Bright Star Institute Policies and Assurances

Learn more about our policies and assurances

Advisors are available to answer any questions you may have.

Equal Opportunity

Bright Star Institute is an equal opportunity training provider/employer, and is able to provide auxiliary aids and services upon request to individuals with disabilities.

Every applicant and employee is required to complete our Equal Opportunity Training Lesson here: https://app.mindsmith.ai/learn/cmn3la3v001jilb04bybxokwn

Equal Opportunity Is The Law - English
Equal Opportunity Is The Law - Spanish

1. Equal Opportunity & Non-Discrimination Assurance (§ 38.25: The Promise)

At Bright Star Institute, we believe that everyone deserves an equal shot at success. In accordance with federal law (29 CFR § 38.25), we provide a formal 'Assurance' that we do not discriminate against any applicant, student, or employee. This means that as a recipient of federal financial assistance, we promise that no person will be excluded from our programs, denied benefits, or treated differently based on:

  • Who you are: Race, color, national origin, sex (including pregnancy, childbirth, and related medical conditions, transgender status, and gender identity), age, or disability.
  • What you believe: Religion or political affiliation.

This is our legal and ethical promise to maintain a training environment where everyone is welcome, respected, and given a fair chance to learn and work. Contact the State of Delaware Department of Education, 35 Commerce Way, Suite 1, Dover, DE 19901 with any questions.


2. Duration of Our Commitment (§ 38.26: The Timeline)

At Bright Star Institute, our promise of non-discrimination isn't just a one-time statement; it is a lasting commitment tied to the resources we use to serve you. In accordance with federal regulation 29 CFR § 38.26, our Equal Opportunity (EO) and non-discrimination rules stay in effect for as long as we use federal funds or property to provide training. Specifically, this means:

  • For our Programs & Classes: As long as we are receiving active grant funding to provide your education.
  • For our Technology & Equipment: For as long as we own and use equipment (like computers or software) purchased with those funds.
  • For our Facilities: For as long as any building or space funded by these grants is used to provide training or related services.

WE DO NOT UTILIZE ANY GRANT FUNDS FOR SPECIFIC HARDWARE, SOFTWARE SUBSCRIPTIONS, OR FACILITIES.


3. Transfer of Resources & Property (§ 38.27: The Transfer Rule)

Our dedication to equal opportunity follows the resources we use to train you. In accordance with federal regulation 29 CFR § 38.27, we ensure that the 'no discrimination' rule follows the property. If we ever sell, transfer, or pass along any building, facility, or piece of equipment that was originally paid for with federal grant money, the new owner or user is legally required to:

  • Sign the same promise: They must formally agree to the same non-discrimination standards we uphold.
  • Follow the same rules: They must ensure that those resources are never used in a way that discriminates against students, staff, or the community.

WE HAVE NO BUILDING, FACILITY, OR PIECE OF EQUIPMENT THAT WAS ORIGINALLY PAID FOR WITH FEDERAL GRANT MONEY.


4. Language Access & Support (§ 38.9: The Language Rule)

We believe that language should never be a barrier to professional growth. In accordance with federal law (29 CFR § 38.9), we are committed to providing 'Limited English Proficient' (LEP) individuals with meaningful access to all our programs and services. We take 'reasonable steps' to ensure those who do not speak English well can still use our programs, including providing free, accurate, and timely translations or interpreters and ensuring digital tools include a Babel Notice explaining how to get free help.

BABEL NOTICE
BRIGHT STAR INSTITUTE PROVIDES LANGUAGE ASSISTANCE SERVICES UPON REQUEST. ALL CONTENT ON THIS WEBSITE MAY BE VIEWED BY THE APPLICANT’S PREFERRED LANGUAGE. CLICK THE LANGUAGE BUTTON AND SELECT THE LANGUAGE OF YOUR CHOICE.


5. Reasonable Adjustments (§ 38.14: The Adjustment Rule)

If you have a disability and need a change in our rules or policies to participate fully, we provide 'Reasonable Accommodations.' In accordance with 29 CFR § 38.14, we will make every effort to modify our procedures to support your learning, provided it does not fundamentally alter the nature of the training program or create an 'undue hardship' (significant difficulty or expense).


6. Effective Communication (§ 38.15: The Clear Talk Rule)

We communicate with people with disabilities as effectively as we do with everyone else. In accordance with 29 CFR § 38.15, our digital training and software are designed to work with screen readers, and we provide TTY or relay services for phone communication. Additionally, we take full responsibility for providing qualified interpreters; we will never require a student to bring their own.


7. Programmatic & Physical Accessibility (§ 38.13: The Access Rule)

All Bright Star Institute programs and facilities are accessible. In accordance with 29 CFR § 38.13, this includes Physical Accessibility (buildings are easy to enter and navigate) and Programmatic Accessibility (digital portals, teaching methods, and online simulations are designed so everyone can participate regardless of a disability).


8. Inclusive Learning (§ 38.17: The Integration Rule)

We believe that inclusion is key to a great education. In accordance with federal law (29 CFR § 38.17), we provide all our training and services in the 'most integrated setting appropriate' for each student. This means we do not separate students with disabilities into different classes or locations unless it is absolutely necessary for them to get the same benefit as everyone else.


9. Orientation & Rights (§ 38.39: The Orientation Rule)

Your journey begins with a clear understanding of your protections. In accordance with 29 CFR § 38.39, during any orientation for new students or staff—whether held in person, online, or via video—we include a dedicated discussion about non-discrimination laws. We share this information in languages and formats that ensure every participant fully understands their right to equal opportunity.


10. Auxiliary Aids & Services (§ 38.4(h): The Support Kit)

We provide 'Auxiliary Aids and Services' to ensure effective communication with people who have disabilities. In accordance with 29 CFR § 38.4(h), this includes tools such as qualified sign language interpreters, braille or large-print materials, closed captioning, and assistive listening devices. These are provided at no additional cost to ensure equal participation.


11. Public Notification & The Sharing Rule (§ 38.34 - 38.36)

We ensure that every student, job applicant, and staff member knows their rights. In accordance with 29 CFR § 38.34 - 38.36, we prominently display the official 'Equal Opportunity Is the Law' notice on our website and in our buildings. This notice is a permanent part of every student handbook and digital file, explaining that discrimination is illegal and providing contact info for the Civil Rights Center (CRC).


12. Partner Compliance (§ 38.37: The Partner Rule)

We work closely with the State Governor and local grant offices to ensure consistency. In accordance with 29 CFR § 38.37, we ensure that even smaller service providers and training partners follow the same communication and non-discrimination standards required by larger state agencies.

WE HAVE NO PARTNERSHIPS IN THE DELIVERY OF OUR CERTIFIED PROGRAMS.


13. Marketing Tagline (§ 38.38: The Marketing Rule)

Bright Star Institute is an equal opportunity employer/program. Auxiliary aids and services are available upon request to individuals with disabilities.


14. Proactive Outreach (§ 38.40: The Outreach Rule)

We are proactive in making sure everyone has access to our programs. In accordance with 29 CFR § 38.40, we make 'reasonable efforts' to reach out to diverse groups—including different races, genders, religions, and abilities—through advertising in diverse media and consulting with local community organizations.


15. Our Resolution Process (§ 38.72 - 38.73)

At Bright Star Institute, we take every report of discrimination seriously. In accordance with 29 CFR § 38.72, we follow a strict, state-approved process:

  • Clear Communication: We complete investigations within 90 days and provide a written list of issues being reviewed.
  • Mediation: We offer mediation as a way to settle problems fairly outside of a formal hearing.
  • State Standards: Per § 38.73, we follow the official 'Rulebook' established by the Delaware Department of Labor.

16. Recordkeeping & Privacy (§ 38.41(b)(2): The Recordkeeping Rule)

To ensure our programs remain fair and accessible, we are required by law to collect confidential demographic information, including race, sex, age, and disability status. In accordance with 29 CFR § 38.41(b)(2), we also track 'Limited English Proficiency' (LEP) to ensure our training remains accessible to everyone. This data is kept strictly confidential and used solely for compliance monitoring.


17. Equal Opportunity Officer (§ 38.28 - 38.31: The EO Officer Rule)

If you think that you have been subjected to discrimination under a WIOA Title I–financially assisted program or activity, you may file a complaint within 180 days from the date of the alleged violation with either: the recipient’s Equal Opportunity Officer (or the person whom the recipient has designated for this purpose);

Wanda Holifield
Local Level One Stop Operator Equal Opportunity Officer
Delaware Workforce Development Board
Fox Valley Office Building, 3rd Floor 4425 N. Market Street, Wilmington, DE 19802
E-mail: Wanda.Holifield@Delaware.gov


18. Anti-Harassment & Non-Retaliation (§ 38.10 & § 38.19)

We maintain a training environment defined by respect and safety. In accordance with 29 CFR § 38.10, harassment of any kind—including sexual harassment or harassment based on any protected category—is strictly prohibited and will not be tolerated.

Furthermore, per 29 CFR § 38.19, we strictly prohibit Retaliation. No student or employee will be intimidated, threatened, coerced, or discriminated against for filing a complaint, testifying, or participating in any investigation or hearing related to their rights. We protect your right to speak up without fear of 'payback' or negative consequences.


19. Citizenship & Authorization (§ 38.11: The Citizenship Rule)

At Bright Star Institute, we support a diverse and authorized workforce. In accordance with 29 CFR § 38.11, we do not discriminate based on citizenship status or 'worker status.' As long as an individual is legally authorized to work or participate in training within the United States, they have an equal right to access our programs, benefits, and services without being excluded based on their national origin or citizenship.


LIMITED ENGLISH PROFICIENCY (LEP) PLAN

Organization Name: Bright Star Institute
Designated EO Officer: Patrick C Spada
Effective Date: 2026–2029
Authority: 29 CFR § 38.9; Section 188 of the Workforce Innovation and Opportunity Act (WIOA).


I. POLICY STATEMENT

Our organization is committed to providing meaningful access to all programs, services, and activities for individuals with Limited English Proficiency (LEP). In accordance with 29 CFR § 38.9, we provide oral interpretation and written translation services at no cost to the individual. We ensure that language barriers do not exclude any person from career training, certifications, or essential services.

II. THE FOUR-FACTOR ANALYSIS

To determine the "reasonable steps" required for compliance, we conduct an ongoing assessment based on the following four factors:

  1. Demographics: We track the number or proportion of LEP persons eligible to be served or likely to be encountered in our service areas (including Delaware, New Jersey, and other active regions).
  2. Frequency of Contact: We monitor how often LEP individuals interact with our staff, website, and digital training platforms.
  3. Nature and Importance: We recognize that professional certifications and workforce development are high-priority services that require precise communication for participant success and safety.
  4. Resources and Costs: We balance the need for language services with our available resources, prioritizing the translation of "Vital Documents" to ensure legal and safety compliance.

III. LANGUAGE ASSISTANCE MEASURES

To ensure immediate and effective communication, the following measures are active:

  • Identification of Language Needs: Staff utilize "I Speak" language identification cards and localized signage to help participants identify their primary language at the point of entry.
  • Oral Interpretation: * Bilingual Staff: Where qualified staff are available, they provide direct assistance.
    • Telephonic Interpretation: We maintain access to professional interpretation services for real-time support during training or administrative sessions.
  • Written Translation: * Vital Documents: Applications, consent forms, grievance procedures, and "Equal Opportunity is the Law" notices are translated into languages that meet the "Safe Harbor" threshold (5% or 1,000 persons in the service area).
    • Digital Access: Key program information on our WordPress/LMS platforms is provided in accessible formats.

IV. STAFF TRAINING

The Equal Opportunity (EO) Officer ensures all instructors and administrative staff are trained on:

  • The legal obligation to provide language assistance under § 38.9.
  • The prohibition against requiring an LEP individual to provide their own interpreter (specifically prohibiting the use of minor children as interpreters).
  • How to document the provision of language services in the student record.

V. NOTICE TO LEP PERSONS

We provide notice of the availability of free language assistance through:

  • Multilingual taglines on all recruitment materials, brochures, and flyers.
  • Postings in physical office locations and on the landing pages of our Learning Management System.
  • Inclusion of LEP rights in the initial orientation for all new program participants.

VI. MONITORING AND UPDATES

This plan is reviewed annually by the EO Officer to account for changing demographics and to ensure that interactive training—including gamified e-learning and simulation quizzes—remains accessible to all learners.


Employee Selection Processes and Procedures

Organization: Bright Star Institute
Effective Date: 2026–2029
Governing Authority: 29 CFR § 38.18 (Employment Practices); 29 CFR § 38.40 (Universal Access)


I. Purpose

The purpose of this policy is to ensure that all current employees and applicants for employment are fully informed of the procedures used for selection, promotion, and career advancement. This transparency ensures that our selection processes are based solely on merit and job-related qualifications, free from discrimination.

II. Policy Statement

Bright Star Institute is committed to maintaining a transparent and equitable selection process. All personnel actions, including recruitment, hiring, promotion, and transfer, are conducted in a manner that provides equal opportunity to all qualified individuals regardless of race, color, religion, sex, national origin, age, disability, or political affiliation.

III. Communication of Procedures

To ensure that all employees and applicants are informed of selection processes, the following procedures are implemented:

  1. Job Postings: All internal and external vacancies will be posted with clear, objective job descriptions that outline the required knowledge, skills, and abilities (KSAs).
  2. Access to Information: Information regarding how to apply, the stages of the selection process (e.g., interviews, testing, reference checks), and the criteria for evaluation will be made available to all applicants upon request.
  3. Employee Handbook: Our selection and promotion procedures are detailed in the Employee Handbook, which is provided to every employee during initial orientation.
  4. Orientation and Training New employees will receive a briefing on career advancement opportunities and the specific procedures required to apply for internal promotions.

IV. Selection Criteria

  • Job Relatedness: All selection criteria, including any pre-employment tests or "Simulation Quizzes," must be directly related to the essential functions of the job.
  • Reasonable Accommodation: We provide reasonable accommodations for qualified individuals with disabilities during the application and selection process (e.g., providing alternative formats for testing).
  • Review of Procedures: The Equal Opportunity (EO) Officer will periodically review selection tools and interview protocols to ensure they do not create an adverse impact on any protected group. The Equal Opportunity (EO) Officer will periodically review selection tools and interview protocols to ensure they do not create an adverse impact on any protected group.

V. Notification of Results

Applicants and employees participating in a selection process will be notified of the status of their application in a timely manner. Feedback regarding selection decisions may be provided upon request to help employees understand how to better qualify for future opportunities.

VI. Complaint Procedure

Any employee or applicant who believes that the selection process was not followed or was conducted in a discriminatory manner has the right to file a grievance in accordance with our Equal Opportunity Complaint Processing Procedures.


Reasonable Accommodation for Individuals with Disabilities

Organization: Bright Star Institute
Effective Date: 2026–2029
Governing Authority: 29 CFR § 38.14(a); 29 CFR § 38.18(d); Section 188 of the Workforce Innovation and Opportunity Act (WIOA).

I. Policy Statement

Bright Star Institute is committed to providing equal opportunity in all aspects of employment and training. In accordance with 29 CFR § 38.14(a) and § 38.18(d), we provide reasonable accommodations to qualified individuals with disabilities—including applicants, registrants, employees, and participants—to ensure they have equal access to all aids, benefits, services, and training.

II. Scope of Accommodation

We provide modifications or adjustments to the work or training environment that enable a qualified individual with a disability to:

  • Participate in the application or registration process.
  • Perform the essential functions of a job or successfully complete training programs.
  • Enjoy the same benefits and privileges of employment or training as are enjoyed by similarly situated individuals without disabilities.
  • Our policy ensures physical accessibility by maintaining ADA-compliant entryways, restrooms, and classrooms, while providing adaptive equipment and individualized accommodations to ensure all students can navigate and use our facility safely.
  • We provide programmatic accessibility by offering flexible instructional methods, accessible digital materials, and reasonable accommodations, ensuring all individuals have equal opportunity to participate in and benefit from our training.

III. Interactive Process

When an individual requests an accommodation, or when the need for an accommodation is apparent, our organization engages in a timely, informal interactive process with the individual. The goal of this process is to identify the precise limitations resulting from the disability and potential reasonable accommodations that could overcome those limitations.

IV. Employment Practices (§ 38.18(d))

We ensure that no qualified individual with a disability is denied any employment opportunity (including hiring, promotion, or training) based on the need for a reasonable accommodation. Our selection procedures are reviewed regularly to ensure they do not screen out individuals with disabilities unless the criteria are job-related and consistent with business necessity.

V. Undue Hardship

In accordance with § 38.14(a)(1), we provide all requested accommodations unless it can be demonstrated that the accommodation would cause an undue hardship (significant difficulty or expense). Any denial based on undue hardship will be provided in a written statement to the individual explaining the specific reasons for the decision.

VI. Confidentiality

All medical information obtained during the accommodation process is kept strictly confidential and maintained in separate medical files, apart from the individual’s general personnel or student file.

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