1. Civil Rights
FNS Instruction 113-1

2. Civil Rights
Civil Rights instruction is applicable to ALL programs and activities who receive Federal financial assistance, whether those programs and activities are federally funded in whole or not

3. Civil Rights Federal Financial Assistance is:
Anything of value received from the Federal government
Includes cash grants, training, excess computers, loans, property donations and any other goods or services provided with Federal funds
TEFAP and state commodities constitute Federal financial assistance

4. Civil Rights Purpose of Civil Rights training:
Provides guidance and direction to Federal financial recipients and their clients
Explains compliance and enforcement of non-discrimination policies
Promotes fairness and equality of treatment

5. Civil Rights Authority provided through:
Title VI of the Civil Rights Act 1964
Americans with Disability Act
Title IX of the Education Amendments of 1972
Section 504 of the Rehabilitation Act of 1973
Age Discrimination Act of 1975
The Personal Responsibility and Work Opportunity Reconciliation Act of 1996
Food Stamp Act of 1977
Executive Order 13166
USDA Departmental Regulation
7CFR Part 16, Equal Opportunity for Religious Organizations

6. Civil Rights Responsibilities: Training
Compliance with civil right laws, regulations and requirements
Equal treatment for religious organizations
Public Notification and Assurances
Data collection
Complaint Processing
LEP services – providing other language services
Accommodating persons with disabilities
Conflict resolution
Customer Service

7. Civil Rights
Civil Rights Training & Oversight:
Member Agencies

8. Civil Rights Discrimination is prohibited on the basis of: Race Color
National Origin
Sex
Age
Disability
Religious Creed
Political Beliefs

9. Civil Rights Types of Discrimination: Disparate Treatment
Discriminating treatment of an individual or class of people based on a particular belief
Disparate Impact
Rules, policies or guidelines not intended to cause discrimination but exclude a particular class of people
Retaliation
Deliberate discrimination as a response or revenge

10. Civil Rights Exceptions:
Congress can establish a program that is intended for certain groups of people, and it is not discrimination to exclude those who do not meet eligibility requirements
Examples: WIC, senior programs, children’s programs, etc.

11. Civil Rights When Do Civil Rights Rules Apply?
Any time there is any Federal financial assistance
USDA/TEFAP commodities
State commodities
Any training, equipment and other goods and services supported or assisted through Federal assistance

12. Civil Rights Requirements: Treat all people with dignity and respect
Complaints do come to the Foodbank
Display the USDA “And Justice for All . . .” non-discrimination poster in a place where it can be seen by ALL who visit the premises

13. Civil Rights

14. Civil Rights Requirements:
Include USDA non-discrimination statement on all materials and websites that mention USDA funded programs
Provide public notification including:
Posted hours of operation
Program eligibility guidelines
Non-discrimination policy
Procedures to file a complaint

15. Civil Rights Requirements: Maintain confidentiality
No social security numbers
Do not discuss a person’s situation
Collect data when appropriate
USDA/TEFAP Eligibility Form – Form can not be modified or other items attached
Monthly Reporting Form

16. Civil Rights Requirements: Cooperate with State and Federal reviewers
If there is a non-compliance issue, correction of problem is expected
Failure to comply with civil rights rules can lead to loss of Federal financial assistance
Agencies may have to pay back value of the food
Sexual harassment is prohibited

17. Civil Rights Requirements: Advise people on how to file a complaint:
Toll Free: or (TTY)
Regional Director, Civil Rights/EEO W. Jackson Blvd, FL Chicago IL

18. Civil Rights Other Requirements:
Make sure people with disabilities are accommodated
Physical or mental impairment that substantially limits one or more major life activities. Disabilities are not specifically named under the ADA but include mobility, sight, hearing, etc.
Provide other language assistance to persons with Limited English Proficiency

19. Civil Rights Limited English Proficiency:
An LEP individual is a person who is unable to speak, read, write or understand the English language at a level that permits him or her to interact effectively with health and social services agencies and providers
Must provide language assistance
that results in accurate and effective communication
at no cost

20. Civil Rights Language Assistance:
Does not require applicants/clients to:
use family or friends as interpreters
use minor children as interpreters
Must NOT be required to disclose
Proof of immigration/citizenship
Social Security Number

21. Civil Rights Equal Opportunity For Religious Organizations:
Prohibits discrimination on the basis of religion, religious belief, or religious character in the administration of Federal funds.
Provided that direct USDA funds do not support any inherently religious activities such as worship or religious instruction.

22. Civil Rights Equal Opportunity For Religious Organizations
Religious organizations do NOT have to remove religious art, icons, scriptures or other religious symbols.
No organization that receives direct financial assistance from the USDA can discriminate against a program beneficiary on the basis of religion or religious belief.

23. Civil Rights Reminders: If conflicts occur, remain calm
Follow the platinum rule
Treat people the way they would like to be treated

24. Civil Rights Final Steps:
Agencies are responsible for training of their staff and/or volunteers
Use the provided Checklist in your agency
Retain each Checklist for 3 years
Complete and Sign the 2nd Checklist with Your Name and Agency
Pass completed Checklists to the front

25. Civil Rights
Questions?