Universities around the country are on the hunt for Title IX Coordinators. The job descriptions are all similar, most taking from language written in the Department of Education’s April 2015 guidance on Title IX Coordinators. Once a ‘bonus’ title for some (un?)lucky employee in student affairs, human resources or diversity and equity offices on campuses, the Title IX Coordinator has now become a stand alone, dotted line report to University President’s and school district Chancellors. Except, it hasn’t. Most universities are not convinced of the need for another direct report to leadership and certainly not one focused on sex discrimination.

But for all the guidance on duties and structure for Title IX, there is little advice on what type of person needs to be a Title IX coordinator. Some schools have taken the “find a lawyer” approach, being comforted by the idea that career attorneys know the law, and can help us abide by it. Some, albeit fewer, have taken the advocate approach– someone who has supported survivors, or worked in rape crisis centers and women’s centers. The truth is, neither of these absolutes work.

A strong Title IX Coordinator must be both of those qualities, and more. A strong Title IX Coordinator understands the law, thinks independently and works with the community to create change. A strong Title IX Coordinator is part advocate– understanding that sometimes, the role requires you advocate for those who are vulnerable and silenced. A strong Title IX Coordinator is also an expert in risk management. Risk management is about knowing how to avoid risk, but also knowing when to take risks. A strong Title IX Coordinator is closely respected by and connected to leadership, because leadership needs to not only take their advice, but prioritize it.

Strong Title IX coordinators across the country did not need the most recent joint guidance from the Department of Education and Department of Justice regarding bathroom usage and sex discrimination because they were already telling leadership we must treat all of our students in a manner consistent with the student’s gender identity. Strong Title IX coordinators were ensuring that university and school leadership were clear that having transgender students use single stalls is not considered equal treatment. Strong Title IX Coordinators were saying NO loudly and clearly, publicly and privately, to directives they knew were violations of Federal law. Strong Title IX Coordinators raised hell this week, and every week.

Strong Title IX Coordinators are looking into dress code policies that disproportionately impact girls, the sex abuse to prison pipeline, keeping pregnant and parenting students in school, researching ways to support women of color disproportionately impacted by interpersonal violence and ensuring transgender students are not only getting equal access to bathrooms and housing, but are going to college in the first place. Strong Title IX Coordinators are saying, women in STEM programs cannot be our only pipeline program for women if we are serious about Title IX and equity work. Strong Title IX Coordinators are working with programs that target male students and using male students as contributors to the movement to end interpersonal violence. Strong Title IX Coordinators are walking hand in hand with trans students to send a clear message that they answer to Federal law that is clear on this subject.

If your Title IX Coordinator did not think to say it, was scared to say it, or even worse, wasn’t ever asked for their opinion: your Title IX structure or program is insufficient. Title IX Coordinators are change agents, risk managers and risk takers. They are tasked with ensuring compliance by challenging deeply embedded structures, this work is not easy. Title IX Coordinators can’t just read and recite the law, they must translate it. They can’t pick and choose to implement aspects of Title IX that don’t disturb the status quo, they must propel the status quo forward. They can’t just be asked for their opinion out of courtesy, their determinations and feedback must be sought first and centrally. Title IX Coordinators can’t be asked to do compliance work within a supplied framework– they must be architects of the framework.

A strong Title IX Coordinator, an effective Title IX Coordinator, needs to be part compliance officer, part advocate, part risk manager, part risk taker, and ultimately… part revolutionary. If you haven’t created the space for your Title IX Coordinator to do so, it is only a matter of time before you find yourself at risk of losing Federal funding. So ask yourself, do you really want a strong Title IX Coordinator? Then act accordingly.