AEA 267, April 2, 2014

*Frequent CitationsLook for the * during this presentation. These are some of the most frequent citations of noncompliance found during accreditation/school improvement and focused equity visits!

Designation of CoordinatorCoordinate

compliance efforts for federal civil rights laws

One or more persons can be assigned

Documentation and Record Keeping

Known to staff, students and parents

Carry out responsibilities under the law

Job description and annual objectives

District employee; OCR recommends someone other than superintendent

*Role of Equity CoordinatorKnowledge of Federal and State Civil Rights

LawsBoard Policies and Administrative ProceduresDissemination of Information (Notification)Professional DevelopmentFacilitating the Grievance ProcessMonitoring and Analysis of Disaggregated

Data and Diversity on Advisory Committees

Knowledge of Federal and State Civil Rights LawsTitle IX Educational Amendments of 1972

(gender equity)Title VI – Civil Rights Act of 1964 (race and

national origin equity) Office for Civil Rights Vocational Education

Guidelines 1979 (equity in CTE programs)Title II Americans with Disabilities Act

Section 504 of the Rehabilitation Act of 1973 (disability equity)

*Accessibility of FacilitiesCentral administration/board roomOffices, classrooms, and labsGymnasium/auditorium/playing fieldsRestrooms/locker rooms/water fountainsComputer labs/ICN roomsCafeteria/media centerParking/access route/entranceSignageWebsite

Compliance is Not Conditional Based Upon Demographics

Even if no student with a physical impairment is enrolled, a recipient or public entity must be prepared to take steps to make its program or activity in existing facilities accessible as the need arises and in a timely manner.

Standards for new construction apply regardless of the number of persons with physical impairments

Board Policies and Administrative ProceduresTo ensure the agency has the required board

policies and grievance procedures in placeBoard-adopted policies on nondiscrimination

in programs and employmentCover all the protected classes, including

socioeconomic statusReviewed, revised or reaffirmed every five

years

*Non-Discrimination PoliciesProgram and EmploymentRace, Color, National Origin (Language)Gender & Marital StatusDisabilityReligion & CreedAge (Employment Only)Sexual Orientation & Gender IdentitySocioeconomic Status (Program Only)

Seven Categories for RaceHispanic/LatinoAmerican Indian or Alaska NativeAsianBlack or African-AmericanNative Hawaiian or Other Pacific IslanderWhiteTwo or More

Nondiscrimination ChartGuidance on requirements for protected

classes for programs, employment, and bullying/harassment.

Provides sample notification which must include:

Nondiscrimination for all protected classesGrievance procedure for processing

complaintsName, title, address and phone number of

equity coordinator

EmploymentBoard policy EEO/AA*Equal Employment

Opportunity/Affirmative Action Plan EEO/AA

Job descriptionsJob applications and hiring processStaff evaluation

Harassment, Bullying and HazingPerson designated to investigate

complaintsGrievance procedureResponsibility for incidents on school

site, on school vehicles, and at school sponsored events

Policy must cover employees, students, and volunteers

Report on state data base

*Dissemination of InformationNon-Discrimination PolicyIdentity and Contact Information for Equity

CoordinatorInformation About Grievance Procedure and

Distribution of Grievance FormsMajor Annual Publications, Brochures,

Handbooks, Registration Handbooks, WebsitePublic Posting and Local NewspaperWebsiteHarassment and Bullying Notifications

Professional Development

Incorporated into EverythingEquity and School ImprovementMulti Cultural and Gender FairCultural ProficiencyEnglish Language LearnersStudents with DisabilitiesCommon Core Must Ensure Equity

Common Core Must Ensure EquityEnsure comparable positive outcomes for all

students on all achievement indicatorsEnsure equitable access to education

services and inclusion for all studentsEnsure equitable treatment for all studentsEnsure equitable resource distributionEnsure equitable opportunities to learn for all

studentsEnsure equitable shared accountability

Resources Cultural Proficiency: A

Manual for School Leaders by Dr. Randall Lindsey, to assist staff in bringing more cultural awareness into classroom environment and to prepare students for living in a diverse society

Teaching with Poverty in Mind and/or Engaging Students with Poverty in Mind by Eric Jensen to learn how schools can improve the achievement and life readiness of economically disadvantaged students.

Facilitating the Grievance ProcedureAligned with Non-Discrimination PolicyStudents, Parents, Employees and Applicants

for EmploymentGrievance FormsFacilitated by Equity Coordinator

An Effective Grievance Procedure

Clearly Describes the Process for Filing a Grievance

Provides impartiality on the part of the investigator

Clearly spells out time limits on process steps

Provides written documentation from grievant, the party grieved against and the investigator

*Monitoring and Analysis of Disaggregated DataIntegration and Inclusion on the basis of Gender,

Race/National Origin and DisabilityAttendance centers and coursesMonitor integration/inclusion by reviewing

enrollment data annually (at a minimum)Provide a summary of attendance center,

program and course enrollment trends noted over the past three years and a description of how these data are collected and used, with what frequency, by whom, and for what purposes.

EdInsight Equity ReportsPurpose is to examine student, employment

and course dataStudent and course data disaggregated by

gender, race, special education, 504 plan, ELL status and SES

Employment data by gender and raceOriginate from multiple sourcesAvailable from 2009-2010 forwardEach district has a trained staff personAEA can provide training

When Isolation/Segregation ExistsCounselors and instructors of classes

where isolation exists must be notified.Counselors and instructors must review

their policies, practices, and curriculum to ensure that they are not contributing to the isolation.

Counselors and instructors must document that they are currently implementing strategies to involve students from groups that have been underrepresented.

Strategies should be documented and kept in equity file.

*Monitoring of Diversity on Advisory CommitteesBoard Policy that Promotes InclusionGender Balance, Racial/Ethnic Diversity &

Persons with Disabilities on the SIACGender Balance, Racial/Ethnic Diversity &

Persons with Disabilities on Career & Technical Advisory Committees

Equity Advisory Committee

Purpose of the Equity Review1. Office for Civil Rights Compliance2. Recommendations3. Inclusive environments4. School Improvement

Civil Rights Monitoring ProcessOffice for Civil Rights of the U.S. Department of Education requires state education agencies to develop “Methods of Administration” to reasonably assure that sub-recipients of federal financial assistance are in compliance with federal civil rights laws and to correct areas of non-compliance.

Selection CriteriaCourse enrollment data in career and technical programs disaggregated by gender, disability and race

Changing demographicsComplaints or referralsTime elapsed since last equity review

Letter of FindingEquity Policy and ProcessEquity, School Improvement and the Educational

ProgramPhysical Education, Extra-Curricular Activities and

AthleticsAccess, Integration and InclusionSupport Services for Special PopulationsClimate and DisciplineEmployment, Personnel, and Advisory Committees

Voluntary Compliance PlanThe LEA will develop a voluntary

compliance plan (VCP) addressing any non-compliance issues and send the plan to the DE within 60 calendar days of the date of the Letter of Finding

The Equity Consultant will notify the LEA if revisions to the plan are needed and will approve the final plan

Monitoring and Follow UpDocumentation of evidence of remedies will be submitted to the equity consultant

A follow up visit to monitor completion of all items, including accessibility, will occur about a year after the visit

Civil RightsIowa Civil Rights Commission400 E. 14th St., Des Moines, Iowa 50319515-281-4121

Office for Civil Rights, U.S. Department of Education Citigroup Center , 500 W. Madison Street,Suite 1475, Chicago, IL 60661-7204Telephone: (312) 730-1560 Facsimile: (312) 730-1576Email: OCR.Chicago@ed.gov

ContactMargaret Jensen ConnetEquity ConsultantIowa Department of EducationOffice: 515-281-3769Cell: 515-402-2739Email:

margaret.jensenconnet@iowa.gov

Educateiowa.govEquity Education