In January 2019, the Association for the Treatment of Sexual Abusers (ATSA) submitted comprehensive comments on the proposed changes to Title IX rules, particularly regarding the handling of sexual harassment in educational institutions. ATSA supports an inclusive definition of sexual harassment, encompassing a range of behaviors that interfere with equal access to education. The organization criticizes the proposed rules for narrowly defining sexual harassment, arguing that this could lead to underreporting and insufficient support for both victims and those who exhibit concerning behaviors.

ATSA emphasizes the need for policies that enable early intervention, offering individualized, risk-based interventions. The document also highlights the importance of sanctions being individualized and appropriate to each case, rather than adopting a one-size-fits-all approach. Additionally, ATSA advocates for equal representation and access to advisors for all parties involved in a Title IX grievance process, ensuring fairness and equity.

This document reflects ATSA’s commitment to promoting safe educational environments, balanced policies, and the effective prevention of sexual harassment in academic institutions.