Civil Rights On-Site Reviews, Instructions, and Documentation

Compliance Review Procedures

This document is intended to provide guidance to those local education agencies (LEA) that have been selected to receive a civil rights compliance review as they gather their compliance plan documentation. Procedural instructions are provided, as well as descriptions of the types of documentation that LEAs should provide for the review.

Complete all applicable forms, including the lengthy compliance plan, sent to you by PDE’s civil rights on-site reviewer. Electronically send the completed compliance plan to Cynthia Gross, PDE’s civil rights on-site reviewer, at cygross@pa.gov at least 10 working days prior to the review. This will allow time for the responses to be reviewed by Pennsylvania Department of Education (PDE) prior to the visit. If there are questions, the responses will be highlighted and returned to the subrecipient electronically. The areas in question will be discussed further during the review.
Provide a map and/or travel directions from Harrisburg to your educational institution for the reviewer.
Collect documentation to substantiate compliance. Documentation should be compiled in five folders. These are:
Section A: Administration
Section B: Counseling/Advisement
Section C: Cooperative Vocational Education Work Study, Job Placement and Apprenticeship Training
Section D: Access and Admission to Career and Technical Education Programs
Section E: Equal Opportunity (Please note the last five questions in Section E pertain to postsecondary/adult providers only.)

Label each document and place in the appropriate folder to correspond with each assurance in the questionnaire (e.g., A.1.a.). Place all documents in the same sequence as they appear on the questionnaire. It is permissible to cross-reference when two or more questions may be substantiated by the same documentation, by referring the reviewer to the previous document(s).

In each folder, insert the appropriate documentation to substantiate a response to each question. If a large notebook or other publication contains only a few pages that demonstrate compliance, select or copy only the applicable pages for documentation. For website references, print the first page of the website section and applicable page(s) that the documentation references.

Please note that PDE may retain some civil rights documentation. Therefore, an institution may choose to maintain an agency set of the documents provided to PDE.

The above-mentioned folders, the original copy of the questionnaire and other applicable forms should all be made available to PDE upon arrival at the designated location at the institution. If possible, a computer and wireless internet access should be provided for the reviewer’s use.
Reserve a workroom which is easily accessible to students and staff for the reviewer to use to verify documentation, compile findings and conduct the required interviews.

Section A: Administration

Please do not send any documents. Provide only the specific information pertaining to the request not entire newspapers, binders, etc. In preparing the documents, label each with the assurance number (e.g., A.1.a.).

Note- Numbering below is not sequential. Item numbers refer to like-numbered items in the compliance plan document that may need additional clarification.

#1-Review the annual and continuous notices of nondiscrimination per the guidelines on the PDE website. The annual notice identifies the cluster of career and technical education programs offered. It is published in newspaper(s) once a year prior to the start of school or can be posted on the school’s website.
#2-The continuous notice does not identify program clusters but references the Boy Scouts and other youth groups. It is a separate notice from the annual notice. Provide a copy of the home page of your website, student handbook(s), information sent to parents, course description books, periodic memoranda, student newspapers, written announcements, bulletins, catalogs, application forms, collective bargaining agreement(s) and other written and/or audiovisual materials which include a policy of nondiscrimination.
#4-Indicate how individuals with sensory impairments receive information regarding career and technical education opportunities. These may be documents for parents/guardians and/or students. If there is a family with limited English language skills, provide a copy of the materials, applicable notifications and a list of services.
#5- Provide a copy of board minutes or other documentation, which substantiates that the coordinator(s) for civil rights activities have been officially appointed.
#6-Provide a copy of a grievance procedure related to Title VI of the Civil Rights Act of 1964; Title IX of the Education Amendments of 1972; Section 504 of the Rehabilitation Act of 1973 and Title II Americans with Disabilities Act. If there are different civil rights grievance procedures for students and for employees, provide both.
#7-Provide the date of construction of all buildings, dates of alterations and applicable construction standards. Identify actions taken to remove physical barriers.
#8-Provide documentation that shows how disabled school-aged persons are located annually. Examples are: regional or local school census which includes inquiries regarding possible disabling conditions, public awareness media campaign, radio/TV announcements, newspaper announcements, presentations to local groups and/or routine screening procedures for kindergarten enrollees, etc. The intermediate unit generally conducts this activity and publishes a regional announcement on nondiscrimination in August each year.
#11- Provide copies of job announcements or other correspondence regarding job vacancies sent to the media, individuals and other recruitment sources within the past 24 months. Ensure that “Equal Opportunity Employer” appears at the bottom of newspaper advertisements.
#13- Provide copies of employment applications and employee contracts for each classification and an explanation of the interviewing process.
#14- Identify the procedures established for accommodating disabled employees. If accommodations have been made in the past five years, provide a brief explanation.
#15-Provide copies of tests, structured interview questions and procedures used for screening applicants. If interviews result in scoring applicants, describe how scores are applied and/or ranked.

Section B: Counseling/Advisement

#1-Provide a copy of any administrative directive or other appropriate memoranda that instructs faculty and counselors on the selection and purchase of non-biased career information as well as on the language and illustrations of non-biased course descriptions and course information sheets. Also, provide a copy of course description handbooks, catalogs, occupational information brochures and a list of tests and other resources, including audiovisual resources, which are used in career education courses or career presentations.
#2-Provide a list of agencies, if any, or personnel who provide interpreting services as needs arise.
#4-Provide documentation which identifies and analyzes practices that may contribute to disproportionate enrollments by race and sex. If voluntary remedial action was taken, describe the action and timeframe.
#6-Provide a list or a copy of each announcement of loans, grants, scholarships, prizes, etc., made available to students. If there are national origin minority persons with limited English language skills, provide copies of translated announcements or an explanation of how announcements are translated. Postsecondary institutions must also address how the information is provided to visually-impaired students.

Section C: Cooperative Vocational Education Work Study, Job Placement and Apprenticeship Training

#1-Provide correspondence to and from sponsors or publications relative to nondiscrimination in employment that contain a nondiscrimination announcement. Provide the total number of students in co-op, job placement programs, apprenticeship and work-study by race, sex and disability. Provide your policy and/or criteria for entering a work study (including diversified occupations), co-op, job placement and apprenticeship training.
#2-Provide copies of any job announcements received from potential employers, job vacancy postings and/or telephone logs documenting requests for student employees.
#3-Provide a copy of any written agreements between the educational institution and union or other sponsors to verify the inclusion of a statement of nondiscrimination. Provide a copy of the apprenticeship training program’s policy of nondiscrimination.
#4-Provide a sample copy of a signed agreement between a trainee, the institution and an employer to verify the inclusion of a statement of nondiscrimination.

Section D: Access and Admission to Career and Technical Education Programs

#1-Provide the admission policy, including the eligibility criteria and/or selection procedures, used to determine entrance into a career and technical education program.
#2-Provide the admission application for secondary and/or adult career and technical education programs.
#3-Numerical limitations relative to admission will be reviewed on-site through interviews with appropriate personnel. Indicate if these are published and when applicable.

Section E: Equal Opportunity

#1-Provide a list of supplementary aids provided by the career and technical center or home school.
#2-Indicate if facilities/accommodations are comparable for both genders.
#3-Provide a list of academic adjustments provided by the institution, the Pennsylvania Office of Vocational Rehabilitation or other sources.
#7-Indicate the availability of student housing and handicapped accessibility.

​Civil Rights On-Site Reviews, Instructions, and Documentation