methods of administration (moa) overview and updates 2019-2020 · 2019-10-09 · 10. moa -...

Methods of Administration (MOA)Overview and Updates 2019-2020

1201800315 SID Check-in vF.pptx

MOA - 2019-2020

ObjectivesProvide an overview and foundation of the MOA program

Share updates, requirements, and expectations

Discuss how ESCs can help


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The “Methods of Administration” is the program under which OCR delegates to the states the authority to conduct broad civil rights compliance reviews of CTE subrecipients.

What is MOA?


Purpose of the MOA program

To ensure students enjoy equal access to Career and Technical Education (CTE) programs and activities regardless of race, color, national origin, sex, or disability.

MOA - 2019-2020


MOA - 2019-2020

Essential Background Materials

Authority:34 C.F.R. § 100.4(b)(2)Vocational Education Guidelines, 34 CFR, Part 100, Appendix B (March 21, 1979 Federal Register notice)September 1996 revised Memorandum of Procedures(MOP)


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Essential Background MaterialsStatutes and Regulations:

Title VI of the Civil Rights Act of 1964 and its implementing regulations (34 C.F.R. Part 100) – Prohibits discrimination on the basis of race, color, or national origin.

Title IX of the Education Amendments of 1972 and its implementing regulations (34 C.F.R. Part 106) – Prohibits discrimination on the basis of sex.

Section 504 of the Rehabilitation Act of 1973 and its implementing regulations (34 C.F.R. Part 104) – Prohibits discrimination on the basis of disability.

Title II of the Americans with Disabilities Act of 1990 and its implementing regulations (28 C.F.R. Part 35) – Prohibits discrimination on the basis of disability.


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Electronic ResourcesMETHODS OF ADMINISTRATION – TEAhttps://tea.texas.gov/si/CTEMOAmonitoring/Methods of Administration – Office of Civil Rights (OCR)https://www2.ed.gov/about/offices/list/ocr/frontpage/faq/rr/policyguidance/moa.html

Regulations enforced by OCRhttps://www2.ed.gov/policy/rights/reg/ocr/index.html

Guidelines for Vocational Education Programshttps://www2.ed.gov/about/offices/list/ocr/docs/vocre.html

Reading Room - OCRhttps://www2.ed.gov/about/offices/list/ocr/publications.html

https://tea.texas.gov/si/CTEMOAmonitoring/

https://www2.ed.gov/about/offices/list/ocr/frontpage/faq/rr/policyguidance/moa.html

https://www2.ed.gov/policy/rights/reg/ocr/index.html

https://www2.ed.gov/about/offices/list/ocr/docs/vocre.html

https://www2.ed.gov/about/offices/list/ocr/publications.html


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Creating a common languageCTE Program: A sequence of at least two CTE courses for three or more credits in an area of study at a campus or feeder pattern.

Recipient Universe: Recipients receive funding from the U.S. Department of Education, and operate CTE programs.

Subrecipient Universe: Subrecipients receive funding from the U.S. Department of Education through the state agency andoperates a CTE program.


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Creating a common language (cont.)Targeting Plan: A methodology and ranked list of subrecipients (campuses) with the greatest potential for civil rights noncompliance.

Methodology: A selection criteria placing emphasis on equitable opportunities for participation in CTE.

Ranked List: A sampling of campuses with the highest potential for discrimination based on enrollment data

Required Visits - 2.5% of campuses in the recipients universe or 25 visits


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Creating a common language (cont.)Letter of Findings (LOF): A state agency issues an LOFto a subrecipient following an on-site review of the subrecipient’s policies and practices.

Voluntary Compliance Plan (VCP): A state agency and a subrecipient negotiate a VCP that lists the corrective actions that the subrecipient must take to remedy the findings of noncompliance listed in the LOF. The corrective actions must be approved by the agency and be consistent with the Guidelines, applicable regulations, and accessibility standards, and should include a month and year of anticipated completion. The Superintendent’s signature is required.


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How the MOA program works


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MOA Methodology 2019-2020 and 2020-2021

A standard methodology was used to assign scoring points to each of four student groups: gender (female), ethnicity (African American), disabilities and English Learners (EL) in relation to Career and Technical Education (CTE) enrollment.


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MOA Methodology 2019-2020 and 2020-2021Comparison by CTE enrollment.

GROUP CTE ENROLLMENT TOTAL ENROLLMENT %% <- +>

- below norm + above norm

STATE 777,606 1,583,039 49.12% norm

DISABILITY 54,652 138,398 39.49% -9.63%

ENGLISH LEARNER 58,013 144,493 40.15% -8.97%

AFRICAN AMERICAN 89,842 196,270 45.77% -3.35%

FEMALE 375,696 774,414 48.51% -0.61%

MALE 401,007 808,463 49.60% 0.48%

HISPANIC 410,726 798,717 51.42% 2.30%


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MOA Methodology 2019-2020 and 2020-2021

Percentage of participation in CTE was utilized to identifycampuses with potential discriminatory practices. A CTEparticipation ratio was determined for each campus and foreach student group at the campus. For each student group,the ratio of CTE students in that group was compared to theratio of CTE students at the campus. ie.: total CTEenrollment/ total student enrollment minus the CTEgroup/total group enrolment. Points were then assigneddepending on the significance statewide of potentialdiscrimination.


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MOA Methodology 2019-2020 and 2020-2021Point assignment

GROUP % CTE ENROLLMENT% <- +>

- below average + above average

Points Assigned

STATE 49.12% norm Norm - 0

DISABILITY 39.49% -9.63 30 max

ENGLISH LEARNER 40.15% -8.97 25 max

AFRICAN AMERICAN 45.77% -3.35% 20 max

FEMALE 48.51% -0.61% 20 max

MALE 49.60% 0.48% Not Applicable

HISPANIC 51.42% 2.30% Not Applicable


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MOA Methodology 2019-2020 and 2020-2021To determine which campuses were eligible for staging, campuses were filtered for having at least one coherent sequence of courses resulting in the targeted universe. Campuses were excluded from the targeted universe for the following:• A student population with fewer than 20 CTE students • A student population with fewer than 10 students in a group• A student population with less than a 5% variance below the

campus norm• Districts on record as having received an MOA visit• For districts with multiple identified campuses, only the

campus with the highest point total is selected for an on-site review.


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MOA Targeting Plan 2019-2020 and 2020-2021MOA Subrecipient Universe1907 secondary campuses in Texas offering two or more CTE courses in a sequence at the campus.

Selection Criteria – October 2017Campus demographic and enrollment data

Ranking ProcedureRanked on factors that would indicate the possibility of, or a potential for, problems in the administration of the CTE programs or the provision of access to their CTE programs.


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MOA Ranking 2019-2020 and 2020-2021Ranking was determined by the total number of points for all categories and the subrecipients with the highest number of points were selected for an on-site MOA review.

In previous reviews, “Hispanic” was utilized as an ethnic minority. That is no longer the case in Texas and was dropped from the targeting process.


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MOA Ranking 2019-2020 and 2020-2021Campuses receiving the same number of points were rank ordered by CTE student enrollment, with the largest enrollment listed first down to the smallest enrollment.

The rational for excluding districts with a history of past reviews was elected due to the numbers of district/campuses in the universe and the need to demonstrate best practices more widely across the state.

Any campus receiving a point total of 75 would be automatically included for on-site review no matter their last visit date.


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SCOPE


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Indicator StructureI. Administrative Requirements;II. Recruitment, Admissions, and

Counseling;III. Accessibility;IV. Comparable Facilities; V. Services for Students with

Disabilities;VI. Financial Assistance;VII. Work-study, Cooperative Programs,

and Job Placement; andVIII. Employment.


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MOA DOCUMENTATION REQUEST (2019)To streamline work and to assist the campuses that are due a Methods of Administration (MOA) visit, we are requesting documents prior to the Method of Administration (MOA) Onsite Review.

Two sets of documentation will be requested of each campus receiving an MOA visit.(Please submit all documentation to TEA at least four weeks prior to the onsite review. For materials that are on-line, please render as PDF and provide link for review.)


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Accessibility InformationSend a site/campus map and floor plan for facilities of the schools being reviewed, that includes paths of travel, buildings, and parking lots

(Note- use date that construction began, not date of completion, otherwise an incorrect higher standard may be used to determine compliance.)


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Accessibility Information (cont.)Date(s) of original construction, and identify areas on map

Date(s) and area(s) of subsequent renovation(s)/alteration(s), if any, and identify areas on map with lines separating original construction or other renovations or alterations

Dates of ramp added/installed, if any, and identify on map or floor plan

Dates that elevators/lifts were installed, if any, and identify on map or floor plan


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Accessibility Information (cont.)Date of the last resurfacing and/or relining of each the parking lots at each school being reviewed, and identify on map

Total parking spaces in each lot at each school being reviewed, and identify on map

Ensure that stand-alone buildings, parking lots are included in the site maps.


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Accessibility Information (cont.)o Please color-code the maps to the date of construction or renovation.

Utilize the Color Key:

Construction before June 4, 1977--Readily Accessible standard—Black on whiteConstruction between June 4, 1977 and January 18, 1991--ANSI standard—GreyConstruction between January 18, 1991 and January 26, 1992--UFASstandard—OrangeConstruction after January 27, 1992--ADA standard—Yellow

Areas can be filled or outlined


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Material and Information This Request for Material and Information are cross-referenced with the MOA Access to Career and Technical Education Program Workbook.

For items that satisfy the documentation requirements for an indicator, the district should not duplicate the information for the onsite review.

Google Drive will be the primary receptacle for documentation. You can learn more about Google Docs at: https://edu.gcfglobal.org/en/googledriveanddocs/ . DO NOT SUBMIT IDENTIFIABLE INFORMATION VIA GOOGLE DOCS. ISAM WILL RECEIVE ALL INFORMATION THAT CONTAINS IDENTIFIABLE INFORMATION.

https://edu.gcfglobal.org/en/googledriveanddocs/


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Timeline and ProcessOn site:• Entry conference• Folder reviews• Interviews • Student Interviews• Facility review• Exit conference


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District Preparation Prior to Onsite Interviews

• Personnel should be prepared to discuss and have copies of documentation demonstrating non-discrimination for access to CTE courses, pathways and CTE related activities.

• Student populations will be defined by the methodology creating the need for the MOA visit.


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Student Populations That May Be Included

• African-American students• Female students • Students with disabilities • English Learners


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Include the following documentation for each student

• Coherent sequence of CTE courses;• Course Schedule• Evidence of Four Year Plans that demonstrate a

CTE coherent sequence;• Evidence of career inventory or interest inventory

being completed; and,• Evidence of appropriate counseling in reference to

CTE.


MOA - 2019-2020

CTE Folder Review• The appropriate personnel should be prepared to

discuss and have copies of the documentation of one CTE student that is as complete as possible.

• Appropriate personnel will share 5 student folders not in CTE.

• Staff should be able to discuss opportunities for access to CTE courses for students not enrolled in a coherent sequence.


MOA - 2019-2020

Students With DisabilitiesIf the campus is identified for students with disabilities, students selected should include a variety of disabilities and instructional arrangements. Include:• the documentation of five students with a

disability who are in CTE pathways, and

• five students with disabilities who are not in acoherent sequence of courses.


MOA - 2019-2020

For students with disabilities include the following:• evidence of reassignment of classes or modifications

making buildings accessible;• evidence of modifications that would include redesign;• auxiliary aids and services being provided in CTE classes;• evidence of CTE teacher’s participation in ARD

discussions; and,• evidence of discussion of CTE in the ARD deliberations

or during transition meetings.

Students With Disabilities (cont.)


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Additionally, campus shall provide class schedules for all students who use a wheelchair and for all students with a visual impairment or with an auditory impairment.

Students With Disabilities (cont.)


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1. Administrative


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1. Administrative, cont.


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2. Recruitment, Admissions, and Counseling


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2. Recruitment, Admissions, and Counseling, cont.


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3. Accessibility


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3. Accessibility, (cont.)


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4. Comparable Facilities


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5. Services for Students with Disabilities


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5. Services for Students with Disabilities, (cont.)


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6. Financial Assistance


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7. Work-Based Learning, Cooperative Programs, and Job Placement


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7. Work-Based Learning, Cooperative Programs, and Job Placement, (cont.)


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8. Employment


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8. Employment (cont.)


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Next steps?


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Timelines

• Receipt of report – 10 days

• Voluntary Compliance Plan (VCP) – 45 days

• Documentation of Corrective Activities – 90 days


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Who Is Here Today?


Division of Review, Support and Monitoring

Jennifer Alexander, Ed.D.Division of Review and Support, Director

Susie CoultressDivision of Review and SupportSpecial Populations Monitoring, Director

Gordon FranzenMethods of Administration - CoordinatorDivision of Review & Support

Texas Education Agency


MOA - 2019-2020

© 2018 by the Texas Education AgencyCopyright © Notice.The Materials are copyrighted © and trademarked ™ as the property of Texas Education Agency (TEA) and may not be reproduced without the express written permission of TEA except under the following conditions:

1) Texas public school districts, charter schools, and education service centers may reproduce and use copies of the Materials and Related Materials for the districts' and schools' educational use without obtaining permission from TEA.

2) Residents of the state of Texas may reproduce and use copies of the Materials and Related Materials for individual personal use only, without obtaining written permission from TEA.

3) Any portion reproduced must be reproduced in its entirety and remain unedited, unaltered, and unchanged in any way.

4) No monetary charge can be made for the reproduced materials or any document containing them; however, a reasonable charge to cover only the cost of reproduction and distribution may be charged.

Private entities or persons located in Texas that are not Texas public school districts, charter schools, or education service centers, or any entity, whether public or private, educational or non-educational, located outside the state of Texas must obtain written approval from TEA and will be required to enter into a license agreement that may involve the payment of a licensing fee or a royalty.For information, contact the Office of Copyrights, Trademarks, License Agreements, and Royalties, Texas Education Agency, 1701 N. Congress Ave., Austin, Texas, 78701-1494; phone 512-463-7004, email: [email protected].


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