Development of FTA EEO Program Plans

THOMAS HOUSTON is uniquely positioned to assist your company with overall EEO program development including EEO program plans, training seminars, and ongoing compliance monitoring. THOMAS HOUSTON can efficiently produce cost-effective Equal Employment Opportunity (EEO) programs for your company. Our Project Team’s experience with the concerns and processes of combining government compliance with grant recipient’s personnel policies and practices allows us to alleviate the pressures involved in developing a program. Our EEO programs are written to meet the very precise, regulatory specifications and are customized to ensure that each organization’s specific efforts are addressed.

Department of Transportation Steps Up Its Civil Rights Oversight

The Federal Transit Administration (FTA) has stepped up its civil rights oversight and EEO program compliance. Not only are EEO Programs under greater scrutiny by the FTA for EEO plan development, training and monitoring, but so too are the plans of grant subrecipients and contractors. THOMAS HOUSTON is uniquely qualified to develop and monitor EEO Program plans given our years of experience producing Plans for grant recipients, subrecipients, contractors and subcontractors that have passed FTA’s scrutiny. We have serviced clients for more than 39 years, and have developed one of the most experienced EEO/AA teams available.

Recent updates to the Circular call for more in depth analysis regarding employment practices (i.e. hires, terminations, promotion activity, compensation, etc.) and Protected Veterans and Individuals with Disabilities’ applicant and hire activity. THOMAS HOUSTON is poised to provide these additional required analyses to ensure organizations remain compliant with all regulation requirements as newly defined.

Does your Organization meet the Criteria that Requires an EEO Program (EEOP)?

The EEO program is required of all DOT/FTA direct grant recipients, State DOT’s, subrecipients, contractors and subcontractors that meet the following thresholds:

  • Employs 100 or more transit-related employees; and
  • Receives capital or operating assistance in excess of $1 million, or;
  • Receives planning assistance in excess of $250,000.

Direct grant recipients and State DOT’s that meet the above thresholds are also required to submit their written EEO programs (EEOP) to the FTA every four years. Subrecipients, contractors and subcontractors meeting the above thresholds are required to submit their written EEO programs to the direct grant recipient or State DOT.

Furthermore, grant recipients, subrecipients, contractors and sub-contractors with 50-99 transit-related employees, that meet the above dollar thresholds, are required to prepare a modified EEOP and maintain it as it may be requested by the Office of Civil Rights or during a State Management review or Triennial review.

THOMAS HOUSTON can assist your organization in preparing the required elements of your EEO Program:

  • Submission every 4 years to the FTA or the direct grant recipient
  • Statement of EEO Policy
  • Communication and Dissemination
  • Designation of EEO Officer
  • Utilization Analysis
  • Goals/Timestable Projection
  • Assessment of Employment Practices
  • Annual Plan Monitoring & Updates

Contact Us to assist you with these and other additional requirements of your EEO Program.

FTA EEO Program Monitoring

Program monitoring ensures compliance with Circular 4704.1. Our team performs this vital service on behalf of FTA grant recipients who lack the resources, time, and expertise to internally monitor the EEO Programs of subrecipients, contractors, and subcontractors.

The Program Monitoring process should serve the following purposes:

  • Assess EEO accomplishments
  • Enable the agency to evaluate the EEO program during the year and to take any necessary corrective action regarding the development and execution of programs or goals and timetables
  • Identify those units which have failed to achieve a goal or to implement affirmative steps to alleviate concentrations or goal attainment
  • Provide a precise and factual database for future projections
  • Provide documentation to support actions that affect minority and female job applicants or employees
  • To keep management informed of program effectiveness

FTA Training Programs

FTA Circular 4704.1A Ensuring Compliance in EEO Programs

Register for this informative hour on the basic requirements of preparing an EEO Program meeting the requirement of DOT/FTA (formerly UMTA) Circular 4704.1. This information is timely due to the high-volume of new ARRA funding grant recipients. DOT/FTA has made numerous procedural changes to enforcement within the past 24 months.

Attendees will be provided up-to-the-minute focal areas and "hot button" issues and will walk away with an understanding of DOT/FTA oversight and be better equipped to prepare for compliance reviews, complaints, and Triennial reviews by the agency.

FTA EEO Basics for Supervisors and Managers

The DOT’s Urban Mass Transit Agency (UMTA) issued Circular 4704.1 in 1988 requiring the development of an EEO Program for transit authorities meeting both an employee threshold and dollar threshold of direct Federal assistance and capital investments. The Federal Transit Administration (UMTA’s successor agency) reissued that Circular in 2016 and became effective on October 1, 2017. The revised Circular (4704.1A) now requires transit supervisors and managers receive EEO training within 90 days of entrance into the position—though no specific training was identified. This webinar, “EEO Basics for Transit Supervisors and Managers,” was developed by THOMAS HOUSTON in conjunction with Sotherlund Consulting to meet this requirement and focuses directly on transit authority management’s EEO responsibilities found in the Circular.

EEO Complaint Investigations in the Transit Industry

FTA Revised Circular 4704.1A requires a robust EEO program complete with an EEO Official who will investigate complaints and oversee the program itself. Additionally, the Circular requires EEO training for the EEO Official and all individuals investigating EEO complaints. This webinar was expressly designed for the transit industry. It covers the types of EEO complaints; forms of discrimination; complaint processing; development of an investigative plan; document review; interviewing techniques for the complainant, witnesses, and the accused; common mistakes to avoid in investigations; and the DOT/FTA complaint process. Employer-specific policies/guidance would supplement this EEO investigative training module.

Presented by: Jude Sotherlund of Sotherlund Consulting in partnership with THOMAS HOUSTON.

FTA and the Americans with Disabilities Act

This self-paced training program will show how The Americans with Disabilities Act (ADA) applies to both public and private ground transportation providers. The ADA rules that apply to transportation are regulated by the U.S. Department of Transportation (DOT).

This presentation will give you a high level view of the regulations and requirements for ground transportation providers and will provide guidance to recipients and subrecipients of Federal Transit Administration (FTA) financial assistance necessary to carry out provisions of the Americans with Disabilities Act (ADA) of 1990, Section 504 of the Rehabilitation Act of 1973, as amended, and the DOT’s implementation regulations.