The document is a formal comment letter submitted by leading higher education associations in response to NASA's proposed reporting requirements concerning findings of sexual harassment, other forms of harassment, or sexual assault involving principal investigators or co-investigators at recipient institutions. The signatories affirm their commitment to safe, harassment-free academic and research environments and support NASA’s goals. However, they raise substantial concerns about potential unintended consequences of certain aspects of the proposed requirements, including reporting obligations triggered during preliminary administrative actions, lack of clear definitions, confidentiality risks, and possible conflicts with privacy laws such as FERPA and state regulations. The letter cautions that overly broad or premature reporting could discourage the use of important interim protective measures and potentially harm the reputations and careers of individuals who are ultimately not found responsible.
The associations call for more narrowly tailored reporting, clearer definitions (recommending alignment with language in pending federal legislation), confidentiality safeguards, harmonization with other federal agency requirements (such as NSF and pending Title IX regulations), and the establishment of secure reporting channels and appeal processes. They suggest that subrecipients should bear direct reporting responsibility to NASA to address privacy considerations, and note concerns about compliance with differing layers of federal and state law. The letter urges flexibility in notification timelines, recommends a more transparent and collaborative approach to finalizing the requirements—potentially via stakeholder roundtables—and underscores the importance of open dialogue with the higher education community to develop effective, legally sound, and practical policies for addressing harassment in the scientific workplace.
