Policy & Procedures Manual
Sexual Misconduct and Complaint Procedures Policy
Marywood University (the “University”) “honors the uniqueness and dignity of each human person” (Core Values of Marywood University, Respect). The University declares and affirms a commitment to maintaining a comfortable, healthy, and safe learning, living, and working environment for all members of the Marywood community. Marywood does not condone and will not tolerate sexual discrimination or sexual violence of any kind, including, but not limited to, rape, domestic violence, dating violence, sexual assault, stalking, sexual exploitation, harassment based on sex, sexual activity for which there is no
Marywood University does not discriminate on the basis of sex in its educational programs and in other activities operated by the University and is required by Title IX, and specifically 34 C.F.R. Part 106.9, not to discriminate in such a manner. This extends to employees of and applicants for admission to Marywood University. Inquiries concerning the application of Title IX may be directed to the Title IX Coordinator or a Deputy Title IX Coordinator for the University, or to the Assistant Secretary for the Office of Civil Rights of the United States Department of Education, Philadelphia, PA (see below for contact information).
Marywood University is committed to taking all necessary steps to comply with any obligations it may have under Title IX of the Civil Rights Act of 1964, as amended, Title VII of the Civil Rights Act of 1964, as amended, and the Campus Sexual Violence Elimination (Campus SaVE) Act of 2013. These are explicit civil and legal applications of the formulation of beliefs already cherished in Marywood’s religious commitment, objectives, and practices.
The Marywood University Sexual Misconduct and Complaint Procedures Policy (“the Policy”) applies to all faculty, staff, administration, employees, students, volunteers, and visitors on campus property. Additionally, the Policy applies to the conduct of all faculty, staff, administration, employees, students, volunteers, and visitors at off-campus University-sponsored events, including, but not limited to, academic and educational programming, internships, study abroad programs, athletic events, and all other University programming, as well as to the conduct of all faculty, staff, administration, employees, students, volunteers, and visitors occurring off-campus but having an effect on the University’s educational environment.
Marywood will process all complaints reported under this Policy regardless of where the conduct occurred to determine whether the conduct occurred in the context of its educational program or has continuing effects on campus or in an off-campus program or activity.
Anyone believing s/he has been the victim of, or a witness to, or otherwise has reason to believe or become aware of conduct that may be in violation of this Policy by, or involving, any member of the University community, guests, or visitors on University property, any property controlled by the University, including off-campus University sponsored events, or off-campus should report the incident as soon as possible to the Title IX Coordinator or one of the Deputy Title IX Coordinators.
Marywood University will take the steps to stop any and all misconduct, prevent its recurrence, and correct its discriminatory effects on the complainant and others.
Preservation of Evidence
The preservation of evidence in incidents of sexual violence is critical and particularly time-sensitive. The University administrator, faculty, or staff member who first hears such an incident from a complainant will inform the complainant of the importance of preserving evidence by taking the following actions:
1. Seek medical assistance at the hospital, ideally within 72 hours of the incident.
2. Do not shower, bathe, wash hands or face, or douche.
3. Try not to urinate.
4. If oral contact took place, refrain from smoking, eating, drinking, or brushing teeth.
5. If clothes are changed, place soiled clothes in a paper bag (plastic destroys evidence).
During the initial meeting between the complainant and the University Title IX Coordinator or Deputy Title IX Coordinator, the importance of taking those actions will be reiterated.
Individuals reporting an incident under this Policy should contact one of the individuals below:
Dr. Patricia E. Dunleavy, Associate Vice President for Human Resources
Title IX Coordinator – for complaints against a member of the faculty, staff or administration
86 Liberal Arts Center
Ms. Ann O'Brien, Assistant Director of Service Learning and Community Service
Deputy Title IX Coordinator – for complaints against students
Swartz Center for Spiritual Life, Room 132
Mr. Ross Novak, Senior Director of Student Conduct and Residence Life
Deputy Title IX Coordinator – for complaints against students
The Tony Domiano Center for Student Life
Ms. Meghan Cruciani, Assistant Vice President for Student Success
Deputy Title IX Coordinator – for complaints against a member of the staff or administration
227 Liberal Arts Center
Any member of the Marywood community may call the University Whistleblower Hot Line at 855-278-2074 and/or use the
Individuals may also direct inquiries or file complaints with:
Office for Civil Rights,
U.S. Department of Education
The Wanamaker Building
100 Penn Square East, Suite 515
Philadelphia, PA 19107-3323
Telephone: (215) 656-8541
Facsimile: (215) 656-8605
Responsible Employees and Confidential Reports
The University encourages the reporting of incidents that may be in violation of this Policy. Furthermore, all employees of Marywood University (i.e., staff, administrators, and faculty) have an obligation to report all incidents that may be in violation of this Policy. The University understands many people who are the recipient of conduct that may be in violation of this Policy may wish to keep the incident confidential. As such, it is important that complainants, and potential complainants, be aware of confidentiality and mandatory reporting requirements in order to make an informed decision regarding reporting the incident.
Complainants who wish to make a report but do not want the University to take any action are encouraged to consult with a professional counselor, medical professional, or ordained member of the clergy. In general, this includes the following individuals on the Marywood campus: licensed counselors in the Counseling/Student Development Center; and licensed counselors in the Psychological Services Center.
Professional staff in the Student Health Services Center and the University chaplain have an obligation to
As stated above, all Marywood University employees are obligated to report to the Title IX Coordinator or one of the Deputy Title IX Coordinators any information that they receive relating to incidents that may be in violation of this Policy. Therefore, if a complainant does not want the University to take any action, the complainant should consider reporting to one of the truly confidential resources outlined above, as opposed to another employee of the University.
University faculty, staff, and administrators who know, or in the exercise of reasonable care should have known, of conduct that may be in violation of this Policy and who fail to appropriately handle the report of the incident may be subject to disciplinary action.
Marywood University will fully investigate every report. The University will not allow any form of retaliation against individuals who report an incident or who cooperate in the investigation of such reports in accordance with this Policy. Individuals who knowingly make false reports may be subject to sanctions depending on the facts and circumstances of the particular incident.
Cases involving alleged conduct that may violate this Policy demand special attention to issues of privacy. Dissemination of information relating to these cases is limited so as to ensure, as fully as possible, the privacy of the individuals involved, in accordance with applicable law.
In all cases, the University will take preventative measures to preserve confidentiality and privacy to the extent permissible by applicable law.
Complainants have the right to review options and available assistance for interim changes to academic, living, transportation, and working conditions. If the complainant requests such an accommodation, and the accommodation is reasonably available, the University will take prompt action to implement the requested accommodation. The University will endeavor to not inconvenience the complainant in taking interim remedial measures.
Examples of interim accommodations include, but are not limited to, no contact orders, changes in academic or living situations as appropriate with minimum burden on the complainant, counseling, escort services, academic support, as well as the option to retake a course or withdraw from a course without penalty.
Drug and Alcohol Amnesty
The University encourages reporting and seeks to eliminate any potential barriers to reporting. The University also understands that an individual who was under the influence of drugs or alcohol at the time that an incident took place may be hesitant to report for fear that he/she will be subject to a violation of the University alcohol and other controlled substances regulations, including the Drug-Free Workplace Policy, the Code of Conduct Policy, and the Alcohol and Controlled Substances Policy for Students. An individual who reports an incident that may be in violation of this Policy, either as a complainant or a third-party, will not be penalized for violating the University’s alcohol and other controlled substances policies for his/her own consumption of alcohol or drugs at or near the time of the incident, provided that such violation did not and does not place the health or safety of any other person at risk. The University may, however, initiate an educational discussion regarding the drug and/or alcohol use.
Marywood University encourages complainants to pursue criminal charges against the person(s) believed to have committed the act in violation of this Policy. The University has personnel on staff who can explain criminal complaint procedures and assist complainants in beginning the process of filing a criminal complaint. Additionally, if necessary, University administrators will notify the appropriate law enforcement officials in accordance with any obligations under federal, state, and local laws. Police investigation and legal prosecution are conducted outside of and in addition to University procedures. Criminal charges and a disciplinary charge may be pursued at the same time. However, the complainant need not pursue criminal charges in order to file a complaint with the University. Should the complainant elect to proceed with both, however, the University will comply with and help to enforce any applicable judicial no-contact, restraining, and protective order.
Marywood will cooperate with law enforcement agencies, including any request that the University temporarily suspend the fact-finding aspect of a Title IX investigation while the law enforcement agency gathers evidence. This suspension is generally 10 days in length; however, specific circumstances may dictate a longer delay. During this time, the University will continue to implement interim accommodations and update the parties
Complainants are encouraged to seek assistance both on-and off-campus, as needed, to address issues stemming from the incident. A list of services both on-and off-campus is included below.
Consent means an informed, freely given agreement, communicated by clearly understandable words or actions, to participate in each form of sexual activity. Consent cannot be inferred from silence, passivity, or lack of active resistance. A current or previous dating or sexual relationship is not sufficient to constitute consent, and consent to one form of sexual activity does not imply consent to other forms of sexual activity. By definition, there is no consent when there is a threat of force or violence or any other form of coercion or intimidation, physical or psychological. A person who is the object of sexual aggression is not required to physically or otherwise resist the aggressor; the lack of informed, freely given consent to sexual contact constitutes sexual misconduct.
Dating violence is defined as physical, sexual, or psychological/emotional violence within a dating relationship.
Domestic violence is defined as sexual or intimate partners engaging in one or more of the following acts:
1. Attempting to cause or intentionally, knowingly or recklessly causing bodily injury, serious bodily injury, rape, involuntary deviate sexual intercourse, sexual assault, aggravated indecent assault, or indecent assault with or without a deadly weapon;
2. Placing another in reasonable fear of imminent serious bodily injury;
3. Inflicting false imprisonment;
4. Knowingly engaging in a course of conduct or repeatedly committing acts toward another person, including following the person, without proper authority, under circumstances which place the person in reasonable fear of bodily injury.
Off-campus property includes, but is not limited to, University programming, internships, study abroad programs and sporting events.
Rape is defined as an individual engaging in sexual intercourse with another individual:
1. by forcible compulsion;
2. by threat of forcible compulsion that would prevent resistance by a person of reasonable resolution;
3. when the other individual is unconscious or is unaware that the sexual intercourse is occurring;
4. where the individual has substantially impaired the other individual’s power to appraise or control his or her conduct by administering or employing, without the knowledge of the complainant, drugs, intoxicants or other means for the purpose of preventing resistance; or
5. where the other individual suffers from a mental disability which renders the complainant incapable of consent.
Sexual assault is defined as threats of, or deliberate physical contact of a sexual nature that is against another person’s will or without consent. Examples of such behavior include, but are not limited to the following:
1. deliberate physical contact of a lewd type, including brushing, touching, grabbing, pinching, patting, hugging and kissing;
2. deliberate or reckless threats, actual or implied, of physical contact of a sexual nature that results in reasonable fear of sexual assault or physical harm;
3. coerced sexual activities, including rape. Rape, the most severe type of sexual assault, is legally defined in Pennsylvania as sexual intercourse that is coerced through force or threats of force, or with someone who is unconscious or with someone who is so mentally deranged or deficient as to be incapable of consent.
Sexual Harassment is defined as conduct that is sexual in nature, unwelcome, and denies or limits a person’s ability to participate in or benefit from a school’s educational program. Sexual violence is a severe form of sexual harassment.
There are three forms of sexual harassment: quid pro quo, hostile environment, and retaliation.
Quid pro quo harassment can only be carried out by a faculty member, an administrator, or another employee. It consists of unwelcome sexual advances, requests for sexual favors, or other verbal or physical conduct of a sexual nature; and submission to, or rejection of such conduct results in adverse educational or employment action. Some examples include:
1. submission to such conduct is made, either explicitly or implicitly, a term or condition of an individual’s employment or education; or
2. submission to or rejection of such conduct by an individual is used as a basis for employment or educational decisions affecting such individual.
Hostile environment can occur on or off campus and can be carried out by faculty, administrators, another employee, students, and third parties visiting the educational institution. It occurs when harassment is sufficiently severe, pervasive, or persistent so as to interfere with or limit a person’s ability to participate in or benefit from the services, activities, or opportunities offered by an educational institution.
Retaliatory harassment occurs when an adverse educational action is taken against a person because of the person’s participation in a complaint or investigation of discrimination or sexual misconduct.
Examples of sexual harassment also include: obscene gestures, visual harassment such as derogatory cartoons, posters and drawings, sexually explicit e-mail, texting, or voice mail and other verbal or physical conduct of a sexual nature such as uninvited touching of a sexual nature or sexually related comments. Depending upon the circumstances, prohibited conduct can also include sexual joking, vulgar or offensive conversation or jokes, commenting about an individual’s physical appearance, conversation about an individual’s own or someone else’s sex life, teasing or other conduct directed toward a person because of his or her gender which is sufficiently severe or pervasive to create a hostile working environment. It may range from inappropriate sexual suggestions to coerced sexual relations.
Stalking is defined as engaging in a course of conduct or repeatedly committing acts towards another person, including following the person without proper authority, under circumstances which demonstrate either an intent to place the other person in reasonable fear of bodily injury or to cause substantial emotional distress to the other person or engaging in a course of conduct or repeatedly communicating to another person under circumstances which demonstrate or communicate either an intent to place such other person in reasonable fear of bodily injury or to cause substantial emotional distress to the other person.
Sexual Exploitation includes, but is not limited to, prostituting another person, non-consensual visual or audio recording of sexual activity, non-consensual distribution of photos, images or information of an individual’s sexual activity or intimate body parts, non-consensual voyeurism, coercing someone against their will to engage in sexual activity, or knowingly transmitting sexually transmitted disease (STD) without disclosing STD status.
Individuals are encouraged to file complaints with the Title IX Coordinator or the appropriate Deputy Title IX Coordinator. Once a report of an incident is made to the Title IX Coordinator or a Deputy Title IX Coordinator by a witness to an incident or an individual comes forward to report an incident, the Title IX Coordinator or a Deputy Title IX Coordinator will meet with the alleged victim to discuss the importance of preserving evidence, the right to file a criminal complaint, interim accommodations, and the right to file a complaint with the University.
If the complainant chooses to file a complaint with the University, the individual may proceed formally or informally. The Title IX Coordinator or a Deputy Title IX Coordinator will acknowledge receipt of the complaint to the complainant and simultaneously notify the alleged offender of the complaint, in writing. Both notices will include the specific alleged offenses, the name of the investigator assigned to the complaint, and a copy of the Policy (or link). Generally, the University will notify the respondent/alleged offender of the name of the complainant.
Although neither party can be required to participate in the process, all parties are encouraged to participate to ensure an accurate and objective process and outcome. If a respondent/alleged offender chooses not to participate, the University will proceed with the complaint without the respondent/alleged offender’s participation.
In situations when the complainant elects to proceed informally, in which case the parties do not proceed through the University’s formal resolution process, the Title IX Coordinator or Deputy Title IX Coordinator will determine the steps to take to resolve the issue. The parties may elect to resolve the matter through mediation UNLESS the situation involves sexual assault and/or sexual violence. Should the complainant elect to proceed informally, s/he may elect to stop the informal process at any time and proceed through the formal process.
If the complainant decides to proceed formally, either initially or after opting out of the informal process, the complainant should submit within ten (10) working days a formal complaint, preferably in writing, to the Title IX Coordinator or Deputy Title IX Coordinator who originally fielded the complaint. The complaint must include detailed factual information concerning the incident(s) and should include what the complainant feels will correct the situation. The Title IX Coordinator or Deputy Title IX Coordinator will appoint an investigator from a pool of trained faculty, administrators and professional staff. All Marywood investigators are trained on the handling of complaints of sexual harassment, the University’s Sexual Misconduct and Complaint Procedures Policy, and applicable confidentiality requirements.
Marywood is committed to ensuring that real or perceived conflicts of interest by those handling the investigation are eliminated. For example, co-workers in the same department, advisors to students, and club advisors will not be used in investigations involving their areas. Individuals who believe that bias or a conflict of interest has occurred should contact the Title IX Coordinator or a Deputy Title IX Coordinator, who will address the concern.
The Associate Vice President for Human Resources, Title IX Coordinator, in consultation with the President, will decide the appropriate course of action in cases where a conflict of interest is evident or possible.
Within five (5) working days after receipt of a formal complaint, the investigator will commence a thorough investigation. Investigations will be conducted as expeditiously as possible. The entire process, as outlined below, should be completed within sixty (60) calendar days after the complaint, either formal or informal, is filed. This timeframe may vary, however, depending on confidentiality requests, availability of witnesses, the scope of the investigation, and any unforeseen circumstances.
Generally, within ten (10) working days after the initiation of the investigation, and every ten (10) working days thereafter until receipt of the final outcome, the investigator must provide, simultaneously, a written summary of the complaint and the proceedings to date to both the complainant and the alleged offender.
The investigation will include, where possible, interviews with the complainant, the alleged offender, and witnesses identified by either party or during the course of the investigation. The investigator will send a copy of the interview notes to each interviewee with a request to review for accuracy and confirm in writing. The investigation will also include the examination of documentation, both submitted by the parties and uncovered during the course of the investigation. Both parties are encouraged to present potential witnesses and relevant documentation.
Requests to review documentation should be addressed to the Title IX Coordinator. Individuals may request to review documents included within the investigatory file. Due to privacy issues, some of the documentation may be redacted prior to the request being honored.
Also during the course of the investigation, the prior conduct of the complainant and the accused may be reviewed, but the prior relationships of the complainant with anyone other than the alleged offender may not be relevant and, therefore, generally will not be reviewed.
Should the investigation include meetings with the complainant and/or the alleged offender, the complainant and the alleged offender are permitted to be accompanied by the advisor of their choice, including an attorney. Advisors may attend proceedings with their advisee, but may only speak to their advisee. Advisors may not interrupt or otherwise disrupt proceedings. All communication throughout the entire investigatory process will be directed to the advisee.
The University cannot guarantee equal advisors. The University has counselors and other employees who may be able to assist in the proceedings, and upon request, the University will provide such assistance to either party. The University is not responsible for paying any attorney or other outside advisor.
Both parties are allowed to discuss and share information relating to their complaint with others that may support or assist them in presenting their case. It is expected that advisors will keep all information shared private.
Upon conclusion of the investigation, the investigator will provide a written document that includes the facts uncovered during the investigation and all witness statements (with redactions as noted above) to the Title IX Coordinator (in conjunction with the Deputy Title IX Coordinator for cases involving student complaints against students). The Title IX Coordinator or the Deputy Title IX Coordinator will provide, simultaneously, a copy of this investigator’s report to both the complainant and the alleged offender. The complainant and alleged offender will have 5 working days to review and provide feedback to address any perceived inaccuracies in the report.
The investigator will provide, separately, an addendum to the investigator’s report that will include his or her findings, based on a preponderance of the evidence, along with recommendations, to the Title IX Coordinator (in conjunction with the Deputy Title IX Coordinator for cases involving student complaints against students).
If the alleged offender admits to the charges, or in instances where it is obviously clear that no violation of the Policy occurred, the investigator and the Title IX Coordinator or the Deputy Title IX Coordinator will determine sanctions and other recommendations, and conclude the investigation.
In all other cases the Title IX Coordinator or the Deputy Title IX Coordinator will then appoint a review panel composed ideally of three (3) members, at a minimum two (2) members, from the pool of trained investigators.
The review panel will meet with the investigator, who will present his/her findings to the review panel in person. The review panel may interview witnesses, including the complainant and/or alleged offender, or alternately may direct the initial investigator to interview additional persons. Both the complainant and the alleged offender may submit questions to the review panel for the review panel to ask of the other side.
The review panel will determine, based on a preponderance of the evidence, whether the alleged offender violated the Policy. The review panel will then provide conclusions and disciplinary recommendations to the Title IX Coordinator (and the Deputy Title IX Coordinator as appropriate). After a decision is made concerning resolution of the complaint and any disciplinary actions to be imposed, the Title IX Coordinator (or the Deputy Title IX Coordinator as appropriate) will notify simultaneously the complainant and the alleged offender in writing of the outcome of the investigation. Such notification will include the allegations, findings based on a preponderance of the evidence, rationale, and sanctions in accordance with policy and applicable laws. The Title IX Coordinator or the Deputy Title IX Coordinator will notify any other parties of any recommendations assigned to them.
If the alleged offender is found to have violated the Policy, action will be taken to eliminate the discriminatory or harassing conduct, including, but not limited to, extending the interim remedial actions, as well as issuing a warning, no contact order, suspension, transfer, discharge, or dismissal of the offender or anyone making a knowingly false complaint. In situations where the alleged offender is found to have violated the Policy by committing stalking, the recommended sanctions include no contact order, suspension, transfer, and, in extreme situations and at the University’s discretion, discharge or dismissal from the University. In situations where the alleged offender is found to have violated the Policy by committing sexual assault, rape, sexual exploitation, domestic violence, or dating violence, the recommended sanction will be suspension or dismissal from the University. The University reserves the right to modify sanctions depending on the facts and circumstances of the particular incident.
Employees involved in such incidents may be subject to other existing University policies for repeated patterns of similar incidents, failure to cooperate, or additional or egregious policy violations.
Either party, if not satisfied with the final outcome of the hearing panel and the Title IX Coordinator/Deputy Title IX Coordinator, will have ten (10) working days after receipt of the outcome letter to file an appeal for one of the following reasons:
1. The presentation of new evidence;
2. Allegation that relevant evidence was not considered;
3. Allegation of procedural error;
4. Disproportionate sanctions.
Appeals must be in writing and submitted to the Associate Vice President for Human Resources, Title IX Coordinator, who will determine, within 3 days, whether the appeal has merit based on one of the above-stated reasons. If the appeal falls within one of the four above-listed criteria, the Associate Vice President for Human Resources, Title IX Coordinator will forward the written appeal to the President of the University. Within five (5) working days the President will direct the appeal to the appropriate University body, described below. The appeals committee will have thirty (30) working days to review and make a recommendation to the President of the University. The appeals committee may review the initial investigation as well as independently investigate the claim. Within ten (10) working days after receipt of the recommendation from the appeals committee the President of the University will provide a written response to both parties in the original complaint. The decision of the President of the University is final and binding.
Claims against Faculty Members including Librarians, Administrators, Professional Staff, and Support Staff
The President of the University will appoint and convene a committee of five (5) employees comprised of professional staff, administrators, and/or faculty who are independent of the claim.
Claims against Students
The President of the University will refer the appeal to the Vice President for Enrollment Services and Student Success who will convene an Appeal Board. The Appeal Board will review the complaint and make a recommendation to the Vice President for Enrollment Services and Student Success who will notify the President of the recommendation.
Retaliation of any kind is prohibited. Anyone who reports an actual or suspected incident, or who participates in an investigation of an incident under this Policy, will not be subjected to retaliation. If a complainant or witness believes s/he has been subjected to retaliation, s/he should contact the Associate Vice President for Human Resources, Title IX Coordinator or the Senior Director of Student Conduct and Residence Life, Deputy Title IX Coordinator. Anyone found to be in violation of this retaliation provision may be subject to disciplinary action.
A list of Marywood University and community resources is available below and in the Human Resources Office, the Senior Director of Student Conduct and Residence Life Office, the Student Health Services Office, the Office of Disabilities Services, and the Counseling and Student Development Center.
Students are encouraged to use the services of the Counseling and Student Development Center, the Student Health Services Office, and the Office of Disabilities Services on campus. Employees are encouraged to contact the University’s Employee Assistance Program (EAP) or the Associate Vice President for Human Resources for a list of providers.
On Campus Resources:
Counseling and Student Development Center
Dr. Robert Shaw, Director
McGowan Center Room 1017
Senior Director of Student Conduct and Residence Life Office
Mr. Ross Novak, Senior Director of Student Conduct and Residence Life/Deputy Title IX Coordinator
The Tony Domiano Center for Student Life
Office of Disabilities Services
Ms. Diane Webber, Associate Director
Liberal Arts Center Room 223
Human Resources Office
Dr. Patricia E. Dunleavy, Associate Vice President/Title IX Coordinator
Liberal Arts Center Room 86
Student Health Services Office
Ms. Linda McDade, RN, Director
Loughran Hall Terrace Level
Geisinger Community Medical Center
1800 Mulberry St
Scranton PA 18510
Moses Taylor Hospital
700 Quincy Ave
Scranton PA 18510
Regional Hospital of Scranton
746 Jefferson Ave
Scranton PA 18510
Women’s Resource Center
06/12/14 - Approved/established by the President of the University.
08/01/14 - Revision to include change in Deputy Title IX Coordinators approved by the President of the University.
05/10/16 - Revision mandated by changes to the Title IX statute. Revision approved by the President of the University as recommended by the Policy Committee of the University.
07/12/16 - As Dr. Alan M. Levine's position as Vice President for Academic Affairs ended on June 30, 2016, a proposal to amend the policy to remove him as a Deputy Title IX Coordinator for faculty members was made. At its July 12, 2016 meeting, the President's Cabinet recommended that this change be made and on July 12, 2016, the President approved it.