Title VI Complaint Process
The City of Edmond uses the following, detailed internal procedures for prompt processing and resolution of all Title VI complaints received directly by any of its departments having responsibilities under the Title VI and the related Nondiscrimination statutes. These procedures include but are not limited to:
1. Any person, group of persons, or entity that believes they have been subjected to discrimination under Title VI of the Civil Rights Act may file a written complaint with the Title VI Coordinator. A complaint may also be filed by a representative on behalf of such a person.
2. In order to have the complaint considered under this procedure, the complaint must be filed no later than 180 calendar days after:
- The date of the alleged act of discrimination; or
- Where there has been a continuing course of conduct, the date on which that conduct was discontinued.
3. Complaints shall be filed using the City’s Title VI Complaint Form (available at edmondok.com/CivilRights, or by contacting the City of Edmond Planning Office). Complaints shall set forth, as fully as possible, the facts and circumstances surrounding the claimed discrimination. In the event that a person makes a verbal complaint of discrimination to an officer or employee of the recipient, the person shall be interviewed by the Coordinator. If necessary, the staff coordinator will assist the person in reducing the complaint to writing and submit the written version of the complaint to the person for signature. The complaint shall then be handled in the usual manner.
4. Upon receipt of the signed complaint form, the Title VI Coordinator will log-in the complaint, determine the basis of the complaint, authority/jurisdiction, and who should conduct the investigation.
5. The Title VI Coordinator reviews and determines the appropriate action regarding every Title VI complaint. The City will not proceed with or continue a complaint investigation if:
- The complaint is, on its face, without merit.
- The same allegations and issues of the complaint have been addressed in a recently closed investigation or by previous federal court decisions.
- The complainant’s or injured party’s refusal to cooperate (including refusal to give permission to disclose his or her identify) has made it impossible to investigate further.
6. The Title VI Coordinator will investigate the complaint and log the following information within ten (10) calendar days of receipt of the allegation(s):
- Name, address, and phone number of the complainant.
- Email address if available.
- Basis of complaint (i.e., race, color, national origin, sex, age, religion, disability/handicap, income).
- Date of the alleged discriminatory act(s).
- Date of complaint received by the recipient.
- A statement of the complaint.
- Other agencies (state, local or Federal) where the complaint has been filed.
- An explanation of the actions the recipient has taken or proposed to resolve the issue(s) raised in the complaint.
7. Within ten (10) business days, the Title VI Coordinator will acknowledge receipt of the allegation, inform the complainant of action taken or proposed action to be taken to process the allegation(s). The notification letter shall contain(s):
- The basis of the complaint.
- A brief statement of the allegation(s) over which the City has jurisdiction.
- A brief statement of the City’s jurisdiction over the recipient to investigate the complaint; and
- An indication of when the parties will be contacted.
8. If the complaint is against a contractor or sub recipient(s), the City will have (15) business days from the receipt of the complaint to advise the appropriate state or federal agency (e.g., ODOT for transportation related projects) of the receipt of a complaint, and the status of the investigation.
9. The Title VI Coordinator will work with appropriate parties to conduct an in-depth, personal interview with the complainant(s). Information gathered in this interview includes: identification of each complainant by race, color, sex, age, religion, national origin, disability/handicap, or income status; name of the complainant; a complete statement concerning the nature of the complaint, including names, places, and incidents involved in the complaint; the date the complaint was filed; and any other pertinent information the investigation team feels is relevant to the complaint. The interviews are recorded either on audio tape or by taking notes. Every effort will be made to obtain early resolution of complaints at the lowest possible level.
10. Within (15) business days of receiving comments from the federal or state agency, the Title VI Coordinator will meet with all parties to the complaint to discuss the comments received by the federal or state agency.
11. Within sixty (60) calendar days from the date the original complaint was received, the Title VI Coordinator will coordinate the preparation of a written investigative report. The investigative report shall include a narrative description of the incident, identification of persons interviewed, findings, and recommendations for disposition. The written report shall be reviewed and finalized by the Title VI Coordinator and sent to the City Attorney.
12. The City Attorney will review the investigative report and meet with the Title VI Coordinator and City Manager to determine the appropriate action. Within ninety (90) calendar days of receipt of the complaint, the Title VI Coordinator will issue a “Letter of Findings” to the complainant.
13. If the complaint cannot be resolved by the Department to the satisfaction of all parties concerned, the party not satisfied is advised of his or her right to appeal pursuant to Title 49, Code of Federal Regulations, Part 21. The appeal must be filed, in writing no later than (180) calendar days after the date of the alleged discrimination, unless the time for filing is extended by the Secretary to:
Office of Civil Rights
1200 New Jersey Avenue, SE
8th Floor E81-314
Washington, DC 20590
A complaint may be filed with the Secretary; U.S. Department of Transportation, before, during, or after the complaint has been filed with the City of Edmond.