This effort aligns with the university’s efforts to comply with federal regulations and Ohio Senate Bill 1.
What is an Equal Opportunity (EO) Program Review?
An EO Program Review (EOPR) is a type of response that can be used for reports made to CRCO that do not identify a CRCO policy violation, but do identify potential barriers to EEO and/or non-compliance with the EEO policy for one or more protected classes. EOPRs are designed to be in-depth consultations between the Civil Rights Compliance Office (CRCO) and units with a focus on reviewing specific policies, procedures, practices, behaviors, or environments to determine and remedy the root causes of potential EO barriers and/or non-compliance. Program reviews are not the same as a CRCO investigation.
Who participates in an EOPR?
- Initial Notification: Before the initiation of an EOPR, CRCO will notify the applicable senior leader, manager, and any other key stakeholders related to the policy, procedure, practice, behavior, and/or environment that will be reviewed.
- Implementation: To support an in-depth review, CRCO will identify and consult individuals who may have knowledge or direct experience with the identified policy, procedure, practice, behavior, and/or environment that is being reviewed. This could include managers, employees, subject matter experts, process owners, program participants, students, etc.
- Conclusion: The senior leaders, managers, and key stakeholders who were notified at the beginning of an EOPR are notified when an EOPR has concluded. This notification identifies if any EO barriers and/or noncompliance were identified and if an action plan will be implemented. Conclusions are tracked by CRCO and communicated with university partners as needed.
- Action Plan: CRCO and the unit(s) involved in an EOPR will partner to identify all individuals and units that need to be notified of and included in the remediation for identified EO barriers and/or noncompliance.
What is a barrier to EO?
Policies, procedures, practices, behaviors, or environments that unintentionally limit equal opportunity for members of a protected class.
Some barriers are easy to identify, and others are embedded in policies or day-to-day processes and/or behaviors and may appear neutral, but have a disproportionate impact on members of a protected class.
Focus Areas for a Program Review:
- Recruitment (employees, students, volunteers)
- Selection (does not apply to student admissions to the university or academic programs)
- Hiring
- Compensation
- Promotions
- Discipline, terminations, or removal from classes/programs
- Workplace/classroom environments
- Student, employee, or other university-affiliated organizations and programs
- Admission into a specific class or nonacademic program
How can a Program Review be Initiated:
- Report received by CRCO
- Identified trends or observable behaviors by CRCO staff related to a possible EO barrier or noncompliance
- Request received by CRCO from a unit
How is a Program Review Concluded?
It is important to note that a barrier to EO and/or noncompliance is NOT the same as discrimination or harassment. Therefore, EOPRs are not punitive and are only intended to be in-depth consultations to advance EO at the university. The are two possible conclusions to an EOPR:
- EO barrier and/or noncompliance IS NOT identified: the applicable unit(s) is notified, the conclusion is documented, and the EOPR is closed.
- EO barrier and/or noncompliance IS identified: CRCO will notify and partner with the applicable unit(s) to develop an action plan to remedy the identified EO barrier and/or noncompliance. CRCO will follow up with the unit (s) to offer consultation, support the completion of the action plan, and close the Review once the action plan has been completed.
What if a possible policy violation is identified during an EOPR?
If, during an EOPR, behavior is identified that would constitute possible harassment or discrimination and/or other CRCO policy violation, it will be referred to the CRCO Assistant Vice President and Title VI Officer for review and potential investigation.
If behavior is identified that would constitute a possible policy violation for a policy that is not owned by CRCO, the Director of EEO will partner with CRCO leadership to refer the information to the applicable university office for review.
At the direction of the Director of EEO, an EOPR may continue for matters outside of those referred for review and potential investigation.