Civil Rights Compliance Reviews
Review of Documentation
Items requested and reviewed during desk audit may include:
- most recent handbooks for: students; faculty/administration; parents; or others;
- CTE course catalog/guide with course descriptions;
- recruitment and promotional materials related to CTE courses and programs used by the district (e.g., public announcements disseminated by the district or BOCES concerning CTE programs, including copies of notices intended to reach limited English proficient, hearing impaired, or visually impaired students and/or parents;
- policies or procedures for admission to CTE programs, including application process, entrance exam types and other prerequisites prior to enrollment;
- application and admissions forms related to CTE programs used by district school/guidance counselors;
- copy of grade 9-12 master schedule;
- complete listing of middle level CTE courses offered by the district;
- listing of special programs for students with disabilities;
- student and faculty grievance policies and procedures, including the appeal process, for Title IX (sex discrimination) and §504 (discrimination based on disability);
- a copy of two discrimination complaints (one from a student and one from a staff member) based on race, color, national origin, gender, or disability, including all documentation of resolution of the complaints;
- Title IX and Section 504 compliance officers’ contact information;
- copy of comprehensive developmental school counseling/guidance plan per CR 100.2 J(2)(b)
- list of language groups served and translated documents for English language learners and/or parents;
- copies of written agreements used with employers providing cooperative education, internships, or other work-based-learning experiences;
- documentation of required professional development sessions related to DASA, civil rights, culturally responsive instruction, or issues related to discrimination based on race, color, national origin, gender, and disabilities; and
- IEPs of students in NYSED-approved programs.
Interviews and Surveys
The following individuals or groups may be contacted for interviews and or surveys:
- CTE advisory committee members;
- Students and parents;
- Title IX coordinator(s);
- 504 Coordinator(s);
- Human resources manager;
- Superintendent, assistant superintendent, building principal(s);
- Guidance counselors, guidance department chair;
- Building facility manager(s); safety coordinator(s);
- DASA coordinator(s);
- School social workers;
- WBL coordinator;
- CTE, academic, bilingual, and special education teachers and administrators;
- School law enforcement/safety officer(s); and
- Staff that contributed to the Perkins grant application.
Voluntary Compliance Plans
Directions for Developing a Voluntary Compliance Plan (VCP)
- When areas of non-compliance are identified, a VCP must be developed and submitted to NYSED within 90 days of receipt of the preliminary Letter of Findings and Attachment of Findings.
- VCPs must:
- list each specific violation identified in the letter of findings (LOF)
- describe specific action steps which will be taken to remedy the violation(s)
- list the supporting documentation that will show the violation has been resolved
- establish a a date by which the correction of each violation (MM/YYYY) will be completed, if an interim remedy is needed, include its own estimated completion date (MM/YYYY) for those violations with remedies more than two years away
- identify the person responsible for implementation of each violation.
- VCP is often a chart with five columns:
- statement of each violation/ finding
- proposed remedy for each violation/finding
- supporting documentation to show the violation is resolved
- estimated date of completion (MM/YYYY) of each remedy
- person responsible for completion of the remedy for each finding
- When writing VCP, definite dates must be used (MM/YYYY), not a season, e.g., fall of XXXX or year
- When writing VCP, contingencies are not acceptable: e.g., "When a new budget is approved..." If a violation needs significant capital, an acceptable interim solution that will temporarily remedy the violation must be developed
- Ensure notice of nondiscrimination includes five protected classes of individuals: race, color, national origin, sex, and disability, plus compliance officer name and contact information. Ensure there is a grievance procedure available to students, staff, etc.
- Ensure compliance officers' contact information is readily available: name, title, address, email and phone number at a minimum.
- Ongoing monitoring and guidance will be provided until all noncompliance issues contained in the voluntary compliance plan are resolved.