On February 14, 2025, the US Department of Education’s Office for Civil Rights (OCR) issued a Dear Colleague Letter in which OCR announced that it would begin applying the race discrimination protections set forth in Title VI of the Civil Rights Act of 1964 in a broader context beyond college admissions, and that OCR would begin “tak[ing] appropriate measures to assess compliance” with Title VI and applicable regulations in order to eliminate the use of racial preferences and stereotypes in education programs and activities.
On March 14, 2025, OCR announced that it had begun investigating 52 institutions of higher education (IHEs) that OCR suspects of violating Title VI. In its press release, titled “Office for Civil Rights Initiates Title VI Investigations into Institutions of Higher Education,” OCR states that it is investigating 45 of those IHEs based on their partnership with “The Ph.D. Project,” six IHEs based on allegedly “awarding impermissible race-based scholarships,” and one IHE for allegedly administering a “program that segregates students on the basis of race.”
According to OCR, The Ph.D. Project is “an organization that purports to provide doctoral students with insights into obtaining a PhD and networking opportunities, but limits eligibility based on the race of participants.” The 45 IHEs under investigation by OCR for partnering with the Ph.D. Project are:
- Arizona State University – Main Campus
- Boise State University
- Cal Poly Humboldt
- California State University – San Bernadino
- Carnegie Mellon University
- Clemson University
- Cornell University
- Duke University
- Emory University
- George Mason University
- Georgetown University
- Massachusetts Institute of Technology
- Montana State University–Bozeman
- New York University
- Rice University
- Rutgers University
- The Ohio State University – Main Campus
- Towson University
- Tulane University
- University of Arkansas – Fayetteville
- University of California–Berkeley
- University of Chicago
- University of Cincinnati – Main Campus
- University of Colorado – Colorado Springs
- University of Delaware
- University of Kansas
- University of Kentucky
- University of Michigan–Ann Arbor
- University of Minnesota–Twin Cities
- University of Nebraska at Omaha
- University of New Mexico – Main Campus
- University of North Dakota – Main Campus
- University of North Texas – Denton
- University of Notre Dame
- University of Nevada – Las Vegas
- University of Oregon
- University of Rhode Island
- University of Utah
- University of Washington–Seattle
- University of Wisconsin–Madison
- University of Wyoming
- Vanderbilt University
- Washington State University
- Washington University in St. Louis
- Yale University
The IHEs under investigation by OCR for alleged impermissible race-based scholarships and race-based segregation are:
- Grand Valley State University
- Ithaca College
- New England College of Optometry
- University of Alabama
- University of Minnesota, Twin Cities
- University of South Florida
- University of Oklahoma, Tulsa School of Community Medicine
If you have any questions regarding the content of this alert, please contact Buster Melvin, Higher Education Team co-leader, at emelvin@barclaydamon.com; Chloe Shortz, associate, at cshortz@barclaydamon.com; or another member of the firm’s Higher Education Team.