The University of Kentucky reported that nearly 1,250 partnerships and memberships have been flagged for further review due to potential violations of the Civil Rights Act, according to a campus-wide email from UK President Eli Capilouto. 

The email, sent on Tuesday, Dec. 9, said UK’s report is still under review by the Office for Civil Rights, and the partnerships UK marked as “FLAGGED FOR CANCELLATION/DEEPER REVIEW” have “not necessarily” been discontinued. 

According to UK’s Monitoring Federal Changes site, final determinations regarding what memberships and partnerships will be terminated will be made after UK completes further review based on the OCR’s feedback. 

“We’re conducting a more detailed review of the organizations we flagged to confirm their status and any required actions under federal guidance when we hear back from OCR,” Tiana Thé, executive director for UKPR, told the Kernel in a text.

The campus-wide email said the university’s continued review will involve assessing flagged relationships to “better understand their purpose” and determine whether they are “essential to its academic, clinical, research or service missions.”

Partnerships will be evaluated based on whether the organizations may be considered discriminatory due to limiting participation based on “race, gender or similar characteristics” and whether the relationships are critical to students’ accreditation or licensure.

The organizations flagged for cancellation/deeper review of the relationship were already determined by UK to meet at least one of the following evaluative criteria, according to the report sent to the OCR:

• Organization name: whether the organization’s name includes racial, ethnic, gender-based identity-specific terms that could indicate restricted participation.
• Former name: whether a prior name included such terms, even if recently changed.
• Website content: whether public-facing materials reference preferential benefits, representation or eligibility tied to a protected characteristic or contain terminology such as “anti-racism,” “structural racism” or similar concepts that may indicate identity-based restriction.
• Leadership development programs: whether any internal programs are limited to or expressly participation based on race or other protected characteristics.
• Employment-related policies: whether the organization engages in employment actions, trainings, DEI programs or affinity groups that limit opportunities based on race.

This report was sent in response to a letter UK received from the OCR on Sept. 23. The Kernel reported on Oct. 1 that UK had 60 days to determine the future of its relationships with identity-based groups after the OCR found that UK violated Title VI through a partnership with the PhD Project, a nonprofit organization whose mission is to provide minority students with easier access to graduate business programs. 

The report, which was due to the OCR on Dec. 1, did not include any university-level registered student organizations.

“The list reflects institution-level memberships or partnerships supported by university resources,” Thé said on Dec. 9.  “To the extent that they appear, any RSOs on the list reflects the university’s institutional relationship with the national organization, not a review of the related student organization. Registered student organizations are not the focus of this OCR review.”

The Kernel’s previous coverage suggested that the OCR investigation impacted RSOs, as UK Spokesperson Jay Blanton attributed changes to RSO funding to the OCR and House Bill 4 on Oct. 16. 

Thé told the Kernel on Nov. 16 that these changes to student groups were in response to House Bill 4 and “federal directives,” including a memorandum from U.S. Attorney General Pam Bondi, which was also linked in Capilouto’s email, as well as “OCR information.”

During the OCR review process, the email said UK will pause renewals and approvals for new memberships and partnerships supported by institutional funds.

“Individuals may continue participating in professional communities, but no new membership payments or renewals will be processed until we receive federal guidance and can issue clear university-wide criteria for future decisions,” Capilouto said in the email.

Roughly 400 memberships and partnerships remain in place and were “immediately identified as essential because they are required for accreditation, certification, licensure or other legal or mission-critical purposes,” the email said. 

The full report and the complete list of memberships and partnerships, both secure and flagged, are available here.