Title VI compliance is a situation where the Iowa DOT has effectively implemented all the Title VI requirements or can demonstrate that every good faith effort has been made toward achieving this end.
Pursuant to 23 U.S.C. § 302, the FHWA's primary recipient is the state highway (transportation) agency. In Iowa, the Iowa DOT is the primary recipient. The Iowa DOT and its subrecipients and contractors, are all required to prevent discrimination and ensure nondiscrimination in all programs and activities whether they are federally funded or not.
Subrecipients of federal assistance include cities, counties, contractors, consultants, suppliers, universities, colleges, transit agencies, and regional and metropolitan planning agencies.
Federally assisted programs include any transportation project, program or activity for the provision of services and/or other benefits. Such programs include education, training, work opportunities, health, welfare, rehabilitation, housing or other services, whether provided directly by the Iowa DOT or indirectly through contracts or other arrangements with other agents.
Discrimination under the Iowa DOT's Title VI Program is an action or inaction, intentional or not, through which any intended beneficiary, solely because of race, religion, color, national origin, sex, age, disability, income status or retaliation has been otherwise subjected to unequal treatment or impact under any Iowa DOT program or activity.
Discrimination based on the grounds referenced above limit the opportunity for individuals and groups to gain equal access to services and programs. In administering federally assisted programs and activities, the Iowa DOT cannot discriminate either directly or through contractual or other means by:
A Title VI complaint may be filed by any individual who alleges he/she has been subjected to discrimination or adverse impact under any Iowa DOT program or activity based on race, religion, color, national origin, sex, age, disability, income status or retaliation.
A signed, written Title VI complaint must be filed within 180 days of the date of the alleged act of discrimination. The complaint must include the following information.
A federal-funds recipient is prohibited from retaliating against any person because he or she opposed an unlawful policy or practice, made charges, testified, or participated in any complaint action under Title VI. If you believe that you have been retaliated against, immediately contact the Iowa DOT's Office of Employee Services' civil rights section.
Upon receipt, the Iowa DOT's Office of Employee Services' civil rights section will determine which agency has jurisdiction to handle the complaint. If the Iowa DOT does not have jurisdiction to handle the complaint, it will be forwarded to the appropriate agency. To file a Title VI complaint, you may obtain the necessary forms by contacting the civil rights coordinator at the phone number listed below.
A primary recipient is an entity or person that directly receives federal financial assistance and/or manages a program or activity, which would subject them to Title VI compliance responsibilities. In this situation, the Iowa DOT is the primary recipient.
A subrecipient is an entity or person that indirectly receives federal financial assistance to implement a program or activity, which subjects them to Title VI compliance responsibilities. A subrecipient may include, but is not limited to, a city, county, metropolitan or regional planning organization, transit agency, college/university, contractor or subgrantee.
Subrecipients must include notifications in all solicitations for bids of work or material and agreements subject to Title VI of the Civil Rights Act of 1964 and other nondiscrimination authorities.
Subrecipient's contractor(s) may not discriminate in the selection and retention of any subcontractors. Subrecipients, contractors and subcontractors may not discriminate in their employment practices in connection with highway construction projects or federal financially assisted projects
Subrecipients must provide, when requested, statistical data (race, color, national origin) of participants and beneficiaries of their programs. Data includes, but is not limited to, public meetings, relocations, low income and limited-English proficient individuals served.
Subrecipients and contractors must take reasonable steps to provide meaningful access to LEP individuals. Among the factors to be considered in determining what constitutes reasonable steps to ensure meaningful access are the: