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1. There are now two university policies that prohibit discrimination based on sex. The Title IX Policy and Grievance Procedures apply to formal complaints of sexual harassment defined by the United States Department of Education’s Title IX regulation. All other forms of sexual harassment, sexual misconduct, and sex-based discrimination not covered by the Title IX Policy and Grievance Procedures are covered by the University’s Procedures for Complaints Alleging Gender-Based or Sexual Misconduct in the Workplace (when respondents are faculty or staff) and the Student Code of Conduct (when respondents are students). I want to emphasize that all forms of sex-based discrimination and harassment that had been prohibited by our policies, whether under the Title IX Policy or other policies, remain prohibited.
2. We have returned to a limited definition of employees who are considered “responsible employees.” Because of the 2020 Title IX regulations, the following are “responsible employees": 

• Senior Staff
• Faculty with administrative or supervisory responsibilities (deans and associate deans, heads and chairs, vice provosts, graduate and undergraduate program directors, faculty athletic representatives, and directors of centers and institutes)
• All staff that serve as academic advisors
• All coaches and trainers
• All advisors to Registered Student Organizations, intramural sports, and other student groups
• All personnel in Student Affairs, including Residential Life employees, except for confidential employees
• Staff in managerial and supervisory roles

3. The federal definition of sex discrimination under the 2020 Title IX regulations does not include gender identity, gender expression, or sexual orientation. However, Massachusetts law prohibits discrimination and harassment based on gender expression, gender identity, and sexual orientation, and the university’s Sexual Misconduct Policy and Student Code of Conduct maintain protections.
4. Only those involved in processing Title IX reports and complaints must take Title IX training annually. However, all faculty and staff (especially those who continue to be Responsible Employees) will be invited to take Title IX and preventing sexual harassment training through our online training vendor, Vector Solutions, in the next few weeks. This training is recommended to ensure that faculty and staff are aware of possible requirements under our policies and how to address reports of prohibited discrimination and harassment affecting the campus community. All newly hired employees will be required to take the Vector Training within 45 days of their start dates as this is required by Massachusetts state law.
5. Because of protections under 2020 TIX regulations, and other federal and state laws, our policy will continue to prohibit discrimination and provide reasonable accommodations due to pregnancy, childbirth, or related medical conditions including lactation or the need to express breast milk.