North Central Regional Mental Health Board (NCRMHB) and Way To Go CT is dedicated to a policy of non-discrimination in the conduct of its business, including its Title VI responsibilities. Way To Go recognizes its responsibilities to the communities in which it operates and to the society it serves. It is the NCRMHB and Way To Go CT’s policy to utilize its best efforts to assure that no person shall, on the grounds of race, color, or national origin, be excluded from participation in, be denied the benefits of, or be subjected to discrimination under its program of mobility management services and related benefits.

Title VI Plan Statement

Approved by Board September 25, 2013

I. Plan Statement

Title VI of the Civil Rights Act of 1964 prohibits discrimination on the basis of race, color, or national origin in programs and activities receiving Federal financial assistance. Specifically, Title VI provides that “no person in the United States shall, on the grounds of race, color, or national origin, be excluded from participation in, be denied the benefits of, or be subjected to discrimination under any program or activity receiving Federal assistance (42 U.S. C. Section 2000d).

The North Central Regional Mental Health Board (NCRMHB) is committed to ensuring that no person is excluded from participation in NCRMHB programs or activities on the basis of race, color, religion, sex, or national origin as protected by Title VI and Title VII of the Civil Rights Act 9f 1964.

Environmental Justice and Executive Orders 13166 and 12898 further amplify Title VI by requiring programs or activities receiving Federal assistance to identify and address disproportionately high and adverse human health or environmental effects of its programs, policies and activities on minority and low-income populations.

This plan was developed to guide the NCRMHB in its administration and management of Title VI-related activities

II. NCRMHB Affirmative Action Policy

It is the policy of the NCRMHB to offer equal employment and promotion opportunities to qualified applicants and employees without regard to race, color, religion, sex, age, marital or civil union status, national origin, ancestry, gender, sexual orientation, physical or psychiatric or substance abuse disability, or marital status

We believe NCRMHB Affirmative Action Policy (see Affirmative Action Policy attached Appendix A of the NCRMHB Personnel Policies) is consistent in all respects with the objectives of the Civil Rights Act of 1964 and all other federal and state regulations pertaining to equal employment opportunity.

The NCRMHB Executive Director is responsible for monitoring NCRMHB compliance with Title VI requirements. Any employee who is of the opinion that the policies, procedures and practices set for in NCRMHB Personnel Policies have been improperly or inequitably applied or who has other grievances against the Agency may seek redress through the grievance procedure delineated in pages 9-10 of the NCRMHB Personnel Policies.

III. Membership, Recruitment, and Public Involvement

NCRMHB was created by Connecticut Statue to ensure that citizens are involved in planning and monitoring the mental health services provided by the State of Connecticut. NCRMHB promotes the active participation of citizen volunteers in all aspects of behavioral health planning. Such activities are designed to increase sensitivity and awareness of the special needs and culture of persons with disabilities, low-income and minority groups and to encourage their participation in planning for services maximally responsive to their needs

According to Connecticut Statute each of the 37 towns in our service area is responsible for appointing a representative to the Catchment area council (CAC) for their area. NCRMHB provides town officials with templates for use in advertising the need for representatives in local papers if they are having difficulty identifying a representative. Town appointees are people who are living with a mental health or substance use disorder, their family members, or lay persons in the community concerned for them. Town appointees may elect service providers to work in partnership with them on the CAC. Each CAC may elect up to four representatives to sit on the Board of Directors. A large percentage of our members with behavioral health disorders are also living on very low incomes. Over 50% of our members are either individuals living with a behavioral health disorder or family members of someone living with a behavioral health disorder.

The NCRMHB Executive Director seeks out and invites membership though community leaders of various racial and ethnic groups in our region in order to promote membership that is reflective of the demographics of their communities. NCRMHB also seeks volunteers on-line through VolunteerMatch and participates in Greater Hartford Leadership Express Match sessions as needed to recruit members of racial and ethnic groups that are underrepresented.

NCRMHB also conducts annual surveys and focus groups in order to capture local and regional data and perspectives about needs and emerging trends. Input is gathered from DMHAS funded providers, town social services and community organizations that serve as referral agencies, people who use mental health services, their family members, and concerned citizens. The NCRMHB Executive Director seeks out and invites participation though community leaders of various disability organizations, senior centers, town social services offices, providers of transportation, behavioral health services, older adult services to identify most effective means to encourage the participation and garner the perspectives of persons with disabilities, including low-income and minority members of our target population. The results of these reviews are published annually on the NCRMHB website.

IV. Limited English Proficiency Plan

Language for individuals with Limited-English Proficiency (LEP) can be a barrier to accessing important benefits or services, understanding and exercising important rights, complying with applicable responsibilities, or understanding other information provided by federally funded programs and activities.

Title VI or the Civil Rights Act of 1964 requires entities that receive federal assistance to examine the services they provide, identify any need for services to those with limited English proficiency (LEP), and develop and implement a system to provide those services so LEP persons can have meaningful access to them.

NCRMHB will take all reasonable steps in compliance with Title VI of the Civil Rights Act of 1964 to ensure meaningful access to programs and activities provided by the Board to individuals with LEP, thereby preventing discrimination.

NCRMHB will provide language assistance in the following two methods: 1) oral interpretation whether in person or via telephone interpretation services; (2) and written translation. Oral interpretation can range from on-site interpreters for critical services to telephonic interpretation services. Written translation can range from translation of an entire document to translation of a short description of the document. NCRMHB notices of outreach or public events or availability of published resource materials will include a statement that persons with Limited English Proficiency may request language assistance. NCRMHB will determine which items or activities will be translated given regional demographics, requests received and resources available. These may include, but not be limited to: outreach presentations, public meetings and notices, brochures, resource guides, and in person call-center guidance.

V. Complaint Process and Procedures

The NCRMHB Executive Director is responsible for monitoring NCRMHB compliance with Title VI requirements. Any employee who is of the opinion that the policies, procedures and practices set for in NCRMHB Personnel Policies have been improperly or inequitably applied or who has other grievances against the Agency may seek redress through the grievance procedure delineated in pages 9-10 of the NCRMHB Personnel Policies.

Other individuals who are of the opinion that the policies set forth in this Title VI Plan have been improperly or inequitably applied may are encouraged to address their concerns promptly to the person whose conduct has offended them. Often this action alone will resolve the problem. NCRMHB recognizes, however, that an individual may prefer to pursue the matter through formal grievance procedures. As the NCRMHB designated Title VI Coordinator, the Executive Director is responsible to receive and act on these complaints. NCRMHB encourages the prompt reporting of complaints so that constructive action can be taken before relationships become irreparably strained. Complaints can be submitted verbally or in writing to the NCRMHB Executive Director. As soon as possible after the NCRMHB Executive Director will interview the complainant, interview appropriate other parties, examine relevant records and take any other action which will enable a full understanding of the issue.

The NCRMHB Executive Director will mediate, provide information and counseling or take other actions likely to assist the parties to resolve the issue through informal discussion. If the parties believe such a resolution is possible, the Executive Director will provide a written summary to the parties outlining the nature of the dispute and its recommended resolution.

If the complainant requests a formal decision or rejects a proposed resolution, the Executive Director will render a decision within 20 days and provide a written report to the complainant and the NCRMHB Board of Directors Chairperson. The complainant may file a written grievance with the Executive Committee of the NCRMHB Board of Directors. The Executive Committee will solicit written opinions from all parties in the dispute including the Executive Director. The Executive Committee will render a decision within 90 days and send it to the Board of Directors for further action.

In the alternative the complainant may contact William Pierce, Customer Rights and Grievance Specialist (860) 418-6933, william.pierce@ct.gov, to file a formal grievance with the Department of Mental Health and Addiction Services (DMHAS).