Dear PRA Coordinator:
The Defense of Freedom Institute for Policy Studies (“DFI”) is a national nonprofit organization
dedicating to defending and advancing freedom and opportunity for every American family,
student, entrepreneur, and worker and to protecting the civil and constitutional rights of Americans
at school and work. DFI envisions a republic where freedom, opportunity, creativity, and
innovation flourish in our schools and workplaces.
On December 13, 2021, the U.S. Department of Education’s (“ED”) Office for Civil Rights
(“OCR”) published a notice concerning proposed revisions to OCR’s Mandatory Civil Rights Data
Collection (“CRDC”).
1 ED proposes to create and collect data on a new “nonbinary” sex category
(in addition to the current “male” or “female” sex categories) and to retire data collection that
indicates the number (1) of high school-level interscholastic athletics sports in which only male