There are, of course, plenty of explanations for this lack of action and many of them are foreshadowed in the legislative battle to pass the original bill. After all, civil rights enforcement was never popular. Those who wanted stronger enforcement were always in the minority. Members of Congress were nervous about giving too much power to the executive branch in administering policies. Similarly, elected state officials are not happy with bureaucrats dictating to them how organizations in their states are operated.
State universities are unwilling to cede authority over local institutions to federal officials.
Finally, members of Congress are elected by people who tend to resist strong enforcement procedures and this fact, as Halpern suggests, limits what the law was meant to do. The role of the courts and reform-minded civil rights lawyers are very important ingredients to this story as well. Litigation proved an important vehicle for challenging the way Title VI was implemented. A federal judge got very involved in the operations of the OCR, and for fifteen years his court orders shaped what the agency did and how it did it. Litigation swirled around the OCR for its entire history and shaped both who had influence over what the agency did and how the agency operated.