Title IX in Practice: Facilities, Uniforms, Contests and Coaching

Title IX enforcement has rarely stood still for long, but the last 18 months have seen significant change. Athletic directors who set a Title IX self-assessment aside a few years ago are finding the ground has shifted with new executive actions, rescinded regulations, and a landmark Supreme Court ruling having all arrived since early 2025.

This is a good moment for a working refresher, not on the headline-grabbing questions alone, but on the everyday compliance areas that quietly determine whether a school’s athletic program is actually equitable in part by focusing on facilities, uniforms, contests and coaching.

None of this is new territory for the law. What is new is how closely the Office for Civil Rights (OCR), the courts and state legislatures are all watching it at once, which makes now a smart time for every athletic director to walk the halls, the locker rooms and the schedule board with fresh eyes.

The Legal Framework of Title IX
Title IX itself does not specifically mention sports. Its athletics obligations come from the 1979 Policy Interpretation that sorted a school’s duties into three baskets: participation opportunities, athletic financial assistance and “other program areas” – informally known among compliance professionals as the “laundry list.” Facilities, uniforms, contests and coaching all live in that third basket.

The laundry list covers 11 categories, referred to in the NIAAA’s LTC 506 course as the acronym “PLAYING FAIR”: provision of equipment and supplies, locker rooms and facilities, assignment and compensation of coaches, medical and training services, publicity, and more. The legal standard across these categories is not identical spending, but comparable quality, availability and treatment. That distinction is worth emphasizing, because it is the single- most common point of confusion among coaches and boosters.

Facilities
Facilities compliance covers practice fields and gymnasiums, locker rooms, training and weight rooms and competition venues. The question the Office for Civil Rights (OCR) asks is not whether every team gets the same building, but whether the facilities available to boys and girls teams are comparable in quality, size and scheduling access.

Scheduling is where most facilities problems actually hide. A school can own two gymnasiums of equal quality and still run afoul of Title IX if one sex’s teams consistently get the 6 p.m. slot and the other gets 6 a.m. The resolution starts with a simple exercise: pull a season’s worth of practice schedules and sort them by team and time. Patterns that look accidental on a week-by-week basis often become obvious across a full season.

Locker rooms and training rooms deserve the same scrutiny. “Comparable” does not require identical square footage, but it does mean similar condition, similar proximity to fields and courts, and similar access to training staff and equipment.

Uniforms and Equipment
Uniforms and equipment are governed by the same comparable- quality standard. A program does not need to spend identical dollars on every team’s gear, but it does need to keep replacement cycles, condition and fit-for-purpose roughly in step across sports. The most common compliance trap here is informal and unintentional: hand-me-down equipment quietly migrates to one sex’s teams while the other consistently receives new purchases, simply because that is how budget requests have always been prioritized.

A useful habit is to track uniform and equipment age by team, not just by sport, and to review that list annually alongside the athletic budget. When a pattern shows up, it is far easier to correct in a budget meeting than to explain in a compliance complaint. It is also a good time to create, update or check team uniform purchasing schedules. If teams have a regular cycle to purchase uniforms on a scheduled year, this is one way to document compliance as everybody that is scheduled is more likely to be treated fairly.

Contests and Scheduling
This category covers the visible, public-facing side of a program: game times, venues, promotion and travel. Prime-time scheduling such as Friday nights, homecoming weekends, the main gym instead of the auxiliary gym, should rotate fairly across sports and sexes over a season, not default by habit to the same high-profile programs.

Publicity is worth focusing on its own, because it is the area athletic directors most often overlook. Game-day announcements, senior night ceremonies, program printing and social media coverage are all part of the “other athletic benefits and opportunities” that Title IX addresses. If one program’s highlights consistently make the school’s social channels and another’s do not, that gap is a compliance conversation, not just a communications one. All athletes should be valued for their contributions and celebrated equally as each student and team represents their school and community.

Travel and game-day support round out this category. Transportation quality, lodging for overnight contests, and per diem or meal allowances should be comparable for teams playing at a similar competitive level.

Coaching
Coaching compliance has three parts: compensation, access to qualified coaches and coach-to-athlete ratios. Stipends should be comparable for coaches with similar experience, season length and responsibilities, not necessarily identical, but explainable by factors other than the sex of the athletes coached. A cautionary note with this area, however, athletic directors should communicate with their school’s director of human resources relative to the federal equal pay act and any compensation requirements laid out by the Equal Employment Opportunity Commission (EEOC).

Access to experienced, qualified coaching matters as much as pay. A program that consistently assigns its most experienced coaches and largest support staffs to boys teams, while girls teams cycle through first-year or inexperienced coaches, has a Title IX exposure even if every coach is paid on the same scale. The same logic applies to assistant coaches, athletic trainers and strength staff time.

Taking Steps to Build a Habit of Compliance
A Title IX self-assessment is a proactive leadership function, not a reactive one. It works best as an annual habit rather than a response to a complaint. A few practices make the habit sustainable:

• Establish a school district Title IX Athletic Team alongside the district’s Title IX coordinator.

• Build Title IX into the coaches’ handbook and revisit it at every coaches’ meeting and new-coach orientation, not just once a year.

• Extend the self-assessment down to middle school athletics where applicable. Participation patterns often start well before ninth grade.

• Keep the athletic program connected to the rest of district administration rather than operating as its own island. Title IX compliance works better as a shared institutional habit than an athletic department secret.

An athletic self-assessment is one of the simplest ways to put this into practice. The checklist below is a starting point an athletic director can run through once a season.

Title IX athletics compliance assessment as a proactive leadership function should be an athletic director’s priority. This can begin with an annual self-assessment. Schools should not wait for a complaint to be filed before addressing issues of gender equity in their athletic programs.

Once a year, athletic directors should put the boys and girls program side-by-side and compare facilities, equipment, uniforms, schedules, travel, coaching, medical and training services, publicity and other benefits. And then ask: “If someone asked me tomorrow why these two programs are treated differently, could I give them a legitimate, objective and documented answer?” That is the practical standard for an athletic director.

Participation in education-based interscholastic athletics comes with great benefits to those students who choose to participate. In many ways it is about the experience. Schools must ensure that all students who participate in the school’s education-based athletics program are getting the best experience possible.

Dr. Steve Amaro, CMAA, is principal of Freedom High School in Oakley, California, after previously as assistant principal, English content coach, athletic director and tennis coach for the school. He is a member of the High School Today Publications Committee. He can be reached at amaros@luhsd.net.

Peg Pennepacker, CAA, served 36 years in public education including 26 years as a high school athletic director. She is an NIAAA national faculty member and instructor for the four legal issues in athletics courses. She is a member of the High School Today Publications Committee and currently a school board director in the Upper Perkiomen School District, Pennsburg, PA. She can be reached at pegpennepacker@ gmail.com.