EOD > Equal Employment Opportunity

Equal Employment Opportunity & Affirmative Action Strategic Plan

Strategies to Improve Diversity within

State Government

Designation of Responsibilities
Introduction To The EEO Strategic Plan
Major EEO Laws and Rules
Agency Overview
Agency EEO Staffing
Agency Equal Employment Opportunity Policy Statements
Availability of the Current Equal Employment Opportunity Strategic Plan (EEOSP)
Policy Dissemination of EEO Related Information
Recruitment Strategies
Recruitment/Outreach
Recruitment/Application
Recruitment/Literature
Selection Strategies
Selection/Qualifications
Selection/Position Descriptions
Selection/ Employee Interviews
Adverse Impact
EEO Placement/Orientation
EEO Performance Evaluations
EEO Training Strategies
EEO Discipline Strategies
EEO Separation Strategies/Exit Interviews
EEO Monitoring Strategies
Summary of Corrective Actions to be Taken During the New Fiscal Year
Agency Diversity Best Practices
ADA Customer Service Self-Evaluation Review Format

Designation of Responsibilities

EEO Plan

ADA Plan

Name:
Title:
Address:
Telephone:
E-Mail Address:

Introduction to the EEO Strategic Plan

Pursuant to the Ohio Administrative Code 123:1 – 49 – 01 "The Ohio Department of Administrative Services will assure equal opportunity in state services to prohibit discrimination because of race, color, religion, sex, including sexual harassment, national origin, age, disability, veterans status and to promote the full realization of equal opportunity in state service through a continuing Equal Employment Opportunity (EEO) program for executive agencies under the purview of the Governor of the state of Ohio."

The purpose of an Equal Employment Opportunity (EEO) Strategic Plan is to eliminate discriminatory employment practices. An EEO Strategic Plan is a detailed, results-oriented set of procedures which, when carried out results in full compliance with equal employment opportunity requirements through full utilization of minority groups, women, and disabled persons at all levels of the workforce. The program seeks to bring women, minorities and disabled persons into all levels of the workforce.

The format is designed to reflect clear, goal directed activity (not to be confused with employment goals). Each section will address a specific review of the agency's current status for all EEO action items (i.e. recruitment, selection, training and upward mobility, discipline, separation and internal monitoring).

Major EEO Laws and Rules

THE U.S. CONSTITUTION
Article VI – Supremacy Clause
"This Constitution, and the laws of the United States which shall be made in pursuance thereof; and all treaties made, or which shall be made, under the authority of the United States, shall be the supreme law of the land; and the judges in every state shall be bound thereby, anything in the constitution or laws of any state to the contrary notwithstanding."

Amendment 13
"Neither slavery nor involuntary servitude, except as a punishment for crime whereof the party shall have been duly convicted, shall exist within the United States, or any place subject to their jurisdiction." "Congress shall have the power to enforce this article by appropriate legislation."

Amendment 14
"All persons born or naturalized in the United States, and subject to the jurisdiction thereof, are citizens of the United States and the state wherein they reside. No state shall make or enforce any law which shall abridge the privileges or immunities of citizens of the United States; nor shall any state deprive any person of life, liberty, or property, without due process of law; nor deny to any person within its jurisdiction the equal protection of the laws."

FEDERAL STATUTES
The Civil Rights Act of 1866
"All persons within the jurisdiction of the United States shall have the same right in every state and territory to make and enforce contracts, be sued, be parties, give evidence, and to the full and equal benefit of all laws and proceedings for the security of persons and property as is enjoyed by white citizens, and shall be subject to like punishment, pains, penalties, taxes, licenses, and exactions of every kind, and to others."

The Civil Rights Act of 1871
"Every person who, under color of any status, ordinance, regulation, custom, or usage, or any state or territory subjects, or causes to be subjected, any citizen of the United States or other person within the jurisdiction thereof to the deprivation of any rights, privileges, or immunities secured by the Constitution and laws, shall be liable to the party injured in an action at law, suit in equity, or other proper proceeding for redress."

The Equal Pay Act of 1963
"Requires that individuals must receive equal pay for equal work regardless of sex. The federal enforcement agency is the Equal Employment Opportunity Commission."

Title VII of the Civil Rights Act of 1964 (as amended in 1991)
"Forbids that anyone be excluded from participation in, denied the benefits of, or otherwise be subjected to discrimination on the basis of race, color, religion, sex (including sexual harassment), and national origin. The federal enforcement agency is the Equal Employment Opportunity Commission." The amended provides compensatory and punitive damages for sex, religion, national origin, and disability discrimination, makes easier proof of disparate impact, bans use of differential test scores, makes illegal mixed-motive employment decisions, makes it possible to award expert fees to prevailing parties in civil rights lawsuits, expands time limits for challenging seniority systems, extends job bias protections to senate, house and presidential employees as well as those working for state and local government officials, establishes a Technical Assistance Training Institute for the EEOC, and creates a Glass Ceiling Commission to study and make recommendations concerning upward mobility.

Title VII of the Civil Rights Act of 1964 (as amended)
"Forbids employment discrimination on the basis of race, color, religion, sex (including sexual harassment), and national origin. The federal enforcement agency is the Equal Employment Opportunity Commission." It was amended to include compensatory and punitive damages.

The Age Discrimination in Employment Act of 1973
"Requires that governmental agencies receiving federal monies be non-discriminatory toward the disabled. The pertinent section is enforced by guidelines of the respective federal grantors."

The American with Disabilities Act of 1990
Incorporates portions of the Rehabilitation Act of 1973 but forbids employment discrimination for the disabled persons whether or not the employer receives federal funds. Enforcement is by the Equal Employment Opportunity Commission, the U.S. Attorney General, and the Office of Federal Contract Compliance Programs.

 FEDERAL PRESIDENTIAL ORDER
Executive Order 11246
Covers all employers with government contracts of more than $10,000. The order applies to contractors and subcontractors on construction projects financed in whole or in part by federal funds. Requirements are: a non-discrimination clause in every contract regarding race, color, religion, sex, or national origin. In addition, the subsequent Revised Order No. 4 requires such contractors and subcontractors with 50 or more employees and a contract or $50,000 or more to develop and implement an Equal Employment Opportunity plan. The enforcement agency is the Office of Federal Contract Compliance Programs (OFCCP).

Section 4112 of the Ohio Revised Code
Forbids employment discrimination on the basis of race, color, religion, sex, ancestry, national origin, disability, and age (40 years or more). The state enforcement agency is the Ohio Civil Rights Commission.

The Administrative Code of the Director of the Ohio Department of Administrative Services and Gubernatorial Executive Orders
Section 123:1-49 of the Administrative Code forbids employment discrimination within state agencies on the basis of race, color, religion, sex including sexual harassment, national origin, disability, age (40 years or more), and veteran status (Vietnam Era, disabled, or Desert Storm/Shield). The enforcement is by the Ohio Department of Administrative Services, Equal Opportunity Division.

PRESIDENTIAL EXECUTIVE ORDERS

GUBERNATORIAL EXECUTIVE ORDERS

Agency Overview

Please submit a copy of your agency's organizational chart, a description of each division's function types of classifications and qualifications used for each and location of outlying offices and institutions. Describe the chain of command for personnel decisions and explain any unique aspects of the agency structure, which may present problems.

Purpose : Pursuant to the Ohio Administrative Code: 123:1-49-01, EEO Officers' shall have primary responsibility for assisting the agency head in implementing equal employment opportunity in state government, including how to appropriately prevent, investigate and resolve complaints of discriminatory harassment and retaliation. EEO Officers' should also be responsible for mediation, setting and achieving EEO training objectives, providing guidance to the agency head in developing agency-specific policies, plans and implementing whatever corrective strategies are required to ensure equal opportunity and compliance. EEO Officers must be qualified to effectively discharge their duties, must have knowledge in the area of EEO law and relevant policies.

The EEO Officer shall work closely with the staff members in order to:

(A) Periodically appraise its personnel operations to assure their conformity with these regulations and the agency's plan.

(B) Appoint an Affirmative Action Executive whose functions include:
(1) Advising the head of the agency with respect to the preparation of equal employment opportunity programs, procedures, regulations, reports, and the EEO Strategic Plan.

(2) Evaluating from time to time the sufficiency of the total agency program for equal employment opportunity and reporting thereon to the head of the agency with recommendations as to any improvement or correction needed, including remedial or disciplinary action with respect to managerial or supervisory employees who have failed to cooperate fully or who are in violation of the program.

(3) Making changes in programs and procedures designed to eliminate discriminatory practices when so authorized by the head of the agency.

(4) Evaluating tests, employment policies, practices and qualifications and reporting to the head of the agency and to the State EEO Coordinator any such policies, practices and qualifications which have unequal impact on minorities, women and disabled persons. This function shall be performed in cooperation with the Department of Human Resources.

The EEO Officer shall work closely with the staff members in order to:

(5) Providing counseling to any aggrieved employee or applicant who believes that he or she has been discriminated against because of race, color, religion, sex, national origin, disability and age.
(6) Receiving and Investigating complaints of discrimination and attempting to resolve on an informal basis the matter raised by the employee or applicant in a complaint of discrimination.
(7) Publish the functions, rules and activities of the office by posting the following information on official bulletin boards:

(a) The name and address of the State EEO Coordinator.

(b) The names and addresses of the Appointing Authority, Affirmative Action Executive, and Deputy Affirmative Action Executive: and the fact they are available to counsel employees or applicants for employment who believe they have been discriminated against because of race, color, religion, sex, national origin, age or disability.

(c) The right of each employee and applicant for employment who believes that he or she has been discriminated against because of race, color, religion, sex, national origin, age or disability to file a complaint.

(d) The complaint procedure and time limits for such complaints as established by these regulations.

(D) Follow the Equal Employment Opportunity Commission Guidelines adopted by reference in 123:1-49-06 of these regulations.

(E) Submit the EEO Strategic Plan annually in a format prescribed by the Ohio Department of Administrative Services, Equal Opportunity Division.

Agency EEO Staffing  

EEO Staffing: Example of Flow Chart

Example of EEO Officer’s Responsibilities:

The EEO position is classified as an EEO Executive. This position is full time and exempt from the bargaining unit. Responsibilities include conducting internal and external EEO investigations; acting as the ADA coordinator and responding to accommodation requests made pursuant to the Americans with Disabilities Act (ADA) or Chapter 4112 of the Ohio Revised Code; managing the Minority Business Enterprise and the Encouraging Diversity, Growth and Equity Programs; managing the Construction Contractors.

The EEO Executive reports to the Human Resources Administrator for most EEO issues however, regarding issues of discrimination, this position reports to the Director. The EEO Unit conducts new employee orientation, EEO training for employees and conducts supervisory/managerial EEO training on an annual basis.

The EEO Executive and staff investigates allegations of discrimination which may be in violation of Title VII of the Civil Rights Act of 1964 based on a protected class (i.e., race, religion, sex, national origin or color) or The Age Discrimination in Employment Act (ADEA). The Civil Rights Unit also investigates claims of retaliation, sexual harassment, and discriminatory harassment.

The EEO Executive and staff manages the Minority Business Enterprise and the Encouraging Diversity, Growth and Equity Programs which mandate state agencies, colleges and universities to set- aside 15% and 5% respectively, of the their total aggregate budget to conduct business with minority and economically disadvantaged vendors. Also, approximately 2% of the 5% is mandated set-aside to conduct business with minority contractors.

The EEO Executive and staff also manage Construction Compliance programs, which should meet specific monetary criteria and provide construction/renovation of state facilities. On-site visitations are conducted throughout the construction/renovation period to determine compliance. This information is communicated to the Equal Opportunity Division through monthly reports. The EEO Unit informs the agency head regarding the agency EEO progress and other relevant via monthly reports.

Agency Equal Employment Opportunity Policy Statements  

Agency EEO Policy
Goal : To effectively communicate the state of Ohio's EEO policy to employees and the public. The dissemination of policies must be designed to achieve the widest distribution possible. Executive agency heads, Human Resource and EEO professionals are responsible for disseminating the EEO Policy internally and externally. Agencies will make material available in alternate formats such as large print, on cassette or in Braille, to accommodate persons with disabilities.

Equal Employment Opportunity Policy
Abstract:
The policy of the Ohio Department of Administrative Services (DAS) is to fully comply with applicable federal, state and local laws, rules, regulations and guidelines regarding Anti-Discrimination/ Anti-Harassment and Retaliation. Discrimination against employees and applicants based on a race, color, religion, sex (including sexual harassment), national origin, disability and age (40 years or older) is prohibited.

Sexual Harassment Policy Statement Abstract:
It is the policy of the State of Ohio to maintain a working environment free from any discrimination, and to prohibit sexual harassment among its employees, including discriminatory sexual advances or harassment adversely affecting an employee's terms and conditions of employment either directly or indirectly.

Sexual harassment is defined as any unwelcome or unwanted sexual advances, requests for sexual favors, and other verbal or physical conduct of a sexual nature when any one of the following criteria is met:

1. Submission to such conduct is made either explicitly or implicitly a term or condition of the individual's employment;
2. Submission to rejection of such conduct by an individual is used as the basis for employment decisions affecting such individual; or
3. Such conduct has the purpose or effect of unreasonably interfering with an individuals work performance or creates an intimidating, hostile, or offensive work environment.

Anti-Discrimination/Anti-Harassment
Abstract:
It is the policy of Ohio Department of Administrative Services (DAS) to prohibit discrimination and harassment of applicants and employees, due to race, color, religion, sex, including sexual harassment, national origin, disability, age (40 years or older) or veteran status. (Discriminatory Harassment will not be tolerated in the Ohio Department of Administrative Services' workplace.) The Supreme Court made clear that employers are subject to vicarious liability for unlawful harassment by supervisors. The standard of liability set forth in these decisions is premised on two principles: 1) an employer is responsible for the acts of its supervisors, and 2) employers should be encouraged to prevent harassment and employees should be encouraged to avoid or limit the harm from harassment. In order to accommodate these principles, the Court held that an employer is always liable for a supervisor's harassment if it culminates in a tangible employment action.

Retaliation Defined:
Retaliation is a discriminatory practice. Equal Employment Opportunity statutes prohibit a covered entity from retaliating against an individual who has engaged in protected activity, which includes both participation in the EEO process and opposition to discrimination. The prohibition against retaliation is very broad and covers more than merely discriminatory treatment with respect to terms, conditions, or privileges of employment. The anti-retaliation provisions prohibit any adverse treatment that is based on a retaliatory motive and is reasonably likely to deter the charging party or others from engaging in protected activity.

Listed below are the three essential elements of a retaliation claim:

· Protected Activity -- opposition to discrimination or participation in the statutory complaint process
· Adverse Action
· Causal Connection between the protected activity and the adverse action

Discriminatory Harassment Defined
Harassment does not violate federal law unless it involves discriminatory treatment on the basis of race, color, sex, religion, national origin, age of 40 or older disability, or protected activity under the anti-discrimination statutes. Furthermore, the anti-discrimination statutes are not a "general" civility code. Thus, federal law does not prohibit simple teasing, offhand comments, or isolated incidents that are not "extremely serious". Rather, the conduct must be "so objectively offensive as to alter the 'conditions' of the victims employment". The conditions of employment are altered only if the harassment culminated in a tangible employment action or was sufficiently severe or pervasive to create a hostile work environment.

EEO Policy:
Please provide a current copy of your agency's EEO, Anti-Discrimination/ Anti Harassment and Sexual Harassment Policy.

EEO Discrimination:
Does you agency utilize discrimination complaint form other than the DAS ADM 4400? Yes No
Has this form been approved by DAS/EOD? Yes No
If no, please explain:

Availability of the Current Equal Employment Opportunity Strategic Plan (EEOSP)

Pursuant to the Ohio Administrative Code, 123:1-49-04 Establishment of Affirmative Action Plan, each Agency shall establish, maintain, and carry out a continuing Affirmative Action Plan designed to promote equal opportunity in every aspect of agency personnel policy and practice.

The EEO Strategic Plan is a public document, which may be reviewed by interested internal or external parties during normal working hours as follows:

Contact Person(s) Location(s)

Contact Person(s) Location(s)

Contact Person(s) Location(s)

Contact Person(s) Location(s)

The State of Ohio's Equal Employment Opportunity program for state employees and applicants prohibits discrimination on the basis of race, color, religion, sex (including sexual harassment), national origin, age (40 years or more) or veteran status (Vietnam Era, disabled, or Desert Storm/Shield).
Agency employees ________________________ have been _______________________ will be notified of the availability of the plan for review via inner office mail and staff meetings by July 1, 2004.

Current Status:

2. The statement will be disseminated to all external recruitment sources on:

3. The agency head will disseminates EEO Policy and implementation information to respective managers on:

4. The managers will disseminate equal employment opportunity information to respective supervisors on.

5. Supervisors will disseminate equal employment opportunity information to respective employees on.

6. The Federal Equal Employment Opportunity Commission and Ohio Civil Rights Commission's

Posters ___ are currently being ___ will be by July 1, 2004 prominently displayed in the following locations:

Please note: you may contact the Federal Equal Employment Opportunity Commission at 800-669-4000 to receive "Equal Employment is the Law" and you may contact the Ohio Civil Rights Commission's at 888-278-7101 to receive posters.

Recommendations about where agencies may dissemination the EEO policy:

1. Does the agency maintain a current list of minority, women, disabled persons and veterans’ recruitment sources? Yes No

If yes, by whom (title): Date:

If no, please explain:

2. Has your agency actively conducted outreach recruitment for minority, women, disabled persons and veteran sources? Yes No

If yes, by whom (title): Date:

If no, please explain:

3. Diversity Recruitment Outreach Efforts:
Function: Date:
Function: Date:
Function: Date:
Function: Date:
Function: Date:

If no diversity outreach has occurred, please explain:

4. Does your agency utilize an internal employment application form other than the standard DAS application? Yes No

If yes, please explain:

5. Since the application form is considered a test, have your forms been screened in order to eliminate any illegal or potentially discriminatory questions and by whom?

If yes, by whom (title):

If no, please explain:

1. Since the EEO message is conveyed through your agency's literature, are publications screened in order to ensure minorities, women and disabled persons are portrayed in a positive manner? Yes No

If yes, by whom (title): Date:

If no, please explain:

2. Has the language in your publications been screened to ensure that non-discriminatory and non-sexist language is not used? Yes No

If yes, by whom (title): Date:

If no, please explain:

3. Is "the state of Ohio is an equal opportunity employer" included on your publications? Yes No

If no, please explain:

Current Status :

Agency Comments/Concerns :

A selection procedure, defined by the Uniform Guidelines, is any measure, combination of measures, or procedure used as a basis for any employment decision. Selection procedures include, but are not limited to, traditional paper and pencil tests, training programs, probationary periods, physical, education, and work experience requirements, informal or casual interviews and unscored application forms. Clearly, employment interviews, as well as other factors such as minimum qualifications and physical exams, are selection procedures as defined under this standard. The above selection procedures lead to employment decisions; hiring, promotions, demotions, membership referrals, retention of employees, etc.

All selection procedures must be job related. A job task analysis must be conducted to show the knowledge, skills and abilities needed to perform the job. Documentation should be prepared demonstrating the job-relatedness of a selection procedure to show that the procedure is content valid. For example, when a job task analysis reveals that answering and forwarding telephone calls are important skills for a receptionist position, then using "efficient telephone skills" as a minimum qualification would be a valid selection criterion because it is job-related.

Federal Validation Standard : Criterion-related, content and construct validity cap described asevidence of the validity of a test or other selection procedure by a criterion-related validity study should consist of empirical data demonstrating that the selection procedure is predictive of or significantly correlated with important elements of job performance. Evidence of the validity of a test or other selection procedure by a content validity study should consist of data showing that the content of the selection procedure is representative of important aspects of performance on the job for which the candidates are to be evaluated.

The Ohio Department of Administrative Services, Human Resources Division develops the qualifications, which serves as minimum qualification for all classifications. These qualifications affect the state of Ohio's pay plan. When these qualifications are developed by the agency, they must meet Federal Validation Standards.
1. Has your agency developed its own qualifications, and if so for what positions? Yes No
If yes, by whom (title): Date:

If no, please explain:

2. Are minimum qualifications developed by DAS for all classifications? Yes No
If no please explain:

3. Do the agency qualifications meet Federal Validation Standards? Yes No
If no please explain:

Positions descriptions provide information needed to assign a position to an appropriate classification. A position description should be reviewed and revised annually to ensure equality and to illuminate equal pay for equal work issue.
1. Are all position descriptions accurate and up to date? Yes No
If yes, by whom (title): Date:

If no, please explain:

2. How often are such reviews conducted?

Please explain:

3. Is advance step hiring used by this agency? Yes No

 If yes, by whom (title): Date:

If no, please explain the process:

• The interview is also considered a test; have all supervisors responsible for selecting employees received training to ensure that the proper applicant was selected? Yes No

If yes, by whom (title): Date:

If no, please explain:

Selections/Interviews/Upward Mobility
1. Do interviewers document the applicants' response during the hiring employee responses during and exit interviews? Yes No

If no, please explain:

2. Does your agency post all vacancies? (Externally, Internally and via the Internet) Yes No
If yes, by whom (title)

If no, please explain:

3. Are any positions excluded from the postings? Yes No

If yes, please explain:

4. Please provide a listing of all classifications/positions that were excluded from posting:

Current Status:

Agency Comments/Concerns:

Goal : To ensure that employment practices don't unfairly impact a specific group of persons. Adverse impact effect may be defined as a substantially different rate of selection in hiring, promotion, or other employment decision, which works to the disadvantage of a race, sex or ethnic group. It would be considered the selection that works to the disadvantage of a protected group such as a minority, women and disabled persons. The best way to determine whether adverse effect results from the use of seemingly objective selection requirements is to review the data on the reasons for rejection of individuals for each focus job title. Both the number and proportion of non-minority applicants or employees and the number and proportion of minority applicants or employees rejected for hire (or promotion) for each of the cited reasons should be computed. The same sort of statistics should be generated for women and men. Where the user's evidence concerning the impact of a selection procedure indicates adverse impact but is based upon numbers which are too small to be reliable, evidence concerning the impact of the procedure over a longer period of time and/or evidence concerning the impact which the selection procedure had when used in the same manner in similar circumstances elsewhere may be considered in determining adverse impact. Where the user has not maintained data on adverse impact as required by the documentation section of applicable guidelines, the Federal enforcement agencies may draw an inference of adverse impact of the selection process from the failure of the user to maintain such data, if the user has an underutilization of a group in the job category, as compared to the group's representation in the relevant labor market or, in the case of jobs filled from within, the applicable work force.

Objective: Conduct an adverse impact studies to ensure selection procedures are reviewed to ensure that they are not bias (based on protected class status)

Determining the Source of Disparities and Deficiencies:
Organizations can easily determine the selection rate for each of the groups by subtracting the rejection rate from 100%. For example, if 30% of non-minorities are rejected on the basis of educational requirements and 53% of minorities are rejected, the selection rates for non-minorities and minorities would be 70% and 47% respectively as seen by applying the formula.

Rate of Selection + 100% - Rate of Rejection
If the selection rate for minorities (or women) is less than four-fifths (4/5), or 80% of the selection rate for the remaining applicants, then there is an adverse effect and the selection method which prompted the effect (for example, educational requirements) would have to be validated as a prediction of satisfactory job performance. To make this computation, divide the selection rate for the covered group to the selection rate for the remaining applicants. Compare the results to the figure 80%. In our example, the figures would be as follows:

Selection Rate for Minorities (47%) = 67% (which is less then 80%)
Selection Rate for Non-Minorities (70%)

An adverse effect would exist in this situation.

If no individual selection requirement is causing an adverse effect, but the percentage of minorities or women selected for employment is less than 80% of the remaining applicants selected, then the organizations entire employee selection process must be reviewed and validated. Adverse effect may also be inferred by examining the level of employment reached by protected class members in comparison to the percentage of protected class members in the relevant geographical area.

Goal: Newly hired employees should be provided with basic employment information during the first couple weeks on the job. New employee position descriptions, fringe benefits information, policies, procedures, and EEO are a few of the topics, which should be covered.

Objective: The state of Ohio's efforts to increase diversity will be strengthened by educating employees about EEO laws, EEO policy and individual rights/responsibilities under the Policy.

1. Are EEO representatives included in the agency's new employees’ orientation session? Yes No

If yes, by whom (title):

If no, please explain:

2. What type of EEO topics are covered?

EEO Topics Include:

Goal: Performance evaluations are designed to gauge employee performance. It should provide the necessary supervisory feedback to identify areas to be improved as well as to reinforce those activities that meet or exceed standards. Supervisors are encouraged to evaluate the performance of their employees on an annual basis.

Objective: To ensure that each employee is provided a timely, non-discriminatory, honest evaluation of his/her job performance on an annual basis and (twice during the probationary period).

1. Have supervisors received training on how to conduct performance evaluations in a non-discriminatory manner? Yes No

If yes, by whom (title): Date:

If no, please explain:

2. Are employees provided with a timely, non-discriminatory, honest evaluation of their performance annually? Yes No

If yes, by whom (title): Date:

If no, please explain:

3. Are performance evaluations monitored to ensure non-discrimination and timely preparation? Yes No

If yes, by whom (title): Date:

If no, please explain:

Current Status:

Agency Comments/Concerns:

Goal: Training programs are often an integral part of an employer's Equal Employment Opportunity policy. Training and apprenticeship programs can increase the number of qualified minorities, women, disabled persons and veterans available for job placement.

Objective: Whether training is for the purpose of improving job performance or providing opportunity for upward mobility, each type of training should be evaluated by the participants to ensure proper conduct and determine whether or not training needs are actually being met.

1. What employees are responsible for coordinating internal/external training opportunities?
(Title):

( Title):

2. Does your agency have a structured selection procedure to determine what employees will attend training, which will ultimately provide an opportunity for upward mobility? Yes No
If yes, please explain:

If no, please explain:

3. Does your agency collect EEO data on trainees? Yes No

If yes, by whom (title):

If no, please explain:

4. Does your agency analyze the training session evaluations to ensure non - discrimination? Yes No

If yes, please explain:

If no, please explain:

Goal: The administration of discipline should be progressive and equitable. It should set clear standards and warn of consequences for non-compliance. Discipline that is not properly or equitably administered has the negative effect of discrediting the rule, policy, procedure and it's administrator. Discipline should be designed to rehabilitate employees who choose to correct their behavior; as well as justify the termination of those who do not.

Objective: To ensure equal discipline for like offenses is administered consistently for state of Ohio employees regardless of the employees' race, sex, color, disability, national origin, age and religion.
1. Does the agency have a written progressive disciplinary policy? Yes No

If yes, please explain: Date:

If no, please explain:

2. Have all supervisors received copies of the discriminatory policy? Yes No

If yes, by whom (title): Date:

If no, please explain:

3.Have all employees received copies of the discriminatory policy? Yes No

If yes, by whom (title): Date:

If no, please explain:

4. Have all supervisors received training on how to implement discipline in a non-discriminatory manner? Yes No

If yes, by whom (title): Date:

If no, please explain:

5. What percent of supervisors still need training?

Please explain:

Current Status:  

Agency Comments/Concerns:

EEO Separation Strategies/Exit Interviews

Goal: The impact of an excellent recruitment program may be negated by a high separation rate. The exit interview is primarily a problem-solving tool and can reveal reasons employees leave their jobs. It can provide the organization with information about how to correct the causes of discontent and reduce the costly problem of employee turnover.

Objective: To conduct a confidential exit interview for all voluntary terminations will divulge an employee's actual reasons for leaving. Based upon such input, agencies may then plan to change procedures, improve supervision, eliminate discrimination, etc. in order to lessen the turnover rate and to improve the quality of employment.

1. Are exit interviews conducted on all voluntary separations? Yes No

If yes, by whom (title): Date:

If no, please explain:

2. Please explain the process by which they are conducted.

3. If exit interview forms are mailed out, what is the return rate?

4. Has your agency analyzed the exit interview data to determine, if an adverse number of minorities and/or women are leaving the agency? Yes No

If yes, by whom (title): Date:

If no, please explain:

5. Are the exit interview results analyzed to ensure non-discrimination and separation trends? Yes No

If yes, by whom (title): Date:

If no, please explain:

Current Status:

Agency Comments/Concerns:

Goal: Agency heads are accountable to their respective managers for ensuring that Human Resource and EEO professionals, managers, and supervisors receive training in EEO laws, the implementation of the state of Ohio policies, and how to carry out managerial and supervisory responsibilities under this Policy. In turn, agency heads must hold managers and supervisors accountable for the effective implementation of policies.

Objective: Monitoring efforts involve your agency conducting periodic audits of your internal EEO/Human Resources process and results. The following actions should be taken:

Prepare a thorough written monthly/quarterly or an annual report to the agency head and provide an analysis of:

The results of the report should be reviewed with all levels of management. Top management should be advised of the effectiveness of the program and presented with recommendations to improve the areas that are non-compliant or unsatisfactory.

1. Does your agency Director receive an EEO report on a consistent basis regarding the agency status of your EEO program? Yes No

If yes, by whom (title): Date:

If no, please explain:

2. How often is the report submitted to your director?

3. Please provide the topics that are included:

Current Status:

Agency Comments/Concerns:

Provide Agency Diversity Best Practices

ADA CUSTOMER SERVICE SELF-EVALUATION REVIEW FORMAT

Brief Description of the Department:   

Brief Description of the Division, District, or Institution:  

Brief Description of the ADA Program:

SELF-EVALUATION PROCESS

Background

The Americans with Disabilities Act (ADA) and its implementing regulations require all public entities to evaluate their policies and practices to identify and correct any that are not consistent with the ADA. Policies or practices that discriminate against or prevent participation by individuals with disabilities are strictly prohibited. All interested persons, including those with disabilities, or organizations representing them, must be given an opportunity to participate in the self-evaluation process by submitting comments. Agencies must ensure that this occurs and must develop methods for considering and, if necessary, acting on the comments received.

One way to provide an opportunity for comments and participation is to post public notices and/or hold public hearings. Public notices should clearly identify the purpose and goals of the evaluation. Agencies may also wish to include employees, clients or other persons with disabilities, or organizations representing persons with disabilities, in the evaluation process itself.

Evaluations should be kept on file for 3 years, and should list the persons consulted or heard from, the areas considered, the problems identified, and the modifications or changes made. Changes to agency policies or practices should reflect and incorporate public comments where appropriate.

Checklist:

1. Are individuals with disabilities and/or individuals from organizations representing persons with disabilities consulting with you during the self-evaluation process? Yes No NA

If you answered no to the above question you are required to develop procedures to ensure that interested parties are provided adequate opportunity to provide comments and suggestions.

List the steps taken to ensure that interested parties are included in the evaluation process.

ADA CUSTOMER SERVICE SELF-EVALUATION REVIEW FORMAT

3. List the names and addresses of interested people participating and/or providing comments.

4. Have you developed procedures to ensure that records of your evaluation (including responses 1-3 above), as well as our transition plans, are kept for a period of 3 years. Yes No NA

If you answered no, you must develop such procedures.

Notification

Background

In addition to the required self-evaluation of policies and practices every agency is required to notify current and potential employees and recipients of services as well as the general public, that it complies with the ADA in all its programs, services and activities. Each agency is responsible for ensuring that this poster or a comparable notice is posted in conspicuous places in all facilities, that an appropriate non-discrimination statement is included on all printed materials distributed to the public and that employees and recipients of services are notified of your compliance with the ADA.

It is important to note that your notices themselves must be provided in a way that will ensure that they reach all persons, including those with disabilities. In other words, the notices themselves must be accessible. For example, posters must be placed at an accessible height (between 54 and 66 inches from the floor) and copies of printed materials must be available upon request in Braille, large print and/or audio formats.

Finally, notices must include the name of your ADA Coordinator and information on how a complaint can be made if a person feels that he or she has been discriminated against because of a disability.

Checklist:

Have you posted notices stating your compliance with ADA in conspicuous places in all your facilities? Yes No NA

If you have answered no to this question, you are required to develop and post an appropriate notices.

Have you made your posted notice accessible to persons with disabilities? Is it posted at a height that can be read by persons in wheel chairs (54" - 66" from the floor)? Can it be made available in Braille, large print or audio formats or can it be read to persons with visual or other disabilities? Yes No NA

If you answered no, steps must be taken to assure that the notice is accessible.

Does your notice include the name, business and telephone number of your ADA Coordinator as well as information on how individuals can file a complaint if they feel they have been discriminated against because of a disability? Yes No NA

If you answered no, your notice must be revised to include the required information.

Have you communicated your compliance with ADA and your non-discrimination policy to all current employees and recipients of services and benefits? Yes No NA

If you answered no, you must take steps to notify all current employees and recipients of services and benefits that your agency does not discriminate in employment or in providing services or benefits. This notification should also include the name, business address and telephone number of your ADA coordinator and information on filing complaints.

Have you taken steps to ensure that potential and future employees and service recipients are made aware of your compliance with ADA? Yes No NA

If you answered no, you must develop procedures to ensure that potential and future recipients receive such notice.

List the steps you have taken or will take to notify current and future employees and service recipients of your compliance with ADA.

Do you include an appropriate non-discrimination statement on all printed materials distributed to potential employees, services recipients and the general public? Yes No NA

If you answered no, you must revise existing materials and develop a plan to ensure that all future materials include an appropriate non-discrimination statement. (Note: To avoid wasting current brochures and similar items, a sticker, stamp or insert could be used to add the appropriate statement to these materials.)

Have you taken steps to ensure that your staff fully understands your organization’s policy of non-discrimination and can take all appropriate steps to facilitate the participation of individuals with disabilities in agency programs and employment opportunities? Yes No NA

If you answered no, you must establish a mechanism to ensure that your staff fully understands their responsibilities. One way to do this is to provide periodic training and to include information in new employees orientation programs.

Complaints

Background

The ADA requires that each public entity identify at least one employee to coordinate its efforts to comply with the ADA. This coordination must include the investigation of complaints filed alleging discrimination or violation of the ADA. Employees, service recipients and applicants for employment and services must be notified of the name, business address and telephone number of your ADA coordinator and of the procedures for filing a complaint.

ADA CUSTOMER SERVICE SELF-EVALUATION REVIEW FORMAT

Employment complaints’ based on disability will be handles in the same way as other complaints regarding discrimination in employment. The established Equal Opportunity Division (EOD) complaint procedure can be used in these cases.

Agencies must develop an internal procedure for handling complaints from applicants and recipients of services.

Checklist:

Have you identified an ADA Coordinator or other employee who will be responsible for receiving and processing discrimination complaints? Yes No NA

If you answered no, you must identify this person.

Are appropriate personnel familiar with the EOD Complaint Procedures to be used for complaints of employment discrimination based on disability? Yes No NA

If you answered no, you must ensure that appropriate staff receive copies of the procedure (which is included in your seminar folder) and training, if needed.

Have you developed an internal grievance procedure to be used for receiving and processing complaints of discrimination based on disability from recipients of and applicants for services? Yes No NA

If you answered no, you must develop, publish and disseminate a policy.

Use of Contractors

Background

The ADA states that a public entity may not directly or through contractual, licensing or other arrangements discriminate against persons with disabilities in providing benefits or services, or in employment. A department which licenses facilities or enters into contracts with other public or private institutions, businesses or agencies to provide services or programs must ensure that those agencies, institutions or businesses comply wit the ADA.

To accomplish this objective, agency personnel involved in licensing or in writing or negotiating contracts must be made aware of these ADA requirements. Persons monitoring or auditing state funded programs must check for compliance with the programmatic, employment related and public accommodation requirements of the ADA. In addition, contracts should include language to the effect that the contractor is aware of and in compliance with the requirements of the ADA and its regulations. Contractors must be made aware of the ADA requirements to ensure that they are in compliance. A contract’s failure to comply could result in a state agency being held liable for a contractor’s licensee’s non-compliance.  

ADA CUSTOMER SERVICE SELF-EVALUATION REVIEW FORMAT

Checklist:

Have you taken steps to ensure that appropriate agency personnel understand the ADA requirements as they apply to contractors? Yes No NA

If you answered no, you must provide information and or training to those personnel.

Do persons monitoring or auditing state funded programs check for compliance with the ADA? Yes No NA

If you answered no, steps must be taken to ensure that state funded programs are checked for compliance with the programmatic, employment and public accommodation requirements of the ADA.

Have you included language in agency contracts to ensure that contractors are aware of their obligations to facilitate the participation of persons with disabilities in programs and activities they operate on behalf of the agency? Yes No NA

If you answered no, steps must be taken to include ADA related language in all contracts.

Have you developed a procedure to disseminate information about the ADA to all contractors? Yes No NA

If you answered no, you need to establish a procedure. Recognized material on ADA compliance and implementation are the Technical Assistance Manuals for Titles I, II and III (Included in your agency notebook) and the Uniform Federal Accessibility, Standards, available from the U.S. Architectural and Transportation Barriers Compliance Board Procedures will be developed incorporating relevant DAS procedures, if any, and disseminated to contractors.

Telephone Communication

Background

Where a public entity communicates with applicants and beneficiaries by telephone, TDDs or equally effective telecommunication systems are required to communicate with individuals with impaired speech or hearing. Although a statewide relay service was recently implemented, those departments with extensive telephone contact with the public are encouraged to have TDDs to provide access that is more immediate than a relay service. Telephone emergency services, such as fire, police, ambulance and, modems. TDD and relay service numbers must be published in the same manner as non-TDD numbers. Sign age concerning the availability of TDD pay phones or other TDD required phones must also be posed in public locations.

Checklist:

Does your organization have a procedure for communicating effectively over the telephone with hearing-impaired persons?

Telephone Communication Yes____ No ____ NA ____

If you answered no, you need to establish a procedure. This should include TDD phones in areas with extensive public contact.

Have TDD numbers or telephone relay numbers been added to all agency directories, pamphlets, brochures, letterhead, etc.? Yes_____ No _____ NA _____

If you answered no, you need to add these numbers to all directories, pamphlets, etc.

If your organization used “800" incoming WATTS telephone service in its program, have you taken steps to ensure that this service is usable by persons with hearing impairments? Yes _____ No_____ NA _____

If you answered no, you must ensure that the WATTS line is accessible to persons with speech and hearing impairments.

Have you taken steps to familiarize appropriate staff with the operation of TDDs and other effective means of communicating over the telephone with hearing impaired persons? Yes_____ No _____ NA_____

If you answered no, it is advisable to provide staff training. DAS Telecommunications can provide assistance and/or make appropriate referrals as needed.

Documents and Publications

Background

All interested persons, including persons with impaired vision or hearing or with learning or processing disabilities, must be able to obtain information on the existence and location of accessible services, activities and facilities. In addition, publications and documents must be free of discriminatory and other inappropriate language.

Checklist:

Do you have a procedure for making documents available in alternate formats (e.g., audiotape, Braille, large print, computer disk)? Yes_____ No _____ NA _____

If you answered no, you must develop such a procedure.

Have you received agency publications and documents to identify and remove discriminatory language or any language or images that may patronize or stigmatize persons with disabilities? Yes No NA

If you answered no, you must complete such a review and remove any inappropriate language or images. Fliers providing examples of appropriate and inappropriate terminology are included in your seminar folder.

Such a review is an ongoing process as a matter of routine. A reminder will go to all staff reminding staff to consider the wording of text as well as any pictures used in publications.

Interpreters, Assistive Devices, Adaptive Equipment

Background

Public entities are required to secure the services of a qualified interpreter when conducting business with a recipient of state services who is deaf. Public speeches should be given with the assistance of a sign language interpreter or hard copy transcripts should be made available upon request. Note: Hard copy transcripts are not sufficient if the public will be invited to engage in a dialogue with the speaker.

Public entities are also required to furnish appropriate auxiliary aids and services when necessary to afford an individual with a disability an equal opportunity to participate in, and enjoy the benefits of, the public entity’s services, programs or activities. This can include qualified readers and interpreters, taped, Braille or large print materials, or close-captioned video programs. The public entity must provide an opportunity for individuals with disabilities to indicate their chosen form of accommodation. The public entity should honor the choice unless it can demonstrate that another effective means of communication exists, or that the means chosen would pose an undue financial or administrative burden or would fundamentally alter the service, program or activity in question.

Employers and service providers are required to make reasonable accommodations to assure full participation by people with disabilities. There is a wide variety of equipment available to assist in this process. To reduce future costs, when make purchases agencies should consider equipment that can be readily modified.

Checklist :

Does your organization have a procedure to ensure that qualified interpreters are provided in an expeditious manner when needed at meetings, interviews, conferences, hearings or public appearances by agency officials? Yes No NA

If you do not have a procedure to locate and to hire a qualified interpreter, you need to develop this procedure. The Rehabilitation Services Commission can assist you with this process.

Are auxiliary aids available (or sources identified where they an be readily obtained) for individuals with speech, vision or hearing impairments to ensure effective participation in programs or activities? Yes No NA

If you answered no, you are required to establish relevant procedures to obtain and use auxiliary aids when needed.

Does your organization purchases office equipment that can be readily modified for people with disabilities? Yes No NA

If you answered no, you should review and revise your purchasing procedures as needed.

Undue Financial and Administrative Burden

Background

Title II requires a public entity to make its programs accessible in all cases except where to do so would result in a fundamental alteration in the nature of the program or present undue financial and administrative burdens. Similarly, Title I requires that reasonable accommodations be made to allow applicants and employees to perform available jobs, unless to do so would pose an undue financial or administrative burden. The decision that compliance would result in such alterations or burdens must be made by the head of the public entity or his or her designee and must be accompanied by a written statement of the reasons for reaching that conclusion. The determination must be made by a high level official, no lower than a department head, having budgetary authority and responsibility for spending decision.

Checklist:

Have you established a procedure for ensuring that decision about undue financial and administrative burdens are made properly and expeditiously? Yes No NA

If you answered no, you must establish a procedure. Please keep in mind that it will be difficult for the state, with its extensive resources, to show undue burden.

Program Accessibility

Background

Title II of the ADA requires that all programs, services and activities provided to the public by state and local government agencies be free of discrimination and disparate treatment and accessible to persons with disabilities. This means that people with disabilities are entitled to full and equal enjoyment of aids, benefits and services that these aids, benefits and must be equal to and as effective as those provided to other individuals. In addition the aids, benefits and services should not be provided differently or separately unless it is necessary to do so to ensure equal effectiveness. All activities related to your programs and services must be analyzed and modified if necessary to ensure non-discrimination.

ADA CUSTOMER SERVICE SELF-EVALUATION REVIEW FORMAT

Program Accessibility

Background Continued

In general, each independent program or service should be analyzed separately. All elements of your program should be reviewed to ensure that services and benefits are equally accessible to, and effective for, persons with disabilities, that the administration of the services and benefits is free from discrimination based on disability, that communications reach all persons including those with disabilities, and that effective application and selection procedures exists for persons with disabilities. Public service announcements must also be reviewed and revised as necessary to include closed captioning or sign language interpretation.

As you review the programs, services, and/or activities provided by your agency directly, or by another entity under contract, you should focus on the accessibility of the programs, services or activities. There are a number of ways that a program can be made readily accessible such as:

• Assigning aides to beneficiaries
• Making home visits
• Redesigning equipment
• Altering existing facilities

The Accessibility Checklist will help you to make a determination regarding architectural barriers and how they can be removed if necessary. A transition plan outlining structural changes was to be completed by January 26, 1992. Structural changes identified in the transition plan must be completed by January 26, 1995.

Checklist:

Have you reviewed materials and procedures used to advertise your program or service or to recruit individuals to participate in your programs to assure that they are accessible to and do not discriminate against persons with disabilities? Yes No NA

If you answered no, you need to complete such an analysis and take necessary steps to correct policies or materials that may result in disparate treatments or restrict accessibility. Your analysis should include a review of meetings, oral presentations, printed materials, advertisements, and other processes or materials used to recruit or to make persons aware of your program.

Have you reviewed your public service announcements and added closed captioning or sign interpretation? Yes No NA

If you answered no, you must review and revise these announcements as necessary.

Have you reviewed your eligibility criteria and any test used in the admission process for your program to assure that they do not discriminate against or result in disparate treatment of persons with disabilities? Yes No NA

If you answered no, you must complete such a review and make changes in criteria and tests as needed to eliminate any disproportionate adverse impact on applicants with disabilities.

Have you established a procedure to provide alternative tests or other accommodations in the testing process (e.g., readers) to persons with disabilities such as hearing or vision impairments or learning disabilities? Yes No NA

If you answered no, you must develop such a procedure and ensure that alternative tests or accommodations are readily available.

Have you taken steps, including providing ADA training to appropriate staff and providing auxiliary aids as needed, to ensure non-discrimination in any interviewing process related to your program? Yes No NA

If you answered no, you must review your interview process and ensure non-discrimination by training staff, making auxiliary aids available and revising procedures as needed.

Have you reviewed all forms, brochures and other written materials listed in advertising, selection or provision of services or in any other aspects of the program to assure they include an appropriate non-discrimination statement and do not include language that tends to discriminate or result in disparate impact? Yes No NA

If you answered no, such a review must be completed and changes made as needed.

Do you have a procedure to assure that all printed materials can be made available in alternate formats if needed? Yes No NA

If you answered no, such a procedure needs to be developed.

Have you reviewed tools, equipment and other devices used in the program to ensure that, with or without accommodations, they are usable by and accessible to persons with disabilities? Yes No NA

If you answered no, such a review must be completed.

Do you have a procedure to make accommodations or provide auxiliary aids as needed to ensure full access to your program for persons with disabilities? Yes No NA

If you answered no, such a procedure needs to be established.

Have you analyzed each of the following program elements to ensure that they are accessible to persons with disabilities, and that reasonable accommodations or auxiliary aids are available if needed?

Transportation services Yes No NA

Health services, insurance and other benefits Yes No NA

Housing Yes No NA

Financial aid Yes No NA

Counseling services Yes No NA

Employment services Yes No NA

Food services Yes No NA

Social, Recreational and Athletic Activities Yes No NA

If you answered no to any of the above, you must take steps to ensure that the services or benefits involved are equally accessible to and effective for persons with disabilities, and that procedures are in place to provide reasonable accommodations as needed.

Have you completed the Accessibility Checklist for each location you agency provides programs, services or activities? Yes No NA

If you answered no, please complete.

Have you prepared a Facilities Transition Plan as needed for all locations identified in Item 1? Yes No NA

If you answered no, please complete.

Does your agency have an evacuation plan for all locations, which identifies areas of rescue assistance? Yes No NA

If you answered no, please prepare or revise a plan and make sure it is communicated.

If you provide separate or different programs or activities for persons with disabilities, do you also ensure that they are not denied the opportunity to participate in those that are not separate or different if they so choose? Yes No NA

If you answered no, you must take steps to ensure such participation is available.

When selecting sites or locations for facilities, do you select sites that facilitate the accomplishments of the objectives of the service, program or benefit for persons with disabilities? Yes No NA

If you answered no, you must develop procedures that ensure that site selections are made with the needs of persons with disabilities in mind.

Do you administer services, programs and activities in the most integrated setting appropriate to the needs of qualified persons with disabilities? Yes No NA

If you answered no, you must take steps to ensure that you provide services, activities and benefits in the most integrated setting possible.

Do you maintain in operable working condition those features of facilities and equipment that are required to be readily accessible to and usable by persons with disabilities? Yes No NA

If you answered no, you must take steps to ensure that equipment is properly maintained.

Do you provide signage at all inaccessible entrances to each of you facilities, directing users to an accessible entrance or to a location where they can obtain information about accessible facilities? Yes No NA

If you answered no, you must install appropriate signage.

Do you have the international symbol for accessibility at each accessible entrance to each of your facilities? Yes No NA

If you answered no, you must install such sign age.

Have you reviewed boards, councils or other bodies on which program participants sit to ensure persons with disabilities have equal opportunity for selection and participation? Yes No NA

If you answered no, you must complete such a review and modify procedures if necessary.

Employment

Background

The ADA prohibits discrimination in employment against persons with disabilities and makes disparate treatment unlawful. This applies to all areas of employment, including the recruitment and hiring process, classification and pay, promotion and advancement opportunities, training and development, health insurance and other benefits and all other employment related activities. It is also unlawful to discriminate against a person who has a friend or relative with a disability. For example, to refuse to hire someone for fear that excessive absenteeism would result form their relationship to a person with a disability would be a violation of the ADA.

An employer may not refuse employment to a person with a disability if the individual, with or without reasonable accommodation, can perform the essential function of the job. It is important when you are planning to fill a position to identify the essential functions, to include that information in all job postings and to review the position description and revise it if necessary to identify functions. This review must be completed on a position-by-position basis.

The ADA provides that employment can be refused if employing a person with a disability would pose a “direct treat” or significant risk to the safety of others that cannot be eliminated by modification of policies, practices or procedures or by provision of auxiliary aids or services. For example, under certain circumstances, the ADA permits employers to refuse to assign food-handling duties to employees with communicable diseases transmitted through the handling of food.

Checklist:

1 . Have you analyzed your employment practices in general to identify and correct policies, procedures and/or written materials that may tend to discriminate or result in disparate treatment of persons with disabilities or person who have friends or relatives with disabilities? Yes____ No_______ NA_______

If you answered no, such an analysis must be completed.

2. Are your hiring procedures (application process, testing and interviewing) carried out in wheel chair accessible locations, using accessible formats (e.g., Braille, audio) and providing necessary accommodation (e.g., reader, sign language interpreter)? Yes No NA

If you answered no, you must take steps to ensure accessibility.

3. Have you determined that your policies and practices are free of discrimination and provide equal access to persons with disabilities in each of the following areas?

Recruitment and advertising Yes No NA

Application forms and processing Yes No NA

Interviewing, including structured interviews Yes No NA

Employment testing Yes No NA

Hiring, upgrading, promotion, demotion, transfer, layoff, termination and rehiring Yes No NA

Disciplinary process and procedures Yes No NA

Rates of pay or any other form of compensation and changes in compensation Yes No NA

Job classifications and assignments Yes No NA

Organizational structures Yes No NA

Sick leave, leave without pay and all other kinds of leave Yes No NA

Sick leave, leave without pay and all other kinds of leave Yes No NA

Selection & Financial support for training, professional meetings, conferences and other related activities Yes No NA

Health, Life and other Insurance benefits Yes No NA

Agency sponsored social and recreational programs Yes No NA

If you answered no to any of the above, you must identify procedures, policies and materials that may lead to disparate treatment and take appropriate action to modify them.

Do you have a procedure for responding to requests for accommodations to the known physical or mental disabilities of an otherwise qualified applicant or employee? Yes No NA

If you answered no, you need to adopt such a procedure. Accommodation should be readily available and, whenever the applicant or employee should in a format choose possible.

Do you have a procedure to determine when an individual with a disability poses a direct threat to health or safety of the individual or others? Yes No NA

If you answered no, you need to develop such a procedure.

Do you have a procedure to ensure that positions are analyzed when being filled and at other critical times to identify essential job functions, and those postings, position descriptions and other materials reflect these essential functions? Yes No NA

If you answered no, you need to develop such a procedure.

Do you provide training on employment compliance with the ADA to hiring managers and supervisors and other personnel involved in developing and/or applying personnel policies and practices? Yes No NA

If you answered no, you should develop a plan to provide such training.

Do you have a procedure to document decisions not to hire or promote because of “undue” hardship”? Yes No NA

If you answered no, you must develop such a procedure.

Do you ensure that you do not require medical exams or any other kind of pre-employment inquiry into an applicant’s disability until after a conditional offer of employment has been made to the applicant? Yes No NA

If you answered no, you must establish procedures to ensure that such inquiries are handled appropriately.

If offers of employment are conditional on satisfactory completion of a medical exam, do you take steps to ensure that medical information is collected and maintained on separate forms and in separate files, and treated as confidential information? Yes No NA

If you answered no, you must develop procedures to ensure that such records are appropriately collected and maintained.

If needed you may provide additional ADA related comments.