AEA 267, April 2, 2014

*Frequent Citations Look 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 Coordinator Coordinate 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 Coordinator Knowledge of Federal and State Civil Rights Laws Board Policies and Administrative Procedures Dissemination of Information (Notification) Professional Development Facilitating the Grievance Process Monitoring and Analysis of Disaggregated Data and Diversity on Advisory Committees

Knowledge of Federal and State Civil Rights Laws Title 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 Facilities Central administration/board room Offices, classrooms, and labs Gymnasium/auditorium/playing fields Restrooms/locker rooms/water fountains Computer labs/ICN rooms Cafeteria/media center Parking/access route/entrance Signage Website

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 Procedures To ensure the agency has the required board policies and grievance procedures in place Board-adopted policies on nondiscrimination in programs and employment Cover all the protected classes, including socioeconomic status Reviewed, revised or reaffirmed every five years

*Non-Discrimination Policies Program and Employment Race, Color, National Origin (Language) Gender & Marital Status Disability Religion & Creed Age (Employment Only) Sexual Orientation & Gender Identity Socioeconomic Status (Program Only)

Seven Categories for Race Hispanic/Latino American Indian or Alaska Native Asian Black or African-American Native Hawaiian or Other Pacific Islander White Two or More

Nondiscrimination Chart Guidance on requirements for protected classes for programs, employment, and bullying/harassment. Provides sample notification which must include: Nondiscrimination for all protected classes Grievance procedure for processing complaints Name, title, address and phone number of equity coordinator

Employment Board policy EEO/AA *Equal Employment Opportunity/Affirmative Action Plan EEO/AA Job descriptions Job applications and hiring process Staff evaluation

Harassment, Bullying and Hazing Person designated to investigate complaints Grievance procedure Responsibility 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 Information Non-Discrimination Policy Identity and Contact Information for Equity Coordinator Information About Grievance Procedure and Distribution of Grievance Forms Major Annual Publications, Brochures, Handbooks, Registration Handbooks, Website Public Posting and Local Newspaper Website Harassment and Bullying Notifications

Professional Development Incorporated into Everything Equity and School Improvement Multi Cultural and Gender Fair Cultural Proficiency English Language Learners Students with Disabilities Common Core Must Ensure Equity

Ensure comparable positive outcomes for all students on all achievement indicators Ensure equitable access to education services and inclusion for all students Ensure equitable treatment for all students Ensure equitable resource distribution Ensure equitable opportunities to learn for all students Ensure 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 Procedure Aligned with Non-Discrimination Policy Students, Parents, Employees and Applicants for Employment Grievance Forms Facilitated 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 Data Integration and Inclusion on the basis of Gender, Race/National Origin and Disability Attendance centers and courses Monitor 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 Reports Purpose is to examine student, employment and course data Student and course data disaggregated by gender, race, special education, 504 plan, ELL status and SES Employment data by gender and race Originate from multiple sources Available from forward Each district has a trained staff person AEA can provide training

When Isolation/Segregation Exists Counselors 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 Committees Board Policy that Promotes Inclusion Gender Balance, Racial/Ethnic Diversity & Persons with Disabilities on the SIAC Gender Balance, Racial/Ethnic Diversity & Persons with Disabilities on Career & Technical Advisory Committees Equity Advisory Committee

Purpose of the Equity Review 1. Office for Civil Rights Compliance 2. Recommendations 3. Inclusive environments 4. School Improvement

Civil Rights Monitoring Process Office 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 Criteria Course enrollment data in career and technical programs disaggregated by gender, disability and race Changing demographics Complaints or referrals Time elapsed since last equity review

Letter of Finding Equity Policy and Process Equity, School Improvement and the Educational Program Physical Education, Extra-Curricular Activities and Athletics Access, Integration and Inclusion Support Services for Special Populations Climate and Discipline Employment, Personnel, and Advisory Committees

Voluntary Compliance Plan The 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 Up Documentation 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 Rights Iowa Civil Rights Commission 400 E. 14 th St., Des Moines, Iowa Office for Civil Rights, U.S. Department of Education Citigroup Center, 500 W. Madison Street, Suite 1475, Chicago, IL Telephone: (312) Facsimile: (312)

Contact Margaret Jensen Connet Equity Consultant Iowa Department of Education Office: Cell:

Educateiowa.gov Equity Education