​In September of 2014, a good friend called to ask for my advice on a job offer. He had been chosen by a large university to assist them with meeting compliance under the VAWA (Violence Against Women Act). This was, in part, due to an alcohol and drug intervention program he had created years ago that was still having great results. The university hoped he would be able to create something similar for sexual assault on campus. We began to speak about the devastating impact of sexual assault on students, and it seemed to me like intervention was just too late, as the damage that sometimes could be prevented had already been done. I suggested that if he were to take this position, he should attempt to implement a program of prevention that protects all parties involved (potential victims/survivors, would-be perpetrators, and the colleges).

As we all know, once you set a goal, your Reticular Activating System begins its job. This is especially true when the goal is packed with extreme value, or extreme threat. Sexual assault at colleges has become a heavily-publicized issue in a very short period of time. Due to attention from TV news and magazines, and increasing social media scrutiny, the topic has become inescapable. The more I noticed this increasing awareness, the more I began to have conversations with my wife or close friends about the subject. We would share stories we heard during our time in college or high school that at the time we didn’t realize would be considered sexual assault. We discussed how the average 18-year-old struggles with the definition of consent, what their rights are if they’ve been assaulted, or even the different ways assault can happen.

This is why in January of 2015, I helped create “3E—Campus Safety.” Along with LaDonte King (Asst. Dir. for Government Affairs for Associated Students at University of California, Santa Barbara), we consulted multiple experts from colleges and universities about this important topic. The 3E program is focused on helping colleges nationwide Educate, Empower, and Enforce.

Fast forward to July 1, 2015

Institutions of higher education across the country are grappling with meeting significant requirements specified by VAWA. New reporting, policy and training requirements are mandatory and many colleges are still seeking compliance solutions past the July 1st deadline.

Colleges accepting Title IV funds are now obligated to inform students about campus violence and how to protect themselves: What is consent? Can it be given while impaired? What is the definition of rape? Does a bystander have an obligation? Colleges must educate their students about prevention, how to report an incident, and the school’s policy. Training must cover all the bases in-depth and in terms that students understand. VAWA requires colleges and universities to:

  • Report domestic violence, dating violence, and stalking 
  • Adopt student discipline procedures, such as notifying victims of their rights 
  • Adopt institutional policies to address and prevent campus sexual violence 
  • Offer primary prevention and awareness programs to promote understanding of rape, acquaintance rape, domestic violence, dating violence, sexual assault, and stalking; and which explain appropriate bystander interventions 
  • Communicate institutional policies and disciplinary action for dating violence, sexual assault, and stalking.

According to Dr. Shalamon Duke, Executive Director of the National Campus Violence Reduction Initiative and advisor to colleges across the country, institutions of higher education ignore these requirements at their peril. “The headlines and statistics about campus violence are compelling,” he says. “Colleges are now obligated to take prescribed steps to inform and educate their students. Procrastinating on this critical and high-profile issue is a disservice to students who need to understand prevention as well as policy.” Under Title IX, federally-funded schools are required to assure that students are not denied or limited in their ability to participate in the school’s educational programs or activities on the basis of gender. Under Title IX, a school violates a student’s rights regarding student-on-student sexual violence when the following conditions are met:

  1. the alleged conduct is sufficiently serious to limit or deny a student’s ability to participate in or benefit from the school’s educational program, i.e. creates a hostile environment; and 
  2. the school, upon notice, fails to take prompt and effective steps reasonably calculated to end the sexual violence, eliminate the hostile environment, prevent its recurrence, and, as appropriate, remedy its effects. (Title IX and Sexual Violence)

After attending a session on this topic at a conference for Career Colleges in May of 2015, it became clear that this sector was one of the last to be informed about the new requirements and regulations. After the session, one participant stated, “It seems like we are being set up for failure. Knowing how much scrutiny the industry has been under lately, we are now finding out about this days before it is to go into effect.”Upon leaving the conference, Dr. Joe Pace, Mike Seifert, and I had a lengthy conversation about the need to assist our partners by providing them with information and resources addressing this issue. Below you will find a few steps that are recommended by Dr. Duke and others in order to be proactive and gain compliance.

First, Dr. Duke recommends reviewing training programs against VAWA and Title IX requirements. “A number of products are now on the market and few cover all the bases, especially when it comes to student education.” Then follow these steps

  • Put a competent Title IX coordinator in place 
  • Develop your Title IX policy 
  • Post your Title IX policy on your website along with the coordinator’s information 
  • Train staff on sexual assault, VAWA, and Title IX procedures
  • Find a good student prevention program to inform students on the laws, your policies, their rights, etc.

This is where the 3E- Campus Safety program comes in.  Where most programs on the market are either one dimensional (meaning they only focus on bystander intervention or one form of assault) 3E is comprehensive and provides information on topics that students need to understand from consent, harassment, stalking, bystander intervention, how to report acts of violence, and much more.  Jules Irvin-Rooney, an attorney and national consultant on the Clery Acty, stated that “it is the schools duty to educate students on more than just bystander intervention and the Office of Civil Rights will be looking to see what effort campuses have made to educate faculty, staff and students to prevent Sexual Assault.“Another attribute that helps 3E stand out from the rest is that it is fully dynamic and customizable.  The majority of programs on the market are static meaning every college get the same exact program. 3E actually keeps the core information (definitions, laws, etc.) the same but allows each institution the ability to customize points (logo, college policies, contact information, etc.).  This is also very important because most programs on the market are focused on the 2 or 4 year campus model. 3E and its customization allows Career Colleges to deliver a program and experience that is unique and relevant to their students.

We know this is all very new for many of our schools and we are here to assist.  On Friday, September 25, 2015 we will be holding a webinar to discuss in more depth and to provide a demo of the 3E Campus Safety program to assist our schools with Educating, Empowering, and Enforcing this critical information.



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