The latest Dear Colleague letter from the OCR reminds us that every school district, college or university that receives federal financial assistance needs to designate someone as Title IX Coordinator. The letter points out that having a Coordinator with genuine authority goes a long way toward keeping your school in compliance with the law.

The letter says that your Title IX Coordinator should not have any conflicts of interest.  What does that mean?  The letter says “For example, designating a disciplinary board member, general counsel, dean of students, superintendent, principal, or athletics director as the Title IX coordinator may pose a conflict of interest.”  So the OCR’s strong suggestion is that you should have a fulltime Title IX Coordinator on staff, someone with no other job duties.

This presents some practical problems, especially in small districts.  Consider Mudflap ISD, where the superintendent starts his day by driving the bus.  He also serves as business manager, director of HR, athletic director, and occasionally substitutes in the math class.  Mudflap does not have a lot of money to be spent on administrative positions.  So they are supposed to hire a fulltime Title IX Coordinator?

The feds don’t seem to recognize that there is a big difference between the University of Texas and Mudflap ISD.

But you ought to read the letter for yourself.  It’s important.  http://www2.ed.gov/about/offices/list/ocr/letters/colleague-201504-title-ix-coordinators.pdf

DAWG BONE:  BE SURE YOU HAVE A TITLE IX COORDINATOR WITH ADEQUATE AUTHORITY AND TRAINING.