Narrative: III. b. 8.

The Determining the Location of a Minnesota WorkForce Center policy requires that the "The WFC location will be accessible to all populations including individuals with disabilities." The Office of Diversity and Equal Opportunity is the final authority in determining if a location meets the accessibility criteria to be certified as a WorkForce Center.

The Minnesota WorkForce Center System Certification Standards policy provides guidance on the implementation standards for the equal access obligations under WIOA. WorkForce Centers must be universally accessible to all populations including but not limited to various racial and ethnic groups, persons for which English is not their first language, ex— felons, people who are homeless, Veterans, various age groups, different genders, and individuals with disabilities.

All partners are covered by Title II of the ADA and the equal opportunity and nondiscrimination elements of Section 188 of WIOA and, therefore are subject to the same standards.

PROVIDE ARCHITECTURAL ACCESSIBILITY FOR INDIVIDUALS WITH DISABILITIES

The WorkForce Center System provides integrated program services through the development and maintenance of an accessible environment. All facilities open to the public as well as administrative offices must be accessible to and useable by the broadest population. All partners are covered by Title II of the ADA and the equal opportunity and nondiscrimination elements of Section 188 of WIOA and, therefore, are subject to the same set of standards.

The Determining the Location of a Minnesota WorkForce Center policy states, "DEED must ensure that all services are compliant with applicable laws, regulations and policies. DEED may therefore, withhold certification and/or funding from a location that does not meet the criteria established in this and related policies and laws." The Policy goes on to state, "the WFC location will be accessible to all populations including individuals with disabilities (see Site Selection document for guidance.)"

The Section of the Policy titled Minnesota WorkForce Center System Certification Standards provides detailed information regarding the criteria and the process for selecting, remodeling or moving a WorkForce Center. WorkForce Centers must meet the standards set forth in the Policy. The Policy identifies the tools used to assist in evaluating and determining access requirements. They include: • The ADA Site Selection Criteria and Access Standards — The standards were developed to assess the accessibility of potential WorkForce Center (WFC) locations and identify the building elements that are critical to program access. The standards address the obligation by all WFC partners under Section 504 of the Rehabilitation Act, Title II of the Americans with Disabilities Act (ADA) and Section 188 of the Workforce Innovation and Opportunity Act (WIOA). • The site and building element descriptions are intended to help determine if a site location has the most basic accessible features to ensure equal access to participants with disabilities. If the site does not have the required features, modifications can be made to create improved access. It is imperative that a review be conducted prior to lease negotiations so that access issues can be addressed and remediated. • It is the responsibility of DEED and its partners to choose sites that are accessible to and usable by the broadest population. DEED, as the designated state agency for WIOA implementation, is responsible for oversight and implementation of access standards regardless of the WIOA entity that holds the lease. • During site reviews, the ADA Checklist for Existing Facilities is used. The checklist is based on the 2010 ADA Standards for Accessible Design. The Institute for Human Centered Design and the ADA National Network developed the checklists. Using the checklists, a comprehensive review is done on sites, including approach and entrance, access to goods and services, toilet rooms, and additional access. DEED developed a review schedule for all Comprehensive WorkForce Centers. Site visits for recertification of the 48 WorkForce Centers are scheduled on a three—year cycle Comprehensive WorkForce Centers that are newly developed, remodeled or relocated are included in the review and are prioritized. There is generally an eighteen month lead time on remodeling or relocation. Affiliate WorkForce Centers are required to provide full access and opportunities to all job seekers including serving individuals with disabilities. Physical locations, services and programs must comply with Section 188 of WIOA and provisions of the American with Disabilities Act of 1990, as amended. DEED will work closely with Affiliate WorkForce Centers to have them provide an annual assessment on architectural and programmatic accessibility for individuals with disabilities. A review schedule for Affiliate WorkForce Centers will occur during Program Monitoring Visits. PROVIDE PROGRAMMATIC ACCESSIBILITY FOR INDIVIDUALS WITH DISABILITIES All DEED and its partners WorkForce Centers programs and activities must be programmatically accessible, which includes providing reasonable accommodations for individuals with disabilities, making reasonable modifications to policies, practices, and procedures, administering programs in the most integrated setting appropriate, communicating with individuals with disabilities as effectively as with others and providing appropriate auxiliary aids or services, including assistive technology devices and services, where necessary so individuals with disabilities have an equal opportunity to participate in, and enjoy the benefits of the program or activity.” DEED has developed a variety of methods to ensure that its programs and activities are universally accessible to individuals with disabilities. They include: • The Minnesota WorkForce Center System Certification Standards discussed earlier identifies both physical and programmatic accessibility requirements. Customers with disabilities must be able to participate and benefit from the services available in the WorkForce Center System, as do all customers. In addition to the site accessibility standards, the Policy identifies the following requirements: • Development of an evacuation and safety plan • Notice displayed and available in alternate formats upon request • Inclusion of tag lines • Identification of Minnesota Relay • Availability of accommodation and modifications • Staff knowledge of assistive technology • Use of auxiliary aids and services • Community resources • Complaint processes. • Technology standards have been developed for all WorkForce Centers. Assistive technology available in the WorkForce Centers includes Pocket Talker, Zoom Text, Jaws, and TV/VCR with built—in captioning decoder, OVAC 210, Optelec CCTV (in selected sites), large screen monitor, and UbiDuo. Each WorkForce Center has an accessible computer station that includes software and hardware that provides access enhancements. The notice of the availability of these products and services is widely distributed among WorkForce partners for use by all consumers. As Resource Area equipment is updated, the access stations also receive updated hardware and software. In 2014, DEED did an assistive technology upgrade in all the WorkForce Centers. The JAWS software and Zoom Text was upgraded to the most recent version. In 2018, DEED will review the assistive technology in all the WorkForce Centers and may recommend the use of new assistive technologies. • DEED’s Policy and Procedure Manual (PPM 215), Office Identification Policy includes requirements for interior signage. The policy provides information on character proportion, character height, raised/Brailed characters, contrast, placement height and pictorial symbols. • All WorkForce Center staff must be trained in and promote the use of Minnesota Relay or a customer’s preferred relay service. A relay service is used to effectively communicate with individuals who have speech, hearing, or other disabilities. ARE ABLE TO COMMUNICATE WITH INDIVIDUALS WITH DISABILITIES AS EFFECTIVELY AS WITH OTHERS Public entities are required to ensure that applicants, participants and members of the public with disabilities have communication access that is equally as effective as that provided to people without disabilities. Since the majority of information in today’s environment is available primarily through electronic means, DEED’s public website provides program and customer information in a user—friendly venue. When developing, purchasing, maintaining, or using electronic and information technology, DEED and its partners must utilize electronic and information technologies, applications, or adaptations which: 1) Incorporate accessibility features; 2) Are consistent with modern accessibility standards, such as Section 508 Standards (36 CFR part 1194) and W3C’s Web Content Accessibility Guidelines (WCAG) 2.0 AA; and (3) Provide individuals with disabilities access to, and use of, information, resources, programs, and activities that are fully accessible, or ensure information provided by the electronic and information technologies are provided to individuals with disabilities in an equally effective and equally integrated manner. MN.IT’s Office of Accessibility provides services and technical support to the State of Minnesota executive branch. MN.IT has set standards for IT Accessibility. On their website a page is devoted to accessibility information for state agencies. It includes information on creating electronic documents, an information implementation toolkit for accessibility, and tools, training and testing information for creating accessible videos, podcast and webinars. The Chief Information Accessibility Officer is a dedicated position within MN.IT that is focused solely on assisting state agencies in identifying solutions to technology access issues. Accessibility has been a central focus for the web development team. DEED’s accessibility resources in the Vocational Rehabilitation Unit as well as staff at State Services for the Blind continue to be involved in any webpage updates ensuring accessibility for the blind and visually impaired, as well as users who are Deaf or hard-of-hearing, or who have mobility impairments, and those with cognitive and reading disorders. DEED’s web development team strives for accessibility that extends beyond minimum compliance. If, however, users are unable to access information, they may request information in alternate formats and it will be provided in a timely manner. STAFF TRAINING AND SUPPORTS DEED’s Workforce Coordination Training Team is able to provide on—demand training for all WorkForce Center staff and partners. These trainings can be in person or webinar based depending on the topic and need.