Published on: June 24, 2026
An ATIXA Tip of the Week by Kayleigh Baker, J.D.
A bipartisan bill introduced in Congress could significantly reshape how federally funded schools, colleges, and universities approach Title VI compliance, particularly with respect to antisemitism-based discrimination and other discrimination on the basis of race, color, and national origin. The Jewish American Security Act (JASA), introduced in the Senate (S.4576) by Senators Jacky Rosen (D-NV) and James Lankford (R-OK) and in the House as a companion bill (H.R. 9211) by Representatives Dan Goldman (NY-10) and Mike Lawler (NY-17), would strengthen federal efforts to combat antisemitism across educational settings, Jewish communal institutions, and online platforms.
The Senate bill was introduced in May 2026 and referred to the Committee on Homeland Security and Governmental Affairs. A bipartisan House companion bill was introduced in June 2026 and referred to several committees.
Although the bill is framed, largely, as a response to instances of antisemitic-based discrimination, its compliance structure should be read more broadly by Title VI practitioners. The bill reflects a continued federal interest in developing a more formalized Title VI compliance infrastructure, one that increasingly resembles aspects of Title IX administration.
What JASA Would Require from ED
If enacted, JASA would direct the Department of Education (ED), through the Office for Civil Rights (OCR), to provide annual training to recipients of federal financial assistance. ED would also need to create public awareness campaigns for students about Title VI rights and recipient responsibilities.
The bill would require ED to issue annual written reminders to recipients about their Title VI obligations, including examples of conduct that may create a hostile environment. Notably, the bill contemplates specifically including examples of curricula that could contribute to a hostile environment in K-12 settings.
JASA would also require ED to appoint an Antisemitism Coordinator within the Department. That role would oversee ED’s technical assistance, training, written guidance, complaint trends, directed investigations, and compliance reviews involving antisemitism under Title VI. The bill would further require ED to establish a Title VI Clearinghouse to publish best practices and recommendations on safety, security, dialogue, and mutual understanding in higher education and K-12 schools. It remains unclear whether these obligations would transfer to the Department of Justice (DOJ) under the recent Interagency Agreement (IAA) between DOJ and ED relating to the enforcement of civil rights laws, or whether Congress will amend aspects of the bill should it show signs of likely passage.
Additionally, OCR would likely need to put in place additional regulations to fully implement JASA and explain the obligations placed on recipients of federal funds. That process could take as much as eighteen months post-passage. We don’t know at this time whether the bill will take effect upon passage, whether there will be an enforcement deadline clarified in the bill, or whether the bill’s effect will toll until regulations are published, but no matter what, compliance is still in the distance. Regardless, we can start to prepare now for its eventual passage if we wish to be proactive.
What JASA Would Require from Recipients
For schools, districts, colleges, and universities, JASA would create several direct compliance obligations. Each recipient would need to designate at least one Title VI Coordinator to coordinate compliance with Title VI, its implementing regulations, and the new statutory requirements. If a recipient has more than one Title VI Coordinator, one would need ultimate oversight.
Recipients would also need to ensure that Title VI Coordinators and any designees receive training within 90 days of assuming the role, within 90 days of a significant change in responsibilities, and annually thereafter.
The bill would require recipients to adopt and implement a nondiscrimination policy based on race, color, and national origin. It would also require a published Title VI grievance procedure. That procedure would need to explain how anyone can report conduct that may constitute discrimination based on race, color, and national origin. It must also identify the Title VI Coordinator’s contact information, provide notice of the grievance procedures, describe available supportive measures, and establish a process for investigating and resolving reports.
The grievance procedure would need to lay out how to address allegations of discrimination by the institution itself, or by employees, students, or third parties, including reports where the respondent is unknown. If it is determined that discrimination occurred, the recipient would need to stop the conduct, prevent recurrence, and remedy discriminatory effects. Recipients would also need to provide notice of outcome to the reporting individual and any other affected person or entity, as appropriate.
What This Means Now
For now, JASA does not change existing legal obligations. It is proposed legislation, not law. Still, institutions should pay close attention. JASA is bipartisan, bicameral, and backed by many of the nation’s largest Jewish organizations, including the Anti-Defamation League (ADL), the Jewish Council for Public Affairs (JCPA), the Orthodox Union, and the Union for Reform Judaism. It also gives a clear preview of where federal Title VI compliance may be headed: designated coordinators, annual training, written policies, grievance procedures, supportive measures, outcome notices, website posting requirements, annual notices, and extensive recordkeeping obligations.
Even if JASA does not become law, ED (or DOJ) could still issue a Notice of Proposed Rulemaking (NPRM) and pursue Title VI regulatory changes through the rulemaking process. States may also move to fill perceived gaps if federal legislation stalls.
What This Signals
JASA may or may not become law, but either way, it is a meaningful signal. Title VI compliance is moving toward a more formalized structure, and institutions that wait for final legislation or regulations may find themselves behind.
Schools, districts, colleges, and universities should begin assessing whether their current Title VI infrastructure is built to withstand greater scrutiny. At a minimum, recipients should review who owns Title VI compliance, whether policies and procedures are accessible and clear, how reports are documented and resolved, whether supportive measures are available, and whether employees with Title VI responsibilities are trained consistently.
The practical message is simple: regardless of whether JASA ultimately becomes law, Title VI compliance is becoming more operationalized. Institutions should prepare accordingly.
Monitor JASA’s status on the Congressional bill tracker, and review the text of the Senate and House bills.
Need expert Title VI compliance guidance? Contact inquiry@tngconsulting.com.