Wausau board adopts updated Title IX policies to meet new federal requirements

The Wausau School District board on July 8, 2024, approved revised Title IX policy language to align district procedures with recent U.S. Department of Education amendments that the administration said take effect Aug. 1.

Administration attorney-backed edits and a new policy (2264) for incidents occurring Aug. 1, 2024, onward and revisions to existing policy 2266 for prior events were presented by district staff. The presenter said the federal amendments, released April 17, broaden the definition of "hostile work environment," expand the district's duty to respond to complaints, and allow complaints to be filed orally as well as in writing. The district's attorney advised removing a fixed "two-day" response requirement and replacing it with language like "promptly after learning" to reflect a reasonable timeline.

The presentation stressed that the changes affect multiple roles and processes: the Title IX coordinator, investigators, decision-makers and appeal decision-makers have adjusted or blended duties; supportive measures available to students and staff are expanded; and certain student- and staff-specific provisions (including pregnancy-related protections) were clarified. The administration emphasized the district must have an approved policy in place by Aug. 1 to remain aligned with the federal amendments tied to continued federal funding.

Board members pressed for more documentation comparing Neola template language with the district attorney's edits and asked for legal rationale for recommended deviations from Neola. One member said they were uncomfortable approving substantial wording without seeing redlines and legal notes; another noted that several states have filed appeals against the federal modifications and sought clarity on consequences if the district did not adopt new language by the deadline. The administration said the district consulted its attorney, who had also conferred with Neola attorneys, and offered to return in August with a full redline and legal background.

The board voted to approve the updated Title IX language presented at the meeting, with administrators and the board agreeing to bring back a marked-up comparison and supporting legal analysis at the next meeting so members can review the precise changes and their implications.

What happens next: The district will apply policy 2266 to allegations that occurred prior to Aug. 1, 2024, and policy 2264 to allegations on or after Aug. 1. The board said it will revisit the draft language in August with redlines and attorney notes before making any further amendments.