On December 1, 2025, the University of Kentucky (UK) Office of Legal Counsel sent a letter to the U.S. Department of Education’s Office for Civil Rights (OCR) regarding the institution’s process and decision to terminate memberships/partnerships with about 1,200 external organizations, including 15 FABBS member societies. The university reviewed its external relationships at the behest of OCR, following an investigation which determined UK’s association with a specific non-profit constituted a violation of Title VI of the Civil Rights Act of 1964. This legislation prohibits recipients of federal funding from engaging in discrimination based on race, color, or national origin.
Complaint and Investigations
Sometime in early 2025, OCR received a complaint alleging that UK violated Title VI by supporting a conference held by The PhD Project. This award-winning nonprofit partners with organizations across the country – including universities – to increase the number of underrepresented minorities in business schools across the U.S. Its conference offers “prospective doctoral students a realistic look at every phase of the PhD journey, as well as an opportunity to network with current doctoral students, university representatives, college professors and PhD Project partners.” UK paid partnership fees to The PhD Project and financially supported faculty traveling to the annual conference.
As a result of the complaint, in March 2025, OCR opened investigations into UK, along with 44 other universities that have also partnered with The PhD Project. In the announcement, OCR claimed that the nonprofit “limits eligibility based on the race of participants,” presumably due to its focus on diversity and inclusivity.
In September, OCR announced the result of its UK investigation, determining that the university had violated Title VI by partnering with The PhD Project and providing financial support. In response, not only did UK end its relationship with that non-profit, but OCR also required the university to “conduct a review of all memberships or partnerships with external organizations to identify any…that may restrict participation based on race.” UK President Eli Capilouto signed an agreement to do so on October 1.
UK’s Review
The December letter from UK to OCR summarized its review process, in which it evaluated membership/partnership organizations on five parameters: organization name, former name, website content, leadership development programs, and employment-related policies. Essentially, UK checked to see if each organization had any references to racial, ethnic, gender-based, or other identity-specific terms that could indicate it restricted participation in its activities in some way. Further, it flagged organizations that used terminology such as “anti-racism” or “structural racism,” and also investigated whether they engaged in DEI initiatives. Organizations could be flagged for cancellation if even just a small part of their programming seemed to limit participation in some way, such as hosting a mentoring event for a certain group during an otherwise open conference.
Of the nearly 1,600 external organizations identified during the review, UK flagged about 1,200 for “cancellation or deeper review.” The university will maintain another 400 memberships/partnerships with organizations that may limit participation in some way but are essential to the institution for one reason or another. For example, UK is maintaining its relationship with the American Psychological Association (APA) because of accreditation, certification, licensure, and/or compliance obligations.
Despite being flagged for “cancellation or deeper review,” the letter indicates UK has already terminated relationships with those 1200 organizations, suggesting that it will not undertake any additional reviews.
Going Forward
FABBS will continue to gather information and alert colleagues about this development, especially regarding the implications these terminated relationships will have for our member societies. At this time, it is unclear exactly what these terminations will mean for UK and its employees, aside from no longer paying membership or partnership fees (as is the case with The PhD Project). It may be that faculty will no longer be able to pay for society memberships or conference travel using their discretionary funds. Further, there are still 44 institutions from the original OCR investigation that have yet to respond, so these terminated relationships might extend far beyond UK.
If you have any questions or information to share, you can reach FABBS at info@fabbs.org.
