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Given the notably acute fiscal constraints on LEAs, we presume that a extensive vast majority (90 %) will slide into Group 2-conference all specifications of the proposed polices and applicable rules, but not working with restricted methods to manage a Title IX compliance construction beyond this sort of demands. In basic, the Department assumes that recipients slide into a single of 3 teams: (1) Recipients who have complied with the statutory and regulatory prerequisites and both did not comply with the 2011 DCL or the 2014 Q&A or who lessened Title IX things to do to the amount expected by statute and regulation right after the rescission of the 2011 DCL or the 2014 Q&A and will continue on to do so (2) recipients who ongoing Title IX activities at the amount required by the 2011 DCL or the 2014 Q&A but will amend their Title IX activities to the stage required less than latest statute and the proposed polices issued in this continuing and (3) recipients who continued Title IX functions at the amount essential less than the 2011 DCL or the 2014 Q&A and will go on to do so soon after last polices are issued. To be distinct, these estimates are not meant to discourage recipients from investigating at a higher level

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Nor do these estimates of a decrease in investigations forecast a reduce in recipient's obligation to react in some acceptable way to a report of sexual harassment. Due to the absence of sufficient information about such rate structures and the hugely individualized character of supportive measures delivered to complainants and respondents, we are unable to at this time deliver this kind of estimates with any precision. Such responses will not be dictated by the recipient's grievance processes, but may possibly involve conversing with the reporting get together, discussing possibilities, connecting him or her with suitable on- or off-campus means, conducting some form of more investigation, and other supportive steps. Again, assuming that Clery Act studies correlate with all incidents of sexual harassment (as defined in these proposed polices), we believe a further more reduction in the selection of investigations per IHE per calendar year of about .18, working with the range of non-campus, general public property, and described-by-law enforcement reports as a proxy for the amount of off-campus sexual harassment investigations at this time remaining executed by IHEs. As a end result, we estimate that every IHE in Group 2 will practical experience a reduction in the quantity of Title IX investigations of roughly .93 for every 12 months. We think that the provision of supportive measures will choose somewhere around 3 hrs for every report for Title IX coordinators and 8 hrs for an administrative assistant at the LEA amount

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