Core Monitoring Guide

2005 National Equal Opportunity Training Conference

Learning Objectives
At the conclusion of this training, you will:
• • • Understand how the guide is structured and used. Understand how indicators are used to determine if the Civil Rights objective has been met. Understand the roles and responsibilities of grant recipients and federal staff as federal staff monitor an entity’s compliance with Equal Opportunity laws.

Overview
• Structure and Use of the Guide • Roles and Responsibilities • Grantee Community • Federal Staff • Review of a Notice

Guide Structure
• Core Activities
– Design and governance – Program and grant management systems – Financial management systems – Service delivery – Performance accountability

• Appendices

Core Activity Structure
• Objectives
– Relate to each core activity – Requirements or expectations

• Indicators
– – – – Attributes or criteria Attest to achievement of objectives C for compliance E for effectiveness

Core Activity Structure
• FPO Guidance
– Questions or documentation examples – Assist in assessment of indicator

• Source and Notes

Using the Guide
Role and Responsibilities of Federal Staff • Gather reference documents • Review source documents • Observe notices posted • Interview grantee staff • Walk through the facility

Using the Guide
Role and Responsibilities of the Grantee
• Provide source documents to federal staff for review
– Policy manual and written procedures – Written discrimination complaint procedure – Publications, materials, and brochures

• Provide staff for interviews • Provide full access to facilities

Using the Guide
• Objective conclusions • Summary findings
– At the objective level
• Promising Practices • Findings or High-Risk Factors • Other Observations

• Results
– Formal written report

Objective 2.3 Civil Rights
Recipients of DOL financial assistance must comply with: Title VI - Civil Rights Act of 1964 Section 504 – Rehabilitation Act Title IX, Education Amendments of 1972 Age Discrimination Act of 1975 Section 188 of the Workforce Investment Act

Indicators
• Policies and Procedures
– Do they reflect applicable laws and regs?

• Notices
– Do they inform readers of the discrimination complaint process, EO and Sec 504 policies? – Are they in languages appropriate for the population being served?

• Accessible Facilities

Indicator 2.31
• Policies and procedures
– Written discrimination complaint procedure – Is wording required by 29 CFR 37.30 in publications, materials, and brochures? – Monitoring compliance with EO law – EO is The Law notice

Indicator 2.32
Notices
– Does it provide contact information, overview of discrimination complaint process, etc? – Where and in what format are notices posted? – Language appropriate for population served?

Notice
EQUAL OPPORTUNITY IS THE LAW
It is against the law for this Recipient of Federal financial assistance to discriminate on the following basis: Against any individual in the United States, on the basis of race, color, religion, sex, national origin, age, disability, political affiliation or belief; and Against any beneficiary of programs financially assisted under Title I of the Workforce Investment Act of 1998 (WIA) on the basis of the beneficiary’s citizenship/status as a lawfully admitted immigrant authorized to work in the United States, or his or her participation in any WIA Title I-financially assisted program or activity.

Discrimination Complaint Procedure
If you think that you have been subjected to discrimination under any WIA Title I-financially assisted program or activity, you may file a complaint within 180 days from the date of the alleged violation with either: • The Recipient’s Equal Opportunity Officer, Valerie Kitchings, Department of Employment Services, 77 P Street, NE, Washington, DC 20002 or the person whom the Recipient has designated for this purpose; or • The Director, Civil Rights Center (CRC), U.S. Department of Labor, 200 Constitution Avenue, NW, Room N-4123, Washington, DC 20210.

Discrimination Complaint Procedure
If you elect to file your complaint with the recipient, you must wait until the recipient issues a written Notice of Final Action, or until 90 days have passed (whichever is sooner), before filing with the Civil Rights Center. If the Recipient does not give you a written Notice of Final Action on your complaint within 90 days of the day on which you filed your complaint, you do not have to wait for the Recipient to issue that notice before filing a complaint with the CRC. However, you must file your CRC complaint within 30 days of the 90-day deadline (in other words, within 120 days of the day on which you filed your complaint with the Recipient). If the Recipient does give you a written Notice of Final Action on your complaint, but you are dissatisfied with the decision or resolution, you may file a complaint with the CRC. You must file your CRC complaint within 30 days of the date on which you received the Notice of Final Action.

Contact Information
FOR INFORMATION OR TO FILE A COMPLAINT, CONTACT: VALERIE KITCHINGS, Equal Opportunity Officer, valerie.kitchings@dc.gov Department of Employment Services, Office of Equal Opportunity 64 New York Avenue, NE, 3rd Floor • Washington, DC 20002 (202) 671-2568 • TDD/TTY (202) 673-6994 • Fax (202) 673-7019 Auxiliary aids and services are available upon request to individuals with disabilities. Equal Opportunity Employer/Provider __________________________________________________________________ I acknowledge having read and understood the above notice. Signature: _______________________________ Date: ___________________________________

Indicator 2.33

• Grantee’s location and facilities
– Physically accessible and usable

Conclusion

Did we achieve our objectives?