ADA & Title VI Plan & Complaint Process
Americans with Disabilities Act Plan
Including policies regarding General ADA Requirements and Reasonable Modifications for Lorain County Mobility Management
Introduction and Purpose
The Americans with Disabilities Act of 1990 (ADA) requires that individuals with disabilities receive the same level of service as non-disabled individuals. Services that are “separate but equal” are not acceptable. Section 504 prohibits discrimination on the basis of disability in any program or activity receiving Federal financial assistance.
This ADA policy is written to establish operating and service guidelines and procedures for the implementation of the requirements of the Americans with Disabilities Act of 1990 (ADA), the U.S. Department of Transportation (U.S. DOT) regulations for implementing ADA (49 CFR Parts 27, 37 and 38), and any applicable state laws and regulations. Lorain County Mobility Management complies with ADA requirements with] respect to the services it provides. These include: individual and group training on accessing and using public transit; written materials on transportation resources in Lorain County; individual assistance on brokering transportation for persons with disabilities, seniors, or low-income workers; employer training on federal transportation benefits; and coordination of 5310 and other vehicles for shared use.
ADA Policy Statement
It is the policy of Lorain County Mobility Management to comply with all the legal requirements of federal and state laws and regulations as they pertain to individuals with disabilities. If state laws and federal regulations are contradictory, the federal ADA regulations prevail. Lorain County Mobility Management provides transportation information services without discrimination to all persons including individuals with disabilities. Discrimination on the basis of disability against any person will not be condoned or tolerated.
Goals: Service is provided in a manner that meets the following goals:
1. Provides information and assistance utilizing safe, accessible, and dignified services to all persons, including individuals with disabilities.
2. Provides information on and assistance accessing transportation resources that accommodate a wide range of mobility aids within the confines of available vehicles and commercial standard equipment.
Applicability: This policy applies to all Lorain County Mobility Management employees, and services. It applies equally to all persons needing and/or using the services provided by the system.
Disability: With respect to an individual, a physical or mental impairment that substantially limits one or more of the major life activities of such individual; a record of such an impairment; or being regarded as having such an impairment.
Mobility Device: A device that is designed to assist an individual with disabilities with locomotion. Examples include wheelchairs, canes, crutches, and walkers. Also called mobility aid.
Service Animal: Any guide dog, signal dog, or other animal that has been individually trained to work or perform tasks for an individual with a disability, including, but not limited to, guiding individuals with impaired vision, alerting individuals with impaired hearing to intruders or sounds, providing minimal protection or rescue work, pulling a wheelchair, or fetching dropped items.
Wheelchair: A mobility aid belonging to any class of three- or more- wheeled devices, usable indoors, designed or modified for and used by individuals with mobility impairments, whether operated manually or powered.
General Guidance and Procedures for Implementing Policy
Recruitment and Employment
As stated in the agency personnel policies, the agency is an Equal Opportunity Employer (EOE) and fully complies with ADA in its recruitment, hiring, and continued employment practices.
All complaints of discrimination on the basis of disability will be promptly and objectively investigated and forwarded to Ryan Aroney at United Way of Greater Lorain County and promptly and objectively investigated. Complaints are also be submitted to the ODOT Civil Rights Office.
Lorain County Mobility Management will promptly communicate its response to the complaint allegations, including its reasons for the response, to the complainant. The response will be documented. Corrective or disciplinary action will be taken for behavior prohibited by this policy, up to and including termination of employment.
Documentation of each complaint will be kept on file for a minimum of one year, and a summary of all complaints will be kept for at least five years. This meets DOT regulations that require FTA grantees to maintain all complaints of noncompliance with 49 CFR Part 27 for one year, and a record of all such complaints, which is permitted to be in summary form, for five years.
Title VI Notice to the Public
Lorain County Mobility Management’s Notice to the Public is as follows:
Lorain County Mobility Management
Lorain County Mobility Management 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 she or he has been aggrieved by any unlawful discriminatory practice under Title VI may file a complaint with the United Way of Greater Lorain County.
For more information on the Lorain County Mobility Management civil rights program, the procedures to file a complaint, or to file a complaint, please contact Ryan Aroney, President & CEO at 440-277-6530; email firstname.lastname@example.org; or visit our administrative office at 642 Broadway Avenue, Lorain, OH 44052. For more information, visit www.uwloraincounty.org or www.MOVELoraincounty.org
For transportation-related Title VI matters, a complaint may also be filed directly with the:
Ohio Department of Transportation, Attn: Office of Opportunity, Diversity, and Inclusion, Title VI Coordinator, 1980 West Broad Street, Mailstop 3270, Columbus, Ohio 43223
Federal Transit Administration, Office of Civil Rights, Attention: Complaint Team, East Building, 5th Floor-TCR, 1200 New Jersey Ave., SE Washington, DC, 20590.
If information is needed in another language, contact 440-277-6530.
Lorain County Mobility Management Notice to the Public is posted in the public areas of the office.
Front office of United Way of Greater Lorain County
Title VI Complaint Procedure
Lorain County Mobility Management’s Title VI Complaint Procedure is made available in the following locations:
☒ Agency website, if available: uwloraincounty.org and MOVELoraincounty.org
☒ Hard copy in the central office
☒ Agency Title VI Plan
Any individual, group of individuals or entity that believes they have been discriminated against on the basis of race, color, or national origin by Lorain County Mobility Management may file a Title VI complaint by completing and submitting the agency’s Title VI Complaint Form.
Any individual having filed a complaint or participated in the investigation of a complaint shall not be subjected to any form of intimidation or retaliation. Individuals who have cause to think that they have been subjected to intimidation or retaliation can file a complaint of retaliation following the same procedure for filing a discrimination complaint.
A complaint must be filed with United Way of Greater Lorain County no later than 180 days after the following:
The date of the alleged act of discrimination; or
The date when the person(s) became aware of the alleged discrimination; or
Where there has been a continuing course of conduct, the date on which that conduct was discontinued of the latest instance of the conduct.
Once the complaint is received, United Way of Greater Lorain County will review it to determine if our office has jurisdiction. A copy of each Title VI complaint received will be forwarded to the Ohio Department of Transportation within ten (10) calendar days of receipt. The complainant will receive an acknowledgement letter informing her/him whether the complaint will be investigated by our office.
United Way of Greater Lorain County has 45 days to investigate the complaint. If more information is needed to resolve the case, United Way of Greater Lorain County may contact the complainant requesting further information. The complainant has 10 business days from the date of the letter to send requested information to the investigator assigned to the case. If the investigator is not contacted by the complainant or does not receive the additional information within 10 business days, United Way of Greater Lorain County can administratively close the case.
After the investigator reviews the complaint, the agency will issue one of two (2) letters to the complainant: a closure letter or 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 letter of finding (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 wishes to appeal the decision it must direct the appeal to the agency initially. The complainant has 10 days after the date of the closure letter or the letter of finding to do so. If there is outstanding concern, the appeal may be directed to the state DOT or FTA. The appeal process information will be included in the letter.
A person may also file a complaint directly with the: Ohio Department of Transportation, Attn: Office of Opportunity, Diversity and Inclusion 1980 West Broad Street, Mailstop 3270, Columbus, OH 43223
Federal Transit Administration, Office of Civil Rights, Attention: Complaint Team, East Building,
5th Floor-TCR, 1200 New Jersey Ave., SE Washington, DC, 20590.
Approved by: United Way of Greater Lorain County Board of Directors
Date Approved: January 1, 2023
ADA Contact Information
Name & Title: Ryan Aroney, President & CEO
Mailing Address: 642 Broadway Avenue, Lorain, Ohio 44052
Phone Number: 440-277-6530
Email Address: email@example.com
Reasonable Modification Contact Information
Title: Ryan Aroney, President & CEO
The fillable ADA/Title VI Complaint PDF Form is below!
Here is a link to the entire Americans with Disabilities Act Plan:
Here is a link to the entire Title IV Plan:
Here is the link to download the ADA/Title VI Complaint Form: