VOLUNTARY COMPLIANCE AGREEMENT BETWEEN THE UNITED STATES OF AMERICA AND THE TOWN OF LEWISBORO, NEW YORK

A. POLICIES AND PROCEDURES

5. Within 90 days of the effective date of this Agreement, Lewisboro will distribute the attached Notice ("Attachment A") to all agency heads; publish the Notice on its Internet homepage at http://www.lewisborogov.com (the "Homepage"); and post copies in conspicuous locations in its public buildings.  In addition, Lewisboro will publish the Notice in a newspaper of general circulation serving Lewisboro on two separate occasions approximately 90 days and 180 days after the effective date of this Agreement.  Lewisboro will refresh the posted copies of the Notice and update the ADA Coordinator information contained in the Notice, as necessary, for the life of this Agreement.  Lewisboro will provide copies of this Notice to any person upon request, including in large print format.

6. Within 90 days of the effective date of this Agreement, Lewisboro will assign or hire an employee as the ADA Coordinator for Lewisboro.

7. Within 90 days of the effective date of this Agreement, Lewisboro will adopt the attached ADA Grievance Procedure ("Attachment B").  Lewisboro will distribute the ADA Grievance Procedure to all agency heads, post copies of it in conspicuous locations in its public buildings, and publish it in alternate formats so that they are immediately available upon request.  Lewisboro will refresh the posted copies and update the contact information contained on the ADA Grievance Procedure (including in large print format copies), as necessary, for the life of this Agreement.  Copies (including copies in large print format) will be provided to any person upon request.

8. Within 120 days of the effective date of this Agreement, Lewisboro will amend its employment policies to comply with the regulations of the U.S. Equal Employment Opportunity Commission implementing title I of the ADA, codified at 29 C.F.R. Part 1630. At minimum, those policies will provide that Lewisboro:

   1. will not discriminate on the basis of disability in its hiring or employment practices.

   2. will not ask a job applicant about the existence, nature, or severity of a disability.  Applicants may be asked about their ability to perform specific job functions.  Medical examinations or inquiries may be made, but only after a conditional offer of employment is made and only if required of all applicants for the position.

   3. will make reasonable accommodations for the known physical or mental limitations of a qualified applicant or employee with a disability upon request unless the accommodation would cause an undue hardship on the operation of Lewisboro's business.  If an applicant or an employee requests a reasonable accommodation and the individual's disability and need for the accommodation are not readily apparent or otherwise known, Lewisboro may ask the individual for information necessary to determine if the individual has a disability-related need for the accommodation.

   4. will maintain any employee's medical records separate from personnel files and keep them confidential.

   5. will make an individualized assessment of whether a qualified individual with a disability meets selection criteria for employment decisions. To the extent that Lewisboro's selection criteria have the effect of disqualifying an individual because of disability, those criteria will be job-related and consistent with business necessity.

9. Within 120 days of the effective date of this Agreement, Lewisboro will promulgate and enforce a Town of Lewisboro Police Department's Policy Statement on Effective Communication with People Who are Deaf or Hard of Hearing ("Attachment C") and will distribute to all new police officers a copy of the ADA Guide for Law Enforcement Officers When in Contact with People Who are Deaf or Hard of Hearing, which can be found at: http://www.ada.gov/lawenfcomm.pdf.

10. Lewisboro will report to the U.S. Attorney's Office within 180 days of the effective date of this Agreement the actions it has taken to comply with paragraphs 5 through 9 above.