Navigating Title VI Compliance in a Post-DEI Environment

In the wake of the February 2025 Dear Colleague Letter (DCL) and subsequent legal challenges, federally funded colleges and universities (actually, any preschool or K – 12 institution that receives federal funds) have entered a new era of compliance expectations. Institutions that have championed Diversity, Equity, and Inclusion (DEI) efforts must now reassess how those programs align with Title VI of the Civil Rights Act, which prohibits discrimination based on race, color, or national origin.

To further complicate matters, a federal injunction issued in April 2025 has temporarily paused enforcement of several elements of the DCL and related documents. However, institutions must still prepare for the likely evolution of federal oversight and ensure their practices are compliant while staying true to their mission.

This article was prompted by a recent webinar I attended, hosted by a respected PR organization and featuring a leading Michigan legal firm. The session centered on Title VI and post-DEI compliance but offered surprisingly few actionable takeaways. That experience motivated me to develop a framework that may be helpful for institutions to assess their communications and programs and begin to adapt with intention.

So, what should your institution do now?

1. Understand the Scope of the Changes

The DCL raised red flags for any federally funded institution using race-based criteria in programming, scholarships, or hiring. Even if your institution is not directly affected by the current court injunction, the DCL signals a broader regulatory shift. Preparing now could help you stay ahead of future rulings.

2. Conduct a Strategic Audit

A proactive audit allows institutions to examine their DEI-related programs, communications, and policies through the lens of compliance. It also creates a framework for identifying risks and adapting practices in a thoughtful, mission-aligned way.

To support this, here is a Title VI Compliance & Communications Audit Checklist. This tool walks you through key areas to assess—from programming and messaging to policy alignment and stakeholder engagement.

→ [Download the PDF Checklist]

3. Shift Language Without Losing Meaning

Many institutions are now revisiting how they communicate their values. Instead of using terms like "diversity" or "equity," colleges can focus on student success, inclusion, and belonging through more neutral, mission-aligned language. For example:

• Original: "We foster diverse workplaces and classrooms."

• Alternative: "We strive to ensure every employee and student feels supported, respected, and able to contribute fully."

  
  

This approach is more compliant while still signaling your institutional commitment to fostering an environment of belonging and support.

4. Engage Your Legal, Communications and Other Teams

This is not just a legal issue—it's a messaging and reputational one. Collaborate across departments to align your language, policies, and promotional materials. Offer updated training and clear guidelines that equip your staff to communicate effectively and in compliance with Title VI.

5. Keep Listening, Learning, and Adapting

The legal landscape is still evolving. Stay connected to updates from the U.S. Department of Education's Office for Civil Rights (OCR), your state system, and peer institutions. Above all, stay grounded in your mission to serve students and communities equitably and effectively.

Need help with a communications audit or re-messaging? Contact Villa Marketing, LLC today and let's get started.

Disclaimer: This article is intended for informational purposes only. I am not an attorney, Title VI expert, or HR professional and the content herein does not constitute legal or professional advice. Institutions should consult with their legal, HR, and Title VI teams to ensure full compliance.