In their January 2019 comments on proposed Title IX rule changes, ATSA advocates for a comprehensive definition of sexual harassment that includes a range of behaviors impacting equal access to education. They criticize the proposed narrow definition, fearing it may reduce incident reporting and support for victims and perpetrators. ATSA supports individualized sanctions, equitable representation for all parties, and the application of Title IX rules to all educational institutions. The letter emphasizes the need for evidence-based prevention programs and policies promoting safe learning environments.