Title VI ImplementaƟon Plans 

What is a Title VI ImplementaƟon Plan? 

A Title VI Plan is the standard operaƟng procedure for how Title VI of the 1964 Civil 

Rights Act is implemented and overseen  by a State Highway AdministraƟon. The plan should 

detail the who, what, how, when, and the why for each of the State Highway AdministraƟon’s 

programs and acƟviƟes in relaƟon to Title VI.   

Who is required to have a Title VI Plan? 

State Highway AdministraƟons  are required to annually submit Title VI Plans to FHWA. 

This requirement comes from, 23 C.F.R. § 200.9(b)(11), which states: State Highway AdministraƟons (SHAs) “shall annually submit an updated Title VI implemenƟng plan to the Regional 

Federal Highway Administrator for approval or disapproval.”

What does a Title VI Plan contain? 

Title VI Plans are intended to be public documents which convey the day to day operaƟons of the Title VI Program within a State Highway AdministraƟon. The plan should be user 

friendly and accessible to members of the public. The plan needs to be updated annually.  

What are the EssenƟal Elements of a Title VI Plan? 

The Title VI Plan is required  by 23 C.F.R. § 200.9 to contain the following 11 elements. These 

elements may be  stand alone, however it is oŌen more useful to address elements together 

such as combining data collecƟon and analysis with program area procedures, sub-recipient 

review procedures, and LEP procedures rather than as a separate and independent element.

1. Standard USDOT Title VI Assurances.   7. Complaint Procedures 

2. OrganizaƟon & Staffing  8. DisseminaƟon of Title VI InformaƟon 

3. Program Area Review Procedures  9. Limited English Proficiency 

4. Subrecipient Review Procedures 10. Review of STA DirecƟves 

5. Data CollecƟon and Analysis Methods  11. Compliance & Enforcement 

6. Training Procedures  Procedures
           

   

Title VI ImplementaƟon Plans 

What is the process for Plan submiƩal and review? 

SHAs must submit their plans to FHWA division offices for review and approval by October 1st  

each year. FHWA division offices then electronically submit the plan and approval documents

to the FHWA  Office of Civil Rights for reporƟng purposes by December 1st of the same year.

What does FHWA review in a Title VI Plan? 

1.  Are both internal and external review 5.  Is all of the informaƟon up to date? 

processes discussed in detail?  6.  Was the plan submiƩed by October 

2.  Do Program area secƟons describe  1st? 

acƟons that are related to Title VI?  7.  Is the plan easily accessible to the 

3.  Are data sources and collecƟon proce- public?

dures described in detail? 8.  Are vital porƟons of the plan translated to languages other than English 

following the LEP plan? 

What is a Title VI Plan used for? 

A Title VI plan may be used by the State DOT to inform the public and their recipients of the 

standard process for reviewing programs, projects and recipients to  ensure compliance with 

Title VI of the Civil Rights Act. The plan may also be used by members of the state DOT to inform internal state DOT employees on the processes to follow in their respecƟve program areas. The Title VI Plan should also aid in informing recipients on their obligaƟons under Title VI. 

What about elements not listed in the RegulaƟon? 

While not required by regulaƟon, a state DOT may have other elements that make the plan

more user friendly. For example, plans may contain a policy statement, glossary of terms,  an 

introducƟon, or a definiƟon  of acronyms used in the document. However, FHWA discourages

including elements that are not specifically covered under Title VI bases of race, color or naƟonal origin. Plans should not include state specific bases of discriminaƟon, other federal regulaƟons outside of Title VI, or programs and acƟviƟes enforced by other federal agencies. 
Where do I go for more informaƟon? 

Please visit the  FHWA Title VI  website for more informaƟon on Title VI 

Plan requirements.