I worked as a Title IX coordinator at a K-12 institution. While most of the allegations were inocuous we had to remember that in order for it to be considered a Title IX it has to be discrimination on the basis of sex.

EXCERPT: (CFR)

Subpart C—Discrimination on the Basis of Sex in Admission and Recruitment Prohibited

§ 106.21   Admission.

(a) General. No person shall, on the basis of sex, be denied admission, or be subjected to discrimination in admission, by any recipient to which this subpart applies, except as provided in §§106.16 and 106.17.

(b) Specific prohibitions. (1) In determining whether a… >>>

Good question, but this was not addressed in the training from my knowledge. I would refer to your institution's policy.