Women's Equality Day 2022

Shaping Title IX: ERA Supporters Submit Official Comments to DOE

Noreen Farrell, Executive Director

Read ERA student client stories

On Sept. 12, 2022, ERA supporters submitted 185 official comments to the Dept. of Education on newly proposed Title IX regulations. Responding to the Department’s request for public feedback, students, parents, educators, advocates, and other ERA community members urged better protections for students experiencing discrimination, harassment, and sexual violence. (More below.)

The proposed regulations would undo horrific Trump-era changes, but we know the Biden Administration can do even better. And they need to act now. This is our opportunity to safeguard student rights at the federal level while states continue to attack trans children.

“While we are heartened to see the reforms proposed by the Department of Education, we will always push for greater protections for our nation’s most vulnerable students, including students of color, LGBTQI+ students, and victims of sexual violence.”

-Executive Director Noreen Farrell

Of 240,000+ comments submitted nationally, ours were unique: our team held listening sessions at high schools across the country this summer and incorporated student feedback. What’s more, our template allowed and encouraged commenters to share personal experiences while using our official formatting and citations to ensure their voices will be heard.

The 185 supporters who joined us from 28 states include:

  • a teenager whose school “has received concerning complaints about sexual harassment,”
  • a grandmother and “always-voter,”
  • a public school teacher in Maryland,
  • an advocate in Texas,
  • “the aunt of a soon-to-be 15 year old trans child” in California who wishes “all kids to be healthy and safe as well as my nephew,”
  • a concerned citizen in Georgia,
  • a high school director of security, and
  • the parent of a gender nonbinary 8th grader who “is very concerned that transgender kids like them are being excluded from sports and school facilities correlating with their gender identity.”

Together, we reminded Education officials that students are the experts on what is needed from schools to ensure gender-based discrimination and harassment do not interfere with their education. So taking student feedback and concerns into account, we recommended the following:

  • Requiring trauma-informed training for all school employees involved in the Title IX process
  • Protections for students who choose to speak out publicly about the sexual violence, harassment, or gender discrimination they experienced
  • Options for high school students to consult a school employee confidentially about an incident without mandating an official Title IX report
  • For college and higher education, eliminating live cross-examination (interrogation) at Title IX hearings, which is very often retraumatizing for the survivor; and lowering the evidence standard, which was raised under the Trump Administration, making it often impossible to “prove” the sexual assault/harassment occurred

Read ERA’s official organizational comment.


Help us keep this student-powered activism going with a donation to our NextGen fund, which builds innovative student partnerships; mobilizes students on core issues impacting them; increases economic security for families with children; ensures equity in academics and sports through Title IX enforcement; and trains, supports, and connects pro bono attorneys with students in need.

Let’s keep students’ voices at the forefront of our advocacy work, always.

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