CTE Civil Rights - Methods of Administration

Framework and Responsibilities of MOA Program

Utah State Board of Education (USBE) has the responsibility to conduct compliance reviews on any or all of the following areas outlined in the Guidelines for all subrecipients:  

1. Administrative requirements (Section IV.O); 

1. 1. Annual Public Notices
   2. Continuous Non-Discrimination Notices
   3. Grievance Procedures
   4. Designation of Coordinators (Title IV and 504)
      
2. Recruitment, admissions, and counseling (Section IV.A,K,N and L, Section V.A-E);
3. Physical accessibility (Section IV.N);
4. Comparable facilities (Section VI.D);
5. Services for students with disabilities (Section IV.N and VI.A);
6. Financial assistance (Section VI.B);
7. Work-study, cooperative programs, and job placement (Section VII);
8. Housing (Section VI.C); and
9. Employment (Sections VIII.A-F). 

These periodic reviews are completed through any combination of tools:  

• data requests/reviews,  
• data analysis, 
• desk reviews of publications and policies, 
• onsite reviews, 
• website reviews, 
• interviews, 
• surveys, and 
• facilities reviews.  

Common Terms

1. CTE:  Career and Technical Education
   
   
2. Methods of Administration (MOA) Program: Pursuant to the MOA Guidelines, each state must have a MOA compliance program to prevent, identify, and remedy race, color, national origin, sex, and disability discrimination in its subrecipients’ CTE programs by: (1) collecting and analyzing civil rights data and information; (2) conducting periodic compliance reviews of select subrecipients; (3) providing technical assistance to subrecipients upon request; and (4) periodically reporting its MOA activities and findings to OCR.
   
   
3. Methods of Administration (MOA) Plan: Each state agency must create an MOA plan outlining how it will administer the four required components of its MOA Program outlined above. The 2020 MOP sets out three sections for the MOA plan: (1) Introductory information; (2) Plan for performing oversight responsibilities; and (3) Technical assistance.
   
   
4. Letter of Findings (LOF): A state MOA agency issues written findings of unlawful discrimination or a letter of findings to a subrecipient following an on-site review of the subrecipient’s policies and practices in all or some of the following areas: administrative requirements; recruitment, admissions, and counseling; physical accessibility; comparable facilities; services for students with disabilities; financial assistance; work-study, cooperative programs, and job placement; housing; and employment. OCR generally uses the term LOFs to describe this process of documenting findings of unlawful discrimination. LOFs are not necessarily required if there were no findings of unlawful discrimination.
   
   
5. Voluntary Compliance Plan (VCP): A state MOA agency and a subrecipient negotiate a voluntary compliance plan that lists the corrective actions that the subrecipient must take to remedy the findings of noncompliance listed in the LOF. The corrective actions must be approved by the agency and be consistent with the Guidelines, applicable regulations, and applicable physical accessibility standards.
   
   
6. Monitoring: The state MOA agency’s activities to confirm implementation of corrective actions in VCPs. Monitoring is not the same thing as onsite reviews.  

Technical Assistance

The Utah State Board of Education (USBE) provides robust technical assistance and training to support subrecipients in complying with federal civil rights laws in Career and Technical Education (CTE). These efforts are grounded in the Methods of Administration (MOA) Guidelines issued by the U.S. Department of Education’s Office for Civil Rights (OCR), which require states to prevent, identify, and remedy discrimination based on race, color, national origin, sex, or disability. 

Required Annual Training

Methods of Administering Civil Rights in CTE: The required annual training courses are made available through Canvas for LEA CTE Directors. Additional participants in the required training are based on topics and reviewed year by year. This course has enabled open, self-enrollment.

Canvas Online Registration
Link supports users with an established USBE Canvas account.
Canvas Online Registration 
Link supports new registrations. Register as student with join code YGBF73.

Technical Assistance Training Topics

Administrative Topics: Annual Public Notification, Continuous Nondiscrimination Notice, Grievance Procedures, Most Responsible Persons (Title IX and 504)
Time Needed : 30 Minutes
Who Should Participate: CTE Director, CTE Coordinators, First-Hand Participants in the Roll Out

Grievance Procedures: Detailed Grievance Procedures Review
Time Needed : 20 Minutes
Who Should Participate: CTE Director, First-Hand Participants of Grievance Procedures

Recruitment in CTE: Understand Recruitment Issues and the Law
Time Needed : 60 Minutes
Who Should Participate: CTE Director, CTE Coordinators, Counselor Supervisor(s)

Admissions to CTE: Thinking of Setting Criteria? Review the Issues, How to Develop an Equitable Approach
Time Needed : 60 Minutes
Who Should Participate: CTE Director, CTE Coordinators, Anyone with a Charge to Setting Policy

Counseling and CTE: Build a Bridge of Cooperation
Time Needed : 60 Minutes
Who Should Participate: CTE Director, CTE Coordinators, CTE Teachers, Counselors (Supervisors/Managers)

Civil Rights and Data: Understand Your Data and Act with Appropriate Strategies
Time Needed : 2 Hours
Who Should Participate: A pre-meeting should occur prior to scheduling a time for the technical assistance to ensure that your current data is correct and who should participate in this training.

ADA/504 Compliance:  Understand Compliance in the School and Classroom 
Time Needed : 60 Minutes
Who Should Participate: CTE Director, CTE Coordinators, 504 Coordinator, Facilities Coordinator

Race and School Programming: OCR Review of the August 2023 Dear Colleague Letter
Time Needed : 60 Minutes
Who Should Participate: CTE Director, CTE Coordinators

Resources

USBE-CTE Special Populations

The Carl D. Perkins Career and Technical Education Act (Perkins V) includes provisions that prioritize expanding access to and supporting success within CTE programs to designated special populations.