Frameworks

The frameworks we work in

Five federal frameworks govern nearly everything a civil rights office touches. Knowing which one governs a matter, and when more than one does, is the first decision in the file and the one most often made by accident.

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The first decision in the file

Which framework governs?

The five

One overview for each

Each has its own overview covering scope, obligations, and where institutions usually go wrong.

Title IXSex discrimination and sex-based harassment in education programs receiving federal funds.20 U.S.C. § 1681 · 34 CFR Part 106
Title VIDiscrimination on the basis of race, color, or national origin, including shared ancestry.42 U.S.C. § 2000d · 34 CFR Part 100
Title VIIEmployment discrimination, harassment, and retaliation by covered employers.42 U.S.C. § 2000e · 29 CFR Part 1604
ADA and Section 504Disability access, accommodations, grievance process, and digital accessibility.42 U.S.C. § 12101 · 29 U.S.C. § 794
Clery ActCampus crime reporting, timely warnings, and the annual security report.20 U.S.C. § 1092(f) · 34 CFR § 668.46

Side by side

Who enforces it, and how a matter arrives

Who enforces it, who it reaches, and how a matter typically arrives.

Framework	Enforced by	Reaches	How a matter arrives
Title IX	OCR intake, Justice Department investigation	Recipients of federal financial assistance	OCR complaint, generally within 180 days
Title VI	OCR intake, Justice Department investigation	Recipients of federal financial assistance	OCR complaint, generally within 180 days
Title VII	Equal Employment Opportunity Commission	Employers with 15 or more employees	EEOC charge, commonly 180 or 300 days
ADA and Section 504	OCR and the Department of Justice	Fund recipients, public entities, public accommodations	OCR or DOJ complaint, or private suit
Clery Act	Department of Education	Postsecondary institutions in federal student aid	Department review, not an individual complaint

Filing windows are stated as they commonly apply and are subject to waiver, tolling, and state variation. Confirm the operative deadline with counsel rather than from a table.

When more than one governs

The intersections are where files fail

These are the four we see most. Each pairs two frameworks that run on different clocks, different agencies, or different counting rules.

Title VII and Title IX

An employee who is also a student

A graduate assistant harassed by a supervisor can raise Title VII as an employee and Title IX as part of the education program. The two run on different clocks and different agencies, so deciding which governs, or that both do, is the first entry in the file rather than a question for later.

Title VI and Title IX

Harassment based on race and on sex

Conduct rarely arrives sorted by protected class. A single course of conduct can be Title VI and Title IX at once, and analyzing only the more familiar one is the most common way an institution ends up with an incomplete record.

Section 504 and Title IX

Disability and the grievance process

A complainant or respondent with a disability may need accommodations to participate in a Title IX process. That is a Section 504 obligation running alongside the Title IX one, and it does not pause because a matter is open.

Clery Act and Title IX

Clery and Title IX together

The VAWA provisions in Clery require statistics and procedures for sexual assault, dating and domestic violence, and stalking. The same incident is a Title IX matter and a Clery statistic, counted under different rules, which is where classification errors originate.

How we work inside them

Across frameworks, not one at a time

The obligations arrive together, so the work does too.

Service
Investigations
Neutral investigations under any of the five, including matters already in progress and multi-framework files.
Learn more
Service
Fractional leadership
Serving as your coordinator across frameworks rather than one at a time, which is how the obligations actually arrive.
Learn more
Method
The Playbooks
Four volumes setting out the method for Title IX, Title VI, ADA and Section 504, and Title VII.
See the series

Scoping

Not sure which framework governs?

Bring the matter to a scoping call. We sort out which frameworks apply, and where they meet, before anything else is decided.

Book a scoping call How we help

The frameworks we work in

One overview for each

Who enforces it, and how a matter arrives

The intersections are where files fail

An employee who is also a student

Harassment based on race and on sex

Disability and the grievance process

Clery and Title IX together

Across frameworks, not one at a time

Investigations

Fractional leadership

The Playbooks

Not sure which framework governs?

Work with us

Work here