Methods of Administration: State Plan 2020
Background
On February 6, 2020, the U.S. Department of Education’s Office for Civil Rights (OCR) and Office of Career, Technical, and Adult Education (OCTAE) jointly issued an updated Memorandum of Procedures (MOP) for State agencies responsible for the administration of career and technical education (CTE) to use in developing the “methods of administration and related procedures” they will follow in carrying out their civil rights obligations under the “Guidelines for Eliminating Discrimination and Denial of Services on the Basis of Race, Color, National Origin, Sex and Handicap in Vocational Education Programs” (MOA Guidelines) (34 C.F.R. Part 100, Appendix B). This Memorandum of Procedures supersedes and replaces the prior Memorandum of Procedures issued in July 1979, and rescinds prior guidance issued in the form of “Dear Colleague” letters regarding the Methods of Administration (MOA) program. This updated MOP does not affect or alter the 1979 MOA Guidelines.
The 2020 Memorandum of Procedures is based on the following objectives:
- Ensuring the continuing State role in partnership with OCR in protecting the civil rights of all CTE students consistent with the requirements of the MOA program.
- Giving State agencies the opportunity to align their MOA and Perkins management systems, so that Perkins civil rights administration and MOA civil rights administration can be harmonized, better aligned, and more effective overall.
- Improving civil rights technical assistance to CTE subrecipients and State agencies in order to facilitate voluntary compliance.
- Using existing data gathered and reported under the Perkins statute for civil rights oversight and technical assistance.
- Strengthening State use of the OCR enforcement network and complaint resolution resources.
State Requirements
Under the MOA Guidelines and subsequent 2020 Memorandum of Procedures, each State must have a “Methods of Administration” compliance program to prevent, identify, and remedy race, color, national origin, sex, and disability discrimination in its subrecipients’ career and technical education programs. The compliance plan must include the following components:
- Collecting and analyzing civil rights data and information
- Conducting periodic compliance reviews of select subrecipients
- Providing technical assistance to subrecipients upon request
- Periodically reporting its activities and findings to OCR
The MOA Plan describes how the State will fulfill these responsibilities as well as how the State will do the MOA work that will be summarized in its biennial report. The MOA plan will be submitted to the U.S. Department of Education for review by the Office for Civil Rights by July 1, 2020. The approved MOA plan will take effect within one year.
State Plan
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