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Title VI & Civil Rights Requirements for FTA Subrecipients

The Division of Transit & Rail (DTR) is the CDOT division responsible for managing funds from the Federal Transit Administration (FTA). These funds are used for the planning, development, operation, and integration of transit and rail into the statewide transportation system. The Civil Rights & Business Resource Center works with the DTR to implement and monitor compliance with FTA's civil rights requirements. 

Title VI of the Civil Rights Act of 1964 

Title VI of the Civil Rights Act of 1964 and related statutes prohibit discrimination on the basis of race, color, national origin, sex, and age in any federally-assisted program and activity. These statutes apply to the Division of Transit & Rail and organizations or municipalities (referred to as subrecipients) that receive federal funds through DTR. 

Subrecipients must develop a Title VI program that complies with  FTA Circular 4702.1B, “Title VI Requirements and Guidelines for Federal Transit Administration Recipients.” Subrecipients must submit Title VI plans to CDOT on a schedule to be determined by DTR and CDOT civil rights staff. Please refer to this FTA subrecipient Title VI guidance and template for helpful information in creating or updating a Title VI plan.

Americans with Disabilities Act

The Americans with Disabilities Act (ADA) prohibits discrimination against persons with disabilities and helps to ensure equal access. Subrecipients are subject to various ADA and U.S. Department of Transportation regulations (including 49 CFR parts 27, 37, 38 and 39) depending on the type of subrecipient and funding that it receives. 

For more information, please refer to FTA Circular 4710.1 at https://www.transit.dot.gov/regulations-and-guidance/fta-circulars/americans-disabilities-act-guidance-pdf. You can also find more information for subrecipients at https://www.codot.gov/business/civilrights/ada/local-agency.

Disadvantaged Business Enterprise Program

CDOT’s Division of Transit and Rail has adopted a race-neutral program to meet its DBE tri-annual goal. Therefore, subrecipients of federal funds from CDOT do not need to set DBE goals on contracting opportunities, but must comply with the DBE program and report all DBE participation on contracting opportunities.  

Equal Employment Opportunity

FTA’s Equal Employment Opportunity (EEO) program is designed to prevent discrimination against employees or employment applicants because of race, color, religion, sex, disability, age or national origin. Generally, a subrecipient must submit an EEO program to CDOT if it employs 50 or more transit-related employees and requests or receives capital or operating assistance in excess of $1 million in the previous Federal fiscal year, or requests or receives planning assistance in excess of $250,000 in the previous Federal fiscal year.

For more information, please refer to FTA Circular 4704.1A at https://www.transit.dot.gov/regulations-and-guidance/civil-rights-ada/eeo-circular.

CDOT Compliance Reviews

DTR, in coordination with CDOT civil rights staff, is responsible for conducting compliance reviews of its subrecipients. Part of that review includes a review of the subrecipient’s compliance with civil rights requirements. The review process evaluates how effective the subrecipient is at ensuring nondiscrimination, and could include a site visit, collection of relevant documents, and interviewing employees. Subrecipients should ensure that their policies and procedures remain up-to-date.

Subrecipient Title VI Resources

Federal Transit Administration (FTA)


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