Notice and Communication

ELEMENT 2: Notice and Communication
[29 CFR Part 37.29 through 37.36]

Background:

Recipients must provide initial and continuous notice that they do not discriminate on any prohibited ground. The requirement is that this notice must be provided to registrants, applicants and eligible applicants/registrants; participants; applicants for employment and employees; unions or professional organizations that hold collective bargaining agreements with the recipients; sub-recipients that receive WIA Title I funds from the recipients; and members of the general public, including those with limited vision and hearing. Section 37.29 requires the recipient to further take appropriate steps to ensure communications with individuals with disabilities are as effective as communications with others.

Customers entering a Missouri Career Center may view the “Equal Opportunity is the Law” poster, prominently displayed near the resource areas. The “EO is the Law" poster, in both English and Spanish formats, continues to be required signage for all Career Centers. Individuals receiving services are provided the WIA Complaint and Grievance Guide, recently updated and made available on the agency’s website. The Guide contains an “Acknowledgement of Receipt” section, requiring the signature of the customer adjacent to the Notice. The document may be down loaded and completed electronically for a consistent method of distribution. 

The State EO officer is responsible for ensuring monitoring occurs for local workforce regions relative to EO compliance. 

The EO Notice is displayed on the newly developed Equal Opportunity website for the agency. We are currently processing Spanish translation for the website Notice and the updated Complaint and Grievance Guide. 

To the extent information in languages other than English is provided and the manner in which the State ensures that persons of limited English speaking ability have access to its programs and activities, on a basis equal to that of persons who are proficient in English, is continually reviewed to ensure compliance. Using the most recent census data, Spanish appears to be the predominant non-English language spoken by limited English proficient (LEP) persons in Missouri. The Division (DWD) contracts with separate entities to provide interpretive services for LEP customers. The One-Stop system utilizes a contract with Language Line for services ranging from oral to written translation, to in person or telephonic interpretation.

The State EO officer will charter a workgroup, planned for the next scheduled TA session, to review and update policy, with the goal to develop a comprehensive plan that ensures eligible LEP individuals have meaningful access to all Missouri One-Stop programs and services. 

While each local area provides training to new employees on a regular basis, in order to communicate policy and conduct training regarding nondiscrimination and equal opportunity, the State EO officer will continue to coordinate with the DWD training coordinator, applicable equal opportunity related sessions. The Division’s training unit has designed a training calendar for use by internal and partner staff for communicating available opportunities. 

The State EO officer is researching curriculum for development of a universal Equal Opportunity training for the One-Stop system. The objective is to have a web based product, required in conjunction with new employee orientation and available to all partner staff, including Local Workforce Investment Boards. The initial training components will incorporate principles of the 29 CFR Part 37; the covered bases of discrimination, the state’s obligations and procedures for filing discrimination complaints. 

Attachments for Element 2

Notice and Communication

II-A   WIA Complaint and Grievance Guide for the Missouri One-Stop System

II-B   DWD Issuance 06-01