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Perkiomen Valley board reviews new Title IX policy and maps rules for schools under injunction
Summary
Solicitor and administration outlined proposed Policy 103.2 to implement the August 2024 Title IX regulations for district schools not covered by a court injunction; the committee discussed off‑campus jurisdiction, appeal changes and a planned website list of schools subject to the policy.
Solicitor Ryan Moran told the Perkiomen Valley School District policy committee that the district must split its discrimination and harassment rules because some schools remain covered by a court injunction while others will be governed by the U.S. Department of Education’s August 1, 2024, Title IX regulations.
"The first policy we're gonna review is 103, and this is the policy ... governing discrimination," Moran said as he walked the committee through proposed changes that move Title IX‑specific definitions and procedures into a new Policy 103.2. He told the board the goal is a clear line between conduct that occurred before Aug. 1, 2024, and conduct that occurs afterward.
Moran underscored two operational complications: (1) certain schools are listed in a court injunction, so they must continue to follow pre‑regulation policies (103 and 104), and (2) other schools not listed in the injunction would be governed by 103.2 for Title IX harassment and discrimination occurring on or after Aug. 1, 2024. "If those schools get added to the injunction, then they would be added to our website, and then they would not be governed under 103.2," he said, describing a plan to publish the list of covered schools when notice is received.
Key changes flagged for administrators and the board included a narrowed appeal filing standard under 103.1 — appeals must state specific grounds — and a procedural reorganization that moves Title IX definitions and some investigatory procedures into 103.2 and Attachment 3. Moran also highlighted new regulatory text making Title IX protections potentially apply to off‑campus or out‑of‑country conduct: "even if some conduct occurred outside of the educational program or activity or outside the United States," the new language says.
Moran said the district will move toward a single‑investigator/decision‑maker model in schools governed by 103.2, and he identified certain "confidential employees" (school psychologists, counselors, social workers, nurses) whose confidentiality obligations the policy will recognize while clarifying limits where safety concerns exist.
Board members sought operational clarity about how quickly the district must act if a school’s injunction status changes. Moran recommended posting the current list of injunction‑covered schools on the district website and removing or adding schools as official notices arrive; he said additional policy edits would be required if the litigation resolves.
The committee did not take a final vote on 103/103.2/104 at the meeting; administrators indicated the policies will proceed through the district’s policy reading schedule and would be adjusted if the courts alter the injunction. The board agreed to incorporate solicitor and Fox Rothschild counsel input and to include attachment text plainly in materials for first reading so readers do not need to hunt for the definitions.
