November 4, 2015 The Role of the Equity Coordinator in Schools Kathy Enslin, AEA 267

Date There are Six Responsibilities of the Equity Coordinator: 1. Knowledge of federal and state civil rights law 2. Equity policies and procedures required by law 3. Dissemination of information to staff, students and community 4. Professional development on rights and responsibilities 5. Civil rights grievance process which is prompt and effective; 6. Monitoring of disaggregated data

Date Knowledge of Federal and State Civil Rights Laws: Develop and maintain a working knowledge of Title IX (gender equity), Section 504 Americans withDisabilities Act (disability equity), Title VI of the Civil Rights Act (race/national origin equity) and relevant state laws.

Date Policies and Procedures: To ensure that the agency has the required board policies and grievance procedures in place.

Date Dissemination of Information: To ensure that information about the nondiscrimination policies, harassment/bullying/hazing policies, the name and contact information for the equity coordinator(s)NOT THE SUPERINTENDENT, and information about the related grievance procedure is disseminated annually to board members, administrators and all employees, students, parents, and applicants for employment. This information must be included in all major annual publications and the district’s website.

Date Professional Development: To arrange for the training of staff and students that will make them aware of their rights under the legislation as well as assist them to carry out their responsibilities under the law.

Date Facilitate the Grievance Process: To mediate conflicts and to ensure prompt and effective processing of complaints through the facilitation of the agency’s board adopted civil rights grievance procedure.

Date Monitoring: To monitor the agency’s compliance with the legislation by reviewing and disseminating disaggregated student achievement data, building and course enrollment data, student activity data, and employment and personnel data. Membership on district advisory committees should be monitored for gender balance, the inclusion of individuals representing diverse racial/ethnic groups, as well as persons with disabilities.

The Iowa Educational Equity Review Process: Information for Educational Agencies ✤ It is the policy of ____________________ not to discriminate on the basis of ✤ race, creed,color, sex, sexual orientation, gender identity, national origin, disability, religion, age, political party affiliation, or actual or potential parental, family or marital status ✤ in its programs, activities, or employment practices as required by the Iowa Code sections and (2), Titles VI and VII of the Civil Rights Act of 1964 (42 U.S.C. § 2000d and 2000e), the Equal Pay Act of 1973 (29U.S.C. § 206, et seq.), Title IX (Educational Amendments, 20 U.S.C.§§ 1681 – 1688), ✤ Section 504 (Rehabilitation Act of 1973, 29 U.S.C. § 794), and the Americans with Disabilities Act (42 U.S.C. § 12101, et seq.).

Summary of New Equity Guidance August, 2015 The Iowa Department of Education (IDOE) and the Iowa Association of School Boards (IASB) are issuing new guidance on three policies and related procedures related to educational equity based on guidance provided by the Office for Civil Rights (OCR), U.S. Department of Education. Because of the timing of the release of this new guidance, districts will have up to one year to implement the changes to current policies and procedures. By September 1, 2016 districts will be accountable for implementing new policies and procedures that align with this guidance.

Prior Guidance NEW for Annual and Continuous Notice of Nondiscrimination. Prior to August, 2015, the guidance for the publication of the annual and continuous notice of nondiscrimination indicated a district could use the same terminology for both notices. Annual and Continuous Notice of Nondiscrimination. Beginning September 1, 2015, the new guidance for the publication of the annual and continuous notice of nondiscrimination indicates there are two different notice requirements: 1. The annual notice of nondiscrimination must be published prior to the beginning of each school year; 2.must include all of the protected classes; the name, title, address, telephone number and address of person(s) designated to coordinate Title IX and Section 504 compliance; 3.must include the district’s grievance procedure; and 4.must include a brief summary of the recipient’s program offerings and admissions criteria for career and technical education programs.

Prior Guidance Continued New For Prior to August, 2015, the guidance for the publication of the annual and continuous notice of nondiscrimination indicated a district could use the same terminology for both notices. 2. The continuous notice of nondiscrimination must include all of the protected classes; ✤ the name, title, address, telephone number and address of person(s) designated to coordinate Title IX and Section 504 compliance; ✤ the district’s grievance procedure. ✤ Continuous notice requirements is met by prominently publishing the non-discrimination notice on an on-going basis in all major district publications.

Prior Guidance New for Civil Rights Grievance Procedure. Prior to August, 2015, the IASB sample policy and related procedures described a four-step process for filing a grievance related to discrimination. Beginning September 1, 2015, the new IASB sample policy and related procedures include steps required by OCR. The new procedures have been simplified and align more closely with related bullying and harassment complaint procedures. (Related IASB Sample Policies: 102 Series) Anti-Bullying and Harassment Policy and Procedures. Prior to August, 2015, the IASB sample policy for procedures to report complaints related to bullying and harassment included a first step for the complainant to “Communicate to the harasser that the individual expects the behavior to stop, if the individual is comfortable doing so.” Anti-Bullying and Harassment Policy and Procedures. Beginning September 1, 2015, the new IASB sample policy and related procedures will remove this first step based on guidance from OCR and research in best practice. The complaint procedure aligns more closely with related grievance procedures in the case of discriminatory harassment. (Related IASB Sample Policies: 104 Series)

Educational Equity Review Process ✤ 1. Selection Criteria ✤ There are several criteria used to determine who will have an equity review each year. The universe from which school districts are selected for equity reviews includes all the school districts with secondary career and technical education programs. Districts will be considered for selection for a focused equity visit if six or more years have passed since their last focused equity visit. The criteria used to select districts from that universe include: ✤ (1) A review of course and program enrollment data in career and technical programs disaggregated on the basis of gender, disability and racial/ethnic background; ✤ (2) Changing demographics within the boundaries of an educational agency; ✤ (3) Complaints received from parents, students, staff, applicants for employment or community representatives and referrals from Department of Education staff or other state or regional agencies; and ✤ (4) The time elapsed since the district’s last equity review.

2. Notification of On-site Review ✤ The notification of the Equity Visit usually occurs in May. During the month of May, each agency selected to receive an on-site review during the following school year will be notified by letter as to the date of the review, and the identity of the review team leader.

3. Orientation ✤ In September of each year there will be orientation sessions presented for educational agencies having school improvement visits with a focus on equity. Participants will receive: ✤  Materials to be reviewed ✤  Persons to be interviewed ✤  Sample Equity Site Visit Schedule ✤  Equity Review On-Site Manual ✤  Equity Data Table

4. Duration of Site Visits ✤ The on-site reviews may be days in length. This will vary with the size of the agency being reviewed.

5. Members of the Review Team ✤ The equity on-site review team will have 6-9 members. The number of team members will vary with the size of the educational agency being reviewed.

6. Specific Materials Reviewed by Team Members ✤ Refer to Equity Document Review Checklist for documents needed and submission methods. Timeline for submission is no later than two weeks prior to the beginning of the visit.

7. Persons to be Interviewed ✤ See Department of Education website for the List of Required On-Site Interview Groups document.

8. Building Accessibility Tour ✤ A review of facilities will be conducted during the accessibility portion of the Equity Site Visit. This will be the time for the district’s Director of Buildings and Grounds or designee to provide a tour of school facilities. The Department of Education will be reviewing the district’s responsibility for completing periodic self-evaluations of the accessibility of programs and facilities to students, staff, parents and community members with disabilities. The DE will review the district’s accessibility plan that describes how the programs and services in buildings or areas of buildings that are inaccessible are made available to students, staff, parents, and community members with disabilities. Your facility review will be focused on the high school and the central administration building. The facility review will be scheduled during or near to the time of the equity site visit and arrangements will be made with the district by DE staff to schedule the review.

Consequences of Continued Non- Compliance ✤ In the event a district does not submit a voluntary compliance plan, or does not show good faith effort to complete its voluntary compliance plan, the State Director, on behalf of the State Board, will take one of following actions: ✤ Notify the United States Department of Education Office for Civil Rights (federal law) ✤ Notify the Iowa Civil Rights Commission or the Attorney General’s Office (state law except Chapter 256) ✤ Inform the school accreditation process

Equity Coordinator Responsibilities Checklist

Knowledge of Federal Civil Rights Laws Read and maintain a working knowledge of Title IX, Section 504 and Americans with Disabilities Act, Title VI of the Civil Rights Act, and Office for Civil Rights (OCR) Guidelines for Eliminating Discrimination in Career and Technical Education found on Equity Education website. Read OCR Dear Colleague Letters found on Equity Education website: 12/accreditation programapproval/equity education. Analyze and remedy barriers to accessibility of facilities for persons with disabilities.

2. Policies and Procedures Review Nondiscrimination and Grievance Policies: Programs and Employment. 3. Dissemination of Information Annual Notice of Nondiscrimination must include all protected classes, notice of grievance procedure and name and contact information for equity coordinator (refer to Protected Classes Chart on Equity Education webpage)

Continuous Notice of Nondiscrimination consistent in all major written publications, including district website (refer to Protected Classes Chart on Equity Education webpage). Notice posted to website on home page or within one click on an obvious link. Notice provided to community of national origin persons with limited English language skills in their language. Review grievance procedure, update grievance forms and make them available on website, offices, buildings. Review Bullying and Harassment policy for alignment with protected classes and required components

Information about the non- discrimination policies, harassment/bullying/hazing policies, the name and contact information for the equity coordinator(s), and the related grievance procedure is disseminated annually to: board members administrators all employees studentsparents applicants for employment. Consider making annual equity reports with recommendations to the School Improvement Advisory committee (SIAC) and the school board.

Professional Development Training of staff that will make them aware of their rights under the legislation as well as assist them to carry out their responsibilities under the law. Training of students that will make them aware of their rights under the legislation as well as assist them to carry out their responsibilities under the law. Conduct periodic conversations with students and staff on ways the district might respect, reflect and celebrate all facets of diversity.

Professional Development Provided to Staff: Multicultural and Gender Fair Practices Cultural Proficiency English Language Learners Students with Disabilities, including Section 504

Facilitate the Grievance Process Mediate conflicts and ensure prompt and effective processing of complaints through the facilitation of the agency’s board adopted civil rights grievance procedure. Training received by equity coordinator(s) on grievance procedures, role in the complaint process and how records are kept (including sexual harassment).

Monitoring: Review school registration handbooks, course descriptions, program brochures, and course announcements. they do not promote stereotypes or restrictions based on race, color, national origin, sex, disability or other protected groups  Review supports available for English Language Learners and students with disabilities in courses  Review counseling program and identify steps taken to ensure that disproportionate course enrollment does not result from unlawful discrimination in counseling activities  Review counseling program to ensure access for English Language Learners and students with hearing impairments Review course promotional materials and activities to ensure they do not promote stereotypes or restrictions based on race, color, national origin, sex, disability or other protected groups.  Review supports available for English Language Learners and students with disabilities in courses  Review counseling program and identify steps taken to ensure that disproportionate course enrollment does not result from unlawful discrimination in counseling activities  Review counseling program to ensure access for English Language Learners and students with hearing impairments Review supports available for English Language Learners and students with disabilities in courses.  Review counseling program and identify steps taken to ensure that disproportionate course enrollment does not result from unlawful discrimination in counseling activities  Review counseling program to ensure access for English Language Learners and students with hearing impairments Review counseling program and identify steps taken to ensure that disproportionate course enrollment does not result from unlawful discrimination in counseling activities  Review counseling program to ensure access for English Language Learners and students with hearing impairments

Review counseling program to ensure access for English Language Learners and students with hearing impairments. Summary of annual review of course enrollment data disaggregated by subgroup. Description of how these data are collected and used, frequency, by whom, for what purpose. Evidence that counselors, educators and administrators are taking on-going steps to recruit students who have been over or underrepresented

Equity Contact information: Margaret Jensen-Connet Consultant for Equity in School Improvement Division of Learning and Results Iowa Department of Education Grimes State Office Building Des Moines, Iowa Phone (515) Mobile: (515) Kathy Enslin Assistant Chief/HR Director AEA Cedar Heights Drive Cedar Falls, IA Phone (319) Mobile (319)