Gender Equity: Men's and Women's Participation in Higher Education
(Letter Report, 12/15/2000, GAO/GAO-01-128).

Since Title IX of the Education Amendments was enacted in 1972, women's
participation in higher education academic programs has increased
significantly. Women's participation in predominantly male fields such
as business, law, and medicine has also increased greatly although
changes in other predominantly male fields, such as engineering and
physical science, have been smaller. In some predominantly female
fields, including elementary education and nursing, there have been
increases in the proportion of men receiving degrees. In the 1995-96
school year, first-year college men and women were about as likely to
receive financial aid and received about the same average amounts of
grant and loan aid. Men continue to outnumber women on faculties in
predominantly male fields at colleges and universities. Women's
participation in intercollegiate sports at 4-year colleges and
universities has increased while men's participation has dropped
slightly, although they still participate at a higher rate than do
women. On average, in the 1998-99 school year, the National Collegiate
Athletic Association member schools spent more per male intercollegiate
sports participant than female participant in recruiting, coaches'
salaries, and operations. However, they spent more on athletic
scholarships for women than for men. Men continue to hold the majority
of athletics director positions in intercollegiate athletics. Because
various factors such as other civil rights laws and changing societal
attitudes have also contributed to changes in women's roles, it is
difficult to isolate Title IX's specific effects.

--------------------------- Indexing Terms -----------------------------

 REPORTNUM:  GAO-01-128
     TITLE:  Gender Equity: Men's and Women's Participation in Higher
	     Education
      DATE:  12/15/2000
   SUBJECT:  Women
	     Sports
	     Statistical data
	     Sex discrimination
	     College students
	     Higher education

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GAO-01-128

A

Report to the Ranking Minority Member, Subcommittee on Criminal Justice,
Drug Policy and Human Resources, Committee on Government Reform, House of
Representatives

December 2000 GENDER EQUITY Men's and Women's Participation in Higher
Education

GAO- 01- 128

Letter 3 Appendixes Appendix I: Scope and Methodology 32

Appendix II: Federal Agencies With Title IX Enforcement Responsibilities 35

Appendix III: Supplemental Information Concerning Title IX and Higher
Education 37

Appendix IV: Supplemental Information Concerning OCR Cases Involving
Intercollegiate Athletics 39

Appendix V: Comments From the Department of Education 43 Appendix VI: GAO
Contacts and Staff Acknowledgments 49

Related GAO Products 50 Tables Table 1: Important Events and Cases Involving
Title IX Issues 7

Table 2: Intercollegiate Athletics Program Expenditures Per Male and Female
Participant, NCAA Colleges and Universities, School Year 1998- 99 19 Table
3: Disposition of Postsecondary Title IX Complaints

With the Office for Civil Rights, Fiscal Years 1994 Through 1998 28 Table 4:
Disposition of Title IX Postsecondary Compliance

Reviews, Fiscal Years 1994 Through 1998 30 Table 5: Percentage of Degrees
Awarded to Women in

Predominantly Male Fields of Study, School Years 1971- 72 and 1996- 97 37
Table 6: Estimated Participation Rates in Intercollegiate

Sports at 4- Year Colleges and Universities, School Years 1966- 1967 to
1998- 1999 38 Table 7: Top 10 Athletics Issues in the 139 Cases OCR Acted

On, Fiscal Years 1994 Through 1998 39 Figures Figure 1: Percentage of
Degrees Awarded to Women in

Predominantly Male Fields of Study, School Years 1971- 72 and 1996- 97 11

Figure 2: Estimated Participation Rates in Intercollegiate Sports at 4- Year
Colleges and Universities, School Years 1971- 72 to 1997- 98 17 Figure 3:
Means of Resolving Cases Involving the Three- Part Test,

Fiscal Years 1994 Through 1998 40

Abbreviations

EADA Equity in Athletics Disclosure Act EEOC Equal Employment Opportunity
Commission GED general educational development NAIA National Association of
Intercollegiate Athletics NCAA National Collegiate Athletic Association NCES
National Center for Education Statistics OCR Office for Civil Rights SAT
Scholastic Assessment Test

Let t er

December 15, 2000 The Honorable Patsy Mink Ranking Minority Member
Subcommittee on Criminal Justice,

Drug Policy and Human Resources Committee on Government Reform House of
Representatives

Dear Congresswoman Mink: Discrimination against women in areas such as
college admissions, intercollegiate athletics, and employment was widespread
40 years ago. Although civil rights laws in the 1960s barred discrimination
in employment, similar protection was not available for students at colleges
and universities until the adoption of Title IX of the Education Amendments
of 1972. 1 Title IX attempted to address inequities between men and women by
prohibiting discrimination on the basis of sex in education programs and
activities receiving any federal financial assistance, including federally
backed student loans and research grants and contracts. Women's
participation in higher education can present only one facet of women's
status in our nation's economy and society. In the almost 30 years since
title IX was enacted, women's roles in American life have changed greatly,
and the effects of title IX on men and women continue to be debated.

You asked us to review and report on what is known about title IX's
contribution to changes in higher education. Specifically, you asked us to
(1) determine the extent to which women's participation in higher education
academic programs has changed since title IX was enacted, (2) determine the
extent to which men's and women's participation in intercollegiate athletics
programs at 4- year schools has changed since title IX was enacted, and (3)
describe what is known about title IX's effect on men's and women's
participation and, more specifically, about how federal enforcement of the
law has led to change.

1 20 U. S. C. sect.sect. 1681- 1688.

To address these questions, we obtained information from the Department of
Education and the two largest athletics associations for 4- year colleges
and universities- the National Collegiate Athletic Association (NCAA) and
the National Association of Intercollegiate Athletics (NAIA). They provided
some similar information for a previous report. 2 We also interviewed
representatives of organizations with expertise or interest in title IX and
a wide range of views on title IX policy. Our review focused on concerns
about gender equity among postsecondary students. As you requested, we are
also providing information on women's participation as faculty members and
athletics directors and on intercollegiate athletic expenditures. (See app.
I for details concerning our methodology.) In conducting our review, we
relied on data obtained from Education, NCAA, and NAIA, which, although
unverified, are considered the best available and are extensively used by
the research community. Because recent information on intercollegiate
athletic expenditures was not available from these sources at the time of
our review, we also used data published by The Chronicle of Higher
Educationand additional data available on its website. Education plans to
make such data available in the future. Our work was done between November
1998 and September 2000 in accordance with generally accepted government
auditing standards.

Results in Brief Since title IX's enactment in 1972, women's participation
in higher education academic programs has increased significantly, whether

measured by the proportion of students enrolled in higher education who are
women, numbers of women enrolled, or the proportion of women who have
received degrees in certain fields of study in which men were the
predominant degree recipients. 3 In 1950, about one- quarter of
undergraduate students were women. Women's share of undergraduate enrollment
increased to 43 percent in 1971 and 56 percent in 1997. Women's
participation in a number of predominantly male fields such as business,
law, and medicine has also increased greatly although changes in other
predominantly male fields, such as engineering and physical science, have
been smaller. In some predominantly female fields, including elementary

2 Intercollegiate Athletics: Comparison of Selected Characteristics of Men's
and Women's Programs( GAO/ HEHS- 99- 3R, June 18, 1999). 3 We defined
predominantly male fields of study as those in which, in school year 1971-
72, (1) women earned fewer than 25 percent of the degrees awarded and (2) at
least 5,000 bachelor or 1,000 first professional degrees were awarded. The
25 percent figure is based on the Department of Labor's definition of
nontraditional occupations.

education and nursing, there have been increases in the proportion of men
receiving degrees. In the 1995- 96 school year, first- year college men and
women were about as likely to receive financial aid and received about the
same average amounts of grant and loan aid. Men continue to outnumber women
on faculties in predominantly male fields at colleges and universities.

Women's participation in intercollegiate sports at 4- year colleges and
universities has increased while men's participation has dropped slightly,
although they still participate at a higher rate than do women. From title
IX's enactment to the 1997- 98 school year, the number of women in
intercollegiate sports grew from an estimated 30,000 (1.7 percent of
fulltime enrolled undergraduate women) to 157,000 (5. 5 percent of full-
time undergraduate women). Over the same period, the number of men
participating fell from about 248,000 (10.4 percent of full- time
undergraduate men) to about 234,000 (9.5 percent of full- time undergraduate
men). On average, in the 1998- 99 school year, NCAA member schools spent
more per male intercollegiate sports participant than female participant in
recruiting, coaches' salaries, and operations. However, they spent more on
athletic scholarships for women than for men. Men continue to hold the
majority of athletics director positions in intercollegiate athletics.

Because various factors such as other civil rights laws and changing
societal attitudes have also contributed to changes in women's roles, it is
difficult to isolate title IX's specific effects. We found widespread
agreement, however, among representatives from the higher education
community and title IX observers, regardless of their perspective on current
title IX policy, that title IX has contributed to increased opportunities
and participation for women in the classroom and on the playing field. There
was no agreement, however, on whether the law has contributed to the decline
in the number of men involved in intercollegiate sports. Although Education
has not terminated its funding for any postsecondary institution for a
violation of title IX, federal enforcement has had an effect through other
means. Education's Office for Civil Rights (OCR), which has the lead
enforcement responsibility for most title IX issues, has instead enforced
title IX through a variety of methods, including complaint investigations,
compliance reviews, and the issuance of policy guidance. OCR's approach to
enforcement emphasizes collaboration and negotiation, consistent with
statutory requirements to attempt to secure compliance by voluntary means.
In addition, private lawsuits have played an important role in title IX
enforcement.

We provided the Department of Education, NCAA, and NAIA drafts of this
report for comment, and they generally agreed with our findings.

Background With certain exceptions, title IX requires all educational
institutions receiving any form of federal financial assistance to prohibit
sex

discrimination in academic, extracurricular, and other programs. 4 Because
most postsecondary schools have students who receive federal financial
assistance, such as federal or federally backed student loans, title IX
applies to the large majority of 2- year and 4- year schools, both public
and private. Title IX's provisions apply to all operations of college and
university programs, including admissions, instruction, financial aid,
intercollegiate athletics, housing, employment, and counseling.

As table 1 shows, application of title IX has evolved since it was enacted.
For example, in 1984, the Supreme Court held that title IX did not apply to
intercollegiate sports and other programs that did not directly receive
federal funding. In 1988, however, the Congress passed the Civil Rights
Restoration Act, which restored the earlier interpretation and broad
application of title IX. It provided that any program, including athletics
programs, offered by schools that receive or benefit from federal funding
must provide equal opportunities to men and women regardless of whether the
specific program benefits from federal funding.

4 Some schools receiving federal financial assistance are subject to some,
but not all, of title IX's provisions. For example, schools with religious
affiliations that have religious tenets that conflict with title IX
provisions may be granted an exemption from compliance with those
provisions. Also, certain single- sex undergraduate programs and military
academies are exempt from admissions and recruitment provisions of title IX.

Table 1: Important Events and Cases Involving Title IX Issues Year Event/
Case Importance

1972 Title IX enacted a First federal law specifically prohibiting sex
discrimination at educational institutions receiving federal financial
assistance.

1974 Women's Educational Equity Act Provided for educational equity for
women at all levels of education through grants

enacted b and contracts for curricula, textbooks, training, research,
counseling, and other educational efforts.

1975 Title IX regulations finalized c Responded to nearly 10, 000 public
comments, most concerning athletics. 1979 OCR policy interpretation

Established standards for assessing compliance with requirements concerning
concerning intercollegiate sports d intercollegiate sports, including
athletic scholarships, other benefits and services,

and a three- part test concerning participation opportunities. 1979 Cannon
v. University of Chicago e Held that private parties may file suit in title
IX cases. 1984 Grove City College v. Bell f Held that title IX applied only
to programs that directly receive or benefit from

federal financial assistance. Thus, other programs, such as intercollegiate
sports programs that do not receive federal funds are not subject to these
laws.

1987 Civil Rights Restoration Act of Restored institution- wide jurisdiction
for applying civil rights laws, superceding the 1987 g Grove City College v.
Bell decision.

1990 OCR title IX athletics investigator's Provided detailed guidance for
investigators evaluating compliance with title IX in

manual h intercollegiate and interscholastic sports, including criteria
concerning participation, scholarships, facilities, coaching, and
scheduling.

1992 Franklin v. Gwinnett County Public Held that monetary damages are
available to plaintiffs in private title IX actions. Schools i 1994 Equity
in Athletics Disclosure Act j Facilitated assessment of gender equity in
schools' intercollegiate athletics

programs by requiring schools to report participation and resources for
men's and women's sports programs.

1996 Cohen v. Brown University k Upheld standards established in OCR's 1979
three- part test for assessing compliance with requirements concerning
intercollegiate athletics participation opportunities.

1996 OCR clarification of intercollegiate Provided additional explanation
and examples concerning OCR's test to determine

athletics policy guidance l whether schools have achieved equal opportunity
in intercollegiate athletics participation.

1997 OCR sexual harassment policy Provided policy guidance on title IX
prohibitions against sexual harassment in

guidance m schools. 1998 OCR “Dear Colleague” letter

Clarified policy guidance on substantial proportionality in athletic
scholarships. regarding athletic scholarships n a 20 U. S. C. sect.sect. 1681- 1688.

b Originally enacted as section 408 of P. L. 93- 380; current provisions of
the Women's Educational Equity Act can be found at 20 U. S. C. sect.sect. 7231-
7238. c 45 C. F. R. Part 86, currently found at 34 C. F. R. Part 106.

d Title IX of the Education Amendments of 1972: A Policy Interpretation;
Title IX and Intercollegiate Athletics, 44 Fed. Reg. 71413 (Dec. 11, 1979).
For details concerning the three- part test, see app. IV. e 441 U. S. 677
(1979).

f 465 U. S. 555 (1984).

g 20 U. S. C. sect. 1687. h Department of Education, OCR, Title IX Athletics
Investigator's Manual, 1990. In conducting investigations, OCR has used this
and a previous manual issued in 1980. These manuals have been clarified by
more recent policy guidance. i 503 U. S. 60 (1992).

j 20 U. S. C. sect. 1092( g). k 809 F. Supp. 978 (D. R. I. 1992)( Cohen I); 991
F. 2d 888 (1st Cir. 1993)( Cohen II); 879 F. Supp. 185 (D. R. I. 1995)(
Cohen III); 101 F. 3d 155 (1st Cir. 1996)( Cohen IV). l Department of
Education, OCR, “Clarification of Intercollegiate Athletics Policy
Guidance: The ThreePart

Test” (Jan. 16, 1996). m Department of Education, OCR, “Sexual
Harassment Guidance: Harassment of Students by School

Employees, Other Students, or Third Parties,” 52 Fed. Reg. 12034 (Mar.
13, 1997). On Nov. 2, 2000, OCR published in the Federal Registerfor a 30-
day comment period “Revised Sexual Harassment Guidance: Harassment of
Students by School Employees, Other Students, or Third Parties.” This
revises OCR guidance in light of recent Supreme Court cases relating to
sexual harassment in schools. See Gebser v. Lago Vista Independent School
District, 524 U. S. 274 (1998), and Davis v. Monroe County Board of
Education, 526 U. S. 626 (1999).

n July 23, 1998.

Because many federal agencies fund education activities covered by title IX,
they are potentially involved in enforcement activities. (For a list of
agencies, see app. II.) Two agencies have major roles: the Department of
Justice, which coordinates civil rights enforcement efforts, and Education's
OCR, which investigates most types of complaints and allegations. The
Department of Justice coordinates the development of federal agencies' title
IX regulations, coordinates arrangements for referrals of cases between
agencies, and represents federal agencies in title IX court proceedings, as
needed. The Equal Employment Opportunity Commission (EEOC) also investigates
individual complaints of employment discrimination, including those under
title IX if OCR refers them to EEOC, and those filed against recipients of
federal financial assistance that are subject to Title VI of the Civil
Rights Act of 1964. 5 OCR investigates employment discrimination cases that
involve allegations of “systemic” or patterns and practices of
employment discrimination and those that allege both employment
discrimination and discrimination in federal aid recipients' other
operations. 6 Individuals or groups also have the option of filing suit in
federal court or filing a complaint through the institution's grievance
procedure. They may do so independent of any administrative action, such as
a complaint investigation, by OCR or any other agency.

5 These investigations are conducted under Title VII of the Civil Rights Act
of 1964. 6 Attorney General Order No. 992- 83, 28 C. F. R. part 42 (1982);
29 C. F. R. part 1691 (1984).

Education's Office of Student Financial Assistance has responsibility for
enforcing another gender- equity law, the Equity in Athletics Disclosure
Act. 7 Under this act, coeducational colleges offering intercollegiate
athletics and participating in federal student financial aid programs, such
as Pell grants and federal student loan programs, must disclose certain
information by gender, such as the number of varsity teams, the number of
participants on each team, the amount of operating expenses, and coaches'
salaries. Colleges must make these reports available to students, potential
students, the public, and Education.

Women's Participation Although women were a minority in higher education
before title IX was

Has Increased in enacted, women students now substantially outnumber men. In
1997,

colleges and universities enrolled 1. 5 million more women undergraduates
Academic Programs in

than men undergraduates. Women's participation has increased in many Higher
Education

fields of study that were predominantly male in the 1971- 72 school year,
including law and medicine. In other fields, such as engineering and
computer and information science, men remain a sizeable majority even though
the gap has narrowed. However, women still comprise a small share of faculty
in fields that have been predominantly male. Men's participation in
predominantly female fields, such as nursing and elementary education, has
also increased, although women remain the overwhelming majority in these
fields. Financial aid is generally provided to women and men equally when
similar college costs and financial means are considered.

7 20 U. S. C. sect. 1092( g).

Women's Enrollment Since title IX's enactment in 1972, both men and women
have participated

Exceeds That of Men in higher education programs in greater numbers, with a
marked increase

for women. From fall 1971 to fall 1997, the number of women enrolled in the
nation's colleges and universities more than doubled, from about 3.7 million
to 8.2 million. 8 The number of men enrolled increased by about onequarter,
from about 5. 2 million to about 6.5 million. In 1971, a little more than
one- half of high school graduates were women, yet women comprised only 43
percent of college undergraduate enrollment. By 1997, the numbers of men and
women graduating from high school were about the same, but women represented
56 percent of undergraduates. The Department of Education projects that
women's proportion of enrollment will continue to increase to about 58
percent of total enrollment by 2009. According to researchers, fewer men
than women attend college in part because men, in the years after high
school, are attracted to job opportunities that on average pay more than
those available to young women. For example, among students from the high
school class of 1992, who received a high school diploma or general
educational development (GED) credential and did not attend postsecondary
institutions in 1993, women who worked earned an average of 64 percent of
the amount men did. In addition, many more men than women enter the armed
forces.

Degrees Awarded to Women Since the 1971- 72 school year, the percentage of
women who have received

in Predominantly Male degrees in some predominantly male fields of study has
increased

Fields Have Increased but significantly (see fig. 1). For example, in school
year 1971- 72, women

Extent Varies received only 1 percent of all dentistry degrees, compared
with 37 percent

in 1996- 97. Women's share of business degrees also increased greatly during
this period, from 10 percent to 49 percent.

While women comprise a smaller percentage of baccalaureate degree recipients
in such predominantly male fields as engineering, physical science, and
computer science, women's share of degrees in these fields has also
increased significantly since 1971. For example, women's share of
engineering degrees in the 1996- 97 school year was 17 percentï¿½up from 1
percent in school year 1971- 72. In addition, the percentage of women
receiving degrees in the physical and computer sciences at least doubled

8 This includes undergraduate, graduate, and first professional students at
all higher education institutions, including 4- year, 2- year, and less than
2- year colleges and universities. This excludes institutions that offer
only vocational and continuing education programs.

over the same period, from 15 percent to 37 percent and 14 percent to 27
percent, respectively.

Figure 1: Percentage of Degrees Awarded to Women in Predominantly Male
Fields of Study, School Years 1971- 72 and 1996- 97

Percentage

60 1971- 72 1996- 97

50 49

50

44 44

41

40

37 37

30

27 22

20

19 17 15

14 10

9

10

7 1

1

0 Zoology

Business Political Law Medicine Dentistry Physical

Computer Engineering Science Science

Science

Note: Data shown are for first professional degrees for law, medicine, and
dentistry and for bachelor degrees in the other fields of study. For data
supporting this figure, see table 5 in app. III.

Several factors contribute to the continued predominance of men in certain
fields. For example, an Education study on engineering, a field that has
historically seen a low level of participation by women, showed that women
and men following an engineering path in college came equally prepared with
a math and science background. 9 However, there was a 20- percent gap
between men's and women's completion rates. According to the study, women
who left engineering did not leave because of poor academic performance,
although they expressed a higher level of academic dissatisfaction than men
who left the field. The study suggested that women's underrepresentation was
due, in part, to their lower level of interest in engineering, their
discomfort in a peer environment where they are a minority, and the
perception that engineering is a male occupation.

Several other studies had similar findings regarding women in the physical
sciences such as physics, chemistry, astronomy, and geology. Recent studies
provide insight into the role that precollege preparation, selfconfidence,
work and family, availability of role models, peer support, and teaching
methods play in women's participation in science, math, and engineering. 10
According to these studies, in grade 12, high school girls took fewer
courses in science, scored slightly lower on standardized science exams,
were more likely to have negative attitudes toward science, and were less
likely to declare science as a college major, as compared with high school
boys. At the undergraduate and graduate levels, factors that deterred women
from preparing for a career in science included peer pressure, neglect or
hostility from predominantly male peers and faculty, lack of mentors,
insufficient financial support, and the reluctance of some faculty to
establish an advisory relationship with individual students.

9 Department of Education and the National Institute for Science Education,
Women and Men of the Engineering Path: A Model for Analyses of Undergraduate
Careers( May 1998). 10 Department of Education, National Center for
Education Statistics (NCES), Findings From the Condition of Education, 1997:
Women in Mathematics and Science, NCES 97- 982 (1997); Sandra L. Hanson,
Lost Talent: Women in the Sciences( Philadelphia, Penn.: Temple University
Press, 1996); Gerhard Sonnert, W ho Succeeds in Science? The Gender
Dimension (New Brunswick, Mass.: Rutgers University Press, 1995); and Eileen
M. Byrne, Women and Science: The Snark Syndrome( The Falmer Press, 1993).

While studies have found that differences between men and women in math and
science achievement test scores have decreased over the years, men continue
to outscore women in these disciplines. In some cases, the differences were
quite small. For example, among 12th graders who took the 1996 National
Assessment of Educational Progress test, average math scores for men and
women were 305 and 303, respectively; the average science scores were 152
and 148. In other cases, the differences were larger. For example, the
National Science Foundation's 1999 study shows that 1996 Scholastic
Assessment Test (SAT) math scores for men averaged 527 (from 520 in 1991),
while SAT math scores for women averaged 492 (from 482 in 1991). 11

Research has also identified differences between men's and women's interests
in the physical sciences. Surveys of freshmen women, for example, indicate
that, while a growing proportion plan to major in the physical sciences,
women are still outnumbered by men. 12 Specifically, the percentage of
freshmen women planning to major in the physical sciences increased from 0.8
percent in 1971 to 1.6 percent in 1998. While the percentage of freshmen men
declined from 3.1 percent to 2. 6 percent during the same period, a
significantly greater number of men than women showed interest in these
subjects.

Women comprised a smaller percentage of doctoral degree recipients than
baccalaureate recipients in predominantly male fields. In the 1996- 97
school year, for example, women earned 29 percent of all doctoral degrees in
business, 23 percent in physical science and science technologies, 16
percent in computer science, and 12 percent in engineering and engineering-
related technologies.

Similarly, a smaller percentage of full- time faculty members in these
fields were women. In fall 1992, the latest year for which data were
available, women comprised 31 percent of business faculty, 17 percent of
political science faculty, 36 percent of law faculty, 12 percent of physical
sciences

11 National Science Foundation, Women, Minorities, and Persons With
Disabilities in Science and Engineering: 1988,NSF 99- 87 (Feb. 1999). The
study also reported that men consistently outscored women in the verbal
components of college entrance exams, such as the SAT, in 1991 and 1996, but
these differences were narrower. For women, the average verbal score
increased from 495 to 503; for men, it increased from 503 to 507.

12 Alexander Astin, et al., The American Freshman: Thirty Year Trends( Los
Angeles, Calif.: University of California, Los Angeles, 1997), and The
American Freshman: National Norms for Fall 1998( Los Angeles, Calif.:
University of California, Los Angeles, 1998).

faculty, 20 percent of computer science faculty, and 6 percent of
engineering faculty. For the 1996- 97 school year, 24 percent of full- time
tenured faculty at all 4- year schools in all fields of study were women.

More Men Earned Degrees Women are still the predominant degree recipients in
fields such as

in Predominantly Female nursing, elementary education, and home economics,
even though men's

Fields, yet Men Remain a share of these degrees has risen slightly since
1971. For example, between

Small Minority school years 1971- 72 and 1996- 97, men's share of degrees
increased from 3

percent to 11 percent in nursing, 9 percent to 12 percent in elementary
education, and 4 percent to 12 percent in home economics. In contrast, men's
share of degrees in special education declined from 13 percent to 11
percent. Overall, women received a somewhat smaller proportion of degrees in
these predominantly female fields in 1996- 97 compared with 1971- 72, yet
nearly 9 out of 10 of the degrees in these fields in school year 1996- 97
were awarded to women.

Little Difference in Student In school year 1972- 73, full- time first- year
college women received lower

Financial Aid by Gender average amounts of scholarships and grants than men
did. Typically,

Exists After Considering women relied more on the support of family,
friends, and loans, while men

Financial Need and Costs of had more savings and earnings from employment.
In contrast, in 1995- 96,

first- year college women and men were about equally as likely to receive
Attendance

aid and received about the same average amounts of grant and loan aid. 13
Men's and women's financial need did not vary to a statistically significant
extent. Women were, however, more likely than men to have dependents other
than spouses. Men were more likely to receive veterans' aid and athletic
scholarships.

13 We excluded noncitizens who were not eligible for aid under federal
student aid programs. Among all undergraduates (except for the same
noncitizens), men were more likely to receive loans and women were more
likely to receive grants. These differences were generally not statistically
significant when we compared men and women with similar financial means and
costs of attendance. The Department of Education assesses each student's
financial means using a formula for an expected family contribution. This
formula takes into account such factors as income, assets, dependents,
marital status, and the number of family members enrolled in eligible higher
education programs (20 U. S. C. sect. 1087kk).

As the number of women in postsecondary education has increased since the
enactment of title IX, so has the amount of financial aid they have
received. In the 1972- 73 school year, full- time freshmen women from the
previous year's high school graduating class (1971- 72) received an average
of $1,541 ($ 899 in grants and $642 in loans in constant 1995- 96 dollars).
14 Full- time college freshmen women from the high school graduating class
of 1995 who attended postsecondary institutions during the 1995- 96 school
year received an average of $3, 535 ($ 2,392 in grants and $1,143 in loans).
The average amount of aid rose 129 percent after adjusting for inflation. By
comparison, full- time freshmen men from the same high school classes who
attended postsecondary institutions during the next school year received an
estimated average of $1,456 ($ 937 in grants and $519 in loans in 1995- 96
dollars) in 1972- 73 and $3,027 ($ 1,952 in grants and $1,075 in loans) in
1995- 96. The estimated average amount of aid for men rose 108 percent after
adjusting for inflation.

Men's Participation in The proportion of college women who participate in
intercollegiate sports

Intercollegiate at 4- year colleges and universities has increased. From
title IX's enactment

to the 1997- 98 school year, the number of women in intercollegiate sports
Athletics Is Greater

at NCAA (Division I, II, III) and NAIA member schools grew from an Than
Women's, but the

estimated 30,000, or 1. 7 percent of full- time enrolled undergraduate
Difference Has

women, to 157,000, or 5.5 percent of full- time undergraduate women. Over
the same period, the number of men participating fell from about 248,000

Narrowed (10.4 percent) of full- time undergraduate men to about 234,000
(9.5

percent) of full- time undergraduate men. The increase for women was rapid
through the mid- 1980s, then more gradual. The number of men participating
varied, with the lowest participation rate reported in 1981. Despite
different trends for men and women, male participants continue to outnumber
female participants in intercollegiate sports. Approximately 77,000 more men
than women participated in 1997- 98. 15

14 These averages cover students who received aid and those who did not. We
adjusted these figures for inflation using the Bureau of Labor Statistics
consumer price index for all urban consumers. While we recognize that this
index has limitations, we chose to use it to adjust for inflation because we
concluded that it was the best available index for this purpose. See, for
example, Consumer Price Index: More Frequent Updating of Market Basket
Expenditure Weights Is Needed( GAO/ GGD/ OCE- 98- 2, Oct. 9, 1997).

15 From 1997- 98 to 1998- 99, the number of participants on men's teams
increased to about 237, 000 and the number on women's teams increased to
about 167, 000. Comparable fall 1998 enrollment data were not available to
calculate changes in participation rates.

Unlike marked trends in the number of women athletes, the estimated
athletics participation rateï¿½intercollegiate athletics participants as a
percentage of all full- time undergraduate students at 4- year colleges and
universitiesï¿½has remained fairly steady for both genders since the mid1980s.
16 In the first decade or so after title IX came into effect, women's

participation rates increased rapidly while men's participation rates
declined. Since the mid- 1980s, the number of women participating and the
number of women's teams have continued to rise, but not much faster than the
increase in the number of full- time female undergraduates enrolled at 4year
schools. Despite these increases for women, men's participation rate at 4-
year schools was still higher than women's in the 1997- 98 school year, as
shown in figure 2.

16 We calculated the two estimated participation rates- one for men and one
for women- by dividing the number of male or female intercollegiate sports
participants reported by NCAA and NAIA by the number of full- time male or
female undergraduates at all 4- year schools in the fall. The total number
of intercollegiate sports participants may exceed the number of athletes in
intercollegiate sports programs because some athletes participate in more
than one sport and are counted more than once in NCAA and NAIA participation
statistics. See app. I for notes concerning the limitations of these data.

Figure 2: Estimated Participation Rates in Intercollegiate Sports at 4- Year
Colleges and Universities, School Years 1971- 72 to 1997- 98

Percentage

12

Men

10 8 6

Women

4 2 0 1971- 72

1976- 77 1981- 82

871985- 881986- 86 891987- 901988- 911989- 921990- 931991- 941992- 951993-
961994- 971995- 981996- 1997- Note: Estimates are of intercollegiate sports
participantsï¿½NCAA Divisions I, II, and III, plus NAIAï¿½as

a percentage of full- time undergraduates. Annual estimates of athletics
participation were available beginning in 1981. In previous years, NCAA did
not compile data annually but did so at 5- year intervals. Fall enrollment
data for full- time undergraduates at 4- year schools by gender were not
available for 1982 through 1984. For data supporting this figure, see table
6 in app. III.

Women's athletics programs typically have lower expenditures than men's
programs, and in many cases they have lower expenditures per participant.
However, it is difficult to analyze universities' and colleges' spending on
athletics by gender since title IX's enactment because complete and
comparable data are not available for several years after its enactment. The
Equity in Athletics Disclosure Act (EADA) will facilitate analysis of such
spending in the future. The act requires schools to prepare reports on
athletics participation and expenditures and make them readily available
beginning October 1996, but Education was not required to compile such
reports until the Higher Education Amendments of 1998. To implement these
provisions, in November 1999, Education published rules for the collection
of data concerning each school's athletics participation and expenditures.
Such data should provide a basis for analyzing future trends in schools'
revenue and expenses for men's and women's intercollegiate sports programs.

In the 1998- 99 school year, NCAA coeducational schools spent more per male
than female intercollegiate sports participant on recruitment, coaches'
salaries, and operations. However, the average expenditure per participant
for athletics- related financial aid (scholarships) was higher for women
than for men. 17 There were also differences by division as shown in table
2. For example, NCAA Division I- A schools (colleges and universities that
typically offer the greatest number of athletic scholarships and have large
football programs) spent more per male participant than female participant
in each of four expenditure categories. Specifically, recruiting and
operating expenditures at Division I- A schools were about 70 percent higher
for male than for female participants. In contrast, the average expenditures
per participant for schools in Divisions I- AA, I- AAA, II, and III differed
much less by gender. Some differences, particularly in Division I- A, may in
part reflect the greater noninstitutional revenue typically generated by
men's sports programs. In 1997- 98, according to NCAA's gender- equity
study, the 91 Division I- A schools responding to NCAA's survey indicated an

17 The Chronicle of Higher Educationcollected 1998- 99 EADA reports from 858
of the 959 active, coeducational NCAA member schoolsï¿½a response rate of 89
percent. These data include only expenditures allocated to either men's or
women's intercollegiate sports programs. Expenditures for coed sports are
allocated to the men's and women's programs based on the percentage of male
and female participants. Expenditure categories include recruiting,
athletically related financial aid, coaches' salaries, and operating
expenses (lodging, meals, transportation, officials and uniforms, and
equipment for both home and away contests). They do not include general
expenditures that were not allocated to either gender. They also do not
include debt service and replacement of facilities. Division III schools do
not award athletic scholarships.

average of $11.8 million in revenue attributable to men's sports and $1. 1
million in revenue attributable to women's sports. 18

Table 2: Intercollegiate Athletics Program Expenditures Per Male and Female
Participant, NCAA Colleges and Universities, School Year 1998- 99

Recruiting a Scholarships b Coaches' salaries c Operations (“ Game
Day”) d Division/ Subdivision Men Women Men Women Men Women Men Women

I- A $987 $579 $6, 404 $5, 815 $5,136 $3,393 $28,848 $17, 111 I- AA 375 256
4, 151 4, 454 2,356 1,920 9,572 8, 415 I- AAA 382 300 4, 768 5, 634 2,698
2,304 12,014 11, 247 II 113 100 2, 278 2, 421 1,430 1,422 5,262 5, 293 III
64 46 e e 852 874 1,822 1, 787 Weighted average $347 $229 $4, 269 $4, 418
$2,212 $1,785 $9,944 $7, 467

Note: These calculations were based on The Chronicle of Higher
Education'scompilation of data from coeducational active NCAA members.
Participants in intercollegiate athletics represent the sum of the number of
intercollegiate (undergraduate) athletes on each team at each school. Some
athletes participate on more than one team and are counted more than once in
these data. a These calculations are based on data from 815 of the 959 NCAA
members. We excluded institutions

that did not provide information concerning numbers of participants or
recruiting expenditures. We included institutions that indicated they did
not have any recruiting expenditures. b These calculations are based on data
from 532 of the 596 members of NCAA Divisions I and II. We

excluded institutions that did not provide data concerning numbers of
participants or scholarships. We included institutions that indicated they
did not provide any scholarships. Because an individual is eligible for only
one athletic scholarship even if he or she participates in more than one
sport, analysts often compare scholarships per athlete rather than per
participant. This comparison adjusts for athletes participating on more than
one team because it is based on an unduplicated count of athletes. Based on
this adjustment, the 532 schools reported spending $4,458 in scholarships
per male athlete and $4,861 per female athlete. c These calculations are
based on data from 853 NCAA members. We excluded institutions that did not

provide information concerning coaches' salaries or numbers of participants.
d These calculations are based on data from 856 NCAA members. We excluded
institutions that did not

provide information concerning “game day” operating
expensesï¿½expenses attributed to home, away, and neutral site contestsï¿½or
numbers of participants. e NCAA Division III schools are excluded from these
calculations because they do not award athletic

scholarships.

18 NCAA, 1997- 98 NCAA Gender- Equity Study( Indianapolis, Ind., NCAA, Oct.
1999). Revenue generated by athletics programs is not a consideration in
determining whether equal athletics opportunities are available to both men
and women. A school has the responsibility to ensure that its men's and
women's athletics programs provide equitable services. To do so, it must
ensure that appropriate funds are expended for both men's and women's
programs without regard to their ability to generate revenue.

Men continue to hold the majority of top positions in intercollegiate
athletics. We found only one female athletics director among the 259 NCAA
Division I schools responding to our survey for school year 1990- 91. 19
More recently, however, private researchers who surveyed NCAA member schools
in school year 1997- 98 found increased numbers of female athletics
directors who are responsible for administering both men's and women's
athletics programs. Nevertheless, women were still the minority. These
researchers identified 23 women in such positions at responding schools in
NCAA Division I, 41 in Division II, and 102 in Division III. 20 In addition,
we identified 6 women athletics directors at the 114 NCAA schools sponsoring
Division I- A football, as of October 1999.

Title IX and Federal We found widespread agreement among those we
interviewed that title IX

Enforcement Have has increased women's participation in both academics and
intercollegiate

athletics even though the law's effect cannot be isolated from the effects
of Contributed to Greater

other legal and social changes that have aimed to increase gender equity.
Gender Equity in

There is also widespread agreement that enforcement efforts led by Higher
Education

Education's OCR have played a role in title IX's effect on women's
increasing participation in higher education programs. These efforts have
included developing policy guidance, providing technical assistance to
schools and associations, investigating and resolving complaints, conducting
compliance reviews, and working with the Department of Justice to file
friend- of- the- court briefs in significant title IX litigation. OCR's
enforcement efforts emphasize collaboration and negotiation.

Extent of Title IX's Effect Education and athletics officials, researchers,
and legal expertsï¿½both

Cannot Be Assessed critics and supporters of title IX policyï¿½told us they
believe that title IX

Without Taking Other has had a significant and favorable effect on women's
participation in

Factors Into Account postsecondary education because it has eliminated many
explicit barriers

to opportunities in higher education for women. More specifically, they 19
Intercollegiate Athletics: Compensation Varies for Selected Personnel in
Athletic Departments( GAO/ HRD- 92- 121, Aug. 19, 1992). 20 Vivian Acosta
and Linda Jean Carpenter, “Women in Intercollegiate Sport: A
Longitudinal Study- Twenty- One Year Update, 1977- 1998” (1998). This
study was based on a survey administered to all schools that were active
members of NCAA in school year 1997- 98 and that had a women's athletics
program. The researchers received completed surveys from 234 of 308 Division
I schools, 196 of 261 Division II schools, and 280 of 363 Division III
schools.

said discriminatory practices such as quota systems limiting the number of
women admitted to graduate and public undergraduate programs and higher
admissions standards for women than for men largely disappeared with title
IX's passage. 21 Among the examples cited of pre- title IX discrimination in
admissions were the following:

A prominent public university restricted women to no more than 45 percent of
its undergraduate population annually. An Ivy League university's school of
veterinary medicine admitted two

women per year. An agriculture college required women's SAT scores to be 30
to 40 points

higher than men's to gain admission. A prominent private university's school
of nursing did not permit

married women to be students. In addition, title IX allowed women to
participate in various academic and athletics programs and activities that
were previously available only to men.

Those we spoke with noted, however, that women's increased participation was
a trend that began before title IX's passage. For example, the percentage of
female undergraduates increased before enactment of title IX from about one-
quarter of undergraduate students in 1950 to 43 percent in 1971. This
suggests that other laws, together with changing social views, likely played
a role in shaping the trends we observed. For example, the Equal Pay Act
establishing equal pay for men and women was enacted in 1963, and
legislation barring sex discrimination in employment was enacted in 1964.
Such efforts to bring about more equitable treatment of women in the
workplace may have encouraged women to enroll in postsecondary schools and
to participate in predominantly male fields of study at colleges and
universities. The women's movement and other social trends also contributed
to changing attitudes about women's roles. Finally, changes in federal
student financial aid policy in the early 1970s gave more middle- class
students, men and women alike, greater access to higher education, resulting
in higher enrollment levels for both genders.

21 In a 1971 hearing before a House Committee, the Director of the
Department of Health, Education and Welfare's OCR stated that university
officials candidly told the office that, in many cases, they had higher
standards, such as higher grade point average requirements, for women than
for men.

While those we interviewed also agreed that title IX has had the effect of
increasing women's participation in intercollegiate sports, their views
varied about title IX's effects on men's sports. According to OCR officials,
it is a misperception that title IX is responsible for declines in the
number of men's sports opportunities. OCR guidance does not require cutting
men's teams. Schools choose their own methods for complying with title IX,
and none of the OCR options for compliance necessitate cuts in men's
athletic programs. Nonetheless, some said title IX has had a substantial
detrimental effect on men's sports, citing as evidence that some schools
eliminated men's intercollegiate sports teams to add women's teams. Their
view is that schools are in effect compelled to cut men's teams in light of
decreasing athletics budgets and the threat of a title IX investigation or
lawsuit. Others disagreed, saying that the law itself has not significantly
harmed men's opportunities and that decreases in some men's sports teams are
caused, in part, by declining interest in those sports. They said schools
can achieve compliance without cutting men's sports teams by transferring
resources from more expensive men's programs to financially vulnerable men's
and women's programs.

As with participation trends in academics, factors other than title IX may
also have influenced participation in intercollegiate sports. For example,
from the mid- 1960s to the early 1970s, just before title IX was enacted,
men's annual participation rates in intercollegiate sports declined and
women's participation rose. 22 Changing social and cultural attitudes appear
to have contributed to women's increased interest and participation in
athletics before title IX was passed.

22 Even though the number of male sports participants rose during this
period from an estimated 227, 000 to 248,000, the number of full- time male
undergraduates rose at a faster rate. As a result, the estimated
participation rate fell from 11. 9 to 10. 4 percent between the 1966- 67 and
1971- 72 school years. During the same period, the estimated number of
female intercollegiate participants increased from about 15, 000 to about
30, 000, and the participation rate rose from 1. 1 percent to 1. 7 percent.

Although one study asked a limited number of respondents to identify the
factors that led to gains in women's participation, we did not find any
studies that directly assessed the effect of title IX apart from other
factors, such as similar state laws. 23 According to the researchers we
contacted, there is no reliable method for separating title IX's effect from
the effect of other factors.

Federal Enforcement Has We found widespread agreement among the officials,
observers, and

Contributed to Title IX's experts we spoke with that efforts to enforce
title IX have contributed to

Effect the law's effect on women's participation in academics and in

intercollegiate athletics. Although Education had not used its most severe
legal sanctions to enforce compliance with title IX at colleges and
universitiesï¿½funding termination or referral to the Department of Justice
for enforcement by federal courtsï¿½it has facilitated change by using
enforcement means short of these measures. These measures include issuing
letters of violation and, in the absence of formal findings of violations,
obtaining voluntary resolution agreements to address concerns OCR has
identified. 24 The legal experts we interviewed said OCR's other enforcement
efforts, along with court cases filed against schools by private parties,
have been important in establishing accountability and deterring
noncompliance. They and others added that most title IX disputes do not
involve either OCR or the courts because schools frequently resolve title IX
complaints through internal campus grievance procedures required by
regulations implementing title IX.

23 The study was based on a telephone survey administered in 1986 to 61
selected respondents in 12 states with state title IX laws, including state
title IX coordinators, vocational education gender equity coordinators, and
legislators. More than one- third of the 61 respondents identified the
federal law as the cause for gains in women's participation even though most
respondents considered their state law to be stronger than the federal law.
Most other respondents cited a combination of factors, including the federal
law. (See Phyllis W. Cheng, “The New Federalism and Women's
Educational Equity: How the States Respond,” paper presented at the
Association of American Geographers 1988 Annual Meeting; Phoenix, Ariz.;
Apr. 7, 1988.)

24 OCR's data system for cases resolved from fiscal years 1982 through 1993
indicates that the Department initiated administrative procedures that could
have led to a suspension of federal funding in cases where OCR found that
school districts had violated title IX and in cases where OCR found that
colleges and school districts had violated other discrimination laws. Since
fiscal year 1994, according to OCR officials, OCR has issued four Notices of
Opportunity for Hearing, a step in the process to terminate a school's
funding; none of these concerned title IX issues. Also, since fiscal year
1994, OCR referred 21 cases to the Department of Justice, none of which
concerned title IX. Eighteen of these involved a single event and
allegations of racial discrimination.

OCR's most severe enforcement tool is its ability to recommend that
Education undertake a termination process by which a school can be
prohibited from receiving federal funding, including participation in
federal student loan programs. OCR can also refer cases to the Department of
Justice for prosecution. Since title IX was enacted, however, Education has
neither suspended nor terminated a college's or university's federal
funding, nor has OCR referred to the Department of Justice a case against a
postsecondary institution for a title IX violation. The decision not to use
these sanctions has been criticized by some and lauded by others. Some
individuals we interviewed said that OCR's enforcement has not been
aggressive enough and that OCR has gone to great lengths to work out
compromises rather than refer a case to the Department of Justice for
prosecution. However, title IX requires that OCR seek voluntary resolution
of violations before terminating a school's funding. According to OCR
officials, when the agency finds violations, it has been able to minimize
confrontation and reduce the harm that would be caused by loss of federal
funds by obtaining voluntary compliance. It ensures that voluntary
compliance agreements, in fact, remedy violations by monitoring
implementation of the agreements. Enforcement efforts also include issuing
regulations and policy guidance, communicating the requirements of title IX,
resolving complaints, and conducting compliance reviews.

OCR's Policy Guidance Although OCR has developed regulations and provided
guidance on a

Emphasizes Athletics and Other broad range of title IX issues,
intercollegiate and interscholastic athletics

Issues have received considerable attention over the years. 25 Examples of
OCR's

development and communication of athletics policies include such documents
as a 1979 policy interpretation that introduced the three- part test 26 that
OCR uses to assess equity in opportunities for athletics participation; a
1990 athletics investigator's manual; a clarification of its intercollegiate
athletics policy guidance in 1996; and a clarification of its

25 OCR's athletics policies are designed for intercollegiate athletics, but
the general principles often apply to club, intramural, and interscholastic
athletics programs, which are also covered by the regulations.

26 Under the three- part test, intercollegiate athletics programs may
establish compliance with title IX by meeting any one of the following
criteria: (1) the number of male and female participants is substantially
proportionate to their full- time undergraduate enrollments, or (2) the
school has a history and continuing practice of expanding the program for
the underrepresented gender (usually women's programs), or (3) the school is
fully and effectively accommodating the interests and abilities of the
underrepresented gender in intercollegiate sports. See app. IV for details.

policy on athletic scholarships in July 1998. OCR also appointed a national
coordinator for title IX athletics in 1994.

When individuals have brought lawsuits, court rulings have generally upheld
the policy guidance that OCR has developed. For example, members of Brown
University's intercollegiate women's gymnastics and volleyball teams sued
the university after it eliminated funding for and reduced the status of the
teams. 27 They argued that the university had failed to comply with
regulations concerning men's and women's opportunities for participation in
intercollegiate athletics as interpreted by the Department's three- part
test. Brown University challenged the three- part test and argued that it
had complied with the regulations requiring that the university be equally
effective in meeting the interests and abilities of men and women
undergraduates in intercollegiate sports. Through a series of four separate
decisions, each of the three parts of OCR's three- part compliance test was
considered. In the third decision, the trial judge discussed all three
parts, upholding the validity of the OCR compliance test as it was used to
enforce title IX. 28

OCR has developed title IX policy guidance to address sexual harassment and
sex discrimination in a number of other areas, including the assignment of
pregnant and parenting students; health insurance coverage for pregnancy;
preadmission inquiries into marital and parental status; religious
exemptions; hiring and assignment of teachers by gender, vocational, and
educational opportunities; and graduate and professional school admissions.
OCR has also provided information and guidance in other areas with several
publications covering title IX in general and others focused on specific
concerns. Title IX: 25 Years of Progressdiscusses women's progress since
title IX was enacted but also helps communicate title IX requirements.
Similarly, OCR documents, including Title IX Grievance Procedures: An
Introductory Manual, Title IX and Sex Discrimination, and Nondiscrimination
on the Basis of Sex in Federally

27 Cohen v. Brown University, 809 F. Supp. 978 (D. R. I. 1992)( Cohen I);
991 F. 2d 888 (1st Cir. 1993)( Cohen II); 879 F. Supp. 185 (D. R. I. 1995)(
Cohen III); 101 F. 3d 155 (1st Cir. 1996)( Cohen IV).

28 This third decision is generally identified as Cohen III, 879 F. Supp.
(D. R. I. 1995). For other cases, see Boucher v. Syracuse University, 164 F.
3d 113 (2d Cir. 1999); Roberts v. Colorado State Board of Agriculture, 998
F. 2d 824 (10th Cir. 1993); Kelley v. Board of Trustees of the University of
Illinois, 35 F. 3d 265 (7th Cir. 1994); Horner v. Kentucky High School
Athletic Association, 43 F. 3d 265 (6th Cir. 1994); and Favia v. Indiana
University, 7 F. 3d 332 (3d Cir.

1993).

Assisted Programs, provide specific details concerning title IX
requirements. OCR publicizes its policies and procedures through
publications, the press, Internet web pages, and presentations at
conferences such as those sponsored by NCAA. OCR also responds directly to
inquiries from schools and organizations regarding interpretations of title
IX.

Complaint Investigations Between fiscal year 1982 (the earliest year for
which records were

Covered a Broad Range of Title available 29 ) and fiscal year 1998,
individuals and groups filed 5, 227

IX Issues complaints related to title IX at postsecondary institutions. 30
These

complaints dealt with such issues as admissions, athletics, employment,
harassment, and student health benefits. Focusing on complaints received
since fiscal year 1994 provides a clearer view of OCR's complaint resolution
efforts because that was the first year in which OCR's case information
system began tracking the resolution of each issue in a case. 31 Thus, this
tracking system makes it easier to identify the resolution of issues related
specifically to title IX. 32

29 The Department of Health, Education, and Welfare handled title IX
complaints before the establishment of the Department of Education. We were
not able to obtain data on numbers of complaints or their resolution for
fiscal years 1972 through 1981.

30 Title IX postsecondary complaints have been a minor proportion of all
complaints filed with OCR, representing 9 percent of the approximately 61,
000 complaints OCR received and 30 percent of all complaints related to
postsecondary institutions. OCR's other civil rights enforcement activities
include laws concerning discrimination on the basis of race, color, and
national origin (Title VI of the Civil Rights Act of 1964); age (Age
Discrimination Act of 1975); and disabilities (Section 504 of the
Rehabilitation Act of 1973 and Title II of the Americans with Disabilities
Act of 1990).

31 A previous GAO report discussed OCR's case information system and OCR's
revised approach for handling complaints. (See Department of Education:
Resolving Discrimination Complaints Has Improved With New Processing System(
GAO/ HEHS- 99- 4R, Mar. 23, 1999).

32 OCR's earlier case information system, which provides data for fiscal
years 1982 to 1993, indicates the resolution of cases, but 1,419 of the
3,834 title IX postsecondary complaints in the earlier data system also
included nontitle IX issues with no indication of how those issues were
decided. OCR concluded that 1, 656 of these cases were inappropriate for
OCR. In 835 cases, no change or corrective action was required to bring the
schools into compliance; in 1,214 cases, change was facilitated. In 129
cases, the result was unclear. OCR's disposition on specific issues was not
indicated.

During fiscal years 1994 through 1998, OCR received 1,395 postsecondary
title IX complaints and acted on 1, 455 complaints, including those that had
been filed earlier (see table 3). 33 OCR identifies three types of
dispositions: a change facilitated, no change required, and complaints
inappropriate for OCR. OCR concluded that 860 complaints (59 percent) were
inappropriate for OCR action. 34 In 279 resolved complaints (47 percent),
OCR officials concluded that the filing of the complaint or OCR's
investigation and subsequent action facilitated a change to remedy the
alleged violations. 35 In some instances, the school resolved the issue
raised by the complainant. In other instances, OCR negotiated an agreement
for a change. In 316, or 53 percent, of resolved complaints, OCR concluded
that no change was required because, for example, OCR found no violation of
title IX or found insufficient evidence to support a finding of
noncompliance. Complaints with a change facilitated covered a wide range of
prominent athletics issues (see app. IV). Of the 136 cases involving
athletics, 27 cases were inappropriate for OCR. Among the remaining 109
athletics cases, OCR facilitated change in 91 cases (83 percent).

33 During fiscal years 1994 through 1998, OCR acted on a total of 25,236
complaints, including 6,838 concerning postsecondary education. As of the
end of fiscal year 1998, 437 postsecondary complaints were pending.

34 For 19 percent of these complaints, OCR determined that another agency
(usually EEOC) had primary jurisdiction. The other complaints were not
investigated for a variety of reasons; for example, the school or issue was
outside OCR's jurisdiction, or the complainant did not supply sufficient
information.

35 These results do not include allegations of civil rights violations under
laws other than title IX, such as allegations of racial or age
discrimination, or discrimination on the basis of disability. During fiscal
years 1994 through 1998, 612 (42 percent) of title IX postsecondary
complaints also involved allegations of violations of other civil rights
laws.

Table 3: Disposition of Postsecondary Title IX Complaints With the Office
for Civil Rights, Fiscal Years 1994 Through 1998

Change No change

Inappropriate Issue facilitated a required b for OCR c Total

Athletics 91 18 27 136 Sexual harassment 73 109 265 447 Grievance or other
procedures 51 35 54 140

Employee issue 24 36 219 279 Retaliation 21 51 65 137 Evaluation and grades
15 49 102 166 Admissions 13 39 75 127 Other student rights 11 16 31 58
Financial assistance 5 11 14 30 Discipline 1 16 30 47 Unspecified
educationrelated service issue 1 2 53 56

Other 39 58 129 226 Total unduplicated count of complaints d 279 316 860 1,
455

Note: Some complaints covered more than one type of issue. The table
indicates OCR's disposition for each type of issue, such as admissions or
athletics. a Includes those complaints in which at least one issue resulted
in the complainant withdrawing the

complaint with change by the institution alleged to have violated title IX
or in OCR negotiating an agreement for corrective action. This includes
complaints in which one or more issues led to change regardless of whether
other issues led to change, did not require change, or were inappropriate
for OCR. b Includes those complaints in which (1) the complainant withdraws
the complaint without change by

the institution alleged to have violated title IX, (2) OCR determined that
there was insufficient evidence to support a finding of a violation, or (3)
OCR concluded that no violation occurred. This includes complaints in which
no change was facilitated in connection with any issue and in which OCR
decided no change was required for one or more issues, regardless of whether
other issues were inappropriate for OCR. c Includes complaints that (1) were
referred to another agency (EEOC or the Department of Health and

Human Services, for example) or (2) involved an allegation over which OCR
had no jurisdiction. This does not include any complaints in which one or
more issues led to change or in which OCR decided no change was required. d
Total does not equal the sum of the number of complaints because 298 of them
involved issues of

more than one type.

OCR Has Initiated Fewer Title IX OCR can initiate compliance reviews.
According to OCR officials,

Postsecondary Compliance compliance reviews are selected based on numerous
factors, including

Reviews in the 1990s Than in survey data, OCR complaint information, and
information provided by

Previous Years parents, education groups, media, community groups, and the
public.

These targeted reviews typically address alleged violations that are broader
in scope and affect a larger number of individuals than complaint
investigations, which often involve a smaller number of individuals. During
fiscal years 1982 through 1989, OCR initiated an average of 39 postsecondary
title IX reviews each year. That number dropped to an average of about 10
per year in fiscal years 1990 through 1995 and to zero in fiscal years 1996
through 1998. In fiscal year 1999, OCR began two title IX postsecondary
compliance reviews concerning intercollegiate athletics. According to OCR
officials, the decline resulted from resource constraints and a focus on
other title IX priorities. Rather than conducting as many compliance
reviews, OCR has emphasized the development and dissemination of policy
guidance to assist postsecondary schools in preventing title IX violations.

Recent title IX compliance reviews have been focused on athletics (see table
4). This represents a change from earlier years, when reviews tended to
focus more on admissions and other matters such as sexual harassment. Of the
41 title IX postsecondary compliance reviews OCR acted on in fiscal years
1994 through 1998, 30 involved athletics issues. In terms of the changes
facilitated, reviews focused on athletics were even more prevalent,
accounting for 29 of the 33 changes reported by OCR.

Table 4: Disposition of Title IX Postsecondary Compliance Reviews, Fiscal
Years 1994 Through 1998

No change Issue Change facilitated a required b Total

Athletics 29 1 30 Grievance or other procedures 2 0 2

Sexual harassment 2 3 5 Admissions 0 5 5 Other 1 5 6 Total unduplicated
count of reviews c 33 8 41

Note: A single review may involve more than one title IX issue. It may also
cover allegations of civil rights violations in addition to violations of
title IX, such as retaliation, racial or age discrimination, or
discrimination on the basis of disability. a Cases include those in which at
least one issue resulted either in a change made by the institution

reviewed or in OCR negotiating an agreement for a change. b Cases include
those in which OCR (1) determined that there was insufficient evidence to
support a

finding of a violation or (2) concluded that no violation occurred. c Total
does not equal the sum of the number of cases because some cases involved
issues of more

than one type. Six compliance reviews involved issues of more than one type.

Agency and Athletics We provided a draft of this report to Education and an
earlier draft to

Association Comments Education, NCAA, and NAIA for comment. We discussed the
contents with

their representatives. In its comments, the Department said that, in
general, and Our Evaluation

the report provided a good overview of OCR's title IX postsecondary
education enforcement efforts. Both Education and NCAA also provided
technical comments, which we incorporated where appropriate. Education's
comments are included in appendix V.

As arranged with your office, unless you announce its contents earlier, we
plan no further distribution of this report until 7 days after the date of
this letter. At that time, we will send copies to the Honorable Richard W.
Riley, Secretary of Education; representatives of NCAA and NAIA; and
appropriate congressional committees. We will make copies available to
others on request. Please contact me at (202) 512- 7215 if you or your staff
have any questions. Other contacts and staff acknowledgments are listed in
appendix VI.

Sincerely yours, Marnie S. Shaul, Director Education, Workforce, and

Income Security Issues

Appendi Appendi xes x I

Scope and Methodology We focused our review of title IX and higher education
on (1) men's and women's participation in higher education academic
programs, (2) men's and women's participation in intercollegiate athletics
programs at 4- year colleges and universities, and (3) information about
title IX's effect on participation rates and the changes due to federal
enforcement. As you requested, we are also providing information concerning
women's participation as faculty members and athletics directors and
intercollegiate athletic expenditures. In conducting our review, we relied
on data obtained from Education and intercollegiate athletics associations
which, although not verified, are considered the best available and are used
extensively by researchers. Because recent information on intercollegiate
athletic expenditures was not available from these sources at the time of
our review, we also used data published by The Chronicle of Higher
Education, as well as additional data available on its website. Education
plans to make such data available in the future.

To determine men's and women's participation in higher education academic
programs, we gathered and analyzed data on the numbers of men and women who
attended institutions of higher education and received bachelor and selected
first professional degrees. We also analyzed estimates of male and female
students who received financial aid and the average amounts received. We
obtained these data from the Department of Education's National Center for
Education Statistics (NCES). Data on the numbers of enrolled students and
the numbers of degree recipients came from fall enrollment and completion
components of NCES' Integrated Postsecondary Education Data System, which
provides data for fall 1986 and succeeding years, and its predecessor, the
Higher Education General Information Survey, which provides data for earlier
years. We used data for all higher education institutions in the 50 states
and the District of Columbia and excluded data for U. S. territories. Higher
education institutions include 2- year and 4- year colleges and universities
that offer associate or more advanced degrees. Full- time enrollment data
for the 1960s did not include a count of full- time extension students.

To determine men's and women's receipt of financial aid, we obtained and
analyzed data from an NCES study funded by Education, “National
Longitudinal Study of the High School Class of 1972.” For similar data
from a more recent period, we used NCES' National Postsecondary Student Aid
Survey for the 1995- 96 school year. In analyzing the distribution of
financial aid by gender, we considered the proportion of men and women
receiving aid and the average amounts of aid they received in loans, grants,
and scholarships. We used t- tests to assess the statistical significance of

differences by gender for all undergraduate postsecondary students and
separately for five types of institutions: (1) public 4- year, (2) public
lessthan- 4- year, (3) private not- for- profit 4- year, (4) private not-
for- profit lessthan- 4- year, and (5) proprietary (for- profit)
institutions. To further investigate the differences in the proportion of
male and female students receiving grants and scholarships, we estimated the
average proportion of men and the average proportion of women receiving
grants in groups based on students' financial standings as measured by their
expected family contribution and their estimated costs of attendance.

To analyze participation in intercollegiate athletics at 4- year colleges
and universities, we gathered participation statistics from the two largest
4- year intercollegiate sports associationsï¿½the National Collegiate Athletic
Association (NCAA) and the National Association of Intercollegiate Athletics
(NAIA). To estimate rates of participation in intercollegiate sports, we
divided the sum of estimated participants for both associations by the
estimated total full- time undergraduate enrollment at all 4- year
institutions. In several respects, data concerning athletics participation
do not provide a precise estimate of intercollegiate participation. For
example, both NCAA and NAIA provide estimates of the number of
intercollegiate athletes that represent the sum of the number of athletes on
each team at each school. Some athletes participate on more than one team
and are counted more than once in these data. Some 4- year institutions are
members of both NCAA and NAIA. By adding participation statistics for both
associations, we counted the athletes at those schools twice. According to
NCAA, as of April 1999, 61 schools were members of both associations. Based
on the number of teams and team size averages for the 1997- 98 school year,
we estimated that these schools accounted for about 3 percent of male
participants and 2 percent of female participants.

Estimates of the numbers of participants in many years were based on
national average squad sizes, 1 rather than a census of athletes on each
team. Some 4- year colleges and universities are not members of either NCAA
or NAIA but sponsor varsity intercollegiate sports programs. As of fall
1996, NCAA and NAIA schools enrolled an estimated 88 percent of all full-
time undergraduate students at all 4- year colleges and universities. The
number of student athletes at NCAA and NAIA member schools represents nearly
all student athletes at 4- year schools, according to association officials.
NCAA data do not include participants for sports sponsored by

1 The squad size is the average number of players on the team.

fewer than 10 schools, and NAIA data include a few schools located in
Canada.

To analyze intercollegiate athletic expenditures, we obtained information
from The Chronicle of Higher Education, which collected Equity in Athletics
Disclosure Act (EADA) reports from 858 of the 959 NCAA member schools for
school year 1998- 99, the most recent year for which data were available.
These schools were active association members and sponsored both men's and
women's athletic programs. To calculate expenditures per participant, we
analyzed information only for schools that reported both expenditures and
the number of intercollegiate athletic participants. As a result, some
calculations were based on information provided by fewer than 858 schools.
In addition to calculating average expenditures by gender, we calculated
averages for groups of colleges and universities (NCAA Division I- A, I- AA,
I- AAA, II and III). For each category of expenditures reported by the
schools (recruiting, scholarships, coaches' salaries, and operations), we
aggregated expenditures and divided them by the total number of male and
female participants, respectively. To analyze intercollegiate athletic
revenue, we obtained data from the 1997- 98 NCAA Gender- Equity Study, which
presents data provided by 747 of the 1031 NCAA member institutions.

To obtain information on the effects of title IX and specifically the role
of federal enforcement in realizing those effects, we performed literature
searches in general, government, and legal data sources, and discussed title
IX with 24 education and athletics officials, researchers, legal experts,
and others. From Education, we obtained OCR publications concerning title IX
and detailed data concerning all postsecondary title IX cases (compliance
reviews and complaints) from fiscal year 1982 through fiscal year 1998. We
interviewed OCR and other Department officials, obtained written responses
to inquiries, and reviewed documents concerning several selected cases.

Federal Agencies With Title IX Enforcement

Appendi I I x Responsibilities The Department of Justice coordinates title
IX enforcement. There are 29 federal agencies that have responsibility for
enforcing title IX. However, until recently only four agencies had issued
title IX regulations: the Department of Agriculture, Department of
Education, Department of Energy, and the Department of Health and Human
Services. On August 30, 2000, 20 federal agencies and the Department of
Justice issued a title IX common rule to eliminate discrimination based on
sex in education programs or activities that use federal money or other
assistance. The Department of Justice is assisting the following federal
agencies in drafting separate title IX regulations: Department of Labor;
Institute for Museum and Library Sciences; National Endowment for the Arts;
National Endowment for the Humanities; and the United States Information
Agency. The Department of Justice is also drafting a delegation agreement
that will explain the enforcement responsibilities among agencies in cases
where an educational institution receives funding from more than one federal
agency.

The 29 federal agencies and departments with title IX enforcement
responsibilities are the following:

Agency for International Development Corporation for National and Community
Service Department of Agriculture Department of Commerce Department of
Defense Department of Education Department of Energy Department of Health
and Human Services Department of Housing and Urban Development Department of
the Interior Department of Justice Department of Labor Department of State
Department of Transportation Department of the Treasury Department of
Veterans Affairs Environmental Protection Agency Federal Emergency
Management Agency General Services Administration Institute for Museum and
Library Sciences National Aeronautics and Space Administration National
Archives and Records Administration

National Endowment for the Arts National Science Foundation National
Endowment for the Humanities Nuclear Regulatory Commission Small Business
Administration Tennessee Valley Authority United States Information Agency

Supplemental Information Concerning Title IX

Appendi xI I I and Higher Education Table 5 shows the data that support
figure 1 in the letter portion of this report. Data are for first
professional degrees for law, medicine, and dentistry and for bachelor
degrees in the other fields. We computed these figures using NCES' data on
awards of degrees.

Table 5: Percentage of Degrees Awarded to Women in Predominantly Male Fields
of Study, School Years 1971- 72 and 1996- 97

Women as percentage of 1971- 72 1996- 97

total Men Women Men Women 1971- 72 1996- 97

Zoology 4, 325 1, 197 1, 751 1, 775 22 50 Business a 109,688 11, 578 116,
512 110,096 10 49 Political science b 22,845 5, 290 16, 081 12,892 19 44 Law
c 20,266 1, 498 22, 548 17,531 7 44 Medicine d 8,423 830 9, 121 6, 450 9 41
Dentistry e 3,819 43 2, 387 1, 397 1 37 Physical science f 17,663 3, 082 12,
165 7,255 15 37 Computer science g 2,941 461 18, 041 6,731 14 27 Engineering
h 50,638 526 62, 510 12,491 1 17 Note: We identified predominantly male
fields as those in which, in school year 1971- 72, (1) women represented
fewer than 25 percent of degree recipients and (2) at least 5,000 bachelor
or 1, 000 first professional degrees were awarded. The 25 percent figure is
based on the same criteria used by the Labor Department to define
nontraditional occupations. a Includes degrees in business management and
administrative services, marketing operations and

marketing and distribution, and consumer and personal services. b Includes
degrees in political science and government but excludes degrees in public
administration

and international relations. c Includes bachelor of law and doctor of law
degrees.

d Doctor of medicine degree. e Includes doctor of dental surgery and doctor
of dental medicine degrees. f Includes degrees in general physical sciences,
astronomy, astrophysics, atmospheric science and meteorology, chemistry,
geology, miscellaneous physical sciences, physics, science technologies, and
other physical sciences. g Includes general degrees in computer science and
information science, computer programming, data

processing technology, information science and systems, and computer
systems. h Includes degrees in engineering and engineering- related
technologies, such as electrical and

electronic technologies and industrial production technologies.

Table 6 shows the data that support figure 2 in the letter portion of this
report. We computed these figures using data from the NCAA, the NAIA, and
the NCES fall enrollment data set.

Table 6: Estimated Participation Rates in Intercollegiate Sports at 4- Year
Colleges and Universities, School Years 1966- 1967 to 1998- 1999

Full- time Participants in undergraduates at

intercollegiate 4- year institutions

athletics (in Participation rate as a

(in thousands) b thousands, estimated) percentage c Year a Men Women Men
Women Men Women

1966- 67 1,911 1,346 227 15 11.9 1. 1 1971- 72 2,385 1,800 248 30 10.4 1. 7
1976- 77 2,304 2,000 236 63 10.2 3. 1 1981- 82 2,363 2,290 216 86 9.1 3. 7
1985- 86 2,330 2,299 249 126 10.7 5. 5 1986- 87 2,322 2,334 239 122 10.3 5.
2 1987- 88 2,344 2,410 229 122 9.8 5. 1 1988- 89 2,387 2,507 231 124 9.7 5.
0 1989- 90 2,409 2,576 225 122 9.4 4. 7 1990- 91 2,455 2,637 232 125 9.5 4.
7 1991- 92 2,474 2,673 230 118 9.3 4. 4 1992- 93 2,472 2,691 227 120 9.2 4.
5 1993- 94 2,454 2,682 231 126 9.4 4. 7 1994- 95 2,430 2,707 222 129 9.1 4.
8 1995- 96 2,418 2,750 236 145 9.7 5. 3 1996- 97 2,422 2,802 235 150 9.7 5.
3 1997- 98 2,450 2,877 234 157 9.5 5. 5 1998- 99 d d 237 167 d d a Annual
estimates of athletics participation were available beginning in 1981. In
previous years, NCAA did not compile data annually but did so at 5- year
intervals. Enrollment data for full- time undergraduates at 4- year schools
by gender were not available for 1982 through 1984. b The numbers given are
fall enrollment figures.

c These estimated participation rates were calculated by dividing the
estimated number of NCAA and NAIA participants by the total number of full-
time undergraduates at 4- year colleges and universities. See app. I for a
discussion of the limitations of these estimates. d Data were not available.

Supplemental Information Concerning OCR

Appendi xI V

Cases Involving Intercollegiate Athletics Because athletics has been a
controversial aspect of title IX enforcement, we conducted additional
analyses of OCR's actions in this area. From fiscal years 1994 through 1998,
OCR acted on 166 cases (136 complaints and 30 compliance reviews) involving
athletics issues. OCR concluded that 27 of the complaint cases were
inappropriate for OCR. The 139 remaining cases covered 16 different
athletics issues identified by OCR staff. Table 7 shows the 10 issues most
frequently cited in these cases.

Table 7: Top 10 Athletics Issues in the 139 Cases OCR Acted On, Fiscal Years
1994 Through 1998

Issue Number of cases

Accommodation of interests and abilities (opportunities to participate in
intercollegiate sports) a 86

Athletics financial assistance and scholarships 77 Athletics equipment,
supplies, and facilities 76 Assignment and training of coaching staff 69
Opportunity to receive coaching 67 Travel and per diem 60 Athletics
recruitment 58 Medical and training facilities and services 55 Scheduling 53
Support services 52 Note: Cases typically involved more than one issue. In
17 cases, OCR staff indicated a general athletics issue code without
specifying any of the codes shown in this table. According to OCR officials,
a complaint concerning a specific athletics issue at a school sometimes
prompted investigations of other athletics issues at the school. a These
include cases identified as involving issues concerning accommodation of
interests and

abilities, denial of participation, or recruitment.

Among the various issues included in an athletics investigation, OCR
assesses schools' compliance with requirements concerning equitable
opportunities to participate in intercollegiate sports. To comply, schools
must meet any one of the three following criteria, which Education refers to
as a three- part test: (1) opportunities for intercollegiate- level
participation for male and female students are provided in numbers
substantially proportionate to their respective enrollments, or (2) the
institution can show a history and continuing practice of program expansion
that is demonstrably responsive to the developing interests and abilities of
members of the underrepresented gender, or (3) it can be demonstrated that
the interests and abilities of members of the

underrepresented gender have been fully and effectively accommodated by the
present program. According to OCR officials, in no case did OCR agree to
hold a school to a standard below that indicated in its regulations and
publications, although schools were given time to come into compliance.

In more than half (74) of the 139 athletics cases acted on by OCR during
this period, OCR assessed schools' compliance with the three- part test and
either determined that the school had complied or determined which part of
the three- part test the school would most likely meet. In each case the
school selected which part of the three- part test it would use. Figure 3
shows how many of these schools chose each part.

Figure 3: Means of Resolving Cases Involving the Three- Part Test, Fiscal
Years 1994 Through 1998

Number of OCR Cases

50

49

40 30

21

20 10

4

0 Substantial

History and Full and Effective Proportionality

Continuing Program Accommodation of Expansion

Interests and Abilities

Note: The second and third parts focus on expanding the program for the
underrepresented gender and the full and effective accommodation of the
interests and abilities of the underrepresented gender. In each of the cases
shown, the underrepresented gender was female.

In 21 cases, schools were found to be in compliance or chose to come into
compliance with the first part of the three- part test by achieving
substantial proportionality in intercollegiate sports participation. OCR
assesses proportionality by comparing the percentage of participants in
intercollegiate athletics who are women with the percentage of full- time
undergraduates in the student body who are women, and comparing the
percentage of participants who are men with the percentage of full- time
undergraduates who are men. OCR would consider opportunities to be
substantially proportionate where the number of opportunities that would be
required to achieve proportionality would not be sufficient to support a
viable team. If, for example, 50 percent of full- time undergraduates are
women and 47 percent of intercollegiate athletes are women (47 women and 53
men), six additional women would be needed to make women's participation
proportionate. Because this number is too few to form a team, OCR would
regard the school as having substantially proportionate participation. If,
on the other hand, the school had twice as many women and men participating
(94 women and 106 men), 12 additional women would be required to make
women's participation proportional. If OCR determined that 12 additional
participants were sufficient to support a viable team for which there was
interest and ability on campus, then OCR might determine that participation
opportunities at that institution were not substantially proportionate.
Disparities could also be regarded as substantially proportionate if the
numbers of full- time undergraduate men and women in the student body
unexpectedly changed substantially. OCR allows participants who compete in
more than one sport to be counted as a participant in each sport. As a
result, the total number of participants counted can exceed the actual
number of athletes.

In four cases, schools were found to be in compliance with the second part
of the three- part test by showing a historical and continuing expansion of
the intercollegiate athletics program for the underrepresented gender
(typically women's programs).

In 49 (two- thirds) of 74 cases, schools were found to be in compliance or
chose to come into compliance with the third part of the three- part test.
This required that they provide intercollegiate sports teams for women where
sufficient numbers of women were interested in participating in a particular
sport, where students had sufficient ability to sustain an intercollegiate
team, and where there were opportunities to compete with teams at other
schools.

In addition to these 74 cases, OCR identified 10 cases that were resolved
before fiscal year 1994. Two of the 10 schools chose to come into compliance
through the first part (substantial proportionality) and 8 chose the third
part (full and effective accommodation of interests and abilities).

Comments From the Department of

Appendi xV

Education Now on p. 23.

Now on p. 6.

Now on p. 7.

Now on p. 8. Now on p. 8. Now on p. 18.

Now on p. 24. Now on p. 24.

Now on p. 29. Now on p. 35.

Now on p. 39. Now on pp. 39 and 40.

Now on p. 41. Now on p. 41.

Now on p. 42.

Appendi xVI

GAO Contacts and Staff Acknowledgments GAO Contacts David Bellis, Assistant
Director, (415) 904- 2272 Benjamin Pfeiffer, Senior Analyst, (206) 287- 4832
Staff

In addition, Benjamin F. Jordan, Jr., Ann P. McDermott, Meeta Sharma,
Acknowledgments

Stanley G. Stenersen, and Stefanie G. Weldon made key contributions to this
report.

Related GAO Products Intercollegiate Athletics: Comparison of Selected
Characteristics of Men's and Women's Programs( GAO/ HEHS- 99- 3R, June 18,
1999).

Department of Education: Resolving Discrimination Complaints Has Improved
With New Processing System( GAO/ HEHS- 99- 47R, Mar. 23, 1999).

Intercollegiate Athletics: Status of Efforts to Promote Gender Equity (GAO/
HEHS- 97- 10, Oct. 25, 1996).

Department of Education: Efforts by the Office for Civil Rights to Resolve
Asian- American Complaints( GAO/ HEHS- 96- 23, Dec. 11, 1995).

Women's Educational Equity Act: A Review of Program Goals and Strategies
Needed( GAO/ PEMD- 95- 6, Dec. 27, 1994).

Intercollegiate Athletics: Compensation Varies for Selected Personnel in
Athletic Departments( GAO/ HRD- 92- 121, Aug. 19, 1992).

(104951) Let er t

GAO United States General Accounting Office

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Appendix I

Appendix I Scope and Methodology

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Appendix I Scope and Methodology

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Appendix II

Appendix II Federal Agencies With Title IX Enforcement Responsibilities

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Appendix III

Appendix III Supplemental Information Concerning Title IX and Higher
Education

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Appendix IV

Appendix IV Supplemental Information Concerning OCR Cases Involving
Intercollegiate Athletics

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Appendix IV Supplemental Information Concerning OCR Cases Involving
Intercollegiate Athletics

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Appendix IV Supplemental Information Concerning OCR Cases Involving
Intercollegiate Athletics

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Appendix V

Appendix V Comments From the Department of Education

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Appendix V Comments From the Department of Education

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Appendix V Comments From the Department of Education

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Appendix V Comments From the Department of Education

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Appendix V Comments From the Department of Education

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Appendix VI

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