University of California President Janet Napolitano — and thousands across the country — delivered an unequivocal message to the Trump administration this week about sweeping changes proposed for how campuses must respond to sexual harassment and assault allegations: They’re wrongheaded.

Education Secretary Betsy DeVos’ overhaul of the federal Title IX law would discourage victims from reporting abuse, limit schools’ ability to prevent sexual misconduct and let more students get away with it, Napolitano and UC’s Title IX Coordinator Suzanne Taylor wrote Monday in a 14-page letter calling the changes “overly prescriptive” and “unworkable.”

DeVos wants to narrow the definition of sexual harassment, reduce the kind of cases schools can investigate, and replace universities’ fact-finding investigations with court-like hearings in which advocates for students accused of sexual misconduct would cross-examine alleged victims. Testimony from anyone who isn’t cross-examined would be excluded. The proposal includes other dramatic changes to the law that has banned gender discrimination in education since 1972.

The UC president is far from alone in condemning the revisions. As the 60-day public comment period ended Wednesday, some 100,000 people — averaging about 1,600 a day — have posted opinions or written in, hoping to influence DeVos to change, keep or flat-out abandon her plan.

Among them are the 23 California State University presidents and Chancellor Timothy White, who say that excluding testimony is “draconian.”

The Association of American Universities, representing 60 top research universities, including Stanford, criticized the plan as making it “more difficult for universities to protect students who experience sexual harassment.”

Campuses haven’t always done that well. They’ve ignored harassment and assault not only by students, but by faculty. Administrators have created barriers — intentionally or not — that make it hard to report problems. And when barriers come down, lenience for misconduct has often been the norm.

Since 2011, well before the #MeToo movement hit in 2017, a student revolt commenced across the country that continues today. Through federal complaints, state audits, press scrutiny and lawsuits, women have forced universities to better comply with Title IX by taking complaints seriously and investigating them promptly.

Under President Obama, the U.S. Department of Education issued 19 pages of guidelines to encourage this. They reinforced the “preponderance of evidence” standard for investigators to decide whether harassment had “more likely than not” occurred. They discouraged cross-examination because of the potential for trauma. And they called mediation “improper” because it would require alleged victims and perpetrators to somehow fix the problem together, as if asking the robber and the robbed to resolve their differences.

A subsequent Q&A clarified how campuses should help students navigate the emotional process of reporting sexual misconduct, while making it clear that due process was available to all.

DeVos rescinded both documents in 2017, earning applause from groups such as “Save Our Sons,” which defend accused students. At the core of her overhaul is DeVos’ view that the nation’s “believe the victim” movement clouds schools’ approach and tilts the scales unfairly toward accusers. Some students have sued for the right to cross examine their accusers.

On Nov. 29, the Trump administration proposed extensive Title IX revisions, including mandatory court-like hearings that require schools to “treat complainants and respondents equally, giving each a meaningful opportunity to participate in the investigation and requiring the (school) ... to provide a predictable, consistent, impartial process for both parties.”

Many critics, including UC’s Napolitano, say their procedures already achieve that. UC’s process does not include a hearing, but lets each party have an adviser, identify witnesses, present evidence, question the other side and appeal the outcome, Napolitano wrote.

“Nearly half a century after Title IX’s adoption, these rules should reflect our nation’s increased understanding of sexual harassment, the damage it wreaks, and how to counteract it — and our commitment to change. They do not,” she wrote.

Among the proposal’s other key changes:

• A higher standard of evidence: Evidence of sexual misconduct would have to be “clear and convincing” — harder to prove than the current “preponderance of evidence” — unless “preponderance” is also used for other kinds of conduct cases.

• Narrower definition of sexual harassment: Schools could no longer find that a student was sexually harassed unless the conduct was “so severe, pervasive, and objectively offensive that it effectively denies” the student equal access to the education program.

• Duty to report: Students could no longer expect their campus to stop sexual harassment simply because they told a trusted employee about it. Only employees with “actual knowledge” of the harassment — a Title IX coordinator or official with authority to discipline — would have to respond.

• On campus only: Under Obama-era guidance, if a student alleges sexual misconduct, “regardless of where the conduct occurred, the school must process the complaint.” The proposal would “require (schools) to dismiss a formal complaint” if the conduct occurred outside its “program or activity.”

“Title IX should be protecting survivors and holding universities accountable, yet these rules do the exact opposite,” Kylie Murdock, a UC Berkeley junior and sexual assault survivor, wrote on the comment site. She pointed to the cross-examination requirement.

“I’ve run into my assaulter on campus three times, and each time I’ve had an overwhelming anxiety attack where I couldn’t breathe and started crying,” Murdock wrote. “If I were required to be cross-examined, the effects would most likely be tenfold. ... Nobody should be required to relive the trauma of their violent assault. This requirement will also severely curtail reporting.”

A random look at responses from around the country suggests that supporters are in the minority.

One was Erick Guerrero, who said he was falsely accused of sexual harassment while a professor at the University of Southern California. He called cross-examination “necessary to determine issues of credibility.”

The Education Department will publish a review of the comments and identify changes in the final rules, said a spokesman for DeVos, who spoke on condition of anonymity. There is no deadline.

Nanette Asimov is a San Francisco Chronicle staff writer. Email: nasimov@sfchronicle.com Twitter: @NanetteAsimov