1. Sexual Misconduct Policy Title IX & Violence Against Women Act (VAWA)
National American University
Responsible Employee Training
2015

2. Title IX and VAWA
Title IX of the Education Amendments of 1972 (20 USC § 1681 et seq.) and the Violence Against Women Reauthorization Act of 2013 (VAWA) (42 USC § et seq.) together prohibit sex discrimination, sexual harassment, sexual violence, domestic violence, dating violence, and stalking that take place on a campus, via other media, or at a university sponsored event. These acts are prohibited whether by a student, faculty member, staff member, or a third party.
Source: United States Department of Education Office of Civil Rights and Violence Against Women Act (VAWA) Federal Registry

3. NAU’s Sexual Misconduct Policy and Harassment and Nondiscrimination Policy are available at:
Each responsible employee should carefully review NAU’ Sexual Misconduct Policy and Harassment and Nondiscrimination Policy available at:
NAU Public Website
Undergraduate, Master’s, and Doctoral Academic Catalogs
Student Portal
MyNAU Faculty and Staff Intranet

4. “Responsible Employees”
The following persons are designated as “responsible employees” in NAU’s Sexual Misconduct Policy:
Faculty
Campus Directors
Regional Academic Deans
Regional Vice Presidents
Human Resources Employee Relations
System Director for Human Resources

5. Responsible Employees are Required to:
If a responsible employee becomes aware of, or should have reasonably been aware of, an incident of sexual misconduct, the employee is required to:
Report the incident to the Title IX Coordinator.
Promptly complete an intake form with information about the incident and provide the intake form to the Title IX Coordinator (even if the student asks that no action be taken). The intake form is available at
Implement interim measures, as appropriate.

6. When an Incident is Reported to You:
Ask open-ended questions (Example: “Tell me what has been going on “ ) Avoid leading questions.
First Priority: LISTEN
Be empathetic
Encourage the person to file a police report – but don’t push
Encourage the person to receive a medical exam (A medical exam is not required to file a police report.)
Inform the person that you are required to report the information to the Title IX Coordinator.
Be aware that the story may be disconnected and the person may have difficulty remembering all details. This does not mean that the person is not truthful.
Remember: You are receiving the initial complaint. You are not conducting an investigation.

7. Do Not: When an incident is reported to you: Don’t ask . . .
Why were you there?
Did you drink too much?
Why did you wear what you did?
Why did you wait so long to report the incident?
Don’t blame the victim.
Don’t judge the victim.
Don’t let you opinions and reactions show.
Don’t make admissions. Say, “If that happened, I am so sorry.”

8. Interim Measures
The Title IX Coordinator and Campus Director will determine and implement measures, as appropriate. However, you can take immediate actions to provide comfort and protection.
Consider the person’s immediate needs and the safety of other students, faculty, and staff.
For example, you can . . .
Walk the person to the next class or the person’s car
Excuse the student from class
Provide a community resource list, which is available at each campus and on NAU’s website at

9. Confidentiality Do not promise confidentiality.
A request for confidentiality is considered by the Title IX Coordinator.
Strict confidentiality may limit the university’s ability to respond to the complaint.
Ask the person to sign a consent form available at
The incident can only be discussed with people with a “need to know.”
Campus Director
Title IX Coordinator
Regional Academic Dean
Human Resources
Office of General Counsel

10. Contact Information
Students should contact:
Karen Hoffman Title IX Coordinator/System Director, Office of Student Concerns S. Highway 16 Rapid City, SD (Office)
Employees should contact:
Michael Morford Human Resources Employee Relations S. Highway 16 Rapid City, SD (Office)