Schools have been required to publish their racially nondiscriminatory policy since
1975. Allowable methods were in a newspaper or through broadcast media. Now,
schools can comply with this IRS requirement by publishing their racially
nondiscriminatory policy online.
The other methods are still allowable, including publication in a newspaper of
general circulation in the area that serves all racial segments of the community, and
broadcast media that is in the school’s service area and is expected to be effective.
To fulfill the requirement with an online publication, the policy needs to be on its
primary publicly accessible homepage throughout the tax year. The prominence of
the publication is important. IRS says there should be a reasonable expectation that
it will be noticed by visitors to the homepage. There shouldn’t be any special log in
or searching necessary. Also there shouldn’t simply be a link to another webpage
where the policy exists.
Of course regardless of the method that is chosen, the school needs to demonstrate
that it is following its policy.