Compliance Overview 2023

About IDEAA’s Compliance Work

The mission of the Office of Institutional Diversity, Equity & Affirmative Action is to promote a deep understanding and appreciation among the diverse members of the University community to result in justice and equality in educational, employment and contracting opportunities, as well as to lead efforts to create an inclusive academic and work environment. The Office of Institutional Diversity, Equity & Affirmative Action supports the University’s mission.

IDEAA works to ensure that the University is compliant with non-discrimination and equal opportunity laws and regulations such as: Title VII of the Civil Rights Act of 1964; the District of Columbia Human Rights Act; Executive Order 11246, as amended; Sections 503 and 504 of the Rehabilitation Act of 1973, as amended; the Vietnam Era Veterans’ Readjustment Assistance Act of 1974, as amended; the Americans with Disabilities Act of 1990, as amended; Title IX of the Education Amendments of 1972; the District of Columbia Protecting Pregnant Workers Fairness Act of 2014; the Equal Pay Act of 1963; the Age Discrimination in Employment Act of 1967; the Age Discrimination Act of 1975; Title VI of the Civil Rights Act of 1964; and the federal Pregnant Workers Fairness Act.

To uphold the University’s compliance with these laws and regulations, IDEAA carries out the following responsibilities on behalf of the University: provides informal resolution services, including mediation, as a way to resolve allegations of harassment, discrimination, and related retaliation; investigates allegations of harassment, discrimination, and related retaliation; conducts administrative reviews and climate assessments; coordinates requests for accommodation based on disability, religion or pregnancy; prepares annual updates to the University’s affirmative action plan; provides training to the University community on relevant topics, such as implicit bias and bystander intervention; develops University policies and procedures related to EEO/AA, non-discrimination, and sexual misconduct; completes compliance reports; assists with the University’s supplier diversity efforts; and coordinates the response to bias-related incidents as a core member of the Bias Reporting Team.  Additionally, IDEAA’s Office of Title IX Compliance is responsible for upholding the University’s compliance with Title IX of the Education Amendments of 1972 and relevant federal and local laws against sex discrimination.

Accommodations

IDEAA is responsible for coordinating the University’s response to accommodation requests in accordance with federal and District of Columbia laws, as well as University policies. IDEAA provides accommodation assistance to applicants for employment and current employees, including staff, AAPs, faculty, student employees, and visitors, in some instances.

Requests for accommodation may be based on disability, religion, or pregnancy, childbirth, or breastfeeding. Examples of workplace accommodations may include equipment or software; office furniture; the opportunity to take reasonable, periodic breaks; an alteration of the work schedule; access to a lactation room; or temporary relocation of a work space.

To request an accommodation, individuals are invited to contact IDEAA in one of the following ways:

  1. Submit an online request for a:
    1. Disability accommodation
    2. Religious accommodation 
    3. Pregnancy accommodation (based on pregnancy, childbirth, breastfeeding, or a related medical condition)
  2. Send an email to IDEAA at ideaa@georgetown.edu
  3. Call IDEAA at 202-687-4798

IDEAA considers each accommodation request individually and engages in an interactive process with the employee/applicant and the department. IDEAA may request documentation to support an accommodation request and houses supporting documentation confidentially within IDEAA.

To ensure that all requests for accommodations based on disability, religion, or pregnancy, childbirth, or breastfeeding are given full consideration by the University, supervisors, managers, and department chairs may neither grant nor deny an accommodation without consultation with IDEAA.

For more information about accessibility at Georgetown, please visit the University’s Accessibility website and the IDEAA website.

Affirmative Action

Georgetown University is committed to promoting the full realization of equal employment opportunity through an affirmative action program, in compliance with applicable laws. It is the goal of Georgetown University and its departments to advertise, recruit vigorously, and employ qualified candidates, particularly minority persons, women, veterans, and persons with disabilities. This effort upholds the University’s Affirmative Action Plan as well as the requirements of the Department of Labor’s Office of Federal Contract Compliance Programs.  

All academic departments are required to comply with the University’s Affirmative Action in Employment Policy, which stipulates posting a position for open recruitment and advertisement. In support of this policy, academic departments are required to submit a Faculty Recruitment Plan to IDEAA for review and approval prior to open recruitment.

Alternative Resolution

Alternative Resolution is a voluntary, collaborative opportunity to address issues of possible bias, discrimination, harassment, or retaliation through a confidential non-investigative process, to build mutual understanding and promote healing. Any individual who believes that they may have experienced possible discrimination, harassment, or retaliation in a Georgetown University program or activity, on- or off-campus, may request Alternative Resolution by sending an email to ideaa@georgetown.edu or calling (202) 687-4798. Requests for Alternative Resolution are recorded in IDEAA’s files.

Alternative Resolution is facilitated by a neutral IDEAA staff member within a reasonably prompt time frame. IDEAA encourages the use of alternative resolution, where appropriate.

Bias Reporting

Georgetown University has a rich tradition of embracing people from a wide spectrum of differing identities, including faith, race, ethnicity, culture, sexual and gender diversity, ability, socioeconomic status, and backgrounds. The University considers acts of hate and bias unacceptable and antithetical to its commitment as an inclusive and respectful community. 

The purpose of the Bias Reporting System is to document and respond to bias-related incidents experienced by community members, including students, faculty, staff/AAPs, and to provide affected community members with support and resources. Through the Bias Reporting System, Georgetown tracks and reviews bias-related incidents, offers resources to impacted community members, identifies opportunities for educational programming, and shares information with reporting individuals regarding options for next steps. Reporting bias may lead to both informal and formal actions in response to concerns identified, including an investigation through one of the University’s formal grievance procedures, following which the University can hold accountable individuals found to have violated a University policy.

Please be aware, however, that while the expression of an idea or point of view may be offensive or inflammatory to some, it is not necessarily a bias-related incident. The University values freedom of expression and the open exchange of ideas. The expression of controversial ideas and differing views is a vital part of the University discourse. While this value of openness protects controversial ideas, it does not protect harassment or expressions of bias or hate aimed at individuals, where such expression violates University policies.

Climate Assessments

Climate assessments provide an opportunity for departments/units to gain an understanding of how faculty and staff experience and perceive their workplaces. IDEAA generally conducts climate assessments through questionnaires and voluntary individual or group meetings with faculty and staff. Information obtained through climate assessments is kept private and results typically are shared in aggregate form, or in a de-identified manner. IDEAA generally makes recommendations to the departmental or unit leader following a climate assessment.

Formal Complaints

IDEAA reviews, investigates, and resolves alleged violations of the University’s Equal Opportunity and Non-Discrimination in Employment and Non-Discrimination in Education Policies, Affirmative Action Policy, the Policy Statement on Harassment, the Policy on Sexual Misconduct, and the Policy on Consensual Sexual or Romantic Relationships.

If you believe you have experienced discrimination in violation of one of these policies, you may choose to file a complaint with IDEAA. Please note that any faculty or staff member (other than those who are statutorily prohibited from reporting) who learns of conduct that may violate the University’s anti-harassment policy must contact the IDEAA at 202-687-4798, within 24 hours, or as soon as possible. If in doubt as to whether certain conduct violates this policy, or if you have any questions about this policy or its application, please call IDEAA for a consultation.

To review the University’s Grievance Procedures or file a discrimination complaint with IDEAA, please refer to the Grievance Procedures (new window) and the Discrimination Complaint Form (new window). Additional information about IDEAA’s complaint investigation and administrative review processes is available in IDEAA’s Frequently Asked Questions document.

Applicants or Employees who believe they have been denied a job or an equal opportunity to apply for a job based on a disability, covered medical condition, or religion, refused a request for reasonable accommodation, or have been asked illegal medical questions or have been required to take an illegal medical examination may contact IDEAA at (202) 687-4798, fax at (202) 687-7778, through our confidential email service at ideaa@georgetown.edu, or may choose to file a complaint with IDEAA. Our office is located at 37th & O Streets, NW, M36 Darnall Hall, Washington, DC 20057.

Investigations & Administrative Reviews

IDEAA investigates complaints over which it has jurisdiction; for example, complaints must allege conduct prohibited by a Georgetown University non-discrimination or anti-harassment policy and must be timely filed. To be accepted for investigation, a complaint must allege conduct, which, if substantiated, would constitute a violation of one or more of IDEAA’s policies. Individuals who file complaints are encouraged to provide as much detailed information as possible, including when the reported incident took place and the reason for the reporting individual’s belief that the conduct falls within IDEAA’s policies.

IDEAA reviews administratively certain alleged violations of Georgetown’s institutional non-discrimination and anti-harassment policies, such as instances where an individual

chooses not to file a formal complaint but alleges serious or systemic conduct, which, if substantiated, could constitute a violation of an IDEAA policy.

IDEAA has the authority to initiate an administrative review at any time when, in the judgment of the Associate Vice President for Equal Opportunity, Affirmative Action and

Compliance, such action is warranted. A department head or other University official may also request that IDEAA conduct an administrative review, if this official becomes aware of alleged discrimination, harassment, or related retaliation.

Additional information about IDEAA’s complaint investigation and administrative review processes is available in IDEAA’s Frequently Asked Questions document.

Language Access & Diversity

Georgetown University celebrates language diversity and is committed to providing equal access to university services, programs, and activities. The university strives to create a culture of linguistic inclusion by increasing visibility of language diversity and supporting access to language assistance resources.

Schools and Departments are responsible for ensuring meaningful access to their programs, services, and activities to individuals in a timely, reasonable, and effective manner, in accordance with law. Individual Schools and Departments are responsible for arranging and paying for translation and interpretation services to ensure equal access to information, programs, and services, where required by law. 

If you have questions about the process for arranging language assistance services, please contact IDEAA.

The following university policies are available in multiple languages. If you need assistance with translations of other IDEAA-related policies into additional languages, please contact us at ideaa@georgetown.edu. 

Title IX

Title IX of the Education Amendments of 1972 (“Title IX”) prohibits discrimination based on sex in any educational programs, which includes sexual harassment or any acts of sexual misconduct. Title IX requires the University, upon becoming aware of any incident of sexual harassment and misconduct to respond appropriately to protect and maintain the safety of the University community, including students, faculty, and staff. 

Georgetown University prohibits sexual misconduct, including sexual harassment, sexual assault, domestic/dating violence, and stalking. 

Discrimination based on sex, including sexual misconduct and discrimination based on pregnancy or parenting status, subverts the University’s mission and threatens permanent damage to the educational experience, careers, and well-being of students, faculty, and staff. 

The University provides resources for students, faculty, and staff/AAPs on issues relating to sexual misconduct, discrimination based on sex, and discrimination based on pregnancy, including options for getting immediate help; the University’s policies against sexual misconduct; how to report sexual misconduct; the University’s Sexual Misconduct Reference Guide; and campus initiatives. 

Data related to Title IX matters may be accessed in annual reports on the Title IX website: https://sexualassault.georgetown.edu/get-involved/annual-reports/.

Workshops

IDEAA offers interactive, educational workshops to the Georgetown University community, upon request. To request one of the workshops below, please send a request to ideaa@georgetown.edu.

Available workshops include:

  • Active Bystander Intervention
  • Bias Reporting System
  • Diverse Recruitment and Hiring
  • Employee Accommodations (for supervisors)
  • Gender Identity and Expression
  • Implicit Bias
  • Mandatory Reporting (Title IX, Discrimination/Harassment)
  • Microaggressions
  • Planning Accessible Events
  • Preventing and Addressing Sexual Harassment

Pre-Recorded Training: Title IX Mandatory Reporting Training (new window)

A Snapshot of Some of IDEAA’s 2023 Compliance Activities

IDEAA’s staff worked on a large number of matters during the 2023 calendar year. For example, IDEAA worked on more than 582 formal complaints, administrative reviews, accommodation requests, bias reports, and educational workshops in 2023. In addition to these matters, IDEAA responded to many other important matters not reflected in the summary below, including reports of compliance concerns, requests for consultation, and Title IX matters (for example, apart from the 582 matters reported above, IDEAA’s Title IX Office received and responded to 199 reports of sexual misconduct from across our campuses during the 2023 calendar year). The data reflected in the pie graph below and the discussion that follows represent only a portion of IDEAA’s work.

Pie chart illustrating that Bias Reports constituted 24.6%, Formal Complaints 21.1%, Recruitment Plan Review 20.3%, Accommodation Requests 16.7%, Trainings and Educational Workshops 15.6%, and Administrative Reviews 1.7% of reported compliance activities.

Formal complaints

  • IDEAA received more than 123 formal complaints during the 2023 calendar year.
    • Of these, 42 were filed by staff, 6 were filed by faculty, 61 were filed by students or student organizations, 2 were filed by third parties, and 11 were filed by unnamed persons. 
    • 61 formal complaints were filed against staff, 32 against faculty, 28 against students, 11 against the university, and 8 against unnamed persons. Of the complaints filed against faculty, 66% were filed by students, 16% were filed by other faculty members, and 9% were filed by staff.
    • Sexual harassment, race, and retaliation were the most common bases for formal complaints.

Bar chart illustrating that of the formal complaints filed in 2023, 42 were filed by staff, 6 were filed by faculty, 61 were filed by students or student organizations, 2 were filed by third parties, and 11 were filed by unnamed persons.

Bar chart illustrating that of the formal complaints filed in 2023, 61 were filed against staff, 32 against faculty, 28 against students, 11 against the university, and 8 against unnamed persons.

Row chart illustrating bases on which formal complaints were filed in 2023. 77 formal complaints included an allegation of sexual harassment, 53 included an allegation of race-based discrimination, 52 alleged retaliation, 34 alleged national origin discrimination, 34 included a claim of sex/gender-based discrimination, 22 alleged discrimination based on color, 20 alleged religious discrimination, 19 alleged disability-based discrimination, 17 included claims of discrimination based on personal appearance or political affiliation, 14 alleged discrimination based on family responsibility and/or gender identity/expression, 6 alleged discrimination based on marital status and/or sexual orientation, 5 discrimination based on matriculation, 3 based on veteran status, and 2 based on genetic information.

Basis For ComplaintTotal
Age30
Color22
Disability19
Family Responsibility14
Gender Identity/Expression14
Genetic Information2
Marital Status6
Matriculation5
National Origin34
Other42
Personal Appearance17
Political Affiliation17
Race53
Religion20
Retaliation52
Sex/Gender34
Sexual Harassment77
Sexual Orientation6
Veteran Status3

Administrative reviews

  • IDEAA initiated approximately 10 administrative reviews in 2023. Of these, 50% concerned matters brought to IDEAA’s attention by students regarding alleged conduct by faculty members. The remaining administrative reviews involved allegations raised by administrators, staff, or third parties about reported conduct by staff members. The administrative reviews addressed claims of alleged discrimination based on sex or gender, race, religion and/or national origin.
  • During calendar years 2022 and 2023, IDEAA initiated approximately 23 administrative reviews. Due to the relatively small number of reviews conducted in 2023, results for 2022 and 2023 are presented here in the aggregate, to preserve confidentiality. Following careful review of the available information and the totality of the circumstances, in 43% of the administrative reviews, IDEAA identified violations of policy and/or made recommendations to address concerns. Examples of outcomes of administrative reviews may include training/educational workshops, changes in procedures, implementation of safeguards, compliance monitoring, and referrals for potential disciplinary or corrective action. 

Total new accommodation requests 

  • IDEAA facilitated approximately 97 new requests for accommodation based on disability, religion, and pregnancy filed by faculty and staff/AAPs, as well as applicants for employment. In addition to these requests, IDEAA facilitated and monitored ongoing accommodation requests to ensure that they continue to meet the needs of employees and departments.

Disability accommodations

  • IDEAA facilitated more than 74 disability accommodation requests from faculty and staff/AAPs, as well as approximately 9 disability accommodation requests from applicants for employment.

Religious accommodations

  • IDEAA facilitated approximately 6 religious accommodation requests from faculty and staff/AAPs.

Pregnancy accommodations

  • IDEAA facilitated approximately 8 pregnancy or related accommodation requests from faculty and staff/AAPs.

Pie chart illustrating that 85.6% of accommodation requests were based on disability, 8.2% were based on pregnancy, and 6.2% were based on religion.

Educational workshops conducted

  • IDEAA staff conducted more than 91 educational workshops across our campuses. Topics included Title IX education and awareness, implicit bias training, active bystander intervention, and non-discrimination, anti-harassment, and non-retaliation training, such as on topics covered under Title VI of the Civil Rights Act of 1964.

Graphic illustrating that of the educational workshops conducted, 41.8% focused on Title IX matters, 30.8% focused on other matters (e.g., gender identity and expression, non-discrimination/anti-harassment, non-retaliation), 19.8% focused on Implicit Bias, and 7.7% focused on Active Bystander Intervention. 

Faculty recruitment plans reviewed

  • IDEAA reviewed approximately 96 faculty recruitment plans and approximately 22 recruitment plans for fellows. For each recruitment plan, IDEAA provided input to help diversify candidate pools and the Georgetown University workforce.

Reports of Bias-Related Incidents

Some Highlights of IDEAA’s Proactive Work

  • Accessible Commencement: IDEAA contributed to university-wide efforts to make commencement ceremonies more accessible, including by collaborating with campus partners to update the accessible commencement web page and supporting increased availability of sign language interpreters, captioning, and assistive listening devices. 
  • Alternative Resolution process: IDEAA implemented the alternative resolution process. Alternative Resolution is a voluntary, collaborative opportunity to address issues of possible bias, discrimination, harassment, or retaliation through a confidential non-investigative process, to build mutual understanding and promote healing. Alternative Resolution may be used in lieu of, or as an initial step prior to, filing an IDEAA complaint. If a formal complaint is filed, the parties also have the option to utilize IDEAA’s Informal Resolution process, as described in IDEAA’s grievance procedures.
  • Accessibility Website: IDEAA collaborated closely with campus partners on the University’s accessibility website, which provides a centralized hub for information and resources regarding accessibility at Georgetown.
  • Updated Planning Accessible Events page: IDEAA updated its Planning an Accessible Event web page to include best practices for planning accessible events to support the University’s commitment to providing inclusive and accessible events for everyone, including disabled participants.
  • Accessible Events Guide: In collaboration with the Academic Resource Center, the Disability Cultural Center, and the Office of Strategic Communications, IDEAA contributed to the creation of the following guides designed to increase accessibility of University events:
  • Language Diversity & Access: IDEAA celebrates language diversity and is committed to providing equal access to university services, programs, and activities. IDEAA contributed to the university’s commitment to creating a culture of linguistic inclusion by increasing visibility of language diversity and supporting access to language assistance resources.
  • Information & Resources page: IDEAA created a centralized web page with information about its processes and resources for individuals who may experience discrimination, harassment, or related retaliation: https://ideaa.georgetown.edu/information-and-resources/. 
  • Updated Interpretive Guidance on Protected Bases: IDEAA clarified that the University interprets its non-discrimination and anti-harassment policies to prohibit discrimination, including harassment, based on actual or perceived shared ancestry or ethnic characteristics, or citizenship or residency in a country with a dominant religion or distinct religious identity. This protection against discrimination includes antisemitism, caste-based discrimination, and anti-Muslim and anti-Arab discrimination. Covered discrimination based on race, color, national origin, and/or religion may include, for example, discrimination involving: racial, ethnic, or ancestral slurs or stereotypes; an accent or name commonly associated with particular shared ancestry or ethnic characteristics; and personal appearance, including skin color, physical features, or style of dress that reflects both ethnic and religious traditions. See https://ideaa.georgetown.edu/protected-bases/. 
  • Resource Guides: IDEAA provides resource guides for community members with information about our processes. Links to a selection of the resource guides are available below.

Helpful Links

Make a report

File a formal complaint

Request a meeting with an IDEAA staff member

Request an accommodation

Speak with a confidential resource

  • Journey’s employee assistance program provides customized well-being resources through its digital platform as well as concierge-level support for individuals seeking therapy or coaching. Journey provides free mental health therapy and support for all benefits-eligible employees and their families in the Washington, DC, metro area, across the United States and internationally.

Report an accessibility barrier

To consult IDEAA about possible discrimination, harassment, or related retaliation, contact: (alpha order)

Sydney Adams, 
Deputy Title IX Coordinator and Civil Rights Investigator
sa2054@georgetown.edu 

Samantha Berner
Title IX Coordinator and Director of Title IX Compliance
Samantha.Berner@georgetown.edu

Mary Chlopecki
Senior Investigator and Counsel
mc2672@georgetown.edu

Rebecca Cpin
Director of Affirmative Action Compliance & Data Analytics
Rebecca.Cpin@georgetown.edu

Sharrell McCaskill
Accessibility Manager and Civil Rights Investigator
sm3728@georgetown.edu

Bisi Ladeji Okubadejo
Associate Vice President for Equal Opportunity, Affirmative Action, and Compliance
Olabisi.Okubadejo@georgetown.edu

Ruby Smith
Office Administrator and Project Manager
ruby.smith@georgetown.edu

Tonya Turner
Associate Director
hindst@georgetown.edu

LaDreena Walton
Deputy Title IX Coordinator and Civil Rights Investigator
ladreena.walton@georgetown.edu 

Members of IDEAA’s Intake and Care Management Team are available to speak with individuals who have questions about IDEAA’s process. The Intake and Care Management Team conducts initial intake and assessment of formal complaints and reports of discrimination, harassment, and related retaliation. The Intake and Care Management team also offers information about supportive resources, facilitates requests for accommodation, and works with community members to resolve IDEAA-related matters through non-investigative processes such as mediation.

Notice of Non-Discrimination

Georgetown University is committed to providing equal educational and employment opportunities and embraces the diversity of its faculty, staff, and students. Georgetown prohibits discrimination or harassment on the basis of any protected characteristic, as outlined below.  

Non-Discrimination in Education

Georgetown University provides educational opportunities without regard to, and does not discriminate on the basis of, age, color, disability, family responsibilities, familial status, gender identity or expression, genetic information, marital status, national origin, personal appearance, political affiliation, race, religion, sex, sexual orientation, source of income, veteran’s status or any other factor prohibited by law in its educational programs and activities.

Non-Discrimination in Employment

Georgetown University provides equal opportunity in employment for all persons, and prohibits unlawful discrimination and harassment in all aspects of employment because of age, color, disability, family responsibilities, gender identity or expression, genetic information, marital status, matriculation, national origin, personal appearance, political affiliation, race, religion, sex, sexual orientation, veteran’s status or any other factor prohibited by law.

Prohibition against Retaliation

Georgetown University prohibits retaliation, harassment, or other adverse action against an individual for making a complaint in good faith, assisting in an investigation, opposing harassment or otherwise exercising rights protected by law. It also prohibits taking any adverse academic or employment related action against an individual based on an unsubstantiated allegation or rumor of harassment. Retaliation should be reported promptly to the Office of Institutional Diversity, Equity, and Affirmative Action and may result in disciplinary action up to and including dismissal.

Coordination of Compliance

The following person has been designated to handle questions regarding Georgetown’s non-discrimination and affirmative action policies:

Bisi Ladeji Okubadejo
Associate Vice President for Equal Opportunity, Affirmative Action, and Compliance
Section 504, Americans with Disability Act, and Age Act Coordinator
Georgetown University
Office of Institutional Diversity, Equity, and Affirmative Action
M-36 Darnall Hall
37th and O Streets, N.W.
Washington, D.C. 20057
202-687-4798

The following person has been designated to handle questions regarding Georgetown’s Title IX policy:

Samantha Berner, J.D.
Title IX Coordinator and Director of Title IX Compliance
Georgetown University
Office of Institutional Diversity, Equity, and Affirmative Action
M-36 Darnall Hall
37th and O Streets, N.W.
Washington, D.C. 20057
(202) 687-4798

Individuals with inquiries regarding these policies are encouraged to first contact the employees listed above. Individuals with inquiries about Title IX may also choose to contact the U.S. Department of Education’s Office for Civil Rights.