The U.S. Department of Education's Office for Civil Rights (OCR) has reached an agreement with the Palo Alto Unified School District in Palo Alto, California after finding that the district's handling of complaints violated Title IX of the Education Amendments of 1972. Title IX prohibits discrimination on the basis of sex in education programs and activities receiving federal financial assistance.

During OCR's June 2013 proactive investigation of the district's handling of Title IX complaints, OCR received a complaint in March 2014 alleging that the district failed to respond promptly and equitably to reports that students were subjected to sexual harassment. OCR's investigation included reviewing the policies and procedures utilized by the district, reviewing investigative and discipline files provided by the district, conducting on-site visits, and interviewing district staff.

Under the terms of the resolution agreement, the district has agreed to take actions, including the following:

• Conduct an investigation to address the deficiencies that OCR identified with respect to the district's response to reports and complaints of violations of Title IX.
• Review the behavioral incident reports of alleged violations of Title IX at the district's high schools for school years 2012-13 through 2015-16 to determine whether the district responded promptly and equitably to each incident.
• Revise the district's Title IX policies and procedures to ensure that they provide for prompt and equitable response to reports and complaints of Title IX violations.
• Develop and implement a confidential online system where students and parents/guardians can make anonymous reports of Title IX.
• Develop a district-wide confidential tracking system that collects data concerning reports and complaints concerning Title IX violations, including the steps taken to address and resolve them.
• Provide an annual report from the Title IX coordinator to the superintendent and Board of Education summarizing the reports and Title IX complaints that are filed with district.
• Provide mandatory annual training for employees regarding the district's revised policies and procedures, including their obligation to respond to Title IX reports and complaints promptly and effectively.

A copy of the March 8 letter of findings can be found here, and the agreement is posted here.