Intercollegiate Athletics: Status of Efforts to Promote Gender Equity
(Letter Report, 10/25/96, GAO/HEHS-97-10).

Pursuant to a congressional request, GAO reviewed Department of
Education and National Collegiate Athletic Association (NCAA) efforts to
promote gender equity in intercollegiate athletics by implementing title
IX of the Education Amendments of 1972, focusing on: (1) steps taken by
states to promote gender equity in college athletic programs; and (2)
what existing studies show about progress made since 1992 in promoting
gender equity in intercollegiate athletics.

GAO found that: (1) since 1992, the Department of Education's Office of
Civil Rights (OCR) has focused on prevention of title IX violations by
clarifying its policies on title IX compliance and increasing technical
assistance to help colleges meet title IX requirements while it
continues to investigate the relatively few complaints filed each year;
(2) NCAA created a task force to examine gender equity issues and now
requires certification that athletic programs at all Division I schools
meet NCAA-established gender equity requirements; (3) state efforts to
promote or ensure gender equity in intercollegiate athletics vary
considerably; (4) of the 22 states that reported having laws or other
requirements to specifically address gender equity in intercollegiate
athletics, 13 reported having full- or part-time staff responsible for
gender equity issues; and (5) results from 8 national gender equity
studies show gains in the number of women's sports that schools offer,
number of female students participating in athletics, and percentage of
scholarship funds available to female students, but many women's
athletics programs lag behind those for men in the percentage of female
head coaches, salaries paid to coaches, and proportion of women athletes
to total undergraduate enrollment.

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

 REPORTNUM:  HEHS-97-10
     TITLE:  Intercollegiate Athletics: Status of Efforts to Promote 
             Gender Equity
      DATE:  10/25/96
   SUBJECT:  Civil rights law enforcement
             Sports
             Sex discrimination
             Colleges/universities
             Women
             College students
IDENTIFIER:  NCAA Athletics Certification Program
             NCAA Gender Equity Study
             
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Cover
================================================================ COVER


Report to the Honorable
Cardiss Collins, House of Representatives

October 1996

INTERCOLLEGIATE ATHLETICS - STATUS
OF EFFORTS TO PROMOTE GENDER
EQUITY

GAO/HEHS-97-10

Gender Equity in College Athletics

(104845)


Abbreviations
=============================================================== ABBREV

  NCAA - National Collegiate Athletic Association
  OCR - Office for Civil Rights, Department of Education
  WBCA - Women's Basketball Coaches Association

Letter
=============================================================== LETTER


B-274047

October 25, 1996

The Honorable Cardiss Collins
House of Representatives

Dear Ms.  Collins: 

More than 100,000 American women now participate in intercollegiate
athletics each year.  This is a four-fold increase since enactment of
title IX of the Education Amendments of 1972.  Title IX prohibits sex
discrimination in any education program or activity, including
intercollegiate athletics, at colleges and universities (hereafter
referred to simply as "colleges") receiving federal financial
assistance.\1 Some have noted this increase as a move toward "gender
equity" in athletics--that is, progress toward a fair distribution of
athletic opportunity and resources between men's and women's athletic
programs.  But many have pointed to the gap that still remains in
overall opportunity between men's and women's programs. 

For example, in 1992, the National Collegiate Athletic Association
(NCAA)\2

reported that although the numbers of male and female undergraduates
enrolled at college campuses in 1991 were roughly the same, women
constituted about 30 percent of all student athletes at the time, and
women's programs received about 23 percent of the athletic operating
budgets.  Also in 1992, we reported on the gender and compensation of
athletic department personnel at NCAA Division I schools--typically
those schools with larger athletic programs.  We found, for example,
that men held all the athletic director, head football coach, and
head coach for men's basketball positions, except at one school,
where a woman was the athletic director.  Also, head coaches for
women's basketball always had lower average compensation than head
coaches for men's basketball.\3

To assist your ongoing review of the implementation of title IX, you
asked us for further information on gender equity in intercollegiate
athletics.  Specifically, you asked us to determine (1) the steps the
Department of Education and NCAA have taken since 1992 to promote
equity between men and women participating in intercollegiate
athletics, (2) the steps states have taken to promote gender equity
in athletic programs at colleges, and (3) what existing studies show
about the progress made since 1992 in promoting gender equity in
intercollegiate athletics. 

We gathered information on efforts to promote gender equity at the
national level from the Department and NCAA and obtained information
on states' efforts by surveying each of the 50 states and the
District of Columbia.  We also consulted academic researchers and
professional organizations and identified eight major studies that
evaluated the progress being made toward gender equity in
intercollegiate athletics.  The studies were all national in scope
and were issued since 1992.  We reviewed each study and summarized
its key findings but did not verify the accuracy of the information
presented in the studies.  (See app.  I for details of our scope and
methodology.)


--------------------
\1 In this report, "federal financial assistance" means financial
assistance from the Department of Education or any agencies
delegating jurisdiction to the Department. 

\2 NCAA is a voluntary, unincorporated association that administers
intercollegiate athletics for nearly 1,000 4-year colleges and
universities. 

\3 Intercollegiate Athletics:  Compensation Varies for Selected
Personnel in Athletic Departments (GAO/HRD-92-121, Aug.  19, 1992). 


   RESULTS IN BRIEF
------------------------------------------------------------ Letter :1

In order to continue the move toward gender equity in intercollegiate
athletics, the Department of Education, NCAA, and the states have
taken a variety of actions.  The Department's strategy for addressing
gender equity issues in intercollegiate athletics has been to prevent
title IX violations from occurring as well as to investigate the
relatively few athletic complaints that are filed each year.  The
preventive activities emphasized by the Department's Office for Civil
Rights (OCR) include clarifying its policies on complying with title
IX and making additional technical assistance available to colleges
to help them meet title IX's requirements.  OCR also appointed a
National Coordinator for Title IX Athletics to help effectively
manage these title IX activities.  OCR has put less emphasis on
compliance reviews in recent years. 

Since 1992, NCAA has created a task force to examine gender equity
issues and has adopted a number of its recommendations.  For example,
NCAA now requires certification that the athletic programs at all
Division I schools meet NCAA-established gender equity requirements,
which include preparing an institutional plan describing gender
equity goals and a timetable for their achievement.  NCAA also
educates and trains its member schools in how to comply with title
IX. 

States vary considerably in their efforts to promote or ensure gender
equity in intercollegiate athletics.  For example, 22 states reported
having laws or other requirements specifically addressing gender
equity in intercollegiate athletics, and 13 of the 22 states told us
that they have full- or part-time staff responsible for gender equity
issues.  In addition, eight states use indicators such as female
student athlete participation rates to measure schools' progress
toward gender equity.  Most of the eight states using this indicator
reported that progress has been made toward gender equity since
implementation of state efforts. 

While gender equity has yet to be fully achieved in intercollegiate
athletics, incremental gains continue to accrue.  Results from eight
national gender equity studies reinforce that gains have occurred
since 1992 in the number of women's sports that schools offer, the
number of female students participating in athletics, and the
percentage of scholarship funds available to female student athletes. 
For example, many schools have recently added, or plan to add within
the next 3 years, at least one women's athletic program.  The studies
also show, however, that many of the schools' women's programs lag
behind those for men when comparing such factors as the percentage of
female head coaches, the salaries paid to coaches, and the proportion
of women student athletes to the total undergraduate enrollment
(women often constitute half of all undergraduates but a little over
one-third of student athletes). 


   BACKGROUND
------------------------------------------------------------ Letter :2

Title IX prohibits discrimination on the basis of sex in any
education program or activity, including intercollegiate athletics,
at colleges receiving federal financial assistance.\4 The
Department's OCR is responsible for enforcing federal civil rights
laws as they relate to schools, including title IX.  In fiscal year
1995, OCR operated on a $58.2 million appropriation and with 788
full-time-equivalent staff. 

Federal regulations implementing title IX became effective in 1975
and specifically required gender equity in intercollegiate athletics. 
The regulations gave colleges a 3-year transition period (through
July 21, 1978) to comply fully with the regulations' requirements
that equal athletic opportunity be provided for men and women.  In
1979, OCR issued a Policy Interpretation providing colleges with
additional guidance on what constituted compliance with the gender
equity requirements of title IX.  Under the Policy Interpretation,
OCR applies a three-part test to help determine whether colleges
provide equal athletic opportunity to male and female student
athletes.  To help determine whether equal athletic opportunity
exists, OCR assesses

  -- whether "intercollegiate level participation opportunities for
     male and female students are provided in numbers substantially
     proportionate to their respective enrollments";

  -- whether, when "the members of one sex have been and are
     underrepresented among intercollegiate athletes .  .  .  the
     institution can show a history and continuing practice of
     program expansion which is demonstrably responsive to the
     developing interests and abilities of the members of that sex";
     or

  -- whether, when "the members of one sex are underrepresented among
     intercollegiate athletes, and the institution cannot show a
     history and continuing practice of program expansion, as
     described above .  .  .  it can be demonstrated that the
     interests and abilities of the members of that sex have been
     fully and effectively accommodated by the present program."

Colleges must meet any one of the three criteria of the test. 

In addition to the three-part test, OCR may use other factors to
assess equality of opportunity in intercollegiate athletics,
including the financial assistance and travel expenses provided to
student athletes, the degree of publicity provided for athletic
programs, the extent to which colleges recruit student athletes, and
the extent of opportunities to participate in intercollegiate
competition.  OCR also assesses coaches' assignments and compensation
insofar as they relate to athletic opportunity for students. 

OCR both investigates discrimination complaints and conducts
compliance reviews.  Compliance reviews differ from complaint
investigations in that they are initiated by OCR.  Moreover,
compliance reviews usually cover broader issues and affect
significantly larger numbers of individuals than most complaint
investigations do, although some complaint investigations can be just
as broad in scope and effect.  OCR selects review sites on the basis
of information from various sources that indicates potential
compliance problems.  OCR is authorized to initiate administrative
proceedings to refuse, suspend, or terminate federal financial
assistance to a school violating title IX.  However, in the more than
2 decades since title IX was enacted, according to an OCR official,
the Department has not initiated any such administrative action for
athletic cases because schools have complied voluntarily when
violations have been identified. 

In addition to OCR's enforcement of title IX, the Department
implements the Equity in Athletics Disclosure Act.  Under the act,
coeducational colleges offering intercollegiate athletics and
participating in any federal student financial aid program are
required to 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.  This
information must be reported separately for men's and women's teams,
and colleges were to have prepared their first reports by October 1,
1996; thereafter, reports are to be prepared annually by October
15th.  Colleges must make the information available to students,
potential students, and the public.  Reports are not required to be
submitted to the Department, but copies must be made available to the
Department upon request. 

NCAA is a key organization in intercollegiate athletics.  It is a
voluntary, unincorporated association that administers
intercollegiate athletics for nearly 1,000 4-year colleges and
universities.  NCAA member colleges belong to one of three divisions,
the specific division generally depending on the number of sports the
college sponsors.  Typically, colleges with the largest number of
athletic programs and facilities belong to Division I, and those with
smaller programs are in Division II or III.  Division I schools are
further divided into three categories, Divisions I-A, I-AA, and
I-AAA, with those that have the larger football programs generally
placed in Division I-A. 


--------------------
\4 Title IX of the Education Amendments of 1972, P.L.  92-318, as
amended (20 U.S.C.  1681 et seq.). 


   OCR EMPHASIZES BOTH PREVENTION
   AND COMPLAINT INVESTIGATIONS
------------------------------------------------------------ Letter :3

OCR's strategy for encouraging gender equity in intercollegiate
athletics emphasizes both preventing title IX violations and
investigating complaints, although it receives relatively few
complaints about alleged violations.  Principal elements of OCR's
preventive approach include issuing guidance and providing technical
assistance.  In addition, a National Coordinator for Title IX
Athletics has been appointed to manage title IX activities.  OCR also
considers compliance reviews important to prevention but has
conducted few of them in recent years. 


      GUIDANCE ISSUED TO CLARIFY
      TITLE IX THREE-PART TEST
---------------------------------------------------------- Letter :3.1

OCR issued its "Clarification of Intercollegiate Athletics Policy
Guidance" in January 1996 in response to requests from the higher
education community to clarify the three-part test criteria presented
in the 1979 Policy Interpretation.  The Policy Interpretation allowed
colleges' intercollegiate athletic programs to meet any one of the
three criteria of the test to ensure that students of both sexes are
being provided nondiscriminatory opportunities to participate in
intercollegiate athletics. 

In 1994 and 1995, OCR initiated focus groups to obtain a variety of
views on its title IX guidance on intercollegiate athletics. 
Comments from the focus groups indicated that clarification of the
three-part test was needed.  While OCR was developing the
clarification, the Congress held hearings in May 1995, during which
concerns were expressed that the three-part test was ambiguous, thus
confirming the need for additional guidance.  Subsequently,
congressional members asked the Assistant Secretary for Civil Rights
to clarify OCR's policy on the three-part test.  The resulting 1996
clarification elaborates upon each part of the three-part test of
equal athletic opportunity, provides illustrative examples of its
application, and confirms that colleges are in compliance if they
meet any one part of the test. 

The clarification states that a college meets the first criterion of
the test if intercollegiate participation opportunities are
substantially proportionate to enrollments.  Such determinations are
made on a case-by-case basis after considering each college's
particular circumstances or characteristics, including the size of
its athletic program.  For example, a college where women represent
52 percent of undergraduates and 47 percent of student athletes may
satisfy the first part of the three-part test without increasing
participation opportunities for women if there are enough interested
and able students to field and support a viable team. 

The second part of the test concerns program expansion.  OCR's
clarification focuses on whether there has been a history of program
expansion and whether it has been continuous and responsive to the
developing interests and abilities of the underrepresented sex.  The
clarification does not identify fixed intervals of time for colleges
to have added participation opportunities.  To satisfy the second
part of the test, a college must show actual program expansion and
not merely a promise to expand its program. 

Under the third part of the test, a determination is made whether,
among students of the underrepresented sex, there is (a) sufficient
unmet interest in a particular sport to support a team, (b)
sufficient ability to sustain a team among interested and able
students, and (c) a reasonable expectation of intercollegiate
competition for the team in the geographic area in which the school
competes.  To make its determination, OCR evaluates such information
as requests by students to add a sport, results of student interest
surveys, and competitive opportunities offered by other schools
located in the college's geographic area. 

Since fiscal year 1992, OCR has investigated and resolved 80
intercollegiate athletics complaints to which the three-part test was
applied.  Of these 80 colleges, 16 either demonstrated compliance or
are taking actions to comply with part one; 4, with part two; and 42,
with part three.  The remaining 18 schools have yet to determine how
they will comply because they are still implementing their settlement
agreements.  These agreements obligate the schools to comply with one
part of the three-part test by a certain date, but OCR's monitoring
efforts do not yet indicate which part of the test they will satisfy. 


      TECHNICAL ASSISTANCE
      PROVIDED THROUGH VARIED
      ACTIVITIES
---------------------------------------------------------- Letter :3.2

OCR provides technical assistance through such activities as
participating in on-site and telephone consultations and conferences,
conducting training classes and workshops, and disseminating
educational pamphlets.  For example, OCR staff conduct title IX
workshops for schools, athletic associations, and other organizations
interested in intercollegiate athletics.  Although OCR could not tell
us the total number of technical assistance activities it conducted
specific to title IX in intercollegiate athletics, it did provide 47
examples of national, state, or local title IX presentations made
between October 1992 and April 1996.  OCR also coordinates title IX
education efforts with NCAA.  For example, the Assistant Secretary
for Civil Rights spoke at an NCAA-sponsored title IX seminar in April
1995, and OCR representatives have participated in subsequent
NCAA-sponsored seminars.\5


--------------------
\5 OCR has also worked with other executive agencies, such as the
Department of Justice, in support of title IX policies and practices. 


      NATIONAL COORDINATOR MANAGES
      TITLE IX ATHLETICS
      ACTIVITIES
---------------------------------------------------------- Letter :3.3

The Assistant Secretary for Civil Rights created the position of
National Coordinator for Title IX Athletics in 1994.  According to
the National Coordinator, who reports directly to the Assistant
Secretary, this position was created to (1) improve the coordination
of resources focused on gender equity in athletics among OCR's 12
offices; (2) prioritize management of title IX activities; (3) ensure
timely, consistent, and effective resolution of title IX cases and
other issues; and (4) ensure all appropriate OCR staff are trained in
conducting title IX athletics investigations in accordance with
revised complaint resolution procedures.\6

The National Coordinator told us the creation of the position has
resulted in greater consistency in resolving athletics cases and
faster responses from OCR offices to athletics inquiries.  These
improvements were accomplished, in part, by more frequent
communication between the National Coordinator and OCR offices using
a recently implemented national automated communications network,
improved on-the-job training for OCR staff in case resolution, and
the establishment of a central source of title IX athletics
information. 


--------------------
\6 In 1994, to improve the timeliness, documentation, and quality of
its investigations and reviews and to maximize the use of its
available resources, OCR issued a revised Case Resolution Manual
describing a streamlined approach to resolving and tracking civil
rights complaint cases. 


      FEW COMPLAINTS FILED
---------------------------------------------------------- Letter :3.4

Although OCR investigates and resolves all intercollegiate athletics
complaints that are filed in a timely manner,\7 fewer than 100 such
complaints were filed between October 1991 and June 1996.  These
complaints represented 0.4 percent of all civil rights complaints
filed during that period (see table 1).  Most of the approximately
23,000 complaints filed with OCR during that period dealt with other
areas of civil rights, including disability, race, and national
origin. 



                          Table 1
          
             Title IX Intercollegiate Athletics
          Complaints Filed With OCR, Fiscal Years
                          1992-96

                                             Percentage of
                                                 all civil
                                 Number of          rights
Fiscal year                     complaints      complaints
--------------------------  --------------  --------------
1992                                    16             0.4
1993                                    28             0.6
1994                                    19             0.4
1995                                    19             0.4
1996\a                                  14             0.4
==========================================================
Total                                   96             0.4
----------------------------------------------------------
\a For the 9 months ending June 30, 1996. 


--------------------
\7 OCR takes action upon those complaints filed within 180 calendar
days of the last act of alleged discrimination.  OCR can resolve
complaints either through an expedited procedure that addresses the
specific allegation or through an investigation of an institution's
entire athletic program. 


      LESS EMPHASIS ON COMPLIANCE
      REVIEWS
---------------------------------------------------------- Letter :3.5

OCR's title IX activities have focused recently more on policy
development, technical assistance, and complaint investigations and
less on assessing schools' compliance with title IX through
compliance reviews.  Although its strategic plan emphasizes the value
of conducting OCR-initiated compliance reviews to maximize the effect
of available resources, it conducted only two such reviews in 1995
and none in fiscal year 1996, and it plans none in fiscal year 1997. 
OCR attributes this decline to resource constraints. 

As table 2 shows, OCR conducted 32 title IX intercollegiate athletics
compliance reviews during fiscal years 1992 through 1996, with the
largest number being conducted in 1993. 



                          Table 2
          
             Title IX Intercollegiate Athletics
            Compliance Reviews Conducted by OCR,
                    Fiscal Years 1992-96

                                             Percentage of
                                                 all civil
                                 Number of          rights
                                compliance      compliance
Fiscal year                        reviews         reviews
--------------------------  --------------  --------------
1992                                     5             6.5
1993                                    14            13.6
1994                                    11             6.9
1995                                     2             2.1
1996                                     0               0
==========================================================
Total                                   32             5.6
----------------------------------------------------------

   NCAA HAS TAKEN A VARIETY OF
   ACTIONS SINCE 1992
------------------------------------------------------------ Letter :4

NCAA's constitution charges it with helping its member colleges meet
their legislative requirements under title IX.  Following the 1992
NCAA Gender Equity Study, which showed that women represented 30
percent of all student athletes and received 23 percent of athletic
operating budgets, NCAA created a task force to further examine
gender equity in its member colleges' athletic programs.  NCAA has
since implemented the following recommendations made by the task
force. 


      ADOPTING GENDER EQUITY AS AN
      ORGANIZATIONAL PRINCIPLE
---------------------------------------------------------- Letter :4.1

NCAA incorporated the principle of gender equity into its
constitution in 1994.  Recognizing that each member college is
responsible for complying with federal and state laws regarding
gender equity, the principle states that NCAA should adopt its own
legislation to facilitate member schools' compliance with gender
equity laws. 


      INCLUDING GENDER EQUITY AS A
      REQUISITE FOR CERTIFICATION
---------------------------------------------------------- Letter :4.2

According to NCAA, the Athletics Certification Program, begun in
academic year 1993-94, was developed to ensure that Division I
athletic programs are accredited in a manner similar to the way
academic programs are accredited.  The certification process includes
a review of Division I colleges' commitment to gender equity.\8
Schools are required to collect such information as the gender
composition of their athletic department staff and the resources
allocated to male and female student athletes.  Schools must also
evaluate whether their athletic programs conform with NCAA's gender
equity principle and develop plans for improving their programs if
they do not.  As of June 1996, NCAA reported that 70 of the 307
Division I schools (or 23 percent) had been certified.  The remaining
schools are scheduled to be certified by academic year 1998-99. 

The certification procedure takes about 2 years to complete and
includes site visits by an NCAA evaluation team and self-studies by
the schools.  Schools not meeting certification criteria must take
corrective action within an established time frame.  Schools failing
to take corrective action may be ineligible for NCAA championship
competition in all sports for up to 1 year.  If, after 1 year the
school has not met NCAA's certification criteria, it is no longer an
active member of NCAA.  According to NCAA, to date it has not been
necessary to impose such sanctions on any school undergoing
certification. 


--------------------
\8 The other areas examined during certification are commitment to
rules compliance; academic integrity; fiscal integrity; and
commitment to equity, which includes minority issues and student
athlete welfare, in addition to gender.  Division II and III schools
currently do not require certification. 


      UPDATING THE GENDER EQUITY
      STUDY
---------------------------------------------------------- Letter :4.3

NCAA's 1992 gender equity study reported the results of a survey of
its membership's athletic programs.  The study will be updated every
5 years, with the next issuance scheduled for 1997.  To update the
study, NCAA developed and distributed a form to collect information
on colleges' athletic programs.  The data the form is designed to
gather include the information schools must collect under the Equity
in Athletics Disclosure Act.  Thus, in addition to publishing its
gender equity study, NCAA will be able to aggregate the data in
reports prepared by colleges under the Disclosure Act.  The deadline
for submitting data collection forms to NCAA is the end of October
1996. 


      EXPANDING OPPORTUNITIES
      THROUGH EMERGING SPORTS
---------------------------------------------------------- Letter :4.4

To help schools achieve gender equity in intercollegiate athletics as
well as to meet the interests and abilities of female student
athletes, the NCAA Gender Equity Task Force identified nine emerging
sports that may provide additional athletic opportunities to female
student athletes.  Effective September 1994, NCAA said that schools
could use the following sports to help meet their gender equity goal: 
archery, badminton, bowling, ice hockey, rowing (crew), squash,
synchronized swimming, team handball, and water polo.  In academic
year 1995-96, 122 of the 995 (or 12 percent) NCAA schools with
women's varsity sports programs offered at least one of the emerging
sports. 


      PROVIDING TECHNICAL
      ASSISTANCE
---------------------------------------------------------- Letter :4.5

In 1994, NCAA developed a guidebook on achieving gender equity.  The
guidebook supplements OCR's title IX guidance and provides schools'
athletic administrators with basic knowledge of the law and how to
comply with it.  NCAA also coordinates with OCR to provide its member
schools--and others--training and technical assistance through title
IX seminars.  NCAA held two such seminars in April 1995 (the
Assistant Secretary for Civil Rights participated in one of the
seminars) and two in April 1996.  The seminars were attended by
athletic directors, general counsels, gender equity consultants, OCR
representatives, and others representing groups interested in gender
equity in intercollegiate athletics. 


   STATES' GENDER EQUITY EFFORTS
   VARY CONSIDERABLY
------------------------------------------------------------ Letter :5

States promote gender equity in intercollegiate athletics through a
variety of means.  Over half of the states were involved in promoting
gender equity in intercollegiate athletics.  To identify state gender
equity initiatives, we surveyed state higher education organizations
in all 50 states and the District of Columbia.  For reporting
purposes, we collectively refer to the 51 respondents as states. 
Overall, 32 of the 51 states (63 percent) had taken some type of
action to promote gender equity in intercollegiate athletics. 
Information provided by the 51 respondents is summarized in table 3;
appendix II discusses the responses in more detail. 



                          Table 3
          
            Summary of State Actions to Promote
              Gender Equity in Intercollegiate
                         Athletics

                             Number of
Type of action                states\a  Remarks
----------------------  --------------  ------------------
Developed legislation               22  Three states
 or other requirements                   implemented both
                                         legislation and
                                         other
                                         requirements.
Designated a gender                 13  Four states had
 equity official or                      full-time
 coordinator                             positions; nine
                                         had part-time
                                         positions.
Provided technical                  11
 assistance and
 training
Coordinated collection               8
 of schools' athletic
 reports
Coordinated schools'                 7
 gender equity self-
 studies
Used indicators to                   8  Most states
 measure schools'                        measured number
 progress toward                         of female student
 gender equity                           athletes and
                                         number of women's
                                         sports.
Either monitored or                 11  State action was
 coordinated schools'                    not required, but
 compliance with the                     most states
 Equity in Athletics                     planned to
 Disclosure Act or                       collect copies of
 planned to do so                        disclosure
                                         reports and
                                         provide guidance
                                         on the act's
                                         requirements.
----------------------------------------------------------
\a Some actions were implemented by more than one state; therefore,
total actions by states exceed 51. 

Some respondents also provided observations of conditions that they
believe may facilitate or hinder gender equity in intercollegiate
athletics at colleges within their states.  Conditions that some
believed may facilitate gender equity included a commitment from
individuals in leadership positions, state gender equity legislation,
and a high participation by girls in K-12 athletics.  Conditions that
some believed may hinder gender equity included insufficient funds;
the presence of football programs, which women are unlikely to
participate in; and the perception that women are not as interested
in athletics as men are. 


   STUDIES SHOW SOME ADVANCES IN
   GENDER EQUITY BUT WOMEN'S
   ATHLETIC PROGRAMS STILL ARE NOT
   COMPARABLE WITH MEN'S PROGRAMS
   IN SOME RESPECTS
------------------------------------------------------------ Letter :6

The eight studies on gender equity in intercollegiate athletics that
we identified showed that women's athletic programs have made slight
advances since 1992 toward gender equity as measured by the number of
sports available to female students, the number of females
participating in athletics, and the percentage of scholarship
expenditures for women's sports.  The studies also show, however,
that women's programs remain behind men's programs as measured by the
percentage of female head coaches, comparable salaries for coaches,
and ratio of student athletes to undergraduate enrollment. 

All eight studies were national in scope and examined gender equity
in the athletic programs at NCAA-member schools since 1992.  Although
most of the studies used surveys, some studies were based on
different sample sizes or time periods, making direct comparisons
among studies inappropriate.  While the studies selectively evaluated
the effect of title IX on various aspects of gender equity in
intercollegiate athletics, they did not evaluate schools' compliance
with title IX.  See appendix III for additional information on the
studies; see also the bibliography. 


      STUDIES REPORTED SOME
      ADVANCES TOWARD GENDER
      EQUITY
---------------------------------------------------------- Letter :6.1

The studies reported some advances toward equity between men's and
women's intercollegiate athletics: 

  -- The average number of sports offered to women rose from 7.1 in
     1992 to 7.5 in 1996, an increase of almost 6 percent. 

  -- Schools in all three NCAA divisions have added women's programs
     in the last 5 years, which one study attributed to the
     implementation of title IX legislation. 

  -- An almost equal number of women's and men's sports (about 4.5)
     used marketing and promotional campaigns designed to increase
     event attendance. 

  -- In fiscal year 1993, women at NCAA Division I schools received
     about 31 percent of athletic scholarship funds, an increase of
     about 3 percentage points from fiscal year 1989.  Similarly,
     women's programs received 24 percent of total average athletic
     operating expenses, including scholarships, scouting and
     recruiting, and other expenses--also an increase of about 3
     percentage points from fiscal year 1989. 

  -- Female student participation in intercollegiate athletic
     programs has increased.  For example, one study showed that the
     proportion of female student athletes increased from 34 percent
     of all student athletes in 1992 to 37 percent in 1995, an annual
     rate of increase of 1 percentage point.\9


--------------------
\9 In 1972, when title IX was passed, women accounted for 15 percent
of all intercollegiate athletes. 


      STUDIES REPORTED WOMEN'S
      ATHLETICS LAG BEHIND MEN'S
      ATHLETICS IN SOME RESPECTS
---------------------------------------------------------- Letter :6.2

The studies also showed that women's athletic programs continue to
lag behind men's programs in certain respects: 

  -- Most of the head coaches for women's teams are male.  In 1996,
     women accounted for about 48 percent of head coaches for women's
     teams.  This represented a slight decline (0.6 percentage
     points) from the percentage of female coaches in 1992.  In
     contrast, more than 90 percent of women's teams were coached by
     females in 1972, the year title IX was enacted. 

  -- Head coaches of women's basketball teams earned 59 percent of
     what head coaches of men's basketball teams earned, as reported
     in 1994. 

  -- Women often constituted half of all undergraduates in 1995,
     while constituting only 37 percent of all student athletes. 


   AGENCY COMMENTS
------------------------------------------------------------ Letter :7

In commenting on a draft of our report, the Department of Education
clarified several issues, including the reason compliance reviews
have declined, the extent of OCR's work with other agencies in
support of title IX policies and procedures, the differences between
compliance reviews and complaint investigations, and the context in
which coaches' employment is considered by OCR in a title IX review
(see app.  V).  The Department also offered a number of technical
changes.  In general, we agreed with the Department's comments, and
incorporated them into the report, as appropriate. 


---------------------------------------------------------- Letter :7.1

We are sending copies of this report to the Secretary of Education;
appropriate congressional committees; the Executive Director, NCAA;
and other interested parties.  Please call me at (202) 512-7014 if
you or your staff have any questions about this report.  Major
contributors to this report were Joseph J.  Eglin, Jr., Assistant
Director; R.  Jerry Aiken; Deborah McCormick; Charles M.  Novak;
Meeta Sharma; Stanley G.  Stenersen; Stefanie Weldon; and Dianne L. 
Whitman-Miner. 

Sincerely yours,

Carlotta C.  Joyner
Director, Education and
 Employment Issues


SCOPE AND METHODOLOGY
=========================================================== Appendix I

To determine the actions the Department of Education has taken to
promote gender equity in intercollegiate athletics since 1992, we
interviewed the National Coordinator for Title IX Athletics and
analyzed information from the Department's Office for Civil Rights
(OCR).  We obtained information on the National Collegiate Athletic
Association's (NCAA) gender equity actions by interviewing its
Director of Education Outreach, Director of Research, and officials
in its Compliance Department.  We also analyzed documentation they
provided. 

To identify state gender equity initiatives, we developed a
questionnaire and sent it to agencies with oversight responsibility
for public higher education in each of the 50 states and the District
of Columbia.  In nearly all cases, we spoke with staff at the higher
education agency.  When necessary for clarification, we conducted
follow-up telephone interviews.  We supplemented this information
with supporting documentation provided by state representatives. 

The questionnaire went to 56 organizations:  41 higher education
boards or boards of regents,\10 9 state university or college
systems, 5 community college systems, and 1 public 4-year
institution.\11 Five states had separate higher education oversight
organizations for 2- and 4-year institutions.  We therefore received
two sets of responses from these states, one for 2-year and the other
for 4-year institutions.  We combined the two sets of responses into
one response to reflect the state's gender equity initiatives.  We
received completed surveys from all 50 states and the District of
Columbia. 

The questionnaire requested data on the existence of state gender
equity officials; type of gender equity initiatives, if any (that is,
legislation, requirements, policy recommendations, or other actions);
methods used to promote gender equity; indicators used to measure
gender equity; actual or estimated trends for each indicator;
compliance and guidance efforts associated with the Equity in
Athletics Disclosure Act; and conditions that help or hinder gender
equity within the state.  All information was self-reported by state
representatives, and we did not verify its accuracy. 

To identify studies on gender equity in intercollegiate athletics
issued since 1992, we conducted a literature search and consulted
academic experts and professional organizations that deal with gender
equity, intercollegiate athletics, or both.  (See app.  IV for a list
of organizations contacted for this report.  We have also included a
bibliography.) The sources we consulted identified eight studies on
gender equity in intercollegiate athletics that were national in
scope and were issued since 1992.  Most of the studies were surveys
of NCAA schools.  We reviewed the information in the studies and
summarized the key findings, but we did not verify their accuracy. 

We performed our work between April and August 1996 in accordance
with generally accepted government auditing standards. 


--------------------
\10 Also included were state departments of education, departments of
postsecondary education, higher education coordinating boards, and
commissions of higher education. 

\11 This institution was the only public 4-year higher education
organization in its state. 


SUMMARY OF RESPONSES TO GAO'S
SURVEY OF STATE EFFORTS TO PROMOTE
GENDER EQUITY IN INTERCOLLEGIATE
ATHLETICS
========================================================== Appendix II

This appendix contains the responses to questions we asked higher
education officials in the 50 states and the District of Columbia
(referred to in this appendix as 51 states) about gender equity in
intercollegiate athletics efforts.  All responses reflect statewide
gender equity actions. 



                               Table II.1
                
                   Does Your Education Agency Have a
                  Designated Gender Equity Official or
                              Coordinator?

                                                        Number
                                                            of  Percen
Response                                                states       t
------------------------------------------------------  ------  ------
Yes, full-time                                               4       8
Yes, part-time\a                                             9      18
No                                                          38      75
======================================================================
Total                                                       51   100\b
----------------------------------------------------------------------
\a Amount of time spent on gender equity issues ranged from under 1
percent to 50 percent. 

\b Actual total exceeds 100 because of rounding. 



                               Table II.2
                
                    Does Your Education Agency Have
                 Regulatory Authority Over State Public
                     Higher Education Institutions?

                                                        Number
                                                            of  Percen
Response                                                states       t
------------------------------------------------------  ------  ------
Yes                                                         34      67
No                                                          17      33
======================================================================
Total                                                       51     100
----------------------------------------------------------------------


                               Table II.3
                
                Does Your State Legislature Have Its Own
                Legislation, Other Than Federal Title IX
                Legislation, Regarding Gender Equity in
                       Intercollegiate Athletics?

                                                        Number
                                                            of  Percen
Response                                                states       t
------------------------------------------------------  ------  ------
Yes, enacted in 1970s                                        6      12
Yes, enacted in 1980s                                        3       6
Yes, enacted in 1990s                                        4       8
No, but legislation is pending                               0       0
No, our state has no such legislation                       38      75
======================================================================
Total                                                       51   100\a
----------------------------------------------------------------------
\a Actual total exceeds 100 because of rounding. 



                               Table II.4
                
                 To Which Institutions Does the Gender
                       Equity Legislation Apply?

                                                                Number
                                                                    of
Type of schools to which law applies                            states
--------------------------------------------------------------  ------
Public colleges and universities                                    13
Private colleges and universities                                    2
Community colleges                                                  11
Vocational colleges                                                  7
Secondary schools                                                    7
Elementary schools                                                   7
----------------------------------------------------------------------
Notes:  Respondents were asked to check all that applied.  Thirteen
states responded to the question. 



                               Table II.5
                
                Does Your Education Agency Have Its Own
                Requirements, Policy Recommendations, or
                    Other Actions, Other Than State
                Legislation, Regarding Gender Equity in
                       Intercollegiate Athletics?

                                                        Number
                                                            of  Percen
Response                                                states       t
------------------------------------------------------  ------  ------
Yes, requirements                                            4       8
Yes, policy recommendations                                  2       4
Yes, other action                                          5\a      10
Yes, policy recommendation and other action                  1       2
No                                                          39      76
======================================================================
Total                                                       51     100
----------------------------------------------------------------------
Note:  Respondents were asked to check all that applied. 

\a Responses included (1) developed technical assistance and training
materials regarding state legislation; (2) convened the Priority
Study Group on Intercollegiate Athletics as an advisory body; (3)
sponsored annual conferences on gender equity and technical
assistance in applying title IX; (4) published a statement that an
equal commitment to access and quality must be made; (5) prepared
annual reports to Board of Regents that included data on gender,
sports, participation rates, operating budgets, scholarships, and
staffing; and (6) carried out a study of the athletic program using
NCAA certification criteria during a 1989 pre-test. 



                               Table II.6
                
                 To Which Institutions Does the Gender
                 Equity Requirement, Recommendation, or
                          Other Action Apply?

                                                                Number
                                                                    of
Type of schools to which action applies                         states
--------------------------------------------------------------  ------
Public colleges and universities                                    11
Private colleges and universities                                    1
Community colleges                                                   9
Vocational colleges                                                  5
Secondary schools                                                    2
Elementary schools                                                   2
----------------------------------------------------------------------
Notes:  Respondents were asked to check all that applied.  Twelve
states responded to the question. 



                               Table II.7
                
                   Which Mechanisms to Promote Gender
                Equity Are Centrally Coordinated by Your
                      Agency on a Statewide Basis?

                                                                Number
                                                                    of
Type of mechanism                                               states
--------------------------------------------------------------  ------
Provide technical assistance and training                           11
Coordinate institutional reports                                     8
Coordinate institutional gender equity plans/self-evaluations        7
Conduct enforcement and monitoring                                   4
Impose sanctions and penalties                                       4
Coordinate institutional gender equity grievance procedures          3
Other                                                              1\a
Coordinate institutional student interest and abilities survey       0
----------------------------------------------------------------------
Notes:  The table shows the mechanisms in the order that they are
most often used, not in the order asked in the questionnaire. 
Respondents were asked to check all that applied.  Nineteen states
responded to the question; the remaining 32 indicated they did not
coordinate such mechanisms statewide. 

\a Oral reports are presented at semi-annual meetings between
athletic directors and faculty athletic representatives in an effort
to raise gender equity issues. 



                         Table II.8
          
            What Kinds of Indicators Measure the
           Progress in Achieving Gender Equity in
                 Intercollegiate Athletics?

Indicator used to        Number of
measure gender equity       states  Trends
----------------------  ----------  ----------------------
Female student athlete           8  6 increased from 5 to
 participation rates                 70%; 2 had no data
                                     available
Number of women's                8  2 increased, by 3% and
 sports, teams, or                   33%; 1 increased but
 both                                no data available on
                                     how much; 5 had no
                                     data available
Women coaches'                   6  1 increased by 10%; 5
 participation rates                 had no data available
Salaries/compensation            6  1 increased by 8%; 5
 for women's coaches                 had no data available
 and administrators
Expenditures on                  5  1 increased by 7%; 4
 women's athletics                   had no data available
Allocation of state              4  1 increased but no
 funds to promote                    data available on how
 gender equity                       much; 3 had no data
                                     available
Number of gender                 2  2 had no data
 equity complaints                   available
 filed
Number of compliance             1  1 had no data
 reviews or                          available
 investigations
Number and type of               0
 sanctions imposed
Other                            0
----------------------------------------------------------
Notes:  We told the respondents that several indicators can be used
to measure the degree of progress in achieving gender equity in
intercollegiate athletics.  We asked what indicators, if any, are
being centrally coordinated by the state's education agency on a
statewide basis.  For each indicator, we asked which of the following
trends have been observed since legislation or other actions have
been taken:  increase (___% increase), no change, decrease (___%
decrease), or data not available.  Answers could be based on actual
or estimated data, and respondents were asked to check all that
applied.  The table shows the mechanisms in the order that they were
most often reported, not in the order posed in the questionnaire. 

\a Eight states responded to the question; the remaining 43 states
did not use any indicators. 



                               Table II.9
                
                 Does Your Office Monitor or Coordinate
                 Postsecondary Institutions' Compliance
                With the Equity in Athletics Disclosure
                              Act of 1994?

                                                        Number
                                                            of  Percen
Response                                                states       t
------------------------------------------------------  ------  ------
Presently monitors                                           2       4
Plans to monitor                                             3       6
Other type of coordination                                   6      12
Does not monitor                                            40      78
======================================================================
Total                                                       51     100
----------------------------------------------------------------------
Note:  The Equity in Athletics Disclosure Act requires higher
education institutions that offer intercollegiate athletics and that
participate in any financial aid programs under title IV of the
Higher Education Act to disclose annually--to students, prospective
students, and the public--information on their women's and men's
athletic programs. 



                              Table II.10
                
                How Does Your Office Monitor--or Plan to
                  Monitor--or Coordinate Postsecondary
                   Institutions' Compliance With the
                            Disclosure Act?

                                                                Number
                                                                    of
Response                                                        states
--------------------------------------------------------------  ------
Request copies of annual disclosure reports from each                8
 institution
Conduct on-site compliance reviews or other program audits           1
Other                                                              2\a
----------------------------------------------------------------------
Notes:  Respondents were asked to check all that applied.  Eleven
states responded to the question. 

\a Other responses were (1) technical assistance in complying with
Disclosure Act requirements and (2) school presidents are responsible
for compliance. 



                              Table II.11
                
                  Have You Provided Guidance to Ensure
                  Institutions' Disclosure Reports Are
                 Made Easily Available and in a Timely
                                Manner?

                                                        Number
                                                            of  Percen
Response                                                states       t
------------------------------------------------------  ------  ------
Yes                                                          2       4
No, but plan to provide guidance                             9      18
No, do not plan to provide guidance                         39      76
Do not know                                                  1       2
======================================================================
Total                                                       51     100
----------------------------------------------------------------------


                              Table II.12
                
                What Conditions Have You Observed Within
                Your State That Facilitate Gender Equity
                     in Intercollegiate Athletics?

                                                                Number
                                                                    of
Conditions                                                      states
--------------------------------------------------------------  ------
Commitment to gender equity by campus leadership, athletic           8
 directors, board members, or all
Support for and increased participation of girls in K-12             6
 athletics
Gender equity is a campus priority                                   5
State legislation                                                    5
Public awareness/support for gender equity or interest in            5
 women's athletics
Positive attitude/support/climate for women in sports                5
Successful women's teams                                             4
Federal, state, and campus pressure and support for gender           3
 equity
OCR and NCAA activities to promote gender equity                     3
Students' interests                                                  2
Other                                                              5\a
----------------------------------------------------------------------
Notes:  Respondents were asked to check all that applied. 
Twenty-three states responded to the question. 

\a Other responses were (1) women in leadership positions, (2)
intercollegiate competition for women, (3) fear of sanctions against
men's sports, (4) losing a gender equity lawsuit, and (5) equity in
use and quality of facilities that support athletics. 



                              Table II.13
                
                  What Conditions Have You Observed in
                Your State That Hinder Gender Equity in
                       Intercollegiate Athletics?

                                                                Number
                                                                    of
Conditions                                                      states
--------------------------------------------------------------  ------
Lack of resources                                                   10
Presence of football teams\a                                         7
Negative/unsupportive attitude                                       6
Lack of commitment from leadership                                   3
Lack of women in leadership                                          3
Lack of attention paid to women's sports relative to men's           3
Perceived or actual lack of interest by women in athletics           2
Recruitment pipeline not as strong for women                         2
Other                                                              4\b
----------------------------------------------------------------------
Notes:  Respondents were asked to check all that applied. 
Twenty-four states responded to the question. 

\a Some respondents stated that the cost and size of football
programs, especially nonrevenue-producing programs, make it difficult
to achieve gender equity in athletics.  In addition, if football is
revenue-producing, it tends to receive greater priority than other
sports. 

\b Other responses were (1) fear of reducing resources for men's
sports, (2) language is not gender-fair so the socialization girls
grow up with hinders gender equity in later years, (3) lack of a
coordinated effort across postsecondary systems, and (4) compliance
is voluntary because institutions do not have to report their
activities to the Commission. 


SUMMARY OF STUDIES ON GENDER
EQUITY IN INTERCOLLEGIATE
ATHLETICS
========================================================= Appendix III

The eight national studies we identified that were issued between
1992 and 1996 examined various aspects of gender equity within NCAA
schools' intercollegiate athletics programs.  Because they varied in
the time periods they studied, sample size, purpose, and methodology,
the studies cannot be compared with each other.  While some studies
discuss the overall effect of title IX on women's athletics, they do
not present sufficient information to determine whether the colleges
were in compliance with title IX.  The following is a summary of the
key findings of each study. 


   WOMEN IN INTERCOLLEGIATE SPORT,
   A LONGITUDINAL STUDY, NINETEEN
   YEAR UPDATE, 1977-1996
------------------------------------------------------- Appendix III:1

Authors and Date of Study:  Acosta and Carpenter (1996)

Scope and Time Period Studied:  All NCAA schools, academic years
1977-78 to 1995-96

Summary:  This longitudinal study examined the number of sport
offerings as an indicator of opportunities for women athletes to
participate in intercollegiate athletics at NCAA schools.  It also
reported the percentage of NCAA schools offering each type of sports
program.  The study identified 24 sports that schools could offer to
female students.  The percentage of schools offering sports programs
to female students in 1996 varied considerably by sport, ranging, for
example, from 98.3 percent of schools offering basketball to 0.3
percent offering badminton.  In addition, the average number of
sports being offered to female intercollegiate athletes generally
increased from 7.1 sports per school in 1992 to 7.5 sports in 1996,
for all three NCAA divisions (see table III.1).  The study noted that
the average number of women's sports offered in 1996 was the highest
since this information was first reported in 1978.  The average
number of sports offered per school was also reported for each NCAA
division for 1996:  8.3 (Division I), 6.1 (Division II), and 7.8
(Division III). 



                        Table III.1
          
            Average Number of Sports Offered to
          Female Intercollegiate Athletes by NCAA
              Schools, Academic Years 1992-96

                                         Average number of
Academic year                            sports per school
--------------------------------------  ------------------
1992                                                   7.1
1993                                                   7.0
1994                                                   7.2
1995                                                   7.3
1996                                                   7.5
----------------------------------------------------------
The study also examined the percentage of female coaches and female
administrators (head athletic directors) as two other indicators of
participation opportunities for women at NCAA schools.  The study
found that, for women's teams, the percentage of female coaches and
female administrators were lower than percentages of male coaches and
administrators.  While figures for individual years fluctuated, they
did not vary much between academic years 1992 and 1996 (see table
III.2).  The study also noted that the percentage of female coaches
in 1996 was the second lowest representation level since title IX was
enacted in 1972.  By contrast, more than 90 percent of women's teams
were coached by females in 1972. 



                        Table III.2
          
           Representation of Women as Coaches and
          Administrators of Women's Teams at NCAA
              Schools, Academic Years 1992-96

                    Percent of women's  Percent of women's
                      coaches that are      administrators
Academic year                   female     that are female
------------------  ------------------  ------------------
1992                              48.3                16.8
1993                              48.1                  \a
1994                              49.4                21.0
1995                              48.3                  \a
1996                              47.7                18.5
----------------------------------------------------------
\a Data not readily available. 

The study concluded that title IX has had more of a positive effect
on participation opportunities for female student athletes than for
female coaches and administrators. 


   MARKETING IMPLICATIONS OF TITLE
   IX TO COLLEGIATE ATHLETIC
   DEPARTMENTS (PRELIMINARY
   REPORT)
------------------------------------------------------- Appendix III:2

Authors and Date of Study:  Barr, Sutton, McDonald, and others (1996)

Scope and Time Period Studied:  Members of the National Association
of Collegiate Marketing Administrators at NCAA schools, 1996

Summary:  The study of marketing and promotion of women's programs
involved a survey of members of the National Association of
Collegiate Marketing Administrators.  The study preliminarily
concluded that NCAA schools and their marketing departments appeared
to have good intentions in supporting women's programs, but athletic
departments were not adding the personnel needed to effectively
market and promote women's sports.  The study reported the following: 

  -- Women's sports received 37 percent of schools' mean athletic
     marketing budgets.  This result was positively correlated with
     the overall athletic department budget allocated to women's and
     men's sports. 

  -- The mean number of sports offered at NCAA schools was 9.2 for
     women and 9.2 for men.  Given the relative equality of the two
     estimates, the study suggested title IX may have had a positive
     effect on the number of women's sports being offered. 

  -- Marketing and promotional campaigns designed to increase event
     attendance were used for an almost equal number of women's
     sports (4.5) and men's sports (4.6); however, the study did not
     indicate the attendance levels or whether they had increased as
     a result of marketing and promotional campaigns. 

  -- Schools at each NCAA division level have added women's programs
     in the last 5 years as a result of title IX legislation; the
     mean number of women's programs added ranges from 1.0 to 3.5
     sports per school.  Within Division I-A, the method cited most
     frequently for deciding what programs to add was direction from
     an NCAA conference to its member schools to add specific sports. 
     For Division I colleges with no football programs, the most
     frequent method was the elevation of an existing club sport to
     the intercollegiate level. 

  -- Not many men's sports programs have been dropped in the last 5
     years:  the mean number ranged from 0.1 to 1.0 per school.  The
     most common reasons given for reducing men's sports were to
     comply with title IX and to contain athletic programs' costs. 

  -- No women's sports programs had a full-time staff member devoted
     to marketing their sports. 


   PARTICIPATION STATISTICS
   REPORT, 1982-1995
------------------------------------------------------- Appendix III:3

Authors and Date of Study:  NCAA (1995)

Scope and Time Period Studied:  All NCAA schools, academic years
1982-83 to 1994-95

Summary:  Female student athlete participation rose from 34 percent
of all student participation in 1992 to 37 percent in 1995, an
increase of about 1 percentage point a year. 


   TITLE IX:  FAIRNESS ON THE
   FIELD
------------------------------------------------------- Appendix III:4

Authors and Date of Study:  USA Today (1995)

Scope and Time Period Studied:  NCAA Division I-A football schools,
academic year 1994-95

Summary:  The study assessed the effects of title IX on college
campuses by surveying the 107 NCAA Division I-A schools.  The
responses for the 95 schools that replied showed the following: 

  -- Women were, on average, 33 percent of student athletes and 49
     percent of undergraduates. 

  -- Female athletes received 35 percent of scholarships the schools
     provided. 

  -- Forty percent of the schools added a women's sport in the last 3
     years.\12

  -- Fifty-nine percent of the responding schools planned to add at
     least one women's sport in the next 3 years. 


--------------------
\12 The second part of the three-part test of compliance with title
IX requires schools to establish a history and continuing practice of
program expansion for members of the underrepresented sex. 


   SLOW PROGRESS ON EQUITY
------------------------------------------------------- Appendix III:5

Authors and Date of Study:  Chronicle of Higher Education (1994)

Scope and Time Period Studied:  NCAA Division I schools, academic
year 1993-94

Summary:  The survey measured progress in achieving gender equity
since the 1992 NCAA Gender Equity Study was issued showing
disparities in the number of male and female student athletes and the
amount of athletic scholarship money they received.  The survey
concluded that little had changed since the NCAA study was issued. 
It identified a slight increase in the proportion of female student
athletes and their share of athletic scholarship funds; however,
participation opportunities and scholarship funds continued to lag
behind those for men, even though women constituted over half of the
colleges' undergraduates. 

Responses from 257 of the 301 NCAA Division I schools showed the
following: 

  -- Women made up about 34 percent of varsity athletes and about 51
     percent of undergraduates. 

  -- Female athletes received almost 36 percent of scholarship funds. 


   REVENUES AND EXPENSES OF
   INTERCOLLEGIATE ATHLETICS
   PROGRAMS:  FINANCIAL TRENDS AND
   RELATIONSHIPS, 1993
------------------------------------------------------- Appendix III:6

Authors and Date of Study:  NCAA (1994)

Scope and Time Period Studied:  All NCAA schools, fiscal year 1992-93

Summary:  NCAA's study of member schools' expenses found that about
24 percent of the total average operating expenses went to women's
programs at Division I schools in fiscal year 1992-93 (see table
III.3).




                        Table III.3
          
           Expenses for Women's Athletic Programs
              at NCAA Division I Schools as a
            Percentage of Total Average Athletic
          Operating Expenses, Fiscal Year 1992-93

                                Percent of total operating
                                 expenses spent on women's
Type of expense\a                                 programs
----------------------------  ----------------------------
Grants-in-aid (scholarships)                          30.8
Scouting and recruiting                               21.3
Other\b                                               20.3
Total average operating                               23.5
 expenses
----------------------------------------------------------
\a Administrative expenses are excluded because NCAA reported them in
the aggregate and did not allocate them between men's and women's
programs. 

\b Includes such items as salaries and wages, equipment and supplies,
and team travel. 


   1992-1993 SURVEY, WOMEN'S
   VOLLEYBALL PROGRAMS
------------------------------------------------------- Appendix III:7

Authors and Date of Study:  American Volleyball Coaches Association
(1995)

Scope and Time Period Studied:  Coaches at NCAA schools and schools
belonging to other athletic associations or college systems that
officially conduct intercollegiate volleyball programs, 1993

Summary:  The survey gathered information on various aspects of
coaches' compensation, including that of head coaches, at NCAA
schools and schools belonging to other athletic associations or
college systems with intercollegiate volleyball programs.  However,
meaningful findings were derived only from NCAA Division I women's
intercollegiate volleyball programs.  Response rates were lower for
all the other schools with volleyball programs.  Response rates were
particularly low for men's programs, precluding any comparisons
between men's and women's programs.  For women's volleyball, the
survey showed about 48 percent of head coaches were female, and their
average base salary was $32,383, about 2 percent less than that
earned by males coaching women's volleyball. 


   1994 SURVEY OF WOMEN'S
   BASKETBALL COACHES ASSOCIATION
   DIVISION I HEAD COACHES
------------------------------------------------------- Appendix III:8

Authors and Date of Study:  Women's Basketball Coaches Association
(WBCA) (1994)

Scope and Time Period Studied:  Head coaches at NCAA Division I
schools who were WBCA members, 1994

Summary:  The survey included an examination of head coaches'
salaries, employment contract terms, budgets, and staffing at NCAA
Division I schools with basketball programs.\13 Information for both
men's and women's basketball programs was provided by the head coach
of the women's program.  The results showed significant disparities
between women's and men's basketball programs in the average base
salary for the head coach, coaching contracts, and program budgets
(see table III.4).  For example, head coaches of women's basketball
earned 59 percent of what head coaches of men's basketball earned,
and women's average annual athletic budgets were 58 percent of men's
budgets.  The study also reported that men's basketball programs
employed more graduate staff and at higher average salaries than
women's programs.  For women's basketball programs, however, few
differences were found in average base salary and contract terms for
male and female head coaches. 



                        Table III.4
          
          Selected Comparisons of Coaches of Men's
          and Women's Basketball Programs at NCAA
           Division I Schools, Academic Year 1994

              Average base                         Average
                salary for  Length of head          annual
Program         head coach  coach's contract      budget\a
----------  --------------  ------------------  ----------
Men's              $76,566  70% had a contract    $253,865
                             for 3 or more
                             years; 8% had no
                             contract
Women's             44,691  51% had a contract     148,194
                             for 3 or fewer
                             years; 25% had no
                             contract
----------------------------------------------------------
\a Includes operation, travel, and recruiting; excludes salary. 

Appendix IV

--------------------
\13 Although 127 of 246 schools provided information for the survey,
only 99 of the 127 respondents provided salary information. 


ORGANIZATIONS CONTACTED FOR THIS
REPORT
========================================================= Appendix III

American Association of University Women, Washington, D.C. 

American Council on Education, Washington, D.C. 

American Sports Institute, Mill Valley, Calif. 

Boise State University, Boise, Idaho

Center for Research on Girls and Women in Sport, University of
Minnesota, Minneapolis, Minn. 

Council of Chief State School Officers, Washington, D.C. 

Eastern Oregon State College, LaGrande, Oreg. 

Education Commission of the States, Denver, Colo. 

Harvard School of Public Health, Cambridge, Mass. 

Moorhead State University, Moorhead, Minn. 

National Association for Girls and Women in Sport, Reston, Va. 

National Association of Collegiate Women Athletics Administrators,
Sudbury, Mass. 

National Coalition for Sex Equity in Education, Clinton, N.J. 

National Softball Coaches Association, Columbia, Mo. 

National Women's Law Center, Washington, D.C. 

Princeton University, Princeton, N.J. 

Smith College, Northampton, Mass. 

Trial Lawyers for Public Justice, Washington, D.C. 

University of California, Berkeley, Calif. 

University of Massachusetts, Amherst, Mass. 

Washington State University, Pullman, Wash. 

Women's Educational Equity Act Publishing Center, Education
Development Center, Inc., Newton, Mass. 

Women's Institute on Sports and Education, Pittsburgh, Pa. 

Women's Sports Foundation, East Meadow, N.Y. 

Young Women's Christian Association, New York, N.Y. 




(See figure in printed edition.)Appendix V
COMMENTS FROM THE DEPARTMENT OF
EDUCATION
========================================================= Appendix III



(See figure in printed edition.)



(See figure in printed edition.)



(See figure in printed edition.)



(See figure in printed edition.)


BIBLIOGRAPHY
=========================================================== Appendix 0

Acosta, Vivian R.  and Linda Jean Carpenter.  Women in
Intercollegiate Sport, A Longitudinal Study, Nineteen Year Update,
1977-1996.  Brooklyn, N.Y.:  Brooklyn College, 1996. 

American Volleyball Coaches Association.  1992-1993 Survey, Women's
Volleyball Programs.  Colorado Springs, Colo.:  AVCA, 1995. 

Barr, Carol A., William A.  Sutton, Mark M.  McDonald, and others. 
Marketing Implications of Title IX to Collegiate Athletic Departments
(preliminary report).  Amherst, Mass.:  University of Massachusetts,
1996. 

Blum, Debra E.  "Slow Progress on Equity." Chronicle of Higher
Education (Oct.  26, 1994), p.  A45.  http://www.chronicle.com (cited
Mar.  4, 1996). 

Cheng, Phyllis W.  "The New Federalism and Women's Educational
Equity:  How the States Respond." Paper presented at the annual
meeting of the Association of American Geographers, Phoenix, Ariz.,
1988. 

Feminist Majority Foundation.  Empowering Women in Sports, No.  4. 
Arlington, Va.:  Feminist Majority Foundation, 1995. 

Fulks, Daniel L.  Revenues and Expenses of Intercollegiate Athletics
Programs:  Financial Trends and Relationships, 1993.  Overland Park,
Kans.:  NCAA, 1994. 

Grant, Christine and Mary Curtis.  Gender Equity:  Judicial Actions
and Related Information.  Iowa City, Iowa:  University of Iowa, 1996. 
http://www.arcade.uiowa.edu/proj/ge (cited Mar.  1, 1996). 

Knight Foundation Commission on Intercollegiate Athletics.  Reports
of the Knight Foundation Commission on Intercollegiate Athletics: 
March 1991 - March 1993.  Charlotte, N.C.:  Knight Foundation
Commission on Intercollegiate Athletics, 1993. 

Lederman, Douglas.  "A Chronicle Survey:  Men Far Outnumber Women in
Division I Sports." Chronicle of Higher Education (Apr.  8, 1992), p. 
A1.  http://www.chronicle.com (cited Mar.  21, 1996). 

Lyndon B.  Johnson School of Public Affairs.  Gender Equity in
Intercollegiate Athletics:  The Inadequacy of Title IX Enforcement by
the U.S.  Office for Civil Rights, Working Paper No.  69.  Austin,
Tex.:  University of Texas at Austin, 1993. 

National Collegiate Athletic Association.  Participation Statistics
Report, 1982-1995.  Overland Park, Kans.:  National Collegiate
Athletic Association, 1996. 

National Federation of State High School Associations.  1995 High
School Athletics Participation Survey.  Kansas City, Mo.:  National
Federation of State High School Associations, 1995. 

Raiborn, Mitchell H.  Revenues and Expenses of Intercollegiate
Athletics Programs:  Analysis of Financial Trends and Relationships,
1985-1989.  Overland Park, Kans.:  NCAA, 1990. 

Tom, Denise, ed.  "Title IX:  Fairness on the Field." USA Today,
three-part series (Nov.  7-9, 1995), pp.  4C, 8C. 

Women's Basketball Coaches Association.  1994 Survey of WBCA Division
I Head Coaches.  Lilburn, Ga.:  WBCA, 1994. 


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