The federal office confirmed Thursday that it has opened an investigation at Dixie State. It said it is focusing on whether the school failed to respond to her appeal after its resolution of allegations against her.
She contends the allegations were made in retaliation for her original complaint.
In a statement, Dixie State said it will assist with the investigation but could not comment on details of the case.
"The university is fully committed to complying with all policies and following all processes to protect its students, faculty, and staff," the statement said. "Decisions are made with the best interest of the university community in mind."
With the opened investigation, Dixie State joins a growing list of Utah universities being evaluated by the feds for potential Title IX violations. The other three schools the University of Utah, Westminster College and Brigham Young University are specifically under investigation for allegedly mishandling sexual assault complaints from students.
Willard previously told The Salt Lake Tribune that she immediately faced retaliation for filing complaints against two art faculty members in January 2016, and that Cindy Cole, the Title IX coordinator, failed to address it. Federal law prohibits universities, including students, from retaliating against an individual "for the purpose of interfering with any right or privilege secured by [Title IX]."
About six months later, the school notified Willard that the sexual harassment claim against one individual was unsubstantiated, she said. She never received word about the status of her other complaint, she added.
The U.S. Department of Education recommends that schools complete their investigation within 60 days, but it's not a requirement.
Two months later, in August 2016, the school launched an investigation into allegations of misconduct against Willard including stalking a faculty member, copying a school key and being intoxicated at a school event that allegedly occurred in 2015, she said. She denies the allegations, but the school expelled her.
Days later, she found out the school had been investigating and found her responsible in a sexual harassment claim filed against Willard by another art department faculty member, she said. Willard said she was never given official notice of the case or given a chance to defend herself.
Willard appealed, but she said she has not received a response.
She is unlikely to see a swift resolution of the federal investigation. Though the office has said it aims to resolve complaints in 180 days, it can take longer depending on the case. Westminster, for example, has been under investigation since January 2015.
This is exacerbated by the growing list of schools being scrutinized; as of Wednesday, the office was investigating 339 sexual violence cases at 239 higher education institutions.
If a school is found to have violated Title IX, it usually reaches a settlement with the federal government and must show it is making new efforts to comply with the law. A school could lose its federal funding, though experts say that has never happened.