Summer is a critical time for reviewing Title IX policies and procedures before the start of a new academic year. When students return, institutions need more than technically compliant language. They need policies that are current, internally consistent, and practical for the employees responsible for implementing them. Because Title IX obligations affect reporting, response, supportive measures, investigations, resolution processes, and training, even small policy gaps can create confusion at sensitive moments.

Because the current Title IX regulations have not been updated substantially since 2020, a strong summer review begins with the text of your institution’s Title IX policy itself. Institutions should examine whether definitions, scope provisions, reporting options, and procedural descriptions reflect actual campus practice and remain compliant with Title IX. Institutions should also be aware of less significant updates that have occurred since the 2020 regulations were published. For example, in 2025, FBI crime definitions, on which the regulations rely, replaced “fondling” with “criminal sexual contact.”

It is also especially important to ensure that related materials align with your Title IX policy and procedures. Handbooks referencing Title IX, websites, training slides, templates of notice letters and determinations, and internal protocols and guidelines may have been updated at different times, leaving inconsistent terminology or outdated references. Those inconsistencies can create problems when a complainant or respondent relies on one source while administrators follow another. Summer is the right time to correct those issues before caseloads take off in the fall.

Policy updates should also account for implementation challenges that your institution may have experienced. A Title IX policy may appear complete on paper while still leaving staff uncertain about intake responsibilities, emergency removals, informal resolution best practices, advisor participation, documenting and implementing supportive measures, or coordinating with related student conduct and HR processes. Institutions should use the summer to identify where personnel have encountered confusion and whether revisions would improve clarity. If employees are relying on unwritten practices rather than clear policy guidance, that is a sign the written framework may need refinement.

Campuses should also consider accessibility and trust. A Title IX policy is not effective if the people who need it cannot find it or understand it. Students and employees should be able to identify where to report, what support is available, and what process the institution will follow. Clear communication is both a practical risk-management tool and a service to the campus community.

Title IX policy review works best as a summer project, not a fall emergency. Institutions that update, align, and clarify their policies now will be better prepared to respond consistently and confidently when the semester begins. Hunton’s Higher Education team regularly reviews and revises Title IX policies and procedures for institutions and advises clients on Title IX best practices and legal updates. If you would like to discuss how we can assist your institution, please contact Gerry Leone, Amy Fabiano, or Brigid Harrington.