On April 24, the U.S. Department of Education’s Office for Civil Rights (OCR) published a “Dear Colleague” letter to update and clarify existing guidance on the role of Title IX coordinators. OCR stressed the importance of an independent (i.e., reporting directly to an institution’s senior leadership) and full-time Title IX coordinator to reduce the chances for any conflict of interest in the Title IX coordinator carrying out his or her responsibilities in overseeing an institution’s compliance with Title IX, including its Title IX grievance procedures. OCR also offered suggestions on ways in which an institution can support its Title IX coordinator, including making the coordinator a visible part of campus life, communicating with students and employees about the coordinator’s role and availability as a resource, and providing regular and effective training to Title IX coordinators. In conjunction with this Dear Colleague letter, OCR also published a letter addressed to Title IX coordinators to highlight key aspects of their role and Title IX Resource Guide for use by institutions and Title IX coordinators to help with compliance efforts.
Client Tip: Institutions should review the OCR’s Dear Colleague letter and Title IX Resource Guide and assess whether any changes in the administrative structure are warranted. Even if no administrative changes are necessary, the Title IX Resource Guide can serve as a valuable source of information to help structure the role and responsibilities of the Title IX coordinator.