Section 504 Impartial Due Process Hearing Procedures

The following procedures are Movement School’s impartial due process hearing procedures pertaining to the identification, evaluation, or educational placement of student who, because of a disability, need or a believed to need related services and other supports under Section 504 of the Rehabilitation Act of 1973.

For disputes about the identification; evaluation; placement; provision of a free appropriate public education; and discipline of students under the Individual with Disabilities Education Act (“IDEA”), Movement School complies with the impartial due process hearing procedures established under the Individual with Disabilities Education Act, Article IX of Chapter 115C of the North Carolina General Statutes, Chapter 150B of the North Carolina General Statutes, and the North Carolina Policies Governing Services for Children with Disabilities in matters involving disputes. More information about disputes under the IDEA is accessible here:

A. Request for Section 504 Impartial Due Process Hearing
The parent/guardian of a student (or an adult student) with a disability as defined by Section 504 of the Rehabilitation Act of 1973 (“Section 504”) may request an impartial hearing to resolve disagreements related to the identification, evaluation, or educational placement of the student under Section 504. See 34 C.F.R. § 104.36.

B. Scope of Jurisdiction for a 504 Impartial Due Process Hearing

  1.  A 504 Impartial Due Process Hearing (“504 Hearing”) is available to resolve disagreements relating to the identification, evaluation, or educational placement of a student with a disability, as provided in Section 504.
  2. A 504 Hearing is not available for disagreements arising under Section 504 that do not relate to identification, evaluation, or educational placement.
  3. A 504 Hearing is not available for disputes or disagreements that can be addressed through the due process procedures set forth in the Individuals with Disabilities Education Act (“IDEA”). See 20 U.S.C. § 1415 (f).

C. Parties to a 504 Hearing

  1. The parties to a 504 Hearing are (1) the parent/guardian of a minor student with a disability under Section 504, or the student if 18 or older (the “Complainant”); and (2) Movement School’ administration, represented by the district’s Section 504 Coordinator (“504 Coordinator”) or designee (the “Respondent”).
  2. To be eligible for a Section 504 Hearing, a student must be enrolled in Movement School. Withdrawal from enrollment is grounds to reject a request for hearing or terminate a hearing procedure that is in process.

D. Request for a 504 Hearing

  1. A request for a 504 Hearing shall be made in writing and directed to the 504 Coordinator.
  2. A hearing must be requested within sixty (60) calendar days of the decision giving rise to a dispute related to the identification, evaluation, or educational placement of a student.
  3. A request for a 504 Hearing must include the following information:

a. The name, street address, mailing address (if different), telephone number, and e-mail address (if available) of the Complainant;

b. The name of the student, residence address of the student (or available contact information in the case of a homeless student), and name of the school the student is enrolled in and attending;

c. A description of the decision(s) made by the school giving rise to the dispute, including facts and dates relating to such decision(s) and the name(s) of the individual(s) who made such decision(s);

d. A specific description of how the decision(s) violated Section 504; and

e. A proposed resolution to the dispute to the extent known or reasonably available to the Complainant at the time.

  1. When the Complainant requests a 504 Hearing, he or she must bring all claims and all potential claims that can be raised at the time Complainant makes his or her request.
  2. A Complainant may, in lieu of a 504 Hearing, make a written request for a hearing before the board. If a Complainant requests a hearing before the board, he or she waives his or her right to a hearing by an impartial hearing officer. Upon request of the Complainant, the board will hold a hearing. The board will provide a written response within thirty (30) days after receiving the request, unless further investigation is necessary, or the hearing necessitates that more time be taken to respond.

E. Screening by 504 Coordinator

  1. The 504 Coordinator shall review the request for a 504 Hearing in consultation with the board attorney.
  2. The 504 Coordinator may deny a 504 Hearing request if the request does not meet the criteria of Sections I, III, or IV.
  3. The 504 Coordinator also may deny a 504 Hearing request if the request does not present a viable claim under Section 504. This provision is to avoid unnecessary expense and educator time in addressing clearly unmeritorious claims, analogous to the manner in which unmeritorious claims in judicial proceedings may be resolved without trial through dismissal or summary judgment. In making this decision, the 504 Coordinator shall not deny a claim merely because the 504 Coordinator thinks the claim is unlikely to prevail. Rather the board attorney shall be guided by the standards of Rules 12(b) and 56 of the North Carolina Rules of Civil Procedure, dealing with dismissal and summary judgment, respectively.
  4. The 504 Coordinator may deny the 504 Hearing request if any of the following are true:

a. The same or similar allegation(s) based on the same operative facts has been previously decided;

b. The board has recently investigated or is currently investigating the same or similar claim(s) based on the same operative facts in the same school year for the same student;

c. The same or similar claim based on the same operative facts has been filed by either the Complainant or someone other than the Complainant against Movement School through the board’s internal grievance procedures or another federal, state, or local civil rights enforcement agency; or

d. The board obtains credible information indicating that the allegations raised by the Complainant are currently resolved and are therefore no longer appropriate for investigation.

  1. The 504 Coordinator may communicate with the Complainant to clarify and/or narrow the request for hearing.
  2. The 504 Coordinator shall notify the parties of his/her decision as to whether the parent is entitled to a 504 Hearing. If a request for a 504 Hearing is denied in full or in part, the notice shall identify the reason(s) for the denial.
  3. The 504 Coordinator shall complete his/her review and notify the parties within fourteen (14) calendar days of receipt of the hearing request if feasible. This time period may be extended if it is necessary for the 504 Coordinator to communicate with the Complainant.

F. Appointment and Engagement of an Impartial Hearing Officer (“IHO”)

  1. Within ten (10) school days of the written notice from the 504 Coordinator approving a 504 Hearing, or as soon thereafter as is feasible, the 504 Coordinator shall appoint an Impartial Hearing Officer (“IHO”).
  2. The IHO shall have expertise and experience in disability law. The 504 Coordinator will consult with the board attorney regarding suitable IHOs.
  3. The 504 Coordinator and the Movement School Finance Officer shall approve and execute an Engagement Agreement with the IHO. The Engagement Agreement shall include a reasonable “Not to Exceed” amount. If the “Not to Exceed” amount precludes a 504 Hearing, then Movement School shall renegotiate the Engagement Agreement with the IHO.

G. Pre-Hearing Procedures

  1. Within ten (10) school days after execution of the Engagement Agreement, the IHO shall arrange a pre-hearing conference with the parties. The pre-hearing conference may be by telephone.
  2. At the pre-hearing conference, the IHO shall:

a. Secure a date, time, and location for the hearing that is convenient to both parties and, if feasible, schedule to commence within thirty (30) calendar days of the pre-hearing conference;

b. Ascertain whether the parties will be represented by counsel at the hearing; and

c. Identify the specific issues to be addressed during the hearing based on the request for hearing, the proposed resolution provided by the Complainant, and the board attorney’s screening of the request for hearing.

  1. After the pre-hearing conference, the IHO shall notify the parties of the results of the pre- hearing conference and any other relevant matters concerning the hearing.
  2. The parties shall provide to each other and the IHO a list of witnesses and any documents to be presented during the hearing at least five (5) school days in advance of the hearing, unless otherwise permitted by the IHO for good cause shown. The IHO has the authority to exclude any documentary evidence which was not provided and any testimony of witnesses who were not identified at least five (5) school days before the hearing.
  3. Each party shall be limited to ten (10) witnesses, unless otherwise permitted by the IHO for good cause shown.
  4. If the Complainant designates more than five (5) Movement School employees as witnesses, Movement School may elect to have no more than five (5) of such designated witnesses attend the hearing. On request of Movement School, the IHO may rule that any Movement School employee designated as a witness by the Complainant need not appear if the witness’s testimony appears likely to be redundant, irrelevant, or of marginal value.
  5. Documentary evidence shall be directly related to the specific issues identified by the IHO during the pre-hearing conference.
  6. Each party shall be limited to five hundred (500) pages of documents (not counting 504 plans, evaluation results, meeting notes, and notices of meetings), unless otherwise permitted by the IHO for good cause shown.
  7. If a party submits for evidence any audio recordings exceeding sixty (60) minutes cumulative, the party shall identify (by minute and seconds) the portion(s) of the recording to be presented as evidence and a “best efforts” transcription of such portion(s).
  8. The 504 Coordinator shall arrange for a tape recording of the hearing. Each party will be entitled to receive a copy of the tape recording. In addition, if requested by either party, the IHO shall arrange for the hearing to be recorded by a court reporter who is to be paid for his or her attendance by the party requesting the court reporter.

H. Hearing Procedures

  1. A hearing is to be completed within sixty (60) school days of appointment of execution of the Engagement Agreement, unless an extension of time is granted at the request of either party for good cause shown or by mutual agreement of the parties.
  2. A hearing is not to last more than two (2) days. Accordingly, each party shall be limited to two hundred forty (240) minutes of hearing time to present his or her main case and rebuttal (not counting cross-examination time or questions by the IHO). Parties shall organize their cases so as to make their presentations within these time limitations.
  3. The North Carolina Rules of Evidence are instructive, but not controlling; the IHO may admit any evidence deemed, in his/her sole discretion, to be competent and relevant.
  4. The party requesting the hearing carries the burden of proof.
  5. The parties have the following rights in a hearing:

a. To be represented by legal counsel with each party being responsible for its own attorney’s fees;

b. To present evidence and cross examine witnesses;

c. To request that the IHO prohibit the introduction of evidence and testimony of any witnesses that were not disclosed five (5) business days prior to the hearing;

d. To obtain a copy of the tape recording of the hearing;

e. To obtain at their own expense a copy of the transcript of the hearing, if the hearing is recorded by a court reporter;

f. To submit a pre-hearing statement at least forty-eight (48) hours prior to the hearing; and/or a post-hearing statement within seven (7) calendar days after the hearing.

  1. In connection with the hearing, the IHO shall:

a. Maintain an atmosphere conducive to fairness and civility;

b. Maintain impartiality;

c. Ensure that the evidence in the hearing is relevant to the issues identified at the pre- hearing conference, or to any subsequent amendment of the issues if such amendment is mutually agreed upon by the parties or otherwise permitted by the IHO for good cause shown;

d. Maintain accurate record of the proceedings; and

e. Efficiently move the case to conclusion within the two (2) day limitation.

I. Decision of Impartial Hearing Officers

  1. A written decision shall be issued to all parties setting forth the IHO’s Findings of Fact and Conclusions of Law based on the evidence presented in the hearing.
  2. The decision shall be issued within thirty (30) calendar days after the conclusion of the hearing, unless extended for good cause upon request of either party to the hearing.
  3. The IHO shall apply the legal standards that would apply to a civil lawsuit alleging a violation of Section 504 within the jurisdiction of the Fourth Circuit Court of Appeals.
  4. The IHO’s decision is final and binding on all parties unless either party files a timely appeal.

J. Appeal

Either party may appeal, in writing, to any entity with competent jurisdiction, within fourteen (14) calendar days after receipt of the decision. Movement School does not by these 504 Hearing procedures purport to confer jurisdiction on a court. The rules and procedures of the entity to which an appeal is made shall govern the proceeding(s).

K. Modification of Mutual Consent

The parties may by mutual consent modify any of the procedures set forth herein, so as to achieve convenience or efficiency under the particular circumstances.

L. Timelines

The timelines specified in these procedures for action by Movement School employees/agents or the IHO shall be regarded as directory and subject to “best efforts,” but failure of Movement School employees/agents or the IHO to meet a timeline under these procedures shall not invalidate otherwise lawful actions or decisions.

Title IX Sexual Harassment

Prohibited Conduct and Reporting Process Policy

I. Purpose

The Board prohibits discrimination on the basis of sex, including any form of sexual harassment as that term is defined under Title IX, in any education program or activity of the School. The Board takes seriously all reports and Formal Complaints of sexual harassment. The School does not discriminate on the basis of sex in its education programs or activities, including admission and employment, in accordance with Title IX of the Education Amendments Act of 1972 and federal regulations.

Any person with questions about this policy should contact the School’s Title IX Coordinator whose information is listed at

II.         Reason for Policy

The United States Department of Education has adopted formal rules related to sexual harassment as prohibited by Title IX of the Education Amendments of 1972 (May 2020). These new regulations require additional procedures and policies related to programs using federal funds. The new law focuses on procedures for reporting, investigating and finding illegal sexual harassment as the term is defined by the rule. The Board has always prohibited discrimination based on sex and sexual harassment in educational programs and activities implemented by it. This policy is intended to comply with the mandates of 34 CFR 106 and other provisions of Title IX.

III.         Definitions

A.    Sexual Harassment
Sexual Harassment prohibited under Title IX and by this policy is conduct on the basis of sex occurring in a School education program or activity that satisfies one or more of the following:

    1. an employee of the School conditioning the provision of an aid, benefit, or service of the School on an individual’s participation in unwelcome sexual conduct;
    2. unwelcome conduct determined by a reasonable person to be so severe, pervasive, and objectively offensive that it effectively denies a person equal access to the School’s education program or activities. This determination requires consideration of all the facts and circumstances, including, but not limited to, the ages and disability statuses of the harasser and the victim and the number of individuals involved and their authority;
    3. sexual assault including rape, statutory rape, fondling, and incest;
    4. dating violence;
    5. domestic violence; or
    6. stalking

Sexual assault, dating violence, domestic violence, and stalking will be defined in accordance with applicable law.

Conduct that satisfies this standard is not sexual harassment for purposes of this policy if the conduct occurred (1) outside the United States or (2) under circumstances in which the School did not have substantial control over both the harasser and the context in which the harassment occurred.

Examples of conduct on the basis of sex that would be considered sexual harassment if the conduct satisfies the criteria above include, but are not limited to:  unwelcome sexual advances; requests for sexual favors; and other verbal or physical conduct of a sexual nature, such as deliberate, unwelcome touching that has sexual connotations or is of a sexual nature; suggestions or demands for sexual involvement accompanied by implied or overt promises of preferential treatment or threats; pressure for sexual activity; continued or repeated offensive sexual flirtations, advances, or propositions; continued or repeated verbal remarks about an individual’s body; sexually degrading words used toward an individual or to describe an individual; sexual assault; sexual violence; the display of sexually suggestive drawings, objects, pictures, or written materials; posting sexually suggestive pictures of a person without the person’s consent; and forwarding pornographic material to a classmate or other member of the School community.  Acts of verbal, nonverbal, or physical aggression, intimidation, or hostility based on sex or sex-stereotyping may also constitute sexual harassment.

Conduct that is determined not to meet the definition above may violate other Board policies or established standards of conduct and will be treated accordingly.  For example, conduct that does not meet the definition of Title IX sexual harassment above may nevertheless violate other Board policies.

B.    Consent

Consent is informed, freely and affirmatively given through mutually understandable words or actions that indicate a willingness to participate in the sexual activity.  Consent can be withdrawn at any time.  There is no consent when there is force, expressed or implied, or when coercion, intimidation, threats, or duress is used.  Whether a person has taken advantage of a position of influence over another person may be a factor in determining consent.  Silence or absence of resistance does not imply consent.  Consent to one type of sexual activity does not amount to consent to another type of activity.  Prior consent or sexual relations with the same person do not imply future consent.  The fact that both people are in a relationship does not, by itself, establish consent.  A person cannot consent if they are unconscious, asleep, or impaired to the extent that they do not understand what is going on.  Minors under the age of 16 are incapable of giving consent to sexual activity with a person more than four years older than the minor.  Consent may never be given by mentally disabled persons if their disability was reasonably knowable to a sexual partner who is not mentally disabled.  Consent between parties engaging in sexual activity does not prevent the school system from taking disciplinary action against the parties for violation of any other board policy.

C.    Report

A report is an oral or written notification that an individual is an alleged or suspected perpetrator or victim of sexual harassment.

Making a report initiates the interactive process with the Complainant described below. No disciplinary action will be taken against a Respondent for sexual harassment based on a report alone.

D.    Formal Complaint

A Formal Complaint is a document signed and filed with the Title IX Coordinator by a Complainant or signed by the Title IX Coordinator alleging sexual harassment against a Respondent and requesting that School officials investigate the allegation(s).  Filing a Formal Complaint initiates the Complaint process.

E.     Complainant

The Complainant is the individual(s) who is alleged to be the victim of conduct that could constitute sexual harassment, regardless of whether a Formal Complaint is filed.

F.     Respondent

The Respondent is the individual(s) who has been reported to be the perpetrator of conduct that could constitute sexual harassment.

G.    Complaint Process

Complaint process means the process for investigating and reaching a final determination of responsibility for a Formal Complaint of sexual harassment.  The sexual harassment complaint process is set forth in Administrative Regulations adopted by the Superintendent and should comply with all Title IX requirements.

H.    Title IX Coordinator

The Title IX Coordinator is a School official who is designated to coordinate the School’s response to sexual harassment and allegations of sexual harassment. Contact information for the Title IX Coordinator is posted on the School’s website.

I.      Supportive Measures

Supportive measures 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 Formal Complaint or where no Formal Complaint has been filed.  Such measures are designed to restore or preserve equal access to the School’s education program and activities without unreasonably burdening the other party, including measures designed to protect the safety of all parties or the School’s educational environment, or deter sexual harassment.

Supportive measures available to the parties include, but are not limited to, counseling, mental health services referral, extensions of deadlines or other course-related adjustments, modifications of work or class schedules, escort services, mutual restrictions on contact between the parties, changes in work locations, leaves of absence, increased security and monitoring, and other similar measures determined by School officials to be necessary to protect the safety or educational or employment activities of a party.

J.      Days

Days are calendar days unless specified otherwise.

K.    Student(s)

“Student(s)” means the Student and/or the Student’s parent or legal guardian unless the context clearly indicates otherwise. When the Complainant or Respondent is a Student, references to those terms also include the Student’s parent or legal guardian unless the context clearly indicates otherwise.

L.     Actual Knowledge

“Actual knowledge” means a School employee has notice of sexual harassment or allegations of sexual harassment.

IV.         Reporting Sexual Harassment

A.    Students

Any Student who believes he or she is a victim of sexual harassment occurring during or as part of the School’s educational programs or activities may report the matter to the Superintendent, the Title IX Coordinator, or to any teacher, counselor, or other School employee. Likewise, a Student who has witnessed conduct amounting to sexual harassment may report such conduct.

B.    School Employees and Board Members

Any employee or member of the Board who has actual knowledge of sexual harassment or allegations of sexual harassment occurring in the education program or any activity of the School must report that information immediately to the Title IX Coordinator.

Any of the following confers “actual knowledge” and must be reported immediately:

    1. a report of sexual harassment from a Student or other person;
    2. the employee or Board member witnesses conduct that is or reasonably could be sexual harassment; or
    3. the employee or Board member discovers evidence of sexual harassment, such as sexualized graffiti on School property, or otherwise has reliable information or reason to believe that a Student, employee, or other individual may have been sexually harassed in violation of this policy, even if no one has reported the sexual harassment.

Employees who observe an incident of harassment are expected to intervene to stop the conduct in situations in which they have supervisory control over the perpetrator, and it is safe to do so.  An employee with actual knowledge of possible sexual harassment in violation of this policy who does not promptly report the conduct and/or take proper action as required by this subsection, or who knowingly provides false information about the incident, will be subject to disciplinary action, up to and including dismissal.

Any doubt about whether particular conduct is possible sexual harassment must be resolved in favor of reporting the conduct.

The mandatory reporting requirements of this Policy are in addition to required reporting under other policies, under State law, and pursuant to State Board of Education Policies. In addition, School officials should report incidents to law enforcement as appropriate.

C.    Reporting By Others

All other members of the School community are strongly encouraged to report any act that may constitute an incident of sexual harassment in violation of this policy to the Superintendent, or the Title IX Coordinator.

D.    Content of the Report

To the extent possible, reports should be sufficient to put School officials on notice of conduct that could constitute sexual harassment. Employees making mandatory reports should provide as much detail about the alleged sexual harassment as is known, unless such disclosure would violate law or standards of professional ethics.  Reports, other than mandatory reports by employees, may be made anonymously, but anonymous reports may limit the School’s ability to respond fully if the alleged victim is not identified.

E.     Time Period for Reporting

    1. Students and others may make a report at any time, preferably as soon as possible after disclosure or discovery of the facts giving rise to the report.
    2. School employees and Board members with actual knowledge of sexual harassment must report that information immediately.

V.  Response by School Officials with Actual Knowledge of Sexual Harassment

A.    Generally

School officials must respond promptly and impartially to actual knowledge of sexual harassment and do so in a manner that is not deliberately indifferent. Such response will include an interactive process and supportive measures.

B.    Interactive Process

Upon receiving a report of alleged sexual harassment, the Title IX Coordinator shall promptly contact the Complainant (and the Complainant’s parent or guardian if appropriate). This contact must occur within three days, excluding weekends, absent extenuating circumstances. The Title IX Coordinator shall also notify the Superintendent of the report and, if an employee is the Complainant or Respondent, the senior human resources official.

When contacting the Complainant, the Title IX Coordinator shall do all of the following during the contact and shall document the same:

    1. Offer supportive measures;
    2. Consider the Complainant’s wishes with respect to supportive measures;
    3. Explain that supportive measures are available with or without the filing of a Formal Complaint; and
    4. Explain the process for filing a Formal Complaint with the Title IX Coordinator and the response required of the School when a Complaint is filed, including all the following:
      • The filing of a Formal Complaint will be pursuant to Administrative Regulation XXX and will initiate the Formal Complaint process;
      • The Formal Complaint may be filed in person, by mail, or by electronic mail and must be filed with the Title IX Coordinator;
      • The steps of the formal process include: notice to the Respondent; investigation during which both parties may present evidence and ask questions; a decision by an objective Decision-Maker; and the right to appeal the Decision;
      • The approximate time frame for concluding the Complaint process;
      • That School officials will treat both parties equitably;
      • The possibility that Formal Complaints may be consolidated; and
      • The requirement that, under some circumstances, the Title IX Coordinator may be required to file a Formal Complaint should the Complainant not choose to do so.

C.    Supportive Measures

After considering the Complainant’s wishes, the Title IX Coordinator shall arrange the effective implementation of appropriate supportive measures unless, in the exercise of good judgment, the Title IX Coordinator determines that supportive measures should not be provided.  If supportive measures are not provided to the Complainant, the Title IX Coordinator shall document why supportive measures were not provided and why not providing supportive measures is not deliberately indifferent to known sexual harassment.

The supportive measures available to the Complainant and the Respondent are set forth above in Section III. H.

D.    Title IX Coordinator Decision to File Formal Complaint

    1. Complainant declines to file a Formal Complaint;
    2. Coordinator decides on case-by-case basis;
    3. Standard is based upon the obligation for School not to be deliberately indifferent;
    4. Decision must not be based upon the credibility or merit of the Complaint;
    5. Filing of Formal Complaint by Title IX Coordinator does not signify agreement or disagreement with the allegations; nor does the filing render the Title IX Coordinator a party to the Complaint; and
    6. The Coordinator must document the decision whether to file a Formal Complaint and the reasons therefor.

E.     Presumption of Non-Responsibility

A Respondent identified in any report under this Policy is presumed not responsible until responsibility has been established by a preponderance of evidence in accordance with the Formal Complaint Procedures set forth in Administrative Regulation ”Title IX Sexual Harassment – Grievance Process.”

F.     Due Process

No discipline may be imposed upon an employee or Student without following applicable due process procedures, unless the individual agrees to disciplinary action pursuant  to a settlement or mediation process; provided, however, that a Respondent may be subject  to removal, suspension, or leave in accordance with State law and Board Policy.

   VI.  Retaliation Prohibited

Retaliation against any person for the exercise of rights under Title IX or interference with those rights in any way, is strictly prohibited and will be subject to disciplinary action. The identity of any person who has made a report or Complaint of sex discrimination or sexual harassment or who is the alleged perpetrator of sexual discrimination or sexual harassment will be confidential unless otherwise required or permitted by law.

VII.         Formal Complaint Process

The Superintendent will publish notice of and adopt procedures consistent with Title IX Regulations to ensure a prompt and equitable resolution of Student and employee Formal Complaints alleging sexual harassment under Title IX. See [LINK] for the Administrative Regulation outlining Formal Complaint Procedures.

VIII.         Records

The Title IX Coordinator shall create and maintain for a period of seven years records of all reports and Formal Complaints of sexual harassment.  For each report or Formal Complaint, the Coordinator shall document the following:

  1. Any actions, including any supportive measures, taken in response to the report or Formal Complaint;
  2. That School officials have taken measures that are designed to restore or preserve equal access to the School’s education program and activities;
  3. Why School officials believe their response to the report or Complaint was not deliberately indifferent; and
  4. If supportive measures were not provided to the Complainant, why that was not clearly unreasonable in light of the known circumstances.

In conjunction with the Superintendent, the Title IX Coordinator shall also maintain for seven years all materials used to train the Title IX Coordinator, Investigators, Decision-Makers, and any person who facilitates an informal resolution process.  These materials will be made publicly available on the School’s website.

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