State and Local EO Officers ELEMENT 1: Designation of State and Local Level Equal Opportunity (EO) Officers
[29 CFR Part 37.23 through 37.28]
Background:
The Governor of Missouri has designated the Department of Economic Development, Division of Workforce Development (DWD) to administer the implementation of the nondiscrimination and equal opportunity provisions of the Workforce Investment Act of 1998. The nondiscrimination and equal opportunity provisions contained in 29 CFR Part 37.23 require all recipients, except those which are small entities or service providers, designate EO officers. This requirement also sets forth clear direction for who can serve as EO officers and what their responsibilities are. The Director of the Division of Workforce Development has ultimate responsibility for administration of the WIA Equal Opportunity program in the state and, on behalf of the Governor, ensures that the Workforce Investment Act, One-Stop System partners comply with the provisions contained in the federal regulations.
Consistent with 29 CFR Part 37, Missouri addresses how it and its recipients are complying and will continue to comply with the requirements. All recipients are required to make known to their applicants, eligible applicants, participants, employees and applicants for employment, the name, title, address and telephone number of the equal opportunity officer for the region/LWIA. This may be done by memoranda, posting, publications, etc.
In compliance with the nondiscrimination requirements for the MOA, the Division has designated a State Level EO officer and individual Local Level EO officers, representing the fourteen (14) Local Workforce Investment Areas (LWIAs). (The identity of each individual designated is made available by name, position title, business address (including e-mail address) and telephone number (including TDD/TTY number).
Equal Opportunity Officer Designation at the State Level
Ms. Juanita D. Reynolds is designated as the State EO officer and reports directly to the Director, Roderick Nunn, on all matters related to equal opportunity and nondiscrimination. The position includes oversight responsibility for coordinating, implementing, maintaining and monitoring the nondiscrimination and equal opportunity requirements of the U.S. Department of Labor Federal Regulations, 29 CFR Part 37.
Ms. Reynolds’ position description reflects duties that ensure Missouri complies with Section 188 of WIA and 29 CFR Part 37. Duties include, but are not limited to the following:
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Coordinating the State EO responsibilities under 29 CFR Part 37;
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Functioning as the state’s liaison with the Civil Rights Center;
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Providing technical assistance and guidance to the local level EO officers statewide to ensure compliance with federal regulations and other applicable regulations, policies, procedures and directives;
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Developing and publishing the recipient’s procedures for processing discrimination complaints and making sure those procedures are followed; and
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Overseeing the development and implementation of the state’s MOA.
Equal Opportunity Officer Designation at the Local Level
Missouri operates the WIA One-Stop system within fourteen (14) regions or LWIAs. All equal opportunity matters, within the regions, are referred directly to the individual Local EO officer. The Local EO officers are responsible for, but not limited to:
The State EO officer, with the support of the Division Director, is proactive in providing local EO officers with information and identifying and meeting training needs. These efforts are to further ensure that local service delivery staff, including partner staff, gain a clear understanding of the nondiscrimination and equal opportunity requirements, thus ensuring compliance with the laws and regulations. The focus for the planned technical assistance sessions, is to ensure those individuals with the critical role of ensuring nondiscrimination in the provision of services are knowledgeable and understand the requirements in the Equal Opportunity regulations. We are in the development phase of equal opportunity curriculum that will become part of the required orientation for all new DWD employees. In addition, to ensure the local level EO officers are sufficiently trained regarding their roles and responsibilities, we are requesting funding to support registration expenses for attendance at the National EO Conference, as well as, providing regularly scheduled, quarterly technical assistance sessions through 2007.
Budget
The programmatic funding requests, for the Equal Opportunity (EO) requirements, are submitted to the Director of Administration for review and decision. The requests include such items as document translation, brochure/poster printing, compliance monitoring visits, (instate expenditure) and participation in national conference (out of state expenditure) and other professional development related technical assistance.
Small recipients and service provides, defined in section 37.4 are not required to designate an EO officer, but must assure compliance with the non discrimination and equal opportunity provisions of WIA.
January, 2006, the Division of Workforce Development issued a memorandum to Local Workforce Investment Board Directors, with existing policy and procedures for re-identifying individuals to serve as equal opportunity officers at the local level. The current list of State and Local Officers can be found on the EO website.
Attachments for Element 1
Designation of State and Local Level Equal Opportunity (EO) Officers
I-A Memorandum of Understanding (MOU) Guidelines
I-B Memo to Workforce Investment Board Directors w/ DWD Issuance 05-01
I-C List of EO Officers
I-D Re-designation Letter
I-E Professional Development Notification/Quarterly TA Sessions |