CIVIL RIGHTS TRAINING Brought to you by the

Goals of Civil Rights Equal treatment for all applicants and beneficiaries under the law. Knowledge of rights and responsibilities. Elimination of illegal barriers that prevent or deter people from receiving benefits. Dignity and respect for all.

Federal Financial Assistance Triggers Civil Rights Responsibilities Federal financial assistance is anything of value received from the Federal government. This includes the food and other items you receive from the Food Bank.

Civil Rights Laws Title VI—Civil Rights Act of 1964—Race, color, national origin Title IX of the Education Amendments of 1972—Sex Section 504 of the Rehabilitation Act of 1973—Disability Americans with Disabilities Act—Disability Age Discrimination act of 1975—Age Civil Rights Restoration Act of 1987—Race, color, national origin Program statutes and regulations—race, color, national origin, sex, age, and disability

What is a Protected Class? Any person or group of people who have characteristics for which discrimination is prohibited based on law, regulation, or executive order. Protected classes in The Emergency Food Assistance Program (TEFAP) & Commodity Supplemental Food Program (CSFP) are race, color, national origin, age, sex, and disability.

Types of Discrimination Disparate treatment - Someone of a protected class who is treated differently may sue the agency. Disparate impact - Results from action or rule from the complaint about the agency. Reprisal/Retaliation - Negative treatment due to prior civil rights activity by an individual or his/her family or known associates or for cooperating with an investigation – may sue agency.

2004 “Equal Opportunity for Religious Organizations” Regulations Protect Faith-Based Organizations Faith Based Organizations (FBOs) and Community Based Organizations (SBOs) have equal footing. Prohibits discrimination against an organization on the basis of religion, religious belief or character in the distribution of funds. Clarifies that FBOs can use space in their facilities without removing religious art or symbols.

Law Protects Beneficiaries No organization that receives direct assistance from the USDA can discriminate against a beneficiary or prospective beneficiary on the basis of religion or religious belief. FBOs retain their independence and carry out their mission, as long as USDA funds (or activities) do not support worship, religious instruction or proselytization.

Training All who work with Food and Nutrition Service (FNS) funded programs must be trained. First line workers (including volunteers) and supervisors must receive annual training. There are flexibilities in how training is provided.

Civil Rights Required Training Topics Collection & use of data Effective public notification systems Complaint procedures Compliance review techniques Resolution of non compliance Reasonable accommodation of people with disabilities Language assistance Conflict resolution Customer Service

Collection & Use of Data Required for CSFP. Currently not required in TEFAP except initial estimates. Data collected about beneficiaries should be kept secure and confidential. Helps determine if there are disparities between the potentially eligible population and the participating population or shows discrimination. Outreach efforts can be targeted.

Collection & Use of Data People self-declare. If they refuse to disclose info, you or someone else will code for them based on perception. RATIONALE: Discrimination is often based on perception, and others would probably have a similar perception to the person doing the coding.

Public Notification Prominently display the “And Justice for All” poster. Inform potentially eligible persons, applicants, participants and grassroots organizations of programs or changes in programs. Provide appropriate information in alternative formats for persons with disabilities. Provide information in other languages for Limited English Proficiency (LEP) populations.

Public Notification Include the required nondiscrimination statement on all appropriate FNS and agency publications, web sites, posters and informational materials. Convey the message of equal opportunity in all photos and other graphics that are used to provide program or program related information.

Non-Discrimination Statement “In accordance with Federal law and U.S. Department of Agriculture policy, this institution is prohibited from discriminating on the basis of race, color, national origin, sex, age, or disability. To file a complaint of discrimination, write: USDA, Director, Office SW, Washington, D.C or call (800) or call (202) (TTY). USDA is an equal opportunity provider and employer.”

Compliance Investigation Be aware of the bases for which complaints may be filed: race, color, national origin, age, sex, and disability. Never discourage groups or individuals from filing complaints or from voicing allegations of discrimination. Know where to file a complaint - USDA.

Compliance Investigation To file a complaint, write to: USDA, Director, Office of Civil Rights, 1400 Independence Avenue, SW, Washington, D.C or call (800) or (202) (TTY). In the Midwest Region write to: Regional Director, Civil Rights/EEO, 77 W. Jackson Blvd., FL 20, Chicago, IL or call (312)

Compliance Reviews Pre-award, post award, and special. Check for non-discrimination and ensure civil rights requirements are being followed.

Resolution Of Noncompliance Corrective Actions: Cease inappropriate actions. Institute appropriate procedures. Failure/Refusal can result in loss of federal assistance!

Reasonable Accommodation Ensure Access for People with Disabilities!! Parking lot, entrances & exits, halls, elevators, restrooms, sign language interpreters, Braille signage, service animals. Alternative arrangements for service.

Language Assistance People with Limited English Proficiency (LEP) need to be served in other languages. Outreach in other languages is important. Service must be provided - as well as being flexible in how service is provided.

Language Assistance How service is provided depends on: Number and proportion of LEP persons served. Frequency of LEP persons’ contact with program. Nature & importance of program. Resources available and costs. Shortage of resources does not eliminate this requirement!!

Language Assistance Children who are minors should not be used as interpreters. Volunteers may be used, but make sure they understand interpreter ethics—particularly confidentiality! See for more information.

Conflict Resolution Try to remain calm. Try to explain the situation. Get help, especially if threats or if violence is possible. Use Alternative Dispute Resolution (ADR) techniques.

Customer Service Platinum Rule “Treat others the way they want to be treated.” Double Platinum rule “Treat others the way they don’t even know they want to be treated”. Anticipate, anticipate, anticipate. Don’t just meet your customer’s expectations, EXCEED them.

Questions?