- 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.
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 US DOL Civil Rights Center (CRC) every two years, with Indiana’s next submission due September 2020. Indiana’s 2018-2020 NDP provides detail on physical and programmatic accessibility and can be found at: https://www.in.gov/dwd/files/State%20of%20Indiana%20Nondiscrimination%20Plan%202018%20-%202020.pdf.
The State EO Officer ensures Indiana’s Local Workforce Development Areas (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 developed DWD Policy 2016-09, Equal Opportunity and Nondiscrimination Guidance Letter (see https://www.in.gov/dwd/files/3511/2016-09-P_EO_Nondiscrimination_Guidance.pdf) outlining 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/3196.htm. Training modules relevant to physical and programmatic accessibility include, for example, the EO 101 and Compliance with Disability Nondiscrimination Requirements modules.
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 work stations are in place in WorkOne offices throughout the state. Title II pays for one-on-one interpreters for visual and hearing impaired individuals attending adult education programming. Testing accommodations are available for both the TABE and TASC assessment as well.
The TTY/TDD Communication Nondiscrimination 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 will also be trained 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 Job Seekers with Disabilities website (https://www.in.gov/dwd/files/3511/2016-10-P_One_Stop_Center_Certification_with_Attachment.pdf) to include resources for both job seekers and employers. DWD will work to build new partnerships and enhance existing partnerships, such as with the Governor’s Council for People with Disabilities and FSSA/VR.
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 is trained to ask every constituent if s/he require accommodations. 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 constituent 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 that staff will be encouraged to use is the Guidepost for Success, which is a set of key educational and intervention strategies for youth, including those with disabilities. 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.
Physical Accessibility: State and Local EO Officers worked with the LWDAs to conduct accessibility compliance surveys of WorkOne offices during the last One-Stop Certification cycle (completed spring 2018). The EO Officers checked the accessibility to 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 DWD’s Compliance staff.
One-Stop Certification: DWD Policy 2016-10, One-Stop Center Certification, outlines the process utilized during the last cycle of center certifications, which were completed in spring 2018 (see https://www.in.gov/dwd/files/3511/2016-10-P_One_Stop_Center_Certification_with_Attachment.pdf). As this occurs every three years, the next cyrcle of certifications will begin in late 2020 and complete in spring 2021. Regarding physical and programmatic accessibility criteria for center certifications, please see details on the Certification Review Form (https://www.in.gov/dwd/files/3511/2016-10-P_One_Stop_Center_Certification_with_Attachment.pdf).
For further details regarding physical and programmatic accessibility, please refer to the NDP referenced above.