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- Institutions are moving toward an integrated civil rights response model
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As federal civil rights compliance grows increasingly complex, and as federal scrutiny intensifies, colleges and universities face mounting pressure to reevaluate their traditional approaches to handling complaints of Title IX (sex-based discrimination and harassment) and Title VI (race, color, and national origin-based discrimination and harassment[1]). Historically, many institutions have maintained separate processes for responding to these two types of complaints, but recent legal developments and guidance suggest that an integrated approach may offer significant advantages.
While Title IX compliance is subject to detailed regulatory requirements, evolving state laws and recent federal guidance indicate that applying the Title IX complaint and investigation framework to Title VI issues is generally favored. This model provides increased process uniformity and consistency, which is particularly valuable in today’s enforcement landscape. Consequently, a growing number of colleges and universities are moving toward an integrated civil rights response model that unifies the reporting mechanisms, policies and procedures, investigative processes, and supportive measures for students, faculty, and staff who have experienced discrimination or harassment, regardless of what protected characteristic that discrimination or harassment is based on.
Benefits of an integrated response model
Adopting an integrated approach to institutional discrimination complaints presents several notable benefits. First and foremost, it promotes consistent policies and procedures across the institution for responding to potential civil rights violations. Such consistency ensures equitable treatment for all individuals, regardless of the type of discrimination or harassment they have experienced. By establishing uniform guidelines, institutions can eliminate disparities in how cases are managed and resolved, and pre-empt any impression that they are providing more process – and therefore treating with more seriousness – discrimination on the basis of, for example, sex, as opposed to discrimination on the basis of other characteristics like race or national origin.
This approach allows for streamlined case management. An integrated model reduces duplicative efforts and ensures that civil rights reports and complaints are processed according to standardized protocols. This efficiency not only saves time and resources but also helps to prevent confusion and delays that can arise when multiple offices or teams are involved in managing cases, or when multiples bases for discrimination are asserted in a single complaint.
Comprehensive support for affected parties is also enhanced through coordinated efforts. Parties involved in civil rights complaints benefit from access to more robust resources and clearer communication throughout the process. They can receive consistent guidance and supportive measures, which helps to alleviate the stress and uncertainty often associated with filing a complaint or being the subject of an investigation.
Coordination of processes often leads to improved overall compliance as the integrated model facilitates better monitoring of complaint trends, documentation, and responses to reports. This capability is invaluable for internal audits and for responding to federal enforcement actions. Institutions are better positioned to demonstrate adherence to legal requirements and to proactively address areas of concern.
The integrated approach also supports proactive risk management. Colleges and universities can respond more effectively to inquiries or investigations from the U.S. Department of Education’s Office for Civil Rights (OCR) or the U.S. Department of Justice, or to systemic concerns raised by stakeholders, and are better equipped to identify areas for improvement before issues escalate. By taking a holistic view of civil rights compliance, institutions strengthen their ability to navigate regulatory challenges and safeguard their campus communities.
Finally, cross-team collaboration is enhanced under this model. On-campus civil rights, student affairs, and human resources teams are better prepared to address the full spectrum of civil rights complaints, including those with intersectional elements. This expertise and sensitivity are essential for providing comprehensive support and for fostering a culture of respect and inclusion on campus.
Challenges of an integrated response model
Despite its many advantages, the integrated model also presents several challenges that institutions must carefully consider. One major concern is the demand on resources. Revising policies and procedures, consolidating offices, and retraining staff require significant investments of time and financial resources. Institutions must ensure they have adequate capacity to manage the transition and to sustain the integrated model over time. Change may also be more of a constant for coordinated processes, as updates to either Title IX or Title VI regulations or guidance may require edits of a unified policy or process.
Relatedly, some institutions may view conforming their Title VI processes to the strict regulatory requirements of Title IX to be “over-compliance.” Title IX and Title VI do have differing legal requirements, and each statute therefore presents distinct compliance obligations. A unified approach may inadvertently diminish the focus on certain issues or, conversely, place undue emphasis on others. It is essential that institutions retain a nuanced understanding of both sets of requirements and avoid a one-size-fits-all mentality.
Change management poses another challenge, as stakeholders who are accustomed to existing structures may resist the transition. Students, faculty, and staff may have concerns about how the new model will affect their rights and experiences. Effective communication and strong leadership are necessary to address these concerns, build trust, and ensure broad buy-in for the new approach.
Centralization can also create potential bottlenecks or delays, particularly if the centralized on-campus civil rights office is understaffed or overwhelmed by a high volume of cases. Such challenges can impact the timeliness and effectiveness of investigations and resolutions. Institutions must proactively monitor workloads and allocate sufficient resources to prevent these issues from undermining the goals of the integrated model.
Given these challenges, colleges and universities should weigh the potential benefits and drawbacks carefully when designing and implementing an integrated civil rights response.
Practical steps for implementation
For institutions of higher education considering the transition to an integrated civil rights response, careful planning is essential. The first step is to conduct a thorough assessment of current policies and procedures. Identifying differences, gaps, and areas of overlap between the institution’s current Title VI and Title IX processes and offices will provide a roadmap for revision and consolidation.
Legal counsel should be engaged early in the process to ensure that updated policies and procedures comply with federal, state, and local laws and guidance, as well as best practices. This collaboration is crucial for safeguarding the institution against potential legal challenges and for maintaining a high standard of compliance.
Establishing–and adequately staffing and funding–a unified office on campus, such as a Civil Rights Office or Office of Equal Opportunity, can help promote efficiency and accountability. Centralizing responsibility for civil rights complaints streamlines case management and enhances oversight. Ongoing staff training is equally important, not only to maintain legal compliance but also to ensure consistency in investigations and support services across all types of complaints.
Communication is another critical element of successful implementation. Institutions should invest in clear, proactive outreach to students, faculty, and staff to build trust and transparency around the new model. Updating websites, hosting informational sessions, and providing accessible channels for reporting concerns are all effective strategies for engaging the campus community.
By thoughtfully considering these practical steps and maintaining a commitment to equity and compliance, colleges and universities can successfully transition to an integrated civil rights response model. Doing so positions institutions to better serve their campus communities, respond to evolving legal requirements, and foster a safe, inclusive environment for all.
[1] Title VI’s protected characteristics include combinations of race, color, and national origin, such as shared ancestry.
Amy Fabiano is a senior attorney with Hunton Andrews Kurth LLP in Boston.
Brigid Harrington is a senior attorney with the firm in Boston.
Gerard T. “Gerry” Leone, Jr. is Special Counsel with the firm in Boston.
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