Title VI

Tucson Jewish Community Center
Title VI Implementation Plan

Download Discrimination Complaint Form HERE

Contents

Executive Summary. 3

Non Discrimination Policy Statement. 6

Non Discrimination Notice to the Public. 7

Non Discrimination Notice to the Public -Spanish. 8

Discrimination ADA/Title VI Complaint Procedures. 9

Discrimination ADA/Title VI Complaint Form.. 12

Discrimination ADA/Title VI Investigations, Complaints, and Lawsuits. 14

Public Participation Plan. 15

Limited English Proficiency Plan. 17

Non-elected Committees Membership Table. 20

Monitoring for Subrecipient Title VI Compliance. 21

Title VI Training. 22

Title VI Equity Analysis.. 23

Board Approval for the Title VI Program… 26

Organizational Chart…27

 

Executive Summary

 

The mission of the Tucson Jewish Community Center is to cultivate and enrich Jewish identity, ensure Jewish continuity, foster wellness, and broaden communal harmony.

The Tucson Jewish Community Center was incorporated in 1955 and is housed in a 110,000-square-feet facility built in 1989 and recently renovated in 2015. With more than 2000 families and 5000 members, the Tucson J is open to the Tucson community of all faiths.

Our different departments include: Arts and Culture; Health and Wellness; Special Needs Services; Children, Youth and Family Engagement; and Early Childhood Education.

Arts and Culture offers a variety of adult classes, lectures and clubs. This department also manages on-campus art installations, such as the rotating Fine Art Gallery and the Sculpture Garden.  The Tucson International Jewish Film Festival is also run by Arts and Culture staff.

Health and Wellness manages the Fitness Center, personal training, special classes, the youth Triathlon team, adult and youth sport leagues, tennis, our aquatics programming, and the many special athletic events we host. Up to 120 free weekly classes are included in our gym membership.

Special Needs Services prides itself on serving individuals with a wide range of disabilities. Participants may have a diagnosis of developmental delay, autism, Down syndrome, or physical disabilities such as cerebral palsy. Clients focus on developing independent living and social skills, as well as maintaining and cultivating skills they have already learned. Aides and adaptations are created as needed to support each participant in successfully completing daily activities, and innovative programming is designed to target specific skills. Special Needs Services programming is divided into: Taglit, year-round day program for youth with disabilities; Summer Taglit: A high-school summer program (for participants ages 14-20); Camp J Inclusion (for campers ages 3-14); and our newest program, After-school Inclusion (for children from kindergarten-5th grade). Special Needs Services has received 5310 grant funds for four different vehicles that serve SNS exclusively. We received the first 5310 program vehicle in 2010.

Children, Youth and Family Engagement programs include camps, after-school child care and clubs, and a host of special events, while Early Childhood Education manages a privately funded, play-based preschool serving more than 300 children ages six weeks to pre-K and manages all preschool learning and infant/toddler care and education.

  

What type of program fund(s) did you apply for?

☒        5310

☐        5311

☐        Other (please explain)                                                                                                                       

 

Type of Funding Requests? (Select all that apply)

☒        Vehicle Funds

☐        Operating Funds

☐        Other (please explain)                                                                                                                       

 

Non Discrimination Policy Statement

 

The Tucson Jewish Community Center policy assures full compliance with Title VI of the Civil Rights act of 1964, the Restoration Act of 1987, section 504 of the Rehabilitation Act of 1973, the Americans with Disabilities Act of 1990 (ADA), and related statutes and regulations in all programs and activities.  Title VI states that “no person shall on the grounds of race, color, national origin, or disability be excluded from participation in, be denied the benefits of, or be otherwise subjected to discrimination” under any Tucson Jewish Community Center sponsored program or activity.  There is no distinction between the sources of funding.

Tucson Jewish Community Center also assures that every effort will be made to prevent discrimination through the impacts of its programs, policies and activities on minority and low-income populations. Furthermore, Tucson Jewish Community Center will take reasonable steps to provide meaningful access to services for persons with limited English proficiency.

When Tucson Jewish Community Center distributes Federal-aid funds to another entity/person, Tucson Jewish Community Center will ensure all subrecipients fully comply with Tucson Jewish Community Center Title VI Nondiscrimination Program requirements. The President/CEO has delegated the authority to Emily Malin, Title VI Program Coordinator, to oversee and implement FTA Title VI requirements.

______________________

Todd Rockoff, President/CEO

Non Discrimination Notice to the Public

 

Notifying the Public of Rights Under Title VI and ADA

Tucson Jewish Community Center

 The Tucson Jewish Community Center operates its programs and services without regard to race, color, national origin or disability in accordance with Title VI of the Civil Rights Act of 1964, Section 504 of the Rehabilitation Act of 1973, and the Americans with Disabilities Act of 1990 (ADA). Any person who believes she or he has been aggrieved by any unlawful discriminatory practice under Title VI may file a complaint with the Tucson Jewish Community Center.

For more information on the Tucson Jewish Community Center’s civil rights program, and the procedures to file a complaint, contact Emily Malin, 520.299.3000 x168, email EMalin@tucsonjcc.org; or visit our administrative office at 3800 E River Rd, Tucson, AZ 85718. For more information, visit tucsonjcc.org.

A complainant may file a complaint directly with the Arizona Department of Transportation (ADOT) or the Federal Transit Administration (FTA) by filing a complaint directly with the corresponding offices of Civil Rights:  ADOT: ATTN: Title VI Program Manager 206 S. 17TH Ave MD 155A RM: 183 Phoenix AZ, 85007 FTA: ATTN: Title VI Program Coordinator, East Building, 5th Floor-TCR 1200 New Jersey Ave., SE Washington DC 20590

If information is needed in another language, call 520.299.3000 and ask for staff who can speak the language you require.  Para información en español llame al 520.299.3000 y pida conversar con un hispanohablante.

  

Non Discrimination Notice to the Public -Spanish

 Aviso Público Sobre los Derechos Bajo el Título VI Y ADA

del Tucson Jewish Community Center

 Tucson Jewish Community Center (y sus subcontratistas, si hubiera) asegura complir con el Título VI de la Ley de los Derechos Civiles de 1964, Sección 504 de la Ley de Rehabilitación de 1973 y La Ley de ciudadanos Americanos con Discapacidades de 1990 (ADA).   El nivel y la calidad de servicios de transporte serán provehidos sin consideración a su raza, color, o pais de origen.

Para obtener más información sobre el programa de Tucson Jewish Community Center de derechos civiles, y los procedimientos para presentar una queja, contacte Emily Malin, 520.299.3000 x168, email EMalin@tucsonjcc.org; o visite nuestra oficina administrativa en 3800 E River Rd, Tucson, AZ 85718.  Para obtener más información, visite tucsonjcc.org.

Se puede presentar una queja directamente con Arizona Department of Transportation (ADOT) o Federal Transit Administration (FTA) mediante la presentación de una queja directamente con las oficinas correspondientes de Civil Rights: ADOT: ATTN Title VI Program Manager 206 S. 17th Ave MD 155A Phoenix AZ, 85007 FTA: ATTN Title VI Program Coordinator, East Building, 5th Floor –TCR 1200 New Jersey Ave., SE Washington DC 20590

 

The above notice is posted in the following locations: online, in the public area by our Special Needs Services administrative offices and in our transit vehicles.

 This notice is posted online at tucsonjcc.org

Non Discrimination Complaint Procedures

These procedures provide guidance for all complaints filed under Title VI of the Civil Rights Act of 1964, Section 504 of the Rehabilitation Act of 1973, and the Americans with Disabilities Act of 1990 (ADA) as they relate to any program or activity that is administered by Tucson Jewish Community Center, including consultants, contractors and vendors. Intimidation or retaliation as a result of a complaint is prohibited by law. In addition to these procedures, complainants reserve the right to file a formal complaint with other State or Federal agencies or to seek private counsel for complaints alleging discrimination.  Every effort will be made to resolve complaints at the lowest possible level.

  • Any person who believes he and/or she has been discriminated against on the basis of race, color, national origin, or disability may file a Discrimination complaint by completing and submitting the agency’s Title VI Complaint Form.
  • Formal complaints must be filed within 180 calendar days of the last date of the alleged act of discrimination or the date when the alleged discrimination became known to the complainant(s), or where there has been a continuing course of conduct, the date on which the conduct was discontinued or the latest instance of the conduct.
  • Complaints must be in writing and signed by the complainant(s) and must include the complainant(s) name, address and phone number. The ADA/Title VI contact person will assist the complainant with documenting the issues if necessary.
  • Allegations received by fax or e-mail will be acknowledged and processed, once the identity of the complainant(s) and the intent to proceed with the complaint have been established. For this, the complainant is required to mail a signed, original copy of the fax or email transmittal for the complaint to be processed.
  • Allegations received by telephone will be reduced to writing and provided to the complainant for confirmation or revision before processing. A complaint form will be forwarded to the complainant for him/her to complete, sign and return for processing.
  • Once submitted Tucson Jewish Community Center will review the complaint form to determine jurisdiction. All complaints will receive an acknowledgement letter informing her/him whether the complaint will be investigated by the Tucson Jewish Community Center or submitted to the State or Federal authority for guidance. 
  • Tucson Jewish Community Center will notify the ADOT Civil Rights Office of ALL Discrimination complaints within 72 hours via telephone at 602-712-8946; or email at civilrightsoffice@azdot.gov.
  • Tucson Jewish Community Center has 14 days to investigate the complaint. If more information is needed to resolve the case, the Authority may contact the complainant. The complainant has 10 business days from the date of the letter to send requested information to the investigator assigned to the case. If the investigator is not contacted by the complainant or does not receive the additional information within 10 business days, the Authority can administratively close the case. A case can be administratively closed also if the complainant no longer wishes to pursue their case.
  • After the investigator reviews the complaint, she/he will issue one of two letters to the complainant: a closure letter or a letter of finding (LOF). A closure letter summarizes the allegations and states that there was not a Discrimination violation and that the case will be closed. An LOF summarizes the allegations and the interviews regarding the alleged incident, and explains whether any disciplinary action, additional training of the staff member or other action will occur.
  • A copy of either the closure letter or LOF must be also be submitted to ADOT within 72 hours of that decision. Letters may be submitted by hardcopy or email.
  • A complainant dissatisfied with Tucson Jewish Community Center decision may file a complaint with the Arizona Department of Transportation (ADOT) or the Federal Transit Administration (FTA) offices of Civil Rights: ADOT: ATTN ADA/Title VI Program Coordinator 206 S. 17TH Ave MD 155A RM: 183 Phoenix AZ, 85007 FTA: Attention Title VI Program Coordinator, East Building, 5th Floor-TCR 1200 New Jersey Ave., SE Washington DC 20590
  • A copy of these procedures can be found online at: org

If information is needed in another language, contact 520.299.3000.  Para información en español llame al: 520.299.3000.

Discrimination Complaint Form

Section I:
Name:
Address:
Telephone (Home): Telephone (Work):
Electronic Mail Address:
Accessible Format Requirements? ☐ Large Print ☐ Audio Tape
☐ TDD ☐ Other
Section II:
Are you filing this complaint on your own behalf? ☐Yes* ☐No
*If you answered “yes” to this question, go to Section III.
If not, please supply the name and relationship of the person for whom you are complaining.
Please explain why you have filed for a third party:
Please confirm that you have obtained the permission of the aggrieved party if you are filing on behalf of a third party. ☐Yes ☐No
Section III:
I believe the discrimination I experienced was based on (check all that apply):

 

☐ Race              ☐ Color                    ☐ National Origin                  ☐ Disability

 

Date of Alleged Discrimination (Month, Day, Year):

 

Explain as clearly as possible what happened and why you believe you were discriminated against. Describe all persons who were involved. Include the name and contact information of the person(s) who discriminated against you (if known) as well as names and contact information of any witnesses. If more space is needed, please use the back of this form.

 

Section VI:
Have you previously filed a Discrimination complaint with this agency? ☐Yes ☐No
If yes, please provide any reference information regarding your previous complaint.
Section V:
Have you filed this complaint with any other Federal, State, or local agency, or with any Federal or State court?

☐ Yes             ☐ No

If yes, check all that apply:

☐ Federal Agency:

☐ Federal Court:                                                     ☐ State Agency:

☐ State Court :                                                        ☐ Local Agency:

Please provide information about a contact person at the agency/court where the complaint was filed.
Name:
Title:
Agency:
Address:
Telephone:
Section VI:
Name of agency complaint is against:
Name of person complaint is against:
Title:
Location:
Telephone Number (if available):

You may attach any written materials or other information that you think is relevant to your complaint.  Your signature and date are required below

 

 

 

Signature                                                                                            Date

 

Please submit this form in person at the address below, or mail this form to:

Tucson Jewish Community Center, Title VI Coordinator

3800 E River Rd

Tucson, Arizona, 85718

520-299-3000

EMalin@tucsonjcc.org

A copy of this form can be found online at tucsonjcc.org

Formulario de Quejas de Discriminación

Sección I:
Nombre:
Dirección:
Teléfono (Particular): Teléfono (Trabajo):
Dirección de correo electrónico:
¿Requerimientos de accesibilidad de formato? ☐ letra grande ☐ audio
☐ español ☐ otro
Sección II:
¿Está usted presentando esta queja a su nombre? ☐Sí * ☐No
*Si respondió que “sí” a esta pregunta, dirígase a la Sección III.
De lo contrario, por favor proporcione el nombre de y su relación con la persona para la cual usted esta presentando esta queja.
Por favor confirme por qué esta usted presentándose para un tercero:

 

Por favor confirme que usted ha obtenido el permiso de la persona perjudicada si es que está presentando esta queja de parte de un tercero. ☐ Sí ☐No
Sección III:
Creo que la discriminación por la que pasé fue basada en mi (marque todo lo que corresponda):

 

☐ raza               ☐ color                    ☐ nacionalidad de origen                  ☐ discapacidad

 

Fecha de la presunta discriminación (mes, día, año):

 

Explique con toda claridad possible lo que sucedió y por que usted creo que sufrió disciminación. Describa a todas las personas involucradas. Incluya sus nombres y la información de contacto de los mismos (si se conoce) asi como los nombres y la información de contacto de cualquier testigo. Si se require más espacio, use el reverso de esta hoja.

 

 

 

 

 

Sección VI:
¿Ha usted presentado previamente una queja de discriminación ante esta agencia? ☐ Sí ☐No
De ser así, por favor proporcione cualquier información de referencia relacionada a su queja previa.
Sección V:
¿Ha usted presentado esta queja ante cualquier otra agencia federal, estatal o local o ante cualquier corte federal o estatal? ☐ Sí                     ☐ No

De ser así, marque todo lo que corresponda:

☐ agencia federal:

☐ corte federal:                                                      ☐ agencia estatal:

☐ corte estatal :                                                     ☐ agencia local:

Por favor proporcione infomación de contacto de una persona en la agencia/corte donde se presentó la queja.
Nombre:
Título:
Agencia:
Dirección:
Teléfono:
Sección VI:
Nombre de la agencia a la cual se esta denunciando:
Nombre de la persona a quien se esta denunciando:
Título:
Ubicación:
Teléfono (de estar disponible):

Puede usted adjuntar cualquier material escrito o cualquier información que le pareciera relevante a esta queja. Su firma y la fecha se requieren a continuación:

 

 

 

Firma                                                                                      Fecha

 

Por favor entregue este formulario en persona, envíelo por correo o por correo electrónico usando la información a continuación:

Tucson Jewish Community Center, Title VI Coordinator

3800 E River Rd

Tucson, Arizona, 85718

520-299-3000

EMalin@tucsonjcc.org

 

Una copia de este formulario esta disponible en línea en tucsonjcc.org

Discrimination Investigations, Complaints, and Lawsuits

This form will be submitted annually.  If no investigations, lawsuits, or complaints were filed, a blank form will be submitted.

 

Description/Name Date (Month, Day, Year) Summary (include basis of complaint: race, color, national origin or disability) Status Action(s) Taken (Final findings?)
Investigations
1)
2)
Lawsuits
1)
2)
Complaints
1)
2)

 

 

x Tucson Jewish Community Center has not had any ADA nor Title VI Discrimination complaints, investigations, or lawsuits in 2016.

Public Participation Plan

Tucson Jewish Community Center

Public Participation Plan

At this time, Tucson Jewish Community Center only receives capital request grants from the Arizona Department of Transportation for fleet vehicles. In the event Tucson Jewish Community Center were to apply for other types of Federal funding for transportation, Tucson Jewish Community Center will engage the general public in its planning and decision-making processes, as well as its marketing and outreach activities. The public will be invited to participate in the process whether through public meetings or surveys.

The Tucson Jewish Community Center also engages in various outreach efforts, such as our annual Family Wellness Festival. We expect to see more than 2,000 individuals at our 2017 Festival, an event that is free and open to the public. The Family Wellness Festival is designed to help educate individuals and families on the importance of making healthy lifestyle choices while providing them with wellness resources and support. In the upcoming year Tucson Jewish Community Center will hold the Family Wellness Festival in October.

Tucson Jewish Community Center is engaging its entire clientele in its planning and decision-making processes, as well as its marketing and outreach activities.  All are invited to participate in the process whether through meetings or surveys.  The Tucson J Annual Meeting is a forum we offer in which to receive feedback. We advertise this meeting via email blast, postcards, posters in the building and all details are posted to our website. In the upcoming year Tucson Jewish Community Center will hold the Tucson J Annual Meeting on May 8.

In addition to this event, The Tucson Jewish Community Center maintains a general website and Facebook account to provide consistent access to information about our services via that medium:

 

The following is a sample survey we use to solicit feedback from client families:

Limited English Proficiency Plan

Tucson Jewish Community Center

Limited English Proficiency Plan

Tucson Jewish Community Center has developed the following Limited English Proficiency Plan (LEP) to help identify reasonable steps to provide language assistance for LEP persons seeking meaningful access Tucson Jewish Community Center services as required by Executive Order 13166.  A Limited English Proficiency person is one who does not speak English as their primary language and who has a limited ability to read, speak, write, or understand English.

This plan details procedures on how to identify a person who may need language assistance, the ways in which assistance may be provided, training to staff, notification to LEP persons that assistance is available, and information for future plan updates.  In developing the plan while determining the Tucson Jewish Community Center’s extent of obligation to provide LEP services, the Tucson Jewish Community Center undertook a U.S. Department of Transportation four-factor LEP analysis which considers the following:

  • The number or proportion of LEP persons eligible in the Tucson Jewish Community Center service area who may be served or likely to encounter by Tucson Jewish Community Center program, activities, or services

While the below chart shows general estimates for our city, the Tucson Jewish Community Center Special Needs Services Transportation fleet only provides transportation for youth with disabilities who participate in our programming.

 

Persons with Limited English Proficiency (LEP) Estimate

 

% of Persons 5 Yrs. & Over that speak English very well % of Persons 5 Yrs. & Over that speak English less than very well
Total Persons 5 years and over 492,389 89.5% 10.5%
English Speaking Only 66.4%
Speak a Language other than English 33.6% 68.7% 31.3%
Spanish with LEP 28.7% 69.7% 30.3%
Other Indo-European languages with LEP 1.8% 74.2% 25.8%
Asian & Pacific Island languages with LEP 2.0% 52.0% 48%
Other Languages with LEP 1.2% 64.1% 35.9%

 

  • The frequency with which LEP individuals come in contact with Tucson Jewish Community Center services

The population of Tucson has historically boasted a substantial Spanish-speaking population. Similarly, the area has a growing refugee population. The population for whom we provide transportation—youth with disabilities—is a relatively small segment of the population who come to us through State referrals. We do not often come in contact with LEP individuals, but when we do, they are typically non-verbal or Spanish speakers.

  • The nature and importance of the program, activities or services provided by the Tucson Jewish Community Center to the LEP population

Special Needs Services is a major focus area of the Tucson Jewish Community Center, serving over 70 individuals with disabilities including Autism Spectrum Disorder, Down syndrome, developmental delay and impaired physical function. Transportation is a crucial component of the population we serve. For example; children with disabilities are fully integrated into our seasonal camp activities, including field trips. Taglit summer and winter program participants are often on a vocational track that involves them being transported to sites where they volunteer to gain work experience. Taglit year-round day program also includes volunteering at work sites as well as field trips that aim to educate and integrate participants into the community. Some of the places we visit regularly are The University of Arizona, Edith Ball Adaptive Recreation Center, a variety of city parks, Ben’s Bells, the Tucson Mall, Casa de los Niños, Unscrewed Theater, among others.

  • The resources available to Tucson Jewish Community Center and overall costs to provide LEP assistance. A brief description of these considerations is provided in the following section.

Special Needs Services currently employs three staff members who are bilingual in English and Spanish.  A statement in Spanish will be included in all public outreach notices.  Every effort will be made to provide vital information to LEP individuals in the language requested.

 Safe Harbor Provision

Tucson Jewish Community Center complies with the Safe Harbor Provision, as evidenced by the number of documents available in the Spanish language. With respect to Title VI information, the following shall be made available in Spanish:

 

  • Non Discrimination Notice to the Public
  • Non Discrimination Complaint Procedures
  • Discrimination Complaint Form

 

In addition, we will conduct our marketing (including using translated materials) in a manner that reaches each LEP group. Vital Documents include the following:

 

  • Notices of free language assistance for persons with LEP
  • Notice of Non‐Discrimination and Reasonable Accommodation
  • Outreach Materials

 

Special Needs Services is part of the Tucson Jewish Community Center. The Taglit program is contracted through the state of Arizona as a qualified vendor through the Division of Developmental Disabilities (DDD), which funds the programming by approximately 95%.

 

The participants for whom we provide transportation come to us through DDD referrals, and their language needs are accessed at the moment they are enrolled in the program. At that moment we ensure we have staff on board who can communicate with them, whether they are non-verbal or have limited English proficiency. Our ridership is limited to these clients alone and all drivers are the same direct service professionals who are assigned to our clients and therefore are equipped and prepared to meet their language needs. We currently have three staff members who are bilingual in English and Spanish.

 

 

 

Non-elected Committees Membership Table

 

A sub recipient who selects the membership of transit-related, non-elected planning boards, advisory councils, or committees must provide a table depicting the membership of those organizations broken down by race. Subrecipients also must include a description of the efforts made to encourage participation of minorities on these boards, councils, and committees.

Table Depicting Membership of Committees, Councils, Broken Down by Race

Body Caucasian Latino African American Asian American Native American
Population TYPE % HERE% TYPE % HERE% TYPE % HERE% TYPE % HERE% TYPE % HERE%
TYPE THE NAME OF THE COMMITTEE HERE TYPE % HERE% TYPE % HERE% TYPE % HERE% TYPE % HERE% TYPE % HERE%
TYPE THE NAME OF THE COMMITTEE HERE TYPE % HERE% TYPE % HERE% TYPE % HERE% TYPE % HERE% TYPE % HERE%
TYPE THE NAME OF THE COMMITTEE HERE TYPE % HERE% TYPE % HERE% TYPE % HERE% TYPE % HERE% TYPE % HERE%

 

Describe the process the agency uses to encourage the participation of minorities on such committees should be included

 

x Tucson Jewish Community Center does NOT select the membership of any transit-related committees, planning boards, or advisory councils.

 

 

Monitoring for Subrecipient Title VI Compliance

 

x Tucson Jewish Community Center does NOT monitor subrecipients for Title VI compliance.

 

 

Title VI Training

 

Tucson Jewish Community Center participate in all required ADOT trainings. Tucson Jewish Community Center staff participated in the Title VI training that was part of the 5310/5311 Coordinated Mobility Program Webinar offered on March 28, 2017. Tucson Jewish Community Center will also participate in all required trainings held in the future. Additionally, all Special Needs Services professionals receive Title IX training, (Title IX of the Education Amendments Act of 1972 is a federal law that states: “No person in the United States shall, on the basis of sex, be excluded from participation in, be denied the benefits of, or be subjected to discrimination under any education program or activity receiving Federal financial assistance.”) The Code of Personnel Practices, given to all new staff, includes a section on Unlawful Discrimination and Harassment that outlines where to find Title VI LEP procedures.

 

Title VI Equity Analysis

 

Tucson Jewish Community Center has no current or anticipated plans to develop new transit facilities covered by these requirements. No facilities covered by these requirements have been developed in the past.

Board Approval for the Title VI Program

A COPY OF THE JUNE 20 2017 BOARD MEETING MINUTES WILL BE ATTACHED HERE

 

Organizational Chart