Title VI Plan. St. Coletta of Wisconsin, Inc. Title VI Plan Elements

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1 Title VI Plan St. Coletta of Wisconsin, Inc. Adopted on: 4/28/2014 Adopted by: Ted Behncke, Chief Operating Officer Revised on: This policy is hereby adopted and signed by: St. Coletta of Wisconsin, Inc. Executive Name/Title: Executive Signature: Title VI Plan Elements 1. Policy Statement, Authorities and Citations 2. Notice to the Public 3. Complaint Procedure 4. Complaint Form 5. List of transit related Title VI Investigations, Complaints and Lawsuits 6. Public Participation Plan 7. Language Assistance Plan 8. Minority Representation Table and Description Note: Additional materials will be attached, if required. Page 1 of 19

2 St. Coletta of Wisconsin, Inc. Title VI Plan I. POLICY STATEMENT, AUTHORITIES AND CITATIONS A. POLICY OF NONDISCRIMINATION St. Coletta of Wisconsin, Inc. assures that no person shall on the grounds of race, color, national origin, religion, sex, disability, or age as provided by Title VI of the Civil Rights Act of 1964, as amended, 42 U.S.C. 2000d, The Rehabilitation Act of 1973, as amended, 29 U.S.C. 794, et seq. and The Americans with Disabilities Act of 1990, as amended, 42 U.S.C et seq. be excluded from participation in, be denied the benefits of, or be otherwise subjected to discrimination under any St. Coletta of Wisconsin, Inc. sponsored program or activity. St. Coletta of Wisconsin, Inc. further assures every effort will be made to ensure nondiscrimination in all of its programs and activities including transportation services and transportation-related benefits, whether those programs and activities are federally funded or not. Title VI compliance is a condition of receipt of Federal funds. St. Coletta of Wisconsin, Inc. s Chief Operating Officer and Title VI Coordinator are authorized to ensure compliance with provisions of this policy and with the law, including the requirements of Federal transit laws, specifically 49 U.S.C. 5332, U.S. DOT regulations, Nondiscrimination in Federally-Assisted Programs of the Department of Transportation-Effectuation of Title VI of the Civil Rights Act of 1964, 49 CFR part 21, U.S. DOT regulations, specifically 49 CFR parts 27, 37, 38, and 39, and any other applicable Federal statutes that may be signed into law or Federal regulations that may be promulgated. Chief Operating Officer Date St. Coletta of Wisconsin, Inc. B. AUTHORITIES As required by 49 CFR 21.7, St. Coletta of Wisconsin, Inc. will comply with Federal guidance implementing Federal nondiscrimination laws and regulations, except to the extent FTA determines otherwise in writing. St. Coletta of Wisconsin, Inc. shall comply with 49 U.S.C. 5332, 42 U.S.C. 2000d, and 49 CFR Part 21 in the manner it conducts each Project, undertakes property acquisitions, and operates its Project facilities, including: its entire facilities and its facilities operated in connection with its Project. St. Coletta of Wisconsin, Inc. promptly takes the necessary actions to carry out the laws and regulations, including: notifying the public that discrimination complaints about transportation-related services or benefits may be filed with U.S. DOT or FTA, and submitting information about its compliance with these provisions to U.S. DOT or FTA upon their request. St. Coletta of Wisconsin, Inc. ensure that if it transfers FTA funded real property, structures, or improvements to another party, any deeds and instruments recording that transfer will contain a covenant running with the land assuring nondiscrimination: (1) while the property is used for the purpose that the Federal funding is extended, and (2) while the property is used for another purpose involving the provision of similar services or benefits. Make any changes in its Title VI implementing procedures as U.S. DOT or FTA may request to comply with Title VI of the Civil Rights Act, 42 U.S.C. 2000d, U.S. DOT regulations, 49 CFR part 21, and Federal transit laws, 49 U.S.C Comply with Federal guidance issued to implement Federal nondiscrimination requirements, except as FTA determines otherwise in writing. Extend the requirements of 49 U.S.C. 5332, 42 U.S.C. 2000d, and 49 CFR part 21 to each Third Party Participant, including any: (1) Subrecipient, (2) Transferee, (3) Third Party Contractor or Subcontractor at any tier, (4) Successor in Interest, (5) Lessee, or (6) Other Third Party Participant in its Project. Include adequate provisions to extend the requirements of 49 U.S.C. 5332, 42 U.S.C. 2000d, and 49 CFR part 21 to each third party agreement, including each: (1) Page 2 of 19

3 subagreement, (2) property transfer agreement, (3) third party contract or subcontract at any tier, (4) lease, or (5) participation agreement. As required by U.S. DOT regulations, Nondiscrimination on the Basis of Handicap in Programs and Activities Receiving or Benefiting from Federal Financial Assistance, 49 CFR part 27, specifically 49 CFR 27.9, and consistent with 49 U.S.C. 5307(c)(1)(D)(iii), St. Coletta assures that it will comply with the following prohibitions against discrimination on the basis of disability, of which compliance are a condition of approval or extension of any FTA funding awarded to: (1) Construct any facility, (2) Obtain any rolling stock or other equipment, (3) Undertake studies, (4) Conduct research, or (5) Participate in or obtain any benefit from any FTA administered program, and ensure any program or activity receiving or benefiting from Federal funding that U.S. DOT administers, no qualified people with a disability will, because of their disability, be: (1) Excluded from participation, (2) Denied benefits, or (3) Otherwise subjected to discrimination. The United States has a right to seek judicial enforcement of any matter arising under Title VI of the Civil Rights Act, 42 U.S.C. 2000d, U.S. DOT regulations, 49 CFR part 2. St. Coletta of Wisconsin, Inc. Title VI plan will remain in effect as long as: (1) Federal funding is extended to its project and/or service, (2) Project property is used for a purpose for which the Federal funding is extended, (3) Project property is used for a purpose involving the provision of similar services or benefits, or (4) Ownership or possession is retained of its Project property, or (5) FTA may otherwise determine in writing. ST. COLETTA OF WISCONSIN INC. S CHIEF OPERATING OFFICER St. Coletta s Chief Operating Officer is authorized to ensure compliance with provisions of St. Coletta s policy of non-discrimination and with the law, including the requirements of 23 CFR Part 200 and 49 CFR Part 21. St. Coletta grants compliance function and Title VI coordination shall be performed under the authority of the St. Coletta Chief Operating Officer. ST. COLETTA OF WISCONSIN INC. S TRANSPORTATION MANAGER St. Coletta s Transportation Manager will perform the duties of the Title VI Manager and ensure implementation of St. Coletta s Title VI Federally Funded Transportation Program. The Title VI Manager has other duties and responsibilities in addition to Title VI. This position shall have a direct reporting relationship and access to St. Coletta s Chief Operating Officer. ST. COLETTA OF WISCONSIN INC. S TITLE VI COORDINATOR St. Coletta of Wisconsin Inc. s Human Resources Generalist will perform the duties of the Title VI Coordinator and ensure Title VI compliance in accordance with St. Coletta of Wisconsin Inc. s Title VI Federally Funded Transportation Program. The Title VI Coordinator has other duties and responsibilities in addition to Title VI. This position shall have a direct reporting relationship and access to St. Coletta of Wisconsin Inc. s Chief Operating Officer. II. TITLE VI PLAN IMPLEMETATION AND PROGRAM ADMINISTRATION As authorized by St. Coletta of Wisconsin Inc. s Chief Operating Officer, the Title VI Coordinator is responsible for initiating, monitoring and ensuring St. Coletta of Wisconsin Inc. s compliance with Title VI requirements as follows: A. PROGRAM ADMINISTRATION. Administer the Title VI program and coordinate implementation of the plan. Ensure compliance with the assurances, policy and program objectives. Perform Title VI program reviews to assess administrative procedures, staffing and resources; provide recommendations as required to St. Coletta of Wisconsin Inc. s Chief Operating Officer. Page 3 of 19

4 B. COMPLAINTS. Review written Title VI complaints that may be received by St. Coletta of Wisconsin Inc. following adopted procedural guidelines (see Section III Complaint Procedures). Ensure every effort is made to resolve complaints informally at the local and regional level. C. TRAINING PROGRAMS. Conduct or facilitate programs on Title VI issues and regulations for St. Coletta of Wisconsin Inc. employees; and facilitate Title VI training for appropriate staff and contractors. A summary of training conducted will be reported in the annual update. D. TITLE VI PLAN UPDATE. Review and update St. Coletta of Wisconsin Inc. s Title VI Plan as needed or required. Present updated plan to St. Coletta s Chief Operating Officer for approval. E. ANNUAL ACCOMPLISHMENT REPORT. Prepare an annual accomplishment report of Title VI accomplishments and changes to the program in the preceding Federal fiscal year; identify goals and objectives for the upcoming year as required. F. PUBLIC DISSEMINATION. Work with St. Coletta of Wisconsin Inc. staff to develop and disseminate Title VI program information to St. Coletta of Wisconsin Inc. employees, contractors, subcontractors, consultants and sub-consultants and beneficiaries as well as the general public. Public dissemination may include postings of official statements, inclusion of Title VI language in contracts or other agreements, website postings and annual publication of St. Coletta of Wisconsin Inc. s Title VI Policy Statement in newspaper(s) having a general circulation and informational brochures. Ensure public service announcements or notices are posted of proposed projects, hearing, meetings, or formation of public advisory boards, in newspapers or other media reaching the affected communities. Ensure the full utilization of available minority publications or media; and where appropriate, provide written or verbal information in languages other than English. G. ELIMINATION OF DISCRIMINATION. Work with the Human Resources Department, and other St. Coletta of Wisconsin Inc. departments to establish procedures for promptly resolving deficiencies, as needed. Recommend procedures to identify and eliminate discrimination that may be discovered in any St. Coletta of Wisconsin Inc. process. III. COMPLAINT PROCEDURES ALLEGATIONS OF DISCRIMINATION IN FEDERALLY ASSISTED PROGRAMS OR ACTIVITIES A. Overview These procedures cover all complaints filed under Title VI of the Civil Rights Act of 1964 as amended, Section 504 of the Rehabilitation Act of 1973, Civil Rights Restoration Act of 1987, and the Americans with Disabilities Act of 1990, relating to any program or activity administered by St. Coletta of Wisconsin Inc. of Wisconsin, Inc., as well as to sub-recipients, and contractors. Law prohibits intimidation or retaliation of any kind. The procedures do not deny the right of the complainant to file formal complaints with other state or Federal agencies or to seek private counsel for complaints alleging discrimination. Every effort will be made to resolve complaints informally at the local and regional level. B. Procedures 1. Any person who believes she or he has been discriminated against on the basis of race, color, or national origin by St. Coletta of Wisconsin Inc. may file a Title VI complaint by completing and submitting the agency s Title VI Complaint Form. St. Coletta of Wisconsin Inc. investigates complaints received no more than 180 days after the alleged incident. St. Coletta will process complaints that are complete. 2. Once the complaint is received, St. Coletta of Wisconsin Inc. will review it to determine if our office has jurisdiction, acceptability, a need for additional information, or the investigative merit of the Page 4 of 19

5 complaint. In some situations, St. Coletta of Wisconsin Inc. may request an independent outside agency to conduct the investigation. 3. Once St. Coletta of Wisconsin Inc. decides its course of action, the complainant will receive an acknowledgement letter within five (5) calendar days informing her/him of such action. The complainant will be logged into the records of the Title VI Coordinator, and the basis for the allegation identified including race, color, national origin, handicap/disability, age or sex. 4. St. Coletta of Wisconsin Inc. has 60 days to investigate the complaint. If more information is needed to resolve the case, St. Coletta of Wisconsin Inc. may contact the complainant to respond in writing on the allegations. The respondent will have ten (10) calendar days upon receipt of notification letter, to provide St. Coletta of Wisconsin Inc. with his/her response to the allegations. If St. Coletta of Wisconsin Inc. is not contacted by the complainant or does not receive the additional information within 30 business days, St. Coletta of Wisconsin Inc. can administratively close the case. A case can be administratively closed also if the complainant no longer wishes to pursue their case. 5. St. Coletta of Wisconsin Inc. will prepare a written investigative report within the 60 days of the complaint. The report will consist of narrative description of the incident, persons interviewed, its findings, and recommendations for proper disposition. 6. The recommendations will be reviewed by St. Coletta of Wisconsin Inc. attorneys or their representatives. They may discuss the complaint and recommendations with appropriate staff of St. Coletta of Wisconsin, Inc. The report can/will be modified as needed and made final for its release to the parties involved. 7. Once the investigative report becomes final, oral briefings will be scheduled with each party with in fifteen (15) days. All parties will receive a copy of the investigative report during the briefings and be notified of the respective results and appeal rights. 8. After the investigator reviews the complaint, she/he will issue one of two (2) 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 case will be closed. A letter of finding (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, she/he has 15 days after the date of the letter or the LOF to do so. A person may also file a complaint directly with the Federal Transit Administration, at FTA Office of Civil Rights, 1200 New Jersey Avenue SE, Washington, DC If information is needed in another language, then contact (920) An annual Log of Complaints will be maintained by St. Coletta of Wisconsin Inc. The Log of Complaints will contain the following information for each complaint filed: The name and address of the person filing the complaint The date of the complaint The basis of the complaint The disposition of the complaint Page 5 of 19

6 St. Coletta of Wisconsin, Inc. Title VI Complaint Procedure is made available in the following locations: Agency website, either as a reference in the Notice to Public or in its entirety Hard copy in the central office Available in appropriate languages for LEP populations, meeting the Safe Harbor Threshold. (Not currently applicable as all LEP populations are less than 2% of overall population) Other, HOW TO FILE A TITLE VI COMPLAINT St. Coletta of Wisconsin, Inc. is committed to providing safe, convenient, reliable and courteous transportation for our customers. We realize that no matter how hard we try, you may not always be 100% satisfied with our service. So we can ensure that we are meeting our goal, we encourage your feedback. There are several ways to file a complaint with us. The easiest, most convenient way to file a complaint is to simply call us at (920) The Title VI Coordinator will take your complaint and refer the information to our supervisory staff for investigation. Another option is to submit your complaint in writing. Written complaints can be submitted either through at eweber@stcolettwi.org or by mail to: St. Coletta of Wisconsin, Inc. Attn: Title VI Coordinator N4637 County Road Y Jefferson, WI Written complaints may also be delivered in person to St. Coletta of Wisconsin Inc. between the hours of 8:00 am and 4:30 pm Monday through Friday. No matter the method that you use to file your complaint, be assured that it will be forwarded to our supervisory staff for review and follow-up. All services that St. Coletta of Wisconsin Inc. provides are offered without regard to race, color, or national origin in accordance with Title VI of the Civil Rights Act of If you feel that you have been denied the benefits of, excluded from participation in, or subject to discrimination on the basis of race, color or national origin by St. Coletta of Wisconsin Inc., you have the right to file a Title VI complaint by completing and submitting a complaint to St. Coletta of Wisconsin Inc. and/or the Federal Transit Administration using the Title VI Complaint Form. Page 6 of 19

7 Title VI Complaint Form The St. Coletta of Wisconsin, Inc. Title VI Complaint Procedure is made available in the following locations; Agency website, either as a reference in the Notice to Public or in its entirety and Hard copy in the central office. Section I: Name: Address: Telephone (Home): Electronic Mail Address: Accessible Format Requirements? Section II: Large Print TDD Telephone (Work): Audio Tape Other Are you filing this complaint on your own behalf? Yes* No *If you answered "yes" to this question, go to Section III. If not, please supply the name and relationship of the person for whom you are complaining: Please explain why you have filed for a third party: Please confirm that you have obtained the permission of the aggrieved party if you are filing on behalf of a third party. Section III: Yes No I believe the discrimination I experienced was based on (check all that apply): [ ] Race [ ] Color [ ] National Origin Date of Alleged Discrimination (Month, Day, Year): Explain as clearly as possible what happened and why you believe you were discriminated against. Describe all persons who were involved. Include the name and contact information of the person(s) who discriminated against you (if known) as well as names and contact information of any witnesses. If more space is needed, please use the back of this form. Section IV Have you previously filed a Title VI complaint with this agency? Yes No Section V Have you filed this complaint with any other Federal, State, or local agency, or with any Federal or State court? [ ] Yes [ ] No If yes, check all that apply: [ ] Federal Agency: Page 7 of 19

8 [ ] Federal Court [ ] State Agency [ ] State Court [ ] Local Agency Please provide information about a contact person at the agency/court where the complaint was filed. Name: Title: Agency: Address: Telephone: Section VI Name of agency complaint is against: Contact person: Title: Telephone number: You may attach any written materials or other information that you think is relevant to your complaint. Signature and date required below Signature Date Please submit this form in person at the address below, or mail this form to: St. Coletta of Wisconsin, Inc. Attn: Title VI Coordinator N4637 County Road Y Jefferson, WI Page 8 of 19

9 IV. TITLE VI IMPLEMENTATION ACTIVITIES IN PLANNING ACTIVITIES A. PLANNING ACTIVITIES 1. Public Involvement in Planning Activities & Title VI a. St. Coletta of Wisconsin Inc. shall be a member and actively participate in the Jefferson County Transportation Coordinating Committee, whose purpose is to work towards a locally developed coordinated transportation plan. b. Through the participation in the Jefferson County Transportation Coordinating Committee St. Coletta of Wisconsin Inc. shall invite participation of a cross section of the populace from social, economic, and ethnic groups in the planning process by disseminating written program information through public service announcements in local media, when forming citizen advisory committees or planning board, and requesting involvement. c. To promote inclusive public participation, St. Coletta of Wisconsin, Inc. will use its resources available to employ the following strategies, as appropriate: Provide for early, frequent and continuous engagement by the public. Expand traditional outreach methods. Select accessible and varied meeting locations and times. Employ different meeting sizes and formats. Use social media in addition to other resources as a way to gain public involvement TITLE VI MONITORING PROCEDURES The following sets forth the procedure that will be followed in monitoring the level and quality of transit service provided to minorities in the St. Coletta of Wisconsin Inc. transportation coverage area in compliance with the Title VI regulations. A. QUALITY OF SERVICE Quality of service shall be monitored through customer satisfaction surveys designed to provide information about passenger demographics, trip purposes, and service ratings. B. CORRECTIVE ACTION If inequities in service are identified or perceived by transit users, a review of corrective action will be undertaken. Actions involving service level changes will be addresses through the existing decision-making structure. C. MONITORING FREQUENCY An assessment of service level, vehicle assignment, load factors, and service access was performed in conjunction with the Jefferson County Transportation Coordinating Committee s locally developed coordinated transportation plan and is revised with each grant cycle. Future monitoring reviews will be undertaken when major changes occur and upon publication of new census information. Page 9 of 19

10 TITLE VI NOTICE TO THE PUBLIC St. Coletta of Wisconsin, Inc. Notice to the Public as a recipient of Federal Funding, assures that no person shall on the grounds to race, color, sex and national origin in accordance with Title VI of the Civil Rights Act be excluded from participation in, be denied the benefits of or be otherwise subjected to discrimination under any St. Coletta of Wisconsin Inc. sponsored program or activity. St. Coletta of Wisconsin Inc. further assures every effort will be made to ensure nondiscrimination in all of its programs and activities, whether those programs and activities are federally funded or not. Any person who believes she or he has been aggrieved by any unlawful discriminatory practice under Title VI may file a complaint with St. Coletta of Wisconsin Inc. or with the Federal Transit Administration by filing a complaint with the Office of Civil Rights, Attention: Title VI Program Coordinator, East Building, 5 th Floor-TCR, 1200 New Jersey Ave., SE Washington, DC, For more information on the St. Coletta of Wisconsin, Inc. civil rights program, and the procedures to file a complaint, contact (920) or eweber@stcolettawi.org or visit our administrative office at N4637 County Road Y, Jefferson, WI For more information, visit The St. Coletta of Wisconsin, Inc. Notice to the Public is posted in the following locations: Agency website The following sentence is being added to the St. Coletta of Wisconsin website. If information is needed in Spanish, Chinese or Korean languages, call or eweber@stcolettawi.org. Public areas of the agency office (common area, public meeting rooms, etc.) Inside vehicles Rider Guides/Schedules (Not Applicable) Transit shelters and stations (Not Applicable) Other: St. Coletta of Wisconsin is in contact with several translators that will be translating the Public Notice, Complaint Procedure and Complaint Form documents into the Spanish, Chinese and Korean languages. Language Assistance Plan Overview Title VI of the Civil Rights Act of 1964, 42 U.S.C. 2000d, et seq., and its implementing regulations provide that no person shall be subjected to discrimination on the basis of race, color, or national origin under any program or activity that receives Federal financial assistance. Most individuals in Wisconsin read, write, speak and understand English. There are some individuals for whom English is not their primary language. If these individuals have a limited ability to read, write, speak, or understand English, they are considered limited English proficient, or LEP. Executive Order 13166, Improving Access to Services for Persons with Limited English Proficiency, 1 directs each federal agency that is subject to the requirements of Title VI to publish guidance for its respective recipients clarifying that obligation. The US DOT Policy Guidance Concerning Recipients Responsibilities to Limited English Proficient (LEP) Persons 2 discusses the concept of safe harbor with respect to the requirements for translation of written materials Federal Register 50121, August 16, Federal Register 74087, December 14, Page 10 of 19

11 The LEP Safe Harbor provision stipulation was created to provide access to vital documents in a written format for non-english users who, because of small numbers may not meet the threshold for providing more expansive language access services as identified in the Language Assistance Plan. Safe Harbor requires, at a minimum, a written translation of vital documents (ADA paratransit eligibility forms, Title VI complaint forms, information regarding access to essential services, etc.) for each LEP group that meets the LEP language threshold (5% or 1,000 individuals, whichever is less). Methodology This document uses data from the US Census and the American Community Survey (ACS) to provide a detailed LEP analysis for the service area of St. Coletta of Wisconsin, Inc. The ACS is an ongoing survey that provides data every year giving communities the current information they need to plan services and investments. The ACS publishes data in many forms on the Census Bureau American Fact Finder website The data was accessed at the link listed above and searched by: Topic or Name: State, County or Place: Language Spoken at Home By Ability to Speak English for the Population 5 Years and Over Specify the location - city or county, state and/or zip code Plan Components As a recipient of federal US DOT funding, St. Coletta of Wisconsin, Inc. is required to take reasonable steps to ensure meaningful access to our programs and activities by LEP persons. This document includes the following elements: 1. The results of the Four Factor Analysis, including a description of the LEP population(s), served. 2. A description of how language assistance services are provided by language 3. A description of how LEP persons are informed of the availability of language assistance service 4. A description of how the language assistance plan is monitored and updated 5. A description of how employees are trained to provide language assistance to LEP persons 6. Additional information deemed necessary If information is needed in Spanish, Chinese or Korean languages, call or eweber@stcolettawi.org. St. Coletta of Wisconsin is in contact with several translators that will be translating the Public Notice, Complaint Procedure and Complaint Form documents into the Spanish, Chinese and Korean languages. St. Coletta of Wisconsin, Inc. does meet the Safe Harbor Threshold. Item #1 Results of the Four Factor Analysis (including a description of the LEP population(s) served) Factor 1 Demography St. Coletta of Wisconsin primarily provides programs and services to persons with developmental disabilities and other challenges in Jefferson County. Some programs, services and activities also extend Page 11 of 19

12 into Dane and Waukesha Counties. Based on a review of the American Community Survey (ACS) data in Jefferson, Dane and Waukesha counties, St. Coletta of Wisconsin does meet or exceed the safe harbor threshold. Jefferson County reports a population of 78,038. Of this total, 1,790 and/or 2% of the population speaks English less than well with Spanish as the primary language. Dane County has a population of 454,072. Of this total, 10,153 and/or 2% of the population speaks English less than well with Spanish as the primary language. And, in Waukesha County, there is a population of 366,607. Of this amount, 3,609 and/or 1.6% is identified as speaking English less than well with Spanish as the primary language. The Spanish, Chinese and Korean languages do meet the safe harbor threshold requirement for providing written translation of vital documents. Factor 2 Frequency St. Coletta of Wisconsin, Inc. provides rides to 15,860 persons per year. St. Coletta of Wisconsin Inc. has an open door policy and will provide rides to any person who requests a ride. If an individual has speech limitations, the dispatcher or driver will work with the Transportation Manager and St. Coletta of Wisconsin Inc., if needed to ensure the individual receives access to the transit service. The dispatcher or driver will log each Spanish, Chinese or Korean language related situation on the appointment calendar. These logs are tracked monthly with DOT required ridership documents. Factor 3 Importance St. Coletta of Wisconsin Inc. understands an LEP person with language barrier challenges also faces difficulties obtaining community integration opportunities and that adequate transportation is key to connecting LEP persons to these essential services. St. Coletta of Wisconsin Inc. has identified activities and services which would have serious consequences to individuals if language barriers prevented access to information about or the benefits of those programs. The activities and services include providing emergency evacuation instructions in our facilities, homes and vehicles and providing information to each on security awareness or emergency preparedness. St. Coletta of Wisconsin Inc. s assessment of what programs, activities and services are most critical was determined through contact with community organization(s) that serve LEP persons including those who are deaf or mute, as well as contact with LEP persons themselves to obtain information on the importance of the modes or the types of services provided to the LEP populations. Factor 4 Resources and Costs Even though St. Coletta of Wisconsin, Inc. does not have a separate budget for LEP outreach, we have worked with our admissions and marketing departments to implement low cost methods of reaching LEP persons. Item # 2 Description of how Language Assistance Services are Provided, by Language St. Coletta of Wisconsin, Inc. has access to a bilingual speaking person through the Jefferson County Aging and Disability Resource Center. Item # 3 - Description of how LEP Persons are Informed of the Availability of Language Assistance Service St. Coletta of Wisconsin, Inc. does the following to inform LEP persons of the availability of language assistance services: provide pictograms and other symbols in relevant published materials and strive to employ multilingual staff including sign language. Item # 4 Description of how the Language Assistance Plan is Monitored and Updated Page 12 of 19

13 St. Coletta of Wisconsin, Inc. meets on an annual basis to ensure the Title VI requirements are met including driver training and certifications. Item # 5 - Description of how Employees are Trained to Provide Language Assistance to LEP Persons St. Coletta of Wisconsin Inc. schedules annual employee education on how to meet the needs of LEP populations. New employees are educated on the needs of clients served and how best to meet their needs. An important discussion point is that of language assistance. If a driver or employee needs further assistance related to LEP riders, he/she will work with the Transportation Manager to identify strategies to meet the language needs of the riders/customer. Page 13 of 19

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17 Minority Representation Information A. Minority Representation Table The table below depicts St. Coletta of Wisconsin, Inc. one committee which is related to all aspects of service at St. Coletta of Wisconsin Inc. including transit: Consumer Leadership Council. The demographic data in the table below indicates the participation of minorities on committees and councils is reflective of the demographic makeup of St. Coletta of Wisconsin, Inc.. Body Caucasian Hispanic African American Asian American Native American General Population 95% 2.5% <1% <1% <1% Population Residentially Served 95.5% 1.5% 1% 1% 1% Consumer Leadership Council 96% 0% 0% 0% 4% A. Efforts to Encourage Minority Participation St. Coletta of Wisconsin, Inc. understands diverse representation on committees, councils and boards results in sound policy reflective of its entire population. As such, St. Coletta of Wisconsin, Inc. encourages participation of all its citizens. As such St. Coletta of Wisconsin Inc. strives to include persons of all races on all committees/ councils. As vacancies on boards, committees and councils become available, St. Coletta of Wisconsin, Inc. will make efforts to encourage and promote diversity. To encourage participation on its boards, committees and councils, St. Coletta of Wisconsin, Inc. will continue to reach out to community, ethnic and faith-based organizations to connect with all populations. In addition, St. Coletta of Wisconsin, Inc. will use creative ways to make participating realistic and reasonable. Page 17 of 19

18 List of Transit Related Title VI Investigations, Complaints and Lawsuits Sub recipient: St. Coletta of Wisconsin, Inc. Contact Person: Signature: Date: Check One: X There have been no investigations, complaint and/or lawsuits filed against us during the report period. There have been investigations, complaints and/or lawsuits filed against us. See list below. Investigations 1. Date (Month, Day, Year) Summary (include basis of complaint: race, color, or national origin) Status Action(s) Taken 2. Lawsuits Complaints **In the calendar years of 2012 and 2013 no investigations, lawsuits of complaints were filed. St. Coletta of Wisconsin, Inc. Title VI Complaint Procedure is made available in the following locations: Agency website, either as a reference in the Notice to Public or in its entirety Hard copy in the central office Available in appropriate languages for LEP populations, meeting the Safe Harbor Threshold. (Not currently applicable as all LEP populations are less than 2% of overall population) Other, Page 18 of 19

19 DOCUMENTED PUBLIC OUTREACH DOCUMENTATION The direct public outreach and involvement activities conducted by St. Coletta of Wisconsin, Inc. are summarized in the table below. Efforts include meetings, surveys, focus groups, etc. Information pertinent to each event and/or activity will be provided to WisDOT upon request. Date St. Coletta of Wisconsin, Inc. Department Event Date Publicized / Communication Method (Public Notice, Posters, Social Media) Outreach Method (Meeting, Focus Group, Survey, etc.). Notes (Meeting size and format, location, Number of Attendees, etc.) 8/13/2013 Development 4/30/2014 Human Resources Jefferson County Transportation Committee Meeting Publication Public Notice Public Notice 5/30/2014 Marketing Publication Public Notice 6/30/2014 Marketing Publication Public Notice Meeting Paper Copies of all the Title VI Plan and Complaint forms will be made available at the main corporate office. Title VI Plan and complaint form will be published on website. All vehicles shall posted with the Title VI notice to the public. Sub recipient: St. Coletta of Wisconsin, Inc. Contact Person: Signature: Date: Page 19 of 19