EROC’s Full Testimony during the Department of Education’s Title IX Public Hearing.


Washington, DC | June 11, 2021

Good Afternoon and thank you to all survivors who came forward to share their testimony verbally and written this week. I believe you. My name is Kenyora Parham, serving as the Executive Director of End Rape On Campus. I’d like to remind the Department of Education that prior to, during, and after the Betsy DeVos-era, campus sexual violence continues to remain a public health crisis that widens and deepens the education gap and mental health disparities for students, more specifically student survivors I have spoken with, who identify within and attend Historically Black Colleges & Universities, Tribal and Hispanic serving institutions, and community colleges, may be Muslim, Jewish, LGBTQIA, are neurodiverse, undocumented, or a combination of the above or other intersectional and marginalized identities. 

These students face higher rates of sexual harassment and overall violence in addition to their peers and counterparts, who attend predominately white institutions. Yet, they underreport due to being unaware of their rights under Title IX, their subjection to victim-blaming ideology held by their peers, campus administration and public safety, and the additional perpetuation of stereotypes and biases–both conscious and subconscious that ultimately denies these students their right to understand, engage in and navigate the Title IX process, and ultimately gain justice. 

The undue burden and mental health effects of not only having been violated by their perpetrators, but also by the very institutions that should be there to support them, are instead denying and silencing them. Furthermore, it doesn’t help when the narrative that campus sexual assault only happens to those who don’t look like them are continuously portrayed by the media or within our history books. Therefore, we must center and uplift these students and make them hidden no more.

Here are five, non-exhaustive priority areas we recommend the Department of Education, through an intersectional, survivor-centered, and trauma-sensitive lens, swiftly and appropriately address and replace within the current regulations. Please note that our full written statement is forthcoming.

  1. The requirement of all institutions of higher education to adopt a comprehensive, educational training program, designed to equip their communities on an ongoing basis about gender-based violence and harassment and their rights under school policy and relevant laws. 
  2. Adopt new language that expands upon the sexual harassment definition and that ensures that regardless of the level of severity of the harassment, students’ experiences are taken seriously and swift action is taken to address incidences.
  3. Enforce regulations that explicitly prohibit any form of retaliation against student survivors, including, but not limited to disciplining students who report they were sexually harassed or witnessed prohibited sexual misconduct on school grounds, the threat and removal of scholarships, visas, and other accommodations and resources. 
  4. Provide transparency to students at institutions that claim exemption from Title IX, including a list of those schools who claim exemptions and explicitly list what constitutes exemption.
  5. Expand upon access to and types of supportive measures and accommodations that are culturally competent, intersectional, and appropriately support student survivor’s continued access to education, including the enforcement of orders of protection, and the requirement of free access for mental health and disability services.

All students regardless of and with respect to their identities, deserve an education that is free from violence. I yield my time.