Last week we looked at a proposed IRS rule that could tie a private school’s tax-exempt status to how it handles race in admissions, scholarships, and other programs. The real point was not about the IRS specifically; rather, it was that education compliance issues rarely stay inside a single legal framework anymore.

This week gives us a K-12 example of the same idea, and this time the law doing the work is not Title IX at all.

On September 1, DOJ sued Kansas City, Kansas Public Schools over a district guidance document covering transgender and gender-nonconforming students. The lawsuit does not allege a Title IX violation. Instead, DOJ alleges the district’s guidance violates the Family Educational Rights and Privacy Act (FERPA) and the Protection of Pupil Rights Amendment (PPRA) by preventing parents from accessing their children’s education records and by allowing staff to gather sensitive information about students without prior written parental consent.

The case follows an ED FERPA investigation that opened in August 2025. ED found the district out of compliance with FERPA in July 2026 and out with PPRA last month. The district proposed a voluntary resolution agreement, but the ED rejected it. The district disputes DOJ’s allegations and maintains it is in full compliance with both laws. These are allegations in a newly filed complaint, not a court ruling, and no judge has weighed in yet.

Even so, the underlying point holds regardless of how the case resolves, and it is the same one from last week. A single policy covering a student’s name, pronouns, gender identity, parent communications, support plans, records, restrooms, locker rooms, or athletics can touch several legal frameworks at once. A Title IX analysis by itself will not catch everything.

Schools should be asking a broader set of questions about any policy in this space:

• Does the policy create or maintain an education record?
• What rights does a parent have to inspect that record?
• Could the way information is collected implicate PPRA?
• What does applicable state law require?
• Do written policies match what employees are actually trained to do?

Race and gender identity are different issues, but they are teaching schools, districts, and institutions the same lesson. A review built around one law may miss what the others require.