What is the Methods of Administration (MOA) Program?
- The purpose of the MOA program is to ensure students have equal access to Career and Technical Education (CTE) programs and activities regardless of race, color, national origin, sex, or disability.
- The Federal Department of Education Office for Civil Rights (OCR) oversees the civil rights compliance programs of 68 state agencies that administer the CTE MOA program at the secondary and post-secondary levels across the country.
- Compliance is monitored at a state level using a formal MOA compliance program led by the MOA Coordinator.
- Authority: OCR’s 1979 Vocational Education Guidelines (Appendix B to 34 CFR Parts 100 and 104 and Appendix A to 34 CFR Part 106).
Colorado CTE programs are administered by the State Board for Community Colleges and Occupational Education (SBCCOE), and by extension, the Colorado Community College System (CCCS). The MOA Coordinator is Becky Giacomelli, who has served in this position since December 2019. The position is integrated into the CCCS Internal Audit department and is overseen by David Summerlin, Senior Manager Internal Audit, and Danielle Bundy, Director of Internal Audit.
If you have recently been notified of a civil rights monitoring review, and you have questions, please contact us.
Why are we being reviewed?
Subrecipients (School or campus) operating an approved CTE Program that receives federal Department of Education funding are eligible for a review. Subrecipients are not selected because of any complaint or concerns, but rather a documented risk assessment is performed to determine which entity to select for a review. Our selection process takes several factors into consideration, including, but not limited to:
- Demographic data
- CTE Enrollment data
- Total headcount
- Age of facilities
- Date of last MOA review
What happens after we receive the notification??
Start gathering the requested materials (MOA info request doc) and information (Self-Assessment doc).
Information can be provided as hard copy, or sent electronically via email or file share. If there is Personally Identifiable Information (PII) included in anything you send, please ensure that it is properly redacted to protect the privacy of the students and staff. If you have any questions about what to send, please contact us.
We will contact you to schedule the review. Types of reviews may include: -A full scope review -A targeted review -A technical assistance review
If the review includes an on-site facilities visit, blueprints are required to confirm dates of construction and any alterations. Additionally, a representative will be needed to escort the MOA Coordinator.
Interviews will be scheduled with relevant personnel to obtain an understanding of processes for complying with civil rights laws.
A Letter of Findings (LOF) will report the results of the review within 60 days of the onsite visit and/or interviews.
The LOF will identify what was reviewed and any findings of non-compliance; including the criteria for compliance and any corrective action that is required. We will schedule an exit conference to discuss the LOF and answer any questions you have.
The Subrecipient will develop a Voluntary Compliance Plan (VCP)
As a result of the review, the subrecipient must document how it will remedy findings of non-compliance in a VCP. We will work with you to develop a Voluntary Compliance Plan (VCP) which will outline specifically how compliance will be achieved and a completion timeline for each item in the LOF.
We will follow up on the VCP Once the VCP is approved, follow up will be conducted upon completion. This will be done by the MOA Coordinator, who will also provide technical assistance as needed to ensure compliance is achieved.