Published by Fractional Coordinator, Inc. | Sexual Assault Awareness Month | April 2026

Every April, colleges and universities across the country hang teal ribbons, host candlelight vigils, and issue statements affirming their commitment to survivor support. Sexual Assault Awareness Month has become a fixture of the academic calendar, a moment of visibility for an issue that affects one in five women and one in sixteen men during their college years.

But behind the awareness campaigns, a quieter crisis is unfolding. Title IX coordinator positions, the roles legally required to receive, investigate, and respond to reports of sexual misconduct, are going unfilled. At small colleges, community colleges, and under-resourced universities, the coordinator's desk is sometimes empty for months at a time. And when a survivor walks through the door, there is no one there to meet them.

"Awareness without infrastructure is not enough. Survivors need someone to call. Not a vacancy notice."

A LEGAL REQUIREMENT, AN INSTITUTIONAL AFTERTHOUGHT

Title IX of the Education Amendments of 1972 prohibits sex discrimination, including sexual assault and harassment, in any educational program receiving federal funding. For decades, compliance was loosely defined. That changed in 2020, when the Department of Education, under Secretary Betsy DeVos, issued binding regulations requiring institutions to designate a Title IX coordinator, publish their contact information, and follow defined grievance procedures, including mandatory live hearings and cross-examination at the post-secondary level.

The Biden administration sought to overhaul those rules in 2024, proposing regulations that expanded survivor protections, broadened the definition of sex discrimination, and lowered procedural barriers to reporting. Many institutions began the work of updating their policies accordingly.

That work was upended on January 9, 2025, when a federal district court in Kentucky vacated the Biden-era regulations in their entirety, finding that the Department of Education had exceeded its statutory authority. Three weeks later, on January 31, 2025, the Trump administration confirmed what many had anticipated: institutions must immediately revert to the 2020 regulations, including for all open investigations, regardless of which framework was in place when the alleged conduct occurred.

The practical consequences are significant. Under the reinstated 2020 rules, institutions must separate the roles of investigator and decision-maker, conduct live hearings for all formal complaints, and permit cross-examination of parties and witnesses. Sexual harassment must meet a higher threshold, defined as conduct that is severe, pervasive, and objectively offensive, rather than the broader standard the Biden rule had proposed. And Title IX's jurisdiction is again limited to conduct occurring within an institution's education programs and activities.

For institutions that had moved toward the Biden framework, the reversion is not simply a policy update. It is a structural overhaul, requiring revised grievance procedures, updated training, and a coordinator who understands the procedural demands of the 2020 rules well enough to implement them correctly and immediately.

What the regulations do not require, in any version, is that the coordinator be experienced, well-resourced, or reliably present. At many institutions, the Title IX role is assigned to an existing staff member who already carries a full portfolio: a dean of students, an HR director, a general counsel. The result is a function that is technically fulfilled but practically hollow.

THE STAFFING GAP IS GETTING WORSE

Higher education is in the midst of a staffing contraction. Budget pressures, declining enrollment in some sectors, and administrative restructuring have led institutions to eliminate or consolidate positions across student affairs and compliance. Title IX coordinators are not immune.

The demand for qualified Title IX professionals has surged even as institutional budgets for the role have stagnated. A 2021 workforce study by the Education Commission of the States found that Title IX coordination responsibilities were distributed unevenly across institutions, with smaller colleges far less likely to have a dedicated coordinator than their larger counterparts, and far more likely to assign the function to an administrator with competing responsibilities.

At community colleges, which enroll roughly 40 percent of all undergraduate students in the United States, the resource gap is most acute. These institutions serve some of the most vulnerable student populations: first-generation students, adult learners, students experiencing housing insecurity. They are also, systematically, the least likely to have robust Title IX infrastructure.

"Community colleges enroll 40% of all undergraduates, and are among the least likely to have a dedicated Title IX coordinator on staff."

WHAT THE GAP COSTS SURVIVORS

When a survivor reports sexual misconduct to their institution, the law entitles them to a prompt, equitable, and supportive response. They are entitled to information about their rights, referrals to campus and community resources, interim supportive measures, and a fair grievance process.

What they often encounter instead is a delayed response, an undertrained responder, or a referral to someone who does not have the bandwidth or expertise to help. The consequences are not abstract.

Research consistently shows that institutional responses, or their absence, shape whether survivors continue their education. A 2022 study published in the Journal of Interpersonal Violence found that survivors who perceived their institution's response as inadequate were significantly more likely to withdraw from coursework, change their major, or leave school entirely.

The institutional gap is now compounded by a federal one. Secretary of Education Linda McMahon, sworn in on March 3, 2025, has presided over a dramatic contraction of the Office for Civil Rights, the federal body responsible for investigating Title IX complaints. Under her leadership, OCR laid off roughly half its staff and shuttered seven of its twelve regional offices. The results have been documented in stark terms: OCR resolved zero complaints of sexual harassment or violence in all of 2025, and opened fewer than ten sexual violence investigations between March and September of that year. During the same period, ninety percent of all civil rights complaints received by OCR were dismissed.

In February 2026, a coalition of 112 survivor advocacy organizations sent a joint letter to Secretary McMahon and Assistant Secretary for Civil Rights Kimberly Richey demanding action. The letter noted that OCR had effectively ceased to function as a resource for student survivors while directing what remained of its limited capacity toward investigations targeting transgender students.

The implication for institutions is direct: federal enforcement is not a backstop. For survivors who report today, the institution is the response. If the institution does not have a qualified coordinator in place, there is no meaningful recourse available.

"When OCR resolves zero sexual misconduct complaints in a year, the institution is not the last line of defense. It is the only one."

A NEW MODEL FOR INSTITUTIONS THAT CANNOT AFFORD TO WAIT

The traditional model of Title IX compliance assumes something that is increasingly untrue for many institutions: that they can afford a full-time, experienced coordinator on staff at all times. Hiring cycles for qualified candidates can take six months or more. Vacancies during investigations or peak reporting periods create legal exposure and real harm.

The current regulatory moment makes this more urgent, not less. Institutions operating under the reinstated 2020 rules must manage quasi-judicial grievance processes that require specialized knowledge: how to properly separate investigative and adjudicative functions, how to conduct or oversee live hearings, how to advise on cross-examination procedures, and how to document findings in written determinations that can withstand scrutiny. These are not tasks that can be absorbed into an already full workload.

Fractional coordination, the model of engaging an experienced Title IX professional on a part-time, interim, or project-specific basis, offers institutions a way to maintain meaningful compliance without the cost structure of a full-time hire.

This is not a workaround. It is a recognition that expertise should not be a luxury available only to well-resourced institutions. A small liberal arts college in rural Vermont and a flagship state university should both be able to provide survivors with a response that is legally sound, trauma-informed, and humane.

"Title IX expertise should not be a luxury. Every survivor, at every campus, deserves a qualified, present, and prepared coordinator."

WHAT EFFECTIVE TITLE IX SUPPORT ACTUALLY LOOKS LIKE

Effective Title IX coordination is not simply a matter of processing paperwork. It requires a coordinator who understands the nuances of federal regulations, can conduct fair and thorough investigations, is trained in trauma-informed practice, can navigate the intersection of Title IX with Title VI, Section 504, and the ADA, and can serve as a resource to faculty, staff, and students across the institution.

It also requires availability. Disclosures do not happen on a schedule. Survivors who reach out and are met with a busy signal, literal or figurative, often do not reach out again. The window of institutional response is narrow and consequential.

Fractional coordinators bring this expertise to institutions precisely when and where it is needed: during vacancies, during high-volume periods, during investigations that exceed internal capacity, or as an ongoing part-time engagement for institutions that do not have the budget for a full-time role.

THE AWARENESS WE STILL OWE SURVIVORS

Sexual Assault Awareness Month asks us to see survivors. To believe them. To act. For higher education institutions, that obligation extends beyond the month of April. It requires building and sustaining the infrastructure that makes a meaningful response possible, not just possible, but ready.

The regulatory environment will continue to shift. It always does. What cannot shift is the institution's obligation to have someone in place who is qualified to respond when a student comes forward. Hanging a teal ribbon is easy. Ensuring that there is a trained, present, and prepared Title IX coordinator available to every student who needs one, that is the work. And for many institutions, it is work that cannot wait until the next hiring cycle.

IS YOUR INSTITUTION READY?

If your institution has a Title IX vacancy, is navigating a complex investigation, or needs to ensure your grievance procedures are aligned with the reinstated 2020 regulations, Fractional Coordinator is ready to help.

We offer experienced, credentialed Title IX coordination on a fractional, interim, or project basis, so your campus is never without the expertise your students deserve.

Visit fractionalcoordinator.com to schedule a consultation.

REFERENCES

1. Cantor, D., Fisher, B., Chibnall, S., et al. (2019). Report on the AAU Campus Climate Survey on Sexual Assault and Misconduct. Association of American Universities.

2. U.S. Department of Education, Office for Civil Rights. (2020). Nondiscrimination on the Basis of Sex in Education Programs or Activities Receiving Federal Financial Assistance. 85 Fed. Reg. 30026.

3. U.S. Department of Education. (2025, January 31). Dear Colleague Letter: Enforcement of Title IX of the Education Amendments of 1972. Office for Civil Rights.

4. Education Commission of the States. (2021). Title IX Coordinators: Roles, Responsibilities, and Institutional Support in Higher Education. ECS Policy Brief.

5. Patterson, D., & Campbell, R. (2022). Institutional Betrayal and Its Relationship to Student Educational Outcomes Following Sexual Assault. Journal of Interpersonal Violence, 37(1-2), NP1-NP24.

6. National Women's Law Center. (2026, February 23). NWLC and Student Advocacy Groups Demand Department of Education Action on Student Sexual Violence Complaints Under Title IX. nwlc.org. See also: K-12 Dive. (2026, February 10). Trump's OCR Resolved No K-12 Sexual Harassment, Assault Complaints in 2025.

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If you or someone you know needs support: RAINN National Sexual Assault Hotline 1-800-656-HOPE (4673)