; (2) an analysis of the number of such complaints and their substance; and (3) a narrative of the action the institution took with respect to such complaints. (b) Audit The Inspector General of the Department of Education shall complete an annual audit of the institutions of higher education that are in the top 5 percent of institutions based on the per capita number of complaints described in subsection (a) received by the institutions, controlling for student population, to examine the process for addressing such complaints and the need for any referrals to the Office for Civil Rights of the Department of Education. (c) Study The Inspector General of the Department of Education shall conduct a study— (1) regarding why there is a disparity between the complaints regarding discrimination on the basis of race, color, or national origin in violation of title VI of the Civil Rights Act of 1964 ( 42 U.S.C. 2000d et seq. ) that are submitted to institutions of higher education and such complaints that are submitted to the Office; and (2) quantifying the distinction described in paragraph (1). 5. OCR process reforms The Office for Civil Rights of the Department of Education shall not close or dismiss any complaint due to resolution by another Federal, State, or local civil rights enforcement agency or through a recipient’s internal grievance procedures.