The Office for Civil Rights Signals that the 2020 Title IX Regulations are in Effect
January 16, 2025A recent publication from the U.S. Department of Education’s Office for Civil Rights (“OCR”) has signaled that, in the wake of a federal district court vacating the 2024 Final Rule, the 2020 Title IX regulations are in effect moving forward. On January 14, 2025, OCR published a guidance document related to the 2020 Title IX regulations. While the guidance is focused on online or digital sexual harassment, it suggests OCR’s view that institutions should now be reverting to the 2020 regulations for all Title IX matters. Indeed, endnote 2 of the document states, “On January 9, 2025, a federal district court issued a decision vacating the 2024 Final Rule. Consistent with the court’s order, the 2024 Title IX regulations are not effective in any jurisdiction.”
Accordingly, institutions should ensure that their policies and procedures are compliant with the 2020 Title IX regulations moving forward. Cullen and Dykman LLP’s Higher Education team will continue to monitor for important developments impacting Title IX compliance and will provide updates as necessary.
Cullen and Dykman LLP is here to assist you in adapting your policies and procedures to comply with the 2020 Final Rule and interpreting any additional guidance issued by the U.S. Department of Education.
Should you have any questions about the impact of the 2020 Final Rule on your institution’s Title IX policies and practices, please contact Jennifer McLaughlin (jmclaughlin@cullenllp.com), Dina Vespia (dvespia@cullenllp.com), Nicole Donatich (ndonatich@cullenllp.com), or Sarah Franzetti (sfranzetti@cullenllp.com).