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Plan: Colorado PYs 2024-2027
Combined Plan C

Section: Adult Education and Family Literacy Act Program

Narrative: 4.

Published
Located in:
  • Program-specific Requirements for Adult Education and Family Literacy Act Programs

    The Unified or Combined State Plan must include a description of the following as it pertains to adult education and literacy programs and activities under title II of WIOA, the Adult Education and Family Literacy Act (AEFLA). 

    • Section 427 of the General Education Provisions Act (GEPA)

      EQUITY FOR STUDENTS, EDUCATORS, AND OTHER PROGRAM BENEFICIARIES

      OMB Control Number 1894-0005 Expiration 02/28/2026

      Section 427 of the General Education Provisions Act (GEPA) (20 U.S.C. 1228a) applies to a State applicant submitting a state plan for a formula grant from the US Department of Education.  The State applicant is responsible for completing the GEPA Section 427 form that provides a description of the steps the State proposes to take to ensure all program beneficiaries have equitable access to, and participation in, its Federally funded, State-level project or activity.  The State applicant is also responsible for ensuring that its subrecipient applicants complete the GEPA Section 427 form or a State developed form that sufficiently meets the GEPA Section 427 requirement for any local-level-project and activity and maintains the subrecipients’ responses in the State office.

      GEPA Section 427 Form Instructions for State Applicants

      State applicants must respond to the following four questions:

      1. Describe how your entity’s existing mission, policies, or commitments ensure equitable access to, and equitable participation in, the proposed project or activity.

      2. Based on your proposed project or activity, what barriers may impede equitable access and participation of students, educators, or other beneficiaries?

      3. Based on the barriers identified, what steps will you take to address such barriers to equitable access and participation in the proposed project or activity?

      4. What is your timeline, including targeted milestones, for addressing these identified barriers?

       

      • Applicants identify any barriers that may impede equitable access and participation in the proposed project or activity, including, but not limited to, barriers based on economic disadvantage, gender, race, ethnicity, color, national origin, disability, age, language, migrant status, rural status, homeless status or housing insecurity, pregnancy, parenting, or caregiving status, and sexual orientation.

      • Applicants use the associated text box to respond to each question.  However, applicants might have already included some or all this required information in the narrative sections of their applications or their State Plans.  In responding to this requirement, for each question, applicants may provide a cross-reference to the section(s) in their State Plans that includes the information responsive to that question on this form or may restate that information on this form.

      • Applicants are not required to have mission statements or policies that align with equity to apply.

      • Applicants that have already undertaken steps to address barriers must still provide an explanation and/or description of the steps already taken in each text box, as appropriate, to satisfy the GEPA Section 427 requirement.

      • Applicants that believe no barriers exist must still provide an explanation and/or description to each question to validate that perception, as appropriate, to satisfy the GEPA Section 427 requirement.

      GEPA Section 427 Instructions to State Applicants for their Subrecipient Applicants

      The State grantee provides a subrecipient applicant seeking Federal assistance instructions and guidance for how it must comply with the GEPA Section 427 requirement.  The State grantee determines the form and content of the information a subrecipient applicant must include in its application regarding the steps it proposes to take to ensure equitable access to, and equitable participation in, its local-level project or activity. For example:

      • The State grantee may require its subrecipient applicant to use and submit the GEPA Section 427 form that it is required to submit to the Department; or

      • The State grantee may use a State-developed form that is sufficient to meet the GEPA Section 427 requirement.

      • The State grantee maintains the subrecipient applicants’ responses in the State office.

      Please refer to GEPA 427 - Form Instructions for AEFLA Application Package

4. What is your timeline, including targeted milestones, for addressing these identified barriers?

Section 427 of the General Education Provisions Act (GEPA) (20 U.S.C. 1228a) applies to a State applicant submitting a state plan for a formula grant from the US Department of Education.  The State applicant is responsible for completing the GEPA Section 427 form that provides a description of the steps the State proposes to take to ensure all program beneficiaries have equitable access to, and participation in, its Federally funded, State-level project or activity.  The State applicant is also responsible for ensuring that its subrecipient applicants complete the GEPA Section 427 form or a State developed form that sufficiently meets the GEPA Section 427 requirement for any local-level-project and activity and maintains the subrecipients’ responses in the State office.

 GEPA 427 - Form Instructions for AEFLA Application Package

State applicants must respond to four questions. 

The final of four questions is:

What is your timeline, including targeted milestones, for addressing these identified barriers?

Current Narrative:

AEI takes a multi-pronged approach to ensure compliance with Section 427. 

The mission of the Colorado Department of Education (CDE) is to ensure that all students are prepared for success in society, work, and life by providing excellent leadership, service, and support to schools, districts, and communities across the state. CDE’s vision is for all students in Colorado will become educated and productive citizens capable of succeeding in society, the workforce, and life. The mission of the Office of Adult Education Initiatives (AEI) is to empower adult education providers to effectively serve individuals and communities. AEI’s vision is to contribute to community success through collaboration that transforms individual lives. 

The Office of Adult Education Initiatives (AEI) has taken multiple steps to ensure federally funded adult education programs are providing equitable access to, and participation in, adult education services in regards to students, teachers, and other program beneficiaries with special needs. All applicants are required to describe how they ensure equitable access and participation for students, teachers, and other program beneficiaries with special needs, and address how they help learners to overcome barriers related to gender, race, national origin, color, disability, and/or age through their grant application. AEI monitors the plans submitted for Section 427 compliance.

Additionally, all applicants are required to submit Local Accessible Design Assurance and identify a local point of contact to fulfill the role of their grant’s Accessible Design Coordinator. The purpose of the Accessible Design Assurance is to address Section 188 of the Workforce Innovation and Opportunity Act and ensure compliance with specified federal laws and regulations, including the Americans with Disabilities Act of 1990 (ADA). As described in the assurance, each grantee’s local Accessible Design Coordinator is responsible for:

  • Coordinating with their program director and larger organization, if applicable, to develop and implement a written procedure that describes the implementation of the CDE AEI Accessible Design Policy.
  • Ensuring that learners are informed about the availability of instructional and testing accommodations as part of their enrollment process/orientation and anytime NRS assessment is taking place.
  • Ensuring that program staff are fully trained on the Accessible Design Policy.
  • Ensuring that instructional staff implement and are supported with any accommodations required to meet learners' needs.
  • Ensuring that the program provides fully accessible services that meet reasonable criteria.
  • Evaluating the accessibility of the program’s facilities for individuals with physical impairments and establish a transition plan, if necessary.
  • Ensuring any new construction is accessible. (A site accessibility checklist for on-site facilities is available to assist programs in determining if buildings comply with the ADA).
  • Responding to questions and requests from individuals with disabilities.
  • Collecting and securely filing any learner-provided disability documentation.
  • Documenting and reporting (as applicable) accommodations requested from and provided to individuals with disabilities.
  • Confidentially sharing current information about disabilities with program staff, only as necessary, as supported by the Americans with Disabilities Act (ADA) and the Family Educational Rights and Privacy Act (FERPA).
  • Documenting annual participation in training related to serving learners with disabilities, including the legal rights of learners with disabilities. (Training may include on-site training opportunities provided by the Division of Vocational Rehabilitation (DVR) or other training providers, approved online resources such as Literacy Information and Communication System (LINCS), posted webinars, etc.)
  • Participating in AEI trainings for Accessible Design Coordinator and completing the Programmatic Accessibility course within the first three months of hire.
  • Ensuring supports are available for instructional staff in differentiated instruction and strategies to employ with all learners.

The execution of the assurance and local accessible design plan is monitored by AEI staff at the beginning of each program year and during monitoring. Professional learning opportunities are provided to grantees annually (with a typical frequency of every month) by AEI in collaboration with disability experts from the Rocky Mountain ADA and the Colorado Department of Vocational Rehabilitation. Quarterly to bi-monthly professional development for grantees is provided annually on Justice, Equity, Diversity, and Inclusion (JEDI) to support grantees in addressing any identified barriers to ensuring equitable access and participation. Topics covered include economic disadvantage, gender, race, ethnicity, color, national origin, disability, age, language, migrant status, homeless status or housing insecurity, and sexual orientation.

AEI collaborates with multiple offices and agencies to understand and try to meet the needs of various populations around the state. AEI is fortunate enough to have a longstanding relationship with CDE’s Office of Migrant Education and Office of Culturally and Linguistically Diverse Education. As part of the Colorado Department of Education’s ongoing tribal consultations, AEI is collaborating with the Colorado Commission of Indian Affairs to ensure tribal concerns and needs are reflected in adult education services. AEI takes a multi-pronged approach to ensure compliance with Section 427. The AEI Office also regularly collaborates with the Colorado Office of New Americans and the Colorado’s Office of the Future of Work’s Digital Equity staff to support access to digital navigation and other supports.

AEI provides grantees customer satisfaction survey tools to support their efforts in collecting feedback from adult learners and adult education staff on program access, effectiveness, and inclusivity. Anonymized results of the survey are provided to participating grantees annually to help inform local improvement efforts.

AEI also conducts data validation and monitoring and frequently reviews program data disaggregated by the barriers outlined in the statute against state and local demographic data to spot trends in service provision and technical assistance opportunities. Where areas of improvement around equitable access and participation are identified. AEI designs and provides ongoing professional development and, as applicable, targeted technical assistance and monitoring to support grantees in meeting GEPA requirements. Where improvement needs persist or where non-compliance is ongoing, grantees may be subject to performance improvement and corrective action planning.

AEI views these activities and milestones as an ongoing process to address GEPA requirements and plans to continue the following activities:

  • Grant application GEPA response monitoring
  • Accessible Design Assurance and Local Accessible Design Plan review and monitoring
  • Accessible Design Coordinator training series
  • Programmatic Accessibility Moodle Course
  • Justice, Equity, Diversity and Inclusion training series
  • Customer Satisfaction Surveys (Adult Learners and Adult Education Staff)
  • Data analysis and monitoring
  • Collaboration efforts with the CO Office of New Americans, CO Division of Vocational Rehabilitation, CDE’s Office of Migrant Education and Office of Culturally and Linguistically Diverse Education, the Colorado Commission of Indian Affairs, and other partners supporting equitable access for specific populations