Title IX Task Force Report

The Title IX Task Force was charged by former President Caslen to critically evaluate the institution’s effectiveness in addressing sexual harassment and violence (SHV) and to offer recommendations to enhance the institution’s effectiveness in addressing SHV.

Guided by principles of respect, accountability, and empowerment, the Task Force believes that as a flagship university, USC can improve processes to support the needs of both complainants and respondents. While the Task Force’s findings point to several such areas, it also acknowledges the investments the institution has made and the diligence of the many employees who strive to keep our community safe each day.

Findings

Overall Trends

The annual rate of reported cases of SHV was fairly stable, relative to the growth in the institution’s size. The rates are lower than estimated national rates of SHV. Most complaints concerned students against other students. Incidents involving faculty respondents and student complaints were relatively rare.

Training and Education

Training for stakeholders (students, faculty, staff, managers) and for implementers (staff providing SHV services) are all lacking in frequency and customized content. Of note is the need for specialized training for professionals directly involved in addressing SHV and managers of employees involved in cases of SHV.

Reporting

The current reporting system is difficult to navigate, and the process of reporting is an adverse and potentially re-traumatizing experience, creating significant barriers to reporting and pursuing a complaint.

Investigation

Few reported cases are formally investigated, with a large proportion of complainants opting out. Further, cases against faculty are less likely to result in a reasonable cause finding than those against student and staff.

Disciplining

There is no faculty-governed process for disciplinary action short of termination for faculty. Further, there is inconsistency in documentation and execution of discipline for faculty and staff. There is a lack of guidelines regarding handling conduct that falls short of policy violation but is nonetheless inappropriate.

Advocacy

There is a lack of continual review of risk to the complainant, which may undermine measures to protect against further harassment and retaliation. While support is offered to student respondents through the Respondent Resource Committee, in practice, few student respondents utilize these services.

Broader areas of concern

Staffing, job scope, reporting structures, and coordinating mechanisms require attention. There is a lack of centralized information management and public reporting. The culture of the institution and students does not reflect a shared commitment to addressing SHV.

Recommendations

The challenges faced by the institution are complex and systemic, and the Task Force’s recommendations reflect this complexity. The Task Force’s recommendations address three core principles. The first is respect: the process of addressing potential SHV violations must be conducted in a manner that respects the rights of both complainants and respondents and be conducted with interpersonal sensitivity. The second is accountability: all members of the university community need to recognize their shared accountability for stopping SHV. The third is empowerment: all members of the USC community should, through training, information sharing, and trust in the system, be empowered to respond effectively to SHV. Specifically we recommend:

Increase the frequency and tracking of training and education activities and expand offerings to targeted populations.
Improve both complainant and respondent experiences through the reporting and investigating process by reviewing all websites, forms and communications to be more user-friendly, interpersonally sensitive and non-threatening to both complainant and respondent.
Develop and maintain investigative protocols and rubrics for evaluations of cases. Document cases in a manner that is consistent with protocols and rubrics. Review cases to assure adherence to policy, protocols and rubrics.
Create a system to assure that the disciplinary actions are consistently delivered. Create guidelines for corrective action and monitoring of inappropriate behavior that falls short of policy violation. Develop procedures for consistent, thorough and centralized record keeping of disciplinary and corrective action. Revise the Faculty Manual and/or policy to address faculty misconduct and discipline.
Develop trauma-informed first responder protocols to ensure that no matter which reporting office receives the report, the complainant receives consistent information about support services and reporting options. Continually assess ongoing risk to complainants and revise supportive measures accordingly.
Evaluate the organization structure to maximize effectiveness with particular attention to deputy Title IX coordinator role, the coordination between academic units and the SHV offices, and the Office of Equal Opportunity Programs (EOP) line of reporting. Consolidate information management and annual reporting. Work toward a culture of collaboration, accountability and trust.

Next Steps

The work of the Task Force represents the first step in improving the university community’s response to SHV. Further work is needed to provide further clarity on some underlying problems, benchmark best practices, and implement changes. Accordingly, this report serves to guide the work of Cozen O’Connor, an external firm engaged by the University who will continue to work with members of the task force to further develop and implement these recommendations.

Interpersonal Violence