Independence Again
2435 Oak Park Drive Cookeville, TN 38506 - Independence Again North
224 Garrett Ave. Cookeville, TN 38501- Independence Again West
255 Kacie Ave. Cookeville, TN 38501 - Independence Again Central
Web: IndependenceAgain.org
Independence Again
Policy and Procedure Directive
Title: Title VI Policy#: TV-001.4
Standard: Admit File Service Area: Residents File
Effective Date: 12/22/2014 Revised: 6/28/2020
Title VI/Nondiscrimination Coordinator:
The Independence Again's Title VI/Nondiscrimination Coordinator is its Executive Director. The Coordinator shall have lead responsibility for coordinating the administration of the Title VI and related statutes program, plan and assurances for the Independence Again. The Title VI training shall be yearly no later than the last day of June each year and within 90 days after a staff (paid or unpaid) begins working in a position of authority.
The Title VI/Nondiscrimination Coordinator is authorized to ensure compliance with the provisions of Independence Again’s statement of nondiscrimination and with the appropriate laws and regulations. The Title VI/Nondiscrimination Coordinator will also ensure implementation of the Independence Again nondiscrimination policy statement and will be responsible for initiating, monitoring, and ensuring Independence Again is compliant with Title VI requirements.
The Title Vl/Nondiscrimination Coordinator's role and responsibilities include but are not limited to the following:
1) Program Administration: Being the focal point for the Title VI implementation and monitoring of programs and/or activities receiving federal financial assistance. Ensuring that Title VI requirements are included in appropriate policy assistance. Ensuring that Title VI requirements are included in appropriate policy directives and that the procedures used have built in safeguards to prevent discrimination. Ensure compliance with Title VI assurances, policies, and program objectives.
2) Public Dissemination of Information: Develop and disseminate Title VI program information (and, where appropriate, in languages other than English)
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Staff/Volunteers, residents, and sub-recipients, including contractors, subcontractors, consultants and the general public. The public dissemination program shall involve the posting of Independence Again’s Title VI Policy Statement: a) in contracts or other agreements and bid specification packages; b) on Independence Again website, www.independenceagain.org; c) in all of Independence Again locations where residents reside or visitors attend. The dissemination to employees/officials will include: a) an annual training to all staff (paid/unpaid), board members and residents; b) Posting on Independence Again’s website; c) Acknowledgements of Independence Again Title VI in the new employee orientation plan.
3) Annual Work Plan: Available to the State of Tennessee, SAMSHA, Department of Children Services and Department of Corrections via email to the board to review and forwards upon request or upon incident no later than the last date of June each year:
a) The report will include the following information:
i) Title VI complaint procedures (if applicable, if not N/A)
ii) Record of Title VI investigations, complaints or lawsuits, and
dispositions (if applicable, if not N/A)
iii) Plan to involve persons with Limited English Proficiency (LEP)
(1) Plan to include LEP is to contact Tennessee Technological or
other local providers for a translator upon reports of LEP
needs or upon staff realization of need. Staff will consistently
inform residents that if they need assistance to let staff
know in case management meetings.
iv) Environmental Justice Plan
(1) Staff/Volunteers must actively engage residents and
participate in meaningful involvement in programs that will help
establish independence on a case-by-case basis.
(2) Involvement of residents regardless of race, color, national
origin, or income in the development, implementation, and
enforcement of their individual plan.
v) Title VI notices to the public: “No person in the United States shall, on the ground of race, color, or national origin, be excluded from
participation in, be denied the benefits, or be subjected to
discrimination under any program activity receiving Federal financial assistance.”
vi) Update the Annual report of Title VI accomplishments and changes to the program in the preceding Federal fiscal year.
4) Address Violations: Assisting with the correction of Title VI related problems or discriminatory practices or policies found through self-monitoring and review activities. When deficiencies are found, reasonable procedures will be promptly
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addressed to the Board of Directors and will be implemented to correct the deficiencies and to put in writing the corrective action(s).
5) Complaint Process: Implementation of procedures for the prompt processing of Title VI internal and external discrimination complaints. No staff/volunteer or Board Member shall engage in any form or retaliation against a person or their family for filing a Title VI complaint. All staff/Volunteers and Board Members will encourage residents to advocate for themselves if barriers are presented.
6) Complaint Resolution: Overseeing the investigation of external Title VI complaints.
7) Training Program Development: Facilitate the development and implementation of training programs on Title VI issues and regulations and, other nondiscrimination authorities, for Independence Again staff (paid/unpaid), Board Members, Residents and as needed contractors, and subrecipients. A summary of training conducted will be reported in the annual update.
8) Complaint Transparency: Forwarding Title VI complaints filed against Independence Again the State of Tennessee point of contact via email shall be done immediately upon resolution and no later than 10 calendar days from the investigation initiating.
a) In the event the filing complainant is involved with the Department of Children Services, Probation or Department of Corrections, Substance Use Provider, Mental Health Provider or other accountability partners these points of contacts will also be informed in a timely manner - with an
appropriate release on file.
9) Data Collection: Coordinating the collection and maintenance of statistical data on race, color, national origin, English language proficiency and sex of participants in the beneficiaries of Independence Again outside funding sources. Information will be gathered through TNWITS unless Independence Again utilizes a new information collection resource (HMIS). The gathering procedures will be reviewed annually to ensure sufficiency of the data in meeting the requirements of the Title VI program.
a) In the event staff is unable to gather this information due to resident refusal to answer staff will respect the residents wishes and report as refused to answer.
10) Title VI Plan Update: If updated, provide a copy of the Title VI Plan to the State of Tennessee upon request. Independence Again will update the Title VI Plan in the event of law changes to ensure compliance - as quickly as awareness is made. In the event the plan change places Independence Again at risk of non-compliance with any
contract Coordinator will reach out to points of contacts and ensure resolution Title VI PP - TV - 001 3
options are presented to the board in a timely manner. Independence Again will update and renew its Title VI Assurances every other year (even years) or as necessary on the occasion of a change in the County, City, State, Federal level.
Title VI Coordinator Contact Information:
Title VI/Nondiscrimination Coordinator
Lynda M. Loftis-Webb, LADAC
2435 Oak Park Drive
Cookeville, TN 38506
Cell: (931) 510-9775
Phone: (931) 933-5914
The Independence Again Board of Directors will coordinate with the Title VI/Nondiscrimination Coordinator to ensure compliance with Title VI requirements for County, City, State and Federal Compliance.
1) Responsibilities for Title VI requirements include, but are not limited to the following:
2) Environmental Justice compliance on all State or federally funded projects; 3) Collecting and analyzing data to numerically assess the reach and impact of its program funds;
4) Comply with Limited English Proficiency Plan and Environmental Justice/Public Participation monitoring and reporting requirements;
5) Coordinate with Title VI/Nondiscrimination Coordinator to ensure all required information is provided in a timely manner.
___________________________________________ _____________________
Staff / Residents Signature Date
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