About

Compliance

SBA Non-Discrimination Compliance Policy

Headwaters School has received a loan pursuant to the Paycheck Protection Program administered by the Small Business Administration (“SBA”).  This policy is intended to demonstrate good faith compliance with the regulations issued by the SBA and by other governmental agencies enforcing the laws that attach to the School due to the School’s receipt of federal financial assistance through the SBA loan.   This policy shall remain in place from the time the School receives the SBA funding until the loan is paid or forgiven.

Compliance

List of 4 items.

  • Non-discrimination, Anti-harassment, Non-retaliation

    The School acknowledges its obligations to prohibit discrimination, harassment, or retaliation on the basis of race, color, national origin, age, sex, disability/handicap, or religion in admission to its educational programs, activities, and services, and in employment opportunities.  Retaliation against an individual for filing a complaint under this policy or participating in the informal or formal resolution is prohibited.
  • Academic and Non-Academic Services for Persons with Disabilities

    The School remains committed to excellence in educational programming and acknowledges its obligation to ensure that no otherwise qualified individual with a disability shall, solely by reason of his/her disability, be excluded from participation in, be denied the benefits of, or be subjected to discrimination under any program or activity receiving federal financial assistance. This includes both academic and non-academic services, such as counseling, extracurricular services, athletics, transportation, health services, recreational activities, clubs, and other activities.  
    The School will also assess its ability to make reasonable accommodations to disabled individuals to permit such persons to participate in and enjoy the benefits of the School’s programs and activities so long as doing so does not fundamentally alter the nature of the School’s program.  Individuals who seek an accommodation should contact Terra Lynch (Section 504), Learning Specialist, t.lynch@headwaters.org, 807 Rio Grande St. Austin, TX 78701, 512-480-8142. 
  • Employment Obligations for Applicants and Employees with Disabilities

    The School acknowledges its obligation under the SBA regulations and laws applicable to recipients of federal financial assistance to prohibit discrimination against any employee or applicant based upon his/her disability.  This obligation extends to all aspects of employment, including the hiring and employment processes.
    The School will also assess its ability to make reasonable accommodations to disabled individuals so long as doing so does not create an undue hardship.  Individuals who seek an accommodation should contact Terra Lynch (Section 504), Learning Specialist, t.lynch@headwaters.org, 807 Rio Grande St. Austin, TX 78701, 512-480-8142. 
  • Facilities Access

    The School acknowledges its obligation under the SBA regulations to operate its programs and activities in existing facilities so they are readily accessible to qualified individuals with disabilities. The location in facilities (or movement of classes, meetings, etc. to other facilities) will be scheduled in a manner that will not knowingly deny a student, employee, parent, or visitor with a disability the opportunity to participate on the same basis as such persons without disabilities. Accommodations may be provided to allow access to educational programming or meetings.

Complaints

List of 7 items.

  • Who may make a complaint?

    A person (student, parent, employee, or applicant) may use this complaint procedure to report a concern or allegation that s/he is being denied an equal opportunity to access the School’s education programs, activities or services, including employment opportunities.
  • Who can a complaint be made to?

    A complaint may be reported to the Compliance Officer, an Administrator, or to a staff member. Any complaint received by an Administrator or staff member shall be promptly reported to a Compliance Officer for handling. 
  • How do you file a complaint?

    A complaint may be made verbally or in writing. The School has an SBA Complaint Form available for those who choose to use it.   

    A complaint may also be filed with the SBA directly by sending a letter to the Administrator, Small Business Administration (SBA), Washington, D.C. 20416.

    Or you can file a complaint with the Department of Education’s Office of Civil Rights (OCR).
    OCR’s electronic complaint form is at the following website:

    You may also email OCR’s
    Discrimination Complaint Form or your own signed letter to ocr@ed.gov. If you write your own letter, please include the information identified above.
  • Are there timelines for filing a complaint?

    Timelines are flexible, but a person with a complaint should try to report it within thirty (30) calendar days after an alleged discriminatory incident.  If the complaint is filed directly with the SBA or OCR, it must be filed within 180 days of the alleged discriminatory action.
  • How long will it take to have a complaint handled?

    While the School will try to handle the complaint as expeditiously as possible, there can be unexpected or unforeseen circumstances that cause delay. Complaints involving a handicap/disability and request for accommodation will be promptly referred to a 504 team for handling. Those complaints that require an investigation will be completed within thirty (30) days of the complaint, if possible. Should more time be required, the Compliance Officer will notify the complainant.
  • Informal complaint process

    This policy provides an individual the option of filing an informal complaint (verbally or in writing), which allows a fuller range of options in facilitating prompt resolution of an issue(s). It is the choice of the individual complaining whether to initially pursue an informal complaint procedure. The Compliance Officer, or his/her designee, shall explore an informal resolution with the complainant, which may involve providing advice to the complainant on how to handle the issue(s) or reviewing this policy with persons involved in the issue. If the matter involves the conduct of another person, an informal resolution could involve a meeting with the complainant and that person provided both individuals agreed. Resolution through this informal procedure will be promptly explored. At any time, the complainant may request to end the informal procedure to move to the formal complaint process.
  • Formal complaint process

    An individual may file a formal complaint (verbally or in writing) under this policy. The complainant may use the SBA Complaint Form that the School can provide or should provide the following information: a statement of the complaint that identifies the issue, provides pertinent facts, identifies those involved, and states what remedy is sought. If complainant does not provide a written statement, the Compliance Officer will prepare a statement for the complainant to review for accuracy after interviewing him/her.
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Policy Clarification

Since it's founding, Headwaters School has had an anti-discrimination policy in place and it will go back into effect after the PPP loan is forgiven. 

Our policy is included in handbooks, as well as part of our admissions and employment webpages. To fully comply with our maintaining our Section 501(c)(3) status for private schools, Headwaters School has also published this policy publically as required by the IRS.

The policies set forth and compliance and investigation procedures are pursuant to the School’s obligations under the terms of its Small Business Administratio (SBA) Paycheck Protection Program (PPP) Loan. These policies will be in effect until the SBA PPP Loan has been satisfied in full and has been fully forgiven.

School Compliance Officers

The School identifies the following individuals to act as its Compliance Officers under this policy:
  • Title IX Compliance OfficerLeslie Hirsch, Director of Human Resources (Title IX), l.hirsch@headwaters.org, 807 Rio Grande St, Austin, TX 78701, 512-480-8142. 
  • Title IX Compliance OfficerPaul Cronin, Director of Studies (Title IX), p.cronin@headwaters.org, 807 Rio Grande St, Austin, TX 78701, 512-480-8142. 
  • Section 504 Compliance Officer: Terra Lynch (Section 504), Learning Specialist, t.lynch@headwaters.org, 807 Rio Grande St. Austin, TX 78701, 512-480-8142. 
The Compliance Officers shall be responsible for coordinating the School’s effort to meet its responsibilities under this policy. The Compliance Officers will receive and investigate any complaints filed under this policy and make recommendations to the Head of School for the prompt and equitable resolution of complaints.  The School will provide its Compliance Officers and staff appropriate training on this policy and their obligations hereunder.


Notice of Non-Discrimination

Based on receipt of federal financial assistance through a Paycheck Protection Program loan administered through the U.S. Small Business Administration (SBA) under the CAREs Act, the School acknowledges its obligation to prohibit discrimination, harassment, or retaliation on the basis of race, color, religion, age, national origin, sex, citizenship status, genetic information, handicap or disability in admissions, access, employment, tuition assistance, educational policies, or other school administered student and employee programs and activities.  Questions regarding the School’s compliance with the application and administration of the School’s nondiscrimination policies should be directed to Leslie Hirsch, Director of Human Resources (Title IX), l.hirsch@headwaters.org, 807 Rio Grande St, Austin, TX 78701, 512-480-8142; Paul Cronin, Director of Studies, (Title IX), p.cronin@headwaters.org, 807 Rio Grande St, Austin, TX 78701, 512-480-8142; or Terra Lynch (Section 504), Learning Specialist, t.lynch@headwaters.org, 807 Rio Grande St. Austin, TX 78701, 512-480-8142, or to the U.S. Department of Education's Office for Civil Rights (OCR) or to the SBA.  Please refer to the School’s SBA Non-Discrimination Compliance Policy on the School’s website for information on how to file complaints with OCR or the SBA.
 
This notice will remain in effect until the School has satisfied and paid off the SBA Paycheck Protection Loan.

Springs Campus

18 months to Pre-K
6305 Menchaca Rd.
Austin, TX 78745
Phone: 512-443-8843

Creek Campus

Elementary School
9607 Brodie Ln.
Austin, TX 78748
Phone: 512-804-2708
Fax: 512-628-4810

River Campus

Middle & High School
807 Rio Grande St.
Austin, TX 78701
Phone: 512-480-8142
Fax: 512-480-0278