That is a misrepresentation that I also made in a different thread (not out of malice, just because I was trying to process a lot of information all at once).

However, while it is misrepresentation of the precise wording, it isn’t a misrepresentation of the spirit of that section of the letter. That section explicitly says that schools can prohibit counsel from being present and since it also allows schools to prohibit parties from cross-examining each other (if it is discouraged, it obviously can be prohibited), the logical conclusion is that, at least in some, possibly many, cases students will have absolutely no means by which to perform a cross-examination (since they will be prohibited and they won’t have a counsel to do it for them).