When the Superintendent is the Title IX Coordinator: Why It’s Worth a Second Look
In many districts, especially smaller ones, it’s not uncommon for administrators to wear multiple hats - whether because of lean staffing, budget restraints, or the “all hands on deck” reality of running a school district. But when it comes to Title IX and ensuring an impartial response to allegations of staff misconduct, combining roles can create its own set of conflicts and challenges.
Superintendents have a huge job. They are often responsible for managing the budget, overseeing curriculum and supporting instructional quality, managing staff, community and board relations, ensuring legal compliance and mitigating risk, and more. The Title IX Coordinator, on the other hand, is a role defined by the regulations and is responsible for training, Title IX compliance, and ensuring a prompt and fair response to reports of sexual harassment or discrimination, among other things.
Both roles are essential, but blending them can blur important lines of oversight and accountability.
Using the Chicagoland area as an example.
Based on our research, 30% of superintendents and similar titles (e.g., Executive Director, Head of School) in Cook County, Illinois are also the designated Title IX Coordinator.
Why Separation Matters
Maintaining Objectivity
The Title IX process relies on impartiality. When the same person who leads the district is also managing investigations or compliance reviews, it can create real or perceived conflicts of interest. Even when handled with care, others may worry that decisions are influenced by reputation, liability, or internal politics. Worse yet, the person investigating or overseeing allegations may be worried about (or even covering up) their own actions or those of individuals whom they directly supervise.
Encouraging Reporting
Students, staff, and families need to feel comfortable coming forward. Reporting to someone who wields significant power over employment decisions, school evaluations, budgets, litigation, and school culture can discourage transparency and stoke fears of retaliation, even unintentionally. A designated coordinator independent from those functions helps foster trust in the process.
Ensuring Oversight and Balance
Effective compliance depends on checks and balances. If one person is responsible for both implementing and monitoring Title IX, opportunities for oversight are limited. An independent coordinator helps verify that procedures are followed, timelines are met, investigations are thorough and findings are well-supported, and corrective actions are appropriate and documented.
Managing Workload and Complexity
At a minimum, Title IX compliance involves detailed recordkeeping, coordinating training for staff and students, and prompt response to urgent situations. Beyond that, effective compliance includes ongoing assessment and improvement to school culture and climate, data tracking to bolster prevention efforts, and a commitment to following (and improving) policies and procedures. Superintendents already carry heavy operational responsibilities, and it’s not always practical to expect one individual to also manage the Title IX Coordinator role.
Possible Implications
⚠️Student Safety at Risk
Having an impartial Title IX Coordinator ensures every report is handled with the same rigor, no matter who the respondent is or how much liability may be feared. If bias or conflicts skew the process, complaints get ignored or mishandled, leaving students at risk. Moreover, having a Title IX Coordinator with time and expertise to drive cultural changes and proactive prevention can identify and stop misconduct before it escalates.
📜 Federal Noncompliance
The Office for Civil Rights requires Title IX Coordinators to be impartial, free of conflicts, and well trained. Assigning the superintendent to this role invites bias, divided loyalties, and gaps in expertise, which can subject the district to avoidable OCR scrutiny.
🔎 Compromised Investigations
When someone with institutional authority or personal relationships with those involved oversees Title IX investigations, the process can appear biased or incomplete, even if handled with integrity. At worst, investigation outcomes can actually be changed by these influences. Either option erodes trust within the school community, risks student safety, and can discourage future reporting. It may also give the impression that leadership prioritizes control over compliance, which undermines confidence in the system and student safety.
🏛️ Civil Liability
In legal proceedings under Title IX, complainants must allege that the district acted with deliberate indifference. This can include failing to take concerns seriously, botching an investigation, or failing to implement institutional safeguards through training and appropriate policies. Whether or not supported by the evidence, a superintendent’s dual role can be seen as contributing to the problems.
Best Practice Alternative
Assign a dedicated, trained Title IX Coordinator who operates independently from the superintendent’s chain of command. If they need help, appoint deputies or engage outside help to make sure this role is well-supported and executed.
Establish clear reporting lines so the Coordinator reports directly to the school board and not a single district leader, helping maintain neutrality and objectivity.
Consider outsourcing investigations and compliance reviews to ensure independence, transparency, and community trust.
At Campus Integrity Group, we understand the unique challenges schools face when balancing leadership responsibilities with Title IX compliance. We provide customized training to help districts establish clear roles, ensure federal compliance, and build confidence in their processes. Whether your district needs full Title IX support or simply a second set of eyes, Campus Integrity Group is here to help.
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