URMIA Matters

Preparing for Change in Title IX

November 15, 2023 Host: Julie Groves with guest Pat Mathis Season 4 Episode 25
URMIA Matters
Preparing for Change in Title IX
Show Notes Transcript

In this episode of URMIA Matters, Julie Groves interviews Pat Mathis, Co-founder and Managing Member- Title IX Solutions, LLC, about the upcoming changes in the Title IX regulations. Pat explains what the new regulations mean for colleges and universities, and how they affect the responsibilities of students, faculty, and staff. Pat also shares some practical tips and best practices for Title IX coordinators and risk managers to prepare for the new regulations, such as reviewing policies, training staff, and communicating with stakeholders. Julie and Pat also discuss some of the challenges and opportunities that the new regulations will bring for Title IX compliance and prevention efforts.


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Show Notes
Pat’s URMIA AC2023 Session: Exploring Title IX: Understanding Regulations, Risks, and Preparing for Change [available to AC2023 attendees only]


Pat Mathis, Co-founder and Managing Member- Title IX Solutions, LLC


Julie Groves, Director of Risk Services- Wake Forest University


Julie Groves: Hi, everyone. I'm Julie Groves, Director of Risk Services at Wake Forest University, and I'll be your host for today's episode of URMIA Matters. We're going to be discussing Title IX, and more specifically, we're going to talk about a risk manager's involvement in Title IX issues. Joining me today is Pat Mathis, the co-founder and managing member of Title IX Solutions.

Thank you for being on the podcast today, Pat. Welcome to you. I will let everyone know that this podcast is a follow up discussion of sorts to Pat's presentation at our recent annual conference in Baltimore. He and Jessica Kennedy from Washington University in St. Louis led a session entitled Exploring Title IX, Understanding Regulations, Risks, and Preparing for Change. And this presentation gave an overview of Title IX, and Pat and Jessica discussed the anticipated changes in the 2022 notice of proposed rulemaking for Title IX. And those are just a few of the highlights, but there was some great information covered and we'll put a link to the presentation in the show notes. So those of you who attended the conference can take a look at that presentation. So, before we start, Pat, why don't you tell us a little bit more about yourself and maybe tell us how you were involved in URMIA?

Pat Mathis: Thank you, Julie. And I appreciate the opportunity to be here today. So, I'm a practicing attorney. Most of my work is involves working with the business clients and their various business-related matters. I'm also, as you mentioned, a co-founder of Title IX Solutions with my partner and good friend, Tom Denton. And I serve as the managing member of Title IX Solutions. So, in that role, I work with our clients and with our employees and consultants, contractors on various Title IX related issues. And enjoy the work very much. I’m also a trustee at Illinois College, a small liberal arts college in in Illinois, central Illinois. I've been on the board for 17 years and I've been the chair of the finance and audit committee for the last 10 or so. So, I appreciate the risk issues that colleges are facing across the country as well as the financial issues that go with that. So, hopefully, our conversation today may help some of our audience recognize and address a few of the risk issues that are out there in the Title IX world. 

Julie Groves: Well, great. Well, I'm looking forward to it. So, cause Title IX is a very, very important topic. So, while we have a lot of people listening to this podcast who are risk managers, there may be some who aren't or who are risk managers, but don't have a lot of real interaction with the folks in their Title IX office. So, could you, I mean, this might be hard to do, but could you give us just a high-level overview of Title IX, like Title IX for dummies, you know, those books that are that series. Is there a way you can sort of give folks a little high-level overview of what Title IX is?

Pat Mathis: Sure, I'll try to do that in short order. So, the current regulations that govern Title IX were issued in 2020 by the Department of Education. And essentially, they focus on three areas of what are defined as sexual harassment. So that includes quid pro quo behavior, which is essentially an employee of a school conditioning some benefits such as a grade or otherwise on unwelcome sexual conduct, typically by a student or an employee. The 2nd type of behavior is sexual violence, which includes rape and date violence, stalking that type of behavior. And the 3rd involves what they call the Davis standard of behavior, which is unwelcome conduct determined by a reasonable person to be so severe, pervasive, and objectively offensive that it effectively denies a person equal access to a college’s education program or activity. I always like to read that whole definition because it's so cumbersome, but that's probably 1 of the more focused areas of the regulation. So those 3 types of behavior are the subject of the Title IX regulations.

Those regulations require that when schools become aware of an incident of sexual harassment that the Title IX coordinator is, is required to address that with the complainant which is the Title IX term for a victim and in particular, the school is to provide supportive measures for the complainant that will be as non-punitive as possible as it relates to the respondent, which is the perpetrator under Title IX terms. The other area of the regulations that is relevant to our conversation today is that if the complainant files a formal complaint, the Title IX office, the Title IX coordinator is required to conduct an investigation of that alleged incident of sexual harassment.

The burden is on the school, not on either party to prove guilt or innocence. There are a very set formulaic prescription of information that's to be provided during the course of the investigation to both parties. The investigations are supposed to be equitable and both parties treated equally at the conclusion of that investigation, the investigation report then goes to the parties and to a hearing officer or decision maker is the Title IX term for a formal hearing process at the university level. K through 12 is a little bit different. And at the conclusion of that hearing, the decision maker is to determine whether the respondent is responsible for the alleged incident of sexual harassment and the sanctions that may be imposed upon the respondent as a result of that finding. There's also the opportunity for the either party to appeal that decision. Both parties have the opportunity for an advisor to work with them during the course of the investigation and the hearing. And currently the regulations provide that once a complaint is filed, either party may ask for how the school may offer informal resolution as part of that process. So that is the big picture in 3 minutes or less. 

Julie Groves: Oh, that was very helpful. So, you know, when you think about Title IX, I think there, there are probably external hazards and there are internal hazards. So, when you think about that, what types of hazards do you see related to the external world?

Pat Mathis: I think generally there are three areas outside or external hazards the first of which is the Department of Education Office of Civil Rights or OCR has the authority to investigate complaints of sex discrimination in any form. At universities and colleges, anyone may file a complaint of alleged sex discrimination regarding an incident or a pattern at a school. OCR will then evaluate that complaint initially to determine whether it is indicative of sex discrimination. And if OCR determines that it is, and it has jurisdiction, it will notify the school and the parties involved and conduct an investigation. Those investigations may be rather protracted during the course of the investigation, the parties, including the school, obviously, may resolve the investigation through a resolution process, or at the end, if it's not resolved by agreement, OCR may issue a resolution order which may require the school to remediate a particular incident that was in question in the investigation.

And also, the school may adopt a protocol or process to address it on an ongoing basis, which OCR may monitor for a period of time following the resolution the risk in those in that process is 1st of all, the time involved and the time of both staff and outside advisors, whether they be attorneys, accountants, or otherwise to assist the school and responding to the investigation request by OCR. The obvious expense that goes with engaging external advisors and the negative publicity that may come out of just the fact that the school is under investigation, because that is public record as well as the fact that there may be an ultimate resolution issued at the conclusion. So, there is a kind of a broad-based negative factor to the OCR investigation process and obviously a risk to schools and their reputation and ultimately recruiting and all of those things that go with it. So, that’s 1 area that is of concern.

The 2nd area is litigation and there is increasing litigation surrounding Title IX. And by the way when I'm referencing Title IX, I probably should have mentioned this earlier, schools, most schools have a sexual misconduct policy as part of their school code of conduct, which may encompass behavior beyond those 3 defined areas of sexual harassment under Title IX. Some of those policies will dovetail with the Title IX policy. Others will be different in the grievance process, the investigation, the hearing process but it's not uncommon for schools to have both a Title IX policy that complies with the regulations and a broader sexual misconduct policy. For the purposes of our conversation today, I'm going to talk about, I'm going to use the term Title IX to encompass both of those types of issues.

So, as I mentioned a moment ago, there's increasing litigation related to a Title IX issues by both complainants and respondents and just a couple of examples of types of cases being brought, complainants are under Title IX, there is a specific bar under the regulations for retaliation against a party who is involved in the Title IX process. And there have been a number of cases brought throughout the country by complainants alleging retaliation by the institution as a result of their either filing a complaint or making a report of sex discrimination to their school or to a representative of their school. So, there are a couple of recent cases that have involved college athletes who have reported situations on their team where they have felt discriminated against because of their sex or their sexual orientation. And they felt that the coaches and the school either ignored them or worse threatened to remove them from the team, which would have cost them their scholarship. And so, the claims in those cases were based upon the fact that the school retaliated against their attempt to report an incident of sex discrimination.

Other complainants have brought actions for deliberate indifference. The regulations require that schools not be deliberately indifferent when they respond to a Title IX complaint. And these cases focus principally on the fact that a school may have had a report of an incident of sexual harassment or sex discrimination. And the school did little or nothing to address that complaint or that report. And so, these claims have been based upon the argument that the school violated the deliberate indifference requirement under the regulations.

And the 3rd area that is has been more and more prevalent is an argument of heightened risk, which is kind of the reverse of deliberate indifference, where deliberate indifference is the allegation is that the school was indifferent after an incident occurred. The heightened risk argument is that the school was aware of a situation, which gave rise to the risk of sexual harassment and effectively did nothing to respond to it. So, it's a different turn on essentially the same argument that a school has been non responsive respondents have also increasingly brought litigation against schools on a variety of theories. And many of these theories are in the development stage, but no one really wants to be a target of Title IX litigation.

So, several legal respondent cases have been based upon the theory of breach of contract, that a school has a contract with their students, and part of that contract involves their policies as they relate to Title IX or sexual misconduct, and that schools are expected to follow those policies, and that they fail to do so either in the course of the investigation or in the course of a hearing. And a student may have been expelled or suspended. And the argument is that the school failed to follow its own policy, that it breached its contract with its students who were paying tuition to attend that institution, and that is a breach of, of contract between the parties. Other respondents have brought suit based upon the theory of selective enforcement, essentially that that not every student is treated the same or more commonly that there is a different treatment for complainants than there is for respondents and that either in the investigation process or in the hearing process that the school is obviously either directly or through its representatives and those stages of the case biased against the respondent or they are treating respondents differently than complainants.

So, for instance, in a hearing, the respondent may have been limited in their ability to cross examine the complainant or in the ability to present witnesses, whereas the complainant was arguably given more leeway during the course of that hearing process and the respondent is contending that had they been given that same leeway as a complainant they would have had a better opportunity for a favorable outcome in the area. There are some cases brought on erroneous outcome where the respondent is alleging that the either during the investigation or during the hearing. If sufficient information had been developed by the investigator or allowed it into the hearing process that the outcome would have been different than what it was as it relates to the responder.

So, all of these theories are premised upon something not being right during the course of the Title IX process. And we're going to talk in a moment about how to review your process and why to review your processes, but I think the salient item that comes out of all these cases is that if you don't have a good policy and you don't have good protocols or you don't follow those, that's where issues come up. That's where litigation comes from. That's where OCR comes on your campus because of the fact that someone has made a mistake. You know, it's the old saying plans fail because it's either a bad plan or bad execution. And that's the probably the most salient issue to remember about risk management in the Title IX.

Julie Groves: So, when you speak about having important policies and procedures in place, you know, that seems like that might be more of a hazard related to the internal world. So, do you have other internal hazards that we should be aware of? 

Pat Mathis: Yes, yes. So, there are... I see these risks breaking down into several, several areas. You have general risk, let's call that the big picture Title IX risk area. So, a lack of a clear and correct Title IX policy. It's surprising that the people that work in the policy consulting side of our practice still bump into schools that have Title IX policies that don't comply with the 2020 regulations. So probably a seminal point is to ensure that your policy comports with the Title IX regulations and several states have. Sexual misconduct statutes as they relate to colleges and universities, and it's important to ensure that your policies conform to those requirements as well. Secondly, we have schools that lack a Title IX coordinator and still out there surprisingly. So, a few. And Title IX coordinators who are ill prepared for their positions, that's a big deal because the Title IX coordinator is the quarterback for your Title IX team, and that's their expectation under the regulations of that Title IX coordinator be the one who truly is a coordinator for the entire process.

There's a lack of transparency. Regulations require that your Title IX policy, contact information for your Title IX coordinator, and the training materials provided to your Title IX staff be on your website. And it's surprising how many schools don't dot the I and cross the T on that particular area. There are personnel issues, training issues, it's important that your Title IX people be trained and know what the world of Title IX is about, both at the macro level in dealing with the Title IX regulations, but also at the micro level to understand their school’s policies to understand what's required of them and their respective role and to understand the process in total.

So that if they're a decision maker, they should be familiar with what the school's investigation process is about. And beyond that, beyond the macro/micro, their skill set should be part of their training. So, an investigator should understand the process of interviewing a victim who may have been impacted by the traumatic effect of the event in question. Trauma informed interviewing is a skill that takes not only education, but practice. But it's important, whether you're the Title IX coordinator, the investigator, decision maker, advisor, informal resolution facilitator, to understand the impact of trauma on victims in some cases, and to understand empathetic interviewing, both for complainants and respondents, because these are important skill sets to do the process correctly.

We see schools that fail to respond to incidents. You know, the Title IX regulations require that when the school becomes aware of an incident the Title IX coordinator is supposed to provide information regarding supportive measures to the complaint and the opportunity to have support either on campus or outside, the opportunity to report it to the police, the opportunity to file a complaint and begin any Title IX grievance process schools still slip up. So, these are things that are important to understand happen at the, at the big picture level. You have policy risk, whereas I mentioned before, some policies don't comply with the Title IX regulations. You have situations where the parties Aren't notified correctly of the allegations and the policy violations.

I think one of the things that happens in many cases is when an incident is reported the title nine coordinator gets the complaint. And doesn't hone in on the specific allegations as they relate to the policy. So, an incident that may have involved this type of behavior may be a violation of Title IX, because it is sexual violence, it's domestic violence or date rape, but it may also violate the school sexual misconduct policy, which may be more expansive in what's construed as sexual misconduct. It's important that the Title IX coordinator evaluate what has been alleged to have happened and how that fits within the school's policy.

So that when the investigator is asked to undertake the investigation, the investigator clearly understands what the timeline coordinator is looked at and, and what the focus of that investigation should be. And frankly, in a lot of cases, that investigation and the alleged violations may evolve as the investigator begins the process. And it's important that there be a dialogue between the investigator and the Title IX coordinator as to where that case is going, what potential violations the investigator is looking at, and at the end of the day, what that report is going to pull together from the investigation process and incorporate into the investigation report that ultimately moves through the parties and to the decision maker for the hearing and ultimately a determination of whether there's a violation of one or more of the school's policies.

So, clarity is where a lot of these cases miss out on what should be the initial step in the whole grievance process. And obviously you can understand how complainants or respondents may end up filing suit because what was alleged to have happened and the violations that were considered don't necessarily fit together and don't support each other. So that's a big area that I believe needs attention. Schools sometimes on supportive measures are more punitive than they need to be. As I mentioned a few moments ago supportive measures for complainants are supposed to be non-punitive to respondents. And in many cases, that's a little hard to do because they seem to be punitive.

If you have a no contact order or you separate students in classes, so they're not in the same class and they're not in the same dormitory, they may seem punitive to one or the other. And, but sometimes that's the practical reality. If you talk to Title IX coordinators, they have to deal with the real world.

And it's one thing, if you're on a campus with 40,000 students, it's another thing. If you're on a campus with 400 students, the practical aspects of supportive measures have to be weighed against the punitive aspects. But listening to the complainant and the respondent and trying to make an accommodation that will work well for both of them in your situation is far better than bringing the hammer down, so to speak without that input on either side.

Julie Groves: So, given all of that great information, how do you suggest that risk managers work with their Title IX offices to address some of these, you know, um, kind of internal, external hazards and risks that you've just mentioned? 

Pat Mathis: Well, what I would suggest is the risk managers, first of all, work with the Title IX coordinator and the Title IX department to audit their current programs. What's, what do they have in place? What's being done right? What's working well? And what's being done wrong? And what is not working well? And, and just as a checklist, I would start with the school's policies. I would want to ensure, first of all, that those policies are consistent with the Title IX regulations and state statute, that they reflect what's mandated to be in those policies.

Beyond that, I would look at what the policies may lay out as part of the process that may be beyond the scope of the statutory or regulation requirements, but are still there because they were thought to be a good idea. And maybe they are a good idea. But for instance, Title IX regulations don't set out a specific absolute timeline for completing an investigation, but many schools have a 60-day, 30-day, 90-day timeframe without any real cushion around that.

And so, you can see where respondents or complainants in filing a suit allege that a policy was violated because there was an absolute 60-day cutoff, and the case wasn't done. Look at the policies, both as to their compliance, but also their practical operation, what's working in your processes now that may or may not fit what the policy is doing. And if it's not working, right, refine your policy to make it work better. Secondly, I would look at your campus environment. How does your campus feel about Title IX and sexual misconduct and how much is it permeating the philosophy of your campus or how much is it ignored as a real issue, there's still schools where it's almost treated like a joke. Which is hard to believe in today's age, but it is not uncommon for students or faculty or employees to give it short shrift. And that's not a philosophy that that's really acceptable. And that philosophy needs to start at the top. I think it needs to start with the board of trustees and the president, and it needs to permeate your cabinet, your faculty, your staff, and students need to understand that this is important, this is a real issue and it's taken seriously.

I'd look at camp. I'd look at your education process as far as faculty, staff students, how are people educated about the rules under your policies? The reporting processes and how accessible are that information to them and how is it incorporated into your process on an ongoing basis? It's not a 1-hour presentation during orientation. It's a constant. It's a constant reminder. But this is part of our campus culture. I'd look at your staff training. How much do your, how much do your Title IX people know about their roles? Large schools have full time Title IX investigators. Oftentimes they're experienced law enforcement investigators. They've interviewed hundreds of people. And they are certainly well trained and have an exceptional background in the interview process. Other smaller schools, Title IX investigators may be a professor who volunteered for the job, or a staff member was volunteered for the job. They've taken a couple of hours and well, maybe more than a couple, but they've taken a couple of courses, and they are certified, so to speak, or get a badge, so to speak. But that doesn't make them necessarily qualified for some particularly challenging cases.

Evaluate your stamp performance. So, beyond the training, how are they doing? Look at their reports. And sometimes you'll want an outside voice on that. And there's some schools that are consortiums of Title IX coordinators. It's a great opportunity to take advantage of that, that resource. So, if you want a third party to look at your investigator’s performance, so to speak, maybe ask an experienced investigator from another school to look at a redacted report or look at a redacted file and just see how effective that investigator is. And if they're not as effective as you want, perhaps more training can help them to get better. Evaluate your supportive measures. What do you have beyond the grievance process? What do you have in your system to support complainants to address the issues that they're dealing with as a result of some type of sexual harassment?

Consider internal versus external audits. External audits are more expensive. They bring the benefit of outsiders who have maybe a broader experience and are more objective. Benefit of insiders are that they have a much better feel for your campus, much closer experience with your Title IX process and frankly are less expensive. So, weigh those factors and it depends upon each school and where you are in the process. And as risk managers, you can probably be more objective in making that decision as to how you evaluate your institution's Title IX staff and protocols. And finally, for all risk managers, look at your insurance coverage. I can't tell you how many schools, when you ask them whether they have coverage for this, will look, look at you and say, I don't really know. And part of that is because Title IX coordinators are not necessarily on the risk management side. So, they're dealing with the nuts and bolts of Title IX cases.

And sometimes they're wearing three or four hats. They're the HR director or they're the provost or they're somebody. And so, their area is not insurance coverage. So, look at your policies. First of all, make sure you have coverage. Just as importantly, make sure that everyone on your campus knows the importance of getting the, the information about an incident upstream to the risk management office, so that if you have a time frame for reporting an incident, or you may have denial of coverage that you don't find out about the incident.

Two years after it occurred, when somebody drops a complaint on your desk, because you should have notified your carrier when the attorney during the Title IX hearing said, you know, this is a violation of due process, this is going to come back to bite your school somewhere down the road, and nobody bothered to tell the risk management people that, oh, by the way, you should notify our carrier that we may have a problem out here, get a file opened, even if it just sits in the carrier's office, so what? But the worst thing that any insured can have is a denial of coverage as we all know.

Julie Groves: Definitely. So, let's just pivot the conversation a little bit and talk about the Title IX regulations. And of course, we don't know when the new regulations will be released. So, while we're waiting for this release, how can risk managers help their institution prepare for these new regulations?

Pat Mathis: Well, I think the first thing to do is to take all that you've learned from your audit and refine your current policies and your current practices, because that's where you are today. That's where we are today. So, take all of that information, all of that knowledge, sort it out, figure out what you need to do, who's going to be responsible for it, and begin that, that process with what you have today, because that's the foundation. Beyond that, look at the new proposed regulations.

They’re big, they're bulky. And they're different than what we have today. So, today, under the Title IX regs, for instance, we have three areas of coverage under Title IX, quid pro quo behavior, Davis standard behavior, and sexual violence. Going forward, the regulations are much broader in their discussion of what is what is covered. Within the Title IX regulations, so gender identity, sexual orientation, pregnancy, pregnancy-related discrimination all come now within the new regs definition of sex-based harassment. So, sex-based harassment is the original three sexual harassment, but it's now much broader, so your policy has to address those additional areas as types of sex discrimination or sex-based harassment. And the new regulations now have two grievance processes in place if they get adopted that way, one deals with sex-based harassment, which is akin to sexual harassment and the grievance process that we have under the current regulations, investigation, hearing, appeal, informal resolution. That's all there, but the new regulations have a much broader focus as to what is covered under Title IX, and that it focuses on sex discrimination, and it focuses on the importance of non-hostile environments for schools on their campuses, so that there is a completely separate grievance process now set out under the regulations for investigating allegations of sex discrimination, which are beyond the sex-based harassment.

That is the separate grievance process within those regs. Schools are also now going to be required under the new regs to monitor their environment on their campus and to ensure that when they see sex discrimination that they adopt curative measures for that they monitor those curative measures and that they ensure that that sex discrimination does not continue. In addition, the preamble notes, the Title IX coordinators are to monitor impediments to reporting of incidents of sex discrimination or sex-based harassment on their campus, which may include surveys. It may include focus groups, may include emails, and it's an ongoing process. So, the burden of monitoring Title IX compliance is much broader under the proposed regulations than it is under the 2020 regs that we're operating under today.

My suggestion is that if you're a risk manager, you get with your Title IX people. And as I said earlier, you fix what may not be working right under your current system or improve what may be working right, but could be better. But in addition to that, you break down those proposed rules and you begin to look at your policy and what may be affected. So, for some people, that may be a margin note for some people that may be a working model for some people. It may be an outline of your current policy with the potentials put in red within it, but begin to think about what those new regulations will require. And as you're updating your current policy, you're thinking about where these pieces will fit and what they will mean. And some of them are frankly mundane. They're the language that needs to go into your policy to address sex-based harassment versus sex discrimination. But others, others may be much more nuanced to fit what you're doing today versus what may be required under the under the proposed regulations.

So, for instance, many schools have a pre-hearing conference with the parties and their advisors, and some decision makers may have a very formal pre conference outline that they provide to all their parties as to what's going to be covered, how they're going to rule in a hearing, how the hearing itself may take place. The new rules have some revisions for the hearing process. Your school may opt to change that, but you need to think about that. And you need to think about the peripheral pieces that go with it. So, it's a time of flux since we don't know when the regs may be finalized, but at the same time if you're going to evaluate where you are today, you should look ahead to what may come in the future.

Julie Groves: So, if we switch that a little bit to think about those folks who actually supervise the Title IX process. What advice would you give to those folks again, given this delay in the new guidelines? And you may have touched on some of this already when you were talking about what risk managers should think through, but are there other specific things you think would be helpful for those who supervise Title IX?

Pat Mathis: You know, I think the most important thing if we're talking about risk management or risk mitigation, a good friend of mine is a trustee with me, and he is the chair of the risk management working group within the board of trustees and his uh, his big, big buzzword is risk mitigation. I think if you're looking at risk mitigation within your Title IX staff, the most important thing is to have policies and protocols that, first of all, comply with the statute, secondly, work on your campus, and thirdly, ensure that your personnel at whatever level follow through on that. So, if you have a policy that any time any staff member becomes aware of an incident of sexual harassment, they are mandated to report it to your Title IX coordinator and there's a form out there to do it and a timeline to do it.

Make sure that every staff member knows that if your Title IX investigator is, is required to follow a format for their investigation and their index of their report and their report itself and you do transcripts of every interview. Make sure that happens. Make sure those files are well organized and that the decision that the decision maker makes is supported by the investigation record and by the hearing record itself. So, the big deal is to follow the rules. I guess that's the simple way to put it. And as I mentioned at the beginning, we talk about the type of issues that come up, whether it be with OCRs, OCR investigations, or complainant litigation, or respondent litigation. Most of that is focused on the failure of schools to do what they are supposed to do and to do it effectively.

Julie Groves: Well, this is I'm sure that, you know, we could, this just feels like we've touched the tip of the iceberg. I'm sure that we could talk about this for a lot longer because there is so much to know about this and there are so many nuances, you know, and especially as we wait for the new guidance to come out and once the new guidance comes out, you know, it can be very overwhelming. So, you know, this has just been very, very helpful. Before we kind of wrap up our conversation, do you have anything else you want to share with the audience this afternoon? 

Pat Mathis: No, I appreciate the time today, Julie, and the opportunity to talk about this. It's a big issue. And frankly, as all of us in higher ed know unfunded mandates are miserable to begin with. And this is just an expansion of what has been an unfunded mandate under Title IX from the very beginning. And all of us, or most schools, I think, across the country are facing enrollment issues and financial strains and budget strains, and this is just one more issue that we have to deal with, but it's extremely important. It's extremely important to the students who are affected, both complainants and respondents, that we do this work right. And it's extremely important for us as risk managers to ensure that it's done right for the protection of our institutions. 

Julie Groves: Well, very well said. And I want to, again, thank you so much for being here today and, you know, we really appreciate your guidance and expertise to help us deal with this really important issue. You know, it's, it's so critical for us to have partnerships with folks like yourself who have this, you know, very specific knowledge and expertise. So, we really, really appreciate you being here today. And you know, we will look forward to the release of the new regulations and we will see what those say, and you may be having another conversation at that point. So, but thank you, Pat, again, so much for being here today. And this wraps another episode of URMIA Matters.