Title VI of the Civil Rights Act of 1964, along with other nondiscrimination authorities,
prohibits discrimination based upon race, color, national origin, sex, age, disability, income status,
and limited English proficiency in any program or activity of an entity that receives Federal-aid.
To ensure continuous compliance with Title VI, the Federal Highway Administration, the FHWA,
requires each Federal-aid recipient to have a Title VI program.
The program includes methods of administration, a system of policies and practices,
typically contained in an implementation plan.
Let’s look at critical elements of an implementation plan and additional documentation related to Title VI.
A policy statement describes an agency’s commitment to not discriminate on the basis of race,
color, national origin, sex, age, disability, limited English proficiency, or income status when carrying out
programs or activities conducted by the agency, its contractors, or subrecipients of federal assistance.
The policy statement is signed by the agency’s chief executive officer.
Organization and staffing shows how people in the agency support the program and resolve issues.
The Title VI program organization will be managed by it's administrator,
who has direct access to the chief executive officer and is identified in the policy statement.
Monitoring of the demographics of program participants, and beneficiaries,
and activities promotes compliance with Title VI programs.
Monitoring addresses activities that are both internal to the organization, such as employee training on Title VI,
and external to the organization, such as the use of bilingual advertisements for project meetings
or outreach to low income communities to obtain their input on transportation decisions.
Process and procedures for handling complaints provide the steps your agency will take
if a member of the community alleges discrimination.
Process and procedures also address the actions your agency will take if a contractor or subrecipient of Federal-aid
doesn’t comply with Title VI program requirements.
In addition to the implementation plan, recipients must have on file:
A Title VI assurances document,
An annual work plan of Title VI activities and actions,
and an annual accomplishment report.
This report highlights your organization’s efforts to ensure nondiscrimination practices in all agency activities.
As a subrecipient,
your State Department of Transportation, or State DOT, may require your agency to maintain similar documentation.
If your agency is a recipient or subrecipient of federal funds, it is required to have an approved implementation plan,
which documents a system of policies and practices that implement your Title VI program.
In practice, your State DOT may allow agencies that serve very small populations
to develop an abbreviated Title VI implementation plan, otherwise known as a Title VI agreement.
The implementation plan or agreement must be approved by your State DOT.
During a program review with your State DOT,
your agency will review your agency’s implementation plan or agreement and other Title VI documents.
Locate your Title VI program documents and verify that your State DOT has approved your implementation plan or agreement.