Human Services Council

Transportation Services

Title VI Policy and Procedures

Title VI of the Civil Rights Act of 1964 prohibits discrimination on the basis of race, color and national origin in programs and activities receiving Federal financial assistance.

The Human Services Council’s Transportation Services is committed to ensuring that no person is excluded from participation in, or denied the benefitsof safe and reliable transportation services on the basis of race, color or national origin, as protected by the Title VI in Federal Transit Administration (FTA Circular 4702.1.A). HSC operates all programs without regard to race, color or national origin.

Title VI Policy Statement: The Human Services Council (HSC) will ensure that their programs, policies, Bylaws and activities all comply with Health Care Authority (HCA), Washington State Department of Transportation (WSDOT) and/or the Federal Transit Administration Title VI regulations and complaint process.The Human Services Council is committed to creating and maintaining transportation services that are free from all forms of discrimination.HSC will take appropriate measures to prevent discrimination based on (but not limited to) an individual’s race, color, and national origin. Appropriate corrective and/or disciplinary action will be taken to address behavior that violates this policy and the rights and privileges it is designed to protect. If you believe you have been subjected to discrimination under Title VI, you may file a complaint as outlined below.

Your Comments Are Welcome!

Please let us know how things are working for you. We do a better job when we know what you need. Each compliment is shared with the employees or contractor involved. Each suggestion or complaint is investigated.

If you would like a copy of the complete Title VI Policy and Procedures you may request that information using one of the methods listed below.

Reasonable Access for Limited English Proficiency (LEP) Individuals

HSC is committed to providing equal access to all individuals. Our Transportation Call Center has access to two contracted language providers and bi-lingual staff to assist in arranging transportation for LEP clients. HSC tracks primary non-English languages spoken within HSC’s service region through census data, caller and community partner statistics and public outreach in order to support services for LEP clients. HSC posts and distributes transportation brochures and complaint procedures in these primary languages, as well as in English.

You can contact our Transportation Services in the following ways:

  1. Phone line:
  • From within Clark County, Customers can contact Employment or Reserve-A-Ride Transportation at: 360-258-2103 and Non-Emergency Medical Transportation at 360-694-9997.
  • From outside Clark County, our Transportation Department can be reached toll free at 800-752-9422.
  1. Fax: Written feedback can be sent by fax to 360-694-1446.
  2. Language Line: For customers who speak a language other than English, Transportation Services will utilize the services of a Language Line to facilitate the call or provide assistance utilizing the skills of bi-lingual employees. For customers who are deaf or hearing impaired, HSC uses the Telecommunications Relay Service at 1-800-833-6388 or 711.
  3. US Mail: Customers can mail their feedback to Human Services Council/Transportation Services at: 120 NE 136th Avenue, Suite 215, Vancouver, WA 98684.
  4. Web-Site: Customers can offer feedback through an e-mail link on the Human Services Council Web-site by visiting Transportation Services at:

How to file a comment or complaint:

Information and forms about the Customer Comment Process, including how to submit a complaint, will be made available:

  1. When customers are approved for transportation services.
  2. On the HSC website.
  3. Upon request

*Complaints must be filed within 180 days of the date of alleged incident/occurrence.

The following information may be helpful when filing a complaint:

  1. How, when, where and why you believe you were discriminated against.
  2. Details of the incident including date, time, location and contact information of any witnesses
  3. Your name, mailing address and preferred method of contact for follow up purposes
  4. Any other pertinent information
  5. If the complaint is against one of the HSC’s contracted transportation provides the following information will also be needed:
  6. Transportation Company Name
  7. Vehicle Number
  8. Driver’s Name

Note: HSC encourages complaints to be sent via certified mail that is sent through the U.S. Postal Service and/or ensure that written correspondence can be easily tracked.

Feedback/Complaint Review Process:

All feedback from customers is valued and will be reviewed by Transportation Services. After review, customer communication will be distributed to the appropriate HSC representative for investigation.

  1. Customer concerns, complaints, or compliments will be forwarded to the appropriate transportation staff for follow-up.
  2. Questions regarding Title VI complaints of discrimination or bias including: race, color, and/or national origin will be sent to the Transportation Services Manager for investigation.
  3. HSC will follow any additional complaint requirements of grantor or public funding source as specified by contract.

Feedback/Complaint Acknowledgement:

Complaints received by HSC Transportation Services are documented and assigned to the appropriate transportation staff for investigation. When legible contact information is provided, a response will be sent to the person filing the complaint within seven (7) business days. HSC maintains a tracking system for feedback from customers that provides a unique identification number for each complaint.

Anonymous Comments/Complaints:

If you wish, you may make a comment or complaint without providing HSC with your name or contact information. When a complaint is filed anonymously, we will investigate the complaint, but no follow-up response will be provided to the person filing the complaint.

Protection from Retribution:

Customers of HSC Transportation Services can submit feedback without fear of retribution from the agency. If a customer believes they have been treated unfairly in response to the feedback or a complaint they submitted, they should contact the HSC Transportation Services Manager at (360) 735-5741. HSC will appropriately address any retaliatory behavior by an HSC employee or contractor.

Customer Appeals Process: Any person who is dissatisfied with the response they receive from HSC Transportation is welcome to appeal the decision; a team of transportation staff/professionals will review

Customer appeals.

Customer’s accessing HSC Transportation Services funded by Washington State Department of Transportation have the right to file a complaint or lawsuit with one of the following organizations:

Organization Name and Address
Washington State Department of Transportation
Public Transportation Division
Attn: Title VI Coordinator
P O Box 47387
Olympia, WA 98504-47387 / Federal Transit Administration
Attn: Title VI Program Coordinator
East Building, 5th Floor – TCR
1200 New Jersey Ave, SE
Washington, DC 20590 / U.S. Department of Justice
Civil Rights Division
Coordination and Review Section - NWB
950 Pennsylvania Avenue, NW
Washington, DC 20530

Complaint Tracking

HSC will track the all complaints, including the following required information:

  • Type of complaint, investigation, or lawsuit
  • Date of complaint, investigation, or lawsuit
  • A summary of the allegation(s)
  • The status of the complaint, investigation, or lawsuit
  • Actions taken in response to the complaint, investigation, or lawsuit

All information must be tracked until the complaint, investigation, or lawsuit has been closed. The records will then be stored according to state and federal record retention requirements. Tracked information will be reported to WSDOT as the grantor of the funds as required in the WSDOT “Guide to Managing your Public Transportation Grants”.

FOUR FACTOR ANALYSIS FOR TITLE VI POLICY

HSC staff will receive a copy of this policy and be trained annually on best practices, statistics and any legal, policy or program updates pertaining to the provision of service to LEP clients. Employees will have regular opportunities to discuss questions, concerns or issues surrounding services for LEP clients with their supervisor, coworkers, and/or Transportation Services Manager.

HSC will identify the LEP individuals eligible for transportation services or likely to be encountered in these programs through the following methods:

  • Call center staff will track client languages spoken including whether those individuals speak English “well”, “not well” or “not at all”, as well as where the client lives in relation to transit stops/stations
  • HSC community partners will track this same information during their direct contact with clients accessing transportation services and; HSC will include this client information to its tracking and reporting systems
  • HSC will review census and local demographic information to determine concentrations of LEP individuals in the service area and will identify and meet with community partners to identify transportation needs for the core LEP individuals identified and provide information regarding transportation services offered by HSC

Through direct client contact, use of interpreter services and census data gathering HSC currently identifies Spanish as the primary non-English spoken languages in two of the counties served. 2010 Clark County statistics indicated 7.6% persons of Hispanic or Latino origin and 14% of households speak languages other than English. In Cowlitz County statistics indicated 7.7% persons of Hispanic or Latino origin and 7.4% of households speak languages other than English. In Wahkiakum County 5.2% of the households speak languages other than English. Direct calls across all transportation services provided by HSC that required translation services or that were handled by bi-lingual screening staff averaged 23 per month.

HSC staff track client languages spoken based on their direct experience in arranging services or providing information regarding transportation options and census information, as well as documented information regarding primary languages and ethnicity provided by partner agencies who screen clients on HSC’s behalf. Those statistics including primary language, number of clients, resources used for interpretation and costs of resources are tracked on a monthly basis.

HSC also partners closely with local social service and government agencies in screening clients for eligibility and referring for services. HSC tracks the number of LEP clients referred through our partner agencies by using a referral form that requests primary language information. HSC then tracks that information on its database for clients receiving services.

HSC operates several volunteer programs. Through those programs schools, local non-profits and low-income individuals are served through the use of volunteers. With these strong connections to local community partners who provide direct services to LEP clients, HSC staff and volunteers are able to educate these agencies regarding the core transportation and interpreter services provided by HSC.

HSC reviews the most current U.S. Census data to determine demographics in the region served by HSC.

In addition to outreach with social service, non-profit and government agencies within each county served, HSC also participates in variety of diversity events allowing staff to connect directly with representatives of, and for, various ethnic populations to better understand the culture, needs and concerns of those populations.

When procuring vendors to provide direct or other services for, or on behalf of the Agency, HSC advertises its interest in recruiting Minority and Women Owned Businesses and utilizes information gathered from the State of Washington Office of Women’s Business Enterprises (OMWBE) to target its procurement announcements to identified business. During annual meetings with HSC subcontracted vendors, information and forms are provided to subcontractors regarding how to become a registered business and be listed on the OMWBE website.

HSC provides three core services to the counties served: 1) transportation brokering, 2) volunteer services and 3) veterans services. These programs are offered to Medicaid eligible clients, low-income, seniors, individuals with disabilities, veterans, at-risk populations and the general community for our volunteer programs. HSC operates other transportation programs that serve low-income individuals seeking employment and seniors and individuals with disabilities in accessing medical services as well as basic services beyond medical care.

Because these services provide support so that all individuals can have access to anything from basic to life sustaining medical care it is imperative that HSC communicates its ability to serve LEP clients in a number of ways. HSC does so by providing a description of services on its website, translates brochures in the primary languages spoken within the region served, hires bi-lingual staff that reflects the demographics of the community, and engages community partners in sharing information regarding these services with their LEP clients.

On a bi-annual basis, HSC will survey LEP clients directly and will enlist the support of its community partners in surveying LEP clients that utilize HSC services, but do not necessarily come in regular contact with HSC or its staff. The goal of the survey will be to gather input from the LEP population on the usefulness of the forms, publications and website content and any suggestions for improvement.

FinalTitle VI Policy & Procedures4-17/CK1