EEOC Office of Legal Counsel staff members wrote the following letter to respond to a request for public comment from a federal agency or department. This letter is an informal discussion of the noted issue and does not constitute an official opinion of the Commission.
Federal EEO Laws: Strategic Plan for Federal Youth Policy
January 20, 2011
Office of the Assistant Secretary for Planning and Evaluation
U.S. Department of Health and Human Services
200 Independence Ave, SW
Washington, DC 20201
Re: Request for Comments Regarding Strategic Plan for Federal Youth Policy
Dear Ms. Potter:
The Equal Employment Opportunity Commission (EEOC) submits this letter in response to the Department of Health and Human Service’s request for comments on the development of a strategic plan for Federal youth policy. See 75 Fed. Reg. 80054 (Dec. 21, 2010). As described below, we applaud the inclusion of employment in the framework for input on the strategic plan and recommend that equal employment opportunity be added to this section. In addition, we invite the Working Group to add a link to EEOC’s youth web site, www.youth.eeoc.gov, on www.findyouthinfo.gov. Finally, we identify several ways in which youth may assist in the development and dissemination of youth programs.
The EEOC enforces the federal laws that prohibit employment discrimination on the basis of race, color, religion, sex, national origin, age, disability, and genetic information. See Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C. § 2000e et seq.; the Age Discrimination in Employment Act of 1967, as amended, 29 U.S.C. § 621 et seq.; Titles I and V of the Americans with Disabilities Act of 1990, as amended, 42 U.S.C. § 12101 et seq.; the Equal Pay Act of 1963, 29 U.S.C. § 206(d); and Title II of the Genetic Information Nondiscrimination Act, 42 U.S.C. § 2000ff et seq. Further, the EEOC is charged with coordinating and leading the federal government’s efforts to eradicate workplace discrimination.1
On March 11, 2009, Congress passed the Omnibus Appropriations Act, 2009 (Pub. L. 111-8). The House Appropriations Committee Print, Division F—Departments of Labor, Health and Human Services, and Education, and Related Agencies Appropriations Act directed the Interagency Working Group on Youth Programs to, among other things, develop a strategic plan for Federal youth policy. The Working Group developed a framework to assist in the development of the strategic plan.
We commend the Working Group for including employment in the framework. Early work experience provides a foundation for career success and economic self-sufficiency. As a result, it is crucial that teens have a positive first work experience. However, as recent work force entrants, many young adults may be unaware of federal employment discrimination laws and the protections they provide to workers. In addition, young workers may be particularly vulnerable to discrimination by individuals who take advantage of their inexperience, desire to succeed, and reluctance to report problems. Accordingly, we recommend that the Working Group include equal employment opportunity in the employment section of the strategic plan and consider the additional suggestions outlined below.
II. The Working Group Can Improve the Coordination of Youth Programs by Supplementing and Publicizing www.findyouthinfo.gov.
In subpart (d) of Part III of the Federal Register notice, the Working Group requests comments regarding how Federal agencies can improve the coordination, effectiveness, and efficiency of programs affecting youth. To enhance the coordination of youth programs and services, we invite the Working Group to add a link to EEOC’s youth web site, www.youth.eeoc.gov, on www.findyouthinfo.gov.
As part of our outreach efforts, EEOC created a web site, www.youth.eeoc.gov, to educate young adults about their equal employment opportunity rights and responsibilities. The web site explains the different types of job discrimination that young workers may encounter and suggests strategies that they can use to prevent, and, if necessary, respond to such discrimination. The web site includes an interactive tool that allows young workers to analyze sample job discrimination scenarios. The web site also includes examples of EEOC cases involving discrimination of young workers. To ensure that visitors to www.findyouthinfo.gov are aware of this resource, we invite the Working Group to add a link to www.youth.eeoc.gov on www.findyouthinfo.gov. In addition, we would be happy to add a link to www.findyouthinfo.gov on www.youth.eeoc.gov.
The web site created by the Working Group, www.findyouthinfo.gov, is a valuable resource for youth, youth organizations, parents, educators, policy-makers, and other interested parties. Because many young adults rely heavily on social media for entertainment, information, and communication, the Working Group might consider utilizing social media to publicize www.findyouthinfo.gov, share updates, and provide information about upcoming events or opportunities for youth and/or entities that work with youth.2 The Working Group might also consider other cost-effective marketing ideas, such as Ad Council campaigns, to promote the web site among youth and relevant stakeholders.
III. Engaging Young Adults in the Development and Dissemination of Youth Programs and Services Will Enhance the Success of these Efforts.
In subpart (e) of Part III of the Federal Register notice, the Working Group requests comments regarding how youth can be engaged in enhancing the success of programs affecting youth. Based on our experience, including young adults in the creation and distribution of youth-related programs and services improves the content of the product, broadens the marketability of the product, and strengthens the overall effectiveness of the product.
Young adults can play a vital role in the development and dissemination of programs and services related to youth. Youth can help identify issues that may merit additional attention by agencies and stakeholders. Youth can also provide recommendations about how agencies can effectively notify young adults of relevant programs and initiatives. For example, a teen focus group convened by our Phoenix office proposed numerous ideas for reaching youth audiences, including television and radio commercials, movie theater advertisements, use of celebrity spokespeople, educational television broadcasts, and discrimination plot lines on popular television shows.
In addition to identifying issues of interest and proposing communications strategies, young adults can review material intended for their peers and provide insight into the type of content, style, and tone that attracts teens’ attention. For example, the Phoenix teen focus group provided suggestions about outreach techniques that would resonate with their peers, including incorporation of color and graphics in handouts, use of humor in handouts and presentations, and discussion of tips for young adults new to the job market. Similarly, a Washington D.C. teen focus group provided feedback on characteristics of web sites that they frequented, which proved useful in the development of www.youth.eeoc.gov.
Finally, because teenagers may be especially likely to listen to fellow teenagers, agencies might consider enlisting youth to disseminate information to their colleagues. EEOC has worked with young adults to develop videos, public service announcements, presentations, and outreach material for their peers regarding EEOC and equal employment opportunity. EEOC also partnered with the American Society of Newspaper Editors’ High School Journalism Initiative to host a national press conference for high school journalists on discrimination and harassment of young workers.
By collaborating with each other, with youth, and with other interested parties, federal agencies can strengthen the effectiveness and efficiency of youth-related programs and services. Together, we can ensure a brighter future for today’s youth and for future generations.
Thank you for the opportunity to provide these comments. If you have questions or would like to discuss these comments, please feel free to contact Lisa Schnall, Attorney Advisor, at 202-663-4845.
Acting Assistant Legal Counsel
1 Under Executive Order 12067, the EEOC coordinates federal equal employment opportunity regulations, practices and policies. The Executive Order is available on the EEOC web site at: http://www.eeoc.gov/abouteeoc/35th/thelaw/eo-12067.html.
2 Information about government use of social media is available at http://www.usa.gov/webcontent/technology/other_tech.shtml.
This page was last modified on March 7, 2011.
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