Recently, New York Governor Kathy Hochul signed a bill into law which is now NY Educ Law § 6436-a, and it requires Title VI coordinators on every college campus across the State.
Title VI of the Civil Rights Act of 1964 is a federal law that prohibits discrimination on the basis of race, color, or national origin in any program that receives federal funding. Title VI coordinators are focused on colleges and universities only for now. The job is designed to work with students, faculty, and staff to combat discrimination on campus.
What’s Section 6436‑a All About?
At its core, section 6436‑a is designed to strengthen compliance with Title VI of the Civil Rights Act of 1964 which generally prohibits discrimination across the country on the basis of race, color or national origin. The New York State law specifically:
- Requires each college and university in New York to designate a Title VI Coordinator within 90 days of August 26, 2026.
- Empowers the coordinator to act as the central point of contact for all discrimination-related issues which is designed to ensure a streamlined and consistent response process
- Assigns clear duties to the coordinator, including:
- Offering supportive measures to individuals making discrimination complaints;
- Notifying those who complain about relevant policies and procedures; and
- Managing a fair and effective system for investigation and resolution.
- Mandates the State Division of Human Rights, in collaboration with higher education institutions, to develop annual training materials for both students and staff, making sure that all stakeholders understand their rights and responsibilities under Title VI
- Requires the coordinator to notify all students and employees about the nondiscrimination policy statements, links to reporting procedures, contact information, and other pertinent details
- Includes provisions for designees, training for coordinators and their teams, and comprehensive recordkeeping of all reports, investigations, actions taken, and training attendance. There also will be training for students on Title VI procedures effective August 26, 2026.
State Ed Site Visits
Title VI coordinators are designed to ensure that college campuses are sufficiently compliant with Title VI. The New York Education Department conducts site visits to check on whether post-secondary institutions receiving federal funds are fully accessible and don’t engage in discrimination. The new law should ensure that all institutions easily pass these site visits so long as their new Title VI coordinators do their job.
With New York being the first, it wouldn’t be hard to imagine that other States may follow in a wave that is reminiscent of the Title IX expansion in the early 2010s. In fact, the University of Delaware and the University of Mississippi both created job postings for a Title VI coordinator. The new wave may have officially begun.
Compliance with Non-Discrimination Laws
If you have any questions or concerns about how to ensure your organization’s compliance with Title VI or simply with New York’s and the federal government’s anti-discrimination laws, please reach out at info@coppolalegal.com or call us at 716-839-9700. We can help design policies and provide trainings and ensure your compliance goals are met – so you don’t have to worry about risk.
Remember, we’re here to help.
