Module IV EO Monitoring for Compliance

1. Module IVEO Monitoring for Compliance

2. Agenda • Monitoring Responsibilities • Minimum Requirements: EO Annual Monitoring • Data/Record Analysis • Assessment of Administrative Obligations • EO Monitoring In Indiana • EO Monitoring Factors

3. Learning Objectives • State oversight responsibilities for WIOA monitoring • Identify EO monitoring requirements under WIOA • List the minimum requirements for annual monitoring • Identify acceptable documentation for monitoring requirements

4. Monitoring Responsibilities • Each Governor is responsible for: (29 CFR Part 38.51): • Ensuring compliance with the nondiscrimination and EO provisions of WIOA and EO Regulations and negotiating, where appropriate, with a recipient to secure voluntary compliance if non-compliance is found • Annually monitoring compliance of recipients

5. Minimum Requirements: EOAnnual Monitoring • Statistical or quantifiable analysis of required records and data collected by recipient and an investigation of any significant differences to determine whether those differences appear to be caused by discrimination • Assessment to determine whether recipient has fulfilled its administrative obligations under WIOA and the Nondiscrimination Plan

6. Data/Record Analysis • Annual analysis must cover: • Record review by race/ ethnicity, sex, limited English proficiency, • preferred language, age, • and disability status to • determine significant • differences • Analyses of records, interviews, and other appropriate methods to determine causes of differences

7. Assessment of Recipient Administrative Obligations • The assessment covers: • Assurances • EO Officers • Notice & communication • Data and information • Affirmative Outreach • Monitoring & evaluating policy development, communication, and training • Corrective action & sanctions • Complaint processing procedures • Other responsibilities via NDP

8. EO Monitoring In Indiana • EO Monitoring consists of: • Interview-style assessments • Desk-top reviews • Site visits • Post-review report • Corrective Actions/Sanctions

9. EO Monitoring In Indiana(Not an all inclusive list!) • WDB staffing chart and Local EO Officer job description • “EO is the Law” posters • Completed Complaint Forms and documentation • Handicap & visually impaired accessible assistive technology • Examples of ways the recipient is providing “equal access” for Title I WIOA services and activities (affirmative outreach)

10. EO Monitoring In Indiana(Not an all inclusive list!) • Examples of ways recipient is providing reasonable steps to ensure meaningful access to LEP individuals • Examples of Babel Notices and Tag Lines • Monitoring instruments and instructions • Information on the extent to which EO training has been carried out or is planned

11. EO Monitoring Factors • ADA Accessibility

12. EO Monitoring Factors(con’t.) • Local EO Officer

13. EO Monitoring Factors(con’t.) • Notice and Communication

14. EO Monitoring Factors(con’t.) • Data & Information Collection Main.

15. EO Monitoring Factors(con’t.) • Affirmative Outreach

16. EO Monitoring Factors(con’t.) • Recordkeeping

17. EO Monitoring Factors(con’t.) • Complaint Records

18. Q&A Monitoring and Compliance

19. RECALL RECAP Monitoring and Compliance