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FTA’s Equal Employment Opportunity (EEO) Program Compliance

Natalie LeFlore


The FTA's Office of Civil Rights helps FTA recipients develop, implement, and monitor an effective EEO Program to ensure that recipients do not discriminate against any employees or applicants for employment.


The Federal Transit Laws provide that "no person in the United States shall on the grounds of race, color, religion, national origin, sex, or age be excluded from the participation in, be denied the benefits of, or be subjected to discrimination under any project, program or activity funded in whole or in part through financial assistance under this Act." 


Transit agencies and State DOTs that are direct recipients of financial assistance directly from FTA and that meet the two-prong threshold described in Circular section 1.4 are required to submit EEO Programs to FTA.


In addition to the requirement to submit EEO Programs to FTA, a direct recipient is responsible for monitoring its sub-recipients and contractors by collecting and reviewing EEO Programs from sub-recipients and contractors.


An EEO Program is a detailed set of procedures and employment information designed to ensure entities meet the EEO requirements. FTA requires entities meeting the below thresholds to either submit or prepare and maintain an EEO Program.


Threshold Requirements:

Any FTA applicant, recipient, sub-recipient, and contractor who meet both of the following threshold requirements must implement all of the EEO Program elements, and submit an EEO Program every four years:


  • Employs 100 or more transit-related employees, and

  • Requests or receives capital or operating assistance in excess of $1 million in the previous Federal fiscal year, or requests or receives planning assistance in excess of $250,000 in the previous Federal fiscal year.


Any FTA applicant, recipient, sub-recipient, and contractor who meets both of the following threshold requirements must prepare and maintain an abbreviated EEO Program:


  • Employs between 50-99 transit-related employees, and

  • Requests or receives capital or operating assistance in excess of $1 million in the previous Federal fiscal year, or requests or receives planning assistance in excess of $250,000 in the previous Federal fiscal year.


EEO Program Components include:


  • Statement of Policy

  • Dissemination

  • Designation of Personnel Responsibility

  • Utilization Analysis

  • Goals and Timetables

  • Assessment of Employment Practices

  • Monitoring and Reporting 


Abbreviated EEO Program Components include:


  • Statement of Policy

  • Dissemination Plan

  • Designation of Personnel Responsibility

  • Assessment of Employees Practices

  • Monitoring and Reporting Plan


FTA's EEO Circular (4704.1A) provides guidance to FTA grant recipients necessary to carry out Equal Employment Opportunity requirements and prepare EEO Program Plans.


 

The LeFlore Group was established in 2002 as a full-service support group with the purpose of helping the transit industry navigate government compliance, project and program management, and organizational improvement. Through over 20 years of experience, TLG has helped numerous agencies solve complex business problems.


TLG has assisted several agencies in drafting and implementing their EEO Programs. Having a federally compliant program in place is a crucial part of an agency's eligibility to receive grant funding. TLG can assist with everything from conducting a Utilization Analysis to training your EEO officer. 


If your agency is in need of EEO program compliance support, feel free to contact Rudy LeFlore for more information.


Rudy LeFlore

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