Operations Issuance: 2019-15

Issuance Number: 2019-15

Date: April 18, 2019

To: San Diego Workforce Partnership Subrecipients

From: Kai Jackson, Director of Finance

Subject: Operations Manual Update: Chapter 9 – Nondiscrimination & Equal Opportunity Policy and Complaint Procedures

Purpose:

The purpose of this issuance is to notify SDWP Subrecipients of revisions and/or additions to the following policies: Chapter 9 – Nondiscrimination & Equal Opportunity Policy and Complaint Procedures, including its attachments.

Significant changes have been made to the above chapter and attachments including but not limited to:

  • Refresh of the chapter and attachment formatting.
  • Attachment added
    • Reasonable Accommodation Policy and Procedure Guide
  • Additional definitions were added:
    • Babel
    • Complainant
    • Employment-related Training
    • Nondiscrimination & Equal Opportunity (EO) Complaint
    • Hearing Officer
    • Incident Report Complaint
    • LEP Individual
    • LEP Plan
    • Meaningful Access
    • Primary Language
    • Program Grievance Complaint
    • Service Provider
    • Teletypewriter (TTY)
  • Section II title has been changed from “Subrecipient Policy & Procedure Requirement” to “Subrecipient Complaint Policy & Procedure Requirement”.
  • Section II, Part A – Requirement of Policy has been expanded to include additional guidance regarding requirements of Subrecipient complaint policies & procedures:
    • Notice and Communication is split into three (3) subcategories
      • a) Communication and Notice in Orientations
      • b) Complaint & Incident Reporting Policy Notice
      • c) Equal Opportunity is the Law Notice   
    • Publications, Broadcasts, and Other Communications has been added as a separate item
    • Discrimination Prohibited Based on Disability has been added as a new item
    • Reasonable Accommodation has been added as a separate item and additional guidance is provided
    • Service Animals has been added as a separate item and additional guidance is provided
    • Program Access to Individuals with Limited English Proficiency (LEP) has been split into six (6) subcategories and additional guidance is provided
    • Data and Information Retention, Reporting, and Confidentiality has been split into one (1) subcategory and additional guidance is provided
    • Complaint Log has been added as a separate item
  • Section II, Part B title has been changed from “Nondiscrimination & EO Complaint Procedures” to “Addressing Nondiscrimination & EO Complaints”.
  • Section II, Part C title has been changed from “Program Grievance Complaint Procedures” to “Addressing Program Grievance Complaints”.
  • Section II, Part D title has been changed from “Incident Report Complaint Procedures” to “Addressing Incident Report Complaints”.
  • Section III title has been changed from “SDWP Complaint Procedures” to “The Workforce Partnership Complaint Processing Procedures”.
  • Section II, B and C have been expanded to include additional guidance regarding requirements of Subrecipient complaint policies & procedures.

Action:

Effective April 18, 2019 all WIOA Subrecipients are required to follow the guidelines outlined in the Chapter and attachments. If you have any questions regarding this issuance, please contact your Contract Administrator at (619) 228-2900.

References:

  1. To access the chapters and their attachments, go to workforce.org and click on the collapsed menu icon located on the top right hand side of the webpage.
  2. Click on “Operations Resources” section.
  3. Click on “Operations Manual” to see the list of chapters and operational issuances.
  4. Click on “Attachments” next to any chapter to view the policy and attachments.