Correct. It's a Federal program, but the NCAA does comply with it and has their own program enforcing it. While Title IX is mainly focused on equal participation, benefits and discrimination, it's the sexual antics of Zach Smith on school property, on school time, and while he was representing the University (e.g. at the White House) that may be touching on a violation of some aspect of Title IX. (Not an attorney or compliance officer here).
But the problem with the NCAA...you never know when they are going to strike, or rules they will try to enforce. They come down hard on some schools, yet let others off with a wrist slap for the same violations. Interesting we haven't heard much from them in a while. I wonder if "the powers that be" at the major universities finally stood up to them and told them to back off or they will disband from the NCAA. And I have no insight on this subject at all...just going by observation from the past few years versus the late 90s and early 2000s.