USC is committed to fostering a respectful university culture where all community members can thrive in a safe learning, working, and living environment. The university is engaged in multi-disciplinary and university-wide efforts to transform its Human Resources, compliance, Title IX, Clery Act, and youth protection programs, incorporate lessons learned, and drive change through its commitment to care, compliance, and culture. These efforts prioritize our Unifying Values.
The OCR 2020 Findings and Resolution Agreement webpage also includes information about the February 2020 Resolution Agreement with the U.S. Department of Education’s Office for Civil Rights (OCR). Below is a comprehensive summary of the university’s efforts.
OCR Resolution Agreement Response and Deliverables
Centralized Reporting Directive
On November 11, 2021, Felicia Washington, Senior Vice President of Human Resources, Equity, and Compliance (“SVP Washington”), issued a memo to all university employees (faculty, staff, and student workers) reminding them of their employee reporting obligations under Title IX and the Clery Act and supplying information needed to help employees connect students to resources and provide support. Additionally, the university updated the Equity, Equal Opportunity, and Title IX (EEO-TIX) webpage to include new content on Faculty and Staff Reporting Responsibilities.
On January 18, 2022, SVP Washington issued a Centralized Reporting Directive in alignment with the OCR Resolution Agreement. In her university-wide message, she reminded university employees of their obligation to immediately forward to EEO-TIX any reports, disclosures, or other known information about sexual or gender-based harassment and violence of which they are aware and provided additional information about how to make a report to EEO-TIX. The community message also provided an update on other initiatives, such as the posting of the Notice of Non-Discrimination, updates to the Policy on Prohibited Discrimination, Harassment, and Retaliation, and the upcoming Supervisor File Review. She closed by thanking students, staff, and faculty for doing their part to “ensure centralized reporting, which is the foundation of an inclusive and diverse University community where discrimination, harassment, and retaliation are not condoned, tolerated, or enabled.”
Supervisor File Review
In accordance with the OCR Resolution Agreement, all university employees designated as supervisors were to be required to review their records and personnel files for current employees under their supervision to identify any past complaints or reports of sex discrimination received since January 1, 2016 and that were not previously reported to the centralized reporting offices. For the purpose of this effort, supervisors were defined as any staff member who had an individual reporting directly to them in Workday or had supervisory responsibilities and any faculty member, including adjuncts, as they may manage Research Assistants (RAs), Teaching Assistants (TAs), students in laboratories, or have other supervisory duties. To ensure that all supervisors were identified and included in the review, the University completed a short survey of all other employees to identify any individuals with supervisory responsibilities who might not be captured as such in Workday.
On February 28, 2022, the SVP HREC and Provost launched the Supervisor File Review through a communication sent to all identified supervisors. Supervisors were instructed to complete this review, report any previously unreported complaints or reports to the EEO-TIX Office, and confirm completion of the file review process by completing an Attestation Form by April 4, 2022.
To support them in this task and facilitate uniform and consistent compliance with the Supervisor File Review, the university created a dedicated website to provide additional tools and detailed instructions, including FAQs and a dedicated email address for questions, which resulted in more than 1100 email inquiries fielded by the project team.
EEO-TIX conducted a full review of each of the 160 reports that were submitted during the Supervisor File Review and resolved each matter. The majority of the reports were incidents that had previously been reported and were forwarded by supervisors in an abundance of caution.
Our Commitment to Care
Employee Relations Advisory and Consultative Group
In November 2021, the Employee Relations Advisory and Consultative Group (ER Advisory Group) was convened at the invitation of SVP Washington and then Provost Charles F. Zukoski to provide valuable insight and input for the university’s efforts to improve our systems, processes, and culture; provide better care for our people; promote accountability in keeping with our Unifying Values; and create an employee relations function within University HR to be proactive in addressing workplace misconduct, interpersonal conflict, and other conduct of concern for all faculty and staff.
Building on the work of prior committees, the ER Advisory Group reviewed current processes and procedures, drafted guiding principles, and made specific recommendations to build a robust Employee Relations unit and provide widespread awareness, confidence, and trust in the processes.
With the hiring of an Executive Director of Employee and Labor Relations (ELR) in June 2022, implementation of the recommendations of the ER Advisory Group is well underway and includes: onboarding the needed ELR staff , creating internal protocols, collaborating with partner investigatory and compliance offices to coordinate the response to workplace concerns, reviewing and revising staff policies for equity and clarity, and creating communication pathways with complainants and respondents, as well as the broader community.
Implementation of Enterprise-wide Data Management System
In March 2021, the university began to use Meyestro™, a critical incident response management system that integrates regulatory frameworks, effective industry practices, and institutional policies and procedures in a cloud-based platform that enables centralized and pan-institutional incident tracking, response coordination, management, monitoring, and data collection and analysis. This interactive, multi-user platform allows the university to respond efficiently and collaboratively to concerns and manage the case workflows of various responding units. Customized for USC, Meyestro embeds legal and compliance principles and operationalizes the university’s own policies and procedures to support institutional goals and values.
The Meyestro platform was first developed for EEO-TIX to record and track information related to reports of sexual and gender-based harassment and violence and other forms of discrimination and harassment based on protected characteristics and related retaliation. In February 2022, to further our commitment to enhancing our coordinated responses to reports of all concerns from our community, the university expanded the use of the enterprise data management system to onboard other units that investigate and manage complaints and reports of misconduct, including Human Resources, Faculty Affairs, Culture, Ethics, and Compliance, Threat Assessment, and other offices providing supportive services.
The system allows for real-time reporting, enhanced information-sharing across units, integration of compliance and policy requirements, and timely coordinated and consistent provision of care, resources, support, and processes. It is also designed to integrate and track all applicable procedures and legal requirements, track trends (incident types, locations, individuals), and internal and external reporting.
Report & Response Website Integration
As part of USC’s commitment to create an environment where our community feels safe, heard, and protected, the university has launched the USC Report & Response website – the single destination for reporting needs. USC community members can report concerns – as a Trojan, a guest, a Designated Employee, or anonymously – about an incident they have observed, experienced, or that a USC community member has shared with them that may violate university policies or run counter to USC’s Unifying Values.
Launched in July 2023, USC Report & Response replaced the former Help & Hotline reporting site, creating one user-friendly location for reporting, accessinginformation about available confidential and private supportive resources, and learning what to expect after making a report.
The Report & Response portal is integrated directly with the university’s enterprise data management system, further enabling a centralized response system that includes uniform intake of all incidents, prompt review of each report, and timely coordination of response, safety assessments, and support by all relevant constituencies.
EEO-TIX Ongoing Efforts 2021-Present
NASEM Action Collaborative Working Group
As a founding member of the National Academy of Sciences, Engineering, and Medicine’s (NASEM) Action Collaborative (“Action Collaborative”) that was established in 2018, the university in 2021 established its own Working Group co-chaired by the Vice President of EEO-TIX and the Director of the USC Center for Gender Equity in Medicine and Science (GEMS). The Working Group is made up of faculty and staff and has a primary goal to go beyond legal compliance to ensure culture change that will reduce sexual and gender-based harassment in higher education.
As an active member of the Action Collaborative, the USC Working Group has shared with them information about key university initiatives, including GEMS, the Wellbeing Collective, and LGBTQ+ violence prevention and intervention services provided through Relationship and Sexual Violience Prevention and Services (RSVP). In addition, Working Group members assist with authoring research-based perspective papers for the Action Collaborative, including one titled, “Guidance on Guidance for Conducting Campus Climate Surveys and Measuring Sexual Harassment Prevalence.”
Campus Coordinated Response Team
EEO-TIX and Student Health co-sponsor USC’s Campus Coordinated Response Team (CCRT). The CCRT, formed in early 2020 at the recommendation of the AAU Survey Task Force report, is comprised of campus (including faculty, staff, and students) and local community partners who have expertise in providing services to the LGBTQ+ community. A key accomplishment of the CCRT was publishing Creating an LGBTQ+ Inclusive Campus: A Guidebook prepared by the Campus Coordinated Response Team on Trauma-Informed, Culturally Sensitive and Inclusive Teaching for LGBTQ+ Students at USC in early 2022. The CCRT meets regularly to identify policies, practices, procedures, services, and resources that need to be created or enhanced to ensure an inclusive and welcoming environment for LGBTQ+ USC community members and visitors.
Gender Identity and Sexual Orientation Systemic Barriers Working Group
In June 2022, EEO-TIX created the Gender Identity and Sexual Orientation Systemic Barriers (GISOSB) working group, which it co-chairs with the Director of Student Equity and Inclusion Intercultural Services, including the LGBTQ+ Student Center. In alignment with USC’s Unifying Values, GISOSB’s mission is to bring together key stakeholders from across the USC community to identify and remove systemic barriers that hinder: (1) full participation in the academic, co-curricular, employment, and healthcare programs and activities of the university; (2) access to university resources, activities, facilities, and services; and (3) access to clear and direct information about navigating university systems as they relate to gender identity and sexual orientation. GISOSB also seeks to develop new and/or modify existing policies, procedures, and practices as part of its efforts to identify and remove systemic barriers to community access to and participation in the university’s facilities, programs, and services relating to gender identity and sexual orientation. While these barriers may similarly impact USC students, staff, faculty, patients, and other visitors, the GISOSB recognizes individual systems impacting each constituency may differ. Additionally, the GISOSB recognizes that individuals have multiple identities, and it is committed to adopting an intersectional approach when advocating for systemic changes related to gender identity and sexual orientation. Since its inception, the GISOSB has been instrumental in enhancing housing, enrollment, and registration systems to make them more welcoming of our many students, faculty, and staff who identify as transgender or nonbinary.
Title IX Hearing Model
In 2021, to enhance the Title IX hearing model, EEO-TIX hired a full-time Hearing Manager, with responsibilities for managing the logistics leading up to and through a hearing (including scheduling and providing administrative and technology support during the hearing for the external); serving as the primary point of contact for the hearing and providing support for the parties, Hearing Advisors, and witnesses; and assisting parties with connecting with their EEO-TIX Care Manager for support and accommodations, as needed, throughout the hearing process.
If a party does not have a Hearing Advisor, the Hearing Manager will appoint a trained external Hearing Advisor for the party, at no cost. The university-appointed Hearing Advisor’s role is to assist the party with preparation for the hearing (up to a maximum of 10 hours) and to attend the full duration of the hearing with their advisee to support them and ask questions on their behalf.
Live hearings are conducted using Zoom video-technology to allow both parties to see and hear one another and the witnesses, while also providing a trauma-informed, professional setting. The Hearing Manager model employed by EEO-TIX is a leading model in the field and routinely receives great appreciation from parties and witnesses who participate in the hearing process.
EEO-TIX Website Enhancements
EEO-TIX hired a full-time dedicated Communications and Marketing Director who, among other responsibilities, manages the EEO-TIX website. Since 2021, upgrades to the website have included: creating a web page for the NASEM Action Collaborative working group; posting of a Frequently Asked Questions document on Student Supportive Measures; creating a web page for EEO-TIX’s dedicated healthcare team and also for its equity team, the latter of which manages the university’s affirmative action program and other equity services; adding an online feedback form so that community members may provide feedback on EEO-TIX’s services at any time; and adding an announcements section on the home page to raise awareness of civil rights and equity-related news.
Intake, Outreach, and Support Team
In 2021, as part of EEO-TIX’s commitment to enhancing the experiences of our university community, created a dedicated Intake, Outreach, and Support team for the University Park Campus (UPC) community, as well as for the Health Sciences Campus (HSC) community. Members comprising this team include the Deputy EEO-TIX Coordinator for Healthcare, as well as two full-time Deputy Coordinators for Intake, Outreach, and Support. These coordinators serve as the “front door” of EEO-TIX, responding to all reported concerns received by EEO-TIX and meeting with community members to discuss support resources available to them, regardless of whether they choose to file a Formal Complaint, as well as providing information about reporting and resolution options so that parties can make informed choices. In addition, EEO-TIX has hired a total of four Intake, Outreach, and Care Managers. The primary responsibility of the EEO-TIX Care Managers is to provide assistance in connecting community members to reasonably available supportive measures, such as academic or workplace accommodations, connection to counseling, and mutual avoidance of contact directives. In any Formal Resolution, each party will be assigned an EEO-TIX Care Manager to check in with them periodically to ensure they are receiving the support they need throughout the EEO-TIX process. The EEO-TIX Intake, Outreach, and Support team members regularly coordinate with key campus partners to support students, faculty, and staff working with EEO-TIX, including Student Affairs, Human Resources, Academic Advisors, Athletics, Counseling Services, Housing, Department of Public Safety, Registrar, and faculty.
Ongoing Prevention and Education
USC is committed to providing prevention and education programming and training to every student, staff, and faculty member. The comprehensive offering includes required annual training for undergraduate and graduate students, and required biennial training for all faculty, staff, and student workers.
Student Health Initiatives
Expanded and Elevated Role of Dr. Sarah Van Orman
In August 2023, USC announced that Dr. Sarah Van Orman, Chief Health Officer for USC Student Health, would assume an expanded and elevated campus role as a University Vice President and the Chief Campus Health Officer. In this role, Dr. Van Orman will seek to embed health and wellness into all aspects of campus culture and facilitate the goal of establishing USC as a health-promoting university. She has supported the development of new, comprehensive programs to address campus sexual assault and gender-based violence, student well-being, trauma-informed care delivery, and mental health.
Building a Culture of Consent
Building a culture of consent is a fundamental step in eliminating sexual assault, sexual misconduct, and gender-based harm in our campus communities. The USC Task Force on the 2019 AAU Survey on Campus Climate on Sexual Assault and Sexual Misconduct found “transforming an institutional campus culture that celebrates integrity, respect, trust, and achievement will take our collective resolve to fully realize.” Annually, a community message from Vice President for Student Life, Vice President for EEO-TIX, and Vice President and Chief Campus Health Officer is sent to all students at the beginning of the school year, listing campus and community resources and information about university policies.
The message establishes the expectation that every student understands that clearly obtaining consent in relationships and intimate encounters is the norm and reflects our Unifying Values. It also provides information about the required Sexual Assault Prevention training for all students and Consent and Healthy Relationships training for undergraduate students.
Additionally, the message offers information about available resources, including Relationship and Sexual Violience Prevention and Services (RSVP), EEO-TIX, and how to report a concern via the Report and Response website, and is accompanied by a publication called “Culture of Consent: What are USC programs doing to prevent campus sexual assault?”
To emphasize the commitment to fostering a safe environment free from sexual harassment and assault, the university now enforces completion of the Sexual Assault Prevention Programs through mandatory registration holds for all three undergraduate years.
RSVP Enhancements and Updates
RSVP is a Counseling and Mental Health Services unit within USC Student Health, Keck Medicine of USC. RSVP provides an advocate team for 24/7 response in situations of gender- and power-based harm, including sexual assault, domestic violenc, and stalking. All mental health providers are clinical faculty in the Department of Psychiatry and the Behavioral Sciences of the Keck School of Medicine.
RSVP has undergone changes in staffing and enhanced services. In January 2023, Deborah Schleicher, PsD was promoted to Director of Violence Prevention in RSVP. She is also Clinical Assistant Professor of the Department of Psychiatry and Behavioral Sciences at Keck School of Medicine. Dr. Schleicher has deep experience in trauma-informed prevention and education of campus sexual violence. She previously worked at the UCLA Rape Treatment Center and was USC’s Campus and Community Outreach Coordinator facilitating educational presentations related to gender and power-based harm for college campuses throughout Los Angeles.
Additional positions have been added to the RSVP team, including Associate Director and USC’s first Male Engagement Coordinator, who is tasked with developing and delivering culturally specific prevention strategies and approaches that engage, educate, and motivate individuals of the USC community who identify as male and masculine in the eradication of gender-based violence. Furthermore, RSVP has bolstered direct services to survivors, such as the expansion of the Student Health unit that supports survivors and the 24/7 operation of Confidential Advocates who can be accessed at any time by calling Student Health at (213) 740-WELL.
The RSVP website has undergone an update, moving to a new platform that is integrated into the Counseling and Mental Health website. The updated website streamlines services specifically available for survivors of sexual assault by directly linking to confidential counseling services, reporting options, and other resources. The site includes relevant announcements, webinar recordings, and information about urgent matters when necessary.
Changing culture, however, takes more than increased staffing, new educational prevention education modules, or a higher level of policy enforcements. Creating a culture of consent and healthy relationships requires the whole community to understand the severity of the problem and then collectively work toward positive change at both the individual and systems level.
Sexual Assault Prevention and Community Equity (SPACE)
In spring 2022, partners in the USC Wellbeing Collective began to examine the physical environment (or sexual geographies) that USC students inhabit, using the groundbreaking research of Jennifer S. Hirsch and Shamus Khan, “Sexual Citizens.” This research produced a toolkit to help campuses reshape their built environment: the Sexual assault Prevention And Community Equity (SPACE) toolkit. The initiative, led by the Wellbeing Collective, involved multiple partners, including Housing, Residential Education, Student Life, and Student Health, the Provost’s Office, Real Estate and Asset Management Administrative Operations, USC students, and other stakeholders. The partners in this group applied the principles in the toolkit in a series of explorations and focus groups. The work revealed the challenges in the built environment that “tilt” intimate encounters into situations where one person is disempowered to control the encounter. The result is the re-imagined Traditions space, in the center of campus, which is piloting a weekend late night space for students to gather and socialize, with other locations under consideration.
Sex Week at USC
Sex Week, held every October, is a series of inclusive, informative, and illuminating events supported by USC Student Health, in partnership with student groups. The week-long program provides a sex-positive, fun, and educational experience where USC students can engage, and together, Let’s Talk About Sex!
Highlights from Sex Week 2023 included a film screening, the Sexploration Tent, which provided an inclusive and interactive sex-positive hangout space, and Sex in the Dark, a panel discussion featuring experts who answer anonymous questions about intimacy and sex.
The information below provides a chronological summary of the efforts to enhance university responses to transform campus culture, build trust, and live our unifying values from 2018-2021 and is maintained for reference.
2020-2021 Academic Year
During the 2020-2021 academic year, the university launched the Office for Equity, Equal Opportunity, and Title IX (EEO-TIX), a centralized report and response office that provides consistent and equitable access to supportive measures and informal and formal resolution options, and implemented a university-wide Policy on Prohibited Discrimination, Harassment, and Retaliation that applies to all students, staff, and faculty. Key accomplishments during the course of this academic year included hiring a first-ever Vice President for Equity, Equal Opportunity, and Title IX, who also served as the university’s Title IX Coordinator, and an inaugural Deputy EEO-Title IX Coordinator for Health Care; expanding staff and resources within the EEO-TIX Office; strengthening internal protocols and improving document management systems within the EEO-TIX Office; and training Title IX investigators, decision-makers, appellate authorities, and implementers on the final Title IX regulations, released by the Office for Civil Rights in May 2020. These changes were implemented to comply with the February 2020 OCR Resolution Agreement and the final Title IX regulations, as well as to incorporate effective and promising practices nationally.
The university has also invested in expanding its Clery Act Compliance Program and enhancing coordinated Title IX and Clery Act responses to reports of sexual assault, dating violence, domestic violence, and stalking.
More detailed information on these efforts is below.
Deputy EEO-Title IX Coordinator for Health Care & Health Care Title IX Investigators
In November 2020, the university welcomed Nicoli Richardson as the inaugural Deputy EEO-TIX Coordinator for Healthcare. This role satisfies an important element of the Resolution Agreement and reflects the university’s continued commitment to integration and coordination of Title IX responsibilities between Keck Medicine and the university. This role reports directly to the Vice President for Equity, Equal Opportunity, and Title IX.
The university designated a Senior Investigator to serve as the Health Care Title IX Investigator. The Health Care Title IX investigator reports to the Deputy EEO-TIX Coordinator-Healthcare and focuses on reports of discrimination, harassment, and retaliation based on sex and other protected characteristics in the Keck Medical Enterprise involving employees, students, and patients and other third parties.
Office for Equity, Equal Opportunity, and Title IX
On Aug. 14, 2020, in conjunction with the implementation of the Policy on Prohibited Discrimination, Harassment, and Retaliation (the Policy), the university officially announced the opening of the Office for Equity, Equal Opportunity, and Title IX (EEO-TIX Office). The EEO-TIX Office combines the prior functions and staff of the Office of Equity and Diversity and the Title IX Office to provide a centralized resource for all students, staff, and faculty regarding reports of discrimination, harassment, and retaliation under the Policy. The centralization of supportive, prevention, investigative, and resolution processes within the EEO-TIX Office ensures a coordinated and consistent approach across all campus constituents, as well as helps the university consistently track patterns or trends; provide equitable access to reasonably available supportive measures; ensure that fair, impartial, and timely grievance processes are followed; and take prompt, equitable, and responsive action to remedy concerns. The EEO-TIX Office is overseen by the Vice President for Equity, Equal Opportunity, and Title IX.
Vice President for Equity, Equal Opportunity, and Title IX (and Title IX Coordinator)
In the summer of 2020, the university hired Catherine Spear, an experienced leader in the civil rights in education field as its inaugural Vice President for Equity, Equal Opportunity and Title IX (EEO-TIX) to coordinate the university’s compliance with federal and state civil rights laws and lead the university’s efforts to foster a community free from discrimination, harassment, and retaliation. The VP EEO-TIX is responsible for ensuring the university’s monitoring of and compliance with laws, policies, and procedures relating to discrimination based on age, race, color, sex, national origin, religion, disability, protected veteran status, and other protected classifications under Title VI and Title VII of the Civil Rights Act of 1964, Title IX of the Education Amendments of 1972, the Violence Against Women Act (VAWA), the Age Discrimination Act of 1975, and other federal and state laws and regulations pertaining to equal rights and nondiscrimination laws.
The VP EEO-TIX spent almost two decades in key leadership positions at the U.S. Department of Education, as well as seven years managing Title IX and other civil rights programs within institutions of higher education. The VP EEO-TIX reports directly to the Senior Vice President for Human Resources, Equity, and Compliance, with a dotted line reporting relationship to President Carol L. Folt.
In January 2021, the university created two new Deputy Coordinator for Investigation and Resolution positions to assist in directing the operations of EEO-TIX, with regard to formal and alternative resolutions and managing timely, high-quality, fair, and thorough investigations. Together, they supervise and ensure attention to the professional development of a team of EEO-TIX investigators, ensure legally compliant investigative practices and protocols, assist with the training of internal and external investigators, and provide training and education programs about EEO-TIX resolution processes to university community members.
In its first year of growth, in addition to the VP EEO-TIX, EEO-TIX added the following new roles: Deputy EEO-TIX Coordinator — Healthcare; two Senior Investigators —Healthcare; Associate Vice President for EEO-TIX and Deputy Title IX Coordinator; Communications and Marketing Director; Senior Investigators (for the Academic side); Training, Education, and Prevention Coordinator; Hearing Manager; Executive Assistant to the VP EEO-TIX/Office Manager; Equity and Inclusion Specialist/Senior Database Analyst; two Deputy Coordinators — Intake, Outreach, and Support; two Deputy Coordinators — Investigation and Resolution; and two Intake, Outreach, and Care Managers.
University-wide Policy on Prohibited Discrimination, Harassment, and Retaliation
On August 14, 2020, in compliance with the final Title IX regulations issued in May 2020, the university implemented a new university-wide Policy on Prohibited Discrimination, Harassment, and Retaliation (Policy) and two accompanying Resolution Processes. The Policy coordinates and replaces USC’s existing student, faculty, and staff policies to streamline access to reporting options, resources, and procedural options. The Policy incorporates a university-wide approach to preventing and responding to discrimination and harassment on the basis of protected characteristics, retaliation, and specific forms of harassment based on sex: sexual assault, dating violence, domestic violence, stalking, and related forms of conduct. It applies to all university community members – students, faculty, staff, and third parties. Under the Policy, designated university employees continue to have reporting responsibilities to ensure prompt and consistent access to resources and information for all community members.
The Policy includes a robust intake and outreach process. Any person who seeks support or assistance under the Policy will be provided with a written and clear articulation of resources, supportive measures, options, and processes. The Policy is accompanied by two sets of Resolution Processes: one applies to all forms of sexual harassment, sexual assault, dating violence, domestic violence, stalking, and retaliation, and another that applies to all other forms of prohibited discrimination and harassment based on protected characteristics and related retaliation. Both sets of resolution processes follow a parallel process for intake and outreach, initial assessment, the provision of supportive measures, investigations, and informal resolution. The formal resolution processes include: notice and a meaningful opportunity to respond; equitable opportunities for the parties to participate; trained and experienced investigators and decision-makers free from conflict of interest and bias; the right to an advisor of choice throughout the process; use of the preponderance of evidence standard; and reasonable time frames for the investigation, resolution, and appeal. Under both resolution processes, the investigation procedures are robust, including an opportunity to present witnesses and information, review all of the evidence at the end of the investigation, submit written comments, review a written investigation report, and submit written comments.
As required by Title IX regulations, the resolution process for sexual misconduct includes a live hearing (which may be virtual) in front of a neutral and impartial decision-maker, where the party’s advisors have the right to pose relevant questions to the other party or witnesses. The decision-maker cannot consider any statements that are not subject to this questioning (cross-examination). The university will provide an advisor for any individual who does not have an advisor at the hearing. The procedures for other forms of discrimination and harassment provide all of the same procedural safeguards through the investigation as the sexual misconduct process; the only distinction is that the investigator, in consultation with the Vice President for Equity, Equal Opportunity, and Title IX (EEO-TIX), makes the determination of responsibility; no live hearing is required.
The Policy was developed through an inclusive process that involved consultation with university administrators and staff in the former Office for Equity and Diversity (OED) and Title IX Office, the incoming VP for EEO-TIX, external subject matter experts, and a newly-created internal committee — the Policy and Community Advisory Committee (PCAC) (see below). The Policy was disseminated to faculty, staff, and students on Aug. 14, 2020.
Enhanced Communications Regarding the EEO-TIX Office and Policy
The opening of the EEO-TIX Office was accompanied by a newly developed website that provides an overview of the office, information about the VP EEO-TIX, information about how to report discrimination and harassment, a link to the Policy and the university’s Notice of Non-discrimination, a set of Frequently Asked Questions, and a robust list of campus and community resources. It also includes a link to training materials for USC employees involved in the reporting and resolution processes as required under the Title IX regulations. Additionally, the website has an online feedback form for community input on the new policy and process, as well as related concerns.
In addition, the website includes a flow chart explaining reporting options:
And an infographic regarding key Policy provisions:
Policy and Community Advisory Committee (PCAC)
In the summer of 2020, following the May 2020 release of the final Title IX regulations, the university convened a Policy and Community Advisory Committee (PCAC) to assist the university in ensuring that it carefully considered the interests, perspectives, and impacts that changes in policies, procedures, practices, and systems might have on its many diverse schools and units. The PCAC, comprising faculty, staff, and students, serves as an important voice in the university’s efforts to improve systems, processes, and culture, better care for its people, and promote accountability and responsibility in keeping with its institutional values. The PCAC includes the presidents of the Academic Senate and Staff Assembly, representatives from Graduate and Undergraduate Student Government, and faculty and staff at schools and departments across the university. While the charge of the PCAC encompasses all issues related to people, culture, and accountability, one of the first issues PCAC considered was the development of a revised Title IX policy that incorporates the required policy actions under the OCR Resolution Agreement and the final Title IX regulations. PCAC has been meeting since June 2020 to engage in dialogue about Title IX and the impacts of the final Title IX regulations for university stakeholders and constituents. PCAC is an ongoing committee that will continue to provide a forum for community dialogue and engagement.
2019-2020 Academic Year
Spring 2020: Student Well-being Index Survey
In spring 2020, USC Student Health developed a Student Well-being Index Survey (SWIS) to be used as an annual tool to track the population health of USC students in targeted areas of inquiry. The findings from SWIS are used to measure USC’s progress toward strengthening a culture driven by student well-being and to support planning, implementation, and evaluation of USC Well-being Collective efforts. The Wellbeing Collective seeks to enhance the culture of equity and inclusion, cultivate a culture where individuals and communities thrive, disrupt the culture of at-risk substance use, and foster a culture of consent and healthy relationships. Over 20 cross-campus departments, units, and recognized student organizations at USC have committed to work collaboratively with the Wellbeing Collective in support of these goals.30,312 USC students were invited to participate in the SWIS from April 9 to May 8, 2020. Participants were chosen by a random sampling (or census sample) to include undergraduate and graduate/professional students at the university Park Campus, undergraduate and graduate/professional students at the Health Sciences Campus, and graduate/professional online students. Approximately 6,831 students submitted the survey (22.5% response rates) as of May 8, 2020. Gender-based violence measures were included in the bystander behavior and sexual violence sections of the Student Well-being Key Performance Indicators Module and the Hazing Module. The Student Well-being Key Performance Indicators were developed by the Wellbeing Collective in partnership with USC Student Affairs, USC Student Health and other campus partners.
Resolution of Directed Investigation by the U.S. Department of Education, Office for Civil Rights
In February 2020, the university entered into a Resolution Agreement with the U.S. Department of Education, Office for Civil Rights (OCR) that focuses on centralizing the university’s response to sexual and gender-based discrimination and harassment, improving record keeping and data management systems, and expanding training and education. Additional information about the resolution of the OCR investigation is available on the OCR 2020 webpage.
Campus Coordinated Response Team (CCRT)
In February 2020, USC Student Health, Relationship and Sexual Violence Prevention and Services (RSVP) formed the USC Campus Coordinated Response Team (CCRT) to oversee the development and implementation of policies, prevention initiatives/efforts, and responses to address sexual and gender-based harassment and violence, with a tailored and particular focus on the LGBTQ+ student cohort. The CCRT includes approximately 30 members from campus partners, including Residential Education, Disability Services, Public Safety, USC Student Health, Student Activities, Undergraduate and Graduate Student Government, Threat Response, Crisis Intervention, Office of International Students, LGBT Resource Center, EEO-TIX, and Student Life.
The initial goals for the CCRT included:
- Developing, implementing, reviewing, and revising programs and procedures to effectively respond to gender-based harassment and discrimination, including sexual assault, domestic/intimate partner violence, dating violence, and stalking;
- Promoting prevention and intervention efforts that are appropriate, research-informed, culturally relevant, and inclusive of historically marginalized or underserved groups;
- Assessing USC’s campus climate regarding gender-based harassment, discrimination, and violence;
- Evaluating current strategies and programs aimed at preventing and responding gender-based harassment, discrimination, and violence; and
- Developing and overseeing a communications strategy to engage USC students, faculty, and staff in prevention and response efforts.
Expanded Resources for Support
In January 2020, the university announced the creation of a sexual assault survivor Advocates Program, providing 24/7 on-call assistance to survivors. The university created five new USC Student Health Advocates dedicated solely to helping survivors at USC. The Advocates Program expanded the scope of services provided by RSVP, providing after-hours accompaniment to a forensic examination and free transportation.
LGBTQ+ Violence Prevention and Intervention Services
In early 2020, the university received a California Office of Emergency Services (CalOES) grant to hire a full-time advocate to provide trauma-informed and culturally sensitive supportive services for LGBTQ+ students. The full-time advocate works closely with RSVP’s violence prevention specialist to develop prevention and outreach approaches and materials, with a goal to train the whole Public Safety force in culturally-appropriate and trauma-informed practices when responding to students who have been impacted by sexual and relationship violence. The grant supports the further development of the CCRT with a focus on the LGBTQ+ student cohort and assists the university in developing more specialized approaches for other student cohorts that have high rates of sexual victimization. The CalOES grant also allowed the university to designate a half-time safety officer trained in trauma-informed approaches to implement ongoing training and consultation to other campus safety officers who may work with LGBTQ+ students. All intervention and prevention activities for this grant are guided by the CCRT, comprised of campus and local community partners who have expertise in providing services to the LGBTQ+ community.
NASEM Retreat: A Conversation about Sexual Harassment: Prevention, Response, Remediation, and Evaluation
On Jan. 17, 2020, the university hosted a retreat, entitled A Conversation about Sexual Harassment: Prevention, Response, Remediation, and Evaluation. The retreat was part of the university’s efforts as a founding member of the National Academies of Sciences, Engineering, and Medicine’s (NASEM) Action Collaborative on Preventing Sexual Harassment in Higher Education (see below). The retreat was designed to inform a larger audience of the 2018 NASEM report, titled Sexual Harassment of Women: Climate, Culture, and Consequences in Academic Sciences, Engineering, and Medicine, and the university’s involvement as a founding member of the Action Collaborative, which is to share innovative ways schools are already engaging in addressing and preventing sexual harassment; to brainstorm around the themes of the four NASEM Action Collaborative working groups; to clarify the roles of central offices and resources; and to map the next steps as a university, including possible development of an organizational structure specifically directed toward Gender Equity and related issues. The retreat included student, faculty, and staff representatives from each school; deans; and key organizational units involved in addressing and preventing sexual harassment on campus.
New Senior Leadership in Key Areas
In the summer of 2019, USC inaugurated Dr. Carol L. Folt as its new president and welcomed Charles Zukowski as university Provost, Winston Crisp as Vice President for Student Affairs, and Felicia A. Washington as Senior Vice President of Human Resources, Equity, and Compliance. Under President Folt’s leadership, this initial leadership team was strongly focused on fostering a culture of accountability and responsibility, remedying harmful impacts of George Tyndall’s actions, and working to prevent similar conduct from occurring again.
As of January 1, 2020, SVP Washington oversaw the university offices responsible for professionalism, ethics, compliance, and investigations, including the EEO-TIX office, which as noted above is responsible for preventing and responding to discrimination and harassment on the basis of protected characteristics. The newly created Human Resources, Equity and Compliance (HREC) website highlighted the SVP HREC expanded leadership role, which is to support people, create accountability, and advance USC’s mission. The website acts as a “front door” to the broader scope of offices, initiatives, and collaborations led by the SVP of HREC.
2018-2019 Academic Year
AAU Campus Climate Survey
In the spring of 2019, the university participated in the AAU Campus Climate Survey on Sexual Assault and Misconduct. The survey was designed to capture data on the incidence and prevalence of sexual harassment and gender-based violence on USC campuses, as well as assess students’ perceptions related to campus resources and bystander and reporting behaviors. The study also provided data for the USC community to make informed decisions on resource allocation to plan and implement appropriate comprehensive prevention efforts and programs. The university previously participated in the AAU Survey in 2015; a comparison of the 2015 and 2019 data allowed the university to measure progress in reducing incidents of sexual assault and misconduct.
Between April 2 and May 5, 2019, all USC students were invited to complete the survey. A total of 8,381 undergraduate, graduate, and professional students responded to the survey – a total survey response rate of 17.9%. Overall, 15.8% of undergraduate students and 19.5% of graduate and professional students responded to the survey.
In July 2019, the University created a Sexual Assault Climate Survey Task Force (AAU Survey Task Force) to review the AAU Survey findings; review its validity and reliability; develop specific recommendations for campus policy, practices, and services based on findings; develop a comprehensive communications plan for sharing the survey results; and make recommendations for future program evaluation and research. As part of its charge, the AAU Survey Task Force reviewed the recommendations from the Joint Task Force Final Report and consolidated select recommendations to supplement recommendations by the AAU Survey Task Force. The AAU Survey Task Force was led by Co-Chairs then Vice President of Student Affairs and Chief Health Officer and Associate Vice Provost for USC Student Health. AAU Survey Task Force members included key stakeholders from Title IX, USC Student Health, Relationship and Sexual Violence Prevention, Communications, Executive Operations, Faculty, and Student Governments, as well as an independent external consultant.
Beginning in October 2019, the AAU Survey Task Force offered a variety of in-person and virtual forums to socialize the campus community to the results of the AAU survey. Those forums included town halls, focus groups to reach disproportionately affected student populations, and AAU Data Walks, a participatory way to share relevant data with affected communities. In addition to the sharing of information, these in-person and virtual sessions provided an opportunity for students in academic and cultural communities to better understand the data and its implications, as well as share their own experiences related to sexual assault and misconduct on campus. Together the engagement yielded participation by over 500 students and provided diverse forums for robust discussion and feedback. Throughout all engagement efforts, students were invited to share observations and insights and offer input on prevention and response planning.
The AAU Survey Task Force made two overarching recommendations: create a Campus CoordinatedResponse Team (CCRT) charged with developing, implementing, and overseeing various methods for comprehensive sexual harassment and assault prevention, and publicize and make available the full report and recommendations for implementation of the AAU Survey Final Report. Additional recommendations included: (1) further develop and promote campus comprehensive prevention resources; (2) provide comprehensive prevention-oriented training for all students, faculty and staff throughout their time at USC; (3) evaluate and expand methods to increase reporting; (4) increase accountability for incidents of sexual harassment perpetrated by faculty and staff; (5) collect additional data; (6) increase education regarding sexual harassment; and (7) continue university efforts to decrease alcohol consumption.
In October 2020, the AAU Survey Task Force released the final AAU Survey Task Force Report.
National Academies of Sciences, Engineering, and Medicine’s (NASEM) Action Collaborative on Preventing Sexual Harassment in Higher Education
On April 20, 2019, the university joined the National Academies of Sciences, Engineering, and Medicine (NASEM) to launch an Action Collaborative on Preventing Sexual Harassment. The university is a founding member of the Action Collaborative, which has four primary goals: raise awareness, elevate evidence-based institutional policies, gather and apply research, and develop a standard for measuring progress in order to reduce and prevent sexual harassment in higher education. These goals reflect the university’s ongoing mission to continue to lead our university into the future with civility and mutual respect. To facilitate the university’s commitment to these goals, the university formed a working group composed of 15 fifteen staff and faculty members. This working group’s efforts built upon the foundation established by the Joint Task Force.
As a founding member, the university committed to developing new approaches to address sexual harassment from a preventive orientation; implementing and testing new or revised programs, policies, and practices each year; sharing the results from these new or revised approaches each year; and identifying and engaging a group of additional individuals at the institution who can assist and inform this work (including experts, researchers, key stakeholders and individuals with job responsibilities related to issues of sexual harassment).
In December 2020, the VP EEO-TIX agreed to assume co-leadership – along with Dr. Parveen Parmar, Keck School of Medicine faculty member and director of the Center for Gender Equity in Medicine and Science (GEMS) – of the NASEM Action Collaborative on Preventing Sexual Harassment in Higher Education working group at USC (see below). The university is a founding member of the Action Collaborative, which is focused on identifying, researching, developing, and implementing evidence-based policies and practices for addressing and preventing all forms of sexual harassment and promoting campus climates of civility and respect.
Prevention and Education
In January 2019, the university announced that USC Student Health was expanding its outreach and education efforts to include educational offerings for students and others on topics such as obtaining consent from sexual partners, creating healthy relationships, and reporting instances of sexual harassment or other forms of victimization. A USC Student Health prevention specialist and three prevention educators were hired to teach members of the USC community how to combat sexual assault and relationship violence and to share information about resources available to victims.
The university built on its existing orientation program, Think About It, to develop a new workshop on affirmative consent. The university also developed a pilot in-person workshop, Trojans Respect Consent, to be delivered to incoming first-year students. Additionally, the university has a Healthy Relationships Workshop and a Sexual Harassment (for Graduate Students) Workshop.
The university sponsored and coordinated Bringing in the Bystander training for student leaders and a select group of faculty and staff in collaboration with Undergraduate Student Government. Bringing in the Bystander is an in-person, educational program that encourages participants to become positive bystanders in instances of sexual and interpersonal violence and harassment. Through Bringing in the Bystander, students gain the skills and knowledge to intervene before or during an incident, speak up when their peers make light of sexual or dating violence, support survivors of trauma, and learn practical skills for safe and effective intervention. Bystander Intervention Workshops have since been offered to student leaders across the campus.
Trauma-Informed Care
In 2019, the university adopted trauma-informed principles throughout USC Student Health. To better implement training and shifts in practices, USC Student Health formed a Trauma-Informed Care Steering Committee to shepherd the organizational transformation. The Steering Committee includes designated members of executive leadership teams and department heads or their designees. To facilitate the consistent application of the Trauma-Informed Care principles, all staff in USC Student Health attended an in-person training and completed online video and reading requirements. Training will continue on a bi-annual basis to ensure sustainability.
In addition, during the summer of 2019, USC Student Life (then Student Affairs) convened an institute to introduce their staff to trauma-informed student services and the Community Resilience Model (CRM), a wellness workshop. Approximately 200 staff from all departments in Student Life attended.
Office of the Ombuds
In January 2019, the university created the USC Office of the Ombuds to provide independent, confidential, and impartial support for the university community. Katherine Greenwood was appointed to the University Ombuds at the University Park Campus and Thomas Kosakowski was appointed the University Ombuds at the Health Sciences Campus. The Office of the Ombuds serves as a problem-solving resource and strives to create a safe place for people who come to the office to discuss and examine concerns. The Office of the Ombuds can help address a wide variety of issues and concerns, including organizational climate, change management, interpersonal issues, ethical concerns, issues of perceived unfairness or incivility, behavioral or stylistic differences in the workplace or classroom, or inquiries related to university procedures and policy. The Office of the Ombuds can also identify patterns, trends, or systemic concerns and share this upward feedback with the university through anonymized and depersonalized data and information.
President’s Culture Commission
On Nov. 13, 2018, then Interim President Wanda Austin announced the launch of the President’s Culture Commission to oversee the university’s efforts to improve campus culture. The President’s Culture Commission grew out of the work of the Task Force on Workplace Standards and Employee Wellness, which was created in August 2017 to address root issues related to the issues attendant to the former Dean of the Keck School of Medicine. The Task Force on Workplace Standards and Employee Wellness sought to understand, identify, and handle mental health challenges; improve campus wellness, especially in the health professions; balance individual and privacy rights with campus protection; understand the intersection of addiction and criminal conduct; improve the flow of information across campus; and ensure that incoming reports of improper actions, even if anonymous or questionable, get referred to the appropriate office. The Task Force on Workplace Standards and Employee Wellness, comprised of faculty, staff, and students, assessed four areas of culture: leadership, concerns, wellness, and values.
Vice President, Ethics and Compliance and Chief Compliance Officer
In November 2018, USC welcomed Stacy Giwa as Vice President, Ethics and Compliance and Chief Compliance Officer. Since her arrival, Giwa has helped to establish a new Office of Culture, Ethics, and Compliance (OCEC), which works across the university to explore values and engage faculty, staff, and students in driving culture change based around identified values and behaviors; partners with key stakeholders to build effective compliance programs; and investigates complaints related to conflicts of interest, privacy and security laws, health care billing, and misconduct related to research grants and Code of Ethics violations not within another office’s jurisdiction. Giwa focuses on values and culture with the goal of strengthening integrity and ethical decision-making across the university.
Joint Provost/Academic Senate Task Force
In the summer of 2018, the university created the Joint Provost/Academic Senate Task Force (Joint Task Force). The Joint Task Force, comprising students, staff and faculty, was charged with developing recommendations for cultivating a culture and environment at USC in which sexual harassment is not allowed to persist, where reporting of harassment is encouraged and expected, and where reports and instances of harassment are handled appropriately. The Joint Task Force focused on faculty misconduct and harassment, including faculty mentoring and supervision, communications and transparency, and gender harassment. The Joint Task Force issued its Final Report, Interrupting Sexual Misconduct and Gender Harassment at USC: Recommendations by the Joint Provost/Academic Senate Task Force on Sexual Harassment and Gender Violence, on March 25, 2019. The Joint Task Force made recommendations in the following five areas: acknowledge the past and look to the future; codify values and promote standards of conduct; implement relevant, accessible, and transparent policies and procedures; institute and evaluate an alternative response system; and, strengthen infrastructure on sexual misconduct and gender harassment.