The Office for Civil Rights within the U.S. Department of Education released a new guidance packet clarifying the responsibilities and powers of Title IX coordinators across universities. The package included a “Dear Colleague Letter” — a letter to Title IX coordinators — and a Title IX resource guide, aiming to restructure Title IX offices to make coordinators more visible and reporting more direct across college campuses.
Emily Renda, project coordinator for the Office of the Vice President for Student Affairs, said because the University’s Title IX Office — housed under the Office of Equal Opportunity Programs — is already following many of the OCR’s guidelines, they may only need to implement very small changes in response to the new packet.
“Our policy fits pretty well with how this guidance describes a Title IX coordinator,” Renda said. “The things that we’re really reading on are the resolution and the OCR complaint to see if they have any other relevant guidance about what else we could do.”
However, she said the University is still using the guidance package to find what is important to change and what is important to keep the same.
“It’s more of teasing out what are our action items that might come out of this,” Renda said.
The University may adapt to new guidelines by restructuring the University’s Title IX Office. Although there is already a Title IX coordinator and multiple deputy coordinators, Renda said a course of action the University may take is assigning a Title IX coordinator to each specific school within the University.
“We already have the deputy structure that they talked about, but we don't necessarily have all students handled under one Title IX pipeline right now,” Renda said. “We might want to think about restructuring.”
Another way the Title IX Office will have to restructure is by creating a more direct reporting system. Rather than reporting to a supervisor, the OCR recommends reporting to senior leadership, such as a university president.
“It seems as though what OCR is trying to communicate is that this should be one of the top priorities for an institution, so having the direct report is of value,” Renda said.
The University is also considering creating a page on its website specifically for Title IX Office to increase its visibility and transparency.
“By publicizing the functions and responsibilities of the Title IX coordinator, the recipient demonstrates to the school community its commitment to complying with Title IX and its support of the Title IX coordinator’s efforts,” said the Department of Education’s “Dear Colleague” letter.
A final way the University can adopt these guidelines is by placing the annual campus climate survey under the control of the Title IX Office.
“This kind of detail they’re talking about is having the Title IX coordinator overseeing the implementation of the climate survey, which this particular go-round it was not through the Title IX coordinator,” Renda said.
The OCR has been releasing new guidelines more in the past four years than it has in the past 15 years. The office sent out its initial package in 2001, then added updates in 2011 and 2014.
“There’s been a lot more concentrated focus at the federal level on this issue and how they're going to enforce it, which means that there’s a lot more frantic updating and policies than there has been in the past,” Renda said. “I don't anticipate that we’ll be getting this frequency of guidance for much longer and [the guidelines] will probably remain in effect for some time.”
Overall, Renda said she thought the new guidelines will be beneficial in the long run because they will encourage the prioritization of a separate office for Title IX coordinators within each university. By adding more uniformity, she said it will be easier for colleges to enforce Title IX.
“It’s good for uniformity across a lot of colleges that don’t necessarily understand what a Title IX coordinator does,” Renda said. “I think it’s going to both add the credibility to institutions that have already made that move but it will also standardize Title IX enforcement across the board.”
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