Federal Non-Discrimination

Title VI is a federal non-discrimination program that prohibits discrimination on the basis of race, color or ethnicity.  5310 agencies must have a Title VI Plan that:

1. Is formally adopted by the agency’s Board of Directors

2.   Includes a Title VI Notice to the Public

   • The Notice to the Public must be included in English and all languages indicated by the Title VI Language Assistance Plan

   • The Notice must be posted in three locations: (1) Each 5310 vehicle, (2) In agency facilities, and (3) On the agency website 

3. Includes the agency’s Title VI Complaint Form and complaint procedures in English and other languages indicated by the Language Assistance Plan.

4.  Requires the agency to track and document all Title VI Investigations, lawsuits, and complaints and provides a tracking table.

5. Includes the required Public Participation Plan

6. Includes the required Language Assistance Plan, including 4-factor analysis

7. Addresses the requirements related to transit planning and advisory boards

8. Addresses the Equity Analysis requirements.

Click here to download the Title VI Plan template for 5310 agencies.

5310 agencies must have Equal Employment Opportunity (EEO) policies and procedures that meet the following requirements.

EEO policy statements should:

1. Express the agency’s commitment that all employment actions, will be administered without regard to race, color, religion, national origin, sex, age, genetic information, disability, veteran status, or other protected class.

2.  Explain that the responsibility for implementing the EEO Program is assigned to an agency executive who reports directly to the CEO/GM.  

3. State that applicants and employees have the right to file complaints alleging discrimination with the EEO Officer or office.

4. State that retaliation against an individual who files a charge or complaint of discrimination or participates in an employment discrimination proceeding is strictly prohibited and will not be tolerated.

5. State the agency’s commitment to provide reasonable accommodations to applicants and employees, absent undue hardship.

6. Designate an executive as an EEO officer who will report to and is directly responsible to the agency’s CEO/GM. The policy must name the EEO Officer or their position title and publicize the contact information in all internal communications regarding the agency’s EEO Program.

Dissemination of EEO Policy:

• Internal Dissemination: Subrecipient agencies must maintain appropriate documentation that the EEO policy and program have been brought to the attention of employees and managers. This also includes posting official EEO statements on bulletin boards, near time clocks, in employees' breakrooms, and in the employment/personnel office.

• External Dissemination: Subrecipient agencies recruitment ads (e.g. newspapers, magazines, websites, and social media) must state that the agency “is an equal employment opportunity employer.”

EEO Complaints:

Agencies must document and track complaints received regarding the Equal Employment Opportunity Program and the subsequent complaint procedure process.  If complaints are related to the Transportation program, subrecipient agencies must notify FDOT District Six of the complaint and the disposition.  Records of transportation-related complaints and the FDOT notification must be submitted for review during the Triennial Review.

Click here to download an EEO Policy template. 

5310 agencies are required to have an ADA Equivalency of Service Policy and procedure.  Agencies are required to provide the same (equivalent) transportation service to passengers needing a lift or ramp as they do for ambulatory passengers who do not need a lift or ramp.  

The Equivalency of Service policy should:

1.  State the agency’s commitment to providing equivalent service, and

2.  Detail the process the agency will implement if a passenger needs a lift or ramp when their lift/ramp-equipped vehicle is not in service, or they do not operate a lift/ramp-equipped vehicle.

3. Agencies can arrange with other 5310 or public paratransit agencies to provide accessible transport for their passenger, as long as the service is equivalent to (the same as) the service provided to their other passengers.

Even if your agency does not currently serve passengers needing a lift-equipped vehicle, the ADA regulations require that your agency anticipate and plan for the needs of future possible passengers.

Any time an agency purchases a non-accessible vehicle (not equipped with a lift or ramp) through the 5310 program, the agency must sign a “Certificate of Equivalent Service,” pledging to provide equivalent (or the same type of) transportation services to all passengers, whether or not they need an accessible vehicle.   

Click here to download an ADA policy template.