Skip to content

Civil Rights Compliance Program (Trident Enterprises)

For more information contact Sharon Wong via email: swong@cccco.edu or 916.327.5486


Chancellor's Office Authority
Civil Rights Legislation
Related Documents
Background
CCC and Civil Rights Activities
College Selection Criteria
On-Site Review Components
On-Site Review
Findings  

Chancellor's Office Authority

In accordance with an agreement with the Office for Civil Rights and the California Community Colleges Chancellor's Office (CCCCO) a Methods of Administration (MOA) authorized the Career Education Practices Unit to conduct compliance reviews of and provide technical assistance to the state’s 72 districts and 112 community colleges. Primarily focused on career technical education (CTE) programs, the civil rights review process involves a systematic assessment of the college’s fundamental commitment to comply with federal civil rights laws and regulations.

Civil Rights Legislation

The Guidelines for Eliminating Discrimination and Denial of services on the basis of Race, Color, National Origin, Sex and Disability in Career/Vocational programs (34 C.F.R. Part 100, Attachment B) were issued on March 21, 1974 (44 Federal Regulations 17162-17175). These responsibilities derive from and provide guidance supplementary to:

  • Title VI of the Civil Rights Act of 1964, and its implementing regulations prohibiting discrimination on the basis of color and national origin.
  • Title IX of the Education Amendments of 1972, and its implementing regulations prohibiting discrimination on the basis of sex.
  • Title II or Section 504 of the Rehabilitation Act of 1973 and its implementing regulations prohibiting discrimination on the basis of disability.
  • Americans with Disabilities Act (ADA) of 1990 and its implementing regulations prohibiting discrimination on the basis of disability
  • The Guidelines for Eliminating Discrimination and Denial of Services on the Basis of Race, Color, National Origin, Sex and Disability in CTE Programs of 1974 and its implementing regulations.

Annual Public Notification of Nondiscrimination

Prior to the beginning of each school year, recipients must advise students, parents, employees and the general public that all CTE programs will be offered regardless of race, color, national origin, sex, or disability. The notice must include a brief summary of program offerings and admission criteria and the name, office address, and phone number of persons designated to coordinate Title IX and Section 504 compliance activity. If a recipient’s service area contains a community of national origin minority persons with limited English language skills, public notification materials must be disseminated to that community in its language and must state that recipients will take steps to assure that the lack of English language skills will not be a barrier to admission and participation in vocational education programs.

Annual Notice to the General Public includes:

Background

The federal guidelines state that the state agency (recipient) responsible for the administration of Career Technical Education programs shall submit to the United States Department of Education the Methods of Administration (MOA) and related procedures it will follow in carrying out its civil rights obligations under the guidelines. In July of 1979, OCR issued its Memorandum of Procedures (MOP) setting forth the procedures and minimum requirements for state agencies (recipients) regarding the development of civil rights compliance programs covering sub-recipients (colleges) that provide CTE programs and receive federal financial assistance. In September of 1996 the Office for Civil Rights (OCR) issued revisions to the MOP. The relevant provisions of all existing state agency MOA agreements approved by OCR remain valid, unless modified by the September 1996 revisions to the MOP. In 1999, a self-evaluation booklet was designed as a user-friendly tool in preparing for and in conducting civil rights reviews. This document continues to remain in force and is available.

CCC and Civil Rights Activities

The federal Memorandum of Understanding as agreed upon requires the Chancellor’s Office to:

  • Conduct an annual desk-audit review of all eligible programs using available enrollment statistics and other information to identity areas of possible non-compliance.
  • Conduct a comprehensive on-site review of at least 25% of the colleges, but no fewer than three and no more than 25 each year.
  • Identify findings of non-compliance and work with college/district officials to obtain Voluntary Compliance via a Voluntary Compliance Plan (VCP) to remedy findings.
  • Conduct yearly review of VCP’s for completion.
  • Respond to and assist in resolution of civil rights compliance issues by providing technical assistance in the development and completion of VCPs.

College Selection Criteria

The California Community College Compliance Review Process is conducted annually. All 112 colleges are divided into a four-year cycle with one cycle reviewed each year. Although these cycles were created in 1984 as new colleges were established they were added to one of the cycles. The cycles were created using demographics and geography to balance each cycle. Within each cycle a subset of colleges are evaluated based upon statistical data, staffing, civil rights issues and recent on-site visits. A minimum of 3 colleges each year are selected via computer programs and other information include, but not limited to:

  • Pending civil rights litigation complaints or grievances
  • Data from enrollment reports that may indicated disproportionate enrollments
  • Information or reports from the Office for Civil rights
  • Recent of pending enforcement proceeding by the Office for Civil Rights
  • Complaints of non-compliance associated with Section 504 and Title II - ADA
  • Date of last on-site review

On-Site Review Components

Upon selection and notification of an on-site review a pre-interview is arranged to explain the process, respond to questions and establish dates for a review that will generally take two to three days. Components may include, but not be limited to:

  • Document reviews
  • Interviews with faculty, students, counselors, etc.
  • Accessibility of all facilities for disabled students and faculty
  • Program facilities and access
  • Satellite centers

On-Site Review

After meeting with the designated local contact, the consultants conducting the review will examine the supportive documentation, visit sites, and interview responsible personnel related to each of the required areas. The extent of the review will depend on the nature of the particular indicator and information provided for the reviewers.

Findings

At the conclusion of the review, the consultants will conduct an exit interview with college personnel to discuss their findings. Any additional information that has been gathered by the college may be presented during the exit interview. Based on the reviewers' final evaluation, a formal letter of findings will be issued from Chancellor's Office identifying the violations and providing a timeline for the development and instructions on submission of a Voluntary Compliance Plan (VCP) addressing identified compliance violations. Approximately a year after submission, the Chancellor's Office will request an update of the VCP. The update reports on the progress and/or completion of activities stated in the VCP to address specific findings. The updates are compiled by the Chancellor's Office into a biennial report that is submitted to the federal Office for Civil Rights.


For Division website assistance, contact Jeannine Clemons at jclemons@cccco.edu.