OCR Takes Drastic Action in Title VI Case

Cambridge, USA, September 30, 2025

The US Department of Health and Human Services’ (HHS) Office for Civil Rights (OCR) has taken an extraordinary and aggressive step against Harvard University, formally referring the institution for suspension and debarment proceedings. This action could ultimately make the Ivy League school ineligible to receive new federal funding and contracts, a financial blow potentially costing billions and severely impacting its world-class research operations.

The OCR’s referral stems from its finding that Harvard violated Title VI of the Civil Rights Act of 1964 by exhibiting “deliberate indifference” toward discrimination and harassment faced by Jewish and Israeli students on its campus since October 7, 2023. This move escalates the long-running legal and political battle between the university and the current administration.

Headline Points

 * Drastic Enforcement: The HHS Office for Civil Rights (OCR) referred Harvard to its suspension and debarment office, which determines if an entity is eligible to do business with the federal government.

 * Title VI Violation: The OCR’s action is based on a June 2025 finding that Harvard acted with “deliberate indifference” toward severe, pervasive harassment of Jewish and Israeli students, violating Title VI.

 * Financial Threat: Debarment proceedings threaten to cut off Harvard from billions of dollars in federal research grants and contracts, the lifeblood of its extensive scientific and medical research.

 * Administrative Hearing: Harvard has been notified of its right to a formal administrative hearing to contest the Title VI violation findings before an administrative law judge.

The Basis for Debarment

The decision by the OCR to refer Harvard for suspension and debarment proceedings is a rare and highly aggressive form of federal civil rights enforcement. Suspension temporarily excludes an entity from receiving new federal funds while debarment proceedings take place, with a final debarment permanently prohibiting the institution from entering into new government contracts for a specified period.

The OCR’s initial Notice of Violation, issued in June 2025, concluded that Harvard failed to take appropriate action to address a hostile environment of harassment and intimidation directed at Jewish and Israeli students by other students and faculty. The agency is leveraging its authority under Title VI, which prohibits discrimination based on race, color, or national origin—a protection that federal guidelines extend to encompass discrimination based on shared ancestry, such as Jewish or Israeli identity.

Looming Financial Catastrophe

For a research powerhouse like Harvard, the financial implications of a debarment are immense. The university typically receives billions of dollars in federal funding for research, much of it from agencies like the HHS and the Department of Defense. A funding cutoff would jeopardize thousands of research projects, from medical breakthroughs to national security initiatives, and could force significant operational restructuring.

This referral takes on new significance given that a federal judge recently ruled against the government’s earlier attempt to freeze over $2 billion in Harvard’s existing research grants. That judge had argued the administration failed to follow proper Title VI procedures and acted unlawfully. By initiating the formal suspension and debarment process, the government is now attempting to bypass those legal restrictions by following a different, formal regulatory pathway to block the university from future funding.

Harvard’s Next Move

In its statement, the OCR confirmed that it has notified Harvard of its right to a formal administrative hearing. This hearing will allow the university to present its defense against the allegations of deliberate indifference before an HHS administrative law judge. Harvard has historically maintained that it is fully compliant with all federal anti-discrimination laws and has been taking substantial steps to combat antisemitism and all forms of bias on its campus.

The university now faces a critical deadline to decide whether to accept the findings, attempt to negotiate a compliance agreement, or engage in a high-stakes administrative and legal fight that will likely determine its long-term financial relationship with the US government.