Office for Civil Rights Releases Updated Case Processing Manual
Manual Updated for the First Time Since 2022
U.S. Department of Education’s Office for Civil Rights (OCR) released an updated version of its Case Processing Manual (CPM), which last was updated in 2022.
A comparison of the 2025 CPM and 2022 CPM reveals significant updates in language clarity, enforcement procedures, and institutional responsibilities. In addition to stylistic refinements (someone favors the Oxford comma) and reorganization of some of the content, this update eliminates much of the vague or ambiguous phrasing found in the 2022 CPM.
For example:
2022 CPM:
"Where a final agreement is not reached by the 30th calendar day, OCR will immediately resume its investigation."
2025 CPM:
"Where a final agreement is not reached by the 30th calendar day, the investigation will resume no later than on the 31st day after negotiations were initiated."
Previously, “immediately resume” could have been interpreted as within a few days or even a week or longer. The revised wording provides clear expectations: investigations will resume no later than the day after the 30-day deadline.
Even minor wording changes carry significant implications. For instance, under the new CPM, complaint timelines will begin when a complaint is "sent" to OCR rather than when it is "received"—a seemingly small but impactful shift.
Then there are the larger changes, such as:
First Amendment and Due Process Protections: A new section explicitly addresses the First Amendment.
·Expanded Investigative Determination: A new subsection under Section 303, titled “Negotiations On-Going at the End of the 90-day Period” was added, and is further referenced under Section 305: Letter of Impending Enforcement Action.
Stricter Deadlines for Information Requests: Requested information must now be submitted within 14 days, rather than 20 days allowed in the 2022 CPM.
Clearer Guidance on Investigations and Resolutions: Specific clarifications have been made regarding complaint dismissals and resolution procedures.
For a full breakdown, a side-by-side comparison of the 2022 and 2025 editions is available to download below.
Left Column: 2022 CPM text
Right Column: 2025 CPM text
Red + Bold: Updated language in both versions
Strikethroughs: Deleted text from the 2022 CPM
Red + Bold (without strikethroughs): New additions in the 2025 CPM