Civil R​​ights​​ On-Site Reviews, Instructions, and Documentation

Complia​​nce Review Procedures

This document is intended to provide guidance to those local education agencies (LEA) that have been selected to receive a civil rights compliance review as they gather their compliance plan documentation. Procedural instructions are provided, as well as descriptions of the types of documentation that LEAs should provide for the review.

1. Complete all applicable forms, including the lengthy compliance plan, emailed to you by Cynthia Gross, PDE's civil rights on-site reviewer. Electronically return the completed compliance plan to Cynthia Gross at cygross@pa.gov at least 10 working days prior to the review. This will allow time for the responses to be reviewed by Pennsylvania Department of Education (PDE) prior to the visit. If there are questions, the responses will be highlighted and returned to the subrecipient electronically. The areas in question will be discussed further during the review. Please do not send any physical documents.
2. Collect documentation to substantiate compliance. Documentation should be compiled into electronic folders following the order of the compliance plan document.
   1. Label each document and place it in the appropriate folder to correspond with each assurance in the compliance plan (e.g., A.1.a.). It is permissible to cross-reference when two or more questions may be substantiated by the same documentation, by referring the reviewer to the previous document(s).
      
   2. In each folder, insert the appropriate documentation to substantiate a response to each question. If a large notebook or other publication contains only a few pages that demonstrate compliance, copy only the applicable pages for documentation. For website references, provide links to the evidence or screenshots.
      
3. The above-mentioned folders, the original copy of the compliance plan and any other applicable forms should all be made available to PDE upon arrival at the institution. Wireless internet access should be provided for the reviewer's use.
   
4. Reserve a workroom which is easily accessible to students and staff for the reviewer to use to verify documentation, compile findings and conduct the required interviews.

Section A: Administration

Note: Numbering below may not be sequential. Item numbers refer to like-numbered items in the compliance plan document that may need additional clarification.

• #1-Review the annual and continuous notices of nondiscrimination per the guidelines on the PDE website. The annual notice identifies the cluster of career and technical education programs offered. It is published in newspaper(s) once a year prior to the start of school or can be posted on the school's website.
• #2-The continuous notice does not identify program clusters but may reference the Boy Scouts and other youth groups. It is a separate notice from the annual notice. Provide a copy of the home page of your website, student handbook(s), information sent to parents, course description books, student newspapers, catalogs, application forms, collective bargaining agreement(s) and other written and/or audiovisual materials which include a policy of nondiscrimination.
• #3-Indicate how individuals with sensory impairments receive information regarding career and technical education opportunities. These may be documents for parents/guardians and/or students. If there is a family with limited English language skills, provide a copy of the materials, applicable notifications and a list of services.
• #4- Provide a copy of board minutes or other documentation, which substantiates that the coordinator(s) for civil rights activities have been officially appointed.
• #5-Provide a copy of a grievance procedure related to Title VI of the Civil Rights Act of 1964; Title IX of the Education Amendments of 1972; Section 504 of the Rehabilitation Act of 1973 and Title II Americans with Disabilities Act. If there are different civil rights grievance procedures for students and for employees, provide both.
• #9- Provide copies of job announcements or other correspondence regarding job vacancies sent to the media, individuals, and other recruitment sources within the past 24 months. Ensure that “Equal Opportunity Employer" appears at the bottom of newspaper advertisements.
• #11- Identify the procedures established for accommodating disabled employees. If accommodations have been made in the past five years, provide a brief explanation.
• #12-Provide copies of tests, structured interview questions and procedures used for screening applicants. If interviews result in scoring applicants, describe how scores are applied and/or ranked.
• #14- Provide copies of employment applications and employee contracts for each classification and an explanation of the interviewing process.
• #15-Provide the date of construction of all buildings, dates of alterations and applicable construction standards. Identify actions taken to remove physical barriers.

Section B: Counseling/Advisement

• #1-Provide a copy of course description handbooks, catalogs, occupational information brochures and a list of tests and other resources, which are used in career education courses or career presentations.
• #2-Provide a list of agencies, if any, or personnel who provide interpreting services as needs arise.
• #4-Provide documentation which identifies and analyzes practices that may contribute to disproportionate enrollments by race and sex. If voluntary remedial action was taken, describe the action and timeframe.
• #6-Provide a list or a copy of each announcement of loans, grants, scholarships, prizes, etc., made available to students. If there are national origin minority persons with limited English language skills, provide copies of translated announcements or an explanation of how announcements are translated. Also address how the information is provided to visually-impaired students.

Section C: Access and Admissi​on to Career and Technical Education Programs

• #1-Provide the admission policy, including the eligibility criteria and/or selection procedures, used to determine entrance into a career and technical education program.
• #2-Provide the admission application for secondary and/or adult career and technical education programs.
• #3-Numerical limitations relative to admission will be reviewed on-site through interviews with appropriate personnel. Indicate if these are published and when applicable.

Section D: Equal Oppo​​rtunity

• #1-Provide a list of supplementary aids provided by the career and technical center or home school.
• #2-Indicate if facilities/accommodations are comparable for both genders.
• Postsecondary institutions must also respond to the items below.
• #3-Provide a list of academic adjustments provided by the institution, the Pennsylvania Office of Vocational Rehabilitation or other sources.
• #7-Indicate the availability of student housing and handicapped accessibility.