Civil Rights Review of CTE Programs St. Louis Community College

Civil Rights Review of CTE Programs St. Louis Community College

Welcome  Gina Benesh, Manager, Career and Technical Education programs  Linda Nissenbaum, Manager, Access Office, disAbility Support Services

St. Louis Community College  Demographics  College was established in 1962  More than 1.2 million people have attended STLCC  The college consists of 4 main campuses, the College Center, and 4 off-campus sites  Each year, more than 81,000 students enroll  College transfer and career programs  Job skill, personal development, and preparatory classes  Customized training programs

Notification

“The Letter”

 “The Missouri Department of Elementary & Secondary Education is required by an agreement with the U.S. Department of Education to conduct civil rights compliance reviews for educational institutions in Missouri that receive federal funds and that offer career and technical educational programs.”  “Your school has been selected....”  “...a process approved by the U.S. Department of Education...”

“The Letter”  “The Department, as a receipient of federal education funds, is required by the U.S. Department of Education...”  “The purpose of the review is to ensure that local schools are providing access to educational programs in compliance...with the civil rights statutes:

“The Letter”  The Civil Rights Statutes Include:  Title VI of the Civil Rights Act of 1964  Title IX of the Educational Amendments of 1972  Section 504 of the Rehabilitation Act of 1973  Vocational Education Program Guidelines for Eliminating Discrimination and Denial of Services...

Introductions Have you experienced or conducted a Civil Rights Review of CTE programs?

The Team-District  Vice-Chancellor, Academic & Student Affairs  College Attorney  Director, Enrollment Management  Director, Information Research & Planning  Manager, Career & Technical Education  Manager, Employment & Recruitment (HR)  Manager, Engineering & Design

The Team-Campuses  Vice Presidents of Academic Affairs  Vice Presidents of Student Affairs  Department Chair, Counseling  Access Office Managers

Explanation of Requirements I. Administrative II. Recruitment III. Admissions IV. Student Financial Assistance V. Counseling& Prevocational Programs VI. Students w/Disabilities VII. Accessibility VIII. Comparable Facilities IX. Work Study/Job Placement X. Employment XI. Site Selection Student Eligibility Criteria

I.Administrative  Notify of nondiscrimination and harassment policies.  Notify of bias-free accessibility to vocational programs.  Designate an employee(s) to coordinate efforts to comply with Section 504, Title II, and Title IX.  Adopt and publish a grievance procedure to provide for prompt resolution of discrimination complaints.  Title VI, Title IX, and Section 504 signed statement of assurance.

II.Recruitment Recruitment activities must:  Include all potential students regardless of sex, race, color, national origin, or disability. Be bias-free.  Be provided by a diverse team, representing components of the community (if applicable).  Be accessible by members of English-limited populations and persons with sensory impairments.

III.Admissions Recipients must:  Admit without regard to sex, race, color, national origin, language ability, or disability.  Avoid preadmission inquiries about marital, parental, or disability status.  Have policies in place for serving limited- English proficient students.  Use admission tests that do not measure disabilities (postsecondary).

IV.Financial Aid Recipients must:  Make financial aid available to all students regardless of sex, race, color, national origin, or disability.  Award sex-restricted aid only when established by legal instrument.  Provide bias-free information.  Provide information in a variety of languages and formats.

V.Counseling & Prevocational Programs Recipients must:  Provide counseling materials that are nondiscriminatory.  Provide counseling services based on sex, race, color, national origin, or disability.  Avoid directing disabled students toward more restrictive career objectives.  Assure that disproportional enrollments do not result from discrimination.

VI.Students w/Disabilities Recipients must:  Provide access and benefits to all courses, programs, services, or activities for students w/disabilities.  Provide related aids or adaptations.  Measure academic achievement and ability rather than disability.  Provide postsecondary housing without regard to sex, race, color, national origin, or disability

VII.Accessibility Standards for:  Existing facilities initiated before 6/4/77  Programs and facilities are readily available to people with disabilities.  New construction initiated between 6/4/77 and 1/17/91  Each facility is readily accessible and usable by people with disabilities.  New construction initiated after 1/18/91  Each facility is readily accessible and usable by people with disabilities.  New construction initiated after 1/27/92  Each facility is readily accessible and usable by people with disabilities.

VIII.Comparable Facilities Recipient must:  Provide facilities for males, females, and/or students with disabilities that are comparable to one another.

IX.Work Study, Coop, Job Placement, Practicums Recipient must:  Provide opportunities in the above programs for all students regardless of sex, race, color, national origin, or disability.  Assure that prospective employers do not discriminate.  Assure that partners in apprenticeship training do not discriminate.  Secure written agreements that assure nondiscrimination.

X.Employment Recipient must:  Prevent discrimination in employment practices on the basis of sex, race, color, national origin, or disability.  Prevent segregation, exclusion, or other discrimination against students through its employment practices.  Assure that pre-employment inquiries regarding disability, marital, or parental status is not made.  Notify all faculty of nondiscrimination policies.  Arrange salary schedules to reflect conditions and responsibilities of employment.  Provide reasonable accommodations to qualified candidates.

XI.Site Selection and Student Eligibility Criteria Recipient must:  Maintain eligibility criteria that is nondiscriminatory.  Locate sites that are accessible to all populations and not label sites as intended for minority students.  May not alter physical plans of facilities that would segregate on the basis of sex, race, color, national origin, or disability.  Create geographic boundaries that do not exclude students based on race, color, or national origin.

On Site Review- Persons to Be Interviewed  Chief School Administrator  Dean of Career Education  Career Education Administrator  Career Education Teachers (2)  Title IX and/or 504 Coordinator(s)  Counselor/Placement Director  Special Education Director  Career Education Students (3-5)

Documentation – Standard I  Document(s) which designate the Title IX and Section 504 Coordinator(s) that includes name (or position), business address, and phone number   Job description for Title IX and Section 504 Coordinator(s) including duties and responsibilities of the position(s)  Copy of notification for faculty, staff, students, and the public re: name (or position), business address, and phone number of the Title IX and Section 504 Coordinator(s) Student Handbook  Employee Handbook

Documentation – Standard I- Interview Questions  Chief Administrator:  How were the Title IX and Section 504 positions designated?  How do you inform the public of the names of these coordinators?  Counselor/Placement Director/Vocational Teacher/Student:  Who would you contact in the event you believed that you had experienced discrimination?

Documentation – Standard II  A copy of the signed Title VI, Title IX, Section 504 or a combined assurance document  A copy of the governing body minutes authorizing the assurances

Documentation – Standard III  Copy of the policy of nondiscrimination which contains grievance procedures  ures.html ures.html  Copy of nondiscrimination policy dissemination plan  Copy of annual notice to faculty, staff, and students  Staff-Manual.pdf Staff-Manual.pdf 

Documentation – Standard IV  Copy of board-approved harassment policy  d_Policy.pdf d_Policy.pdf  Plan for dissemination of policy to students, staff, and the public  Documentation of notice  ies_and_Procedures/Student_Rights_and_Resp onsibilities.html ies_and_Procedures/Student_Rights_and_Resp onsibilities.html

Standard III & IV Interview Questions  Chief Administrator:  Who is designated to handle claims of harassment or discrimination?  How do you notify staff, students, and the public regarding the policies and grievance procedures?  Counselor/Placement Director/Vocational Teacher/Student:  Where are the district’s harassment and non- discrimination policies located?  How and when are you informed of these policies?  How would you file a grievance?

Documentation – Standard V  Career Education enrollment demographics (form provided)  Written selection criteria for textbooks and other materials  Copy of promotional activities and materials  Copy of ESOL policy  Copy of vocational recruitment, selection and admission procedures

Standard V Interview Questions:  Chief Administrator:  How does the district ensure equal access to vocational programs for all students?  What are district policies regarding students with disabilities and LEP students?  Counselor/Placement Director/Vocational Teacher/Student:  What materials do you use for recruiting students into vocational programs  How do you ensure that selection and recruitment are nondiscriminatory?

Standard V Interview Questions:  Vocational Teacher:  How do you recruit nontraditional, minorities, and students with disabilities?  Student:  How is your gender/race represented in informational materials?

Documentation – Standard VI  Copy of written agreements with organized labor entities that provide apprenticeship programs  Copy of training agreements with employers  Copy of placement procedures that ensure nondiscrimination  Copy of nondiscrimination policy given to employers

Standard VI Interview Questions  Chief Administrator:  How does the district work with business and labor to assure equitable environments for work based activities?

Documentation – Standard VII  Copy of certified and non-certified job applications  Copy of job descriptions for all positions  AllItems.aspx?RootFolder=%2fdocs%2fDocume nts%2fDocument%20Archive%2fHuman%20Res ources%2fJob%20Descriptions&FolderCTID=0x EB958828A9CF33489B078EB3FBDF5D0D AllItems.aspx?RootFolder=%2fdocs%2fDocume nts%2fDocument%20Archive%2fHuman%20Res ources%2fJob%20Descriptions&FolderCTID=0x EB958828A9CF33489B078EB3FBDF5D0D

Standard VII Interview Questions  Chief Administrator:  What safeguards have been instituted to ensure that the district does not discriminate in employment practices?  Vocational Teacher:  How does the district ensure that its employment practices are nondiscriminatory?

Documentation – Standard VIII  Copy of the plan for the delivery of guidance services  nd_Employment_Services/Student_Services.html nd_Employment_Services/Student_Services.html  Copy of the district/institution assessment plan  /Assessment/Missions-Based_Assessment.html /Assessment/Missions-Based_Assessment.html  Copy of the procedures for the development of IEP’s for the students with disabilities  _st_louis_cc.pdf _st_louis_cc.pdf

Standard VIII Interview Questions  Counselor/Placement Director:  How do you ensure that your guidance services are nondiscriminatory?  Student:  What kind of career information have you received?  Tell me what a nontraditional occupation is?

Documentation – Standard IX  Copy of the ADA self-study  Copy of the ADA transition plan  Notice of activities and facilities accessibility  ability_checklist_for_events.pdf ability_checklist_for_events.pdf 

Standard IX Interview Questions  Chief Administrator:  How do you make the public aware of accessible facilities? How often?

Days of Review The Review Team  Manager, CTE  Manager, Access Office (Former ADA Coordinator)  Manager, Engineering & Design The DESE Review Team  Director of Civil Rights Compliance  Coordinator of Career Education

Days of Review Meeting with District Administration and Staff  Vice Presidents of Academic Affairs  Vice Presidents of Student Affairs  Director of Enrollment Management  Director, Information Research & Planning  Deans  Manager of Employment and Recruiting  Manager of Employment & Recruitment  Manager, Engineering & Design  Managers, Access Offices

Days of Review Meeting with Administration Leadership Team & Select Members  Chancellor  Vice Chancellor of Academic & Student Affairs  President of Wildwood Campus  College Attorney  Manager of Employment & Recruitment

Campus Review  Campus-wide Meeting  Faculty Interviews (19 faculty-total)  Student Interviews (19 students-total)  Campus Tour  CTE Classrooms  Restrooms  Gym/Pool Areas  Access Offices  Accessibility

Findings  STLCC Recognized for :  Continuous Nondiscrimination Notice  Identifying persons responsible for coordinating Title IX & Sec. 504 and including contact information  Adopting & publishing grievance procedure  Nondiscrimination in eligibility/admissions criteria, counseling materials &activities, work study, cooperative education, and job placement.

Findings  STLCC Recognized for :  Access to Programs, Activities, and Services includes accessible sites, classrooms, restrooms, adaptive equipment, provision of accommodation, auxiliary aids, and services.  Recruitment materials that are not limiting, available to all potential students, and avoid stereotyping  Providing comparable facilities for students with disabilities, males, and females

Findings  STLCC Recognized for :  Recruitment materials & personnel represent persons of varying races, male & female, disabilities, and national origins.  Non-limitation of participation in programs due to potential workplace discrimination  Admissions tests allow for accommodations so that students can accurately reflect their ability(s) and not their disability(s)

Findings  STLCC Recognized for :  Financial assistance, work study, coop, and job placement is available regardless of sex, race, color, national origin, or disability  Nondiscrimination in employment practices and opportunities.

Findings  STLCC Needs to:  Make materials available in the language of national origin minority communities in the service area for students and parents with limited English Skills available. This includes:  Notice of nondiscrimination  Counseling materials  Recruitment materials  Financial aid information

Our Learning  Language-----  Continue to build compliance into every program, policy, procedure, and facility  Revised ADA Form-CurricUNET  Continue to offer training for faculty and staff on compliance and awareness  Continue to include notification of compliance in publications and website

Questions?