Located in:
- III. Operational Planning Elements
The Unified or Combined State Plan must include an Operational Planning Elements section that supports the State’s strategy and the system-wide vision described in Section II(c) above. Unless otherwise noted, all Operational Planning Elements apply to Combined State Plan partner programs included in the plan as well as to core programs. This section must include—
- b. State Operating Systems and Policies
The Unified or Combined State Plan must include a description of the State operating systems and policies that will support the implementation of the State strategy described in section II Strategic Elements. This includes—
- b. State Operating Systems and Policies
III. b. 8. Addressing the Accessibility of the One-Stop Delivery System for Individuals with Disabilities
Describe how the one-stop delivery system (including one-stop center operators and the one-stop delivery system partners), will comply with section 188 of WIOA (if applicable) and applicable provisions of the Americans with Disabilities Act of 1990 (42 U.S.C. 12101 et seq.) with regard to the physical and programmatic accessibility of facilities, programs, services, technology, and materials for individuals with disabilities. This also must include a description of compliance through providing staff training and support for addressing the needs of individuals with disabilities. Describe the State’s one-stop center certification policy, particularly the accessibility criteria.
Current Narrative:
Vermont’s One-Stop partners have evaluated the one-stop delivery system to ensure that all employment education and training programs are available and accessible. Collectively, partners are providing resources to individuals in need of specific and specialized assistance in overcoming barriers to employment.
In Vermont's comprehensive AJC all services are provided through a combination of physical and virtual colocation, creating the most integrated setting appropriate for individuals to receive services. A significant effort is underway to update workstations in the resource areas to offer the most up-to-date assistive technology and to train One-stop staff and partners in how to use these resources. Later in the summer, partners will explore whether the to publicly highlight the technology and resources to the public – primarily employer partners – to demonstrate ways that they can be more inclusive and accommodating to future job applicants and current employers.
Vermont’s one-stop career centers are fully accessible for individuals with disabilities and have access to a variety of specialized equipment to support employees and customers. Staff meet people where they are – physically, educationally, cognitively, and emotionally – to provide services. Clients have great autonomy and participate heavily in the development of their career plans. Orientations and workshops are provided in integrated settings unless an individual requests or demonstrates a need for separated service provision. VDOL and VR have partnered to provide Disability Etiquette training to VDOL staff through the winter and spring of 2020 and will expand this and subsequent inclusivity trainings to all One-stop staff beginning in the summer of 2020, as stand-alone trainings and integrated into the bi-annual cross-trainings described in Strategy C.
VDOL has identified Dirk Anderson, VDOL General Counsel, as it’s EOO, while Sarah Buxton, State Director of Workforce Development, serves as the state-level EOO.
VDOL’s non-discrimination and equal opportunity policy is provided here:
PROVIDING NOTICE OF EQUAL OPPORTUNITY AND NONDISCRIMINATION
Prohibited Discrimination
No individual in the United States may be excluded from participation in, denied the benefits of, subjected to discrimination under, or denied employment in the administration of or in connection with any Title I financially assisted program or activity, on the ground of race, color, religion, sex, national origin, age, disability, or political affiliation or belief and for beneficiaries only, citizenship or participation in any WIOA Title I program.
WIOA Sec. 188 and 29 CFR Part 38
Providing Initial and Continuing Notice
- All recipients receiving financial assistance under Workforce Innovation and Opportunity Act Title I, must provide initial and continuing notice that it does not discriminate on any prohibited ground.
- Recipients for the purpose of equal opportunity and nondiscrimination regulations include, but are not limited to:
- State level agencies that administer, or are financed in whole or in part by WIOA Title I funds;
- State Employment Security Agencies;
- State Workforce Investment Boards;
- WIOA grant recipients such as service providers and eligible training providers;
- One-stop operators; and
- One-stop partners (by inclusion in one-stop centers)
- Notice must be provided to:
- Registrants/applicants and eligible applicants/registrants;
- Participants;
- Applicants for employment and employees in WIOA funded programs;
- Unions or professional organizations that hold collective bargaining or professional agreements with the recipient; and
- Members of the public, including those with impaired vision, hearing or Limited English Proficiency.
- Recipients must take appropriate steps to ensure that communications with individuals with disabilities are as effective as communications with others.
- Notice must be provided to:
WIOA Sec. 188; 29 CFR Part 38.34 and 20 CFR 683.600
- Equal Opportunity Notice Poster (29 CFR 38.35)
The posters, which are printed in English and Spanish, must be posted in prominent areas of the agency to provide notice of equal opportunity and nondiscrimination.
Note: “Equal Opportunity is the Law” posters are available through the VDOL.
- “Equal Opportunity is the Law” Signature Form
- All individuals registered in WIOA should read, understand and sign the complaint procedure signature form with a copy to the individual and a copy in their file. (WFD-3 Rights and Benefits Form)
- Service providers are required to provide the complaint procedure signature form to all current employees (WIOA partially or fully funded positions) and ensure that all new employees receive this form when they begin employment (again WIOA partially or fully- funded positions). All employees should read, understand and sign the complaint procedure form. Furnish a copy to the employee and place a copy in their personnel file.
- Applicants for WIOA services or applicants for employment with the recipient are covered by the appropriate display of posters.
- “Equal Opportunity is the Law” Signature Form
Publications
Recipients of Workforce Innovation and Opportunity Act funds must provide notice that WIOA Title I financially assisted programs or activities are an “equal opportunity employer/program” and that “auxiliary aids and services are available upon request to individuals with disabilities” in recruitment brochures and other materials that are ordinarily distributed or communicated in written and/or oral form, electronically and/or on paper, to staff, clients, or the public at large, to describe programs financially funded through WIOA Title I.
Recipients that publish or broadcast WIOA Title I program information on news media must ensure that such publications and broadcasts state that the program or activity is an equal opportunity employer/program (or otherwise indicate that discrimination in the WIOA Title I financially assisted program or activity is prohibited by Federal law) and indicate that auxiliary aids and services are available upon request to individuals with disabilities.
Where materials indicate that the recipient may be reached by telephone, the materials must state the telephone number of the TTY or relay services used by the recipients.
29 CFR Part 38.36
Notification of Grievance Due Process
All WIOA Title I and National Emergency Grant participants must be provided information about their right to file a grievance within 180 days of the alleged violation and the opportunity for an informal resolution that may include a hearing within sixty days of filing the grievance. Verification of notification must be included in all adult, youth and dislocated worker program participant files. (WFD-3 Statement of Rights and Benefits form)
WIOA Regs. at 20 CFR Part 683.600