Resolution Agreement

Chicago Public School District #299

OCR Case Nos. 05-11-1034 and 05-89-1020

Chicago Public School District #299 (the District) agrees to fully implement this resolution 

agreement (Agreement) to resolve U.S. Department of Education, Office for Civil Rights (OCR), case 

number 05-11-1034 and case number 05-89-1020, and to ensure its compliance with Title IX of the 

Education Amendments of 1972 (Title IX), 20 U.S.C. § 1681, and its implementing regulation, 34 

C.F.R. Part 106, with respect to the issue of whether the selection of interscholastic sports at the 

District’s high schools (not including charter schools) effectively accommodates the interests and 

abilities of male and female students to the extent necessary to provide equal athletics opportunities. 

The District has voluntarily agreed to adhere to the terms of this Agreement.

GUIDING PRINCIPLES OF THE AGREEMENT

In determining whether the selection of high school interscholastic sports at the District effectively 

accommodates the interests and abilities of male and female students to the extent necessary to 

provide equal athletics opportunities, the District will demonstrate compliance at each District high

school.

Compliance at each high school will be measured by using the three-part test of compliance1

showing at each school that: 1) interscholastic participation opportunities are provided in numbers 

substantially proportionate to the respective enrollments of boys and girls; or 2) that the District can 

show a history and continuing practice of program expansion that is demonstrably responsive to the 

developing interests and abilities of the members of that sex; or 3) that the interests and abilities of 

the underrepresented sex are fully and effectively accommodated by the present program.

Once compliance at an individual high school with any part of the three-part test is demonstrated as 

determined by OCR, the District will be notified of this determination and will then not be required 

to submit information about the school under the terms of Sections I through V of this Agreement.

Following submission by the District of compliance data for an individual high school and pending 

notification of OCR's determination regarding compliance, the District will not be required to submit 

any further data regarding said school, unless requested by OCR; the terms of this Agreement will

end when the District demonstrates compliance at each District high school, which is anticipated to 

be no longer than four years after the date the District signs this agreement.

 1

On December 11, 1979, the Department issued its Intercollegiate Athletics Policy Interpretation, at 44 Fed. Reg. 71,413 et seq,

which further clarified OCR’s Title IX athletics requirements. The Policy Interpretation is generally applicable to interscholastic 

athletics and states that OCR will apply the following three-part test to assess whether an institution is providing nondiscriminatory 

athletic participation opportunities: 1) whether interscholastic participation opportunities are provided in numbers substantially 

proportionate to the respective enrollments of boys and girls; or 2) where one sex is underrepresented among athletes, whether the 

institution can show a history and continuing practice of program expansion that is demonstrably responsive to the developing

interests and abilities of the members of that sex; or 3) where one sex is underrepresented among interscholastic athletes and the 

institution cannot show a history and continuing practice of program expansion, whether the interests and abilities of the 

underrepresented sex are fully and effectively accommodated by the present program. Id. at 71418.
Page 2 – OCR Case Nos. 05-11-1034 and 05-89-1020

I. ADMINISTRATIVE REQUIREMENTS

A. The District has established a process for compiling and maintaining a database containing 

an accurate record of the interscholastic sports offered for boys and for girls at each District 

high school. The database will also include a listing of the different levels (varsity, junior

varsity, sophomore, and freshmen) at which each sport is offered for boys and for girls at 

each District high school and the number of boys and the number of girls participating in 

each level of each sport at each District high school. The process established by the District 

will include mechanisms for ensuring that the information contained in the database is 

current, complete and accurate. 

B. By September 15 annually until OCR has dismissed its monitoring of this Agreement, the 

District will provide to the Principals and Athletic Directors at each District high school 

written instructions describing the District’s obligations under the terms of this Agreement, 

and also outlining the District’s internal procedures and guidelines for ensuring that the 

District timely, completely and accurately documents its compliance with the terms of this 

Agreement, including by implementation of the process referenced in Item I.A of this 

Agreement. The District will annually provide to the Athletic Director at each District high 

school training on the relevant requirements of Title IX as they pertain to the provision of 

equal athletic opportunities to boys and girls.

C. The District has appointed an Athletics Equity Liaison (Liaison) to communicate, 

collaborate, and consult directly with OCR concerning the District’s implementation of this 

Agreement. The Liaison will be responsible for ensuring timely implementation of this 

Agreement as well as timely submission of documentation of the implementation to OCR. 

The duties of the Liaison will include ensuring that all District high schools and relevant 

administrators in the District’s Central Office procure and maintain current, complete and 

accurate information needed by the District to demonstrate its implementation of the 

Agreement. 

D. By no later than June 15 annually beginning in 2015 for any high school that has not 

demonstrated compliance as determined by OCR, the District’s Athletics Equity Liaison will 

provide to the Athletic Director and Principal at each District high school a written report 

detailing each high school’s current status with respect to each part of the “three-part test.” 

REPORTING REQUIREMENTS: I.A and I.B

The District has provided documentation to OCR that the process referenced in Item I.A of this 

Agreement has been established and provide a detailed description of the process with supporting 

documentation, including a sample of the database. The District will also provide by September 30 

annually copies of the instructions and applicable internal procedures and guidelines, along with 

proof of receipt of the required information by the Athletic Director for each high school, plus 

materials provided to the Athletic Directors and sign-in sheets for the trainings, as referenced in Item 

I.B.
Page 3 – OCR Case Nos. 05-11-1034 and 05-89-1020

The report will include interscholastic athletics participation rates by sport and gender for all 

sports and levels of competition at each high school for the prior school year. To assist with 

the Liaison’s preparation of the report each year, the Liaison will use information from 

recent District student surveys and any other surveys and assessments of the athletic 

interests of students, plus descriptions of any requests for the addition of new sports or 

levels of competition at the high school that were received during the prior school year, and 

any actions taken by the high school in response. 

E. To ensure accountability, the Liaison will annually notify the Athletic Director and Principal 

at each District high school that failure to comply with the terms of this Agreement as 

explained in the written document described in I.D above and/or any staff member’s failure 

to cooperate with the Liaison could be subject to discipline consistent with the District’s 

employee discipline policies and procedures. The District will ensure that the Liaison reports 

on a regular basis to the District’s Legal Department any school administrator who does not 

provide timely and full reports as required, fails to comply with the terms of this Agreement 

and/or fails to cooperate with the Liaison. The District’s Legal Department will then 

investigate the report and, if applicable, the District will take appropriate action consistent 

with the District’s employee discipline policies and procedures. 

REPORTING REQUIREMENTS: I.C, I.D, and I.E

The District has provided to OCR the Liaison’s name and contact information. By August 1, 2015, 

the District will provide OCR reports for schools it asserts are in compliance with part 1 of the threepart test, including detailed documentation supporting its assertion that the schools are in compliance 

with part 1. Between September 1 and October 30 annually during the pendency of this monitoring, 

the District will provide OCR with a copy of the report provided to each high school in accordance 

with Item I.D of this Agreement. From September 30, 2015 through October 30, 2015, the District 

will provide OCR with a description of the actions taken or planned by each high school not

previously found by OCR to be in compliance with part one, to achieve compliance with part one or 

three of the three-part test, along with the timeframe for such compliance. By September 30

annually, the District will provide OCR with its annual notification to the CPS Athletic Directors and 

CPS Principals and the employee discipline policies and procedures referenced in Item I.E of this 

Agreement. By June 30 annually, the District will provide information to OCR about all reports made

by the Liaison to the District's Legal Department regarding any District high school administrator 

pursuant to Item I.E of this Agreement, including outcomes of such reports. 
Page 4 – OCR Case Nos. 05-11-1034 and 05-89-1020

II. EFFECTIVE ACCOMMODATION OF INTERESTS AND ABILITIES

The District acknowledges that Title IX, its implementing regulation at 34 C.F.R. § 106.41(c)(1), 

and applicable OCR policies require the District to effectively accommodate the interests and 

abilities of members of both sexes. The District agrees to provide athletic participation 

opportunities that are either substantially proportionate to the enrollment in its high schools, by sex,

or to demonstrate that the interests and abilities of female students are fully and effectively 

accommodated by the District’s current athletics program. OCR acknowledges that in certain 

limited instances, an individual school may have a history and continuing practice of program 

expansion that is that is demonstrably responsive to the developing interests and abilities of the 

underrepresented sex and that the District may demonstrate this to OCR in those limited instances. 

III. DETERMINATION OF UNMET INTEREST AND ABILITY 

In order to determine whether there is unmet interest and ability among female students in the 

District’s high schools who are underrepresented in the District interscholastic athletics programs, 

the District will take the following actions:

F. By September 30, 2015, for high schools not determined by OCR to be in compliance with 

part one, the District will complete an objective assessment of athletic interests. The 

assessment will include results from the surveys of athletic interests and abilities that have 

been conducted by the District since the 2013-14 school year, and will be conducted 

annually, so long as the survey has been pre-approved as to content by OCR, and the 

methodology, implementation and response rates of each survey at each high school 

maximizes the possibility of obtaining accurate information and facilitating responses. From 

April 1, 2015 - September 30, 2015, the District will administer a survey of athletic interests 

and abilities to all current freshmen, sophomores and juniors, as well as incoming freshmen 

for the 2015-16 school year, who have not already responded to the most recent District 

surveys of athletic interests and abilities. The District will use the survey results, in part, to

determine the existence and/or scope of any unmet athletic interests of female students at 

each District high school. The assessment will also consider whether the interested students 

at these District high schools have the ability to sustain an Illinois High School Athletic 

Association (ISHA) sanctioned sports team, noting that they do not need the ability to 

sustain a successful or elite team, but only need to show that they have the potential to 

participate in team try-outs, practices and competitions and, with coaching, the potential to 

attain sufficient ability to participate at the particular level of competition (varsity, junior 

varsity, etc.) in which they have expressed interest. If the assessment indicates interest in a 

sport or team not sanctioned by the IHSA, then the assessment will also indicate whether the 

school has the ability to sustain interscholastic competition with other schools in the sport in 

the school’s normal competitive region and geographic area.

2 The assessment will be based 

 2

The District will refer to the Title IX implementing regulation, and to the Policy Interpretation and applicable OCR 

policy guidance that was issued in 1996 and 2010 for clarification regarding the meaning of “normal competitive region 

and geographic area.” Throughout this Agreement “normal competitive region” and “geographic area” refer to the 
Page 5 – OCR Case Nos. 05-11-1034 and 05-89-1020

on multiple indicators of interests and, if applicable, multiple indicators of abilities, and will 

include the following:

1. The results of the most recent survey of female students at these District high schools 

so long as it was pre-approved as to content by OCR and was implemented by the 

District to maximize the possibility of obtaining the greatest number of responses at 

each school, and accurate information and facilitating responses. 

2. A review of the results of other recent surveys of students, if any, or other 

information collected from students, if any, using a method that is designed to fully 

and accurately assess unmet athletic interests and, if applicable, abilities in 

interscholastic sports among female students in accordance with the principles 

outlined above in item III.F.1. 

3. Identification of sports, squads, and levels of sports for female students that are not 

currently offered at a District high school but are offered either by schools that 

compete within the league(s) in which the District competes or by schools that are 

within the District’s normal competitive region and geographic area.

4. During the 2014-2015 school year, the Athletic Director at each District high school 

will complete a survey that identifies:

a. any club sports3 in place at the high school, the names of the club sports 

and the number of female students who participated in the club sports; 

b. popular sports offered during physical education courses at the high 

school and in community sports leagues, clubs or other youth programs 

offered in the high school’s geographic area; 

c. if available where records exist, the number (or if unavailable, an 

estimation) of female students who were cut from each high school 

team, the reasons they were cut, whether any of the cut students had the 

ability to compete in that sport and whether the number of females cut 

from one level (e.g., varsity) was sufficient to sustain another level in 

that sport (e.g. junior varsity); and, 

d. to the extent available, any requests (whether oral, written, formal or 

informal) made to the school on behalf of female students to add a 

particular sport, squad, or level of sport, or to elevate an existing club or 

intramural sport to interscholastic sport status.

e. If available (or if unavailable, an estimation of) the girls' teams that have 

been eliminated in the past five school years.

 normal competitive region and geographic area of each individual high school. In evaluating whether there is a 

reasonable expectation of interscholastic athletic competition for a particular sport in a particular high school’s normal 

competitive region, consideration is given to available competitive opportunities in the geographic area in which the 

high school’s athletes primarily compete, including competitive opportunities offered by other schools against which the 

high school competes and competitive opportunities offered by other schools in the particular high school’s geographic 

area, including those offered by schools against which the particular high school does not now compete. See, 

http://www2.ed.gov/about/offices/list/ocr/docs/clarific.html; and 

http://www2.ed.gov/about/offices/list/ocr/letters/colleague-20100420.html 3

For purposes of this Agreement, the District defines a “club” sport as any competitive sport that is not currently 

recognized by the IHSA such as rugby, field hockey, ice hockey etc.
Page 6 – OCR Case Nos. 05-11-1034 and 05-89-1020

 

5. Any other information that demonstrates the athletic interests and, if applicable, 

abilities of female students in the District’s high schools. 

REPORTING REQUIREMENTS – SECTION III - THE ASSESSMENT

From September 30, 2015 through October 30, 2015, the District will provide OCR a detailed 

final report about the assessment conducted pursuant to Section III of this Agreement for each 

identified District high school that OCR has determined is not in compliance with part one, 

including, at a minimum, the following information:

a. A complete description of the methodology used to conduct the survey, including how 

the survey was distributed, the number of surveys distributed, the grade levels of 

students who received the surveys, any planned follow-up to the initial distribution of 

the survey, the names and contact information for the individual(s) who analyzed the 

responses to the surveys, and the protocol for retaining a copy of any notes or other 

documents compiled during the review of the surveys. 

b. A copy of the results of the survey referenced in Section III.A.1., above, including but 

not limited to the number of students, by sex, who indicated an interest in each sport.

c. An analysis of the results of any other recent surveys of students, if any, or other 

information collected from students using a method that is designed to fully and 

accurately assess unmet athletic interests and, if applicable, abilities in interscholastic 

sports among female students. 

d. A summary of sports, squads, and levels of sports for female students that are not 

currently offered at a District high school but are offered either by schools that compete 

within the Chicago High Schools Athletic Association, commonly referred to as the 

Chicago Public League, or in schools that are within the District's normal competitive 

region and geographic area.

e. For the 2014-15 school year, for these high schools, rates of participation by female 

students in interscholastic sports and club sports; 

f. If available, a summary of the number of female students who were cut from each high 

school team and level, and the reasons they were cut, if known.

g. A copy of any written requests and a summary of any non-written requests made by or 

on behalf of female students to add a particular sport, squad, or level of sport, or to 

elevate an existing club or intramural sport to interscholastic sport status. 

h. If available, a description of any teams that were eliminated at any of these District 

high school during the past five school years, regardless of gender, including the 

number of participants who were on the team in the year it was eliminated and the 

reason for the team’s elimination, if known. 

i. Any other information that was considered by the District as part of its assessment in 

determining whether it is fully and effectively accommodating the athletic interests and 

abilities of female students in District high schools. 
Page 7 – OCR Case Nos. 05-11-1034 and 05-89-1020

IV. ACTIONS TO INCREASE ATHLETIC OPPORTUNITIES4 

The District anticipates that for the 2014-15 school year it will demonstrate to OCR that as many as 

12 of its high schools are currently in compliance with part one. 

As to the high schools that are not determined by OCR to be in compliance with part one, if through 

the above-described assessment, the District identifies a sport or sports in which there is sufficient 

but unmet interest and, if applicable, ability of female students to participate at the interscholastic 

level at a particular high school, the District will undertake efforts to add athletics opportunities as 

described below at the high school(s) until such time as either (1) the high school is fully and 

effectively accommodating the expressed interests and abilities of female students (i.e., there 

remains no unmet interest and ability); or (2) the participation rate for female students in the high 

school’s interscholastic athletics program is substantially proportionate to their rate of enrollment at 

the high school. 

For purposes of this provision, “sufficient interest” is defined as the minimum number of athletes 

needed to support a team. For “sufficient ability,” it is sufficient that interested students have the 

potential to sustain an interscholastic team and students will not be required to demonstrate they 

have sufficient ability if students participating in existing sports or teams are not typically required 

to demonstrate through try-outs or some other process that they possess sufficient ability to 

participate in the specific sport or at the particular level of competition (varsity, junior varsity, etc.) 

in which they have expressed interest. The District may, if applicable, submit information to OCR 

demonstrating that it duly publicized the addition of teams or sports at a school and made try-outs 

available to students at a reasonably convenient time, but that despite its efforts, an insufficient 

number of students attended try-outs to support the establishment of an interscholastic team.

In providing additional athletic opportunities for female students to either accommodate their 

expressed interests and abilities or until their rate of participation is substantially proportionate to 

their rate of enrollment at each District high school, the District shall do the following:

A. Sports Currently Offered:

1. The District will determine, for sports that are currently offered as IHSA sanctioned or nonIHSA sanctioned interscholastic sports at the particular District high school, whether there is 

a sufficient number of female students with the interest and, if applicable, ability to support 

the creation of additional levels of competition (junior varsity, sophomore, etc.), and 

sufficient competition within the Chicago High Schools Athletic Association commonly 

referred to as the Chicago Public League, as well as the District’s normal competitive region

 4

The District will refer to the Title IX implementing regulation, the Policy Interpretation and applicable OCR policy 

guidance that was issued in 1996, 2008, and 2010 that specifically discusses the application of the three-part test for 

clarification of terms and compliance standards contained herein, as well as for determining which interscholastic 

athletic activities can be counted for the purpose of Title IX compliance

(http://www2.ed.gov/about/offices/list/ocr/docs/clarific.html;

http://www2.ed.gov/about/offices/list/ocr/letters/colleague-20080917.html;and

http://www2.ed.gov/about/offices/list/ocr/letters/colleague-20100420.html).
Page 8 – OCR Case Nos. 05-11-1034 and 05-89-1020

to support additional levels of competition in those sports. If so, the District will implement

a plan to add additional levels of competition or squads at the same or a lower level of 

competition at the high school at a minimum of 10 high schools for the 2015-2016 

competitive season in those IHSA sanctioned sports, consistent with the above 

determination. New levels or squads of currently existing sports will continue to be added at 

all high schools for the 2016-2017 competitive season and additions of levels or squads will 

continue until such time as the high school has demonstrated to OCR compliance with the 

three part test, but by no later than the 2018-2019 competitive season.

2. In order to increase the competitive participation opportunities for students who are 

members of the underrepresented sex, the District will consider expanding the squad sizes, 

in accordance with IHSA rules and regulations, for interscholastic sports currently offered at 

the particular District high school, consistent with the nature of each sport and the level of 

interest in each sport. The District will increase the size of each squad where determined to 

be appropriate. If necessary, the District will provide sufficient coaching staff to support the 

addition of new athletes to any given squad and take any other steps necessary to ensure that 

the new athletes on each expanded squad are provided meaningful opportunities to 

participate in interscholastic athletics. 

B. Sports Not Currently Offered: 

The District will determine whether there is a sufficient number of high school female students 

with sufficient interest and, if applicable, ability to support the addition of a team or multiple 

teams (varsity, junior varsity, sophomore, etc.), in sports not currently offered by the particular

District high school as interscholastic sports, and whether there is sufficient competition within 

Chicago High School Athletic Association commonly referred to as the Chicago Public League

and within that high school’s normal competitive region and geographic area for those 

teams/sports. If so, the District will implement a plan at each high school to add a team or 

multiple teams in those sports at the relevant high school(s) beginning where possible for the 

2015-2016 competitive season but beginning no later than for the 2016-17 competitive season 

and continuing in ensuing years until such time as the high school has demonstrated to OCR 

compliance with the three part test, but by no later than the 2018-2019 competitive season. 

Where necessary, additional levels or squads will be added where possible beginning for the 

2016-17 competitive season but beginning no later than the 2017-18 competitive season in new 

sports added at each school until such time the school has demonstrated compliance to OCR 

with the three part test, but by no later than the 2018-2019 competitive season.

C. Response to Developing Interests and Abilities:

For any sport that is not currently offered by the particular District high school where there is a 

sufficient number of female students who have interest and, if applicable, ability in that sport, 

but where the District determines that there is not sufficient competition within the Chicago 

High School Athletic Association commonly referred to as the Chicago Public League, the 

District will take ongoing reasonable steps to develop students’ interests and abilities. The steps 
Page 9 – OCR Case Nos. 05-11-1034 and 05-89-1020

may include establishing club sports, exploring the feasibility of establishing competition in the 

Chicago High School Athletic Association commonly referred to as the Chicago Public League 

or otherwise in the District’s normal competitive region and geographic area, and advocating 

with the IHSA to elevate such sports to interscholastic status, or elevating such sports to 

interscholastic status when competition becomes available. 

OCR has made clear to the District and the District understands that OCR does not require or 

encourage the elimination of any District athletic teams and that it seeks action from the District 

that does not involve the elimination of athletic opportunities, because nothing in Title IX or the 

three-part test requires an institution to cut teams or reduce opportunities for students who are 

participating in interscholastic athletics in order to comply with the provisions of Title IX 

relating to the effective accommodation of the interests and abilities of male and female 

students.

Additional Interscholastic Opportunities: 

To the extent that the District adds any sports or additional levels of teams at any of its high 

schools, the District will provide those teams in a manner comparable to other interscholastic 

teams, with sufficient funds in their budgets to cover expenses that include, but are not limited 

to: coaches, equipment and supplies, travel funds, publicity and support services. The District 

will also publicize any new sports or additional levels of teams through written notices posted at 

the particular District high school at which the sport or team was added, and postings on the 

District’s website. 

REPORTING REQUIREMENTS – SECTION IV

1. By June 30, 2015 (Fall, Winter and Spring Sports) for the 2014-15 academic year, and by 

November 30 (Fall Sports), April 1 (Winter Sports) and June 30 (Spring Sports) of each 

ensuing academic year covered by this Agreement, the District will provide OCR with a 

copy of the roster for each team at each District high school, as verified and attested to by 

the Athletic Director or coach for each team. 

2. The District has provided OCR the breakdown/enrollment by sex at each District high 

school for 2014-2015 and it will do so on November 1 of each ensuing academic year 

covered by this Agreement. 

3. Between September 30 through October 30 of each ensuing academic year covered by 

this Agreement, the District will provide information regarding any increases to the size 

of its squads, as described by Section IV.A.2. above. 
Page 10 – OCR Case Nos. 05-11-1034 and 05-89-1020

V. ADDITIONAL COMMITMENTS TO IMPROVE THE ATHLETIC OPPORTUNITIES 

FOR THE UNDERREPRESENTED SEX 

A. The District will develop a process or procedure for students or other interested parties, such 

as coaches or parents, to use in requesting the addition of new sports or levels of sports at 

the District’s high schools. The procedure will be written and notice of it will be published 

on the District’s website.

5

 The individual responsible for responding to any requests is the 

Athletics Equity Liaison, identified above and her name and contact information will 

continue to be published on the website. 

B. By September 15, 2015 and by September 15th of each school year, the District will provide 

written notice to coaches, physical education teachers, guidance counselors and principals, 

of all sports offered at each District high school. 

C. By September 15, 2015, and by September 15th of each school year, the District will provide 

a written description of all of its sports offerings at each District high school to any high 

school students enrolled in their physical education classes. This information will also be 

posted on the District’s website.

D. The District will maintain the interscholastic athletic squad lists, which shall reflect the 

participation numbers for each sport, by sex, as of each team’s first competitive event. 

These records will not be destroyed for five years or otherwise altered so that they can be 

submitted to OCR consistent with the terms of this Agreement.

E. The District will establish, post and regularly update on the world wide web a publicly 

available athletics “web page” for the District; the web page will include a description of the 

sports offerings at each high school, including at a minimum, the interscholastic and club 

sports available to male and female students at each high school, the season in which the 

sport competes and the name and contact information for the athletic directors for each high 

school. 

 5 See, http://cps.edu/Programs/Before_and_after_school/AthleticsSports/Pages/AthleticsSports.aspx

REPORTING REQUIREMENTS – SECTION V

1. By September 30, 2015, the District will submit a copy of its procedure for requesting new 

sports, as required by Section V.A, above, and a link to the location on its webpage where 

the revised procedure is located.

2. By September 30, 2015, the District will provide OCR with a copy of the notices provided 

to coaches and students, as required by Section V.B, C, and E, above, and a link to the 

location on its webpage where the notices are located.
Page 11 – OCR Case Nos. 05-11-1034 and 05-89-1020

OCR is cognizant of the District’s reported ongoing financial constraints and it will work with the 

District to ensure the timely implementation of the Agreement despite those constraints. 

The District understands that by signing this Agreement, it agrees to provide data and other 

information in a timely manner. Further, the District understands that, during the monitoring of this 

Agreement, OCR may visit District schools, interview District staff, and request such additional 

reports or data as are necessary for OCR to determine whether the District has fulfilled the terms of 

this Agreement and is in compliance with the regulation implementing Title IX at 34 C.F.R. § 

106.41(c)(1), which was at issue in this case. Before OCR visits a District school or interviews any 

District staff, OCR will provide the District with at least five school days’ notice of the school visit 

or interview.

The District understands that OCR will not close the monitoring of this Agreement until OCR 

determines that the District has fulfilled the terms of this Agreement and is in compliance with the 

regulation implementing Title IX at 34 C.F.R. § 106.41(c)(1), which was at issue in this case. 

/s/ July 1, 2015

______________________________ _______________

Annette Gurley Date

Chief Officer of Teaching and Learning

______________________________

Title