Narrative: III. b. 9.

OWD and its local WDBs are obligated to provide affirmative outreach (formerly universal access) to programs, services, and activities as required in Section 188 of WIOA. OWD and its recipients are responsible for taking the appropriate affirmative outreach steps to ensure equal access to programs and services that include outreaching to various groups protected by Section 188 of WIOA including, but not limited to, persons of different sexes, various racial and ethnic/national origin groups, various religions, individuals with limited English proficiency, individuals with disabilities, and individuals in different age groups.

OWD and its recipients are committed to including a diverse demographic group in all of its programs and services, which include gender, various racial and ethnic groups, individuals with disabilities and different age groups. The nondiscrimination and equal opportunity performance is measured by conducting an annual statistical data analysis utilizing the 4/5th rule and the 2-standard deviation test on all programs, services, activities, and employment practices associated with Missouri’s workforce system. 

Some outreach strategies include, but are not limited to, advertising in community newsletters, newspapers, radio stations, or any other media that could reach targeted populations. This includes sending notices about job openings to schools, local colleges, and community service groups about services and activities offered in the job centers. OWD and its recipients routinely communicate and consult with schools, community groups, and advocacy organizations. 

OWD and its recipients are required to conduct an annual data analysis of programs, services, and employment practices. This annual assessment compares the workforce data of jobseekers utilizing job centers with Missouri’s civilian labor force. The results of this analysis are used to determine future performance goals for the state and its recipients as well as an outreach plan. The outreach plan includes OWD and its recipients identifying current and potential partners such as other government agencies, community-based organizations, nonprofits, and private businesses and organizations that are current WIOA core and combined state plan partners as well as those who could become partners. 

Recommendations are developed based on the data analysis for improving outreach, services and service delivery, as well as labor market strategies. The outreach strategies are intended to be methodologies for making contact with all segments of the population in the local service area, especially those who are currently underserved. The labor market strategies include devising techniques to stimulate the local economy; therefore, generating more employment and skills training opportunities for Missouri jobseekers. Based on the results of the data analysis assessment, the state and its recipients are able to develop outreach and recruitment plans to broaden the pool of those groups for whom the assessment indicates there should be higher levels of employment and participation in programs and services. 

The regional language study may show that there are large groups of people in a local workforce development area who do not speak English or who have very limited proficiency in the language. OWD and its recipients may find local populations that include large groups of people who speak and communicate only in a language other than English. In this case, clearly, a plan should be developed to reach, communicate with, and improve services to those non-English speaking populations.

Effective January 3, 2019, WIOA recipients must also record the limited English proficiency (LEP) and preferred language of each applicant, registrant, participant, and terminee. Such information must be stored in a manner that ensures confidentiality, and must be used only for the purposes of recordkeeping and reporting, determining eligibility, where appropriate, for WIOA Title I-financially assisted programs or activities, determining the extent to which the recipient is operating its WIOA Title I-financially assisted program or activity in a nondiscriminatory manner, or other use authorized by law.

OWD and its WIOA recipients must conduct an assessment of the language needs in each service area. The assessment must involve the identification of the languages that are likely to be encountered in the provider’s service area, estimating the number of LEP individuals who are eligible to receive services or benefits who are directly affected by the provider’s program or activity. It is required that the following four factors are considered to determine the nature of language assistance provided and to ensure the most effective, meaningful access for LEP individuals, participating in or seeking benefits from, the program or activity:

1. The number or proportion of LEP individuals served or encountered in the eligible service population or likely to be directly or significantly affected by program or activity;
2. The frequency with which LEP individuals come in contact with the program or activity;
3. The nature and importance of the program, activity, or service provided by the recipient; and
4. The resources available to the recipient and costs in carrying out the program or activity.

OWD and its recipients must consider the scope of the program or activity for which the population is eligible, the size and concentration of the population that needs services or information, and take reasonable steps to provide services and information in the appropriate languages. This includes making the “Equal Opportunity is the Law” (EO) Notice, brochures, and other materials considered communications available in various language translations. If there is not a large group of non-English speaking people in the local workforce development area, OWD and its recipients are obligated to take reasonable steps to meet the language needs of that person(s). OWD and its recipients provide training to staff to utilize the language line, Language Link, to accommodate customers who are limited in English proficiency. OWD and its recipients also train staff on how to utilize translation and interpreting services.

OWD is in partnership with the Missouri Rehabilitation Services for the Blind and provides the EO Notice in braille and large print formats as well as online for customers with low vision or who are blind. This helps to ensure that communications with individuals with disabilities are as effective as communications with others. 

OWD partners with MERIC to provide ongoing analysis of minority population groups in Missouri that include senior workers, women, African Americans, Hispanics, and Asians. These analyses assist local WDBs and regions on how to recruit and target populations that are underserved in the workforce system. 

OWD and its recipients are expected to meet the needs of their customers by ensuring affirmative outreach to their programs, services, and activities for all eligible individuals. OWD and its recipients promote affirmative outreach by understanding the local needs, marketing programs and services and providing outreach in the communities served. These are accomplished by involving community groups and schools in planning, collaborating with partners, training staff, and ensuring equal and effective service delivery for all individuals.

OWD is in partnership with Adult Education and Literacy and refers English language learners to them for classes in English. This helps to ensure clients improve their economic potential as well as their ability to function in Missouri’s society.