Title VI Plan Template for Section 5310 Transportation Providers

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 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 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 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, 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)). 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.