2Civil RightsCivil 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
3Civil Rights Federal Financial Assistance is: Anything of value received from the Federal governmentIncludes cash grants, training, excess computers, loans, property donations and any other goods or services provided with Federal fundsTEFAP and state commodities constitute Federal financial assistance
4Civil Rights Purpose of Civil Rights training: Provides guidance and direction to Federal financial recipients and their clientsExplains compliance and enforcement of non-discrimination policiesPromotes fairness and equality of treatment
5Civil Rights Authority provided through: Title VI of the Civil Rights Act 1964Americans with Disability ActTitle IX of the Education Amendments of 1972Section 504 of the Rehabilitation Act of 1973Age Discrimination Act of 1975The Personal Responsibility and Work Opportunity Reconciliation Act of 1996Food Stamp Act of 1977Executive Order 13166USDA Departmental Regulation7CFR Part 16, Equal Opportunity for Religious Organizations
6Civil Rights Responsibilities: Training Compliance with civil right laws, regulations and requirementsEqual treatment for religious organizationsPublic Notification and AssurancesData collectionComplaint ProcessingLEP services – providing other language servicesAccommodating persons with disabilitiesConflict resolutionCustomer Service
7Civil RightsCivil Rights Training & Oversight:Member Agencies
8Civil Rights Discrimination is prohibited on the basis of: Race Color National OriginSexAgeDisabilityReligious CreedPolitical Beliefs
9Civil Rights Types of Discrimination: Disparate Treatment Discriminating treatment of an individual or class of people based on a particular beliefDisparate ImpactRules, policies or guidelines not intended to cause discrimination but exclude a particular class of peopleRetaliationDeliberate discrimination as a response or revenge
10Civil 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 requirementsExamples: WIC, senior programs, children’s programs, etc.
11Civil Rights When Do Civil Rights Rules Apply? Any time there is any Federal financial assistanceUSDA/TEFAP commoditiesState commoditiesAny training, equipment and other goods and services supported or assisted through Federal assistance
12Civil Rights Requirements: Treat all people with dignity and respect Complaints do come to the FoodbankDisplay the USDA “And Justice for All . . .” non-discrimination poster in a place where it can be seen by ALL who visit the premises
14Civil Rights Requirements: Include USDA non-discrimination statement on all materials and websites that mention USDA funded programsProvide public notification including:Posted hours of operationProgram eligibility guidelinesNon-discrimination policyProcedures to file a complaint
15Civil Rights Requirements: Maintain confidentiality No social security numbersDo not discuss a person’s situationCollect data when appropriateUSDA/TEFAP Eligibility Form – Form can not be modified or other items attachedMonthly Reporting Form
16Civil Rights Requirements: Cooperate with State and Federal reviewers If there is a non-compliance issue, correction of problem is expectedFailure to comply with civil rights rules can lead to loss of Federal financial assistanceAgencies may have to pay back value of the foodSexual harassment is prohibited
17Civil 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
18Civil Rights Other Requirements: Make sure people with disabilities are accommodatedPhysical 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
19Civil 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 providersMust provide language assistancethat results in accurate and effective communicationat no cost
20Civil Rights Language Assistance: Does not require applicants/clients to:use family or friends as interpretersuse minor children as interpretersMust NOT be required to discloseProof of immigration/citizenshipSocial Security Number
21Civil 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.
22Civil 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.
23Civil Rights Reminders: If conflicts occur, remain calm Follow the platinum ruleTreat people the way they would like to be treated
24Civil Rights Final Steps: Agencies are responsible for training of their staff and/or volunteersUse the provided Checklist in your agencyRetain each Checklist for 3 yearsComplete and Sign the 2nd Checklist with Your Name and AgencyPass completed Checklists to the front