1. Child Nutrition Programs
4/15/2017
Civil Rights Training
Child Nutrition Programs
(SNP)

2. 4/15/2017
Training Purpose
USDA requires all Child Nutrition staff attend civil rights training annually to prevent discrimination
This training plays a key role in providing excellent services 2

3. What are Civil Rights? Civil Rights refer to the:
4/15/2017
What are Civil Rights?
Civil Rights refer to the:
Rights of “personal liberty” guaranteed by the 13th and 14th Amendments to the U.S. Constitution and Acts of Congress
Fair and equitable treatment of all customers and employees 3

4. Goals of Civil Rights Eliminate barriers to program benefits
4/15/2017
Goals of Civil Rights
Eliminate barriers to program benefits
Provide equal treatment to all
Explain rights and responsibilities
Show respect and dignity to all 4

5. What is a Protected Class?
4/15/2017
What is a Protected Class?
A protected class refers to any person or group of people who have a characteristic for which discrimination is prohibited by law
Protected classes in the SNP include:
Race
Age
Color
Sex
National Origin
Disability 5

6. Collecting and Reporting Participant Data
4/15/2017
Collecting and Reporting Participant Data
All schools must have a system to collect racial and ethnic data of program participants
Self-identification or self-reporting is the preferred method of obtaining data
Visual observation shall be used when the applicant does not self-identify
Data must be maintained for 3 years plus the current year
Access restricted to authorized school personnel 6

7. Racial and Ethnic Data 2 Ethnic Categories 5 Racial Categories
4/15/2017
Racial and Ethnic Data
2 Ethnic Categories
Hispanic or Latino
Non Hispanic or Latino
5 Racial Categories
American Indian or Alaskan Native
Asian
Black or African American
Native Hawaiian or Other Pacific Islander
White 7

8. 4/15/2017
Public Notification
Inform potentially eligible persons, applicants, participants and grassroots organizations of the availability of the SNP
Display the “And Justice for All” poster
Order via Stacey Macklin at
Include the nondiscrimination statement on all informational materials and websites that describe the SNP 8

9. Public Notification Nondiscrimination Statement
4/15/2017
Public Notification Nondiscrimination Statement
The U.S. Department of Agriculture prohibits discrimination against its customers, employees, and applicants for employment on the bases of race, color, national origin, age, disability, sex, gender identity, religion, reprisal, and where applicable, political beliefs, marital status, familial or parental status, sexual orientation, or all or part of an individual’s income is derived from any public assistance program, or protected genetic information in employment or in any program or activity conducted or funded by the Department. (Not all prohibited bases will apply to all programs and/or employment activities.)
If you wish to file a Civil Rights program complaint of discrimination, complete the USDA Program Complaint Form, found online at or at any USDA office, or call (866) to request the form. You may also write a letter containing all of the information requested in the form. Send your completed complaint form or letter to us by mail at U.S. Department of Agriculture, Director, Office of Adjudication, 1400 Independence Avenue, S.W., Washington, D.C , by fax (202) or at Individuals who are deaf, hard of hearing or have speech disabilities may contact USDA through the Federal Relay Service at (800) ; or (800) (Spanish)
USDA is an equal opportunity provider and employer. 9

10. Public Notification Communicate using methods such as:
Internet and computer based applications
Newspaper
Radio/television
Letters/leaflets/brochures
Bulletins 10

11. Reasonable Accommodations for Persons with Disabilities
4/15/2017
Reasonable Accommodations for Persons with Disabilities
A school is required to provide food substitutions or modifications if:
A medical statement, signed by a licensed physician, is on file and describes the participant’s disability (as defined in federal regulations) that prevents the participant from eating the regularly offered foods, and
The licensed physician has indicated the substitutions or modifications that the participant needs
For a Standard Operating Template visit: 11

12. Reasonable Accommodation Scenario
4/15/2017
Reasonable Accommodation Scenario
Example:
A parent of a student who has been diagnosed with celiac disease requests that gluten-free food items be provided to their child at all meals.
What must the school do and how does this relate to civil rights? 12

13. Reasonable Accommodation Language Assistance
4/15/2017
Reasonable Accommodation Language Assistance
SFAs must take reasonable steps to assure “meaningful” access to the information and services they provide…especially for people with Limited English Proficiency (LEP).
Meaningful access may include:
The distribution of SNP meal benefit forms (Applications for Educational Benefits, household letter and approval/denial letter) in 34 different languages
Hiring a bilingual interpreter to assist applicants or participants 13

14. 4/15/2017
Customer Service
A school must provide equal access to all eligible participants regardless of race, color, national origin, sex, age, or disability
All participants must be treated in the same manner
Each participant receives the same menu items in the same amounts
All participants are included in meals, snacks, activities, and discussions
Participants with special needs will have their needs addressed based on the severity of the need
Standards of behavior are not based on membership in a protected class 14

15. 4/15/2017
Conflict Resolution
Skills can help staff provide good customer service and avoid potential civil rights complaints
5 goals:
Avoid the desire to blame
Improve the situation
Communicate your feelings directly
Improve relationships and increase communication
Avoid repeating the situation 15

16. Conflict Resolution Scenarios
4/15/2017
Conflict Resolution Scenarios
A group of high school students is unhappy about the menu served at school. They decide to write a letter to the editor of the local newspaper instead of speaking directly with the cafeteria manager. The cafeteria manager is unaware of the problem until she faces the angry principal with newspaper in hand. Principal position: Do something about this, I don’t need bad publicity for my school! The principal schedules a meeting at 9:00am today with the unhappy students, the principal, and cafeteria manager. 16

17. Complaints of Discrimination
4/15/2017
Complaints of Discrimination
Allegation may be based on race, color, national origin, age, sex or disability
Filed within 180 days; written or verbal
SFAs must make an effort to obtain:
Name, address, and telephone number of the complainant
The nature of the incident or action
The basis on which the complainant believes discrimination exists
The names, telephone numbers, titles, and business or personal addresses of persons who may have knowledge of the action
The date(s) during which the alleged actions occurred
Forward the complaint 17

18. SFA Complaint Procedure
4/15/2017
SFA Complaint Procedure
SFAs should have a written complaint procedure. The procedure should outline:
Accepting a Complaint
Verbally and in writing
Transcribing a Complaint
Collecting relevant information
Forwarding a Complaint
Agency complaints are forwarded to
For a CR Complaint Procedures Template visit: 18

19. 4/15/2017
Compliance Reviews
Examines activities to determine adherence with civil rights requirements
Definition of “Noncompliance”: A factual finding that any civil rights requirement, as provided by law, regulation, policy, instruction, or guidelines, is not being adhered to 19

20. Examples of Noncompliance
4/15/2017
Examples of Noncompliance
Denying an individual or household the opportunity to apply for FNS program benefits or services on the basis of a protected class
Providing FNS program services or benefits in a dissimilar manner on the basis of a protected class (except as a disability accommodation)
Selecting FNS program sites or facilities in a manner that denies an individual access to FNS program benefits, assistance, or services on the basis of a protected class 20

21. Resolution of Noncompliance
4/15/2017
Resolution of Noncompliance
If non-compliance is indicated, corrective action must be taken immediately to achieve voluntary compliance 21

22. Additional Resources OSN Civil Rights webpage:
4/15/2017
Additional Resources
OSN Civil Rights webpage:
Training sign-in sheet template
Training agenda template
Complaint procedures template
Civil Rights self assessment tool
Civil Rights training power point
USDA, FNS Civil Rights webpage:
USDA laws, regulations and guidance
Frequently asked questions 22

23. 4/15/2017
Questions 23