Civil Rights Review of CTE Programs St. Louis Community
College
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Civil Rights Review of CTE Programs St. Louis Community
College
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Welcome Gina Benesh, Manager, Career and Technical Education
programs Linda Nissenbaum, Manager, Access Office, disAbility
Support Services
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St. Louis Community College Demographics College was
established in 1962 More than 1.2 million people have attended
STLCC The college consists of 4 main campuses, the College Center,
and 4 off-campus sites Each year, more than 81,000 students enroll
College transfer and career programs Job skill, personal
development, and preparatory classes Customized training
programs
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Notification
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The Letter
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The Missouri Department of Elementary & Secondary Education
is required by an agreement with the U.S. Department of Education
to conduct civil rights compliance reviews for educational
institutions in Missouri that receive federal funds and that offer
career and technical educational programs. Your school has been
selected.... ...a process approved by the U.S. Department of
Education...
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The Letter The Department, as a receipient of federal education
funds, is required by the U.S. Department of Education... The
purpose of the review is to ensure that local schools are providing
access to educational programs in compliance...with the civil
rights statutes:
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The Letter The Civil Rights Statutes Include: Title VI of the
Civil Rights Act of 1964 Title IX of the Educational Amendments of
1972 Section 504 of the Rehabilitation Act of 1973 Vocational
Education Program Guidelines for Eliminating Discrimination and
Denial of Services...
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Introductions Have you experienced or conducted a Civil Rights
Review of CTE programs?
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The Team-District Vice-Chancellor, Academic & Student
Affairs College Attorney Director, Enrollment Management Director,
Information Research & Planning Manager, Career & Technical
Education Manager, Employment & Recruitment (HR) Manager,
Engineering & Design
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The Team-Campuses Vice Presidents of Academic Affairs Vice
Presidents of Student Affairs Department Chair, Counseling Access
Office Managers
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Explanation of Requirements I. Administrative II. Recruitment
III. Admissions IV. Student Financial Assistance V. Counseling&
Prevocational Programs VI. Students w/Disabilities VII.
Accessibility VIII. Comparable Facilities IX. Work Study/Job
Placement X. Employment XI. Site Selection Student Eligibility
Criteria
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I.Administrative Notify of nondiscrimination and harassment
policies. Notify of bias-free accessibility to vocational programs.
Designate an employee(s) to coordinate efforts to comply with
Section 504, Title II, and Title IX. Adopt and publish a grievance
procedure to provide for prompt resolution of discrimination
complaints. Title VI, Title IX, and Section 504 signed statement of
assurance.
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II.Recruitment Recruitment activities must: Include all
potential students regardless of sex, race, color, national origin,
or disability. Be bias-free. Be provided by a diverse team,
representing components of the community (if applicable). Be
accessible by members of English-limited populations and persons
with sensory impairments.
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III.Admissions Recipients must: Admit without regard to sex,
race, color, national origin, language ability, or disability.
Avoid preadmission inquiries about marital, parental, or disability
status. Have policies in place for serving limited- English
proficient students. Use admission tests that do not measure
disabilities (postsecondary).
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IV.Financial Aid Recipients must: Make financial aid available
to all students regardless of sex, race, color, national origin, or
disability. Award sex-restricted aid only when established by legal
instrument. Provide bias-free information. Provide information in a
variety of languages and formats.
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V.Counseling & Prevocational Programs Recipients must:
Provide counseling materials that are nondiscriminatory. Provide
counseling services based on sex, race, color, national origin, or
disability. Avoid directing disabled students toward more
restrictive career objectives. Assure that disproportional
enrollments do not result from discrimination.
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VI.Students w/Disabilities Recipients must: Provide access and
benefits to all courses, programs, services, or activities for
students w/disabilities. Provide related aids or adaptations.
Measure academic achievement and ability rather than disability.
Provide postsecondary housing without regard to sex, race, color,
national origin, or disability
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VII.Accessibility Standards for: Existing facilities initiated
before 6/4/77 Programs and facilities are readily available to
people with disabilities. New construction initiated between 6/4/77
and 1/17/91 Each facility is readily accessible and usable by
people with disabilities. New construction initiated after 1/18/91
Each facility is readily accessible and usable by people with
disabilities. New construction initiated after 1/27/92 Each
facility is readily accessible and usable by people with
disabilities.
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VIII.Comparable Facilities Recipient must: Provide facilities
for males, females, and/or students with disabilities that are
comparable to one another.
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IX.Work Study, Coop, Job Placement, Practicums Recipient must:
Provide opportunities in the above programs for all students
regardless of sex, race, color, national origin, or disability.
Assure that prospective employers do not discriminate. Assure that
partners in apprenticeship training do not discriminate. Secure
written agreements that assure nondiscrimination.
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X.Employment Recipient must: Prevent discrimination in
employment practices on the basis of sex, race, color, national
origin, or disability. Prevent segregation, exclusion, or other
discrimination against students through its employment practices.
Assure that pre-employment inquiries regarding disability, marital,
or parental status is not made. Notify all faculty of
nondiscrimination policies. Arrange salary schedules to reflect
conditions and responsibilities of employment. Provide reasonable
accommodations to qualified candidates.
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XI.Site Selection and Student Eligibility Criteria Recipient
must: Maintain eligibility criteria that is nondiscriminatory.
Locate sites that are accessible to all populations and not label
sites as intended for minority students. May not alter physical
plans of facilities that would segregate on the basis of sex, race,
color, national origin, or disability. Create geographic boundaries
that do not exclude students based on race, color, or national
origin.
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On Site Review- Persons to Be Interviewed Chief School
Administrator Dean of Career Education Career Education
Administrator Career Education Teachers (2) Title IX and/or 504
Coordinator(s) Counselor/Placement Director Special Education
Director Career Education Students (3-5)
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Documentation Standard I Document(s) which designate the Title
IX and Section 504 Coordinator(s) that includes name (or position),
business address, and phone number
http://www.stlcc.edu/Non_Discrimination/
http://www.stlcc.edu/Non_Discrimination/ Job description for Title
IX and Section 504 Coordinator(s) including duties and
responsibilities of the position(s) Copy of notification for
faculty, staff, students, and the public re: name (or position),
business address, and phone number of the Title IX and Section 504
Coordinator(s) Student Handbook Employee Handbook
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Documentation Standard I- Interview Questions Chief
Administrator: How were the Title IX and Section 504 positions
designated? How do you inform the public of the names of these
coordinators? Counselor/Placement Director/Vocational
Teacher/Student: Who would you contact in the event you believed
that you had experienced discrimination?
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Documentation Standard II A copy of the signed Title VI, Title
IX, Section 504 or a combined assurance document A copy of the
governing body minutes authorizing the assurances
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Documentation Standard III Copy of the policy of
nondiscrimination which contains grievance procedures
http://www.stlcc.edu/disAbility/Grievance_Proced ures.html
http://www.stlcc.edu/disAbility/Grievance_Proced ures.html Copy of
nondiscrimination policy dissemination plan Copy of annual notice
to faculty, staff, and students
http://www.stlcc.edu/Document_Library/FV/FV- Staff-Manual.pdf
http://www.stlcc.edu/Document_Library/FV/FV- Staff-Manual.pdf
http://www.stlcc.edu/Document_Library/factfinder.pdf
http://www.stlcc.edu/Document_Library/factfinder.pdf
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Documentation Standard IV Copy of board-approved harassment
policy http://www.stlcc.edu/Document_Library/Boar d_Policy.pdf
http://www.stlcc.edu/Document_Library/Boar d_Policy.pdf Plan for
dissemination of policy to students, staff, and the public
Documentation of notice
http://www.stlcc.edu/Student_Resources/Polic
ies_and_Procedures/Student_Rights_and_Resp onsibilities.html
http://www.stlcc.edu/Student_Resources/Polic
ies_and_Procedures/Student_Rights_and_Resp onsibilities.html
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Standard III & IV Interview Questions Chief Administrator:
Who is designated to handle claims of harassment or discrimination?
How do you notify staff, students, and the public regarding the
policies and grievance procedures? Counselor/Placement
Director/Vocational Teacher/Student: Where are the districts
harassment and non- discrimination policies located? How and when
are you informed of these policies? How would you file a
grievance?
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Documentation Standard V Career Education enrollment
demographics (form provided) Written selection criteria for
textbooks and other materials Copy of promotional activities and
materials Copy of ESOL policy Copy of vocational recruitment,
selection and admission procedures
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Standard V Interview Questions: Chief Administrator: How does
the district ensure equal access to vocational programs for all
students? What are district policies regarding students with
disabilities and LEP students? Counselor/Placement
Director/Vocational Teacher/Student: What materials do you use for
recruiting students into vocational programs How do you ensure that
selection and recruitment are nondiscriminatory?
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Standard V Interview Questions: Vocational Teacher: How do you
recruit nontraditional, minorities, and students with disabilities?
Student: How is your gender/race represented in informational
materials?
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Documentation Standard VI Copy of written agreements with
organized labor entities that provide apprenticeship programs Copy
of training agreements with employers Copy of placement procedures
that ensure nondiscrimination Copy of nondiscrimination policy
given to employers
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Standard VI Interview Questions Chief Administrator: How does
the district work with business and labor to assure equitable
environments for work based activities?
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Documentation Standard VII Copy of certified and non-certified
job applications Copy of job descriptions for all positions
http://docs.stlcc.edu/docs/Documents/Forms/
AllItems.aspx?RootFolder=%2fdocs%2fDocume
nts%2fDocument%20Archive%2fHuman%20Res
ources%2fJob%20Descriptions&FolderCTID=0x0
12000EB958828A9CF33489B078EB3FBDF5D0D
http://docs.stlcc.edu/docs/Documents/Forms/
AllItems.aspx?RootFolder=%2fdocs%2fDocume
nts%2fDocument%20Archive%2fHuman%20Res
ources%2fJob%20Descriptions&FolderCTID=0x0
12000EB958828A9CF33489B078EB3FBDF5D0D
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Standard VII Interview Questions Chief Administrator: What
safeguards have been instituted to ensure that the district does
not discriminate in employment practices? Vocational Teacher: How
does the district ensure that its employment practices are
nondiscriminatory?
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Documentation Standard VIII Copy of the plan for the delivery
of guidance services
http://www.stlcc.edu/Student_Resources/Career_a
nd_Employment_Services/Student_Services.html
http://www.stlcc.edu/Student_Resources/Career_a
nd_Employment_Services/Student_Services.html Copy of the
district/institution assessment plan
http://www.stlcc.edu/Faculty_and_Staff_Resources
/Assessment/Missions-Based_Assessment.html
http://www.stlcc.edu/Faculty_and_Staff_Resources
/Assessment/Missions-Based_Assessment.html Copy of the procedures
for the development of IEPs for the students with disabilities
http://www.stlcc.edu/disAbility/Library/transition_to
_st_louis_cc.pdf
http://www.stlcc.edu/disAbility/Library/transition_to
_st_louis_cc.pdf
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Standard VIII Interview Questions Counselor/Placement Director:
How do you ensure that your guidance services are
nondiscriminatory? Student: What kind of career information have
you received? Tell me what a nontraditional occupation is?
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Documentation Standard IX Copy of the ADA self-study Copy of
the ADA transition plan Notice of activities and facilities
accessibility http://www.stlcc.edu/Disability/Library/access
ability_checklist_for_events.pdf
http://www.stlcc.edu/Disability/Library/access
ability_checklist_for_events.pdf
http://www.stlcc.edu/disAbility/Index.html
http://www.stlcc.edu/disAbility/Index.html
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Standard IX Interview Questions Chief Administrator: How do you
make the public aware of accessible facilities? How often?
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Days of Review The Review Team Manager, CTE Manager, Access
Office (Former ADA Coordinator) Manager, Engineering & Design
The DESE Review Team Director of Civil Rights Compliance
Coordinator of Career Education
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Days of Review Meeting with District Administration and Staff
Vice Presidents of Academic Affairs Vice Presidents of Student
Affairs Director of Enrollment Management Director, Information
Research & Planning Deans Manager of Employment and Recruiting
Manager of Employment & Recruitment Manager, Engineering &
Design Managers, Access Offices
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Days of Review Meeting with Administration Leadership Team
& Select Members Chancellor Vice Chancellor of Academic &
Student Affairs President of Wildwood Campus College Attorney
Manager of Employment & Recruitment
Findings STLCC Recognized for : Continuous Nondiscrimination
Notice Identifying persons responsible for coordinating Title IX
& Sec. 504 and including contact information Adopting &
publishing grievance procedure Nondiscrimination in
eligibility/admissions criteria, counseling materials
&activities, work study, cooperative education, and job
placement.
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Findings STLCC Recognized for : Access to Programs, Activities,
and Services includes accessible sites, classrooms, restrooms,
adaptive equipment, provision of accommodation, auxiliary aids, and
services. Recruitment materials that are not limiting, available to
all potential students, and avoid stereotyping Providing comparable
facilities for students with disabilities, males, and females
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Findings STLCC Recognized for : Recruitment materials &
personnel represent persons of varying races, male & female,
disabilities, and national origins. Non-limitation of participation
in programs due to potential workplace discrimination Admissions
tests allow for accommodations so that students can accurately
reflect their ability(s) and not their disability(s)
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Findings STLCC Recognized for : Financial assistance, work
study, coop, and job placement is available regardless of sex,
race, color, national origin, or disability Nondiscrimination in
employment practices and opportunities.
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Findings STLCC Needs to: Make materials available in the
language of national origin minority communities in the service
area for students and parents with limited English Skills
available. This includes: Notice of nondiscrimination Counseling
materials Recruitment materials Financial aid information
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Our Learning Language----- Continue to build compliance into
every program, policy, procedure, and facility Revised ADA
Form-CurricUNET Continue to offer training for faculty and staff on
compliance and awareness Continue to include notification of
compliance in publications and website