SUBRECIPIENT MONITORING

Documenting Evidence of Agency Staff Title VI Training

 Manufacturers Assistance Group staff is given Title VI training, and agency can answer affirmatively to all the following questions:

1. Are new employees made aware of Title VI responsibilities pertaining to their specific duties?

2. Do new employees receive this information via employee orientation?

3. Is Title VI information provided to all employees and program applicants? 4. Is Title VI information prominently displayed in the agency and on any program materials distributed, as necessary?

The following Title VI training will be provided to Manufacturers Assistance Group’s staff:

1. Information on Title VI such as the requirements of Title VI, the protections afforded, and Manufacturers Assistance Group’s obligations under Title VI.

2. Information regarding displayed Title VI information and program materials such as the Title VI Nondiscrimination Notice to the Public.

3. Information on Manufacturers Assistance Group’s Title VI Complaint Procedures, Title VI Complaint Form, and the complaint investigation process.

4. Information on Manufacturers Assistance Group’s outreach efforts from the Public Participation Plan and the agency’s efforts to engage minority and LEP populations. Manufacturers Assistance Group will identify staff that are likely to routinely encounter or have frequent contact with members of the public and/or customers, as well as their supervisors and all management staff. Manufacturers Assistance Group will include the Title VI training as part of the orientation for new employees. Existing employees, especially those who frequently encounter the public and/or customers, will take part in retraining or new training sessions to keep up to date on their Title VI responsibilities on a yearly basis. The Title VI training will be administered in conjunction with training on Manufacturers Assistance Group’s Language Assistance Plan and a summary of the agency’s LEP responsibilities as discussed in the later Section G. “Language Assistance Plan.”

MONITORING AND UPDATING THE LEP PLAN

Manufacturers Assistance Group conducted a Public Engagement Process for the 2018 Title VI Program. This process includes Community Meetings to seek input, provide education, and highlight key components of the Title VI Plan. Materials have been created to explain Title VI polices as well as provide education on how they relate to minority populations.

Manufacturers Assistance Group staff provided briefing to the Board of Directors and Advisory Bodies

Manufacturers Assistance Group provided a 30 day public comment period to provide opportunities for feedback on the 2024-2026 Title VI Program.

Comments are accepted during the public outreach period via:
Email
Mail
Phone
In person

Butler County Sheltered Workshop

Efforts made to Encourage Minority Participation on Committees

• Direct solicitation of minority representatives to serve on advisory bodies
  

SUBRECIPIENT ASSISTANCE

Summary of 2021-2024 Public Outreach Efforts

PUBLIC ENGAGEMENT PLAN

Title VI Outreach Best Practices

The following training will be provided to Manufacturers Assistance Group staff:

1.  Information on Manufacturers Assistance Group Title VI Procedures and LEP responsibilities.
2.  Description of language assistance services offered to the public.
3.  Use of Language Identification Flashcards.
4.  Documentation of language assistance requests.



The cost of language assistance is low to no cost and will be provided upon request.

 



The LEP Plan is a component of Manufacturers Assistance Group’s Title VI Plan requirement.

Manufacturers Assistance Group will update the LEP plan as required. At minimum, the plan will be reviewed and updated when it is clear that higher concentrations of LEP individuals are present in the Manufacturers Assistance Group service area. Updates include the following:

1.  How the needs of LEP persons have been addressed.
2.  Determine the current LEP population in the service area.
3.  Determine as to whether the need for, and/or extent of, translation services has changed.
4.  Determine whether local language assistance programs have been effective and sufficient to meet the needs.
5.  Determine whether Manufacturers Assistance Group’s financial resources are sufficient to fund language assistance resources as needed.
6.  Determine whether Manufacturers Assistance Group has fully complied with the goals of this LEP plan.
7.  Determine whether complaints have been received concerning Manufacturers Assistance Group’s failure to meet the needs of LEP individuals.

STAFF TRAINING

F.  Advisory Bodies

Title VI Assurances

Manufacturers Assistance Group agrees to comply with all provisions prohibiting discrimination on the basis of race, color, or national origin of Title VI of the Civil Rights Act of 1964, as amended, 42 U.S.C. 200d et seq., and with U.S. DOT regulations, “Nondiscrimination in Federally-Assisted Programs of the Department of Transportation – Effectuation of Title VI of the Civil Rights Act,” 49 CFR part 21.

 

Manufacturers Assistance Group assures that no person shall, as provided by Federal and State civil rights laws, be excluded from participation in, be denied the benefits of, or be subjected to discrimination under any program or activity. Manufacturers Assistance Group further ensures every effort will be made to ensure non-discrimination in all programs and activities, whether those programs and activities are federally funded or not.

 

Manufacturers Assistance Group meets the objectives of the FTA Master Agreement which governs all entities applying for FTA funding, including Manufacturers Assistance Group and its third-party contractors by promoting actions that:

Ensure that the level and quality of service is provided without regard to race, color, or national origin.
Identify and address, as appropriate, disproportionally high and adverse effects of programs and activities on minority populations and low-income populations.
Promote the full and fair participation of all affected Title VI populations in decision making.
Prevent the denial, reduction, or delay in benefits related to programs and activities that benefit minority populations or low-income populations.
Ensure meaningful access to programs and activities by persons with Limited English Proficiency.



Agency Information


The mission of Manufacturers Assistance Group is to provide a productive employment opportunity to lower range educable and upper level trainable mentally challenged adults over the age of 16 who have a productive capacity in a sheltered workshop environment but whose capacities are such that there is little or no prospect that vocational rehabilitation training could develop their potentials sufficiently to make them realistically employable in competitive industry.
 

Manufacturers Assistance Group was incorporated on June 21, 1966 and has continued to provide continuous employment to handicapped individuals since that time.  The facility operates in a modern 40,000 square facility at 3080 Cravens Road in Poplar Bluff, MO.

 

Manufacturers Assistance Group has a service area of all of Butler County, Missouri. 

Employees must reside in Butler County.  Butler County has a population of 39,587 people.  To qualify for employment at Manufacturers Assistance Group individuals must have a mental disability and be approved by the Missouri Department of Elementary & Secondary Education Sheltered Workshop Section to qualify for services.  Individuals must also be at least sixteen years of age.  Federal law also prohibits individuals enrolled in school from being employed in sheltered workshops.


Manufacturers Assistance Group is governed by a Board of Directors.  Members are appointed by the Butler County Commission.  Each director serves a three year term and may be reappointed at the end of his or her term.


Notice to the Public

Notifying the Public of Rights under Title VI

Manufacturers Assistance Group posts Title VI/ADA notices on our agency’s website, in public areas of our agency, in our board room, and on our buses and vans.


Manufacturers Assistance Group operates its programs and services without regard to race, color, or national origin, in accordance with Title VI of the Civil Rights Act of 1964.

Manufacturers Assistance Group operates its programs and services without discrimination against individuals with disabilities, in accordance with the American with Disabilities Act of 1990.

If you believe you have been discriminated against on the basis of race, color, or national origin by Manufacturers Assistance Group, you may file a Title VI complaint by completing, signing, and submitting the agency’s Title VI Complaint Form.


Members of the public can request additional information on nondiscrimination obligations by contacting Jeff Arnold, Managing Director by phone at 573-785-1624 or mail at 3080 Cravens Rd, Poplar Bluff, MO 63901.  Information is also available on our website at magsws.com.



How to file a Title VI/ADA complaint with Manufacturers Assistance Group:

 

Submission of Complaint: Any person or group who feels that he or she, individually, or as a member of any class of persons, on the basis of race, color, or national origin has been unfairly deprived of benefit, or unduly burdened by the transportation planning process, or denied the benefits of, or subjected to discrimination caused by Manufacturers Assistance Group may file a written complaint with the Managing Director. You are not required to use this form; a letter with the same information is sufficient. Note: Upon request, assistance, in preparation of any necessary written material, will be provided to a person(s) who is unable to read or write. Complaints should be mailed or sent to:

 

Managing Director-Manufacturers Assistance Group-3080 Cravens Road-Poplar Bluff, MO 63901

 

In addition to the complaint process at Manufacturers Assistance Group, complaints may be filed directly with the Federal Transit Administration, Office of Civil Rights, Region VII, 901 Locust Street, Suite 404, Kansas City, MO 64106.

Complaints must be filed within 180 days following the date of the alleged discriminatory occurrence and should contain as much detailed information about the alleged discrimination as possible.

The form must be signed and dated, and include your contact information.

If information is needed in another language, contact (573) 785-1624.

 

Procedure for Filing a Title VI Complaint

Filing a Title VI Complaint

The complaint procedures apply to the beneficiaries of Manufacturers Assistance Group’s programs, activities, and services.

 

RIGHT TO FILE A COMPLAINT: Any person who believes they have been discriminated against on the basis of race, color, or national origin by Manufacturers Assistance Group may file a Title VI complaint by completing and submitting the agency’s Title VI Complaint Form.  Title VI complaints must be received in writing within 180 days of the alleged discriminatory complaint.

HOW TO FILE A COMPLAINT: Information on how to file a Title VI complaint is posted on our website, and in public areas of our agency.

 You may download the Manufacturers Assistance Group Title VI Complaint Form at magsws.com, or request a copy by writing to Manufacturers Assistance Group, 3080 Cravens Rd, Poplar Bluff, MO 63901.  Information on how to file a Title VI complaint may also be obtained by calling Jeff Arnold at (573) 785-1624.

 

You may file a signed, dated complaint no more than 180 days from the date of the alleged incident.  The complaint should include:

Your name, address, and telephone number
Specific, detailed information (how, when, and why) about the alleged act of discrimination.
Any other relevant information, including the names of any persons, if known, the agency should contact for clarity of the allegations.

Please submit your complaint form to Manufacturers Assistance Group, 3080 Cravens Road, Poplar Bluff, MO 63901.

 

COMPLAINT ACCEPTANCE:  The Managing Director will process complaints that are completed. Once a completed Title VI Complaint Form is received, the Managing Director will review it to determine if Manufacturers Assistance Group has jurisdiction. The complainant will receive an acknowledgement letter informing them whether or not the complaint will be investigated by Manufacturers Assistance Group.

INVESTIGATIONS: Manufacturers Assistance Group will generally complete an investigation within 90 days from the receipt of a completed complaint form.  If more information is needed to resolve the case, Manufacturers Assistance Group may contact the complainant.  Unless a longer period is specified by Manufacturers Assistance Group, the complainant will have ten (10) days from the date of the letter to send requested information to the investigator assigned to the case.

If the requested information is not received within that timeframe the case will be closed.  Also, a case can be administratively closed if the complainant no longer wishes to pursue the case.

LETTERS OF CLOSURE OR FINDING: After the Title VI investigator reviews the complaint, the Title VI investigator 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 Title VI violation and that the case will be closed.

-A letter of Finding (LOF) summarizes the allegations and provides an explanation of the corrective actions taken.

 

If the complainant disagrees with Manufacturers Assistance Group’s determination, the complainant may request reconsideration by submitting the request in writing to the Title VI investigator within seven (7) days after the date of the letter of closure or letter of finding, stating with specificity the basis for the reconsideration. Manufacturers Assistance Group will notify the complainant of the decision either to accept or reject the request for reconsideration within ten (10) days. In cases where reconsideration is granted, Manufacturers Assistance Group will issue a determination letter to the complainant of the reconsideration review.

 

A person may also file a complaint directly with the Federal Transit Administration, at the FTA Office of Civil Rights, 1200 New Jersey Avenue SE, Washington, DC 20590.

 

If information is needed in another language, contact Jeff Arnold at Manufacturers Assistance Group, 3080 Cravens Road, Poplar Bluff, MO 63901, or at (573) 785-1624.



Attachment 3

Monitoring Title VI Complaints, Investigations, Lawsuits

 Documenting Title VI Complaints/Investigations

All Title VI complaints will be entered and tracked in Manufacturers Assistance Group’s complaint log. Active investigations will be monitored for timely response on the part of all parties. The agency’s Title VI Coordinator shall maintain the log.




 

 

 

 

 



​

 Language Assistance Plan

Manufacturers Assistance Group Limited English Proficiency Plan


This limited English Proficiency (LEP) Plan has been prepared to address Manufacturers Assistance Group’s responsibilities as a recipient of federal financial assistance as they relate to the needs of individuals with limited language skills. The plan has been prepared in accordance with Title VI of the Civil Rights Act of 1964; Federal Transit Administration Circular 4702.1B, dated October 1, 2012, which states that the level and quality of transportation service is provided without regard to race, color, or national origin.


Executive order 13166, titled “Improving Access to Services for Persons with Limited English Proficiency,” indicates that differing treatment based upon a person’s inability to speak, read, write or understand English is a type of national origin discrimination. It directs each federal agency to publish guidance for its respective recipients clarifying their obligation to ensure that such discrimination do not take place. This order applies to all state and local agencies which receive federal funds.

Service Area Description:  All of Butler County, Missouri

Manufacturers Assistance Group has developed this LEP Plan to help identify reasonable steps for providing language assistance to persons with limited English proficiency who wish to access services provided by Manufacturers Assistance Group. As defined in Executive Order 13166, LEP persons are those who do not speak English as their primary language and have limited ability to read, speak, write, or understand English. This plan outlines how to identify a person who may need language assistance, and the ways in which assistance may be provided.

 

In order to prepare this plan, Manufacturers Assistance Group undertook the four-factor LEP analysis which considers the following factors:

 
Four Factor Analysis

The number and proportion of LEP persons eligible to be served or likely to be encountered in the service area:

A significant majority of people in the Butler County service area are proficient in the English language. Less than 1% of the population five years of age and older speak English “less than very well”- a definition of limited English proficiency.

2024 - 2026 Title VI Program Public Engagement Process

EQUITY ANALYSIS OF FACILITIES

Manufacturers Assistance Group does not have subrecipients.



Manufacturers Assistance Group does not have subrecipients.

 

Manufacturers Assistance Group has not constructed any storage facilities, maintenance facilities, or operation centers in the last three years. 

A.  Fixed Route Transit Providers

Manufacturers Assistance Group is not a transit provider that operates fixed route service, or transit provider that operates fifty (50) or more fixed route vehicles in peak service and are in an urbanized size area with a population of 200,000 or more.

Thus, the requirements to set system-wide service standards and policies, collect and report demographic data, monitor transit service, and to evaluate service and fare changes, are not applicable to Manufacturers Assistance Group.

OVERALL COSTS

Manufacturers Assistance Group established a Public Participation Plan that included an outreach plan to engage minority and limited English proficient populations.  Notices of public meetings for input were published on the Manufacturers Assistance Group Facebook page and all employees were given notices of the meetings to distribute to friends and neighbors.  The notices were also posted on all entry doors to the facility. 

A public meeting for input is held at the facility which is centrally located in the county and will be held yearly to address any concerns or needs for limited English populations. 

Surveys were conducted to find resources of translators in house and outside the facility.

A formal comment period was conducted to solicit comments for any recommendations to improve services of the facility.  Comments were accepted by email, mail and phone calls to the facility.

A publicly available summary report is available to the public.

Manufacturers Assistance Group

2.  Frequency of Contact by LEP Persons with Manufacturers Assistance Groups Services:

The Manufacturers Assistance Group staff reviewed the frequency with which office staff and drivers have contact with LEP persons. To date Manufacturers Assistance Group has, on average 0 requests per month for an interpreter. Manufacturers Assistance Group averages 0 phone calls per month.

3. The importance of programs, activities or services provided by Manufacturers Assistance Group to LEP persons:

Outreach activities, summarized in Manufacturers Assistance Group’s Title VI Public Engagement Plan, includes public meetings and open houses held at schools, churches, libraries, and other non-profit locations, and include specific outreach to LEP persons to gain understanding of the needs of the LEP population, and the manner (if at all) needs are addressed.

4.  The resources available to Manufacturers Assistance Group and overall cost to provide LEP assistance:

Strategies for Engaging Individuals with Limited English Proficiency include:

     1.  Language line. Upon advance notice, translators can be provided.
     2.  Language identification flashcards.
     3.  Written translations of vital documents (identified via safe harbor provision)
     4.  One-on-one assistance through outreach efforts.
     5.  Website information
     6.  To the extent feasible, assign bilingual staff for community events, public hearings and Board of Directors    meetings and on the customer service phone lines.

Goal

The goal of the Public Engagement Plan is to have significant and ongoing public involvement, by all identified audiences, in the public participation process for major agency outreach efforts. The Public Engagement plan describes the proactive strategies, procedures, and desired outcomes that underpin Manufacturers Assistance Group’s public and private participation activities.

 • To understand the service area demographics and determine what non-English languages and other cultural barriers exist to public participation.

 • To provide general notification of meetings and forums for public input, in a manner that is understandable to all populations in the area.

• To hold public meetings in locations that are accessible to all area stakeholders, including but not limited to minority and low-income members of the community.

• To provide methods for two-way communication and information and input from populations which are less likely to attend meetings.

• To convey the information in various formats to reach all key stakeholder groups.

 

Identification of Stakeholders

 Stakeholders are those who are either directly or indirectly affected by an outreach effort, system or service plan or recommendations of that plan. Stakeholders include but are not limited to the following:

• Board of Directors – the governing board of the agency. The role of the Board is to establish policy and legislative direction for the agency. The Board defines the agency’s mission, establishes goals, and approves the budget to accomplish the goals.

• Advisory Bodies – non-elected advisory bodies review current and proposed activities of the agency, and are encouraged to be active in the agency’s public engagement process. Advisory bodies provide insight and feedback to the agency.

• Transit riders and clients

• Minority and low-income populations, including limited English proficient persons

• Local jurisdictions and other government stakeholders • Private businesses and organizations

• Employers

• Partner agencies
 

Elements of the Public Engagement Plan

It is necessary to establish a public participation plan that includes an outreach plan to engage minority and limited English proficient (LEP) populations. Elements of the Public Engagement Plan include:

1.  Notice

           a. Official notification of intent to provide opportunity for members of the general public to participate in public engagement plan development, including participation in open board meetings and advisory committees.

2.  Engagement Process/Outreach Efforts

          a.  meetings
          b.  rider outreach
          c.  services for the disabled (Notices of opportunities for involvement and engagement for

               agency transit riders and clients include contact information for people needing these or other special                       accommodations.
d. attendance and interaction at local group (TAFY) that includes individuals from the special education departments of local high schools, and other local entities that provide services for individuals with disabilities.

3.  Comments from Agency Riders or Clients

a. Comment periods are used to solicit comments around an agency service or system change.

b. Comments from riders or clients are accepted through various means:

     i. Dedicated email address at info@magsws.com.

     ii. Website at magsws.com

   iii. Regular mail at 3080 Cravens Road, Poplar Bluff, MO 63901

   iv. Telephone at 573-785-1624

 
4.  Response to input from Agency Riders or Clients

All comments from Agency Riders or Clients are provided to the Board of Directors prior to   decision making.  A publicly available summary report is compiled, including all individual comments.                      

 

 
Manufacturers Assistance Group ensures all outreach strategies, communications, and public involvement efforts comply with Title VI. Manufacturers Assistance Group’s Public Engagement Plan proactively initiates the public involvement process and makes concerted efforts to involve members of all social, economic, and ethnic groups in the public involvement process.  Aligned with the above referenced communication tactic, Manufacturers Assistance Group provides the following:

a.  Title VI non-discrimination notice on agency’s website.
b.  Agency communication materials in languages other than English (subject to Safe Harbor parameters).
c.  Services for Limited English Proficient persons. Upon advance notice, translators may be provided.