HomeMy WebLinkAbout20242897.tiffRESOLUTION
RE: ADOPT EQUAL EMPLOYMENT OPPORTUNITY (EEO) ACTION PLAN POLICY FOR
WELD COUNTY COMMUNITY DEVELOPMENT BLOCK GRANT (CDBG) PROGRAM
WHEREAS, the Board of County Commissioners of Weld County, Colorado, pursuant to
Colorado statute and the Weld County Home Rule Charter, is vested with the authority of
administering the affairs of Weld County, Colorado, and
WHEREAS, pursuant to Section X(B)(1) of the President's Executive Order 11246,
executed September 24, 1966, stipulates grantees of entitlement funds are to require
subrecipients to submit an Affirmative Action Plan for compliance of equal employment
opportunities prior to acceptance of awarded funds, and
WHEREAS, Many Weld County municipalities participating in the Community
Development Block Grant (CDBG) Program do not have the staffing resources to develop their
own Equal Employment Opportunity Plan and would therefore be non -compliant to receive
federal funding through the entitlement program, and
WHEREAS, the Community Development Block Grant (CDBG) Program Advisory
Committee and Manager desires to adopt a policy that meets federal requirements to help
mitigate civil rights compliance issues with advisement from the U.S. Department of Housing and
Urban Development (HUD), and
WHEREAS, the Board has been presented with an Equal Employment (EEO) Action Plan
Policy between the County of Weld, State of Colorado, by and through the Board of County
Commissioners of Weld County for the benefit of the Weld County Community Development Block
Grant (CDBG) Subrecipients to use as part of the county's entitlement program, with further terms
and conditions being as stated in said policy, and
WHEREAS, after review, the Board deems it advisable to approve and adopt said policy,
a copy of which is attached hereto and incorporated herein by reference.
NOW, THEREFORE, BE IT RESOLVED by the Board of County Commissioners of Weld
County, Colorado, that the Equal Employment (EEO) Action Plan Policy between the County of
Weld, State of Colorado, by and through the Board of County Commissioners of Weld County for
the benefit of the Weld County Community Development Block Grant (CDBG) Program
Subrecipients, is approved and adopted.
CC : CDBC,(ER/c, ), CR(Kh)
to /3o/2.L(
2024-2897
F10080
ADOPT EQUAL EMPLOYMENT OPPORTUNITY (EEO) ACTION PLAN POLICY FOR WELD
COUNTY COMMUNITY DEVELOPMENT BLOCK GRANT (CDBG) PROGRAM
PAGE 2
The above and foregoing Resolution was, on motion duly made and seconded, adopted
by the following vote on the 30th day of October, A.D., 2024.
ATTEST:
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Weld County Clerk to the Board
BOARD OF COUNTY
WELD COU
ISSIONERS
OLORADO
Kevin D. Ross, Chair
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Deputy Clerk to the Board�► R �� (AYE)
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County ney (NAY)
10130/74`` r. Lori Saine
Date of signature:
2024-2897
FI0080
BOARD OF COUNTY COMMISSIONERS
PASS -AROUND REVIEW
PASS -AROUND TITLE: Weld County Equal Employment Opportunity (EEO) Policy for the Weld County
CDBG Grant Program
DEPARTMENT: CDBG
PERSON REQUESTING: Elizabeth Relford & Karin McDougal
DATE: 10/4/2024
Brief description of the problem/issue: As you all know, federal law prohibits discrimination based on protected
characteristics from entities such as Weld County or our municipalities that accept federal funds or otherwise provide
places of public accommodation. Therefore, in order to comply with federal law, the standard subrecipient agreement in
use by Weld County CDBG Program contains a whole suite of terms regarding civil rights. One term in particular, Sec
X(B)(1), requires the Subrecipient to "be committed to carry out pursuant to the Grantee's specifications an Affirmative
Action Program in keeping with the principles as provided in President's Executive Order 11246 of September 24, 1966"
and requires the Subrecipient to submit a plan for an Affirmative Action Program prior to receiving grant funds. These
terms come from federal regulation related to federal contract compliance. Many Weld County municipalities, especially
the smaller ones, do not have such a plan and find this requirement problematic as they do not have the bandwidth to
adopt formal plans. To help mitigate this problem, the standard subrecipient agreement in Sec X(B)(1) also requires us
to provide guidelines to our subrecipients on meeting these requirements. Staff recommends, and HUD agrees this is a
prudent course of action, that Weld County adopt a policy that meets the federal requirements that subrecipients can
then adopt with minor changes in lieu of creating their own plan from scratch. This will hopefully alleviate the burden on
our municipalities we collaborate with through CDBG or other federally funded projects while simultaneously fulfilling our
end of the bargain we agreed to when we entered into the subrecipient agreements. As the term affirmative action is
used in many different contexts that could create confusion for what this policy is meant to accomplish, Staff is
recommending calling it an Equal Employment Opportunity Policy to be more precise.
The attached policy was drafted by the County Attorney's office in coordination with CDBG staff and the Human
Resources Department. Staff requests the Board's consideration of this policy and to place it on the next available
BOCC agenda.
What options exist for the Board?
1. The Board considers approval of this policy on the next available BOCC agenda.
2. The Board requests a work session to further discuss the policy.
Consequences: Option 1 will create a more efficient and quicker process for the drafting and approval of
subrecipient agreements. Choosing option 2 would require each municipality, who does not already have an
affirmative action plan to create one.
Impacts: This policy would provide a mechanism for easing and ensuring compliance with the federal
regulations surrounding Equal Employment Opportunity.
Costs (Current Fiscal Year/ Ongoing or Subsequent Fiscal Years): No cost.
Recommendation:
Staff recommends option 1.
Approve Recommendation Schedule
Place on BOCC agenda Work Session Other/Comments:
Perry L. Buck, Pro-Tem
Mike Freeman, Chair
Scott K. James
Kevin D. Ross
Lori Saine
INN
2024-2897
F10O'6O
EEO ACTION PLAN
WELD COUNTY GOVERNMENT
WELD COUNTY, COLORADO
Page 1 of 10
Table of Contents
EEO POLICY STATEMENT 3
EEO ACTION PLAN 4
ORGANIZATION 5
RESPONSIBILITIES 6
A. Management Responsibility and Policy Dissemination 6
B. Administration and Communication of the Plan 6
C. Responsibilities of Managers and Supervisors 7
ACTION ORIENTED PLANS 8
INTERNAL AUDIT AND REPORTING SYSTEM 9
A. Personnel Activities 9
B. Documentation 9
C. Reporting 10
Page 2 of 10
EEO POLICY STATEMENT
The County complies with all provisions of equal employment opportunity laws. Recruiting, selection, and
advancement of employees will be based on their relative ability, knowledge, skills, and other relevant
nondiscriminatory factors.
The County will:
Recruit, hire, train and promote persons in all job titles without regard to disability, race (including
hair texture, hair type or protective hairstyles commonly or historically associated with race (e.g.,
braids, locs, twists, tight coils or curls, cornrows, bantu knots, afros and headwraps), color,
creed, sex (including pregnancy), disability, age (over 40), national origin, sexual orientation
(including actual or perceived orientation), gender identity, gender expression, ancestry, religion,
marital status, membership in the state National Guard, civil -air -patrol status, and lawful activities
during nonworking hours.
Administer all personnel actions such as compensation, benefits, transfers, layoffs, return from
layoff, County -sponsored training, education, and tuition assistance without regard to the
protected characteristics listed above.
Any applicant or employee who believes they have been harassed, discriminated against or subject to
retaliation by a co-worker, supervisor, agent, client, vendor, or customer of the County, in violation of
the foregoing policies, or who is aware of such harassment, discrimination or retaliation against
others, should immediately provide a written or verbal report to their supervisor or to Human
Resources to report such incidents. After a report is received, a thorough and objective investigation
will be undertaken. The investigation will be completed, and a determination made and communicated
to the employee or applicant as soon as practical. The County expects all employees to fully
cooperate with any investigation conducted by the County into a complaint of proscribed harassment,
discrimination, or retaliation, or regarding the alleged violation of any other County policies.
If the County determines that this policy has been violated, remedial action will be taken,
commensurate with the severity of the offense. Appropriate action will also be taken to deter any
future harassment or discrimination prohibited by this policy. If a complaint of prohibited harassment,
discrimination or retaliation is substantiated, appropriate disciplinary action, up to and including
termination of employment, may be taken.
Page 3 of 10
EEO ACTION PLAN
The County of Weld (County) is committed to ensure equal employment opportunity within the
County government. It is the policy of the County to actively seek qualified applicants to fill vacant
positions based on the applicant's experience, qualifications, and the criteria outlined in posted job
descriptions.
The County is committed to hiring the best candidate for the position and does not intend to exhibit
favoritism towards any group or person(s).
The demographics of Weld County will be the region utilized to guide recruiting practices.
The County will actively recruit applicants, including members of protected classes, through
appropriate posting sites and publications as our commitment to creating an equal employment
opportunity.
Our commitment to opportunity for equal employment is not limited to recruitment but also applies
to ongoing employment practices within the organization to include employee training and
development.
Page 4 of 10
ORGANIZATION
WELD COUNTY HOME RULE GOVERNMENT
County Citizens
C
Assessor
I
County
Attorney
County
Council
Board of County
Commissioners
i
1
Sheriff
Corrections, Law Cntorcemant,
Animal Control, Foronsic Lab,
Task Force, Code Enforcement
Department of
Finance and
Administration
Commissioner
Coordinator
Accounting
Budget
Capital Projects
Contract Administration
Grant Administration
Finance Division
Human Resources
Printing and Supply
Purchasing
Public Informat on Office
Risk Management
Special Projects
Treasurer's Office
Information Services
GIS and Mapping
Telecom Services
Public Safety IT
Clerk to the Board
Housing Authority
r
Department of
Public Health and
Environment
Commissioner
Coordinator
Health Administration
Environmental Health
Public Health Services
Health Communication,
Education and Planning
Board of Public Health
Coroner
Justice Services
Public Safety
Communications
Wireless
Communications
I
Department of
Public Works
Commissioner
Coordinator
Engineering
Road and Bridge
1 _
Facilities
rOffice of Emergency
Management
1
Fleet Services
I
Department of
Planning Services
Commissioner
Coordinator
011-1c and
Recorder
Recording, Mnfnr Vehicle, rinctions
Planning and Zoning
Building Inspection
Board of Adjustment
International Building Code,
Planning Commission
Utility Board
at and Gas Energy
County Extension
Office
Fair Board
Department of
Human Services
Commissioner
Coordinator
Human Services
Social Services
AAA
Child Support
Assistance Payments
Child/Adult Protection
Employment Services
Veterans Service
Red = Elected
Positions
Page 5 of 10
RESPONSIBILITIES
A. Management Responsibility and Policy Dissemination
Elected Officials and Department Heads are responsible for complying with the requirements of
the County's Equal Employment Opportunity (EEO) Action Plan. Human Resources, in
cooperation with the County Attorneys, will maintain compliance with all federal, state, and local
equal employment opportunity laws and regulations, including, but not limited to, Title VII of the Civil
Rights Act of 1964;Title 41, Subtitle B, Chapter 60 of the Code of Federal Regulations; Title 24,
Article 34, Part 4 of the Colorado Revised Statutes; and Section 2-2-140 of the Weld County Code.
Human Resources is responsible for governing the recruitment and employment practices
applicable to the established policy. Human Resources will complete the necessary reporting
requirements.
All questions, complaints, and suggestions concerning the equal employment opportunity policy and
action plan shall be directed to Human Resources.
B. Administration and Communication of the Plan
Under the direction of the Board of County Commissioners, the Chief Human Resources Officer or
designee, has the responsibility for designing and ensuring the effective implementation of the EEO Action
Plan. These responsibilities include without limitation:
1) Developing EEO policy statements; EEO action programs and internal and external
communication processes;
2) Assisting in the identification of Plan/EEO problem areas;
3) Assisting departments in arriving at effective solutions to Plan/EEO problems;
4) Designing and implementing an internal audit and reporting system that:
a) Measures the effectiveness of the Plan;
b) Determines the degree to which Plan goals and objectives are met; and
identifies the need for remedial action.
5) Keeping the Board of County Commissioners informed of the action plan progress and
reporting potential problem areas;
6) Reviewing the Plan with all Department Heads, Elected Officials, and managers at all levels to
ensure the policy is understood and followed in all personnel activities;
7) Auditing any County postings or bulletins to ensure compliance information is posted and up to date;
and
8) Serving as a liaison between the County and enforcement agencies.
Page 6 of 10
C. Responsibilities of Managers and Supervisors
It is the responsibility of all managerial and supervisory staff to implement the Plan. These responsibilities
include without limitation:
1) Assisting in the identification of problem areas, formulating solutions and establishing departmental
goals and objectives when necessary;
2) Reviewing the qualifications of all applicants and employees to ensure qualified individuals are
treated in a nondiscriminatory manner when hiring, promotion, transfer and termination actions
occur; and
3) Reviewing the job performance of each employee to assess whether personnel actions are justified
based on the employee's performance of their duties and responsibilities.
Page 7 of 10
ACTION ORIENTED PLANS
A. Programs To Meet Established Goals
The County will institute action programs to eliminate identified problem areas and to help achieve specific
EEO action goals. These programs include without limitation:
1) Conducting annual analyses of job descriptions to ensure they accurately reflect job functions;
2) Reviewing job descriptions by department and job title using job performance criteria;
3) Making job descriptions available to recruiting sources and available to all members of management
involved in the recruiting, screening, selection and promotion processes;
4) Evaluating the total selection process to ensure freedom from bias through:
a) Reviewing job applications and other pre -employment forms to ensure information
requested is job -related;
b) Evaluating selection methods that may have a disparate impact to ensure that they are job -
related and consistent with business necessity;
c) Training personnel and management staff on proper interview techniques; and
d) Training in EEO for management and supervisory staff.
5) Using techniques to improve recruitment and increase the flow of minority and female applicants
as required by federal law. The County presently undertakes the following actions:
a) Include the phrase "Equal Opportunity Employer" in all printed employment advertisements;
b) Place job announcements, when appropriate, in local minority news media and women's
interest media;
c) Disseminate information on job opportunities to organizations representing minorities,
women and employment development agencies when job opportunities occur;
d) Encourage all employees to refer qualified applicants; and
a) Hiring an outside vendor to perform a compensation study.
6) Ensuring that all employees are given equal opportunity for promotion. This is achieved by:
a) Posting all promotional opportunities;
b) Offering assistant to employees in identifying promotional opportunities, training and
educational programs to enhance promotions and opportunities for job rotation or transfer;
and
c) Evaluating job requirements for promotion.
Page 8 of 10
INTERNAL AUDIT AND REPORTING SYSTEM
The County's CHRO or their designee is responsible for developing and preparing the formal Plan
documents. The CHRO is responsible for the effective implementation of the Plan; however,
responsibility is likewise vested with each department head or elected official. The County's audit and
reporting system is designed to:
1) Measure the effectiveness of the EEO program;
2) Document personnel activities;
3) Identify problem areas where remedial action is needed; and
4) Determine the degree to which the Plan goals and objectives have been obtained.
A. Personnel Activities
The following personnel activities are reviewed to ensure nondiscrimination and EEO for all individuals
without regard to their race, color, sex, sexual orientation, marital status, religion, or national origin:
1) Recruitment, advertising and job application procedures;
2) Hiring, promotion, upgrading, award of tenure, layoff and recall from layoff;
3) Rates of pay and any other forms of compensation including fringe benefits;
4) Job assignments, job classifications, job descriptions and seniority lists;
5) Sick leave, leaves or absence, or any other leave;
6) Training, apprenticeships, attendance at professional meetings and conferences; and
7) Any other term, condition, or privilege of employment.
B. Documentation
The following documents are maintained as a component of the County's internal audit process:
1) An applicant flow log showing the name, race, sex, date of application, job title, interview status and
the action taken for all individuals applying for job opportunities;
2) Summary data of external job offers and hires, promotions, resignations, terminations, and
layoffs by job group and by sex and minority group identification;
Page 9 of 10
3) Summary data of applicant flow by identifying, at least, total applicants, total minority applicants
and total female applicants for each position;
4) Maintenance of employment applications (not to exceed one year); and
5) Records pertaining to the County's compensation system.
C. Reporting
The County's audit system includes an annual report documenting the County's efforts to achieve its EEO
Action Plan responsibilities. Department Heads are asked to report any current or foreseeable EEO problem
areas and are asked to outline their suggestions/recommendations for solutions. If problem areas arise,
the manager or supervisor is to report problem areas immediately to the HCRO. During annual reporting,
the following occurs:
1) The HCRO will discuss any problems relating to significant rejection ratios, EEO charges, etc., with
the Board of County Commissioners and other Elected Officials; and
2) The HCRO will report the status of the Plan goals and objectives to the Board of County
Commissioners and other Elected Officials and will recommend remedial actions for the effective
implementation of the Plan, if necessary.
Page 10 of 10
Notice of Public Hearing Concerning Adoption of Equal Employment Opportunity (EEO)
Action Plan Policy for Weld County Community Development Block Grant (CDBG)
Program
Notice is hereby given that an Equal Employment Opportunity (EEO) Action Plan Policy
has been submitted to the Board of Weld County Commissioners for the Weld County Community
Development Block Grant (CDBG) Program. A copy of the EEO Action Plan Policy is available
for public inspection from 8:00 a.m. to 5:00 p.m. weekdays in the Office of the Clerk to the Board,
Weld County Administrative Building, 1150 O Street, Greeley, Colorado 80631. All interested
citizens, groups, and organizations representing the interests of citizens are encouraged to submit
written or oral comment concerning said EEO Action Plan Policy.
A public hearing will be held in the Chambers of the Board of County Commissioners of
Weld County, Colorado, Weld County Administration Building, 1150 O Street, Assembly Room,
Greeley, Colorado 80631, at the date and time specified below, for adoption of said EEO Action
Plan Policy. Members of the public may inspect said Plan Policy and file or register any comments
at any time prior to its adoption.
Docket #: 2024-72
Hearing Date: October 30, 2024
Hearing Time: 9:00 a.m.
Board of County Commissioners
Weld County, Colorado
Dated: October 14, 2024
Published: October 16, 2024, in the Greeley Tribune
Prairie Mountain Media, LLC
PUBLISHER'S AFFIDAVIT
County of Weld
State of Colorado
The undersigned, Agent , being first duly sworn
under oath, states and affirms as follows:
1. Helshe is the legal Advertising Reviewer of
Prairie Mountain Media LLC, publisher of the
Greeley Tribune.
2. The Greeley Tribune is a newspaper
of general circulation that has been published
continuously and without interruption for at least
fifty-two weeks in Weld County and
meets the legal requisites fora legal newspaper
under Colo. Rev. Stat. 24-70-103.
3. The notice that is attached hereto is a true copy,
published in the Greeley Tribune
in Weld County on the following date(s):
Oct 16, 2024
Signature
Subscribed and sworn to me before me this
I &dayof Mo19.01 iW.
(SEAL)
SHAYLA NAJERA
NOTARY PUBLIC
STATE OF COLORADO
NOTARY ID 20174031965
MY COMMISSION EXPIRES July 31, 2025
Account: 1099690
Ad Number: 2080457
Fee: $14.50
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