# Title VI Plan Template for Section 5310 Transportation Providers

Canonical URL: https://nemtguide.com/templates/title-vi-plan/ · Updated 2026-10-02

A Title VI plan is the civil rights program a group files with its state DOT when it gets federal transit money through the state, such as Section 5310 vans. Under FTA Circular 4702.1B it holds a public notice, a complaint procedure and form, a complaint list, outreach and language plans, and board approval. Contractors that only drive for a grantee follow the grantee's plan instead.

- A group that receives Section 5310 vans or money through the state files a Title VI plan with the state, on the state's schedule.
- A company that only drives under contract for a grantee files no plan of its own, but must follow the grantee's.
- You may adopt the state DOT's notice, complaint form, and complaint procedure, and you still log and answer your own complaints.
- DOT removed the disparate impact rules from 49 CFR part 21 on June 11, 2026. The notice and complaint duties remain.
- Get your board's approval before you submit, and send the minutes or resolution with the plan.

Title VI of the Civil Rights Act of 1964 bars discrimination based on race, color, or national origin in any program that receives federal money. When your organization gets Section 5310 vans or operating money through the state, the state must show the Federal Transit Administration that you follow those rules, so it asks you for a written Title VI program, usually called a Title VI plan. This template holds each part FTA's circular asks of a small van program, in the circular's order, plus a contractor list and a training record.

## Who needs a Title VI plan

Federal transit money moves in steps, and the step you are on decides what you owe. FTA's circular, C 4702.1B (October 1, 2012), sets three roles:

- **Direct and primary recipients**, such as state DOTs, file their own Title VI programs with FTA every three years and collect plans from the groups they fund.
- **Subrecipients** get money or vehicles passed through from a recipient. They file a Title VI plan with that recipient on the recipient's schedule. A nonprofit or public body with [Section 5310 vans](https://nemtguide.com/guides/section-5310-grants/) is a subrecipient.
- **Contractors and subcontractors** do not prepare or submit a Title VI program. They must follow the program of the recipient they work for, and the recipient is responsible for making sure they do (chapter II, section 6).

So a for-profit company that runs trips under a purchase of service contract follows the grantee's plan and files none of its own. If your [nonprofit arm](https://nemtguide.com/guides/nonprofit-nemt/) receives 5310 vans through the state, it is a subrecipient and needs this plan. The duty lasts as long as the grant: Wisconsin's Cycle 51 guidelines (calendar year 2027) keep grantee duties, including a Title VI plan, in force until WisDOT approves disposal of the vehicle.

Medicaid rides bring a separate set of civil rights rules from the Department of Health and Human Services. Those are covered in the [Section 1557 nondiscrimination notice](https://nemtguide.com/templates/section-1557-nondiscrimination-notice/) template.

## How to use this template

1. **Ask your state DOT transit office for its rules first.** Get its template, due date, and portal. Colorado collects plans on a schedule its transit and civil rights staff set, and Minnesota wants a first submission in its grant system and yearly updates after that.
2. **Decide what to adopt.** A subrecipient may adopt the state's notice, complaint procedure and form, public participation plan, and language plan where they fit its service (chapter III, section 4). If you adopt the state's notice, add a line saying riders may complain directly to you, as Part 2 does.
3. **Fill in Part 1 and name a coordinator,** the person who takes complaints and keeps this plan current.
4. **Work through Part 7 with real numbers.** FTA's circular says the agency that funds you should give you data on the race and English ability of people in your service area (chapter III, section 11). Minnesota offers a language data tool for this.
5. **Fill in only the parts that apply.** Skip Part 8 if you have no advisory committee whose members you choose, and Part 9 if you hire no one to drive for you.
6. **Have your board approve the plan** with the Part 11 resolution, before you submit it.
7. **Submit it, then post it.** Put the notice on your website, in your office where the public goes, and in your vehicles. Put the complaint procedure and form on your website (chapter III, sections 5 and 6).
8. **Keep it alive.** Log every Title VI complaint in Part 5 and your [complaint log](https://nemtguide.com/templates/nemt-complaint-log/), train staff (Part 10), and review the plan on the state's schedule.

## The template

### Part 1: Organization and approval

| Field | Entry |
|---|---|
| Organization name | |
| Address, phone, and website | |
| Title VI coordinator (name, title, phone, email) | |
| Agency that passes you federal money (state DOT or other recipient) | |
| Federal programs and grant numbers (for example, Section 5310 vehicle grant) | |
| Vehicles bought or leased with federal money (number and type) | |
| Service area (counties or cities) | |
| Who rides (older adults, people with disabilities, general public) | |
| Plan period (from and to) | |
| Date approved by the board, and resolution number | |
| Date submitted to the state, and how | |

### Part 2: Notice to the public

> **Your rights under Title VI**
>
> [Organization name] runs its rides and services without regard to race, color, or national origin, as Title VI of the Civil Rights Act of 1964 requires.
>
> If you believe we treated you unfairly because of your race, color, or national origin, you may file a complaint directly with us. You may also file with [state DOT office, address, phone] or with the Federal Transit Administration, Office of Civil Rights, 1200 New Jersey Avenue SE, Washington, DC 20590, phone 888-446-4511.
>
> To learn more about our civil rights duties or how to file a complaint, call [phone] (relay users dial 711), email [email], or visit [office address] during [hours]. Our complaint procedure and form are at [web address].
>
> If you need this information in another language, call [phone].

Print the last line in each language Part 7 says you must cover.

| Where the notice is posted | Languages | Date posted | Date checked |
|---|---|---|---|
| Website (page address) | | | |
| Office lobby or front desk | | | |
| Meeting rooms | | | |
| Inside each vehicle | | | |
| Rider guide or brochure | | | |
| Other | | | |

### Part 3: How to file a complaint

1. **Who may file.** Anyone who believes [organization name] denied them a ride or service, or treated them differently, because of race, color, or national origin. A family member or advocate may file for them with their permission.
2. **When.** Within 180 days of the event.
3. **How.** Fill out the complaint form in Part 4, or send a letter, email, or call. Staff write down a complaint made by phone or in person, read it back, and ask the person to sign it. Help is free for anyone who needs another language or format.
4. **We confirm receipt** in writing within [___] business days and say whether we will investigate.
5. **We investigate** within [___] days. We may ask you for more information. If you do not answer within [___] business days, we may close the case. You may also withdraw it.
6. **We answer in writing.** A closure letter explains why we found no violation. A letter of finding explains what we found and what we will do about it, such as retraining or discipline.
7. **You may appeal** to [title] within [___] days of our letter.
8. **We tell [state DOT]** about each complaint within [___] days, as our grant agreement requires.
9. **No retaliation.** No one will be threatened or punished for complaining or for helping an investigation. We keep the name of the person who complained private except as the investigation needs.
10. **Other places to file.** You may file with [state DOT] or with the Federal Transit Administration at any time.

### Part 4: Complaint form

| Field | Entry |
|---|---|
| Your name | |
| Address | |
| Phone and email | |
| Format you need (large print, audio, relay or TTY, other) | |
| Language you prefer | |
| Are you filing for yourself (yes or no) | |
| If not, the person's name, your relationship, and whether you have their permission | |
| I believe I was treated unfairly because of my (check all that apply): race, color, national origin | |
| Date of the event | |
| Trip, route, or service involved | |
| What happened, and why you believe it was discrimination | |
| Names of the people involved, if known | |
| Witnesses and how to reach them | |
| Have you complained to us about this before (yes or no) | |
| Have you filed this with another agency or a court (which one, contact person) | |
| Signature and date | |
| Office use: date received, received by, case number, date confirmation sent | |

### Part 5: Title VI investigations, lawsuits, and complaints

List only those that allege discrimination because of race, color, or national origin, since your last plan.

| Type (investigation, lawsuit, or complaint) | Date filed | Summary, with the basis claimed | Status | Action taken or final finding |
|---|---|---|---|---|
| | | | | |
| | | | | |
| | | | | |
| | | | | |

### Part 6: Public participation plan

| How you reach riders and the public | Who it reaches | How often | Last done (date and what you learned) |
|---|---|---|---|
| Notice and comment cards in vehicles | | | |
| Rider survey by phone or on paper | | | |
| Visits with senior centers, dialysis social workers, and disability groups | | | |
| Meetings of the local coordinated transportation plan | | | |
| Faith and community groups that serve people who speak other languages | | | |
| Translated flyers or radio notices | | | |
| Phone interviews for riders who do not read or write | | | |

| Field | Entry |
|---|---|
| Groups in your area least likely to be heard, and how you will reach them | |
| Meeting times and places chosen for riders' convenience | |
| Summary of outreach since the last plan | |

### Part 7: Language assistance plan

**7a. Four factor analysis**

| Factor | What you found | Data source and date |
|---|---|---|
| 1. Number or share of people with limited English in your service area, by language | | |
| 2. How often they contact you (calls, intake, rides, complaints) | | |
| 3. How important your service is to them (medical trips, dialysis, food) | | |
| 4. Your budget for language help, and what it costs | | |

**7b. Help by language**

| Language | People with limited English in your area | Vital documents translated (yes or no) | Interpreter (phone or in person) |
|---|---|---|---|
| | | | |
| | | | |
| | | | |

| Field | Entry |
|---|---|
| Vital documents you translate (Title VI notice, complaint form, ride application, rider rules) | |
| Interpreter service and phone number | |
| How a driver gets an interpreter on the road | |
| How riders learn that language help is free | |
| How staff are trained to give language help, and when | |
| How and when you review this plan | |

### Part 8: Planning and advisory committees

Fill in only for a non-elected committee or council whose members you choose.

| Committee | Total members | Members by race | How you invite minority members to join |
|---|---|---|---|
| | | | |
| | | | |

### Part 9: Contractors

| Contractor | Service provided | Title VI clause in contract (yes or no, date) | Notice posted in their vehicles (yes or no) |
|---|---|---|---|
| | | | |
| | | | |

### Part 10: Training record

| Name | Role | Date | Topic and trainer |
|---|---|---|---|
| | | | |
| | | | |
| | | | |

### Part 11: Board approval

> Resolution number [___] of the [board of directors or governing body] of [organization name]
>
> The [board] has reviewed the Title VI plan of [organization name] dated [date], including its notice to the public, complaint procedure and form, list of complaints, public participation plan, and language assistance plan. The [board] approves the plan, names [name, title] as Title VI coordinator, and directs staff to submit it to [state DOT] and to carry it out.
>
> Adopted on [date] by a vote of [___] to [___].
>
> Signed: ______________________ [name, title]  Date: __________
>
> Attest: ______________________ [name, title]  Date: __________

Attach the signed resolution or the meeting minutes to the plan you submit.

## What FTA's circular requires of a subrecipient

Chapter III of Circular 4702.1B lists the general requirements every FTA recipient follows. For a subrecipient that runs no fixed routes, they come down to these.

- **Assurances.** The state collects a signed Title VI assurance from you before it passes on FTA money (chapter III, section 2, under 49 CFR 21.7). Wisconsin has applicants sign its certifications and assurances at application and again at the grant agreement.
- **The notice.** DOT's rule requires recipients to tell riders and the public about their protection under Title VI ([49 CFR 21.9(d)](https://www.ecfr.gov/current/title-49/section-21.9)). FTA's notice must say you run your programs without regard to race, color, or national origin, how to get more information, and how to file a complaint. At a minimum it goes on your website and in the public areas of your office, and FTA encourages vehicles too. The plan lists where it is posted (chapter III, section 5).
- **Complaints.** You need written procedures for investigating and tracking Title VI complaints, and a complaint form that names race, color, and national origin, both on your website (chapter III, section 6, and appendix D).
- **The list.** Keep a list of Title VI investigations, lawsuits, and complaints naming you, with the date filed, the allegation, the status, and what you did (chapter III, section 7).
- **Public participation.** A plan to reach minority and limited English populations, and a summary of what you did since the last plan (chapter III, sections 4 and 8).
- **Language help.** A four factor analysis and a written language plan that describes your riders with limited English, the help you give in each language, how you tell people about it, how staff are trained, and how you update the plan (chapter III, section 9). Vital documents include complaint forms, notices of rights, and applications, such as a paratransit eligibility form.
- **Committees.** If you choose the members of a non-elected planning or advisory body, a table of its members by race and what you do to encourage minority members (chapter III, section 10). DOT's rule still bars denying anyone a seat on such a body because of race, color, or national origin (49 CFR 21.5(b)(1)(vii)).
- **Board approval** before submission, with the resolution or minutes attached (chapter III, section 4).

The circular sets a written translation safe harbor. Translating vital documents for each language group that makes up 5 percent or 1,000 people, whichever is less, of the people you serve or are likely to serve counts as strong evidence that you meet the written translation duty. When a group that reaches 5 percent has fewer than 50 people, you may instead give written notice in that language of the right to a free interpreter (chapter III, section 9).

If you build a garage, maintenance shop, or operations center with FTA money, the circular also asks for a Title VI equity analysis of the site before you choose it (chapter III, section 13). See the next section before you start one.

## What changed in 2025 and 2026

**DOT's disparate impact rules are gone.** On June 11, 2026, DOT removed the parts of its Title VI rule that banned practices with a discriminatory effect, even without discriminatory intent (91 FR 35424). The rule reserved 49 CFR 21.5(b)(2), limited the facility siting rules in 21.5(b)(3) and (d) to choices made with a discriminatory purpose, and removed the affirmative action language in 21.5(b)(7) and (c)(1) and the employment paragraph in 21.5(c)(3). It took effect the day it was published. Intentional discrimination is still barred, and the notice duty in 21.9(d) and the complaint rules in 21.11 did not change.

The rule lists the parts of FTA's circular it calls related to disparate impact: the facility siting equity analysis, service monitoring and service and fare equity analyses for fixed route systems, and the investment analyses states and planning organizations do. DOT said it expects shorter Title VI submissions as a result. As of September 2026, FTA still posts Circular 4702.1B, and its Title VI page (last updated February 13, 2025) still names it, so ask your state DOT which parts it still collects before you drop any.

**The language order changed, the plan did not.** Executive Order 14224, signed March 1, 2025, made English the official language and revoked Executive Order 13166, the order the circular cites for its language rules. The order says it requires no change in the services agencies provide. The Justice Department rescinded its own language guidance for recipients, applicable March 21, 2025, and reminded recipients and subrecipients that denying language help can be evidence of national origin or disability discrimination in some circumstances (90 FR 15721). The circular bases its language plan on DOT's own guidance of December 14, 2005 (70 FR 74087).

States still ask for the language plan. Minnesota's subrecipient checklist includes it as of October 2026, and Connecticut's January 2026 instructions give up to 5 of 100 points to traditional 5310 applicants that show how people with limited English will learn about the service.

## What four state DOTs ask of 5310 subrecipients

States run the review, so their rules decide what you file and when. These four show the range as of October 2026.

| State | What it asks for | When |
|---|---|---|
| Colorado | A Title VI program that follows Circular 4702.1B, with CDOT's subrecipient template as a guide | On a schedule set by CDOT's transit and civil rights staff |
| Minnesota | Notice, complaint procedure and form, complaint list, public involvement and language plans, committee makeup, training proof, board resolution | First in its grant system, then updated every year |
| Wisconsin | Follow all federal civil rights rules, including developing and carrying out a Title VI plan | From application until WisDOT approves disposal of the vehicle |
| Connecticut | Sign off on Title VI compliance with the application, and meet Title VI requirements before the grant agreement | At application, before the agreement is sent |

Colorado's compliance reviews of subrecipients can include a site visit, a document request, and staff interviews. Its page also notes that a separate FTA equal employment opportunity program is generally needed only by a subrecipient with 50 or more transit employees that requested or received more than $1 million in capital or operating help, or more than $250,000 in planning help, in the previous federal fiscal year. A program with fewer than 50 transit employees falls below that line.

If you drive under contract for a public transit agency, you follow that agency's Title VI program as a contractor, and the federal ADA rules for contractors apply to you too. See [ADA paratransit contractor](https://nemtguide.com/guides/ada-paratransit-contractor/).

## Frequently asked questions

### Does a NEMT company that drives for a Section 5310 grantee need its own Title VI plan?

Not if it is only a contractor. FTA's circular says contractors and subcontractors do not prepare or submit Title VI programs, but they must follow the program of the recipient they work for, and the recipient makes sure they do (FTA Circular 4702.1B, chapter II). Expect the grantee to put nondiscrimination clauses in your contract and to ask you to post its notice in your vans.

### Can we use the state DOT's notice and complaint form?

Yes. A subrecipient may adopt the notice, complaint procedure and form, public participation plan, and language plan of the agency that passes it the money, where they fit its service. If you adopt the state's notice, you must still tell riders they can file complaints directly with you (FTA Circular 4702.1B, chapter III). You keep your own list of complaints either way.

### How often do we update the plan?

On the schedule your state sets. FTA has state DOTs and other direct recipients file every three years, and their subrecipients file on whatever schedule the state asks. Minnesota, for example, wants an initial submission in its grant system and yearly updates after that. Update sooner when your service area, languages, or contacts change.

### Do we still need a language assistance plan after the English executive order?

Ask your state DOT, and plan on yes. Executive Order 14224 of March 1, 2025 revoked the order the circular cites for its language rules, but said it requires no change in agency services. FTA's circular still lists a language plan, and Minnesota's subrecipient checklist still asks for one. The Justice Department has reminded recipients and subrecipients that denying language help can be evidence of discrimination in some circumstances.

### How long does someone have to file a Title VI complaint?

A complaint to the U.S. Department of Transportation must be filed within 180 days of the alleged discrimination, unless DOT extends the time (49 CFR 21.11(b)). FTA's sample complaint procedure uses the same 180 days. No one may threaten or punish a person for complaining or for helping an investigation (49 CFR 21.11(e)).

### Who has to approve the plan?

Your board of directors, or the official who makes policy decisions for your organization, before you submit it. Send a copy of the board resolution, the meeting minutes, or similar proof of approval with the plan (FTA Circular 4702.1B, chapter III).

## Official resources

- [FTA Circular 4702.1B, Title VI Requirements and Guidelines (PDF)](https://www.transit.dot.gov/sites/fta.dot.gov/files/docs/FTA_Title_VI_FINAL.pdf)
- [FTA Office of Civil Rights: Title VI page](https://www.transit.dot.gov/title6)
- [eCFR: 49 CFR part 21, DOT's Title VI rules](https://www.ecfr.gov/current/title-49/subtitle-A/part-21)
- [Minnesota DOT: subrecipient Title VI plan template and language data tool](https://www.dot.state.mn.us/civilrights/nondiscrimination-subrecipient-reviews-guidance.html)
- [Colorado DOT: FTA subrecipient Title VI requirements and template](https://www.codot.gov/business/civilrights/fta-subrecipients)