State CTE Requirements to Address Civil Rights Compliance
Statutory basis and applicable requirements
Hawaii’s public education institutions have existing and ongoing responsibilities towards civil rights compliance as (sub)recipients of direct and indirect moneys and support from the US DOE. These general responsibilities require compliance with federal statutes and regulations that include Title VI of the Civil Rights Act of 1964, Title IX of the Education Amendments of 1972, Section 504 of the Rehabilitation Act of 1973, the Age Discrimination Act of 1975, the Boy Scouts of America Equal Access Act of 2001, and Title II of the Americans with Disabilities Act of 1990 (ADA). Additionally and specific to career and technical education, Appendix A to Title VI provides Guidelines for Vocational Education Programs. Other institutional responsibilities and requirements are also elaborated through “Dear Colleague Letters” and other guidance documents from the US Department of Justice and US DOE’s Office for Civil Rights (OCR)
Under the OCR, state career and technical education agencies are required to conduct certain civil rights compliance activities to eliminate discrimination in their sub-recipient schools and colleges and comply with federal civil rights regulations, including those Guidelines. To meet its requirements, Hawaii’s State CTE Center annually selects two public high schools and one community college. Selection is primarily based upon analysis of student enrollment data (by ethnicity, gender, disability, and English proficiency) in CTE programs compared to the entire school/college. The methods of review include examination of documents and procedures, interviews with personnel, and accessibility assessment of the institution’s physical facilities and online/digital media.
- September – Hawaii State CTE Center selects secondary (2) and postsecondary (1) subrecipients for on-site civil rights review.
- September to October – Entrance meetings are held with selected subrecipients to provide more detailed information regarding the on-site review process.
- November to February – The Hawaii State CTE Center conducts the civil rights review. The on-site review lasts between a single day to a few weeks, depending upon the size of the subrecipient (number of programs and physical area and dispersion of facilities) and scheduling logistics.
- Within 60 calendar days of the conclusion of the review – The Hawaii State CTE Center issues a Letter of Findings.
- Within 90 calendar days of the issuance of Letter of Findings – The Hawaii State CTE Center negotiates a Corrective Action Plan that is finalized and serves as binding agreement towards remediation.
- Within timeframe negotiated in Corrective Action Plan – The Hawaii State CTE Center monitors the subrecipient’s implementation of the Corrective Action Plan. Negotiated timeframes are typically between a month to two years; extensions are granted on a case-by-case basis as circumstances warrant.
Eight areas of concern covered by the CTE civil rights review
- Administrative Requirements, including notices of nondiscrimination and grievance procedures;
- Recruitment, Admissions, and Counseling;
- Accessibility of programs, online/digital media, and/or physical infrastructure for students to gain admittance into and participate in CTE for-credit programs of study, or that students would utilize in their pursuit to graduate and obtain diploma or certificate noting CTE certification, concentration, commendation, etc. (therefore this accessibility review extends to facilities for core subjects and other graduation requirements as well as common areas);
- Comparable facilities for students with disabilities or based upon gender;
- Services for students with disabilities;
- Financial assistance;
- Work study, cooperative CTE programs, and job placement; and
More information about the review process, particularly if your school/college has been selected
How to Contact Us
The CTE Center responds to questions and concerns of educational institutions relating to civil rights reviews or requests for technical assistance. Contact the CTE Civil Rights and Educational Technology Specialist by phone at 808.956.4052 or e-mail: firstname.lastname@example.org