Narrative: III. b. 8.

WIOA SYSTEM ACCESSIBILITY FOR ALL MARYLANDERS

Maryland’s WIOA oversight entities are committed to ensuring that individuals with disabilities have equal access to all WIOA covered programs and activities. The State of Maryland will ensure that sub-recipients establish and implement appropriate procedures and processes under the Americans with Disabilities Act (ADA) and Rehabilitation Act -Title IV.

The State of Maryland has taken necessary steps to identify compliance under Section 188 of WIOA which contains provisions identical to those in Section 188 of WIA. Additionally, the State will ensure that all local workforce areas comply with provisions that prohibit discrimination against individuals who apply to, participate in, work for, or come into contact with programs and activities that receive financial assistance from USDOL, United States Department of Education, and the U.S. Department of Health & Human Services.

Section 188 of WIOA prohibits discrimination on the grounds of race, color, religion, sex, national origin, age, disability, or political affiliation or belief, among other bases. Section 188 also requires that reasonable accommodations be provided to qualified individuals with disabilities in certain circumstances. American Job Center are expected to meet the needs of their customers by ensuring universal access to their programs and activities for all eligible individuals. Universal access includes performance of the following functions:

• Understanding local needs • Marketing and outreach • Involving community groups and schools • Effecting collaboration, including partnerships and linkages • Staff training • Intake, registration and orientation • Assessments and screening • Service delivery

Maryland’s American Job Centers are required to provide reasonable accommodation for individuals with disabilities to ensure equal access and opportunity. The term “reasonable accommodation” is defined as “modifications or adjustments to an application/registration process that enables a qualified applicant/registrant with a disability to be considered for the aid, benefits, services, training or employment that the qualified applicant/registrant desires;” or “modifications or adjustments that enable a qualified individual with a disability to perform the essential functions of a job, or receive aid, benefits, services, or training equal to that provided to qualified individuals without disabilities,” or “modifications or adjustments that enable a qualified individual with a disability to enjoy the same benefits and privileges of the aid.” American Job Center will make visible to participants that:

• Section 188 implements the nondiscrimination and equal opportunity provisions of WIOA, which are contained in Section 188 of the statute. • Section 188 prohibits discrimination on the grounds of race, color, religion, sex, national origin, age, disability, political affiliation or belief, among other bases. • Section 188 also requires that reasonable accommodations be provided to qualified individuals with disabilities in certain circumstances.

The State expects local providers to acknowledge in local plans and/or policies that they understand that, while Section 188 regulations ensure equal opportunity for individuals with disabilities, sub-recipients may also be subject to the requirements of:

• Section 504 of the Rehabilitation Act, which prohibits discrimination against individuals with disabilities by recipients of Federal financial assistance • Title I of the ADA, which prohibits discrimination in employment based on disability • Title II of the ADA, which prohibits State and local governments from discriminating on the basis of disability • Section 427 of the General Education Provisions Act • Maryland Anti-Discrimination laws

MONITORING OF SITES

For WIOA programs under DLLR’s oversight, in order to confirm compliance under Section 188, DWDAL State Regional Program Monitors will conduct an onsite review. Prior to the commencement of the visit, the Monitor will confirm with the Program Manager or Director that notification of the visit was received, staff are aware, and requested information prior to the visit is unchanged. The Program Monitor will observe the site’s triage system, confirm that appropriate federal signs are visible to participants, and examine the kiosk to confirm that appropriate WIOA, Veteran, ITA, OJT information is available. A site walk-through will determine whether: • EO Law Posters are in plain sight, centrally located, in needed languages; provide State and local EO Officer contact information • WIOA, Veteran, ITA, OJT Literature is present • EO tagline (inserted and correct); TTY/TDD or Relay Service number when phone number is listed • Accessibility • Disability entrance signage; entrance; parking lot • Accessible stations; Assistive Technology The Monitor will perform a case file review analyzing documentation, intake processes, eligibility determination and access to services based on the laws under WIOA Title I, and Title IV from randomly selected files for the Program year. Tests will be performed using the monitoring tools created by the Monitoring Unit along with instruments provided by DLLR Office of Fair Practices. A report will be developed highlighting any discrepancies, findings or concerns that will be forwarded to the Office of Fair Practice, and the Office of the Assistant Secretary for further review. The WIOA Partners are dedicated to ensuring that subject matter experts in relevant areas, such as disabilities and accessibility, are included in monitoring best practice training and discussions to ensure that WIOA programming is delivered thoroughly and effectively. DORS self-monitors compliance with the provisions of the Americans with Disabilities Act to ensure that all offices, programs, services, technology, and materials are fully accessible to staff with disabilities and consumers with significant disabilities. On a daily basis, staff with disabilities and participants in the Vocational Rehabilitation program monitor DORS for accessibility. Monitoring activities are also conducted by the United States Department of Education, Rehabilitation Services Administration, as well as by state and federal auditors. DHR provides assistance to individuals and families with disabilities applying for or receiving TANF by ensuring equal access to people with disabilities; ensuring that policies, practices, and procedures are modified for people with disabilities where necessary; and ensuring that methods of administration do not discriminate on the basis of disability. Applicants and recipients are provided special accommodations and auxiliary aids such as interpreters for individuals with hearing impairments, large type reading materials for individuals with visual impairments and telephone interviews for those customers who unable to visit a LDSS. Further, specifically with TANF workforce development programs, DHR requires Local Department of Social Services (LDSS) to complete an annual Plan for Achieving Self-Sufficiency. Included in the annual plan are project descriptions for all work program activities. LDSS are required to describe in the plan their assessment, reasonable accommodation and monitoring processes which will include a communication strategy with vendors that provide workforce development services, if applicable. Additionally, DHR conducts monthly technical assistance/monitoring calls and annual on-site monitoring visits with each LDSS, which includes evaluation of ADA compliance. Compliance will be measured, among other things, by the promulgation of policies, tracking of requests for reasonable accommodations and participation in DHR ADA trainings. Finally, monitoring is also conducted by the U.S. Department of Health and Human Services as well as state and federal auditors.