ࡱ> q wbjbjt+t+ " AAӫ]8.N^f"88`iii^^^^^^^$_af9^iNiii9^8`i(8(`^i^4 [44^`\*QL]>Dane County Job Center Physical and Program Access Survey Results Purpose Services and activities provided by the One-stop system must comply with a number of regulations concerning provision of services to people with disabilities. As recipients of federal funds from the U.S. Department of Labor and other federal sources, the One-stop system and One-stop Centers must comply with Section 504 of the Rehabilitation Act. As activities provided or made available by state or local governments, the One-stop system must comply with Title II of the Americans with Disabilities Act (ADA). The One-stop system must also abide by specific regulations on nondiscrimination and equal opportunity for services provided under the Workforce Investment Act (29 CFR Part 37), which focus not only on services for people with disabilities but address equal opportunity for a wide range of other groups and individuals. This is otherwise known as WIA 188. The One-stop system is required to have anticipated the needs of people with disabilities in the physical design of centers, as well as the design of services. Programs or activities of One-stop Centers, when viewed in their entirety, must be readily accessible and useable by people with disabilities. Therefore, people with various physical and mental disabilities should be able to go into a One-stop Center and use many of the available services, without having to make special requests for accommodations. In addition, individuals have the right to ask for accommodations to meet their own specific needs. The overall purpose of this project, therefore, is to review the physical and program accessibility of the Job Centers within Wisconsin, specifically regarding persons with disabilities. Although legal standards are being used as the objective evaluation instrument, this document is not meant to place blame on an individual or point out personal deficiencies in any area. The evaluation instrument was developed in a cooperative endeavor among many organizations. The minimum threshold of legal standards applied all three of the aforementioned laws and regulations. This document will address facts according to specific physical characteristics and reflect experiences that were encountered as a result of reviewing certain aspects of the job center. This document will specifically apply standards of federal law. It is understood that Wisconsin has access standards, but to clarify issues that relate to funding obligations and contract compliance, the federal standards will be emphasized. The document will be used as a means to explore improvements to the job center system for people with disabilities and document best practices. An analysis of the strengths and weaknesses of the Dane County Job Center will be provided with the survey finding, along with recommendations and possible resources. This document is not intended to be a comprehensive analysis of all issues that may or may not involve the Dane County Job Center. Nor should the document be construed as a legal interpretation of any of the regulatory guidance. Project Background The State Independent Living Council (SILC) and the Division of Vocational Rehabilitation (DVR) develop the Wisconsin State Plan for Independent Living (SPIL) every three years. After conducting a comprehensive needs analysis, a significant area of need focused on some weaknesses the Wisconsin One-stop system has had serving potential customers with disabilities. DVR and the Division of Workforce Solutions (DWS) had piqued interest in assessing and improving the One-stop service delivery capacity. Communication has been a key element and has been delivered through the workforce development boards across the state. A core development team comprised of SILC, DVR, DWS and the Great Lakes Business and Disability Technical Assistance and IT Center (DBTAC) has been developing project mechanics. Methodology A proposed project outcome is that a community-based partnership will evolve into a statewide technical assistance network. One method to achieve this outcome is through increased communication and collaboration of existing resources. The project team developed a comprehensive process for assessing the Wisconsin One-stop system. After reviewing evaluation instruments in other states, the project team decided that a new instrument needed to be developed that addressed many program analysis issues that are often overlooked. These include items such as public notice, grievance procedures and the designation of a public employee. Teams were developed to objectively work with the local workforce boards and job center staff. Team leaders from area Independent Living Centers (ILCs) worked with representatives from DVR and DWS to conduct the interview portion of the evaluation. Documents and representatives from individual programs in a given One-stop were identified and requested to participate. Once the assessment was completed, it was forwarded to SILC for review. SILC forwarded the information to the project writer. A project writer provides the opportunity to provide the data with a consistent voice. Although the aforementioned process was uniform, teams were told to modify their methodology according to the local environment. Therefore, the same elements will be analyzed, but the particular approach to obtain the data may vary slightly. The assessment of the Dane County Job Center at1819 Aberg Avenue in Madison, Wisconsin was undertaken on May 20, 2003. Members of the survey team included; Rebecca Patterson, Access to Independence Elayne Moore, DWS Anne Velasco, DVR Dane County Job Center partners present for the physical assessment included: Laura Hutner, Support Services Facilities Manager for Dane County Richard Johnson, ADA Coordinator in Dane County Silvia Mauerman, Employment and Training Coordinator Dane County Job Center partners present for the interview portion of the survey: Silvia Mauerman, Employment and Training Coordinator Mary Pasholk, Employment Services Coordinator The following partners were interviewed via phone on May 30, 2003: Leslie Mirkin, DVR Coordinator Liz Green, W-2 Program Supervisor Dan Kiddle, W-2 Program Coordinator It does not appear as though all on-site partners were interviewed for this survey. The centers website lists the following agencies as located at the Dane County Job Center: Dane County Department of Human Services Job Service DVR Employment and Training Association Forward Service Corporation Over 50 Employment Service Shea Services Tenant Resource Center Madison Area Technical College Wisconsin Development Board of Southcentral Wisconsin The Center offers core, intensive and training services on site and operates M-F on regular business hours. Facts Program Access Integrated Programs All Dane County Job Center partners interviewed for the survey indicated that they have adopted an informal policy of integrating persons with disabilities into programs and services. To the best of their knowledge, no individual has ever been denied services due to a disability. There do not appear to be any formal, written agreements or processes in place to assure equal treatment of the disabled. The ES Coordinator admitted the center sometimes has difficulties getting ASL interpreters on short notice. People will call to register for a workshop, but there isnt enough time to book an interpreter for the event. When asked by the survey team what the center has done to ensure a full range of integrated services, the partners gave several examples. They re-did the pressure buttons on the entrance doors. They put forth a huge effort to get accessible workstations for the center. They have also made accommodations for their various employment tests. They can be given one-on-one in order to be read aloud or to give extra time. The W-2 Program Supervisor added her case managers will go to a persons home if they are unable to come to the center for services. The center also has a wheelchair available at the front door for customers needing such assistance. They can also arrange for transportation for clients if they cannot get their own. When asked to describe policies and practices that would allow an individual with a disability to choose to participate, the partners replied, They do whatever is necessary to make services available for everyone on equal terms. The center has a way of getting materials Brailled by sending them to the county for printing. If someone wants to attend a workshop, but an interpreter cannot be contracted for, they will tape and interpret the workshop later for the individual. That person would also get any materials given out during the event. They also provide employment testing in alternative forms or one-on-one. The center does not appear, however, do have formal policies and practices in place to ensure a disabled individual can participate. B. Staff Development The partners interviewed indicated all staff receives Windmill training provided by DVR. Windmill covers such subjects as anti-discrimination, civil rights, disability and diversity. It is given once a year and is monitored by the state. The partners stated building-wide training was offered last May (2002) through DVR. Its offered once a year, but scheduling depends on funding. The partners also indicated all new hires receive training on disability-related issues. The center has a regular training schedule and a new employee attends the next available training after being hired. All staff has information on what services other programs and agencies provide within the job center, as well as those in the greater community. The case managers for W-2 also receive special training. They get regular training on using interpreters and the TTY. They also receive regular training on civil rights. DVR employees receive regular training in civil rights, accessibility and confidentiality, among others. Many also get training on the use of the accessible computer hardware and software. None of the partners indicated they have a written policy concerning staff development in accessibility issues. There is no formal method to implement training after it is received. No formal method of testing competencies in training or in providing follow-up. The statement was made, Supervisors dont stand over staff shoulders. W-2 cases are monitored randomly on a monthly basis. There are random surveys on customer service done quarterly. That gives an overall picture on how staff is doing. Staff is also free to talk to a supervisor if they feel another staff member is acting inappropriately. The partners felt most customers are very vocal about expressing their complaints. C. Reasonable Accommodations/Modifications  The partners indicated the center has formal procedures in place to deal with accommodation/modification requests. The front desk staff usually gets the request first. They will make sure it gets handled or sent to the right agency or case manager. There is a clerical supervisor for the front room who ensures that accommodations take place. The survey team did not indicate whether they reviewed these procedures or not. The W-2 Coordinator stated the center has a lot of in-house resources. There is also a list-serve to connect the county W-2 program employees. If someone has a question, they can put it on the list-serve so everyone in the county program will see it and have a change to answer. The partners indicated all new employees are trained on these procedures. There is also a procedure manual at the front desk. The survey did not indicate if they reviewed the manual. The center also has cheat sheets in many different locations to act as a quick reference for staff. The procedures are reviewed on an irregular basis. Each of the agencies has a staff person located in the front lobby. These staff members meet regularly. Policies are evaluated during these meetings. The W-2 Coordinator indicated their policies are reviewed annually. The partners stated the determination of undue burden is one that is beyond their authority to make. They have never run into a need for such a determination, but would refer the case downtown for someone to evaluate if they did. They indicated they rely on DVR for advice. They can also talk to the ADA Coordinator. When asked how staff is made aware of the processes required to document a denial, they stated supervisors have the authority to fill out the necessary paperwork in order to send it downtown. In describing their appeal process, the partners stated the complaint goes to the state and it is addressed at a state level hearing. They also stated the center has no process or policy they know of to determine whether a modification would fundamentally alter the nature of the program. They added it was up to the state to decide. It is not clear here if the partners are addressing these issues as state employees or center employees. The survey did not always attribute statements to a given individual. The partners indicated fees are never charged. The Employment Services Coordinator added she believed it was illegal to charge fees. The partners interviewed stated they had never had a situation where they were unable to provide an accommodation. They get complaints, but have always been able to deal with them. D. Communication Resource room staff provided information on those alternate forms of communication available to customers. They indicated, for the most part, information was available in large print, through readers or through computer disks and adaptations. They did not list any information as readily available in Braille, nor did they list an accessible website or audiotape. When listing alternative formats for the hearing impaired, staff included: paper and pen, note takers, interpreters, and as an alternative to a phone to call employers, TTY and Assistive listening device. They did not check telephone amplification, video conferencing, captioned videos or films or CART as being available at the center. Information on job search and placement, resume development, individual plan development, career information, DVR (intake, eligibility, assessments and the programs appeal process), are available through the centers accessible website, according to the three partners who completed the alternative formats section of the survey. The state does not list the Madison job center as having an accessible workstation, but the partners indicated they did. The center has signs giving directions to the TTY. Neither the workforce development nor job center websites have been Bobby AAA approved. Public Notice The partners stated there is no standard language used on center publications to indicate the availability of reasonable accommodations or modifications. They indicated there are disclaimer notices posted on the display cases. Those notices are also on all the materials that go out to customers. All the registration materials have them. The partners also added those disclaimers are included in their brochures, as well as postings on the wall and in ads. They said they make it a point to inform all customers about the accommodations procedures upon registration. This is done both by case managers as well as the resource room staff. The survey team did not indicate if they reviewed any of the centers publications or located any disclaimer notices posted throughout the center. There is nothing on the centers opening web page indicating they will provide reasonable accommodations to customers if requested. There is nothing stating the center and its partners are equal opportunity programs. The centers TTY number is also not listed on that page. The partners informed the survey team every customer registering for services is told about the accommodation policy. The resource room is self-help, unless someone asks for assistance. They indicated there is staff there that will help if needed. There is always a JobNet person available to provide assistance. The survey team did not note if the resource room has signage allowing customers to know such accommodations are available. Everyone who signs up for meeting or training session can participate, according to the partners. They will do whatever they can to allow someone to participate. According to those interviewed, they have not had a problem. The Dane County Job Center utilizes a variety of methods to inform the public about their services. They have their own website, which is also available in Spanish. There are job fairs, mailings, newspaper ads, radio ads and ads in the phone book. The partners indicated that all ads have disclaimers about accommodations. Designation of Responsible Employee It does not appear as though the center has a designated Equal Opportunity Officer. The partners indicated each agency is responsible for complaints about services or staff. If there is a serious complaint, they added, it goes to the areas DVR supervisor. The survey did not indicate if there is any information posted or listed that identifies the location of the responsible employee as Equal Opportunity Officer. (WIA Section 37.26) The partners stated staff is informed of the centers complaint policy during orientation. It is also in the procedural manual. There was no indication as to how they inform the public. From the responses provided by the partners during the interview, it is not clear if they understood to what the questions really pertained. Complaints The Dane County Job Center has a written policy and procedures for dealing with customer complaints and grievances. It is included in the centers procedural manual and staff is informed of it during orientation. The partners indicated disability-related issues or concerns are handled at the agency level, unless it is a physical issue about the building. A staff member is supposed to talk to the person to attempt to resolve the issue. If that is not possible, they are instructed to take the issue to a supervisor. The partners also indicated any official publication would have the information on the complaint procedure. This would include newsletters, intake paperwork and registration forms. The survey team did not mention if they reviewed any materials for this information. No mention was made by the partners of the centers Complaint Coordinator. Nor did the survey note the posting of any information as to the identity or location of that individual. The states universal menu of services for this center list two individuals as the complaint coordinator(s). Evacuation The center has formal policies and procedures concerning the emergency evacuation of the facility. Partners indicated that it is regularly communicated to all staff, partners and customers. It is part of a manual. They also have cheat sheets available to staff to reinforce their training. The facility has visual and audible alarms. There is also a center-wide intercom system. It is the responsibility of the floor captains to make sure everyone in their section is informed and taken to a safe place. There are maps on the walls of each room designating the safe place within the building. There is also a security guard who checks the building, including restrooms, to ensure that people are aware of any emergency situations. The guards and floor captains act as a unit to ensure everyone is safe. Since customers are not allowed past the resource room without being accompanied by an employee, it would be rare for a customer to be alone during an emergency. It is the responsibility of the employee to assist any client, with or without a disability, to safety. If necessary, the employee will call upon a guard to assist them. The survey team noted that none of the DVR employees volunteered to be floor captains. They stated they were too busy. DVR is the only partner that does not have staff acting as floor captains. All staff has been trained in emergency procedures. The building does not have stairs or elevators and all exits are accessible. The survey team did not indicate if they reviewed the emergency evacuation procedures. Physical Access  People with disabilities should be able to arrive on the site, approach the building, and enter the building as freely as anyone else. At least one path of travel should be safe and accessible for everyone, including people with disabilities. Route of Travel The exterior route of travel for the Dane County Job Center appears to be in compliance with Title III of the Americans with Disabilities Act of 1990. This site has no ramps. Parking/drop off areas It appears that the parking/drop off areas meet almost all minimum guidelines for accessibility. This includes; number of spaces, spaces designated as van accessible, signage, access aisles, and slope. However, there is no curb from the job center parking lot to the sidewalk directly in front of the accessible doors and the area does not have a detectable warning as required. The lot does not appear to have a formal passenger-loading zone. The Support Services Facilities Manager indicated she was not satisfied with the access stripes recently painted on the crossing zone. At present, the crossing zone is only slightly wider than one of the accessible spaces. She would like to have it repainted so that the crossing zone is the same width as all the accessible spaces combined. Currently, no policy exists for allowing disabled employees to utilize accessible parking. The question was raised as to whether there are enough accessible spaces for both customers and staff. That question was not answered. The center does not appear to have a policy in place to deal with the unauthorized use of accessible parking. Entrances The job center has two public entrances, both at the front of the building. The facility has other entrances in the back of the building for employee use. All entrance doors appear to meet minimum ADAAG requirements for width, threshold level, maneuvering clearances, ease of opening and rate of closing and all other requirements. There do not appear to be any inaccessible entrances. Stairs/Lifts/Elevators The facility is on one floor. There are no stairs, lifts or elevators. Lobbies/Corridors The main entrance provides direct access to the lobby and reception desk. No barriers appear to exist along the path of travel connecting all services. All public elements appear to be on an accessible route of travel. There is one floor to the building. To the left of the lobby is a set of closed doors leading to DVR staff offices. To the right is a hallway leading to UI (closed to the public), the day care center and workshop/meeting rooms. Ahead of the lobby and slightly to the left, is a set of propped open doors leading to the W-2 services area. The survey did not mention the locations of any of the other center partners within the facility. Rooms and Spaces The center is divided into several areas used for services and programs. Customers are not allowed beyond the lobby area without an employee escort. The policy is to escort clients both in and out of the staff services area. The lobby is also the resource room. The center also has several workshop rooms. The survey noted the W-2 offices are cubicles. No other spaces providing core, intensive or training services were included in the survey.  Not all internal signage complies with accessibility guidelines. Braille signage is not provided, except at the restrooms. The Braille signage is not accompanied by a contrasting sign with the name of the permanent room or feature displayed in tactile lettering. According to the survey, the rooms and spaces meet all other minimum requirements for accessibility. Staff had mentioned during the interview portion that the center had accessible workstations. It is not clear if the center has the required minimum 5% of their public workstations wheelchair accessible. The drinking fountain, public use phones, and signage as to the location of the TDD/TTY device appear to meet minimum ADAAG requirements. Toilets Rooms Both publicly accessible restrooms appear to meet all minimum accessibility requirements requirements. However, they do not have visual alarms. While the survey indicated all minimum requirements for accessibility were met, the team also noted that because of the way the door and wall are situated in the womens restroom, it could be difficult for someone in a wheelchair to open the door and get out. Staff indicated that situation occurred once with a customer but, has not happened before or since. Because measurements and/or diagrams were not provided with the survey, it is not clear what the problem is or how it could be corrected. The survey team also noted the Braille sign for the womens restroom was off, but staff indicated it was being replaced. Memorandum of Understanding The Memorandum of Understanding was not addressed in the survey. At the time of this report, the writer did not have a copy to review. Analysis The Dane County Job Service partners and staff have utilized both formal and informal approaches in dealing with the needs of their clients, including those with disabilities. Staff indicated they work well together, allowing agencies to deal more effectively with the disabled. The center has a number of written policies and procedures in place to assist staff in making sound decisions. They have instituted center-wide training on disability issues. The center partners have taken the effort to remodel the facility to provide maximum accessibility for the disabled. All public entities are required to do a self-evaluation (28 CFR 35.103) to evaluate current policies and practices in order to identify and correct inconsistencies with the ADA. It is not clear if the Dane County Job Center or its partners has ever done such an evaluation. DOL TEIN 16.99 covers 29 CFR Part 37 and includes five accessibility checklists that walk a one-stop through the process. Utilizing these guidelines on a regular basis can aid a center in meeting the various requirements in WIA program and physical access, thereby increasing the level of service provided to those with disabilities. The Dane County Job Center is considered a comprehensive center under the Workforce Investment Act (WIA) regulations. Generally speaking, the assessment data demonstrates that the center has both strengths and potential weaknesses when serving persons with disabilities. Most programs and services take place within the physical confines of the center. The job center partners work cooperatively to implement their programs and address issues. To that end, there are additional formal policies and procedures that can provide their staff with direction should they need assistance in dealing with disability issues and, more importantly, the disabled. Discussions about accessibility frequently emphasize facilities and equipment - the physical factors that make a One-Stop usable. Accessibility of services is less concrete and readily visible but equally important. Service accessibility means that, for example, staff can use TTY machines or request interpreters; that information for customers with disabilities is available in a variety of formats and presented in a clear, understandable fashion; that emergency procedures take account of customers with disabilities; and that in general, customers with disabilities are able to equally benefit from the services of the One-Stop system as all other customers. Where program access is concerned, the staff and partners of the Dane County Job Center appear to rely on formal processes and communication to address the needs of the disabled. Program partners indicated they have a written policy and procedure to deal with the issue of reasonable accommodations/modifications. All staff has access to the process through the procedures manual. There are also so-called cheat sheets throughout the facility to aid staff in providing answers on available accommodations. The partners stated the cost of providing such accommodations could be divided among the partners according to rent share or absorbed by the individual partner, if the participant requires the accommodation for a specific program or service. When asked about the process for determining undue burden, the partners indicated they would not make such a decision, but would send it downtown for someone to evaluate. This comment makes it sound as if the center, itself, does not have a process for determining undue burden, and that the partners were referring to their state agency and not the One-stop. Because an entity can claim undue burden should financial resources dictate that its program cannot afford to make services available to people with disabilities, the issue becomes an important one to the center as a whole. WIA 188 regulations dictate that, in dealing with an undue burden, rationale must be written and signed by the appropriate employee, an individual representing the center or the WDB. The threshold to claim undue burden is a high one. Such a decision can affect all the partners within the center and perhaps, even beyond. A similar comment was made when asked about determining whether a policy or practice modification would fundamentally alter the nature of the program. The partners stated they knew of no such policy since it is up to the state to decide. When local One-Stop systems design services, they are required to proactively anticipate the needs of people with various physical, mental, and sensory disabilities. The obligation to provide program access does not require a public entity to take any action that it can demonstrate would result in a fundamental alteration in the nature of the program or activity or in undue financial and administrative burden. This determination can only be made by the head of the public entity or his designee and must be accompanied by a written statement of the reasons for reaching that conclusion. Moreover, these policies and processes are to encompass the One-stop and its services. The fact that individual agencies within a center have such procedures in place does not relieve the One-stop from its obligation to do so. It is also important to have a formal process in place to document the denial of a request and to have a formal appeal process in place. Regulations require that such a denial would have to be made by a member of senior management. For a center to say, we would never deny an accommodation and, therefore, do not need formal processes or policies is an unsound approach. Once again, when partners described their appeal process in cases on denied reasonable accommodation/modification, they stated the complaint goes to the state and it addressed at a state level hearing. The One-stop must also have a formal appeals process in place. From partner comments, it does not appear the center has such a process or, if they do, partners are not aware of its existence. Having an accessible job center means letting the disabled know that special accommodations or services are available to them. If individuals are not aware that the staff can and will provide auxiliary aids for their benefit, they may not use the services at all. The partners indicated that there is not, at this time, a formal policy or procedure covering the use of such language. They noted, however, that the information is put on all materials and disclaimers are posted throughout the building. The WDAs website may also need to be modified to meet required standards, as there does not appear to be any such language on the provision of accommodations anywhere on the site. As part of its efforts to provide universal access, One-Stops must do outreach and marketing to both the general public and specific populations, including people with disabilities. The center appears to use a variety of formats, both visual and audio, to let the public know of its services and programs. The introduction of a center-wide policy for disability-related training allows uniformity in preparing staff to deal with various issues. The center provides training to its staff on a number of disability issues and also tries to make sure staff is aware of programs and services offered by other agencies. However, they do not appear to have a formal method of assuring competency or incorporating what has been learned into action. While there appear to be complaint or grievance procedures and policies in written form, partners do not seem to be aware of the existence of the centers Complaint Coordinator(s). There also seems to be some confusion as to the identity and nature of the designated employee. Once again, the partners indicated if the DVR supervisor could not handle the complaint, it would go to the state for a hearing. Formalized staff training that is center-wide in nature could address these areas. As was stated earlier in this report, the One-stop system is required to have anticipated the needs of people with disabilities in the physical design of centers, as well as the design of services. Whether anyone has ever come in with a particular disability or not, the center should be prepared to meet their needs. While it may not be feasible to have all materials available in Braille, for example, key products could be produced in large print and on hand when needed. The partners indicated they were able to produce information in Braille. However, the resource room staff made no mention of any materials readily available in that format. Only some of the materials are available in large print and the resource room relies heavily on paper and pen to accommodate the hearing impaired. The staff knows how to access interpreters, but it can take as long as two weeks to secure one for the center. The center appears to have written policies and procedures for emergency evacuations. It also has designated staff assigned to check the facility to ensure total evacuation. Staff periodically receives updates on procedures. The facility has both visual and audible alarms, but the bathrooms do not have visual alarms as required. The overall goal of this project is to have a path of travel that is readily accessible to and useable by people with disabilities. Just as it is important to provide programs and services to disabled individuals once they enter the One-stop, it is of equal importance to provide an accessible route to and within the facility. In that regard, the Dane County Job Center appears to have taken a pro-active approach in making that facility an accessible one. Most minimum physical accessibility guideline requirements appear to be met. Then again, the survey team did not evaluate all of the areas used for core, intensive and training services and programs. Nor did they review public computer workstations for access. The partners indicated the resource room has an accessible workstation, as does DVR. However, dependent upon the total number of public workstations within the center, that may or may not meet guideline requirements. The specific items that may pose a barrier to individuals with disabilities are listed here: There is no curb from the job center parking lot to the sidewalk directly in front of the accessible doors and the area does not have a detectable warning as required. Not all internal signage complies with accessibility guidelines. Braille signage is not provided, except at the restrooms. The Braille signage is not accompanied by a contrasting sign with the name of the permanent room or feature displayed in tactile lettering. The bathrooms do not appear to have visual alarms. At the time of the survey, the Braille sign for the womens restroom was not in place. The Dane County Job Center has a number of apparent strengths on which to build a better service delivery system. The partners work as an integrated team to resolve issues. They are pro-active in addressing the physical accessibility of the center. They appear to have a number of formal policies in procedures in place to better address the needs of the disabled. The recommendations offered herein will assist the center and its partners create more effective policies and procedures for issues such as reasonable accommodations, undue burden and communications, among others. To date, staff indicated that, to the best of their knowledge, no one with a disability has ever been denied services at the center. Until the disabled public is fully aware that the services exist and that accommodations will be made, it may never be known how many never attempted to use those services in the first place. Recommendations The recommendation(s) section is meant to provide some practical suggestions based on the information provided during interviews, documents that have been submitted and analyzed, and the physical assessment. From a practical perspective, the comments are meant to improve customer service and afford greater opportunity to potential patrons. In addition, it is important to point out two important points. Both the Rehabilitation Act, as amended, and the Americans with Disabilities Act had provisions built into their implementation that were to assist entities with compliance measures. Many people misunderstand the program access requirements. There is no grandfather clause, and one does not exist with the Workforce Investment Act either. Title II of the ADA stated tat public entities conduct a self-evaluation of their programs and services. Self-evaluations were due January 26, 1993. From a structural perspective, buildings were to develop and implement a transition plan. A transition plan would identify the structural barriers to people with disabilities and their participation in programs. Transition plans were to be completed by July 26, 1995. That is, a Title II entity was to have eliminated barriers that posed a physical barrier to program participation by July 26, 1995. Therefore, the current proactive steps being taken by the collective organizations on Operation One-Stop also assist the Wisconsin one-stop system with compliance measures. Establish a method of communication between the one-stop and aging and disability resource center. Ensure that outreach methods include the workshops that may be offered by individual job center programs (i.e., interviewing, resume writing, computer research, job search) Ensure that accommodations are provided in a reasonable timeframe. Ensure that alternative formats are provided to the requesting party within a reasonable timeframe (and have the timeframe specified in policy). Undertake a biannual physical and program accessibility self-evaluation using, at a minimum, accessibility checklists and survey instruments that have been provided and approved by U. S. Government agencies or instrumentalities thereof. Develop, and implement a written policy describing how partners will integrate persons with disabilities into programs and services. Develop a process for distributing the integration policy to appropriate personnel. Continue to utilize a team approach for disability-related issues. Develop and implement a policy and procedure ensuring that adequate disability-related training is periodically provided to all relevant staff. Develop a short, self-administered assessment tool focusing on disability-related knowledge (disability civil right legislation) for staff to complete annually. Continue to provide cheat sheets for the staff on available accommodations. Continue to use the centers procedure on the provision of reasonable accommodations and modifications by the One-stop and its partners. Develop a definition of and guidelines for what is considered reasonable to provide staff and persons with disabilities a realistic level of expectations. Continue to take and analyze requests for accommodations on a case-by-case basis. Develop a procedure that ensures staff are aware of policies and procedures to handle requests. Develop a center-wide policy and procedure for determining undue burden. Conduct training on how certain program related decisions may fundamentally alter the program. Develop a process for distributing the policy and procedures on undue burden to all relevant staff. Develop a process for determining whether a policy or practice modification would fundamentally alter the nature of the program. Develop a formal policy and procedure for determining how partners will pay for necessary accommodations or modifications. Develop a methodology to ensure staff is aware of the policies and procedures. Ensure that the centers complaint, grievance and appeals processes each have a due process. Ensure that the complaint, grievance, and appeals processes are posted. Develop a train the trainer program to ensure staff is competent with all the features of the accessible workstation. Develop a policy and procedure to ensure information readily available at the center for the general public is also readily accessible in alternative formats to those with disabilities. (Ex. Large print, Braille or audiotape.) Develop the methodology necessary to ensure staff is aware of the procedures to providing materials in alternative formats. Continue to maintain a list of resources pertaining to interpreter services and the procedures to ensure staff knows how to access such services. Develop expanded outreach methods to unserved or underserved people with disabilities. Develop training to staff on where people with disabilities frequently engage in activity. Develop policy and procedures to ensure public information is provided in a variety of accessible formats. Develop standardized language on the provision of auxiliary aids and services to be used on all materials regardless of format, disseminated by the center and on any partner services offered through the center. Develop a process to ensure non-program specific customers are aware of the availability of auxiliary aids and services when using center resources. Develop a process to ensure the website is Bobby AAA approved. Ensure the centers Equal Opportunity Officer/Responsible Employee receives adequate training to handle disability-related issues. Develop methods conveying information on the identity, location and means of contact of the centers EOO/Responsible Employee. Develop a policy and procedure that ensures staff is aware of the responsible employees (EOO) name, location and means of contact. Ensure that communication methods exist that informs individuals with disabilities their rights whether or not they are a part of a specific program. Ensure the grievance process is specific to disability-related issues. Develop procedures identifying those individuals responsible for handling disability-related issues. Develop a procedure within the MOU that implements compliance with disability civil rights legislation and how partners will collaborate to meet those obligations. Develop policies and procedures that ensure contractors comply with disability related legislation. Ensure proper staff have received these procedures. Ensure proper staff know how to use these procedures. Ensure MOU and lease agreements reflect disability legislation compliance. Develop a process to provide a safe route of travel for the visually impaired from the entrance to the parking lot. Develop a process to ensure all internal signage meets minimum ADAAG guidelines. Develop a process to ensure emergency alarm systems meet minimum ADAAG requirements. PAGE  PAGE 18 WIA Sec. 37.5 Forms of discrimination that are prohibited by this part. No individual in the United States may, on the ground of race, color, religion, sex, national origin, age, disability, political affiliation or belief, and for beneficiaries only, citizenship or participation in any WIA Title I--financially assisted program or activity, be excluded from participation in, denied the benefits of, subjected to discrimination under, or denied employment in the administration of or in connection with any WIA Title I--funded program or activity. ADA 35.130 General prohibitions against discrimination. (a) No qualified individual with a disability shall, on the basis of disability, be excluded from participation in or be denied the benefits of the services, programs, or activities of a public entity, or be subjected to discrimination by any public entity. WIA Sec. 37.8 A recipient's responsibilities regarding reasonable accommodation and reasonable modification for individuals with disabilities. With regard to aid, benefits, services, training, and employment, a recipient must provide reasonable accommodation to qualified individuals with disabilities who are applicants, registrants, eligible applicants/registrants, participants, employees, or applicants for employment, unless providing the accommodation would cause undue hardship. ADA 35.150 Existing facilities. General. A public entity shall operate each service, program, or activity so that the service, program, or activity, when viewed in its entirety, is readily accessible to and usable by individuals with disabilities. WIA Sec. 37.9 A recipient's responsibilities to communicate with individuals with disabilities. (a) Recipients must take appropriate steps to ensure that communications with beneficiaries, registrants, applicants, eligible applicants/registrants, participants, applicants for employment, employees, and members of the public who are individuals with disabilities, are as effective as communications with others. (b) A recipient must furnish appropriate auxiliary aids or services where necessary to afford individuals with disabilities an equal opportunity to participate in, and enjoy the benefits of, the WIA Title I--financially assisted program or activity. In determining what type of auxiliary aid or service is appropriate and necessary, such recipient must give primary consideration to the requests of the individual with a disability. WIA Sec. 37.29 A recipient's obligations to disseminate its equal opportunity policy. (a) A recipient must provide initial and continuing notice that it does not discriminate on any prohibited ground. (b) As provided in Sec. 37.9, the recipient must take appropriate steps to ensure that communications with individuals with disabilities are as effective as communications with others. ADA 35.106 Notice. A public entity shall make available to applicants, participants, beneficiaries, and other interested persons information regarding the provisions of this part and its applicability to the services, programs, or activities of the public entity, and make such information available to them in such manner as the head of the entity finds necessary to apprise such persons of the protections against discrimination assured them by the Act and this part. WIA Sec. 37.23 Designation of an Equal Opportunity Officer. Every recipient must designate an Equal Opportunity Officer (``EO Officer''), except small recipients and service providers, as defined in Sec. 37.4. The responsibilities of small recipients and service providers are described in Secs. 37.27 and 37.28. ADA 35.107 Designation of responsible employee and adoption of grievance procedures. (a) Designation of responsible employee. A public entity that employs 50 or more persons shall designate at least one employee to coordinate its efforts to comply with and carry out its responsibilities under this part, including any investigation of any complaint communicated to it alleging its noncompliance with this part or alleging any actions that would be prohibited by this part. The public entity shall make available to all interested individuals the name, office address, and telephone number of the employee or employees designated pursuant to this paragraph. ADA 35.107 Designation of responsible employee and adoption of grievance procedures. (b) Complaint procedure. A public entity that employs 50 or more persons shall adopt and publish grievance procedures providing for prompt and equitable resolution of complaints alleging any action that would be prohibited by this part. ADA Sec.36.101 Purpose. The purpose of this part is to implement title III of the Americans with Disabilities Act of 1990 (42 U.S.C. 12181), which prohibits discrimination on the basis of disability by public accommodations and requires places of public accommodation and commercial facilities to be designed, constructed, and altered in compliance with the accessibility standards established by this part. ADAAG 4.30.6 Mounting Location and Height. Where permanent identification is provided for rooms and spaces, signs shall be installed on the wall adjacent to the latch side of the door. Where there is no wall space to the latch side of the door, including at double leaf doors, signs shall be placed on the nearest adjacent wall. Mounting height shall be 60 in (1525 mm) above the finish floor to the centerline of the sign. Mounting location for such signage shall be so that a person may approach within 3 in (76 mm) of signage without encountering protruding objects or standing within the swing of a door. ADAAG 4.30.4* Raised and Brailled Characters and Pictorial Symbol Signs (Pictograms). Letters and numerals shall be raised 1/32 in (0.8 mm) minimum, upper case, sans serif or simple serif type and shall be accompanied with Grade 2 Braille. Raised characters shall be at least 5/8 in (16 mm) high, but no higher than 2 in (50 mm). Pictograms shall be accompanied by the equivalent verbal description placed directly below the pictogram. The border dimension of the pictogram shall be 6 in (152 mm) minimum in height. ADAAG 4.28.1 General. Alarm systems required to be accessible by  HYPERLINK "http://www.access-board.gov/adaag/html/" \l "4.1" 4.1 shall comply with 4.28. At a minimum, visual signal appliances shall be provided in buildings and facilities in each of the following areas: restrooms and any other general usage areas (e.g., meeting rooms), hallways, lobbies, and any other area for common use. ADAAG 4.29.5 Detectable Warnings at Hazardous Vehicular Areas. If a walk crosses or adjoins a vehicular way, and the walking surfaces are not separated by curbs, railings, or other elements between the pedestrian areas and vehicular areas, the boundary between the areas shall be defined by a continuous detectable warning which is 36 in (915 mm) wide, complying with  HYPERLINK "http://www.access-board.gov/adaag/html/" \l "4.29.2" 4.29.2. 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