HomeMy WebLinkAboutRES 047 Draft 01 2020-2022COUNTY OF HAWAII
STATE OF HAWAI `I
RESOLUTION NO. 47 21
A RESOLUTION APPROVING THE COUNTY OF HAWAII DEPARTMENT OF
PARKS AND RECREATION 2020 TITLE VI PLAN PURSUANT TO THE FEDERAL
TRANSIT ADMINISTRATION TITLE VI CIRCULAR 4702.111 REQUIREMENTS AND
GUIDELINES
BE IT RESOLVED BY THE COUNCIL OF THE COUNTY OF HAWAII.
WHEREAS, Title VI of the Civil Rights Act of 1964 (42 U.S.C. § 2000d et seq.)
prohibits discrimination on the basis of race, color or national origin for recipients of federal
financial assistance; and
WHEREAS, the Department of Parks and Recreation (P&R), as a recipient of Federal
Transit Administration ("FTA") financial assistance for the purchase of vehicles to provide
transportation for the Coordinated Services for the Elderly program, must prepare and submit to
the FTA a Title VI Plan that is compliant with FTA Circular 4702.1 B Title VI Requirements and
Guidelines for FTA Recipients ("Circular"); and
WHEREAS, P&R prepared the attached 2020 Title VI Plan in compliance with the
requirements set forth in the Circular and reported that P&R provides public transit service in
conformance with Title VI legislation that prohibits discrimination on the basis of race, color, or
national origin; and
WHEREAS, the 2020 Title VI Plan must be approved by the County's governing entity,
the Hawai'i County Council, prior to submission to the FTA, pursuant to the Circular's
Requirements and Guidelines; now therefore,
BE IT RESOLVED BY THE COUNCIL OF THE COUNTY OF HAWAII, in
accordance with Article 111, Section 3-1 of the Hawai'i County Charter, the County of Hawai'i,
that the 2020 Title VI Plan, attached hereto and which by reference is made a part hereof, be
approved; and
BE IT FURTHER RESOLVED that P&R Director can make minor or editing changes
to the 2020 Title VI Plan; attached hereto, provided no substantial additions or deletions may be
made; and.
BE IT FINALLY RESOLVED that the County Clerk shall transmit a copy of this
resolution to: (1) Mayor Mitchell D. Roth; (2) Department of Parks and Recreation Director
Maurice Messina; and (3) J Yoshimoto, Deputy Corporation Counsel, Office of the Corporation
Counsel.
Dated at Kona Hawai'i,, this 17th day of March 2021.
INTRODUCED BY:
COUNCIL MEMBER, COUNTY OF HAWAI"I
COUNTY COUNCIL
County of Hawaii
Hilo, Hawai'i
I hereby certify that the foregoing RESOLUTION was by
the vote indicated to the right hereof adopted by the COUNCIL of the
ount} of I lawai'i on March 17, 2021
ATTEST:
0)
ROLL CALL VOTE
Reference: C-119/PRPSC-14
RESOLUTION NO. 47 2
AYES NOES
ABS
FX
CHUNG
x
DAVID
X
INABA
x
KAN EALIl-KLEIN FELDER
x
KIERKIEWICZ
x
KIMBALL
x
LEE LOY
x
RICHARDS
x
VILLEGAS
x
8 0
1
0
Reference: C-119/PRPSC-14
RESOLUTION NO. 47 2
Created: January Ib, 2020
Coordinated Services for the Elderly
County of Hawaii
Dept. of Parks and Recreation
Elderly Activities Division
1
All
CQDtents
FTAI3/0 .............................. ........................................... ........................................................................................
I
TitleK7Plan .............. ..................................... .................................. ......................................................................
1
ExecutiveSummary ........................ ....................................................................
..................................... ....... 3
Non Discrimination Policy Statement ............................................................. .................................................
3
Non Discrimination Notice tothe Public .................................................................................
......................... 5
List ofLocations Where Title VlNotice |sPosted ..............................................................................................
Discrimination Complaint Procedures ................................................. ............................................................
7
DiscriminationComplaint Form ......................................................................................................................
10
Discrimination Investigations, Complaints and Lawsuits ................................................................................
13
PublicParticipation Plan .............................................................................................................................
................ I5
Limited English Proficiency Plan ......................................................................................................................
17
Non -elected Committees Membership Table .................................................................................................
2O
Monitoring for 531OSub-Recipient Title NCompliance .................................................................................
2O
TitleV1Training ...................................................................................................
........................................... 21
Title V1Equity Analysis .......................................................................................
Error! Bookmark not defined.
Board Approval for the Title v|Program .......................................................... ..............................................
2Z
OrganizationalChart ................................................................. .....................................................................
Z5
APPENDIX: ......... ....................... .............................................................................
....................................... 24
Four -Factor Analysis .......................................................................................................
................................ 24
N
The Hawaii County, Department of Parks and Recreation Coordinated Services for the Elderly
Program offers senior citizens 60 years and older a wide variety of services within three major
components consisting of Transportation (essential shopping, medical appointments, congregate
meal sites, and recreational activities), Chore (light housekeeping, errand running), Information
and Assistance (providing information on available community resources, networking with
services providers). One phone call to our office is your direct linkage to services and
information available in Hawai` i County, such as: Determining your particular needs; Making
referrals to appropriate resource agencies or providing assistance to follow-up on your particular
needs; Providing you with information about programs and services; Issuing the County Senior
Citizen ID card which offers discounts from various business establishments; and Providing you
with other key services, such as in-home chore (which includes light housekeeping, laundry,
meal planning, cooking, shopping assistance, personal care, running errands, escort, etc.),
transportation, friendly visiting, letter reading/writing, translating/interpreting, counseling,
financial affairs, housing assistance, client advocacy and outreach activities.
Non Discrimination Policy Statement
The Coordinated Services for the Elderly assures full compliance with Title VI of the Civil
Rights act of 1964, the Restoration Act of 1987, and related statutes and regulations in all
programs and activities. Title VI states that "no person shall, on the grounds of race, color, or
national origin, be excluded from participation in, be denied the benefits of, or be otherwise
subjected to discrimination" under any the Coordinated Services for the Elderly's sponsored
program or activity. There is no distinction between the sources of funding.
The Coordinated Services for the Elderly also assures that every effort will be made to provide
programs, services and activities in a nondiscriminatory manner to minority and low income
populations. Furthermore, the Coordinated Services for the Elderly will take reasonable steps
to provide meaningful access to services for persons with Limited English Proficiency (LEP).
When the Coordinated Services for the Elderly distributes Federal -aid funds to another
entity/person, the Coordinated Services for the Elderly will ensure all sub -recipients fully
comply with the Coordinated Services for the Elderly's Title VI Nondiscrimination Program
requirements. The Director, Hawaii County Department of Parks and Recreation has
delegated the authority to the Elderly Activities Operations Assistant Director to oversee and
implement FTA Title VI requirements.
Maurice Messina
SIGNATURE OF AUTHORIZED OFFICIAL
Director, Department of Parks and Recreation
TITLE
Nor,, Discrlminatior� 'N'otice -to the Public
IMPORTANT: The Non -Discrimination Notice to the Public must also be provided IN ANY
LANGUAGE(S) SPOKEN BYLimited English Proficiency (LEP) POPULATIONS THATMEET THE
SAFE HARBOR THRESHOLD
Notification of Rights Under Title VI
Coordinated Services for the Elderly
The Coordinated Services for the Elderly operates its programs and services
without regard to race, color, or national origin in accordance with Title VI of
the Civil Rights Act of 1964, and related nondiscrimination authorities, any
person who believes she or he has been aggrieved by any unlawful
discriminatory practice under Title VI may file a complaint with the
Coordinated Services for the Elderly.
For more information on the Coordinated Services for the Elderly Title VI
Program, and/or discrimination complaint procedures, contact the
Operations Assistant Director., at (808) 323-4320, email:
ead2C&hawaiicounty.gov; or visit our administrative office at West Hawaii
Civic Center, Building B, 74-5044 Kailua-Kona, HI 96740
A complainant may file a complaint directly with the State of Hawaii
Department of Transportation (HDOT) Office of Civil Rights, ATTN: Title
VI Specialist, 200 Rodgers Boulevard, Honolulu, HI 96819 or the Federal
Transit Administration (FTA) ATTN: Title VI Program Coordinator, East
Building, 5th Floor -TCR 1200 New Jersey Ave., SE Washington DC 20590.
If information is needed in another language, contact: Tasha Hoggatt,
Equal Opportunity Officer 1 ADA Coordinator at (808) 961-8361.
Para infonnaci6n en Espaftol /lame: Tasha Hoggatt, Equal Opportunity
Officer 1 ADA Coordinator at (808) 961-8361.
!7
IMPORTANT: The Non -Discrimination Notice to the Public must also be provided IN ANY
LANGUAGE(S) SPOKEN BYLimited English Proficiency (LEP) POPULATIONS THATMEET THE
SAFE HARBOR THRESHOLD
USL of Locations Where Title V1 Notice Is Posted
The Title VI Non -Discrimination Notice to the public is currently posted at the following
locations:
Location Name
Address
city
Coordinated Services
West Hawaii Civic Center, Building B
Kailua-Kona, M
for the Elderly, West
74-5044 Ane Keohokalole Hwy
Hawaii
Kailua-Kona, HI 96740
Coordinated Services
1055 Kinoole Street, Suite 106 Hilo, Hawaii
Hilo, HI
for the Elderly, East
96720
Hawaii
Coordinated Services
Island -wide
Island -wide
vehicles
Coordinated Services
Island -wide circulation
Island -wide
for the Elderly
circulation
Brochures
County of Hawaii
bLtpLLwww.parks.hawaricounty-lov crivisionsLeldenL rl -
--
Island -wide
Coordinated Services
-activities coo rd i nated-se rVi ces-to r-th e-eldlerl -cse
Website
Discrimination Complaint- Procedures
These procedures provide guidance for all complaints filed under Title VI of the Civil Rights Act
of 1964, as they relate to any program or activity that is administered by the Coordinated
Services for the Elderly, or its consultants, contractors and vendors. In addition to these
procedures, complainants have the right to file a formal complaint with other State or Federal
agencies or to seek private counsel for complaints alleging discrimination. Every effort will be
made to resolve complaints at the lowest possible level.
(1) Any person who believes they have been discriminated against on the basis of race, color,
or national origin, may file a discrimination complaint by completing and submitting the
agency's Title VI Complaint Form.
(2) Formal complaints must be filed within one -hundred eighty (18 0) calendar days of the
latest incident of alleged discrimination, or the date when the alleged discrimination
became known to the complainant(s), or where there has been a continuing course of
conduct, the date on which the conduct was discontinued or the latest instance of the
conduct.
(3) Complaints must be in writing and signed by the complainant(s) and must include the
complainant(s) name, address and phone number.
(4) Allegations received by fax or e-mail will be acknowledged and processed, once the
identity of the complainant(s) and the intent to proceed with the complaint have been
established. For this, the complainant(s) is required to mail the signed, original of the fax
or email transmittal for the complaint to be processed.
(5) Allegations received by telephone will be reduced to writing and provided to the
complainant(s) for confirmation or revision before processing. A complaint form will be
forwarded to the complainant(s) to complete, sign and return for processing.
(6) Once submitted Coordinated Services for the Elderly will review the complaint form to
determine jurisdiction. All complainants will receive an acknowledgement letter
informing them of whether the complaint will be investigated by the Coordinated
Services for the Elderly or submitted to the State or Federal authority for processing.
Investigations
(1) The Coordinated Services for the Elderly will investigate discrimination complaints
against its sub -recipients; all other discrimination complaints filed against the
Coordinated Services for the Elderly will be investigated by the HDOT OCR.
(2) For discrimination complaints filed against the Coordinated Services for the Elderly
within seventy-two (72) hours or three (3) calendar days of receipt, the Coordinated
Services for the Elderly will notify HDOT OCR of the discrimination complaint being
filed. The complaint will then be logged identifying its basis of discrimination, the
status, and the next steps. HDOT OCR then will assume jurisdiction and follow HDOT's
complaint procedures for investigating the complaint.
(3) For discrimination complaints filed against the Coordinated Services for the Elderly
sub -recipients (i.e., consultants, vendors, and contractors) the Coordinated Services for
the Elderly will assume jurisdiction and will investigate and adjudicate the case.
(4) The Coordinated Services for the Elderly has ninety (90) days to investigate the
complaint. If more information is needed to resolve the case, the Authority may contact
the complainant(s). The complainant(s) has ten (10) business days from the date of the
letter to send requested information to the investigator assigned to the case. If the
investigator is not contacted by the complainant(s) or does not receive the additional
information within ten (10) business days, the Authority can administratively close the
case. A case can be administratively closed also if the complainant(s) no longer wishes
to pursue their case.
(5) After the investigation is completed, an investigative report will be drafted, and the
parties will be notified of the outcome. A letter shall be issued summarizing the
investigative findings, and whether or not there was a violation of the Agency's
nondiscrimination policy. In instances where there was no finding, the parties will be
informed of such and that the case is closed. In cases where there appeared to be a
violation, the parties shall be informed that appropriate action shall be taken to ensure
that the alleged act(s) of discrimination stopes. Complainants shall be notified of their
right to pursue other avenues of recourse.
(6) A copy of the investigative report and the notification letter shall be submitted to HDOT
OCR within seventy-two (72) hours of being issued to the parties.
(7) A complainant dissatisfied with the Coordinated Services for the Elderly's decision
may file a complaint with the Hawaii Department of Transportation, Office of Civil
Rights, Title VI Specialist, 200 Rodgers Boulevard, Honolulu, HI 96819 or the Federal
Transit Administration offices of Civil Rights, Attention Title VI Program Coordinator,
East Building, 5th Floor -TCR 1200 New Jersey Ave., SE Washington DC 20590.
(8) A copy of these procedures can be found online at HDOT OCR website:
httu:lll idot,hawaii. ovlad inistrationlocrltitle-vi-pro,,ra /
0
If information is needed in another language contact, Tasha Hoggatt, Equal Opportunity
Officer /ADA Coordinator at (808) 961-8361.
Para infonnaci6n en Espaftol Ilame: Tasha Hoggatt, Equal Opportunity Officer / ADA
Coordinator at (808) 961-8361.
L
Discri all in a tion 'ornplah- � �-orm
P" c'
Name:
Address:
Telephone (Home):
Telephone (Work):
Electronic Mail Address:
Large Print El Audio Tape 0
Accessible Format Requirements? TDD 0 Other ❑
k'.
*91
-
Are you filing this complaint on your own behalf? Yes* El No F
*If answered "yes " to this question, go to Section III,
If not, please supply the name and relationship of
the person for whom you are complaining.
Please explain why you have filed for a third party:
Please confirm that you have obtained the permission of the
Aggrieved party if you are filing on behalf of a third party. 0 Yes F-1 No
R9"'915R!11"'.'k%
10-
I believe the discrimination I experienced was based on (check all that apply):
Race 0 Color El National Origin F
Date of Alleged Discrimination (Month, Day,Year): Click or tap here to enter text.
Explain as clearly as possible what happened and why you believe you were discriminated
against. Describe all persons who were involved. Include the name and contact information
of the person(s) who discriminated against you (if known) as well as names and contact
information of any witnesses. If more space is need, please use the back of this form.
Owg 1W g +
Have you previously filed a discrimination complaint with this
agency? ❑ Yes 0 No
ce
If yes, please provide any reference information regarding your previous complaint.
a Pa• ... .rc ��. ... .. ..°�be '.n ortF .... .^?f'. ..... .. `. ? .. ?,.s -^, s .. ... z., ....�.. .... ... ir'�k ,•a, ..S � .2� .. i.. .. YS :�
Have you filed this complaint with any other Federal, State, or local agency, or with any Federal
or State court?
❑ Yes O No
If yes, name all that apply:
Federal Agency:
Federal Court:
State Court:
State Agency:
Local Agency:
Please provide information about a contact person at the agency/court where the complaint
was filed.
Name:
Title:
Agency:
Address:
Telephone:
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Name of agency complaint is against:
Name of person complaint is against:
Title:
Location:
Telephone Number (if available):
You may attach any written materials or other information that you think is relevant to your
Complaint. Your signature and date are required below
Signature
11
Date
Coordinated Services for the Elderly
West Hawaii Civic Center, Building B
74-5044 Ane Keohokalole Hwy
Kailua-Kona, HI 96740
Operations Assistant Director
(808) 323-4320
ead2*hawaiicounty.gov
A copy of this form can be found online at:
12
x?d bid=l& id= 102699&cr= 1
INVESTIGATIONS
1) NONE
2)
LAWSUITS
I)NONE
2)
COMPLAINTS
I)NONE
2)
Discrimination Investigations, Complaints and Lawsuits
This form will be submitted annually to HDOT OCR. If no investigations, lawsuits, or
complaints were filed, type "None" for each category.
The Coordinated Services for the Elderly has not had any Title VI discrimination complaints,
investigations, or lawsuits in 2019.
13
Elderly
FTA 5311
Public Participation Plan
14
The Coordinated Services for the Elderly engages the public in its planning and decision-
making processes, as well as its marketing and outreach activities. The public will be invited to
participate in the process whether through public meetings or surveys. As an agency receiving
federal financial assistance, the Coordinated Services for the Elderly made the following
community outreach efforts:
The Coordinated Services for the Elderly has worked in conjunction with the County Civil
Defense for the last three (3) years in the development of the County Evacuation Plan. This plan
specifically addresses the needs of including, at -risk minority and low-income populations. This
partnership also includes a coordinated plan in which this agency will provide vehicles,
transportation and shelter during evacuation emergencies.
15
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11/22/19,
Akamai Living
Event promoted
Community health
Outreach booth, Senior
Annual
Coordinated
Fair, west
by HMSA,
and wellness Fair
ID distribution,
event
Services for the
Hawaii
Elderly Activities
200+ participants
Elderly
Division
Upcoming
Coordinated
Participant
Participant
Participant Survey
Quarterly distribution
Quarterly
Services for the
Survey /
Survey / Program
/ Program
of program surveys to
Elderly
Program
Brochures
Brochures
participants. Program
Brochures
brochures for public
distribution
The Coordinated Services for the Elderly has worked in conjunction with the County Civil
Defense for the last three (3) years in the development of the County Evacuation Plan. This plan
specifically addresses the needs of including, at -risk minority and low-income populations. This
partnership also includes a coordinated plan in which this agency will provide vehicles,
transportation and shelter during evacuation emergencies.
15
In the upcoming year the Coordinated Services for the Elderly will make the following
community outreach efforts:
F&M OW110 IWO M WN1 R 11110111 ',1 lull 11 BlOQW4113 A 1 -1 1 IWA
1) Senior Advisory Council Meeting (Held twice per year, purpose is to disseminate
program information to Senior Club / Nutrition Program site representatives).
2) Senior ID card distribution (Community outreach sessions distributing ID cards and
Information and Assistance services to the public).
3) Senior Center visits (Scheduled site visits to Senior Centers and Nutrition Program
congregate sites to disseminate Information and Assistance).
SUBMIT SAMPLE DOCUMENTS OF THE PUBLIC PARTICIPATION METHODS
YOUR AGENCY USES.
Attachments:
I a — Coordinated Services for the Elderly program brochure.
lb — Coordinated Services for the Elderly client rights form.
lc — Hawaii County Dept. of Parks and Recreation Service Survey.
W1.1
Limited English Proficiency Plan
rem
M=
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Limited English Proficiency
,(LEP) Plan
17
The Coordinated Services for the Elderly has developed the following LEP Plan to help
identify reasonable steps to provide language assistance for LEP persons seeking meaningful
access to the Coordinated Services for the Elderly programs, services, or activities as required
by Executive Order 13166 and §321C, Hawaii Revised Statutes. An LEP person is one who
does not speak English as their primary language, and who has a limited ability to read, speak,
write, or understand English.
This plan details procedures on how to identify a person who may need language assistance, the
ways in which assistance may be provided, training to staff, notification to LEP persons that
assistance is available, and information for future plan updates. In developing the plan while
determining the Coordinated Services for the Elderly's extent of obligation to provide LEP
services, the Coordinated Services for the Elderly undertook a USDOT's four -factor LEP
analysis which considers the following:
(1) The number or proportion of LEP persons eligible in the Coordinated Services for the
Elderly service area who may be served or likely to encounter by the Coordinated
Services for the Elderly program, activities, or services.
Primary Language
Totals
English
69,092
Other
Japanese
.12,326
2,043
Ilocano
1,083
Chinese
136
Spanish
101
Visa an
34
Ta alo
20
(2) The frequency with which LEP individuals come in contract with the Coordinated
Services for the Elderly services.
LEP individuals are contacted by Coordinated Services staff primarily by means of
outreach efforts, providing transportation services, assessments, and referrals from
network agencies and resources.
(3) The nature and importance of the program, activities or services provided by the
Coordinated Services for the Elderly to the LEP population.
The Coordinated Services program provides transportation, information and assistance,
and in-home chore services to seniors 60 years of age and older. The assistance provided
with these components allow seniors to remain independent and living at home for as
long as possible. Frequently within these tasks staff will serve as a liaison on behalf of
clients assisting in oral and or written communication with network agencies and
community resources.
18
(4) The resources available to the Coordinated Services for the Elderly and overall costs to
provide LEP assistance. A brief description of these considerations is provided in the
following section.
The Coordinated Services for the Elderly program will make every effort to provide vital
information to LEP individuals in the language requested whenever possible absent
prohibitive costs.
Resources available:
County of Hawaii Department of Human Resources
County of Hawaii Office of Aging / Aging and Disability Resource Center
CTS Language Link
Safe Harbor Provision
The Coordinated Services for the Elderly complies with the Safe Harbor Provision, as
evidenced by the number of documents available in the Spanish (for example) LEP language.
With respect to Title VI information, the following shall be made available in Spanish (for
example) LEP:
(1) Title VI Notice
In addition, we will conduct our marketing (including using translated materials) in a manner
that reaches each LEP group. Vital Documents include the following:
(1) Notices of free language assistance for persons with LEP
PROVIDE SAMPLE DOCUMENTS OF THE TYPES OF SERVICES YOUR AGENCY
PROVIDES FOR LEP INDIVIDUALS.
Attachment:
3a — Interpretation Services Available flyer
LEP Poster
19
Non -elected C� .mitt e Membershable
A sub -recipient who selects the membership of transit -related, non -elected planning boards,
advisory councils, or committees must provide a table depicting the membership of those
organizations broken down by race. Sub -recipients also must include a description of the efforts
made to encourage participation of minorities on these boards, councils, and committees.
The Coordinated Services for the Elderly does NOT select the membership of any transit -
related committees, planning boards, or advisory councils.
MoniI
toring for 5310 Saab -Recipient Title VI Compliance
HDOT will monitor 5310 sub -recipients' compliance with FTA Title VI requirements.
Oversight includes periodic on-site visits, review of submitted Title VI Plans, review of Title VI
training programs and sub -recipient's agency -conducted surveys etc.
1. Submits its Title VI Plan every three (3) years.
2. Submits its Title VI Plan which has been approved by a governing entity or highest
Authority of the agency.
3. Conducts Title VI Training for all employees. Documents its training program (date,
attendance, topic(s) covered, number of hours per topic per session, lecture, video lesson
etc.).
4. Conducts Title VI Training for all FTA defined Safety -Sensitive Employees. Documents
its training program. (date, attendance, topic(s) covered, number of hours per topic per
session, lecture, video lesson etc.).
5. Posts its Notice of Rights under Title VI Notices in FTA funded vehicles.
6. Posts its Notice of Rights under Title VI Notices in office and other publicly accessible
places, including group meetings and other informational gatherings for its clients, and
general public.
7. Posts its Notice of Rights under Title VI Notices on agency website, brochures, bulletins,
etc.
8. Describes how it monitors Title VI compliance by its officers, and employees.
9. Keeps records of discrimination complaints, and resolutions, etc.
10. Conducts surveys of clients, community, coordinated services to assess the level and
effectiveness of ensuring non-discrimination.
mi
Title V! Training
DESCRIBE HOW YOUR AGENCY TITLE VI COORDINATORS, AND STAFF A.A�K
TV.41NED IN TITLE VI.
11/29/17 — Title VI Compliance Training Webinar for 5310 Grant Vehicle Sub -Recipients
Title VI Coordinators and staff will be trained at least every three years and a log will be created
and maintained to reflect the training completed.
Upcoming ongoing — Coordinated Services for the Elderly quarterly meeting
Monthly district staff meetings
21
Approval of the Title V! Plan by Governing Entity
The Coordinated Services for the Elderly program is a public service agency under the County of
Hawaii, Department of Parks and Recreation, Elderly Activities Division, The Department of
Parks and Recreation submitted its Title VI Plan to the Hawaii County Council for approval
through its Committee on Parks and Recreation and Public Safety, where it was recommended
for approval and transmitted to the full Council on
Committee on Parks and Recreation and Public Safety Committee meeting agenda and report
dated
Attached as Appendix _.
Hawaii County Council Order of Business dated
Attached as Appendix
Resolution No. : Approving the County of Hawaii Department of Parks and
Recreation Title VI Plan pursuant to the Federal Transit Administration Title VI Circular 4702 1
B Requirements and Guidelines. Attached as Appendix _.
22
Organizational Chart,
N r, I M, ITS
2a — Coordinated Services for the Elderly organizational chart
23
Four -Factor Analy-sis
REFERENCE: Federal Transit Administration CIRCULAR 4702.1B
FTA C 4702.1 B Chap. III -7
In order to ensure meaningful access to programs and activities, recipients shall use the
information obtained in the Four Factor Analysis to determine the specific language services that
are appropriate to provide. A careful analysis can help a recipient determine if it communicates
effectively with LEP persons and will inform language access planning. The Four Factor
Analysis is an individualized assessment that balances the following four factors:
Factor 1: Determining the Number and Proportion of LEP Persons Served or
Encountered in the Service Area.
This population will be program- specific. In addition to the number or proportion of LEP
persons served, the recipient's analysis should, at a minimum, identify:
a) How LEP persons interact with the recipient's agency;
b) Identification of affected LEP communities, and assess the number or proportion of LEP
persons from each language group to determine the appropriate language services for
each language group;
c) The literacy skills of LEP populations in their native languages, in order to determine
whether translation of documents will be an effective practice; and
d) Whether LEP persons are underserved by the recipient due to language barriers.
Factor 2: Determine the Frequency with Which LEP Individuals Come into Contact with
MRCS Programs, Activities, and Services.
Recipients should survey key program areas and assess major points of contact with the public,
such as:
a) Use of bus and rail service;
b) Purchase of passes and tickets through vending machines, outlets, websites, and over the
phone;
c) Participation in public meetings;
d) Customer service interactions;
24
c) Ridership surveys; and
f) Operator surveys.
Factor 3: Determine the Importance to LEP Persons of Your Program Activities and
Services.
Generally speaking, the more important the program, the more frequent the contact and the
likelihood that language services will be needed. The provision of public transportation is a vital
service, especially for people without access to personal vehicles. 5310 regional planning
activities will impact every person in a region. Development of a coordinated plan to meet the
specific transportation needs of seniors and people with disabilities will often also meet the needs
of LEP persons. A person who is LEP may have a disability that prevents the person from using
fixed route service, thus making the person eligible for ADA complementary paratransit. Transit
providers, States, and 5 3 1 Os must assess their programs, activities and services to ensure they are
providing meaningful access to LEP persons. Facilitated meetings with LEP persons are one
method to inform the recipient on what the local LEP population considers to be an essential
service, as well as the most effective means to provide language assistance.
Factor 4: Determine the Resource Available to the Recipient and Costs.
Resource and cost issues can often be reduced by technological advances, reasonable business
practices, and the sharing of language assistance materials and services among and between
recipients, advocacy groups, LEP populations and Federal agencies. Large entities and those
entities serving a significant number of LEP persons should ensure that their resource limitations
are well substantiated before using this factor as a reason to limit language assistance.
Developing a Language Assistance Plan.
After completing the Four Factor Analysis, the recipient shall use the results of the analyses to
determine which language assistance services are appropriate. Additionally, the recipient shall
develop an assistance plan to address the identified needs of the LEP population(s) it serves.
USDOT's LEP Guidance recognizes that certain recipients, such as those serving very few LEP
persons or those with very limited resources, may choose not to develop a written plan.
However, FTA has determined it is necessary to require its recipients to develop an assistance
plan in order to ensure compliance. A recipient may formally request an exemption from this
requirement if it believes it fits within the exception described.
Recipients have considerable flexibility in developing a Language Assistance Plan, or LEP Plan.
An LEP Plan shall, at a minimum:
a) Include the results of the Four Factor Analysis, including a description of the LEP
population(s) served;
b) Describe how the recipient provides language assistance services by language;
c) Describe how the recipient provides notice to LEP persons about the availability of
language assistance;
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d) Describe how the recipient monitors, evaluates and updates the language access plan; and
e) Describe how the recipient trains employees to provide timely and reasonable language
assistance to LEP populations.
FTA will solely determine, at the time the recipient submits its Title VI Program or subsequent
to a complaint investigation or compliance review, whether a recipient's plan is sufficient to
ensure meaningful access and thus ensure the recipient is not engaging in discrimination on the
basis of national origin.
Translation of Vital Documents
After completing the Four Factor Analysis, a recipient may determine that an effective LEP plan
for its community includes the translation of vital documents into the language of each
frequently encountered LEP group eligible to be served and/or likely to be affected by the
recipient's programs and services.
Vital written documents include, but are not limited to: 1) consent and complaint forms; 2)
intake and application forms with the potential for important consequences; 3) written notices of
rights; 4) notices of denials, losses, or decreases in benefits or services; and 5) notices advising
LEP individuals of free language assistance services.
Examples of vital documents include an ADA complementary paratransit eligibility application,
a Title VI complaint form, notice of a person's rights under Title VI, and other documents that
provide access to essential services.
Failure to translate these vital documents could result in a recipient denying an eligible LEP
person access to services and discrimination on the basis of national origin.
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For please contact:
Office of:mpap Attest E --mall: dila d-Joblmai pu
t_30 P a3d 64 ml Street, Roam n2 CE: (902) S&5-3"313
HOMI34 Hawaii ME 3 Neghborlslands: 1 (SdM W-5935
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