Title: Methods of Administration MOA Element 2
1Methods of AdministrationMOA Element 2
2Agenda
- Presentation Learning Objectives
- Presentation Key Requirements
- Activity Equal Opportunity Is The Law
- Presentation Notice and Communication
Supporting Documentation - Presentation States Implementation of
Requirements for Notice and Communication
3Learning Objectives
- Explain the federal requirements for EO Notice
and Communication under WIA - Describe the required procedures for
disseminating the Equal Opportunity is the Law
Notice and Tag Lines - Identify the acceptable documentation for EO
Notice and Communication - Describe the States plan for complying with the
EO Notice and Communication requirements under
WIA
4Key Requirements ForNotice and Communication
- 1. The recipient must provide initial and
continuing notice that it does not discriminate
on any prohibited ground (29 CFR 37.29-37.34). - The recipient must provide information that
describes an individuals right to file a
discrimination compliant (29 CFR 37.30 and
37.36). - The recipient must effectively communicate the
Equal Opportunity Is The Law Notice to
individuals with disabilities and to other
populations with special needs (29 CFR 37.31,
37.34 and 37.35).
5Key Requirement 1 Provide Initial Continuing
Notice
- Must provide initial and continuing notice of
nondiscrimination based on prohibited ground.
2-4
6Key Requirement 1 Provide Initial Continuing
Notice (cont.)
- Must provide initial and continuing notice of
non-discrimination based on prohibited ground
2-5
7- Read the
- Equal Opportunity Is the Law Notice
- In your Participant Guide
- Pages 2-5 to 2-6
2-6
8Key Requirement 1 Provide Initial Continuing
Notice
- Identify EO Officer and Provide Contact
Information - Provide EO Is the Law notice to all appropriate
parties - Communicate the Notice Sufficiently
9Key Requirement 1 Provide Initial Continuing
Notice (cont.)
- Identify EO Officer and Provide Contact
Information - Name
- Position title
- Business address, including e-mail address
- Telephone number, including TDD/TTY number
10Key Requirement 1 Provide Initial Continuing
Notice (cont.)
- Provide EO is the Law notice to all
appropriate parties, including - Registrants and applicants for services
- Participants
- Applicants for employment
- Employees
- Unions or professional organizations that hold
CBAs or other professional agreements with the
recipient - Subrecipients that receive WIA Title I funds from
the recipient - Members of the public, including those with
impaired vision or hearing
11Key Requirement 1 Provide Initial Continuing
Notice (cont.)
- Communicate the Notice Sufficiently
- Post the notice prominently in reasonable numbers
and places - Disseminate the notice in internal memoranda and
other written or electronic communications - Include the notice in handbook or manuals
- Give the notice to each participant and include a
signed copy in each participants file
12Key Requirement 1 Provide Initial Continuing
Notice (cont.)
- Requirements for Providing Information
- Obtain signed notices for files
- Include nondiscrimination policy in all
communications - Avoid communicating discriminatory information
- Include the required tag lines in all relevant
communications - Include the TDD/TYY telephone number or relay
service information - Conduct an orientation session
13Key Requirement 1 Provide Initial Continuing
Notice (cont.)
- Requirements for Providing Information
- Obtain signed notices for files
- Include copy of signed notice in participants
file - Where files are kept in electronic format, devise
a process to meet this requirement
14Question
- Where a recipient has an electronic process,
what procedures might the recipient adopt to
ensure that the individual receives and signs the
notice?
2-13
15Key Requirement 1 Provide Initial Continuing
Notice (cont.)
- Requirements for Providing Information
16Key Requirement 1 Provide Initial Continuing
Notice (cont.)
- Requirements for Providing Information
- Avoid communicating discriminatory information
Recipient must not issue any communication that
suggests, by its text or illustration, that the
recipient treats beneficiaries, registrants,
applicants, participants, employees, or
applicants for employment differently, based on
any prohibited ground.
17Question
- Can you give examples of types of information
that may not be communicated?
2-16
18Key Requirement 1 Provide Initial Continuing
Notice (cont.)
- Requirements for Providing Information
- Include required tag lines in all relevant
communications
19Key Requirement 2 Provide Info on Individuals
Right to File Complaint (cont.)
- Requirements for Providing Information
20Key Requirement 1 Provide Initial Continuing
Notice (cont.)
- Requirements for Providing Information
- Include required tag lines in all relevant
communications
A recipient that broadcasts program information
on the news media must recite the tag lines or
otherwise indicate that discrimination is
prohibited by federal law.
21Key Requirement 2 Provide Info on Individuals
Right to File Complaint (cont.)
- Requirements for Providing Information
- Include TDD/TYY telephone number or relay info
anytime you say that recipient may be reached by
phone
22 Term to Know Auxiliary Aids or
Services
- Qualified persons, products, equipment, or
services that effectively deliver materials to - Individuals with hearing impairments
- Individuals with visual impairments
23Key Requirement 1 Provide Initial Continuing
Notice (cont.)
- Requirements for Providing Information
- Conduct orientation session to discuss
individuals right to nondiscrimination equal
opportunity and their right to file a
discrimination complaint
24Activity Determining Proper Notice
- Purpose
- To determine whether a Notice meets the
regulatory requirements - Task
- You are members of the CRC on-site team that is
being asked to determine if a One-Stops posters
comply with the Notice and Communication
requirements. - Examine the poster in your Participant Guide. If
necessary, edit the Notice to be consistent with
the requirements. - Come to a consensus regarding changes if any are
required. - Select a spokesperson from your group to share
your findings. - Time
- 15 minutes
25Key Requirement 2 Provide Info on Individuals
Right to File Complaint
- What to Do If You Believe You Have Experienced
Discrimination - You may file a complaint with either
- Recipient
- Person whom the recipient has designated for this
purpose
26Key Requirement 2 Provide Info on Individuals
Right to File Complaint
- What the EO Is the Law Notice Communicates
- Who may file a complaint
- When a complaint may be filed
- Where to file a complaint
- Timeframes recipient has adopted to process a
complaint
27Key Requirement 3 Provide Effective Notice to
Persons with Special Needs
- Effectively communicate the EO Is the Law
Notice to persons with disabilities or special
needs
28Key Requirement 3 Provide Effective Notice to
Persons with Special Needs (cont.)
- Effectively communicate the EO Is the Law
Notice to persons with disabilities or special
needs
- Provide notices in formats appropriate to persons
with visual impairment - Provide appropriate auxiliary aid or service
where necessary - Mention the recipients TDD/TYY telephone number
or relay service whenever it is said that the
recipient can be reached by phone - Ensure that persons with disabilities and other
special needs can, if they so desire, obtain
information on the availability and location of
accessible services, activities, and facilities - Communicate, in the appropriate language, where a
significant percentage of the recipients
eligible population is made up of persons with
limited English proficiency
29Questions
- What is TDD/TTY and why is its availability
important in ensuring equal opportunity? - What measures can be taken to meet the
communication needs of persons with Limited
English Proficiency?
2-28
30Supporting DocumentationNotice and Communication
- Regulations Implementing Section 188 of the
Workforce Investment Act require that specific
documentation be available in two areas
- Notice and Communication Policy
- Notices and Communications
31Supporting DocumentationNotice and
Communication (cont.)
- Notice and Communication Policy
- Copies of communications from the state
instructing recipients on how to comply with
Notice and Communication requirements - Copies of agendas (including dates) of past and
proposed EO briefings and EO training - Copies of issuances or instructions that relate
to Section 188 or 29 CFR part 37 policy issues
such as - Sexual harassment
- Reasonable accommodation
- Accessibility
32Supporting DocumentationNotice and
Communication (cont.)
- Notices and Communications
- Copy of the posted EO Is the Law Notice
- Copy of the Notice that includes info restate and
sub-state level EO Officers, including their
name, position title, business addresses, and
telephone numbers - Copies of Orientation materials showing that EO
was discussed - Copies of checklists of the contents of
participant and employee files indicating that a
signed copy of the Notice is included - Copies of materials, such as recruitment
brochures, showing that each includes tag lines
and telephone numbers for TDD/TYY access or
telephone relay services
33States Implementation of Notice and
Communication Requirements
To be addressed by the state specialist
- Policy communications and directives to LWIAs
instructing recipients on how to comply with the
Notice and Communication requirements of 29 CFR
37 - Procedures and systems that support the
implementation of Notice and Communication - Additional MOA requirements imposed by the state
to implement the requirements of Notice and
Communication
34Methods of AdministrationMOA Element 2