Published by Fractional Coordinator, Inc. | November 2025

Background

In 2025, two highly visible Title IX cases—one involving Loudoun County Public Schools (LCPS) and another concerning Concordia University Irvine—brought national attention to the consequences of procedural missteps under Title IX.

In Loudoun County, a lawsuit alleged that district leaders ignored witness statements, mishandled documentation, and deleted key evidence in a sexual harassment investigation. Meanwhile, in California, a federal court ordered Concordia University to reinstate its women’s swim and tennis programs after finding probable discrimination in the elimination of women’s athletics.

Together, these cases illustrate a growing trend: institutions are no longer judged solely by the content of their policies, but by the integrity and consistency of their processes.

Fractional Coordinator, Inc. analyzed these incidents to identify actionable lessons for universities and districts seeking to strengthen compliance operations, maintain equity, and prevent systemic risk.

The Challenge

Across education systems, administrators are grappling with fragmented compliance structures and inconsistent enforcement. Many institutions maintain outdated Title IX and ADA/504 frameworks, rely on manual case management, or face turnover among coordinators and investigators.

This environment creates significant exposure when processes fail—whether through missing documentation, incomplete investigations, or inequitable outcomes.

The Loudoun and Concordia cases reveal two critical vulnerabilities:

1. Procedural Breakdown — Investigations that lack documentation, evidence preservation, or transparent communication.

2. Equity Oversight Gaps — Decisions (such as program eliminations or selective enforcement) that inadvertently perpetuate gender-based disparities.

When these weaknesses converge, they erode trust among students, employees, and regulators—and can trigger litigation, OCR review, or public scrutiny.

Our Approach

Fractional Coordinator developed a Title IX Process Integrity Framework to help institutions address these exact challenges. Drawing on the lessons from these cases, our model strengthens both substantive equity and procedural compliance.

Key elements of our approach include:

• Comprehensive Policy Audit

  Reviewing Title IX, ADA/504, and related policies for clarity, consistency, and procedural fairness.

• Case Management System Design

  Establishing structured documentation and tracking systems that preserve evidence, ensure transparency, and prevent information loss during staff transitions.

• Investigation Process Mapping

  Aligning intake, triage, and resolution pathways with current federal guidance while maintaining trauma-informed and culturally responsive practices.

• Equity Impact Analysis

  Reviewing institutional decisions—such as program closures or resource allocations—for unintended gender or accessibility disparities.

• Training and Role Definition

  Equipping coordinators, investigators, and decision-makers with the tools to apply policies consistently and communicate outcomes with clarity and neutrality.

By embedding these practices within institutional infrastructure, schools can ensure that compliance is not reactive—but systemic and defensible.

Outcomes

Institutions implementing the Title IX Process Integrity Framework have achieved measurable improvements, including:

• Increased Policy Consistency

  Consolidation of multiple policies into unified, accessible frameworks that reduce ambiguity and strengthen procedural fairness.

• Improved Documentation & Audit Readiness

  Digital case systems with secure evidence tracking and audit logs, ensuring all decisions can withstand external review.

• Reduced Resolution Timeframes

  Streamlined workflows that decrease average case processing times while maintaining quality and neutrality.

• Strengthened Stakeholder Confidence

  Improved trust from students, employees, and oversight agencies through transparent, equitable, and compliant processes.

By emphasizing accountability over optics, institutions build cultures of fairness that sustain compliance beyond any one leader or regulation.

Key Takeaway

The Loudoun and Concordia cases serve as a warning: policies without process are liability disguised as compliance.

Fractional Coordinator’s approach helps institutions close the gap between policy language and operational reality—creating systems that are not only compliant but credible.

Our consultants partner with schools and districts to implement defensible, equity-centered frameworks that protect both people and purpose.

Visit the case here: StandWithUs for Legal Justice vs. Massachusetts Institute of Technology

Partnering with Fractional Coordinator

Fractional Coordinator, Inc. provides on-demand equity, compliance, and investigative services to educational institutions nationwide. From interim coordination to full Title IX system audits, our team helps organizations navigate complexity with clarity, fairness, and accountability.

To learn more about implementing the Title IX Process Integrity Framework or to schedule a consultation, visit www.fractionalcoordinator.com or contact support@fractionalcoordinator.com.