RESOLUTION AGREEMENT

Alpine School District

OCR Compliance Review 08-20-5001

Alpine School District (“the District”) enters into this Resolution Agreement (“the Agreement”)
to resolve the violations and compliance concerns that the Office for Civil Rights (OCR) of the
U.S. Department of Education (“the Department”) identified in Compliance Review No. 08-20-
5001. This review evaluated the District’s compliance with Title IX of the Education
Amendments of 1972 (“Title IX”), 20 U.S.C. §§ 1681-1688, and its implementing regulations at
34 C.F.R. Part 106, with respect to its policies, grievance procedures, and responses to student-
to-student and employee-to-student sexual assault. Title IX and its regulations prohibit
discrimination on the basis of sex, including sexual harassment, in any education program or
activity operated by a recipient of federal financial assistance from the Department.

Each term of the Agreement applies to all District-operated schools, District-operated charter
schools, contract schools, and/or special purpose schools.

I. Coordination of Compliance with Title IX Through the Title IX Coordinator 1

A. The District will notify students, parents, guardians, and employees of the District’s
designated Title IX Coordinator and their contact information, including their
name(s), office address(es), telephone number(s), and email address(es), and by
including this information in its revised grievance procedures required by Term II
below.

B. The District will notify all of its employees, in writing, that they must promptly notify
the Title IX Coordinator of all Title IX reports or complaints of which they are aware.

C. The District will ensure that the employee designated as its Title IX Coordinator
coordinates its efforts to comply with and carry out its responsibilities under Title IX,
including coordinating:

1. the implementation of its grievance procedures;

2. its Title IX investigations of complaints and reports of student-to-student and

employee-to-student sexual harassment;

3. monitoring outcomes;

4. identifying and addressing any patterns; and

5. assessing any effects of such harassment on the climate of the District and its
schools.

1
If the District chooses to have multiple Title IX coordinators, the policies and procedures required by this
Agreement will apply to all coordinators.
OCR Compliance Review 08-20-5001 page 2

D. The District also will ensure that its Title IX Coordinator:

1. possesses the appropriate and necessary authority to effectively coordinate the

District’s compliance with Title IX;

2. possesses sufficient time available to perform all Title IX-related responsibilities;

3. reports, for supervision purposes, directly to the Superintendent or the

Superintendent’s designee;

4. possesses access to information regarding the administration of school discipline

and incidents of sex-based harassment;

5. is appropriately trained and possesses comprehensive knowledge in all areas over

which the Coordinator has responsibility, including knowledge of the District’s
policies and grievance procedures regarding sex discrimination, including sexual
harassment, and applicable Title IX regulations;

6. is involved in drafting and revising policies and procedures to help ensure these
comply with the requirements of Title IX; and

7. is free of potential conflicts of interest.

E. The Title IX Coordinator will develop a monitoring program to assess the

effectiveness of the District’s overall Title IX anti-discrimination efforts. At a
minimum, the Title IX Coordinator or a qualified designee will annually:

1. review all reports and complaints of discrimination on the basis of sex, including
allegations of sexual harassment by students and employees;

2. review all information collected during the climate surveys required by Term
VIII;

3. compile, evaluate, and analyze all survey, report, and complaint data collected,
including an assessment of whether reported incidents of sexual harassment have
increased or decreased in number and severity and whether there are any
particular locations or programs in the District where a sex-based hostile climate
might exist; and

4. propose recommendations for improving the District’s anti-harassment efforts and

timelines for implementing the recommendations.

F. Reporting

1. By November 1, 2023, the District will submit to OCR documentation

demonstrating its compliance with Terms I.A-B above.
OCR Compliance Review 08-20-5001 page 3

2. By November 1, 2023, the District will submit to OCR for its review and approval
a plan for how it proposes to comply with Terms I.C-D above. The District will
promptly and fully address OCR’s feedback, if any, until the District receives
OCR’s final approval of the plan.

3. By November 1, 2023, the District will provide documentation to OCR of the

proposed monitoring program required by Term I.E.

4. By June 30, 2024, and June 30, 2025, the District will provide documentation to
OCR demonstrating that the Title IX Coordinator completed the annual reviews.
This documentation will include information about the reports and complaints to
the District, including: (i) the date filed, the complainant’s name and status (e.g.,
student or employee); (ii) the respondent’s name and status; (iii) the location (e.g.,
school name or bus); (iv) the type of complaints (e.g., sexual assault, other sexual
harassment, other sex discrimination, or retaliation); and (v) any trends or patterns
identified among the reports or complaints (e.g., a repeat respondent or school).
This documentation also will include: (i) a summary of the climate survey results;
(ii) any actions taken in response to the survey results or any identified trends or
patterns; and (iii) recommendations and timelines for improving the District’s
anti-sexual harassment efforts.

II. Title IX Policies and Grievance Procedures

A. By November 1, 2023, the District will review, revise, and provide to OCR for its
review and approval the District’s policies prohibiting sex discrimination, including
sexual harassment, and its grievance procedures for providing a prompt and equitable
response to reports and formal complaints of student-to-student and employee-to-
student sexual harassment. The District will ensure that its revised Title IX policies
and procedures comply with the Title IX regulations that are in place at the time of
the revision. The District will ensure that its Title IX policies and procedures are
cross-referenced, linked, internally consistent, and do not contain conflicting or
contradictory information. The District’s policies and procedures will ensure that the
respective Title IX-related roles and responsibilities of the Title IX Coordinator(s)
and school-based administrators are distinct and clear with respect to the division of
responsibilities when responding to reports and complaints of sexual harassment.
The District will promptly and fully address OCR’s feedback, if any, until the District
receives OCR’s final approval of the policies and procedures.

B. Within 60 days of OCR’s final approval of the District’s revised policies and
grievance procedures, the District will adopt, publish, provide notice of, and widely
disseminate the approved policies and grievance procedures to students, parents and
guardians, employees, applicants for admission and employment, and all unions or
professional organizations holding collective bargaining or professional agreements
with the recipient. The notice will include, at a minimum:
OCR Compliance Review 08-20-5001 page 4

1. posting a link to the policies and procedures on the District Board of Education
(“Board”) “Policies” webpages;

2. posting a link to the policies and procedures on all the District’s relevant
webpages, including, but not limited to, the District’s “Human Resources,”
“Student Services,” “Educational Equity,” and “Employee Gateway” webpages;

3. posting a link to the policies and procedures on the webpage of each school in the
District;

4. sending the policies and procedures to all District employees;

5. sending the policies and procedures to all parents and guardians of District
students; and

6. including information in each school’s student handbook, parent handbook,

and/or family handbook about how to access the policies and procedures and who
to contact with questions related to the policies and procedures. 2

C. Reporting

Within 60 days of OCR’s final approval of the policies and procedures, the District
will submit to OCR documentation demonstrating that the Board adopted the
approved policies and procedures, and that the District widely disseminated the
approved policies and procedures as required in Term II.B.

III. Notice of Nondiscrimination

A. By November 1, 2023, the District will provide to OCR for review and approval a
revised Notice of Nondiscrimination to be issued to all District students, parents and
guardians, administrators, employees, unions or professional organizations holding
collective bargaining or professional agreements with the recipient, applicants for
employment, and sources of referral of applicants for employment with the District
that is compliant with the regulation implementing Title IX at 34 C.F.R. § 106.8(b).

B. Within 30 days of OCR’s approval of the Notice of Nondiscrimination, the District

will widely distribute the Notice of Nondiscrimination, including by:

1. posting it in common areas throughout the District, including at every District

school and office;

2. posting it on the District’s website and on every District school webpage;

2
All communications required by this Agreement will comply with the requirements of Title VI of the Civil Rights
Act of 1964 regarding providing school-related information to parents and guardians with limited English
proficiency in a language that they understand.
OCR Compliance Review 08-20-5001 page 5

3. sending an email or letter with a copy of the Notice of Nondiscrimination to the

entire District community, including students, employees, parents and guardians,
and volunteers; and

4. including the Notice of Nondiscrimination in its 2024-2025 Student Handbook (or

any similar publication) to be provided to all current students.

B. Reporting

Within 60 days of OCR’s approval of the Notice of Nondiscrimination, the District

will submit to OCR documentation that the District distributed and published the
approved Notice of Nondiscrimination as required by Term III.B.

IV. Training for Personnel

A. For the duration of OCR’s monitoring of this Agreement, the District will ensure that
a qualified trainer with expertise regarding the Title IX regulations applicable to
sexual harassment provides annual training to the District’s Title IX Coordinator(s),
school-level administrators, investigators, decision-makers, any person facilitating an
informal resolution, and other District employees who are designated to be
responsible for any stage of the Title IX grievance procedures and Title IX grievance
process for sexual harassment complaints, including processing, investigating,
adjudicating, and/or resolving reports and formal complaints of sexual harassment to
ensure that investigations are prompt and equitable. The District also will distribute
and publish on the District’s website all materials used to train these individuals as
required by the Title IX regulation at 34 C.F.R. § 106.45(b)(1)(i)(D). The training
will review and include instruction on:

1. the District’s Title IX policies and grievance procedures approved under Term II
above;

2. the definition of sexual harassment under the Title IX regulations and how to
identify what constitutes sexual harassment that meets that definition;

3. what constitutes notice of sexual harassment and the duty to respond to such
notice;

4. reporting sexual harassment and the difference between reports and complaints of
sexual harassment;

5. the scope of the District’s education program or activity;

6. how to correctly code sexual harassment incidents to ensure that they are
appropriately identified and that the District responds to them as required by the
Title IX regulations;
OCR Compliance Review 08-20-5001 page 6

7. available supportive measures for the parties and remedies for complainants and
others subjected to sexual harassment;

8. how to conduct an investigation and grievance process for complaints of sexual

harassment, involving students, employees, and third parties, including, if
applicable, hearings, appeals, and informal resolution processes;

9. how to serve impartially, including by avoiding prejudgment of the facts at issue,

conflicts of interest, and bias;

10. if the District decides to hold a live hearing, how to use any technology that will
be utilized at a live hearing and how to handle any relevancy determinations about
evidence, including when questions and evidence about the complainant’s sexual
predispositions or prior sexual behavior are not relevant as described in the Title
IX regulations;

11. for investigators, how to assess relevance to create an investigative report that
fairly summarizes relevant evidence;

12. recordkeeping requirements under 34 C.F.R. § 106.45(b)(10);

13. notice to all parties of the outcome of the investigation; and

14. the Title IX prohibition on retaliation.

B. For the duration of OCR’s monitoring of this Agreement, the District will provide
annual training to all District employees that will cover:

1. its revised Title IX policies and grievance procedures approved under Term II;

2. how to identify what constitutes sexual harassment, including a hostile

environment;

3. the obligation of the District’s employees to report sexual harassment to the

designated site administrator and the Title IX Coordinator, including allegations
of employee-to-student sexual harassment;

4. the District’s responsibilities under Title IX to respond to reports and formal

complaints of sexual harassment; and

5. the remedies available to parties found to have been subject to sexual harassment.

C. To monitor the effectiveness of the training, the District will administer a survey
about the quality of each training to all trainees. The District will ensure that the Title
IX Coordinator or a designee reviews the survey results and, as appropriate revises
OCR Compliance Review 08-20-5001 page 7

the training materials in response to the survey results to ensure the training’s
effectiveness.

D. Reporting

1. Within 45 days of receiving OCR’s approval of the revised policies and grievance
procedures required by Term II, the District will submit to OCR: (i) draft
materials to train staff pursuant to Term IV.A; (ii) the name(s), job
title(s)/position(s), and qualifications of one or more proposed qualified
individuals to provide the training; (iii) a description of how the training will be
delivered (“delivery method”); and (iv) a proposed deadline by which all staff will
be trained. The District will promptly and fully address OCR’s feedback, if any,
until the District receives OCR’s final approval of the training materials,
trainer(s), delivery method, and deadline, and notice from OCR that no further
reporting is required for this Reporting Requirement IV.D.1.

2. After OCR approves the training materials, the District will deliver that training to
District employees within 100 days. Within 30 days of conducting that training,
the District will provide to OCR documentation that it has provided the approved
training referenced in Terms IV.A-B to the personnel required in Term IV.A,
including: (i) the dates and times of the training; (ii) its delivery method (e.g., in
person, online, or hybrid); (iii) the name(s) and title(s) of the trainer(s); (iv) a
copy of any materials used or distributed during the training; and (v) the training
survey results.

3. Within 30 days of conducting the training required by Term IV.A in school year
2024-2025, the District will submit to OCR: (i) the date(s) and time(s) of the
training session(s); (ii) confirmation that the approved training materials were
used and a copy of any materials distributed during the training; (iii) confirmation
that the approved trainer(s) conducted the training(s); (iv) confirmation that the
approved delivery method was used; (iv) the names of employees who did not
complete the training and a plan to train each person within 30 days; and (v) the
training survey results. The District will promptly and fully address OCR’s
concerns, if any, about this reporting until the District receives notice from OCR
that no further reporting is required for Reporting Requirement IV.D.3.

4. Within 30 days of conducting the training, the District will provide to OCR
documentation that the District published on its website all materials used to train
these individuals as required by the Title IX regulations.

5. Within 30 days of conducting the training, the District will report any proposed
revisions to the training in response to the survey results up to that point for
OCR’s review and approval, make any OCR-approved revisions to the training
within 30 days, and publish any revised training materials on its website within 45
days of OCR’s approval.
OCR Compliance Review 08-20-5001 page 8

V. Training for Students

A. By May 24, 2024, and by the end of any subsequent school years for the duration of
OCR’s monitoring of the Agreement, the District will provide age-appropriate
training for District students in grades 3-12 that will cover:

1. the District’s revised Title IX policies and grievance procedures developed under
Term II, including where to locate the policy and procedures on the District’s
website, and the existence of OCR and its authority to enforce Title IX;

2. the District’s Title IX Coordinator, (including current and complete contact

information), as well as school administrators and their respective roles in
coordinating the District’s response to reports and formal complaints of sexual
harassment;

3. what constitutes sexual harassment;

4. the District’s prohibition against sex discrimination, including sexual harassment;

5. the District’s commitment to having a District environment free from sexual

harassment and other harassment based on sex;

6. a statement that harassment of students based on sex will not be tolerated;

7. what students should do if they believe they or other students have been subjected
to sexual harassment, including how to report such harassment and file a formal
complaint of such harassment with the Title IX Coordinator or their designee; and

8. the supportive measures available to students who report sexual harassment or

retaliation, and the available remedies following a finding of sexual harassment
and/or retaliation after an investigation.

B. Reporting

1. By February 29, 2024, the District will submit to OCR: (i) draft materials to train
students under Term V above; (ii) the name(s), job title(s)/position(s), and
qualifications of one or more proposed qualified individuals to provide the
training; and (iii) a description of the training delivery method (e.g., online, in-
person, in a class vs. an assembly). The District will promptly and fully address
OCR’s feedback, if any, until the District receives OCR’s final approval of the
training materials, trainer(s), and delivery method, and notice from OCR that no
further reporting is required for Reporting Requirement V.B.1.

2. Within 30 days of conducting the training (by the approved deadline), the District
will submit to OCR: (i) confirmation that each school provided the training
session(s) by the approved deadline; (ii) confirmation that the approved training
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materials were used; (iii) confirmation that the approved trainer(s) conducted the
training; and (iv) confirmation that the approved delivery method was used.

VI. Policy and System for Collection and Maintenance of Data and Records

A. By January 12, 2024, the District will develop for OCR’s review and approval a
written policy to implement a centralized record-keeping system that adequately and
accurately documents and preserves all reports and complaints of sexual harassment
as required by 34 C.F.R. § 106.45(b)(10) (“Recordkeeping Policy”). The District
will ensure that the policy and centralized recordkeeping system will include, at a
minimum:

1. definitions of key terms, including but not limited to, sexual assault, dating
violence, domestic violence, stalking, quid pro quo sexual harassment, hostile
environment sexual harassment, and rape;

2. relevant codes in the District’s electronic student information system;

3. relevant codes in the District’s electronic employee information system;

4. electronic tracking of all Title IX reports and formal complaints of sexual

harassment in a manner that includes relevant information related to the report or
complaint, including: (i) the reporter’s name and status (e.g., student, parent,
teacher) for reports; (ii) the complainant’s name and status for formal complaints;
(iii) the respondent’s name and status; (iv) a description of the alleged harassment
(e.g., sexual assault); (v) the names and statuses of all identified witnesses of the
alleged harassment; (vi) the name and job title of the person receiving the report
or complaint; (vii) the date, time, and location of the harassing incident(s); (viii)
the date the District became aware of the incident(s); and (ix) the date the Title IX
Coordinator received notice of the incident;

5. documentation of all disciplinary sanctions issued to students or employees for

violations of the revised Title IX policies and grievance procedures referenced in
Term II;

6. notification in personnel files of all final Title IX determinations against

employees or contractors (e.g., School Resource Officers) consistent with the
Title IX regulation, state and local laws, District policies, and applicable
collective bargaining agreements. The notation will provide a summary of the
nature of the allegation of sexual harassment, indicate whether the District found
that the employee or contractor engaged in sexual harassment, including any
violation of District policies, and, if so, the sanction(s) the District imposed on the
employee or contractor;

7. maintenance of all notification letters and written determinations regarding sexual

harassment provided to and received by the parties; and
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8. documentation of any supportive measures and/or any remedies offered to the

parties and/or other individuals prior to, during, and/or after the completion of an
investigation of sexual harassment.

B. The Recordkeeping Policy also will specify:

1. who is responsible for maintaining specific records and information;

2. how records and information are maintained;
3. how long records must be maintained under the Title IX regulations;
4. how records and information will be destroyed after they have been held for the
length of time required by the Title IX regulations;
5. who is responsible for destroying records and information; and
6. how the District will ensure that the policies and procedures are followed with
fidelity.

C. Within 60 days of OCR’s approval of the proposed Recordkeeping Policy, the

District will adopt and provide notice of the approved policy. The notice will include,
at a minimum:

1. posting a link to the policy on the Board’s “Policies” webpage;

2. sending the policy electronically to all employees; and
3. posting a link to the policy on the District’s “Employee Gateway” webpage.

D. The District will ensure that all District employees implement the centralized
recordkeeping system consistent with the policy requirements set forth in Terms
VI.A-B.

E. Within 60 days of the end of every semester until OCR closes its monitoring of this
Agreement, the District will provide to OCR an electronic, sortable file that includes
a list of all reports and formal complaints of sexual assault that the District received
in the preceding semester. The list will include separate fields for:

1. the name of the reporter;

2. the status of the reporter (e.g., student, parent, employee);
3. the name of the complainant;
4. the status of the complainant;
5. the name of the respondent;
6. the status of the respondent;
7. the date of the report or complaint;
8. the date(s) of the alleged sexual assault(s);
9. the nature of the alleged assault(s);
10. the school(s) involved;
11. the date the investigation commenced;
12. the date(s) the District provided written notice of the allegation(s) to the parties;
13. any supportive measure(s) offered to the complainant, respondent, and/or any
other individual;
OCR Compliance Review 08-20-5001 page 11

14. the date the investigation was completed;

15. the date of the notice of the investigation’s outcome to the parties;
16. the date of any findings;
17. a summary of the findings (e.g., respondent sexually assaulted the complainant at
a school event on X date and retaliated against the complainant on Y date);
18. the date of any appeal (if applicable);
19. the outcome of any appeal (if applicable);
20. any sanctions imposed on the respondent;
21. any remedies offered to the complainant and/or other individual and any provided
remedies;
22. a description of any steps the District took to eliminate and/or prevent the
recurrence of a hostile environment created by the incident;
23. the date of any mandatory dismissal of a formal complaint;
24. the basis for any mandatory dismissal of a formal complaint (e.g., allegations did
not meet the definition of sexual harassment in 34 C.F.R. § 106.30(a));
25. the date of any discretionary dismissal of a formal complaint; and
26. the basis for any discretionary dismissal of a formal complaint.

F. Upon request, the District will provide to OCR within 15 days a copy of the complete
investigative file, including applicable school-level records, student disciplinary
records, employee disciplinary records, and Human Resources/Personnel files. The
data will be produced electronically in a mutually agreed format and will be
organized and labeled as individual files, with all relevant documents for an incident.

G. Within 60 days of the end of each school year, the Title IX Coordinator will provide
to the Superintendent and Board of Education a written summary of the information
captured by the tracking system over the preceding school year, including, but not
limited to:

1. the number of reports and complaints of sexual harassment, disaggregated by

school;
2. the number of reports and complaints of sexual harassment resolved through any
informal process authorized by the Title IX regulations;
3. the number of sexual harassment investigations conducted under Title IX,
disaggregated by outcome;
4. any patterns or concerns about sexual harassment (e.g., repeat harassers or
campuses or activities with multiple reports) raised by the information gathered;
and
5. recommendations for steps the District should take in response to any patterns or
concerns identified.

H. Reporting

1. By January 12, 2024, the District will submit to OCR for its review and approval
a draft of the recordkeeping policy required by Term VI. The District will
OCR Compliance Review 08-20-5001 page 12

promptly and fully address OCR’s feedback, if any, until the District receives
OCR’s final approval of the policy.

2. Within 60 days of receiving OCR’s final approval of the recordkeeping policy,

the District will submit to OCR documentation demonstrating that the District
adopted the approved policy and disseminated the policy as required.

3. Within 60 days of the end of every semester until OCR closes its monitoring of
the Agreement, the District will provide to OCR an electronic, sortable file that
includes all of the information required by Term VI.E above.

4. By July 31 of 2024 and each year thereafter until OCR closes its monitoring of
the Agreement, the District will submit to OCR a copy of the Title IX
Coordinator’s report to the Board. The District will promptly and fully address
OCR’s concerns, if any, until the District receives notice from OCR that no
further reporting is required for this Reporting Requirement.

VII. Civil Rights Data Collection Assessment

A. The District will assess, review, and correct as necessary its data submissions to the
Civil Rights Data Collection (CRDC) regarding harassment/bullying based on sex
and allegations of sexual assault for the 2017-2018 and 2021-2022 reporting periods.
Specifically, the District will review the data the District submitted to the CRDC
regarding harassment/bullying based on sex and allegations of sexual assault for the
2017-2018 and 2021-2022 reporting periods to determine if its submissions for those
years were accurate and complete. If the District submitted incomplete or inaccurate
data for the 2017-2018 and 2021-2022 reporting periods, the District will assess how
and why the District submitted incomplete or inaccurate data for those year(s).

B. The District will develop a plan (the Plan) to ensure timely submission of complete
and accurate data to the CRDC in the future and ensure that all employees who are
responsible for reporting data to the CRDC receive instructions regarding how to
report data to the CRDC in accordance with the Plan.

C. Reporting

1. By January 12, 2024, the District will contact OCR to coordinate next steps for
submitting corrected data to the CRDC for the 2017-2018 school year, and for any
subsequent school years for which the District identified inaccuracies or
deficiencies in its submission(s) regarding harassment/bullying based on sex and
allegations of sexual assault.

2. By January 12, 2024, the District will provide OCR with a copy of the District’s
Plan to ensure timely submission of accurate and complete reporting to the
CRDC. The District will also provide documentation to OCR showing the
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District has shared the Plan with its employees who are tasked with submitting
data to the CRDC and instructed them regarding how to implement it.

VIII. Climate Surveys

A. Beginning in the 2023-2024 school year, the District will administer an annual age-
appropriate climate survey of students in grades 3-12, a biennial climate survey of
parents and guardians, and a biennial climate survey of District employees with
respect to sexual harassment in the District’s schools, programs, and activities. The
surveys will inquire about:

1. the prevalence of sexual harassment in the relevant school and the District;

2. the willingness to report sexual harassment to District personnel;

3. whether students, parents and guardians, and employees have sufficient

information about the District’s policies prohibiting sexual harassment and how to
report it;

4. whether students, parents and guardians, and employees are able to find the
District’s policies and grievance procedures regarding sexual harassment;

5. perceptions of the District’s response to reports and complaints of sexual

harassment;

6. whether employees and students have sufficient information about the District’s
anti-harassment policies and are able to find the appropriate resources when
necessary; and

7. suggestions for reducing incidents of sexual harassment in the District and

improving the District’s response to reports and complaints of sexual harassment.

B. The District will, on a biennial basis:

1. analyze the results, information, and feedback provided in each climate survey;

2. use the results, information, and feedback to propose a plan of action to address
all concerns identified and any revisions to its policies, grievance procedures,
and/or training practices needed to respond to those concerns; and

3. provide for OCR’s review and approval the proposed plan of action and revisions.

C. Reporting

1. By January 12, 2024, the District will submit to OCR a draft plan for conducting
the school climate surveys for OCR’s review and approval. The draft plan will
OCR Compliance Review 08-20-5001 page 14

include an assessment timeline, the proposed student, parent and guardian, and
employee survey instrument(s), and a description of how the assessment(s) will be
conducted and data reviewed.

2. By July 31, 2024, the District will provide OCR with documentation of the
administration of the school climate surveys. The documentation will include, at a
minimum, the date(s) the survey was administered, the survey results, the
District’s analysis of the survey results, and the proposed responsive actions the
District will take to remedy the school climate results, for OCR’s review and
approval.

3. By January 31 of each subsequent year during OCR’s monitoring of the

Agreement, the District will provide OCR with documentation of the annual
administration of the school climate survey for students. The documentation will
include the information in Reporting Requirement VII.C.2 above.

4. By January 31, 2025, the District will provide OCR with documentation of the
biennial administration of the school climate surveys for parents and guardians
and employees. The documentation will include the information in Reporting
Requirement VII.C.2 above.

IX. District Review of Prior Case Files

A. The District will review the case files for a subset of the reported incidents of
employee-to-student and student-to-student sexual harassment from school years
2017-2018 through 2019-2020 that OCR identifies for the District’s review to
determine if further action is needed to provide an equitable resolution of the incident.
Such further action may include offering remedies for individuals affected by a sex-
based hostile environment in the District’s education programs or activities. The
District will complete its review within 60 days of OCR’s identifying the case files
for review.

B. Reporting

Within 30 days of the District’s completion of its review of the case files OCR
identified (i.e., within 90 days of OCR’s notice to the District of the case files
identified), the District will report the following to OCR for each case file: (1) a
summary of the District’s review, including who reviewed the case file, if they
identified other relevant documentary evidence, if they interviewed or otherwise
contacted students, parents/guardians, or employees, and what the review determined
(e.g., the harassment was substantiated and created a hostile environment for two
students); (2) the name of any individual affected by the alleged harassment and
hostile environment, including whether the individual was a student or employee; (3)
a description of all corrective steps the District has taken, including the provision of
any remedies to the affected individual(s) and/or other action(s) (e.g., training for an
employee determined to have sexually harassed District students); and (4) the
OCR Compliance Review 08-20-5001 page 15

name(s) and job title(s) of the District staff responsible for determining any remedies
to provide to the affected individual(s) and/or other action to be taken.

UNDERSTANDINGS AND ACKNOWLEDGMENTS

By signing this Agreement, the District agrees to provide the foregoing information in a timely
manner in accordance with the reporting requirements of this Agreement. Further, the District
understands that during the monitoring of this Agreement, OCR may visit the District, interview
employees and students, and request such additional reports or data as are necessary for OCR to
determine whether the District has fulfilled the terms of this Agreement. The District understands
that OCR will not close the monitoring of the Agreement until such time as OCR determines that
the District is in compliance with the terms of this Agreement and the Title IX statutory and
regulatory obligations at issue in this case.

The District understands and acknowledges that OCR may initiate administrative enforcement or
proceedings or refer this case to the Department of Justice (DOJ) for judicial proceedings in the
event of breach to enforce the specific terms and obligations of this Agreement and/or the
underlying Title IX statutory and regulatory obligations. Before initiating administrative
enforcement (34 C.F.R. §§ 100.9, 100.10), or judicial proceedings to enforce this Agreement,
OCR will give the District written notice of the alleged breach and 60 calendar days to cure the
alleged breach.

This Agreement will become effective immediately upon the signature of the District’s
representative below:

FOR ALPINE SCHOOL DISTRICT:

/s/___________________________________ September 19, 2023____________

Dr. Shane J. Farnsworth, Superintendent Date