Reviewing Post-Secondary Title VI and Title IX OCR Resolutions
First Quarter of 2026
Author: Andrea Stagg, Director of Consulting Services
We are one quarter into 2026 and, so far, we’ve seen OCR publish thirty-six resolutions with post-secondary institutions.
Thirty-one agreements resolved investigations related to Title VI and institutional partnerships with and support of the PhD Project. The remaining agreements include two resolving Title IX complaints and four resolving disability-related cases. The Title VI and Title IX agreements are summarized below, and we’ll post a separate article about the disability discrimination resolutions.
Title VI Agreements
The PhD Project is a nonprofit that aims to expand diversity in the PhD pipeline; because participation is limited on the basis of race, the Department of Education determined that institutions that participated in The PhD Project were violating Title VI. The resolution agreements are nearly identical; each requires the institution to “conduct a review of all memberships or partnerships with external organizations to identify any memberships or partnerships with organizations that restrict participation based on race.” The institution must submit the results of the review to OCR, including the nature or purpose of the membership or partnership, and whether the institution plans to continue that relationship. Ultimately, the institution will formally cancel memberships or partnerships and provide proof of such cancellation to OCR.
Title IX Agreements
OCR resolved Title IX complaints against East Central University in Oklahoma and Meridian Community College in Mississippi in February and March 2026. These complaints identified specific scholarships and alleged that the scholarships’ criteria discriminated against students on the basis of sex in a way that violates Title IX.
The agreements between schools and the OCR provide action items for the identified scholarships, with distinctions between institution-administered funds and funds managed by outside organizations. For institution-administered funds, the agreement says that the schools have three options. First, each can continue to offer sex-restricted scholarships so long as it implements procedures to “ensure the nondiscriminatory awarding of assistance.” This means that students must be selected for the award based on nondiscriminatory criteria, and those selected must be provided the funding regardless of whether they meet the sex-based criteria of the scholarship. Alternatively, the University can remove the sex preference or requirement, or cease offering that particular scholarship.
For the fund at ECU administered by an outside organization, the University will verify that the scholarship does not discriminate on the basis of sex or will “cease its promotion or publication of the scholarship.”
As always, these resolution agreements are only binding for the individual institutions who signed them. But there are takeaways for those of us following at home. If you have not done so yet, consider engaging in a review of current partnerships and scholarships to ensure that they do not discriminate on the basis of any protected categories. Work with legal counsel and risk management professionals to address any memberships, partnerships, or scholarships that pose risk to the institution.
All of these published resolution agreements and letters can be found on OCR’s Recent Resolution Search website.
Our Consulting Team is here if you need a Program Review or Policy & Procedures Review.
This article was edited at 11:30am PT, March 26.
