Earlier, I offered some thoughts on a report issued by the Obama White House Task Force on sexual assault at colleges and universities. Since then, some additional news stories further indicate that the executive branch is taking an aggressive approach to stamping out sexual assault on campus.

The Department of Education’s Office of Civil Rights (“OCR”) has issued a new 53-page document titled “Questions and Answers on Title IX and Sexual Violence.” This new guidance document is complex and sometimes opaque, and many colleges and universities will be inclined to hire new employees to help them understand it. Peter Lake, a higher education consultant and professor of law at Stetson Law School, told Buzzfeed that sexual misconduct consultants will have a “field day” with the new guidance. “A lot of people just got incredibly rich. This will be like Haliburton meets higher education,” he said.

All signs suggest that OCR is prepared to enforce this new document aggressively. It has already gotten into a dispute with Tufts University, which was prepared to enter into an agreement settlement with Tufts. The agreement stated that the document “does not constitute an admission by the University that it is not in compliance with Title IX.” According to Inside Higher Ed, several days later, OCR informed Tufts that it wanted the university to admit that its current policies violated Title IX, a statement that Tufts’ General Counsel Mary Jeka views to be untrue. Tufts has since withdrawn from the agreement. OCR has threatened to withdraw Tufts’s federal funding if a solution cannot be reached. Furthermore, OCR has announced that it has opened sexual violence investigations at 55 other colleges and universities. The list is disproportionately weighted toward high-profile institutions: it includes three Ivy League colleges (Harvard, Princeton, and Dartmouth); Harvard Law School, as well as the University of Virginia, William and Mary, Amherst, Emory,  Swarthmore, and the University of Chicago. The choice of prominent targets suggests that OCR means to send a message to other institutions that even the best-funded sexual assault prevention programs may be insufficient to satisfy Title IX.

The institution on the list that I know best — my undergraduate alma mater, Dartmouth College — seems to have gotten the message. When I read the passage of “Questions and Answers on Title IX and Sexual Violence” that recommends hiring a full-time Title IX coordinator (p. 12), I idly wondered if Dartmouth had a full time Title IX coordinator when I was there. I learned that Dartmouth brought on board a full-time Title IX coordinator for the first time in January. Evelyn Ellis, Dartmouth’s vice president for institutional diversity and equity, told student daily paper The Dartmouth that she thought that the College needed a full-time Title IX employee  because studying the relevant federal regulations required so much time and training.  About  a month later, Dartmouth also opened up a new Sexual Assault Center. The employee promoted to serve as director of the new center, Amanda Childress, made headlines last year for asking at a conference why it would be wrong to expel a student on the basis of an unproven sexual assault allegation.

All in all, this latest round of executive branch action on sexual assault may be tantamount to the enactment of a “Full Employment for Title IX Coordinators and Sexual Assault Prevention Professionals Act of 2014.”