Companion Guide to Video January 2014

www.fhwa.dot.gov/federal-aidessentials

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 its administrator, who has direct 

access to the chief executive officer and is 

identified in the policy statement. 

Civil Rights

Title VI Program

Implementation Plans

A Federal-aid recipient must have a formal plan to prevent discrimination in 

all of its programs and activities
Federal-aid Essentials for Local Public Agencies

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

• 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.
Federal-aid Essentials for Local Public Agencies

The content of this 

document is not a 

substitute for 

information obtained 

from State departments 

of transportation, 

appropriate FHWA 

Division Offices, and 

applicable laws. 

Scenarios have been 

simplified for emphasis 

and do not necessarily 

reflect the actual range of 

requirements applicable 

to the scenario or this 

topic. This document

was created under 

contract number 

DTFH61-11-D-00025 by 

the Federal Highway 

Administration, U.S. 

Department of 

Transportation, and is 

offered to the public to 

heighten and focus 

awareness of Federal-aid 

requirements within the 

local public agencies 

community and 

reinforces the 

importance of these 

necessary policies, 

procedures, and 

practices.

This Companion Resource 

is the script content for 

the video production of 

the same name. 

Additional Resources

• Link to FHWA's Office of Civil Rights Web site with resources to Title VI 

program implementation 

http://www.fhwa.dot.gov/civilrights/

• U.S. DOT regulations for implementing its Title VI nondiscrimination 

requirements

http://www.ecfr.gov/cgi/t/text/textidx?c=ecfr&tpl=/ecfrbrowse/Title49/49cfr21_main_02.tpl

FHWA Title VI and related statues, including regulations for 

implementing Title VI program requirements

http://www.ecfr.gov/cgi/t/text/textidx?c=ecfr&tpl=/ecfrbrowse/Title23/23cfr200_main_02.tpl

• WSDOT's local agency guidelines for Title VI implementation plans 

http://www.wsdot.wa.gov/publications/manuals/fulltext/M36-

63/Lag28.pdf