Title VI
McCall’s Chapel School, Inc.
Title VI Program
Date filed with ODOT Office of Mobility and Public Transit Programs:
October 6, 2025
Table of Contents
D. Procedure for Filing a Title VI Complaint 4
F. Language Assistance Plan. 10
H. Subrecipient Assistance. 16
I. Subrecipient Monitoring. 17
J. Equity Analysis of Facilities. 18
A. Introduction
MCCALL’S CHAPEL SCHOOL, INC. agrees to comply with all provisions prohibiting discrimination on the basis of race, color, or national origin of Title VI of the Civil Rights Act of 1964, as amended, 42 U.S.C. 200d et seq., and with U.S. DOT regulations, “Nondiscrimination in Federally-Assisted Programs of the Department of Transportation – Effectuation of Title VI of the Civil Rights Act,” 49 CFR part 21.
MCCALL’S CHAPEL SCHOOL, INC. assures that no person shall, as provided by Federal and State civil rights laws, be excluded from participation in, be denied the benefits of, or be subjected to discrimination under any program or activity. MCCALL’S CHAPEL SCHOOL, INC. further ensures every effort will be made to ensure non-discrimination in all programs and activities, whether those programs and activities are federally funded or not.
MCCALL’S CHAPEL SCHOOL, INC. meets the objectives of the FTA Master Agreement which governs all entities applying for FTA funding, including MCCALL’S CHAPEL SCHOOL, INC. and its third-party contractors by promoting actions that:
A. Ensure that the level and quality of transportation service is provided without regard to race, color, or national origin.
B. Identify and address, as appropriate, disproportionally high and adverse effects of programs and activities on minority populations and low-income populations.
C. Promote the full and fair participation of all affected Title VI populations in transportation decision making.
D. Prevent the denial, reduction, or delay in benefits related to programs and activities that benefit minority populations or low-income populations.
E. Ensure meaningful access to programs and activities by persons with Limited English Proficiency (LEP).
B. Agency Information
1. Mission of MCCALL’S CHAPEL SCHOOL, INC.
McCall’s Chapel to provide life-changing supports to the residents of McCall’s Chapel so they may live independent, well-adjusted and happy lives in the manner of their own, self-informed choosing.
2. History (including year started)
In 1951 a local minister’s wife was asked to assist a local family in teaching life and skills to a young member of their family with intellectual disabilities. She began her life’s mission of teaching and habilitating children who had disabilities in a normalized, home- like manner. In 1954 she and her husband purchased an abandoned school building and incorporated McCall’s Chapel School to accommodate the needs of four additional children. By 1968, the number of individuals receiving services from McCall’s had grown to 46 children and adults. In 1970, McCall’s continued expansion by purchasing 196 acres adjoining and the current campus was complete by the end of 1975. Today, McCall’s serves 328 adults with intellectual disabilities, including 148 clients who live on our main campus and 180 who live in the greater Ada and surrounding areas.
3. Regional Profile (regional population; growth projection)
Ada Oklahoma’s population in 2023, the last census was 16,536 and projections to show a slight increase with estimates reaching around 17,000 by 2026 and continue to grow moderately to 18,000 by 2035
4. Population served (in relation to regional population)
McCall’s serves individuals with intellectual disabilities (and other disabilities) in a rural area with highly limited public transportation which do not adequately meet the requirements of this special need population. McCall’s Chapel School provides all clients with all transportation as needed.
5. Service area (include map, with any routes utilized)
McCall’s service area will be the greater Ada Oklahoma area, Pontotoc county and adjoining counties with distances to Durant, Duncan, Shawnee and Oklahoma City.
6. Governing body make-up (include terms of office)
McCall’s is governed by a Board of Directors composed of community leaders, relatives and guardians of McCall’s clients. McCall’s President/ CEO reports directly to the board.
C. Notice to the Public
NOTIFYING the PUBLIC of RIGHTS UNDER TITLE VI
McCall’s Chapel School, Inc.
· McCall’s Chapel School, Inc. operates its programs 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 McCall’s Chapel School, Inc.
· For more information on the McCall’s civil rights program, and procedures to file a complaint, contact McCall’s Human Resources department at 580-272-6600; tardery@mccallschapelschool.com; or visit our administrative office at 13546 CR 3600 Ada OK 74820.
· A complainant may file a complaint directly with the Oklahoma Department of Transportation by filing a complaint with the Contract Compliance Division, Attention: Contract Compliance Division Manager, 200 NE 21st Street, Oklahoma City, OK 73105-3204.
· If information is needed in another language contact: tardery@mccallschapelschool.com
*LIST OF LOCATIONS
- Administration building, Cottages 1-15, group homes, and current vehicle fleet, and website www.mccallschapelschool.org
D. Procedure for Filing a Title VI Complaint
Filing a Title VI Complaint
The complaint procedures apply to the beneficiaries of MCCALL’S CHAPEL SCHOOL, INC.’s programs, activities, and services.
RIGHT TO FILE A COMPLAINT: Any person who believes they have been discriminated against on the basis of race, color, or national origin by MCCALL’S CHAPEL SCHOOL, INC. may file a Title VI complaint by completing and submitting the agency’s Title VI Complaint Form. Title VI complaints must be received in writing within 180 days of the alleged discriminatory complaint.
HOW TO FILE A COMPLAINT: Information on how to file a Title VI complaint is posted on our agency’s website, www.mccallschapelschool.org and in public areas of our agency.
You may request a copy in person, in writing or calling to:
McCall’s Chapel School, Inc.
Attn: Human Resources Department
13546 CR 3600
Ada, OK 74820
580-272-6600
tardery@mccallschapelschool.com
You may file a signed, dated complaint no more than 180 days from the date of the alleged incident. The complaint should include:
· Your name, address and telephone number.
· Specific, detailed information (how, why and when) about the alleged act of discrimination.
· Any other relevant information, including the names of any persons, if known, the agency should contact for clarity of the allegations.
Please submit your complaint form to McCall’s Chapel School, Inc.
COMPLAINT ACCEPTANCE: MCCALL’S CHAPEL SCHOOL, INC. will process complaints that are complete.
Once a completed Title VI Complaint Form is received, MCCALL’S CHAPEL SCHOOL, INC. will review it to determine MCCALL’S CHAPEL SCHOOL, INC. has jurisdiction. The complainant will receive an acknowledgement letter informing them whether or not the complaint will be investigated by MCCALL’S CHAPEL SCHOOL, INC.
INVESTIGATIONS: MCCALL’S CHAPEL SCHOOL, INC. will generally complete an investigation within 90 days from receipt of a completed complaint form. If more information is needed to resolve the case, MCCALL’S CHAPEL SCHOOL, INC. TITLE VI COORDINATOR may contact the complainant. Unless a longer period is specified by MCCALL’S CHAPEL SCHOOL, INC. TITLE VI COORDINATOR, the complainant will have ten (10) days from the date of the letter to send requested information to MCCALL’S CHAPEL SCHOOL, INC. investigator assigned to the case.
If the requested information is not received within that timeframe the case will be closed. Also, a case can be administratively closed if the complainant no longer wishes to pursue the case.
LETTERS OF CLOSURE OR FINDING: After the Title VI investigator reviews the complaint, the Title VI investigator will issue one of two letters to the complainant: a closure letter or 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 provides an explanation of the corrective action taken.
If the complainant disagrees with MCCALL’S CHAPEL SCHOOL, INC.’s determination, the complainant may request reconsideration by submitting the request in writing to the Title VI investigator within seven (7) days after the date of the letter of closure or letter of finding, stating with specificity the basis for the reconsideration. MCCALL’S CHAPEL SCHOOL, INC. will notify the complainant of the decision either to accept or reject the request for reconsideration within ten (10) days. In cases where reconsideration is granted, MCCALL’S CHAPEL SCHOOL, INC. will issue a determination letter to the complainant upon completion of the reconsideration review.
A person may also file a complaint directly with the Federal Transit Administration, at the FTA Office of Civil Rights, 1200 New Jersey Avenue SE, Washington, DC 20590.
If information is needed in another language, contact MCCALL’S CHAPEL SCHOOL, INC. Human Resources Director, Tawny Ardery at 580-272-6600.
E. Monitoring Title VI Complaints, Investigations, Lawsuits and Documenting Evidence of Agency Staff Title VI Training
Documenting Title VI Complaints/Investigations
All Title VI complaints will be entered and tracked in MCCALL’S CHAPEL SCHOOL, INC.’s complaint log. Active investigations will be monitored for timely response on the part of all parties. The agency’s Title VI Coordinator shall maintain the log.
Agency Title VI Complaint Log
Date complaint filed
Complainant
Basis of complaint R-C-NO
Summary of allegation
Pending status of complaint
Actions taken
Closure Letter (CL)
Letter of Finding (LOF)
Date of CL or LOF
Documenting Evidence of Agency Staff Title VI Training
MCCALL’S CHAPEL SCHOOL, INC.’s staff receive specialized training and certification in habilitation service and management (DDDCA – Developmentally Disabled Direct Care Aide; and CN – Certified Nursing Assistant) which provides the given Title VI training, and agency can answer affirmatively to all the following questions:
1. Are new employees made aware of Title VI responsibilities pertaining to their specific duties?
2. Do new employees receive this information via employee orientation?
3. Is Title VI information provided to all employees and program applicants?
4. Is Title VI information prominently displayed in the agency and on any program materials distributed, as necessary?
Public Participation Plan
Goal
The goal of the Public Participation Plan is to have significant and ongoing public involvement, by all identified audiences, in the public participation process for major agency outreach efforts.
Objectives
· To understand the service area demographics and determine what non-English languages and other cultural barriers exist to public participation.
· To provide general notification of meetings and forums for public input, in a manner that is understandable to all populations in the area.
· To hold public meetings in locations that are accessible to all area stakeholders, including but not limited to minority and low-income members of the community.
· To provide methods for two-way communication and information and input from populations which are less likely to attend meetings.
· To convey the information in various formats to reach all key stakeholder groups.
Identification of Stakeholders
Stakeholders are those who are either directly or indirectly affected by an outreach effort, system or service plan or recommendations of that plan. Stakeholders include but are not limited to the following:
· Board of Directors – the governing board of the agency. The role of the Board is to establish policy and legislative direction for the agency. The Board defines the agency’s mission, establishes goals, and approves then budget to accomplish the goals.
· Advisory Bodies – non-elected advisory bodies review current and proposed activities of the agency, and are encouraged to be active in the agency’s public participation process. Advisory bodies provide insight and feedback to the agency.
· Agency Transit riders and clients
· Minority and low-income populations, including limited English proficient persons
· Local jurisdictions and other government stakeholders
· Private businesses and organizations
· Employers
· Partner agencies
Elements of the Public Participationt Plan
It is necessary to establish a public participation plan that includes an outreach plan to engage minority and limited English proficient (LEP) populations.
Elements of the Public Engagement Plan include:
1. Public Notice
a. Official notification of intent to provide opportunity for members of the general public to participate in public engagement plan development, including participation in open Board/council meetings, and advisory committees.
2. Public Engagement Process/Outreach Efforts:
a. Public meetings
b. Open houses
c. Rider forums
d. Rider outreach
e. Public hearings
f. Focus groups
g. Surveys
h. Services for the Disabled (Notices of opportunities for public involvement include contact information for people needing these or other special accommodations.)
Events such as public meetings and/or open houses are held at schools, churches, libraries and other non-profit locations easily accessible to public transit and compliant with the Americans with Disabilities Act.
3. Public Comment
a. Formal public comment periods are used to solicit comments on major public involvement efforts around an agency service or system change.
b. Comments are accepted through various means:
i. Dedicated email address.
ii. Website.
iii. Regular mail.
iv. Forms using survey tool for compilation.
v. Videotaping.
vi. Phone calls to Customer Service Center [phone]
4. Response to Public Input
All public comments are provided to the Board of Directors prior to decision making. A publicly available summary report is compiled, including all individual comments.
Title VI Outreach Best Practices
2025-2026 Title VI Program Public Participation Process
McCall’s Chapel school, Inc. uses its vehicles to serve the needs of its several hundred clients who have Intellectual / Developmental Disabilities, who live in and around Pontotoc County. We do not attempt to serve the needs of the general population, as this would create competition in our rural demographic. Therefore, McCall’s will abide by all regulations of Title VI, while we will not have a formal public participation plan.
MCCALL’S CHAPEL SCHOOL, INC. has provided briefings to the Board of Directors.
MCCALL’S CHAPEL SCHOOL, INC. will ensure all outreach strategies, communications and public involvement efforts comply with Title VI. Aligned with the above referenced communication tactics, MCCALL’S CHAPEL SCHOOL, INC. would provide the following (if applicable):
a. Public notices published in non-English publications (if available).
b. Title VI non-discrimination notice on agency’s website.
c. Agency communication materials in languages other than English (subject to Safe Harbor parameters).
d. Services for Limited English Proficient persons. Upon advance notice, translators may be provided.
F. Language Assistance Plan
MCCALL’S CHAPEL SCHOOL, INC. Limited English Proficiency Plan
MCCALL’S CHAPEL SCHOOL, INC. has only had one LEP client since 2011. We are meeting her needs by developing her English proficiency aided by several staff who are bilingual and are her full-time direct care team. Should McCall’s approach the 5% threshold of the LEPs in our overall population, we will develop a formal LEP program.
The limited English Proficiency (LEP) Plan will be prepared to address MCCALL’S CHAPEL SCHOOL, INC. ‘s responsibilities as a recipient of federal financial assistance as they relate to the needs of individuals with limited language skills, if the threshold is reached. The plan would be prepared in accordance with Title VI of the Civil Rights Act of 1964; Federal Transit Administration Circular 4702.1B, dated October 1, 2012, which states that the level and quality of transportation service is provided without regard to race, color, or national origin.
Executive order 13166, titled “Improving Access to Services for Persons with Limited English
Proficiency,” indicates that differing treatment based upon a person's inability to speak, read, write or understand English is a type of national origin discrimination. It directs each federal agency to publish guidance for its respective recipients clarifying their obligation to ensure that such discriminations do not take place. This order applies to all state and local agencies which receive federal funds.
Service Area Description:
Pontotoc County – all of Ada city limits. Outlying areas within the county will include Allen, Byng, Fitzhugh, Francis, Latta, Pickett, Roff and Stonewall.
In order to prepare this plan, if needed, MCCALL’S CHAPEL SCHOOL, INC. would use the four-factor LEP analysis which considers the following factors:
Four Factor Analysis
1. The number and proportion of LEP persons eligible to be served or likely to be encountered in the service area:
A significant majority of people in the MCCALL’S CHAPEL SCHOOL, INC. service area are proficient in the English language. Based on 2010 Census data, 5.1% of the population five years of age and older speak English “less than very well” – a definition of limited English proficiency
LEP Population in MCCALL’S CHAPEL SCHOOL, INC. Service Area
Population 5 years and over by language spoken at home and ability to speak English
Service Area Sector [1]
Service Area Sector [1]
Service Area Sector [1]
Service Area Total
Percentage of Population 5 Years and Older
Population 5 Years and Over
58%
Speak English “less than very well”
Spanish
6%
Speak English “less than very well”
Other Indo-European
0
Speak English “less than very well”
Asian and Pacific Island
1%
Speak English “less than very well”
All Other
0
Speak English “less than very well”
2. Frequency of Contact by LEP Persons with MCCALL’S CHAPEL SCHOOL, INC.’s Services:
The MCCALL’S CHAPEL SCHOOL, INC. staff reviewed the frequency with which office staff, dispatchers and drivers have, or could have, contact with LEP persons. To date, MCCALL’S CHAPEL SCHOOL, INC. has does not have a need for an interpreter. MCCALL’S CHAPEL SCHOOL, INC. averages 0 phone calls per month.
LEP Staff Survey Form
MCCALL’S CHAPEL SCHOOL, INC. is studying the language assistance needs of its riders so that we can better communicate with them if needed.
1. How often do you come into contact with passengers who do not speak English or have trouble understanding you when you speak English to them?
DAILY WEEKLY MONTHLY LESS THAN MONTHLY
2. What languages do these passengers speak?
3. What languages (other than English) do you understand or speak?
4. Would you be willing to serve as a translator when needed?
Frequency of Contact with LEP Persons
Frequency
Language Spoken by LEP Persons
Daily
Weekly
Monthly
Less frequently than monthly
3. The importance of programs, activities or services provided by MCCALL’S CHAPEL SCHOOL, INC. to LEP persons:
Outreach activities, summarized in MCCALL’S CHAPEL SCHOOL, INC.’s Title VI Public Engagement Plan, include events such as public meetings and/or open houses held at schools, churches, libraries and other non-profit locations, and include specific outreach to LEP persons to gain understanding of the needs of the LEP population, and the manner (if at all) needs are addressed.
Outside Organization LEP Survey
Organization: __________________
1. What language assistance needs are encountered?
2. What languages are spoken by persons with language assistance needs?
3. What language assistance efforts are you undertaking to assist persons with language assistance needs?
4. When necessary, can we use these services?
4. The resources available to MCCALL’S CHAPEL SCHOOL, INC. and overall cost to provide LEP assistance:
Strategies for Engaging Individuals with Limited English Proficiency include:
1. Language line. Upon advance notice, translators can be provided.
2. Language identification flashcards.
3. Written translations of vital documents (identified via safe harbor provision)
4. One-on-one assistance through outreach efforts.
5. Website information.
6. To the extent feasible, assign bilingual staff for community events, public hearings and Board of Directors meetings and on the customer service phone lines.
As applicable: Based on our demographic analysis (Factor 1) MCCALL’S CHAPEL SCHOOL, INC. has determined that no language group(s) within its service area meets Safe Harbor criteria requiring written translated “vital documents” by language group(s).
MCCALL’S CHAPEL SCHOOL, INC. will provide assistance and direction to LEP persons who request assistance and will develop a formal LEP at that time.
Staff LEP Training
The following training will be provided to MCCALL’S CHAPEL SCHOOL, INC. staff upon the formal LEP program:
1. Information on MCCALL’S CHAPEL SCHOOL, INC. Title VI Procedures and LEP responsibilities.
2. Description of language assistance services offered to the client(s).
3. Use of Language Identification Flashcards.
4. Documentation of language assistance requests.
Monitoring and Updating the LEP Plan
The LEP Plan is a component of MCCALL’S CHAPEL SCHOOL, INC.’s Title VI Plan requirement.
MCCALL’S CHAPEL SCHOOL, INC. will update the LEP plan as required. At minimum, the plan will be reviewed and updated when it is clear that higher concentrations of LEP individuals are present in the MCCALL’S CHAPEL SCHOOL, INC. service area. Updates include the following:
1. How the needs of LEP persons have been addressed.
2. Determine the current LEP population in the service area.
3. Determine as to whether the need for, and/or extent of, translation services has changed.
4. Determine whether local language assistance programs have been effective and sufficient to meet the needs.
5. Determine whether MCCALL’S CHAPEL SCHOOL, INC.’s financial resources are sufficient to fund language assistance resources as needed.
6. Determine whether MCCALL’S CHAPEL SCHOOL, INC. has fully complied with the goals of this LEP Plan.
7. Determine whether complaints have been received concerning MCCALL’S CHAPEL SCHOOL, INC.’s failure to meet the needs of LEP individual.
G. Advisory Bodies
McCall’s Chapel School does not have any transit- related planning boards, advisory councils, committees or similar bodies, the membership of which is selected by McCall’s, outside of its corporate structure. Should McCall’s ever institute such committees, we will report the racial makeup of such committees at that time.
Table Depicting Membership of Committees, Councils, By Race
Committee [examples]
Caucasian
Latino
African American
Asian American
Total
Population Committee
100%
Access Committee
100%
Citizens Advisory Council
100%
H. Subrecipient Assistance
MCCALL’S CHAPEL SCHOOL, INC. does not have any subrecipients.
I. Subrecipient Monitoring
MCCALL’S CHAPEL SCHOOL, INC. does not have any subrecipients.
J. Equity Analysis of Facilities
MCCALL’S CHAPEL SCHOOL, INC. has not constructed any storage facilities, maintenance facilities, or operations centers in the last three years.
ATTACHMENTS:
TITLE VI COMPLAINT FORM –
The McCall’s Chapel School, Inc., is committed to ensuring that no person is excluded from participation in or denied the benefits of its services on the basis of race, color, or national origin, as provided by the Title VI of the Civil Rights Act of 1964, as amended. The Title VI complaints must be filed within 180 calendar days from the date of the alleged discrimination.
Date of Filing: Name: Address:
City, State, Zip Code: Work Phone:
Home Phone:
E-mail Address:
McCall’s Chapel School, Inc.
13546 CR 3600
Ada OK 74820
Phone: (580) 272-6600
Indicate on what ground(s) you believe you have been discriminated against (check all that apply):
Race
Color
National Origin
Indicate the person(s) who you believe discriminated against you:
Name(s):
Work Location (if known):
Work Phone:
Date of alleged incident
If you have an attorney representing you concerning the matters raised in this complaint, please provide the following:
Name: Address: Work Phone:
E-mail Address:
Explain why you believe discrimination has occurred. If there are witnesses, please provide names, addresses and telephone numbers. Be sure to include how other persons were treated differently than you. Attach additional pages as necessary and any written material pertaining to your case.
What remedy are you requesting? Please be specific:
Have you filed or do you intend to file a charge or complaint concerning the matters raised in this complaint with any other agencies (Federal, State, or local):
Yes No
If so, please provide the following information:
Agency:
Address:
Name of Investigator (if known): Phone Number:
E-mail Address:
Date Filed:
Status of case:
I confirm that I have read the above charge(s) and it is true to the best of my knowledge.
Print or typed name of complainant:
Signature Date
Completed forms must be submitted to the McCall’s Chapel School, Inc.
If you require any assistance in filling out this form please contact the McCall’s Chapel School, Inc. Title VI Coordinator at
580-272-6600.
The McCall’s Chapel School, Inc. ensures that no person or groups of persons shall, on the grounds of race, color, sex, religion, national origin, age, disability, retaliation or genetic information, be excluded from participation in, be denied the benefits of, or be otherwise subjected to discrimination under any and all programs, services, or activities administered by McCall’s Chapel School, Inc. To request an accommodation please contact the McCall’s Chapel School, Inc. ADA Coordinator at 580-272-6600.