Equity Compliance

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Equity, Inclusion & Free Speech
Methods of Administration (MOA) Program
Equity Coordinator Role and Responsibilities

Section 504
Title IX Education
Equity Resources

Equity, Inclusion & Free Speech

The following video recording and PowerPoint presentation broadly discuss the First Amendment, House File 744 (student free speech). They are provided to public school districts pursuant to Iowa Code 256.9(64) and shall be used by school districts to provide training annually to any equity coordinator employed by the school district (Iowa Code 279.75).

Free Speech Under the First Amendment: Training for Public Equity Coordinators and School Districts (9-13-21)
2021 Legislative Session: Equity, Inclusion, and Free Speech Guidance (7-2-21) - Provides summaries of the legislation that creates substantive requirements concerning equity and inclusion, as well as student free speech for elementary and secondary schools.

Methods of Administration (MOA) Program

The U.S. Department of Education Office for Civil Rights (OCR) partners with the Office of Career, Technical, and Adult Education (OCTAE) to oversee the civil rights compliance programs of state agencies that administer career and technical education (CTE) through the Methods of Administration (MOA) program. The purpose of the MOA program is to ensure that all students, regardless of race, color, national origin, sex, or disability, have equal access to high-quality CTE programs.

The Iowa Department of Education (Department) administers the MOA program annually to ensure that sub-recipients of federal assistance comply with program requirements and appropriately address any areas of noncompliance. State agencies’ responsibilities under this program are set out in the Guidelines for Eliminating Discrimination and Denial of Services on the Basis of Race, Color, National Origin, Sex, and Handicap in Vocational Education Programs (Guidelines) (Appendix B of the Title VI regulation and the Section 504 regulation, and Appendix A of the Title IX regulation).

To meet its responsibilities under the MOA program, the Department utilizes an MOA Plan to identify which school districts and community colleges will receive a focused equity and accessibility review of their CTE programs, policies, and facilities. The Department prepares a letter of finding for each school district or community college, and works collaboratively to identify and address areas of noncompliance and determine action steps and deadlines for completion. Additionally, any school district may request technical assistance to ensure compliance in the area of civil rights for their CTE program. The Department submits this information biennially to the OCR.

Equity Coordinator Role and Responsibilities

One of the procedural requirements of Title IX of the Education Amendments of 1972 (prohibiting discrimination on the basis of sex) and Section 504 of the Rehabilitation Act of 1973 (prohibiting discrimination on the basis of disability) is that educational agencies designate one or more employees who will be responsible for coordinating their equity compliance efforts. There is no similar procedural requirement for Title VI of the Civil Rights Act of 1964 (prohibiting discrimination on the basis of race and national origin). However for the sake of fairness, it is recommended that the coordinator’s responsibilities include issues related to race and national origin.

The employee who is designated to coordinate their district’s compliance with civil rights laws plays an essential role in ensuring that all students in our state have equal educational opportunities. Some districts designate one employee while others designate more than one to coordinate compliance with all applicable civil rights laws. These designated employees may have different titles, such as civil rights coordinators, equity coordinators, Title IX coordinators, Title VI coordinators, Section 504/ADA coordinators, disability rights coordinators, etc. The Department collects contact information for designated equity coordinators for each school year. Each school district should provide updated contact information for the employee or employees serving in this role in the Assurances 2023-24 (Public) data collection located in the “Assurances" folder of the Consolidated Accountability and Support Application (CASA).

The Equity Coordinator’s responsibilities go beyond receiving and/or resolving complaints related to unfair treatment, discrimination, denied access to programs or services, bullying, and harassment. The Equity Coordinator plays an active role in ensuring that their schools’ policies, programs, and practices are equitable and comply with state and federal laws by accepting the following six responsibilities:

Knowledge of Federal and State Laws. Develop and maintain a working knowledge of Title IX (gender equity), Section 504 and Americans with Disabilities Act (disability equity), Title VI of the Civil Rights Act (race/national origin equity) and relevant state laws including the Iowa Civil Rights Act and Iowa Anti-Bullying Law.
Policies and Procedures. Ensure that each school has the required board policies and grievance procedures in place.
Dissemination of Information. Ensure that information about nondiscrimination, harassment, and bullying policies, the name and contact information for designated equity coordinator(s), and information about related grievance procedures is disseminated annually to board members, administrators, employees, students, parents, and applicants for employment. This information must be included in all major annual publications and on the school district’s website.
Professional Development. Arrange for training to ensure that all staff and students are aware of their civil rights and that staff are aware of their legal responsibilities.
Facilitate the Grievance Process. Receive, resolve, and/or report to higher authorities complaints from parents, students, and employees to ensure that concerns are handled promptly and effectively according to school board adopted grievance procedures.
Monitoring. Monitor the school’s compliance with state and federal law by reviewing and disseminating disaggregated student achievement data, building and course enrollment data, student activity data, and employment and personnel data.