Civil Rights Compliance Plan Resources

Data Collection

To complete the Civil Rights Compliance Plan, you will need access to data concerning employees and program participants. The following sources may assist you in your data collection efforts.

• Disability data collection, aggregate number of the recipient’s employees with disabilities.
  • Information on the disability of an individual employee is confidential and voluntary. However, reporting only the aggregate number without individual employee identification does not violate confidentiality requirements. Examples of data collection systems used by the Department of Workforce Development and Department of Health and Family Services for this purpose are available.
• Race and ethnicity data collection, race and ethnicity of employees and participants.
  • Recent changes in data collection requirements have resulted in a separation of data about ethnicity (i.e. Hispanic/Latino or not Hispanic/Latino) from data on race. Information regarding ethnicity codes required by the federal Office of Management and Budget.
• Limited English Proficiency Data Collection
  • Please see Limited English Proficiency Requirements Section in this web page.

Affirmative Action Strategies and Recruitment Plan

The following links can provide information to assist you fulfill Wisconsin Contract Compliance Law.

• Wisconsin Contract Compliance Law, Ch. 16.765, Wis. Stats. and ADM 50, Wisconsin Administrative Code Approval of the AA Plan results in the addition of the agency’s name in the DOA Vendor List as an eligible vendor or contractor for the state of Wisconsin.
• Workforce Analysis
• Labor Market Area Analysis. Use the DWD Labor Market website to access your labor market area’s data.
• Experts in the DWD Office of Economic Advisors are available to provide assistance. Experts specialize in particular areas of the state:
  • Dan Barroilhet - South Central and Southwest part of Wisconsin; (608) 242-4885, mailing address 1819 Aberg Avenue, Madison, WI 53704
  • Bill Brockmiller - Western Wisconsin; (608) 785-9337 mailing address, 402 N 8th Street, La Crosse, WI 54601
  • Elizabeth Falk - Southeast Wisconsin, (262) 638-6602, mailing address 1717 Taylor Ave, Racine, WI 53403
  • Beverly Gehrke - Northwest; (715) 634-5289, mailing address 15618 US Hwy 63, Hayward, WI 54843
  • Eric Grosso - Statewide, Northeast and Fox Valley Wisconsin; (608) 266-7034, mailing address 201 E. Washington Ave., Madison, WI 53702
  • Scott Hodek - West Central and North Central Wisconsin, (715) 836-2997, mailing address 221 W Madison St., Eau Claire, WI 54703
  • Jeffrey Sachse - Milwaukee Metro, (262) 695-7784, mailing address 892 Main St., Pewaukee, WI 53072
• Analysis of representation of persons with a disability.
  • Use the data on page one for a county or metropolitan area from http://dwd.wisconsin.gov/oea/affirm.htm to determine what percent of the Labor Force is made up of persons with a disability.
  • http://www.doa.state.wi.us/docs_view2.asp?docid=724

Equal Opportunity Requirements

• This is the Wisconsin Department of Administration, Division of Intergovernmental Relations Link to the U.S. Census and population information data, i.e. Demographic Service Center Home, Census 2000 Basic data, Demographic Services Center Staff, etc. http://www.doa.state.wi.us/dhir/boir/demographic/wisconsin/index.html  
• This is the U.S. Census Bureau, United States Department of Commerce Home Page. To get to the census data by county select "American FactFinder". Then choose one of the items from the "Show Me" drop-down list under "Basis Fact". After identifying the state and county, click on GO. http://www.census.gov/  
• This is DWD's Link to Labor Market Information. Data from this site under the heading of "Affirmative Action" will be helpful in completing this plan.  http://dwd.wisconsin.gov/oea/affirm.htm
• The Human Services Resource System (HSRS) database contains information beginning with the Year 2000 regarding participants served or currently being served in AODA, Mental Health, Physical Disabilities, Developmental Disabilities, and the Elderly programs.   http://www.dhfs.state.wi.us/civilrights/CRC/HRSA-Disability.xls. 
• Equal Opportunity Policy Statement and Notification
• Translations of the model into additional languages (i.e., Russian) are available on the DWS CRC web site http://www.dwd.state.wi.us/dwd/forms/viewsort/list.asp
• Access to Services
• http://www.access-board.gov/adaag/html/adaag.htm#purpose. Information about the elimination of physical barriers in facilities that serve persons with disabilities is available. Compliance to ADA Accessibility Guidelines (ADAAG) is necessary for any new building or any renovation a recipient may undertake to an existing building.
• http:///www.dhfs.state.wi.us/civilrights/CRC/WI_Access.doc provides a facility assessment checklist for your use that includes both the Wisconsin Building Codes requirements and the American with Disabilities Act Accessibility Guidelines (ADAAG). The facility assessment should be treated as a record to be kept on the recipient’s files available for a desk review or an on-site visit by DWD and/or DHFS. Please file this checklist which can be requested of your agency at the time of monitoring by DWD/DHFS.
• Discrimination Complaint/Grievance Procedure.
  • Translations of the model into additional languages (i.e., Russian) are available on the DWS CRC web site http://www.dwd.state.wi.us/dwd/forms/viewsort/list.asp. Copies of the policies that are posted for the public must be completed and signed.
• CARES Race and Ethnicity Statistics by Calendar Year -- 2005, 2006. The CARES Race and Ethnicity statistics counts are unduplicated by calendar year. This Excel spreadsheet includes statistic categories for Race, Ethnicity, Language and Disability for individuals in the CARES system. To view the desired data, select the category tab at the bottom of the Excel spreadsheet and scroll to your county. Individuals are counted only once, regardless of the number of months of eligibility for a given program, the number of programs for which they were eligible or multiple periods of eligibility throughout the year. Race and ethnicity information is provided voluntarily, therefore, there are those that chose not to provide that information to their CARES worker. Those individuals are listed under "Unknown". Gender counts are included in both Race and Ethnicity tabs. Additionally there is a State tab that provides state totals for each category.

Limited English Proficiency Program (LEP) Requirements

As a recipient, you are required to establish a language access policy and procedures to be implemented at a reasonable pace.

• Federal LEP Guidelines for Language Access Requirements.  The US Department of Health and Human Services (HHS) offers the following guidelines:
  • http://www.hhs.gov/ocr/lep/revisedlep.html
• Oral Interpretation. State Contract for Telephone Interpretation
• Written Notice.  http://www.dhfs.state.wi.us/civilrights/LEPposter.pdf
• Written Translation. State Contract for Written Translations. 
• HHS offers guidelines for "safe harbors" which you should consider in planning for the translation of written documents.
• Policy Statement and Notification
  • Translations of the model into additional languages are available on the Division of Workforce Solutions Civil Rights Compliance web site
• LEP Customer Service Language Access Analysis 
• Demographic data sources
  • DWD Demographic analysis.
    The DWD demographers overlaid several census databases to determine counties where LEP populations will likely need translation of vital documents.
  • LEP Methodology and Opinion
  • LEP Demographic Analysis (PDF)
• Other Data Resources. Depending on the recipient’s eligible customer population, the recipient will need to refer to data sources beyond the 2000 Census.
  • Department of Public Instruction: http://dpi.wi.gov/ell/lepdatacoll.html
• Department of Administration: Data for linguistically isolated households.
  • http://www.doa.state.wi.us/dhir/wisconsin/index.html
  • www.doa.state.wi.us/docs_view.asp?docid=407
• Census data http://censtats.census.gov/pub/Profiles.shtml
• http://www.census.gov/population/www/cen2000/phc-t20.html
• Refugee Population data 
  • 2005 (PDF)
  • 2004 (PDF)
  • 2003 (PDF)
  • 2003 (Excel)
• Migrant Workers data
  • 2006 (Excel)
  • 2005 (PDF)
  • 2005 (Excel)
  • 2002 (PDF)
  • 2002 (Excel)

Technical assistance

Technical assistance information is provided in Section H, page 5 of the Instructions and Format for  the Civil Rights Compliance Plan.  Additionally, the same information can be found in:

• DWD (this page is password protected for DWD partners)
• DHFS 

 Last Revised: October 24, 2008