The Job Corps Admissions Process:

1
  The Job Corps Admissions Process
  Essential Eligibility Requirements and Direct
Threat Issues

• Denise M. Sudell, Esq., USDOL Civil Rights Center
  Senior Policy Advisor
• Debbie M. Jones, Disability Specialist, Humanitas
• Valerie R. Cherry, Ph.D., Principal Mental Health
  Consultant, Humanitas
•                                          

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Purpose/Background EERs Direct threat

• Purpose

• In partnership with CRC, Job Corps is revising
  its admissions process to ensure that admission
  criteria are as objective as possible, and that
  the admissions process complies with disability
  nondiscrimination law 
• In this workshop, we will discuss the draft
  Essential Eligibility Requirements (EERs) and
  direct threat assessment guidelines that are
  being developed by a Job Corps/CRC brainstorming
  team

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Purpose/Background EERs Direct threat

• Legal Requirements

• Congressional and administrative mandates require
  Job Corps to
• Enroll and serve applicants who meet the
  eligibility requirements imposed by Congress (as
  interpreted by USDOL in the Job Corps
  regulations), regardless of a particular
  applicants disabilities
• Provide reasonable accommodations for applicants
  and students with disabilities

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Purpose/Background EERs Direct threat

• Legal Requirements

• Among these requirements
• Sections 144 and 145 of the Workforce Investment
  Act of 1998 (WIA) contain general eligibility
  requirements for Job Corps
• USDOL/ETAs Job Corps regulations at 20 CFR
  670.400 and 670.410 implement eligibility
  requirements in WIA statute
• WIA Section 188 contains nondiscrimination and
  equal opportunity provisions -- and USDOL/CRCs
  implementing regulations at 29 CFR part 37
• Section 504 of the Rehabilitation Act of 1973 and
  USDOL/CRCs regulations at 29 CFR part 32

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Purpose/Background EERs Direct threat

• Background

• Brainstorming team comprised of Job Corps
  staff, Job Corps contractor staff, and staff of
  DOL Civil Rights Center (CRC) have been meeting
  on an ongoing basis, beginning in August 2006, to
  develop EERs and resolve related issues
• CRC was invited to partner with Job Corps to
  ensure that the revised admissions process
  complies with applicable nondiscrimination
  requirements and provides equal opportunity for
  applicants in protected groups (particularly
  applicants with disabilities)

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Essential eligibility requirements
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Essential Eligibility Requirements

• What are EERs?

• Essential Eligibility Requirements (EERs) are the
  requirements that are necessary for participation
  in the Job Corps program
• Disability nondiscrimination law prohibits Job
  Corps (and other programs and activities) from
  applying eligibility criteria that unnecessarily
  screen out applicants with disabilities
• Therefore, Job Corps must apply only those
  eligibility requirements that are necessary

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Essential Eligibility Requirements

• Background Job Corps Eligibility Criteria

• Under regulations and current PRH two sets of
  criteria
• Eligibility criteria
• Factors such as age, income, barriers to
  education/employment, etc.
• Additional factors examples
• Needs can best be met
• Participate successfully in group situations
• Not likely to engage in actions . . .
• Covered in ACAT

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Essential Eligibility Requirements

• Concerns about additional factors

• Criteria were subjective
• Few specifics re how to determine if applicant
  met these factors
• Left considerable discretion to ACs
• Concerns were raised
• National Job Corps workgroup recommended
  development of specific criteria
• CRC concerned that discretion was excessive,
  might result in discrimination (intentional or
  unintentional)

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Essential Eligibility Requirements

• Which requirements are essential?

• Requirements imposed by Congress (in WIA)
• Objective criteria e.g., age (including
  waivers), income, specific barriers
• Subjective criteria needs can best be met,
  participate successfully, etc.
• Requirements imposed by other laws, e.g.
• Registration with Selective Service
• Permission of parent or guardian

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Essential Eligibility Requirements

• What our team was asked to do

• Develop specific standards for determining
  whether an applicant meets the subjective
  essential eligibility requirements
• Weve only revised some of the standards others
  remain the same we will not be discussing those
  in this presentation
• Make sure the process complies with legal
  requirements
• Example requiring that disability-related info
  (such as IEPs) be kept in separate files, stored
  securely

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Essential Eligibility Requirements

• Overall Changes

• We have developed specific questions that ACs
  will ask applicants
• Do you understand that . . .? For example, you
  will be expected to . . .?
• Knowing this about Job Corps, are you willing
  to go forward with your application?
• Change in Exhibit 1-1 to make it easier to use
• For each EER, the exhibit asks Does applicant
  meet?
• If yes, go on to next EER if no, applicant
  does not meet eligibility requirements.

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proposed revisions of eligibility criteria
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Essential Eligibility Requirements

• EER Program Suitability

• Can the applicants educational and training
  needs best be met through the Job Corps program?
• If applicant has not graduated from high school,
  s/he wants to earn a high school diploma or GED
  and participate in career technical training.
• If applicant has graduated from high school, s/he
  wants to obtain career technical training.
• After graduation from Job Corps, applicant wants
  to obtain employment, or enter the military,
  and/or continue his or her education.

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Essential Eligibility Requirements

• EER Program Suitability (contd)

• Applicant is able to complete/answer basic Job
  Corps application questions (e.g., birth date,
  address, phone number, last school attended, last
  grade completed) with or without communication
  assistance/reasonable accommodation.
• For instance, an applicants parent or guardian
  may help explain what an applicant with a
  disability that impairs his/her speech is saying
  in response to a question however, the parent or
  guardian should not supply the content of the
  answers to the questions on the applicants
  behalf.

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Essential Eligibility Requirements

• EER Group Participation

• Can the applicant participate successfully in
  group situations and activities?
• Sample question
• Team player Do you understand that in order to
  succeed in Job Corps, you will need to function
  as part of a team? For example, you will share a
  dormitory room, you will be responsible for
  cleaning your living area, and you will need to
  rely on staff and other students to complete
  tasks and assignments.
• Applicant either expresses willingness, or does
  not express active unwillingness.

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Essential Eligibility Requirements

• EER Group Participation (contd)

• Another sample question
• Multi-cultural environment Do you understand
  that if you are admitted to Job Corps that you
  will be living and working with members of
  various races, ethnic groups, political or
  religious affiliations or beliefs, sexual
  orientations, and gender identities, and people
  with disabilities?
• Applicant either expresses willingness, or does
  not express unwillingness to live with (or make
  negative statements about), members of these
  groups.

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Essential Eligibility Requirements

• EER Understanding of Rules

• Has the applicant has been informed about, and
  does he/she appear to understand, the centers
  rules and the consequences of failing to follow
  those rules?

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Essential Eligibility Requirements

• EER Understanding of Rules (contd)

• Question
• Do you understand that if you are accepted into
  Job Corps, you will be expected to comply with
  the rules and regulations of Job Corps? For
  example . . .
• Sample examples
• If you live on center, you will have to follow a
  curfew.
• Your center may have rules about cell phone
  use.
• You may not be permitted to smoke on center.
• You may be required to wear a uniform.

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Essential Eligibility Requirements

• EER Understanding of Rules (contd)

• Applicant either states that s/he is willing to
  follow the rules of the Job Corps program, or
  does not
• Make statements such as, No one tells me what to
  do.
• Express strong objection to one or more of the
  rules that are described to him/her.

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Essential Eligibility Requirements

• EER - Interference with Other Students
  Participation

• Is the applicant likely to engage in actions that
  would potentially prevent other students from
  receiving the benefit of the Job Corps program?
• Does the applicant display disruptive and/or
  threatening behavior during the application
  process? Examples
• Possession of a gun or other illegal weapon
• Attempts to destroy/steal property
• Assault or threatened assault
• Inappropriate sexual behavior

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Essential Eligibility Requirements

• EER Community Relations

• Is it likely that the applicants behavior will
  impede satisfactory relationships between the Job
  Corps center to which the individual might be
  assigned and its surrounding community?
• Applicant expresses a willingness to
• Participate in community services.
• Behave in a manner that reflects positively on
  Job Corps.
• Applicant agrees that s/he will not participate
  in gang-related activities while s/he is enrolled
  in Job Corps

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Essential Eligibility Requirements

• EER Community Services/Positive Representations
  of Job Corps

• Sample Question
• Every center calls on its students to
  participate in community service activities at
  least twice a year.
• Students may also participate in OJT, job
  shadowing, other activities in which they
  interact with local employers.
• Are you willing to participate in these kinds of
  activities?
• Do you understand that while you participate in
  these activities, you are representing the Job
  Corps program and must behave in a manner that
  reflects positively on Job Corps?

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Essential Eligibility Requirements

• EER Community Services/Positive Representations
  of Job Corps

• Examples of community service activities to
  describe to applicant
• Help build, clean up or repair local community
  facilities
• Provide companionship and/or services to people
  in the community
• Participate in environmental clean up

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Essential Eligibility Requirements

• EER Gang-Related Activity

• Sample questions
• If applicant does not show any signs of gang
  activity/participation
• Students enrolled in the Job Corps program are
  barred from participating in any type of
  gang-related activities.
• Do you agree that you will not participate in
  any gang activity while you are in the Job Corps
  program?
• Do you agree that you will not display or use
  gang paraphernalia, symbols, gestures,
  handshakes, colors, dress, and/or any other
  gang-related activities or items while you are in
  the Job Corps program?

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Essential Eligibility Requirements

• EER Gang-Related Activity (contd)

• More sample questions
• If applicant uses or displays gang-related
  behavior or symbols
• I see that you have describe gang-related
  behavior, symbol, activity. Students enrolled
  in the Job Corps program are barred from
  participating in any type of gang-related
  activities. . . .
• (Same questions as on previous slide)

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Essential Eligibility Requirements

• EER Gang-Related Activity (contd)

• More sample questions
• If applicant has a gang-related tattoo, scar, or
  other form of permanent body art
• I see that you have a tattoo, scar, etc.
  related to the name of gang. Students enrolled
  in the Job Corps program are barred from
  participating in any type of gang-related
  activities.
• Do you agree that you will not participate in
  any gang activity while you are in the Job Corps
  program?
• Do you agree that while you are in the Job Corps
  program, you will keep your tattoo, scar, etc.
  covered at all times?

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Essential Eligibility Requirements

• EER Current Court Involvement and/or Agency
  Supervision

• Is the applicant facing pending criminal court
  action? Is the applicant on probation or parole,
  under a suspended sentence, or under the
  supervision of any agency as a result of court
  action or institutionalization? Does the
  applicant have court fines in excess of 500?

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Essential Eligibility Requirements

• EER Maintenance of Sound Discipline

• Is the applicants behaviors incompatible with
  the maintenance of sound discipline?
• Criteria
• Criminal history review
• Does not disclose any disqualifying offenses.
• If any non-disqualifying offenses are disclosed,
  AC will make reasonable judgment of eligibility.
• Applicant agrees to comply with specific Job
  Corps rules

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Essential Eligibility Requirements

• EER Criminal History Review

• AC will complete criminal history review as
  described in revised Appendix 104
• Review will use applicant addresses from past
  three years
• Disqualifying offenses will be listed in Appendix
  104
• Lack of Information If courts/agencies refuse or
  fail to supply information and the applicant
• Admits court involvement/an offense, the AC will
  make a reasonable judgment of eligibility
  consistent with the type of offense admitted to
  by the applicant.
• Denies any court involvement, the AC will inform
  the applicant that concealing a criminal history
  is grounds for immediate discharge from Job Corps
  for fraudulent enrollment.

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Essential Eligibility Requirements

• EER Applicant Agreement

• AC will ask series of questions Do you
  understand that . . .?
• Applicant must agree to each
• Sample questions (not a complete list)
• . . . violence, bullying and harassment are not
  tolerated in Job Corps
• . . . you will be tested for illegal use of
  drugs when you arrive at the center, and if you
  test positive, specific actions listed will be
  taken
• . . . you will have to leave the Job Corps
  program if convicted of illegal drug use,
  possession or sale off-center
• . . . you must abide by Job Corps rules and
  policies to stay in the program

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Program suitability Example

• EER Example 1

• EER I - Can the applicants educational and
  training needs best be met through the Job Corps
  program?

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Program suitability Example

• Scenario

• Applicant comes to the Outreach and Admissions
  office interview with his case manager from a
  local community services program.
• Case manager answers questions for the applicant.
• The Admissions Counselor (AC) instructs the case
  manager and the applicant that the applicant
  should answer the questions.
• The AC asks another question about basic personal
  information and the student appears unable to
  answer the question.

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Program Suitability Example

• What should happen next?

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Program suitability Example

• Scenario

• The AC should remind the case manager and the
  applicant that if he/she is a person who has a
  physical or mental impairment that substantially
  limits one or more of his/her major life
  activities (e.g. is a person with a disability),
  then he is entitled to reasonable accommodation.
  

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Program suitability Example

• Scenario

• Applicant discloses a cognitive disability and
  the case manager explains that the applicant
  needs the language in the questions to be
  simplified and the questions to be repeated to
  aide in understanding.
• The AC simplifies the questions and repeats each
  question at least twice before the applicant is
  expected to respond. Can the applicant now
  answer the questions independently?

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Program suitability Example

• Scenario Outcomes

• Outcome 1
• The applicant cannot answer the ACs questions
  independently even with reasonable accommodation.
• The applicant does not meet this essential
  eligibility requirement and the application
  process stops.
• Outcome 2
• The applicant can answer the ACs questions
  independently with reasonable accommodation.
• The application process continues and the AC
  determines whether the applicant meets the
  remainder of the essential eligibility
  requirements.

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Direct Threat
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Direct Threat

• Direct Threat (DT)

• New direct threat form and guidance for Job Corps
  are being developed
• Job Corps requires that applicants and students
  not have conditions, disabilities, or behaviors
  that pose a direct threat to the health or safety
  of themselves, other students, or staff
• If the direct threat is related to a disability,
  both Job Corps and the law require a
  determination of whether the threat could be
  eliminated or reduced by reasonable
  accommodations or modifications

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Direct Threat

• Direct Threat Legal Standards

• Disability nondiscrimination law defines a
  direct threat as a significant risk of
  substantial harm to the health and safety of the
  individual or others that cannot be eliminated or
  reduced by reasonable accommodation or
  modification
• A significant risk means a high, not a slight,
  probability a speculative or remote risk is
  insufficient

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Direct Threat

• Direct Threat Legal Standards (contd)

• The burden of proof is on Job Corps
• This means that if evidence is equivocal or
  insufficient to prove direct threat, we must
  assume that no direct threat exists

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Direct Threat

• Direct Threat Legal Standards (contd)

• Legal standards are strict re
• When (the point in the process at which) a direct
  threat assessment may take place
• What type of evidence may be considered
• Must be considered
• The most current medical knowledge (if medical-
  or disability-related issue)
• The best available objective evidence about the
  specific applicant or students
• Current condition, disability, or behavior
• Present ability to safely participate in the
  program

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Direct Threat

• Direct Threat Legal Standards (contd)

• What type of evidence may be considered (contd)
• Must not be considered
• Subjective perceptions
• Irrational fears
• Patronizing attitudes
• Stereotypes
• The law makes clear that an individual does not
  pose a direct threat simply because s/he has a
  history of psychiatric disability, or is
  currently receiving treatment for a psychiatric
  disability

44
Direct Threat

• Direct Threat - Process

• During admissions process
• Applicant responds to revised ETA 6-53
• AC does not ask any additional questions/make DT
  judgments just sends file to center
• Health Wellness Manager does initial review
• If information indicates possible direct threat,
  file will be referred to appropriate staff for
  direct threat assessment, as described on next
  slide

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Direct Threat

• Direct Threat Process (File Referral)

• If HW Manager finds that possible direct threat
  (as defined on previous slides) is posed by a
  disability, or a medical-related condition or
  behavior, Mgr will send file to appropriate
  licensed clinical health provider
• If information indicating possible direct threat
  is not related to disability or medical-related
  condition or behavior, Mgr will send file to
  Center Standards Officer/Behavior Management
  Officer
• Objective information must support this referral,
  or no subsequent steps (assessment, etc.) will be
  authorized by law

46
Direct Threat

• Direct Threat Process (The Assessment)

• Assessor must consider four specific factors
  required by law
• Duration of risk
• Nature and severity of the risk
• Likelihood that the potential harm will occur
• Imminence of the potential harm
• On direct threat form, must list specific facts
  that provide evidentiary support for assessors
  judgment

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Direct Threat
Closer Look at the DT Factors

• 1. Nature and severity of the risk in the
  professional judgment of the assessor
• a. What kind of harm is potentially posed by
  this applicants condition, disability, or
  behavior?
• b. What is the seriousness of the potential harm
  in this particular case (e.g., death,
  incapacitation, serious injury, minor
  injury/emotional distress)?
• 2. Duration of the risk in the professional
  judgment of the assessor, how long is the risk
  likely to last?
• 3. Likelihood that the potential harm will occur
  in the professional judgment of the assessor,
  is the likelihood that potential harm will occur
  high, moderate, or low?
• 4. Imminence of the potential harm in the
  professional judgment of the assessor, how soon
  is the harm likely to occur?

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Direct Threat

• DT Assessment Relevant Evidence

• Relevant evidence in making the assessment may
  include
• Input from the individual with a condition,
  disability, or behavior
• The medical history of the individual, including
  his/her experience in previous situations similar
  to those he/she would encounter in the program
• Opinions of medical doctors, rehabilitation
  counselors, or therapists who have expertise in
  the condition involved and/or direct knowledge of
  the individual

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Direct Threat

• Considerations

• Each of the four factors should be taken into
  consideration, however depending upon the
  individual situation, one factor may have more
  significance than another in the assessment

50
Direct Threat

• If Assessor Finds Possible Direct Threat

• If assessor determines possible direct threat
  that is related to a disability or a
  medical-related condition or behavior, s/he must
• Consider whether an accommodation or modification
  could
• Eliminate the risk
• Reduce the risk to an acceptable level
• List possible accommodations/modifications on the
  form
• Assessor must not attempt to determine
  reasonableness

51
Direct Threat

• DT Form and Guidance

• When completed and approved, the direct threat
  form and guidance will be released as a PRH
  Change Notice and will replace the current
  guidance outlined in Appendix 103

52
Direct Threat

• DT Example 1

• A student is in the culinary arts training
  program. This program requires the student to
  work with and around hot stoves and deep fryers.
  The student has an epileptic seizure while
  working in the kitchen. The student manages to
  find a safe place in the cafeteria, and sits down
  until the episode passes. The following week, the
  student experiences another seizure in the
  kitchen and burns his hand, but again manages to
  avoid harming anyone else.
• Using the four factors, determine if a direct
  threat exists, and, if so, list accommodations or
  modifications that might reduce or eliminate the
  risk.

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Direct Threat
Review of DT Factors
1. Nature and severity of the risk in the
professional judgment of the assessor a. What
kind of harm is potentially posed by this
applicants condition, disability, or behavior?
b. What is the seriousness of the potential
harm in this particular case (e.g., death,
incapacitation, serious injury, minor
injury/emotional distress)? 2. Duration of the
risk in the professional judgment of the
assessor, how long is the risk likely to last? 3.
Likelihood that the potential harm will occur
in the professional judgment of the assessor, is
the likelihood that potential harm will occur
high, moderate, or low? 4. Imminence of the
potential harm in the professional judgment of
the assessor, how soon is the harm likely to
occur?
54
Direct Threat
DT Example Suggested Analysis

• 1. Nature and Severity of Risk The type of
  potential harm is burns and/or scalding. The
  seriousness is severe, because the stoves and
  deep fryers reach extremely high temperatures and
  could cause burns or scalding injuries that could
  be life-threatening.
• 2. Duration of Risk The risk will be present
  every time the student works in the kitchen near
  the stoves and deep fryers, during his entire
  work shift.
• Likelihood that the potential harm will occur
  The likelihood of the harm apparently is moderate
  to high the student did not hurt anyone during
  his two episodes, but did hurt himself.
• Imminence of the potential harm The imminence of
  the harm is high as the episodes appear to come
  without warning and cannot be controlled at this
  time.
• A burn or scalding injury will happen
  immediately if the student has a seizure that
  causes him to collide with a stove or fryer, or
  to accidentally push another student or staff
  member into contact with such hot equipment.

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Direct Threat

• Suggested possible accommodations/modifications

• Modify the requirements of the culinary arts
  program to permit the student to work only on
  cold foods, in a part of the kitchen that is
  separate from the stoves and fryers.
• Allow student to work on other areas of the TARs
  for the trade that would not involve the stoves
  or fryers. This would also provide time for the
  student to adjust to any medication changes as
  well.
• Reassign student to another trade.

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Direct Threat

• Possible clinical activities (for licensed
  clinical provider NOT accommodations

• The student should be referred for a medication
  review. If he is taking seizure medication, it
  may need adjustment. If he is not taking such
  medication, it may be indicated.
• Allowing the student to work on other areas of
  the TARs would provide time for him to adjust to
  any medication changes.

57
Direct Threat

• Process of reviewing assessment and suggested
  accommodations/ modifications with student

• Student should be asked to meet with the center
  physician to review assessment
• If student asks to be accompanied by
  representative, he must be allowed to do so
• Interactive process of discussing possible
  accommodations/modifications must take place

58
Direct Threat

• Process of reviewing assessment and suggested
  accommodations/ modifications with student

• If student (or representative) proposes other
  accommodations/modifications that Job Corps
  believes would cause undue hardship/fundamental
  alteration of program, Job Corps must take the
  steps listed on following slide

59
Direct Threat

• Process of analyzing proposed accommodations/modif
  ications

• If Job Corps believes proposed accommodations/
  modifications would create undue hardship/
  fundamental alteration, it must conduct the
  formal analysis of the proposal that is required
  by 29 CFR 37.8, applying factors listed in 29 CFR
  37.4

60
Direct Threat

• Process of analyzing proposed accommodations/modif
  ications

• If, after analysis, Job Corps determines undue
  hardship/ fundamental alteration, it must
• Provide a written statement of the reasons for
  its determination
• Give a copy of the statement to the student
• Offer another solution that would permit student
  to participate in program to greatest extent
  possible

61
Direct Threat

• If student does not accept alternative
  accommodations/modifications offered by Job Corps

• Job Corps must provide written statement
  explaining why no other accommodation/modification
  is possible
• Statement must contain required analyses of any
  other possible accommodation/modification offered
  by student or assessor
• If student continues to decline alternate
  accommodation/ modification he may be separated
  from Job Corps as unqualified

62
Direct Threat

• If student does not accept alternative
  accommodations/modifications offered by Job Corps

• Interactive process, offer of alternative
  solution, students decision to decline must be
  documented

63
Direct Threat

• DT Example 2

• An applicant with a self-disclosed mental health
  disability was hospitalized for several weeks 6
  months ago due to an attempted suicide.
• The applicant participates in the IDT team
  meeting with no observable problems noted by the
  center mental health consultant.

64
Direct Threat

• DT Example 2

• The discharge summary and report from the
  applicants medical professional states that she
  is stable and able to come to Job Corps. However,
  the center recommends denial because members of
  the IDT team feel uncomfortable having a student
  on center with a recent hospitalization for a
  suicide attempt and are concerned about her
  safety.

65
Direct Threat

• Direct Threat Example 2 Answer

• In this example, without objective evidence and
  based only upon speculation and subjective
  feelings of staff, the center cannot support its
  recommendation to deny the applicant due to
  direct threat.

66
Policy changes/Processes
67
Policy/Processes

• Current Policy/Process

• Currently centers may accept the recommendation
  of the AC or they may disagree with that
  recommendation and make recommendations for
  enrollment or for denial, as indicated. The
  three existing reasons for recommendation of
  denial are
• The applicants educational and training needs
  cannot be best met through the Job Corps program
  even with reasonable accommodation
• The applicant cannot be reasonably expected to
  successfully participate in group situations and
  activities and is likely to engage in behavior
  that would prevent other students from receiving
  the benefit of the Job Corps program even with
  reasonable accommodation
• The applicant poses a direct threat to self or
  others that cannot be alleviated with reasonable
  accommodation

68
Policy/Processes

• Process Change

• When EERs are added to the PRH, the admissions
  requirements will remain nearly the same
  however, the process will be different
• OA staff will be responsible for assessing each
  EER and making a determination if the applicant
  meets the EER
• Once OA makes decision that applicant meets a
  particular EER, the center will only be able to
  revisit this EER if new information is presented
  that the OA did not have knowledge of when
  interviewing the applicant

69
Policy/Processes

• Process Change (contd)

• Centers will still be able to recommend denial of
  applicants who are a direct threat to self or
  others

70
Policy/Processes

• Benefits

• Essential eligibility requirements will
• Ensure all those who can benefit from the program
  are given the opportunity to participate
• Give potential applicants an opportunity to
  evaluate their prospects for success in Job Corps
• Eliminate some of the significant center/regional
  differences that exist in the applicant file
  review process

71
Policy/Processes

• Health Questionnaire Update

• ETA 6-53 expires this year and had to be
  resubmitted to OMB for approval
• Prior to submission to OMB, additional questions
  were added that allow Job Corps to gather
  information related to conditions, disabilities,
  or behaviors of ALL applicants who may require
  ongoing care at Job Corps or who may pose safety
  concerns
• Once approved by OMB, the ETA 6-53 will be
  released as a Program Instruction

72
Policy/Processes

• Changes You Can Anticipate

• PRH-1 is being revised to incorporate the process
  and language changes required by implementation
  of new EERs and new direct threat
  process/guidance for Job Corps
• Language to ensure all equal opportunity and
  non-discrimination requirements are being met is
  also being added
• Joint effort between CRC and National Office of
  Job Corps Outreach Admissions and Health Staff

73
Resources
74
http//jcdisability.jobcorps.gov

• Job Corps Disability Website

75
http//jccrdc.jobcorps.gov/ld

• Job Corps Learning Disabilities Website

76
http//jchealth.jobcorps.gov/health-topics/mhd

• Supporting Students with
• Mental Health Disabilities

77
Resources

• Information About Legal Requirements

• Civil Rights Center (CRC)
• U.S. Department of Labor
• 200 Constitution Avenue N.W.
• Room N-4123
• Washington, D.C. 20210
• http//www.dol.gov/dol/oasam/crchome.htm
• EEOC Guidance on Psychiatric Disabilities
  (includes direct threat info)
• http//www.eeoc.gov/policy/docs/psych.html

78
Resources

• How to Contact Us

• Denise Sudell, USDOL Civil Rights Center
• [phone] (voice)
• [phone] (Federal Information Relay Service
  for TTY/TDD)
• sudell.denise_at_dol.gov
• Carol Abnathy, National Office of Job Corps
• [phone]
• abnathy.carol_at_dol.gov
• Peni Webster, National Office of Job Corps
• [phone]
• webster.peni_at_dol.gov