Corporate Policies and Procedures Administrative and Organizational (AD)

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.

Complainant: An MCW student or employee who is alleged to have been subjected to conduct that could constitute Sex-Based Discrimination or Harassment, or Retaliation under this policy; or a person other than a student who was participating or attempting to participate in MCW’s Educational Program or Activity and who was subjected to conduct that could constitute Sex-Based Discrimination, Harassment or Retaliation under this policy that prevented such person from participating in MCW’s Educational Program or Activity.

Complaint. An oral or written request to MCW that can objectively be understood as a request for MCW to investigate and make a determination about allegations of Sex Discrimination, Sex-Based Harassment, or other Prohibited Offenses under this policy.

Confidential Employees: To provide access and support resources without expectation of an investigation, MCW has designated specific employees as Confidential Employees. Those designated as Confidential Employees are not required to report actual or suspected Sex Discrimination or Sex-Based Harassment or Retaliation in a way that identifies the parties involved. They will provide the name and contact information of the Title IX Coordinator with information about how to file a Complaint and that the Title IX Coordinator may be able to offer supportive measures as well as initiate resolution procedures.

MCW’s Confidential Employees are:

• MCW Ombuds
• MCW Student Navigator (licensed professional counselor)
• Faculty, Staff Physicians and Advanced Practice Providers employed by MCW who gain information from a Complainant or Respondent within the context of the patient/provider relationship with the Complainant or Respondent (and within scope of license). This includes, but is not limited to, MCW Behavioral Health providers treating students of MCW or residents
• An employee designated as confidential for the purposes of providing services to persons related to sex discrimination or sex-based harassment
• Faculty conducting MCW IRB-approved human subject research that involves identifiable data or information about a Prohibited Offense that would otherwise be reportable

Confidential Employees will maintain confidentiality except in cases of immediacy of threat or danger, or information involving abuse of a minor, elder, or individual with a disability, or when required to disclose by law or court order.

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. 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.

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.

Dismissal: MCW may dismiss a 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 Complaint or allegations therein or to cease investigative or hearing procedures, or 2) the allegations in the Complaint, if proven, would not constitute a violation of this policy; or 3) specific circumstances prevent MCW from gathering sufficient evidence to reach a determination from the Complaint or allegations therein, including but not limited to anonymity of one or more individuals involved in the report. MCW will provide simultaneous written notice to the Complainant and Respondent, if known, stating the reasons for the dismissal.

Domestic Violence: Crimes of violence (felony or misdemeanor) 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.

Education Program or Activity: Any operation of MCW, regardless of location. This includes operations occurring within any buildings owned or controlled by MCW as well as locations, events, or circumstances over which MCW exercises substantial control over the context in which the alleged Sex Discrimination, Sex-Based Harassment, or other 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.

Final Determination. A conclusion by preponderance of the evidence (more likely than not) that the alleged Sex Discrimination, Sex-Based Harassment, other Retaliation did or did not violate this policy.

Finding of Responsibility. A conclusion by an authorized decision-maker under this policy (including but not limited to a hearing officer) that based upon the preponderance of the evidence, Respondent engaged in the alleged Sex Discrimination, Sex-Based Harassment or Retaliation under this policy.

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

Hearing Officer: A person or panel of persons trained in Title IX policies, procedures and requirements appointed by MCW to make Final Determination including Finding of Responsibility following a formal hearing on the allegations of a Complaint.

Informal Resolution: Alternate resolution strategies made available following the filing of a 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. MCW has the right to determine that the Informal Resolution process is not an appropriate resolution process.

Mandatory Reporter(s): All MCW faculty and employees (including student workers employed by MCW if a violation occurs when the student is serving in the role), other than those designated under this policy as Confidential Employees, are Mandatory Reporters and are expected to promptly report all known details of actual or suspected Sex Discrimination, Sex-Based Harassment, and/or Retaliation to MCW’s Title IX office or Title IX Coordinator immediately.

Notice: When an employee of MCW, student or third party informs the Title IX Coordinator of the alleged occurrence of Sex Discrimination, Sex-Based Harassment or other Prohibited Offenses under this policy.

Parental Status: The status of being a parent, which means a person who, with respect to another person who is under the age of 18 or who is 18 or older but is incapable of self-care because of a physical or mental disability, is a biological, adoptive, foster, stepparent, legal custodian or guardian, in loc parentis with respect to such a person or actively seeking legal custody, guardianship, visitation, or adoption of such a person.

Party: A Complainant and a Respondent.

Pregnancy or related condition: Pregnancy, childbirth, termination of pregnancy, lactation, and any related medical conditions or recovery periods associated with these conditions.

Preponderance of the evidence: The standard of proof applied at a hearing under Title IX. To support a finding of responsibility under Title IX, a Hearing Officer, after consideration of all relevant evidence admitted at the hearing, must be convinced that it is more likely than not, or 51% more likely, that the violation occurred.

Prohibited Offenses: Sex Discrimination, Sex-Based Harassment, Domestic Violence, Dating Violence, Sexual Assault, Stalking and Retaliation.

Respondent: Individual who is reported to be the perpetrator of conduct that could constitute a Prohibited Offense(s) under this policy. In cases of allegations of Sex Discrimination that are of a programmatic nature, MCW is the Respondent.

Retaliation: Intimidation, threats, coercion, or discrimination against any person by a student, or an MCW employee or agent of MCW, for purposes of interfering with any right or privilege secured by Title IX, or because the person has reported information, made a complaint, testified, assisted, participated or refused to participate in any manner in an investigation, proceeding, or hearing under this policy. Retaliation is intentional conduct that adversely impacts a person who has participated in any aspect of any procedures under this policy. Retaliation may include conduct by a peer, student or employee 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.

Sex: Sex assigned at birth, sex stereotypes, sex characteristics, pregnancy or related conditions to sexual orientation, and gender identity. The term ‘gender identity’ refers to a person’s inner sense of their own gender (male/female/non-binary). The term ‘sexual orientation’ refers to an individual’s sexuality preferences (LGBTQ+) and includes a history of one’s sexuality as well as being identified as having a sexual preference.

Sex-Based Harassment: Unwelcome conduct that is either Sexual in nature or on the basis of Sex and which constitutes: 1) Quid Pro Quo Harassment; or 2) Hostile Environment Harassment, or 3) Sexual Assault, Domestic Violence, Dating Violence, or Stalking.

Sexual means the conduct itself has a sexual nature. On the basis of sex means the conduct is targeted at a person because of their Sex.

Quid Pro Quo harassment occurs when an employee, agent or other person authorized by MCW to provide an aid, benefit, or service under an MCW Education Program or Activity explicitly or impliedly conditions the provision of such aid, benefit or service on a person’s participation in unwelcome sexual conduct.

Hostile Environment harassment is unwelcome, sex-based conduct that, based upon the totality of circumstances, is subjectively and objectively offensive and is so severe or pervasive that it limits or denies a person’s ability to participate in or benefit from MCW’s Education Program or Activity (i.e., creates a hostile environment).

Sex Discrimination: Adverse treatment of a person on the basis of the person’s Sex. Conduct which limits or excludes a person from participating in an MCW Education Program or Activity or denies or limits the benefits thereof because of Sex. Prohibited Sex Discrimination includes programmatic discrimination and individualized discrimination where a particular decision or action is taken that adversely impacts the Complainant by limiting, excluding from participation, or denying or limiting benefits of a program or activity. Programmatic discrimination occurs in a systemic way due to an institutional policy or practice, and disparately impacts persons as a group or category and is typically not attributed to an individual Respondent. Sex Discrimination includes sex separation that results in more than de minimis harm.

Sexual Assault: An offense classified as a forcible or non-forcible sex offense under the uniform crime reporting system of the Federal Bureau of Investigation, including rape, statutory rape, fondling and incest. https://ucr.fbi.gov/crime-in-the-u.s/2019/crime-in-the-u.s.-2019/topic-pages/offense-definitions

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 individual 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 Complaint in order to restore or preserve equal access to MCW’s Education Programs and Activities during investigation. Supportive Measures may include, but not be limited to, mutual no-contact orders during the investigation stage. Supportive Measures are not disciplinary and shall be implemented utilizing the least restrictive means possible.

Title IX: Enforced by the U.S. Department of Education’s Office for Civil Rights, Title IX of the Education Amendments of 1972 applies to higher education institutions that receive federal funds.

Title IX Coordinator: MCW has designated a Title IX Coordinator who serves as a neutral party to oversee reports of alleged violations and compliance with Title IX. References to the Title IX Coordinator throughout this policy may also encompass a designee of the Title IX Coordinator for specific tasks.

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.

MCW is committed to providing an educational and employment environment that is free from unlawful discrimination based upon Sex, Sex-Based Harassment and Retaliation. MCW values and upholds the dignity of all members of the MCW community and strives to balance the rights of individuals in the resolution processes within its Title IX program.

This policy describes MCW’s process for investigation and remediation of Complaints of Sex Discrimination, Sex-Based Harassment, and Retaliation within an Educational Program or Activity. All MCW faculty, staff, students, and volunteers are subject to this policy.

Aligned with our values, MCW will treat all Parties with respect before, during and after any process conducted under this policy. MCW will presume the innocence of any Respondent until a determination is reached in the Formal Grievance process or until MCW’s Informal Resolution process has concluded.

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 may 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.

Scope

This policy is only applicable to alleged incidents occurring after August 1, 2024. For alleged incidents of Sex Discrimination and sexual harassment occurring prior to August 1, 2024, the policy and procedures in place at the time of the alleged incident apply. Applicable versions of those policies and procedures are available from the MCW Title IX Coordinator, whose contact information is:

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

Jurisdiction

This policy applies to all allegations of Sex Discrimination, Sex-Based Harassment, or Retaliation within the Education Program and Activities of MCW. This includes MCW’s operations as an institution of higher education. This policy covers incidents occurring at locations, events, or circumstances where MCW exercises substantial control over both the Respondent and the context in which the conduct occurred. This includes any student conduct over which MCW has disciplinary authority, and to misconduct occurring within any location owned or controlled by an MCW-recognized student organization.

This policy may also apply to the effects of off-campus misconduct that limit or deny a Complainant’s access to MCW’s Education Program and Activities.

Vendors serving MCW through third-party contracts are subject to the policies and procedures of their employers.

MCW’s Title IX Coordinator may be able to support and assist a student or employee who reports misconduct that is outside the jurisdiction of this policy, such as when a Respondent is enrolled in or employed by another institution.

Standard of Proof

MCW uses the preponderance of the evidence standard of proof when determining a Finding of Responsibility under this policy or Final Decision that a Respondent’s conduct violated MCW’s Title IX policy. This means that MCW will decide whether it is more likely than not, based upon the totality of information available at the time of decision, that the Respondent is in violation of the Title IX policy.

Mandated Reporting by MCW Employees and Agents:

All MCW faculty and employees of all classifications (including student workers), other than those designated as Confidential Employees, and all authorized agents of MCW are Mandatory Reporters under this policy and are expected to promptly report all known details of actual or suspected Sex Discrimination, Sex-Based Harassment or Retaliation to MCW’s Title IX Coordinator.

The Title IX Coordinator’s contact information is:

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

Complainants may want to carefully consider whether they share personally identifiable information with Mandatory Reporters, as those details must be shared with the Title IX Coordinator.

Failure of a Mandatory Reporter, as defined in this policy, to report an incident of Sex Discrimination, Sex-Based Harassment or Retaliation of which they became aware is a violation of MCW policy and can be subject to disciplinary action for failure to report. A Mandatory Reporter who is themselves a target of Sex Discrimination, Sex-Based Harassment or Retaliation is encouraged, but not mandated, to report as a Complainant.

Reporting Options for Complainants or third parties (parents/guardians):

A Complainant provides Notice to MCW that the Complainant would like to initiate an investigation or other appropriate resolution procedures. A Complainant or other individual with knowledge of a potential violation of this policy may be made using any of the following options:

1. File a Complaint with, or give verbal Notice directly to, the Title IX Coordinator or the Office of Equal Access. Such a Complaint may be made at any time (including non-business hours) by using the following contacts:

Title IX Coordinator: TitleIXCoordinator@mcw.edu
Equal Access: EEOaccess@mcw.edu
Phone: (414) 955-8668 or (414) 955-4858

2. File online Notice electronically: Grievance Form for Discrimination/ Harassment
3. Report using MCW’s EthicsPoint Hotline: https://secure.ethicspoint.com/domain/media/en/gui/61161/index.html

Note that anonymous reports are accepted by EthicsPoint; however, anonymous reports limit MCW’s ability to investigate, respond, and provide remedies, depending on what information is shared. Anonymous reports may lead to Dismissal if MCW is unable to determine, with reasonable certainty, that a potential violation has occurred that can be investigated fairly based upon the information provided. 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 https://www.eeoc.gov/field-office for information about the office closest to you. You may also call 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 #: (800) 421-3481
Facsimile: (202) 453-6012
TDD#: (877) 521-2172
Email: OCR@ed.gov
Web: http://www.ed.gov/ocr

There is not a time limitation on providing Complaints to the Title IX Coordinator. However, if the Respondent is no longer subject to MCW’s jurisdiction and/or significant time has passed, MCW’s ability to investigate, respond and/or provide remedies may be more limited or impossible.

Confidentiality of Reports

MCW makes every effort to preserve the privacy of Complainants and Respondents and those involved in reporting or other witnesses. 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, safety and risk analysis, and resolution of the report. Information is maintained separately from all employee personnel files and student academic files. Confidentiality is not guaranteed. MCW may disclose information to fulfill the purposes of applicable laws and regulations (Title IX), or as otherwise required by law.

Resolution of Complaints

MCW will act on any Notice or Complaint of a potential violation of the Title IX policy that is received by: 1) the Title IX Coordinator; 2) MCW’s Office of Equal Access; or 3) MCW’s EthicsPoint hotline.

The procedures below apply to all allegations of Sex Discrimination, Sex-Based Harassment or Retaliation involving MCW students, staff, administrators, faculty, or third parties.

Intake Process (Title IX Coordinator)

Upon receipt of Notice or Complaint of an alleged violation of this policy, the Title IX Coordinator will initiate a prompt initial evaluation to determine MCW’s next steps. The Title IX Coordinator will contact the Complainant to offer Supportive Measures, provide information regarding MCW’s Formal Grievance and Hearing Process and Informal Resolution Process. It is expected that intake process will typically take one (1) to five (5) business days. 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. Upon recommendation from the Title IX Coordinator, to preserve integrity of the Resolution process, an MCW employee who is a Complainant or Respondent may be placed on paid administrative leave pending investigation of the Complaint.

MCW will adhere to the Complainant’s wishes on whether to proceed with investigation following intake. However, in rare circumstances if information shared with the Title IX Coordinator 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 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 of a minor and contact law enforcement if a report of an occurrence(s) of a Prohibited Offense of a minor is submitted.

The Title IX Coordinator’s decisions regarding Supportive Measures and Emergency Removal are subject to appeal by either a Complainant or a Respondent. Appeals must be submitted via email within 10 calendar days of notice of the Supportive Measure or Emergency Removal action. Appeals shall be determined by the Senior Director, Equal Access: eeoaccess@mcw.edu.

The Title IX Coordinator may determine during the intake process that the allegations in a Complaint, if substantiated, would not constitute a violation of this policy. If the Complaint does not allege conduct that, if proven true, would violate this policy, the Title IX Coordinator will inform the Complainant or Mandatory Reporter, as appropriate, of Dismissal. Dismissal may be appealed within 3 business days of the date of Dismissal to the Senior Director, Equal Access by email to: eeoaccess@mcw.edu.

Advisors

Each Party has a right to an Advisor of their choosing. No Party is required to use an Advisor during Informal Resolution Processes. 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. An Advisor shall not have a conflict of interest with the proceedings or be a witness to any fact relating to allegations in the Complaint. Senior executives and faculty leaders of MCW are not eligible to serve as Advisors.

Resolution Process Selection

MCW offers two pathways by which Complaints of violations of this policy may be resolved: 1) the Formal Grievance and Hearing Process; or 2) the Informal Resolution process. These procedures are MCW’s chosen approach to addressing all forms of Sex Discrimination, Sex-Based Harassment and Retaliation. Resolution proceedings are confidential. All individuals present at any time during either resolution process are expected to maintain confidentiality of the proceedings.

The Title IX Coordinator or designee will provide the Respondent with a notice of the Complaint including a summary of the Complaint and shall then provide both Parties with information about the available Informal Resolution and Formal Grievance and Hearing processes and supportive measures. If an Informal Resolution is acceptable to both Parties and is deemed suitable by the Title IX Coordinator, 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 violations of this policy through Informal Resolution.

MCW’s Formal Grievance and Hearing process complies with all requirements of Title IX, including due process in investigation of Complaints, participation of Advisors, and participation in an independent hearing before a qualified hearing officer or panel responsible to make a Final Determination and/or Findings of Responsibility based upon preponderance of the 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 a Notice or Complaint are provided to the Title IX Coordinator. 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.

Anonymity

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 participate in the investigation of a 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 Complaint to initiate the Formal Grievance and Hearing process upon completion of an appropriate safety and risk analysis.

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 Complaint, they are not the Complainant. The Complainant is the individual (may be unidentifiable) 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, this may impact MCW’s ability to fully provide a remedy to the Complainant. The goal is to provide the Complainant with as much control over the process as possible while also protecting the safety of 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 and Hearing process or action.

If the Complainant elects to take no action, they can change that decision if they decide to pursue a Complaint at a later date.

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 and Hearing 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.

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.