ShareOn April 24, 2015, the United States Department of Education’s Office of Civil Rights issued a new “Dear Colleague” letter concerning Title IX, along with a separate letter to Title IX coordinators and a Title IX Resource Guide. These documents will be of interest to all school districts, colleges an
d universities receiving federal funds and therefore subject to Title IX.
The Dear Colleague letter emphasizes the importance of designating an employee who will be responsible for coordinating the institution’s efforts to comply with and carry out its responsibilities under Title IX – in essence, a Title IX coordinator. In the letter, OCR points out that “some of the most egregious and harmful Title IX violations occur” when an institution fails to designate a Title IX coordinator, fails to train the coordinator properly, or fails to give the coordinator appropriate authority and support. OCR advises that an institution’s Title IX coordinator should be independent, reporting directly to senior leadership, and should be full-time in the position. (The letter does not acknowledge the burden this could place on financially strapped smaller districts and schools.)
The Dear Colleague letter goes on to discuss the duties of Title IX coordinators, appropriate training and support, and the importance of making the Title IX coordinator visible to the school community. An accompanying letter addressed to Title IX coordinators themselves is essentially a pat on the back for them, but it also stresses the significance of their work and the importance of institutional support.
Finally, along with the two letters, OCR provides a Title IX Resource Guide which provides useful summaries of the application of Title IX to various aspects of school operations – such as admissions, athletics, sex-based harassment, employment, and retaliation -- and references important source documents, such as prior Dear Colleague letters, statutory sections, and regulations.
Both April 24, 2015 letters, and the Resource Guide, can be downloaded here.
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Alerts, commentary, and insights from the attorneys of Pullman & Comley’s School Law practice on federal and Connecticut law as it pertains to educational institutions, whether those institutions be public school districts, private K-12 schools, or post-secondary colleges and universities.