The University of Tennessee Title VI Compliance Report and Implementation Plan FY 2017-2018 Table of Contents Section Page
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The University of Tennessee Title VI Compliance Report and Implementation Plan FY 2017-2018 Table of Contents Section Page 1. Table of Contents 2. Overview 1 3. Responsible Officials 3 4. Definitions 4 5. Non-Discrimination Policy 5 6. Civil Rights Office 6 7. Discriminatory Practices 8 8. Federal Programs or Activities 9 9. Data Collection and Analysis 10 10. Limited English Proficiency (LEP) 15 11. Complaint Procedures 19 12. Title VI Training 28 13. Subrecipient Monitoring 32 14. Public Notice and Outreach 37 15. Compliance Reporting 40 16. Evaluation Procedures 41 Appendix A (Federal Programs or Activities Funding Sources) A-001 Appendix B (Limited English Proficiency) B-001 Appendix C (Complaint Procedures) C-001 Appendix D (Training) D-001 Appendix E (Subrecipients) E-001 Appendix F (Vendors) F-001 2. Overview The University of Tennessee (UT) is a state institution of public higher education. The UT System is composed of the Chattanooga, Knoxville and Martin campuses, the Health Science Center in Memphis, the Institute for Public Service, the Institute of Agriculture, the Space Institute in Tullahoma, and the System-wide Administration. With UT Extension having offices in all 95 counties, the University of Tennessee has a presence across the entire State of Tennessee. The mission of the University of Tennessee is as follows: The University of Tennessee System, through its multiple campuses and institutes, serves the people of Tennessee and beyond through the discovery, communication and application of knowledge. The System is committed to providing undergraduate, graduate and professional education programs in a diverse learning environment that prepares students to be leaders in a global society. The UT System’s delivery of education, discovery, outreach and public service contributes to the economic, social and environmental well-being of all Tennesseans. The University spans the State of Tennessee with a network of instructional, research, and service units located in every county. Dr. Joseph A. DiPietro currently serves as President of the University of Tennessee. The Executive Vice President and Chief Operating Officer, Chief Financial Officer, General Counsel, four vice presidents, and chancellors from the Chattanooga, Knoxville and Martin campuses, the Health Science Center, and the Institute of Agriculture, report to the president, as do two special advisors and a number of other individuals. An organizational chart is presented on the next page. 1 2 4. Definitions Definitions, as utilized across the University of Tennessee System when referring to Title VI matters, are as follows: 1. Assurances – A written statement or contractual agreement signed by an authorized subrecipient official in which the subrecipient agrees to administer federally funded assisted programs in accordance with civil rights laws and regulations. 2. Beneficiaries – Those persons to whom the University of Tennessee provides instructional, research, or public service assistance, service or benefits. 3. Compliance – The fulfillment of the requirements of Title VI and other applicable laws, and implementing regulations and instructions to the extent that no distinctions are made in the delivery of any service or benefit on the basis of race, color, or national origin. 4. Contractor – A person or entity that performs services for the University of Tennessee at a specified price. 5. Discrimination – To make any distinction between one person or group of persons and others, either intentionally, by neglect, or by the effect of actions or lack of actions based on race, color, or national origin. 6. Federal Assistance – Any funding, property, or aid provided for the purpose of assisting a beneficiary. 7. Noncompliance – Failure or refusal to comply with Title VI of the Civil Rights Act of 1964, other applicable civil rights laws, and implementing regulations. 8. Subrecipient – Any entity or individual with which the University of Tennessee contracts to perform services funded in whole or in part by federal funds. 9. Vendor - A person or entity that supplies goods or services at an agreed-upon price, at the promised time, and without the need for the University’s intervention, renegotiation, or continued expediting. 4 5. Non-Discrimination Policy All University of Tennessee programs are accessible without regard to race, color, or national origin. UT has a full EEO/AA Statement/Non-Discrimination Statement that is required to be included in position announcements (not paid advertisements) sent to potential referral sources, catalogs, application forms, posters, and other material used in conjunction with the referral and/or recruitment of students, faculty or staff, and publications which contain general information and are made available to alumni/ae, faculty, staff, students or other participants in, or beneficiaries of, University programs. The statement reads as follows: All qualified applicants will receive equal consideration for employment and admissions without regard to race, color, national origin, religion, sex, pregnancy, marital status, sexual orientation, gender identity, age, physical or mental disability, or covered veteran status. Eligibility and other terms and conditions of employment benefits at The University of Tennessee are governed by laws and regulations of the State of Tennessee, and this non-discrimination statement is intended to be consistent with those laws and regulations. In accordance with the requirements of Title VI of the Civil Rights Act of 1964, Title IX of the Education Amendments of 1972, Section 504 of the Rehabilitation Act of 1973, and the Americans with Disabilities Act of 1990, The University of Tennessee affirmatively states that it does not discriminate on the basis of race, sex, or disability in its education programs and activities, and this policy extends to employment by the University. Inquiries and charges of violation of Title VI (race, color and national origin), Title IX (sex), Section 504 (disability), ADA (disability), Age Discrimination in Employment Act (age), sexual orientation, or veteran status should be directed to <each campus/institute Equity & Diversity Office…with contact information>. The University of Tennessee and its subrecipients and/or contractors shall make available any compliance report to be reviewed by the Tennessee Human Rights Commission (THRC) upon request. 5 6. Civil Rights Office The University of Tennessee is organized to effect compliance and implement civil rights enforcement by providing coordination of effort through the System Administration and placing responsibility for implementation at the campus level. Dr. Joe DiPietro, President of the University, has overall responsibility for Title VI activities and compliance while the chancellors are responsible for their individual campuses and institutes. Dr. DiPietro has designated Dr. Noma Anderson, Special Advisor to the President for Diversity and Inclusion, to be responsible for the development and implementation of the University’s Title VI Implementation Plan and subsequent updates. Janice Hodge, Director of HR Technology & Metrics, is responsible for coordinating with the campuses and institutes to write and submit the Title VI Compliance Report and Implementation Plan to the Tennessee Human Rights Commission. Each campus and institute has a named individual in its Equity and Diversity office who coordinates Title VI activities and monitors compliance with Title VI in accordance with federal and state laws. The campus/institute Title VI coordinators are listed below: Chattanooga: • Ms. Rosite Delgado, Interim Director, Equity & Diversity o Ms. Kimberly Golden, Equity Affairs Specialist o Ms. Raegan Johnson, Graduate Assistant o Ms. Charlene Ragland, Administrative Specialist o Ms. Delicia Ragland, Undergraduate Assistant o Ms. J’Tia Williamson, Undergraduate Student Assistant Health Science Center (Memphis): • Dr. Michael Alston, Assistant Vice Chancellor, Equity & Diversity o Ms. Tasha Clark, Sr. Administrative Specialist, Compliance Assurance o Ms. Sophia Mosher, Sr. Administrative Specialist o Ms. Olivia Ralph, JD, Sr. Compliance Consultant o Ms. Lauren Rotonda, Senior Inclusion Strategist o Ms. Stephanie Rozier, Administrative Specialist I Knoxville Area (Knoxville, Institute for Public Service, Institute of Agriculture, System Administration): • Ms. Jennifer Richter, Associate Vice Chancellor, Equity & Diversity o Ms. Nicole Cangey, Administrative Coordinator I o Mr. Nick Meanza, Jr., EEO Investigator o Ms. Izetta Slade, Associate Director o Ms. Tina Smith, Administrative Support Assistant III 6 Martin: • Mr. Joe T. Henderson, Equity & Diversity Officer, Equity & Diversity • Ms. Tina Harris, HR Specialist Space Institute (Tullahoma): • Ms. Patricia Burks-Jelks, Director, Human Resources and Equity & Diversity The responsibilities of the campus/institute Title VI coordinators are listed below. Title VI Coordinator Responsibilities • Assures compliance with Title VI regulations. • Investigates and resolves Title VI complaints. Establishes the process for complaint resolution and enforcement actions. • Records and reports the number and disposition of complaints received each fiscal year. • Notifies the public, employees, and students about Title VI requirements. Documents the specific procedures used for publicizing and distributing Title VI information (brochures, posters, etc.). • Distributes Limited English Proficiency (LEP) information to all parties who may be involved in LEP services. • Oversees