AFFIRMATIVE ACTION PROGRAM for Workers with Disabilities Section 503 41 CFR 60-741 For the Period December 1, 2016 to November 30, 2017 Pima County Community College District 4905 E. Broadway Tucson, Arizona 85709 DUNS # 068414630 EIN # 86-0208787A1 FICE Code # 007266 IPEDS Reporting EEO Contact: Kate Siemsen Walker Advanced Analyst EEO/ADA/AA and Title IX Pima County Community College District 4905 E. Broadway Tucson, AZ 85709 (520) 206-4539
SECTION I Equal Employment Opportunity/Affirmative Action Statement 41 CFR 60-741.44(a) Lee D. Lambert, Chancellor of the Pima County Community College District, has overall responsibility to implement the College s equal employment and affirmative action policy. The College has in turn assigned the responsibility to coordinate and implement that institutional policy to the Advanced Analyst - EEO/AA. This position has the full support and access to senior management officials, through the Office of General Counsel which reports directly to the Chancellor and the Board of Governors. It has been and shall continue to be both the policy and the commitment of Pima Community College to further equal employment opportunities for all persons regardless of race, religion, color, national origin, sex, age, status as a protected veteran or status as a qualified individual with a disability. The College s EEO policy, as well as its affirmative action obligations, includes the full and complete support of the Chancellor, Lee D. Lambert, as well as the College community. 1
SECTION II Review of Personnel processes for Proper Consideration of Qualifications 41 CFR 741.44 (b) The College monitors its employment process to ensure individuals with disabilities are given appropriate consideration and equal access, including provision of necessary accommodations, for employment opportunities based on their job qualifications. The College will, in each case where a person is rejected for employment or promotion, maintain a record sufficient to describe the reasons for the non-selection and the name of the applicant who was selected If the reason for rejection was based on a disability status and an inability to perform the essential functions of the position with or without a reasonable accommodation, a description of the essential functions of the job will be detailed and the fundamental duties that needed to be performed with or without an accommodation will be included as well as any accommodations that were considered. The office of EEO/ADA/AA will make and retain a record of all accommodations established on behalf of qualified applicant(s) who had identified as having a disability and had requested services. 2
SECTION III Physical and Mental Qualifications 41 CRF 60-741.44(c) The College s Compensation/Classification system currently includes a cyclical review process. Each year a series of job family positions are scheduled for review. Because these standards could screen out qualified individuals with disabilities, this review cycle includes an assessment of all physical and mental job qualification standards. The goal is to ensure that these job standards are job related for the position in question, are consistent with business necessity, and relevant to the essential functions of the job. 3
SECTION IV Reasonable Accommodations of Physical and Mental Impairments 41 CFR 60-741.44(d) The College does provide reasonable accommodations for the known physical and mental limitations of an otherwise qualified individual with a disability unless it can demonstrate that the accommodation would impose an undue hardship on the operation of its business or create a direct threat to the College or the employee. The College s ADA Accommodation request, 1501/AC Americans with Disability Act Reasonable Accommodation Guideline for Employees/Applicants, process was designed to facilitate this requirement. If an employee with a known disability is having significant difficulty performing the essential functions of the job, that employee will be referred to the office of the EEO/ADA/AA and Title IX. This Officer has the authority, resources, support, and access to the College s top administration and legal counsel that is needed to ensure the effective implementation of any reasonable accommodation procedures. A written copy of the College s Policies and Procedures for processing a reasonable accommodation request are available to all employees and applicants. Employees and/or applicants may contact the following individual at any time to request an accommodation or to obtain information: Kate Siemsen Walker Advanced Analyst EEO/ADA/AA and Title IX Pima County Community College District 4905 E. Broadway Tucson, AZ 85709 (520) 206-4539 #EEO-ALL@pima.edu 4
SECTION V Anti-Harassment Procedures 41 CFR 60-741.44 (e) Under Board Policy 5.10 Equal Employment Opportunity, ADA, Non-Discrimination and Anti- Harassment (including Sexual Harassment), the College prohibits harassment of its employees on the basis of disability. Any employee who believes they have been harassed in violation of this policy is urged to immediately bring this to the attention of their supervisor or the EEO/AA/ADA Office. Any supervisor who witnesses such harassment, or is otherwise informed of a possible violation of this policy, is directed to bring this to the immediate attention of any College Administrator or the EEO/AA/ADA Office. Failure of a supervisor with such knowledge to promptly advise responsible College officials is grounds for discipline up to and including termination. The investigation of any complaint of harassment shall be conducted promptly under Standard Practice Guide 1501/AA the Procedure for Complaints of Discrimination, Harassment and Retaliation. Employees may contact the following individual at any time to file a complaint or obtain information: Kate Siemsen Walker Advanced Analyst EEO/ADA/AA and Title IX Pima County Community College District 4905 E. Broadway Tucson, AZ 85709 (520) 206-4539 #EEO-ALL@pima.edu 5
SECTION VI External Dissemination of Policy, Outreach and Positive Recruitment 41 CFR 60-741.44(f) The College will review its current recruitment and outreach efforts of individuals with disabilities in accordance with the recommendations of the regulations and develop and implement a comprehensive recruitment and outreach plan during this AA Program year. Currently, responsibility for recruitment and outreach efforts is assigned to the Talent Acquisition team. An annual self-assessment of outreach and recruitment efforts will be conducted and documented. The College lists job openings with the appropriate employment partners that include: List of Outreach Resources Joblist.ala.org Arizona Job Connection Communitycollegejobs.com Facebook Glassdoor Emails from Pima Community College Higheredjobs.com Joblist.ala.org Higher Our Veterans Hireable.com Hispanic Chamber of Commerce HooJobs.com Simplyhired.com Jobs.com Job Help at the Public Library Indeed Insidehighered.com University of Arizona Joblink www.naccs.org Higher Our Veterans Hireable.com Hispanic Chamber of Commerce HooJobs.com Simplyhired.com Jobs.com Job Help at the Public Library Indeed Insidehighered.com Jobertising.com JobsFlag.com Linkedin Monster.com Myjobhelper.com Myaaplan.com NASFAA Career Center Direct Employers Careeravenue.com Ziprecruiter.com 6
Job Fairs Careerbuilder Diversity Job Fair Tucson Employer Outreach Meeting AZDES Career Expo Pascua Yaqui Tribe - Maximizing Your Job Search Presentation West US Dice Virtual Fair - IT Career Fair The A B C's of the ADA "How to Hire the people You Need" training Tucson Employer Outreach Meeting High School/Young Adult Transition Job Fair JTED Employment and Internship Fair Greater Tucson Diversity job Fair Tucson Employer Outreach Meeting UA Career Days Second Chance Job Fair 50 Plus Job Fair DREAM Job Fair TRANS*FORM Employment Fair and Workshop 7
SECTION VII Internal Dissemination of Statement 41 CFR 60-741.44(g) In its efforts to employ, and advance in employment, qualified individuals with disabilities, the College will post its Equal Employment Opportunity/Affirmative Action statement on College bulletin boards, on the College web site, and on this AA Program document. A copy will be included in the College Personnel Policy Statement handbook and the statement will be communicated during new employee on-boarding sessions. Staff members of the College communicate the context of the policy thoroughly at both new employee on-boarding and supervisory training programs. The College includes equal employment and anti-harassment policy(ies) in its Employee Handbook, and makes its policy(ies) available to employees upon request. In August 2016 a special training session was presented by Kate Siemsen Walker, Advanced Analyst for EEO/ADA/AA and Title IX and Jeff Silvyn, General Counsel, for administrative personnel to explain the anti-discrimination and anti-harassment policies, and the employees responsibility for effective implementation. In the AA Program year 2016-17, a new procedure has been implemented by the College related to electronic information technology (EIT) which is articulated in Administrative Policy; 5.10.02. A working group representing all areas of the college was assembled to design the policy and will ensure that the College continues to meet its stated purpose. The College is committed to supporting an electronic information technology (EIT) environment that is accessible to all, and in particular to individuals with disabilities. The purpose of this Administrative Procedure (AP) is to provide procedures for College administrators, instructors and staff to create, maintain and/or procure accessible EIT. 8
SECTION VIII Audit and Reporting System 41 CFR 60-741(h) The College will continue to design and develop a self-audit and internal reporting system that will: Measure the effectiveness of our efforts to identify and recruit qualified individuals with disabilities; Identify the result of efforts to hire qualified individuals with disabilities; Determine whether our efforts expanded our outreach to individuals with disabilities; Determine whether the efforts increased our ability to include individuals with disabilities in our workforce; Indicate any need for remedial action. In the 2015-16 AA Program year the College completed the following activities in support of the development of this tracking and reporting system: In the College s applicant tracking system, PeopleAdmin, applicants were invited to selfidentify as an individual with a disability. Each recruitment shows the number of individuals who identify as having a disability. The PeopleAdmin software is not designed to aggregates data in a meaningful way and only makes available (within a column) those who identify as having a disability. As a result, a manual process was established for gathering and analyzing the data to meet the compliance obligation. There are two processes in place that allows the tracking of employees who voluntarily selfidentify as having a disability: Form CC-305 POST OFFER INDIVIDUAL WITH A DISABILITY SELF-IDENTIFICATION FORM (14CFR60-741-4260). This information is recorded and maintained confidentially in the Human Resources Information System (HRIS) Banner system. In April 2016, the College completed a College-wide survey which was sent to every employee in an effort to allow for the self-identification of those with disabilities, whether the individual needed an accommodation or not. This information is recorded and maintained confidentially in the HRIS Banner system. The survey was sent to a total 9
of 2706 employees; 288 employees responded for a total of 11%; with 69 employees self-identifying as having a disability for a total of 3% of those who responded. 10
SECTION IX Responsibility for Implementation 41 CFR 60-741.44(i) Lee D. Lambert, Chancellor of the Pima County Community College District, has overall responsibility to implement the College s equal employment and affirmative action policy. The College has in turn assigned the responsibility to coordinate and implement that institutional policy to the Advanced Analyst - EEO/AA. This position has the full support and access to senior management officials, through the Office of General Counsel which reports directly to the Chancellor and the Board of Governors. 11
SECTION X Affirmative Action Training CFR 41 60-741.44(j) All personnel involved in the recruitment, screening, selection, promotion, disciplinary, and related processes will be trained to ensure that the College s commitment to equal employment opportunity is carried out. In addition, the College has developed an ADA accommodation request process for employees and applicants to ensure reasonable accommodations are provided upon evaluation of the request. Employees assigned responsibility for the ADA interactive accommodation process are provided annual updated training at the national level to increase knowledge and awareness of changing laws and regulations that can impact the employment opportunities for those with disabilities. 12
SECTION XI Data Collection and Analysis 41 CFR 60-741.44(k) The College will continue to develop those processes and systems that will allow for the tracking and reporting of applicants and those hired who identify with disabilities. The PeopleAdmin software is not designed to aggregates data in a meaningful way and only makes available (within a column) those who identify as having a disability. We continue to work on developing systems that replace the cumbersome manual data extraction required for the collection and analysis: The number of applicants who self-identified as individuals with disabilities; 140; The total number of job openings and jobs filled; job openings 209; jobs filled 162; The total number of applicants for all jobs; 6190; The number of individuals with disabilities hired; 03; The total number of applicants hired; 167 (157 staff and 10 faculty). The AA plan year summary data will be used as a comparison and analysis for the upcoming plan year. 13
SECTION XII Utilization Analysis 41 CFR 60-741.45 Using the job groups established for the utilization analysis under Executive Order 11246 (minorities and women), the College will conduct an annual analysis to compare the representation of individuals with disabilities to the 7% utilization goal established under Federal Regulation 41 CFR 60-741.45. In addition, the College will conduct an employee self-identification survey beginning in the 2015-2016 AA Program year. The survey will be conducted annually to establish an on-going representation of employees who self-identify as individuals with disabilities. 14
SECTION XIII Availability of AAP 41 CFR 60-741.41 The affirmative action program, absent the data metrics, shall be available for inspection to any employee or applicant for employment upon request. The location and hours during which the program may be available for review shall be posted in the Human Resource office, on the College s EEO intranet webpage; and on the College s applicant tracking system information page. 15
SECTION XV Invitation to Self-Identify as Disabled and to Request an Accommodation 41 CFR 60-741.23(c) Effective October 1, 2014, the College implemented the new Voluntary Self-Identification of Disability, form CC-305. This invitation to self-identify as disabled is offered to all applicants. The purpose of this invitation is to offer the applicant the opportunity to inform the College whether they believe Section 503 of the Rehabilitation Act of 1973 applies to them, and affords the applicant the opportunity to request a reasonable accommodation to participate in the application and/or interview process. The same invitation to self-identify is provided to all individuals following their acceptance of a job offer and before they begin work. The purpose of this invitation is to offer an opportunity to request a reasonable accommodation to perform the essential functions of the job. The College invited current employees to self-identify as individuals with disabilities in the Spring of 2016. During the upcoming AAP, the College will conduct additional Voluntary Self- Identification processes; inviting employees to update their disability status and request an accommodation that can support them in the performance of the essential functions of the job. 16