OCR Reminds Schools, Universities They Must Hire Title IX Coordinators

Since 1975 when Title IX regulations were issued, school districts, colleges and universities receiving federal financial assistance have been required to designate a Title IX coordinator. Last week, the U.S. Department of Education’s Office for Civil Rights (OCR) reminded educational institutions of this fact when it released its latest Title IX guidance package.

“To be effective, a Title IX coordinator must have the full support of your institution,” says OCR Assistant Secretary Catherine Lhamon in the Department of Education’s April 24 Dear Colleague Letter. “It is therefore critical that all institutions provide their Title IX coordinators with the appropriate authority and support necessary for them to carry out their duties and use their expertise to help their institutions comply with Title IX… In our enforcement work, OCR has found that some of the most egregious and harmful Title IX violations occur when a recipient fails to designate a Title IX coordinator or when a Title IX coordinator has not been sufficiently trained or given the appropriate level of authority to oversee the recipient’s compliance with Title IX. By contrast, OCR has found that an effective Title IX coordinator often helps a recipient provide equal educational opportunities to all students.”

In the letter, OCR advises that the Title IX coordinator’s role should be independent to avoid any potential conflicts of interest. “For example, designating a disciplinary board member, general counsel, dean of students, superintendent, principal, or athletics director as the Title IX coordinator may pose a conflict of interest,” Lhamon claims. 

The coordinator should be highly visible in the campus community, be full-time and report to senior leadership, such as the district superintendent or university president . The coordinator should also have the authority needed to resolve complaints and appropriate comply with Title IX.

Additionally, the letter recommends that some institutions or districts hire multiple Title IX coordinators.

“For example, some recipients have found that designating a Title IX coordinator for each building, school, or campus provides students and staff with more familiarity with the Title IX coordinator,” OCR claims. The familiarity may result in more effective Title IX training of the campus community.

Other Title IX coordinator duties outlined in the Dear Colleague Letter include:

• Having knowledge of school policies and procedures on sex discrimination, as well as drafting and revising these policies to ensure compliance
• Coordinating collection and analysis of data from annual climate surveys
• Having access to information on enrollment, athletics, discipline and sex-based harassment
• Posting a notice of nondiscrimination on the basis of sex in bulletins, announcements, publications, catalogs, application forms, recruitment materials, and sources of referral of applicants for admission and employment, and unions.
• Notifying students and employees of the name, office address, phone number and email address of the Title IX coordinator. The information should be widely distributed. OCR also encourages schools to create a web page with Title IX information on it.
• Receiving training and possessing comprehensive knowledge of all areas of their responsibility, including policies, procedures, complaints, Federal and state laws, regulations and policies that overlap with Title IX.

The Dear Colleague Letter also reminds schools that it is unlawful to retaliate against individuals, including Title IX coordinators, who file a Title IX complaint, participate in an investigation or advocate for others’ Title IX rights. Additionally, OCR says Title IX compliance requirements apply to reports of harassment based on gender identity or sexual orientation.

The April 24 guidance package includes three documents:

• A Dear Colleague Letter to school districts, colleges and universities reminding them of their obligation to designate a Title IX coordinator.
• A letter to Title IX coordinators that provides them more information about their important role.
• A Title IX resource guide that includes an overview of Title IX’s requirements in several key areas, including recruitment, admissions and counseling; financial assistance; athletics; sex-based harassment; treatment of pregnant and parenting students; and discipline-all topics that frequently confront schools and their Title IX coordinators.

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