1. Equal Opportunity under WIOA: Using WIOA Section 188 as your blueprint for Equal Opportunity Compliance

2. Background
2010 Civil Rights Center monitored the Missouri for Equal Opportunity Compliance
Missouri DWD was charged to revamp their nondiscrimination and equal opportunity program
Missouri faced challenges getting the workforce system on board but through positive successful events like “ Accommodations for Success” a business event held in St. Louis with over 100 employers attending a job fair for people with disabilities. We are finding more and more local boards implementing programs and events through their Local Board Disability Committee

3. Back to the Basics ETA and CRC: A difference in focus
ETA is going to follow your dollars and ensure that dollars are spent in accordance with program requirements
CRC is going to follow to ensure compliance with the nondiscrimination requirements of WIOA Section 188
ETA is going to follow your dollars and ensure that dollars are spent in accordance with program requirements. They will check the essential eligibility requirements of your programs or activities to ensure alignment with federal requirements.
CRC is going to follow the delivery (policies and procedures) of your Labor Department-funded services, training, aid, and benefits to the public to ensure compliance with the nondiscrimination requirements of WIOA Section 188

4. Your contract with the CRC
Methods of Administration(under the proposed EO regulations - Nondiscrimination Plan)
Covers the federally-required nine elements:
Element 1: State & Local EO Officer Designation
Element 2: Notice & Communication
Element 3: Plans, Contracts, & Policies (also known as “Assurances”)
Element 4: Universal Access
Element 5: Individuals with Disabilities
Element 6: Data Collection & Maintenance
Element 7: Monitoring Recipients
Element 8: Complaint Procedures
Element 9: Corrective Actions and Sanctions
Signed by your Governor, on file with the CRC, and is binding on you.
The agreement is binding between the state and the CRC.

5. GET YOUR BOARDS INVOLVED
Information, Education, and Action
NASWA Equal Opportunity Conference
Partnerships with LEAD
Climate Survey with Missouri Job Centers Staff
Climate Survey with Missouri Job Center Customers
Climate Survey with Missouri Job Center Employers
First, we ensured that we educated our Local Workforce Boards on our Methods of Administration and their obligation to nondiscrimination and equal opportunity.
Next, we invited our Local Workforce Board Directors and Local EO Officers to the NASWA EO Conference. This lead to our partnership with LEAD. Our St. Louis City WB (Michael Holmes) was able to convince other Local Boards to partner with LEAD on a pilot initiatives to conduct a climate survey with our staff, customers, and employers.

6. PILOT Partnership Initiative
Why focus on disability?
Disability cuts across race, age, gender, sexual orientation and gender identity, ethnicity, religion and socio-economic status
AND…it is the only minority group that anyone can join at any time
Promising Practices in Achieving Universal Access and Equal Opportunity: A Section 188 Disability Reference Guide
We used this guide as a blueprint for improving access and equal opportunity for our workforce system.

7. Staff Survey Results Ensure centers are accessible for everyone
Increase presence of disability navigator
Refresher training/brush-up on assistive technology
Offer programs for money management
Cross train with Vocation Rehabilitation (Voc Rehab)
Making the Reasonable Accommodation policy more visible for staff and customers
Integrate equipment for people with disabilities

8. Job Seeker Survey Results
670 Job Seekers Responded to the survey
8% Disclosed their disability
Typically 2-3% of participants disclose their disability in initial application process
Overall 94% reported staff were welcoming
6% overall said Job Centers could improve customer service
87% who disclosed a disability reported it was easy to access by car or public transportation
Of those that disclosed a disability, 5 job seekers indicated that they did not receive their accommodation

9. Employer Customer Survey Results
100 Employers Responded to the Survey:
65% of businesses had diversity policies that included disability
68% of businesses had an accommodation policy in place for job applicants and current employees
15% had Employer Resource Group (ERG) or Affinity Group specific to disability
36% of businesses engaged in targeted outreach to job seekers with disabilities, either directly or through partnership
36% of businesses had marketing materials that included or portray employees with disabilities

10. Employer Survey Results Continued
68% of the businesses have a formal or informal process to customize/modify a position to meet the needs of a current or returning employee with a disability (e.g., flexible schedule, modifying a job description, etc.)
20% of the businesses wanted Missouri Job Center Business Service Representatives to follow-up for more services

11. Missouri’s Action Items
Providing training on WIOA Section 188
Separate training for management and front line staff
Provide in 3 different webinar sessions
Reviewing Local Boards Reasonable Accommodation Policy
Revised Case Note Policy
Local Boards will create a strategic Outreach Plan
Bi-annual surveys for Job Seekers and Employers
Annual surveys for Job Center Staff
Create online resources for our business customers

12. Contact Information
Danielle Smith
Missouri
DED/Division of Workforce Development
State Equal Opportunity Officer
Phone: , Missouri Relay Services at 711
Website: