Research Bench Lab

Corporate Policies and Procedures Administrative (AD)

Prohibiting Sexual Harassment and Abuse in Education Programs

Category: Conduct and Conflicts (CC)
Policy#: AD.CC.080
Applies To: All MCW Employees (Faculty, Exempt and Non-Exempt Staff, Post-Doctoral Fellows), Students, and Volunteers

Purpose

The purpose of this policy is to ensure the Medical College of Wisconsin (MCW) is in compliance with the Title IX of the Education Amendments of 1972 (Title IX). MCW prohibits Sex Discrimination, Sexual Harassment, Sexual Assault, Domestic Violence, Dating Violence, Stalking and Retaliation of minors and adults in its Education Program and Activities including within admissions and employment. MCW has developed policies and procedures that provide a prompt, fair and impartial process for those involved in an allegation of a Prohibited Offense(s) and/or Retaliation.

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Definitions

Advisor: A person chosen by a Party or appointed by MCW to accompany the Party to meetings related to the Informal Resolution and/or Formal Grievance processes, to advise the party on the processes, review documents provided to the Parties, and to conduct cross examination for the Party at the hearing, if any.

Clear and Convincing:
The standard of evidence applied at a hearing under Title IX. To support a finding of responsibility under Title IX, a hearing panel, after consideration of all of the relevant evidence admitted at the hearing, must be convinced that it is highly probable that a violation has occurred.

Complainant: Individual who is alleged in a Formal Complaint to have experienced a Prohibited Offense(s) that could constitute Sexual Harassment under Title IX or Retaliation for engaging in a protected activity including participation in a Title IX proceeding or opposition of conduct prohibited by Title IX. The Complainant must be participating in or attempting to participate in the Education Program or Activity at MCW to bring a Formal Complaint under this policy.

Consent: Words or overt actions by a person who is competent to give informed consent indicating a freely given agreement to have sexual intercourse, sexual contact or engage in other activities sexual in nature. Wis. Stat. 940.225(4) Prior Consent to intimate conduct does not constitute Consent for similar or identical conduct in the future.

Dating Violence: Violence committed by a person who is or has been in a social relationship of a romantic or intimate nature with the victim and where the existence of such a relationship shall be determined based on consideration of the following factors: the length of the relationship; the type of the relationship; and the frequency of interaction between the persons involved in the relationship.

Discretionary Dismissal: MCW may dismiss a Formal Complaint or any allegations therein if at any time during the Informal Resolution and/or Formal Grievance Process there is: 1) a written request by the Complainant to the Title IX Coordinator to withdraw the Formal Complaint or allegations therein, or 2) the Respondent is no longer enrolled or employed by MCW, or 3) specific circumstances prevent MCW from gathering sufficient evident to reach a determination from the Formal Complaint or allegations therein. MCW will provide simultaneous written notice to the parties stating the reasons for the dismissal. Discretionary Dismissal is an administrative action not subject to appeal.

Domestic Violence: Violence committed by a current or former spouse or intimate partner of the victim, by a person with whom the victim shares a child in common, by a person who is cohabitating with or has cohabitated with the victim as a spouse or intimate partner, by a person similarly situated to a spouse of the victim under the domestic or family violence laws of the jurisdiction in which the crime of violence occurred, or by any other person against an adult or youth victim who is protected from that person’s acts under the domestic or family violence laws of the jurisdiction in which the crime of violence occurred.

Domestic abuse is defined in Wisconsin criminal law to include any of the following engaged in by an adult person against his or her spouse or former spouse, against an adult with whom the person resides or formerly resided or against an adult with whom the person has a child in common:

  1. Intentional infliction of physical pain, physical injury or illness.

  2. Intentional impairment of physical condition.

  3. A violation of Wis. Stat. 940.225(1), (2) or (3) [Sexual Assault]

  4. A physical act that may cause the other person reasonably to fear imminent engagement in the conduct described above.

Education Program or Activity: Locations, events, or circumstances over which MCW exercises substantial control over both the Respondent and the context in which the alleged Prohibited Offense(s) and/or Retaliation occurs.

Emergency Removal: MCW can act to remove a student Respondent entirely or partially from our Education Programs and/or Activities on an emergency basis after an individualized safety and risk analysis has determined that an immediate threat to the physical health or safety of any student or other individual justifies removal. MCW will evaluate whether an Emergency Removal of a student Respondent is necessary by completing a risk analysis.

Formal Complaint: A Formal Complaint means a document filed and signed by a Complainant or signed by the Title IX Coordinator alleging a Prohibited Offense(s) or Retaliation against a Respondent and requesting MCW to investigate the allegations. The document must contain sufficient information to determine that a violation has occurred, with specific information about each incident including the name of the Respondent(s).

Formal Grievance Process: The process used to address Formal Complaints of Prohibited Offense(s) that includes an investigation, a live hearing that includes a determination, sanctions/remediation, and availability of an appeal.

Incapacitation: A person is presumed incapable of Consent if they are suffering from a mental illness or defect which impairs capacity to appraise personal conduct or is unconscious or for any other reason is physically unable to communicate unwillingness to an act.

Informal Resolution: Alternate resolution strategies made available to Parties following the filing of a Formal Complaint that can be used in place of a Formal Grievance and hearing process if: 1) both parties agree; or 2) when the Respondent accepts responsibility for the alleged Prohibited Offense ;or 3) when the Title IX Coordinator can effectively administer remedial measures which resolve the situation.

Jurisdiction: This policy applies to Formal Complaints of a Prohibited Offense(s) within the Education Program and Activities of MCW, of conduct that takes place on the MCW campus or on property owned or controlled by MCW or at MCW sponsored events of a person in the United States or of Prohibited Offenses that effectively deprive a Party access to MCW Education Programs or Activities. The Complainant must be participating in or attempting to participate in the education program/activities of MCW. The Respondent must be under MCW’s control and supervision at the time of the alleged Prohibited Offense and throughout the Informal Resolution and/or Formal Grievance process in order for this policy to apply.

Mandatory Dismissal: A Mandatory Dismissal will occur promptly under any of the following circumstances: 1) the individual who is alleged to have been subject to a Prohibited Offense(s) is not a current or attempted participant in MCW’s Education Programs or Activities; or 2) the conduct described in the Formal Complaint would not constitute a Prohibited Offense under Title IX, including Sexual Harassment as defined in this policy, even if a determination that it occurred as reported; or 3) the alleged Respondent is not under MCW’s control or within MCW’s authority of influence; or 4) the conduct described in the Formal Complaint did not occur within an MCW Education Program or Activity, and/or did not occur within the United States. MCW will provide simultaneous written notice to the Parties stating the reasons for the Mandatory Dismissal. Mandatory Dismissal is not subject to appeal.

Notice: A Complainant or other individual informs the Title IX Coordinator or other Official with Authority of the alleged occurrence of prohibited conduct, or the Title IX Coordinator or Official with Authority observes the prohibited conduct occurring in MCW’s Education Programs or Activities.

Office of Civil Rights: The Office of Civil Rights of the Department of Education (OCR) enforces Title IX. Individuals experiencing Sexual Harassment or Discrimination in educational programs or activities because of their membership in a protected class have the right to file a formal complaint with OCR at ocr@edu.gov, or to the local OCR office (call 1 (800) 421-3481 for local office information).

Officials with Authority to Institute Corrective Measures (OWA): Officials at MCW who have the authority to institute sanctions and other corrective measures following a finding of responsibility for Prohibited Offenses and/or Retaliation.

Party: A Complainant and a Respondent.

Presumption of Innocence: Until such time as a determination is reached following conclusion of the Formal Grievance process or Informal Resolution process, all Respondents are presumed by MCW to be innocent of the alleged Prohibited Offense(s).

Prohibited Offenses: Sex Discrimination, Sexual Harassment, Domestic Violence, Dating Violence, Sexual Assault and/or Stalking (as those terms are defined herein).

Respondent: Individual who is reported to be the perpetrator of conduct that could constitute a Prohibited Offense(s) under this policy.

Retaliation: Retaliation is when any member of the MCW community takes adverse action by intimidating, threatening, coercing, harassing or discriminating against an individual for the purpose of interfering with any right or privilege or because the individual has made a report or complaint, testified, assisted or participated or refused to participate in any manner in an investigation, proceeding, or hearing under this policy and procedure.

Sexual Assault: Any type of sexual act directed against another person, without Consent of the victim, including instances where the victim is incapable of giving Consent of the following:

  • Non-Consensual Sexual Intercourse: Penetration, no matter how slight, of the vagina or anus with any body part or object, or oral penetration by a sex organ of another person, without the Consent of the recipient. Intercourse incudes vaginal or anal penetration by a penis, object, tongue or finger, and oral copulation (mouth and genital contact) no matter how slight the penetration or contact.
  • Non-Consensual Sexual Contact or attempt to commit the same: The touching of the private body parts of another person for the purposes of sexual gratification, without the Consent of the victim, including instances where the victim is incapable of giving Consent because of their age or because of their temporary or permanent mental or physical incapacity. Non-consensual sexual contact may also be referred to as fondling or groping.
  • Incest: Sexual intercourse between persons who are related to each other within the degrees wherein marriage is prohibited by law.
  • Statutory Rape: Sexual intercourse with a person who is under the statutory age of Consent.

Sex Discrimination: Adverse action taken on the basis of sex, sexual orientation, or gender identity.

Sexual Harassment: Conduct on the basis of sex that satisfies one or more of the following:

  • Quid Pro Quo: An employee of MCW conditioning the provision of an aid, benefit, or service of MCW upon an individual’s participation in unwelcome sexual conduct; or
  • Unwelcome conduct of a sexual nature which is so severe, pervasive, and objectively offensive that a reasonable person could find that such conduct effectively denies the recipient of such conduct equal access to MCW’s education programs or activities;

Stalking: Engaging in a course of conduct directed at a specific person that would cause a reasonable person to fear for their safety or the safety of others; and/or suffer substantial emotional distress.

For the purposes of this definition course of conduct means two or more acts, including, but not limited to, acts which the stalker directly, indirectly, or through third parties, by any action, method, device, or means follows, monitors, observes, surveils, threatens, or communicates to or about, a person, or interferes with a person’s property. Substantial emotional distress means significant mental suffering or anguish that may, but does not necessarily, require medical or other professional treatment or counseling. Reasonable person means a reasonable person under similar circumstances and with similar identities to the Complainant.

Wisconsin law prohibits stalking under Section 940.32 Wis. Stats.

Supportive Measures:
Measures provided by MCW that are non-disciplinary, non-punitive individualized services offered as appropriate, as reasonably available, and without fee or charge to the Complainant or the Respondent before or after the filing of a Formal Complaint or where no Formal Complaint has been filed in order to restore or preserve equal access to MCW’s Education Programs and Activities without burdening the other Party and to protect the safety of everyone or to deter Prohibited Offenses from occurring.

Title IX of the Education Amendments of 1972: Enforced by the U.S. Department of Education’s Office for Civil Rights, Title IX protects people from Sex Discrimination in education programs or activities that receive federal financial assistance. Title IX specifically states: “no person in the United States shall, on the basis of sex, 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.”

Title IX Coordinator: MCW’s has a designated Title IX Coordinator who serves as a neutral party to oversee reports of and compliance with the Title IX of the Education Amendments of 1972.

Volunteers (adjunct or clinical): Individuals who contribute to the programs of MCW without pay, and other individuals not employed by MCW who freely offer to undertake a task or provide a service for the benefit of MCW. Employees, students and interns including interns for experience or credit are not Volunteers.

Policy

MCW is committed to creating and sustaining a safe learning and working environment, as well as other benefits, programs and activities, that are free from Sexual Harassment and Retaliation. In furtherance of this commitment and in compliance with Title IX of the Higher Education Act, MCW prohibits Sexual Harassment, Domestic Violence, Dating Violence, Sexual Assault, Stalking and Retaliation on all MCW campuses and in connection with any MCW Educational Program or Activity. This policy describes MCW’s process for investigation and remediation of reports of Prohibited Offenses and Retaliation within an Educational Program or Activity. All MCW faculty, staff, students, and Volunteers are subject to this policy and are encouraged to utilize the protections and processes set forth herein, regardless of their sex, sexual orientation or gender identity.

Retaliation against any individual making a report under this policy or any individual participating in an investigation in connection with this policy is prohibited and should be immediately reported to the Title IX Coordinator. The Title IX Coordinator will promptly investigate and resolve reports of Retaliation and will take all appropriate steps to protect individuals who fear that they may be subject to Retaliation. Retaliation may include conduct that has the effect of deterring an individual from participating in processes under this policy, including:

  • exclusion from class participation
  • adverse academic or employment actions
  • disparaging comments, threats, increased surveillance, altering environment, stalking and/or intimidation

MCW is committed to ensuring integrity in its Title IX program and resolution procedures. MCW prohibits knowingly providing false information, evidence and intentionally false reports of Prohibited Offenses and Retaliation. Individuals found to have made deliberately false and/or malicious accusations under this policy will be subject to disciplinary action. Witnesses or Parties knowingly providing false evidence, tampering with or destroying evidence, or deliberately misleading an official conducting an investigation or within any part of the resolution process may be subject to discipline. MCW encourages the reporting of Prohibited Offenses and crimes by any member of the MCW community with knowledge or information concerning a Prohibited Offense(s) in the context of any MCW Educational Program or Activity.

All individuals who believe they have been subjected to or who are accused of Prohibited Offenses are encouraged to and have a right to seek support, utilize available resources, file a formal complaint, and be presumed innocent until a Formal Grievance process has concluded. MCW will treat all Parties with respect before, during and after any process conducted under this policy. MCW will presume the innocence of all accused Parties until a determination is reached in the Formal Grievance process or MCW’s Informal Resolution process has concluded.

Procedure

Reporting Prohibited Conduct to MCW

MCW encourages all members of the MCW community to promptly report any information relating to a Prohibited Offense and/or Retaliation to Katie Kassulke, MCW’s Title IX Coordinator. Reports to the Title IX Coordinator can be made verbally in person, via telephone, and/or in writing using email or mail at any time, including during non-business hours.

The Title IX Coordinator’s contact information is:

Katie Kassulke
(414) 955-8668
TitleIXCoordinator@mcw.edu

To provide a Formal Complaint via mail, a Party may use the following address for both the Title IX Coordinator or an Official with Authority listed.

Medical College of Wisconsin
(Name of Individual)
8701 Watertown Plank Road
Milwaukee, WI 53226

Official Notice of a complaint of prohibited conduct under this policy occurs when the Title IX Coordinator or an Official with Authority receives information describing a Prohibited Offense(s). When a report is made to an Official with Authority, MCW institutionally will be considered to have actual knowledge of the complaint and will respond in accordance with this policy.

Officials with authority include the following:

  • Title IX Coordinator
  • Director of Public Safety
  • Dean, School of Pharmacy
  • Assistant Dean for Curricular Affairs, School of Pharmacy
  • Senior Associate Dean, School of Medicine, Main Campus
  • Assistant Provost, Student Inclusion and Diversity
  • Dean, Graduate School of Biomedical Sciences
  • Campus Dean, Medical School Regional Campus, Central Wisconsin
  • Campus Dean, Medical School Regional Campus, Green Bay
  • Program Director, Master of Science in Anesthesia Assistant Program
  • Vice President of Human Resources and Faculty Affairs
  • Director of Talent Planning and Development

In addition to providing MCW Notice by using the process listed above, a Complainant may also report the incident to:

  • local law enforcement

  • Employees may make reports of Prohibited Offenses to the Equal Employment Opportunity Commission (EEOC). Go to the EEOC website for information about the office closest to you. You may also call 1 (800) 669-4000 to discuss your situation.

  • The Office of Civil Rights of the Department of Education (OCR) enforces Title IX. In addition to the resources above, inquiries and complaints under Title IX may be directed to

Office for Civil Rights (OCR)
U.S. Department of Education
400 Maryland Avenue, SW
Washington, D.C. 20202-1100
Customer Service Hotline #: 1(800) 421-3481
Facsimile: (202) 453-6012
TDD#: (877) 521-2172
Email: OCR@ed.gov
Visit the OCR website

Report Intake Process (Title IX Coordinator)

Any person making a report of a Prohibited Offense(s) under this policy, including a Complainant, has discretion to make a Formal Complaint based upon the information reported. No individual is obligated to file a Formal Complaint at any time. Once MCW is on Notice of a report of prohibited conduct (either through the Title IX Coordinator or an MCW Official with Authority), the Title IX Coordinator will describe the process by which a person may make a Formal Complaint.

The Title IX Coordinator’s intake process will typically take one (1) to five (5) business days and can include a discussion with the Complainant to determine if the Complainant wishes to make a Formal Complaint, assistance in making the Formal Complaint, the offer of Supportive Measures, the right to have an Advisor, and the type of resolution the Complainant would prefer. During this time, an individualized safety and risk analysis may be done to determine if an immediate threat to the physical health or safety of any student or other individual justifies Emergency Removal. The Title IX Coordinator will collaborate with institutional officials trained to conduct such threat assessment measures as needed.

If a Complainant does not wish to file a Formal Complaint and does not want a Formal Grievance process to take place, or does not want an investigative resolution to be pursued, they should communicate that request to the Title IX Coordinator or designee, who will evaluate the request in light of the duty to ensure safety of the community and to comply with federal law and institutional policies. MCW will adhere to the Complainant’s wishes on whether to file a Formal Complaint when possible. However, in rare circumstances if information shared with the Title IX Coordinator or other Official with Authority indicates that failure to pursue investigation and remediation may harm the safety and wellbeing of the MCW community, the Title IX Coordinator may independently file a Formal Complaint despite the Complainant’s wishes and may file supplemental or amended complaints as needed.
MCW is required to immediately inform the parents/legal guardian and contact law enforcement if a report of an occurrence(s) of a Prohibited Offense of a minor is submitted.

MCW will respond in a fair and equitable manner to all reports of Prohibited Offenses under this policy.

Initial Evaluation of Formal Complaint

MCW’s Title IX Coordinator is responsible to perform an initial assessment of any Formal Complaint, offer Supportive Measures to each Party and determine next steps. The Title IX Coordinator will assess the facts alleged in the Formal Complaint to determine if the Formal Complaint is actionable under this policy, or if the Formal Complaint is subject to Mandatory Dismissal.

If Mandatory Dismissal is required, the Title IX Coordinator will notify the Complainant. If Mandatory Dismissal occurs because the conduct alleged in the Formal Complaint does not meet the definition of a Prohibited Offense under this policy, the Title IX Coordinator will consider whether other MCW policies may apply and will refer the matter accordingly. Mandatory Dismissal under Title IX is solely a procedural requirement of the law and does not limit MCW’s authority to address a complaint with another policy, process and remedy. A Party can request reconsideration of a Mandatory Dismissal to the Title IX Coordinator by notifying the Title IX Coordinator within seven (7) calendar days. Reconsideration requests will be granted only based upon discovery of new evidence not described in the Formal Complaint.

If Mandatory Dismissal is not required, the Title IX Coordinator will notify the Parties in writing of the Formal Complaint and offer the Parties a choice of MCW’s Title IX: 1) Informal Resolution process; or 2) Formal Grievance process.

Notice to the Parties will include the allegations of a Prohibited Offense(s) with sufficient details known at the time including identities of the involved parties, date and location of the alleged incident, the Formal Grievance process, the availability of an Informal Resolution process, the ability for each Party to have an Advisor of their choice, and the ability to inspect and review all evidence. MCW will inform each Party that the Respondent is presumed not responsible for the alleged conduct until a determination is made at the conclusion of the Formal Grievance process and that MCW prohibits any Party knowingly making false statements or submitting false information during the Formal Grievance or Informal Resolution processes.

MCW will treat Complainants and Respondents equitably by offering Supportive Measures and by following a resolution process before the imposition of any disciplinary sanctions or other actions that are not Supportive Measures against a Respondent. The burden of proof and the burden of gathering evidence rests with MCW. MCW will provide sufficient time to each party before any investigation interview or hearing.

Supportive Measures

MCW will implement Supportive Measures to both Parties in a way that does not unreasonably burden the other Party. Supportive Measures are designed to protect the safety of all Parties and the MCW environment, and/or to deter the occurrence of a Prohibited Offense(s) and/or Retaliation. MCW will maintain the privacy of the Supportive Measures, provided that privacy does not impair MCW’s ability to provide the Supportive Measure. MCW will act to ensure as minimal an academic/occupational impact on the Parties as possible.

Advisors

Each Party has a right to an Advisor of their choosing. A Party can select their own Advisor but if the Party does not have one, the Party may request MCW to provide an Advisor. The Advisor may be from inside or outside of MCW’s community. If MCW provides an Advisor, the Advisor may be an internal or external individual who is trained and familiar with the MCW Title IX Resolution Process. MCW cannot guarantee parity of Advisors, meaning that if one party selects an Advisor who is an attorney, but the other Party does not or cannot afford an attorney, MCW is not obligated to provide an attorney.

Resolution Process

MCW will provide both Parties with information about the available Informal Resolution and Formal Grievance processes. If an Informal Resolution is acceptable to both Parties, the Title IX Coordinator will implement accordingly. No Formal Grievance process is initiated if an Informal Resolution process is desired by both Parties. MCW supports both Parties to expeditiously remediate allegations of prohibited conduct through Informal Resolution.

MCW’s Formal Grievance process complies with all requirements of Title IX, including due process in investigation of Formal Complaints, participation of Advisors, and participation in an in-person hearing before a qualified hearing officer or panel responsible to make findings of responsibility based upon Clear and Convincing evidence.

The MCW Title IX Resolution Process, Informal Resolution and Formal Grievance Process Guides are available under the Attachments section of this policy.

Promptness

All allegations are acted upon promptly by MCW once Notice or a Formal Complaint are provided to an Official with Authority. There may be exceptions and extenuating circumstances that can cause a resolution to take longer, but MCW will avoid all undue delays within its control. If delays occur, MCW will provide a written communication to the Parties about the delay and an estimate of the anticipated additional time that will be needed.

Privacy

MCW will make every effort to preserve the privacy of reports including the identity of any individual who has made a report or complaint of a Prohibited Offense(s) or Retaliation, the identity of the Respondent, witnesses, except where permitted by FERPA or as required by law, or to carry out Supportive Measures and/or the Resolution process arising from this policy. Privacy means that information related to a complaint will be shared with the minimum necessary number of MCW employees who need to know in order to assist in the provision of Supportive Measures, assessment, investigation, and resolution of the report.

Confidentiality

If a Complainant does not wish for their name to be shared, does not wish for an investigation to take place, or does not want to file a Formal Complaint, they may make a request to the Title IX Coordinator who will evaluate that request in light of the duty to ensure the safety of the campus and to comply with state and/or federal law. The Title IX Coordinator has ultimate discretion over whether MCW will proceed when a Complainant does not wish to do so, and the Title IX Coordinator may sign a Formal Complaint to initiate the Formal Grievance process upon completion of an appropriate violence risk assessment.

A compelling risk to health and/or safety may result from evidence of patterns of misconduct, predatory conduct, threats, abuse of minors, use of weapons, and/or violence. The Title IX Coordinator must also consider the effect of the non-participation by the Complainant and the impact it will have on the availability of evidence and the ability to pursue a Formal Grievance process fairly and effectively.

When the Title IX Coordinator executes a Formal Complaint, they are not the Complainant. The Complainant is the individual who is alleged to be the victim of the prohibited conduct. The Complainant retains all rights within this policy and can choose their level of participation. If the Complainant chooses not to participate, MCW will determine an Advisor to be appointed as proxy for the Complainant throughout the process, acting to ensure and protect the rights of the Complainant. MCW’s ability to remedy and respond to the Notice provided by a Complainant, if the Complainant does not want the Title IX Coordinator to proceed with the Formal Grievance process, may impact MCW’s ability to fully provide a remedy to the Complainant. The goal is to provide the Complainant with an much control over the process as possible while also protecting the MCW community.

In cases in which the Complainant requests confidentiality/no formal action and the circumstances allow MCW to honor that request, MCW will offer Informal Resolution options, Supportive Measures, and remedies to the Complainant and the community, but will not otherwise pursue the Formal Grievance process or action.

If the Complainant elects to take no action, they can change that decision if they decide to pursue a Formal Complaint at a later date. Upon making a Formal Complaint, a Complainant has the right, and can expect, to have allegations taken seriously by MCW and to have the incidents investigated and properly resolved through these procedures. Delays may cause limitations on access to evidence, or present issues with respect to the status of the parties.

Independence and Conflict of Interest

The Title IX Coordinator acts with independence and authority free from bias and conflicts of interest. The Title IX Coordinator oversees all resolutions under this policy and the team associated with the resolution. If an MCW employee or student believe that a conflict of interest exists by the Title IX Coordinator or within the Title IX Formal Grievance process, they should report the specific nature of the conflict of interest to the Vice President of Corporate Compliance and Risk Management. If a conflict of interest is determined to be present, the Corporate Compliance Office will appoint a suitable replacement to oversee the investigation and Formal Grievance process in lieu of the Title IX Coordinator.

Any false information provided, or obstruction into the investigation process, by any Party or participant is considered a serious violation of this policy and may subject the non-compliant individual(s) to discipline in accordance with the applicable institutional policy/ies and Handbook(s).

Record Keeping

MCW will maintain records for seven (7) years for each report, and resolution process.

Reporting Requirements to External Agencies

MCW will report findings of violations of this policy to external agencies such as the National Institutes of Health (NIH) and the National Science Foundation (NSF), as required for researchers, as well as, through the credentialing process for clinical providers. MCW may also report findings of violations of this policy to other institutions of higher education and in response to requests for reference information. By accepting employment with MCW, employees agree to be a part of our culture of professionalism and acknowledge that findings may be reported.

References
The Handbook for Campus Safety and Security Reporting (PDF)
Anti-Harassment and Non-Discrimination Policy (AD.CC.050) (internal site that requires unique user ID and password)
University Student Handbook
Medical Student Handbook (PDF)
Graduate Student Handbook (PDF)
Annual Campus Safety Report (PDF)
US Department of Education, Office of Civil Rights
Equal Employment Opportunity Commission
MCW Staff Employee Handbook (internal site that requires unique user ID and password)
MCW Faculty Handbook
MCW Sexual Misconduct Website
MCW Concern Navigation Website (internal site that requires unique user ID and password)
Office of Public Safety Website
VAWA and CLERY Act Policy

Policy Revisions

Effective Date: 07/02/2015
Revision History: 10/15/2015, 4/1/2016, 11/3/2016, 07/01/2018, 08/14/2020
Supersedes Policy: Prohibition on Sex Discrimination and Related Misconduct
Review Date: N/A
Approved By: /S/ John R. Raymond, Sr., MD, President and CEO Medical College of Wisconsin