ADA Compliance Policy and Procedures

Note: The core ADA policy and complaint procedures are incorporated into the Bylaws (Article XI, Sections 8 and 9). This standalone document consolidates those provisions with additional operational guidance for staff and Board use.

I. Policy Statement

PROVENIQ Foundation, Inc. is committed to full compliance with the Americans with Disabilities Act (ADA) of 1990, as amended, Section 504 of the Rehabilitation Act of 1973, the West Virginia Human Rights Act, and all applicable federal, state, and local disability rights laws. The Corporation shall not discriminate against any qualified individual with a disability in employment, volunteer service, Board service, programs, services, or activities.

II. ADA Coordinator

• Current Designated Coordinator: CEO (until a separate designee is appointed)
• Contact: [insert email and phone]
• Responsibilities: Oversee ADA compliance, process accommodation requests, investigate complaints, coordinate training, maintain records, and serve as the Corporation’s primary point of contact for disability-related matters.

III. Reasonable Accommodations

Who May Request

Any employee, applicant, volunteer, Board member, contractor, or program participant.

How to Request

Submit a request (verbal or written) to the ADA Coordinator, direct supervisor, or Board Chair.

Interactive Process

Within five (5) business days of receiving a request, the ADA Coordinator shall initiate an interactive process with the individual to identify the nature of the limitation, explore potential accommodations, and determine an effective accommodation. The Corporation is not required to provide the specific accommodation requested but must provide an effective accommodation unless doing so would impose an undue hardship.

Documentation

All requests and resolutions shall be documented in a confidential ADA log maintained by the ADA Coordinator.

IV. Digital Accessibility

All public-facing platforms (MAYDAY, ShelterOS, LifeLog, VetOS, Foundation website) shall comply with WCAG 2.1 Level AA. Digital accessibility shall be incorporated into the development lifecycle. Periodic accessibility audits shall be conducted. Users shall have a mechanism to report accessibility barriers.

V. Complaint Process

Filing a Complaint

• Written complaint to the ADA Coordinator by email, mail, or online form.
• Verbal complaint to the ADA Coordinator, CEO, or Board Chair.
• Anonymous complaint through the confidential reporting channel.
• Third-party complaint by a representative or advocate.

Investigation Timeline

• Acknowledgment within 5 business days.
• Investigation completed within 30 calendar days.
• Written determination with findings and corrective action.
• Appeal to Board Chair or Governance Committee within 15 calendar days of determination.

VI. Non-Retaliation

Retaliation against any individual who requests an accommodation, files a complaint, or participates in an investigation is strictly prohibited and is grounds for discipline up to and including termination or removal from the Board.

VII. External Remedies

Nothing in this policy prevents an individual from filing a complaint with the EEOC, U.S. Department of Justice, West Virginia Human Rights Commission, or any other appropriate agency.

VIII. Annual Review

This policy shall be reviewed annually by the Governance & Nominating Committee. The CEO shall include a de-identified summary of ADA activity in the annual Board report.