John Billetz, Executive Director of the Idaho High School Activities Association, believes high school athletic directors in his state have a pretty good working knowledge of Title IX. He has seen them respond well to gender-equity complaints over facilities and equipment, and they pushed for volleyball to be exempted along with football, boys' basketball, and girls' basketball from recent cuts to contest limits.

Still, Billetz--and Idaho athletic directors--had no idea until the middle of July that many of the state's high schools might be out of compliance with Title IX based on participation opportunities. Formal complaints named 78 schools where the ratio of boys to girls in athletics exceeded the ratio of boys to girls in the student body.

For example, one complaint claims that Timberline High School in Boise has a 5.7 percent disparity between the percentage of girls playing sports compared to the percentage in the student body. It states that if the numbers were proportional 46 additional girls would be participating in sports.

Filed with the Seattle branch of the Office for Civil Rights (OCR) in the United States Department of Education, the complaints request that the OCR investigate the schools and remedy any inequities. Over the next months, the OCR will evaluate the situations and decide whether to proceed with any investigations.

"The first we heard about it was when someone from Channel 2 [KBOI-TV in Boise] called to say they would be running a report about it that night," Billetz says. "I really believe that administrators understand they have to provide quality programs for both groups. They try to make sure they have the same number of activities for boys and girls, and they're very aware of being equal in budgets, practice times, pep assemblies, and the like. But I don't know if any of us ever considered participation numbers as an issue."

Idaho is not the only state facing investigations of this kind. Schools throughout Oregon and Washington were named in similar anonymous complaints earlier in the year. And in November 2010, the National Women's Law Center (NWLC) filed complaints against 12 school districts across the country, including those in Chicago, Houston, and New York City.

The complaints are based on Title IX's requirement that schools offer equal participation opportunities for boys and girls. Proportionality is just one way a school can demonstrate it is in compliance. It can also show a history and continued practice of adding activities for girls or that it is fully and effectively accommodating girls' interests and abilities in sports.

Those second and third measures are more subjective than proportionality, though. For example, even if a school offers all the activities sanctioned by a state high school association, it still might not be accommodating girls' interests and abilities.

"The OCR evaluates these complaints on a case-by-case basis," says Neena Chaudhry, Senior Council for Education and Employment at the NWLC. "So you need to talk to students and coaches and do assessments that ask girls what sports they want to play. Even if they're not sponsored by the state association, sports played at other area schools at the recreational or club level might be appealing to girls at your school."

Both Billetz and Chaudhry recommend that any school receiving a complaint cooperate with the OCR. "The people at OCR told me they don't come in with a hammer looking to penalize anybody right off the bat," Billetz says. "They want to first determine whether a school is in compliance, and then they'll help the school district make changes if it needs to."

In one such case, Federal Way (Wash.) High School will provide the OCR with participation data, and if it is not satisfied that the school is in compliance, it could ask for remedies. The OCR might direct the school to offer new sports, add sub-varsity teams in currently offered girls' sports, or establish intramural or club sports for girls.

Billetz advises athletic directors to not be complacent on this topic. "Make sure you're well-versed in Title IX issues because somebody out there is watching," he says. "Even when you think you're doing the right things, there are people who will take you to task."

He adds that his state association is working on new educational efforts. "Looking back, one area that possibly we did fall down on is in the interest inventories," he says. "Maybe we needed to do just a little better job of asking our girls what activities they might want us to add."

Resources on Title IX can be found at www.ed.gov and www.nwlc.org.