Overview
On October 6, Representative Ro Khanna (D-CA) and several bipartisan cosponsors reintroduced the Campus Accountability and Safety Act (CASA) in the House of Representatives.[1] In the wake of renewed national attention to how colleges and universities respond to allegations of campus sexual misconduct, CASA would substantially amend the Jeanne Clery Campus Safety Act (the Clery Act) by creating new reporting, training, staffing, transparency, and victim support obligations for institutions of higher education. The bill has been referred to the House Committees on Education & the Workforce and the Judiciary.
CASA was introduced in prior Congresses and was not enacted. Most recently, in October 2025, Senators Kirsten Gillibrand (D-NY) and Chuck Grassley (R-IA) introduced a substantially similar version of CASA, where it was referred to the Senate Committee on Health, Education, Labor and Pensions, but it did not advance further.[2] CASA's repeated reintroduction and continued bipartisan sponsorship suggest that many of its core concepts continue to attract congressional interest. Whether this iteration will gain more traction than its predecessors remains an open question.
Enhanced Reporting Requirements
In its current form, the Clery Act focuses on campus crime reporting and disclosure obligations.[3] CASA would preserve those requirements, while significantly expanding institutions' obligations regarding how they handle reports of sexual assault, sexual harassment, dating violence, domestic violence, and stalking.
Perhaps the most significant change is CASA's requirement that institutions publicly disclose detailed information regarding how sexual misconduct allegations move through campus disciplinary systems. Institutions would be required to track and report, among other things:
- The number of rape and fondling incidents, as defined under the CFR, involving student respondents;
- The number of incidents reported to Title IX coordinators or other responsible employees;
- The number of complainants who seek campus disciplinary action;
- The number of matters processed through institutional disciplinary procedures;
- Findings of responsibility and non-responsibility;
- Sanctions imposed; and
- Cases closed without resolution because a respondent withdrew before adjudication.
Creation of Sexual and Interpersonal Violence Specialists
CASA would also require institutions receiving federal funds to designate one or more “Sexual and Interpersonal Violence Specialists” to serve as confidential resources for complainants. These specialists would operate independently from Title IX investigators and adjudicators and would be responsible for assisting students in understanding reporting options, accessing accommodations, obtaining support services, and navigating institutional and criminal processes.
The bill imposes detailed requirements governing who may serve in this role, required training, confidentiality protections, and reporting obligations. Institutions would also be required to maintain an adequate number of specialists based on institutional size pursuant to future Department of Education (DOE) rulemaking.
Expanded Website Disclosure and Public Information Requirements
CASA would significantly expand the information institutions must make publicly available regarding sexual misconduct reporting and response processes. In addition to annual statistical reporting obligations already required under the Clery Act, CASA would require institutions to maintain easily accessible online disclosures concerning available reporting options, confidential resources, survivor support services, disciplinary procedures, retaliation protections, accommodations, medical and forensic resources, and available community-based advocacy services.
The legislation would further require institutions to publicly identify designated Sexual and Interpersonal Violence Specialists and provide information regarding how students and employees may access those resources. Annual security reports would have to be published in an easily accessible manner, made available in different languages, and prominently displayed on the institution's website.
Expanded Training Requirements
CASA would also direct the DOE, in coordination with the Attorney General, to develop standardized training programs for personnel involved in sexual misconduct investigations and disciplinary proceedings. Training topics would include trauma-informed interviewing, consent, the effects of trauma, reporting barriers, cultural responsiveness, and sexual assault dynamics. Institutions would be required to ensure that covered personnel complete the prescribed training.
Uniform Disciplinary Procedures and Notice Requirements
CASA would require institutions to establish a single, campus-wide disciplinary process for sexual misconduct claims against students attending the institution. It would also prohibit institutions from varying procedures based on a student's status or characteristics (for example, athletic team membership or academic major). The requirement is campus-specific, rather than institution-wide, and only applies to student disciplinary proceedings; it would not extend to non-student respondents.
CASA would also impose new procedural notice requirements. For example, institutions would be required to provide complainants and respondents with written notice within 24 hours of a decision to proceed with an institutional disciplinary process, including information regarding the allegations, applicable procedures, anticipated timelines, and available rights and protections.
Enforcement Exposure
CASA would authorize substantial civil penalties for noncompliance. In some circumstances, penalties could reach up to one percent of an institution's operating budget for each year of noncompliance. CASA would not, however, create a private cause of action to enforce these requirements; enforcement would rest solely with the DOE. This would not foreclose claims independently available under Title IX or other applicable laws.
What Comes Next
Given competing legislative priorities and the historical difficulty of advancing major higher education legislation, it is uncertain whether CASA will be enacted under the current Congress, when ends on January 3, 2027. At the same time, the proposal's bipartisan sponsorship and repeated reintroduction suggest continued congressional interest in expanding federal oversight of institutional responses to campus sexual misconduct.
Colleges and universities should therefore view CASA not only as pending legislation, but also as a potential indicator of future regulatory and legislative trends. Even if the bill does not become law in its current form, institutions may wish to assess whether their existing policies and infrastructure align with the bill's key themes. For example, institutions with particularly complicated or diffuse reporting and/or disciplinary processes might use this as an opportunity to reassess and, as appropriate, tighten or simplify their policies.
Steptoe's Higher Education team regularly advises colleges and universities on Clery Act compliance, Title IX obligations, campus safety requirements, government investigations, and institutional policy development. We are closely monitoring developments relating to CASA and other higher education compliance initiatives and can assist institutions in evaluating potential impacts on policies, procedures, governance structures, and compliance programs as the legislative and regulatory landscape continues to evolve.
[i] Campus Safety and Accountability Act of 2026, H.R. 10761, 119th Cong. (2026).
[ii] Campus Safety and Accountability Act of 2025, S. 2290, 119th Cong. (2025).
[iii] 20 U.S.C. § 1092(f).
