1. New Jersey DOLWD EO Monitoring
“Equal Opportunity: Your business, our business”
General comments about the purpose of monitoring; it is the role of the entire department and its affiliates. Ultimately the governor is accountable (29 CFR Part 37)

2. EO Officers As NJDL&WD EO Officers we:
Investigate discrimination complaints
Provide technical assistance to local EO officers and EO Representatives
Develop MOA, guidance and directives
Conduct mediation
Ensure that services are provided in a fair & equitable manner
Serve as liaisons with the USDOL CRC
The MOA provides a broad description of “periodic monitoring” at 29 CFR Part (d) (2)

3. EO Monitoring Monitoring is another function of our job
We are required to monitor as State EO officers in accordance to Federal Register 29 CFR Part 37 (see – 37.54)
We are therefore authorized to monitor
We monitor recipients receiving federal funds (WIA and One-Stops)
We monitor 18 (core One-Stops) counties annually
This includes all major partners (ES, UI, etc.)

4. Monitoring (cont’d)
Our primary focus is to ensure that One-Stop services are provided in a non-discriminatory and equitable manner
Our first step is to identify the areas to be reviewed in a particular year.
In a two year period, we would have examined all of the following for each One-Stop area:
Our approach is one that builds a positive view of the EO program and fosters cooperation.

5. Items Reviewed in a two Year Cycle
Census data
Equity of services
Organizational composition
Designation of local WIA EO Officer
Local EO file (containing directives and TA material)
Local WIA discrimination complaint file and Logs
Census data is made specific to new Jersey by our Labor Market Information section and can be obtained from our department’s website. Service data is obtained from our Division of One-Stop Administration and Support.

6. Items Reviewed in a two Year Cycle
Bilingual staffing of One-Stop
Universal Access to One-Stop services
EO is the Law notification (Posters/Flyers)
Sexual Harassment notification

7. Items Reviewed (Continued)
Interviews with One-Stop staff to determine awareness and readiness to deliver equitable services
Surveys of One-Stop customers to determine how they feel they are being treated
Observation of service delivery - individual and group
Review of contract assurances
Interviews with staff can become complicated when complaints are made. These complaints may or may not be related to EO issues.

8. Items Reviewed (Continued)
Review of accessibility of One-Stop facility, programs and services
Visit a subcontractor (usually a training school)
Tour the subcontractor facility and check for accessibility
Meet with school administration and interview WIA students

9. Notifying the One-Stop System
After identifying the areas to be reviewed we prepare for our onsite review
We select a Core One-Stop Career Center
We telephone the WIA Director/One-Stop Operator, ES Manager, UI Manager
As part of our program accessibility efforts, we also involve Division of Vocational Rehabilitation Services (DVRS) management
DVRS has become a key player through a federal grant called project Access which calls for identification of local Disability Program navigators, Accessibility Checklist, and $4,500 for each core One-Stop to purchase accessible equipment and software.

10. Notifying the One-Stop System
Each of the parties contacted receives a follow-up memo or letter regarding the dates of the review and a listing of the review topics.
This notice (like our monitoring instruments) is a shell-document on which names and dates are added.
Copies of the notices go to appropriate executive staff within the Department
The development of Shell documents for each stage of your review is an important time saver and lends consistency to your monitoring program.

11. Desk Review Prior to the onsite visit we review the following:
Census data for the One-Stop area
Service data produced by the Department (this data is requested for all one stops earlier in the year)
Organizational charts by ethnicity and gender

12. Onsite Visit The “package” we take to each review includes:
Copies of review notifications
Desk review findings
EO review checklist
Accessibility to Services & Facility Checklists

13. Onsite Visit Forms to review WIA customer records
Customer questionnaire
Forms to record observation of service delivery
Staff questionnaire
Extra copies of directives and EO Posters (Sp/E)

14. The Entrance Interview
The EO team meets with managers/directors of One-Stop programs at the core One-Stop Center
The purpose of the entrance interview is to ensure management and front line staff are prepared for our visit

15. The Entrance Interview
We describe the monitoring activities that will take place
We discuss desk review findings
We gather background information (or updates) about the One-Stop

16. The Entrance Interview
Questions are asked about how the Universal Access mandate is being addressed
Questions are asked about how limited English proficient individuals are being served
The accessibility to facility and programs checklist is completed

17. The Entrance Interview
As requested in the notification sent to the One-Stop Director/Operator, we request desk space or room from which to conduct staff interviews
EO review team members may at this point divide the tasks to be accomplished
One may conduct staff and customer interviews while the other is inspecting files, posters, and verifying accessibility.

18. Interviews Begin with a proper introduction Are conducted anonymously
Nonthreatening
Allow the staff or customer to give full responses
Include notation of person’s gender, ethnicity (where known or observable) and disability (if observable)

19. File Reviews 10% of WIA files reviewed
Maximum of 50 files per program (ES, UI, WIA)
Monitoring checklist is used that notes: receipt for issuance of EO Notice by WIA, absence of discriminatory comments in file, and absence of medical information.

20. File Reviews
Customers name (initials only), ethnicity, gender, and disability are captured on the checklist
Files with problems are noted on checklist and are set aside for discussion with local EO Officer

21. Observation
Observation of individual services (front desk/reception, intake, counseling) and group services (orientation, job club) are conducted unobtrusively
Ethnicity, gender, and disability is noted (as much as possible) in the count of those customers being observed
Checklist is used that identifies service being provided and determination, based on observation, of whether service is being delivered equitably

22. Inspection of Posters
EO is the Law posters should be prominently displayed in public waiting areas and employee break rooms
Name and number of current local EO Officer should be on poster
The EO Representative (State employee whose EO duties are limited) should also be identified on poster

23. Posters (Continued) TDD number should be on poster
Poster should be in Spanish and English
Next to the EO is the Law posters should be the Sexual Harassment posters (also in Spanish and English
Missing or damaged posters will be noted and replaced onsite by EO team
Additional posters may be mailed to the One-Stop

24. Visit to Subcontractor
Part of the notice sent to the WIA One-Stop Director or operator is a request that arrangements be made for the EO review team to visit a training facility that receives WIA funds
We usually ask the local EO Officer (or other senior official) to accompany us
The local EO Officer will see, hear, and learn along with us

25. Subcontractor (continued)
We meet the school president or owner (or other designated representative) and discuss the purpose of the visit
We take a tour of the facility and collect school brochures
Tours are not only educational, but you get a chance to see the school programs in action

26. Subcontractor (continued)
We check for accessibility to individuals with disabilities (signage, parking, exterior/interior paths of travel, elevators, entrances/doors, public facilities, computer stations, fire alarms, and so on)
We interview students placed there by the One-Stop Center under review to determine how they are being treated

27. Subcontractor (continued)
Any findings or concerns are shared with both the local EO Officer and the school president/owner
WE ARE ALMOST DONE!!!!

28. The Exit Conference
After the EO team meets to discuss EO findings the local EO Officer is asked to gather One-Stop Directors and ES/UI Managers
Any issues raised as a result of the review are discussed and, if possible, resolved
EO issues not resolved during the review and exit conference become corrective action requirements

29. Exit Conference (continued)
A date is given for the issuance of the EO monitoring report (within 30 days of the completion of the onsite review)
Those present are informed that corrective action responses are due within 30 days of receiving the report

30. The EO Report After monitoring, we prepare a report about our findings
The report is sent to directors and regional & local management

31. The EO Report
Depending on the areas chosen for review during a particular cycle, the report may contain statements and/or findings about the following:
Legal Authority to Monitor
Notification
Purpose
Methodology
Census & Data findings
Officials who were present during the review

32. The EO Report Background information
Service & facility accessibility checklists
Universal access
Services to LEP customers
Review of customer files
Interviews with staff
Interviews with customers

33. The EO Report Observation of individual and group services
Inspection of EO posters and flyers
Inspection of sexual harassment posters
Inspection of EO complaint file
Review of contract assurances
Inspection of local EO Officer’s file of directives and TA material
Visit to a training subcontractor facility
Technical assistance provided
Exit Conference

34. EO Report
The report includes findings/recommendations and gives a time frame (usually within 30 days of receipt of the report) for a corrective action response
The EO report serves as evidence that the MOA monitoring element has been met and can be reviewed by USDOL.

35. Corrective Action
Corrective action is something a program area needs to address in order to maintain federal compliance with applicable EO laws and regulations
The appropriate program area is required to notify our office as to what steps will be taken to correct an issue(s)
If we do not receive a response, we attempt follow-up contact with the area
Continued non response will result in communication with either Assistant Commissioners, the Chief of staff, Deputy Commissioner or the Commissioner
As a last resort, the USDOL may be alerted and federal funding could be Jeopardized.

36. Things to Consider
The EO Unit is an integral part of the Department within that state
Monitoring should be more beneficial than punitive
Be as prepared as possible for each review
Be on time…use time wisely
Be professional, polite, take pride in what you do
Have plenty of business cards for distribution

37. Thank you!