On April 24, 2015, the Department of Education’s Office for Civil Rights issued a Dear Colleague Letter reminding all schools that receive Federal financial assistance that they must designate at least one employee to coordinate their efforts to comply with and carry out the school’s responsibilities under Title IX of the Education amendments of 1972. This legislation prohibits sex discrimination in education programs and activities, and the designated employees who ensure compliance are generally referred to as Title IX coordinators.

Along with the Dear Colleague Letter, a Title IX Resource Guide was also issued. This is a 26-page document that outlines the scope of Title IX, the responsibilities and authority of a Title IX Coordinator, Title IX’s administrative requirements, the application of Title IX to various issues and information dealing with the process of collection and reporting. Both the Dear Colleague Letter and Resource Guide can be found at http://www2.ed.gov/policy/ rights/guid/ocr/title-ix-coordinators.html.

Designation of a Title IX Coordinator

A school district may decide to designate one or more employees as Title IX coordinators. If a district names multiple individuals as coordinators, however, it must designate one of them as having ultimate oversight responsibility. The titles of other coordinators should clearly show that they are in a deputy or supporting role to the main or head coordinator.

For example, a school district may designate a building principal or assistant principal as a deputy coordinator with oversight of the building to which he or she is assigned. Likewise, the district may designate the school’s athletic director as a deputy coordinator with oversight of the athletic program relative to the compliance framework as Title IX applies to athletics. In both of these examples, each deputy coordinator would be responsible to report directly to the district’s head or senior Title IX coordinator. The school district should encourage all of its Title IX coordinators to work together to ensure consistent enforcement of its policies and Title IX.

The Title IX coordinator cannot have other job responsibilities that may create a conflict of interest. For example, it is not recommended to appoint the district’s athletic director as the head or senior Title IX coordinator because he or she would have to be responsible for handling any allegations of sexual harassment or sexual assault against athletic personnel. Appointing the athletic director could cause a conflict of interest depending on the circumstances.

Schools often utilize individuals in a wide variety of roles to fulfill Title IX coordinator responsibilities, including superintendents, assistant superintendents, human resources directors and diversity coordinators. All individuals who serve in coordinator roles must be trained or have prior experience with the topics of sexual harassment and violence, and must be familiar with, and able to explain, the school’s grievance procedure.

Responsibilities of the Title IX Coordinator

The Title IX coordinator’s primary responsibility is to coordinate the school district’s compliance with Title IX, including the school district’s grievance procedures for resolving associated complaints. In addition, the following responsibilities apply:

• Understand Title IX to ensure that procedural requirements of the legislation are being met. This means developing a working knowledge of Title IX, having a copy of the law available and understanding its requirements. To meet this responsibility, coordinators need to keep informed of current research and legal and judicial decisions related to Title IX.
• Ensure the school district is complying with Title IX. This involves reviewing school district policies to ensure that it is not discriminating based on sex and that information about the school district’s practices, including counseling, are non-discriminatory.
• Coordinate the grievance procedure for Title IX complaints which includes assisting students and parents in filing and investigating the concerns or issues.
• Work to decrease sex discrimination in the school district. This is done by providing technical assistance to other district personnel through program development and in-service training to eliminate sex discrimination and to promote gender equity. Also, these efforts include finding and implementing programs to prevent sexual harassment and discrimination. It is necessary to conduct student surveys to determine athletic interest of all students and ensure that budget and participation are proportionate for both sexes.

The Title IX coordinator must have the authority necessary to fulfill this coordination responsibility. Ultimately, the coordinator must have the full support of his or her school district to be able to effectively coordinate the district’s compliance with Title IX. Furthermore, supporting the Title IX coordinator in the establishment and maintenance of a strong and visible role in the community helps to ensure that members of the school community know and trust that they can reach out to the Title IX coordinator for assistance.

Recommendations for a School’s Title IX Coordinator

• Understand your role and responsibilities – The OCR expects a school district’s Title IX coordinator to have full knowledge of the law and be able to discuss all of the school’s Title IX compliance efforts. Schools need to understand that when the Title IX coordinator is working closely with school district personnel, it is the personnel who may not know or fully appreciate the expectations of the federal government; however, the Title IX coordinator must know the law. 
• Understand your responsibilities and then carry them out – Title IX coordinators must know how to conduct a civil rights investigation that will meet the community’s and OCR’s expectations. There are many considerations when conducting an investigation, and if the Title IX coordinator does not have an understanding of what is expected, he or she must acquire the knowledge.
• Balance the responsibilities – The duties of the Title IX coordinator can be challenging when the coordinator’s views about Title IX compliance may be opposite of other school district personnel or even school board members. The best plan is a balanced approach to show that the coordinator is both a valuable partner who works closely with all stakeholders, but that he or she also understands that compliance is ultimately his or her responsibility.
• Seek opportunities for training – Title IX covers sex discrimination in a variety of forms. The responsibilities of the Title IX coordinator can seem overwhelming, but when those responsibilities are carried out properly, they help create and maintain a welcoming, supportive, equitable and safe environment for all students and school district personnel.

The Title IX coordinator is an invaluable resource to school districts and students at all educational levels. School districts need to support their Title IX coordinators in all facets of the job. By doing this, they will ensure that students will have the freedom to learn and thrive in a safe and trusted environment.