Published on: September 21, 2026
An ATIXA Tip of the Week by Kimberly Pacelli, J.D., M.Ed., and Lauren Starnes, J.D.
Charter schools and charter management organizations often operate with lean administrative teams, overlapping roles, and governance structures that differ from other public K-12 settings. Administrators may oversee multiple campuses while sharing HR, compliance, and student services responsibilities, creating unique Title IX compliance challenges and making role clarity critical.
Effective Title IX compliance in charter schools depends on clearly defined roles, the ability to distinguish Title IX matters from general discipline, and strong coordination across leadership, HR, and student services.
ATIXA recently hosted a Time with IX event on this topic. Below are key takeaways and practical strategies from that conversation. Watch the recording.
Start with the Right Process
Many charter schools do not have a dedicated Title IX Coordinator, though they should! Remember that federal regulations require that all recipients of federal financial aid have a designated and well-publicized Title IX Coordinator.
In some cases, K-12 charter schools are embedded within higher education institutions, meaning a university’s Title IX Coordinator may also serve as Title IX Coordinator for an affiliated K-12 charter school. In other cases, coordinators often hold additional responsibilities in HR, student services, or school operations. How these responsibilities are structured, including where the coordinator sits within the organization and who they report to, can impact both Title IX administration and the coordinator’s autonomy.
These overlapping responsibilities make it especially important to identify which process should lead the response. When a report of sex-based behavior is made, first assess whether Title IX applies. If Title IX does not apply, then the Title IX Coordinator may refer the report to student conduct or employee discipline procedures. Removal from the Title IX process does not mean the matter is dropped—it should be referred to the process best suited to address the report, and supportive measures should always be offered.
Compliance Is More Than Following Procedures
When schools receive notice of potential sex discrimination or sexual harassment, every response should be measured against three core obligations: stop the conduct, prevent its recurrence, and remedy its effects. These principles should guide decisions from initial intake through supportive measures, investigation, resolution, and follow-up.
Practitioners should ask whether their response is reasonably designed to prevent future harm and restore equal educational access. This framework helps schools to calibrate their responses appropriately, avoiding both under-response and unnecessary procedural risk.
Title IX Covers Employees, Too
Title IX protects employees from sex discrimination, not just students. Employee reports and complaints may also trigger Title IX obligations, requiring close coordination between HR and the Title IX Coordinator. Clear communication, defined roles, and consistent procedures can help to ensure that employee matters receive the same careful analysis as student complaints.
Separate Responsibilities to Strengthen the Process
Even though the current federal Title IX regulations took effect six years ago, many public charter schools are still working to build or tune up their staffing and allocation of roles and responsibilities.
Clearly defined roles support prompt, fair, and consistent responses. The Title IX Coordinator oversees compliance, receives reports and complaints, coordinates supportive measures, and manages the overall process. Investigators gather facts. Decision-makers determine whether policy violations occurred. These functions serve different purposes and should remain independent when staffing allows. One key guideline: the Title IX Coordinator may serve as the investigator but cannot serve as the Decision-maker or Appeal Officer.
For charter schools and charter management organizations, maintaining this separation strengthens the integrity of the process by helping to ensure decisions are based on a complete, impartial review of the evidence. When internal staffing cannot support appropriate role separation, partnering with trained external investigators or decision-makers may be the best option.
Strong Systems Reduce Risk
Effective Title IX programs begin with clearly defined roles, consistent decision-making, and careful evaluation of how Title IX and other institutional processes operate together. When administrators understand who is responsible for each step, maintain appropriate separation of functions, and stay focused on stopping, preventing, and remedying discrimination, they build systems that are both legally defensible and responsive to their school communities.
ATIXA provides model policies, certification courses, custom training, and consulting services to support K-12 Title IX compliance. ATIXA’s K-12 Community Membership is a free membership tier built exclusively for K-12 professionals.
Interested in outsourcing your Title IX administration, investigation, or decision-making to the most highly qualified team in the industry? Contact inquiry@tngconsulting.com.