03/28/22 – 2021-2022 Title IX Annual Report and Participation List Submission

March 28, 2022 Athletic Department Blog Updates

Schools are now able to access all of the required online forms to submit their 2021-2022 Title IX Annual Reports. The information in this post presents a summary for each school as you work to complete the required Annual Participation Report as well as the Title IX Report for 2021-2022.

• The deadline for submission is May 2, 2022.
• The online system is currently available for entry and is the only acceptable means of submitting the report.
• If you have specific questions about Title IX and the law itself, our office should be able to help get you some assistance. Asst. Commissioner Darren Bilberry (dbilberry@khsaa.org) is our primary contact for your questions related to the law and its interpretations, and the Commissioner and General Counsel are available should you have other inquiries of that type.
• As for the reports, Information Technology Director Rob Catron (rcatron@khsaa.org) can assist you with electronic issues, including login and report preparation using the online system.

Revisions and Procedures Only for 2021-2022

Obviously, Covid-19 has altered the way each of us operates. However, we have developed alternatives to the traditional reports that should help as we move forward.

• All three roster levels of your school’s sport/sport activities should be included. Please keep the notes below under the Roster and Team Requirements section in mind as you begin to work on your report(s).
• Keep in mind per the Title IX law, part of the purpose of this report is to determine how many athletes were provided the service of coaching and other benefits, and actual game participation (or not participation) does NOT eliminate an athlete or coach from being counted.
• Coaches must be specific as to their original intentions for who was to be on what level team, regardless of actual game play or the number of games.
• Our field audit staff is NOT available at this time as we have temporarily suspended the work of all part-time employees for the current pandemic period. You will be advised when those individuals are back in the office and available in case you have follow-up questions following the submission of your reports.

T61 and T63 Survey Notes:

• Schools are required to submit the student survey with the Title IX report for the 2021-2022 school year.
• A 60% response rate is required on the survey, which is a change from prior years.
• Schools that are not in person can utilize virtual/online teaching resources to have students complete the survey in the same manner as you have managed distance learning.  
• Information Technology Director Rob Catron (rcatron@khsaa.org) can assist you if you wish to request a link to administer the survey. 
• A T63 form is required for all schools for 2021-2022.

Gender Equity Review Committee (GERC) Notes:

• GERC missing meetings may be held prior to the May 2 deadline in order to meet the requirement.
• GERC failure to meet must be noted in the Improvement Plan (Form T60).
• GERC meetings can be conducted virtually.

Final Reports:

• Title IX Reports including summary forms will be provided and published, as well as an acknowledgment from Mr. Bilberry, however, will be Covid-19 noted and no determination made as to compliance with Test 3.

Roster and Team Requirements and Notes

1. All teams that compete interscholastically (against other schools) at any level (freshmen, JV, or varsity) in the twenty sports and sport-activities in which the KHSAA offers a championship shall be included (including both seasons of the Esports offerings).
2. If the sport is a KHSAA sport or sport-activity this year and you had at least one legal practice, then you had that team and should record data including coaches and rosters.
3. Remember that you cannot delete a team level if there are coaches assigned to that team or players assigned to the roster of that team.
4. You cannot delete the level of a team that has practiced this school year. However, you should delete a team (or level of a team) that has had no players, no coaches, no practices, and no contests during the entire school year.
5. Please record your rosters completely and accurately in all sports and sport-activities.
6. In 2021-2022 all sports and sports activities should be included if the association has jurisdiction over that sport or sport activity. If the sport or sport activity is NOT under KHSAA jurisdiction this year (i.e., Ice Hockey, Trap Shooting), then you must have played a minimum of 10 contests against other schools, the team must be under the same supervision as other sports (i.e., the Athletic Director), and the other criteria previously explained in Title IX workshops and other communication.
7. As a refresher, the link to maintain your teams is entitled, “Maintain School Control Panel/Sport Offerings.” The link is located in the “Primary School Database Operations” section of links on your member school login page. Direct link: http://schools.khsaa.org/schools_update/.
8. Although mistakes do occur on the Varsity level, it is apparent that the vast majority of the issues in the roster system pertain to Freshman and/or Junior Varsity teams.
9. Breaking this down further, the majority of the time we see that teams are listed without any players at all on them (which means that someone just forgot to remove the sport offering when you didn’t have enough interest), or that a team sport is listed at a level (freshman, JV or varsity) and roster entry is incomplete or the roster is without enough players to actually field the team (for example, a school stating that they have a JV Football Team, but only has 4 players listed).
10. IT Director Rob Catron also has produced a video that describes the process of adding and removing a team. The direct link to this video is at http://schools.khsaa.org/help-update-member-school-information-non-personnel/.

Notice and Information

1. Roster and team errors were identified and displayed in each School Administrators’ “Your Messages” notification area from within their KHSAA Member School Login.
2. Those specific notices point out specific teams that do not have enough players, and the messages are in a bright red font.
3. Click on the particular error notice to expand and receive more details.
4. If you have roster editing rights (which are assigned to all Principals and ADs, and coaches within the school who have been granted such rights by the AD), you can begin the cleanup process.

Annual System and Reporting

1. This year, based on feedback from the membership, there have been minimal system changes to make this task easier.
2. You will not be able to submit your reports if you have incomplete rosters. Based on roster minimums, the system will instruct you to complete your roster(s) or revise your team grid.
3. The answer is NOT to simply delete nonvarsity teams now that the season is over. The answer is to make a subjective evaluation as to whether or not you actually had the team for 2021-2022, and if so, ensure that an accurate roster is complete.
4. In a routine review of our database, it is evident that a substantial number of member schools have team-related issues that must first be corrected.
5. 2021-2022 is a student interest survey year for all member schools.   
6. The T63 form will NOT allow for entry of a student interest survey if there is less than a 60% response rate. In addition, any entry of 0 as the interest of the students will have to be confirmed since our audit team has found it highly unlikely that no student in the entire survey audience has an interest in a specific sport or sport-activity.
7. Schools again are able to submit both the Title IX report and the Annual Participation list at the same time since both are based SOLELY on a minimal amount of additional data entry and the contents of your online rosters for all sports and sport-activities.
8. *NOTE* Single-gender schools may enter your Participation List information in the same manner, simply bypassing the Title IX information. The system will guide you through the steps.

Final Steps Prior to Forms Entry

There are four primary things that must be done before you start with your actual Title IX and Participation reports:

1. Ensure that all of your team rosters have the minimum number of competitors entered on the roster and have coaches assigned. Throughout this year and in reviewing data from last year, the staff has noticed that several sports had incomplete rosters or listed no one on the non-varsity rosters. This will result in inaccurate data and counting at a minimum and a KHSAA eligibility concern at the worst.
2. Please take the time to check and edit all of your rosters, including the freshman, JV, and varsity levels.
3. A note about wrestling: We have noticed that in sports like wrestling that have an electronic entry portal for events that is separate from the KHSAA system, many schools have not entered the entire roster into the online system and had only entered them into the NWCA system. Remember, your student-athletes are not eligible to participate in a scrimmage or game in any sport or sport-activity if they are not listed on the KHSAA online roster. The postseason columns do not affect any results, only the freshman, JV, and varsity rosters.
4. The same situation as Wrestling exists at times for Track and Field, Cross Country, and Swimming, so ensure that the rosters match from the outside organization site to your school data.
5. Be certain and enter your complete rosters for Competitive Cheer and Competitive Dance, including all levels if you maintain more than one. Keep in mind, you DO NOT list individuals on your cheer or dance rosters if you do NOT compete in the KHSAA Region or KHSAA State competitions, and the sole role is sideline support.  In addition, do not list the members who ONLY cheer or dance at games and are not on your competitive squad. The software will properly exclude the cheerleaders from Title IX reports, but properly include the members on your participation lists.  Competitive Dancers are included in both the Title IX and participation lists.  Likewise, the same rules apply for the coaching staff, ONLY enter coaches if they coach your competitive cheer and/or dance squads.
6. Lastly, have your 2020-2021 financial expenditures data available (including booster expenditures) so that you can complete form T-35. 

Data Entry:

• Once you have completed these steps, you will then log in to the online system and begin your reports.
• Our Information Technology Director Rob Catron has recorded a series of short videos that help with all of the entry functions for rosters and completion of the reports. If you log in tohttp://schools.khsaa.org, there are buttons in the column on the right that take you to these videos.
• Before beginning, it would be advisable to view the videos related to the Roster Entry and Title IX reports, particularly the roster review video on the Title IX page. It is in this important step (roster review) that you can remove individuals who did not participate but may, in fact, be holdovers from past years.
• No paper needs to be submitted and there is NO option for paper submission of the reports. The forms that are posted on the website are samples for you to use in beginning to compile the report and are especially helpful when completing the salary and expense information (T-35). When you submit your report, it will automatically produce the compiled report (in PDF format) and the office will be alerted to its receipt. From there, the Title IX audit staff will review the documents and return any notes to you.

Final Notes:

• Be ever mindful that participation data comes ONLY from the online roster entry. There is no option to count participants and enter the numbers manually; they come totally from your rosters. It is critically important for Title IX counting purposes that you accurately designate which players played multiple levels of the sport, including those below grade 9. If they played freshman, JV, and Varsity, for example, be sure all boxes are checked.
• Mr. Catron’s videos are very direct in terms of adding players, deleting players, and ensuring that the rosters are accurate. Again, you would be advised to view them first.
• Enrollment data from the 2019-2020 school year is based on the KDE data used in classification and has already been seeded into the reports (including the non-public school data submissions). No numbers may be revised or otherwise utilized for enrollment.
• Once your Title IX report has been submitted, you can then immediately electronically submit your Annual Participation List. You will then be able to print copies of both reports for your records should you so desire.

Thanks, and we look forward to receiving your report.