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Compliance officer outlines Title IX and state-law changes; policy updates sent to full committee

March 29, 2025 | Lynn Public Schools, School Boards, Massachusetts


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Compliance officer outlines Title IX and state-law changes; policy updates sent to full committee
The Lynn Public Schools compliance officer briefed the policy subcommittee on a set of revisions to the district’s nondiscrimination and harassment policies and the subcommittee voted to send the drafts to the Committee of the Whole.

Charlie Gallo, Lynn Public Schools compliance officer and Title IX coordinator, told the committee the federal Title IX standard in effect prior to 2024 uses a higher threshold for sexual-harassment findings — "severe, pervasive, and objectively offensive" — limited to sex-based harassment or discrimination. He said the Biden Administration’s 2024 changes expanded that standard but were swiftly rolled back by courts, and the district’s proposed drafts revert Title IX policy language to the 2020 standard recommended by counsel and statewide school associations.

Gallo explained how the proposed policy package separates federal Title IX coverage from state protections: it designates ACA (the harassment policy) for Title IX-specific matters, moves general protected-class coverage into the district’s broader nondiscrimination policy, and relies on Massachusetts law to investigate and address conduct not covered by Title IX. "ACA becomes Title IX only," he said, and an accompanying policy, ACA B, would cite Massachusetts law and apply to employees and students for categories not covered under federal Title IX.

The subcommittee discussed the policy drafts and then moved three policies — ACA, ACAB and AC — to the Committee of the Whole for consideration. The motion carried on a roll-call vote with members present voting yes. The subcommittee later forwarded additional batches of internal-facing and student-facing policies (groups labeled A–I and J–L in the packet) to the Committee of the Whole for review as well.

Gallo noted attorneys from the district’s counsel and the Massachusetts Association of School Committees participated in drafting the revisions. He said the district also revised student-facing policies (responsible technology use, dress code, bullying) to reflect the broader nondiscrimination list and recommended internal policies reference the main nondiscrimination policy to avoid repeated laundry lists if protected classes change in the future.

The policy drafts will be considered by the full Committee of the Whole; committee members had no final votes on the content at the March 27 meeting beyond forwarding the drafts for committee review.

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