Scope. This is the single grievance procedure for complaints of discrimination, harassment, or retaliation based on a protected characteristic — race, color, ethnicity, national origin, sex, sexual orientation, gender identity, disability, religion, marital status, or age — against any student, employee, applicant, parent or guardian, or other person, in any TSAS education program, activity, or employment.
Which track applies. Most complaints follow Track 1 below. A complaint that alleges sex-based harassment as defined by Title IX (see Track 2 definitions) follows Track 2 instead of Track 1; the shared provisions at the end apply to both. Conduct that does not meet the Title IX definitions, or that occurs outside the School’s education program or activity, is handled under Track 1 (and the School may also act under its student or employee conduct policies).
Suspected abuse or neglect of a minor. A report that a student under eighteen (18) may be abused or neglected triggers the immediate DHS and law-enforcement report required by 70 O.S. § 1210.163 and Title 10A at once; that duty is not delayed by this procedure, which may proceed in parallel on any civil-rights dimension.
Designated Coordinator
The Head of School is designated by the Board of Trustees to coordinate the School’s overall compliance with the civil-rights laws listed above.
The Compliance Officer / Coordinator — who serves jointly as the Title IX Coordinator and the Section 504 / ADA Coordinator — processes complaints and coordinates day-to-day compliance:
Dr. Daniel Hahn, Principal
Tulsa School of Arts and Sciences
1202 W Easton St, Tulsa, OK 74127
918.828.7727 · dhahn@tsas.org
If the Coordinator is named in a complaint, or is otherwise involved in the alleged conduct, the complaint shall be filed with and processed by another administrator designated by the Head of School.
Definitions
Complaint: A written, signed complaint alleging that a policy, procedure, or practice of the School, or the conduct of a student, employee, or contractor, discriminates against or harasses a person on the basis of a protected characteristic. (Track 2 uses “formal complaint,” defined below.)
Complainant: A student, employee, applicant, parent or guardian, or other person who submits a complaint.
Respondent: The person alleged to be responsible for the conduct in the complaint, including a person with supervisory responsibility for the practice complained of.
Day: A day on which the School’s administrative office is open (excluding Saturdays, Sundays, and holidays).
Track 1 — General Procedure
Applies to complaints of discrimination, harassment, or retaliation based on any protected characteristic other than Title IX sex-based harassment.
Pre-filing. Before filing a written complaint, the Complainant is encouraged, but never required, to raise the matter informally with the Coordinator in an effort to resolve it.
File (within 30 days). Within thirty (30) days of the alleged violation, the Complainant submits a complaint to the Coordinator stating the Complainant’s name, the nature and date of the alleged violation, the persons responsible, any witnesses, and the relief sought. The Coordinator may also investigate suspected discrimination without a written complaint whenever the Coordinator deems it appropriate.
Notify respondent (within 10 days). Within ten (10) days of receiving the complaint, the Coordinator notifies the Respondent.
Respondent answer (within 10 days). Within ten (10) days of notification, the Respondent submits a written answer confirming or denying the facts, accepting or rejecting the requested relief, proposing alternatives, and identifying any witnesses.
Investigate. Within ten (10) days of receiving the answer, the Coordinator (or an investigator approved by the School) begins a timely, thorough, reliable, and impartial investigation — interviewing the parties and witnesses and reviewing relevant documents. The School may take interim steps to protect the parties pending completion. The investigation should conclude within thirty (30) days; the Coordinator may extend this period by notifying both parties. Findings are decided on a preponderance of the evidence standard.
Decision (within 10 days). Within ten (10) days of completing the investigation, the Coordinator issues a written decision to both parties summarizing the evidence, the findings of fact, and the conclusion. If the allegations are substantiated, the decision is forwarded to the appropriate supervisor or administrator for disciplinary action.
Appeal (within 10 days). Within ten (10) days of the decision, either party may appeal in writing to the Head of School. The Head of School reviews the record — and, at the Head of School’s discretion, statements from the parties — and issues a written decision affirming, modifying, or reversing the Coordinator’s decision within ten (10) days. The Head of School’s decision is the final action at the TSAS level.
The appeal is directed instead to the Board of Trustees, sitting as a body, where (1) the complaint is against the Head of School, or the Head of School has a conflict of interest; or (2) the Respondent is an employee who reports directly to the Head of School, or the Head of School was otherwise the immediate decision-maker in the matter complained of. In a matter under (2) the Board may designate a neutral third party to decide the appeal in its place; in a matter under (1) the Board decides. No individual trustee hears an appeal in an individual capacity. The Board’s decision is the final action at the TSAS level.
Track 2 — Title IX Sex-Based Harassment
Applies instead of Track 1 when a complaint alleges sex-based harassment as defined below. Drafted to the 2020 Title IX regulations, K–12 provisions.
Title IX definitions
Sex-based harassment: Conduct on the basis of sex that constitutes one or more of the following:
- Quid pro quo — a School employee conditioning an aid, benefit, or service of the School on an individual’s participation in unwelcome sexual conduct;
- Hostile environment — unwelcome conduct that a reasonable person would find so severe, pervasive, and objectively offensive that it effectively denies a person equal access to the School’s education program or activity; or
- Sexual assault, dating violence, domestic violence, or stalking as defined in the Clery Act (20 U.S.C. § 1092(f)) and the Violence Against Women Act (34 U.S.C. § 12291(a)).
Education program or activity: Locations, events, or circumstances over which the School exercised substantial control over both the respondent and the context in which the harassment occurred. Limited to conduct occurring against a person in the United States.
Formal complaint: A document filed by a complainant (or the complainant’s parent/guardian) or signed by the Title IX Coordinator, alleging sex-based harassment and requesting that the School investigate. A complaint signed by the Coordinator does not make the Coordinator a party.
Supportive measures: Individualized, non-disciplinary, non-punitive services offered without fee to a complainant or respondent to restore or preserve equal access to education, protect safety, or deter harassment — available with or without a formal complaint.
Role separation and freedom from bias. The Title IX Coordinator, the investigator, the decision-maker, and the appeal decision-maker must be four different persons, each free from conflict of interest or bias, and each trained as required by 34 C.F.R. § 106.45(b)(1)(iii). For any Track 2 matter, these roles are assigned as follows:
- Title IX Coordinator — the School’s designated Compliance Officer / Coordinator (see Designated Coordinator, above). The Coordinator does not also serve as investigator, decision-maker, or appeal decision-maker in the same matter.
- Investigator — a trained third-party investigator engaged by the School.
- Decision-maker — the Head of School.
- Appeal decision-maker — where the respondent is a School employee, the Board of Trustees sitting as a body; in all other matters, a trained third party engaged by the School. In either case the appeal decision-maker is different from the Coordinator, the investigator, and the decision-maker. No individual trustee serves in any of these roles in an individual capacity.
If any person assigned to a role has a conflict of interest or bias in a particular matter — or is themselves implicated in the complaint — the Head of School designates a qualified alternate who meets the same training and impartiality requirements. Where the Head of School is the person implicated, the Board of Trustees sitting as a body serves as the decision-maker and designates a trained third party as the appeal decision-maker.
Reporting and response. Any person may report sex-based harassment to the Title IX Coordinator in person, by mail, phone, or email, at any time. On receiving actual knowledge of sex-based harassment in the School’s education program or activity, the Coordinator will promptly contact the complainant to discuss supportive measures, consider the complainant’s wishes, and explain how to file a formal complaint — with or without a formal complaint being filed.
Emergency removal. The School may remove a respondent on an emergency basis only after an individualized safety and risk analysis finds an immediate threat to physical health or safety justifying removal. The respondent receives notice and an opportunity to challenge the removal immediately afterward. This does not modify any right under IDEA, Section 504, or the ADA.
Filing a formal complaint. A complainant may file a formal complaint with the Coordinator at any time; the Coordinator may also sign one where warranted.
Written notice of allegations. Upon receiving a formal complaint, the School provides both parties written notice of: this grievance process and any informal-resolution option; the allegations in sufficient detail then known (identities if known, the conduct alleged, and date and location if known); a statement that the respondent is presumed not responsible until a determination is made; the parties’ right to an advisor of their choice; the parties’ right to inspect and review evidence; and any prohibition on knowingly false statements. Updated notice is provided if allegations are added.
Dismissal. The School must dismiss the Title IX allegations if the conduct, even if proved, would not constitute sex-based harassment as defined above, did not occur in the School’s education program or activity, or did not occur against a person in the United States. The School may dismiss if the complainant withdraws the complaint in writing, the respondent is no longer enrolled or employed, or circumstances prevent gathering sufficient evidence. A dismissal under Title IX does not preclude action under Track 1 or other School policies. The School notifies the parties of any dismissal and its reasons in writing, simultaneously; dismissal may be appealed on the grounds below.
Consolidation. The School may consolidate formal complaints arising out of the same facts.
Presumption and standard of evidence. The respondent is presumed not responsible until a determination is made at the conclusion of the process. The School applies the preponderance of the evidence standard, applied consistently to students and employees and to all formal complaints.
Investigation. The burden of gathering evidence rests on the School, not the parties. The School provides equal opportunity to present witnesses and inculpatory and exculpatory evidence and to have an advisor. Before the investigative report, the School sends both parties all evidence directly related to the allegations, and the parties have ten (10) days to submit a written response. The investigator then prepares a report fairly summarizing the relevant evidence and sends it to the parties at least ten (10) days before a determination.
Questioning (K–12). Before a determination, the decision-maker affords each party the opportunity to submit written, relevant questions to be asked of any other party or witness, provides the answers to each party, and allows limited follow-up. The decision-maker excludes questions that are not relevant and explains any exclusion. (A live hearing is not required for elementary and secondary schools under 34 C.F.R. § 106.45.)
Determination. The decision-maker, who is neither the Coordinator nor the investigator, issues a written determination that includes the allegations, the procedural steps taken, findings of fact, conclusions on whether the conduct occurred, the rationale for each result, any disciplinary sanctions on the respondent, whether remedies will be provided to the complainant, and the appeal procedures. It is sent to both parties simultaneously and becomes final on the date of the appeal decision or, if no appeal is filed, when the appeal window closes.
Appeal (within 10 days). Either party may appeal a determination or dismissal, in writing within ten (10) days, on these grounds: (1) procedural irregularity that affected the outcome; (2) new evidence not reasonably available at the time that could affect the outcome; or (3) conflict of interest or bias by the Coordinator, investigator, or decision-maker that affected the outcome. The appeal decision-maker, who is different from the investigator and the original decision-maker, issues a written decision to both parties simultaneously, with rationale. This is the final action at the TSAS level.
Informal resolution. At any time after a formal complaint is filed and before a determination, the School may offer a voluntary informal resolution process with both parties’ written, informed consent. The School will not require informal resolution as a condition of enrollment, employment, or any right, and will not offer it to resolve allegations that an employee sexually harassed a student. Any party may withdraw and resume the formal process before it concludes.
Shared Provisions
Apply to both Track 1 and Track 2.
Non-retaliation. The School prohibits retaliation, intimidation, threats, or coercion against any person for making a good-faith complaint, reporting discrimination or harassment, or participating — or declining to participate — in an investigation or appeal. Retaliation is itself a violation of this procedure and will result in responsive action.
Confidentiality. All complaints, notes, documents, and statements are maintained confidentially to the extent reasonably possible and are kept separate from personnel files; no complaint record is placed in an employee’s personnel file unless adverse employment action is taken. Records may become public if official proceedings are initiated, in accordance with law.
External remedy. A Complainant may seek a remedy from the U.S. Department of Education’s Office for Civil Rights within 180 days of the last act of alleged discrimination. This right is independent of the School’s internal procedure and is not affected by the 30-day internal filing deadline (Track 1) or by whether an internal complaint was filed.
Extension of time. Except as otherwise provided in this procedure, any time limit may be extended by mutual consent of the parties. The Coordinator’s authority to extend the Track 1 investigation period, and the timeframes required under Track 2, are governed by their own terms.
Retention. Complaint records — including, for Track 2, records of each investigation, determination, appeal, informal resolution, supportive measures, and required Title IX training — are retained for seven (7) years after resolution.
Legal authority — Title VI & VII, Civil Rights Act of 1964; Title IX, 20 U.S.C. § 1681; Title II, ADA; Section 504, Rehabilitation Act; ADEA; 70 O.S. § 24-163.
Board adoption: 2026-07-21; amended and approved 2026-08-11 (motion 922, 4-0, per draft 2026-08-11 minutes pending September ratification) — appeal routing conformed to counsel’s 2026-08-03 guidance: the Board sits as a body, never an individual trustee, and is the decision-maker in matters involving the Head of School.
Last updated: August 19, 2026