Pomona College President’s Advisory Committee on Sexual Violence Intervention and Prevention Final Report & Recommendations

A Global Issue

The World Health Organization and the United Nations both substantiate gender violence, in particular, sexual violence, as a major public health concern and among the most prevalent human rights violations in the world. It is estimated one in three women will experience physical and/or sexual violence by a partner or sexual violence by a non-partner in their lifetime (Tsai, 2011; WHO 2013). Male, Lesbian, Gay, Bisexual and Transgender identified individuals are also victims of sexual violence, intimate partner violence and/or stalking, and the provision of services to men and LGBT+ survivors needs to be better addressed. Additionally, focused attention on addressing the needs of survivors across marginalized communities (e.g., international students, undocumented students, students of color, religious minorities, etc.) is important. It is well established that sexual violence knows no social, economic or national boundaries. The burden of sexual violence results in a host of negative physical, mental and behavioral health outcomes (Russo & Pirlott, 2006).

The National Context

Title IX of the Education Amendments of 1972 (“Title IX”), a federal law, provides that “no person … shall be excluded from participation in, be denied the benefits of, or be subjected to discrimination under any education program or activity receiving Federal financial assistance.” In April 2011, the federal Department of Education (“DOE”) issued guidance to clarify its interpretation of Title IX related to sexual violence as a form of sex discrimination. Among other things, Title IX requires schools to respond to sexual violence, prevent its recurrence and remedy its effects. In March 2014, President Obama signed the Campus Sexual Violence Elimination Act (Campus SaVE). In September 2017, the DOE issued a Q&A on Campus Sexual Misconduct which provided interim information in advance of the DOE’s proposed sexual misconduct-related rulemaking. Because of these and more recent legislative and regulatory developments, the work that informed this report included a comprehensive review of relevant legislation and guidance to ensure compliance with federal and state law, increase safety on our campus, and enhance our work in the areas of prevention, reporting, response and support as they relate to sexual violence, dating/domestic violence, stalking, sexual harassment and discrimination based on sex, gender and/or gender identity and/or expression.

A Call to Action

Pomona College is deeply committed to equity, diversity and inclusion. We strive to be a caring and collegial community characterized by mutual respect and safety. The problem of sexual misconduct, harassment and/or discrimination is of grave concern and a call to action for all of us.

In order to ensure a comprehensive, caring and effective approach to sexual misconduct, President Gabrielle Starr formed The President’s Advisory Committee on Sexual Violence Intervention and Prevention (“PAC-SVIP”). President Starr appointed Sue McCarthy, Title IX Coordinator, and Oona Eisenstadt, the Fred Krinsky Professor of Jewish Studies and Professor of Religious Studies, to chair the PAC-SVIP.

PAC-SVIP members were appointed by President Starr to ensure key stakeholder participation as well as cross-campus representation by students, faculty and staff. PAC-SVIP members were as follows:

• Margaret G. Lodise, Trustee, ‘85
• Tony D. Boston, Associate Dean of the College; Associate Professor of Physical Education
• Sara Masland, Assistant Professor of Psychology
• Pat Smiley, Professor of Psychology
• William R. Swartz, Professor of Physical Education and Soccer Coach
• Brandon Johnson, Director of Intramurals, Club Sports and Recreation
• Rita Shaw, Student Services Coordinator
• Sefa Aina, Associate Dean and Director of the Draper Center
• Craig Arteaga-Johnson, Assistant Vice President for Advancement, Alumni and Parent Engagement, ‘96
• Ellie Ash-Bala, Associate Dean of Campus Life and Director of the Smith Campus Center
• Jan Collins-Eaglin, Senior Associate Dean of Students for Personal Success and Wellness
• Pharalyn Crozier, Assistant Director, Queer Resource Center
• Nicole Desjardins Gowdy, Director of Study Abroad
• Angel Mason, Senior Associate Athletic Director/Senior Woman Administrator
• Jessica Nickerson, Residence Life Coordinator
• Vicky-Marie Addo-Ashong, Student, ’20
• Daniela Bond, Student, ’20
• Niles Mayan Brooks, Student, ’20
• Molly Rose Gilbey Keller, Student, ’19
• Micah Ayah Abad Maglasang, Student, ‘20
• Hershey Suri, Student, ‘21
• Glen Kraemer, Partner, Hirschfeld Kraemer
• Derek Ishikawa, Associate, Hirschfeld Kraemer, ‘01

Our Work

We laid the foundation for meeting our charge as a group by identifying guiding principles and practices for our work. Core values critical to our work included:

• Creating culture change
• Utilizing a holistic community approach
• Prioritizing the importance of research and evidence-based best practices
• Centering the voices of students and survivors
• Prioritizing the critical importance of diversity, inclusion and cultural competence

Four subcommittees were formed to focus on the respective areas of prevention, reporting, response and support.

The PAC-SVIP at large met 2-3 times per semester. Subcommittees met regularly and reported to the PAC-SVIP on their progress and integrated feedback from the large group into their subcommittee work.

During Fall of 2018 each subcommittee:

• Conducted research focused on their respective area (prevention, reporting, response and support) and sought to identify evidence-based and/or emerging best practices.
• Reviewed existing policies, practices, infrastructure and culture at the College as they relate to their area (prevention, reporting, response and support) and identified existing strengths, barriers, challenges and/or gaps.

During Spring of 2019, each subcommittee:

• Established goals for the College for each of their areas and made recommendations outlining action steps we need to take, and resources needed in order to achieve these goals.
• Met with the President and her executive staff at the May 15^th, 2019 PAC-SVIP meeting to share their work, goals and recommendations.

During Summer 2019, PAC-SVIPs work was concluded and the subcommittee goals and recommendations were synthesized into this final report. This report represents the culmination of work and recommendations of the PAC-SVIP.

Strengths and Resources: Past and Present

Pomona College’s commitment and dedication to addressing sexual violence prevention, reporting, response and support is ongoing and remarkable. Awareness of the breadth and depth of the College’s efforts and consistent progress has somehow been lost to significant constituencies as the focus vacillated between specific claims, national politics, the Department of Education’s actual and proposed changes to Title IX and more. This, combined with programmatic/structural issues and a mounting culture of distrust and polarization, had profoundly harmful effects on progress that has been made, creating space to heal and/or recover from past challenges and the ability to implement positive changes and continued progress.

Our Strengths and Resources

• The College has a full-time, designated Title IX Coordinator with the knowledge, expertise and experience to provide effective leadership and support for the breadth and depth of this work.
• The College has designated Deputy Title IX Coordinators, Campus Security Authorities[1] and Responsible Employees[2].
• The College employs experienced legal counsel to support the work of the Title IX Coordinator and the College around these issues in a manner that demonstrates an unwavering commitment to equity, diversity and inclusion, integrity and an ethic of care.
• The College supports the decisions made in the adjudication of sexual misconduct, harassment and/or discrimination and holds individuals accountable for substantiated policy violations.
• The College provides support for peer programs such as the Project Sister Family Services Campus Advocates, Peer Educators and Women’s Union (“WU”) that is critical to engaging students and supporting student development and student leadership.
• The Associated Students of Pomona College (“ASPC”) support a staff position within ASPC focused on Title IX, sexual violence prevention, reporting, response and support.
• The College has demonstrated a sustained commitment to improving policies, practices, programs and resources regarding sexual violence.
• The College demonstrably cares and is passionate about equity, diversity and inclusion.
• The College supports culturally specific and identity-based resources and spaces on campus and at The Claremont Colleges.
• The PAC-SVIP dedicated considerable resources and time towards this project and has received remarkable support from the President Starr in completing the work represented here.

It should be noted that the implementation of PAC-SVIP recommendations may result in an increase in reports of sexual misconduct which should not be construed as negative nor as an indicator of an increase in the incidence of sexual misconduct at Pomona College. While any incident of sexual misconduct is undesirable, the reporting of such an incident is advantageous so that the individual harmed can access campus and off-campus resources, and the institution can respond to the incident. Thus, Pomona College encourages increased reporting as it indicates an increased awareness or accessibility of reporting mechanisms. It is further expected that, with the implementation of the PAC-SVIP recommendations, the actual incidence of sexual misconduct will decrease over time.

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Common Themes

PAC-SVIP structured its work around four critical areas of focus in addressing sexual violence: prevention, reporting, response and support. Each focus area was assigned to an independently functioning sub-committee comprised of distinct members of PAC-SVIP dedicated to learning more about best practices and research in each area and developing recommendations specific to that area.

While identifying recommendations specific to each focus area, some common recommendations emerged from each subcommittee. It is remarkable to note, and we find it quite compelling that each of the goals and recommendations outlined below were proposed separately by each group working independently. The more we learned, the more it became clear how inextricably linked and interdependent progress in each of the focus areas are to each other.

Priority Goal 1:

Pomona College is dedicated to strengthening our efforts in all four critical areas of focus in addressing sexual violence: prevention, reporting, response and support. We know creating a culture and community of respect, care and accountability is of critical importance to keeping all members of our campus community safe and ensuring Pomona College is a great place to live, learn, work, and grow. We have a strategic plan for addressing campus sexual violence that is an evidence-based, action oriented, and team approach to change.

Priority Recommendation 1-1:

The Title IX, Clery, and CARES (Campus Advocacy, Resources, Education and Support) Office should be fully staffed.

• There is currently just one full-time senior management position dedicated to all four critical focus areas of this work.
  • This position is one with multiple titles and responsibilities.
  • This position serves as an Associate Dean and member of the senior management team within Student Affairs , the Title IX Coordinator, the Clery Officer, and a Diversity Officer for the College.
  • This position is responsible for ensuring the College’s compliance with federal and state law, in particular Title IX and Clery, both of which are remarkably complex and dynamic. This includes extensive quality assurance, tracking, annual training and education requirements for all members of the campus community, oversight for Title IX investigations and adjudications, management of all concerns brought to the attention of the office, and much more.
  • This position is responsible for oversight of the peer support and peer educator programs, the WU and all four critical focus areas of addressing sexual violence (prevention, reporting, response and support).
  • The demand and utilization for the Title IX Office in terms of individual contacts alone (e.g., complaints, formal investigations, informal and alternative resolutions, etc.) more than tripled in 2017-18 from the previous academic year. Online reports via Callisto increased 9-fold during that same year. While we recognize this as a positive sign of progress, indicative of increased confidence in seeking help, we also know that continued increases in demand are not sustainable over the long term without sufficient additional resources.
  • The leadership and expertise of this position is critical to important changes at the campus level related to sexual violence prevention, reporting, response and support; the PAC-SVIP and the Pomona CORE Blueprint Committee (see below).
  • The PAC-SVIP report reflected external confidence in the work of the current leadership of the Title IX Coordinator, Clery Officer, Associate Dean and independently identified the need for additional resources based on continuing challenges.
  • The position also carries with it significant leadership responsibilities for The Claremont Colleges 7C Title IX Working Group, the Office of Violence Against Women Grant, and the Coordinated Campus Response Team.
  • This position currently has administrative support at 50% time.
• Additional staff for the Title IX, Clery and CARES Office, reporting to the Associate Dean/Title IX Coordinator, were identified as essential to the recommendations in this report and were independently recommended by each subcommittee. All subcommittees identified this need as the foremost priority and most imminent need at Pomona College in the area of Title IX, Clery and the CARES Office.
  • The ideal staffing structure recommended by the full committee is to:
    1. Increase the half-time administrative support position currently in place to a full-time one supporting Title IX, Clery and CARES.
    2. Hire two new full-time positions (a prevention coordinator and a support coordinator) as direct reports to the TIX Coordinator.
    3. Continue existing support to hire a graduate assistant.
    4. All should be direct reports to the Title IX Coordinator.
  • The minimum staffing structure recommended by the full committee is to:
    1. Increase the half-time administrative support currently in place to full-time.
    2. Hire one new full-time position (75% prevention and 25% support).
    3. Continue existing support to hire a graduate assistant.
    4. All should be direct reports to the Title IX Coordinator.
  • In either scenario, we believe is it critical for the peer programs (i.e., peer educators, campus advocates and WU staff) to be overseen by the new staff position(s). It was quite clear from our interviews with peer institutions and demonstrated experience at Pomona College that it places the Associate Dean/Title IX Coordinator in a challenging and far-from-ideal situation to continue having direct oversight responsibility for these groups given the potential for conflicts of interest.
    • Note: In regard to the Women’s Union, this program is funded by the VP of Student Affairs budget with paid student staff positions and is housed under the responsibility of the Associate Dean/Title IX Coordinator. Currently, and in the past, WU has received joint support from a designated Gender and Women’s Studies (GWS) faculty (in part for the reasons noted above). This support has historically focused in particular around the WU luncheons. We recommend that this partnership with GWS continue and that a sustainable structure for doing so be jointly identified by the Associate Dean/Title IX Coordinator and the GWS faculty chair and/or Dean of Women

Priority Recommendation 1-2:

The following actions should be taken to ensure Title IX and the CARES Office are physically and psychologically safe and accessible to faculty, students and/or staff who wish to seek support, learn about options and resources, and/or make a report, as well as for staff working in that space.

• Identify new dedicated physical space for TIX and the CARES Office in consultation with Title IX Coordinator as soon as possible.

• Relocate Title IX and the CARES Office to this new space as soon as possible.

• Develop a plan to promote the location of the new office, the fact that it is more accessible and offers improved privacy and confidentiality.
• This new space should be dedicated space for TIX and CARES and should include space for the recommended staffing structure, as well as space for a graduate assistant.
• The CORE Blueprint Committee (see Priority Recommendation 1-4) should research and make recommendations regarding the organizational location of the Title IX, Clery and CARES Office.

• We are aware there has been discussion in the past and currently regarding the organizational location of Title IX at the College. In our research, we learned that faculty and staff expressed concerns and/or questions regarding the placement of the office under Student Affairs, as Title IX obligations and protections apply to faculty and staff, as well as students. Concerns shared included comments related to a perception that Title IX is a student resource only, perceived conflicts of interest, campus culture and politics, and perceived authority and/or independence.
• The Department of Education’s Letter on Title IX Coordinators recommends that the Title IX coordinator’s role should: 1) be independent to avoid any potential conflicts of interest, 2) ensure the TIX coordinator has the appropriate authority, both formal and informal and 3) report directly to the college or university president. While this recommendation may be an appropriate remedy for the concerns noted, making such a change warrants greater consideration of all factors involved.

• Note: Discussion related to concerns around physical space as they relate to reporting needs can be found in the Reporting section of this report.

Priority Recommendation 1-3:

Adopt the CORE Blueprint, CORE Evaluation and supplemental CORE Constructs.

Aligning our work with this nationally recognized framework will demonstrate our dedication to this goal by ensuring we go about doing so with integrity. This framework will help us accomplish this goal by providing us with the most effective evidence-based research, expert guidance and promising and emerging practices specific to addressing sexual violence in higher ed. Collectively, these resources provide us with an actionable framework that helps us integrate the highest standards and promising approaches to addressing sexual violence. Learn more about the CORE Blueprint.

Priority Recommendation 1-4:

Establish the Pomona CORE Blueprint Committee.

The Pomona CORE Blueprint Committee will be an ongoing Pomona College campus leadership team, comprised of representatives from all stakeholder groups, that is aligned with best practices through the CORE Blueprint and is accountable to our campus community and the President of the College. The Pomona CORE Blueprint Committee will guide and implement the recommendations of PAC-SVIP as well as continued innovative and comprehensive efforts in each of the four critical focus areas - prevention, reporting, response and support.

The establishment of the Pomona CORE Blueprint Committee will help to:

• improve communication across and between individuals and departments;
• build trust and rapport among and across constituencies;
• identify new or improved opportunities for collaboration and cooperation;
• empower all stakeholder groups to have an active voice in addressing sexual violence in our community;
• further the work started this year to resolve concerns expressed by faculty/staff, students and administration regarding Pomona’s efforts in each of the focus areas;
• strengthen existing and create new allies in this work, ultimately building a community and campus culture that is empowered to engage effectively in the work of ending sexual violence.

The Pomona CORE Blueprint Committee should include, but is not limited to, the participation of:

• selected representatives from faculty, staff and students;
• the PSFS Campus Advocates;
• the CARES Peer Educators;
• the ASPC Title IX Student Director;
• the Title IX Coordinator & Deputy Title IX Coordinators for the College;
• the Director of the EmPOWER Center;
• and representation from other appropriate stakeholder groups.

In addition, the Pomona CORE Blueprint Committee should:

• represent an ongoing effort and commitment;
• be provided with dedicated funding;
• be convened by the President and housed under the leadership of the Title IX Coordinator;
• establish a clear mission, core values, an assessment plan, and bi-annual goals and objectives;
• include a mechanism for individuals to (anonymously or otherwise) submit comments, critiques, and new ideas regarding the College’s efforts addressing sexual violence.

Priority Goal 2:

Pomona College faculty, staff and students have access to information about and are generally aware of the College’s efforts around prevention, our process, support and resources, and various disclosing/reporting options.

Priority Recommendation 2-1:

Review and assess the Pomona College website in each of these areas (prevention, reporting, response and support) make recommendations regarding and develop an implementation plan for improvements that can enhance understanding and accessibility of this valuable resource.

• Ensure this information is clear and concise.
• Identify ways in which we can provide information in a manner that allows the user to determine what level of detail they want/need.
• Ensure that online resources are easily discoverable, understandable and user-friendly.
• Develop a system for ensuring the Pomona College website is kept up to date and frequently reviewed.

Priority Recommendation 2-2:

In collaboration with the 7C Title IX Working Group, review and assess the 7C support and prevention website in each of these areas (prevention, reporting, response and support), make recommendations regarding and develop an implementation plan for improvements that can enhance understanding and accessibility of this valuable resource.

• Ensure this information is clear and concise.
• Identify ways in which we can provide information in a manner that allows the user to determine what level of detail they want/need.
• Ensure that online resources are easily discoverable, understandable and user-friendly.
• Develop a system for ensuring the TCCS website is kept up to date and frequently reviewed.

Priority Recommendation 2-3:

Review and assess the availability, utilization and quality of programs, training and educational materials in each of these areas (prevention, reporting, response and support), make recommendations regarding and develop an implementation plan for improvements that can enhance availability, accessibility, visibility, utilization and quality of these valuable resources on campus.

Priority Recommendation 2-4:

Determine what print and/or outreach materials are recommended and for what audiences, create and disseminate those in a manner that is fiscally responsible, effective and helpful to the community.

Background

The Prevention Subcommittee was co-chaired by Pat Smiley and William Swartz. Ellie Ash-Bala, Craig Arteaga Johnson and Vickie Marie Addo-Ashong served as members of this committee. Our task is to assess and make recommendations regarding primary prevention efforts at Pomona College in light of best practices. Primary prevention programming 1) prevents initial perpetration of sexual assault, and 2) builds an environment that encourages well-being and healthy choices. In our work, we relied on the Culture of Respect (CORE) Blueprint that provides guidelines for education and evaluation of primary prevention programs for colleges and universities across the country.

Primary prevention is a critical component to facilitating a change in culture and stopping violence before it starts and builds an environment that encourages well-being and healthy choices.

Federal and/or state law requires schools to provide educational programs, awareness raising programs and training on the prevention of sexual harassment, sexual assault, dating/domestic violence and stalking. We must ensure that we provide information about our policies, what constitutes sexual violence and the role of alcohol and drugs in perpetration. We must clearly define consent, share information about risk reduction, and provide information on safe bystander intervention. Currently, the College provides this information to all students on its website, to first-year students through Orientation activities (Student Affairs presentation; InterACT; Teal Dot; Haven), and to student athletes through NCAA required online training.

In addition to reviewing federal and state laws, we conducted research on best practices and the practices of colleges with robust prevention programs. As a result of that research, we selected and relied upon the Culture of Respect (CORE) Blueprint, a handbook that provides guidelines for education and prevention programs for colleges and universities across the country, to guide our work.

What We Learned

Pomona College was one of the 14 colleges and universities in the CORE Blueprint pilot study, begun in 2015, and therefore, we developed our programming according to the 10 components of best practices developed by the group, namely, programming that is comprehensive, varied, sufficient, theory-driven, positive, relationship-based, developmentally appropriate, socioculturally relevant, delivered by trained staff, with a focus on outcome evaluation, and integrated into the institution at multiple levels.

Currently, our prevention efforts are compliant with the law and generally informed by an attention to best practices. However, our efforts are neither comprehensive nor sufficiently coordinated. While Pomona signed on as a pilot institution participating in NASPA’s CORE Blueprint Pilot Program in 2015, the Blueprint is not recognized throughout the Pomona community as a guiding document and has not been fully implemented. Embracing an established and recognized framework such as the CORE Blueprint as the College’s framework will increase the quality of our efforts through alignment with evidence-based approaches that reflect society’s evolving understanding of best practices. Embracing a framework will also enable us to improve our efforts more efficiently over time through alignment with the framework rather than “starting from scratch” each time we wish to update our approach.

Our research revealed that prevention efforts at the College are evaluated inconsistently and are not reviewed as components of a larger framework. There is a need to evaluate each of our prevention efforts against the recommended established framework. In so doing, we will ensure that each of our individual programs is fulfilling its role within a comprehensive strategy and we will also ensure that our efforts are consistent with evidence-based approaches that reflect society’s evolving understanding of best practices. Then, we should also periodically evaluate the framework itself against other available frameworks, to create the opportunity for substantial change in our overall approach if needed.

Our initial review of Pomona’s current practices revealed that we could enhance our programming, by, for example, extending it beyond the first semester of the first year; reviewing other available evidence-based programs aimed at varied audiences and to enhance media literacy; intentionally engaging mentor group leaders; coordinating our efforts with EmPOWER; planning regular (e.g., 3-year) evaluation efforts beyond HEDS; and improving training of peer advocates.

Our initial review also showed that we could benefit from stronger communication and coordination across the 7C’s around primary prevention. Currently, we have stakeholders and different offices/personnel engaged in prevention efforts at Pomona and across the 7Cs with no formal infrastructure dedicated to supporting the coordination and/or communication of this work. In the Collaborations section of this report, we address the desire to enhance coordination across departments and colleges and the personnel engaged in this work to maximize opportunities for shared messaging and experience of prevention efforts.

Currently, many members of the Pomona College community take an active role in preventing sexual violence. At the same time, much more effort and involvement is needed. It will be essential that strong, focused leadership is provided in order to inspire, motivate and facilitate increased involvement of members throughout the Pomona community. This leadership should be spearheaded by a single individual who is recognized as the leader of the prevention effort and who is recruited and resourced with the diverse needs of this role in mind. This individual should “captain” our sexual violence prevention efforts, providing vision and tools, inspiring others and creating shared awareness of our prevention efforts’ strengths and deficiencies. While sexual violence prevention efforts themselves must be dispersed broadly throughout our community, having an individual provide visible and energetic leadership will be important. This leadership will also be critical in ensuring that we do not simply “check the boxes” in implementing efforts, but that we instead maximize their effectiveness and maintain focus on our shared responsibility for ending the violence happening among us.

Peer-education is regarded as an essential component of sexual assault prevention. It is especially useful in empathy-based programming to get students to internalize the social and emotional aspects of sexual violence.

Currently, the College has limited peer education programs that provide services upon request only or in an inconsistent manner, without an established clear mission or established curriculum. With the recent restructuring of the Campus Advocates program under the umbrella of Project Sister Family Services, Pomona College is in a good position to develop a peer-to-peer education program that is proactive in its campaigns.

Current Peer Education Programming at the College includes:

• TCCS Health Education Outreach (HEO)
  • HEO outreach and workshops are typically provided upon request and they provide programming on different issues, including sexual health and sexuality. The HEO employs 11 Peer Health Educators (PHEs) who are tasked with “promoting and exploring health and wellness among their peers,” as per their website. PHEs create programs and provide one-on-one Peer Wellness Coaching by appointment.
• Pomona College Women’s Union (WU)
  • The mission of the WU is broadly to “secure positive changes for women in their personal and political lives and to work toward deconstructing gender-based constraints within both local and global contexts,” per their website. The WU hosts numerous events and lunches, some of which address sexual violence and harassment.

Robust programming addressing positive masculinity, already underway at the EmPOWER Center, is needed on our campus and in our campus dialog as it relates to violence prevention and healthy relationships.

Currently, some metrics related to sexual violence are publicized and the administration has consistently shared information as required by law as well as the results of major surveys. However, due to the complexity of sexual violence data and confidentiality issues related to the data, there is not a set of top-level metrics that is regularly publicized. This has led to uneven understanding of the state of sexual violence at Pomona and differing understandings of what progress toward prevention means. This should be addressed through the establishment of clear, consistent metrics that are publicized routinely.

Based on our close study of the CORE Blueprint and our assessment of Pomona College’s current efforts toward prevention programming, below we outline four major recommendations that will strengthen the content and structure of Pomona College’s commitment to sexual violence prevention.

Prevention Goals & Recommendations

Prevention Goal 1:

Pomona College has a robust peer education program that emphasizes student involvement in creating positive cultural change on campus through extensive and ongoing conversations and programming.

Prevention Recommendation 1-1:

Establish a peer education program under the Title IX and Campus Advocacy Resources Education and Support (CARES) Office, to work under the guidance of a professional in a new full-time position, a Prevention Specialist, focused on education and outreach.

• Please see Prevention Goal 6 below re: our recommendations for this new position. The Prevention Specialist hired under the Title IX Coordinator would assume as their primary function our prevention education efforts. We recommend not blending this role with other staff responsibilities.

Prevention Recommendation 1-2:

Emphasize engaging male-identifying students as stakeholders in preventing sexual violence, dating/domestic violence, stalking and sexual harassment through evidence based best practices.

Prevention Recommendation 1-3:

Identify and outline the College’s educational priorities for peer education to ensure consistent and coherent messaging. Topics may include policy, consent, cultural norms, healthy relationships, positive sexuality, etc.

Prevention Goal 2:

Pomona College is a caring and compassionate community committed to promoting healthy relationships and/or healthy sexual relationships, as well as a culture of equity, inclusion and respect. Our faculty, students and staff are actively engaged in coordinated efforts toward this end.

Prevention Recommendation 2-1:

Programming and events focused on the prevention of sexual violence, dating/domestic violence, stalking and sexual harassment and on related topics such as consent, bystander intervention, gender, healthy relationships, etc. should be encouraged by students, staff, faculty, student groups and departments across campus and should include active collaboration with and among key stakeholders.

Prevention Recommendation 2-2:

Conduct further research on and make recommendations for additional programming aids for Pomona College and/or the 7Cs.

• For example, Circle of 6 is a smart-phone-based app that enables discrete social support from a student’s circle of six friends if a student is in need of assistance at a social gathering.

Prevention Recommendation 2-3:

Prevention efforts should be trauma-informed and intersectional in their content and approach as to ensure intentional collaboration with campus-wide efforts to combat racism, sexism, homophobia and other forms of oppression.

Prevention Recommendation 2-4:

Prevention programs should include topic areas such as consent, gender/gender socialization, sexuality and sexual health, bystander intervention, the role of men as allies and survivors, the role of alcohol and drugs in facilitating sexual violence, healthy and unhealthy relationships, special concerns for marginalized populations (i.e. male survivors, trans survivors, undocumented survivors, etc.), hate and bias, and commonly held myths about these issues.

• Continue to identify successful prevention programs which do not blame the victim but target changing the culture, addressing issues of consent and accountability.

Prevention Goal 3:

The systems Pomona College has in place for the prevention of sexual violence are adopted and implemented from an established and recognized framework for sexual violence prevention, ensuring effectiveness and continued improvability across our prevention efforts.

Prevention Recommendation 3-1:

Adopt and implement the CORE Blueprint as the College’s current framework for sexual violence prevention.

• Publicize and socialize the adoption of the Blueprint throughout the Pomona community so that there is shared awareness of, and commitment to, its “pillars” related to sexual violence prevention.
• In three years, evaluate the framework in order to determine whether the Blueprint is still the most robust to use as the College’s framework for sexual violence prevention (please see the Evaluation recommendation for additional details).
• Consider our thoughts about the CORE Blueprint principles of leadership, evaluation, and metrics, as discussed below.

Prevention Recommendation 3-2:

Develop an assessment plan for prevention programs and systems at Pomona College, in alignment with the CORE Blueprint, to ensure primary prevention programs are evidence-based to the greatest extent possible.

Prevention Goal 4:

Pomona College is committed to proactive evaluation of our prevention efforts to ensure alignment with our current framework for sexual violence prevention and determines the best available framework for the future.

Prevention Recommendation 4-1:

Establish an evaluation team that appropriately reflects the range of stakeholders and has a reasonable level of independence.

• Annually, this team shall evaluate each of our prevention efforts to ensure their alignment with our adopted framework and review their outcomes to ensure their success in fulfilling their role within our overall approach.
• Every three years, this team shall evaluate our current framework and alternative frameworks to determine which framework is the best possible framework for us. Our framework should be chosen based on its:
  • Effectiveness, as reflected in its thoroughness and its evidence-based outcomes
  • Relevance, as reflected in its applicability to Pomona’s characteristics
  • Feasibility, as reflected in its ability to be implemented within our context of staffing, budget and time available.

Prevention Goal 5:

Pomona College shares publicized metrics that create accountability and a shared understanding of progress toward ending sexual violence at Pomona.

Prevention Recommendation 5-1:

Identify a discrete number of key metrics that clarify topics including 1) the number and type of sexual violence incidents at Pomona, 2) indicators of the general campus climate related to sexual violence and prevention, 3) prevention and education efforts, and 4) the College’s response to incidents, including student support, investigations and disciplinary action.

• Establish a routine schedule and procedures for gathering and publicizing the key metrics.
• Ensure publication of metrics do not compromise confidentiality and are sensitive to the concerns of survivors in a small campus environment.
• Appropriately publicize the metrics widely throughout the Pomona College community in a clear manner that places data within the context of historical progress or non-progress and within the context of goals and definitions of “success.”
• Determine who or what group of individuals should implement and actualize this recommendation. This group should periodically review which metrics are considered “key metrics” and determines whether changes are warranted. This group should also review the schedule and procedures for gathering and publicizing the metrics. The group should strive to maintain consistency whenever possible since that will contribute to a shared sense of clarity and accountability around metrics

Prevention Goal 6:

Pomona College supports a dedicated full-time staff position, a leader who inspires and mobilizes all of us as stakeholders in the prevention of sexual violence, by providing vision and tools, leading to a culture-shift by which prevention of sexual violence becomes a shared commitment of everyone within our community.

Prevention Recommendation 6-1:

Establish a full-time, senior position dedicated to lead sexual prevention efforts throughout the Pomona College community and resource the position appropriately so that the individual can provide sufficient motivation and tools for a wide range of constituents.

• At the same time, we recommend that the College engage leaders throughout our community in taking responsibility for the active, positive involvement of themselves and their peers in sexual violence prevention efforts. We wish to emphasize the importance of prevention within the resources deployed overall by the College related to sexual violence. That is, we know substantial resources must go to response and reporting (and should), but prevention should be the College’s first goal; therefore, allocation of resources should be just as substantial in that area.
• This recommendation supports Pillars 3 and 5 of the CORE Blueprint.

Background

The Reporting Subcommittee was chaired by Sue McCarthy; Tony Boston, Ellie Ash-Bala, Rita Shaw, Angel Mason and Micah Maglasang served as members.

Disclosing sexual violence, dating/domestic violence, stalking and/or sexual harassment and/or discrimination can be extremely difficult; the way in which someone (an administrator, staff, faculty, friend or family member) responds to a disclosure can either support a positive healing experience or cause further trauma and discourage someone from seeking needed assistance, such as medical care, legal advocacy, or academic assistance.

Creating an atmosphere of positive support requires an investment in myriad programs and resources. While the specifics may vary from place to place, it is critical that individuals feel safe and supported so that they will report concerns and get help. Institutions can help mitigate the impact of sexual misconduct by creating an atmosphere in which individuals feel safe to seek resources and accommodations and to participate in an administrative and/or legal process to hold offending persons accountable for their actions.

Federal and/or state laws and guidelines have established requirements associated with confidentiality and disclosures/reporting, options for reporting, training requirements for first responders, mandated reporting and more. Title IX, the Clery Act, the April 2014 White House Not Alone Report all served as key documents and excellent resources in guiding our work.

In addition to reviewing federal and state laws, we conducted research on best practices and the practices of peer institutions. As a result of that research, we selected and relied upon the Culture of Respect (CORE) Blueprint to guide our efforts. We also spoke to subject matter experts, talked to students, reviewed the Higher Education Data Sharing (HEDS) Survey on Sexual Assault Campus Climate Survey (SACCS) and read scholarly articles on this subject.

What We Learned

Factors that impact reporting

There are multiple individual, interpersonal, sociocultural and structural factors that impact reporting. Some of these factors facilitate reporting, others serve as barriers to reporting. Some we have no control over, some we can influence, others we perhaps can mitigate.

• Individual factors include things such as personal history/prior victimization; a sense that what happened wasn’t serious enough or that there isn’t enough proof; whether or not one identifies what happened as wrong; feelings of shame and guilt; degree of memory; denial or just not wanting to acknowledge/deal with what occurred; comfort level w/ sexual communication; level of self-efficacy; desire to prevent from happening to another; time and other demands.
• Interpersonal factors include concern about how others might respond (i.e. victim blaming, won’t believe, anger/outrage...); not wanting others to know or become involved; feel it’s private matter; fear of retaliation; don’t want to be labeled as a victim, survivor, etc.; encouragement from friends/family; relationship to offender; and other stressors.
• Sociocultural factors include cultural beliefs; language; intersecting identities and financial concerns.
• Structural factors include process/procedures and knowing what to expect; policy and laws related to the incident itself, underage alcohol use, illegal drug use, standard of proof, definitions of prohibited behavior, confidentiality concerns, and fear of deportation.

The importance of a trauma-informed office

Following the specific guidance of the CORE Blueprint and matching guidance from our research: a compassionate administrative response to a disclosure is critical to supporting those who have experienced harm on a path toward healing, as well as social, academic and professional success.

A trauma-informed office provides a physical space wherein individuals can discuss their experiences with an empathic and knowledgeable person.

• These spaces must be fully funded.
• Funding should cover professional staff salaries to provide efficient prevention and response services, ongoing professional staff development, payment for peer advocates, educators and graduate students, prevention programs and awareness campaign funding and other operating expenses.
• This space should have multiple rooms that includes an office/room that provides privacy and confidentiality for an individual wishing to discuss their concerns.

The emphasis on multiple resources that are visible, accessible and trained

Best practices around reporting stress the importance of having multiple resources that are visible, accessible and trained.

Of note, the importance of visible, accessible, trained and multiple resources is pertinent not only to reporting, but also to response, prevention and support as well. Strengths (or weaknesses) in any one of these four critical focus areas will have a positive (or detrimental) impact on each of the other focus areas, thereby impacting the entire system of addressing sexual violence.

While covered in this section specifically in relationship to reporting, the following best practices are also critical to prevention, response and support:

• Visible resources: people know what the resources are and where they are; they can be found “everywhere” (i.e. website, posters, classes, shared at training/education, at programs/events, orientation, on campus, ongoing)
• Accessible resources: free or low cost; multiple points of entry; culturally sensitive and competent; trauma-informed; clear and understandable; private/confidential
• Trained resources: responsible employees; campus security authorities; first responders; in person & online training
• Multiple resources: anonymous, online, in-person, telephone, informal & formal, familiar & not (multiple key contacts) and a single “go to” office

Reporting Barriers, Challenges & Gaps

In reviewing sexual assault programs and services as they related to reporting at Pomona College the following barriers, challenges and gaps were identified as significant and priority areas for next steps.

• Human resources & competing demands
  These are discussed and synthesized in detail in the Emerging Priorities section of this report.
• Physical & Organizational Location
  Documented concerns expressed by faculty, staff and students regarding the physical space of Title IX and the CARES Office presented throughout the course of our work. In particular, concerns have been expressed surrounding the perceived lack of confidentiality and privacy associated with the current physical and organizational location. This is a known barrier to reporting and compromises the accessibility of the space.
• Perception and campus culture
  These are discussed and synthesized in detail in the Emerging Priorities section of this report.
• Training Needs
  There is a need to strengthen training and create an infrastructure for sustaining critical training initiatives for Campus Security Authorities, Responsible Employees, first responders, as well as faculty, staff and students in general.
• Limited Pomona specific research
  Extensive research exists on factors that impact reporting and help seeking behavior related to sexual violence. The HEDS Survey provides us with limited insight into which factors are most salient for Pomona faculty, students and staff but is not generalizable. There is a need to learn more locally to inform and prioritize our efforts.
• Need for more assessment
  We need more information about the visibility and efficacy of our reporting resources in general. The recommendations in this report focus on anonymous online reporting, as concerns related to the utilization and accessibility of Callisto were shared in our research. Of particular concern is the cost of Callisto alongside the fact that it is not accessible to anyone other than individuals with a pomona.edu email address. As such, there are concerns that it does not lend itself well to The Claremont Colleges environment.

Reporting and Pomona

The Department of Education’s Office for Civil Rights requires every institution designate employees who may receive disclosures from students as responsible employees. Responsible employees also have reporting obligations. The Clery Act, another federal law, deems certain employees as campus security authorities (CSAs). CSAs also have reporting obligations, though much different than those of responsible employees. CSAs are not necessarily the same people deemed responsible employees. Under federal law, there are training requirements for responsible employees and campus security authorities.

Pomona College has a number of existing mechanisms for students, staff and faculty to report sexual misconduct, relative to themselves or others. These include in-person, telephonic, email and online reports to a number of different campus units, including the Title IX and CARES Office, the Dean of Students office, Athletics, Human Resources and the Associate Dean of the College. Each of these units also have a staff member designated as a Deputy Title IX coordinator. Sexual misconduct that also constitutes a crime also may be reported to the Claremont Police Department, independent of or in addition to a report to another campus unit.

By law, institutions of higher education must make confidentiality policies clear. Individuals wishing to discuss a concern with someone need to know the level of confidentiality someone has, what kind of reporting obligations they have and that they are trained.

Privileged and confidential disclosures may be made to professional, licensed counselors, pastoral counselors, the College’s employee assistance program and the Project Sister Family Services Campus Advocates at Pomona College.

Confidential disclosures may be made to college-designated confidential resources. These include the Director of the Queer Resource Center, the EmPOWER Center, and the College Ombuds. These individuals do have reporting requirements under Clery.

Confidential disclosures may be made to the Title IX Coordinator and Deputy Title IX Coordinators. These individuals have reporting requirements under Clery and are obligated to assess for a threat to community.

With respect to reporting, we want to ensure that these resources are commonly known and understood, that faculty and staff understand their reporting obligations and that individuals who have experienced harm have a full and complete understanding of the resources available to them as well as the processes that follow a report.

The vast majority (estimated to be 64-74% per the federal Bureau of Justice Statistics) of sexual assaults and attempted sexual assaults are not reported.

Our recommendations are aimed at ensuring that all members of the Pomona College community understand where and how to report as well as the benefits of reporting, which include connecting to resources, ensuring allegations are investigated by trained professionals, and improving campus safety.

Reporting Goals & Recommendations

Reporting Goal 1:

Pomona College offers robust gatekeeper/first responder workshops (designed for key target audiences and general interest) focused on cultural competency and trauma, ensuring individuals are adept at assisting survivors from various backgrounds in an informed, respectful and effective manner.

Reporting Recommendation 1-1:

Develop a plan and tracking mechanism for ensuring all Pomona College Campus Security Authorities and Responsible Employees receive in-person first responder training that includes information specific to their reporting obligations, as well as information about when, where, how and why to report. Identify ways to communicate these obligations regularly and resources to support these groups.

• Create print and web-based training resources for all CSAs and Responsible Employees that serve as a quick go-to for immediately accessible guidance.
• Send a once/semester email to all CSAs and Responsible Employees that reiterates their reporting obligations.
• Assess training to determine the extent to which new and existing training modules adhere to best practices.

Reporting Recommendation 1-2:

Develop a train-the-trainer model for gatekeeper/first responder workshops available to all students, faculty and staff (who are not CSAs or Responsible Employees) focused on cultural competency, trauma and guidance on what to do when someone discloses sexual violence.

• Identify high priority groups for this training (i.e. sponsors, mentors, student organization leaders, student athletes, etc.)

Reporting Goal 2:

Title IX and the CARES Office is the established go-to on campus resource. It is well known and highly regarded by faculty, staff and students. The Title IX and CARES Office is the hub for reporting, response, prevention and support resources related to all forms of sexual misconduct, domestic and dating violence, stalking, discrimination and harassment based on sex, gender and gender identity and/or expression. The Title IX and CARES Office is a trauma-informed office that provides a physical space wherein individuals can discuss their experiences with an empathic and knowledgeable person.

Reporting Recommendation 2-1:

Title IX, Clery and the CARES Office must be adequately staffed.

As the staffing structure for Title IX, Clery and the CARES Office was a point of discussion in each of the subcommittees, this recommendation by the full PAC-SVIP is supported by the Reporting Subcommittee and is outlined in detail in the Emerging Priorities section of this report.

Reporting Recommendation 2-2:

Title IX and the CARES Office must be located in dedicated space that is physically and psychologically safe and accessible to faculty, students and/or staff who wish to make a report, as well as for staff working in that space.

• Identify new space that is dedicated to Title IX and CARES, is more private and to achieve this goal in consultation with Title IX Coordinator as soon as possible.
• Relocate Title IX and the CARES Office to this new space as soon as possible.

• Develop a plan to promote the location of the office and the fact that it is accessible and offers improved privacy and confidentiality.

Reporting Goal 3:

The College possesses an evidenced-based understanding of the primary factors that impact reporting specifically for faculty, staff and students at Pomona. Strategies for mitigating and/or eliminating barriers to reporting are informed by this knowledge.

Reporting Recommendation 3-1:

Conduct qualitative research designed to develop a stronger knowledge of the most salient factors impacting reporting for faculty, staff and students at Pomona College.

Reporting Recommendation 3-2:

Based on the research noted above, develop a plan for addressing negative impacts and maximizing positive impacts on reporting at Pomona College.

Reporting Recommendation 3-3:

Develop a plan for responding to FAQs and educating the campus community regarding common barriers and/or concerns associated with reporting. These include explaining confidentiality issues/limitations, interim measures, the investigation process, on-campus and off-campus resources, and other relevant information.

Reporting Goal 4:

Pomona College offers and faculty, staff and students are generally aware of various disclosing and reporting options and what to expect should one choose to engage with a particular option. Enabling individuals who have experienced harm to make this choice on their own terms, without any pressure is of the highest priority at Pomona.

Reporting Recommendation 4-1:

Disclosing and reporting options should include confidential disclosure, anonymous report, Title IX report with a request for confidentiality, formal report seeking college adjudication, formal report seeking criminal charges. Reporting options are also available to third-party reporters.

Reporting Recommendation 4-2:

When someone makes a report to a confidential resource, those employees should be permitted to file an anonymous report on that individual’s behalf, if the reporting party desires.

Reporting Recommendation 4-3:

When someone makes a report of any kind, they have the option to identify the accused or simply document that the incident occurred.

Reporting Recommendation 4-4:

Develop a comprehensive plan to promote and educate the campus community on each disclosing and reporting options and where to access more information.

• This plan should include mechanisms for ensuring survivors and those engaging with them understand the difference between a disclosure and report.
• This plan should clearly define what is entailed in each disclosing and reporting option.
• This plan should clearly define the difference between a college designated confidential resource and a legally privileged confidential resource.
• This plan should clearly define the difference between confidentiality and privacy.
• This plan should clearly outline the roles and responsibilities of Deputy Title IX Coordinators, Responsible Employees and Campus Security Authorities and who these individuals are at Pomona College.
• Expand existing online resources (i.e. a handbook, video or perhaps interactive flowchart) to provide individuals with this information.
• Update existing print resources and design a plan for their distribution across campus constituencies at key programs/events and placement in prominent campus offices/locations.
• Develop tailored information for specific populations who may have unique concerns, such as undocumented students, male survivors, lgbtq+, etc.
• Consider adding reporting information on syllabi.

Reporting Recommendation 4-5:

Undertake comprehensive review of Pomona’s website as it relates to Reporting. As the website and the dissemination of information was a point of discussion in each of the subcommittees, this recommendation by the full PAC-SVIP is supported by the Reporting Subcommittee and is outlined in detail in the Emerging Priorities section of this report.

Reporting Recommendation 4-6:

Conduct a comprehensive review of concerns with Callisto and identify alternative online reporting tools with the support of the Project Management team at ITS at Pomona College.

• The anonymous online reporting tool should be user friendly, sensitive to the needs of the individual making a report (trauma-informed) and accessible to any individual wishing to make an online report.
• The online reporting tool should be equipped to allow the reporting party with the option to file a report anonymously or not.
• Ideally, if possible, this reporting tool would allow the reporting party to file a report for safe storage with a time/date stamp.
• This platform should also have the capacity to provide information about campus specific resources and support.

Reporting Goal 5:

Ensure that Pomona’s policies on the reporting of sexual misconduct and the processing of such reports remain accurate and relevant, ensuring they are up to date with any legal, organizational or process changes.

Reporting Recommendation 5-1:

Review and update existing policies to ensure they are clear and accessible to all audiences and contain accurate and clear descriptions of Pomona’s obligations, confidentiality standards and limitations, victims’ rights, and that they fully explain the investigation process and possible outcomes.

Reporting Recommendation 5-2:

Collect broader and systematic stakeholder feedback to inform the annual review of sexual misconduct policies by the Title IX Coordinator and Deputy Title IX Coordinators.

Background

The Response Subcommittee was chaired by Oona Eisenstadt. Derek Ishikawa, Meg Lodise, Brandon Johnson, Daniela Bond and Niles Brooks served as members of this group. Our mission was to improve the process by which formal reports seeking investigation and adjudication of sexual harassment, dating/domestic violence, sexual assault and stalking are handled. We hoped to identify ways to make it clearer, faster and less traumatic.

Sexual harassment, stalking, dating/domestic violence and sexual assault are crimes – and while some survivors turn to the criminal justice system, others look to their schools for help or recourse. Under existing federal law, when a school knows or reasonably should know that one of its students has been sexually assaulted, it is obligated to act. These two systems, the criminal justice and the college administrative process, serve different (though often overlapping) goals. The principal aim of the criminal system is to adjudicate a defendant’s guilt of potential crimes and serve public justice. A school’s responsibility is distinctly different; it is charged with providing an equitable and safe environment for all its students, faculty and staff. This can mean a number of things – from giving someone who has experienced harm a confidential place to turn for advice and support, to effectively investigating what happened, to ensuring fair and equitable hearings and the legal rights of all parties, to adjudicating cases and issuing appropriate sanctions.

Federal law, state law and court decisions provide campuses across the country with important requirements associated with process of investigation and adjudication of claims of sexual misconduct, harassment and discrimination. Title IX, the VAWA, memorandums from OCR, and ongoing court rulings all served as key documents and excellent resources in our review.

In addition to reviewing federal and state laws, we conducted research on best practices and the practices of peer institutions. As a result of that research, we selected and relied upon the Culture of Respect (CORE) Blueprint to guide our efforts. We also spoke to subject matter experts, talked to students, reviewed written pieces by students and reviewed the Higher Education Data Sharing (HEDS) Survey on Sexual Assault Campus Climate Survey (SACCS).

What We Learned

We began by trying to understand what Pomona College students saw as wrong with our process. To do this we (1) looked at lists of demands that have been brought to the administration by student organizations in the past three years,[3] (2) read pieces published by former Pomona students online that included concerns about their experiences with the process, (3) looked at HEDS survey data, and (4) held conversations with many individual students, including members of the 2018-19 student advocates for survivors of sexual assault. We developed a list of issues for examination and approached each one separately. When it was relevant, we also looked at the policies of other Colleges.

One thing of major importance became clear immediately: there is a widespread lack of knowledge among students on several aspects of the process. First, student demand-lists asked us to stop doing things that were not evident in our research of the practices of the College at that time, for example, encouraging survivors to take a leave of absence. Second, individual students asked us to do things we were doing, for example ensuring that a complainant can have someone with them during the hearing procedure. Third, our research suggested that many students (and some faculty) have the perception that cases are almost never resolved and that punishments are always light; for example, one student reported their research revealed widespread belief that the College has never suspended/expelled anyone for assault.[4] Fourth, individual students showed a lack of knowledge about what it is possible for the College to do under law, for example there were strong calls for a complainant not to have to tell their story more than once, a demand that is impossible to meet given fair hearing requirements. We wish to stress that students themselves understood this lack of clarity, at least partially. Fifth, the most frequent complaint observed in demand-lists and from individual students is a lack of transparency. Thus, on the central demand-list that we examined, more than half of the demands involve the publication of clear information about options in the process and the release of data.

For all these reasons, the sub-committee realized that enhancing clarity and transparency was going to be central to our recommendations.

Clarity and transparency are our central recommendations for another reason as well. While the following pertains directly to the work of the Support Subcommittee, the issues identified in the following matter are relevant to all of our subcommittee areas, to prevention, reporting, response and support.

Part way through the spring 2019 semester, the leadership team of PAC-SVIP decided to pause the student peer advocates program. Among the many individual reasons we had to make this decision, all related to concerns with trust: we had come to a point where the student advocates mistrusted the administration, and, to some extent, the administration mistrusted the student advocates. That was a situation that hurt survivors in obvious ways. If a survivor perceives they have to take a side, they will not make use of all the resources at their disposal. Worse than that, they will be confused. They may fearful or angry that, in a situation where they are already hurting, they may become enmeshed in someone else’s personal opinions, judgments and/or bid for political power. In short, polarization and mistrust across programs designed to support survivors is counter to an ethic of care and to do no harm. It was our understanding that this mistrust was widespread and growing. It seems to us that more transparency will allow students to see this. In other words, more transparency is necessary to restore the trust between students and the administration.

Response Goals & Recommendations

Response Goal 1:

Pomona’s investigative and adjudicatory response systems include: a comprehensive sexual misconduct policy; specialized and trauma informed training for all campus officials involved in investigating and adjudicating sexual and domestic/dating violence, stalking and harassment cases; and remain current with federal and state law, as well as with evidence-based best practices.

Response Recommendation 1-1:

The Title IX Coordinator, with the support of the Deputy Title IX Coordinators and Counsel should continue to conduct a comprehensive annual review of Pomona’s sexual misconduct policy, protocols and practices for investigating and adjudicating reported incidents of sexual misconduct, harassment and discrimination.

Response Recommendation 1-2:

Continue to assess best practices pertaining to evidence-based effective and appropriate sanctions for varied offenses of sexual misconduct and about evidence-based strategies for reducing recidivism.

Response Recommendation 1-3:

After a brief review of restorative justice practices, we wish to further evaluate restorative justice as a useful process in some cases of minor sexual misconduct and/or harassment. The subcommittee therefore offers a tentative recommendation: that restorative justice process be considered by the College as an additional option the Title IX Coordinator might offer in such cases.

• The central virtue of restorative justice is that it acknowledges individual and community harm. An incident of sexual misconduct erodes trust on a broad basis. Restorative justice seeks to repair that harm, first between complainant and respondent, and then in the broader community.
• This may require new training for the Title IX Coordinator and others who may be involved.
• This recommendation is tentative as we believe further research needs to be done around feasibility and community readiness.
• This recommendation is also contingent on other aspects of this report in part due to limited resources.

Response Goal 2:

Pomona College faculty, staff and students are generally aware of their options for resolution and especially the College’s process for investigations and adjudication of claims of sexual misconduct, harassment and discrimination. Helping individuals who have experienced harm to understand this process and make informed choices on their own terms, without any pressure is of the highest priority at Pomona.

Response Recommendation 2-1:

Undertake a comprehensive review of Pomona’s Title IX website as it relates to Response. As the website and the dissemination of information was a point of discussion in each of the subcommittees, this recommendation by the full PAC-SVIP is supported by the Response Subcommittee and is outlined in detail in the Emerging Priorities section of this report.

Response Recommendation 2-2:

Create one or more video(s) that cover topics such as options and resources, investigations and hearings, Title IX and the CARES Office, Title IX at The Claremont Colleges, etc.

• The video should be student-centered and explain what happens when students first visit the Title IX office, what student’s options are, what will happen when a student chooses a certain option, what the estimated time frame is for each step of the formal complain
• resolution process and factors that impact the length of this process, and the rights of individuals involved in the process.
• The text of the video should stress the ways in which those involved will be supported at each step, and the parties’ options for participating and withdrawing from the investigation and adjudication process.
• This is the kind of information that can sometimes be difficult to convey on a flow chart or web-site and will likely come across better if presented in a human voice. The video would take a step towards humanizing the considerable information already provided on paper and on the web.
• The video would have to be subject to review at times when the College’s policy changed in a substantial way.

Response Recommendation 2-3:

Information cards should be provided to faculty with a short list of people to call in various situations.

• This list need not be detailed. But there is no doubt, to mention only a couple of examples, that many, if not most faculty, do not know who in the Dean of Students Office is responsible for first-year (or a particular class of) students, or how to order a wellness check in the middle of the night. The card should also remind them that they are responsible employees.

Response Goal 3:

Pomona College fosters an open, transparent dialogue about reporting, recognizing, understanding and ending sexual violence.

Response Recommendation 3-1:

Pending legal consideration, explicit data should be released every five or ten years on the number of reports, the number of hearings, and the number and type of sanctions issued.

• Students, faculty and staff do not always understand the differences between Clery data and Title IX reports. This should be explained in print and in person during outreach presentations.
• Involvement in any complaint resolution process, especially one involving sexual misconduct, is a very private and confidential matter for individuals involved. The College is not permitted, by law and confidentiality, to comment on individual cases. Given the small size of the campus community, the College also cannot release a list of imposed sanctions annually, as cases would be too easy for others to identify, thereby compromising confidentiality. It might be, however, that we could compile this data on a five- or ten-year basis. It would go a long way toward building trust if the campus community could see that over a period of some years, there have been a certain number of expulsions, suspensions, and other forms of sanction/accountability.

Response Recommendation 3-2:

We recommend the College consider regularly holding an open forum in which students can meet with, engage in conversation with, share concerns with and ask questions of the President, the Dean of Students, and/or other key staff members.

• We believe communication is key to building community that is united in our efforts to strengthen the College’s efforts around sexual violence prevention, reporting, response and support. It is important to dedicate regular time and space for such communication, to share concerns, to listen for understanding and to partner around solutions. Open communication promotes accountability and transparency and will help to lift confusions and lay rumors to rest. Listening for understanding promotes empathy and inclusion. Conversation and dialogue promote relationships, shared responsibility and partnering around solutions.
• Such a forum will operate, for students, much like the faculty meeting operates for faculty. It could be supported by the president of the ASPC, who would get the word out and encourage attendance.
• We know that this recommendation is outside our mandate, as fora would address many issues that have nothing to do with sexual misconduct. We recommend it, nevertheless.
• We believe that encouraging healthy communication in general will augment trust and that augmented trust will alleviate many of the concerns associated with reporting sexual misconduct and meeting with the Title IX coordinator.
• Legal counsel could also be asked to participate in relevant meetings. Several issues that have come up on demands-lists or in conversation with students could then be addressed. A conversation with counsel could not only help answer questions, it would, we feel, be deeply reassuring to students, allowing them to see that there are real and caring people concerning themselves on the legal side of these matters.

Response Recommendation 3-3:

It is important that we are very clear about what we can and cannot say. We should be as clear as we can about our reasoning, and as precise as we can about why we cannot say certain things.

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Background

The support subcommittee was chaired by Sara Masland. Pharalyn Crozier, Nicole Desjardins Gowdy (Spring 2019), Sefa Aina (Fall 2018) and Molly Keller (Fall 2018) also served as members. Our focus was to assess student support efforts at Pomona College and to make recommendations about these services in light of best practices. Student support services encompass those which provide direct social, emotional, and/or organizational support to 1) survivors of sexual violence; 2) respondents to claims of sexual violence; and 3) the broader community, including peers of survivors and respondents.

In the spring of 2018, email invitations to participate in the Higher Education Data Sharing Consortium (HEDS) survey on Sexual Assault Campus Climate Survey (SACCS) were sent to 6,014 students across the Claremont Consortium. 25% of students responded (22% of Pomona students specifically, or N = 364), 79% of whom indicated that they knew how to access resources for sexual assault. While this may suggest that the majority of students know how to access support for themselves or their peers in the wake of sexual violence, this result should be interpreted with caution, in part due to potential sampling issues. For example, it is likely that individuals most interested in issues of sexual violence were those who responded to the survey and are also those who are more likely to know how to access services.

The HEDS survey results indicated that 15% of undergraduates have been sexually assaulted at an on-campus or college-sponsored event. This is largely consistent with the research literature on college sexual assault, which indicates that approximately 20% of women and 6.2% of men experience unwanted sexual contact in college (Cantor et al., 2015; Fedina et al., 2015; Krebs et al., 2007; Humphrey et al., 2000; Krebs et al., 2009; Cranney et al., 2015). First-year students are at greatest risk in party and non-party contexts (Cranney et al., 2015).

Sexual assault has serious psychological and functional consequences. The experience of rape is clearly implicated in the onset of posttraumatic stress disorder (PTSD), depressive disorders (e.g., Zinzow et al., 2012), and other psychopathology. This has been well demonstrated across contexts and demographic groups, including college students (Lindquist et al., 2013). A number of risk factors for the experience of sexual assault or other victimization have been identified, including substance use, the experience of previous sexual assault (e.g., Humphrey et al., 2000) and pre-existing mental health symptoms (e.g., Kaysen et al., 2006; Miron et al., 2014). For example, depressive symptoms may increase the risk for experiencing sexual violence (Krahe et al., 2017). This indicates that accessible mental health support services for all students, even if they have not experienced sexual violence during their time at Pomona, is likely to contribute to prevention efforts.

Support services are critical for ensuring the mental health and functioning of survivors. They are also critical for mitigating the effect of sexual violence on academic outcomes. A significant body of research indicates that sexual violence of various forms (e.g., rape, intimate partner violence; Brewer et al., 2018) results in lower GPAs and significant academic difficulties.

Further background on the prevalence, significance, and consequences of sexual violence on college campuses is provided in the CORE Blueprint (NASPA, 2017).

What We Learned

Our initial focus was on mapping the landscape of support services offered at the College. To this end, we met with various stakeholders and organizations to compile a comprehensive list of student support resources. These included Monsour Counseling and Psychological Services, the EmPOWER Center, and the Dean of Students Office. We reached out to but did not have the opportunity to meet with the McCalister Center for Religious Activities Chaplains. When available, we requested data on service utilization and efficacy. We sought information regarding the specific format of services, procedures for student outreach and enrollment, service utilization, and outcomes.

Once we had developed a sound understanding of current services available at Pomona College, we sought to evaluate those services in light of best practices. We paid particular attention to the Culture of Respect (CORE) Blueprint to guide our examination of student support services and best practices. This framework reflects a strategic effort to assess and improve how universities and colleges prevent and respond to issues of sexual violence. We also conducted a series of interviews with peer institutions to learn about their experiences developing support services, with particular focus on understanding the structure of their services, what has worked well, and what challenges they have faced.

Notably, much of the effort of this committee was dedicated to the pressing matter of dissolving and rebuilding the peer advocates program. Interviews with peer institutions were primarily designed to aid these efforts, significant research time was spent to ensure that any new programming was consistent with evidence-based practice, and the sub-committee chair, Sara Masland, participated in the interviews for the first cohort of new advocates.

Current Support Services

Peer Advocates

During the time this sub-committee was convened, significant changes to the peer advocate program were implemented. Notably, the CORE Blueprint includes recommendations for support services that are potentially relevant to a re-imagined peer advocate program. Recommendations for the new peer advocate program are included below under Support Goal 6.

EmPOWER Center

The EmPOWER Center is a 7C resource devoted to providing support to 7C students, faculty and staff effected by sexual violence, dating/domestic violence, stalking and sexual harassment; educating the community; and preventing sexual violence, dating/domestic violence, stalking and sexual harassment. Rima Shah, director of the EmPOWER Center, met with Sara Masland to discuss services provided as well as service utilization. In addition to Rima, the Center is also staffed by a grant administrator and student interns.

The EmPOWER Center provides unlimited counseling sessions to any 7C student effected by sexual violence, dating/domestic violence, stalking and sexual harassment, broadly defined. This can include survivors of sexual violence and friends/family and those seeking guidance in how to best support survivors. The EmPOWER Center has also provided limited support services for respondents (i.e., those who are accused of sexual misconduct or questioning whether they have committed an act of sexual misconduct). Counselors are trained staff from Project Sister Family Services, a local community resource. Project Sister staff are currently on-site at EmPOWER 5 days/week. This has been increased from 2-3 days/week over the past several years in response to demand. Counselors provide 1-on-1 support, as well as group support. Students may also receive support over the phone, which effectively makes this service available to students who are studying abroad or in domestic off-campus programs. One limitation to this access, however, is that the different time zones students may be studying in may make it difficult to contact EmPOWER Center during business hours.

Enrolled groups (support groups with a defined beginning and end date with expected enrollment and attendance) have been successful in terms of adequate enrollment numbers, low attrition, and student satisfaction. Drop in groups have not yielded the same success in terms of enrollment and attendance. Notably, past groups were limited to women—a group for non- binary students was offered once, but low enrollment led to its premature end. Non-binary students may still receive 1-on-1 support. Since the time of this writing, we have learned a mixed-gender support group will be offered Fall 2019. Student interns lead additional groups throughout the academic year (e.g., art for healing).

The Center is housed at 1030 Dartmouth Avenue, and employs a safe-house like system for access. The front entrance is locked, and visitors must ring a doorbell to gain entry. This ensures that once inside, visitors feel and are safe. However, due to limited staffing, there is occasion when someone is not available to answer the door. While not a common occurrence, there is the ` potential this may happen and could cause someone who has been harmed and is seeking help to feel discouraged. While someone can contact EmPOWER via phone for help, staffing levels at EmPOWER should adequately ensure someone is always available to answer the door during normal business hours. The Center also has a confidential back entrance. When students arrive for counseling appointments, they have the option of using this back entrance. It is equipped with a separate door buzzer, which alerts the counselor that someone has arrived at the confidential entrance. A curtain can then be drawn to separate the entrance from the rest of the building (where student interns, other visitors, and other staff may be present). This ensures that the visitor is seen only by the counselor with whom they have scheduled an appointment.

In the 3 years the EmPOWER Center has been running, they have increased their services in response to demand. Originally, a Project Sister counselor was on-site 2 days/week. That first increased to 4 days/week, and then to 5 days/week (this second increase from 4-5 days/week was made possible by grant funding).

Students from all colleges have used EmPOWER. In Fall 2017, 50 students were supported. During this semester, Pomona and Scripps students were the most frequent visitors. In Fall 2018, 54 students were supported and Pomona, Scripps, and HMC students were the most frequent visitors. Students were predominantly female, were both new and continuing (i.e., had received services in past semesters), and were supported via one-on-one counseling and/or group counseling. Race/ethnicity data were not available. Utilization rates by College are collected but are not reported publicly here to preserve confidentiality. In Spring 2018, the Center began tracking reasons for support: there were 42 sexual assault survivors, 11 dating/domestic violence survivors, and 1 stalking survivor.

Outcome tracking of counseling and support group services offered at the EmPOWER Center is conducted by Project Sister. Project Sister does not release all of the data in an effort to protect confidentiality. We therefore do not, at this time, have a sense of attrition rates, satisfaction, or whether the services provided successfully attenuate distress/symptoms of psychopathology, lead to desired long-term outcomes, or prevent poor functional outcomes of interest (e.g., academic distress). One piece of available data comes from a survivor support group conducted in 2017-2018: all 6 participants in this group rated the services as “strongly helpful” (5 on a 5-point scale).

Monsour Counseling and Psychological Services (MCAPS)

During the Fall 2018 semester, Sara Masland met with Fiona Vajk, Assistant Director and Training Director of MCAPS. Fiona outlined the services available at MCAPS. At the time of the meeting, students could receive 8 sessions of individual therapy each year. She noted that this is a soft limit, and that exceptions are sometimes made if clinical assessment indicates that a few more sessions are needed or that referral to another provider is contraindicated. She also noted that this limit is relatively new. In recent history, the limit was 6 sessions/semester, which was then scaled back to 10 sessions/year, and then again to 8 sessions/year. These changes were made in response to changes in demand and staffing levels.

Counselors at MCAPS use a range of methods and therapeutic approaches (e.g., integrative approaches). Although students can use 8 sessions/year, the modal number of sessions used per year is 5 (at both MCAPS and according to national numbers from college counseling centers), which indicates that many students who successfully access MCAPS are not using all of the available sessions.

At the time of this conversation, the current waitlist at MCAPS was 2 weeks. It had been as high as 4 weeks in Fall 2018, in part due to staff changes and medical leaves. MCAPS, at the time of this interview, was staffed by 8 FTEs and 4 post-doctoral fellows. The case load for FTEs varies, but each FTE is expected to devote 60% of their time to direct clinical hours. Assuming a 40- hour work week, this would translate to 192 hours of therapy available each week (excluding services provided by post-docs, which would add an additional 96 hours, for a total of 288 hours/week).

At the time this report was written, changes to MCAPS were in the process of implementation, including the hiring of additional staff, changes in funding and payment, and augmentation of the maximum session limit.

In addition to individual therapy, MCAPS also runs a number of groups. Prior to the EmPOWER Center’s establishment, MCAPS ran a group for survivors. However, as EmPOWER now meets this need, students stopped enrolling in the MCAPS group and it was terminated. For students currently off-campus (e.g., at international or domestic study away programs), MCAPS on-call counselors are available for a single session consultation.

In times of crisis, students may be seen on a walk-in basis during normal business hours. After hours, they are directed to an on-call therapist via the MCAPS phone. They may also contact the Chaplains, Campus Safety, the Dean on Call, or a number of hotlines housed outside of Pomona (e.g., the National Suicide Hotline, Crisis Text Line, The Trans Crisis Line).

MCAPS tracks outcomes (pre/post-treatment diagnostics, interval symptom measures, satisfaction). The support sub-committee has requested this outcome data to inform future recommendations for existing and/or additional support related programs/services.

Study Abroad and Domestic Off-Campus Study Programs

Pomona students regularly attend a wide range of international study abroad programs as well as domestic off-campus study programs. Approximately half of all Pomona students attend study abroad programs, typically during their junior year. Over the past five years, this averages to 101 students abroad per semester. Participation in domestic programs and exchanges is also steady, with a five-year average of four students participating each semester. Pomona students remain enrolled at the College while participating in approved off-campus study programs and continue to pay their Pomona tuition. While students have a reasonable expectation of access to services available to them on-campus or comparable alternatives while studying in an off-campus program, it is equally important to acknowledge the limitations associated with varied cultural norms, laws, regulations and resources abroad. It is important to note that support for students studying in an off-campus program may involve extending support for incidents that have occurred prior to the off-campus study, for incidents that occur while studying off-campus, and for the continuation of support when students leave off-campus programs and return home.

Study abroad programs include direct-enroll programs managed by foreign universities, programs run by U.S.-based or international third-party providers, and programs run by Pomona College in partnership with foreign universities and/or U.S. college consortia. Domestic programs include Claremont McKenna College’s Washington Program and Silicon Valley Program; the Marine Biological Laboratory Semester in Environmental Science at Woods Hole; and domestic exchange programs with Spelman College, Colby College, and Swarthmore College. Students studying off- campus study in a variety of settings such as foreign universities, other U.S. colleges, courses taught by U.S.-based third-party providers, courses taught by faculty contracted by Pomona College or one of our consortia, internship sites, field stations, and research laboratories. Off-campus program housing includes home stays, residence halls with local and international students (in the U.S. or abroad), apartments with other program students, apartments with local and international students, field stations, hostels, guest houses, and other accommodations.

The variety of program types and resources available introduces a host of complicated dynamics that make the process of negotiating support around issues of sexual violence more difficult and less transparent. This is particularly true when survivors and respondents attend different home institutions, a situation that arises even outside of the context of off-campus study. Additionally, many if not all international universities and third-party providers are not bound by Title IX, although many do have their own sexual misconduct policies and procedures. Furthermore, in many cases, students abroad live in large urban environments and navigate and interact in much more public spaces than they tend to use in Claremont. Socializing abroad happens frequently in cafes, bars, and clubs in host communities, which puts students into contact with individuals not associated with their program or host institution. Students abroad also tend to include independent travel in their semester and visit a wide range of cities and countries on their own, outside the auspices of their program structure. Some programs also include local and international travel as part of their academic and extracurricular activities. Each of these trips introduces a new set of cultural norms, legal structures, interpersonal dynamics, and settings in which students must adjust and learn to navigate on their own.

Students attending foreign universities and third-party provider programs find a range of depth and breadth of services to support students facing issues of sexual violence. They may or may not have access to mental health counseling, survivor support and advocacy resources, counseling for respondents, on-campus medical care, academic accommodations, and other key avenues of support through their programs. The availability of resources in their program cities also varies. In some cases, access to services in English may be limited. Depending on factors such as local customs and laws, definitions of rape and sexual assault, criminal procedures, students’ relatively short stay in the host city, and perpetration of violence by strangers not associated with their programs, the safety of and access to legal or disciplinary action may present particular challenges. For example, in countries where certain behaviors are criminalized (such as homosexuality or pre-marital sex), survivors might put themselves at further risk if they choose to pursue criminal or legal action. This highlights a key need for knowledgeable and sensitive on-site staff to help guide students through the legal, institutional, and cultural environment they are in. Selection of program partnerships should be made with this consideration in mind.

Insurance is another key component of care and support for students abroad. The insurance provided by study abroad programs may or may not cover services such as mental health counseling and STD/HIV testing. Medications such as Plan B and Post-Exposure Prophylaxis may or may not be available in their host countries and may or may not be covered under the insurance provided by their programs. Students abroad all have insurance provided by Pomona College through AIG and the International Student Identity Card (ISIC), which covers emergency medical care and evacuation. Mental health coverage through these plans is limited, though they would be likely to cover therapy for trauma experienced abroad. Students are also expected to maintain their primary insurance coverage while abroad. In many cases however, including for students on the Student Health Insurance Plan (SHIP), students studying abroad may be expected to pay up front for services and submit claims to the insurance provider for reimbursement. In such cases, the College should consider whether financial resources may be extended to assist.

As far as Pomona’s resources are concerned, for students currently off- campus (e.g., at international or domestic study programs), Monsour’s on-call counselors are available for a single session consultation. The EmPOWER Center is also available to students by phone, however communicating across time zones may make it difficult for some students to access the Center during business hours. The Dean of Students Office also offers a free distance counseling program for international students (the Morneau Shepell International Student Support Program), which provides access to a culturally knowledgeable person and therapy in a variety of languages. Although this is geared toward international students, it has been leveraged for students who are abroad because it is accessed via phone, web, or text. Students may use this service for ad hoc counseling sessions as needed or for more regularly scheduled therapy sessions. It is an important service that provides easy access to counseling for students all over the world and is particularly important for students in places without access to culturally- competent, English-speaking counselors. While there is empirical support for tele mental health interventions broadly speaking (e.g., Hailey et al., 2008; Hilty et al., 2013), there is also evidence that tele mental health may be less comfortable for individuals seeking services (e.g., Jenkins-Guarnieri et a., 2015)—a finding that may be particularly relevant in the context of sexual violence. In cases where students do not have other options for counseling, this service presents a reasonable stop-gap alternative, however, consideration should be made for in-person mental health care when possible, as a priority.

To prepare them for the off-campus experience, students going on international programs participate in a general pre-departure orientation that includes information and resources on sexual violence as well as support resources available at Pomona and more generally on their programs. In some cases, students also participate in program-specific pre-departure orientations hosted by their program providers. Additionally, students participate in on-site orientations led by their host universities and/or program providers that include information on sexual violence and local resources. Approved programs have student affairs staff who are able to support students in cases of sexual violence. Staff at Pomona in the Office of Study Abroad, Dean of Students, Title IX, and other relevant offices are available and regularly communicate with students abroad seeking support to help them navigate their resources. Depending on the program, students on domestic programs may or may not have a pre-departure orientation and participate in on-site orientations offered by their programs. The Dean of Students, Title IX, and other relevant staff at Pomona remain available to offer support.

The diverse nature of off-campus study programs both domestically and abroad highlight the need for 1) strong partnerships with program providers, 2) consideration of local circumstances and available resources in approving new programs, 3) clearly outlining support available, and 4) providing assistance for navigating the variety of resources for students participating in these programs.

Distributed Supports and Confidential Resources

In addition to the support services provided by specific programs, students may also seek support from student health services, the Dean of Students Office, from on-call Deans, from College Chaplains, and from Campus Security. There are also a number of individuals on campus who are designated as confidential resources. Students may speak with them about issues of sexual violence without the requirement that instances of sexual violence be officially reported under Title IX. The 7C support and prevention website lists confidential resources across the campuses. These services are important for students who feel the need to speak with someone, but who are not ready to report or who may never wish to report. Below, we recommend that the number of confidential resources be expanded, and particularly within centers that serve underrepresented students (e.g., the CLSA, the OBSA).

Pomona on-call Deans, prior to this year, did not receive trauma-informed training on how to respond to a survivor of sexual assault. Effective this summer (2019), Pomona on-call Deans will receive in person trauma informed training on best practices for supporting survivors. On-call Deans also receive a manual which details how to support students in a variety of situations, including after a sexual assault. On-call Deans are also trained by shadowing someone on-call for a week prior to joining the on-call rotation. During this week of shadowing, on-call Deans learn appropriate documentation and protocol in relation to the issues that come up. On-call Deans also have the ability to consult with other members of the on-call team when issues arise that are beyond the scope of their knowledge.

Support Goals & Recommendations

Support Goal 1:

The College contributes to support a staffing and funding structure at the EmPOWER Center to meet the demand for safe, confidential survivor support services. These services include individual and group counseling. Counselors use therapeutic approaches empirically grounded for the treatment of presenting problems associated with trauma and sexual violence, dating/domestic violence, and/or stalking.

Support Recommendation 1-1:

The EmPOWER Center’s staffing is currently supported in part by significant grant funding. It is one of the strongest recommendations of this committee that the College work with our 7C partners to prevent the possible grant expiration from impacting EmPOWER’s services, which may include the provision of additional stop-gap or permanent funding.

Support Recommendation 1-2:

Create a “rainy-day fund” for use at the discretion of the EmPOWER Center.

• Currently, the Center has been able to provide services without a waitlist. However, this has at times required the Center to pay for more hours from Project Sister counselors. A rainy-day fund would allow for the Center to hire counselors on an “as-needed” basis to ensure both that no survivor has to wait for services and that the integrity of other programming is protected.

Support Recommendation 1-3:

Provide a dedicated fund to help students with transportation to Project Sister and other mental health resources off campus.

• During the course of our interviews, we discovered that this funding is sometimes available to students. However, because it is not formally articulated within our written policy, students are largely unaware of its existence. Students are able to utilize the Foothill Transit Class Pass to travel within Los Angeles County for free. While this is a resource for students, it does not offer door-to-door transportation for survivors in the wake of a sexual assault. Since some students prefer to seek services at Project Sister to avoid interacting with other students around these issues or being seen leaving EmPOWER Center, we recommend that students have access to a fund for transportation costs. This fund could be overseen by a confidential resource, such as EmPOWER. This recommendation is consistent with the CORE Blueprint’s call to increase access to off-campus mental health resources.

Support Recommendation 1-4:

Ensure that services are available to trans and non-binary students.

• EmPower Center provides services for students, faculty, and staff regardless of gender identity and expression, sexual orientation, age, ability, ethnic and racial identity, religious affiliation, cultural identity, and immigration status.
• At the time this report was written, support groups were not available for student survivors who identify as male, trans masculine, or non-binary. EmPOWER (with Project Sister, who provides the group leader) has attempted to offer a drop-in group in the past, but attendance was limited, which raised concerns that 1-2 individuals does not make a group and is not conducive to the group counseling process. The lack of a support group for diverse gender identities further challenges the Consortium’s OVW grant terms and Title IX guidance related to providing comparable services to all students.
• We understand a mixed-gender support group will be offered Fall 2019. We strongly support this resource and recommend that a group open to diverse gender identities be offered each semester through the EmPOWER Center or perhaps an alternate venue, at a time likely to facilitate attendance (which may be best determined by polling the student body). Given the challenges to date with enrollment, these groups should be heavily advertised to increase enrollment.

Support Recommendation 1-5:

Collaborate with the 7Cs to support a new FTE staff person at the EmPOWER Center.

• Currently, the reception area of EmPOWER is overseen by student interns. While student interns at EmPOWER do good work, they are not able to be there for all of the hours the Center is open, nor are they able to help with many of the administrative tasks currently handled by the Director. Hiring an administrative support at EmPOWER would ensure that any survivor who visits EmPOWER during normal business hours is able to access the Center. It would also free the Director from administrative tasks that often compete with the essential work of the EmPOWER Center, including the provision of support, educational programming, prevention efforts, and grant submissions.

Support Goal 2:

Outcome tracking of the Project Sister Campus Advocates at Pomona College and individual counseling and support group services for survivors at EmPOWER and MCAPS is comprehensive and shared in a manner that does not compromise confidentiality. Data is collected that relates to utilization, attrition rates, satisfaction, or whether the services provided successfully attenuate distress/symptoms of psychopathology, lead to good long-term outcomes, or prevent poor functional outcomes of interest.

Support Recommendation 2-1:

Implement enhanced outcome tracking for survivor support services.

• It is essential that survivor support services are accessible and effective.
• It is recommended that outcomes are tracked across a range of areas, including mental health (e.g., symptom measures), satisfaction with services, and academic outcomes (e.g., retention) as appropriate.
• When possible, outcome data should be collected in such a way that outcomes may be evaluated specifically for underrepresented or marginalized students, as well as those students who have experienced directly, or have been indirectly impacted by, sexual violence.

Support Goal 3:

The College offers accessible, safe and confidential support services for individuals accused (be it formally or not) of having engaged in behaviors that may constitute sexual violence, dating/domestic violence, sexual harassment and/or stalking. These services utilize therapeutic approaches empirically validated for the treatment of the associated presenting problem(s).

Recommendation 3-1:

Establish respondent services outside of the EmPOWER Center.

• The College currently provides case managers for all parties to a complaint, in addition to permitting parties to have access to support persons and advisors throughout the process; although case managers provide parties with additional opportunities to get information about the process and related support services, the College has received feedback that additional support resources are needed for students responding to allegations of misconduct.
• In the absence of such an established resource, the EmPOWER Center has filled this need on rare occasion. This may include conversations and counseling related to questions about whether one has acted inappropriately, supportive counseling for respondents as they navigate allegations, and beyond. While we believe that these services should be available, it is critical that they be transparent and housed outside of the EmPOWER Center. The relatively small space of the EmPower Center and the potential for complainants and respondents to inadvertently run into each other at the EmPower Center strongly necessitates separate spaces for respective parties to a complaint.
• We recommend that a small work group, comprised of staff with expert knowledge and who are currently in student support roles, be convened to determine the best location and procedure for respondent services at Pomona College.

Support Goal 4:

The College contributes to support a staffing and funding structure at MCAPS to meet the demand for evidence based, culturally competent individual counseling services related to sexual violence, dating/domestic violence, stalking and/or sexual harassment. Counselors use therapeutic approaches empirically validated for the treatment of presenting problems associated with trauma and sexual violence, dating/domestic violence and/or stalking.

Support Recommendation 4-1:

Collaborate with the 7Cs to increase staffing at MCAPS.

• Once established, outreach efforts to publicize increased capacity and remedy the perception of understaffing will be important.
• While increasing staffing levels at MCAPS, emphasis on the recruitment of staff who understand intersectional and marginalized identities will help mitigate expressed student concerns about finding such a therapist at MCAPS.
• At the time this report was written, recent changes were being implemented at MCAPS. These changes align with our recommendation, and we leave this recommendation in place to emphasize our support for the changes and the importance of continued assessment of staffing levels.

Support Recommendation 4-2:

Allow more sessions for survivors of sexual violence.

• With increased staffing, we recommend MCAPS evaluate the ability to provide services for students who have experienced sexual violence with long-term services. This is consistent with the CORE Blueprint, which calls for access to long-term services. Additionally, many of the negative mental health outcomes of sexual violence are likely to demand more than 8 sessions of therapy. For example, the major evidence-based psychotherapies for post-traumatic stress disorder (PTSD) require a minimum of 12 sessions (e.g., Cognitive Processing Therapy).
• At the time this report was written, changes were being implemented at MCAPS, which include increasing maximum sessions. We fully support that change. We recommend that survivors have additional access to resources and sessions above the increased maximums when clinically appropriate.

Support Recommendation 4-2:

Counseling staff treating survivors should be trained specifically in evidence-based practices for outcomes common to the experience of trauma.

• In light of a robust research literature on evidence-based practices for outcomes common to the experience of trauma, additional specialization is recommended for treating professionals. For example, there are well-established, empirically supported treatments for PTSD. The American Psychological Association publishes a list of supported therapies, and we recommend that those treating survivors possess training in some of these evidence-based approaches:
• This recommendation is consistent with the CORE Blueprint recommendations, which highlight the need for available and accessible mental health care with diverse payment options, specifically trained counseling staff, and access to long-term services.

Support Goal 5:

Pomona College has strong partnerships with study abroad program providers, considers local circumstances and available resources for students studying abroad in approving new programs, clearly outlines supports available while abroad and provides assistance for navigating the variety of resources for students participating in these programs. Partner programs have knowledgeable and sensitive on-site staff to help guide students through the legal, institutional and cultural environment they are in. Students are able to access services available to them on-campus or comparable alternatives while studying in an off-campus program.

Support Recommendation 5-1:

Develop a resource for off-campus study abroad participants that informs students of related rights and responsibilities and acknowledges the fact that cultural, institutional, and legal norms and procedures vary based on host institution and host country.

Support Recommendation 5-2:

Determine which on-campus resources are available to students studying off-campus and how services may vary. Prepare a list of resources (Pomona/7C, local, international, U.S., etc.) available to students while studying off-campus and provide to students before they depart and as needed in the event of sexual misconduct.

Support Recommendation 5-3:

Include information about sexual misconduct in pre-departure orientations to prepare students for cultural and institutional differences as well as the resources available to support them.

Support Recommendation 5-4:

Develop training and materials for first responders on campus to provide general education about the off-campus/study abroad contexts and about resources available to students through their programs and local communities.

Support Recommendation 5-5:

Consider resources and support available through programs when identifying potential program partners. Ensure affiliated programs meet Pomona’s expectations for student support, or that there is a reasonable alternative for local support when not available through the program. Develop strong relationships with program partners to increase capacity for collaborative support efforts between home and host institutions.

Support Recommendation 5-6:

Review insurance provided through SHIP in consideration of students’ access to medical and mental health care when studying off-campus. Where students may be expected to pay upfront costs and submit claims for reimbursement later, identify ways to support students with high financial need in this process.

Support Goal 6:

The CARES Office at Pomona College makes available confidential peer support services for students who have experienced sexual violence, dating/domestic violence, stalking and/or sexual harassment. Students providing peer support are appropriately trained, have the privilege of confidentiality and operate in alignment with best practices and within a program that provides clear structure, oversight and integration with supervision and support.

Support Recommendation 6-1:

Continue, and appropriately support, efforts to strengthen the peer advocate program at Pomona College.

• Efforts are currently underway to establish the CARES (Campus Advocacy, Resources, Education, and Support) Office, which includes re-envisioning peer survivor support services and peer education.
• Peer support programs are one way to ensure the type of access to resources outlined by the CORE Blueprint, and it was clear from interviews with similar institutions that peer support (and peer education) are vital parts of a supportive and proactive campus culture. A number of salient recommendations arose from those interviews.

Support Recommendation 6-2:

Student/peer advocates should operate within a program with clear structure, oversight, and integration with administration. For the safety and wellbeing of survivors and advocates alike, for continuity across years, and to ensure accordance with best practices, it is critical that the program operate with oversight.

• We strongly recommend that the source of this oversight come primarily from a new staff hire dedicated to support programs and services at the College (see support recommendation 9-1) .
• Internally, we also recommend a formal structure. Peer programs at other colleges all have some internal working model for delegation of tasks and responsibilities, supervision, and internal oversight.

Support Recommendation 6-3:

Student/peer advocates should complete significant training, should sign written agreements to abide by training principles and College policies, and should be required to participate in ongoing (e.g., weekly) supervision.

• The structure and frequency of trainings and ongoing supervision varies across peer support programs, yet all have clearly articulated processes for both. Potential model training materials, training schedule, and advocate agreement, are available from Middlebury College and other peer institutions.

Support Recommendation 6-4:

The hiring process for the student/peer advocates should be driven by staff and students in collaboration and should have a clear structure. Across all aspects of the CARES Office programs and services, student voices should be valued and supported. This is particularly true in the hiring process. However, staff must make final hiring decisions, based on interviews, student recommendations, external recommendations, and background checks.

Support Goal 7:

Distributed supports and confidential resources across the College are well-trained, address the needs of individuals who have experienced sexual violence, dating/domestic violence, stalking and/or sexual harassment, and are in alignment with best practices.

Support Recommendation 7-1:

Provide further training to on-call deans and assess training for campus safety and college-designated confidential resources.

• On-call deans should be required to complete training that provides them with basic knowledge of how to support survivors from a trauma-informed lens.
• This training should include information about reporting within the college and to the police department so that on-call deans can accurately relay reporting options to survivors.
• On-call deans should also be trained on the process of a SART exam and where to obtain such an exam so that they can speak knowledgably to survivors about such exams.
• Campus Safety’s mandated training should be assessed to ensure that they are trained in a trauma-informed approach that is consistent with best practices of law enforcement.

Support Recommendation 7-2:

Offer training to all faculty and staff, with a particular emphasis on faculty and staff in first responder roles.

• Many faculty and staff, beyond the on-call deans, are the first point of contact that a student may turn to for support, though many have not been trained as student affairs professionals or in trauma-informed responses. Providing relevant and situation-appropriate trainings to help all faculty and staff develop strategies, knowledge, and confidence for supporting students in need would greatly enhance the capacity of our community to respond to students in cases of sexual violence. Topics such as mental health first aid and survivor support, with a trauma-informed approach, would be beneficial to all those to whom students may turn in times of need.

Support Recommendation 7-3:

Strategically increase the number of confidential resources.

• We recommend that at least one staff person from each cultural center be identified as a college-designated confidential resource. This may be the Director of each center (e.g., the Director of the QRC is currently a confidential resource), but there may be someone else in the office more equipped and/or some directors may feel uncomfortable serving in this capacity. Some students from marginalized populations are likely to feel more comfortable going to an identity-based center first. They can then have a warm handoff to a specialist by someone they trust.

Support Recommendation 7-4:

Consider staffing solutions that would allow for SART exams at the student health center.

• Currently, students can complete Sexual Assault Response Team (SART) exams at Pomona Valley Hospital. These exams are initiated and paid for by the local police department, but only if they are notified of a sexual assault. Once notified of a sexual assault, the police contact a Sexual Assault Nurse Examiner (SANE) to complete the exam. These nurses are contracted through Forensic Nurse Specialists and an exam costs about $800 to complete, per Claremont Police Department. If the survivor is unsure about reporting the sexual assault to law enforcement but would still like to receive a SART exam they can contact Project Sister and discuss getting a Violence Against Women Act (VAWA) exam. The experience of marshalling personal and practical resources to find and get to a hospital that can provide SART exams is extremely challenging. While a full-time staff member qualified to conduct SART exams may not be needed, and would likely be prohibitively expensive, we recommend that the College consider the feasibility of and creative solutions for coordinating an on-call resource available to students so that they do not need to leave campus for this critical evaluation.

Support Recommendation 7-5:

Support the development of and participation in a plan for managing the 7C support and prevention website.

• This website is a critical source of information, that is important to maintain, keep up to date and ensure a user-friendly experience.
• Additionally, outreach efforts should be used to ensure that students, faculty, and staff are aware of the website. CORE Blueprint specifically recommends that the link to resources be made available across domains (e.g., on the athletics website, in any guidebook provided to students). We tentatively propose that a Title IX student intern or graduate assistant could be used to support these efforts.
• We further recommend consideration and support of convenient dissemination tools for information about resources. One example of this may include the keycard holders that students receive. Because the holders are handed to every student, and do not rely on students to “opt in” by picking up material, printing information about resources (e.g., a website link) on these holders would ensure dissemination of knowledge.

Support Recommendation 7-6:

Make Post-Exposure Prophylaxis for HIV (PEP) available on campus.

• Although there may be some organization or regulatory issues that must be sorted through to make this possible, we consider this an important support for students. Currently, students can purchase Plan B from vending machines, yet they cannot access PEP through any campus resource. Making PEP available would make this safe and effective treatment accessible to students in the wake of sexual violence. It would have the additional benefit of improving accessibility to this product for students engaged in consensual sex, or any other activity for which HIV exposure is a concern.
• This recommendation is consistent with the CORE Blueprint’s call for timely access to medical services. Furthermore, information on how to obtain PEP should be added to the 7C support website, which currently includes information about obtaining Plan B but not PEP.

Support Recommendation 7-7:

Improve student understanding of available resources and policies.

• It became apparent over the course of our interviews, research, and informal conversations with students, faculty, and staff, that there is often poor understanding of resources and policies.
• This is particularly relevant to students who are off-campus, who may have limited information about what on-campus services they can still use, as well as how to navigate various services available to them in their current location or within their current programs and how these services may complement or work in tandem with campus-based services.
• Similarly, we also recommend that actions are taken to improve the visibility of confidential resources. Students may not know what a confidential resource is, or how to find one. We recommend that efforts are made to increase the visibility of existing confidential resources. These efforts may take many forms (e.g., a video of confidential resources that is played at orientation, which would allow students to see what the confidential people look like instead of just where they are located; and/or a space on the EmPOWER site that has their pictures and contact information.

Support Goal 8:

Pomona College is dedicated to support programs and services that align with evidence-based, best practices surrounding service delivery and assessment.

Support Recommendation 8-1:

The CORE Blueprint outlines several recommendations specifically for support services, which accord with the subcommittee’s recommendations and is in many cases consistent with current support services provided by the College. A rough outline of these are listed here. We recommend adopting the CORE Blueprint as an overarching framework for considering changes to support services for students, and echo the recommendations made elsewhere for the establishment of a Pomona CORE Blueprint Committee.

• Facilitate housing changes
• Offer exam extensions
• Offer distance learning
• Ensure 24/7 access to advocacy services
• Provide acute medical response
• Make crisis and ongoing mental health care available and accessible
  • Offer diverse mental health payment options
  • Facilitate access to off-campus mental health providers
  • Provide affordable long-term services
  • Ensure providers are trained in treating survivors of sexual violence
• Offer tuition reimbursement options on a case by case basis

• Refunding the full tuition for the semester
• Retaining charges for tuition but allowing the student to return the following semester as a full-time student free of charge or with a full scholarship
• Providing partial reimbursement for the duration of time that the student will not be on campus during the semester
• Extending scholarships previously provided to the student to include an additional semester and summer session

Support Goal 9:

The CARES Office is fully staffed and funded to meet the demand for safe, confidential support services offered by the College. These services include peer advocates, respondent services, personal support and information and referral services. These services are provided by and overseen by a professional with relevant experience and expertise.

Support Recommendation 9-1:

Establish a permanent FTE staff person dedicated to overseeing support programs and services at the College, including the student peer advocates and support services for both individuals experiencing harm and for respondents, as well as to address community harm related to sexual violence, dating/domestic violence, stalking and sexual harassment.

• Several of the interviewees mentioned, without prompting, that having a staff positions dedicated to issues of sexual violence support and prevention was critical not only to signaling to students that the administration cares about these issues, but also to the successful maintenance of peer support and peer education programs.
• Some of these positions also allow for staff to function as case managers or emotional supports for students engaged in the Title IX process (e.g., staff may help students navigate complex legal situations that are outside the purview of peer support, or may provide support to survivors in Title IX meetings).
• The College benefits from EmPOWER with regard to support and prevention efforts. However, as a 7C resource, EmPOWER’s ability to devote resources specifically to Pomona are inherently limited and does not allow for the full range of survivor support that other colleges offer.

• For example, Williams College and Middlebury College both have two FTEs dedicated to prevention and support. Bowdoin College and Amherst have both have one FTE dedicated to prevention.

Background

As is evident in this report, throughout the course of our work, each of the sub-committees identified unique opportunities and challenges associated with our Consortium environment. While each campus has a unique culture, history and student body, our students also share experiences, attend classes and social events across campuses and benefit from programs, services and initiatives across the 7Cs. All of this must be recognized and carefully considered in our efforts to strengthen our work around sexual violence prevention, reporting, response and support.

There is strong collaboration among The Claremont Colleges Presidents, Student Deans, Title IX Coordinators, the Coordinated Campus Response Team (CCRT) and EmPOWER focused on strengthening and coordinating our efforts around reporting, prevention, response and support. This work is further supported by our work on the Office of Violence Against Women (OVW) grant managed by EmPOWER.

Campus Safety, the Claremont Police Department, and Project Sister Family Services (our local community-based rape crisis center) work closely with Pomona College and the 7Cs to coordinate our efforts and best support individuals impacted by sexual violence.

While our charge was to focus on sexual violence prevention, reporting, response and support at Pomona College we appreciate the interplay of our unique campus cultures, shared resources and the importance of our Consortium environment in this work. This section of our report represents our effort to speak to what we learned in this regard and suggestions for strengthening existing collaborations.

Collaboration Goal 1:

The 7Cs are dedicated to strengthening the coordination of The Claremont Colleges shared efforts in all four critical areas of focus in addressing sexual violence – prevention, reporting, response, and support. We recognize we have many stakeholders, distinct campus cultures, and many different offices/personnel doing this work across the 7Cs. Our students attend classes, play sports, eat meals, participate in student organizations, socialize, and engage in sexual activity across campus borders. We are committed to strengthening our coordination across the colleges to create targeted opportunities for cohesive messaging and experience of sexual violence prevention, reporting, response and support.

Collaboration Recommendation 1-1:

The7C Title IX Working Group with the support of EmPOWER will consider jointly identifying and prioritizing specific prevention, reporting, response and/or support best practices to recommend for adoption across the campuses.

• This group will explore and discuss the feasibility of and individual campus support for adoption of the CORE Blueprint and/or a commitment to implementing evidence-based practices and ongoing assessment of the efficacy of programs and services in sexual violence prevention, reporting, response and support.

Collaboration Recommendation 1-2:

The 7Cs leadership will explore the feasibility and individual campus support for increased 7C financial support of the EmPOWER Center, as recommended by the prevention, reporting and support subcommittees in this report.

Collaboration Recommendation 1-3:

The 7Cs leadership will consider support for a 7C analysis of the utilization of the EmPOWER Center by College, as well as strengths and/or challenges associated with the lead campus model and the TCCS model for the EmPOWER Center.

• It is our understanding that the EmPOWER Center was launched under the lead campus model as a pilot model for this resource. It is recommended that focus groups or interviews with key stakeholders of this shared resource be held and an assessment of which model for the EmPOWER Center might best ensure the perception of EmPOWER is one of being a resource for all students and that it is more fully utilized by students across the Colleges. Without evidence to suggest one model over the other, it is recommended research into which model best meets the needs of students across the Consortium be conducted and recommendations be made based off of that inquiry.

Collaboration Recommendation 1-4:

The 7C’s will explore the idea of and campus support for establishing select, targeted and cooperative prevention initiatives through a 7C prevention leadership team.

• This team, ideally, should be coordinated by the EmPOWER Center and should include TIX Coordinators or members of the 7C Title IX Working Group and other key stakeholders.
• The team might also include associate deans of students, residential life staff, coaches, health education staff, college drug and alcohol counselors, mentors, peer educators and peer advocates.
• Staff engaged in this work should be provided adequate time available within their workload to devote to common prevention efforts. In other words, this assignment must not create additional responsibilities without removing other assignments from those staff members.
• This team should, while recognizing unique campus needs, ensure similar messaging across New Student Orientation programs.
• This team should coordinate additional prevention efforts across the 5Cs and/or 7Cs as appropriate (i.e. Take Back the Night, Vagina Monologues, Denim Day, etc.…) and also work to prioritize the needs of marginalized student populations, so that students receive some universal education and/or awareness programming beyond New Student Orientation that also attends to intersectionality.
• This team should prioritize the utilization of established evidence-based best practices in determining common programs and initiatives.
• This team will oversee the continuation of existing common prevention efforts, specifically Teal Dot and Haven (with an openness to collaboratively evaluating additional and/or alternative best practices for bystander intervention and online education programs).