Inland Valley Recovery Services
Title VI Program
Healing families and the community since 1962
TITLE VI PROGRAM
Developed and Approved by
IVRS’ Board of Directors
April 28, 2016
IVRS’ Administrative Offices
1260 E. Arrow Hwy.
Upland, CA 91786
(909) 932-1069
www.inlandvalleyrecovery.org
Inland Valley Recovery Services
Title VI Program
Introduction
This document was prepared by Inland Valley Recovery Services (IVRS) and approved by
its Board of Directors to comply with Title VI of the Civil Rights Act of 1964, including new
provisions detailed in U.S. Department of Transportation’s FTA Circular 4702.1B, “Title VI
Requirement and Guidelines for Federal Transit Administration Recipients.”
Table of Contents
Title VI Notice to the Public
2
Title VI Notice to the Public – Spanish
3
List of Locations Where Title VI Notice is Posted
4
Title VI Complaint Procedures
5
Title VI Complaint Procedures – Spanish
6
Title VI Complaint Form
7
Title VI Complaint Form – Spanish
9
List of Transit-related Title VI
Investigations, Complaints and Lawsuits
11
Public Participation Plan
12
Summary of Outreach Efforts
12
Strategies to engage Minority and LEP Populations
in the Public Participation Process
14
Language Assistance Plan / Table of Contents
15
Membership of Non-elected Committees and Councils
23
Title VI Equity Analysis
23
Board of Directors Approval
24
♦♦♦
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Inland Valley Recovery Services
Title VI Program
Title VI Notice to the Public
• IVRS operates its programs and services without regard to race, color, and national origin
in accordance with Title VI of the Civil Rights Act. Any person who believes he or she has
been aggrieved by any unlawful discriminatory practice under Title VI may file a complaint
with IVRS.
• For more information on IVRS’ civil rights program, and procedures to file a complaint,
contact 909-932-1069; email [email protected]; or visit our administrative offices at
1260 E. Arrow Hwy, Upland, CA 91786.
For more information visit www.inlandvalleyrecovery.org
• A complainant may file a complaint directly with the Federal Transit Administration by
filing a complaint with the Office of Civil Rights, Attention: Title VI Program Coordinator,
East Building, 5th Floor-TCR, 1200 New Jersey Ave., SE, Washington, DC 20590.
• If information is needed in another language, contact our administrative offices at (909)
932-1069.
• Si necesita informacion en otro lenguaje, llame a las oficina administrative al (909) 9321069.
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Inland Valley Recovery Services
Title VI Program
Título VI aviso al público
• IVRS opera sus programas y servicios sin importar raza, color y origen nacional según el
título VI de la ley de derechos civiles. Cualquier persona que cree que él o ella ha sido
agraviada por cualquier práctica discriminatoria ilegal bajo el título VI puede presentar una
queja con IVRS.
• Para obtener más información sobre los derechos civiles programa de IVRS y
procedimientos para presentar una queja, póngase en contacto con 909-932-1069; correo
electrónico [email protected]; o visite nuestras oficinas administrativas en 1260 E.
Arrow Hwy, Upland, CA 91786.
Para más información visite www.inlandvalleyrecovery.
• Un demandante puede presentar una queja directamente con la administración de
tránsito Federal para archivar una queja con la oficina de derechos civiles, atención:
Coordinador del programa Título VI, edificio Oriente, piso 5 º-TCR, 1200 New Jersey Ave.,
SE, Washington, DC 20590.
• Si necesita información en otro idioma, comuníquese con nuestras oficinas
administrativas en (909) 932-1069.
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Inland Valley Recovery Services
Title VI Program
List of Locations Where Title VI Notice Is Posted
IVRS’ Title VI notice to the public is currently posted at the following locations:
Location Name
Address
City
Women’s Residential
1260 E. Arrow Hwy #C
Upland
Men’s Residential
1260 E. Arrow Hwy #B
Upland
Administrative Offices
1260 E. Arrow Hwy #E
Upland
Upland Recovery Center
934 N. Mountain Ave. #A&B
Upland
San Bernardino
Recovery Center
939 N. D Street
San Bernardino
**Notice to the Public is also posted on IVRS website at www.inlandvalleyrecovery.org
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Inland Valley Recovery Services
Title VI Program
Title VI Complaint Procedures
Any person who believes he or she has been discriminated against on the basis of race,
color or national origin by IVRS may file a Title VI complaint by completing and submitting
the Title VI Complaint Form. IVRS investigates complaints received no more than 180 days
after the alleged incident. IVRS will only process complaints that are complete. The
following procedures will be followed to investigate formal Title VI complaints:







Within 10 business days of receiving the complaint, IVRS Title VI Program
Administrator will review it to determine if our office has jurisdiction. The complainant
will receive an acknowledgement letter informing her/him whether the complaint will
be investigated by our office.
The investigation will be conducted and completed within 30 days of receipt of the
formal complaint. The complainant will be notified in writing of the cause to any
planned extension to the 30-day rule.
If more information is needed to resolve the case, IVRS may contact the complainant.
The complainant has 10 business days from the date of the letter to send requested
information to the Title VI Administrator. If the Administrator is not contacted by the
complainant or does not receive the additional information within 10 business days,
IVRS can administratively close the case.
A case can also be administratively closed if the complainant no longer wishes to
pursue their case.
Following the investigation, the Title VI Administrator will issue one of two letters to
the complainant: 1) a closure letter or 2) a letter of finding (LOF). A closure letter
summarizes the allegations and states that there was not a Title VI violation and that
the case will be closed. A LOF summarizes the allegations and the interviews regarding
the alleged incident, and explains whether any disciplinary action, additional training of
the staff member or other action will occur.
If the complainant is unsatisfied with the decision, she/he has 30 days after the date of
IVRS closure letter or the LOF to appeal to the IVRS Board or its designee. The
complainant is entitled to review the denial, to present additional information and
arguments, and separation of functions (i.e. a decision by a person not involved with the
initial decision). The complainant is entitled to receive written notification of the
decision of the appeal and the reasons for it.
The complainant may also file a complaint directly with the Federal Transit
Administration, as follows: Title VI Program Coordinator, FTA Office of Civil Rights, East
Building, 5th Floor - TCR, 1200 New Jersey Ave., S.E., Washington, D.C. 20590
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Inland Valley Recovery Services
Title VI Program
Procedimientos de Quejas del Título VI
Cualquier persona que cree o que ha sido objeto de discriminación por motivos de raza,
color u origen nacional por IVRS puede presentar una queja del Título VI, completando el
Formulario de Queja del Título VI de IVRS. IVRS investigara las quejas recibidas no más de
180 días después del supuesto incidente. IVRS sólo procesará las denuncias que sean
completas. Los siguientes procedimientos serán seguidos para investigar las quejas
formales del Título VI:







Dentro de los 10 días hábiles de haber recibido la queja, el administrador de Title VI de
IVRS la revisará para determinar si nuestra oficina tiene jurisdicción. El autor recibirá
un acuse de recibo informando a él / ella si la queja será investigada por nuestra oficina.
Se llevó a cabo la investigación y se terminó dentro de los 30 días siguientes a la
recepción de la queja formal. El denunciante será notificado por escrito de la causa a
cualquier ampliación prevista de la norma de los 30 días.
Si se necesita más información para resolver el caso, IVRS puede ponerse en contacto
con el demandante. El demandante tiene 10 días hábiles desde la fecha de la carta para
enviar la información solicitada al administrador de Title VI. Si el administrador no está
en contacto con el reclamante o no recibe la información adicional dentro de los 10 días
hábiles, IVRS administrativamente puede cerrar el caso.
El denunciante será notificado por escrito de la causa a cualquier ampliación prevista
de la norma de los 30 días.
Un caso también puede ser cerrado administrativamente si el autor ya no desea seguir
su caso. Tras la investigación, el administrador de Title VI emitirá una de las dos cartas
a la demandante: 1) una carta de cierre o 2) una carta de encontrar. En una carta de
cierre se resume las alegaciones y afirma que no había una violación del Título VI, y que
el caso se cerrará. En carta de encontrar resume los hechos denunciados y de las
entrevistas sobre el supuesto incidente, y explica si alguna acción disciplinaria, se
producirá la formación adicional del miembro del personal, u otra acción.
Si el demandante no está satisfecho con la decisión, él / ella tiene 30 días después de la
fecha de la carta de cierre de IVRS o carta de encontrar para apelar a la junta directiva
de IVRS o el personal autorizado. El demandante tiene derecho a revisar la negación,
para presentar información y argumentos adicionales, y para la separación de funciones
(es decir, una decisión de una persona no involucrada con la decisión inicial). El
demandante tiene derecho a recibir una notificación por escrito de la decisión de la
apelación y las razones para ello.
El demandante también puede presentar una queja directamente con la Administración
Federal de Tránsito, de la siguiente manera : Coordinador del Título VI del Programa ,
FTA Oficina de Derechos Civiles, Edificio Este , 5 º piso - TCR , 1200 New Jersey Ave, SE,
Washington, DC 20590.
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Inland Valley Recovery Services
Title VI Program
Title VI Transportation Complaint Form
Section I: Please write legibly
1. Name:
2. Address:
3. Telephone:
3.a. Secondary Phone (Optional):
4. Email Address:
5. Accessible Format
Requirements?
[ ] Large Print
[ ] TDD
[ ] Audio Tape
[ ] Other
Section II:
6. Are you filing this complaint on your own behalf?
YES*
NO
*If you answered “yes” to #6, go to Section III.
7. If you answered “no” to #6, what is the name of the person for whom you are filing this complaint?
Name:
8. What is your relationship with this individual:
9. Please explain why you are filing for a third party:
10. Please confirm that you have obtained permission of
the aggrieved party to file on their behalf.
YES
Section III:
11. I believe the discrimination I experienced was based on (check all that apply):
[ ] Race
[ ] Color
[ ] National Origin
12. Date of alleged discrimination:
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NO
Inland Valley Recovery Services
Title VI Program
13. Explain as clearly as possible what happened and why you believe you were discriminated against.
Describe all persons who were involved. Include the name and contact information of the person(s)
who discriminated against you (if known), as well as names and contact information of any witnesses.
If more space is needed, please use the back of this form.
Title VI Transportation Complaint Form – Pg 2
Section IV:
14. Have you previously filed a Title VI complaint with
IVRS?
YES
NO
Section V:
15. Have you filed this complaint with any other Federal, State, or local agency, or with any
Federal or State court?
[ ] YES*
[ ] NO
If yes, check all that apply:
[ ] Federal Agency __________________________
[ ] State Agency __________________
[ ] Federal Court ___________________________
[ ] Local Agency __________________
[ ] State Court ______________________________
16. If you answered “yes” to #15, provide information about a contact person at the
agency/court where the complaint was filed.
Name:
Title:
Agency:
Address:
Telephone:
Email:
Section VI:
Name of Transit Agency complaint is against:
Contact Person:
Telephone:
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Inland Valley Recovery Services
Title VI Program
You may attach any written materials or other information that you think is relevant to
your complaint.
Signature and date are required below to complete form:
Signature_____________________________________
Date________________
Please submit this form in person or mail this form to the address below:
Titulo VI Forma de Quejas
Seccion I: Por favor escriba legiblemente
1. Nombre:
2. Direction:
3.a. Segundo Telefono (Opcional):
3. Telefono:
4. Correo Electronico:
5. Requisitos de
formato accesible ?
[ ] Lectura Grande
[ ] TDD
[ ] Audio
[ ] Otro
Seccion II:
6. Está presentando esta denuncia en su nombre ?
SI*
NO
* Si usted contestó "sí" al #6, ir a la sección III .
7. Si usted contestó "no" al #6, cuál es el nombre de la persona para quien usted está presentando esta
denuncia ? Nombre:
8. Cuál es su relación con este individuo :
9. Por favor explique por qué está presentando para un tercero :
10. Por favor confirme que usted ha obtenido el permiso
de la parte agraviada en su nombre el archivo .
SI
NO
Seccion III:
11. Creo que la discriminación que viví fue basada en (marque los que correspondan ):
[ ] Raza
[ ] Color
[ ] Origen nacional
12. Fecha de la supuesta discriminación :
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Inland Valley Recovery Services
Title VI Program
Titulo VI Forma de Quejas de Transporte– Pagina
2
Seccion IV:
14. Han presentado anteriormente una queja del
título VI con IVRS ?
SI
NO
Seccion V:
15. A presentado esta queja con cualquier otro Federal, estado o agencia local o con cualquier
Tribunal Federal o estatal ?
[ ] SI*
[ ] NO
Si usted contestó "sí" , marque todas las que aplican :
[ ] Agencia Federal _______________________
[ ] Corte Federal ___________________________
[ ] La Agencia Estatal __________________
[ ] Agencia Local __________________
[ ] Corte Estatal ______________________________
16. Si respondiste "sí" a #15, proporcionar información sobre una persona de contacto en la
Agencia/tribunal donde se presentó la queja .
Nombre:
Titulo:
Agencia:
Direccion:
Telefono:
Correo electronico:
Seccion VI:
Nombre de la Agencia de tránsito que esta denunciando?:
Persona de contacto :
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Inland Valley Recovery Services
Title VI Program
Telefono:
Usted puede adjuntar cualquier material escrito u otra información que crees que es
relevante para su queja.
Firma y fecha son requeridos para completar el formulario:
Firma_____________________________________
Fecha________________
Por favor, envíe este formulario en persona o por correo este formulario a la siguiente
dirección:
List of Transit-Related Title VI Investigations, Complaints, and
Lawsuits –
IVRS has not been involved in any transportation-related Title VI investigations,
lawsuits or complaints.
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Inland Valley Recovery Services
Title VI Program
Public Participation Plan
About IVRS
Inland Valley Recovery Services is a 501(c)3 nonprofit corporation that has been providing
substance abuse recovery and counseling services since 1962. During the past 50+ years,
IVRS has grown into a continuum of care network offering an array of substance abuse
services including detoxification, residential and outpatient treatment, aftercare, substance
abuse prevention & education, and transitional living, along with specialized services for
families and significant others of program participants.
IVRS offers a combination of counseling, education and introduction to the 12-step
recovery process in its treatment programs. It is important for our program participants to
establish a foundation within the 12-step community for long-term sobriety.
IVRS’ Mission is to “Break the Cycle of Addiction and Mend the Lives of Those suffering
from Behavioral Health Conditions”.
IVRS provides detoxification and residential services at its state-of-the-art residential
campus that serves 130 adult men and women and up to 30 children. Program participants
are permitted to have up to two (2) children reside with them while in treatment. The
administration building houses IVRS executive offices and admissions dept.
In addition, IVRS’ operates two Social Service Recovery Centers. They serve as safe alcoholand drug free places for recovering individuals to spend time, attend meetings, and
participate in social activities daily.
IVRS programs are licensed and certified by the State of California Department of Health
Care Services and accredited by CARF, the Commission on Accreditation of Rehabilitation
Facilities. Annually, IVRS serves in excess of 18,000 individuals through a variety of
substance abuse recovery, treatment and prevention services.
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Inland Valley Recovery Services
Title VI Program
Summary of Outreach Efforts
The following is a summary of outreach efforts conducted by IVRS as they relate to Title VI
requirements under the Public Participation Plan. Many of our activities are conducted in
partnership or ad hoc outreach with other service organizations and non-profit agencies
within the community. This is in no way a complete list but rather documents the agency’s
outreach efforts as they relate specifically to minority and low-income populations.
● Marketing and Outreach
The agency also maintains a Marketing and Outreach Committee that meets on a
quarterly basis and sets marketing and outreach goals. Various outreach activities are
conducted throughout the year including public engagements, provider fairs, 12 step
events, and newsletters.
● IVRS Website
Currently, IVRS posts notices and announcements on the agency's website. Additional
public input can be obtained by the Title VI Complaint Form, which is available as a
download in English and Spanish.
● Outreach Specialists
IVRS’ employs outreach specialists that provide intensive substance use screening and
treatment to parents receiving or eligible for public benefits assistance. IVRS skilled
case managers work in collaboration with the local San Bernardino County Transitional
Assistance Department (TAD) Office to provide substance use treatment, crisis
intervention, advocacy, and linkages necessary to help parents on to the road to
recovery. Services are designed to alleviate alcohol and drug use; which hampers
lifestyles, relationships and efforts to find or keep employment.
● Annual Recovery Happens events
IVRS participates in both San Bernardino County and Riverside County Annual
Recovery Happens events. Recovery Happens is a national observance—celebrated
annually throughout the month of September—and promotes the messages that
prevention works; treatment is effective, and that recovery in all its forms is possible. It
also encourages individuals to take action to help expand and improve the availability
of effective recovery services for those in need. These are alcohol-free, family-friendly
events that are no cost to attend and open to the public. These events consist of live
music, brief speeches by prominent members of the community, a children’s area with
games and attractions, information/resource booths and other interactive activities.
IVRS also provides transportation to other agencies in need – to Recovery Happens and
other community events.
● Concert Under the Stars
The Hafif Family Foundation of Claremont sponsors this annual fundraising event: a live
concert and catered dinner in a beautiful, wooded, 150-acre outdoor setting in the
foothills above La Verne. The purpose is to provide a venue for several non-profit
organizations to earn donations for their groups by selling tickets to the events. The
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Inland Valley Recovery Services
Title VI Program
Foundation covers all the costs of food, entertainment, and service so that 100% of the
proceeds go to the non-profit groups selling tickets. IVRS provides transportation to
and from this event.
● Steven’s Hope Run for a Child
The Run for a Child is an annual fundraising event held by Steven's Hope for Children, a
501(c)(3) non-profit organization.
The Run usually offers offers a 10 K, a 5 K
walk/run and a 1 Mile Fun Run. Steven’s Hope for Children provides families of
seriously ill or injured children with housing, emotional support, and other essential
needs during and after the child's treatment. Through the generous support of event
sponsors, volunteers and participants the Run for a Child helps to build relationships
that will last a lifetime, impact families and save the lives of seriously ill or injured
children.
● Upland Foothill Kiwanis Service Organization
Some IVRS staff and board members are members of the Upland Foothill Kiwanis,
which serves minority populations in many ways – including IVRS clientele. IVRS
shares a wonderful kinship with the Kiwanis who hold their annual Christmas breakfast
at IVRS’ residential campus. They donate time, money and other resources to IVRS and
its clients all year long.
● Transportation to and from program services
IVRS provides daily transportation to and from outpatient program services for clients,
children, and adolescents in need, who are participating in IVRS’ outpatient perinatal,
day treatment and adolescent programs. These clients are in need of outpatient alcohol
and drug free treatment and related services, however, lack the transportation
necessary to access the services.
Strategies to engage Minority and LEP Populations in the Public Participation
Process:
●
IVRS’ printed material is printed in English and Spanish. We will continue to
monitor the language proficiency composition of persons served and make
adjustments as necessary.
●
Event information on IVRS’ website is posted in English, with Spanish translation
option available.
●
IVRS’ distributes, and will continue to distribute event information to community
groups and other agencies that serve LEP populations.
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Inland Valley Recovery Services
Title VI Program
●
IVRS’ continues to cultivate relationships with other community agencies that serve
LEP populations.
●
Public outreach events include, but are not limited to attending already existing
community meetings and gatherings, such as resource fairs, faith-based events, and
other community activities in order to invite participation from LEP populations
who may not otherwise attend IVRS-hosted events.
Currently, the Spanish-speaking population is the only population within IVRS’ service area
that is limited English proficient and that utilizes IVRS’ services. IVRS will continue assessing
the language needs of citizens in its service area through its Language Assistance Plan. At such
time, as another group with limited English proficiency reaches significant mass, IVRS will
review this plan and its strategies to engage with non-English speaking populations.
Language Assistance Plan
Table of Contents
Overview
15
Purpose of Language Assistance Plan
16
Overview of Service Area
17
Language Assistance Goals
17
Results of Four Factor Analysis
17
Factor 1
17
Factor 2
19
Factor 3
19
Factor 4
19
Conclusion
20
Language Assistance Implementation Plan
20
Identifying Limited English Proficiency Individuals
20
Providing Services
21
Communicating Availability of Language Assistance
21
Monitoring
21
Employee Training
21
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Inland Valley Recovery Services
Title VI Program
Overview
The first section in this document describes the purpose of the Language
Assistance Plan (LAP). The second section in this document provides the four-factor
Limited English Proficient (LEP) analysis (as outlined by the Department of
Transportation (DOT) used to identify LEP needs and assistance measures. The four-factor
LEP analysis includes:
● Factor 1: The number or proportion of LEP persons in the service area who may be
served or are likely to encounter IVRS, activities, or services.
● Factor 2: The frequency with which LEP persons come in contact with IVRS
programs, activities or services.
● Factor 3: The nature and importance of programs, activities or services provided by
IVRS to the LEP population.
● Factor 4: The resources available to IVRS and the overall cost to provide LEP
assistance.
The third and final section discusses the implementation of the Language
Assistance Plan, which includes methodologies for identifying LEP individuals, providing
services, establishing policies, monitoring the LAP, and recommendations for future LAP
implementations.
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Inland Valley Recovery Services
Title VI Program
Purpose of the Language Assistance Plan
This language Assistance Plan was developed during the process of preparing IVRS’ Title VI
Program to ensure that the service provided by IVRS is accessible to limited English
Proficient (LEP) individuals. Title VI of the 1964 Civil Right Act is one of two federal
mandates that guarantee the provision of meaningful access to federally-funded services
for LEP individuals:

Title VI of the 1964 Civil Right Act prohibits federally-funded agencies from
discriminating against individuals based on race, color, and national origin and
includes meaningful access to LEP customers.

President's Executive Order 13166, "improving Access to Services for Persons with
Limited English Proficiency" (August 11, 2000) : Instructs federal agencies to
improve access to services by mandating that any federally conduced or assisted
programs of activities (e.g. recipients of federal funding) must provide meaningful
access to LEP customers.

Safe Harbor Provision- The Federal Transit Authority Circular 4702.1B states:
“DOT has adopted DOJ’s Safe Harbor Provision, which outlines circumstances that can provide
a “safe harbor” for recipients regarding translation of written materials for LEP population.
The Safe Harbor Provision stipulates that, if a recipient provides written translation of vital
documents for each eligible LEP language group that constitutes five percent (5%) or 1,000
persons, whichever is less, of the total population of persons eligible to be served or likely to be
affected of encountered, then such action will be considered strong evidence of compliance with
the recipient’s written translation obligations. Translation of non-vital documents, if needed,
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Inland Valley Recovery Services
Title VI Program
can be provided orally. If there are fewer than 50 persons in a language group that reaches the
five percent (5%) trigger, the recipient is not required to translate vital written materials but
should provide written notice in the primary language of the LEP language group of the right
to receive competent oral interpretation of those written materials, free of cost.
These safe harbor provisions apply to the translation of written documents only. They do not
affect the requirements to provide meaningful access to LEP individuals through competent
oral interpreters where oral language services are needed and are reasonable. A recipient may
determine, based on the Four Factor Analysis, that even though a language group meets the
threshold specified by the Safe Harbor Provision, written translation may not be an effective
means to provide language assistance measures. For example, a recipient may determine that a
large number of persons in that language group have low literacy skills in their native
language and therefore require oral interpretation. In such cases, background documentation
regarding the determination shall be provided to FTA in the Title VI program.
IVRS’ Title VI Program was prepared in the spring of 2016 in accordance with FTA Circular
4702.1B, Title VI Requirements and Guidelines for Federal Transit Administration
Recipients, October 1, 2012.
IVRS’ Title VI Program Administrator is:
Stacy Blackstone, CEO
1260 E. Arrow Highway
Upland, CA 91786
Email – [email protected]
More information about IVRS’ Title VI Program
is available at: www.inlandvalleyrecovery.org
2. Overview of IVRS’ Service Area
IVRS serves the East Valley and Western Regions of San Bernardino County of California
with facilities located in the Cities of Upland and San Bernardino.
IVRS holds a unique position in regard to meeting the Title VI requirements. As a subrecipient of FTA 5310 Grant funding, the agency's focus is primarily to transport adults and
children within its programs and the community where current public transit options are
insufficient or do not exist. IVRS is headquartered in Upland, CA and provides services to a
majority of minorities and limited English proficient individuals, especially at its San
Bernardino location.
3. Language Assistance Goals
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Inland Valley Recovery Services
Title VI Program
IVRS’ goal is to provide meaningful access to LEP customers of IVRS information and
materials by developing a Language Assistance Plan and by periodic evaluation of the
developed methods and strategies.
4. Results of the Four Factor Analysis
Factor 1:
The number or proportion of LEP persons eligible to be served
or likely to be encountered by the program or recipient.
The results of the analysis are shown on the following page.
The results of the analysis are shown here.
Source: U.S. Census Bureau and Community Survey
IVRS used available census data to determine and identify LEP populations within its
service areas. IVRS utilized the American Community Survey to identify languages other
than English spoken by individuals within the areas. Based on our analysis we found 4
language groups with populations of LEP individuals greater than the Safe Harbor
Provision level of over 5% or 1000 individuals (whichever is less).
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Inland Valley Recovery Services
Title VI Program
After considering the percentages and the low frequency in which other-than-Spanish-LEP
individuals
come
in
Language
Estimate
#
of
Estimate
#
of
Total
contact
with IVRS,
individuals
individuals that
in San
along with
other
that speak
speak English
Bernardino and
Spanish
Margin of Error
Tagalog
Margin of Error
Vietnamese
Margin of Error
Chinese
Margin of Error
English less
than “very
well” in
San
Bernardino
35,729
less than
“very well” in
Upland
Upland
5151
40,880
206
1133
431
1240
1006
1578
+/- 1573
+/- 587
927
+/- 300
+/- 76
809
+/- 246
+/- 228
572
+/- 165
+/- 274
characteristics about LEPs identified throughout the Four Factor Analysis, IVRS will not
immediately translate vital documents into languages other than Spanish. IVRS will
continue to monitor proportions of LEP individuals among these groups and make any
revisions to this policy if any other LEP populations reach a critical threshold. The
frequency in which LEP persons have traditionally and currently contact IVRS is explained
in Factor 2: The frequency with which LEP persons come into contact with the program.
Factor 2: The frequency with which LEP persons come into
contact with the program.
A survey of IVRS’ contracted interpreter services usage reports indicated calls from LEP
persons who require interpreter services constitute less than 1% of our total yearly calls.
Though there may be some months where no calls requiring interpreter service are received,
when we do; these calls are made primarily by Spanish speakers. This shows that LEP callers
do not access our services with a frequency enough to warrant having any of IVRS’ information
translated into a language other than Spanish.
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Spanish speaking individuals have accessed IVRS less than 1% of the total calls received. Other
LEP individuals have not accessed the IVRS service. No LEP callers have accessed IVRS services
other than Spanish. Spanish-speaking calls are successfully completed due to the fact that IVRS
maintains a minimum of Bi-lingual Spanish staff at any given time, which virtually eliminates
need for translation services for our Spanish speaking callers. This demonstrates that LEP
populations DO NOT frequently access our services. At this time we are only translating IVRS
outreach and primary treatment program materials in English/Spanish and will continue to
monitor contact with the agency by other LEP individuals.
Factor 3: The nature and importance of the program, activity, or
service provided by the program to people’s lives.
Regardless of the language our callers speak, their needs seem to be the same across the
board. When callers reach to IVRS for services and information, typically they are in a crisis
situation, in which they have never been in the past. Most callers have never needed
assistance from anyone, and hardship circumstances have placed them in foreign life
circumstances. The importance of IVRS’ services is illustrated by the positive impact we
have on individuals, families and the community.
Factor 4:
The resources available to the recipient for LEP
outreach, as well as the costs associated with that
outreach.
In IVRS’ Public Participation Plan, we laid out the types of outreach activities we undertake.
A large portion of outreach is accomplished through cultivating relationships with key
contacts who also serve the LEP populations of San Bernardino County such as
transportation providers and community resources such as health and human service
providers both in the government and nonprofit sectors. IVRS will keep this network of
contacts informed of activities, services and events. IVRS’ collaborative work with these
other agencies provides additional ways to get our services and information to our LEP
populations. Use of this network is a key element in IVRS’ outreach strategy and has little
or no associated costs.
IVRS provides its brochure in English and Spanish utilizing bilingual and biliterate Spanish
personnel.
 Currently, a minimum of 30% of our staff are fluent in both English and Spanish,
 Translator service is paid for by IVRS when deemed necessary.
 IVRS website is www.inlandvalleyrecovery.org.
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 IVRS also has a Facebook page.
Conclusion
Based on this information IVRS serves many Spanish speaking transit dependent
individuals who do not posses their own mode of transportation. For this reason IVRS is
committed to providing informational material in Spanish as well as English relating to its
services. Vital documents are those that demonstrate how to use services, how to access
services and additional information. All the necessary information about our services is
equally accessible through a phone call to our agency or by visiting our website.
Language Assistance Implementation Plan
Methodologies
Identifying LEP Individuals
As evidenced by the Four Factor Analysis, very few "true" LEP individuals are
referred to IVRS. The predominant minority language in the region is Spanish.
While there is a substantial minority population in the region, the agency has
systems in place to provide access to minority populations.
Providing Services
While the agency does not currently have an on-going need for professional
translation services, on-site agency staff that are fluent in Spanish provide translation
services at all facilities as needed. Documents that are offered in Spanish include:





Title VI Notice to the Public
Title VI Complaint Form
Title VI Complaint Procedures
Consumer Program Handbook including IVRS Grievance Policy
Agency website Title VI information
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Other documents can be translated to Spanish orally as appropriate. Due to the low
literacy rate of consumers at IVRS, most documents are translated orally.
Communicating Availability of Language Assistance
Individuals, who are referred to IVRS for services live in a facility run by a Program
Coordinator, assigned a primary Counselor who provides one-on-one guidance and
program planning. Program Coordinators can arrange for Spanish translation services as
needed. Agency reception staff can also offer translation services to clients and family
members as appropriate.
Monitoring
IVRS maintains an Agency Accessibility Plan which is designed to minimize barriers
that are created by architectural factors, environmental factors, attitudinal factors, financial
and employment barriers and communication barriers such as language. This plan is
reviewed and updated quarterly (and/or at a minimum every 3 years).
IVRS’s Quarterly Quality Assurance Reports are analyzed for trends and patterns
that indicate a need for additional services. These reports include ethnicity and can be used
as a guide to determine the need for additional translation services.
Employee Training
IVRS conducts monthly In-Service training for staff on a variety of topics. Effective
ways to communicate with clients who have limited language proficiency is discussed on a
regular basis.
As a part of the Accessibility Plan, the agency encourages staff interest and
education in learning to more effectively communicate with individuals served at IVRS. The
agency encourages staff to enroll in college classes and will reimburse tuition and books
upon successful completion of related courses. □
Membership of Non-Elected Committees and Councils
IVRS does not have a non-elected transit related advisory council at this time.
Title VI Equity Analysis
IVRS does not have transit related facilities.
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Board of Directors Approval of IVRS’s Title VI Program
A RESOLUTION OF THE IVRS BOARD OF DIRECTORS
AUTHORIZING THE TITLE VI COMPLIANCE PLAN FOR THE
AGENCY.
WHEREAS, IVRS desires to comply with Title VI of the Civil Rights Act of 1964,
including new provisions detailed in U.S. Department of Transportation's FTA
Circular 4702.1B, "Title VI Requirement and Guidelines for Federal Transit
Administration Recipients,"
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WHEREAS, the Board of Directors wishes to authorize approval of the
compliance plan developed by staff to comply with necessary provisions of
the Civil Rights Act,
NOW, THEREFORE BE IT RESOLVED, by the Board of Directors of IVRS as
follows:
1. The CEO is authorized to implement the components of the plan in
order to meet Federal requirements.
2. The CEO is authorized to implement policies that may be necessary to
comply with subsequent revisions or interpretations to the Civil Rights
Act.
PASSED AND ADOPTED by the Board of Directors of IVRS in San Bernardino
County, State of California, on this 28th day of April 2016.
Richard E. Simpson, Ph.D. - Chairperson of the Board
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