Narrative: III. b. 8.

ADDRESSING THE ACCESSIBILITY OF THE ONE–STOP DELIVERY SYSTEM UNIVERSAL ACCESS: A SUSTAINED EFFORT Building on two rounds of funding under the Disability Employment Initiative (DEI), initial steps to provide more comprehensive physical and programmatic access have begun. The Disability Employment Initiative has increased understanding of sensitivity to the complexity of universal access. Given limited human and financial resources, Maine proposes to chart a five year course of improvement leading to institutionalized practices that ensure and sustain universal access. A universal access working group composed of key personnel will be established to implement this effort. Initially, the group will have wide representation that includes the required WIOA partners, related partners/providers, and subject matter experts with backgrounds in accessibility, accommodations, and special populations. Working group membership/representation will be fluid, based on the issue or need being addressed. A universal access coordinator will lead the work group. This dedicated staff position in the Bureau of Employment Services will provide technical assistance to aid the one–stop centers in achieving and sustaining universal access. This Bureau oversees physical access to one–stop centers, the customer complaint resolution process, policy development that affects the delivery of services, and monitoring/certification of one–stop centers. The universal access coordinator will provide technical assistance to aid the one–stop centers in achieving and sustaining universal access. The Bureau will establish MOU’s or other agreements with Bureau of Rehabilitation Services, Bureau of Unemployment Compensation, the Adult Education program, Bureau of Human Resources, Office of Family Independence, Office of Adult and Disabled Services, and other non–labor agencies (i.e. Corrections) to establish commitments to system wide universal access. To establish universal access as a policy and quality assurance initiative, the universal access coordinator will have the authority of a program manager working under the Division of Policy and Evaluation. Under the direction of the universal access coordinator, the work group will draft a five year plan to improve and sustain universal access and when indicated, make recommendations to the State Board through its program policy committee, and directly to the Commissioner of Labor, when indicated, to emphasize department wide authority and support for accessibility. If warranted and if resources allow, the work group will conduct a staff development needs assessment. Planning will include initial and ongoing staff training and an updated assessment of physical accessibility for one–stop centers, WIOA partner provider facilities, vocational rehabilitation providers, and adult education programs. Policy issues will be identified; and guidance will be provided to one–stop centers, local workforce boards, and required partners. That guidance will be refined over time as policies are developed and monitoring/certification activities occur. SECTION 188 CHECKLIST The WIOA Section 188 Checklist developed by the USDOL Office of Civil Rights will be the guiding document for the working group. The checklist is considered a comprehensive overview of requirements and provides reliable advice on achieving and sustaining universal access.

LEVERAGING EXISTING RESOURCES AND CONSTITUENT COMMITTEES Maine will build and maintain a system that includes access based on language, race, national origin, religion, culture/ethnicity, ability/disability, age, sex/gender identity, and all other protected classes under WIOA, the Americans with Disability Act, applicable state laws, and other federal laws related to public access and civil rights. The working group will establish minimum standards of access, based on the Section 188 Checklist, and issue guidance to the system and its partners to help them meet the standards. The Maine State Board has several committees designed to address the workforce needs of specific constituencies, including women, older workers, younger workers, veterans, and people with disabilities. These committees will be asked to advise the universal design working group on programmatic and physical access and to assist with policies and operational guidance to assure that the one–stop system and its partners are accessible and meeting requirements. Other organizations serving and representing job–seeking constituencies, including migrant and seasonal workers, “displaced homemakers,” ex–offenders, populations whose identities are based on culture/ethnicity/religion, youth, people with disabilities, and older Mainers will be consulted and invited to participate in planning, policy review, staff training, testing and evaluating programmatic and physical access, including customer service. The State Rehabilitation Councils for the General and Blind VR programs, as well as related councils for the Deaf/Late Deafened/Hard of Hearing and Development Disabilities, will also be included. Focus groups and surveys of customers and larger affected populations will be used to determine if accessibility goals are being met. Universal access for employers/businesses will be explored and addressed as well. Business organizations will be consulted for their input, and employer accessibility that falls under Section 188 will be assessed. Program or policy efforts that come from that assessment will be incorporated into the working group’s strategic plan. CORE PRIORITIES Developing a vision and working definition of universal access is essential. Maine does not have all the human and financial resources to implement and sustain universal access without a commitment to a long term initiative. Therefore, the initial priority is the development of a five–year strategic initiative, with each year’s efforts building on and refining prior efforts. The system’s vision of universal access will dictate the goal(s) and will provide the destination for the five year course. Determining how to best inspire system investment will be part of the working group’s charge. Staff training and initial policy development will follow quickly. Training: Professional development for any major systems or operational change is one of the best guarantors of sustainability. With the goal of sustained competence related to serving diverse populations and with related policies in mind within the workforce development system and among partner agencies, the work group will develop a training plan that is compatible and synchronized with other staff training. The objective of the universal access training efforts is sustained competence related to serving diverse populations and knowledge of related policies across the system and among partner agencies. Training for employees will include information on locating and providing access to needed resources such as translators and interpreters, transportation services, and alternative formats. The Section 188 Checklist will inform training topics and plans for managers, supervisors, and facility operations staff. Initial training for staff and partners will include, at a minimum: • General orientation to universal access, WIOA and other legal requirements; • Customer service–both culturally sensitive service and general customer service; • Resources within the system and in the larger community; • Complaint resolution. A variety of training approaches will be considered and deployed, depending on available financial and human resources, training topics, and other conditions. Co–training with and for partners will be considered to best use resources and help system partners’ staffs to “be on the same page.” Blending and braiding training resources will be a guiding principle. All one–stop center staff will be trained and required to demonstrate competency in serving diverse populations and knowledge of related policies across the system and among partner agencies. One–stop center certification will depend on demonstrating that employees have achieved the required competencies in universal access. Policies: Existing policies will be reviewed and updated to reflect WIOA intent and to meet the standards articulated in the Section 188 Checklist. Universal access policies that will govern one–stop center certification will be developed in collaboration with the Bureau of Employment Services’ Division of Policy and Evaluation and the State Board Program Policy Committee. Examples of immediate policy priorities include assistive technology and equipment responsibility, website/social media accessibility, programmatic and physical accessibility of workshops and events, service animal protocols, customer flow for the employment network, prohibition of automatic referrals to vocational rehabilitation, alternative formats for required tests/assessments, and consistent use of equal employment and accommodations tag lines. Program participation rules governing required orientation workshops, the RESEA program, and other mandatory programs will be examined to ensure full accessibility, especially access to alternative formats and accommodations. The feasibility of a central accommodations fund and various ways of ensuring/maintaining its solvency will also be explored. DOMESTIC VIOLENCE AND OTHER CHALLENGES TO ACCESS Maine is a leader among states in ensuring that domestic violence victims have legal protections to avoid job loss and loss of unemployment insurance benefits due to domestic violence counseling, treatment and court appointments. The universal access working group will examine how domestic violence affects physical and programmatic access to services and make any necessary changes to address this situation. Similarly, the working group will explore the potential implications of low literacy, financial hardship, and poor housing/homelessness on access to services. Policies and practices designed to mitigate the most challenging circumstances will be investigated in collaboration with low–income individuals, people who are homeless, and the organizations representing them.

MONITORING PROGRESS The Section 188 checklist and policies will be used to monitor the system’s progress toward universal access. Quantitative outcomes will be used, when practical, to assess system accessibility and utilization by WIOA’s priority populations. Best practice models from other systems and other states will be researched and tailored to Maine whenever possible.

Requested Revision; Building on our experience with the Disability Program Navigators grant and two rounds of the Disability Employment Initiative, the Bureau of Employment Services is already in the process of drafting, adopting, and promulgating two policies, one on nondiscrimination and one on accessibility, which will be distributed to local workforce development boards, their chief elected officials, one-stop operators/managers/staff, eligible training providers, and all entities awarded WIOA funds. The policies will cover non-discrimination and access for all classes under Section 188. The policies define and prohibit discrimination, and will require, as appropriate, the provision of auxiliary aids, assistive technology, adaptive equipment, and accommodations, along with physical accessibility, technological/internet accessibility, EEO requirements, and public notice of the availability of auxiliary aids/services and accommodations. The policies will also reference procedures for filing complaints, which are already contained in our CareerCenter Customer Complaint Manual. Current staff people are familiar with the manual and it is available on the shared drive for reference. Staff training includes customer complaint protocols and is part of the core training that we plan to provide to required partners. The policy also requires the State and Local Boards to post required notices, meeting agendas and minutes, and other information and to ensure that their websites, meeting spaces, and documents meet current accessibility standards. Compliance with the policies will be required for one-stop certification. WDBs and operators will develop protocols to assist front-line staff in partner agencies on how to identify appropriate services for individuals and deliver them in an accessible and non-discriminatory fashion. All front-line staff will be informed/reminded of the procedures for handling customer complaints related to discrimination or lack of access. Customer service training will be provided to all front line staff within three months of hire, and after that annually. Managers, in collaboration with BES and the WIOA staff development group, will be responsible for providing and documenting this training, WDBs and operators will be responsible for developing mechanisms to deliver information on local workforce development system resources in an easy-to-access manner, They will conduct outreach to inform the public of these resources. Workforce development system partners and community agencies will also be informed of these resources and how to assist clients and participants in accessing and navigating the workforce system’s resources. In accordance with §678.800, WDBs will be responsible for ensuring that these provisions are implemented. Monitoring will include compliance with these policies. WDBs will assess their one-stops at least once every three years. They will also review and update any criteria when conducting any program reviews or when updating their local plans. When monitoring or other activities reveal a need for system-wide technical assistance, policy updates, or concerns related to non-discrimination and accessibility, the Bureau of Employment Services may provide or assist with providing the necessary TA. We will use the Section 188 checklist, Promising Practices In Achieving Universal Access and Equal Opportunity: A Section 188 Disability Reference Guide, and the USDOL’s Integrated Service Delivery Toolkit to assist system partners, providers, and local boards with guidance on developing their own monitoring tools. Implementing and monitoring compliance with these policies will be overseen by a universal access coordinator and a core Universal Access work group of system stakeholders and subject matter experts from the larger community, including the Alpha One (independent living center), Disability Rights Maine, the state ADA coordinator, Maine CITE (designated adaptive technology provider for the Maine Department of Education), NAMI Maine, and other agencies and entities with relevant expertise in both accessibility and non-discrimination. Members of the state or local workforce boards will be included. The Bureau of Employment Services will implement standard operating procedures that include a designated Assistive Technology specialist in each one-stop. The specialists’ responsibilities will include routine inventories of equipment. One-stop managers will be responsible for ensuring that all assistive technology and adaptive equipment are functioning, and that adequate resources are available to replace/repair equipment, update assistive software, and obtain new equipment when needed. The Bureau of Employment Services will also continue to operate a Ticket-to-Work workforce employment network through the one-stops, ensuring that people receiving federal SSI and DI benefits are served by the workforce system. One-stop managers will designate at least one Ticket-to-Work specialist in each office. Staff training to ensure compliance with Section 188 and ADA/ADAA As part of the state’s implementation of WIOA, the Universal Access work group and the WIOA staff development group will be responsible for providing system-wide training to all required partners’ management and staff. This training will be incorporated into the larger training plan for WIOA implementation. The Universal Access work group will help the broader WIOA staff development group with integrating these trainings into its training plan for WIOA-required partners. Training to be provided in the first six months to a year following approval of the state’s WIOA strategic plan: • Orientation to the Maine workforce development system’s non-discrimination and accessibility policies, including WIOA section 188 • Orientation to the principles of universal access • Customer service training that is culturally and disability sensitive, including an initial interviewing procedure to mitigate “automatic referrals” to vocational rehabilitation • Basic disability awareness and etiquette • ADA/ADAA and Maine Human Rights Act • Job accommodations-legal requirements and how to assist customers (employers and jobseekers) with requesting and negotiating accommodations • Encouraging disability disclosure in the CareerCenter, and how to correctly document the disclosure in the customer case management system • Identification of language interpretation resources and how to access them for customer communications (both ASL and spoken languages) • Use of assistive technology and adaptive equipment in the CareerCenter and customer access to additional assistive technology and adaptive equipment • Customer complaint protocols • General resources on disability and language access Managers and supervisors, in collaboration with our WIOA staff development group, will provide training to new hires, and on an annual or biennial basis to all staff. The training will be recorded; and some training will be offered through online training providers, such as the New England ADA Technical Assistance Center and other regional ADATACs. The Bureau of Rehabilitation Services, Maine Department of Education, and other agencies (such as those named above as Universal Access work group members/resources) will provide, or help provide, training. Examples of other training to be offered, either concurrently or after initial training has been completed. • Hidden disabilities • Deaf culture • Blind culture • Mental health first aid • Service animals • Accessing community resources • Creating accessible documents The WIOA staff development group will identify a method for documenting compliance with training requirements for implementation by supervisors and managers. Documentation will be a required element of one-stop certification and monitoring. The Universal Access work group or its coordinator, in concert with the Bureau of Employment Services Director of Policy and Evaluation. First three months: • Universal Access Work Group formed, coordinator identified/designated • Group meets, identifies its charge, and begins developing training plan Months 6 – 12 • Training providers and modalities identified, plan drafted • Training schedule developed • First set of training provided to all staff Year 2: • Monitoring and one-stop certification tools related to section 188 developed • Monitoring and certification tool tested, revised as needed • Training revised as needed, based on initial delivery • Training continues for new hires and incumbent staff Years 3 – 5 • One stop certification and local monitoring conducted • Issues identified in certification and monitoring process are addressed as appropriate (technical assistance, training revisions, policy revisions) • Training revised as needed • Training is now ongoing and routine • WIOA state strategic plan updated as needed