Baylor campus

The 105 recommendations Baylor was tasked with implementing have been completed, according to the two attorneys who wrote them last year.

Title IX experts who conducted the nine-month investigation into how Baylor University responded to sexual violence reports have given their stamp of approval on the school’s ongoing corrective actions that started taking shape last year.

A 755-page report released Friday marks the second time a group outside Baylor has verified the school’s efforts to correct institutionwide Title IX failures. Baylor’s accrediting agency, which placed the school on “warning status,” has also checked off the completion of 105 recommendations attorneys Gina Maisto Smith and Leslie Gomez handed Baylor in May of last year.

Maisto Smith and Gomez worked for Pepper Hamilton LLP at the time, and they have since moved to the law firm Cozen O’Connor. The two wrote the new audit report and will remain assisting Baylor in an advisory role that started in late June last year.

The accrediting agency based its assessment on a draft of the audit report released Friday and on meetings with Baylor employees and students.

“We view this audit as a very significant step in our process of implementing the 105 recommendations and ensuring we’re doing the right things for our students,” Baylor President Linda Livingstone said in an interview. “I think the important thing is it’s an external verification from two of the leading experts in the field of sexual assault and sexual violence on college campuses.”

The attorneys observed “a firm and unwavering commitment” by the university that created “a viable and sustainable model for Title IX and Clery implementation,” according to the report. They have worked alongside university officials to assist in some of the implementation.

Maisto Smith and Gomez reviewed the various appointments and hires Baylor made since May 26, 2016, when regents removed Ken Starr as president and Art Briles as head football coach. Ian McCaw resigned as athletic director four days later.

Baylor made new hires in the Title IX office, counseling center and the police department, and the football program was overhauled. The university hired Mack Rhoades as athletic director, Matt Rhule as head football coach and Livingstone as president.

Since June 2016, representatives from a variety of university departments on task forces and implementation teams have enacted the recommendations. Bolstered Title IX and Clery policies and renewed commitment to training across the university were pivotal to the audit, according to the report.

“It’s something you’ve got to keep paying attention to and you’ve got to keep working on, on an ongoing basis, so that we can really do everything we can over time to continue to learn and continue to try to prevent sexual assault and sexual violence on our campus, and also to train and educate and deal with those issues as they arise effectively as we can,” Livingstone said.

The university announced in May that the recommendations were “structurally complete.”

The audit report comes as Baylor faces investigations by the U.S. Department of Education’s Office for Civil Rights, the Education Department’s Clery Compliance Division, the Texas Rangers, the NCAA, the Big 12 Conference, and its accrediting agency.

Livingstone, who started as president in June, said more than half of the recommendations were not legally-required mandates, but best practices in higher education compliance. She said Baylor will go above and beyond what is required by governing bodies in enforcing its Title IX policy.

The report states the completion of the recommendations does not negate prior findings or correct past wrongs.

“Our hope is that moving forward, Baylor’s efforts can continue to proactively, continuously and effectively prevent and respond to sexual and gender-based harassment and violence in a manner consistent with Baylor’s institutional values, mission and commitment to maintaining a campus free from discrimination and harassment,” the report states.

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