Pursuant to Title VI of the Civil Rights Act of 1964, 42 U.S.C. § 2000d et seq., and the
implementing regulations of the United States Department of Health and Human Services (“HHS”) and the United States Department of Labor (“DOL”), Chinese Staff and Workers’ Association (“CSWA”), National Mobilization Against Sweatshops (“NMASS”) and Flushing Workers’ Center (“FWC”)(together, the “Complainants”) submit this complaint against the New York State Department of Health (“NYSDOH”) and New York State Department of Labor (“NYSDOL”) for various policies and practices relating to “live-in” 24-hour home care services that are discriminatory and have caused disproportionate adverse impacts on home care aides and Medicaid consumers of home care services on the basis of their race and national origin.
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