Well-informed Title IX Coordinators are required to counteract sex discrimination in education programs in schools and other entities receiving federal financial assistance. (See Title IX Coordinators: Key to Fighting Sex Discrimination in Education PDF handout). Title IX regulations specify that each recipient of federal financial assistance “designate at least one employee to coordinate its efforts to comply with, and carry out, Title IX responsibilities”. However, this requirement has been poorly implemented. In response to requests from Title IX activists, in 1997 and again in 2004 the Education Department (ED) Office for Civil Rights (OCR) sent “Dear Colleague” letters to state education agencies, local school districts, and postsecondary institutions to remind them to comply with Title IX.
In addition to the 1975 Title IX Regulations, the roles and responsibilities of Title IX Coordinators are typically detailed in guidance documents from of the Department of Education’s Office for Civil Rights (OCR). Title IX Coordinators were given extensive responsibilities in the controversial May 2020 Title IX regulations on sexual harassment. Alison Hagani, a summer 2020 FMF intern, searched these regulations for any mention of Title IX Coordinators in her report. “Title IX Coordinator Roles and Responsibilities: A Guide to 2020 OCR Regulations” summarizes the elementary/secondary Title IX process, the post-secondary Title IX process, Title IX jurisdiction, training around Title IX, reporting to Title IX, the formal grievance process, and post-grievance process – as it all pertains to Title IX officers’ responsibilities. Finally, the report explicitly outlines key similarities and differences between the OCR’s new sexual harassment Title IX regulations and the previous regulations of the Obama administration. We encourage others to use this report as a resource to better understand and uplift Title IX Coordinators following OCR’s 2020 regulations. Furthermore, we hope this report empowers educational community members to better understand and thus utilize Title IX Coordinators as resources should they choose.
FMF’s 2016 multi-year study “Reinvigorating The Role of the Title IX Coordinator: A Requirement and Resource” (Executive Summary PDF / Full Report PDF) reveals a major gap between the number of Title IX Coordinators that exist and the number required by law. Institutions covered by Title IX include: state education agencies, 16,000+ school districts, 95,000+ public K-12 schools, 7,000+ postsecondary institutions, museums, libraries, recreation departments, and prisons, as well as other public and private entities that receive federal financial assistance for education.
Many K-12 educational agencies lack designated Title IX Coordinators who are visible and accessible to educators, students, and the public. Even if visible on their institution’s website, few Coordinators are equipped to effectively identify, respond to, and prevent sex discrimination and gender stereotyping. Although 23,000 school district and postsecondary Title IX Coordinators have been appointed to comply with the ED mandatory requests for contact information, relatively few of the 95,000 K-12 public schools have posted their Title IX Coordinators on their websites—often because the school has not yet delegated a Title IX Coordinator. Once designated, Title IX Coordinators must be trained, well supported by their institution, and connected to vertical and horizontal networks of other Title IX Coordinators, equity experts, and their local stakeholders in order to effectively eliminate sex discrimination.
Even when Title IX Coordinators are designated and trained, they may not have expertise in all aspects of Title IX, ranging from academics, to athletics, to employment, to sexual harassment and assault. Thus, FMF and OCR recommend that institutions establish teams of Title IX Coordinators with different specializations who work with the institution’s lead Title IX Coordinator to prevent sex discrimination in all areas covered by Title IX and related governmental equity laws and policies.
In addition to reviewing challenges, the 2016 FMF report, Reinvigorating The Role Of The Title IX Coordinator: A Requirement and Resource applauds recent progress such as the Department of Education’s (ED) 2015 Title IX Coordinators guidance (PDF) and listings of school district and postsecondary school Title IX Coordinators. To find a recent list of Title IX Coordinators in states and large school districts visit FMF’s List of Title IX Coordinators and Gender-Equity Experts in State Education Agencies (PDF).
A focus of the 2016 FMF Title IX Coordinator report is on the important role of Title IX Coordinators in rebuilding the gender equity infrastructure which has been neglected for decades. Title IX Coordinators should be key actors in both the vertical and horizontal infrastructure networks. The vertical infrastructure networks include federal, state, local district and school-level Title IX Coordinators, using both top-down and bottom-up strategies. The horizontal networks include peer Title IX Coordinators; staff responsible for eliminating discrimination based on race, disability, and other potentially discriminatory characteristics; external gender equity experts in specific topics such as employment, athletics, STEM, sexual assault, sex segregation, and LGBTQ issues; and community stakeholders. These equity allies should participate in advisory groups and partnerships with Title IX Coordinators.
For more on the need for developing this infrastructure and reinvigorating the role of Title IX Coordinators see the FMF “Insufficient Funding” section of the Addressing Threats to Title IX web page discussion of the critically important Patsy T. Mink Gender Equity Education Act of 2016 introduced in the Senate and House in July 2016.
Key Title IX Coordinator Documents
Title IX Coordinator Roles and Responsibilities: A Guide to 2020 OCR Regulations
Press Release and FMF Newswire: New FMF Report Describes Ways to Reinvigorate Title IX Coordinators to Eliminate Sex Discrimination.
Executive Summary — Reinvigorating the Role of the Title IX Coordinator: A Requirement and Resource (PDF)
Full 2016 Report — Reinvigorating the Role of the Title IX Coordinator: A Requirement and Resource (PDF)
Title IX Coordinators: Key to Fighting Sex Discrimination in Education (PDF Handout)
FMF Title IX Coordinators on Campus (PDF Handout)
2015 OCR Title IX Coordinator Guidance is found in a letter to school district superintendents or college presidents (PDF), a second letter to Title IX (PDF) Coordinators, and a Title IX Resource Guide (PDF).
Essential Resources for Title IX Coordinators
History and Responsibilities of Title IX Coordinators – 2004 (PDF)
Title IX on State Education Agency Websites – 2005 Report
Title IX on State Education Agency Websites – 2008 Report
