"Title Nein from Outer Space"

Article here. Excerpt:

'The problem with nearly every government program or regulation is that it spawns a private sector industry to leach off the regulation, as well as a new constituency group to support the perpetuation or expansion of the regime.

Today’s example is the egregious Title IX sexual assault protocols for college campuses, which, as noted here previously, isn’t even a formal federal regulation. It proceeded from a “dear colleague” “guidance” letter from the Department of Education—an example of what legal scholars call the growing practice of “informal rule-making.” It may seem informal to you, but when you’re on the receiving end, with the threats and blandishments of the federal government coming at you, it seems about as “informal” as a request from Don Corleone.

The Title IX campus rules would never survive a the formal regulatory rule-making process under the Administrative Procedure Act, but the DOE’s “guidance” letter was enough to generate the Association of Title IX Administrators, which exists to offer expert guidance to college administrators everywhere. (This seems to be the creature of the plainly leech-like NCHERM Group, which offers “risk-management consulting services” to universities.) They offer a premium newsletter, Title IX Today, for a mere $299 a year. Such a deal! (The email I received promoting this must-reading has the subject heading: “Title IX: Now Better than Ever!”)'

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