# Presentation: 545182

## Compliance /Monitoring and Data Collection

- Department of Labor and Industry
- Office of Equal Opportunity

## Purpose of Compliance Monitoring

- To ensure compliance with nondiscrimination and equal opportunity provisions of the Workforce Investment Act and Labor and Industry's EO Program.
- To identify needed changes to practices and policies as well as identification of staff and participant training needs.
- To check discrimination early, forestall complaints and correct violations promptly.

## Federal Programs Unit

- Conducts desk and on-site compliance reviews on selected LWIAs, CareerLinks, UC Service Centers to ensure nondiscrimination in provision of services, admissions, placement, services to Limited English Proficient applicants/participants, clients and claimants.
- Develops, implements and monitors practices, policies and procedures necessary to ensure compliance with federal laws and regulations.
- Develops and facilitates equal opportunity training for LWIAs, CareerLinks and UC Service Centers.
- Ensures, through division staff, equitable delivery of services to customers, claimants, applicants and participants.

## Federal Programs Unit

- Conducts EO Compliance reviews in LWIAs to monitor the provision of equitable services to eligible target groups.
- Develops mandated equal opportunity guidelines and coordinates the monitoring of civil rights compliance with federal laws and regulations.
- Develops and facilitates equal opportunity training for LWIAs, CareerLinks and UC Service Centers.
- Serves as liaison between the Department of Labor & Industry and the US Department of Labor, Civil Rights Center, and other federal and states agencies in matters pertaining to EO Compliance.

**Notes:**
Federal Laws include Section 188 of WIA, 29 CFR part 37 Title VI of Civil Rights Act as amended, Section 504 of Rehab Act 1973, Age Discrimination Act 1975, Title IX of Education Act( ADA/LEP) emphasis. 

## PennsylvaniaLocalWorkforce Investment AreaThe Local Workforce Investment Area provides individualized services to assist people in obtaining and maintaining satisfactory employment. Local Workforce Investment Area placement services are provided at no cost to eligible individuals

## 10 Regions broken down to 23 LWIA which are based on colors (Image)

**Notes:**
10 Regions broken down to 23 LWIA which are based on colors

## All Funding Streams

*All Funding Streams*

## All Funding Streams

*All Funding Streams*

**Notes:**
Data used to monitor a particular LWIAs  participants All funding streams, Adults, Youth, Dislocated Workers this is only a sampling there are many other categories, can look at LEP still working on enhancing lep, race, sex age, etc.

##  Pennsylvania Career Link office or participating agency

## Our Vision:

- Pennsylvania CareerLink is a cooperative effort to provide one-stop delivery of career services to job seekers, employers and other Interesed Individuals. These services are also available in your local Pennsylvania CareerLink office or participating agency.
- Our Mission:
- To function as a self-directed Job Search System providing quality customer service to the people of Pennsylvania enabling all customers to make informed choices.
- Our Goal:
- To provide a self service system in which interested individuals have access to employment, education and training resources.

## Slide 11

**Notes:**
Data used is the 9002a ETA this can be done for any comprehensive CareerLink- the Mini centers data would be included in the comprehensive CareerLinks data.

## Slide 12

## Slide 13

**Notes:**
Pa has 8 UC Service Centers State Wide

## Slide 14

## Information to Collect

- Race
- Ethnicity
- Age
- Sex
- Disability status

## Slide 16

**Notes:**
If you can follow on your handouts these numbers are hard to see this is a breakdown of activity on customers, we can request this information for any time period. INA is information not available over the phone we will not deny service if customer will not answer questions on ethnicity or race.

## Slide 17

**Notes:**
Data used to monitor a particular UC Service Center Data used as a desk audit prior to compliance review to look for disparity this and the next slide shows up as one page.

## PA Separation of Issue Chart

## PA Separation of Issue Chart/ Race Ethnic

## PA Separation of Issue Chart/ Gender

## PA Separation of Issue Chart/ Age

## Training:AKey to Compliance/Monitoring

- The Office of Equal Opportunity believes that training all employees is an important key to compliance for (monitoring/data collection) all recipients of federal funds.  Equal Opportunity training is mandatory for:
- State Employees
- LocalWorkforce Investment Areas and Executive Staff
- CareerLinks-One Stops and Partners

**Notes:**
Hard for the EO Officer or EO Liaison to tell staff putting inappropriate material  on desk can get you in trouble if they don’t  understand Civil Right Laws.  We put heavy emphasis on training we believe a important key to monitoring.

## Training (cont.)

- UC Service Centers
- OVR
- Training Providers
- Other Department of Labor & Industry Employees covered under WIA

## Training conducted to date

- Methods of Administration
- Sexual Harassment
- Equal Opportunity Overview
- ADA/Section 504, Rehabilitation Act of 1973 as amended
- Limited English Proficiency
- Interviewing and Selection

**Notes:**
PA’s strategy: 1. Statewide training on MOA (Dept. executives to local eo officers and liaisons, WIB, partners, etc.  - TALK ABOUT SCHEDULE OF TRAVEL? – ensuring accessibility, translators, etc.
TRAIN THE TRAINER Initiative- in the process of accepting bids on translators lep state wide.
Preparation for reviews by other entities

## Why use data as part of your review

- Two major reasons:
- Analyze data from output reports to identify significant differences, and;
- Identify all equal opportunity commitments made by the recipient.

## Equal Opportunity Data Collection 

- The purpose of equal opportunity data collection is to provide information from which valid judgments as to whether there are any indicators of discrimination in how a program or activity is being operated.
- Sufficient information must be collected to allow the EO Officer or monitoring staff to make comparisons.

- That all needed information is being put into the system.
- That all needed information can be extracted from the system, often through summary output reports.
- And that appropriate analytical techniques are applied to the output reports.

## What is Adverse Impact

- A selection rate for any race, sex, or ethnic group which is less than four-fifths (4/5) or eighty percent of the rate for the group with the highest rate will generally be regarded by Federal enforcement agencies as evidence of adverse impact.

## Advantages and Disadvantages of the 80% Rule

- The 80% Rule has one great advantage over tests of statistical significance such as standard deviation- it is much simpler.  Unlike tests of statistical significance, there is only one formula and it is always used the same way.

## There are some disadvantages.
First it is imprecise.  The 80% Rule always allows for a 20% variance between the most favored rate and the rate of others to which this rate is compared, regardless of the number of individuals in the total pool.  
In other words, the 80%  Rule is insensitive to numbers.  When there are few individuals in the total pool, a difference of 20% between groups may not be statistically significant.  

- First it is imprecise.  The 80% Rule always allows for a 20% variance between the most favored rate and the rate of others to which this rate is compared, regardless of the number of individuals in the total pool.
- In other words, the 80%  Rule is insensitive to numbers.  When there are few individuals in the total pool, a difference of 20% between groups may not be statistically significant.

## On the other hand, when there are many individuals in the total pool, a difference in rates of much less than 80% can be statistically significant.  
By using the 80% Rule, you can run the risk of identifying problems that really are not problems on the one hand, and failing to identify problems that do exist on the other.

- By using the 80% Rule, you can run the risk of identifying problems that really are not problems on the one hand, and failing to identify problems that do exist on the other.

## Second, the 80% Rule cannot measure certain kinds of differences.  For example, the 80% Rule cannot be used to compare differences in the rates of pay among race/ethnic groups.
Third, it is not the method used by CRC.  CRC uses test of statistical significance, most often, the standard deviation.

- Third, it is not the method used by CRC.  CRC uses test of statistical significance, most often, the standard deviation.

## Impact Ratio Analysis Question

- Terminations
- 26 females are terminated out of 231 females employes
- 22 males are terminated out of 349 male employes
- Which is the least favored group?
- Why are they considered the least favored group?
- Does adverse impact exist?
- What is the IRA rate?

- Hires v. Applicants
- There are 53 non-minority applicants, of which 25 are hired.
- There are 86 minority applicants, of which 62 are hired.
- Which is the least favored group, and why?
- Does adverse impact exist, and why?
- At what point can you stop your calculations?

- For additional information please contact the Federal Unit:
- Ms. Crystal Adams: Chief of Federal Programs (717) 772-9195
- Ms. Ina Strain: EO Specialist Federal Programs (717) 772-9196