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A Compliance Moment for Higher Education
What the DOJ’s Medical School Inquiries Signal, and How Institutions Can Strengthen Their Compliance Posture
On March 25, 2026, the Civil Rights Division of the Department of Justice opened compliance review investigations into medical school admissions at Stanford University, Ohio State University, and UC San Diego. The letters requested years of applicant-level data spanning multiple data points per applicant, along with internal communications related to DEI and the use of race in admissions. The schools were given until April 24, 2026, to respond.
These inquiries reflect the ongoing federal focus on Title VI compliance in higher education, particularly in the wake of the Supreme Court’s 2023 decision in Students for Fair Admissions. For educational institutions across the country, this is a timely reminder that proactive compliance, not reactive response, is the right posture.
Whether or not your institution has received a government inquiry, now is the right time to evaluate your civil rights compliance framework, ensure your records are well-organized and defensible, and build the internal infrastructure that demonstrates a genuine commitment to nondiscrimination.
What the DOJ Is Reviewing
The investigations are grounded in Title VI of the Civil Rights Act of 1964, which prohibits recipients of federal financial assistance from discriminating on the basis of race, color, or national origin. The compliance review letters requested:
- Applicant-level data going back years, including test scores, GPAs, ZIP codes, extracurricular activities, alumni and donor relationships, and admissions outcomes
- Internal communications regarding DEI and the use of race in admissions
- Any statistical analyses or internal reviews of admissions trends by race
- Documents reflecting changes in policy following the Supreme Court’s 2023 decision in Students for Fair Admissions
The scope of the request underscores a broader point: compliance reviews examine not just outcomes, but the policies, processes, and documentation behind them. Institutions with well-maintained records, clearly articulated policies, and documented decision-making are far better positioned to respond effectively, regardless of the nature of the inquiry.
A Broader Pattern Worth Noting
These medical school inquiries are part of a wider federal focus on civil rights compliance in higher education. Following October 7, 2023, the Department of Education opened more than two dozen investigations of universities in the last two months of 2023 alone, and that number continued to rise in 2024. In 2025, the Department of Education’s Office for Civil Rights sent letters to over 60 universities in connection with Title VI complaints related to antisemitic discrimination and harassment.
Taken together, these developments reflect a sustained federal interest in how educational institutions are implementing their civil rights obligations. Institutions that have invested in strong compliance programs are well positioned to respond. Those that have not may find themselves facing a more difficult path.
Five Steps to Strengthen Your Compliance Posture
Guidepost Solutions recommends the following steps for any federally funded educational institution seeking to evaluate and strengthen its civil rights compliance framework:
- Conduct a Proactive Data Audit
Review your admissions data before any external inquiry prompts you to do so. Examine outcomes by demographic group, across multiple years and admissions cycles. Look for statistical patterns, documentation gaps, and any inconsistencies between written policy and actual practice. A proactive internal review conducted with the benefit of attorney-client privilege allows institutions to identify and address issues on their own terms.
2. Review Your Policies for Post-SFFA Alignment
Following the Supreme Court’s 2023 ruling, many institutions revised their admissions frameworks, but not all have fully documented those changes. The DOJ specifically requested evidence of policy updates made after the decision. Institutions should ensure that all written admissions policies, scoring rubrics, and guidance materials reflect both current law and current practice, and that any revisions have been clearly memorialized.
3. Organize and Preserve Your Records
Government compliance reviews are inherently document intensive. Institutions with centralized, well-organized records can respond efficiently and credibly. Now is the time to ensure that admissions-related documentation, including committee notes, scoring rubrics, candidate communications, and internal demographic analyses, is preserved and accessible. Establishing clear records retention and litigation hold protocols in advance makes any future response far more manageable.
4. Build Out Your Title VI and Title VII Infrastructure
Title VI compliance is evolving in ways that parallel the development of Title IX enforcement over the past decade. Institutions that built robust Title IX infrastructure early were better prepared when enforcement activity increased. The same investment is warranted for Title VI now. This may include designating a Title VI Coordinator, establishing clear and accessible complaint procedures, conducting regular training for administrators and staff, and implementing periodic climate assessments to identify and address issues proactively. Title VII obligations in faculty and staff employment practices deserve equal attention.
5. Engage Independent Compliance Expertise
Independent compliance advisors and outside counsel serve an important function both before and during any government inquiry. Proactively engaging experts to assess your compliance program, identify gaps, and support policy development demonstrates institutional good faith and positions you to respond more effectively if a government inquiry does arise. Institutions with documented third-party assessments and training records are better positioned to demonstrate the seriousness of their compliance commitments.
Looking Ahead
Guidepost’s Institutional Integrity Practice works with universities and colleges at the point where compliance, investigations, and civil rights obligations intersect. Our team has guided institutions through the full arc of this kind of work, from building the documentation infrastructure that makes a government response manageable, to conducting the independent assessments that demonstrate an institution’s compliance commitments are genuine and not assembled after the fact.
Our work in higher education spans Title VI, Title VII, Title IX, the Clery Act, and VAWA. We conduct independent compliance reviews and admissions data analyses, develop and assess policy frameworks, train administrators and faculty, and support institutions through government inquiries when they arise.
The federal focus on civil rights compliance in higher education is unlikely to diminish in the near term. Institutions that approach this moment as an opportunity to strengthen their compliance frameworks, rather than a problem to be managed reactively, will be better served in the long run.
Strong compliance programs are not just a regulatory requirement. They reflect an institution’s commitment to the students, faculty, and the staff it serves.
MSU Institutional Assessment + RAMAGELLAN MonitorshipEmpire/Liberty Review