Some Illinois school district clients have received emails from professional organizations recently about purported required Title IX training that must be completed by August 14, 2021. Are we experiencing deja vu? Or is there some new requirement that you don’t know about?

The Title IX regulations issued in May 2020 became effective on August 14, 2020. The regulations for the first time required that schools, colleges, and universities provide specific training, including on specific topics, to team members before they work on Title IX sexual harassment matters. The rules did not provide a deadline for the training or other details like how long the training must be or how frequently it should be provided. Because the law’s effective date was the first time a school could first receive a Title IX sexual harassment under the new rules, most took that date (August 14, 2020) as the initial compliance deadline for training.

The regulations recognize that the initial training would not be the end of Title IX team members’ training. Among other things, the comments to the final rule refer to an ongoing estimate of $26,067,620 in 2021 and each subsequent year for training of Title IX team members across the country. There is notably no required deadline for any subsequent training.

What should schools, colleges, and universities do to comply with these somewhat vague training requirements? First, it is essential to adequately train Title IX team members now on the initial regulations if you have not done so already. Second, always carefully scrutinize training options provided, specifically by online course providers, to ensure they have a firm understanding of necessary training requirements.

Those institutions that have completed the Franczek Comprehensive Title IX Training package (including the Basic Training and subsequent role trainings) should not need to complete any other general trainings at this time.