Between Jan. 1, 2002 and Sept. 22, 2014, the Department of Education’s Office for Civil Rights reviewed and closed 11 Title IX complaints against Yale.

This places the University squarely in the middle of the Ivy League, according to OCR documents obtained by The Harvard Crimson through a Freedom of Information Act request. Over the last 12 years, 83 complaints have been filed against Ivy League schools. Harvard and Columbia were the subject of the most complaints, with 16 each, while Dartmouth and Brown were the subject of the fewest, with four and two complaints, respectively. Of those 83 total complaints, 14 led to formal OCR investigations, and only two eventually yielded policy changes — one of which was at Yale.

The OCR information published by The Crimson documented a dramatic uptick in the number of Title IX complaints against the University. While only two complaints were noted between 2002 and 2010 — one in 2002 and another in 2004 — there have been nine filed since the beginning of 2011. Four cases were filed in 2013 and three have been filed thus far this year.

Two of the three filed this year were closed and referred to the Equal Employment Opportunity Commission, while the third was closed due to insufficient detail to infer discrimination.

“The [OCR] has nationwide enforcement authority for Title IX,” said Valerie Bonnette, a private Title IX specialist who previously worked at the OCR for 15 years. “When they get a complaint, they go about the process of trying to figure out the legitimacy of that complaint. They want to make sure it’s not frivolous. If they determine that it is legitimate, they are obligated to investigate it.”

University Title IX Coordinator and Deputy Provost Stephanie Spangler said she did not have enough time to comment yesterday evening.

Of the 11 complaints filed against Yale over the past 12 years, three in total were referred to the EEOC, according to the OCR information published by The Crimson. Two more were closed because the complaint was not timely. According to the OCR procedures, a complaint must be filed within 180 days of the alleged discriminatory action; however, the deadline may be waived by the OCR.

Another complaint was closed because “previous decisions [precluded] processing,” one complaint was being investigated elsewhere and three were closed after the OCR determined there was insufficient information to prove Title IX non-compliance or discrimination.

Only one of the complaints filed led to a policy change at the University.

On March 15, 2011, 16 students and alumni filed a Title IX complaint against Yale citing an “inadequate response” to public episodes of sexual misconduct on campus. According to an April 4, 2011 open letter published by the OCR, schools can be penalized if they do not react to issues of sexual misconduct in a timely matter.

“If a school knows or reasonably should know about student-on-student harassment that creates a hostile environment, Title IX requires the school to take immediate action to eliminate the harassment, prevent its recurrence, and address its effects,” the letter said.

The OCR announced it would open a formal investigation into Yale’s policies two weeks after the complaint was filed in mid-March. The case was closed on June 15, 2012, after Yale and the OCR reached a Voluntary Resolution Agreement, in which an institution and the OCR agree to make institutional changes before the OCR imposes sanctions.

“OCR’s weapons in terms of enforcement are rather drastic, so schools tend to comply when given the opportunity to fix the problems,” Bonnette said.

If universities choose not to comply, Bonnette said, the OCR can terminate certain federal funds to the institution.

According to the Resolution Agreement, the OCR did not officially find Yale in non-compliance of Title IX because the University had taken steps to improve its response to sexual misconduct complaints, ensure compliance with Title IX and resolve the issues of the complaint.

The agreement ultimately led to the formation of a University-wide Title IX coordinator position, as well as the University-Wide Committee on Sexual Misconduct and the commitment to training administrators, faculty, staff and students on sexual misconduct and Title IX issues.

Andrea Seger, an associate at Alden and Associates — a consulting firm on intercollegiate athletics — who has conducted Title IX reviews, said complaints can be resolved without policy changes.

“Many times OCR is looking for a plan to commit to compliance,” said Seger. “If institutions were to take a plan and show that they were going to commit to compliance … that may be acceptable without a policy change.”

For example, if fewer recruitment dollars are spent on women’s athletics programs than men’s athletic programs, allocating a greater budget to the women’s program could constitute a resolution without a policy change, Seger said.

Roughly 17 percent of the Title IX complaints filed against Ivy League institutions resulted in a formal investigation. Seger said complaints filed with the OCR are sometimes closed without a formal investigation because they are not deemed a credible case for Title IX.

She cited an example in which a complaint may actually fall under a different federal title. An individual could file a complaint that female coaches are not paid enough at a university, but since Title IX covers only coaches’ salaries as they impact the female student-athlete experience, the case would be closed without formal investigation and referred instead to Title VII, she said. Title VII prohibits employment discrimination based on race, color, religion, sex and national origin.

Bonnette added that resolutions can be reached between complainants and their universities even before a formal investigation begins, through an early complaint resolution process.

“That is usually a faster way to compliance, in my opinion, when parties can get together and figure out a solution,” she said.

There were 7,500 Title IX complaints received and closed by the federal office of the OCR between Jan. 1, 2002 and Sept. 22, 2014.