HomeMy WebLinkAboutA021 - Resolution approving Agreement between Ames Human Relations Commission and Iowa Office of Civil Rights regarding intake and investigation of Civil Rights ComplaintsITEM #:24
DATE:10-13-26
DEPT:ADMIN
SUBJECT:COOPERATIVE AGREEMENT BETWEEN AMES HUMAN RELATIONS
COMMISSION AND IOWA OFFICE OF CIVIL RIGHTS
COUNCIL ACTION FORM
BACKGROUND:
The City, on behalf of the Ames Human Relations Commission (AHRC), has regularly
contracted with the Iowa Office of Civil Rights (IOCR) to manage the intake and resolution of
civil rights complaints. Under this agreement, IOCR pays the City a set amount for each
complaint form sent to the IOCR (see agreement attached). The agreement allows the
City to use these resources to assist complainants with obtaining and filling out
complaint forms and ensuring they are complete and valid.
In FY 2025/26, staff assisted in completing two discrimination complaints. The City received a
total of $500 for assisting with completing these two discrimination complaints and sending
them to the IOCR for investigation.
IOCR has presented a new agreement for the fiscal year ending June 30, 2027. Due to the
short turnaround time set by the IOCR to sign the agreement, the City requested and received
an extension for additional time for Council to review this agreement and to make a decision at
this meeting. The AHRC has reviewed this agreement and recommends City Council
approval.
ALTERNATIVES:
1. Approve the cooperative agreement between the Ames Human Relations Commission
and Iowa Office of Civil Rights.
2. Do not approve the agreement.
CITY MANAGER'S RECOMMENDED ACTION:
This agreement outlines that IOCR will investigate and resolve civil rights
discrimination complaints. Additionally, IOCR will compensate the City for acting as the
intake agent under this agreement.
The City, AHRC, and IOCR have maintained this arrangement for several years.
Transferring this time-consuming investigation responsibility to the IOCR will allow the
AHRC to focus on connecting and supporting all communities in Ames . Therefore, it is
the recommendation of the City Manager that the City Council adopt Alternative No. 1, as
described above.
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ATTACHMENT(S):
Cooperative Agreement DRAFT 26-27.pdf
FY 27 Letter from Director Stiffler.docx.pdf
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COOPERATIVE AGREEMENT
Between _____
&
IOWA OFFICE OF CIVIL RIGHTS
1. Definitions: As used in this Cooperative Ag reement the following ter ms are defined as
follows:
a) “IOCR” means the Iowa Office of Civil Rights.
b) “Local agency” means the _____ and must comply with the requirements of Iowa
Code §216.19.
c) “Fiscal Year 2027” r uns from July 1, 2026 to June 30, 2027.
d) “Initial Filing Date” means the local agency file-stamp receipt date shown on the
complaint. All complaints must show a local file-stamp receipt date or some other
marker which clearly indicates the date that the complaint was received by the local
commission. Credit will be rejected for complaints without a date stamp or
some other marker indicating the complaint receipt date.
e) “Intake” means receipt by the IOCR of a completed, signed, jurisdictional
complaint for m in any area covered by the ICRA, that is forwarded by the local
agency to the IOCR for processing and investigation.
f) “Resolutions” means case closures resulting in final local agency action, including
administrative closures; conciliated and settled cases; satisfactor y adjustments; no
probable cause deter minations, and closures after public hearing.
2. Authority: In order to effectuate the purposes of the “Iowa Civil Rights Act,” (ICRA) the
IOCR now enters into a Cooperative Agreement with the ______. Iowa Code §216.19.
3. Scope: Under this Cooperative Ag reement, IOCR contracts with the _____ for the
satisfactor y intake and resolution of complaints whose allegations fall within the
prohibitions of Iowa Code §§ 216.6, 216.6A, 216.7, 216.8, 216.8A, 216.8B, 216.8C, 216.9,
216.10, 216.11, and 216.11A. This Cooperative Agreement does not cover complaints that
address allegations outside of these sections of the Iowa Code.
4. Timeliness: This contract recognizes the 300-day filing period for initial complaints, as set
forth in Iowa Code Ch. 216, is deter mined by the day the complaint is recei ved by the
IOCR, NOT the day received by the local commission. Therefore, local commissions are
responsible for ensuring that cases are received by the IOCR within 300 days of the
date of the last incident of discrimination in order to preser ve the Complainant’s rights
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under the ICRA. There should be no expectation of reimbursement for complaints received
by the IOCR after the 300-day filing period.
5. Jurisdiction: Any and all complaints submitted for credit and payment must be a
jurisdictional complaint under the Iowa Civil Rights Act.
6. Transmittal: Submissions for credit must be made via email to icrc@iowa.g ov, unless
another transmittal option is approved by the Executive Director of the IOCR or designee.
7. Period: This Cooperative Ag reement will run during Fiscal Year 2027. There is no
commitment on the part of IOCR to contract with the _______ for the resolution of
complaints after June 30, 2027.
8. Total Amount: The IOCR shall not spend more than $30,000 as ag gregate compensation
to all contracting local commissions for work perfor med under cooperative agreements for
Fiscal Year 2027. If insufficient funds exist for payment of all cases tendered for payment by
the contracting local agencies, payment shall be allocated on a first-come, first-ser ved basis.
9. Payment Date: IOCR agrees to provide payment on an annual basis based upon
satisfaction of the conditions established in this agreement. Payment will be provided for
work perfor med and accepted under this Ag reement by the IOCR, and for cases cross-filed
with the EEOC or HUD, when credit has been approved by that funding agency (IOCR,
EEOC, or HUD). In the case of payment for intake ser vices, IOCR accepts the work
if/when IOCR opens the complaint file corresponding to the intake. Payment is
conditioned upon execution of this contract which must be accomplished and returned to
the IOCR no later than 9/30/26. Ag reements presented after that date will be rejected by
the IOCR absent approval for late submission by the Executive Director of the IOCR, or
designee.
10. Payment Schedule***:
(a) Intakes: See attached Schedule A for breakdown of reimbursement rates based on
the timing of receipt of the complaint for housing and non-housing referrals to the
IOCR.
(b) Resolutions: See Schedule A (attached) for definitions and rate of payment based on
timing of receipt of the complaint closure documentation.
11. Maintenance of Effor t: Iowa Code §216.19(2) provides that a city with a population of
29,000 or greater may maintain an independent local civil/human rights agency, shall
str ucture and adequately fund the local human/civil rights agency in order to effect
cooperative undertakings with IOCR and to aid in effectuating the purposes of the “Iowa
Civil Rights Act,” and when staff is provided, the local agency or commission shall have
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control over such staff. The IOCR reser ves the right to deny payment for closures which
appear to have been adversely affected by a failure to comply with this code section or any
other reasonable indication of lack of independence or neutrality by the local agency in its
investigation of the complaint, and such may ser ve as grounds justifying ter mination of this
agreement.
12. Infor mation Sharing: The filing of a complaint or confidential infor mation pertaining to a
complaint covered by this agreement may be shared between the parties to this agreement as
part of the routine investigation of such complaints, to administer the prog ram for which the
infor mation is collected.
13. Confidentiality: Pursuant to Iowa Code Section 216.15(5), the ______ agrees not to
disclose the filing of a complaint or confidential infor mation pertaining to a complaint
covered by this agreement until the complaint has been officially set for public hearing. Once
a complaint has been officially set for public hearing, the ______ agrees not to disclose
confidential infor mation pertaining to the complaint that is not publicly available, except as
allowed by IOCR’s r ules.
14. Repor ts: The local agency agrees to submit the annual report provided within the invoice
template, listing each intake and resolution submitted for contract credit or payment under
this Agreement. The annual report is due July 3, 2027, for July 1, 2026 - June 30, 2027
activity. Payments under this contract will be made after the annual report is completed,
submitted to the IOCR, and verified to meet the conditions described above. Failure to
provide the annual report may result in forfeiture of funds for the contract year. As a
condition of final payment, the local commission must submit, and IOCR must have
received, all complaints no later than June 30, 2027. Cases submitted after June 30, 2027, will
not be paid.
15. Training: IOCR and the local agency will cooperate in planning, sponsoring, and
conducting necessar y complaint processing training for staff and commissioners.
If required by your local protocol, ordinance or practice, separate signature lines have been provided
for your Mayor and Commission Chair.
Mayor Date
Chair person Date
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Executive Director, Iowa Office of Civil Rights Date
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SCHEDULE A
***The following summarizes the payment schedule.
Intake:
(See definition for
Intake below)
Complaint sent to IOCR for processing
and investigation within 7 days (housing)
or 30 days (non-housing) of initial filing
date with local agency.
$500 for housing cases eligible
for cross-filing with HUD;
$250 for employment cases
eligible for cross-filing with
EEOC;
$125 for cases not eligible for
cross-filing
Complaint sent to IOCR for processing
and investigation greater than 7 days but
within 30 days (housing); greater than 30
days but within 60 days (non-housing) of
initial filing date with local agency.
$250 for housing cases eligible
for cross-filing with HUD;
$150 for employment cases
eligible for cross-filing with
EEOC;
$75 for cases not eligible for
cross-filing
Complaint sent to IOCR for processing
and investigation greater than 30 days
(housing) or 60 days (non-housing) of
initial filing date with local agency.
$0
Resolutions for
Non-housing Cases:
(See definition for
Resolutions below)
Complaint Resolutions sent to IOCR for
closure processing within 180 days of
initial filing date with local agency.
$325 for cases eligible for
cross-filing with EEOC; $100
for cases not eligible for
cross-filing
Complaint Resolutions sent to IOCR for
closure processing g reater than 180 days
but within 600 days of initial filing date
with local agency.
$200 for cases eligible for
cross-filing with EEOC; $50
for cases not eligible for
cross-filing
Complaint Resolutions sent to IOCR for
closure processing g reater than 600 days
of initial filing date with local agency.
$0
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Fur ther Requirements/Infor mation
General
1. Ever y complaint cross-filed with the IOCR requires the submission of a fully and
accurately completed jurisdictional review for m, as provided by the IOCR. The current
version of this document is attached herein and is also available on the IOCR website. All
data indicated on the jurisdictional review paperwork must be transmitted to the IOCR along
with the intake materials.
2. For any complaint cross-filed with the IOCR, a verified signature from the Complainant is
mandatory. Electronic signatures are per mitted. "Electronic signature" means any digital
symbol, sound, or process attached to or logically associated with a digital record and
executed or adopted by a person with the intent to sign the record.
3. Complaints that have been transfer red to the IOCR for investigation for any reason may
only qualify for Intake credit.
Intakes
1. Ever y submission seeking Intake credit from the IOCR must consist of a fully finalized
complaint for m. Any materials or infor mation transmitted that does not utilize a finalized
for m will be ineligible for such credit.
Resolutions
1. Resolution date shall be the date of receipt of the case closure documentation by the IOCR.
a. Case closure documents means investigative reports, respondent position
statement/responses, settlement agreements, withdrawal documents, failure to
cooperate documentation, closure letters sent to parties.
b. All case closure documents including investigative reports, settlement agreements
and withdrawals, must include local and state case numbers, and when cross-filed
with the EEOC, the federal case number.
c. For complaints that have been cross-filed with the EEOC, closure documentation
must include respondent’s response to the complaint. If there has been a
deter mination of No Probable Cause, a copy of the entire complaint must be
provided to the IOCR as part of the closure documentation.
2. For complaints that have been cross-filed with the EEOC and are being closed because of
the Complainant’s failure to cooperate, the file must include a copy of the letter sent by local
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commission to Complainant at their last known address, which explains why their
cooperation is necessary and that their charge will be closed absent response within 30 days. .
3. If the EEOC refuses credit for a complaint, the IOCR’s payment obligations under this
agreement shall be extinguished.
4. IOCR may be required to obtain a full copy of the case file maintained by the local
commission. Digital copies should be provided to IOCR at no cost and within two weeks
of request, or credit will not be granted.
5. HUD prohibits the IOCR from seeking credit for housing complaints cross-filed with HUD
in the same manner as the EEOC, and any such complaints should be refer red to the IOCR
for investig ation after intake.
6. Settlement ag reements for cross-filed EEOC cases cannot include a no-rehire clause or
global release and must indicate in the ag reement itself that the agreement was signed
voluntarily. These are EEOC requirements that will not be waived by the EEOC and cannot
be waived by the IOCR. Any agreements with language that includes the imper missible
language or that is missing the required EEOC voluntar y settlement language will be rejected
by the IOCR (and EEOC) and no payment will be made until the settlement ag reements are
revised accordingly.
Repor ting
1. Annual reports shall be submitted via email. Following approval of submissions, an invoice
will be prepared by the IOCR and submitted to the Department of Inspections, Appeals,
and Licensing’s financial department for payment.
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KIM REYNOLDS, GOVERNOR KRISTEN STIFFLER, EXECUTIVE DIRECTOR
CHRIS COURNOYER, LT. GOVERNOR
September 11, 2026
Re: FY 2027 Cooperative Agreement Proposals
Dear Director/Chair Person:
Enclosed please find the FY2027 cooperative agreement. While it is largely comparable to last year’s
contract, there are two additions that I would like to highlight:
● For agencies that will be requesting refer ral and/or resolution credit, it is now required
to use a date file stamp or some other marker to clearly indicate the date the complaint
was received by the local commission (Cooperative Agreement, §1(d)).
● Updated language has been added to the contract regarding electronic signatures,
reflecting the current standards on the federal level (Cooperative
Agreement/Infor mation, Further Requirements, General, (2)).
● Clarification regarding requesting credit for complaints transferred to the IOCR for
investigation (Cooperative Agreement/Infor mation, Further Requirements, General,
(3)).
If your agency intends to sign a workshare agreement, we must receive the signed agreement no later
than October 1, 2026. This October deadline should allow sufficient time for your agency to
coordinate and collect the appropriate signatures as required by your local ordinances or city
government. Please contact the office if your city needs additional time to execute the workshare
agreement, and my office will review on a case-by-case basis.
I hope you will consider taking advantage of this program.Those local commissions with direct
agreements with the EEOC and/or HUD will not be eligible for payment by the IOCR if payment
is also received by the EEOC or HUD.
Please do not hesitate to contact my office if you have any questions.
Yours ver y tr uly,
/s/ Kristen Stiffler
Kristen Stiffler
Executive Director
Iowa Office of Civil Rights
6200 Park Avenue, Suite 100
Des Moines, IA 50321
kristen.stiff ler@iowa.gov
6200 Park Avenue, Suite 100, Des Moines, Iowa 50321-1270
515-281-4121 / 1-800-457-4416 / Fax 515-242-5840 10