United Community Action Program, Inc.

Title VI

United Community Action Program, Inc.
Cimarron Public Transit System

 Title VI Nondiscrimination and Limited Proficiency Plan
Adopted September 19, 2017
Cimarron Public Transit System (CPTS) agrees to comply with all provisions prohibiting discrimination on the basis of race, color, or national origin in Title VI of the Civil Rights Act of 1964, as amended 42 U.S.C. 200d et seq., and with U.S. DOT regulations, "Nondiscrimination in Federally-Assisted Programs of the Department of Transportation - Effectuation of the Title VI of the Civil Rights Act," 49 CFR Part 21.

CPTS assures that no person shall, as provided by Federal and State civil rights laws, be excluded from participation in, be denied the benefits of, or be subjected to discrimination under any program or activity. CPTS further confirms every effort will be made to safeguard non-discrimination in all programs and activities, whether those programs and activities are fedrally funded or not.

CPTS meets the objectives of the FTA Master Agreement which governs all entities applying for FTA funding, including CPTS and its third-party contractors by promoting actions that:
  • Ensure the level and qualify of transportation service is provided without regard to race, color, or national origin.
  • Identify and address, as appropriate, dis-proportionally high and adverse effects of programs and activities on minority populations and low-income populations.
  • Promote the full and fair participation of all affected Title VI populations in transportation decision making.
  • Prevent the denial, reduction or delay in benefits related to programs and activities that benefit minority populations or low-income populations.
  • Ensure meaningful access to programs and activities by persons with Limited English Proficiency (LEP).

 Title VI and LEP Plan Coordinator:  Laura Corff, 2101 N. 14th Street, Suite 129, Ponca City, OK  74601

580-718-0444   Email Address: lcorff@ucapinc.org

Notice to the Public of Rights
CPTS provides services in a consistent manner without regard to race, color, national origin or limited English proficiency. Title VI of the Civil Rights Act of 1964 as amended and 49 CFR Part 21 prohibits discrimination based on race, color or national origin or limited English proficiency. Title VI notices will be posted on the agency website at www.ucapinc.or, at each transit site and on vehicles. Notices include who can file a complaint and information about submitting a complaint.

 

Members of the public may obtain additional information regarding Cimarron Public Transit System Title VI Non Discrimination and LEP obligations by contacting the Title VI and LEP Plan coordinator.

Procedures for Filing A Complaint

The complaint procedures apply to the beneficiaries of Cimarron Public Transit System (CPTS) programs, activities and services.

Right to file a complaint:  Any person who believes they have been discriminated against on the basis of race, color or national origin by Cimarron Public Transit System may file a Title VI complaint by completing and submitting the agency’s Title VI Complaint Form. Title VI complaints must be received in writing within 180 days of the alleged discriminatory complaint.

How to file a complaint: Information on how to file a Title VI complaint is posted on the agency website, and at each transit site. (The Cimarron Public Transit System complaint form is included as Appendix B.) A copy may be requested by writing to 501 Sixth Street, Pawnee, OK  74058 or email: lcorff@ucapinc.org.   Information on how to file a Title VI complaint may also be obtained by calling Cimarron Public Transit System Title VI Coordinator at 580-718-0444.

A signed, dated complaint may be submitted no more than 180 days from the date of the alleged incident. The complaint should include:

  • Name, address and telephone number;
  • Specific, detailed information (how, why, and when) about the alleged act of discrimination; and
  • Any other relevant information, including the names of any persons, if known, the agency should contact for clarity of the allegations.

Complaints should be submitted to CPTS Title VI Coordinator at 501 Sixth Street, Pawnee, OK  74058.

**Click here to access a copy of the Complaint Form.

Complaint Acceptance:  CPTS will only process complaints that are complete. Once a completed Title VI Complaint Form is received, CPTS will review it to determine if CPTS has jurisdiction. The complainant will receive an acknowledgement letter informing them whether or not the complaint will be investigated by CPTS.

Investigations:  CPTS will generally complete an investigation within 90 days from receipt of a completed complaint form. If more information is needed to resolve the case, CPTS may contact the complainant. Unless a longer period is specified by CPTS, the complainant will have ten (10) days from the date of the letter to send requested information to the CPTS investigator assigned to the case.

If the requested information is not received within that timeframe the case will be closed. Also, a case can be administratively closed if the complainant no longer wishes to pursue the case.

Letters of closure or finding:  After the Title VI investigator reviews the complaint, the Title VI investigator will issue one of two letters to the complainant: a closure letter or letter of finding (LOF).

A closure letter summarizes the allegations and states that there was not a Title VI violation and that the case will be closed.

A Letter of Finding (LOF) summarizes the allegations and provides an explanation of the corrective action taken.

 If the complainant disagrees with CPTS determination, the complainant may request reconsideration by submitting the request in writing to the Title VI investigator within seven (7) days after the date of the letter of closure or letter of finding, stating with specificity the basis for the reconsideration. CPTS will notify the complainant of the decision either to accept or reject the request for reconsideration within ten (10) days. In cases where reconsideration is granted, CPTS will issue a determination letter to the complainant upon completion of the reconsideration review.

If information is needed in another language, contact CPTS at 501 Sixth Street, Pawnee, OK or call 580-718-0444.

Documenting Complaints, Investigations, and Lawsuits

All Title VI complaints, investigations and lawsuits filed against Cimarron Public Transit System will be entered and tracked in a Cimarron Public Transit System complaint log, see Appendix D. Active investigations will be monitored for timely response on the part of all parties.  The Title VI Coordinator shall maintain the log.

Cimarron Public Transit System shall maintain correspondence and documentation related to Title VI complaints, including:

  • Date the complaint was filed
  • Complainant name and contact information
  • Complainant’s race, color, sex and national origin
  • Summary of allegations
  • Status of the Title VI complaints, investigations and lawsuits
  • Actions taken
  • Closure letter stating that there was not a Title VI violation and case is closed
  • Date of closure letter or letter of finding

    Limited English Proficiency

    The original LEP plan was adopted by the United Community Action Program, Inc. Board of Directors on November 13, 2012, and revised in November of 2016.

    INTRODUCTION

    This Limited English Proficiency Plan has been prepared to address Cimarron Public Transit’s responsibilities as a recipient of federal financial assistance as they relate to the needs of individuals with limited English proficiency language skills.  The plan has been prepared in accordance with Title VI of the Civil Rights Act of 1964, 42 U.S.C. 2000d, et seq, and its implementing regulations, which state that no person shall be subjected to discrimination on the basis of race, color or national origin.

    Executive Order 13166, titled Improving Access to Services for Persons with limited English Proficiency, indicates that differing treatment based upon a person’s inability to speak, read, write or understand English is a type of national origin discrimination.  It directs each agency to publish guidance for its respective recipients clarifying their obligation to ensure that such discrimination does not take place.  This order applies to all state and local agencies which receive federal funds, including all Cimarron Public Transit.

    Plan Summary

    Cimarron Public Transit System has developed this Limited English Proficiency Plan to help identify reasonable steps for providing language assistance to persons with limited English proficiency (LEP) who wish to access services provided.  As defined Executive Order 13166, LEP persons are those who do not speak English as their primary language and have limited ability to read, speak, write or understand English.  This plan outlines how to identify a person who may need language assistance, the ways in which assistance may be provided, staff training that may be required, and how to notify LEP persons that assistance is available.

    In order to prepare this plan, Cimarron Public Transit System used the four-factor LEP analysis which considers the following factors:

    1. The number or proportion of LEP persons in the service area who may be served by Cimarron Public Transit System.
    2. The frequency with which LEP persons come in contact with Cimarron Public Transit Services.
    3. The nature and importance of services provided by the Cimarron Public Transit System to the LEP population.
    4. The interpretation services available to Cimarron Public Transit System and overall cost to provide LEP assistance.  A summary of the results of the four-factor analysis is in the following section.

    MEANINGFUL ACCESS:  FOUR-FACTOR ANALYSIS

    1. The number or proportion of LEP persons in the service area who may be served or are likely to require Cimarron Public Transit services.

    Cimarron Public Transit staff reviewed the linguistic diversity of LEP population data from the Migration Policy Institute to determine that 3,200 persons, or 1.4% of population in the Cimarron Public Transit service area, speak English “less than very well”. In Kay County, 1,000 LEP individuals speak Spanish. In Washington County, 700 LEP speak Spanish. 

    1. The frequency with which LEP persons come in contact with Cimarron Public Transit services.

    Cimarron Public Transit staff reviewed the frequency with which the board, office staff and drivers have, or could have contact with LEP persons.  This includes phone inquiries or office visits.  To date, Cimarron Public Transit has had no requests for interpreters and no requests for translated program documents.  The board, office staff and drivers have little contact with LEP persons. Those LEP persons staff do come into contact with have a family member or friend to assist with translation, if needed.

    1. The nature and importance of services provided by Cimarron Public Transit to the LEP population.

    There is no large geographic concentration of any type of LEP individuals in the service area for Cimarron Public Transit.  The overwhelming majority of the population speak only English.  As a result, there are no social, service, professional and leadership organizations within the Cimarron Public Transit service area that focus on outreach to LEP individuals, that the agency is aware of.  Cimarron Public Transit board, office staff and drivers are most likely to encounter LEP individuals through transportation rides, office visits, phone conversations and attendance at board or public meetings.

    1. The resources available to Cimarron Public Transit, and overall costs to provide LEP assistance.

    Cimarron Public Transit reviewed its available resources and determined there are no local citizens available to provide voluntary Spanish translation, however, a part time, bi-lingual driver is available to assist with Spanish translation and a part time, bi-lingual driver is available to assist with Russian translation. It was determined that The Ridership Policy, Title VI Notice to the Public and WorkRide Form were most needed to be translated in Spanish. Each site has a copy available for use. Spanish Translation cards were printed for each transit staff member to assist in communicating with an LEP person who speaks Spanish. The website and brochures have a notice in Spanish, if information is needed in another format. Google translate is another option to provide translation assistance, if needed.

    LANGUAGE ASSISTANCE

    A person who does not speak English as their primary language and who has a limited ability to read, write, speak or understand English may be a Limited English proficient person and may be entitled to language assistance with respect to Cimarron Public Transit services.  Language assistance can include interpretation, which means oral or spoken transfer of a message from one language into another language and/or translation, which means the written transfer of a message from one language into another language.

    How Cimarron Public Transit staff may identify an LEP person who needs language assistance:

    ●Cimarron Public Transit staff can be provided “I Speak” cards to assist in identifying the language interpretation needed, if the occasion arises.

    ●Cimarron Public Transit staff will be informally surveyed periodically on their experience concerning contacts with LEP persons.

    ●When Cimarron Public Transit sponsors an informational meeting or event, an advanced public notice of the event will likely be published in local newspapers, including an opportunity to request an accommodation related to offering a translator (LEP) or interpreter (sign language for hearing impaired individuals).  Additionally, a staff person may greet participants as they arrive.  By informally engaging participants in conversation it is possible to gauge each attendee’s ability to speak and understand English.  Although translation may not be able to be provided at the event, this process will help identify the need for future events.

    Language Assistance Measures

    Although there is a very low percentage of LEP individuals, that is, persons who speak English “not well” or “not at all”, in Cimarron Public Transit System’s service area, the agency will strive to offer the following measures:

    1. Cimarron Transit staff will take reasonable steps to provide the opportunity for meaningful access to LEP clients who have difficulty communicating in English.
    2. The following resources will be utilized to accommodate LEP persons:

    ●Volunteer interpreters for the Spanish language will be contacted for availability within a reasonable time period, as needed.

    ●Attempts will be made for language interpretation for all other languages through Google Translate or telephone interpretation services, as needed and available.

    STAFF TRAINING

    Title VI and LEP training will be provided to Cimarron Public Transit System staff as follows:

    ●The plan will be disseminated to all transit staff. Acknowledgment of receipt and understanding of the plan will be maintained in each transit staff’s personnel file. (See Appendix E). This is a required document for all staff to sign and date.)

    ●CPTS will educate staff on language assistance services offered to the public.

    ●CPTS will disseminate and describe the use of Spanish translation cards.

    ●CPTS will train transit staff to report requests for language assistance.

    ●Transit staff will be trained on how to handle a potential Title VI/LEP complaint.

    TRANSLATION OF DOCUMENTS

    Cimarron Public Transit weighed the cost and benefits of translating documents for potential LEP groups.  Considering the expense of translating documents, the likelihood of frequent changes in documents and other relevant factors, at this time the Ridership Policy and Work Ride Form are the only forms translated into Spanish.

    Due to the small local LEP population, Cimarron Public Transit does not have a formal outreach procedure in place.  Translation resources are limited in this region.  However, when and if the need arises for LEP outreach, Cimarron Public Transit will consider available options.

    When staff prepares a document, or schedules a meeting, for which the target audience is expected to include LEP individuals, documents, meeting notices, flyers, and agendas will be printed in an alternative language based on the known LEP population.

    MONITORING

    Cimarron Public Transit will update the LEP Plan as required.  At a minimum, the plan will be reviewed and updated when data from the new Census is available, or when it is clear that higher concentrations of LEP individuals are present in Cimarron Public Transit service area.  Updates will consider the following:

    ●The number of documented LEP person contacts encountered annually.

    ●How the needs of LEP persons have been addressed.

    ●Determination of the current LEP population in the service area.

    ●Determination as to whether the need for translation services has changed.

    ●Determine whether Cimarron Public Transit’s financial resources are sufficient to fund language assistance resources needed.

    ●Determine whether Cimarron Public Transit fully complies with the goals of this LEP Plan.

    ●Determine whether complaints have been received concerning the agency’s failure to meet the needs of LEP individuals.

    ●Maintain a Title VI compliant log, including LEP to review and determine issues and basis of complaints. (See Appendix D)

    DISSEMINATION OF CIMARRON PUBLIC TRANSIT LEP PLAN

    Cimarron Public Transit System will notify LEP persons of the LEP Plan and how to access language services, by posting signs at conspicuous and accessible locations, which may include but not be limited to the following:

    • United Community Action Program, Inc. website, www.ucapinc.org
    • Cimarron Public Transit System sites
    • Cimarron Public Transit System brochures
    • Press releases, public notices and agendas will provide an opportunity to request an accommodation related to offering a translator (LEP) or interpreter (sign language for hearing impaired individuals) the public that they can request information in another format or language by calling 580-718-0444. A Spanish translation of the Notice to the Public is posted below the English version of notices.

    Title VI and LEP Public Participation Plan

    It is Cimarron Public Transit System’s intent to provide an opportunity for public involvement and full access to the transportation decision making process in each stage of the planning and development of a transportation project to all segments of the population, including minority or low-income communities and populations who are not proficient in English. Public forums are scheduled annually in each county served to invite the public to participate in the transportation plan. Press releases that include the schedule of meetings and locations are published in local newspapers. Legal notices are published in the classified section of the largest newspapers in each county at least two consecutive weeks regarding a notice opportunity. Letters are mailed to elected officials, tribes, and private transit providers. Mass email notices are sent to businesses, contact representatives, chambers and social service organizations.

    To encourage the participation of minorities, the agency by-laws outline board membership. At least one-third of the Governing Board must be comprised of elected public officials, currently holding office or their representatives. At least one-third of the directors shall be persons chosen in accordance with democratic selection procedures adequate to assure that members are representative of low-income individuals and families in the neighborhood served. The remainder shall be officials or members of business, industry, labor, religious, law enforcement, education or other major groups and interests in the community served.

    It should be noted that CPTS transit riders and clients are not asked questions about ethnicity when scheduling a trip. Cimarron Public Transit System does not request or track this information. The program provides an estimated 2,250 trips each week.

    Cimarron Public Transit System has two senior advisory committees, Creek County Senior Advisory Committee and Kay County Senior Advisory Committee. These advisory bodies provide insight and feedback to the agency. They are non-elected bodies that review current and proposed activities of senior projects. Members are invited by transit administration and/or recommended by advisory members or representatives of social service organizations to participate. Meetings are open to the public.

    Senior surveys will be disseminated in Creek and Kay County annually. Surveys to the general ridership public will be disseminated bi-annually.


    Cimarron Public Transit Outreach Practices

    Cimarron Public Transit System ensures all outreach strategies, communications and public involvement efforts comply with Title VI. Cimarron Public Transit System’s Public Participation Plan proactively initiates the public involvement process and makes concerted efforts to involve members of all social, economic and ethnic groups. Events such as public forums and/or open houses are held at public or non-profit locations, are easily accessible to public transit, held convenient times and in compliance with the Americans with Disabilities Act.

    Aligned with the above referenced communication tactics, Cimarron Public Transit System provides the following:

    1. Title VI Non-discrimination and LEP Plan on agency’s website, www.ucapinc.org
    2. Title VI Notice to the public displayed at Transit Sites and in Transit Vehicles.
    3. Upon advance notice, volunteer translators may be provided.
    4. Upon advance notice, agency communication materials may be available in languages other than English, as needed.

    Title VI and LEP Public Engagement Process

    Cimarron Public Transit System will conduct a Public Engagement Process as part of the public forums held annually in the first quarter of the calendar year. This process will seek input, provide education and highlight key components of the Title VI Plan. This plan has been created to explain Title VI policies as well as provide education on how the policies relate to minority populations.

    Cimarron Public Transit System will conduct a 30 day public comment period to provide opportunities for feedback on the 2020-2023 Title VI Program.

    Comments will be accepted during the public outreach period via:

    • Email address
    • Regular mail at 501 Sixth Street, Pawnee, OK  74058
    • Telephone
    • In person

    Cimarron Public Transit System will provide a briefing to the Board of Directors and senior advisory committees regarding all public comments prior to decision making. A publicly available summary report will be compiled, including all individual comments. The report will be available upon written request.

    Public Outreach Efforts

    Cimarron Public Transit System engages in many activities to disseminate information about the program in and around the communities it serves up to including the following:

    • Submit press releases to local newspapers.
    • Host annual public forums in each county served.
    • Publish notices of opportunity in the legal section of major newspapers in the service area each year.
    • Publish advertisements in local newspapers during each year.
    • Maintain memberships in local Chambers of Commerce. Update agency information in Chamber directories and their websites.
    • Participate in local coalitions, committees and initiatives to include outreach, networking, attendance at community meetings and meeting with community leaders and representatives of agencies as a regular course of business.
    • Make presentations to civic and non-profit organizations, as requested.
    • Publish program brochures and disseminate materials throughout communities, via drivers, at transit sites and various locations and social service agencies in service area.
    • Disseminate business cards during regular course of business.
    • Publish contact information in local telephone directories and resource documents.
    • Disseminate surveys to Creek and Kay county seniors each year.
    • Bi-annually disseminate and compile surveys to service area riders, clients and social service agency representatives.

    Cimarron Public Transit Outreach Practices

    Cimarron Public Transit System ensures all outreach strategies, communications and public involvement efforts comply with Title VI. Cimarron Public Transit System’s Public Participation Plan proactively initiates the public involvement process and makes concerted efforts to involve members of all social, economic and ethnic groups. Events such as public forums and/or open houses are held at public or non-profit locations, are easily accessible to public transit, held convenient times and in compliance with the Americans with Disabilities Act.

    Aligned with the above referenced communication tactics, Cimarron Public Transit System provides the following:

    1. Title VI Non-discrimination and LEP Plan on agency’s website, www.ucapinc.org
    2. Title VI Notice to the public displayed at Transit Sites and in Transit Vehicles.
    3. Upon advance notice, volunteer translators may be provided.
    4. Upon advance notice, agency communication materials may be available in languages other than English, as needed.

    Title VI and LEP Public Engagement Process

    Cimarron Public Transit System will conduct a Public Engagement Process as part of the public forums held annually in the first quarter of the calendar year. This process will seek input, provide education and highlight key components of the Title VI Plan. This plan has been created to explain Title VI policies as well as provide education on how the policies relate to minority populations.

    Cimarron Public Transit System will conduct a 30 day public comment period to provide opportunities for feedback on the 2020-2023 Title VI Program.

    Comments will be accepted during the public outreach period via:

    • Email address
    • Regular mail at 501 Sixth Street, Pawnee, OK  74058
    • Telephone
    • In person

    Cimarron Public Transit System will provide a briefing to the Board of Directors and senior advisory committees regarding all public comments prior to decision making. A publicly available summary report will be compiled, including all individual comments. The report will be available upon written request.

    Public Outreach Efforts

    Cimarron Public Transit System engages in many activities to disseminate information about the program in and around the communities it serves up to including the following:

    • Submit press releases to local newspapers.
    • Host annual public forums in each county served.
    • Publish notices of opportunity in the legal section of major newspapers in the service area each year.
    • Publish advertisements in local newspapers during each year.
    • Maintain memberships in local Chambers of Commerce. Update agency information in Chamber directories and their websites.
    • Participate in local coalitions, committees and initiatives to include outreach, networking, attendance at community meetings and meeting with community leaders and representatives of agencies as a regular course of business.
    • Make presentations to civic and non-profit organizations, as requested.
    • Publish program brochures and disseminate materials throughout communities, via drivers, at transit sites and various locations and social service agencies in service area.
    • Disseminate business cards during regular course of business.
    • Publish contact information in local telephone directories and resource documents.
    • Disseminate surveys to Creek and Kay county seniors each year.
    • Bi-annually disseminate and compile surveys to service area riders, clients and social service agency representatives.

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