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 ground 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 financial assistance.”

Subrecipients of public transportation funding from the Federal Transit Administration (FTA), are required to develop policies, programs, and practices that ensure that federal and state transit dollars are used in a manner that is nondiscriminatory. INDEPENDENT LIVING CENTER OF THE HUDSON VALLEY is a subrecipient of FTA financial assistance through a grant from NYSDOT. This Title VI plan details how INDEPENDENT LIVING CENTER OF THE HUDSON VALLEY incorporates nondiscrimination policies and practices in providing transit services to the ridership we serve.

INDEPENDENT LIVING CENTER OF THE HUDSON VALLEY primarily receives program funds from the NYS Education Department and FTA Section 5310 funding through NYSDOT to acquire transit vans for closed-door transportation for program clients at Rensselaer and Columbia Counties in NY. The transportation services require advanced scheduling. Service is operated to and from ILCHV programs, Monday through Friday from 9-5. Services are free of charge.

INDEPENDENT LIVING CENTER OF THE HUDSON VALLEY TITLE VI PLAN

As a subrecipient to NYSDOT receiving Federal Transit Administration Section 5310 and/or 5311 funds, INDEPENDENT LIVING CENTER OF THE HUDSON VALLEY’s Title VI plan shall comply with Title VI of the Civil Rights Act of 1964 as presented with the following elements:

Title VI Notice to the Public, including a list of locations where the notice is posted
Title VI Complaint Procedures (i.e., instructions to the public regarding how to file a Title VI discrimination complaint)
Title VI Complaint Form
List of transit-related Title VI investigations, complaints, and lawsuits
Public Participation Plan, including information about outreach methods to engage minority and limited English proficient populations, as well as a summary of outreach efforts made since the last Title VI Program submission
Language Assistance Plan for providing language assistance to persons with limited English proficiency.
A table depicting the membership of transit related non-elected committees and councils, the membership of which is selected by the subrecipient, broken down by race, and a description of the process the agency uses to encourage the participation of minorities on such committees.
A copy of board meeting minutes, resolution, or other appropriate documentation showing the board of directors or appropriate governing entity or official(s) responsible for policy decisions reviewed and approved the Title VI Program. (Board approval is not required if the subrecipient does not have a Board.)

The INDEPENDENT LIVING CENTER OF THE HUDSON VALLEY shall update its Title VI plan every three years and present the updated plan to NYSDOT for their review and approval.

B1. INDEPENDENT LIVING CENTER OF THE HUDSON VALLEY TITLE VI Policy

The INDEPENDENT LIVING CENTER OF THE HUDSON VALLEY commits to comply with Title VI of the Civil Rights Act of 1964 that prohibits discrimination based on 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 ground 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 financial assistance” (Title VI of the Civil Rights Act of 1964, 42 U.S.C. § 2000d et seq.). This requirement is included in the Section 5310 agreement between INDEPENDENT LIVING CENTER OF THE HUDSON VALLEY and NYSDOT and any related agreements the agency may have with third-party contractors.

For more information on INDEPENDENT LIVING CENTER OF THE HUDSON VALLEY s Title VI program contact:

Title VI Coordinator

INDEPENDENT LIVING CENTER OF THE HUDSON VALLEY

Simeon Goldman, Esq. General Counsel

15-17 Third Street

Troy, New York 12180

Phone (518) 274-0701 V /TDD

Email: sgoldman@ilchv.org

B2. Title VI Public Notice

The INDEPENDENT LIVING CENTER OF THE HUDSON VALLEY’s Notice to the Public is shown in Appendix 6 and posted in the following locations:

☒ Agency website at: www.ilchv.org

☒ Public areas of the agency office located at 15 3^rd Street, Troy, NY 12180

☒ Inside transit vehicles (required by NYSDOT)

☐ At bus stops (optional)

B3. Title VI Complaint Procedures and Complaint Form

The INDEPENDENT LIVING CENTER OF THE HUDSON VALLEY’s Title VI Complaint Procedure is available in the following locations:

☒ Agency website at: www.ilchv.org

☒ Hard copy in the central office

☒ In client intake materials

Anyone who believes they have been discriminated against on the basis of race, color, or national origin, may file a complaint by completing and submitting the Title VI Complaint Form (contained in Appendix 2) to the address below.

INDEPENDENT LIVING CENTER OF THE HUDSON VALLEY
Simeon Goldman, Esq.

Title VI Coordinator

15-17 Third St.

Troy, NY 12180

Phone (518) 274-0701
Email: sgoldman@ilchv.org

The complaint form is not required to file a complaint. The complainant may submit any written report as a complaint notice. INDEPENDENT LIVING CENTER OF THE HUDSON VALLEY will make reasonable modifications and take information verbally if the complainant requires this accommodation.

The INDEPENDENT LIVING CENTER OF THE HUDSON VALLEY investigates complaints received no more than 180 days after the alleged incident. Once the complaint is received, the INDEPENDENT LIVING CENTER OF THE HUDSON VALLEY will follow the steps below:

Acknowledge receipt of the complaint within 10 days (Appendix 3)
Determine if the INDEPENDENT LIVING CENTER OF THE HUDSON VALLEY has jurisdiction to investigate the complaint.
Plan to complete the investigation within 45 days.
Schedule an interview, if deemed necessary.
Determine if other public or private entities are or should be involved.
Determine if additional information is needed. Complainant has 15 days to provide the additional information.
If the INDEPENDENT LIVING CENTER OF THE HUDSON VALLEY is not contacted by the complainant or does not receive the additional information within 15 days, the case can be administratively closed. Additionally, a case can be administratively closed if the complainant no longer wishes to pursue the case.
Determine if meetings with the affected party or other interested parties are needed.

After the investigative process has been completed, the INDEPENDENT LIVING CENTER OF THE HUDSON VALLEY will issue one of two letters to the complainant: a closure letter or a letter of finding (LOF).

A closure letter summarizing the allegations and stating that there was no Title VI violation and that the case will be closed. (Appendix 4)
A letter of finding (LOF) summarizing the allegations and the interviews regarding the alleged incident, and explaining whether any disciplinary action, additional training of the staff member, or other action will occur. (Appendix 5)

If the complainant wishes to appeal the decision, the complainant must submit the appeal within 21 days after the date of the closure letter or the LOF.

Filing complaints with INDEPENDENT LIVING CENTER OF THE HUDSON VALLEY enables the agency to properly investigate the complaint. A person may also file a complaint directly with:

New York State Department of Transportation

Office of Diversity and Opportunity

50 Wolf Road, 6th Floor

Albany, NY 12232

(518) 457-1129 Fax (518) 549-1273

OCR-TitleVI@dot.ny.gov

Federal Transit Administration

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, please contact INDEPENDENT LIVING CENTER OF THE HUDSON VALLEY at 518-274-0701.

Si se necesita información en otro idioma, por favor contacto at 518-274-0701.

B4. Transit Related Title VI Complaints, Investigations and Lawsuits

The INDEPENDENT LIVING CENTER OF THE HUDSON VALLEY maintains a log of all Title VI complaints, investigations, and lawsuits pertaining to its transit-related activities since the last Title VI plan update.

Reporting Period: 2021 2022 2023 Check One:
X	There have been no investigations, complaints and/or lawsuits filed against INDEPENDENT LIVING CENTER OF THE HUDSON VALLEY during the reporting period.
	There have been investigations, complaints and/or lawsuits filed against INDEPENDENT LIVING CENTER OF THE HUDSON VALLEY. See list below.

	Date (Month, Day, Year)	Summary (include basis of complaint: race, color, national origin)	Status (open/closed)	Disposition (finding/no finding)
Complaints
1.
2.
3.
Investigations
1.
2.
3.
Lawsuit
1.
2.
3.

B5. Public Involvement Process

Strategies and Desired Outcomes

This section describes how INDEPENDENT LIVING CENTER OF THE HUDSON VALLEY disseminates vital agency information and engages the public in the decision-making process for transportation services. We seek out and consider the input and needs of interested parties and groups traditionally underserved by transportation systems. These groups may face challenges accessing our services, such as minority and limited English proficient (LEP) persons. Underlying these efforts is our commitment to determining the most effective public involvement methods for a given project or population.

INDEPENDENT LIVING CENTER OF THE HUDSON VALLEY primarily serves only clients that have been determined to be eligible for our transit service by the NYS Education Dept. (Funder). The Funder, as a recipient of federal financial assistance, must comply with all Title VI requirements in the development and delivery of their programs. INDEPENDENT LIVING CENTER OF THE HUDSON VALLEY serves all individuals who are determined by the Funder to be eligible for services, without regard to race, color, or national origin and low-income status.

Public Outreach Activities

INDEPENDENT LIVING CENTER OF THE HUDSON VALLEY’s program decision-making public involvement is limited to the population that meets the eligibility criteria set by the NYS Education Dept. (Funder). The Funder is the lead agency for public involvement in the decision-making process with the goal of offering minority and low-income individuals the opportunity to comment on the benefits of the program services being provided with federal financial assistance. The Funder outreach consists of relationship building with agencies and stakeholders (such as schools, colleges and vocational rehabilitation service providers) that provide services to minority, low income and LEP communities.

INDEPENDENT LIVING CENTER OF THE HUDSON VALLEY may assist the Funder during open-house events and the enrollment period as well as promoting the Funder’s public involvement campaign to a diverse community. Members of the public who request notices and or handouts in a language other than English will be referred to staff who can provide interpretation assistance or to the Funder for assistance.

Summary on Public Involvement Activity

INDEPENDENT LIVING CENTER OF THE HUDSON VALLEY is a closed-door service provider so traditional public involvement activities are not applicable. However, INDEPENDENT LIVING CENTER OF THE HUDSON VALLEY maintains information on its website and actively works with community organizations regarding its commitment to serve all persons regardless of race, color, or national origin.

B6. Language Assistance Plan

To comply with the FTA Title VI requirement on nondiscrimination based on national origin, as it affects limited English proficient (LEP) persons, INDEPENDENT LIVING CENTER OF THE HUDSON VALLEY will take reasonable steps to ensure meaningful access to our programs and activities by persons for whom English is not their primary language and who have a limited ability to read, write, speak, or understand English.

The Language Assistance Plan for INDEPENDENT LIVING CENTER OF THE HUDSON VALLEY is based on a Four Factor Analysis that describes the demographic characteristics of our service area, the frequency with which riders use our services, and the importance of our transportation services. These three factors identify the need for language assistance and are balanced with a fourth factor, that of the available resources with which to provide language assistance to result in an assistance plan to address the identified needs of the LEP population(s) served.

LEP Four Factor Analysis

To determine what the specific languages are spoken in our transit service area and to determine what language services are appropriate for the LEP population, the INDEPENDENT LIVING CENTER OF THE HUDSON VALLEY has conducted a Four Factor Analysis[1]: (1) Demography, (2) Frequency, (3) Importance, and (4) Resources and costs.

Demography: A number or proportion of the LEP population(s) specifically served or that could be served by INDEPENDENT LIVING CENTER OF THE HUDSON VALLEY transit service.
The frequency with which LEP persons come into contact with INDEPENDENT LIVING CENTER OF THE HUDSON VALLEY.
The nature and importance of INDEPENDENT LIVING CENTER OF THE HUDSON VALLEY transit services to LEP population(s).
The resources available for LEP outreach and how employees are trained to provide language assistance to LEP persons.

Our analysis is based on:

internal client registration data for our transportation services.

Factor 1–Demography | Number or proportion of the LEP population(s), specifically served or could be served by INDEPENDENT LIVING CENTER OF THE HUDSON VALLEY transit service.

We examined our transit services and our experiences with LEP individuals who specifically use our transit services to determine the breadth and scope of the LEP preferred language services that were needed in providing the specific transit services.

INDEPENDENT LIVING CENTER OF THE HUDSON VALLEY clients and potential clients are primarily older adults and individuals with disabilities. When our clients register for our demand-response transportation services, they provide information such as address, emergency contact, and mobility aids used (e.g., canes, walkers, or wheelchairs). As part of the registration process any language assistance needs are identified, along with any impairments which may affect the ability to hear spoken language. The review of our internal client data shows that 4 people or 4% of the total number of clients speak English less than very well. For the 4% population of riders who do not speak English very well, they preferred the language assistance in Spanish (4 people or 4%).

Factor 2–Frequency | Frequency with which LEP people come in contact with INDEPENDENT LIVING CENTER OF THE HUDSON VALLEY

The INDEPENDENT LIVING CENTER OF THE HUDSON VALLEY day-to-day clients and their parents or guardians are assessed for their ability to understand English. During the intake process, INDEPENDENT LIVING CENTER OF THE HUDSON VALLEY is able to identify non-English speaking clients with whom we have frequent contact; and therefore, have staff available to provide oral interpretation. Most of our clients speak English very well. Since the last Title VI plan update, INDEPENDENT LIVING CENTER OF THE HUDSON VALLEY has not had to provide our clients with language assistance.

Factor 3–Importance | Importance of the service to clients who need language assistance

INDEPENDENT LIVING CENTER OF THE HUDSON VALLEY’s transportation services are critical to the lives of many of its riders, enabling them to participate as fully as possible in the community, interact and socialize with others, and carry out the activities of daily living.

Therefore, the INDEPENDENT LIVING CENTER OF THE HUDSON VALLEY has staff available to provide oral interpretation, a language line, or translation as needed thus ensuring riders, regardless of the language they speak, can access our service.

Since the last Title VI plan update, INDEPENDENT LIVING CENTER OF THE HUDSON VALLEY has found that our existing language supports meet the needs of our clientele.

Factor 4–Resources and Costs | Resources available and costs

To meet the language assistance needs of our INDEPENDENT LIVING CENTER OF THE HUDSON VALLEY LEP population, INDEPENDENT LIVING CENTER OF THE HUDSON VALLEY utilizes readily available resources and works to strengthen our partnership with other organizations our riders engage with. Some of those readily available resources may include bilingual staff, the inclusion of Google translate toolbar to our website and use of other translation applications, and the NY Office on Aging Services language assistance tools. To supplement these resources, INDEPENDENT LIVING CENTER OF THE HUDSON VALLEY may also retain the services of an interpreter, translate vital documents, and utilize community volunteers. After analyzing the INDEPENDENT LIVING CENTER OF THE HUDSON VALLEY budget and reviewing available resources, cost associated to meet language assistance needs of the LEP population at 5% or greater will be incurred for translating and/or interpreting vital documents.

Results of the Four Factor Analysis

As a result of the four-factor analysis, a written Language Assistance Plan is not required. However, reasonable attempts will be made to accommodate any persons encountered who require written translation or oral interpretation services. Our agency will do this at no cost to the program clientele. Further, we will work with other agencies to identify resources that will effectively meet the needs of LEP individuals.

During the registration process for closed-door service providers, INDEPENDENT LIVING CENTER OF THE HUDSON VALLEY is able to identify non-English speaking clients (or parents or guardians of our clients, as appropriate) with whom we have frequent contact; and therefore, have language assistance tools or staff available to provide oral interpretation.

Providing Language Assistance Services

INDEPENDENT LIVING CENTER OF THE HUDSON VALLEY currently meets the language assistance needs of the Spanish-speaking population through the services of an interpreter, including Google translate on our website, translation applications, accessing community organizations that meet the needs of the Spanish-speaking population, and our multilingual staff. As needed, key documents are translated to Spanish, meeting the threshold for translation of such materials.

Informing LEP Populations of the Availability of Language Assistance

Language assistance is advertised on our website, on the Title VI notice, through posters in our agency, and through program registration materials, as applicable. INDEPENDENT LIVING CENTER OF THE HUDSON VALLEY also utilizes community-based organizations to share the availability of these services, public meetings, rider surveys and interviews, outreach documents, and on vehicles.

Updating the Language Assistance Plan

INDEPENDENT LIVING CENTER OF THE HUDSON VALLEY identifies the language capabilities and language assistance needs of our ridership every time the Title VI plan is updated. Should INDEPENDENT LIVING CENTER OF THE HUDSON VALLEY have more than 5% of persons in a specific language group that requires language assistance, INDEPENDENT LIVING CENTER OF THE HUDSON VALLEY shall comply with the US Department of Justice Safe Harbor Provision and provide written material in the specific language and or oral interpretation of the written material, free of cost. If no change in language assistance needs occurs, the Language Assistance Program will at a minimum be updated during the Title VI plan update.

Training Employees to Provide Language Assistance

INDEPENDENT LIVING CENTER OF THE HUDSON VALLEY employees are oriented on the principles of Title VI and language assistance at hire and when the Title VI plan is updated. New employees will be provided guidance on the needs of clients served and how best to meet their language needs. Training will include review of the following Title VI program components:

Title VI Notice to the Public
Title VI complaint procedures and form
Complaint log
LEP and Language Assistance Plan

If an employee needs further assistance related to LEP individuals, they will work with the INDEPENDENT LIVING CENTER OF THE HUDSON VALLEY’s Title VI Coordinator to identify strategies to meet the language needs of the participants of the program or service.

B7. Minority Representation on Advisory Boards

INDEPENDENT LIVING CENTER OF THE HUDSON VALLEY has no transit-related, non-elected committees or advisory councils.

B8. Recordkeeping and Reporting

INDEPENDENT LIVING CENTER OF THE HUDSON VALLEY maintains records related to the agency’s implementation of Title VI program, including records of the Title VI Plan adoption and approval (see section B5), records of Title VI staff training, public involvement activities, complaints, investigations, language assistance services and other implementation activities.

INDEPENDENT LIVING CENTER OF THE HUDSON VALLEY shall update the Title VI Plan, every three years and submit the plan to the New York State Department of Transportation (NYSDOT) for approval.

B9. Plan and Policy Review

The Title VI policy will be disseminated to employees through training at new employee orientation and every time the plan is updated. The INDEPENDENT LIVING CENTER OF THE HUDSON VALLEY will review its Title VI Plan at least once every three years to determine if modifications are necessary. The INDEPENDENT LIVING CENTER OF THE HUDSON VALLEY directly operates services and will review implementation annually to ensure compliance with Title VI Plan requirements. The agency’s review includes verifying that all employees have received ongoing updates, training, and a copy of the Title VI policies and that all postings are in place and in good condition.

Title VI Plan Monitoring – Activity Log

Date	Activity (Review-Update-Addendum- Adoption-Distribution)	Person Responsible	Remarks
October 20, 2022	Adopted and distributed	Denise Figueroa	Verified intake materials, postings. Verified all employees received Title VI training and copies of Title VI policy.
October 20, 2023	Review of implementation	Denise Figueroa	Verified all new employees received training and copies of Title VI policy.
October 20, 2024	Review of Implementation	Denise Figueroa	Verified all new employees received training and copies of Title VI policy.
October 20, 2025	Review of Implementation	Denise Figueroa	Verified all employees received training and copies of Title VI policy. Verified intake materials, postings.

Program Monitoring

The INDEPENDENT LIVING CENTER OF THE HUDSON VALLEY will monitor the effectiveness of the Title VI program through the feedback from clientele, employees, general public and other agencies (NYSDOT, FTA). INDEPENDENT LIVING CENTER OF THE HUDSON VALLEY seeks opportunities to continuously improve its Title VI plan, public participation outreach efforts and providing meaningful access of our services to LEP individuals.

B10. Facility Location Equity Analysis

As a subrecipient of federal funds, INDEPENDENT LIVING CENTER OF THE HUDSON VALLEY understands we are required to conduct a Title VI equity analysis when planning to acquire land to construct a new transportation facility or expand an existing facility to ensure the location is selected without regard to race, color, or national origin. The facility includes storage facilities, maintenance facilities, and operations centers, but it does not include bus shelters, transit stations, or power substations. The equity analysis requirement applies even to land acquired to construct a new facility that do not receive direct federal funding (as long as INDEPENDENT LIVING CENTER OF THE HUDSON VALLEY receives federal financial assistance, Title VI requirements apply to all programs and activities). The equity analysis compares the equity impacts of various siting alternatives and must occur during the planning phase, prior to the selection of the preferred site, and must include the following:

A description of the outreach to persons potentially impacted.
A comparison of equity impacts of various siting alternatives.
An analysis about whether a disparate impact occurs on the basis of race, color or national origin (including potential cumulative adverse impacts from other facilities with similar impacts in the area) because of the location and construction of a facility. (If there is a disparate impact, the construction of the facility may only occur if there is a substantial legitimate justification, there are no alternative locations that would have a less disparate impact, and it is not a pretext for discrimination).

For any land acquired to construct a new facility INDEPENDENT LIVING CENTER OF THE HUDSON VALLEY will work with NYSDOT to ensure that the equity analysis is completed and submitted to NYSDOT. The equity analysis will be provided upon request to NYSDOT, FTA and during the triennial review.

The below is intended to provide direction to the reader as to whether INDEPENDENT LIVING CENTER OF THE HUDSON VALLEY was required to, completed, and included a Title VI equity analysis with this Title VI Plan update.

Did INDEPENDENT LIVING CENTER OF THE HUDSON VALLEY acquire land to construct a transportation facility in the past three years?

☒ No. INDEPENDENT LIVING CENTER OF THE HUDSON VALLEY has not acquire land to constructed a transportation facility.

☐ Yes. INDEPENDENT LIVING CENTER OF THE HUDSON VALLEY did acquire land to construct, a new transportation facility and completed a Title VI equity analysis to compare the equity impacts of various siting alternatives.

Does INDEPENDENT LIVING CENTER OF THE HUDSON VALLEY plan to acquire land to construct a new transportation facility in the next three years? (check the box next to the appropriate response below)

☒ No. INDEPENDENT LIVING CENTER OF THE HUDSON VALLEY does not plan to acquire land to construct a new transportation facility.

☐ Yes. INDEPENDENT LIVING CENTER OF THE HUDSON VALLEY plans to acquire land to construct a new transportation facility.

If yes, was a Title VI equity analysis completed?

☐ Yes. A Title VI equity analysis was completed. A copy of the analysis is included as Appendix X.

☐ No. A Title VI equity analysis was not completed.

If no, when will the Title VI equity analysis be completed?

C. List of Appendices

Documentation of Board Approval
Title VI Complaint Form
Letter Acknowledging Receipt of Title VI Complaint
Title VI Complaint Letter of Closure
Title VI Complaint Letter of Finding
Title VI Notice to the Public

APPENDIX 1: Documentation of Board Approval

INDEPENDENT LIVING CENTER OF THE HUDSON VALLEY Title VI Plan Board Approval

On behalf of the Independent Living Center of the Hudson
Valley, we the Board have reviewed and adopted the INDEPENDENT LIVING CENTER OF THE HUDSON VALLEY Title VI plan. We the Board are committed to ensuring that all decisions are made in accordance with the adopted Title VI plan, to that end no person is excluded from participation in, denied the benefits of, or otherwise be subjected to discrimination under any INDEPENDENT LIVING CENTER OF THE HUDSON VALLEY services and activities based on race, color or national origin, as protected by Title VI of the Civil Rights Act of 1964 and Federal Transit law under Title 49 Part 21.

Effective:	July 14, 2026
Adopted:	July 14, 2026
*Adopted By:*	Board of Directors of the Independent Living Center of the Hudson Valley, Inc.
*Revised:*	INSERT DATE IF APPLICABLE
*Adopted By:*	NAME OF BOARD OR APPROPRIATE GOVERNING ENTITY OR OFFICIALS

APPENDIX 2: Title VI Complaint Form

INDEPENDENT LIVING CENTER OF THE HUDSON VALLEY Title VI and ADA Complaint Form

Section I:
Your Name:
Address:
Telephone (Home):		Telephone (Work/Mobile):
Email Address:
Accessible Format Requirements?	Large Print		Audio Tape
	TDD		Other
Section II:
Are you filing this complaint on your own behalf?				Yes*	No
*If you answered “yes” to this question, go to Section III.
If not, please supply the name and relationship of the person for whom you are complaining:
Please explain why you have filed for a third party:

Please confirm that you have obtained the permission of the aggrieved party if you are filing on behalf of a third party.				Yes		No
Section III:
I believe the discrimination I experienced was based on (check all that apply): ☐ Race ☐ Color ☐ National Origin ☐ Disability Date of Alleged Discrimination (Month, Day, Year): _____________ Independent Living Center of the Hudson Valley complaint is against: ______________________________________________ Location of where the alleged discrimination occurred:- _____________________________________ 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 attach additional pages. ____________________________________________________________________________________ ____________________________________________________________________________________ ____________________________________________________________________________________ ____________________________________________________________________________________ ____________________________________________________________________________________ ____________________________________________________________________________________

Section IV

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:

☐ Federal Court: ☐ State Agency:

☐ State Court: ☐ Local Agency:

Provide information for the contact person at the agency/court where the complaint was filed.

Name and Title:

Agency:

Address:

Telephone:

You may attach any written materials or other information that you think is relevant to your complaint.

Signature and date required below.

_____________________________________ ________________________

Signature Date

Please submit this form by mail, email or in person to the address below.

INDEPENDENT LIVING CENTER OF THE HUDSON VALLEY
Simeon Goldman, Esq.

Title VI/ADA Coordinator

15-17 Third St

Troy, NY 12180

sgoldman@ilchv.org

This complaint may also be filed directly with the New York State Department of Transportation, Office of Civil Rights, 50 Wolf Road, 6th Floor, Albany, NY 12232, (518) 457-1129 Fax (518) 549-1273, OCR-TitleVI@dot.ny.gov or the Federal Transit Administration, Office of Civil Rights, Attention: Title VI Program Coordinator, East Building, 5th Floor-TCR, 1200 New Jersey Ave., SE Washington, DC, 20590.

APPENDIX 3: Letter Acknowledging Receipt
of Complaint

Date

Name

Address

City, State Zip

Dear Name:

This letter is to acknowledge receipt of your Title VI complaint against INDEPENDENT LIVING CENTER OF THE HUDSON VALLEY alleging _______________________________________________________________.

An investigation will begin shortly. If you have additional information you wish to convey or questions concerning this matter, please feel free to contact this office by contacting our office at (518) 274-0701 or in writing to INDEPENDENT LIVING CENTER OF THE HUDSON VALLEY, 15-17 Third St., Troy, NY 12180 or email: sgoldman@ilchv.org.

Sincerely,

Simeon Goldman, Esq.

Title VI Coordinator

15-17 Third St., Troy, NY 12180

(518) 274-0701

APPENDIX 4: Title VI Complaint Letter of Closure

Date

Name

Address

City, State Zip

Dear Name:

The matter referenced in your Title VI complaint dated __________________ against INDEPENDENT LIVING CENTER OF THE HUDSON VALLEY alleging ________________________________________________ has been investigated. The results of the investigation did not indicate that the provisions of Title VI of the Civil Rights Act of 1964, had in fact been violated. As you know Title VI prohibits discrimination based on race, color, or national origin in any program receiving federal financial assistance.

INDEPENDENT LIVING CENTER OF THE HUDSON VALLEY has analyzed the materials and facts pertaining to your case. There was no evidence identified that a violation of your Title VI rights was denied. I therefore advise you that your complaint was not substantiated and that I am closing the matter in our files.

You have the right to 1) provide additional information to this office for reconsideration of your complaint within seven (7) calendar days of receipt of this final written decision and/or 2) file a complaint externally with the Federal Transit Administration at:

Federal Transit Administration Office of Civil Rights Attention: Title VI Program Coordinator East Building, 5th Floor- TCR 1200 New Jersey Ave., SE Washington DC 20590

Thank you for taking the time to contact us. If I can be of assistance to you in the future, do not hesitate to call me.

Sincerely,

Simeon Goldman, Esq.

Title VI Coordinator

15-17 Third St., Troy, NY 12180

(518) 274-0701

APPENDIX 5: Title VI Complaint Letter of Finding

Date

Name

Address

City, State Zip

Dear Name:

The matter referenced in your letter dated _________________ against INDEPENDENT LIVING CENTER OF THE HUDSON VALLEY alleging Title VI violation has been investigated. The investigation determined non-compliance by INDEPENDENT LIVING CENTER OF THE HUDSON VALLEY in administering the Title VI obligations of nondiscrimination in the programs and services we administer. Immediate efforts are underway to correct the findings.

Thank you for bringing this important matter to our attention. You were extremely helpful during our review of the program to correct our implementation of the Title VI Program. If I can be of assistance to you in the future, do not hesitate to call me at ___________.

Sincerely,

Simeon Goldman, Esq.

Title VI Coordinator

Independent Living Center of the Hudson Valley

15-17 Third St. Troy, NY 12180

(518) 274-0701

APPENDIX 6: Title VI Notice to the Public

Notifying the Public of Rights under Title VI and the ADA

INDEPENDENT LIVING CENTER OF THE HUDSON VALLEY

The INDEPENDENT LIVING CENTER OF THE HUDSON VALLEY operates its programs and services without regard to race, color, and national origin, in accordance with Title VI of the Civil Rights Act of 1964, and for persons with disabilities under the Americans with Disabilities Act of 1990. Any person who believes they have been aggrieved by any unlawful discriminatory practice under Title VI or the ADA may file a complaint with the INDEPENDENT LIVING CENTER OF THE HUDSON VALLEY.

For more information on the INDEPENDENT LIVING CENTER OF THE HUDSON VALLEY’s program, and the obligations and procedures to file a complaint, contact Simeon Goldman, Esq. at 518-274-0701; email sgoldman@ilchv.org; or visit our office at INDEPENDENT LIVING CENTER OF THE HUDSON VALLEY, 15-17 Third St., Troy, NY 12180. For more information on how to contact INDEPENDENT LIVING CENTER OF THE HUDSON VALLEY to find out about Title VI, visit www.ilchv.org

A complainant may file a complaint directly with INDEPENDENT LIVING CENTER OF THE HUDSON VALLEY TITLE VI Coordinator by following the INDEPENDENT LIVING CENTER OF THE HUDSON VALLEY complaint procedures also found on the agency’s website. A complaint can also be filed with the New York State Department of Transportation on its Civil Rights website at https://www.dot.ny.gov/main/business-center/civil-rights/title-vi-ej. Finally, a complaint can be filed directly with the Federal Transit Administration Office of Civil Rights, Attention: Title VI Program Coordinator, East Building, 5^th Floor-TCR, 1200 New Jersey Ave., SE Washington, DC, 20590.

If information is needed in another language, contact 518-274-0701.

Si necesita información en otra idioma, por favor contacto 518-274-0701.

[1] DOT LEP guidance https://www.transportation.gov/civil-rights/civil-rights-awareness-enforcement/dots-lep-guidance