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​The student section will provide information on the civil rights requirements related to serving students in your LEAs.  While all administrative requirements apply to students, and policies must be clearly communicated to students and available for their use, this section highlights the compliance standards related to program access and enrollment, career-related learning, guidance, and placement. ​

 Program Access

​LEAs are required to provide career and technical education course and program offerings in a way that ensures they do not discriminate on the basis of race, color, national origin, sex, disability, or age. Compliance with this standard requires both the establishment of eligibility criteria for enrollment in CTE programs that do not discriminate and the provision of equal access, specifically for students with disabilities and English language learners. In addition, if recruitment activities are conducted then these activities must also be conducted and recruitment materials must be disseminated in a nondiscriminatory manner.

Documentation
  • What documentation can be used to indicate compliance with standards related to eligibility criteria and enrollment?
    • Admission/registration documents
      • ​Enrollment data by program
      • ​Student handbook/course catalog
      • ​Policy and process for admissions into career and technical education programs, which includes directives on pre-admission inquiries
      • ​Waiting list information
      • ​Procedures and criteria for selective admissions for career and technical programs (where there are more applicants than can be accommodated)
      • ​List of non-selected students by demographics and by each selection criteria
      • ​Demographics of selected applicants by selection criteria
      • ​Application or registration form for CTE courses/program
  • What documents can be used to demonstrate the use of policies or accommodations to ensure equal access?
    Documents concerning students with disabilities
    • Example(s) of equipment adapted
    • List of programs in which disabled students have been denied access
    • Procedures for determining need
    • Lists of programs and services offered to both students with disabilities and students without disabilities
    • Description of policy for providing aids and services
    • Description of aids and services available/provided/denied
    • List of materials/resources available for seeing or hearing impaired
    • Number of disabled students denied admission in CTE courses
    • Student handbook/catalog
    • Policies governing use of guide dogs, tape recorders, and note takers
    • Records or equipment schedules for the provision of auxiliary aids and services to students with disabilities
    • Number of disabled students in various courses and programs
    • Programs in which essential requirements or licensing requirements have prevented access
    • List of modifications by program
    • Lists of modifications to tests or test administration
    • Location of accessible testing facility and adequacy of sound and lighting systems
    • Assignment of instructional aides
    • Data on participation in clubs/extracurricular activities by individuals with disabilities
    • Policies and procedures relating to free appropriate public education
    • Section 504 plans, placement records, IEP’s, and similar records of students with disabilities placed in career and technical programs
    • ​Evaluation and placement criteria procedures for 504 plan or IEP

      Documents concerning English Language Learners
    • Procedure for English Language Learner identification and placement
    • Summary of steps taken to increase English Language Learner participation in programs where they have been traditionally underrepresented
    • Specific program enrollment demographics by English Language Learner Status
  • What documents can be used to demonstrate nondiscriminatory recruitment practices?
    • A brochure or information showing the District’s recruitment procedures and activities
    • Recruitment plans and description of recruitment activities
    • Recruitment and promotional brochures/marketing materials, including flyers and newspaper advertising
    • List of recruitment/promotional activities and sites
    • Course catalog
    • Recruitment team demographics and staff demographics
    • Plan for determining primary languages of the community
    • Samples of recruitment materials in other languages
    • Samples of materials in other formats
  • What are some sample recruitment practices? Sample:
    • Information about all CTE programs at Pleasant Valley Technical Education Center is available on the web site. Translation into Spanish can be selected on the web site. In addition, the Pleasant Valley Technical Education Center web site is accessible for individuals with disabilities.
  • What are some alternative forms of recruitment materials? Sample:
    • Pleasant Valley Technical Education Center makes recruitment materials in Braille, large print, audio, and computer-enhanced large print available.
  • Where are these alternative forms of recruitment materials available? Sample:
    • Alternative formats of recruitment materials are available at the Office of Disabilities Coordinator, Information Desk, Counseling Department, and the Admissions Office.
    • Americans with Disabilities Act and Section 508
    • ​The citations for equal access standards can be found by navigating to the homepage and clicking the standards option on the top menu and navigating to access/admissions or by using the following link: https://ilequity.com/standards/access-admissions/program-access
​Definitions
The standards related to serving individuals with disabilities are primarily driven by ADA and Section 508 requirements. The following definitions and articles are provided to assist with interpreting the requirements.
  • Disability
    • ADA (Summary) - Disability with respect to an individual means: a physical or mental impairment which substantially limits one or more major life activities of such an individual; a record of having such an impairment; or being regarded as having such an impairment.
  • “Qualified” individual with a disability
    • ADA (Summary) - Being “qualified” means that an individual with a disability can, with or without reasonable accommodation, perform the essential functions of the employment position that such an individual holds or desires.
    • 504 (Summary) - “Qualified persons with disabilities” means a “handicapped” person who, with reasonable accommodations, can perform the essential functions of the job in question.
  • Reasonable accommodation
    • ​ADA (Summary) - Reasonable accommodations are modifications or adjustments to job-related settings or issues which enable a qualified individual with a disability to compete equally for a desired position, affecting: job application; work environment or circumstances under which position held or desired is customarily performed; equal benefits and privileges of employment which are enjoyed by other similarly situated employees without disabilities.
    • 504 (Summary) - Making facilities used by employees readily accessible and usable by “persons with disabilities.”
  • Undue hardship
    • ADA (Summary) -  “Undue hardship” means an action requiring significant difficulty or expense. In determining whether an accommodation would impose an undue hardship on a covered entity, factors to be considered include: nature and cost; overall financial resources of the facility or facilities involved (including the number of persons employed at such facility and the effect or impact on expenses and resources); overall financial resources of entire business; and type of operation, including the structure and functions of the work force, administrative and fiscal relationship of the facility in question to covered business.
    • ​504 (Summary) - The recipient must make reasonable accommodations unless the recipient can show that the accommodation would impose an undue hardship on the operation of its program. Factors to be considered include: size of the program and its budget; type of operation; and the nature of the cost of the accommodation. Denial of employment based on the need to make accommodation is prohibited.
  • Essential Job Functions
    • ​Fundamental job functions that are essential to the employment position. Essential functions do not include marginal functions of the position that are incidental to the performance of the job. Essential functions may include skills, experience, education, or other job-related requirements.
  • What are the key elements of the ADA?
  • What testing accommodations are required by ADA?
  • What are reasonable accommodations?
  • What is undue hardship?
  • What are suggested services for students?

    Adapted from: Center on Education and Work. (1994, September). A handbook for employers, instructors, and teacher educators. Madison, WI.
Resources
The following resources from the US Department of Education and the World Wide Web Consortium provide guidance on ensuring equal access. 

 Career-Related Learning

​If the LEA provides Career-Related Learning then they must provided these opportunities in a nondescriminatory manner. Assurances that employers participating in any on-the-job training also do not discriminate on the basis of race, color, national origin, sex, disability should also be obtained for all work experiences, work study, apprenticeship, and/or other career-related learning.
 
Documentation
  • What documents can be used to indicate compliance with Career-Related Learning Standards?
    • Copies of any cooperative education training plans and agreements and other written agreements with outside businesses or other agencies (i.e., cosmetology contract, aviation contract, etc)
    • Cooperative work experiences, work study, apprenticeship, and/or other career-related learning, placement policies, and criteria for placement
    • Enrollment and assignment data, including hours of work, of students presently in cooperative work experiences, work study, and/or other career-related learning
    • List of programs and activities concerning cooperative work experiences, work study, apprenticeship, and/or other career-related learning
    • Career-related learning materials available in alternate learning formats
  • What essential elements do assurance need to contain?
    • An indication that the employer does not discriminate with regard to race, color, national origin, sex, disability, or age
    • An indication that the employer understands that the community college does not enter into any agreements with businesses which discriminate with regard to race, color, national origin, sex, or disability 
Resources

 Counseling and Guidance

​The LEA should offer counseling and assessment activities in a non-discriminatory manner,ensure that counseling and assessment materials are accessible to all students, and address disproportionate enrollments in CTE courses and programs.  Importantly, counselors also play a central role in supporting strong, equity-focused CTE programs.

Documentation
  • What documentation can be used to indicate compliance with counseling standards?
    • Guidance plan, policy, and procedure
    • Assessment plan with a list of tests administered
    • Written procedures for evaluation and placement of students with disabilities
    • Promotional and recruitment materials
    • Enrollment demographics
    • Recruitment and admission policies
    • Policy regarding services for Limited English Proficiency (LEP) students
    • Calendar of counseling and pre-vocational activities
    • Admission criteria
    • Enrollment forms
    • Enrollment demographics by class/program
    • Examples of pre-enrollment counseling
    • Examples of revised counseling materials or activities in response to disproportionate enrollments
    • Interest and ability assessments
  • What elements could be included in a nondiscriminatory counseling program?
    • Inform students and parents of their protections under the civil rights laws.
    • Analyze course enrollment data to identify disproportionate enrollment of minority, women, and students with a disability.
    • Identify discriminatory practices in existing guidance/counseling program policies and procedures.
    • Establish goals, objectives, and action steps in community college district guidance plans in response to identified career needs of minority, women, and students with a disability.
    • Implement an ongoing career guidance program to meet students’ needs.
    • Ensure effective communication with LEP students and students with disabilities.
    • Provide support through counseling and consultation with teachers, peers, parents, and students.
    • Assist students in such activities as resume writing, job interviewing, decision making, financial aid applications, educational/career planning, and workplace acculturation.
    • Review guidance materials for stereotypes.
    • Identify female role models as well as role models from minority and from persons with disabilities where they are traditionally underrepresented.
    • Coordinate counseling activities with other community college and community resources and agencies serving special population groups.
    • Support the establishment of an equity advisory council to obtain assistance in implementing non-discriminatory counseling services.
Resources

 Placement

​If the LEA provides placement activities or services for students they must not discriminate on the basis of race, color, national origin, sex, or disability.

Documentation
What documentation can be used to indicate compliance with this standard?
  • Placement policies
  • Criteria for placement
  • Employment notices
  • Enrollment data job placement programs
Additional Information
  • How can counselors have an expanded knowledge of career opportunities?
    In order to avoid “steering” minorities, women, and students with disabilities toward more restrictive career objectives, counselors should obtain updated information about the dynamics of the labor force. Community college districts have established programs to ensure that counselors are apprised of the most recent occupational outlook data, including employer-led workshops on emerging opportunities in a specific field. The sessions also allow counselors to gain first-hand understanding of developments and occupational forecasts in specific industries and organizations. In turn, counselors can disseminate this information to students so they can consider a broader range of options.

    Source: US Department of Education. Office for Civil Rights. (1991). The guidance counselor’s role in ensuring equal educational opportunity.  Available at: http://www.ed.gov/about/offices/list/ocr/docs/hq43ef.html

  • How can counselors cooperate with business?
    There are other ways to involve the resources of the business community. Some colleges arrange for minority, women, and persons with disabilities as role models from occupations in which these groups traditionally have been underrepresented (e.g., female physician or male nurse). The role models provide assistance for career days, exploratory experiences, and as advisers to students.

    In addition, some businesses sponsor job shadowing and summer internship programs that combine community college credit with employment. These programs also encourage students’ further educational attainment by linking academic preparation with job requirements. Some counselors arrange for representatives of the business community to conduct group sessions on preparing resumes and job interview skills. While these programs are normally open to all students, counselors can take special measures to ensure the participation of special populations groups.

    Source: US Department of Education. Office for Civil Rights. (1991). The guidance counselor’s role in ensuring equal educational opportunity. Available at: http://www.ed.gov/about/offices/list/ocr/docs/hq43ef.html 

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