The Office of External Enforcement (OEE) supports CRC's responsibility to assess, investigate and/or adjudicate complaints alleging discrimination, and/or administers and enforces the laws that apply to:
- recipients of financial assistance under Title I of the Workforce Innovation and Opportunity Act (WIOA);
- American Job Center partners listed in WIOA Section 121(b) that offer programs or activities through the workforce development system;
- state and local governments and other public entities operating programs and activities related to labor and the workforce (for disability matters only); and
- any recipients of financial assistance from, or programs conducted by, DOL that are not included in the categories above.
A few examples of covered programs include WIOA programs for adults, youth, and dislocated workers; federal employment and training programs for Native Americans, and migrant and seasonable farm workers; the Senior Community Service Employment Program (SCSEP) for older workers; Trade Adjustment Assistance Programs; and other grant programs administered by DOL agencies.
The various laws administered by CRC that apply to a particular external program or activity, differ in their scope. Together, those laws generally forbid discrimination on the basis of race, color, religion (including failure to accommodate), sex (including pregnancy and gender identity), national origin (including limited English proficiency), age, disability (including failure to provide accessible facilities, accommodations or modifications, or equally effective communications), and political affiliation or belief.
In specific circumstances, as noted below, the laws enforced by CRC also forbid discrimination on the following basis:
- Citizenship/status as a lawfully admitted immigrant authorized to work in the United States (applicable to beneficiaries of WIOA related programs or other programs or activities offered by a One-Stop partner through the One-Stop system).
- Participation in a program or activity that receives financial assistance under WIOA Title I.
- Sexual orientation or status as a parent (prohibited in federally-conducted education and training programs, such as Job Corps).
- Retaliation against, or intimidation of, anyone who takes any of the following actions related to nondiscrimination or equal opportunity in any of the covered programs and activities:
- filing a discrimination complaint;
- opposing a practice that is made illegal by civil rights law; or
- giving information to, testifying at, or in any other way taking part in an investigation, a compliance review, a hearing, or any other type of civil rights-related activity.
OEE conducts compliance reviews pursuant to the programs listed above. CRC may conduct pre-approval compliance reviews of grant applicants for WIOA Title-I – financial assistance (or other grant applicants) to determine their ability to comply with nondiscrimination and equal opportunity provisions of WIOA and other laws, and may conduct post-approval compliance reviews of recipients. The reviews may focus on one or more issues within specific programs or activities.
Additionally, OEE reviews Nondiscrimination Plans (NDP) required under WIOA. Each state’s NDP must be established and implemented by the governor. The plan must be designed to give a reasonable guarantee that all State Program recipients will comply, and are complying with, the nondiscrimination and equal opportunity provisions of WIOA. Furthermore, OEE develops and publishes regulations, guidance, and provides training and technical assistance, for internal and external stakeholders, and other interested parties.
State Responsibilities for Ensuring Access to Unemployment Insurance Benefits, Services, and Information
CRC and DOL's Employment and Training Administration have partnered to issue an updated Unemployment Insurance Program Letter (UIPL) 02-16, Change 1 regarding access to unemployment insurance (UI) programs. The UIPL provides a summary, in the UI context, of regulatory requirements that went into effect in January 2017 for providing access to individuals with disabilities and those with limited English proficiency (LEP). We encourage Equal Opportunity Officers (particularly at the state level), UI staff, and others interested in the accessibility / availability of the nation's UI system for individuals with disabilities and LEP individuals, to review the UIPL and the appendices.