WIOA State Plan Common Elements

Indiana’s WIOA State-level Equal Opportunity (EO) Officer, appointed by the Governor, works within DWD’s Compliance and Policy Division with 100%-time commitment to equal opportunity and nondiscrimination in workforce programs. One of the primary duties of the State EO Officer is to develop and implement the federally mandated Nondiscrimination Plan (NDP). The NDP is a statewide plan for ensuring equal opportunity and nondiscrimination in the availability, access, and service delivery of WIOA Title I funded programs and services. The NDP must be updated and resubmitted to the U.S. Department of Labor Civil Rights Center (CRC) every two years, with Indiana’s latest submission in September 2022. Indiana’s NDP provides detail on physical and programmatic accessibility and can be found at: https://www.in.gov/dwd/files/State_of_Indiana_Nondiscrimination_Plan_2020.pdf. The next NDP updates are due to the U.S. Department of Labor CRC in September 2024.  

Annually, the State EO Officer conducts subrecipient monitoring and data analysis regarding race, disability status, age, ethnicity, gender, and limited English proficiency. The data analysis compares participants to population data to evaluate potential under-service of a group. This process has promoted discussions between DWD and the LWDAs on how to increase services and outreach to under-served populations, including individuals with disabilities. As a result, new partnerships are targeted for the LWDAs to connect wrap around services. Further, the data analysis process has assisted the LWDAs in evaluating internal processes that may be prohibiting certain groups, such as those with disabilities, from participating in programs provided at the WorkOne Centers. 

The State EO Officer ensures Indiana’s LWDAs, sub-recipients, and workforce system partners are aware of, and in compliance with, the NDP and all section 188 responsibilities. Similarly, each LWDA has designated a LWDA EO Officer (Local EO Officer) to carry out these duties at the local level. All Local EO Officers also functionally report to the DWD State EO Officer on matters pertaining to Section 188.  

Together, the State and Local EO Officers implement the NDP and continually review policies and practices. DWD Policy 2016-09, Equal Opportunity and Nondiscrimination Guidance Letter (see https://www.in.gov/dwd/files/activepolicies/2016-09-P_EO_Nondiscrimination_Guidance.pdf) outlines the major provisions of section 188 and 29 CFR 38. The agency has designed several training modules for Local EO Officers and staff, which can be found at https://www.in.gov/dwd/compliance-policy/equal-opportunity/training-resources/. Training modules relevant to physical and programmatic accessibility include, for example, the EO 101 and Compliance with Disability Nondiscrimination Requirements modules. In addition, training and resources are provided through Workforce GPS, an online technical assistance website sponsored by the Employment and Training Administration of the U.S. Department of Labor. Resources and training on disability, employment, accessible technology, and inclusion provide workforce development professionals (i.e., front-line staff) information and training on serving people with disabilities.  

In August 2023, the Indiana Family and Social Services Administration (FSSA) Division of Disability and Rehabilitative Services (DDRS) and DWD, along with several other agencies, participated in the first Indiana Employment First Cross-Council Summitt. DDRS is currently undertaking a significant employment systems transformation effort with the goal of increasing competitive employment outcomes for Hoosiers with disabilities served by the division from 22% in 2022 to 37% in 2027. This represents a 60% increase in competitive integrated employment outcomes over the 5-year period. The goal also supports Indiana’s First policy, passed in 2017, which in part mandated State agencies collaborate to support employment as the first and preferred outcome for individuals with disabilities. The goal will require collaboration and coordination between relevant State agencies, community rehabilitation providers, key advocacy groups, the business community, self-advocates, and families. 

In late 2022 and continuing throughout 2023, DDRS’s Vocational Rehabilitation Services (VRS) hired VRS Navigators. These Navigators serve as a liaison between WorkOne centers (i.e., American Job Centers), VRS staff, and shared customers to deliver employment and training services. Through referral processes between the two agencies and connecting customers with partner agency services, customers will have the resources available to assist and build their pathway to entering the labor force. Early in 2024, VRS and DWD will evaluate the VRS and DWD field offices’ continuation of training services to determine and share best practices of the DWD regions that have VRS navigator staff.  

Also in 2022, DWD acquired a Learning Management System (LMS) to support cross agency training with VRS. DWD and VRS, in partnership with U.S. Department of Labor, developed a training program to cross-train staff within the WorkOne centers and VRS field offices to better coordinate and deliver services to joint customers. There were two training courses developed and successfully rolled out to staff:  

• Workforce Collaboration and Integration: Co-enrollment and Joint Case Management. 

• Workforce Collaboration and Integration: Indiana’s Workforce System and WIOA Program Partners.  

Programmatic Accessibility: Cross-training sessions have also occurred between DWD and VR covering topics such as disability etiquette, Order of Selection, and service coordination. Accessibility workstations are in place in WorkOne offices throughout the State. Title II pays for one-on-one interpreters for visual and hard of hearing individuals attending adult education programming. Testing accommodations are available for assessments as well. 

The Equal Opportunity tagline is included on all external marketing and communication materials to allow people who are deaf and hard of hearing to make calls to each other, and with the assistance of the relay systems, users can communicate with people who do not have TTY systems. DWD and partner staff are knowledgeable on more advanced systems such as Video Relay Services and Video Remote Interpreting. The following sample tagline is below, and when necessary is translated into other languages: 

The WorkOne System is an equal opportunity employer and does not discriminate in the programs and services offered. Auxiliary aids and services are available upon request to individuals with disabilities. The TDD/TTY number is 1-800-743-3333. 

El Programa de Financiamiento asistido de acuerdo con el Titulo 1 de WIOA es un programa de Igualidad de Oportunidades de Empleo. Ayuda y servicios auxiliares están disponibles a solicitud para personas con discapacidad. El numero de TDD/TTY es 1-800-743-3333. 

Additionally, DWD will continue to enhance the Jobseekers with Disabilities website (https://www.in.gov/dwd/job-seekers/job-seekers-with-disabilities/) to include resources for both jobseekers and employers. DWD intends to issue technical guidance to facilitate the creation of accessible. This guidance explains the importance of meeting the standards set in the American with Disability Act, Section 508 of the Rehabilitation Act of 1973, the Web Content Accessibility Guidelines, and WIOA Section 188. The guidance encourages DWD employees and partners to use alternative text, check the accessibility of their fonts and colors, as well as implement Adobe and Microsoft’s built-in accessibility checkers. Adhering to the best practices listed in the technical assistance as well as continuing to research new strategies for creating accessible documents will help ensure that all agency generated documents are accessible to every user, regardless of background. The DWD Communications team regularly updates content to be more accessible on the website and works to ensure that State staff are creating content that is more accessible. The team reviews older content for any accessibility updates. This includes educating and providing training on document accessibility on an as needed basis. for LWDA staff.  

Within the WorkOne centers, staff have been, and will be further, trained to follow established procedures to ensure inclusion and compliance. Starting with intake, staff are trained to ask every customer if accommodations are needed. Customer and WorkOne office staff orientations include a discussion of Equal Opportunity (EO) and the right to file a complaint. Following orientation, services should be reviewed with the customer by determining the client’s eligibility and need for services in an integrated setting. Ongoing training will need to occur to educate staff on the services, funding, and the resources available to determine when it is appropriate to refer to partner agencies and co-enroll individuals in multiple programs, such as Vocational Rehabilitation, to access a greater service array to meet the individual’s needs. Agency partners will seek to coordinate efforts and leverage funding between partner agencies to meet the employment and training needs of the customer. 

Staff will also be trained to use multiple resources and tools to ensure accessibility to services. One such resource is the Guidepost for Success, which is a set of key educational and intervention strategies for youth, including those with disabilities, developed by the Center for Advancing Policy on Employment (CAPE) for Youth. Additionally, one-stop assessments, Individual Education Program (IEPs), and Academic and Career Planning (ACPs) tools will continue to be utilized to identify career paths, barriers to employment, training or service needs, and employability skills. These assessments will also assist with identifying hidden disabilities and the potential need for accommodations. 

All Comprehensive and Affiliate WorkOne offices undergo One-Stop Center Certifications every three years, with the next certification cycle due to be completed in the Spring of 2024. Certifications are conducted in accordance with DWD’s One-Stop American Job Center Certification policy, which can be found on DWD’s policy website at https://www.in.gov/dwd/compliance-policy/policy/active/. Local EO Officers conduct accessibility compliance reviews of WorkOne operations and offices, including programmatic accessibility. Further, programmatic accessibility is evaluated on an annual basis by the State EO Officer and DWD’s Compliance Team during routine WIOA monitoring.  

Physical Accessibility: The One-Stop Center Certification process also includes evaluation of physical accessibility. Local EO Officers conduct accessibility compliance surveys of WorkOne offices checking the accessibility of various areas, such as parking, accessible routes, ramps, entrances and doors, signage, and restrooms. Accessibility compliance surveys are also conducted upon new office openings/moves and physical accessibility is a regular component of annual monitoring by the State EO Officer and DWD’s Compliance staff. 

WorkOne offices have some features to increase accessibility and availability of resources. WorkOnes have accessibility workstations with ergonomics, braille keyboards, and enlarging document capabilities (Ultra Magnifier) for the visually impaired. Workers also have capabilities with Microsoft Accessibility software for speech, hearing, and vision on all DWD computers, including read screens with a text- to-speech or braille displays. UI handbooks are accessible via computer on the DWD website and can be accessed with Microsoft’s speech recognition and Magnifier. DWD is currently examining all of the regions’ websites to ensure capabilities for Browse Aloud services. Additionally, the State EO Officer conducts quarterly meetings with all Local EO officers providing training, technical support, and best practices. 

For further details regarding physical and programmatic accessibility, please refer to the NDP and DWD Policy referenced above.