High School Sports: Many Schools Encouraged Equal Opportunities, but Education Could Further Help Athletics Administrators under Title IX

Research has found that sports participation yields many benefits for youth. Girls' participation in sports has increased dramatically since the passage of Title IX in 1972, but is still lower than for boys. Further, investigations by OCR, which enforces and implements Title IX, have highlighted instances of disparities in the resources provided to girls' and boys' teams.

GAO was asked to review how public high schools encourage equal athletic opportunities. This report examines (1) measures public high schools and athletics administrators have taken to encourage equal athletic opportunities for boys and girls, and (2) factors that affect boys' and girls' participation levels in public high school sports programs. GAO conducted a nationally generalizable probability survey of athletics administrators at 784 public high schools. GAO interviewed nine subject matter specialists selected to provide a range of perspectives. GAO also reviewed relevant federal laws, regulations, and guidance and interviewed OCR officials.

According to GAO's nationally generalizable survey of athletics administrators, public high schools recently took various measures to encourage equal opportunities for boys and girls in sports. For example, a majority assessed resources such as equipment, travel opportunities, and facilities that they provided to girls' and boys' teams and some schools took steps to gauge student interest in specific sports as a means of encouraging equal opportunities, according to GAO's survey. Education's Office for Civil Rights (OCR) guidance indicates that Title IX coordinators—which school districts are required to designate and make visible per regulations for Title IX of the 1972 Education Amendments (Title IX)—should work closely with athletics administrators to determine whether action is needed to address any underrepresentation, or to otherwise encourage equal athletic opportunities. However, GAO estimates that 51 percent of athletics administrators either were unaware of or unsupported by their Title IX coordinator, according to the survey (see figure). These findings raise questions as to whether Title IX coordinators are familiar with and using Education's guidance. Officials from an association for Title IX coordinators said this lack of communication with athletics administrators may be related to some Title IX coordinators' limited understanding of Title IX and athletics. OCR officials said that they did not know the extent to which Title IX coordinators are working with their athletics administrators to encourage equal athletic opportunities because Education generally does not collect this information. Better information on Title IX coordinators could help Education support school districts' efforts to encourage equal sports opportunities for girls and boys.

The factors that most affect boys' and girls' participation in public high school sports are the number of, and interest in, participation opportunities offered, according to GAO's survey and interviews with nine subject matter specialists. Though the survey provided no clear consensus on factors that discourage students from participating in sports, athletics administrators most often perceived students' competing responsibilities as discouraging participation.

GAO is recommending that OCR determine the extent of K-12 Title IX coordinators' knowledge and use of tools in its existing guidance and use this information in its efforts to encourage them to work with athletics administrators to help ensure equal athletic opportunities. Education partially concurred, stating it would consider GAO's recommendation in its complaint investigations, technical assistance activities, and communication practice reviews.

We have previously reported that sports participation yields many benefits  for youth, ranging from positive health outcomes to improved academic  achievement to increased self-esteem, and schools are uniquely  positioned to provide students with opportunities to participate in sports.  We have also reported that girls began playing high school sports in large  numbers only after the passage of Title IX of the 1972 Education  Amendments (Title IX), which prohibits discrimination on the basis of sex  in any education programs and activities by recipients of federal financial  assistance. However, girls’ sports participation remains lower than boys’  participation. Further, the Department of Education (Education) has found  instances of disparities or potential disparities in the benefits and services  provided to girls’ and boys’ teams, including equipment, facilities, and  schedules for practices and games.

You asked us to examine how public high schools encourage equal  athletic opportunities for members of both sexes. This report examines  (1) what measures public high schools and athletics administrators have  taken to encourage equal athletic opportunities for boys and girls, and (2)  what factors affect boys’ and girls’ participation levels in public high  school sports programs.

To examine both of these questions, we conducted a nationally  generalizable web-based survey of athletics administrators in a stratified,  random sample of 784 U.S. public high schools. The survey asked about  factors that encourage or discourage boys’ and girls’ participation in  interscholastic sports (team-based organized sports activities that offer  competition among schools), activities schools conduct related to  encouraging equal opportunities in these sports, and challenges they  encounter in doing so. The survey, which we administered from June  through early September 2017, had a weighted response rate of 42  percent, and the results are generalizable. To obtain additional context  and illustrative examples to supplement our survey data, we conducted  follow-up interviews with eight athletics administrator respondents, who  were selected for variation in their survey responses, such as the extent  to which they conducted activities to encourage equal opportunities, and  their schools’ characteristics, such as locale type (urban, suburban, or  rural). We also interviewed subject matter specialists at nine  organizations, including national associations of athletics and Title IX  administrators (whose membership includes Title IX coordinators);  organizations that advocate for sports and gender equity issues; and  research centers that study these issues. We selected individuals and  organizations to interview to represent a range of perspectives on these  issues. We also reviewed federal laws, regulations, and guidance, and  interviewed officials at Education’s Office for Civil Rights (OCR). Our  analysis should not be used to make conclusions about legal compliance  with Title IX requirements or the presence or absence of discrimination in  public high school interscholastic sports programs.

We conducted this performance audit from February 2017 to May 2018 in  accordance with generally accepted government auditing standards.  Those standards require that we plan and perform the audit to obtain  sufficient, appropriate evidence to provide a reasonable basis for our  findings and conclusions based on our audit objectives. We believe that  the evidence obtained provides a reasonable basis for our findings and  conclusions based on our audit objectives.

Research has found that girls’ participation in sports has increased  dramatically since the passage of Title IX. However, research has also  found that progress toward equal sports participation between boys and  girls has slowed since 2000, and a participation gap remains between the  sexes. We previously reported that federal data from school year 2013- 14 showed that national girls’ participation rates in public high school  interscholastic sports remained nearly 10 percentage points lower than  boys’ rates. The same data showed that at nearly half of schools, girls’ share of sports participation was less than their share of enrollment by 5  percentage points or more.

Within Education, OCR enforces and implements Title IX, which applies  at all educational levels, including colleges, universities, and public school  districts, with limited exceptions. OCR’s most recent annual report  describes its mission as ensuring equal access to education and  promoting educational excellence throughout the nation through vigorous  enforcement of civil rights laws. OCR’s core activities include  responding to civil rights complaints filed by the public and conducting  agency-initiated investigations to enforce federal civil rights laws;  providing technical assistance to help institutions achieve compliance with  the civil rights laws that OCR enforces; and issuing regulations and policy  guidance to ensure equal access to educational opportunity. OCR also  conducts the Civil Rights Data Collection (CRDC), which collects key  information related to civil rights from public elementary and secondary  schools and school districts, including information on interscholastic  sports and teams offered for boys and girls and their participation.

With respect to athletics, Education’s Title IX regulations require schools  that offer sports teams to provide equal opportunities for members of both  sexes. The regulations, along with OCR guidance, specify key elements  OCR considers, among other things, in determining whether schools are  offering equal opportunities (see fig. 1). OCR uses the number of  participants on a school’s sports teams as a proxy for participation  opportunities when determining whether those opportunities are  proportionate for boys and girls.

Recipients of federal education funds, such as public school districts,  bear the responsibility for complying with Title IX. Districts are required  to designate an employee to coordinate efforts under Title IX, and to  make this Title IX coordinator visible. In 2014, we recommended OCR  clarify and disseminate information on the roles and responsibilities of  these Title IX coordinators. In response, during fiscal year 2015, OCR  issued several pieces of Title IX guidance, including a Dear Colleague  letter delineating the specific requirements and duties of coordinators, in  addition to a letter to coordinators and a Title IX resource guide, which  includes guidance on monitoring compliance in athletics. This guide  states that the Title IX coordinator should work closely with many different  members of the school community, including athletics administrators.  Regarding athletics, it recommends tools that Title IX coordinators can  use to encourage equal opportunities in athletics, which include  evaluating whether there is unmet interest in a particular sport and  comparing expenditures on boys’ and girls’ sports teams as an indicator  of benefits provided to those teams.

Athletics Administrators Reported Schools Took Some Steps to Encourage Equal Opportunities, but About Half Did Not Receive Title IX Coordinator Support

To Encourage Equal Opportunities, the Majority of Athletics Administrators Reported That Their Schools Assessed Resources Provided to Boys’ and Girls’ Teams

The majority of public high schools assessed some aspects of their sports  programs over the past 2 years to encourage equal opportunities for  boys’ and girls’ sports teams, according to our nationally generalizable  survey of athletics administrators. Specifically, the estimated percentage  of schools assessing key athletic resources provided to these teams  ranged from 63 percent of schools assessing travel opportunities to 76  percent assessing uniforms (see fig. 2).

In our interviews with eight athletics administrators, we heard a variety of  approaches to assessing these resources. For example, when scheduling  practice times and competitions, five athletics administrators said that  they scheduled a boys’ competition only if they could also schedule a  girls’ competition. Four athletics administrators described watching  practices, inspecting equipment to identify when it needed replacement,  or replacing equipment as their coaches requested it. Four athletics  administrators said that coaches can sometimes influence the distribution  of resources. For instance, one athletics administrator noted that in the  past, his school had unequal facilities for boys’ baseball and girls’ softball,  stemming in part from the boys’ baseball coach being a stronger  advocate for his team. However, these athletics administrators generally  described working with the coaches to ensure that resource allocation did  not create inequalities.

Most schools reported using a mix of public and private funds to support  their athletic programs. An estimated 75 percent of public high schools  received public funding (state or local) for their sports programs; for some  individual sports or school athletics programs, public funding may be the  primary funding source. We estimate that about 52 percent of schools  that received public funding monitored or directed its use to help  encourage equal resources for boys’ and girls’ teams. OCR’s Title IX  Resource Guide encourages Title IX coordinators to periodically review  expenditures on male and female athletic teams as part of their review of  resources. At four schools, athletics administrators told us that they paid  attention to the actual resources girls and boys received rather than  focusing on expenditures, and three of these administrators explained  there could be valid reasons for spending differences. For example, one  athletics director said that both boys’ and girls’ hockey teams at his  school participated in annual tournaments, but the girls preferred a  tournament that did not require a hotel stay, so it was less expensive.

In addition, we estimate that about 81 percent of public high schools had  at least one booster club and, according to our survey, an estimated 51  percent of these schools monitored or directed the club to encourage  equal opportunities. Among the eight athletics administrators we  interviewed, relationships with booster clubs varied. For instance, some  issued booster club guidelines and approved their purchases in advance,  while others had no oversight of booster club expenditures. For  example, one athletics administrator told us that he provides booster club  presidents with written guidelines and approves purchases to make sure  they do not create a Title IX compliance issue. Another athletics  administrator’s school had recently undergone negotiations to obtain  access to booster club expenditure records for the first time so that they  could regularly review those expenditures. OCR has stated in compliance  decisions, and OCR officials confirmed to us in interviews, that it  considers resources provided through the use of private funds, including  booster funding, in assessing whether schools are providing equivalent  resources to teams of each sex. An official from a national association  representing athletics administrators stated that administrators who take  the association’s Title IX trainings are often surprised to learn they should  monitor or direct booster club spending to help ensure equal  opportunities.

Some Athletics Administrators Reported That Their Schools Used Surveys and Other Tools to Gauge Student Sports Interests, Which Can Help Encourage Equal Opportunities

In addition to assessing the various school and booster club resources  provided to boys’ and girls’ teams, some schools recently took steps to  gauge student interest in specific sports as a means of encouraging equal  opportunities, according to our survey. For example, we estimate that 40  percent of schools surveyed students about their sports interests over the  last 2 school years and 25 percent added or changed their sports  offerings based on requests from the underrepresented sex in their  school’s sports program (see fig. 3).

An estimated 31 percent of schools had not recently used any of these  tools, or did not know if they had used the tools, to gauge student interest.  And, according to our analysis of Education’s data, 60 percent of schools  had one sex underrepresented by more than 5 percent in their sports  programs in school year 2013-14.

OCR guidance states that where one sex is underrepresented in sports,  schools can demonstrate they are providing equal participation  opportunities by using multiple indicators to identify, among other things,  whether the sports currently offered meet student interest. OCR  guidance also states that in its investigations the agency determines on a  case-by-case basis whether sports participation numbers at a school are  disproportionate, and whether the school is taking sufficient steps to  accommodate the athletic interests and abilities of both girls and boys.  In addition, OCR guidance describes tools that schools and school  districts can use to assess for themselves whether action is needed to  address any underrepresentation, or to otherwise encourage equal  athletic opportunities. According to the guidance, these efforts should be  led by the school district’s Title IX coordinator.

About Half of Athletics Administrators Were Either Unaware of or Unsupported by Their District Title IX Coordinator

About 51 percent of athletics administrators were either not aware of or  not supported by their Title IX coordinator, according to our survey.  Specifically, we estimate that 40 percent of athletics administrators– serving about 6,110 schools and 5 million students–were unaware of a  Title IX coordinator in their school district and that an additional 12  percent were aware of their Title IX coordinator but received little to no  support from them (see fig. 4). We also found that almost all of the  athletics administrators who were not aware of having a Title IX  coordinator were in a district that had, in fact, designated one.  Specifically, when we matched athletic administrators’ survey responses  with OCR’s data and extrapolated to the population overall, we estimated  that 99 percent of the athletics administrators who were not aware of a  Title IX coordinator in their district were in a school district that had listed  a coordinator in school year 2013-14. Further, an estimated 26 percent of  athletics administrators wanted additional guidance or assistance related  to encouraging equal opportunities for boys and girls, according to our  survey.

Given the significant number of athletics administrators who reported  being unaware of or unsupported by their Title IX coordinators, our survey  results raise questions as to whether Title IX coordinators—whom school  districts must designate and make visible in accordance with Title IX  regulations—are familiar with and using OCR’s guidance on their role and  responsibilities. This guidance states that the Title IX coordinator should  support and work closely with members of the school community,  including athletics administrators, to ensure compliance with Title IX.  When asked about these survey results, officials from an association for  Title IX coordinators and for other related administrators told us that they  were not surprised that a number of athletics administrators were not  aware of or supported by their Title IX coordinator, because the results  are consistent with what they hear when interacting with their members  across the country. Based on these interactions, these association  officials said they have observed that there is often a separation between  athletics and other school departments, and that Title IX coordinators  without an athletics background may be reluctant to engage in oversight  of that department.

Based on their experiences providing training to Title IX coordinators,  these association officials also said that Title IX coordinators’ familiarity  with Title IX requirements has improved somewhat since the release of  OCR’s 2015 guidance delineating their role and responsibilities, but their  familiarity with these requirements is still generally low, particularly with  respect to athletics. In these officials’ opinion, this lack of understanding is  due in part to the complex and wide-ranging nature of Title IX and to the  lack of resources for training in many school districts. These and other  subject matter specialists we interviewed said that other potential factors  contributing to athletics administrators’ lack of awareness of their Title IX  coordinator included high turnover among athletics administrators and  myriad responsibilities of staff in both roles. When Title IX coordinators do  not work closely with athletics administrators, as OCR guidance suggests  they do, they may miss opportunities to make those administrators aware  of tools the guidance recommends that could help advance equal  opportunities. In addition, OCR guidance recognizes that the most serious  Title IX violations tend to occur in districts without a supportive Title IX  coordinator.

OCR officials said that they had learned from their complaint  investigations and compliance reviews that some athletics administrators  were not working with their districts’ Title IX coordinators. However, these  officials said they did not know the extent to which Title IX coordinators  themselves were aware of and using the tools recommended in their  guidance because, outside of these enforcement activities, OCR  generally does not collect information on Title IX coordinators’ knowledge  of or activities related to the guidance. Standards for internal control in  the federal government state that agencies should both obtain quality  information from and communicate quality information to external parties  to help achieve the agency’s objectives and address risks. In OCR’s case, its objectives include ensuring schools actively encourage equal  opportunities for boys and girls as articulated in Education’s Title IX  regulations and OCR guidance, and risks include violations of Title IX that  have not resulted in formal complaints. Absent better information on Title  IX coordinators’ awareness and use of Title IX guidance, OCR may not  have a complete picture of school districts’ ongoing efforts to encourage  equal opportunities, challenges they encounter in doing so, and  successful strategies that might be shared with a broader audience.  Collecting and analyzing this information could enable OCR to target its  communication to Title IX coordinators, and further encourage them to  work with athletics administrators on ensuring equal athletic opportunities.

Available Opportunities Helped Drive Public High School Sports Participation Levels, but Family Resources and Other Factors Could Limit Participation

The Number of and Interest in Opportunities Offered by Schools Encouraged Higher Participation Levels

The number of participation opportunities schools offered, as well as  student interest in those opportunities and in working with specific  coaches at the school, were top factors that encouraged interscholastic  sports participation among public high school students, according to our  survey of public high school athletics administrators. We estimate that  over 70 percent of athletics administrators viewed the number of  interscholastic athletic participation opportunities at their school as  encouraging boys and girls to participate in high school sports (see fig.  5).

Our 2017 report on high school sports access and participation found that  in school year 2013-14, public high schools overall offered the same  number of sports and teams for boys and girls. Of the nine subject  matter specialists we interviewed for this report, six described specific  knowledge of factors that encourage or discourage participation in high  school sports. All six of these subject matter specialists agreed that  opportunity is an important factor affecting student participation,  especially for girls; several specialists also said that the continued  participation gap shows that girls do not have access to an equal number  of roster spots on teams as boys. For example, one researcher, as well  as a representative of a national association of athletics administrators,  suggested that one reason the gap between boys and girls persists is that  schools do not offer girls’ sports with roster sizes equivalent to popular  boys’ sports, such as football. One of the eight athletics administrators  said that this was the case at her school, noting that none of her girls’  teams came close to the size of the football teams. The gap may be  particularly acute for minority girls, according to one subject matter  specialist. Our 2017 report on public high school sports access and  participation found that, for both boys and girls, fewer students attended  high minority and high poverty schools that offered sports, compared to  students at other schools, and these schools had lower participation rates  when they did offer sports.

We estimate that over 75 percent of athletics administrators viewed the  level of student interest in the sports offered by their school as  encouraging participation in their school’s teams. Several subject matter  specialists agreed that offering sports that align with students’ specific  interests is an important aspect of providing meaningful opportunities, but  a few also noted that some schools fail to consider which sports most  interest their female students.

We estimate that 70 percent or more of athletics administrators viewed  student interest in working with certain coaches as a factor that  encouraged participation at their school. As explained by one researcher,  coaching quality plays a large role in encouraging high school sports  participation and a good coach can pull students into a sport and keep  them participating. Alternatively, another researcher noted that less  qualified or inexperienced coaches depress participation. These views  are consistent with our work, in which we reported that the quality of  coaching is a key factor in maximizing the positive effects of sports  participation on students’ personal development.

In addition, research shows that the state of athletic facilities can also  affect a student’s choice to participate in high school sports, and a few  athletics administrators and subject matter specialists we interviewed also  cited this as a factor. For example, one study found that proximity to  sports facilities was a factor predicting children’s participation in team  sports. Another study found that student participation in interscholastic  sports is higher at schools with more sports facilities compared with  schools that have few sports facilities. A few of the subject matter  specialists and one athletics administrator made similar observations  about the relationship between facilities, participation, and inequity. For  example, the athletics administrator said that at his high school, baseball  and softball participation has decreased because their athletic facilities  are located off campus, requiring additional travel for both students and  parents for practices and games. Additionally, representatives from two  advocacy groups noted that parents may have concerns related to school  sports facilities, particularly for the safety of their daughters. For example,  one said that some schools have girls’ teams practice in off-campus  facilities, sometimes in unsafe neighborhoods, without offering  transportation. The other said parents may be concerned when fields are  insufficiently lit or their daughters come home late from practices.

Factors Related to Family and Community Resources and Cultural Expectations May Discourage Participation in Sports

We found no clear consensus in our survey of athletics administrators  regarding factors that tend to discourage students from participating in  sports, and the eight athletic administrators we interviewed had mixed  views on the subject. That said, the most frequently mentioned factors  that were perceived to discourage participation (representing an  estimated 15-35 percent of athletic administrators) were (1) competing  responsibilities, (2) lack of access to athletic feeder programs, (3) the  perceived benefits of joining club teams, and (4) participation costs to the  student.

Competing responsibilities. Over one-quarter of athletics  administrators cited students’ competing responsibilities as  discouraging participation in public high school sports. This could  include a range of responsibilities, including schoolwork, other school  activities, and family obligations. Among the athletic administrators we  interviewed, one noted that many students at his magnet school were  more focused on academics than athletics. A few cited examples of  competing responsibilities that were tied to family resources. For  example, two said that many of their students have jobs and family  responsibilities that prevent them from participating in sports. One of  these administrators said that his school’s student population largely  comes from lower-income families, and many are juggling jobs; in  response, the school changed practice schedules to better match  students’ availability, which has made it easier for more students to  participate.

Lack of access to athletic feeder programs. Some athletics  administrators also mentioned a lack of access to athletic feeder  programs—club or community-based youth sports programs that train  younger children before they enter high school—as discouraging  participation in sports at their public high schools. In addition, a few of  the eight athletics administrators we interviewed saw this lack of  access as being closely related to community or family resources.  Two of these administrators, who worked in lower-income schools,  reported that younger children in their area have very little access to  community or club sports and that students who do not have previous  exposure to sports may lack the skills to participate at the high school  level. One of these administrators also said that having more  community youth sports might increase student interest in playing at  the high school level. A third athletics administrator said that feeder  programs help drive participation in high school sports. In his school’s  competitive environment, students trying out for sports for the first  time when they get to high school are, in most cases, likely to be cut  from the team. He added that he has found that family income is a  major contributing factor to children’s ability to begin training early,  which puts lower income students at a disadvantage. His point was  echoed in one research study that found that as family income  increases, boys and girls tend to enter organized sports at a younger  age.

Perceived benefits of joining club teams. Athletics administrators  also mentioned the presence of club teams that students may choose  over school teams as discouraging participation in public high school  teams. This may be particularly true for higher-income students, as  competitive travel and club teams—which parents and students may  see as offering higher-caliber coaching, more specialized training, and  greater opportunities to compete against elite athletes—can be quite  expensive. Several subject matter specialists we interviewed cited this  as an issue that affects high school sports participation. Further, a few  of the high school athletics administrators we interviewed observed  decreased student participation at their schools due to the presence  of club teams. One athletics administrator from the Southwest  explained that participation is weaker for his school’s Olympic sports,  such as swimming, due to competition from club sports. He noted that  at his high school, this phenomenon makes it more difficult to recruit  other students because the school teams become less competitive.  Another athletics administrator from the Midwest explained that at his  high school, the presence of club sports disproportionally depressed  girls’ participation in high school sports. In particular, he said the  popularity of club girls’ volleyball in the winter reduced participation in  his girls’ basketball teams.

Participation costs. The cost to students of participating in athletics  was also mentioned by some athletics administrators as discouraging  participation in public high school teams. The subject matter  specialists and athletics administrators we interviewed had mixed  views on the effect of costs on student participation. Among the  subject matter specialists, two said that the increasing prevalence of  fees in high school sports programs is threatening participation by  lower-income students. One athletics administrator agreed, saying  that in the past he has dissuaded his school district from charging  participation fees for this reason. Another said that his school does  not charge fees, but students could still be discouraged by the  fundraising required for “extras” such as team t-shirts. In contrast, one  subject matter specialist said that it is typically higher-income schools  that charge students fees to participate in sports, and therefore fees  do not generally affect students in lower-income schools.

In addition to the four most commonly cited barriers from our survey,  several research studies noted that cultural expectations around family  responsibilities and gender roles may also discourage some student  groups more than others. For example, one study found that Hispanic  girls quit sports to take care of younger siblings at higher rates than their  white peers. This and another study noted that students from recent  immigrant families may also be discouraged from participating in sports  because of different cultural expectations around prioritizing sports, and  girls may be additionally affected by expectations around gender roles.  For example, it found that immigrant parents are more likely than non- immigrant parents to believe that boys are more interested in sports than  girls, and that 75 percent of immigrant sons were involved with organized  or team sports compared with 43 percent of immigrant daughters.  Similarly, a study of sports involvement among East African immigrant  girls found that those the researchers interviewed face social barriers to  participation, such as peer criticism, parents’ fears of interactions with  male athletes, and lack of parental support.

Several of the subject matter specialists and athletics administrators with  whom we spoke made similar observations around cultural expectations.  One suggested that differences in sports participation among immigrant  communities may stem from the opportunities to play sports in the  family’s country of origin, noting that the United States is unique in tying  sports teams to its academic institutions. Officials from two advocacy  organizations, one of which advocates for the Hispanic community, noted that some Hispanic families expect daughters to come home after  school to help care for their siblings. This can interfere with participating  in after-school activities. In addition, one athletics administrator we  interviewed, whose school serves a predominantly Hispanic community,  commented that his coaches have seen girls from this community quit  sports teams on several occasions due to family responsibilities. One of  the advocacy organization officials added that schools wanting to improve  participation among Hispanic girls should, for example, consider more  creative scheduling to allow these students to attend practices.

While sports participation for girls has risen dramatically over the last 45  years, a significant gap still remains between boys and girls in public high  school sports. Our findings suggest that the reasons for this gap are  varied and complex, and according to our survey, at many schools,  athletics administrators are not aware of or do not receive support from  their Title IX coordinator. OCR’s guidance suggests that uninvolved Title  IX coordinators are associated with serious Title IX violations, but OCR  does not collect information about coordinators’ level of involvement with  districts and schools outside of its complaint investigations and  compliance reviews. Better information about Title IX coordinators’  awareness and use of OCR’s guidance could help OCR support schools’  and districts’ efforts to provide equal opportunities in their sports  programs.

The Department of Education’s Assistant Secretary for Civil Rights should  determine the extent to which Title IX coordinators at the K-12 level are  aware of and using the tools recommended in OCR’s existing guidance  and any barriers preventing their use of this guidance, and use this  information in OCR’s efforts to encourage them to work with athletics  administrators on ensuring equal athletic opportunities. (Recommendation  1)

We provided a draft of this report to Education for review and comment.  Education provided written comments that are reproduced in appendix III,  as well as technical comments that we incorporated, as appropriate.

In its written comments, Education stated that it partially concurs with our  recommendation that OCR determine the extent of K-12 Title IX  coordinators’ knowledge and use of tools in its existing guidance and use  this information in its efforts to encourage them to work with athletics  administrators to help ensure equal athletic opportunities. Specifically,  Education stated that when OCR conducts investigations in response to  complaints it would look for opportunities to examine whether K-12 Title  IX coordinators were aware of, and using, the tools in OCR’s guidance.  Education also said that when OCR engages in technical assistance  activities, it will encourage Title IX coordinators to work with athletics  administrators to encourage equal opportunities. Education also said that  it will consider our recommendation during its frequent reviews of the  agency’s communications practices.

We agree that these are important first steps in helping ensure that Title  IX coordinators are working with athletics administrators and otherwise  fulfilling their responsibilities to encourage equal opportunities. However,  given our finding that about half of public high school athletics  administrators were unaware of or unsupported by their Title IX  coordinator, we continue to believe the systemic approach we  recommend is necessary. The activities that OCR described in its  response are predicated on a complaint being filed or technical  assistance being requested. This narrow approach means that OCR will  likely not learn the full extent to which K-12 Title IX coordinators are  unaware of or not using the tools in OCR’s guidance. It also means that  its reviews of the agency’s communication practices may be hampered by  incomplete information on how best to encourage Title IX coordinators to  use these tools and work with athletics administrators to ensure equal  opportunities.

As agreed with your offices, unless you publicly announce the contents of  this report earlier, we plan no further distribution until 30 days from the  report date. At that time, we will send copies to the appropriate  congressional committees, the Secretary of Education, and other  interested parties. In addition, this report will be available at no charge on  GAO’s website at http://www.gao.gov.

If you or your staff should have any questions about this report, please  contact me at 617-788-0580 or nowickij@gao.gov. Contact points for our  Offices of Congressional Relations and Public Affairs may be found on  the last page of this report. GAO staff who made key contributions to this  report are listed in appendix IV.

The objectives of this study were to examine: (1) what measures public  high schools and athletics administrators have taken to encourage equal  athletic opportunities for boys and girls, and (2) what factors affect boys’  and girls’ participation levels in public high school sports programs. To  address these objectives, we used a variety of methods, including a web- based survey of public high school athletics administrators; follow-up  interviews with eight survey respondents; reviews of federal law,  regulations, and guidance; and interviews with federal officials at the  Department of Education (Education) and with subject matter specialists.

Web-based Survey of Public High School Athletics Administrators

To obtain school-level perspectives on factors that affect boys’ and girls’  participation levels in public high school sports programs and approaches  schools and athletics administrators have used to encourage equal  athletic opportunities, we designed and administered a survey to athletics  administrators at a generalizable, stratified random sample of public high  schools in the United States. The survey included questions about what  sports and levels of competition the school offered for each sex, how  many boys and girls participated in sports in school year 2015-16, and  factors that encourage and discourage girls’ and boys’ sports participation  at the school. The survey also included a variety of questions related to  the school’s and athletics administrator’s activities to encourage equal  opportunities in the prior 2 years, challenges they faced in encouraging  equal opportunities, sources of guidance on Title IX, booster club  structures and oversight, and data they maintained on funding and  expenditures. In addition, it included a question on whether, to the  athletics administrator’s knowledge, their school district had a Title IX  coordinator.

Our population of interest for the survey was athletics administrators at  public high schools. In terms of the schools, we defined our target  population as public schools offering at least one high school level grade  (9, 10, 11, or 12) that appeared in both Education’s Common Core of  Data (CCD) and Civil Rights Data Collection (CRDC) for the 2013-14  school year, were located in the 50 states and the District of Columbia,  and indicated in the CRDC that they offered interscholastic sports. We  excluded schools that were listed as closed or not operational according  to the school year 2015-16 CCD, as well as single-sex schools and  schools located in U.S. territories. We also obtained the most current  school contact information from the school year 2015-16 CCD.

We originally selected a stratified random sample of 813 from a  population of 15,330 schools in our sampling frame. However, we  ultimately excluded 26 schools from our original population and sample  because they had closed, did not serve high school grades, or did not  offer interscholastic sports, and thus were not considered eligible for our  survey. In addition, we found schools in the population and sample that  shared sports programs and athletics administrators, effectively reducing  the population by 10 schools and the sample by 3 schools for purposes of  our survey. This resulted in a sample of 784 schools from the eligible  population of 15,294.

We stratified this sample based on school type (charter or traditional),  concentration of minority students (low = 0-25 percent, mid = 26-74  percent, high = 75-100 percent),  locale type (urban, suburban, or rural),  and participation rates of male and female students in school year 2013- 14. This created 24 strata as noted in table 1. For the participation rate  strata, we calculated each school’s male and female students’  participation rates using data from the school year 2013-14 CRDC.  Participation rates were defined as the number of sports participants of  that gender divided by the number of enrolled students of that gender,  and these rates were then compared to determine which gender had  higher participation: females or males. We placed schools with equal  participation rates for males and females into the “Females” participation  category because, given the overall higher participation rates for boys, schools with both equal participation rates and higher rates for girls are  rarer.

We chose these strata to ensure schools with the stratum characteristics  were included in the sample. The total sample size of n=813 was inflated  for an expected 60 percent response rate, and we distributed the sample  across the strata for workload and analysis considerations. The sample  size in table 1 optimizes for some groups, while controlling the distribution  across the 24 strata. Specifically, we calculated the Neyman optimal  sample size that resulted in an overall 5 percent margin of error for an  attribute estimate. We allocated samples across strata to achieve  precision goals at two levels: overall population percentage estimates  with margins of errors within plus or minus 5 percentage points, and  subpopulation percentage estimates (i.e. school type, minority level,  locale, or participation group) with margins of errors within plus or minus  10 percentage points, both at the 95 percent confidence level.  Additionally, we ensured a minimum sample of 10 schools in every  stratum.

Based solely on the constraint of an overall margin of error within plus or  minus 5 percentage points, some reporting groups were expected to have  margins of errors that were less than 10 percentage points without the  need of additional explicit constraints. For other reporting groups, we  implemented constraints so that the designed margin of error was within  plus or minus 10 percentage points. Specifically, we included the  following constraints for margins of error of attribute estimates with 95  percent confidence intervals within each reporting group, for a realized  response rate of 60 percent: margins of error within plus or minus 5 percentage points overall, within plus or minus 10 percentage points for urban schools, within plus or minus 10 percentage points for high minority schools, within plus or minus 10 percentage points for charter schools.

Because we followed a probability procedure based on random  selections, our sample is only one of a large number of samples that we  might have drawn. Since each sample could have provided different  estimates, we expressed our confidence in the precision of our particular  sample’s results as a 95 percent confidence interval (e.g., plus or minus 7  percentage points). This is the interval that would contain the actual  population value for 95 percent of the samples we could have drawn.  Unless otherwise noted, all percentage estimates in this report have  confidence intervals within plus or minus 7.7 percentage points. For other  estimates, the confidence intervals or margins of error are presented  along with the estimates themselves.

We took several steps to minimize non-sampling error. We used several  methods to identify the names and email addresses of the athletics  administrators for our selected sample of schools. In some states, the  high school associations had directories we used to obtain this  information. For those that did not, we searched the school’s website or  called the school or district. We administered the survey from June  through early September 2017. To obtain the maximum number of  responses to our survey, we sent e-mails to the principals of the schools  in the sample prior to the survey’s launch, asking them to support and  encourage their athletics administrator to complete the survey. We also  worked with the National Federation of State High School Associations to  have the state associations e-mail their members and encourage them to  participate in the survey. Finally, we sent direct reminder emails to  nonrespondents and contacted nonrespondents over the telephone.

We took additional steps to minimize non-sampling errors, including  pretesting draft instruments and using a web-based administration  system. During survey development, we met with officials from national  groups representing high school activities associations and athletics  administrators and held discussion groups with nine athletics  administrators to explore the feasibility of responding to the survey  questions. We then pretested the draft instrument from April through May  2017 with five athletics administrators in public high schools that were  diverse across a range of characteristics, such as region, school type and  locale, and minority enrollment. In the pretests, we asked about the clarity  of the questions and the flow and layout of the survey. A survey specialist  independent of the project team within GAO also reviewed a draft of the  questionnaire prior to its administration. Based on feedback from the  pretests and the independent review, we made revisions to the survey  instrument. To further minimize non-sampling errors, we used a web- based survey, which allowed respondents to enter their responses  directly into an electronic instrument. Using this method automatically  created a record for each respondent in a data file and eliminated the  errors associated with a manual data entry process.

Despite these efforts, like most surveys, our survey had nonresponse.  Specifically, the weighted response rate was 42 percent. Survey  nonresponse raises the possibility that those athletics administrators who  did respond to the survey may not be representative of the intended  population, due to nonresponse bias. We carried out a nonresponse bias  analysis and identified three potential factors that may have been related  to athletics administrators’ propensity to respond: school concentration of  minority students, school size, and region. In order to adjust for the  potential nonresponse bias, we adjust the sampling weight with a  nonresponse adjustment to form a final weight. Data analyzed using the  final, nonresponse-adjusted sampling weight is assumed to be missing at  random, given the nonresponse adjustments, and therefore unbiased for  the intended population. We used response propensity weighting class  adjustments based on a model that included the variables identified in the  nonresponse bias analysis. We conducted our analysis using survey  software that accounted for the sample design and weighting.

To gain further insights into factors that encourage or discourage  participation in sports, schools’ efforts to encourage equal opportunities,  and the role of the Title IX coordinator, we conducted follow-up interviews  with 8 athletics administrators, chosen from the 105 who had responded  to our survey as of late August and indicated that they were willing to  participate in a follow-up discussion on their responses. Specifically, we  selected respondents to obtain diversity in their responses to a few key  survey questions, as well as certain characteristics of their schools. In  making our selections, we considered their responses to survey questions  on:   their awareness of their Title IX Coordinator, activities their schools conducted within the last two years to  encourage equal opportunities for boys and girls in sports, and whether the school maintains expenditure data on sports and their  willingness to share these data.

We identified school characteristics with the data sources used to create  our survey sampling frame. The characteristics we considered to further  narrow our selection were:  school type (charter or traditional),  school locale (urban, suburban, or rural),  concentration of minority students (low-, mid-, or high-minority).

Additionally, we reviewed open-ended responses in the survey to  determine if there were answers that necessitated additional discussion  or clarification (see table 2).

In our interviews with the athletics administrator at each school, which we  conducted by phone, we asked officials to describe their relationship with  their Title IX coordinator, familiarity with Title IX requirements overall, and  their familiarity with state and local guidance, specifically. We also asked  them to describe their efforts to encourage equal opportunities in sports  and the nature of challenges they have faced in doing so. In addition, we  asked them about funding sources and their use of expenditure data, the  role of booster clubs, and the role of outside funding. For each school  where the athletics administrator reported that they had expenditure data,  we requested a copy of these data. We obtained expenditure data from  three schools. In some cases we obtained additional documentation  such as booster club guidelines, processes for adding school sports, and  participation data. Because we selected the schools for follow-up  interviews judgmentally and only conducted eight interviews we cannot  generalize our findings about their policies, practices, and challenges.

Review of Law, Regulations, and Guidance and Interviews with Education Officials

To understand the requirements for providing equal athletic opportunities  in public high schools and how Education’s Office for Civil Rights (OCR)  monitors and supports public school districts in meeting these  requirements, we reviewed Title IX of the 1972 Education Amendments  (Title IX), Education’s Title IX regulations, and related guidance  documents. We also interviewed OCR and other Education officials.

In addition, we reviewed selected research studies that provided context  and insight into factors affecting high school sports participation.

Interviews with Subject Matter Specialists

To obtain additional context and insights, we selected and interviewed  subject matter specialists, including researchers and officials from  advocacy groups and associations. We selected these subject specialists  so that, together with the athletics administrators we surveyed and  interviewed, they would provide a variety of perspectives on factors that  affect boys’ and girls’ participation in high school sports and approaches  schools use to encourage equal athletic opportunities. The researchers  and officials we interviewed were located at:  the Institute for Research on Women and Gender and the Sport,  Health, and Activity Research and Policy Center at the University of  Michigan,  the Tucker Center for Research on Girls and Women in Sport at the  University of Minnesota,  the Department of Recreation, Sport and Tourism at the University of  Illinois,

National Interscholastic Athletics Administrators Association

National Federation of State High School Associations, and

Appendix II: Survey of Public High School Athletics Administrators

The questions we asked in our survey of public high school athletics administers, as well as definitions used, are shown below. The blanks in the survey were filled in with the name of each athletics administrator’s school. Some questions were only asked if the athletics administrator responded a certain way to a prior question.

Appendix IV: GAO Contact and Staff Acknowledgements

In addition to the individual named above, Bill MacBlane (Assistant  Director), Lauren Gilbertson and Jamila Jones Kennedy (Analysts-in- Charge), Christina S. Cantor, MacKenzie Cooper, Jill Lacey, Benjamin  Sinoff, Andrew Stavisky, Sonya Vartivarian, and Khristi Wilkins made key  contributions to this report. Also contributing to this report were James  Bennett, Deborah Bland, Barbara Bovbjerg, Randy De Leon, Holly Dye,  David Forgosh, Amy MacDonald, and Sheila R. McCoy.

K-12 Education: High School Sports Access and Participation.  GAO-17-754R. Washington, D.C.: September 14, 2017.

Child Welfare: Federal Agencies Can Better Support State Efforts to  Prevent and Respond to Sexual Abuse by School Personnel. GAO-14-42.  Washington, D.C.: January 27, 2014.

K-12 Education: School-Based Physical Education and Sports Programs.  GAO-12-350. Washington, D.C.: February 29, 2012.