Element 4 – Affirmative Action

Purpose

It is the intent of Element Four to address how the State of Idaho (State) and its recipients are complying with the requirements of 29 CFR 38.40 relating to the provision of affirmative outreach to programs and activities.

Narrative

The State has communicated the obligation of recipients (e.g., One-Stop Partners (OSPs), Unemployment Insurance (UI) Wagner-Peyser (WP) and all service providers) to conduct outreach efforts in order to broaden the composition of the pool of those considered for participation or employment in their programs and activities. The State will ensure that recruitment of potential participants is conducted in a nondiscriminatory manner and that the participant pool is a proportionate reflection of the local area as well as individuals with disabilities.

The State uses monitoring tools to ensure that all EO Officers are kept cognizant of their Affirmative Outreach obligations by inquiring into their process of broadening the participation in their programs.

Recipients have made and will continue to make efforts to broaden the composition of those considered for participation or employment in their programs and activities, as described above.

All comprehensive One-Stop Centers must be physically and programmatically accessible to individuals with disabilities, as described in 29 CFR Part 38, the implementing regulations of WIOA Section 188. Technology is a key component in ensuring affirmative outreach by employing a number of strategies to include the following:

• Increased referral services;
• Provision of equal opportunities for workforce training services for both rural and urban areas, as well as for persons with disabilities or other barriers to communication;
• Access to services for persons of all levels of computer literacy; and • Assistance in using the self-service component of the One­Stop Center.

All recipients and sub-recipients work to enhance the employability and increase the earning potential of individuals with multiple barriers to employment. Strategies to address individual needs include: assessments of skills and abilities, basic skills programs, occupational skill training, job analyses, job accommodations, disability awareness training, and other activities that address barriers and support achievement of positive employment outcome. Individuals with multiple barriers to employment are offered a continuum of education, job training, career counseling and job development to enhance attainment and retention of employment. To enhance the employability skill of individuals with disabilities, Local Workforce Development Boards, One-Stop Centers and providers assure:

• Priorities of services for participants beyond the self-service phase are implemented;
• Representation of individuals with disabilities on staff, where feasible;
• Cross-training of staff;
• Disability awareness training for staff;
• Outreach programs for individuals with disabilities;
• Technical assistance to employers including information regarding ADA requirements.

The One-Stop system provides the broadest possible menu for all job seekers. Eligible individuals include:

• Special needs participants;
• Individuals with disabilities;
• Persons with Limited English speaking ability;
• Persons training for nontraditional employment;
• Displaced homemakers;
• Public assistance recipients;
• Veterans;
• Persons with multiple barriers to employment;
• Elderly participants;
• Women;
• Minorities;
• Lesbian, Gay, Bisexual, Transgender & Queer (LGBTQ) communities

Recipients and their service providers strive to provide access to services to clients of both sexes, LGBTQ, the various race, ethnic and age groups, individuals with disabilities as well as individuals with Limited English Proficiency (LEP) which includes:

• Publicity materials (brochures, letters) designed to provide an overview of employment services to the general public;
• Participation: in local and statewide job related events; and
• Coordination and involvement with various agencies, committees, task forces, and projects that focus on employment-related functions, and Wagner-Peyser special programs for targeted groups (e.g., Veterans, Youth, Dislocated Workers, etc.).

One-Stop Centers (OSC) have taken the following actions to ensure affirmative outreach:

• Signs have been posted to inform customers of telephone numbers to call or to see a staff member if an accommodation is needed to receive services;
• Individuals and organizations have been identified and are available if assistance is needed to provide services or information in a language other than English and written procedures are available to staff to assist LEP individuals;
• Employees who have skills in languages other than English have identified themselves and offered their services in assisting any customers by providing instruction, conveying information, or assisting with completing forms;
• Contacts have been developed and maintained with community­based organizations and advocacy groups to ensure the center meets the specific needs of each constituency;
• Coordination linkages with other federal, state and local agencies serving the various segments of the populations have been developed;
• Participation in community employment events such as job fairs, seminars, and public recruitment for employers has publicized the services of One-Stop Centers; and
• On-site visits with employers and community agencies, participation in job fairs, special recruitment efforts, employer seminars, and public relations campaigns have encouraged employer use Idaho’s workforce system.

The State monitors and evaluates the success of recipient efforts to broaden the composition of those considered for participation and employment in their programs and activities, as described above.

The State takes reasonable steps to ensure that policies and procedures do not deny equal access to individuals with Limited English Proficiency (LEP). The State implements, evaluates and documents programs, activities, and services to customers with LEP.

The EO Officers are responsible for monitoring recipient programs and ensuring compliance with the affirmative outreach element of and discrimination and equal opportunity provisions of Section 188 of WIOA. The State continually stresses to recipients the importance of their obligation to expand the diversity of the participant pool and staffing selections.

The State annually monitors the recipients to measure the effectiveness of their efforts to serve and employ a diverse population, including members of genders, various racial, ethnic and age groups, and individuals with disabilities.

In the selection of center locations, consideration is given to accessibility to members of the general population for all programs, services, and benefits.

Current State practices designed to broaden the composition of those considered for participation and employment at the One-Stop Centers include the following:

• Identification of staff with bilingual skills; • Information exchange and collaboration with community organizations regarding translators, interpreters and resources for LEP;
• Publication of selected materials in languages other than English
• Use of interpreters, telephone interpreters and contract interpreters as needed to provide language assistance to customers on a case­by-case basis.