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Sexual harassment complaints at DO schools: A brief overview

Learn about the processes available to students who want to make a sexual harassment allegation while attending a college of osteopathic medicine.

In the wake of criminal charges against the former dean of the Michigan State University College of Osteopathic Medicine (MSUCOM), the Commission on Osteopathic College Accreditation (COCA) recently reviewed all student complaints from the past five years to assess any potential problems or trends regarding sexual harassment allegations in osteopathic medical schools.

The review found no complaints of sexual misconduct against faculty at any COM, nor any complaints involving MSUCOM.

Yet the issue of sexual harassment in medical training has been documented for decades. A 1993 New England Journal of Medicine article detailed the experiences of more than 80 internal medicine residents. In the findings, 73 percent of female residents and 22 percent of male residents reported that they had been sexually harassed at least once during their training.

Little seems to have changed in the past 25 years. In March, JAMA Internal Medicine published  “Persistence of Sexual Harassment and Gender Bias in Medicine Across Generations—Us Too,” which noted that only 20 percent of sexual harassment cases in medicine are reported.

Below, Brian Kim, JD, COCA secretary and AOA vice president of accreditation, outlines the channels available to students who wish to report sexual harassment.

How should students report sexual harassment?

Issues involving sexual harassment should generally be brought to the school’s leadership and its Title IX officer, who is responsible for investigating complaints.

Every accredited school is required to maintain records under the Clery Act, a federal law mandating that all postsecondary institutions participating in the Higher Education Act’s Title IV student financial assistance programs disclose campus crime and security information, including instances of sexual harassment and other sexually motivated incidents, Kim said. Crime statistics are submitted to the U.S. Department of Education.

In addition to any of the established complaint processes through a COM or through the COCA complaint process, students who allege that they were inappropriately touched or threatened may report the incident to law enforcement authorities for criminal investigation. Also, students may report such incidents to the U.S. Department of Education Office of Civil Rights, which maintains regional offices throughout the United States.

Private legal counsel can assist with other forms of harassment, such as name-calling or quid pro quo offers, in which persons of authority offer favorable treatment in exchange for sexual favors.

What about COCA?

Because COCA accredits colleges of osteopathic medicine and ensures each school continuously meets the accreditation standards, it is generally not the best authority to handle reports of sexual harassment, notes Kim. This is because COCA has no authority to directly impose discipline on individual faculty members. The COCA’s authority is to affect the accreditation status of a COM.

“COCA is not the best path for reporting sexual harassment because its role is to ensure accreditation standards are continuously met. Title IX is intended to address sexual harassment, but there may be circumstances in which the Title IX function isn’t effective or fully established, particularly in new COMs,” Kim explained. “In those cases, COCA may be able to provide some recourse for students.”

In order for COCA to validate a sexual harassment complaint, it must determine that an accreditation standard may have been violated. The most important element in making an effective COCA complaint is citing the accreditation standard violated by the alleged behavior, Kim noted.

In sexual harassment cases, violations are likely specific to standards involving ethics, professionalism and student services.

COCA complaint process

COCA rules require complainants identify themselves to the COCA, but the COCA does not disclose the identity of the complainant to the COM. Anonymity is protected throughout the process.

All submissions received by COCA are confidential and are handled solely by AOA staff. If, after an investigation, the COCA Executive Committee determines that further review is necessary, a COM may be subject to a site visit or other monitoring.

The COCA Executive Committee could also refer the matter to the entire COCA for future deliberation. In some cases, complaints could result in an adverse accreditation decision, where the factual underpinnings are directly related to an accreditation standard. Commissioners representing a school that is the subject of a complaint must recuse themselves from participating.

Persistent fear

Fear of reprisals remains a barrier to reporting sexual harassment at the COM level, according to some educators.

“Students are always concerned that their information won’t be able to be kept confidential and that a complaint will have a negative impact on their clerkship rotation grades or on subsequent rotations at that same site, so I am certain that not all situations are reported,” said Karen Nichols, DO, AOA past president and dean of the Midwestern University Chicago College of Osteopathic Medicine.

“My recommendation to any student who’s been harassed is to go to a person in authority whom they trust and, if they don’t get satisfaction, know that there are other pathways to pursue. Students may not realize that there are options available,” Dr. Nichols added.


  1. I wish I had felt confident to report sexual advances when I was a student, especially on away clinical rotations! There is a lot of ambiguity when it comes to these things since med students and residents don’t fall under hospital employee/staff human resources jurisdiction. I hope the AOA, AACOM, COCA try to create avenues so our doctors-in-training don’t feel like they have to accept this behavior as normal part of education.

  2. As a student right now I do not feel like I can report sexual misconduct as I fear it might have a direct impact on my grade.

  3. There were sexual harassment issues in Internship and residency with involved a select number of staff and female residents in the 1980s. fortunately one individual was so blatant with students interns and residents that several of the male residents did report him to the DME. Eventually it came to a legal action which was settled out of court as the Dr. Wife was a lawyer and was unaware of her husbands brash advances to students, Interns, Residents and even patient ‘s daughters, wives, and Mothers. He really did act out. His wife ultimately educated him.

  4. The fact that no reports of sexual misconduct were found, is not surprising. Most cases get swept under the rug or the people who have done sexual misconduct get told to move on or get fired. However, without knowing what criteria they used for the search, I am leery of accepting thier report. After all, MSU-COM happened.

  5. I think COCA needs to have an anonymous avenue for students who want to complain but are afraid to do so. While COCA says they will protect the identity of reporters, we all know that the DO community is small and that politics play a large role I many processes. I have a hard time believing an identity could be kept safe.

  6. Happened all the time .
    Advances were not even disguised in secretive hallways – the most egregious ocurred in the middle of an operating room case where the male surgeon told me ” take your clothes off , in the daylight , and let me have a good look at you ” . I was mortified . No one spoke , nurses giggled like it was so funny and as he was talking about my ” attractive body ” the male pathologist came into the OR behind him & was listening to his tirade . The pathologist later apologized to me about the rude and outrageous behavior of the surgeon but guess what ? nothing . zip . nada . changed .
    So , med students really have no recourse . Your grades are tied to your attendings view of you and an outspoken whistleblower gets no recommendations .
    Old guys seem to rule .
    PS this never happened with female attendings

  7. Complaints equal career suicide. Every female knows that. I cannot speak for males, I assume it is the same. The “stink” follows you everywhere. Having been a sad witness to many, I can say silence protects your future. There is strength in that. Be brave, be beautiful, be careful and travel safely to your destination.

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