Urban League of Broward County & Affiliates
Title VI / Nondiscrimination & 504
Title VI/Nondiscrimination & 504 Policy Statement
The Urban League of Broward County or it’s affiliates will comply with the Title VI Civil Rights Act of 1964 and the Civil Rights Restoration Act of 1987, section 504 of the Rehabilitation Act of 1973, the Americans with Disabilities Act of 1990 (ADA), and related statutes and regulations in all programs, services, and activities. Title VI states that “no person shall on the grounds of race, color, national origin, or disability be excluded from participation in, be denied the benefits of, or be otherwise subjected to discrimination” under any Urban League of Broward County program or activity.
Title VI & 504 Notice to the Public
The Urban League of Broward County or its affiliates will not on the basis of race, color, national origin, sex, age, disability, religion, or family status:
· Deny any person service, assistance, or other benefit for which the person is qualified;
· Provide any person with a service different from that provided to others under the same program;
· Subject any person to separate treatment in any manner related to services or other benefits;
· Limit any person in any way in the use of services, facilities, or any other advantages, privileges, or benefits provided to others under any program;
· Treat any person differently from others in deciding whether the person meets requirements to receive aid, service, or other benefit;
· Deny any person or offer an opportunity different from that offered to others in any program or service;
· Adopt methods that limit participation by any group of recipients or subject them to discrimination; and
· Refer any person to agencies that do not obey civil rights law.
All affiliates and agencies receiving funds through the Urban League of Broward County must sign a statement of compliance with Title VI of the Civil Rights Act of 1964, section 504 of the Rehabilitation Act of 1973, and the Americans with Disabilities Act of 1990 (ADA).
The Urban League of Broward County (ULBC) or its affiliates has established a discrimination complaint procedure and will take prompt and reasonable action to investigate and eliminate discrimination when found. Any person who believes that they have been subjected to discrimination based upon race, color, national origin, sex, religion, age, disability, or family status in any ULBC program or its affiliates, service, or activity may file a complaint with the Title VI Coordinator. If the complaint cannot be submitted in writing, the complainant should contact the Title VI Coordinator for assistance.
Download Title VI & ADA 504 Compliant Form
Donna Marshall
Urban League of Broward County
560 NW 27th Avenue
Fort Lauderdale, Florida 33311
dmarshall@ulbcfl.org
Phone: (954) 625-2589
Hearing Impaired: (800) 955-8771 (TTY/TDD)
Voice: 1-800-955-8770
The Title VI Coordinator has the responsibility for receiving, logging, acknowledging, investigating complaints, and reporting the findings. The Title VI Coordinator will notify the appropriate program director and Title VI Review Committee when a complaint is received.
Title VI & 504 Complaint Process
1. Formal complaints must be filed within (180) calendar days of the last date of the alleged act of discrimination or the date when the alleged discrimination became known to the complainant(s) or where there has been a continuing course of conduct, the date on which the conduct was discontinued or the latest instance of the conduct.
2. Complaints must be in writing and signed by the complainant(s) and must include the complainant(s) name, address and phone number. The Title VI contact person will assist the complainant with documenting the issues if necessary.
3. Allegations must be received by fax or e-mail and will be acknowledged and processed once the identity of the complainant(s) and the intent to proceed with the complaint have been established. For this, the complainant is required to mail a signed, original copy of the fax or email transmittal for the complaint to be processed. Complainants requiring special language services should contact the Agency’s Title VI/Nondiscrimination Coordinator.
4. Once submitted, Urban League of Broward County will review the complaint form to determine jurisdiction. All complaints will receive an acknowledgment letter informing the complainant whether the complaint will be investigated by the Urban League of Broward County or submitted to the County, State, or Federal authority for guidance.
5. The Urban League of Broward County or its affiliates has (45) days to investigate the complaint. If more information is needed to resolve the complaint, the Title VI Coordinator may contact the complainant. The complainant has (10) business days from the date of the letter to send requested information to the Title VI Coordinator. If the Title VI Coordinator is not contacted by the complainant or does not receive the additional information within 10 business days, the Authority can administratively close the complaint. A complaint can also be administratively closed if the complainant no longer wishes to pursue their complaint.
6. After the Title VI Coordinator reviews the complaint, the complainant will issue one of two certified mail letters to the complainant: a closure letter or a letter of finding (LOF). A closure letter summarizes the allegations and states that there was not a Title VI violation and that the complaint will be closed. An LOF summarizes the allegations and the interviews regarding the alleged incident and explains whether any disciplinary action, additional training of the staff member, or other action will occur. If the complainant wishes to appeal the decision, the complainant has (10) days after the date of the letter or the LOF to do so. The appeal will be reviewed by the Title VI Review Committee.
7. The Title VI Review Committee will have broad latitude to review an appealed complaint and make a finding. The committee may discuss the complaint with the complainant, the alleged offender, the Title VI Coordinator, or other parties to determine the facts. The committee will make a finding on the appeal within (15) calendar days of receipt of the request for appeal.
8. If the Complaint cannot be resolved by the Title VI Review Committee, a written report on the situation will be prepared and forwarded to the appropriate state or federal agency. If a complaint involves one of the department’s federally funded programs, the federal agency sponsoring the program will also be notified. Information will also be provided to the parties involved on the procedures for appealing to the federal level.
Retaliation
Retaliation is prohibited under Title VI of the Civil Rights Act of 1964 and related federal and state nondiscrimination authorities. It is the policy of the ULBC that persons filing a complaint of discrimination should have the right to do so without interference, intimidation, coercion, or fear of reprisal. Anyone who feels they have been subjected to retaliation should report such an incident to the Title VI Coordinator.
ADA (Americans with Disabilities Act)/504 Statement
Section 504 ADA (Americans with Disabilities Act)/504 Statement Section 504 of the Rehabilitation Act of 1973 (Section 504), the Americans with Disabilities Act of 1990 (ADA), and related federal and state laws and regulations forbid discrimination against those who have disabilities. Furthermore, these laws require federal aid recipients and other government entities to take affirmative steps to accommodate those with disabilities reasonably and ensure that their needs are equitably represented in programs, services, and activities.
The ULBC or it’s affiliates will make every effort to ensure that its facilities, programs, services, and activities are accessible to those with disabilities. The ULBC encourages the public to report any facility, program, service, or activity that appears in accessible to the disabled. Furthermore, the ULBC will provide reasonable accommodation to disabled individuals who wish to participate in public involvement events or who require special assistance to access ULBC facilities, programs, services, or activities. Because providing reasonable accommodation may require outside assistance, organization or resources, the ULBC asks that requests be made at least (7) calendar days prior to the need for accommodation.
Questions, concerns, comments, or requests for accommodation should be made to the ULBC’s ADA Coordinator:
Donna Marshall
Urban League of Broward County
560 NW 27th Avenue
Fort Lauderdale, Florida 33311
dmarshall@ulbcfl.org
Phone: (954) 625-2589
Hearing Impaired: (800) 955-8771 (TTY/TDD)
Voice: 1-800-955-8770
Limited English Proficiency (LEP)
Title VI of the Civil Rights Act of 1964, Executive Order 13166, and various directives from Federally funded recipients to take reasonable steps to ensure meaningful access to programs, services, and activities by those who do not speak English proficiently. To determine the extent to which LEP services are required and in which languages, the law requires the analysis of four factors:
• The number or proportion of LEP persons eligible to be served or likely to be encountered
by the ULBC’s programs, services, or activities;
• The frequency with which LEP individuals come in contact with these programs, services
or activities;
• The nature and importance of the program, service, or activity to people’s lives; and,
• The resources available to the ULBC and the likely costs of the LEP services.
1. Using census data, the ULBC has determined that LEP individuals who speak English less than well represent approximately 40.8% of the community.
2. The ULBC has received requests for translation or interpretation of its programs, services, or activities into Spanish, Creole, or other languages. In addition, ULBC-sponsored community outreach or public events are attended by significant numbers of LEP speakers. Thus, the ULBC
estimates its contact with LEP individuals to be moderate.
3. For a specific program or activity, ULBC must determine the nature and importance of the program to LEP populations to determine which language assistance services may be needed. ULBC defines as essential any document that advises the public of how to access nondiscrimination and public involvement policies.
4. The ULBC employs a number of proficient Spanish and Creole speakers that are able to interpret and/or provide translation services. The analyses of these factors suggest that LEP services are required at this time. At a minimum, the ULBC commits to:
• Maintain a list of employees who competently speak the LEP language(s) and who are willing
to provide translation and/or interpretation services.
• Distribute this list to staff that regularly has contact with the public.
• Provide public notification in the LEP language of the availability of language assistance.
The ULBC understands that its community characteristics change and that the four-factor analysis may reveal the need for more or varied LEP services in the future. As such, it will at least triennially examine its LEP plan to ensure that it remains reflective of the community’s needs.
Anyone who requires special language services should contact the ULBC’s Title VI Coordinator.
Public Notices:
· English – Persons requiring special language services should contact the Agency’s Title VI/Nondiscrimination Coordinator.
· Spanish – Las personas que requieran servicios de traducción deben comunicarse con el Coordinador del No Discrimin de la Agencia.
· Creole – Moun ki bezwen sèvis lang espesyal yo ta dwe kontakte Koòdonatè ki pa Diskriminasyon.
Helpful Links
U.S. Commission on Civil Rights
U.S. Department of Housing and Urban Development
U.S. Department of Health and Human Services
Title VI of the Civil Rights Act of 1964
Executive Order 13166 (Limited English Proficiency)
Americans with Disabilities Act
Limited English Proficiency (LEP)
Urban League of Broward County is an equal opportunity employer/program. Auxiliary aids and services are available upon request to individuals with disabilities. All voice telephone numbers on this website may be reached by persons using TTY/TDD equipment via the Florida Relay Service at 711.
Public Involvement:
In order to plan for efficient, effective, safe, equitable, and reliable services, the ULBC must have the input of its public. The ULBC also holds public meetings, workshops, and other events designed to gather public input on program/project planning and construction. Further, the ULBC sponsors, attends, and participates in other community events to promote its services to the public. Finally, the ULBC is constantly seeking ways of measuring the effectiveness of its public involvement.
Persons wishing to request special presentations by the ULBC, volunteer in any of its activities, offer suggestions for improvement, or simply learn more about ULBC programs and services should
contact:
Urban League of Broward County
560 NW 27th Avenue
Fort Lauderdale, Florida 33311
Phone: (954) 625-2589
Hearing Impaired: (800) 955-8771 (TTY /TDD)
Voice 1-800-955-8770
dmarshall@ulbcfl.org
Data Collection:
Federal regulations require federally funded recipients to collect racial, ethnic, and other similar demographic data on beneficiaries of or those affected by programs, services, and activities. The ULBC accomplishes this using census data, American Community Survey reports, driver and ridership surveys, its community development department, and other methods. From time to time, the ULBC may find it necessary to request voluntary identification of certain racial, ethnic, or other data from those who participate in ULBC programs, services, or activities. This information assists the ULBC with improving service equity and ensuring effective outreach. Self-identification of personal data to the ULBC will always be voluntary and anonymous. Moreover, the ULBC will not release or otherwise use this data in any manner inconsistent with the FHWA regulations.
Assurances:
Every three years, or commensurate with a change in ULBC executive leadership year, the ULBC must certify to ??? that its programs, services, and activities are being conducted in a nondiscriminatory manner. These certifications are termed ‘assurances’ and serve two important purposes. First, they document the ULBC’s commitment to nondiscrimination and equitable service to its community. Second, they serve as a legally enforceable agreement by which the ULBC may be held liable for breach.
· A complaint must be filed within one hundred eighty (180) days after the date of the alleged discrimination.
· Within (30) calendar days of receiving the complaint, the Title VI Coordinator will conduct a fact-finding investigation.
· Once the completed, and signed complaint is received, within (5) working days the Title VI Coordinator will provide the complainant with a written acknowledgement of the complaint.
· The Title VI Coordinator will meet with the complainant or the staff member who identified the alleged discriminatory activity to determine the nature of the complaint and whether Title VI requirements were violated. The Title VI Coordinator will meet with the director in whose area the alleged violation occurred to ascertain the director’s perspective on the complaint. Upon completion of the investigation the Title VI Coordinator will notify and submit a summary of the investigation to the members of the Title VI Review Committee.
· If the Title VI Coordinator determines that discrimination did not occur, the complainant, Title VI Review Committee, and program director will be informed in writing. The complainant will then have a right to appeal the decision, (10) days after the date of letter.
· If the investigation indicates that discrimination did occur, it will be discussed with the program director. The Title VI Coordinator will discuss ways in which to resolve the complaint and seek voluntary corrective action and will provide a report of such discussions in writing to the complainant, appropriate state or federal agency, and program director.
· The complainant, applicant or program director may appeal any rulings made by the Coordinator to the Title VI Review Committee within (10) calendar days of the receipt of the written findings. The request can include relevant documentation and sworn testimony, if any, from the appealing party, together with any testimony by witnesses having first-hand knowledge of the Title VI violations. The testimony may be in the form of an affidavit and shall describe in detail the circumstances and events that would lead a reasonable person to believe that a Title VI violation has occurred. The Title VI Review Committee will have broad latitude to review an appealed case and make a finding. The committee may discuss the complaint with the complainant, the alleged offender, the Title VI Coordinator, or other parties to determine the facts. The committee will make a finding on the appeal within (15) calendar days of receipt of the request for appeal.
· If the discriminatory activity cannot be resolved by the Title VI Review Committee, a written report on the situation will be prepared and forwarded to the appropriate state or federal agency. If a complaint involves one of the department’s federally funded programs, the federal agency sponsoring the program will also be notified. Information will also be provided to the parties involved on the procedures for appealing to the federal level.