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V OLUNTARY COMPLIANCE AGREEMENTBETWEEN THEUNITED STATES DEPARTMENT OF HEALTH AND HUMAN SERVICESOFFICE FOR CIVIL RIGHTSAND THEWISCONSIN DEPARTMENT OF CHILDREN AND FAMILIESTRANSACTION -00734

TABLE OF CONTENTS1.Introduction1II.Parties to the Agreement3III.Jurisdiction3IV.General Provisions4V.Definitions7VI.Specific Provisions11A.Notification of the Provisions of this Agreement11B.Section 504 and ADA Compliance and Grievance Procedures11C.Title VI Compliance and Complaint Resolution Procedures12D.Preventing and Addressing Allegations of Discrimination Based on Disability inVV-2Programs13Preventing and Addressing Allegations of Discrimination Based on Race, Color,or National Origin in VV-2 Programs30F.DCF VV-2 Program Manuals33VII.Data Collection and Reporting Requirements33VIII.Signatures36

VOLUNTARY COMPLLANCE AGREEMENTBetWeen theu.s. DEPARTMENT OF HEALTH AND HUMAN SERVICESOFFICE FOR CIVIL RIGHTSAnd theWISCONSIN DEPARTMENT OF CIDLDREN AND FAMILIESI.IntroductionA.This Voluntary Compliance Agreement (hereinafter the Agreement) is enteredinto by the United States Department of Health and Human Services, Office forCivil Rights (OCR), and the Wisconsin Department of Children and Families(DCF), l to resolve race and disability discrimination complaints alleging that theDCF's administration ofthe Federally-funded Temporary Assistance to NeedyFamilies (TANF) Program (known as Wisconsin Works or the W-2 Program)violates Title VI of the Civil Rights Act of 1964, Section 504 of the RehabilitationAct of 1973, and Title II oftheAmericans witfl, Disabilities Act of i 990.B.This Agreement resolves OCR Complaint Nos. 02-00727, 02-00728, 02-00729,02-00730, and 02-00731, filed on February 13,2002, by Legal Action ofWisconsin, Inc. (LAW). In the complaints, LAW alleged that the administrationofthe W-2 Program in Wisconsin violates Section 504 and the ADA because,among other things, DCF: designates applicants as ''job ready" without screening or assessing themto determine if any disability affects their ability to work; has not developed and utilized effective screening tools; has not sufficiently trained Resource Specialists and Financial andEmployment Planners (FEPS) to identify disabilities; has not afforded applicants and participants the opportunity for a timely,IOn June 30, 2008, Wisconsin combined the Wisconsin Department of Health and FamilyServices and the Wisconsin Department of Workforce Development to form the WisconsinDepartment of Children and Families (DCF). Throughout this agreement, we will use the term"DCF" to refer to both the Wisconsin Department of Children and Families and its predecessoragency, the Wisconsin Department of Workforce Development.1

comprehensive assessment when the intake interview indicates thepresence of a disability;C. has not developed guidelines as to what a comprehensive assessmentshould include; has not provided reasonable accommodations to participants withdisabilities and participants who have family members with disabilities; has not developed specialized education and training programs forparticipants with mental impairments and learning disabilifies; has not adequately trained FEPS to work with applicants and participantswith disabilities; does not regularly assess a participant's progress in ac ivities to determineif a participant has a disability that requires reasonable accommodations,or whether the needs of a family member with a disability interfere withthe participant's ability to participate in, and benefit from, the W-2Program; does not adequately train and oversee W-2 Agencies with respect tocompliance with Section 504 and the ADA, and otherwise fails to takecorrective action with respect to W-2 Agency compliance violations; and does not provide written materials that contain adequate informationregarding an applicant's or participant's rights under Section 504 and theADA, including, but not limited to, the right to file a complaint.This Agreement also resolves OCR Complaint No. 02-00734 filed against DCFon February 18,2002, by the American Civil Liberties Union of WisconsinFoundation (ACLU-WIF) and the National Association for the Advancement ofColored People Milwaukee Branch (NAACP). The ACLU-WIF and the NAACPalleged, among other things, that DCF: does not have in place sufficient intake, screening, and assessmentprocedures to properly identify and evaluate the needs ofW-2 applicantsand participants with disabilities, all in violation of Section 504 and theADA; fails to ensure that the W-2 Program is accessible to and accommodatespersons with disabilities and persons who have household members withdisabilities, in violation of Section 504 and the ADA, because DCF:"2

ll.llI.ofails to conduct proper reviews of the W-2 Program's intake,screening, and assessment procedures;ouses inadequate notices;oimposes excessive verification requirements;ofails to ensure appropriate assignments; andoimplements inappropriate policies and practices regardingsanctions, case closures, and time limit extensions; discriminates per se against persons with disabilities in certain aspects ofits W-2 Program; and extends time limits in its W-2 Program in a racially discriminatory mannerfor W-2 participants in violation of Title VI of the Civil Rights Act of1964.Parties to the AgreementA.United States Department of Health and Human Services, Office for Civil Rights;and theB.State of Wisconsin Department of Children and Families, the state agencyresponsible for the administration ofthe Wisconsin Works (W-2 Program), aprogram that is funded in part by the Temporary Assistance for Needy FamiliesBlock Grant that provides services to low-income adults with custodial children tohelp them move toward self-sufficiency through employment.JurisdictionA.OCR is the HHS office charged with enforcing civil rights laws as they pertain toprograms funded by HHS, and so has jurisdiction over these complaints pursuantto Title VI ofthe Civil Rights Act of 1964,42 U.S.C.§ 2000d, and itsimplementing regulations at 45 C.F.R. Part 80 (collectively, "Title VI"). Title VIprohibits discrimination on the basis of race, color, and national origin byrecipients ofFederal financial assistance. All entities that receive Federalfinancial assistance from HHS,either directly or indirectly, through a grant,contract, or subcontract, are obligated to comply with, among other things, TitleVI.B.OCR also has jurisdiction overthese complaints pursuant to Section 504 of theRehabilitation Act of 1973,29 U.S.C. § 794, and its implementing regulations at45 C.F.R. Part 84 (collectively, "Section 504"). Section 504 prohibits3

discrimination on the basis of disability by recipients of Federal financialassistance. All entities that receive Federal fmancial assistance from HHS, eitherdirectly or indirectly, through a grant, contract, or subcontract, are obligated tocomply with, among other things, Section 504.IV.C.In addition, OCR has jurisdiction pursuant to Title n of the Americans withDisabilities Act of 1990,42 U.S.C. § 12131 et seq., and its implementingregulations at 28 C.F.R. Part 35 (collectively, "the ADA"). The ADA prohibitsdiscrimination on the basis of disability in State and local government programsand services and requires public entities to make reasonable modifications inpolicies, practices, and procedures when necessary to avoid discrimination on thebasis of disability, unless doing so would fundamentally alter the nature of theprogram, service, or activity. OCR is the designated agency responsible forinvestigating ADA complaints against State and local governments with regard tothe administration of social service programs or activities. See 28 C.F.R. §35.190(b)(3).D.DCF is responsible fot administering the State of Wisconsin's TANF Program.As an instrumentality ofthe State, DCF is obligated to comply with the ADA.As a recipient of Federal financial assistance from HHS in the form ofa TANFBlock Grant, DCF must comply with Section 504 and Title VI.E.The Personal Responsibility and Work Opportunity Reconciliation Act of 1996(PRWORA), 42 U.S.C. § 1305, specifically requires States to operate their TANFprograms in compliance with Section 504, the ADA, and Title VI.General ProvisionsA.The terms of this Agreement do not prejudice any other issues, investigations,reviews, or complaints of discrimination that are unrelated to the subject matter ofthis Agreement and that may be currently pending before OCR. Any unrelatedcompliance matters arising from subsequent reviews or investigations may beresolved separately. Nothing in this Agreement shall be construed to limit orrestrict OCR's statutory and regulatory authority to conduct future complaintinvestigations and compliance reviews related to DCF and the subject matter ofthis Agreement.B.This Agreement does not address or resolve issues involved in any complaintinvestigation, compliance review, or administrative action under Federal laws byother Federal agencies, including any action or investigation under Title II of theADA, Section 504 of the Rehabilitation Act, or Title VI of the Civil Rights Act.C.DCF's execution ofthis Agreement shall not be construed as an admission ofliability by DCF, or as evidence that it has not complied with Section 504, the4

ADA, or Title VI; and further shaH not constitute a waiver ofany defense DCFmay assert in any judicial or administrative proceedings.D.Nothing in this Agreement is intended to relieve DCF ofits obligation to complywith other applicable nondiscrimination statutes and their iIllplementingregulations.E.When requested by DCF, OCR will, at its discreti()n, provide technical assistanceto assist DCF in implementing this Agreement.F.OCR agrees to bring to the attention ofDCF any complaints, related to thematters herein and filed with OCR against DCF, for the period of three (3) yearsfrom the Effective Date of this Agreement; and to attempt resolution of suchcomplaints within the framework of this Agreement before initiating aninvestigation.G.DCF shall not retaliate, intimidate, threaten, coerce, or discriminate against anyperson who has filed a complaint or grievance, or otherwise participated in anymanner in the matters addressed in, or covered by, this Agreement.H.OCR places no restriction on the publication of the terms of this Agreement, andDCF acknowledges that the Agreement may be published on OCR's website anddisseminated by OCR to the public. In addition, OCR may be required to releasethe Agreement and all related materials to any person, upon request, consistentwith the requirements ofthe Freedom ofInformation Act, 5 U.S.C. § 552, and itsimplementing regulation, 45 C.F.R. Part 5. In the event OCR receives such arequest, we will make every effort, as permitted by law, to protect informationthat identifies individuals or that, if released, could constitute a clearlyunwarranted invasion of personal privacy.1.OCR may, at any time, investigate DCF's compliance with this Agreement.J.DCF shall, if requested, provide OCR with access to information and resourcesthat OCR deems necessary to determine DCF's compliance with the terms of thisAgreement. DCF specifically shall permit OCR to inspect premises, interviewwitnesses, and examine and copy documents as is necessary to monitor thisAgreement.K.If at any time OCR determines that DCF has failed to com.ply with the terms ofthis Agreement, OCR shall notify DCF in writing. The notice shall include astatement ofthe basis for OCR's determimition and allow DCF fifteen (15)business days either: (a) to explain in writing the reasons for its actions anddescribe the remedial actions that have been or shall be taken to achievecompliance with this Agreement; or (b) to dispute the accuracy andlor legalsufficiency of OCR's finding. On notice to DCF, OCR may shorten the fifteen5

(15) day period if it determines that a delay would result in irreparable injury toaffected parties. If DCF does not respond to the notice, or if, upon review ofDCF's response, OCR determines that DCF has not complied with the terms ofthe Agreement, OCR reserves the right to reopen its review ofDCF's compliancewith Section 504, the ADA, and Title VI, with respect to the W-2 Program. OCRmay incorporate into its reopened compliance review any relevant evidence ofnoncompliance with this Agreement, and any relevant evidence gathered by OCRprior to the signing of this Agreement.L.Failure by OCR to enforce this entire Agreement or any provision thereof withrespect to any deadline or any other provision herein shall not be construed as awaiver of OCR's right to enforce other deadlines and provisions of thisAgreement.M.This Agreement constitutes the entire agreement between DCF and OCR on thematters raised herein, and no other statement, promise or agreement, either writtenor oral, made by either party or agents of either party, that is not contained in thiswritten Agreement, shall be enforceable.N.This Agreement may be modified by mutual agreement of the parties in writing.O.This Agreement shall become effective on the date it is signed by OCR and DCF(the "Effective Date") and shall remain in effect for three (3) years after theEffective date ("the Term"). If, at any time, OCR determines that DCF is not incompliance, OCR will provide DCF with information concerning itsnoncompliance as required by Section IV(K) of this Agreement. At thecompletion of each year's monitoring, OCR will provide written confirmation asto whether DCF is in compliance with the terms ofthe Agreement at that point.Three years after the Effective Date, at which point if OCR determines that DCFhas complied with the terms of this Agreement, OCR's review and monitoring ofthis Agreement shall terminate. Notwithstanding the Term of this Agreement,DCF acknowledges that it continues to be obligated to comply with Section 504and Title VI for as long as it continues to receive Federal financial assistance, andthat it continues to be obligated to comply with the ADA as an entity of State.government. 2OCR has issued policy guidance that clarifies the obligations Title II of the ADA and Section504 impose on State and local government entities, and on recipients of Federal financialassistance from.H.HS involved in the administration ofTANF programs. See U.S. DepartmentofHealth and Human Services, Office for Civil Rights Prohibition Against Discrimination on theBasis of Disability in the Administration ofTANF (Temporary Assistance for Needy Families)(July 19,2007), http://www.hhs.gov/ocr/prohibition.html, cited in Administration for Childrenand Families, U.S. Department of Health and Human Services, Reauthorization oftheTemporary Assistance for Needy Families (TANF) Program; Final Rule, 73 Fed. Reg. 6772,6775 (Feb. 5,2008).26

V.DefinitionsIn this Agreement, the tenns listed below shall have the following meaning:A.B.Disability and Barrier to Participation in the W-2 Program or Employment1.The tenn "disability" in this Agreement is synonymous with the definitionof "disability" (with respect to an individual) contained in the ADA. 42U.S.C. § 12102(1). See also the definition of "individual with a disability"contained in Section 504. 29 U.S.c. §§ 705(20)(B) and 794(a);2.For purposes of this Agreement, the tenn "barrier to participation in theW-2 program or employment" would include, but not be limited to,situations where an applicant or participant has a family member includedin the W-2 group living in the home who has a disability that poses abarrier to the applicant's or participant's participation in the W-2 Programor employment. Medical documentation must be provided to support theapplicant's or participant's need to remain in the home to provide care forthe W-2group family member.3.The tenn "W-2 group" includes an adult custodial parent, all dependentchildren with respect to whom the individual 3 is a legal custodial parent,and all minor children with respect to whom the individual's dependentchild is a custodial parent. W-2 group includes any nonmarital co-parentor any spouse of the individual who resides in the same household as theindividual and any minor children with respect to whom the spouse ornonmarital co-parent is a custodial parent.Reasonable Modification and Reasonable Accommodation1.The tenns "reasonable modification" and "reasonable accommodation"are defined as changes or adjustments to a covered entity's policies orprocedures to avoid discrimination on the basis of disability and to affordqualified individuals with disabilities an equal opportunity to participatein, and benefit from, services provided under a covered program oractivity. These tenns are often used interchangeably in practice and maybe used interchangeably in this Agreement.2.The provision of reasonable modifications/accommodations may takemany fonns, including, but not limited to, the TANF application process,notifications to beneficiaries of their rights and requirements under theThe tenns "individual" and "person" as used in this section have the same meaning as"applicant" or "participant" as used throughout this Agreement.37

TANF program, assistance in completing forms and collectingverifications, and the provision of auxiliary aids and services.C.D."W-2 Program" refers to DCF's Wisconsin Works Program and its componentpartsI."Unsubsidized Employment": Employment for which a W-2 Agency orcontractor provides no subsidy to the employer, including selfemployment and entrepreneurship.2."Trial Job": A W-2 subsidized employment position that provides workexperience and training which may become permanent unsubsidizedemployment. The W-2 subsidy for Trial Job participants is paid directly tothe employer.3."Community Service Job (CSJ)": A W-2 work-readiness practiceplacement designed to improve the employability ofparticipants byproviding work experience and training in the public and private sectors.4."W-2 Transition (W-2 T)": A W-2 T employment position is forparticipants who have been determined not ready for unsubsidizedemployment and unab"le to successfully participate in one of the other W-2employment positions for reasons such as a participant's incapacitation orthe need to remain in the home to care for another W-2 group memberwho is incapacitated or disabled.W-2 Agency"W-2 Agency" or "W-2 Agencies" refers to entities with which DCF contracts toadminister the W-2 Program and related services to assist individuals to obtainfull time employment.E.Applicant and ParticipantI.2.F.An "applicant" is any individual who has applied for W-2 services.A "participant" is any individual who participates in any component ofW-2.Informal Assessment"Informal Assessment" is a process to gather information about an individual andhis or her family to determine the: Individual's ability to become employed and remain employed;8

G. Services and activities necessary for the individual to become employedand remain employed; Appropriate placement ofa participant on the W -2 employment ladder; Need for further career assessment and planning; Need for vocational evaluation; Existence ofpotential disabilities or other specific limitations throughscreening with a validated screening tool; and Need for a formal assessment of any disabilities or other employmentbarriers by a Qualified Assessing Agency or Individual.Formal Assessment"Formal Assessmenf' is the process of establishing the: Extent and severity of any disabilities or other conditions (e.g., domesticviolence, learning needs, or need to care for disabled child) that mayinterfere with normal functioning in an employment setting or with aperson's ability to meet W-2 program requirements; Effect of a disability or other potential barrier on the person's capacity toobtain and maintain unsubsidized employment, participate in.employment-related activities (e.g., employment training or education) orotherwise meet W-2 program requirements; Need for supportive services, reasonable accommodations, auxiliary aids,or communication assistance; Conditions under which the person is capable of employment oremployment-related activities; Need to make reasonable modifications to policies, practices, andprocedures when necessary to ensure equal opportunity for persons withdisabilities; and Appropriateness of specific assignments in the W -2 program.9

----------H.Qualified Assessing Agency or IndividualA "Qualified Assessing Agency or Individual" is a professional qualified toperform a formal assessment and may include a medical or mental healthprofessional, social worker, psychologist, neuro-psychologist, Division ofVocational Rehabilitation counselor or similar qualified assessing agency orindividual. Characteristics required of the Qualified Assessing Agency orIndividual include:1.Demonstrates a competency or successful completion of training in theappropriate field and is certified by an appropriate accreditationorganization.2.Demonstrates an understanding of the objectives of the formal assessmentbased on W-2 referral information, referral questions, the initial interview,and stated purpose of the evaluation.The Qualified Assessing Agency or Individual must provide an individualizedwritten assessment that enables the FEP to adapt W-2 activities to accommodatethe needs of the applicant or participant.1.J.Resource Specialist and Financial and Employment Planner1.A "Resource Specialist" is a W-2 Agency employee or contractedemployee who makes an assessment of needs, performs initial referrals toservice providers, and evaluates the need for W-2 services.2.A "Financial and Employment Planner" (FEP) is a case manageremployed by, or who has contracted with, a W-2 Agency. The FEPprovides eligibility determinations, job readiness screening, employabilityplanning. and financial and employment case management services;makes referrals to other public or private assistance programs or resources;and determines eligibility for supportive services, such as food stamps,medical assistance, job access loans, child care, and emergency assistance.Employability PlanAn "Employability Plan" (EP) is a written agreement developed by a FEP inconsultation with the participant. It is a case management tool that details alogical, sequential series of actions and becomes a blueprint for change to movethe participant from dependency to self-sufficiency. The participant'soccupational goal, precise tasks required 6fboth the W-2 Agency and theparticipant, and the supportive services needed are identified in the EP.10

VI.Specific ProvisionsA.Notification of the Provisions of this AgreementWithin sixty (60) daysofthe Effective Date of this Agreement, DCF shall providenotification in memorandum form to all W·2 Agencies that identifies the terms ofthis Agreement including, but not limited to, the availability of informal andformal assessments as described below in Section VI(D)(2) and (3).B.Section 504 and ADA Compliance and Grievance Procedures1.Within thirty (30) days ofthe Effective Date of this Agreement, DCFagrees to designate a staff person to oversee DCF's compliance withSection 504 and the ADA in its implementation ofthe W-2 Program(hereinafter the "Equal Opportunity Specialist/EquaJ Opportunity Officer(EO SIEO 0)"). The EOSIEOO shall report directly to the DeputySecretary ofDCF, and not to any intermediary, to ensure that any issues ofnon-compliance with this Agreement are addressed in a timely andefficient manner.2.The EOSIEOO shall, at a minimum, be responsible for:a.conducting periodic reviews ofDCF policies and procedures todetermine whether reasonable modifications ofprograms, policies,and procedures are required to ensure compliance with Section 504and the ADA;b.providing advice and technical assistance to W-2 Agenciesregarding compliance with Section 504 and the ADA;c.overseeing the Section 504 grievance process and the ADAgrievance proce,ss, including ensuring the appropriate and timelyresolution of grIevances, and submitting and implementing acorrective action plan if a grievance is determined to be wellfounded;d.maintaining records of all Section 504 grievances and ADAgrievances filed with DCF in relation to the W-2 Program alongwith records showing resolution oftliose grievances;e.assisting in the development and coordination of training ofW-2Agency staff and contractors regarding the requirements of Section504 and the ADA in the administration of the W-2 Program; and(11

f.3.C.monitoring DCF's compliance with the provisions of Section 504and the ADA, including the compliance of its contractors withSection 504 and the ADA as that compliance relates to the W-2Program, and providing technical assistance to DCF whennecessary to obtain compliance.Within one hundred and eighty (180) days of the Effective Date of thisAgreement, DCF shall review and revise (as necessary) its Section 504Grievance Procedures and its ADA Grievance Procedures so that theymeet the standards set forth in 45 C.F.R. Part 84 and 28 C.F.R. Part 35,respectively. The Section 504 Grievance Procedures and the ADAGrievance Procedures must be made available to applicants andparticipants to ensure that they are aware of their right to file grievancesalleging denials of reasonable accommodations/modifications or equalopportunities to receive benefits or services under the W-2 Program. DCFshall make available its Section 504 Grievance Procedures and its ADAGrievance Procedures in alternative formats so that they are accessible topersons with disabilities upon request.Title VI Compliance and Complaint Resolution Procedures1.Within thirty (30) days of the Effective Date of this Agreement, DCFagrees to designate a staff person to oversee DCF's compliance with TitleVI in its implementation of the W-2 Program (hereinafter the"EOSIEOO"). The EOSIEOO shall report directly to the DeputySecretary ofDCF, and not to any intermediary, to ensure that any issues ofnon-co1Jlpliance with this Agreement are addressed in a timely andefficient manner. The EOSIEOO responsible for Title VI compliance maybe, but is not required to be, the same EOSIEOO responsible for Section504/ADA compliance.2.The EOSIEOO shall, at a minimum, be responsible for:a.conductjng periodic reviews ofDCF policies and procedures todetermine whether changes to DCF programs, policies, andprocedures are required to ensure compliance with Title VI;b.providing advice and technical assistance to W-2 Agenciesregarding compliance with Title VI;c.overseeing the Title VI complaint process and ensuring appropriateand timely resolution of Title VI complaints, and submitting andimplementing a corrective action plan if a complaint is determinedto be well-founded;12

3.D.d.maintaining records of all Title VI complaints filed with DCF inrelation to the W:.2 Program along with records showing resolutionof those complaInts;e.assisting in the development and coordination of training ofW-2Agency staff and contractors regarding the requirements of TitleVI in the administration of the W-2 Program; andf.monitoring DCF's compliance with the provisions of Title VI,including the compliance of its contractors with Title VI as thatcompliance relates to the W-2 Program, and providing technicalassistance to DCF when necessary to obtain compliance.Within one hundred and eighty (180) days of the Effective Date of thisAgreement, DCF shall review and revise (as necessary) its Title VIcomplaint resolution procedures so that they are in compliance with TitleVI. The Title VI complaint resolution procedures must be made availableto applicants and participants to ensure that they are aware of their right tofile complaints alleging denials of equal opportunities to receive benefitsor services under the W-2 Program. DCF shall.present its Title VI .complaint resolution procedures in alternative formats so that they areaccessible to persons with disabilities upon request.Preventing and Addressing Allegations of Discrimination Based on Disability inW-2 Programs1.ObligationsWithin one hundred and eighty (180) days ofthe Effective Date of thisAgreement, DCF shall ensure that its W-2 policies and proceduresconform at a minimum with the requirements enumerated below to ensurethat all applicants and participants are afforded an equal opportunity to'participate in the W-2 Program, regardless of a disability or other barrierto participation in the W-2 program or employment. DCF shall further·ensure that all applicants and participants are afforded individualizedtreatment and effective and meaningful opportunities under the W-2Program.a."Effective and meaningful opportunity" requires that: allapplicants and participants be afforded the same opportunity tobenefit from the W -2 Program; all applicants and participants beprovided meaningful access to the W -2 Program; and the methodsof administration utilized by W-2 Agencies be non-discriminatory.13

b.2."Individualized treatment" requires that applicants and participants .be treated on a case-by-case basis consistent with facts andobjective evidence. Applicants and participants may not be treatedon the basis. of generalizations and stereotypes.Informal Assessment and Screening for Barriersa.DCF shall require that all W-2 Agencies conduct an informalassessment of each applicant at the time the applicant submits hisor her application to participate in the W-2 Program and alsobefore making a change in W -2 placement to determine theapplicant's or participant's strengths and weaknesses and todetermine ifthe applicant or participant has a disability or otherbarrier to participation in the W -2 program or employment. DCFshall require all W -2 agencies to administer an informalassessment at no cost to the applicant or participant.1.Informal assessment shall cover all ofthe following: personal strengths, interests and goals; job skills (including transferable skills), prioreducation, and training; employment history and recent job search efforts; recent career assessment results, if any; emergency s

DCF's response, OCR determines that DCF has not complied with the terms of the Agreement, OCR reserves the right to reopen its review ofDCF's compliance with Section 504, the ADA, and Title VI, with respect to the W-2