative training when there are multiple bodies all resolving the same kinds of complaints across the campus. Unification allows consistent sanctions and responsive actions for the same types of misconduct, whether it is committed by a student, faculty or staff member. Unification fosters collaboration across the departments that are stakeholders, including HR, student conduct, and academic affairs while retaining their needed voice in the resolution process. Critically, a unified process can also be essential to the detection and tracking of patterns of misconduct, to limit the frequency of repeat offenses that vex campuses.
Ultimately, we believe unified models will become the standard accepted practice. For those who fear that campus cultures or politics will not accept a unified approach, we suggest that the momentum created by the DCL make may this the right window of time to champion such sweeping change. It will also be easier in the long run to fix it right the first time, rather than to band aid existing processes not designed for equity in the hopes they will suffice. If we wait, the OCR and the courts will continue to enforce, legislate and remonstrate with what we do in these instances until we end up at a single process. Our hope is that now is the time to envision what can and should be done, and to lay the groundwork for a unified policy and resolution model on your campus.
For additional information on why you should choose the One Policy, One Process Model, click here.
Choose the Version Right for Your Campus. These most recent updates to the former document reflect the differing and growing needs of our clients. As such, ATIXA now offers multiple versions of this document. The ATIXA One Policy, One Process Model is available in three versions, modified to meet your needs, and can be chosen based upon your current processes and campuses preferences.
Version One – The ATIXA One Policy, One Process Model, Investigation-Only*
Investigation -> Coordinator-Implemented Resolution
Version Two – The ATIXA One Policy, One Process Model, Investigation-Only with an Appeal
Investigation -> Appeal -> Coordinator-Implemented Resolution
Version Three – The ATIXA One Policy, One Process Model
Investigation -> Hearing -> Appeal -> Coordinator-Implemented Resolution
*Please consult with your legal counsel to determine which version of 1P1P is best for your campus. In some jurisdictions, courts could find that Version One – Investigation -> Coordinator-Implemented Resolution may not provide sufficient due process for a public university. We believe that all three versions provide sufficient due process, but courts are still on a learning curve when it comes to the innovation of civil rights models in higher education. Versions Two or Three should be evaluated instead.
How can I get the 1P, 1P Model from ATIXA?
Campuses can license it from ATIXA for a fee, can acquire a license by registering for an ATIXA 1P, 1P Training, or can contract for implementation consultation, which includes the model. This Model is included in the Super and Full levels of membership. Learn more about membership with ATIXA here.
How long does a 1P, 1P license last?
Once a license is granted, a campus can use the model indefinitely.
Once we license it, will we receive updates to the 1P, 1P Model if it is updated?
Can ATIXA help my campus to implement the 1P, 1P Model?
The Annual Implementation Assistance Package is designed to help and guide your campus through design, approval and implementation of the One Policy, One Process Model. Campuses may encounter obstacles and challenges when attempting to implement 1P,1P. ATIXA offers a number of support options for your campus. For details on implementation assistance packages available from ATIXA, please click here.
Why should we consider implementing the 1P, 1P Model?
The 1P1P is the only unified civil rights-based policy of its kind. One Policy, One Process transforms and simplifies an institution’s approach to addressing civil rights-based violations by:
- Providing unified policy addressing all forms of discrimination.
- Covering everyone equally with the same kind and degree of protection of their rights.
- Being centrally administered and overseen.
- Simplifying the investigation function.
- Avoiding duplicative training when there are multiple bodies all resolving the same kinds of complaints across the campus.
- Allowing consistent sanctions and responsive actions across the university for the same types of misconduct.
- Fostering collaboration across the departments that are stakeholders.
- Improving the detection and tracking of patterns of misconduct, thereby limiting the frequency of repeat offenses that vex campuses.
Is the 1P, 1P Model just for Title IX compliance?
No. While 1P, 1P is produced and sponsored by ATIXA, the beauty of 1P, 1P is that it is intended to address all civil-rights based violations (e.g.: sex, gender, race, disability, ethnicity, sexual orientation, religion etc.). “One Policy, One Process” does not simply refer to a single process for a single civil right for all constituencies, but a single process for all civil rights based issues for all constituencies.
Does the 1P1P Model replace the student conduct process?
No. Using the model can incorporate the existing student conduct process, supplant it just for Title IX complaints, supplant it for all discrimination complaints, or fully replace the conduct process for all complaints, if desired.
The student conduct process remains intact, though matters involving possible civil rights violations will be funneled through the 1P,1P process, rather than the traditional student conduct process. The nature of civil rights-based violations and allegations are, we believe, best handled using an investigative and resolution process created and upheld using a civil rights-based lens. The traditional student conduct process, as well as our faculty and employee processes are based on role-defined rights, yet the issues involved are not role-defined rights, but civil rights – they cross role-defined boundaries. These rights do not differ because someone is a student or an employee or a faculty member. This Model provides a unified policy that covers everyone equally with the same kind and degree of protection of their civil rights – gender-based rights, disability-based rights, race-based rights, etc.
Does the 1P, 1P Model do away with hearings?
It can, but is designed to allow hearings where due process rights prescribe them. Our Model provides three different means of resolving complaints – conflict resolution, resolution without a hearing and a formal hearing. Conflict resolution is available at the consent of both parties, though is not appropriate for all cases, while any matter can be resolved through either the resolution without a hearing or a formal hearing.
How does the 1P,1P Model address at-will employees with no hearing rights?
The Model allows human resources, the Title IX Coordinator or other appropriate administrators to implement the findings of an investigation without a hearing. Matters involving at-will employees with no hearing rights are investigated through the 1P, 1P process and the findings of the investigation are referred to the Director of Human Resources for implementation and resolution.
Can I get a copy of the 1P, 1P Model to preview before purchasing it?
Yes. ATIXA will provide a partial Model preview without a license. Contact ATIXA at 610-644-7858 or firstname.lastname@example.org for more information.
The Model is available from ATIXA for $2,500 per campus. This includes all three versions of the Model and licensure only. Once payment is received, the Model will be delivered to your campus electronically.
ATIXA Super and Full Members can access all three versions of the Model through the Member Title IX Resource Library. For information on how to join ATIXA and receive your Models, visit our page here.
For details on implementation assistance packages available from ATIXA, please click here. The Annual Implementation Assistance Package is designed to help and guide your campus through design, approval and implementation of the One Policy, One Process Model. Campuses may encounter obstacles and challenges when attempting to implement 1P,1P. ATIXA offers a number of support options for your campus.
For information on purchase, including payment by cheque, contact our team at email@example.com for payment and invoicing. Once payment is received, the Model will be delivered to your campus electronically.
For additional information, please contact our team at firstname.lastname@example.org or 610-644-7858.